ML20137P683

Evaluation Supporting Proposed Decontamination Plan for Portion of Plant to Be Deleted from License SNM-696 & Released for Unrestricted Use,Per Licensee 841116,1206,21 & 851001 Requests

ML20137P683
Person / Time
Site:	07000734
Issue date:	11/26/1985
From:	Crow W, Shum E NRC, NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20137P680	List: ML20137P676 ML20137P683
References
NUDOCS 8512050076
Download: ML20137P683 (7)

Text

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$ 5 W:  ? Q' l NOV 2 61985 FCUP:EYS DOCKET N0: 70-734 LICENSEE: GA Technologies, Inc. (GA)

FACILITY: Fuel Fabrication Facility, San Diego, California

SUBJECT:

EVALUATION OF GA's PROPOSED DECONTMilNATION PLAN Dackcround By letters dated November 16, Decenber 6 December 21, 1984, and October 1, 1985, GA Technologies, Inc. (GA), inforned the Nuclear Regulatory Comission (NRC) that GA had decided to decontaminate a portion of the plant so that it can be deleted from the license and released for unrestricted use. The principal areas to be released include the waste processing area, the associated canyon area, and raw land (nainly hillsides and canyons) surrounding these areas. In addition, GA plans to decontaminate the underground radioactive liquid storage tanks to an extent that they can be released for unrestricted use; however, the above areas are still within GA's current licensed operating area. Although these areas will be cleaned up to the criteria suitable for unrestricted release in the future, they will not be deleted from the GA license. In connection with the above activities, GA by letter dated October 1,1985, submitted a revised decontamination The revised plan contains:

plan reflecting (the 1) aupdated description information of areasfrom to bethe original plan. (2) identification decontaminated, of areas where levels of radioactivity may exceed the regulatory levels for release to unrestricted use prior to decontamination, (3) criteria for release to unrestricted use, (4) methods to identify the quantity of radioactivity in these areas, and (5) decontamination schedule and procedure for detailed firal survey (after decontamination) to demonstrate compliance with the criteria for unrestricted use.

Description of Areas to be Decontaminated The following provides a general description on the various locations where decontamination activities are to be conducted. GA's objective is to cleanup these areas to the proposed criteria suitable for unrestricted use.

A. Underground Radioactive Liquid Waste Holding Tanks

1. Building 9 The Building 9 Tank is a 750-ga11on, poured-in-place reinforced  :

concrete tank. The tank was placed underground 28 years ago and is ,

part of the Building 9 loading dock. The tank was originally used I to dilute non-radioactive liquid waste. The liquid collected in l 4

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NOV 2 61985 the tank was contaminated with thoriun and depleted uranium. At a later time, it was used to hold liquid contaminated with mixed fission and activation products. According to GA, the tank has no history of leakage.

2. Building 2/540 The Building 2/540 Tank is a 1,000-ga11on, poured-in-place reinforced concrete tank. The tank was placed underground 28 years ago.

The tank was used to hold liquid waste contaminated with natural uraniun and thorium from retallurgical labs. No mixed fission or activation products were used in these laboratories. According to GA, the tank has no history of leakage.

3. Building 2/307 The Building 2/307 Tank is a 1,000-gallon, poured-in-place reinforced concrete tank. The tank was placed underground 28 years ago. The tank was used to hold liquid from a shielded research laboratory contaminated with Cs-137, Co-60, and Sr-90.

According to GA, the tank has history of leakage.

4. Building 31 The Building 31 Tank is a 1,000-gallon steel tank. The tank was placed underground 23 years ago. The tank was used to hold hand wash water contaninated with enriched urantun, thoriun, and activation products from the HTGR Critical Facility. According to GA, the tank has no history of leakage.

5. Building 21 The Building 21 Tank is a 1,000-gallon steel tank housed in a concrete cradle and surrounded by gravel. The tank was placed underground 28 years ago and originally served the TRIGA Reactor Facility. Until establishment of the Fuel Development and Research Laboratory (FDRL), there was little use for the tank. After establishment of the FDPL, the tank was used to hold liquid contaminated with mixed fission and activation products. According to GA, the tank has no history of leakage.

6. Building 37 The Building 37 Tanks are two 1,000-gallon steel tanks. The tanks were placed underground 20 years ago and serve the Building 37 Change Rooms. Only hand wash water contaminated with low levels of enriched urantun and thorium drains to the tanks. According to GA, the tanks have no history of leakage.

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NOV 2 61985 The locations of these underground tanks are shown on the site map in GA's submittal (Appendix A, Figure 1).

B. Waste Processing Area

1. Sol'a r Evaporation Ponds The Solar Evaporation ponds consist of four sets of three 20' x 20' concrete ponds, one foot deep, designed to contain contaminated liquid which in turn is evaporated by solar energy. Three set of ponds were used for liquid waste containing enriched uranium e thorium. The fourth pond contained liquid waste contaminated Mt.n mixed fission and activation products. Through the years, when there was a need to place additional liquid waste in the ponds, there was some cross contamination of the ponds if other ponds were full. Sludge was periodically removed, packaged, and shipped to a licensed radioactive waste disposal site.

