ML20135B541
| ML20135B541 | |
| Person / Time | |
|---|---|
| Issue date: | 02/16/1995 |
| From: | Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Johnson T NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20135B362 | List:
|
| References | |
| FOIA-96-529 NUDOCS 9703030092 | |
| Download: ML20135B541 (5) | |
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From:
Wi!Iiam G.
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TC) T fohmso%.g m.s3 Date:
Thursday. February 16, 1995 11:27 am
Subject:
-CHEVRON /ENGELHARD l
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-Attached is a brief chronology and current status on Chevron and
'Engelhard.
We are going to make a final decision on the level of l
-responsibilty that we-(the NRC) will assume at this site. and 1
would like NMSS's input.
The attachment discusses our proposed l
position.
Please review and then call me so I can answer any l
questions and get any feedback you have on this issue.
g Thanks I
Bill Snell (708) 829-9871 CC:
GLS
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C:\\WP51\\WPFILES\\ CHEVRON.CRN i
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9703030092 970221 s
' BABCOCK 96-529 PDR
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1 CHROM @ LOGY CHEVRON /ENGELHARD 1942 -
Manhattan Engineer District (MED) contracted with Harshaw Chemical Company for production of UF, (in the foundry building).
i 1943 -
Production of UF, began in Building G1 (Plant C).
i 1947 -
Operation suostantially expanded.
Analytical work was performed in Building Kl.
Work was performed under MED and AEC contracts.
Equipment and materials was stored in various building unsite.
i 1951 -
Production of UF. discontinued.
1953 -
UF. plant dismantled in May.
1953 -
AEC personnel visit site for pre-decontamination survey and basis for remediation contract.
i 1957 -
Oak Ridge Operations Office conduct another site' survey.
Supplemental Agreement added to contract in June 1958 that assigned to the contractor responsibility for deconning all equipment transferred to them and the premises used in performance of the contract. Also, the decontamination had to be performed in accordance with the recommendations of the report from the above survey.
1959 -
The plant site (including buildings) was released from AEC control upon termination of contract on 12/23/59, which essentially released AEC from all liabilities arising from the contract.
1976 -
An initial radiation survey of Plant C was performed under the Formerly Utilized Sites Remedial Action Program (FUSRAP) by Argonne National Laboratory (ANL) and the Chicago Operations Office. Survey found residual contamination in Plant C and in adjacent soil areas.
1976-1979 - Radiological surveys of entire Harshaw site performed by ANL.
Identified Plant C as having major contamination, with significant levels of contamination found in 16 other buildings and 32 exterior locations.
1978 -
DOE's General Counsel indicates DOE has no legal responsibility or authority under the Atomic Energy Act of 1954 as amended to undertake a cleanup of the Harshaw site. A subsequent review of substantial additional information clearly substantiated the initial opinion of the General Counsel.
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- I 1984 -
ANL-issues the results of their 1976-1979 survey of the i
Engelhard/ Chevron site:
"Several-soil samples were taken from p
around the site. Analyses of these samples indicated extensive soil contamination, as well as suspected contamination of the.
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- river bed in the vicinity of the plant outfall. Scheduled l
subsurface investigation of the site, as well as of the river bed and sewer system, have not been conducted.
... the depth of contamination is unknown... results indicate that the subsurface contamination extends a foot or more in depth in some locations.
i The contaminating material seems to be normal uranium exclusively."
1984 -
DOE notifies ODH and EPA that DOE.has no authority to conduct i
remedial action at Harshaw.
-1991 -
February 26 letter from ODH to NRC: ODH would like to require Engelhard to register with State so that ODH could monitor L
radioactive materials at the site and any decontamination efforts.
Wants to know if NRC has any objection.
1991 -
Nardh 27 letter from NRC to ODH:.NRC has no objection to ODH seeking registration from Engelhard for the purpose of monitoring; radioactive materials at the site and any decontamination efforts.
1991 -
August 5 letter to Engelhard from ODH: ODH authorized release of Building P-1 for demolition. All survey readings were below limits specified by RG 1.86.
