ML20125E548

Submits Request for Addl Info to Enable NRC to Continue Review of 921022 Responses to NRC 920923 RAI Re Proposed Residual Soil Contamination Limits for Facility.Procedures to Be Used to Collect Soil Samples Should Be Described

ML20125E548
Person / Time
Site:	05000054, 07000687
Issue date:	12/04/1992
From:	Dennise Orlando NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Mcgovern J CINTICHEM, INC.
References
NUDOCS 9212170111
Download: ML20125E548 (4)

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,y t DEC 0 ' "39 1 Docket tios. 50-54 70 387 l.icense Nos. Stim- 639 R-81 Mr. James J. McGovern, President / Plant Manager Cintichem, Inc.

P.O. Box 816 Tuxedo, New York 10987

Dear Mr. McGovern,

Nuclear Regulatory Commission staff has reviewed your October 22, 1992 responses to our September 23, 1992 request for additional information concerning the proposed residual soll contamination limits for your Tuxedo, New York facility. Per our teleconference and phone conversations of December 1,1992, listed below is the additional information needed by the NRC staff to complete its review of these limits.

1. Please describe in detail the sampling and analysis that will be performed on the soil Cintichem intends to excavate from the site and then use as backfill on-site at the completion of the decommissioning of the facility.

Information should include, but not be limited to: soil sample collection frequency (e.g., that each backhoe bucket will be sampled, per our teleconference of 12/1/92), sample volumes, sample collection procedures, sample preparation, sample averaging, a description of the methods and equipment used to analyze the sample, the quality assurance program for the sample collection and analysis, and records that will be maintained to support the determination of residual radioactivity in the soil. Also, please describe the method that Cintichem will use to analyze soil for alpha and beta emitting radionuclides.

It is imperative that you describe the procedures Cintichem will use to collect and analyze soil samples-in sufficient detail to allow NRC staff to determine the validity and acceptability of the procedures. Where appropriate, Cintichem should use the methods and procedures outlined in NUREG/CR-5849 which I provided to you earlier this year since Cintichem will need to use these procedures (or acceptable alternatives) in its termination survey. In addition, please confirm that any soil analyses performed to date have been per these methods.

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. DEC 0 41992 J.ames J. McGovern 2

2. During our teleconference it was unclear what Cintichem will do to '

remediate each of the three areas at the facility characterized as surface contaminated areas. Please describe in detail what Cintichem will do at each of these areas to determine the extent and type of contamination and ,

to remove contaminated soil above the cleanup criteria. In addition, provide a description of the depth of contamination for each surface contamination area and the soil depth to bedrock for these areas.

3. Please describe the procedures Cintichem will use to segregate and store soil that is characterized as " clean soil" (i.e., soil with radionuclide concentrations below the cleanup criteria) and contaminated soil. Also, please describe how this soil will be used as backfill and how the soil will be disposed of as radioactive waste. *

4. Please clarify that an allowable " hot spot" will be defined consistent with the guidance in NUREG/CR-5849 as an area where the concentration of i radioactive material in the soil is between 1 and 3 times " unity" as determined by the sum of fractions for the approved soll concentration criteria for the radionuclides present in the soil at that -location.

5. Please provide the radioactive material concentrations in soil and the soil and bedrock surface exposure rate that Cintichem intends to use as background for the site.

6. Please revise the ALARA analysis provided in your October. 22, 1992 letter

, to demonstrate that the proposed soil criteria are as low as reasonably

achievable given tn' e criteria outlined in NRC's letter to you of September 23, 1992. This analysis should evaluate, based on the information currently available,-the-cost 'and benefit (in reduction of.

radiation dose to the public) from incremental increases and decreases in the unrestricted release limit (i.e., the less than 10 mrem / year Cintichem proposed).

7. Please describe-the method by which Cintichem will determine that soil containing radioactive material in excess of the established criteria is not present beneath or adjacent to areas that have been remediated to the established criteria (i.e., how will Cintichem ensure that all material-rentaminated above the cleanup criteria-has been removed from the site, even in cases where that contamination is not contiguous with known contaminated material).

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'+. DEC ei1991 Docket Nos. 50-54 70-687 License Nos. SNM-639 R-81 Mr. James J. McGovern, President / Plant Manager Cintichem, Inc.

P.O. Box 816 Tuxedo, New York 10987

Dear Mr. McGovern,

Nuclear Regulatory Commission staff has reviewed your October 22, 1992 responses to our September 23, 1992 request for additional information concerning the proposed residual soil contamination limits for your Tuxedo, New York facility. Per our teleconference and phone conversations of December 1,1992, listed below is the additional information needed by the NRC staff to complete its review of these limits.

1. Please describe in detail the sampling and analysis that will be performed on the soil Cintichem intends to excavate from the site and then use as backfill on-site at the completion of the decommissioning of the facility.

Information should include, but not be limited to: soil sample collection frequency (c.g., that each backhoe bucket will be sampled, per our teleconference of 12/1/92), sample volumes, sample collection procedures, sample preparation, sample averaging, a description of the methods and equipment used to analyze the sample, the quality assurance program for the sample collection and analysis, and records that will be maintained to support the determination of residual radioactivity in the soil. Also, please describe the taethod that Cintichem will use to analyze soil for alpha and beta emitting radionuclides.

It is imperative that you describe the procedures Cintichem will use to collect and analyze soil samples in sufficient detail to allow NRC staff to determine the validity and acceptability of the procedures. Where appropriate, Cintichem should use the methods and procedures outlined in NUREG/CR-5849 which I provided to you earlier this year since Cintichem will need to use -the;e prceedures (or acceptable alternatives) in its termination survey. In addition, please confirm that any soil analyses performed to date have been per these methods.

