ML20057E036

Forwards Revised Confirmatory & Radiological Survey Plan for Nuclear Lake Site,Pawling,Ny

ML20057E036
Person / Time
Site:	07000903
Issue date:	09/17/1993
From:	Vitkus T OAK RIDGE ASSOCIATED UNIVERSITIES
To:	Nalluswami M NRC
References
NUDOCS 9310070149
Download: ML20057E036 (20)

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ORISE OAK Wi[X'kE sNSTITUTt' r-OR SCE NC E AND E DUC A T ION 1 e 41 L e ' Y r t Nyep t rf.. A f r ft v - i r es ' 1 At t

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'Mr. M. Nalluswami Decommissioning and Regulatory Issues Branch U.S. Nuclear Regulatory Commission Mail Stop: 5E2 Washington, DC 20555

SUBJECT:

REVISED CONFIRMATORY AND RADIOLOG! CAL SURVEY PLAN FOR THE NUCLEAR LAKE SITE, PAWLING, NEW YORK

Dear Mr. Nalluswami:

Enclosed is the subject document which incorporates the comments provided to ESSAP in our September 17, 1993 phone conversation.

If you have any questions, please call either Michele Landis at (615) 576-2908 or me at (615) 576-5073.

Sincerely, Q

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Timothy J. Vitkus Environmental Project Leader Environmental Survey and Site Assessment Program TJV:tte Enclosure

~)h cc: P4e; NRC/MMSS,1EA D. Tiktinsky, NRC/NMSS, 6H3 S'-

J. Austin, NRC/SE2 D. Fauver, NRC/NMSS, 5E2 J. Swift, NRC/6H3 PMDA, NRC/NMSS, 6E6

3. Berger, ORISE/ESSAP M. Landis, ORISE/ESSAP File /225 9310070149 930917 PDR ADOCK 07000903 C

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F O BOX 117. OAK RIDCeE, TENNESSEE 37831 0117

.v.ariaged and opro'ed by ook Ridge Associated t.*wersities b the U 5. Department of Energy

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PROPOSED CONFIRMATORY AND RADIOLOGICAL SURVEY PLAN FOR TIIE NUCLEAR LAKE SITE PAWLING, NEW YORK INTRODUCTION AND SITE IIISTORY Nuclear fuels processing and research began in 1958 at a site near Pawling, New York, known as Nuclear Lake. Initial operations were performed by Nuclear Development Corporation; subsequently, the site was owned and operated by United Nuclear Corporation and Gulf United Corporation. Uranium oxide fuels of various U-235 enrichments were fabricated and tested at the site. Fuels utilizing thorium and plutonium were also fabricated and tested. The testing facilities at the site included several small experimental reactors. In 1972, activities at the site were discontinued and the site was decontaminated and surveyed. A report, indicating that the facilities satisfied the criteria for decommissioning, was prepared by ATCOR.8 The Nuclear Regulatory Commission license for thi: site was then terminated in 1975. The property was acquired in 1979 by the National Park Service (NPS) for the purpose of relocation of the Appalachian National Scenic Trail (ANST).

The NPS contracted Nuclear Energy Services (NES) to conduct additional surveys of portions of the property. Reults of that survey, presented in a July 1984 report, identified a small area of residual contamination in the former Waste Disposal Building.2 No other evidence of contamination in excess of the limits for unrestricted use was noted.

i However, studies and reviews by the Nuclear Lake Management Committee, a iocal citizens group, raised concerns legarding residual contamination in building drains, septic tank and drain field systems, sedime. t in Nuclear Lake, and building interior paint.' The possibility that containers of radioactive or other hazardous wastes were discarded into Nuclear Lake was also indicated by the Management Committee.' As a result of these concerns, the NPS requested that Prepared by the Environmental Survey and Site Assessment Program, Energy / Environment Systems Division, Oak Ridge Institute for Science and Education, under interagency agreement (NRC Fin. No. A-9093) between the U.S. Nuclear Regulatory Commission and the U.S.

Department of Energy.