.1993 -
~ April 5 letter from Chevron to ODH: Chevron states site is not licensed by NRC or ODH. Chevron has received requests from ODH to register site, but it is unclear which regulatory body has authority.
1993 -
June 30 memorandum from NRC OGC: The only viable basis for NRC' jurisdiction would be that the' uranium contamination exceeds the j
unimportant quantity threshold in 10 CFR 40.13(a) and presents an unacceptable risk to health and safety requiring regulatory
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oversight.
If that is the case, it should be handled like any i
other SDMP site that is unlicensed.
j 1994 -
Narch 7.onsite inspection by Ken Lambert. Confirmed levels of contamination.
In Exit Neeting section of report (999-90003/94023), it was stated, "... that if NRC assumes regulatory responsibility for the Chevron building, it would most likely
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assume regulatory responsibility for ihe Engelhard buildings and grounds that are contaminated."
Buildings at the site' had a letter and number designation. Within I
Note buildings, operations taking place had letter designations as a i
" plant". -Technically, the UF. operations took place in Building G-1, at Plant C.
This distinction is not always followed with reference to Building C being made as often as Plant C.
The Chevron plan uses both terms Building C and Plant C, while the t
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e Engelhard plan uses the term Building G-1.
Essentially, they all refer to the same facility.
1994 -
By letter dated November 28, Chevron submits " Decommissioning Plan For Plant C" to NRC RIII for review.
1994 -
By letter dated December 19, Engelhard submits " Decontamination Plan For Engelhard Corporation Pavement and Soils Areas Surrounding Building G-1" to NRC RIII for review.
1995 -
By letter dated January 13, RIII provides response to Chevron on their Plan. Plan was unacceptable and needed additional clarification and information. Problem was Chevron had not hired a contractor to perform the work. The Plan was a " generalized plan" that would be used as a basis for going out for bids for hiring someone to conduct the work. Once a contractor was hired, the Plan would be revised by the contractor to incorporat_e their procedures, equipment, etc.
j CURRENT STATUS Review of Engelhard Plan is completed with response being drafted.
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was almost a carbon copy of Chevron's, so it has the same shortcomings.
Both Chevron and Engelhard are accepting bids and expect to hire a contractor by the end of February 1995.
It is their hope thst they can agree on the same contractor.
The question of the isotopic content of the contamination has been raised. The past studies have referred to the contamination as natural uranium, implying a soil remediation level of 10 pCi/g. However, Engelhard contends that no daughter products are present, and want to use 30 pCi/g. We have told them we will agree to a higher level (per HPPOS-292) if they can show that the daughters are absent. They have proposed taking four samples (soil, concrete) and conducting gamma spec on all four samples plus an alpha spec.on one of the samples. We intend to agree that will be adequate. They have also provided some of the isotopic analysis done by Argonne in the late 1970's to support their position.
We have had several phone discussions with the Ohio Department of Health (ODH). The question has been whether the NRC should also take the lead for the remediation of the Engelhard area surrounding Plant C.
OCH has been working with Engelhard in the past (1991) on the remediation of another building at this site.
In addition, Engelhard is formally i
registered with the State of Ohio in this regard. The concern was that for continuity, would it be better for one agency to have the lead for all the work that was to be done under these two plans, since most of the work would be done in unison and erobably with the same contractor.
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ODH has agreed that it would make sense for the NRC to take the lead for j
the remediation of the grounds surrounding Plant C.
As it stands now, our proposal is that we would take the lead for both the. Chevron Plan C remediation and the remediation of the area surrounding Plan C by Engelhard.
If Engelhard chose to remediate any 1
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.other areas onsite that are known to be contaminated as part of the same effort, we would oversee that work also. ODH would assist us as a
" contributory agency". Other buildings and areas that are contaminated that are not part of this effort will be left for ODH to follow up on with Engelhard.
The other buildings and areas with contamination discussed above are probably less than 20% of. the total onsite contamination. Most of it is in buildings that are occupied.