2. Radioactive Waste Incinerator Site The incinerator was located on a 20' x 20' concrete pad. The unit was placed in operation in 1963 and decommissioned and renoved in 1980. Only the pad remains. The incinerator was used to burn solid waste contaminated with enriched uranium and was equipped with a particulate filter system. The ash was periodically removed from the incinerator and analyzed for U-235.

3. Waste Processing Facility The Waste Processing Facility was constructed to process and package solid waste contaminated with primarily enriched uranium and thorium, small quantities of mixed fission and activiation products, and to process and solidify acid waste contaminated with uranium and thorium.

The waste processing facility was placed into operation 28 years ago.

The surface of the packaging area was asphalt and the solidification area concrete.

4. Upper Storage Yards The upper storage yards were constructed 14 years ago with asphalt surfaces. Only equipment properly packaged for storage and solid waste packaged in accordance with appropriate regulations and awaiting disposal were stored in these areas.

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5. Other Storage Areas An underground storage facility was located at the east end of the  !

Waste Processing Facility. The storage area was constructed by  ;

placing 10-inch diameter transite pipe underground. Slightly irradiated TRIGA fuel elements in capped, steel pipe containers were stored in the facility from 1960 to 1978. According to GA, at the time of removal, no measurable contamination was detected on the external surface of the pipe containers or inside the storage pipes. The yard was abandoned in 1979.

The Ryproducti Storage Bu'ilding is a metal " Butler" building located in the northwest corner of the Waste Processing Facility. Inside the building are:

j a. Four storage wells 13 feet deep by 3 feet in diameter with mnovable shield plugs,

b. Six " lazy susans" located behind a shield wall. The " lazy susan" can be lowered into individual storage wells 12 feet deep, and;

c. Two levels of shielded shelf storage. Liquid cesium chloride was spilled in one of the storage wells several years ago.

A hic 5-level storage bunker for SS-gallon drums reading 50 mr/hr or greater at the surface is located in the southeast end of the Waste Processing racility. The Facility is a three-sided, open top enclosure constructed of burlap bags filled with a mixture of cement and sand and with an asphalt floor. l The drums contained solid waste contaminated with mixed fission and activation products.

C. Canyon Area The Canyon Area is a 1 acre area adjacent to the Solar Evaporation Ponds, i

Waste Processing Facility, and incinerator pad. According to GA, a spill in 1972 from the evaporation ponds contaminated part of this Canyon Area directly below the ponds with approximately 100 grams of enriched uranium and thorium. Water runoff from the Waste Processing Eacility also enters the Canyon Area.

The locations of the above areas are shown in GA's submittal (Appendix A, Figures 1 and 2).

4 The principal area to be released for unrestricted use is shown on Figure III of Appendix A. This area includes the Waste Processing Area (Item B above),

the associated Canyon Area (Item C above), and raw land (mainly hillsides and canyons) surrounding these areas. ,

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g g -- %Qg e NOV 2 61985 Since the sna11 localized storage tank areas are still within the p' ant's licensed operation, they will be decontaminated but not released at the present time for unrestricted use.

Evaluation of GA's Decontamination Plan A. Decontamination Criteria for Unrestricted Releases

1. Facility and Eauipnent The HRC has established guidelines for the decontanination of facilities and equipment prior to release for unrestricted use.

The guidelines provide acceptable surface contamination levels for byproduct, source, or special nuclear materials. The guidelines which are applicable to GA's decontamination activites for facility and equipment, are shown in Table 1, Appendix A, of GA's submittal.

2. Contaminated Soil The NRC issued a Branch Technical Position setting forth soil decontamination linits for unrestricpive releases of soil contaninated with uranium or thorium . These soil limits shall be applied to the GA site. However, there is other radionuclide contamination involving fission product or activated products at the GA site. The staff provided GA with cleanup criteria using the dose linits established in Option 1 in the Branch Technical Position for all radionuclides involved. The staff has evaluated the derived soil limits for various radionuclides as sumarized in the Tables of GA's subnittal (see Appendix A) and found that they are acceptable.

B. Decontamination Plan In Appendix A. GA has outlined the procedures for the proposed decontam-ination activities. This includes characterization of the decontaminated areas, proposed waste disposal to meet released criteria, decontamination schedule, radiological survey plan during cleanup and after cleanup, method to denonstrate corp 11ance with the criteria for unrestrictive release, and the quality assurance plan. The staff has evaluated the above procedures and found that they are acceptable.

1 ll. J. Dircks, Executive Director of Operations, NRC, memorandum to the Comissioners, " Disposal or Onsite Storage of Residual Thorium or Uraniun from Past Operations" presented as a Branch Technical Position from the Uranium Fuel Licensing Branch, October 5,1981.

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NOV 2 615ME Conclusion For the proposed GA decontamination activities, GA has provided acceptable criteria for the decontamination of some portion of their site such that they can be released for unrestricted use. The staff has evaluated the overall decontamination plan submitted by GA and found it acceptable. Therefore, the staff recommends that the GA plan be approved.

