ML20126D079

Comments on Work Plan for Soil Remediation of Natl Park Svc Property Located Near Pawling,Ny for Chevron Usa,Inc

ML20126D079
Person / Time
Site:	07000903
Issue date:	12/09/1992
From:	Vitkus T OAK RIDGE ASSOCIATED UNIVERSITIES
To:	Nalluswami M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 9212240023
Download: ML20126D079 (4)

Text

<

t i

7D -9&3 M

OR1SE O A tt R KsGf INSilf tfit, C>W Etif Nct AN(, f(suc.A1tC;#4 4 P Ji &O v r ( 6 4v l, Or 4MI N1

• i z, f i v s ( % ; g aq December 9,1992 Mr. M. Nalluswami Decommissioning and Regulatory Issues Branch U.S. Nuclear Regulatory Commission Mail Stop SE2 Washington, DC 20555 SUIUECT:

COMMENTS ON TIIE WORK PLAN FOR SOIL HEMEDIATION OF Tile NATIONAL PARK SERVICE PROPERTY, LOCATED NEAR PAWL!NG, NEW YORK, FOR TIIE CIIEVRON USA. INCORPORATED

Dear Mr. Nalluswami:

The ORISE Environmental Survey and Site Aussment Program (ESSAP) has reviewed the subject document and offers the following comments for consideration:

General Comments 1.

Based on the December 7,1992 lette.r from F. Trejo (IES/NES) to J. Austin (NRC), the Work Plan is intended to addre.ss removal of only those " hot spots," specifically identified in the July 1988 ORAU report it should be noted that the ORAU survey was not intended to "characteri7i the residual contamination e: one site or provide sufficient detail to design a remedial action plan. The results of the ORAU survey should be regarded as que.lita@ce with res. at to ihe hodzontal and vertical boundaries of the contamination. it is therefore imixntant that all parties understand the limitations of the ORAU data with respect to its applications to remediation planning.

We feel relatively confident that the major general locations of soil contamination have been identified. Those locations, indicated on the attached figure, will require additional surveying to define the actual extent of soil that will require remediation. There is always the possibility that areas of contamination may not have been identified, because.

of the limited nature of our survey.

2, Figures, which indicate the work areas, should be included in the Work Plan.

3.

The procedures for the surveys, following " hot spot" removal, should be described.

1' 9212240023 921209 i

PDR ADOCK 07000903 C

PDR P O. BOX 117. OAK RIDGE,IENNESSEE 37831-0117 j

. Monoged cmd opem+ed by Ook Ridge Aswcioned Unherst es for the U S. Deponment of Ene<gy f

i

~-

l 4

Mr, Nalluswami December 9,1992 Specific Comments 1.

Section I, Page 1, Second Paragraph: The Work Plan refers to removing isolated " hot.

spots" as identified in the ORAU radiological report.. As discussed in item 1, of General Comments above, because the ORAU survey was a limited radiological survey rather than a " characterization" survey, it is uncertain whether the " hot spots" identified are actually isolated, or rather, indications of more wide-spread subsurface contamination.

2.

Section I, Page 1, Fourth Paragraph: Are the soil. limits for Cs-137. and Pu-239, j

h.dicated in the text, average or maximum levels? How (over what arca/ volume) are the

)

limits to be applied?

]

3.

Section II, Page 1: The first sentence states that the site was " characterized" by ORAU' in 1988. The survey designed and conducted by ORAU in 1988 was intended as a radiological survey that would provide sufficient data to determine whether or not residual contamination was present at the site (see General Comments, Iterr 1). The second paragraph should be changed to read "Cs-137 and Pu-239/240 contamination was identified in soil samples collected from outside the Plutonium Facility-and Waste Disposal Facility". Reference to the size of contaminated areas may be inappropriate.

4.

Section VII, Page 4: What information will be used to determine the boundaries of the radiological control areas?

5.

Section VIII, Page 6, Task 4: This section should include the methodologies'used to adequately characterize the area.

6.

Section VIII, Page 6, Task 5: The type of personnel monitoring devices might, more.

appropriately, be incorporated into the health and ' safety plan rather than in the description of soil excavation procedures. The use of alpha probes to monitor soil for alpha radiation will not be effective, due to the attenuation of alpha particles in soil.

L

.7.

Section VIII, Page 7, Task 6: A description of the soil sampling procedures should be '

provided (see also item 3.1.1, page 4 of Appendix B). Will any surface scans or exposure rate measurements be performed e this time?

0' l <.

a,

,.-,.r,_,-,-._,__.-,-_-,.--,.,,n,U,

, ~,,

--,-r l-____.

.,-.~%

,wm...m..,.,-~

.....,,._,,..-,,hm.--r-.,..,

e,.-

,---y

I l

e

)

)

~ Mr. h4alluswami December 9,1992 If you have questions, please do not hesitate to contact either Michele Landis at (615) 576-2908 or myrelf at (615) 576-5073.

Sincerely, hIfp Timothy J. Vitkus Environmental Project Leader Environmental Survey and Site Assessment Program TJV:tte cc:

J. Austin, NRC/NMSS, SE2 D. Fauver, NRC/NMSS, SE2 T. Mo, NRC/NMSS, 6H3 D. Tiktinsky, NRC/NMSS, 6E6 J. Swift /F,13rown, NRC/NMSS, 6H3 PMDA, NRC/NMSS, 6E6 J. Berger, ORISE M.12ndis, ORISE File /156 1

e e

'f

....~ _ _ _

4 l 41, i - ~.

GUP7b l

0 10E 20E 30E 40E-SOE 60E l

i I

I I

o_

LIGHT WOODED AREA k-N 10S -

/

CRASS

/

ROCKY 5'

205 -

7 99 WOODED g.,

i AREA PLtRONIUM p2 TO-FACIUTY 305 -

gg 4DS -

RETENTION ASPHALT TANK

[

PARKING g

CONCR ' [

SOS - -

LOT w

[

\\

V/

GOS -)

WOODED AREA 4

7DS -

RobD X

OLD ROUTE $5 h

(~ 2.5 KH)

.s l.-

l LOCATIONS OF ELEVATED l'

h SURFACE CAMMA RADIATION I'

FEET GENERAL ARCA OF 0

30 po7ENTIAL SOIL CONTAMINATION METERS nGURE 17:

Plutonium Facility and Waste Disposal Building Area Indicating Locations of Elevated Gamma Radiation-identified by Gurface Scans o

i-

)