ML20128E609

Environ Assessment for License Termination at Cimarron Corp Mixed Oxide Fuel Fabrication Plant

ML20128E609
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Site:	07001193
Issue date:	02/28/1993
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
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ML20128E579	List: ML20128E575 ML20128E609 ML20128E644
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ENVIRONh! ENTAL ASSESShlENT FOR LICENSE TERh11 NATION AT TIIE CIhfARRON CORPORATION'S 511XED OXIDE FUEL FAHRICATION PLANT Docket No. 70-1193 License No. 70-1174 February 1993 U.S. Nuclear Regulatory Commission

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Office of Nuclear hiaterial Safety and Safeguards.

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f CONTENTS Page 1.

INTRODUCTION AND

SUMMARY

1-1 2.

DESCRIPTION OF THE AFFECTED ENVIRONMENT...............

2-1 2.1 Site Locallsn 2-1 2.2 Climate and Meteoroloav 2-3 2.3 Democraohv and Socioeconomics 2-3 2.4 Land..............................

2-7 2.4.1 Land Usage 2-7 2.4.2 Wetlands............................ 2-8 2.5 Biota

?.............................

2. 6 G e ol oa v..............................

2-10 2.6.1 Regional Geology

................... 2 10 2.6.2 Site Geology 2-10 2.7 Hydroloav

.......,.................2-42 2.7.1 Surface Water and Usage...............

2-12 2.7.2 Groundwater and Usage................

2-14 2.8 Environme.nlal Monitorina.~

2-15 References for Section 2...................

2-22 3.

FACILITY AND IMMEDIATE AREA...................... 3.1 3.1 Review of Past Oper_ations 3-3 3.1.1 Gaseous Effluent System 3-3 3.1.2 Liquid Effluent Systems 3"6 3.1.3 External Spills / Leaks 34 7 3.2 Summary of Decontamination.....,..........-.....- 3-8 3.2.1 Decontamination of the External Site

..........3-8 3.2.2 Decontamination of the Building. Interior-3-11 3.3 Post-Decontamination Survey Resulti

.............. 3-10 3.3.1.

Residual Contamination Measures...

......... 3 3.3.2 External-Site Survey-(Soil Sampling in Mixed 0xide Facility Yard) 3-13 3.3.3 Internal Survey Results................ 3-16 References for Section 3....................

3 4.

P0TENTIAL ENVIRONMENTAL IMPACTS....-.........

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LIST OF FIGURES Figure 2.1 Cimarron site vicinity map..................

2-2 Figure 2.2 Location of site environmental monitoring sampling points 2-11 Figure 2.3 Generalized site stratigraphy sequence underlying the Mixed 0xide facility (refer to Figure 2.2 for location for Borehole 1323.

2-13 Figure 3.1 Plot plan of the Cimarron plant and underground piping layout during plant operations 3-2 Figure 3.2 Floor plan of the Mixed 0xide facility 3-4 Figure 3.3 Location of the new sanitary lagoon and underground piping after decontamination and decomissioning.......

Figure 3.4 Soil sample locations for the ORAU confirmatory survey 3-9 and the Kerr-McGee survey.................

3-14 1

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LIST OF TABLES Table 2.1 Average monthly temperatures 'C (*F) near the Cimarron site 2-4 Table 2.2 Average monthly precipitation near the Cimarron site 2-5 Table 2.3 Average monthly wind speeds and directions.in North Central Oklahoma 2-6 Table 2.4 Plants and trees observed at the Cimarron Site'.......

2-9 Table 2.5 Environmental sampling at the Cimarron Site.......,. 2-16 Table 2.6 Depths of groundwater monitoring wells 2-19 Table 3.1 Room identification in the Mixed Oxide Plant-3-5 Table 3.2 Summary of radionuclide concentrations in exterior soil samples collected at the Mixed 0xide Facility....

3-15 Table 3.3 Summary of interior measurements 3-18 Table 3.4 Summary of radionuclide concentrations in soil samples from excavations-at the Mixed Oxide facility 3-20 Table 3.5 Summary of exterior reasurements 3-22 iii

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1.

INTRODUCTION AND

SUMMARY

The Cimarron Corporation Plant (Cimarron) near Crescent, Oklahoma, was operated by Kerr-McGee Corporation for the manufacture of slightly enriched l

uranium and mixed oxide (uranium and plutonium) reactor fuels.

Two major facilities, licensed as two distinct facilities by the Nuclear Regulatory-Commission, are located at the Cimarron site:

the Mixed 0xide Fuel Fabrication Plant (Mixed Oxide Facility) and the Uranium Plant.

This environmental assessment (EA) will deal exclusively with the Mixed Oxide Facility license.

The Mixed Oxide Facility, formerly referred to as the Cimarron Plutonium Facility, was operated from April 1970 to December 1975 by Kerr-McGee Corporation under AEC/NRC Li_ cense Number SNM-1174, Docket Number 70-1193 for the manufacture of mixed oxide reactor fuels. Kerr-McGee does not plan to-conduct future NRC-licensed activities in the Mixed Oxide Facility.

Since ceasing operations, Kerr-McGee has removed equipment from the' facility, decontaminated the building and surrounding soils, and requested termination of the license to allow unrestricted use of the facility that formerly housed the plutonium fuel fabrication operation and of the area within the former security fence for the plutonium facility.

The purpose of this EA-is to-evaluate the environmental impacts of termination of the NRC license and releasing the structure of the former Mixed 0xide facility for unrestricted use.

The interior and exterior of the decontaminated Mixed Oxide Facility and the surrounding grounds have been surveyed by the applicant and the NRC's contractor (Oak Ridge Associated Universities). These surveys examined the concentration of relevant nuclides in the soil, the gamma dose rate'from the soil, and the contamination levels on-interior and. exterior surfaces..These results show:

1)

There is no evidence of any. plutonium contamination of the groundwater.

1-1

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2) There is limited contamination of the surrounding soils.

The average uranium content of the exterior soils is two to three times background levels but about two orders of magnitude below NRC soil guidelines for disposition of contaminated soils with no restrictions.

The average plutonium content of the exterior soils is indistinguishable from i

background and over two orders of magnitude below NRC soil guidelities i

for disposition of contaminated soil with no restrictions.

Two soil samples showed americium contents that were above background but about one order of magnitude below NRC soil guidelines for disposition of-contaminated soil with no restricitons.

The average gamma dose rate at I meter above the soils is indistinguishable from background.

3) The surface contamination levels of plant interior and exterior.

surfaces are, on the average, three orders of magnitude below NRC decontamination guidelines, i

i 1-2

2.

DESCRIPTION OF THE AFFECTED ENVIRONMENT This section provides a brief overview of the Cimarron site and reviews the historical environmental monitoring program results with respect to plutonium.

The site is located in a rural area that is sparsely populated and lightly travelled.

Land is primarily used for grazing cattle and for cultivation.

The water supply is from groundwater. Any contaminants reaching the groundwater pathway would be discharged to the Cimarron River, a non-potable source of water in this area because of naturally occurring elevated chloride concentrations.

The historical environmental monitoring program results were reviewed with emphasis on the soil and groundwater pathways.

Typically, enviror, mental

- samples were obtained from locations 0.8 to 1.6 kilometers (0.5 to 1 mile) away from the Mixed Oxide Facility. Analyses of these samples indicated that no gross contamination of the environment was occurring.

At these sampling locations, plutonium concentrations were indistinguishable from background.

Section 3 of this report focuses on the site-specific sampling that was ennducted as part of the license termination.

2.1 Site location The Cimarron site is located on the south side of the Cimarron River in Logan County, Oklahoma, and approximately 0,8 kilometers (0.5 miles) north of the intersection of Oklahoma State Highways 33-and 74 (Figure 2.1). Guthrie lies 14.5 kilometers (9 miles) to the east of the site, Kingfisher lies 32 kilometers (21 miles) to the west, and the northern edge of the-0klahoma City metropolitan area is about 21 kilometers (13 miles) to the south.

The site covers approximately 440 hectares-(1,100 acres).

The topography of the study area is characterized by-low, rolling hills, incised drainage, and floodplain.

The elevation ranges from 287 to-309 meters (940 to 1010 ft) above mean sea level (HSL).

The Cimarron River floodplain is l

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y the dominant geomorphic feature and is approximately 0.8 kilometers (0.5 miles) wide.' Normal water elevation in the river is 284 meters (930 ft)

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2.2 Climate and Meteoroloav The climate of the site is continental with annual average temperature ranges between 16' and 17'c (60' and 62'F), based on 90 years of National Weather Service records from Guthrie and Kingfisher.3 The monthly averages range from-a low of about 2'c (35'F) in January to about 28'C (83'F) in August (Table 2.1).

Daily temperatures fluctuate greatly as is typical of continental climates.'

Precipitation varies monthly as shown in Table 2.2.

In 1988, the average annual precipitation was 77.11 centimeters (30.36 in.) in Guthrie and 70.36 centimeters (27.70 in.) in Kingfisher.3 The total annual and average monthly. precipitation at the Cimarron' Site would be expected to fall between the Guthrie and Kingfisher measurements. January'and May are the driest and wettest months with averages of 2.5 centimeters (1 in.) and 16.5 centimeters (6.5 in.) of precipitation, respectively.i'3 The closest site with records on wir~ speed is Will Rogers Airport located 51 kilometers (32 miles) east-southeast in Oklahoma City. These records show that the average wind speed in the area is 5.6 m/s (12.6 mph),-and the wind typically blows out of the south southeast for ten months-of the year (Table 2.3).

This data is considered representative of conditions at the Cimarron site since neither location has terrain likely to channel air flow.'

Most tornados in the area occur during the spring from March t'o June.3 2.3 Democraohv and Socioeconomics Between 1970 and 1980, the population of Logan County increased just over 3 percent per yea'c to 26,881.' The population growth rate has slowed since 1980 and is predicted to be 0.6 to 0.7' percent per year from 1980 to 2000.

