ML20134G315

Requests Retention of Contaminated Soil Onsite,In Accordance w/10CFR20.302 Provisions.Underground Line Water Leakage Contaminated Approx 5,300 Cubic Ft of Soil Below Grade.Total Activity Undetectable within 7 Yrs.Fee Paid

ML20134G315
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	08/16/1985
From:	Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8508230219
Download: ML20134G315 (65)

Text

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Consumers Power o.m v-*wa company

"ll"L, General offices. 1945 West Parnall Road. Jackson. MI 49201 (517) 788-1636 August 16, 1985

Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

REQUEST TO RETAIN CONTAMINATED SOIL ON-SITE IN ACCORDANCE WITH 10CFR20.302 The Code of Federal Regulations, Title 10, section 20.302 allows for' approval of proposed procedures to. dispose of licensed material in a manner not otherwise authorized in the regulations. As a result of water leakage from an underground line, approximately 5300 cubic feet of soil was contaminated below grade. The occurrence of this event was reported to the NRC in informational LER 84-03 dated October 19, 1984. Consumers Power Company requests NRC approval to retain the contaminated soil in place in accordance with 10CFR20.302. Justification for this. request is in the attachment to this letter. Retaining the contaminated soil on-site would result in no discernable impact on either the environment or on occupational or public health. The total activity is expected to be undetectable within seven years.

Pursuant to 10CFR170.12(c) a check in the amount of $150 is' attached.

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David J ndeWalle Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point Attachment hC 8508230219 850816

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f ATTACHMENT Consamers Power Company Big Rock Point Plant Docket 50-155

" JUSTIFICATION FOR RETAINING CONTAMINATED SOIL ON-SITE" 4

August 16, 1985 64 Pages 4

0C0885-00018-NLO2

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1 EVALUATION OF 15000NITORED LIQUID RELEASE TO SOIL A volume of contaminated earth located adjacent to the below grade wall of the radweste pump room and extending under the turbine generator building floor has been evaluated for possible retention at its present location. The source of this contamination has been addressed in previous reports to the NRC. The evaluation consists of the following studies:

1) Core samples were taken in the vicinity of the affected area to determine the extent of the leak.

2) The hydrology of the area as described in our Final Hazard Summary Report (FHSR) and the report by James H Zumberge (attached) was reviewed. Core samples indicate the hydrology has not changed since the above reports were written.

3) Alternatives to retaining the earth on-site were evaluated.

Based on the results of this evaluation and the commitments made herein, Consumers Power Company hereby requests authority under 10 CFR 20.302 to retain this earth at its present location.

It is felt there will be no discernible impact on either the environment or on occupational and public health.

DISCUSSION Big Rock Point was shut down on May 30, 1984 after samples taken of water leakage through the below grade wall of the radwaste pump room indicated the presence of tritium and iodine-131. The tritium concentration of these samples closely matched that of the main condensate. Evaluation and testing of underground lines indicated a leak in a two-inch diameter aluminum pipe.

This pipe carries water from the demineralized water supply and condensate process monitor line to the condensate storage tank (see Figure 1 of Attachment II). The pipe was removed, the line was capped and a temporary line was installed.

From an increase in makeup water usage, it was estimated that 20,000 gallons of water had leaked into the soil. Analysis was conducted on samples taken from the primary system, condensate storage tank and water puddled at the base of the' leaking pipe.

The isotopic distribution of the puddled water is very similar to that of the main' condensate. The puddled water sample was chosen as the source term because of the greater concentrations present. This will yield the most conservative estimate of probable dose consequences.

Only the four longer lived isotopes were used in the dose calculations.

I-131 was not included since by the time the sample was taken (July 11), the concentration was already two orders of magnitude less than the concentration calculated to have been released (May 30). The Cs-134 concentration of the source term was increased to 70% of the Cs-137 concentration on the basis of MIO785-0231A-NLO2

2 results of 7 out of 11 soil samples. The resulting source term used in the calculations is as follows:

Table I: Source Term Nuclide Activity Level (pCi)*

Co-60 238.46 Ma-54 132.48 Cs-137 1,741.10 Cs-134 1,218.77

• Total activity in 20,000 gallons On July 11, 1984, soil samples were taken near the area of the line failure.

Samples were taken at three depths, just below the turbine building concrete, at one foot below the concrete and at four feet below the concrete. Five samples were taken at each depth. These samples were analyzed for radionuclide concentration. The location and total activity of each soil sample are indicated on Figure 2 of Attachment II. A listing of the results of the samples is presented in Table 3 of Attachment II.

Additional soil samples were taken to determine the spread of contamination resulting from the condensate makeup line leak. Nine sampling locations were chosen (Figures 3 and 4 of Attachment II). Samples were taken at approximately one-foot intervals to a depth of about ten feet as measured from the track alley floor (including the two locations outside the building). The activity of individual isotopes in each sample and the location of maximum activity of each isotope are listed in Tables 4 and 5 of Attachment II. The total concentration in each sample is recorded in Table II below:

Table II: Total Concentration * (pci/ gram) of Samples Depth Samplina Location (Ft) 1 2

3 4

5 6

7 8

9 0- 1 3.4E-07 1-2 1.3E-07 8.8E-07 1.4E-07 3.2E-07 5.6E-07 2.3E-07

<MDA (MDA 2-3 6.7E-07 3.4E-06

<NDA 8.4E-07 2.0E-06 1.2E-06 (NDA

<NDA 3-4 9.2E-08 6.6E-06 7.3E-07 2.4E-06 2.6E-06 1.1E-06 9.5E-07 7.8E-08 4-5 1.1E-06 3.2E-06 (NDA

<MDA 1.2E-06 9.6E-07 1.9E-06

<MDA 5-6

<MDA 1.4E-07 4.4E-08 1.8E-07 4.4E-07

<NDA

<NDA 2.2E-07 3.2E-07 6-7 7.7E-08

<NDA 7-8 8-9 1.6E-07 9-10 10-11 1.1E-07 O Background concentrations not corrected for.

MIO785-0231A-NLO2

e 3

i The Cs-137 concentrations are important when looking at the transport through l

j the soil since Co-137, having the greatest solubility in water, has the l

highest likelihood of reaching the lake. Also, Cs-137 is expected to be the most concentrated isotope after transport through the soil. Cs-137 has tt.e longest half-life and presents the greatest radiological hazard of the four l

isotopes. The Cs-137 distribution as determined by the sampling described above is presented in Figure 5 of Attachment II.

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Eight 55-gallon drums of contaminated soil were removed by excavation from the area (shown in Figure 5 of Attachment II). This soil will be shipped as low level waste to a licensed burial ground. This application applies to the remaining contaminated soil. The total amount of activity which remained in the soil is estimated to have been 37 pCi. This was determined using data l

from soil samples, #3 through #9 (Figures 3 and 4 of Attachment II). A copy.

of this estimation is enclosed (Attachment III). The average isotopic concentrations are given below:

l Average Nuclide Concentration

• Inci/sm]

Mn-54 1.512E-05 Co-60 2.884E-05 l

Cs-137 3.807E-05 i

l Cs-134 5.776E-05 l

Total 1.398E-04

• The average was calculated only using samples showing >MDA, therefore, it is very conservative.

t Based on a total of 62 soil samples collected throughout the area (and analyzed using samma isotopic techniques), the total estimated activity present was 37 pCi. The total volume of earth contaminated is approximately 8

l 5300 cubic feet. Based on a soil density of 4.99E+04 sm/ft, the average j

concentration of contaminated soil estimated to be in the soil at the time of excavation was 1.4E-04 nCi/gm (and at present is 1.1E-04 nCi/sm). Cs-134 is the most predominant isotope present comprising approximately 37.32% of the total activity; while Cs-137, Mn-54 and Co-60 comprise approximately 33.69%,

I 6.09% and 22.90% (respectively) of the remaining activity.

MIGRATION ANALYSIS AND ENVIRONMENTAL IMPACT An analysis of the migration of isotopes through the soil towards Lake Michigan was performed using methods described in ANSI /ANS-2.17-1980:

i

" Evaluation Of Radionuclide Transport In Groundwater For Nuclear Power Sites" and using groundwater data obtained from the Big Rock Point FHSR. The ANSI model employs geohydraulic and geometrical parameters as a function of 1

MIO785-0231A-NLO2

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radioactive decay to account for retardation of radionuclides by sorption onto/into the soil. The results reveal the leak will reach the lake in seven years. The isotopic concentrations at that time are expected to be:

Nuclide Concentration * [pCi/ml]

Mn-54 2.50E-10 Co-60 5.64E-09 Cs-137 9.00E-08 Cs-134 1.92E-08 j

• These values were calculated assuming all the contaminants were left in the soil (ie, as if no excavation took place).-

l Based on the characterisation discussed above, the potential for migration of the contaminants presents a negligible impact to the environment for the following reasons:

1) The contaminated layer is above the water table (soil layer is about 4 feet thick). The ground in the site area is composed of sand, gravel and weathered limestone, which is well drained. The contaminated water from the leak seeps into the water table then towards Lake Michigan.

J Upward migration of contaminants through the soil is highly improbable.

2) The minimum distance between the contaminated soil and the lake is 89 m.'

Using the rate of flow of 0.035 m/ day, the contaminants will not reach the 1ake for seven years. Some of the contaminants may find their way to the lake sooner due to flowing along underground piping. Taking dilution, dispersion and sorption factors into account, it is conservatively estimated that the activity when the contaminants reach Lake Michigan will be much less than II of the source activity.

3) All the contaminated soil is contained within the radiologically controlled area. Of 62 soil samples outside the excavated area, all reveal concentrations within the limits of 10 CFR 20.106 (Radioactive i

Effluents To Unrestricted Areas) and within the limits of 10 CFR 30.14 (Exempt Concentrations). These concentrations will continue to decrease l

l with time due to radioactive decay, dispersion, dilution, ion exchange and sorption.