Engelhard's current intent is to wait several more years until the building occupants leases end, and then they can remediate the buildings in conjunction with their expected demolition. The contamination is fixed, has been roped off, and is not a current health and safety concern. However, Engelhard is reviewing tisis with concern to future escalating costs of disposal.
ACTION We would like to finalize our position with ODH on what level of responsibility wa intend to assume for this site. We would like NMSS input on what our position should be.
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February 21, 1995
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Engelhard Corporation Chemical Catalysts Group ATTN: Mr. A. G. Kopas, Manager Environmental Services 120 Pine Street P.O. Box 4017' Elyria, OH 44036-2017 l
SUBJECT:
DECONTAMINATION PLAN REVIEW
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Dear Mr. Kopas:
We have completed our review of your " Decontamination Plan For Engelhard Corporation, Pavement and Soils Areas Surrounding Building G-1, 1000 Harvard Avenue, Cleveland, Ohio," and our comments are attached as Enclosure 1.
1 We found your submittal generally acceptable, but several deficiencies need to be addressed before it can be approved. Our primary concern is the failure to adequately address the characterization survey. The normal review process for securing NRC release of a radiologically contaminated site consists of the a
following steps 1.
Submittal of a site characterization plan for NRC approval; j
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Performance of site characterization; 3.
Submittal of the site characterization report for NRC approval; 4.
Submittal of a remediation plan for NRC approval; 5.
Site remediation; 6.
Conduct of a termination survey in accordance with the protocols 4
of NUREG/CR-5849, " Manual for Conducting Radiological Surveys in Support of License Termination", followed by submittal of a report of that survey to NRC for approval; 7.
Performance of a confirmatory survey by NRC; and 8.
Release' of the site when the confirmatory survey verifies that release requirements have been satisfied.
These steps are normally sequential and distinct. However, concurrent pursuit of more than one effort, such as combining remediation with characterization, or verification with remediation, although normally discouraged, is not T
precluded.. The plan you have provided clearly specifies ccncurrent-characterization, remediation, and verification.
In this case, because of the previous radiological assessment (conducted by Argonne National Laboratory from 1976 to 1979), we see no reason to preclude you from conducting 4fgiv4= ?I^ by.
Mr. A.'G. Kopas
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t concurrent characterization, verification and remediation. However, neither the Site Safety and Health Plan or the Characterization Plan have been provided. We'will need-to review.and approve both of these documents prior to giving our approval to begin site remediation.
For additional.information, we have enclosed (Enclosure 2) the most recent revision.of the draft " Branch Technical Position on Site Characterization for
' Decomissioning" which was issued in November 1994. We suggest that you review this document for use in describing your site characterization plan.
As you are aware, Chevron Chemical has provided us with a copy of their plan for the decomissioning of the Chevron Building G-1.
In reviewing their plan, we noted one possible inconsistency between your two plans that needs to be addressed. This possible inconsistency regards the criteria to be' selected for remediation of residual activity in the soil. Our concern regarding this issue is discussed further in the attached coments. However, based on your discussions with Chevron, whose plan we had already comented on, you discussed this issue with Mr. William Snell in NRC Region III in a plone call on January 31, 1995. During that call, you agreed you would collect and analyze several samples to support your position. As a followup, you sent us a-letter dated February 13, 1995, in which you proposed to collect four samples, conduct a gamma spectrometry on each sample, and conduct an alpha spectrometry on one of the samples. We have reviewed your proposed plan for sampling and analysis and agree that it should be adequate to determine whether the radioactive contamination is pur,1fied uranium without its daughters present.
Based on our comments, you are requested to prepare and submit for approval, within 60 days, revisions to the decommissioning plan, including the Characterization Plan and the Site Safety and Health Plan.
We suggest a teleconference call to discuss our coments. This will give us an opportunity.to explain our rationale for our suggested changes to your plan.
Please. contact Mr. William Snell at (708) 829-9871 to arrange a suitable time.
Sincerely.