Approximately 42 percent of the 1980 population in Logan County lived in.

2-3

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Table 2.1 Average monthly temperatures 'C ('F) near the Cimarron site MONTH GUTHRIE KINGFISHER

[

January 2.4 (36.4) 2.2 (36.0)

]

February 5.2 (41.3) 5.1 (41.2)

March 9.9 (49.8) 9.8 (49.6)

April 16.2 (61.2) 16.0 (60.8)

May 20.7 (69.3) 20.8. (69.4)

June 25.5 (77.9) 25.9 (78.6)

July 28.4 (83.1)'

28.7 (83.7)

August 27.8 (82.1) 28.0 (82.4)

September 2.34 (74.1) 23.4 (74.2)

October 17.2 (63.0) 17.2.(62.9)

November 9.6 (49.3) 9.4 (48.9)

December 4.4 (40.0)

. 4.4 (39.9).

ANNUAL AVERAGE 15.9 (60.6) 15.9 (60.6)-

SOURCE: National Climatic Data Center, 1989.

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l Table 2.2 Average monthly precipitation near the Cimarron site PRECIPITATION mm (in.)

MONTH GUTHRIE KINGFISHER January 23.1

(.91) 21.1

(.83)'

February-15.2

(.60) 28.7 (1.13)

March 51.1 (2.01) 44.7 (1.76)

April 66.0 (2.60) 61.5 (2.42)

May 137.7 (5.42) 125.5

'(4.94)

June 100.6 (3.96) 95.5 (3.76)

July 72.1 (2.84) 65.3 (2.57) i August 60.5 (2.38)_

60.7 (2.39).

September

_101.1 (3.98) 91.4 (3.60)

October 67.6 (2.66) 62.0 (2.44)

November 45.7 (1.80) 38.9-(1.53)

December 30.5 (1.20) 8.4

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TOTAL

'771.2 (30.36);

703.7. (27.70).

SOURCE:

National Climatic Data Center. 1989.

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Table 2.3 Average monthly wind speeds and directions in North Central Oklahoma Month Sector Wind Blowing From Wind Speed m/s (mph)

January North 5.8 (13.0)

February North 6.0 (13.4)

March South-Southeast 6.7 (14.9)

April South-Southeast 6.7 (14.8)

May South-Southeast 5.8 (12.9)

June South-Southeast 5.6 (12.5)

July South-Southeast 4.9 (11.0)

August South-Southeast 4.8 (10.7)

September South-Southeast 5.0 (11.1)

October South-Southeast 5.4 (12.1)

November South-Southeast 5.6 (12.4)

December South-Southeast 5.7 (12.7)

SOURCE: Personal communication with Arlen Chitwood, National Weather Service, Will Rogers Airport, Oklahoma City, OK, July 18, 1990.

2-6

1 Guthrie and 6 percent resided in Crescent.

Forty-four percent of the population lived in rural areas.' There were 10,569 housing units, most (79 percent) owned by the occupants.' Suburban development began in the southern part of the county in approximately 1980, but new housing construction in recent years has been slow.a The county is within commuting l

distance of Oklahoma City and is part of the Oklahoma City Metropolitan Demographical Area.'

The economy of Logan County is primarily derived from agriculture with 925 farms averaging 153 hectares (379 acres) in size.

Hay and wheat are the main crops, and cattle are grazed between plantings.' In 1987, a total of 439 businesses were registered in the county with 66 percent employing less than 5 people.

Transportation near the Cimarron site is primarily by road and usage is typical for rural highways.

2.4 Lasi 2.4.1 Land Usage i

The area around the Cimarron site is mainly rural The' predominant uses of land in the area are small grain cultivation and cattle grazing.

Some land-is being developed for residential housing within 8 kilometers (5 miles) of the Cimarron Site.

There are a few houses north of the river on bluffs overlooking the Cimarron River.

To the south there are homes adjacent to a golf course located approximately 1.6 kilometers (1 mile) southeast of the plant on State liighway 33.s The nearest residence is a farm located O.8 kilometers (0.5 miles) southeast of the site.

Recreational facilities in the county include several man-made lakes near Guthrie, small parks in Guthrie

.and-Crescent, two recreational vehicle parks, and the golf course on Highway 33."

2-7

2.4.2 Wetlands The wetlands on the site are confined to the seeps and springs in the draws, and to the three reservoirs on the site.

The reservoirs are designed for a maximum elevation of 293 meters (960 ft), and had water at an elevation of approximately 292 meters (959 ft) during a field survey on July 17, 1990<

The margins of the wetlands are vegetated with eastern red cedar (Juniperus

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virginiana), black willow (SalfA nigra), and American elm (Ulmus americana).

No vegetation was observed in the flowing water of the draws, but pickerel weed (Potomogeton sp.) was observed along the margin of the reservoir. _The edges of the reservoirs are grazed by cattle, and their characteristics are more like farm ponds than natural lakes and ponds.

2.5 Biota The Cimarron site was previously farmland and most of the property is still used for grazing or wheat cultivstion.

The vegetation on the site can be divided into two types:

uplands and stream valleys.

The uplands vegetation is Bermuda grass interspersed with native grasses such as little bluestem, timothy, and grama grass.

Trees are invading the grassland, with eastern red cedar being the dominant tree. American elm, black willow, and green ash are also present.

The stream valleys are dominated by castern red cedar, American elm, and black willow, with occasional black walnut, post oak, and quaking aspen. A total of 25 species of plants was identified during a brief field reconnaissance of the site July 17, 1990 (See Table 2.4).

Small mammals are y

evident on the site.

A striped skunk den was identified in one of the. draws, and there was evidence of pocket gophers in the area below the bluffs.

L The Cimarron River-is the principal aquatic habitat in the area.

The river' salinity originates from salt-springs about 160 kilometers (100 miles) l upstream from the site. Seventy to 80 percent of the fish population in the Cimarron River are minnows-of the family Cyprinidae.

The other 20 to l

30 percent are shad, river carp, _ suckers, buffalos, and catfish, as well as -

game fish such as white bass, white crappies, and sunfish."'

2-8

Table 2.4 Plants and trees observed at the Cimarron Site' COMMON NAME SCIENTIFIC NAME Corn Cockie Agrostemma githago Buffalo Gourd Cucurbita factidissima Black-eyed Susan Rudbeekla hirta Primrose Cenothera sp.

Bull Thistle Cirsium vulgare a

Prairie Gentian Eustoma grandiflorum Greenbrier Smila sp.

Spiderwort Riverbirch Betula nigra Black Cherry Prunus serotina Siberian E1m Ulmus pumila Eastern Red Cedar Juniperus virginiana Post Oak Quercus stellata Redbud Cercis canadensis Honey Locust Gleditsia triacanthos American Elm

-Ulmus americana B1ack Mainut Juglans nigra Black Willow Salix nigra Green Ash Fraxinus pennsylvanica Quaking Aspen Populus tremuloides L1ttie B1uestem Andropogon scoparius Timothy Phleum pratense Grama Grass Tripsacun dactyloides l

(Bvu*? ous sip)-

Indian Grass Sorghastram nutes;:

Russian 011ve Elaeaghus angustifoli:'

• Based on field-observations, July 17, 1990.

b 2-9

L The site is not a critical habitat for any endangered species.

It is on a Whooping Crane flyway, and peregrine falcons and bald eagles could be winter visitors to the site.2 2.6 IltalDSY 2.6.1 Regional Geology The Cimarron site is located in the Great Plains Physiographic Province which is characterized by gently rolling hills and broad flat pl.ains.

The area is underlain by Paleozoic rocks that were deposited alternately under marine and non-marine conditions.'

In the ancient geologic past, this region was subjected to uplift and erosion as recorded in the north-northwest trending normal faults and anticlinal structures comprising the Nemaha Uplift located west of_the site.

No fault lineations have been mapped at the surface in the vicinity of the Cimarron site.'

2.6.2 Site Geology The Permian Garber Sandstone and Wellington Formation immediately underlie the study area.

These formations dip to the west at approximately a 0.4 percent.

to 0.6 percent slope and consist of interbedded sandstones, siltstones,'and shales.

1he Garber Sandstone outcrops in the cliffs.along the Cimarron River.

Unconsolidated Quaternary terrace and alluvial deposits overlie the-consolidated bedrock described above.

The Quaternary deposits are composed'of gravels, sands. silts, and clays that generally range in thickness from 3 to 15 meters (10 to 50 ft).1 The site stratigraphy is described based on the site characterization work of.-

J. L. Grant and Associates (1989).' We.11 1323 is used as a type log to describe the stratigraphic sequence unc;erlying_ the Mixed Oxide facility since it is the deepest borehole located adjacent to the plant-(Figure'2.2)

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referred to as Sandstones A, B, and C, were defined with respect to intervening mudstone layers (Figure 2.3).

All three sandstone units are continuous across the site and are separated by laterally continuous mudstones of variable thickness.' Each of the sandstone units contain discontinuous mudstone or siltstone layers that affect the reservoir characteristics of the equifer. The mudstones are typically poorly consolidated and have a consistency of very stiff to hard sandy silt or clay even at depths greater than 30 meters (100 ft).

Hydraulic conductivities measured in the Garber/ Wellington aquifer at the site are maderate because of the high silt content of the sandstones.'

The depth to water in wells completed in Sandstones A and B rang s between 3 to 9 meters (10 to 30 ft) below ground surface; whereas, depth to water in wells completed in Sandstone C varies from 17 to 18 meters (55 to 60 ft) below the ground surface indicating there is no connection between the deep and shallow aquifers.

The potentiometric surface of both units indicates that the direction of groundwater flow is to the north-northwest based on available data.' The groundwater flow in Sandstone A is strongly influenced by topography and surface water bodies.

2.7 Hydroloav 2.7.1 Surface Water and Usage The Cimarron River is not used to supply drinking water because of elevated chloride concentrations. The chlorides are derived from the Big hi+ Plains located approximately 160 kilometers (100 miles) upstream from the Cimarron facility.'