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the Environmental Survey and Site and Assessment (ESSAP) of the Oak Ridge Institute for Science and Education (ORISE), then known as the Radiological Site Assessment Program of Oak Ridge Associated Universities, conduct investigations and radiological surveys of the site that would address these concerns. The survey was conducted during September 1986 and the results provided in a July 1988 report.'

The survey identified alpha and/or beta surface activity levels in buildings which exceeded the J

NRC surface contamination guidelines. In addition, several soil samples contained elevated levels of plubnium and Cs-137. Electromagnetrometry and ground penetrating radar studies, which were conducted concurrently with the 1986 survey, identified a number of anomalies l

within Nuclear I2ke itself. Radiation Technical Services performed an underwater investigation of these anomalies, during November 1992. The investigation was unable to substantiate that any of the anomalies were the result of metal drums being present in the Lake as originally suspected.5 The site has remained in caretaker status pending decontamination and demolition of site buildings and excavation of contaminated soils. Chevron USA, Inc., under a consent agreement l

with the NRC, contracted NES to characterize and perform remediation of ccatiminated building l

surfaces and soils at the Nuclear Lake Site. Structural decontamination was limited to the Plutonium Facility, Multiple Failure Building and the Waste Disposal Building. Remediation of site soils was performed within the vicinities of the Plutonium Facility, Waste Disposal Building, and Shield Mock-up Building. NES then performed final status surveys of the remediated building and soil areas.

l The N'AC's Division of Low Level Waste Management has requested that the Environmental l

Survey and Site Assessment Program (ESSAP) of the Oak Ridge Institute for Science and Education (ORISE) perform a confirmatory survey of the remediated portions of the Nuclear Lake Site. In addition, ESSAP has been requested to perform radiological-

..:ys of those j

unaffected buildings and open lar.d areas where previous surveys did not i

• ufy significant contaminafion.

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SITE DESCRII'flON The Nuclear Lake Site is located off of Old State Route 55 between the towns of Pawling and Beekman in the eastern portion of New York State. The 460 ha (1136 acre) site is heavily wooded with the exception of the 20 ha lake; clearings in the vicinity of the recently reconstructed dam, which impounds the lake at its southern end; the central portion of the site, where eight of the nine original site buildings are located; and near the entrance to the site, where the ninth building is located.

The site history indicates that of the nine buildings, only four may have been potentially used 2

2 for the processing or storage of radioactive materials. These buildings are the 700 m (7500 ft ),

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Plutonium Facility, the Waste Disposal Building (39 m ), the Shield Mock-up Building (60 m ),

2 and the Critical Facility (510 m ).

The 1986 radiological survey identified residual contamination above the NRC guidelines in the Plutonium Facility, a small area in the Multiple Failure Building, and one measurement location, remediated at the time of the survey, in the Critical Facility. The other buildings located on the site include the Engineering Building 2

(410 m ), the Lodge, and a house currently occupied by the site caretaker that was previously 2

known as the Remote Assembly Building (106 m ),

OBJECTIVES The objectives of the confirmatory survey are to validate the results of the NES final surveys by providing independent document reviews and sufficient data to evaluate the radiological status of the buildings and surrounding soil areas. The radiological survey will be performed to supplement previous survey results and gather additional data, for use by the NRC in determining the radiological status of the remainder of the property.

RESPONSIBILITY Work described in this survey plan will be performed under the direction of Michele Landis, Project Manager and Tim Vitkus, Project leader with ESSAP. The cognizant site supervisor has Nuclear Lake site September 16, 1993 3

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the authority to make appropriate changes to the survey procedures as deemed necessary. After consultation with the NRC site representative, the scope of the survey plan may be altered as i

the survey progresses. Deviations to the survey procedures or this plan will be documented m I

the site log book.