4) The general area radiation levels, both at the surface of the contaminated area (above the turbine building floor) and one meter above the surface, are background, as determined in Attachment III. The dose rate to a j

person digging in the area is estimated to be 2.0E-04 mr/hr.

5) The radionuclide concentrations at the time of sampling and the total j

activity released are given above. The concentrations and activity remaining in the contaminated soil at present and in seven years are expected to be as given in Table III. After seven years, all the i

contaminants will have migrated to Lake Michigan, thereafter it is M10785-0231A-NLO2

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assumed that the concentrations and activities of these isotopes remaining in the soil will be reduced to their natural levels.

OCCUPATIONAL AND PUBLIC HEALTH IMPACT OF RETAINING CONTAMINATED SOIL ON-SITE The potential doses to workers and to the general public due to leaving the contaminated soil in place were determined assuming no excavation of th: coil took place. The exposure pathways considered were direct exposure to the contaminated soil, exposure from inhalation of particles suspended in air during removal of concrete from the turbine building floor and exposure to radionuclides transported to Lake Michigan through ground water flow. The activity in the remaining contaminated soil at the present is determined to be 0.88% of the total activity released. The doses to workers and the general public due to leaving the remaining contaminated soil in place can be taken as 0.88% of the doses calculated when assuming no soil was excavated. The calculated doses for each exposure pathway are sumusarized in Table IV.

EXCAVATING, PACKAGING AND SHIPPING TO A FEDERALLY APPROVEL DISPOSAL SITE The estimated cost for excavation and disposal of the remaining contaminated soil is well over $100,000. The estimated volume of soil to be removed is approximately 5300 cubic feet. This would require

• 720 55-gallon drums. The average total activity per drum, based on a concentration of 1.4E-04 nCi/gm 8

and a soil density of 4.99E+04 am/ft would be about 5.13E-02 pCi. The average concentration of radioactive material in these containers is less than 1% of the concentration that would require regulations for transport under Department of Transportation (DOT) criteria set forth in 49 CFR 173.389 as it defines " Radioactive Material".

Based on the present conditions of radioactive material disposal sites, shipping barrels with such low concentrations would result in inefficient use of the current limited available burial space.

SUMMARY

The estimated total cost of excavation, packaging and transporting the contaminated soil to an approved disposal facility is estimated to be much greater than $100,000. The packages would contain radioactive concentrations much less than that necessary to be considered " radioactive material" as defined in Department of Transportation Regulations and would result in inefficient use of limited available burial space.

Retaining the contaminated soil on-site with approximately 8 inches of concrete covering (the turbine building floor), would result in no discernable impact on either the environment or on occupational and public health. The total activity is expected to be undetectable within seven years.

Any migration of the contaminants would be in the direction of Lake Michigan and would not reach the lake for at least seven years. This leakage would contribute minimally to the concentration of naturally occurring radioactivity and permissible plant releases already present.

MIO785-023IA-NLO2

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6 Table III: Radioactivity [pCi] And Isotope Concentrations [nci/gm] Remaining In Soil vs Time Icstope galfLife Total Activity After Excavation Present. (1 year) 7 Years After Leak In Days Released Activity Concentration Activity Concentration Activity Concentration C:-60 1920 238.46 7.63 2.884E-05 6.69 2.529E-05 3.03 1.145E-05 Mn-54 312 132.48 4.00 1.512E-05 1.78 6.729E-06 0.01 3.780E-08 Cs-137 10950 1741.10 10.07 3.807E-05 9.84 3.720E-05 8.57 3.238E-05 Cc-134 748 1218.77 15.28 5.776E-05 10.90 4.120E-05 1.43 5.406E-06 Tetals 3330.81 36.98 1.398E-04 29.21 1.104E-04 13.04 5.232E-05 NOTES: Total activity released is based on total gallons estimated to have leaked and isotopic concentrations found in a puddled water sample.

Activities and concentrations after excavation were determined using soil samples taken outside the excavated area.

Precent and seven year activities and concentrations are estimated by taking radioactive decay into account for one and czven years (respectively) since the excavation using the following equations:

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Activity At Time, t = (Activity After Excavation) exp t

4 C I'I Y Concentration

=

gm 5301.44

,ft 4.99E+04 gm 1 pCi 3

3 3 is estimated volume of contaminated soil and 4.99E+04 gn/ft is used as soil density.

Where 5301.44 ft MIO785-0231A-NLO2

7 Table IV: Summary of Occupational and General Population Doses General Occupational Population Exposure Pathways Doses Doses arem arem Direct exposure and shine 1.9E-06 9'"~

hr br Direct exposure to person digging at site 2.0E-04 ""*"

Nuclides transported to Lake Michigan through groundwater arem 7.65E-05 l

Single batch release Adult Total Body year intake l.

arem i

1.11E-04 Teen Liver year intake arem 1.10E-05 Released over 7 years Adult Total Body year intake l-arem 1.57E-05 Teen Liver year intake Single release after 7 years (retardation and sorption by soil arem 9.70E-08 accounted for) y,,,g,g,g, arem arem Inhalation of resuspended particles

.03 4*

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> year intake i

f

• The activity of the suspended source term does not exceed the amount necessary to f

deliver a 40 MPC-hour burden.

MIO785-0231A-NLO2

8 CONCLUSION We request to retain the contaminated soil on-site for the above mentioned reasons. TheThe imp:ct on both the environment and occupational and public health would be negligible.

pot:ntial of recontaminating this region is negligible based on the inspection of other piping in the area for proper corrosion protection (See Licensee Event Report 84-03, revision 2, dated October 19, 1984).

O MIO785-0231A-NLO2

I LIST OF ATTACHMENTS Attachment I

Geolon and Hydrolon of the Proposed Reactor Site at Big Rock Point. Near Charlevoix. Michigan by James H. Zumberge Attachment II

Resolution of AIR:BRP-8h-20 " Disposition of Contaminated Soil" Attachment III : Radioactivity Remaining in Soil from Condensate Tank Leak f

o ATTACHMENT I i

OEDID0Y AND NYDROIDGY OF THE FROPOSED REACTOR SITE I

AT BIO ROCK 70!NT, NEAR CHAR 12 VOIX, MICN1GAN James M. Eumberge Geologist Ann Arbor, Michigan 10P00RAPHIC SETTING j

I l

Terrain j

I The proposed site lies in the NE quarter of Section 7, f'

in 5tnraship 34 N, Range 7 W, Charlevoix County, Michigan, near the shore of Lake Michigan. The lake shore consists of scattered limestone outcrops alternating with short stretches of beach containing granular 1

materials ranging in size from sand to coarse boulders and limestone rubble. The land rises fate a mean lake elevation to $80 feet A.T. to l

mbout 700 A.T. a mile or so inland.

tbpographically, the region within a five-mile radius 1

of the site location can be divided into two categories. The first is i

l som or less perallel to the lake shore and is a some of low n11ef which was once submerged beneath the waters of ancestral Lake Michigan.

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Incally, swampy conditions prevail between low ridges of stabilised I

beach deposits.

l The second sone is the upland surface which rises from i

an elevation of about 700 A.T. to over 900 feet A.T. five miles south-f I

east of the site. The upland surface is a constructional terrain con-l l

sisting of till plain containing IN-SE oriented drumlins which rise 40 j

l to 60 feet above the general till plain surface.

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y Drainage Surface drainage flows either northward directly into Iake Michigan or southward into take Charlevoix and thence into Iake Itichigan via mound Iake, and Pine River at the town of Charlevoix. The divide between these two watersheds extends in a northwesterly direc-tion fms a point just south of Susan take in Section 29, thence north-vard into Section 20, northwesterly into the SE corner of Section 18, and finally northward into Iake Michigan.

The surface drainage area in which the proposed site is located is bounded on the south and vest by the divide just described, on the north by take Michigan, and on the east by Susan Creek which originates in Susan Iake and flows northward into take Michigan which it enters at a point about one mile east of Big Rock Point. The total area of this watershed is between 3 and 4 squam alles.

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4 os0tocIC surfIlm Bedrock Geology Bedrock Topography. S e site lies in a belt of lime-stone'of lower Paleozoic age. Se rocks exposed along the lake shore an part of the, Traverse Group of Devonian age. Near the ahom the bedrock surface is either at the smund or covered by thin unconsolidated glacial and lacustrine deposits. Farther inland, the beamck surface is buried beneath the till plain. At the city of Charlevoix, the log of the city well reveals 230 feet of Pleistocene sand and gravel over the Traverse limestone. 21s situation is connon place along the entire eastern shore of Iake Michigan and indicates that the streams entering the lake were deeply entrenched into bedrock during a time when the lake level was several hundred feet lover, about 5,000 years ago. nus, the==i== relief of the bedrock topography is much greater than one would expect from an examination of outcrops along the sh' ore of take Miehi=n. Bedrock Lithology. Borings at the site were made by t.no Raymond Concrete File Cogany to a depth of H) feet. Two borings 400 I feet apart and 500 feet from shore penetrated a grey to black fossiliferous limestone with thin shale partings. Core recovery ranged from a low of 24% in the 8 to 9 foot levels of Boring No. 2 to a high of 100%. Generally,thecorerecoverywasgreaterthan60%andmanysections of two-foot lengths showed 1007. recovery. Poor core recovery seems to be related to venthered sections of the limestone cections with closely