In addition, heavy use of groundwater for irrigation in upstream areas has reduced the river's base flow contributing to increased salinity.

Because of the poor quality of the Cimarron River water, the towns downstream of the plant do not use river water for agricultural or municipal purposes.

The principal sources of useable surface water in the vicinity of the Cimarron facility are small reservoirs that impound surface water runoff. These surface impoundments are used to water livestock.'3 2-12 I

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2.7.2 Grottndwater and lisage There are three primary groundwater sources in the vicinity of the Cimarron site.

These are terrace deposits north of the river, alluvium in the river valley, and the Garber/ Wellington aquifer.' The principal source of groundwater at the site and south of the Cimarron River is from bedrock aquifers in the Garber/ Wellington formation.'

Quaternary terrace and alluvial deposits locally are important sources of-groundwater north of the Cimarron River.

These deposits consist of lenticular unconsolidated gravels, sands, slits, and clays. Well yields of 13 to 16 liters per second (200 to 250 gallons per minute) are common.

Groundwater in the terrace deposits near the town of Crescent flows southward towards the Cimarron River and contributes to its base flow.

Recharge of the terrace and.

alluvial. aquifers occurs through precipitation and infiltration; however, water levels in the alluvial aquifers are commun1y maintained by. streams and rivers.' Groundwater quality from the terrace deposits is good. Water from-the alluvial deposits along the Cimarron River is generally fair to poor because of the salinity of the river water.'

The Garber/ Wellington aquifer consists of a fine-grained sandy siltstone with low permeability at the site. The groundwater in shallow sandstones of. the Garber/ Wellington aquifer such as at the Cimarron site flows laterally toward streams and springs where it discharges to the surface.. A minor compon'ent of' flow 'is vertical and leakage partially recharges deeper confined aquifers.'

The direction of groundwater flow is northwest to the Cimarron River based on mapping by J. L. Grant and Associates.'-

A well search conducted by James L. Grant and Associates identified 23 Lgroundwater wells located south of the Cimarron River and within a 4.8-kilometer (3-mile) radius of the Cimarron facility.

Three of these wells were completed in Quarternary terrace deposits and the remaining 20 were 2-14

completed in the bedrock aquifers." The closest well to the Mixed 0xide

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facility is located approximately 0.8 kilometers (0.5 miles) south j

(upgradient). Data are not available to determine if these wells are completed in Sandstones A, B, or C as defined in Section 2.6.2.

Most wells in the study area provide water for residential use in single households although some wells are used for irrigation." About 70 percent of the people in Logan County are served by private wells, and the remainder use water supplied by the towns or rural water districts.

Nearly all water is supplied by groundwater. A rural public water company supplies potable water to most homes and farms in the vicinity of the Cimarron site.

The groundwater is from wells completed in terrace deposits north of the Cimarron River."

V 2.8 Environmental Monitoring

- An environmental sampling program was established in 1969 before startup of operations at the Mixed Oxide Facility.a from 1972 to 1989, air, surface water, vegetation, ami soil samples were collected'in the vicinity of the site and analyzed or the constituents shown in Table 2.5.

Figure 2.2 illustrates the sample locations (for the different media) within close vicinity of the Mixed Oxide facility.

Other sample locations for' soil, air, vegetation, and surface water at more distant points are not shown on-this map. ~ Annual groundwater monitoring on the site was initiate'd in 1976_after the plant was on stand-by status.

Soil samples collected for the environmental monitoring program consisted of surface and subsurface plugs.

Surface plugs had a 7.6-centimeter (3-in.)

diameter and were collected to a depth of 5 centimeters'(2 in.).- Subsurface plugs had a 7.6-centimeter (3-in.) diameter and were collected to a depth of 25 centimeters (10 in.)."

Soil samples consisting of a composite of 10 surface plugs and a composite of 10 subsurface plugs were collected annually at 17 locations and analyzed for uranium, plutonium, and fluoride _(note not all soll sample locations are shown on Figure 2.2).

Grab _ samples of-groundwater were collected from three production (water) wells and seven monitoring wells and analyzed annually for uranium, plutonium, nitrate, 2-15

i Table 2.5 Environmental sampling at the Cimarron Site

$ AMPLE flGUA[

SAMPLING 1AMPLlWG ffPE Eff No.

LOCA110W Fat 0VtWCY AWALV$ll' Air 1101 WW 0.5 Mile Dally (4 hr eartle) e, p 1102 KM Lake Daily (4 hr sanple) 1103 Jct. 33 74 Dalty (4 hr senple) a surface Water trol Cimstron River Upstream Weekly e, p, Pu, U, F, No.

1202 timstron River

• Downstream Veekly a

1203 Pond WW of Plant Weekly 1204 Pced West of Plant Weekly a

1205 (M Lake test Weekly 1206 Pond WV of Irw:Inerator Weekly 1208 stream WW of old Pond 2 Weekly a

1209 KM Lake West Weekly 1212 Sanitary Lagoon East Weekly 1213 tenitary Lagoon West Weekly.

cround Water 1101 North of Plant Annually a, $, Pu, U, F, WO, 1302

$W af old Pord 1 (dry)

Amually.

1303 Farm SE of Plant Annually a

1304 WW of Old Pond 1 (dry)

Annuelty 1305 WW of Old Pond 2 Anrust ty N

1306 SE of old Pond 2 (dry)

Annual (y 1307 JunetIon Wwy 33 and 74 Annua lly a

1308 WE of Old Pond k (dry)

Annual (y 1300 SW of 01d Pond 2 (dry).

AnnualIy 1310 South of old Pond 2 (dry)

Annually.

i.

l l

a. -_ e a Gross Alpha, $ e Cross Beta, Pu e Plutontuh, U e Tstal Urantua,.F's f tuoride, WO, = Witrate i

2-16 n

L L

l

e Table 2.5 Environmental sampling at the Cimarron Site (Continued)

SAMPlt flGURE

$4MPLikQ SAMPLING TYPE KtY NO.

LOCAll0N F880VENCY ANALY$ll' Soit 1401 North % Mite Quarterly Pu, U, f 1402 North U fence line Guarterly a

1403 South U forwe Line Quarterly a

1464 South n Mlle Quarterly a

1405 test % Mlle Quarterly a

1406 West % Mlle Guarterly a

1407 North 1 Mlle Quarterly a

1408 South 1 Mlle Quarterly a

1409 test 1 Mlle Quarterly a

1410 West i Mlle Quarterly a

1611 Northeast i Mlle Quarterly a

1412 Northwest 2 Miles Quarterly a

1413 Southwest 2 Miles Quarterly a

1414 Southeast 2 Miles Quarterly a

1415 North 3% Miles Quarterly a

1416 North 5 Miles Quarterly a

1417 North 10 Miles Quarterly a

1418 North Pu fence Line Quart >rly a

vegetation 1501 North % Mite Annually Pu, V, f 1502 North U force Lire Annually a

1503 South U fence Line Annualty a

1504 South % Mito Annualty a

1505 test % Mlle Annually a

1506 West % Mlle Annualty a

1507 Covered Pu Pond Anrust t y a

1508 Covered Pond 1 Annuelty a

1509 Covered Pond 2 Annually a

1510 DLd Burlet Pit Annually a

1511 North Pu ferre Line Annually a

a.' s e Cross Alpha, $ a Cross Beta, Pu a Plutontun, U a total Uranlue, f a fluoride, NO, e Nitrate 2-17 1

fluoride, gross alpha and gross beta activity."

Soil data collected from the environmental monitoring program were reviewed to determine if plutonium had been recorded in either the ;urface or subsurface samples.

Pu-239 data from samples collected annually for the period from 1983 through 1989 were reviewed, lhe Pu-239 concentratien was indistinguishable from background for both surface and subsurface soil samples.

Review of historic environmental monitoring data indicates no plutonium contamination of the soil at the sample locations.

The plutonium activity analyzed in groundwater samples collected as part of the historic environmental monitoring program as well as data collected in conjunction with the recent site characterintion efforts were reviewed to determine if there was evidence of plutonium cot.tamination.

Data from the environmental monitoring program were reviewed for 1976 and for the period from 1984 to 1989.

Pu-239 values were indistinguishable from background.

Thirty-six groundwater monitoring wells are located on or in the vicinity of the Cimarron site (figure 2.2).

The completion zones within each well are shown in Table 2.6.

Wells 1301 through 1310 were drilled in the mid-1970s; however, the completion zone is unknown. Wells 1311 through 1317 were drilled between 1984 and 1985 to supplement the existing groundwater monitoring network since six of the original ten wells were dry and one of the wells showed elevated gross alpha activity (Well 1305). Wells 1320 through 1336 were drilled between January and March of 1989 to assess the extent of groundwater contamination at the site. Nineteen wells are completed in Sandstone A, one in Sandstone B, and four in Sandstone C (Table 2.6).

Review of data collected in 1989 from the supplemental groundwater monitoring network (i.e., wells 1311 to 1336) indicated that the Pu-239 concentration ranged from 0.002 to 0.006 pCi/L.

Background values for Pu-239 are less than 0.010 pCi/L in the study area.

The NRC has established 20 pCi/L as an acceptable concentration of Pu-239 for liquid effluent in unrestricted areas (10 CFR 20 Appendix B, 520.2401).

There is no indication of plutonium 2-18 1

I Table 2.6 Depths of groundwater monitoring wells WELL SCREENED INTERVAL m (ft)

SCREENED IN 5

1301 V jant, wri Unknown 1302 Unknown Dry 1303 Unknown Out of Sersice 1304 Unknown Dry-1305 Unknown Unknown-1306 Unknown Unknown 1307 Unknown Sandstone C Total Depth = 43 (140) 1308 Unknown Dry 1309 Unknown Unknown 1310 Unknown'-

-Dry 1311' 7.6 - 12.2 ( 25.0 - 40.0)

Sandstone A 1312' 6.4 - 10.7

( 21.0 - 35.0)

Sandstone A 1313' 7.0'- 11.6 ( 23.0

.38.0)

Sandstone-A 1314' 9.1 - 13.7. ( 30.0 - 45.0)-

_ Sandstone B 1315 3.7 - 8.2

( 12.0 - 2 7. 0 ) --

Sandstone A (?)