DOCUMENT IEVIEW i

ESSAP has reviewed the NES work plan for soil remediation, the decommissioning plan for the Plutonium Facility and Multiple Failure Building, final release survey plan, and final survey report and supporting documentation concerning site characterization and remediation activities.'7 83 Information was evaluated for accuracy, completeness, and compliance with guidelines. Comments for each document were provided to the NRC.:.n.i2 SURVEY PROCEDURES A survey team from ESSAP will visit the Nuclear Lake Site and perform visual inspections, measurements, and sampling. Survey activities will be conducted in accordance with the ORISE ESSAP Survey Procedures. The procedures applicable to this survey are listed on pages 11 and

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12 of this survey plan. The scope of the surveys performed for various portions of the site will be objective dependent. Confirinatory survey procedures will be implemented for remediated portions of the site and radiological surveys procedures, designed to meet draft '

NUREG/CR-5849 requirements, for the remaining portions.

CONFIRMATORY SURVEY PROCEDURES: INTERIOR i

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The following procedures will be used for interior surveys of the Plutonium Facility, the Waste Disposal Buik ing, and the Multiple Failure Building.

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l Reference Grid ESSAP will use the im x 1m termination survey grid system established by NES for referencing measurement and sampling locations. This grid system has been installed on the floor and lower walls (up to 2 m) of each room. Upper walls and ceilings, with the exception of 2 rooms in the Plutonium Facility, were not gridded.

Measurements and samples collected from ungridded surfaces will be referenced to the floor and/or lower grid or to prominent building features.

Surface Scans i

Surface scans for alpha, beta, and gamma activity will be performed over 100% of floor and lower wall surfaces located in the Waste Disposal Building, eastern portion of the Plutonium Facility (Rooms 2-5,14, and 15), and southern portion of the Multiple Failure Building, where l

remedial actions were concentrated. Surface scans of non-remediated portions of the Plutonium Facility (Rooms 1,6-13,16-18), and the northern portion of the Multiple Failure Building, will range in coverage from 50 to 100% dependent upon findings as the survey progresses.

Particular attention will be given to cracks or joints in the floors and walls, ledges, drains, and other locations where material may have settled or accumulated. Scans will be performed using gas proportional, ZnS, GM, and/or Nal detectors coupled to ratemeters or ratemeter-scalers with audible indicators. Locations of elevated direct radiation, detected by scans, will be marked for further investigation.

Surface Activity Measurements i

f Direct measurements for total and removable alpha and beta activity levels will be performed in a minimum of 10% of randomly selected floor and lower wall grid blocks. Additional direct 2

measurements will be performed every 20 m on upper wall and ceiling surfaces and at locations -

of elevated direct radiation detected by surface scans. Direct measurements will be made using gas proportional, ZnS, or GM detectors coupled to ratemeter-scalers. Locations with alpha or Nalcar lake Siis. September 16,1993 5

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beta surface activity levels, which exceed the NRC average surface activity guideline, will be investigated in accordance with Draft NUREG/CR-5849 to determine the average surface activity levels in the contiguous 1 m area.

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A smear sample for determining removable activity levels will be collected from each direct measurement location.

Exnosure Rate Measurements Exposure rate measurements will be performed within each rc,om of the Plutonium Facility and in the center of the Multiple Failure Building and the Waste Disposal Building. Exposure rates will be measured at 1 m above the floor using a pressurized ionization chamber (PIC).

Subfloor Soil Samoline i

Soil samples will be collected from subfloor areas within each building. Sampling locations will be selected in the field based on potential contaminant migratory pathways such as drains or expansion joints. Samples will be collected at an approximate frequency of 1 per 25 m of l

2 affected floor area and 2 samples in unaffected areas.

CONFIRMATORY SURVEY: EXTERIOR The following procedures will be applicable to the perimeter soil areas associated with the Plutonium Facility, the Waste Disposal Building and the Shield Mock-Up Building.

Reference Grid If the reference grid established by NES for characterization and remediation is intact at the time j

of the confirmatory survey, ESSAP will reference measurement and sampling locations to this grid. _Otherwise, ESSAP will use prominent building features to reference measurement and sampling locations.

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,-s Surface Scans Surface scans for gamma activity will be conducted over the exterior grounds of the affected buildings extending out to a distance of 10 m.