5 spaced shale partings, or a highly,)ointed rock, rather than tavernous conditions. Some of the cores are reported as having low porosity. 8 Se limestone beddinC planes are nearly horisontal and the regional dip is to the southeast toward the center of the MAchigan Basin. The log of the Charlevoix water well shows no salt or anhydrite beds down to a depth of kS2 feet. los of City Well, Charlevoix, Miehisan Incation: Section 26, T 36 N, R 8 W. 1 Elevation: 600 feet above sea level. ~ mickness Drilled before 1901 (feet) eet) Pleistocene: 6 6 sand 9 15 Gravel 155 170-Fine sand 6 176 Gravel Sand, quicksand at 214 feet 54 230 Devonian: Traverso: 10 240 Limestone, fine grained earthy 10 250 Limestone, gray Limestone, earthy or chalky, brownish, poroun, snach oxidized shaly, with a strong shals odor, being in fact in 10 260 large part shale Limestone, dark gray arcillaceous and 10 270 somewbat shaly Shale, finely stratified. Compact in 10 280 texture Limactono, focsiliforous whitish, con-taining Atrypa reticulario and other 10 290 focoils f Limactono, white crystalline, containing conoidorable cryotalline calcito. It carried fracnonto of Acervularin davidsoni. Cona portions of the samples 10 300 nro cocrpact and arcillat.cous } l lL-

6 Thickness th Limestone, white chalky, non-are mm ous, fossiliferous. 15 315 Limestone, brovalph, earthy and argillaceous with a st,rong shale odor, Bryosa and other fossils have been observed 7 322 Shale, gray calcareous, of very uniform texture, partially oxidized 8 330 Shale, gray compact calcareous rock, but of massive chatsctor 5 335 Fragmento of Acorvularia davidson1 with the calices free from matrix, and evidently embedded in shale. No shale, however, is retained. 10 345 Shale, gasy calcarcous, mixed with pum white limestone, the latter containing Favosites and Acervularia 5 350 Limestone, gray arcillaceous, and some white limestone, with fragments of Spirifer and I A'cervularia 5 355 Limestone, cray, Acervularia davidsoni is abundant. Favosites and Atrypa reticularis also occur 5 360 Limestone, cray, compact, and semi-argillaceous crinoid stems; much shale is mixed with the limestone 7 367 Fragments of Acervularia davidsoni and Favosites 3 30 Limestone, compact, gray, argillaceous 5 N5 Rock, fine grained, compact, argillaceous 12 $7 Limestone and black shale 3 390 Limestone, gray argillaceous with whiter t I limestone containing Acervularia 10 400 Shale, chalhy; crumbles and soils fingers, cream colored 2 402 Shale, bluish gray, sliGhtly calcareous 8 410 Limestone, compact, brown to croy, weathering earthy 5 415 Shale, cream colored calcareous, identical with rock at 400 feet 5 420 Limestone, compact, brown 10 k30 Shale, cream colored earthy, calcareoun 13 443 Limentone, brown banded, mincles with black and cray shale containing Atrypa 4 447 I reticularis, etc. l Bell formationt Shalc, bluish 35 22

7 Surficial Deposits Glacial Drift. We site area lies within the boundaries of.the Inte Wisconsin drift deposite of Pleistocene age. A narrow belt parallel to the shom of Inhe Michigan contains thin lacustrine deposits and beach sando and gravels associated with former higher stages of Iake Michigan which prevailed at various times since the last retreat of the Inke Michigan clacial lobe. These deposits range from fine cands to coarse gravel and weathered limestone bedrock. The upper surface ic the product of the last ice advance which deposited a stony till of variable thickness over the entire area. In the site area the till is very thin or wholly lacking due to the many episodes of lake history. The ancestral lakes renoved much of the till by wave erncion, and in' places, replaced it with beach deposits or lacustrine sediments. Soils. Generally, the soils in the immediate site area have weakly developed Podzol profiles, are very well drained, and extremely poor from the agricultural point of view. S e major soil in the area is the Eastport Series which is cotsonly developed on low sand rid 6es and dry sand benches, but can also occur on bedmek flats, stony wet clays, and shingle and cobbly beaches. The upland soils, developed on the drumlin-till surface, belong to the Dr. met-Roselayn Association. The soil textures are l mostly sandy loams of medium fertility. Their well drained character i reflects the generally high permoability of the rcrainic materials on which they are developed.

l 7 f GROUFO UATER The General. geologic setting, topo p.g.y, and clientic s conditions of the region provide a basis for a general evaluation of the ground water conditions. The water table at the site area was at 579 feet in my,1959, as sh'ovn by the notes accompanying ' Boring No.1 of the paymond Concrete Pile Company report dated m y 8, 1959. This shows that water table rather than artesian conditions prevail. It can be assumed that the water table rises gradually from Iake Michi6an back to the drainage divide described under surface drainage in this report. It cannot be stated definitely that this surface drainage divide is coincident with the ground water divide because even though the surface drainage on either side is graded to either Iake Michigan or Iake Charlevoix, both of which have the same mean surface elevation,' the slope of the land on the Iake Charlevoix side of the divide is much steeper than on the Iake Michigan side. I Steeper water table gradients, therefore, may result in a water table divide that is closer to the Iake Michigan base level than the surface f drainage divide would indicate. Nevertheless, the water table divide is,most likely not much different than the surface drainage divide between the two lakes. The castern marcin of the watershed is Susan Creek which forms a very definite beundary insofar as both surface and subsurface i vater movement :Ir concerned. The prolininary copy of the U.S.G.S. topographic rap directly onst of the Charlevoi:: Quadrangle shows Susan l

9 i Creek to be a perannent stream. Even though a good portion of the base flow' undoubtedly comes from Susan Iake, Susan Creek itself is undoubtedly effluent in character and draws on Ground water storage to-eustain its base flow, however smil, during periods of drou6ht. Ground Uater Hovement. Ground vnter that originates as infiltration from rainfall which falls on land west of Susan Creek, south of Iake Michigan, and north or east of the divide between Iakes Michigan and Charlevoix, vill eventually reach Iake Mich1==n, either directly by normal ground water movement toward the lake or by ground water flow into Susan Creek and thence to Iake Michigan as 4 surface run-off. In terms of vagrant ground water released at the proposed [ site itself, such water would flow to the lake very quickly except in times of a rapid rise in lake level during a seiche, in which lI case some delay would result beenune of a reduced hydraulie gradient 4. between the site and the lake. Incally, where the water table causes swampy conditions becauce of its proximity to the surface svales between old beach ridges, the movement toward the lake would J be retarded.

10 PLMP TEST ANALYSIS There is little doubt that any ground water that originates as infiltration from rainfall which falls on land west of Susan Creek, south of Lak'e MichiCan, and north or east of the divide between Lakes Michigan and Charlevoix, will eventually reach Iake Michigan, either directly by normal ground water movement toward the lake or by ground water flow into Susan Creek and thence to Lake Michi an C as surface runoff. In terins of vagrant ground water released at the pro-posed site itself, such water would flow to the lake very quickly ex-cept in times of a rapid rise in lake level during a seiche, in which case some delay would result because of a reduced hydraulic gradient l between tpe site and the lake. Locally, where the water table causes svampy conditions because of its proximity to the surface svales f between old beach ridges, the movement toward the lake would be retarded. On December 9, 10, 1959, pump tests were run to deter-mine the coefficients of Transmissibility (T) and Storage (S). The j tests were run on Borings f5, 6, and 7 On December 19, 1959, a slug test was run on Borins #3 This test was designed to measure the infiltration capacity of the clay on the site area. Aquifer Selection. The initial evaluation of the sub-surface geology indicated that a thick sequence of Traverse limestone is overlain by about 50 feet of compact clay till. The upper 10 feet of limestone is badly fractured, indicating higher velocities of

11 ground water compared to the surrounding geologic materials. It was, therefore,' decided to dri13. three borings (see sketch map of boring locations) using f5 as the punip ven and f6 and M as observation vellaf These borings were ccanpleted to depths of 59' 11", 64' 3", and 59' 9", respectively, and penetrated up to 13' of fractured lime-stone. These borinCs essentially penetrate the fractured zone which averaSes about 10 feet in thickness. Water levels in the vens in-dicated artesian conditions as vould be expected. i Boring f5 showed a sand zone from 23' 5" to 29' 5" which produced a flow of 0 33 gallon / minute. Tbe static level of the sand was 133 feet above the ground surface or at an elevation of 591 98. This zone vin be discussed on Page 14. A slug test was run on Boring #3 at a depth of 8 5 - 20 feet. The ven was entirely in clay, and the test shows the capac-ity of the capping clay to transmit water. Ptssp Test. Upon completion of the vens, static water levels were taken, and a short test run to determine the approximate ~ well capacity for an eight-hour pump test which would utilize the i maximum amount of drawdown allowable. On December 9, test' #1 was commenced, pumping at a rate of 5 2 gpm. A ste.ndard 5/8 inch Badger water meter was used with 1 a stop watch to regulate the dischar6e. An electrical contact water level recorder was used on Boring f5 and tape readings were taken on Borings f6 and 7 Readings were taken according to a prearranged sched- ^ ule with each observer using a synchronized watch. Between 60 and 90 l i

12 \\ N LAKE MICHIGAN ( IAW WATER LINE, E 2V. 578 5 AUG. 12, 1939 4 e. BANX SEEPAGE, APPROX. ELEV. 581 DEc. 19, 1959 2 . ' ~ ~.,, ' 0g;:::C 5' O %s ' @' 4 u ',j ' I y 3

• s; 5 o

81 ~ 1i o 's ' Ii %4D ,, g,'-

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__._ =: n l BORING f 3 g // e BORING f 7 ELEY. 590.8 si E 2Y. 590.4 It \\kh \\\\ 11 134 /'> k BORING # $ is ' ' ~ ' Z.~.,j , BORING f 6 L f ELEY. $90 7 e ELEY. $89.9 LOCATION MAP OF WELLS USED IURING FUMP TESTS on DECD4BER 9,10,1959 Scale in Feet 1bo 7.5 50 25 0 5.0 100 . -. -.. ~. -...