1316 5.2 - 9.8 ( 17.0 - 32.0)

Sandstone'A-(?)_

1317 0.9 - 5.5 ( 3.0 - 18.0)

Alluvium l(?)'

1319 Unknown ~

Sandstone C.(7)

Total Depth _= 611(200) 1320 8.7 - 11.7 ( 28.5

-38.5)'

Sandstone A:

1321 34.0 - 37.1 (111.6_- 121.6)-

Sandstone C-1322 7.6 - 10.7 ( 25.0

35.0)

Sandstone.A 1323 35.6 - 38.6- (116.8 - 126.8)

Sandstone C-

_1324 7.6 - 10.7 ( 25.0 --'35.0)

Sandstone A' 4

2 cj 4

I 4

Table 2.6 Depths of grour.dwater monitoring wells (Continued)

WELL SCREENED INTERVAL m (ft)

SCREENED IN-

'i 1325 10.7 - 13.9 ( 35.0 - 45.5)

. Sandstone A 1326 9.8 - 12.9 ( 32.3 - 42.3)

Sandstone A 1327-A 8.8 - 11.9 ( 29.0 - 39.0)

Dry-1327-B 11.9 - 14.9 ( 39.0 - 49.0)

Sandstone A 1328 38.1 - 41.1 (125.0 - 135.0)

Sandstone C1 1329 10.7 - 13.7- (.35.0 - 45.0)

Sandstone A-1330 8.7 - 11.8 ( 28.7 38.7)

. Sandstone'.

A

'.7-6.8_ ( 12.2,-

22.2)

Sandstone A-1331 a

1332 32.3 - 35.4 (106.0 - 116.0)-

Sandstone C-1333 6.7 - 9.8 ( 22.0 - 32.0)

Sandstone A-1334 3.0 - 6.1

( 10.0 - 20.0)-

Sandstone A 1335 9.1 - 12.2

( 30.0 40.0)

Sandstone A 1336 5.5 - 18.5 ( 18.0 28.0)-

Sandstone A Wells 1311, 1312, 1313, and 1314'not'shoen-on Figure-2.2.

These wells are-located by the old burial ground.

i 2-20

'l contamination of the Garber/ Wellington _ aquifer based on ' review of available-data.

e

~

r-i r-b 2-21

?

References for Section 2-1.

' James'L. Grant and Associates Inc., Site Investigation Report'for the Cimarron Corporation Facility, Logan County, Oklahoma, September 12, 1989.

2.

U.S. Nuclear Regulatory Commission, *Drkft of the Final Environmental-Statement of the Kerr-McGee Mixed 0xidt Fabricating Plant, Logan County, Oklahoma," January 16, 1975.

3.

National Climatic Data Center, " Climatological Data Annual Summary:

Ok1ahoma, 1988,". Volume 97, Number 13, 1989.

4.

Personal communication with Axel Graumann, National Climatic Data Center, Asheville, North Carolina, July 19, 1990.

5.

Personal communication with Arlen Chitwood,. National Weather Service, Oklahoma City, Oklahoma, July 13, 1990.

6.

U.S. Department of Commerce, Bureau of the Census, " Census of Population and Housing, 1980," Summary Tape File 3A, Washington, D.C., 1982.

7.

Oklahoma Department of Commerce, " Population Projections-for Oklahoma and Its Counties by Age and Sex, and for Its' Cities, 1980-2010,"

Oklahoma City, Oklahoma, November 1988.

8.

Personal communication with Thomas Stambeck, Logan County Health Department,. July 13, 1990, 9.

Personal communication with David Ranek, Oklahoma State Board of.

Agriculture, Oklahoma City, Oklahoma, July 13, 1990, 10.

Personal communication with Craig.Womack, Oklahoma' Department-of Transportation,-July 13.-1990.-

-11.

Personal communication with Buddy Johnson, Crescent City Manager, July-12, 1990.

12.

-Personal communication with Jim Pigg,' Oklahoma State Department of Health, Oklahoma City,. Oklahoma, July 13, 1990.

13.

Sequoyah Fuels Corporation, Revision of Request-for LicenseiAmendment, License SNM-928, Docket No.-70-925, June 29, 1988.

14.

James.L. Grant and Associates,~Inc., Cimarron Facility Closure Responses-to NRC Questions, May 10,c1990.

~

15.

Kerr-McGee Nuclear Corporation, "Cimarron Facility' Environmental; Monitoring Procedure," KM-NC-20-2, November 10, 1976.

2-22 i

.c;

a1 3.

FACILITY AND IMMEDIATE-AREA This section describes the existing-facility, the past operations that might have contributed to contamination of the environment, the decontamination effort that was conducted at the Mixed Oxide Facility. and the post--

decontamination survey results.

Past operations of the Mixed 0xide Facility are reviewed in Section 3.1 to identify the potential areas-of contamination-from routine plant operation and from past leaks or spills.

In Section 3.2,.

decontamination of the Mixed 0xide Facility is discussed with respect to the external site and to the butidi.1g itself.

Finallj, in Section 3.3, the post-decontamination survey results are summarized with respect to tha external site, the building interior, and interior soil excavations. All reported measurements in this section include background.

- The Mixed Oxide Facility is located approximately 120 meters (400 ft) east of Highway 74, northwest of the Uranium Plant.

Support facilities included a cooling tower; wastewater treatment facilities including two sanitary lagoons and waste holding ponds;.and natural gas supply (Figure 3-1).

Water, nitric acid, caustic soda, hydrogen and nitrogen were piped to the Mixed Oxide-Facility from the Uranium'Plart.'

The exclusion area for the Mixed 0xide Facility is approximately 90 x 120 meters (300 x 400 ft)'and is enclosed by a. chain-link fence (Figure 3.1).

The Mixed 0xide Facility. consists of one building with dimensions-of 30 meters (100 ft) in width, 60 meters _-(200 ft) in --length, and'approximately.15 meters

'(50 ft) in height at its highest point. The building comprises approximately 2,400 m2 (26,000 ft ) of manufacturing, maintenance, office, and laboratory-2 areas.*

The plant is constructed of precast, prestressed concrete exterior walls and roof. --The concrete floor was poured in place after the precast concrete-building was erected. The. concrete roof deck was covered with roofing.and gravel.

Exterior ' building walls have a sandwich type construction with-insulation built in during the concrete casting. All exterior and interior joints in the precast. building were caulked to make an airtight structure. :To 3-1

4

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. I' Figure 3 1 E t plan the cimarron pTant and underground PIPi"9 Tayout during ant operations-3-2 to

c L

facilitate cleaning, all walls, ceilings, and floors throughout the building were finished with a smooth coated surface. Al! supply ducts and piping headers were in smeath cioed enclosures, sealed against the building roof.

3.1 Review of Past Operations The Hired Oxide. Facility was constructed for the purpose of manufacturing d

plutonium-uranium mixed oxide fuel rods. The procass consisted o r.opncipitating plutonium and uranyl nitrate solutions, converting the precipitate into a mixed oxide, pressing the mixed oxide into fuel pellets, and loading the finished fuel pellets into fuel rods. The operation also included scrap dissolution and recycling capabilities together with supporting laboratory facilities.

The past operation of the plant was reviewed to identify how these operations did or could have resulted in residual contamination of the environment. The gaseous and liquid effluent systems are described in Sections 3.1.1 and 3.1.2, respectively.

Past leaks and spills are discussed in Section 3.1.3.

3.1.1 Gaseous Effluent System Air exhausted from the plant consisted of process gases that were removed through a ventilation system and exhausted through at least two sequential, high efficiency particulate air (HEPA) filters to minimize particulate radior,uclides released to the atmosphere. The principal contaminant of concern was plutonium that could become airborne during the operations.

Airflow within the plant was controlled t,y maintaining the pressure of various areas so that net flow was always in the direction of the greatest potential for plutonium contamination. The first floor of the building was divided into three air control zones in order of increasing contamination potential, such that Zone I had the least contamination potential and Zone III had the highest contamination potential (Figure 3.2).3 Table 3.1 identifies the rooms. in the facility and the rooms in each air control zone on the first floor.

Data from stack exhaust samples were reviewed from the plant operating period (1970 to 1974) to determine volume and concentration of the gross alpha 3-3

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mentoonrun (22 ZoneIRooms

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' Zone III Rooms Figure 3.2 Floor plan of the Mixed Oxide Facility 3-4 l

L l

Table 3.1 Room 151entification in the Mixed Oxide Plant 20t1 40, ROOM NAME ROOM h0.

R004 NAME FIRST FLOUR ZONE 111 (Continued)

~

117 Mechanical Room 124 Pellet Processing 20e '

125 torridor 100 Vestibule 126 Vault 101 Reception 127 Scrap Recovery 102 Manager's Office 128 Wet Processing 103 Lmch acom 129 Genera l Lab 104 Men's Locker 130 X Ray Room 105 Women's Locker 131 Store Room Conrunication between Zone 1 and Zone 2 was 132 Gas Analysis through air locks (Roone 107 and 111) 133 Spectrographic Leo ZONE 11 134 Comting Room 106 Laundry 135 Metallography 108 Instrunent Room 136 Darkroom 109 Health Physics 138 Densttemeter Room 110 First Aid 139 Darkroom 112 Janitors Closet 140 Dry Prep Lab 113 Corridor 141 Mass Spectrometry Preparation 114 Personnel Decontamination 142 Mass Spectrometry Calculations consnunication between Zone 2 and Zoce 3 was 143 Mass Spectrcmeter Lab through air Locks (Roons 115 and 137)

SECOND FLOOR ZONE Ill 201 Exhaust Air Fan Roun 116 Maintenance Room 202 Supply Air Fan Room 118 Corridor BASEMENT 119 A!r Lock B01 Scrap Recovery 120 Material Air Lock B02 Wet Processing and Waste Treatment 121-Fabrication and Assently 803 Solvent Extraction 122 x Ray VAULT ROOF 123 Fabrication' Cold Chemical Storage (not on Fig. 3.2) 3-5 1

e

.3 s

r4 released 1to the atmosphere. The' annual volume-ranged from 3' lE+08 cubic meters to 7.4E+08 cubic meters.with' an. average. volume of_6.06E+08 cubic'

- meters. The alpha activity discharged ranged from 3.7 pCi/yr to 30,7 pCi/yr-:

~ '

-!with an: average.value of 17.3 yCi/yr.3 'These data. indicate thatl insignificant concentrations were released to the atmosphere.