Surface scans will be performed using Na1 detectors coupled to ratemeters with audible indicators. Locations of elevated direct radiation detected by scans will be marked for further investigation.

Soil Samnline l

Soil samples will be collected from remediated areas; locations contiguous with the remediated areas; any locations of elevated direct radiation, detected by scans; and from 5 randomly selected '

grid blocks (locations). Samples will be collected at intervals that are representative of 100 m2 areas.

E3nosure Rate Measurements Exposure rate measurements will be made at each soil sampling location. Measurements will be made at 1 m above the surface using a PIC.

RADIOLOGICAL SURVEY PROCEDURES: INTERIOR-The procedures described below are applicable to the interior of the following buildings:

Engineering Building, Shield Mock-Up, Critical Facility, the Lodge, and the Remote Assembly Building.

Reference System ESSAP will use prominent building features to reference measurement and sampling locations.

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Surface Scans Surface scans for alpha, beta, and gamma activity will be performed over a minimum of 10%

of the floors and lower walls (up to 2 m). Additional scans will be performed in drains, cracks, I

on ledges, or other locations where material may have settled or accumulated. Scans will be performed using gas proportional, ZnS, GM, and/or NaI detectors coupled to ratemeters or

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ratemeter-scalers with audible indicators. Locations of elevated direct radiation, detected by scans, will be marked for further investigation.

Surface Activity Measurements r

1 Direct measurements of total alpha and beta surface activity will be performed at 30 measurement locations within each building. Direct measurements will be performed usirg gas proportional, ZnS, and/or GM detectors coupled to ratemeter-scalers. Smear samples for determining removable activity levels will be collected from each direct measurement location.

Should direct measurements identify surface activity levels in excess of 25% of the guidelines, then the scope of the survey may require alteration.

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Exposure Rate Measurements Exposure rate measurements will be made in each building. NUREG/CR-5849 recommends that an exposure rate measurement be performed at each direct measurement location; however, the small size of most of the site buildings may not necessitate this measurement frequency.

Therefore, a minimum of one measurement will be made per building or room, whichever is applicable. Additional exposure rate measurements will be made at locations of elevated direct radiation detected by gamma surface scans. Measurements will be made at 1 m above the l

surface using a PIC.

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Subfloor Soil Snmnline Subfloor soil samples will be collected from 2 locations within each building. Locations will be selected based en the presence of potential migratory pathways such as expansion joints and drains.

RADIOLOGICAL SURVEY PROCEDURES: EXTERIOR I

The following procedures will be used for unaffected portions of the site associated with buildings, roads, walkways, and the dam area.

Reference System The unaffected outdoor areas will be subdivided into 4 survey units (Figure 1). ESSAP will establish a grid system consisting of 50 x 50 m grid blocks to reference measurement and sampling locations within each survey unit. Prominent site features or structures may also be used for reference.

Surface Scans Surface scans for gamma activity will be conducted over approximately 10% of the cleared portions of the site. Scans will be concentrated in those areas associated with the buildings, roads, walkways, and clearings. Scans will be performed using NaI detectors coupled to ratemeters with audible indicators. Locations of elevated direct radiation detected by scans will be marked for further investigation.

Soil Sampline Surface (0 to 15 cm in depth) soil samples will be collected from 30 locations within each of the 4 survey units. Subsurface samples,1 meter in depth, will be collected from a total of 30 of the surface sampling locations. Each of these sample boreholes will be logged for gamma Nwicar lake Sde - September 16,1993 9

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t activity using a Nal detector coupled to a ratemeter, and additional soil samples collected from depth intervals where elevated gamma radiation is identified. ' An additional 30 surface soil samples will be collected from land areas outside of the buildings' perimeter. Soil sample locations will be systematically selected throughout the site or will be located at suspect locations that were identified during surface scans. The sampling intervals will be performed in a manner 2

that will permit approximating the average radionuclide concentration levels over.100 m areas.

l Exposure Rate Measurements Exposure rates will be measured at I m above each soil sampling locations using a PIC or NaI detectors cross-calibrated with a PIC.