O } 13 i i. - minutes, the water level in Borinc i5 dropped 10 feet indicating a j rapid change in transmissibility. The suction head produced was too i large for the pump and, therefore, test fl was suspended. On December 10, after allowing the static level to recover, test (2 was begun with a discharge of 4.0 cpm. The pressure cone was not reduced sufficiently during this test to allow devatering the first test. After of the aquifer which essentially occurred durin6 8 hours of dravdown, 5-1/2 hours of recovery were measured. Results. The dravdown vs time and recovery vs time relationships allow the determination of the coefficient of transmis-sibility, T, defined as the flow of water in gallons / day (under a hydraulic gradient of one) through a rock cross section with a width of one foot.and a depth equal to the thickness of the water bearing formatiod. Also, it permits the determination of, S, the coefficient of storage which is defined as the volume of water released from storage Per unit surface area of aquifer per unit change in the component of head normal to that purface. Under artesian conditions in a vertical column one foot by one foot, the stora6e coefficient equals the volume of water in cubic feet released from an aquifer when the piezometric surface declines one foot. Calculation for the Bic Rock Point Plant was made by These r.cthods are well use of the Theis, Jacob and Theim methods #. For the slug test, a standard known and standard in vell hydraulics. slug formula of T = 114.6 V (1/tm) vac used where: equale volume of the slug in gallons, tm equals time cinec sluc injection in minutes, - and s e quals the re s idual hend abo c. th. ctat i c.

• See Appendix E for cruudown and recovery dctc from all wells.

14 1 The ptump test formulae are based on the assuptions that (~1) the aquifer is uniform in thickness, (2) that the aquifer is both 4 homogeneous and isotropic, and (3) of infinite areal extent. These ^ 1 conditions are never realized in nature and especially so in bedrock aquifers. However, the test formulae represent the best approach that is economically feasible. Therefore, departures of the results can j be attributed directly to departures of the rock. Table 1 shows the values o'f T and S for both tests, and the three different methods. Even with so many departures from the ideal conditions, there is good conformity between the average values of the three methods. l JACOB THEIS THEIM Well No. T S T S T TEST #1 1.8xio-j 6 dd 337 7 da 818 7 8x10-TEST #2 528 834 1 f 5 rec' I 637 6 da 464 109-4.2x10-6 491 3 86x10-5 rec 352 7 di ' 754 -5 880 1 75x10-5 668 2.11x10 rec AVERAGE 590 1.19x10-5 590 2 99xio-5 527 TABLE //1 Transmissibility.(T) and Storage (S)

15 As transmissibility (T) is in gpd/ft of aquifer. and 'permeabili'tyisingpd/ft the average value of T is divided by the He thickness of the fractured zone to arrive at the perunability. average permeability is then seen to be somewhere bet,ve.en 52 7 gal./ day /ft and59 gal./ day /ft. 'he slug test yielded a transmissibility of 4.0 l gal./ day /ft. Since the smount of open hole was 11 5 feet, the per-2 meabilityoftheclayis035 cal./ day /ft. Conclusions on ground' vater flow under existing conditions: (1) The static water levels in the three wells in the test area show that the fractured rock zone is under artesian condi-tions. The elevation of the static levels indicates that there is a The elevations also indicate pressure drop towards Lake Michigan. that there is leakage from the clay into the fractured limestone. Taking the average value of (T) equal to 590 gal./ day /ft, and the approximate thickness of the fractured zone as 10 feet, the flow veloc,ity under existing hydraulic gradients equals 0.05 ft/ day. mis i value is very low compared to most sand and gravel aquifers. (2) The dravdown and recovery vs time relationships indicate a direct connection between the fractured bedrock and Lake Using the recovery data from Boring 87, and the dravdown Michigan. data from #6, positive boundary conditions, i.e., recharge to the aquifer system, were established as being approximately 820 and 850 feet from the pumping well. Lake Michigan is 500 feet away at its Ilecharge vculd not be expe::ted to chov appreciably closest point. ~

) j*. 16 q= until the pressure cone had intersected a sizeable section of the lake. ( (3) The overlying clay till has an exceptionan y low transmissibility, and gives flow velocities of about 0.002 ft/ day. yk l This rate is largely dependent.on the hydraulic gradient which fluc-tuates. However, even if the velocity were doubled it would still / ./ be low. (4) The artesian sand in Boring f5 is believed to represent a beach sand, deposited during the interval elapsed during The overlying the deposition of the underlying and overlying till t till shcus an average penetration of about 5'T blows /12 inches while the underlying till has an average penetration of 109 blows /12 inches. Well drillers in the area report that artesian sand pockets are hit within 50 feet of the Present lake level. The static of the sand i indicates that the source area is probably 1000 feet south of the test area. Examination by the writer of the area inneediately south showed surface expressions of old beaches with back shore swamps. 4' One.of these back shore sussp areas is pictured by the writer as d being connected to the subsurface sand by a sand smear similar to those now present on the surface. Buried beach deposits may be ex-pected in the area, where they will be of limited areal extent, with small yields such that they could only be suitable for small scale domestic purposes. The high static indicates that these sand bodies are under high pressure and vill not permit water to enter them, but to the contrary leak water to the surrounding area. In this respect, the sand acts as a boundary to the pascace of veter.

17 (5) Existing vens in the area are of two types. The shallow wells which are l'ess than 70 feet deep and the deep wells of Just north of generally over 150 feet arsi up to 350 feet in depth. . Char,levoix Lake and in a band approximately one-half mile vide, stretching NW-SE parallel to the lake, are found many shallow type t These wens are located in permeable sands or gravels lying wells. above a tight clay till whose upper surface is thought to be depressed in the insnediate area of Lake Charlevoix. Wells of Type #2 are generally found elsewhere in the They are in the Traverse limestone, at considerable depth, and area. These wells yield up to under artesian conditions for the most part. No heavy producing 50 gpm, but are mostly in the 15-20 gpm range. wells are known of within 2 miles of the site area. Lake Levels The Lake Survey Division of the U.S. Corps of Engineers issues monthly bulletins of levels of the Great Lakes. The period of record for Lakes Michigan and Huron is frca 16(,0 to the present. Lake level fluctuations are of two types, long. range The long-range variations are those related to and short-range. variations in precipitation over the years, whereas the short-range fluctuations are caused by seasonal variances in regional precipita-tion, or very short changes in lake levels due to seiches. Long-Tern Fluctuations. The level of Lake Michi an 6 has varied from a lov of 577 35 feet A.T. which occurred in February, This amounts to 1926, ~ to a hish of 583 68 feet A.T. in June of 1886. a maximum difference in level cf 6.33 roc: durins :ne period of record (1860-1959).

\\ [ la 9 Short-Term Fluctuations. Seasonal variation in precipitation produces a seasonal variation in levels of the Great Lakes. The average difference in the level of Iake Michigan between ( July (high water) and February (low water) is about one foot, but dif-ferences of as much as two feet and as little as O feet have been recorded between these two months for any one water year. Both the lon6-term and short-term seasonal fluctua-tions have the same effect on the water table which rises and falls fr with the level of the lake, at least in the vicinity of the shore. . Seiches. Short-term water level fluctuations with periods of a few hours are called seiches. They are produced by some meteorological force such as high winds or rapid changes in atmospheric pressure. In either case, lake levels fluctuate two to three feet in less than a day. Such rapid changes in the lake level have scnne affect on the near shore ground water because the water tsble is ~ graded to the water plane of lake Michigan. High levels reduce the hydraulic gradient of the water table and result in sluggish movement in the near shore area. Such changes are only temporary, however. Lake Currents The site lies on the south side of Little Traverse Bay, an east-west embayment opening into the northern end of lake Michigan. Invest 1 ations of the currents of Lake Michigan by the C Great Lakes Research Institute of the University of Michigan suggest that two directions of currento exist in Little Traverse Bay. They are both apparently controlled by wind conditions in the area centered

19 mround the Straits of Mackinac. When the prevailing westerly or northwesterly winds an blowing, a clockvise curant moves in the bay which gives rise to a westward moving longshore current on the southern shore of the bay, es demonstrated in the Synoptic Cruises IV and V on June 28 and 29, respectively, in 1955 However, when the .vinds come from the north or northeast quadrant, the current changes to a counterclockwise direction, thereby reversing the loncohore y 1 movement on the south shore of the bay so that it moves in an easterly direction from the site area towarti the head of the boy, as rhown in Synoptic Cruises VI and VII on August 9 and lo, respectively, in 1955 The question naturally arises as to which condition prevails most frequently, the eastern or vestern direction of flow. The answer is based on both meteorological and geological evidence. Wind difection data obtained from the U.S. Coast Guard Lifeboat Station at Charlevoix indicates that the vind is from the northeast quadrant less than 20% of the time. It follows that the westward moving shore current near the site area is the normal situation. Evidence in support of this conclusion also comes from I the presence of a mile-long spit extending into Little Traverse Bay from the north shore at Harbor Springs. This spit curves eastward toward the head of the bay. It is inconceivable that this spit could maintain its orientation with any current other than the clockwise current which prevails when the westerly winds are blowing. Actually, the pattern of currents in the bay may be more i complicated than indicated by the synoptic cruises of the Great Lakes Research Institute. Also, the proposed site area is some 15 miles

20 J A frcui Petoskey at the head of the bay, and it has not been proved with certainty that water enterin6 Lake Michigan at Big Rock Point would, t in fact, move all the way t'o Petoskey at the head of the bay.. k