Soil sampling _ resMts from

.th'e environmental monitoring program support this conclusion (see-

~

Section-2.8).

T 3.1.2 Liquid Effluent Systems Liquid effluent at the plant consisted of four wastestreams: - sanitary wastes;-

change room,-laboratory, and decontamination roem wastewater; hot laundryL

~

s wastewater; and liquid process wastes.' 2 Sanitary wastes-were primarilyi comprised of wastewater from restrooms. These. wastes passed through;a_

2,000-gallon ~ septic tank system and were discharged via a pipeline exiting the.

southeastern corner of the Mixed Oxide Facility to'one of-two sanitary lagoons-located east of the plant (Figure 3.1).-

l Change room, laboratory,;and decontamination room'wastewaters.were dra'ined2

=into one of two underground 10,000-gallonitanks located. 23: meters (75 Lft)

~

north of the facility.~(Figure'3.1). The drain; system'for1these wastes' was comprisedof-twoseparatepipingsystemsfromthefacilityitotheI10,000-gallon underground storage tanks: thel uranium laboratory: room / drain system J

(room 140) and the plutonium 11aboratory rooms drain: system (rooms.'129,D132F 134, 135,.136, 142,1143 and the room 125 corridor, see1 Figure 3.2).3

- Wastewater collectedLiu this system consisted of water from: the showers, ? sink -

1avatory -floor drains in the change rooms;and ~p.ersonnel decontamination' rooms,la sink inithe laboratory (room 129),- and. cold laundry.

O w

The uranium laboratory drain system exited the. building;through1the: east wall,c and the plutonium drain' system exited the facility through'thetnorth wal.1" Both drainage systems terminated lin~ the;two underground 10,000-ga110n collection tanks' located north"of the building'(Figure 3.1)~. - The piping' for both: systems was 5-centimeter (2-in.) durconLpipe. 'The wastewater was:

discharged alternately into one-of-the two _10,000-ga11on tanks, batch sampled

6 1

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c and-released to the sanitary lagoons when the concentrations were less than-4.0E-7 pCi/mi alpha (activity based on soluble Am-241).3 1.'1 quid wastes discharged via overflow of the sanitary lagoons to the Cimarron River consisted of the sanitary and change room and personnel decontamination room wastewaters.

Hot laundry wastewater was generated from exterior clothing contaminated in the range of 500 to 5,000 dpm/60 square centimeters. Wastewater from the hot laundry (one washing machine) was collected and sampled in a tank and alternately discharged to one of the two 6,000-gallon underground tanks located north of the building when the alpha concentration was below 4.0E-6 pCi/ml.3 The tanks were sampled again to ensure h t wastewater was:

below limits and then effluent was discharged to the hypalon-lined plutonium; evaporation pond.

Piping for the two 6,000-gallon storage tanks-exited' the building from the northeast wall (Figure 3.1).

Before May 1972, a flocculation-filtration process was used to remove plutonium and americium from process wastewaters. The treated process wastewaters were collected in one of the two 6,000-gallon tanks and discharged to the plutonium evaporation pond when the concentration was below 4.0E-6 Ci/ml. After this date, liquid process wastes were solidified _in 208-liter (55-gallon) drums for licensed burial o'ffsite.'

Based on review of past operations, the locations for potential contamination by liquid effluents are the areas adjacent to the= underground' storage-tanks, along liquid lines, and around the evaporation ponds and sanitary lagouns.

3.1.3 External Spills / Leaks Contamination outside the building occurred because of solidification process problems. However, one leak involved some spillage of_ natural uranium-uranyl nitrate solution from an aboveground storage tank. Leaks were located on-the-north side of the building in the vicinity of location Pu-44A and on the west side of the building north of the loading dock in the vicinity of_ locations Pu-45A, Pu-48 and Pu-49 (see Figure 3.1). A trailer was used for the 3-7 l

J 1

temporary _ storage of dry solid waste and solidified liquid wastes.pending its 4

transfer to an offsite licensed disposal facility.

Leakage from drums L

containing " solidified" liquid waste was documented on four occasions from.

July 1972 to Aug'.st 1973.' These leaks resulted in alpha contamination of up to 1.0E+8 dpm/60 square centimeters on the ground underlying the trailer.

The contaminated soil or gravel was removed for disposal.as contaminated waste.5 Clean dirt or gravel was replaced in the decontaminated area.

None of these leaks resulted in releases te wirestricted areas.

3.2 Summary of Decontamination Decontaminatior, and decommissioning (D&D) of the Mixed Oxide Facility was.

initiated in 1979.

For the external site, underground piping was removed and contaminated areas were cleaned up.

For the building interior, the D&D-project was divided into several tasks that included decontaminating the. wet ceramics area, scrap process area, dry process area, lab areas,' exhaust fan-room, the building and room ventilation; and removal of the solvent extraction system and the overhead exhaust pipe.

The decontamination'of the area within the security fence is described in Section 3.2.1, and the D&D of the building-

~

is described in Section 3.2.2.

3.2.1 Decontamination of the External Site L

The below-ground waste collection system described in Section 3.1.2 was removed together with associated piping.

The:underg'round piping that ran from-sthe underground storage tanks (6,000- and 10,000-gallon tanks).at the Mixed L

0xide Facility to the former plutonium evaporation _ ponds and_the old sanitary lagoons was removed (Figure 3.1). The sewage treatment lines remained. Areas were decontaminated where required.8 Figure 3.3'111ustrates the location of the remaining underground piping'after decontamination. The two 6,000-gallon sludge tanks and the two 10,000-gallon tanks were removed and packaged for?

~

shipment to a licensed disposal site. The level of radioactivity detected in-the soil after excavation of the tanks was not significantly different from-background.'

3-8

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c le Figure 3.3 Location of the new sanitary lagoon and underground piping after' decontamination and decomissioning 3-9 i.

r The plutonium evaporation and emergency ponds, shown on Figure-3.1, were closed with the approval of NRC and the Environmental Protection Agency's Region VI in 1978. The liquid wastes that had accumulated in the hypalon-lined plutonium evaporation pond and the hypalon-lined plutonium emergency holding basin were allowed to dry.

By the summer of 1976, the ponds were--

essentially dry; and the resultant sludge was removed, mixed with cement and shipped to a licensed offsite burial ground.' Samples 15 x 30 centimeters (6 x 12 in.) in size were taken at 12 locations within the plutonium evaporation pond to a maximum depth of 25 centimeters (10 in.).

The plutonium =

emergency holding basin was sampled in five locations to a maximum depth of 15 centimeters (6 in.).

Samples were analyzed for uranium mass ( g/g), uranium alpha activity (pCi/g), and Pu-238 and Pu-239 alpha activity (pci/g).

The proposed closure method was to fold the lining into the bottom, bulldoze the berm.in on the top and to add soil to fill in the contours to match the adjacent topography.'

NRC and the Oklahoma State Department of Health (OSDH) verified Kerr-McGee's soil sample data by independently sampling the pond bottoms in November 1977 for uranium and plutonium. The NRC results were generally less conservative than the Kerr-McGee results, and the OSDH noted that "the-concentration of y

radioactive materials in the soil in these areas is less than-those concentrations which are exempted from regulation under the Radiation Protection Regulations (Section 4.2).""

The state.-approved the plans for decommissioning and forwarded the data to EPA Region VI.

EPA noted that the residual radioactivity following decontamination was well under EPA's recommended " screening level" for plutonium in the general environment 2

-(0.2 Ci/m "a conservatively developed level at which, for most situations, L

radiation dose will not exceed 1 mrad /yr lung dose or 3 mrad /yr bone dose")

and that Kerr-McGee's plan was appropriate for returning the pond areas to a l

condition suitable for safe unrestricted use." The ponds were closed in 1978.

l Excavation and decontamination of the east and west ::anitary unlined lagoons L

was initiated in 1985.

After removal of-the contaminated 30-centimeter-(12-in.) clay liner, the lagoon areas were' surveyed. A 5 x 5 meter (16 x 16 ft) 3-10 4

i-

grid' was established, and soil samples were collected from depths of 0_ to 0.5, 0.3,- 0.6,_0.9 and :l=.2-meters (0 to 'l.5,1, 2, 3, and.4 ft) depths at each -

sample location." Kerr-ricGee's final. soil sampling and gamma survey results for the ola trast and west sanitary lagoons was submitted to NRC on October 16, 1990. NRC's contractor, ORAU, confirmed via independent measurements that the ponds were decommissioned below the guidelines required for unrestricted use by the NRC.

In 1985, a new lined sanitary lagoon was installed.on top of the backfilled plutonium ovaporation pond and the backfilled plutonium emergency holding pond. The location of the new sanitary lagoon is shown on Figure 3.3.

3.2.2 Decontamination of the Building Interior Dxontumination and decommissioning of the Mixed 0xide Facility building began in 1979 and was completed in 1989.' Equipment was removed and-surfaces were washed, scraped, stripped, chipped and/or scrabbled.

Some inner walls.and flooring sections were removed. Subfloor drains were also remove'd and soil excavated. Building surfaces such as walls 'and ceilings were shot _ blasted with a vacu-blast machine that had been modified by the addition of a cyclone filter to the discharge air stream for effluent control.'3 'Other equipment'-

and techniques were used to decontaminate' floor surfaces depending ~upon the floor coating.