8 SAMPLE ANALYSIS AND DATA INTERPRETATION Samples and data will be returned to ESSAP's Oak Ridge, Tennessee facility for analysis and interpretation. Smears will be analyzed for gross alpha and gross beta activity with a low background proportional counter.

Soil samples will be individually analyzed by gamma spectrometry. The spectra will or reviewed for uranium, thorium, americium, cesium and any other identifiable photopeaks. ladividual samples and/or composite samples, representing groups of up to 10 samples, may also be analyzed for isotopic plutonium by alpha spectrometry.

Individual samples selected for alpha spectrometry will be based on the gamma spectrometry results.

i The smear analytical results and direct measurement data will be converted to units of j

2 dpm/100 cm and exposure rates in pR/h. Soil results will be reported in pCi/g. This data will be compared to the final survey results provided by NES and the NRC generic and site specific guidelines.' The site exposure rates and radionuclide concentrations in soil will also be compared with the background data previously collected.' The radiological survey data will be statistically evaluated and formatted in accordance with NUREG/CR-5849. The results will be provided in a draft report and submitted to the NRC for review and comment.

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i GUIDELINES i

The applicable contaminants identified at the site are plutonium and Cs-137. The guidelines for i

plutonium are as follows:

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Total Activity 2

2 100 dpm/100 cm, averaged over a 1 m area 2

2 300 dpm/100 cm, maximum in a 100 cm area Removable Activity 2

20 dpm/100 cm The surface contamination guidelines. for Cs-137 are those for beta-gamma emitters-l (radionuclides with decay modes other than alpha emission or spontaneous fission) except Sr-90.

These guidelines are:

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Total Activity 2

2 5000 dpm #-7/100 cm, averaged over a 1 m area 2

2 15000 dpm #-7/100 cm, maximum in a 100 cm area Removable Activity 1000 dpm #-7/100 cm2 The site specific soil concentration guidelines are 25 pCi/g and 15 pCi/g for plutonium and Cs-137, respectively.

i The exposure rate guideline currently being used by the NRC is 5 R/h above background.7 TENTATIVE SCIIEDULE i

Measurement and Sampling September 20-25,1993 Sample Analysis September 27-October 8,1993 -

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5 Dran Report October 13,'1993 Final Report October 29,1993 LIST OF CURRENT PROCEDURES TO BE USED IN TIIE SURVEY Applicable procedures from ORISE ESSAP Survey Procedures Manual (Reyision 7; May 31, 1992) include:

Section 5.0 Instrument Calibration and Operational Check-Out 5.1 General Information 5.2 Electronic Calibration of Ratemeters 5.3 Gamma Scintillation Detector Check-Out and Cross Calibration 5.4 Alpha Scintillation Detector Calibration and Check-Out 5.5 GM Detector Calibration and Check-Out 5.6 Proportional Detector Calibration and Check-Out 5.7 Pressurized Ionization Chamber Calibration and Check-Out 5.9 Floor Monitor Check-Out l

5.13 Field Measuring Tape Calibration Section 6.0 Site Preparation 6.1 Clearing to Provide Access 3

6.2 Reference Grid System Section 7.0 Scanning and Measurement Techniques 7.1 Surface Scanning 7.2 Gamma Logging af Boreholes 7.3 Alpha Radiation Measurement 7.4 Beta Radiation Measurement 7.5 Gamma Radiation (Exposure Rate) Measurement Section 8.0 Sampling Procedures Nuck.r 1.ake She - Septenkt 16,1993 12 amrw.n.wucku.i.isp.wi.e.coi

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8.1 Surface Soil Sampling 8.2 Subsurface Soil Sampling-8.7 Determination of Transferable Contamination 8.9 Sample Identification and Labeling Section 9.0 Integrated Survey Procedures 9.2 General Survey Approaches and Strategies s

1 Section 10.0 Health and Safety and Control of Cross Contamination I

Section 11.0 Quality Assurance and Quality Control-i f

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REFERENCES i

1.