• O 2

4 i e I e i 4 m 4

Z 21 . REFERENCES 1. Abrams Aerial Survey Corporation, Aerial Photos of the site area flown November 1957, '(scale 1:6000). 2. Department of Conservation, Michigan Geological Survey: O An Index of Michigan Geology, by Helen Martin and kriel m. Straight, 1950. Page 228 gives location of bedrock out-crops on the south shore of Little Traverse Bay. b. Map of surface formations of Michigan, by Helen Martin, l 1957.- Centennial Geological Map of Michigan (revised,1957), c. by Helen Martin. 3 Great Iakes Research Institute, Currents and Water Masses of Iake Figures 13 (P. 30), Michigan,)by John C. Ayers, et. al.,1958. 24 (p. 53, 38 (P. 79), and SI 5104). k. Melhorn, W.N., Valders Glaciation of the Southern Peninsula of Michigan,1954, unpublished Ph. D. thesis, Univ. of Michigan, ? Dept. of Geology. i 5 Michigan Geological Society Annual Guidebook, The Traverse Group } of the Northern Part of the Southern Peninsula of Michigan, 1949, by William Kelley. Map No. 4 shows serial map of the j Traverse formation for Charlevoix and Emet Counties, Michigan. j 6. Raymond Concrete Pile Company, Gow Division, Test Boring Report, Borings No.1 and No. 2 at Big Rock Point, Michigan, May 8,. 1959 ] 7 Spurr, S.R. and Zumberge, J.H., Inte Pleistocene Features of Cheboygan and Emmet Counties, Michigan,1956, Amer. Jour. . Sci., vol. 254, p. 96-109 8. U.S. Army Corps of Engineers, Iake Survey Division, Monthly Bulletin of Iake Ievels for August 1959 U.S. Dept. of Agriculture: 9 Photo Index Mosaic of Charlevoix County, Michigan,1938, a. (cheet 1 of 3). Photo Index Mosaic of Emmet County, Michigan,1938, b. (sheet 2 of 2). Both of these include the area surrounding Little Traverse Bay. 10. U.S. Geological Survey, Topo6raphic Branch, Charlevoix and Charlevoix lake 15-minute Quadrangle topographic maps. ._m,. ._m

22

11. Wilson, J.T., Zuberge, J.H., and Marshall, E.W., A Study of Ice on an Inland Lake,1954, Snow Ice and Permafrost Research Establistument, U.S. Corps of Engineers, Report 5

~

12. Vestch, J.O., Soils and Lands of Michigan.1953, Michisan State College Press.

13 zumberge, J.H., Effects of Ice on Shore Development.1954, Proceedings of the 4th Conference on Coastal Engineers,

p. 201-205 14.

Zumberge, J.H., Guidebook for the Friends of the Pleistocene f Midwest Section. 1956. ?- em i l

~ APPENDIX A WELL

• LOGS OF B0llINGS USED DLRING P134P TEST Borinc f5, Elevation 590 7 0' - l' Sandy ions and or6anic matter.

l' - 7'5" Clayey brown sand and broken limestone. 7'5" - 23'5" Hard sandy and cravelly brown clay, few limestone fragments. 23'5" - 29'5" compact meditsi brown sand, some gravel. 29'5" 48'A Hard sandy brown clay, some gravel, few boulders and limestone fracments. 48'A 49'7" Compact clayey brown sand, gravel and broken limestone. 49'7" - 59'11" Limestone, poor recovery. Boring f6,. Elevation 589 9 08 - 2'10" Broken limestone, some clayey sand. 2'10" - 14'i Sandy medium to medium hard brown clay, some gravel. 14'A 41'5" Hard sandy and gravelly brown clay, few limestone fragments. 41'5" - 46'A Sandy medium brown clay, little gravel. 46'* - 55'3" Hard sandy and gravelly brown clay, some broken limestone. 55'3" - 64'3" Limestone, good to poor recovery. Boring f(, Elevation 590.4 0' - 3'8" Loose brown cand, s ee limestone. 3'8" - 7'0" compact clayey brown rand, and broken limestone. 7'0".- 16'10" Hard sandy brown clay, seme gravel and broken limestone. 16'10" - 22'10" Boulders and hard brown clay. 22'10" - 46'11" Hard sandy and Brave 11y brown clay, seme limestone frapnents. 46'11" - 5989" Limestone, recovery fair. Boring f3, Elevation 590.8 (No 106)

• These lo6s are from Raymond Concrete Pile Company preliminary reports.

9 9 0 0 APPENDIX B O j'

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t 3 i e s, l i ATTACHMENT II RESOLUTION OF AIR: BRP-84-20 " DISPOSITION OF CONTAMINATED SOIL" DECEMBER 20, 1984 i l 4 I l l l i Prepared by TAHancock M * < * *::::. L -~ -.__.___,

• • N w. _

1. 7'44.w_,,

j 4 Discussion and Analysis Rock Point was shut down on May 30, 1984 after samples taken of water 313 leakage into the below grade wall of the radwaste pump room indicated the f tritium and iodine-131.. The tritium concentration of these , presence o ] samples closely matched that of the main condensate. Evaluation and testing of underground lines indicated a leak in a two-inch diameter aluminum pipe. This pipe carries water from the demineralized water supply and condensate process monitor line to the condensate storage tank (see Figure 1). The pipe was removed, line capped and a temporary line installed. i i From an increase in makeup water usage, it was estimated that 20,000 gallons i of water were leaked. Analysis was conducted on samples taken fram.the primary system, condensate storage tank and water puddled at the base of the leaking pipe. A partition factor of 1000 (from NUREG-0016) was applied to the i l primary sample to account for activity loss across the steam drum before entering the condensate process monitor line. On May 30, a sample of the condensate storage tank was taken and analyzed using gamma spectroscopy (GeLi detector). The samples of the puddled water were taken on July 11, and back decayed to May 30. The concentrations (pCi/ml) and the percentages of total activity of each isotope in the samples are compared below: Table 1: Source Ters Determination Main Condensate Puddled Water Nuclide Primary System Storate Tank From Leak 2.11E-07 1.2% 1.74E-06 0.8% Mn-54 Co-60 1.94E-07 16.6% 2.80E-07 1.6% 3.16E-06 1.51 1.57E-05 92.1% 1.70E-04 80.4% I-131 Cs-137 5.12E-07 43.9% 5.85E-07 3.4% 2.35E-05 11.1% Cs-134 4.61E-07 39.5% 2.64E-07 1.71 1.30E-05 6.2% 4 Total 1.167E-06 100.0% 1.704E-05 100.0% 2.114E-04 100.0% The isotopic distribution of the puddled water is very similar to that of the main condensate. The puddled water sample was chosen as the source term because of the greater concentrations present. This will yield the most conservative dose consequences. 1-131 Only the four longer lived isotopes were used in the dose calculations. was not included since by the time the sample was taken (July 11), the concentration was already two orders of magnitude less than the concentration calculated to have been released (May 30). The Cs-134 concentration of the source term. was increased to 70% of the Cs-137 concentration on the basis of results of 7 out of 11 soil samples. The resulting source term used in the calculations is as follows:

J.' : 9 ~;.. -!~

1-??:2

5 . o Table 2: Source Ters Nuclide Activity Level (pci)* Co-60 238.46 Nn-54 132.48 Cs-137 1,741.10 Cs-134 1,218.77

• Total activity in 20,000 gallons On July 11, 1984, soil samples were taken near the area of the.line failure.

Samples were taken at three depths, just below the turbine building concrete, Five at one foot below the concrete and at four feet below the concrete. samples were taken at each depth. These samples were analyzed for radio-nuclide concentration. Just below the turbine building floor, maximum total soil contamination was 1.3E-03 pCi/ gram. At a depth of one foot below the turbine building floor, maximum total soil contamination was 1.7E-02 pCi/ gram. At a depth of four feet below the turbine building floor, maximum total soil contamination was 1.2E-03 pCi/ gram. Also, at the four-foot depth, water samples were taken. Analysis of the unfiltered water sample resulted in a total contamination of 8.5E-05 pCi/ml. The location and total activity of each soil sample are indicated on Figure 2. A listing of the results of the samples is presented in Table 3. Additional soil samples were taken to determine the spread of contamination resulting from the condensate makeup line leak. Nine sampling locations were chosen (Figures 3 and 4). Samples were taken at approximately one-foot intervals to a depth of about ten feet, when possible, as measured from the track alley floor (including the two locations outside the building). The activity of individual isotopes in each sample and the location of maximum The total concentra-activity of each isotope are listed in Tables 4 and 5. tion in each sample is recorded below: l l ,:- :i. ;;....- n.

