ML20071P426

Advises of Contamination Control Plans Involving Removal of Top Soil to Depth of 6-8 Inches from Areas to Be Graded & Burial in Trenches W/Min Cover of 6 Inches of Clean Soil. Request for License Change Will Be Submitted

ML20071P426
Person / Time
Site:	Oyster Creek
Issue date:	10/27/1982
From:	Fiedler P GENERAL PUBLIC UTILITIES CORP.
To:	Crutchfield D Office of Nuclear Reactor Regulation
References
NUDOCS 8211020505
Download: ML20071P426 (6)

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GPU Nuclear g

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P.O. Box 388 Forked River, New Jersey 08731 609-i693-16000 Writer's Direct Dial Number:

October 27, 1982 Mr. Dennis M. Crutchfield, Chief Operating Reactors Branch #5 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Contamination Control During a recent site facility upgrading project, an uncertainty was identified which pertains to the control of radioactive material. The project consists of paving an area near our New Radwaste Building. The work requires proper grading and excavation of approximately 17,000 cubic feet of soil in order to facilitate proper drainage, work area requirements, etc. As a normal precaution, soil samples of this area were taken and analyzed for activity.

The total number of samples and activity discovered is included as Attachment I to this letter. As can be seen from the data, low level activity is present; however, it is well below the limits established in 10 CFR Part 30.

Our problem, and possibly a problem at other utilities, is that there are no definitive regulations or even guidelines which address the "de minimis" waste issue. The disposition of material such as we have, comprises the scope of our problem. The various burial sites do not regard this as contaminated material and will reject such shipmenta.

We have contacted our project manager in NRR, and the resident inspectors at the Oyster Creek site regarding our problem. Their recommendation was to either:

(1) prepare a submittal requesting a change to our license, or (2) indicate and provide a justification for our proposed actions.

Commencirs on November 1,1982, we plan to remove the top soil to a depth of six (6) to eight (8) inches f rom the areas to be graded and bury this in trenches with a minimum cover of six (6) inches of clean soil. In the near fu t ure, this area may be paved with asphalt. Attachment II to this letter provides the justification for our actions. A request for a license change, in order to avoid confusion and possible misinterpretations regarding any future similar situations, will also be submitted.

8211020505 821027 PDR ADOCK 05000219 P

PDR GPU Nuclear is a part of the General Public Utikties System

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. s s, Mr. Dennis M. Crutchfield Page 2 October 27, 1982 s

Our actions will provide a greater degree of control over the soil; however, whether we leave the soil as is, or bury it in trenches, we have

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determined the contamination levels would not af feet the health and safety of a

the public or personnel at this site. If you have any additional questions, please contact me or Mr. Michael Laggart of my staff at (609) 971-4643.

Very truly yours, E

Peter B. Fiedler Vice President and Director Oyster Creek PBF:MWL:lse At tachment cc:

Mr. J. Lombardo NRC Project Manager - Oyster Creek U.S. Nuclear Regulatory Commission Washington, D.C.

20555 NRC Resident Inspector Oyster Creek Nuclear Generating Station

s Forked River, NJ 08731 Mr. Ronald C. Haynes, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 s

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ATTACHHTM 2, e.

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SURFICIAL SOIL SAMPLES COLLECTEI) PRIOR TO PAVING OF RCA Samples Collected on October 8 and 9, 1982, l', 9 -

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Analyzed at Radiation Management Corporation, Philadelphia ( PA '

on October 10 and 11, 1982

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NOTES:

1.

All units are pCi/Kg (wet), % errors are 2 std. dev.

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not detected

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3.

Sabple locations were taken over approximately 29,000 sq. f t.

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Samples designated "A" were taken f rom an area previously graded.

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Sample #'

Co 60 Cs 137 Cs 134 Mn 54 Al A2 306.7 +25.4%

A3 126.4 460.2%

97.4 +59%

A4 1594'4k0.Y c

1814 +10%

AS 109.4 +52.

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A6 344.9 +28%

468.9 115.

4 A7 c'

-761.8 +20.6%

745.8 +14%

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A8 j,_

l A9 I

A10 All 57.3 _+85%

B1 2762 _+10%

2432 +10%

B2 184 +56.2%

264.3 +25.8%

B3 2135 _+10%

2435 _+10%

B4 14312 +10%

8002 +10%

784.7 +20.6%

B5 39066 _+10%

28366 _+10%

1822 _+12%

439.5 +58%

B6 3621 _+10%

2900 _+10%

136 _+40.4%

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Sample #

Co 60 Cs 137 Cs 134 Mn 54 B7 2484 +10%

2296 +10%

B8 1455 +10.4%

1071+15.63 B9 7233 +10%

8570 +10%

388.7 +32.8%

x B10 1690 +10.1%

1663 +10% -

Bil 24251 110%

5714 +10%

540.7 136.6%

2556 +10.8%

B12 1479 111.8%

1514 +10%

70.7 +57.6%

B13 3054 +10%

1909 +10%

127.8 +43%

B14 40000 24000 2700 This sample counted at Oyster Creek Chemistry Dept., as a check prior to shipping B15 1966 +10%~

4299 +10%

137.4 +33.6%

C1 826.4 +18.2%

688.4 115.2%

C2

- 14090 +10%

11110 +10%

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206.9 125%

C3

'3017 +10%

1967 +10%

C4 4055 115%

4927 110%

237.5 141.8%

C5 1567 111.4%

1348 110.6%

3103 110%

3511 +10%

303 133.2%

C6

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C7 3651 +10%

3585 +10%

199.6 +55.8%

C8 4009 +10%

3807 +10%

335 +29%

C9

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1190 +16%

1347 +12.5%

C10 4714 +10%

3066 +10%

203 132.6%

C11 1787 +10%

1723 +10%

143 136%

C12 768 +18.2%

819 +14.2%

C13 605 118.4%

553 115.2%

D1 Impossible to collect sample in this location (computer selected) - under chromate storage tank.

D2 2014 +11.2%

1594 +10%'

D3 503 _+20.2%

446 _+19%

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Co 60 Cs 137 Cs 134 Mn 54 D4 618 +76.8%

62.4 +77.2%

D5 1722 +10.4%

1422 +10%

D6 863 +15.6%

625 +14.2%

D7 1126 +15.4%

777 +21.0%

D8 689 +18.2%

634 +16.2%

D9 1575 +10%

1677 +10%

El 1110 +15.2%

510 +21.8%

E2 540 +17.8%

377 +19.6%

E3 913 +16.2%

844 +14.4%

E4 43470 +10%

5051 +10%

111 +82.2%

E5 581 +17.4%

412 +22.2%

E6 1292 +12.2%

615 +16.8%

E7 1004 +15%

784 +14.8%

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ATTACHMENT 11 Justification of the Proposed Disposal Method Our justification from a health and safety perspective of the proposed burial within the owner controlled area is the following:

1.

A shallow burial below a thin layer of clean topping material will prevent further migration of the material via wind blown dust. The dispersal of the contamination over the entire sampled area indicates ready transport by the wind.

2.

Environmental samples show no transport of the material into the ground water downstream of the contaminated area. Shallow burial should not alter the dif fusion characteristics of the material.

3.

The external dose rate from this material, when buried, will contribute less than 500 milli-rem per year to any member of the population. Assuming continuous occupancy and no shielding from the clean covering material, NCRP 50, Table 2-17 predicts dose rates at one met..* te be approximately 30 micro R/hr. This calculation assumes ut.itorm soil concentrations of 5 pico curies per gram of cobalt 60 and 4 pico curies per gram of cr.sium 137.

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