The most successful method for decontaminating the production and -laboratory floor (Zone,III rooms) was a machine which_ used a rotating drum with milling cutter flails that contained tungsten carbide blades.13-A needle scaler was used to decontaminate inside corners of walls and other areas which; were inaccessible with other equipment.

3.3 Post-Decontamination Survey Results In mid-1989,' decontamination and follow-up radiological surveys were completed l by Kerr-McGee, and a report submitted to NRC.. A confirmatory survey of-the Mixed Oxide. Facility was completed _in August 1988 and October 1989 by the Environmental Survey and Site Assessment Program of'0ak Ridge. Associated Universities (0RAU), and 'a final report was submitted to NRC in January 1991.6 3-11 f

contamination at the site, the current status of the exterior site (i.e., soil sampling in the Mixed Oxide Facility yard), and the current status of the building interior are discussed in Sections 3.3.1, 3.3.2, and 3.3.3, respectively.

3.3.1 Residual Contamination Measures Three measures were used to evaluate the residual levels of contamination on the exterior of the Mixed 0xide Facility building.

These were:

concentrations of relevant nuclides in comparison to background, the exposure rate at one meter from the surface in comparison to background, and NRC soil concentration guidelines for releasing a site for unrestricted use.

NRC guidelines for acceptable contamination levels in soil for unrestricted use are contained:in the " Branch Technical Position for Disposal or Onsite Storage of Residual Thorium or Uranium Wastes from Past Operations" (46 FR 52061, October 23, 1981), and in NRC Policy and Guidance Directive FC 83-?'t;

" Termination of Byproduct, Source and Special Nuclear Material Licenses,", Acceptable Soil Contamination levels.

For the survey of the interior-of the Mixed 0xide Facility building,1two measures were used: the exposure rate measurements relative _ to background, and NRC guidelines for decontaminating facilities and equipment. The contamination guidelines used inside the facility were derived from Table 1 of U.S. Atomic Energy Cor. mission Regulatory Guide 1.86, " Termination of Operating Licenses for Nuclear Reactors," June, 1974.

In July 1982, NRC developed Annex C, " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material." This guidance is identical to Table 1 in Regulatory Guide 1.86 except a footnote was added which provided guidelines for dose rates from beta-gamma emitters in surface contamination (Footnote f).

These values are also incorporated into a draft ANSI standard, ANSI-13.12, purportedly based on the practical performance limits for portable survey instruments rather than on acceptable risk.7 Summary tables for this section present measured soil concentrations, exposure rate measurements, and NRC guidelines.

3-12 l

1 3.3.2 External Site Survey (Soil Sampling in Mixed Oxide Facility Yard)

The Kerr-McGee survey and ORAU confirmatory survey focused on the exclusion area within the fenced portion of the Mixed Oxide Facility.

Exterior surveys of the facility were made. Soil sampling within the fenced area was conducted by both Kerr-McGee and ORAU.

Kerr-McGee took direct gamma readings at 51 locations on a grid with 15-meter (50-ft) centers.

Eight locations were selected for radiochemical analysis in areas where it was suspected there might be potential contamination (i.e., areas cleaned up after leaks, the waste storage trailer area, rainfall runoff collection areas, and under roof drains).

These Kerr-McGee sample locations-are shown on Figure 3.1 and Figure 3.4.

At these locations, samples were taken from the surface to a maximum depth of 1.2 meters (4 ft), and analyzed for Pu-239, Ra-226, Ra-228, and U-238. The concentrations of Pu-239 and U-238 ranged from <0.001 to 0.097 pCi/g and <1.4 to 2.03 pCi/g, respectively (Table 3.2).

Plutonium -

concentrations were detected at background levels. Only one sample contained U-238 above background levels, and it was located at the southwest corner of the Mixed 0xide Facility yard adjacent to the fence.

The ORAU confirmatory survey used an exterior reference grid' spaced on 10-meter (33-ft) centers to cover the Mixed 0xide facility yard and adjoining the fence (Figure 3.4).

Both surface and shallow borehole soil samples were collected.

Seventy-three surface -soil samples-were-collected at the intersections on this grid from depths of 0 to 38 centimeters (0 to 15 in.).

Fifteen shallow borehole samples were collected at various accessible. depths to a maximum of 1.5 meters (5 ft). Approximately I kg of soil was collected at each sample location.'

Soil samples were also collected at two locations identified by. elevated gamma activity, five samples were collected at surface drainage outfalls, and 37 samples were collected from subfloor excavations within the building. The two-soil samples with elevated gamma levels north of the building were collected from the excavations for the piping to the underground-storage tanks.

Sample 3-13

g m

ml f_

290F l <,

I O

I l

h4 I

1 i r-u m

280K-w a

g N

.i

@ Cooling Tower 270t?

260t? :

mm5lM74 Eik O

250K-S e

Excavation S

240t? :

I

)

230K:

Building u

f i

220W~

'g 2:

210N-~

g I

I4 60W 50W 45W 30W 20W 10W OW 10E 20E 30E l

l CRAll!kmany Karr-McGas krvey o

. Sg ps.,

llr

• a*= '-*. c a

no

@ shesow m(< i.s m) u, - %.

l d Underground Pping Encavenlon Y

Aspheit Cement P - Plusonium Fence Figure 3.4 Soil sample locations for the ORAU confirmatory survey and the Kerr-McGee survey l

3-14 l

l

_ m, r_...

o A

- c..

Table'3.2: Sumary of radionuclide concentrations -in exterior soil samples: collected.'

lat the Mixed Oxide. Facility'(pC1/g)*

tq i.

j Radionuclide concentration (nCl/a) terr-McGee sackgrowuf '

Mixed Oxide Facility Analysis Concentration Yard

. Surface Drainage Mixed Omide or Exposure WRC

'-(0-15 cm deeth) outfatt Facitity Yard Rate Gui fet id Wo. of '

(Range)

Radionuclide

- Meas.*

Average.

No. of -

- (Range)

No. of Meas.

Average peas.

-(Range)

Range U-235 89

-(0.1 - 1.5) 5 (0.1 - 16.8)

NM"

<0.1 - 0.2

. 30 0.3 0.3 U-238

-89 (0.2 - 7.7) 5

-(1.4 - 5.01.

15

- (<1.4

.2.03)

<0.3 - 0.9 30 1.9.

2.9 -

Pu-238 130.

(0.005 - 0.02)*'

5 (0.01 - 0.06)

<0.1 25 -

! ~

0.0097 0.02 Pu-239/240 30 (0.005 - 0.09)*

.5 (0.01 - 0.7) 15

(<0.001 - 0.097)-

<0.1 25 LJ 0.017 0.16 l

. 5. An-241*.

.2

-(0.8

.4.6) s 5

..(<0.2 - <0.3)-

NM

+0.1

'30

<0.26 -

Exposure Rate 9'- 10 1

(sR/h)'-

7 - 11* -

8

• 11 (Contact) 1 meter a.

Source: ORAU,.1991, and correspondence from S. c. Mmson, Kerr-McGee to S. Wicat,' ORAU,' octobee 3,1969.

b.

Ntaber of measurements made looking for the specific nuclides.

c.

HM = not measured.

d.

Composite samples.

' e.

An-241 only detected in two samples (correspondence from J." Berger, ORAU, to R. ratchy, SAIC,~3/22/91). '

f.~ Exposure rate measurement at one meter unless otherwise shown.'

' g.

Exposure rate measurements were made by ORAU at each ' location where a soit sample was taken in the Pu-Flant yard. ;

'h.1 When applying the guideline, the stan of < the ratios of. radionuctide concentration and guideline concentration must be less than 1.0. -

A y

b m

a r-y

-s-'*-

,4..+.

/

4,

.ym,g g3,..r-g 4 M,s.Er q'y,.v.u a

.4y..,

h-

9 locations are shown on Figure 3.4 and analytical results for exterior soil samples in the Mixed 0xide Facility yard are summarized in Table 3.2.

The average concentration of U-235, U-238, Pu-238, and Pu-239/-240 in 137 surface-soil samples was 0.3, 1.9, 9.7E-03, and.l.7E-02 pCi/g, respectively.

These averages represent concentrations of these isotopes for depths from the surface to 15 centimeters.

t Certain trends were noted in the distribution of the radionuclides especially-vith respect to uranium isotopes.

The concentration of the uranium isotopes was higher on the eastern side of the building (east was defined as all samples taken east of 15W on Figure 3'.4).

The eastern side of the building had average concentrations of U-235 and U-238 of 0.3 pCi/g and 2.1 pCi/g, respectively, compared to average concentrations of 0.2 pCi/g and 1.6 pCi/g for U-235 and U-238 on the west side of the facility.

The same-relationship was noted at various depths. These approximately. 33 percent higher concentrations on the east side of the building may reflect the presence of

. windblown uranium from the Uranium Plant located southeast of the Mixed 0xide Facility (Figure 3.1).

The uranium and plutonium concentrations in the Mixed 0xide Facility yard were either at or slightly above background indicating that some-contamination was present. Americium-241 was detected by gamma spectrometry in only two-soil samples, and was not believed to be widely distribute'd around the site." Total uranium concentrations exceeded NRC-guidelines at two locations but average levels for the Pu-plant yard were -

within guidelines. The tot 11 exposure rate at one meter ranged from 7 to 11 pR/h which compares favorably with the background level of-9 to-10 pR/h.

3.3.3 Internal Survey Results Kerr-McGee performed a-final release verification survey of the rooms located ^

on the first floor in Zone III, the basement, the _second floor, and the vault (Figure 3.2 and Table 3.1) to evaluate and demonstrate the' effectiveness:of-the decontamination effort at the Mixed Oxide Facility.

For the final. release verification survey, Kerr-McGee gridded the walls and-floors of each-room located in Zone III on 2-meter (6.5-ft) centers. The fixed and removable 3-16

alpha activity levels were determined at five locations in a 2-meter-(6.5-ft) square:

at the center, and at the four midpoints between the center and the corners of the grid.