6 Table 6: Total Concentration * (WCi/ gram) of Samples Samplina Location Depth -(Ft) 1 2 3 4 5 6 7 8 9 0- 1 3.4E-07 1-2 1.3E-07 8.8E-07 1.4E-07 3.2E-07 5.6E-07 2.3E-07 (NDA (MDA 2-3 6.7E-07 3.4E-06 <MDA 8.4E-07 2.0E-06 1.2E-06 (MDA <MDA 3-4 9.2E-08 6.6E-06 7.3E-07 2.4E-06 2.6E-06 1.1E-06 9.5E-07 7.8E-08 4-5 1.1E-06 3.2E-06 <MDA (MDA 1.2E-06 9.6E-07 1.9E (MDA 5-6 (MDA 7.4E-07 4.4E-08 1.8E-07 4.4E-07 (MDA <MDA 6-7 7.7E-08 2.2E-07 3.2E-07 (MDA 7-8 8-9 1.6E-07 9-10 10-11 1.1E-07 CBackground concentrations not corrected for. The Cs-137 concentrations are important when looking at the transport through the soil since it has a long half-life and is most likely to reach the lake. The Cs-137 distribution as determined by the sampling described above is presented in Figure 5. Calculations In order to determine the potential doses to workers and to the general population due to leaving the contaminated soil in place, calculations of direct exposure to the contaminated soil, of exposure fran inhalation of resuspended particles, and of exposure to radionuclides transported to the lake through groundwater were performed. The dose rate to workers due to direct exposure was calculated by modeling the contaminated soil as a cylinder shielded by eight inches of concrete (the turbine build'ing floor). The method of calculation was derived from Theodore Rockwell's Reactor Shieldina Desian Manual, (p 364). . 0. ". 5 8 - 0 21 ^. ;- ? ~ ' " ~

7 s. Ro = 4.45 m ,7 4 h = 1.22 m s t = 8" = 0.203 e f f y

1. M M't--0'

\\ O

• asv

(bs)

E,(bi See ei)] Ro] 2ps 3,c gt where Sv = Volume Source Strength I fy[(og, s a buildup factor n' ps = attenuation coefficient of source material ,( bg = I S t; !$h'3r,q t = thickness of shield l e *-t Es(b) = b dt i i,.... v --..,N 6t3 I D=9togifeIR/hr Figure 6: Dose to Workers The source is modeled assuming an isotropic distribution to a depth where the groundwater is believed to begin. This assumption will yield conservative results, as in reality, the source will sink to a greater depth where it will ( merge with the water table and be diluted. Also, the total source strength is taken as 1 MeV gammas again contributing to conservative results since most of the isotopes yield gammas of lower energy. This method results in a dose rate of 9.28E-04 mres/hr to the workers (refer to calculation folder for details). The dose rate to the general population at the site boundary, due to direct exposure to the contaminated soil, could be calculated as the dose at Point 2 (as labeled in Figure 6); this dose rate is expected to be negligible. For conservatise, and ease of calculation, it is assumed the cylinder is directed toward the site boundary. t I i I f I l ' 'it '...:.-U M-::-::

8

73. '

4 ~ - S l ',o ~ s I I ' ~, / ) } 4--X,s8, 4 x,. 2*d r 1 Figure 7: Dose to Population at the Site Boundary To a point at the site boundary, the source can be taken as a disk source and the dose rate can be quickly determined. b= In (1 + ) for a disk source IR/hr X2 b(Point 2)=. ( "'" I)

• (

) 84) In (1 + X t i Using this method, the dose rate to population at the site boundary was found to be 1.03E-07 ares /br. The doses due to inhalation of resuspended particles were calculated to determine the, ef fect of removing the c$ncrete slab above the contaminated soil. A volume fraction of concrete to contaminated soil of 4E-05 was used to determine the source term in air. To decernine if this activity posed a hazard during concrete removal, the amount of activity required to produce (by acute exposure) 40 MPC-hours was calculateo assuming an employee works in the general vicinity 40 hours per week. This,ount of activity was then i l ratioed with the suspended source term, the results of which show no MPC burdens were exceeded. I l The population dose from atmospheric dispersion of this contaminated concrete dust was also investigated. The maximum doses to the total body were calculated using the GASPAR computer code. The doses are reported in mrem us:,ng a population of 1.54E-05 spanning a 50-mile radius. The total body dose from all radionuclides in the source term is 6.36E-08 manrem. This yields a

!-::::A-T':1-!~*E

9 dose of 4.14E-10 area per average person in a 50-mile radius. The dose contributions of the individual isotopes are presented below: Determination of Doses Due to Inhalations 1 Occupational Population Activity Ago* Activity Manrem Total Body l Nuclide [pCi} [pCil A4o Population Within 50 Miles Mn-54 5.30E-03 1.34 4.0E-03 2.'64E-10 Co-60 9.50E-03 5.76 1.6E-03 7.26E-09 i Cs-137 6.96E-02 0.144 4.8E-01 3.43E-08 Cs-134 4.88E-02 0.096 5.1E-01 2.18E-08

• A o is the amount of activity required to produce 40 MPC-hours burden.

4 NOTE: Biological data taken from ICRP2 iMPC. taken from 10 CFR 20, Appendix B, Table 1, Column 1. Two cases were considered for the dose due to migration of radionuclides into Lake Michigan. Case 1, a worse case situation, examines the iose consequences as if the 20,000 gallon source term (Table 2) were to be released into Lake Michigan as a liquid batch release. Case 2 examines the consequences from the release af ter traversing approximately 89 meters of soil to the lake by groundwater flow. This case was calculated by using ANSI /ANS-2.17-1980: " Evaluation of Radionuclide Transport in Groundwater for Nuclear Power Sites.". This model employs geohydraulic and geometrical parameters as a function of radioactive de* cay to account for retardation of radionuclides by sorption onto/into soil. The following equation was used: 2 W t,y q y-2 (* ~ Y+ + At ] x [ erf -erf c=4RN p,t. exp- [ 4 E,t 2 TE t. a d y y e concentration of radioisotope a activity per unit area of source Porosity of soil (void fractf >~ of the medium equal to 0.2) a t time since release x distance away from sou gr now d lake in the direction of groundwater flow) A radioactive decay constant y radius of source f width of source K distribution coefficient (a measure of the reaction between the d contaminant. the fluid, and the medium, taken equal to 0.0) R retardation coefficient (a measure of the capability of the porous medium d to impede, by sorption, the movement of a particubr radionuclide carried by the fluid = 1 + p(K ' ' "" as 1.0) d

b bulk densit, of the soil

-C...:-!7'?-!?M

10 a 1 D dispersion coefficient (relates the concentration of a contaminant to g the flux of contaminant) longitudinal dispersivity (radius of source) a ' V,g hydraulic velocity of groundwater, equal to 0.015 m/d V O A V, i g g g= V = n,R D E =p d d . Numerical values for the parameters are given in the calculation folder. The expected concentrations of individual radionuclides were calculated for Note that the time of release various times and distances from the source. was taken as May 30, 1984. This was the day the condensate pumps were shut down and the leak was stopped. It is believed the leak began earlier; however, due to lack of an exact date May 30 was used. The rate of ground-l water flow to the lake is 0.035 m/ day. This results in a seven-year travel i l time for the radionuclides to reach the lake (89 meters). Using the above equation to account for retardation in the soil, the concentrations of each isotope -reaching the lake were calculated (x = 89 m, t = 2,500 days). Table 7: Concentrations at Lake Nuclide Concentration {pci/m1} Ma-54 2.50E-10 Co-60 5.64E-09 Cs-137 9.00E-08 Cs-134 1.92E-08 The dose rate to the general population due to a liquid batch release (Case 1) was determined using the LADTAP Code (Liquid Annual Dose To All Persons). The code was run for two cases - the total source release at once and the total source released over seven years time. The resultant dose consequences for the adult total body and limiting age group critical organ for both Cases I and 2 are presented in Table 8. Table 8: Release to Lake mrem Case Dose Consequences Yr Intake 1 Adult Total Body 7.89E-03 Teen Liver 1.14E-02 2 Adult Total Body 1.13E-03 Teen Liver 1.62E-03 l l -The dcse calculatzen of Case 1 uses a Cs-137 concentration of 1.74E-03 Ci/yr. The concentratien actually reaching the lake is 6.8E-06 Ci/yr (ie, 9.00E-08 pC1/mi x 20,000 gal x 3,785 ml/ gal x 10~6 Ci/pci in a single release)

. * '.__/.- 3:

11 +

e. the actual dose to the population will be on the order of 1E-05 arem, much

. less than the five millires annual dose limit defined in 10 CFR 50 Appendix I. Summary of Results The quantities of radionuclides released onsite and into Lake Michigan have been estimated and found not to exceed the limits defined by 10 CFR 20.106 (Radioactive Effluent.s to Unrestricted Areas) or by 10 CFR 30.14 (Exempt Concentrations). Table 9: Summary of Releases May 30 Concentration' Concentration

• 10 CFR 20.106*

Leak Concentration Released to Released to MPC 10 CFR 30.14* Nuclide [pci/all Lake [pci/ml) Lake [pci/ml] [pci/al] [pCi/ml] Co-60 3.15E-06 1.26E-06 5.64E-09 5E-05 SE-05 Mn-54 1.75E-06 6.22E-09 2.50E-10 1E-04 1E-03 Cs-137 2.30E-05 1.96E-05 4.00E-08 2E-05 Not Listed Cs-134 1.61E-05 1.54E-06 1.92E-08 9E-06 9E-05 1 Radioactive decay (7 years) taken into account 2 Radioactive decay as well as sorption and retardation in the soil considered for X = 89 meters and t = 2,500 days $From10CFR20,AppendixB,TableII, Column 2,SolubleConcentrations From 10 CFR 30.70, Column II In addition to the limits on quantities of individual isotopes released to unrestricted areas, limits for combinations are defined in 10 CFR, 20.106 'and 10 CFR 30.14. 10 CFR 30.14 as per 9 30.70 limit for combination = I * ****

• • • I
• i* " '* S 1 exempt concentration At Lakel,1.26E-06,6.22E-09,1.54E-06 = 0*042 I

SE-05 IE-03 9E-05 10 CFR 20.106 as per 9 20, App B e nCentrati n f is t Pe l limit for combination = I g3 l MPC isotope l ) At Eakel _ 1.?6E-06, 6.22E-09, 1.96E-05. 1.54E-06 _. g 2 5E-05 1E-04 2E-05 9E-06. l

i!-0._~A-!??3-!F05

i 12 i o But, taking sorption and. retardation of the isotopes during transport throush the soil into account: At Lake,5.64E-09 ,2.5E-10, 9.0E-08,1.92E-08 = 0.007 t I 5E-05 1E-04 2E-05 9E-06 Since the release of radioactivity in this case is well~within the ILaits of 10 CFR 20.106, the requirements of 10 CFR 20.302 (Method for Obtaining Approval of Proposed Disposal Procedures) do not apply. The potential doses to workers and to the general population due to leaving the contaminated soil in place have been determined. The results are presented below: Table 10: Summary of Occupational and General Population Doses General Occupational Population Exposure Pathways Doses Doses Direct exposure and shine 9.28E-04"'[" 2.03E-07"[*" Nuclides transported to Lake Michigan through groundwater 7.89E-03 Single batch selease Adult Total Body year intake 1.14E-02 Teen Liver g,g, 1.13E-03,,,",'[t,g, Released over 7 years Adult' Total Body 1.62E-03 Teen Liver year intake IE-05 Single release after 7 years I'*' I""*"* (retardation and sorption by soil accounted for) 4.14E-10 arem Inhalation of resuspended particles

• The activity of the suspended source term does not exceed the amount necessary to deliver a 40 MPC-hour burden.