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James J. McGovern 2

2. During our teleconference it was unclear what Cintichem will do to remediate each of the three areas at the facility characterized as surface contaminated areas. Please describe in detail what Cintichem wi'l do at each of these arsas to determine the extent and type of contamination and to remove contaminated soil above the cleanup criteria. In addition, provide a description of the depth of contamination for each surface contamination area and the soil depth to bedrock for these areas. ,

3. Please describe the procedures Cintichem will use to segregate and store soil that is characterized as " clean soil" (i.e., soll with radionuclide concentrations below the cleanup criteria) and contaminated soil. Also, please describe how this soil will be used as backfill and how the soil will be disposed of as radioactive waste. -

4. Please clarify that an allowable " hot spot" will be defined consistent with the guidance in NUREG/CR-5849 as an area where the concentration of radioactive material in the soil is between 1 and_3 times " unity" as determined by the sum of fractions for the approved so.i concentration criteria for the radionuclides present in the soil at that location.

i Please provide the radioactive material concentrations in soil 'nd the 5.

soll and bedrock scrface exposure rate that Cintichem intends to use as backg ound for the site.

6. Please revise the ALARA analysis provided in your October 22, 1992 letter to demonstrate that the proposed: soil criteria are as loN *s reasonably achievable given the criteria outlined in NRC's letter to ',ou of l

September 23, 1992. This analysis should evaluate, based on the information currently available, the cost and-benefit (in reduction of radiation dose to the publ' ' f. so incremental increases and decreases in ,

the uarestricteri release linot (i.e., the less than 10 mrom/ year Cintichem -

proposed). '

7. Please describe the method by vhich Cintichem will determine that soil containing radioactive material in excess of the established criteria is not present beneath or ?djacent to areas that have been remediated to the established criteria-(i.e., how will Cintichem ensure that all material.  !

contaminated above the c'aanup criteria has been removed from the site, ,

even in cases where that contamination is not contiguous with known contaminated material).

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. DEC 0 41932 James J. McGovern 2 I

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2. During our teleconference it was unclear what Cintichem will do to i remediate each of the three areas at the f acility characterized'as' surface  !

contaminated areas. Please describe in detail what Cintichem will do at  !

each of these areas to determine the extent and type of contamination and to remove contaminated soil above the cleanup criteria. In addition, provide a description of the depth of contamination for each surface ,

contamination area and the soil depth to bedrock for these areas. ,

3. Please describe the procedures Cinlichem will use to segregate and store ,

soil that is characterized as " clean soll" (i.e., soil with radionuclide '

concentrations below the cleanup criteria) and contaminated soil. Also, please describe how this soil will be used as backfill and how the soil will be disposed of as radioactive waste.

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4. Please clarify that an allowable " hot spot" will be defined consistent '

with the guidance in NUREG/CR-5849 as an area where the concentration of radioactive material in the soil is between 1 and 3 times " unity" as determined by the-sum of fractions for the approved soil concentration criteria for the radionuclides present in the soil at that location.

5. Please provide the radioactive. material concentrations in soil and the soil and bedrock surface exposure rate that Cintichem intends to use as ,

background for the site.

a L 6. Please revise the ALARA analysis p:ovided in your October 22, 1992 letter to demonstrate that the proposed soil critoria are as low as reasonably _

achievable given the criteria outlined in NRC's letter to you of September 23, 1992. This analysis should evaluate, based on the j information currently available, The cost and benefit (in reduction of ,

l radiation dose to the public) from incremental increases and decreases in_ l j the unrestricted release limit (1.e.. .the less than 10 mrem / year Cintichem proposed).

7. Please dnscribe the method by which Clntichem will detcrmine that soil  :

containing radioactive material in excess of the established criteria-is not present beneath or adjacent to areas that have been remediated to the established ccireria (i.e., how will Cintichem ensure that all material-contaminated abava the cleanup criteria has been removed from the site, -

even in cases where that contamination is rot contiguous with known contaminated material).

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DEC 0 4 02 Jan:es J. ' McGovern 3 i

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8. Per-our phone conversation of December 4, 1992, you indicated that 1 Cintichem has developede X s for 7 of the radionuclides outlined in Table 2 i of your October 22, 1992 letter. Please supply the data, procedures, and analyses used to develop these K, values. 'l

9. Please confirm that the soil that will be reindiated to the sub-surface limits will only be deposited, or allowed to remain on-site, in areus that will be covered by at least 25 feet of building rubble and topped t)y at least three feet of clean soil.

If you have any questions please contact me at (301) S04-2566.

Sincerely,

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Dominick A. Orlando, Project Manager Decommissioning and Regulatcry Issues Branch Division of Low-Level k'aste Management and Decommissioning Office of Nucicar Material Safety and Safeguards cc: See attached list Distribution: Cent =raLFile NMSS r/f LLDR r/f RBangart WDrach JAustin JSurmeier MWeber TCJohnson D0rlando JParrot UEid CDaily TMichaH s l

POR YES d_ NO Category: Proprietary ._ or CF only ACNW YES NO .4 IG YES NO i SUBJECT ABSTRACT:RE0VES15 ADDIT 10F. INFORMAIION ON SITE DECOMMISSIONING .

OFC LLDR 6 LLOR C LLDR,o,f G  ;

NAME [ MWeber _JANhn DATE /s/ V/92 /2 /Yfg2 j . f;//92

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Ca COVER E = COVER & ENCLOSURE N = NO COPY 9

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