Ceilings were not gridded in this fashion because of the closely spaced rafters.

Survey measurements were made on the bottom of each rafter and on the ceiling midway between adjacent rafters at 2-meter (6.5-ft) intervals.

Measurements on adjoining rafters were staggered at one meter increments.

Piping and duct work was surveyed on all accessible surfaces at 2-meter (6.5-ft) intervals.

Results of the Kerr-McGee survey are shown on Table 3.3.

ORAU conducted confirmatory interior and exterior surveys of the building.

Exterior building surveys were performed on a 10-meter (33-ft) grid, and interior surveys of building floors and lower walls were conducted on a 1-meter (3.3-ft) grid.' Both gas proportional and ZnS scintillation alpha detectors and thin Nal(TI) (low-energy) gamma scintillation detectors were used to scan building surfaces.

Locations of elevated activities were noted for further investigation.

Building floors and lower walls received 100 percent scans; upper walls, ceilings, and other overhead surfaces were randomly scanned focusing on locations of highest contamination potential and suspect surfaces indicated as the survey progressed. Activity measurements on interior building surfaces were conducted on randomly selected grid blocks on the floors and lower walls.

Within a selected grid, total alpha and beta-gamma activity were systematically measured at the center and at four points midway between the center and corners of the block.

Smears for removable activity (gross alpha and gross beta) were made at the grid location that had the highest direct reading. Single-point measurements for total and removable alpha and beta-gamma activity were made on upper walls, ceilings, other overhead surfaces, equipment, and suspect areas as determined by surface scans. The surface scans of interior building surfaces identified 24 rooms with residual activity that exceeded NRC guidelines. Further remediation of these areas reduced activity levels to below guideline values.' Beta-gamma activity measurements were not made it most locations since alpha activity was considered the controlling factor for the anticipated contaminants.

3-17

Table 3.3 Summary of interior measurements Radionuctide surf ace Contaminatien Cross At@ a surface (pCl/100 cd)*

(dpm/100 cd) fixed Alpha Removable Al% a No. of U-234 U-235 U-238 No. of Pu-238 Pu-239/240 Range of Range of Uranium (Range)

(Range)

(Range)

Plutonium (Range)

(Range)

Background

Location Measurements Measurements Meas.

Average Average Average Mees.

Average Average Exposure Rate Att Rooms

<13.0 - 230 (O f

<2.0 - 18 (0) 49 (0.9 - 55.5)

(0.1 - 3.5)

(0.6 - 20) 48 (0.1 - 2.9)

(0.1 - 12.7)

<3.0 - 240 (K)

<0.6 - 18 (K) 5.7 0.4 3.5 0.3 1.1 Zone 1 aooms

<17.0 - 74 (0)

<3.0 - 7 (0) 6 (2.1 - 10.8)

(0.1 - 0.9)

(1.5 - 5.1) 6 (0.1 - 0.9)

(0.1 - 4.8) 6.4 0.4 4.9 0.3 1.1 Zone !! Rooms

<21.0 - 100 (D).

<3.0 - 9 (0) 9 (2.0 - 7.1)

(0.1 - 0.4)

(1.8 - 3.9) 9 (0.1 - 1.7)

(0.1 - 12.7) 3.8 0.2 2.9 0.4 2.3 Zone III Roorns

<13.0 - 210 (0)

<2.0 - 18 (0) 25 (1.3 - 55.5)

(0.1 - 3.5)

(1.2 - 20) 24 (0.. - 2.9)

(0.1 - 6.5)

<3.0 - 240 (K)

<1.3 - 18 (K) 7.3 0.5 4.2 0.2 e.0 Desement

<21.0 - 230 (0)

<3.0 - 5 (0) 4 (0.9 -

3.6)- (0.9 - 3.6)

(0.1 - 0.2) 4 (0.1 - 0.2)

'o.1 -

0.3)-

<5.1 - 128 (K) 0.6 - 12 (K) 2.2 2.2 0.1 0.1 C.2 Second Ftoor

. <21.0 - 140 (0)

<3.0 - 12 (0) 3 (1.9 - 8.3)

(0.1 - 0.3)

(1.4 - 10.4) 3 (0.1 - 0.2)

(0.1 - 0.2)

<9.5 - M (K)

<1.5 - 12 (K) 4.7 0.2 4.6 0.1 0.2 y

cold Chemical

<18.0 - 152 (0)

<3.0 - 12 (0) 1 1.9 0.2 1.9 1

0.2 0.2

<1.5 - 12 (K)

Storage to NOT MEASURED sanitary Orain

<28.0 - 30 (0)

<3.0 - 7 (0)

Guidetine*

Plutonium 100* - 300' 20 Uranius 5000* - 15,000' 1,000 Expostare Rate

• 9 - 10 (A /h) 7.5 - 11.6 R

l 1 meter 1

Froe ORAU confirmatory survey, January, 1991.-

a.

b.

(0) = (RAU confirmatory survey, Jaruary,1991.

(K) = Kerr-McGee' final verification survey, August,1989.

NRC, Amex C, " Guidelines for Decontamination of Facilities and Equipnent Prior to Release for Unrestricted use or Termination of Licenses c.

Source:

for 8yprockJet, source or Special Nuclear Materiet," July, 1982.

Ten exposure-rate measurements were made inside the facility with a pressurized Ionization chamber.

d.

Average over 1m' e.

f.

Maxinam creer 100ca/

-The range and average concentrations' of residual radionuclides measured by 0RAU are shown in Table--3.3.

The range of measurements'and the-average:

~ concentration were calculated for all rooms and then_ broken down-by= 1ocation within the building (i.e., Zone 1, Zone-II,-Zone III Rooms,-- the basement and?

the second floor), All radionuclide activity measurements were below NRC guidelines and ten exposure rate measurements within the-facility ranged from 7.5.to 11.6 R/h.at ;one neter which is comparable to background-exposure rate measurements (Table 3,;.

The average concentration of U-234, U-235, U-238,-

Pu-238, and Pu-239/240 was 5.7, 0.4, 3.5, 0.3, and 1.1 pCi/g, in all, rooms, H

respectively.

No americium is reported in the table because it' was below R

detection limits of 0.1 to 0.3 pCi/g'.

Excavations made for the purpose of removing the piping indicated residual plutonium activity in the soil..The range of contamination of subfloor soil samples from the Mixed Oxide Facility is 'shown in Table 3.4. ' The average'-

I value of U-235, U-238, Pu-239/240, and Am-241 from interior soil: samples was -

}

0.2, 0.8, 0.4, and 0.6 pCi/g, respectively. These values are above-background.'

but well below NRC guidelines (Table 3.4).

One drum of excavated soil i

contained total plutonium and Am-241 concentrations in excess of NRC -

guidelines; however, samples of residual subfloor-soil were-all below the

-guideline levels.' Outside the-building, one sample from the-piping excavation shown on Figure 3.4 had a total plutonium activity of 110 pCi/g.-

However, the total _ plutonium concentration. measured in 5 samples at or within' the 10-meter grid averaged-21 pC1/g which is below the guideline (refer to j

Figure 3.4 for sample locations). Measurements inside the. sanitary drainage q

system are summarized in Table 3.3.

Surface alpha activity was measured at _71 exterior surfaces including the building exterior, walkways (cement), the. sanitary drain system,- and_ the loading dock.- -If surface activity levels exceeded 100 dpm/100 cm on' single.

d 2

point measurements, the surrounding area was scanned to determine the 1

contamination level when averaged over.1 cubic meter.-- Forty samples'of paint

- from' walls,13' samples of concrete.from exterior walls and-sidewalks,.

L scrapings of external surface material, and three samples of roof gravel: were also collected and analyzed by gamma spectroscopy for uranium and americium, 3-19 l

u i

~,

p

=4.a

' Table 73.4 ;Sumnary of rtdionuclide ccncentratiens in soil samples from excavations in the Mixed Oxide Facility:(pCi/g)*

7,--

w th' Radionuclide Concentration (DCi/s)

Subftoor Excavation '

underaromd Pfoino Excavation Backgrossid

- +

huutiers

. Cont.entration

.Wister Nuter. '

.. of -

.(Range)

. of 3 (Range)-

of.

'of-Exposure NRC Radionuctide-Measurements

' Average-Measurements Average Measurements Rate '

Guidetines"

~

'U-235 31'

(<0.1 - 0.5)-

2' (0.3 - 0.4) 5

<0.1 - <0.2

, 30 g 0.2 0.35

'U-238 31 (0.2 - 1.6)"

2-

-(2.3 - 4.1) 5

<0.3 - 0.9

- 30

- 0.8 ~

3.2

' Pu-238 -

NN'.

2

.(0.01 - 10.4)

.1

<0.1 ~

' 25 5.2 Pu-239/240

' 5 (0.006 - 2.04) 2

'.(0.15 - 99.3)*'

1

<0.1-25

. 0.4 49.7 -

- 6 (0.04 - 0.2f 0.09 y

~

31

-(0.1 - 10.0)-

1'

(<0.2) ~

5

<0.1 30 An-241

' O.6 to 9 - 10

-O Exposure Rate.

. 12 - 13 (pR/h) 1 meter

.a.

~ source: OPAL, 1991.

Jl 4

b.

Mu ser of measurements made tooking for'the specific nuclide.

c c.

MM = not' measured.

d.

Composite saaptes.

e J lOne sample from the piping excavation contained residual plutonium activity of approximately 110 pCi/s; however, the averaged total-plutonium concentration in 5 samples at or within the.10-m grid averaged 21 pCi/g which is below the NRC guideline value.

f.. When applying the guideline;I the' sum of' ratios' of radionuclide concentretion and guideline concentration must be. tess than 1.0. z-

l g.

Memorandus from R.E.' Ctsiningham, Directorf Division of Fuel Cycle and Materlat Safety,. NMSS, NRC," to WRC Regional Administrators' and Branch Chiefs of' the c

Division of Fuet Cycle and Material Safety, NMSS, NRC, *Poticy and Guidance Directive FC 83-23

. Termination of Byprodact, Source and Special Nuclear Materiet.