10 CFR 20.101(a) states that no occupationally exposed individual shall receive in any calender quarter a dose to the "whole body, head and trunk, active blood forming organs, lens of the eye or gonads" in excess of 1.25 rem. As shown above the dose at the surface of the turbine floor would be 9.2SE-4 mren/hr. Thus, even if a worker was to lay on the turbine flcer

'.!!-::::A.F::-!??!

13 continuously for the quarter a dose of only 2.03 mren would be given and the federal limit would not be exceeded. 5 10 CFR 20.103(a) refereaces occupational exposure by inhalation. It is recognized that the inhalation potential proposed previously is highly l unlikely and very conservative in its approach; however, for purposes of doing i a complete analysis it was undertaken. Calculations show no worker will be or has been exposed to airborne concentrations required to exceed 40 MPC hours. 10 CFR 20.105(b)(1) and (2) concerns direct exposure of the general public in an unrestricted area. As shown earlier, a person would be able to stand at-the site boundary fence and conservatively receive a dose of 1.03E-07 mres/hr thus not exceeding the federal limits of 2 ares /hr or 100 arem in seven consecutive days. 10 CFR 20.106(d) is concerned with concentrations of radioactive material released through a pipe, stack or other conduit at the boundary of the restricted area. As stated, these concentrations "may be determined by applying appropriate factors for dilution, dispersion or decay between the point of discharge and the boundary." The source term for liquid effluent release to Lake Michigan is below Appendix B limits at the source. The results using the LADTAP code show that dose consequences to the general public using worse case assumptions are negligible. 10 CFR 50, Appendix I-states that "the calculated annual total quantity of all radioactive material from all light-water-cooled nuclear power reactors at a site should not result in an annual dose or dose commitment to the total body or to any organ of an individual in an unrectricted area from all pathways of exposure in excess of 5 millireas." As shown in Table 10, if a teenager were to stand at the site boundary and in the lake for a full year, the total dose received would be 1.23E-02 area (ie,1.03E-07 mrea/hr direct exposure x S,760 hours / year + 1.14E-02 area / year intake). 1 i i h i ':~ ~2__A-:'.2-T' i

14 4 i Table 3: Soil and Unfiltered Water Samples Near Line Failure Concentrations (pCi/ gram] 7/10/84 (Fe i Mn-54 Co-58 Fe-59 Co-60 Zn-65 An-110 I-131 Cs-134 Cs-136 Cs-137 Nb-95 La-140 Total f)ci.i l. Location A 1.2E-5 7.4E-4 3.8E-4 2.0E-5 .5.4E-4 1.7E-05 6.2E-5 1.3E-3 H l.32s-4' '6'.3E-5"~~7IEE-5 7.6E-05 ~ ~ ~ 3.3E-4 2.2E-6 1.3E-4 6.7E-5 3.3E-6 1.0E-4 1.8E-6 i H.7E-b 3.7E-6 6.6E-6 8.6E-6 1.2E-3 8.4E-6 1.2E-4 4.1E-4 1.8E-5 5.6E-4 2.2E-6 2.4E-5 3.2E-5 6 4.IE-5~ ~ ~ ~ I~~~ Location B ~ 2.8E-4 1.6E-4 8.8E-6 2.2E-4 2.5E-6 8.2E-6

7. 3'54

. U 'I'.55E-6' ~ ~i?55E-6 1.2E-5 1.8E-5 9.7E-5 1.7E-2 8.6E-5 3.2E-4 6.0E-4 3.1E-4 8.7E-3 I 4.5E-4 4.8E-6 2.4E-4 3.6E-4 6.3E-4 6.3E-6 1.6E-4 1.7E-4 1.1E-5 2.4E-4 1.2E-6 4 1.9E-5 1.5E-6 1.2E-5 1.7E-5 Location C 4.3E-6 3.3E-4 8.6E-5 6.4E-6 1.3E-4 2.9E-6 9.8E-6 6.6E-4 0 3.9E-5 3.IE-6 1.9E-5 2.9E-5 1.4E-3 I l.2E-4 9.lE-6 6.4E-5 8.2E-5 4.9E-6 2.3E-5 9.9E-5 3.7E-4 2.1E-5 5.3E-4. 1.5E-5 3.9E-4 4.2E-6 5.6E-5 1.1E-4 5.2E-6 1.5E-4 2.4E-6 l 4 2.7E-5 .l.9E-6 1.7E-5 2.1E-5 Location D 1.7E-4 1.3E-5 5.3E-5 3.1E-6 7.1E-5 0 l'.65-5 ~~iTOE-6 7.9E-6 7.IE-6 2.2E-4 2.1E-6 6.6E-5 5.1E-5 2.2E-6 7.7E-5 i H.5E-6 4.lE-7 4.lE-6 5.4E-6 3.7E-4 3.1E-6 7.5E-5 9.9E-5 2.2E-6 1.4E-4 1.2E-6 4 2.0E-5 f.HE-7 1.lE-5 1.5E-5 1 Location E 1.2E 4 1.3E-5 3.1E-5 2.0E-6 4.2E-5 9.2E-7 O l.iE-5 6.'UE-7 6.3E-6 1.2E-5 ~ 6.9E-5 2.5E-5 1.6E-6 1.9E-5 1.6E-5 1.7E-6 3.0E-6 1.lE-4 1 3.4E-6 1.8E-6 3.9E-6 3.1E-6* 1.5E-6 2.2E-5 3.0E-5 1.7E-6 4.32E-5 4 5.0E-6 '

• Fi....i uni i ltereil water sampic

] . _ [~~ '._ _Z Unf11tered Water Sample ~~ 4.3E-05 1.5E-05 1.0E-05 1.2E-05 2.6E-6 4 3.4E-6 IC0185-0222A-TI'03-TI'05

15 Table 4: Activity in Soil Samples Depth Concentrations [pci/gn] (ft) Grass Mn-54 Co-60 Cs-137 Cs-134 I-131 Location No 1 1-2 792 1.3E-07 l 2-4 780 9.2E-08 4-6 833 (MDA Location No 2 BKG 0-1 606 3.4E-07 (3.2-7) 1-3 623 5.2E-07 (3.1-7) 1.5E-07 3-5 456 6.4E-07 (4.2-7) 4.2E-07 5-7 1141 4.6E-08 3.1E-08 7-9 1196 1.6E-07 (1.6-7) 9-11 1570 ~1.1E-07 (1.2-7) Location No 3 1-2 617-1.2E-07 4.9E-7 (3.1-7) 2.6E-07 2-3 645 1.4E-07 4.8E-7 (3.6-7) 1.7E-06 1.1E-06 3-4 668 2.8E-07 6.7E-07 (2.9-7) 3.2E-06 1.7E-06 1.5E-07 (Ag 110 m 5.5E-07) 4-5 1.2E-06 1.2E-06 8.3E-07 Location No 4 1-2 704 1.4E-07 2-3 654 <MDA 3-4 746 4.5E-7 (2.6-7) 2.8E-07 4-5 844 <MDA 5-6 671 4.3E-7 (2.9E-7) 3.1E-07 Location No 5 1-2 500 1.3E-07 1.9E-07 2-3 481 3.8E-7 (4E-7) 4.6E-7 3-4 718 1.8E-07 5.6E-08 4'-5 950 <MDA 5-6 994 4.4E-08 Location No 6 1-2 780 3.6E-7 (2.5-7) 2.OE-07 2-3 696 7.4E-08 3.2E-7 (2.8-7) 8.8E-07 6.7E-07 5.8E-08 i 3-4 628 4.1E-07 5.8E-7 (3 1-7) 9.9E-07 6.1E-07 4-5 609 6.1E-07 5.1E-07 9.8E-08 5-6 916 9.3E-08 8.6E-8 Location No 7 1-2 816, 2.3E-07 2-3 536 1.7E-07 5.7E-07 4.5E-07 3-4 653 7.9E-07 3.1E-07 4-5 599 6.5E-07 3.1E-07 5-6 1353 3.4E-07 9.7E-08 (Continued)

. _ _ _...' F '. - !!. :

16 l \\ Table 4: Activity in Soil Samples (Contd) l I . Depth Concentrations [pci/ge] (ft) Grass Mn-54 Co-60 Cs-137 Cs-134 I-131 Location No 8 1-2 (MDA 2-3 <MDA 3-4 610 6.8E-07 2.7E-07 4-5 392 1.3E-06 5.7E-07 5-6 803 (MDA 6-7 1191 <MDA 2.2 E-07 7-8 992 <MDA Location No 9 1-2 542 <MDA 2-3 529 <MDA 3-4 562 7.8E-08 4-5 681 <MDA 5-6 962 <MDA ~ 6.5E-08 6-7 1191 2.5E-07 Table 5: Location of Maximum Concentration Sample Maximum Concentration [pci/gm] Location Depth Mn-54 Co-60 Cs-137 Cs-134 I-131 6 4'-5' 6.1E-07 8 4'-5' 1.3E-06 3 3'-4' 3.2E-06 3 3'-4' 1.7E-06 3 3'-4' 1.5E-07, o l 1 l . : ' : I ' - :. _ A-7. ".1 - 7' : S