ATCOR, Inc., " Final Survey Results After Decontamination, Gulf United Nuclear Fuels i

Corporation Plutonium Facility, Pawling, New York", January 1974.

2.

Nuclear Energy Srvices, "UNC Facility Survey and Radiological Analysis", July 1904.

t 3.

Letter from C. W. Gillert, Acting Chairperson, Nuclear Lake Management Committee to D. A. Richie, United States Department of Interior, July 1985.

4.

Oak Ridge Associated Universities, " Radiological Survey of the Nuclear Lake Site, Pawling, New York", July 1988.

5.

Radiation Technical Services, Inc. " Underwater Investigation of Nuclear Lake".

6.

Nuclear Energy Services, " Work Plan for the Soil Remediation of the National Park Service Property Located Near Pawling, New York for the Chevron USA, Incorporated",

November 1992.

7.

Nuclear Energy Services, " Decommissioning Plan for the Plutonium Facility and Multiple Failure Building of the National Park Service Property Located Near Pawling, New York for Chevron USA, Incorporated", February 1993.

8.

Nuclear Energy Services, " Final Release Survey Plan of the National Park Service Property Located Near Pawling, New York for Chevron US A, Incorporated", May 1993.

9.

Letter from T. J. Vitkus, ORISE to M. Nalluswami, U.S. Nuclear Regulatory Commission, " Comments on the Work Plan for Soil Remediation of the National Park Service Property, Located Near Pawling, New York for the Chevron USA, Incorporated", December 9,1992.

10.

Letter from M. R. Landis, ORISE to M. Nalluswami, U.S. Nuclear Regulatory Commission, " Comments of the Decommissioning Plan for the Plutonium Facility and Multiple Failure Building of the National Park Service Property Located Near Pawling, New York for Chevron USA, Incorporated", March 18, 1993.

11.

Letter from M. R. Landis, ORISE to M. Nalluswami, U.S. Nuclear Regulatory Commission, " Comments on Final Release Survey Plan, National Park Service Property, Pawling, New York", March 30,1993.

12.

U.S. Nuclear Regulatory Commission, " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use of Termination of License for Byproduct, Service, or special Nuclear Material", August 1987.

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i REFERENCES (Continued) 13.

U.S. Nuclear Regulatory Commission, " Guidance and Discussion of Requirement for an Application to Terminate a Non-power Reactor Facility Operating License," Revision 1, September 1984.

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APPENDIX A NUCLEAR LAKE SITE COST ESTIMATE PAWLING, NEW YORK 4

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APPENDLX A NUCLEAR LAKE SITE COST ESTIMATE PAWLING, NEW YORK Plan Preparation - $17,400 Plan preparation includes the following activities: document reviews, survey plans, trip planning, and the cost and time estimates.

On-Site Activities - $70,000 On-site activities will include 30 man-days at the site performing the following: alpha, beta, and gamma surface scans, mapping, direct measurements and smears, exposure rate measurements, and soil sampling.

The on-site expenses also include trip preparation (equipment calibration and packing),

travel to and from the site (airlines and rental vehicles), hotel expenses, and per diem, unpacking equipment, and logging in' samples.

Sample Analysis - $30,600 Based on the information obtained from ESSAP cost estimate sheets, smear analysis will cost approximately $1,500, gamma spectrometry will cost approximately $14,000, and alpha spectrometry for 25 samples will cost $15,000.

Reoort Preparation - $27,600 The report preparation will include the following activities:

tabulation of data, illustrations, and writing and reviewing the draft and final reports, word processing and reproduction.

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Total Cost Estimate -- $145,600

• Estimates arefor sun'ey ofall areas listed in the NRC Requestfor Technical Assistance received by ESSAP. Reduction or increase in the number of areas being surveyed would 1

result in changes to the original estimate in the "on-site activities' and " sample analyses" l

categories. Due to the nature of the survey, this estimate is a best guess site and survey l

findings may change the scope of the survey and increase or decrease the cost estimate.

The NRC site representative will be nonfied ifmajor changes to the scope of the sun'ey need to be taken.

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