Original-Signed.By W. G. Snell for Gary L. Shear, Chief Fuel Cycle and Decommissioning Branch
. Project Code: 687
Enclosures:
As stated cc w/ encl 1 only:
J. Glenn, NMSS T. Johnson, NMSS D. C. Baer, Ohio Department of Health g g i.
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\\ENGLHARD.PLN DOCUMENT NAME: B:
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RIII C-NAME Snell ( m Shear 006S k
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DATE 02/24/95 02/21/95 OFFICIAL RECORD COPY j
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Region ill Comments on Decontamination Plan for Engelhard Corooration Pavement and Soils Areas Sutroundina Building G-1 1000 Harvard Avenue, Cleveland. Ohio g
Pace 2. Section 2.0-The third paragraph refers to Reference 2.5.
Since there. is no such reference provided in Section 2.4, Reference, please correct this error.
Pace 2. Section 2 0 The plan describes the onsite radioactive contamination as " normal uranium (refined uranium which is neither enriched nor depleted in the "V1sotope including its short half-life daughters
"'Th and "'Pa)".
The preface to the Argonne Report stated "the contaminating material seemed to be normal uranium 4-exclusively." The Chemical Waste Management Report states the contaminant was
" natural uranium and its decay daughter thorium". The plan states that the remediation level for residual soil activity will be 30 pCi/g, "(it is assumed that normal uranium is no more hazardous than enriched uranium; therefore the limit of 30 pCi/g should be more than adequate to meat the exposure guidel ines). "
Because of the discrepancy between what was. stated by the Argonne Report, the Chemical Waste Management Report, and your-plan, and the lack of clarity as to the nature of the activity, a technical justification will need to be provided to support a remediation value in excess of 10 pCi/g, the criteria for natural uranium. Based on a January 31, 1995 telephone call between NRC Region Ill, Engelhard and Chevron, and a February 13, 1995 letter from Engelhard, it is our understanding that Engelhard will'be collecting soil and concrete samples to determine the isotopic content of. the contamination. We understand that gamma spectrometry will be performed on all samples and alpha spectrometry on one sample. The results of these sample analyses will then be provided to the
- NRC to support any value selected for remediation that exceeds 10 pCi/g. The i
value selected should be consistent between the Chevron and Engelhard. plans.
I Paae 3. Section 2.1.2 This section states that the contractor will provide a Site Safety and Health Plan and a Radiological Characterization Survey Plan prior to mobilization of the decommissioning effort. Both of these plans will need to be provided for review and approval before approval of the Decommissioning Plan.
The Characterization Plan is key in that it is intended to provide a i
substantial portion of the data'in support of the Final Radiological Status Survey.
Because the purpose of a characterization study is to identify areas needing remediation, statistically rigorous data collection comparable to that required for a final termination survey is not necessary if the results are sufficient to guide remediation to levels permitting release of the site for unrestricted use. However, when characterization data is to be applied to the final survey if they show compliance with the criteria for unrestricted
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release, then 'you must specify their collection.follows the guidance in NUREGlCR-5849, Manual for Conducting Radiological Surveys in Support of License Termination.
Please provide your characterization survey plan consistent with NUREG/CR-5849. Please also provide a copy of the Site Safety and Health Plan.
Paoes 4-5. Section 2.1.2 Although this section discusses gridding, surveying and remediation of soil and concrete surfaces, no discussion is provided addressing storm drains in the area.
With known ground contamination and onsitt storm drains that discharge into the Cuyahoga River, provide information on what surveys will be conducted to determine whether any drains are contaminated and if so, i
determining whether the contamination exists in the Cuyahoga River.
Pace 23. Section 3.4 i
This section discusses the temporary onsite storage of radioactive waste generated during the decommissioning operation. He advised that it is our position that if radioactive waste can not be shipped offsite withTn 60 days of approving the final termination survey report (which would authorize unrestricted release of the site), we may vsgaire you to apply for a license to store the waste.
General Comment The lack of a site map makes it difficult to visualize the layout of the site.
Please provide a figure showing the site.
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