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t - ATTACHMENT III RADIOACTIVITY REMAINING IN SOIL DUE TO CONDENSATE TANK LEAK EA-TAH-85-06 1 Performed By: TAHancock Technical Review By: JLBeer Administrative Review By: DPHoffman t 4 July 8, 1985 MIO785-0236A-NLO2

1 Problem Statement Describe the present conditions of the remaining contaminated soil in the area of the main condensate leak. Include an estimate of the amount of contaminated soil remaining, the total activity and concentrations of radioisotopes in the soil, and dose rates expected to result from leaving the soil in place. Input Data Isotopic concentrations based on soil samples taken near the area of the' line failure (Tables 3 and 4 and Figures 2 and 5 of Reference 1). Amount of soil excavated = eight 55 gallon drums Estimated total activity released = 3330.8 pCi ' Rate of groundwater flow = 0.035 m/ day (as per the FHSR). Assumptions Assumptions made in the " disposition" report calculations (Reference 1) are carried through. The total amount of soil removed by excavation was contaminated and contained the bulk of the contaminants released. References 1. Disposition of contaminated soil calculations summarized in report titled Revised Resolution of AIR-BRP-84-20 " Disposition of Contaminated Soil". 2. Rockwell, Theodore III; Reactor Shieldina Design Manual Calculations Estimate of the Amount of Contaminated Soil Remaining Based on the ground water flow of 0.035 m/ day, the distance the contaminants traveled through the soil in 41 days (believed to be the duration of the leak) is 4.7 feet. The excavation removed a volume corresponding to a travel distance of 3.6 feet. Assuming the width and depth of the excavation were sufficient to contain the vertical and horizontal (perpendicular to the direction to the lake) spread of contaminants, the volume remaining is 4 feet deep, 3.125 feet wide and 1.1 feet long (ie, 13.75 cubic feet). There are supply and drain lines in the area of the leak providing pathways of "least j resistance" in which the contaminants can spread. Detectable levels of the j radioisotopes have been found in samples out to a distance of 30 feet from the leak site and down to a depth of 5 feet, verifying that this has occurred. MIO785-0236A-BX01

2 ( The minimum volume of soil which would have to be removed is determined from Figure 5 of Reference 1. ( r = 30 feet .6 area er3/8 x r2 = 1060.29 ft3 J 1 r. 3 .5 volume = 5 ft (1060.29 ftu) = 5301 ft3 .4j To remove all the contaminated soil would require much tunnelling resulting in a large cost for soil removal. The soil would be disposed of in 55 gallon 4 drums (volume = 7.35 ft ). This would require the use and disposal of an estimated 721 drums. j Activity And Concentration Of Radioisotopes In Soil The average concentrations of each~ isotope left in the soil were calculated by averaging the concentrations in soil samples #3 through #9 taken in the area beneath the turbine building floor. The average includes only those samples l showing results greater than MDA which greatly overestimates the true average j concentration and activity in the soil.. The activity of each isotope is determined from the sample concentration using the following equation: k Activity [pci] = FpCi"20,000 gallons (41 days [(7.481 gallons)([28316.8 10 daysi f I ft3 h Concentration ,1 ft+ ) { Where: 20,000 gallons is the estimated volume of the leak

• Y" is the fraction of total leak spreading beyond the excavated I

,Y area (ie, excavated to 3.6 feet; ground water flow = 0.035 m/ day which indicates 31 days worth of spread was excavated, therefore, 10 days worth of the leak remains). The leak is believed to have begun 41 days prior to sampling. Assuming the isotopes are distributed uniformly in the soil, the concentration [nci/ gal of each isotope can be determined as follows: Concentration [nci/sm) = Activity [pcil 1000 [nci/pcil = 3.78E-06 (Activity [pci]) .V [ft*] p [ss/ft*] M10785-0236A-BX01 L ,l

3 3 Where V = 5301 ft 3 p = 4.99E+04 ge/ft This is a conservative assumption since the soil would act as a filtering media with the largest concentration being closest to the source and decreasing with distance. The activity in the soil at present can be estimated by taking radioactive decay into account for one year. The resulting activities and concentrations in the soil are given below: Table 1: Total Activities and Average Concentrations In Soil At Excavation At Present Half Sample Life Concentration Activity Concentration Activity Concentration Nuclide [ Days] [pCi/ mil [pCi] [nci/gm] [pCi] [nCi/gm] Mn-54 312 2.167E-07 4.00 1.512E-05 1.78 2.529E-05 Co-60 1920 4.132E-07 7.63 2.884E-05 6.69 6.729E-06 Cs-137 10950 5.456E-07 10.07 3.807E-05 9.84 3.720E-05 Cs-134 748 8.276E-07 15.28 5.776E-05 10.90 4.120E-05 _ 1;tcls 2.003E-06 36.98 1.398E-04 29.21 1.104E-04 The percentage of the total activity released to the soil which still remains x 100 = 0.88% 3 30 8 Dose Rates Expected To Result From Leaving The Soil In Place The contaminants will eventually reach Lake Michigan resulting in a dose rate to the public of less than yea 7{[take( O = 8. -08 yea take 1.0E-05 is the dose rate previously calculated using Where 1.0E-05 year intake the LADTAP code (Liquid Annual Dose To All Persons) assuming all the activity released went directly into Lake Michigan (ie, removal of activity by excavation was neglected). t The Doses to people working in the area will result mostly from direct shine. dose rate at the surface of the turbine building floor over the contaminated soil and one meter above can be determined using methods described in the Rockwell Reactor Shielding Design Manual. MIO785-0236A-BX01

4 e.., f. e, Dose Rate At Surface:

1. v0

/ 3 Lg / o e se 0) f a, E (b ) E2( 1 n n $= 2 t p h' I e ASSUYE3 I CYLINDER Ro = 30 ft = 914.4 cm h = 5 ft = 152.4 cm h ~ t = 8" = 20.32 cm 8 1ACYuat 8 8 CYLINDE R -Assuming uniform concentration throughout the volume. i,,,___ I N h's % s Activity At Excavation = 36.98 pCi Activity At Present = 29.21 pCi The values of the remaining parameters can quickly be determined. Activity = 3.43E-03 sec"I ~3 ca SV E I, Volume -I p, E attenuation coefficient in soil (taken as concrete) = 0.1249 cm h1 = 24.019 cm f fy = I (fraction of activity due to isotope t) fyt ~ 0.8 Mev B E buildup through concrete = 5.09 ba = Ipx of shielding = 2.538 sec 0 = 45.01 f 2 (b ) = 1.85E-02 E t E2 (basece) = 0 -2 The resulting flux is ( = 1.29E-03 sec"I co The dose rate can be determined by dividing the calculated flux by the flux of 0.8 MeV gammas which would result in a dose rate of 1 R/hr. = 1.9 -09 g = 1.9E-06 g D =_ $ to 31 e IR/hr -2 Where $ to give IR/hr = 6.8E+05 acc"I co O HIO785-0236A-BX01

5 1 This dose rate, as well as the dose rate which would be calculated at 1 meter above the surface, will not be detectable above background. The dose to a person digging in the area includes dose from inhalation of resuspended particles and dose from direct exposure in the center of the area. The dose due to inhalation of suspended particles was previously investigated and show that the maximum occupational dose commiitment in an eight hour day would be 0.03 mrem.,The dose to the person digging is calculated below: W W? 'g - Let the contaminated volume be 'p(w ;- D s'p ~1 - modeled as eight cylindrical e T7 j,_-;,' sources. Assume the volume t I removed by the person (in " 'T T s' ' % - - - which he stands) is a cylinder dr$ of 1.5 ft radius. 2 3 V of the cylinder = 1/8 [V of the contamiitated soil - hnr ] = 658.2 ft Then, Ro of the cylinder = 6.4732 ft = 197.3 cm Using Rockwell methods, the dose rate from one cylinder is calculated. 8J. { '*kg,7p At P2 8' +=2a ) F(0,b ) 01=02=0 ,/ 2 g 4 's i e s s / i h = 5 ft = 152.4 cm I 's a = 1.5 ft = 45.72 cm I -3 i s S = 3.43E-03 see cm y i. s y j The remaining parameters are easily evaluated: i S,\\ / i I B = 1.007 f' P, Z = 27.49 cm i l 0 = 59" I, g8 o b2 = 3.44 ( C i F(0,b ) = 1.9E-02 2 -o -2 The resulting flux is $ = 1.74E-02 sec'I cm and the corresponding dose rate is Do = 2.6E-08 R/hr = 2.6E-05 mr/hr The total dose rate to the person digging is then D = 8Do = 2.0E-04 mr/hr HIO785-0236A-BX01

e..e 6 Summary of Results Based on the analysis above, the amount of contaminated soil is approximately 8 which would result in the disposal of about 720 55-gallon drums. 5300 ft The total activity in this soil is estimated to have been 36.98 pCi at the time of excavation and is estimated to be 29.21 pCi at the present time. This is 0.83% of the total activity believed to have been released into the soil. The average concentration in the soil is estimated as 1.1E-04 nCi/gm. Dose rates at the surface of the turbine building floor, one meter above the turbine building floor, and to a person digging in the area are not expected to be detectable above the background levels. Dose rates to members of the public as a result of release to Lake Michigan are also negligible. l l MIO785-0236A-NLO2 j}}