> Licenses," November 4,1983.=

W 1

I s

q

't b

I e.q.

x -.t g,p 9,

c 9

s n.,

y.

~,-

s

'd 4

and alpha spectroscopy for plutonium contamination. Concrete and paint samples were-taken by chipping or scrapiny material from approximately 100 square centimeters'of. surface.

Certain portions of the building exterior ar.d

-the loading dock had elevated total alpha and beta activity.

Subsequent analyses of several samples with elevated direct measurements showed that the predominant activity was uranium indicating probable windblown uranium from.

the adjacent Uranium Plant.

The range of concentration values for external activity measurements are summarized in Table 3.5.

It is noted that the ratio of U-234 to U-238 for all of the samples except the roof sample is in the range of 3-30.

This ratio is indicative.of enriched uranium and would not have come from the Mixed Oxide Facility.

3-21

i

)

Table 3.5 Summary of exterior measurements" Remevable surface contaminatico (dpat/100 cd)

Radionuclide Concentrations (pci/g)

No.

Alpha Beta No.

Pu-239/

Location Sano. (dpm/100 cm') (dpa/100 cd)

Alpha Beta Samp.

U-234 U-235 U-238 Pu-238 240 surface 5

<28 <350 --1900

<3 - 3

<6 - 8 Drainage Outfstl Fence 10 50 - 1100*

<350 - 610

<3 - 18

<6 - 15 1 115.4

• 1.8 5.67

• 0.52 35.2 t 1.0 0.04 a 0.04 0.15 0.07 --

Concrete 17 30 - 2500*

<350 - 3500

<3 - 3

<6 - 9 Stairs /

6 40 - 1800*

<350 - 2900

<3 - 3

<6 - 8 Manways East 9

.40 - 6500*

<350 - 3700

<3 - 58

<6 - 12 1 (C)*

476 t 9 22 e 3 15 a 2 0.01 : 0.02 0.14 s 0.05' Stairway /-

1 (P)*

6062

• 89 356 z 27 540 t 90 0.15 s 0.15 0.52

• 0.17 Watt

.Y Building 7

<28 - 220

<350

<3 - 5

<6 - S N

Exterior N

Cooting 3

<28 - 80

<350 - 610

<3

<6 - 13 Tower Sanitary 5

<28 30 -

<350 - 560

<3 - 7

<6 - 78 Drain

-Loading 11

<21 - 220

.<370 - 1,100

<2

<5 1 (C)*

4.55 s 0.24 0.26 2 0.08 1.06 2 0.12 0.01 0.01 0.13 2 0.04 Dock Gravel /

3 0.45 - 0.86 0.01 - 0.12 0.38 - 0.51

<0.01 - 0.05

<0.01 - 0.01 Roof

a.. Source: ORAU, 1991. Att t values represent the 95% confidence levet for indivicbat samples, the dashed values represent the range of values.for multiple samples.

b.

C = Concrete.

c.

P = Paint.

d.

High measurements are a result of wind-blown uranium from the Uranium Facility, and remediation will occur tnder that license.

r

-1..m

-g

-m g

g

m References for Section 3 1.

Kerr-McGee Nuclear Corporation, " Request for Plutonium Plant Release,"

Docket 70-1193, August 1989.

2.

U.S. Atomic Energy Commission, License Application for _the Kerr-McGee Nuclear Corporation Cimarron Facility," Amendments l_and 2. License No.

SNM-ll74, Docket No. 70-1193, December 12, 1973, pp.-1-2 to 3-5.

3.

U.S. Nuclear Regulatory Commission, " Draft of the Final Environmental Impact Statement of the Kerr-McGee Mixed 0xide Fabricating Plant, Logan County, Oklahoma," January 16, 1975.

4.

U.S. Atomic Energy Commission, Region III, Director of Regulatory Operations,

Subject:

" Anonymous Allegations Regarding Leaks of Plutonium:

Waste Drums and Unsafe Practices at Kerr-McGee's Guthrie, Oklahoma, Fuel Fabrication Facility," R0 Investigation Report No. 070/1193/73-01, November 11, 1973.

5.

Kerr-McGee Corporation, Contamination Incident Report 8-73-7,fAugust 18, 1973.

6.

Oak Ridge Associated Universities (0RAU), " Confirmatory. Survey of the-Cimarron Corporation Mixed 0xide Fuel Fabrication Plant," Crescent, Oklahoma, January 1991.

7.

Personal communication from Dr. Jacob Shapiro, ANSI-13.12 Chairman, to Dr. R.L. Gotchy, Science Applications International Corporation, January 3, 1991.

8.

Letter from B.S. Hallet, NRC, to J.C. Stauter, Cimarron Corporation,

Subject:

Routine safety inspection conducted by G.M.-France III at the-Cimarron Corporation Facility, dated May-10, 1989.

9.

Letter from W.J. Snelley, Kerr-McGee Nuclear Corporation, to L.C. Rouse,.

NRC,

Subject:

Dockets 70-1193 and 70-925, dated August' 19, 1977.-

10. Memorandum from W.G. Browne, NRC, to NRC Distribution, " Safety Evaluation Report-License Amendment Application for Backfilling.the Retention or -

Settling. Ponds and Returning them to Normal Usage, License No.'SNM-1174,.

Docket No. 70-1193, Amendment No. 2," July 10, 1978.

11. Letter from.C.B. Spotts, EPA,-to R.W. Starostecki, NRC,

Subject:

Rev'i ew.

of data and plans concerning decommissioning of waste uranium and plutonium evaporation ponds at the Kerr-McGee Cimarron Fabrication Facility, dated June 26, 1978.

12.

Letter from S. Munson, Kerr-McGee Corporation, to S. Wical,

Subject:

Cimarron Facility Survey and Sampling Results, dated October' 16, 1990, 3-23

p..=

13.

U.S. Department of Energy, " Decontamination and Decomissioning of the-Kerr-McGee Cimarron Plutonium Fuel Plant", OE-AC06-83RL 10382, Report-No. 6..

14. Personal communication from J,0. Berger (0RAU) to R.L. Gotchy, March 22, 1991.

i 3-24

---

.__._._____u

i d

o 4.

POTENTIAL ENVIRONMENTAL IMPACTS The proposed action is to release the Mixed 0xide Facility and surrounding grounds for unrestricted use. Based on the data shown in Section 3, Cimarron Corporation has decontaminated and decommissioned the Mixed Oxide Facility and associated grounds to below guidelines required for unrestricted use by the NRC.

It is NRC's judgment that the applied guidelines adequately protect the i

public health and safety, and the environment.

Therefore, the NRC finds that termination of the Mixed Oxide Facility license (L'icense No. SNM-Il74) and conversion of the related facility to unrestricted use will pose no significant impact to the snvironment or the health and safety of the public.-

t Because the entirety of the Mixed Oxide facility and associated grounds lies within the area held by the Uranium Facility license (License No. SNM-928),

further surveys of these released areas will be necessary to ascertain that no cross-contamination occurs during decommissioning activities related to the termination of the Uranium Facility license.

This type of survey is common i

practice for unlicensed lands nearby or potentially contaminated by a licensed site before termination of a license is granted.

Remediation of any detected cross-contamination will be required before termination of the Uranium--

Facility license is granted.

Alternatives to the present termination of the Mixed Oxide facility license include:

(1) no further actions (i.e., license the facility indefinitely without further enanges to the site); (2) requiring'further cleanup of the Mixed 0xide facility and related grounds before final termination; or (3) delaying termination of the Mixed 0xide facility license until the Uranium facility license (License No. SNH-928) is.also ready for termination.

The first alternative of no further actions related to the Mixed Oxide facility causes a loss of resources and is an unnecessary burden on both the licensed company and the government.

Requiring licensing of a site which meets NRC cleanup guidelines.in perpetuity means that the land and associated constructs would sit without further use instead of allowing the land to be used for alternative business (e.g., warehouse) or other use, At the same-4-1 i

--,r,..

m m.

-m,

-.m

_._e

time, costs for licensing continue for both the company holding the license (through license fees, security, and site monitoring) and the government (overseeing the license and inspections).

Since the land and associated constructs have met NRC unrestricted use guidelines, this alternative would not improve public health and safety.

The second alternative to the proposed action calls for further cleanup of the Mixed Oxide f acility before final termination.

Since the cite has already been decommissioned to NRC guidelines, and in many places, background radiation levels, unless new data is presented which shows a significant safety increase with lower criteria, this alternative would put an unnecessary burden on the licensed company, and at the same time, could also unnecessarily set a precedence for more restrictive release criteria for all NRC licensees.

Without new supporting data, this alternative would only cost the licensed company additional money without adding significant benefit to the health and safety of the public and is therefore not necessary.

The third alternative would be to keep the Mixed Oxide facility under license until the Uranium facility license is ready for ttrmination, and then terminate both licenses simultaneously.

This alternative does have some merit because the Mixed 0xide Facility and associated grounds are completely within the perimeter of the Oranium facility licensed grounds therefore leading to a potential for cross-contamination.

However, as mentioned above, remediation of any cross-contamination would be required under the Uranium Facility license prior to its termination, if the proposed action is accepted. This last alternative places an unnecessary regulatory burden on the licensee to continue holding a license on a facility and grounds for which any future contamination would be a result of cross-contamination from a second licensed facility. As such, remeaiation of the cross-contamination would be the responsibility of the second license, leaving little reason to require the licensee hold a license on an otherwise clean facility.

Therefore, delayed termination of the Mixed Oxide Facility license would render no benefit to the health and safety of the public.

4-2

Because none of the discussed alternatives loads to a significant increase in the protection of the health and safety of the public versus the proposed action, and the proposed action makes no significant impact on the environment, the NRC finds that the Mixed 0xide facility license (License No. SNM-Il14) should be terminated.

4-3

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