Original S16ned By.

E. Y. Shum E. Y. Shun Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and 11aterial Safety, Hf4SS Approved by: -. ,6,

. . Crow, TActing Chief

Enclosure:

Appendix A (GA Technologies 1td dtd 10/01/85) omer) Fgh FCU FCUF

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APPENDIX A GA's DECONTANINATION PLAN SUBMITTED ON OCTOBER 1, 1985

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na renningi.,  ;

,- @er To: 696-8023 GA Technologies Inc. 1 October 1985'-

Po Bcx 356C8 [# ;N SAN ciEGo CAL;FcAMA 92138 /N , ,

1619) 455 3000 '

{ i [. . . w- 3 Mr. William T. Crow .

Office of Nuclear Material y- > '

Safety & Safeguards \X U.S. Nuclear Regulatory Commission N N Washington, D.C. 20555 \'

Subject:

Docket 70-733: Plan for Cbtaining Release of Certain Areas to Unrestricted Use. (8 copies)

Reference:

(a) GA letter #696-6077 dated 11/16/84 (b) GA letter #696-6085 dated 12/6/84.

(c) GA letter #696-6092 dated 12/21/84

Dear Mr. Crow:

Enclosed are eight (8) . copies of a plan ' prepared' by GA' Technologies Inc.

(GA) for obtaining approval to release certain portions of its site to unrestricted use. This plan is a revised version of a previously sub-mitted plan and supporting information (References a, b and c). It has been modified in response to recommendations contained in an NRC draft evaluation of the original plan as well as to reflect GA's current strategy for obtaining release following discussions with Messrs. Thomas and B. Brock of Region V. Further, the enclosed plan includes an updated schedule.

Your early approval of our criteria and plan are respectfully requested.

Ihank you for your timely support in this regard. If you have any questions or cg-please contact me at (619) 455-2823.

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Very truly yours, y -,0 0 f A Y $.

g 7 Keith E. Asmussen KEA:he QW r^

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Licensing Administrator e A3 Enclosure fs _ g; 'y' Plan for Obtaining Approval to Release

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Discrete Areas to Unrestricted Use.

cc: Mr. John B. Partin, NRC, Region V (1 copy)

Department of Health, State of California (Attn: Ben Kapel) (1 copy)

MSG

PLAN FOR OBTAINING APPROVAL TO RELEASE DISCRETE AREAS TO UNRESTRICTED USE I. Objectives The objectives of this plan are to provide:

1. a description of sites to be released to unrestricted use

2. identification of areas where levels of radioactivity approxi-mate or exceed the regulatory levels for release to unrestricted use (prior to decontamination) 3 methods to identify and quantify levels of radioactivity in these areas

4. criteria for release to unrestricted use

5. a procedure for a detailed final survey (after decontamination) to demonstrate that radioactivity levels in the areas meet the -

, . criteria for unrestricted release.

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l II. Summary of Plan Our plan for releasing the sites to unrestricted use is as follows:

1. Identify the activities and their site location, and for each site provide *

a. a brief history of the activity;

b. a characterization of any residual radioactive materials, including a listing of the principal nuclides, and estimates of their concentrations, and total quantity;

c. proposed disposition of contaminated materials;

d. schedule proposed dates for clean-up, survey and release to unrestricted use.

2. Decontaminate any such location to:

a. meet the license criteria for release of. a facility or equipment to unrestricted use (Table 1) and/or' '

b. remove any contaminated soil and/or vegetati'on until the residuals meet the NRC policy (SECY 81-576) Option 1 cri-teria. This option assures that no individual is likely to receive an external radiation exposure at a rate greater than 10 pR/hr above background measured at one (1) meter above the surface or 20 millirem /yr to the lung or 60 milli-rem /yr to the bone. See Table 2.

3 Provide NRC with the results of our final surveys and request NRC confirmatory surveys to independently verify that the spe-cified sites and their environs have been appropriately decon-taminated.

4. Request NRC confirmation (s) that soils surrounding the removed underground radioactive material storage tanks listed above have been decontaminated to acceptable levels for release to unrestricted use. This confirmation will be used as evidence the locations need not be reconsidered at the time of future decommissioning activity.

5. Request and obtain a license amendment indicating that the several acres which contained and surrounded the waste pond area, incinerator area, waste processing and storage areas and the adjacent canyon areas have been appropriately cleaned up and may be released to unrestricted use.

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TABLE A -

ACCEPTABLE SURFACE C0lifAllillATI0li LEVELS  ; ,

liUCLIDti3 AVEAAGEbc( gggggggb d f AElf)VADLEbaf nat, U 235, U-230, and sociated decay products 5,000 dpa e/100 cm2 15,000 d,'../100 cm2 l 1,000 dem e/100 cm2 2

insurar.ics Ra-226, Ra-228, . ,

-?)0, th-228, pa-231, , 100 dps/100 cm2 300 dps/100 cm2 * '

2??, .-125, 1-129 20 dem/100 cm2 e

i -nat. *h-232, Sr-90,

! -223,1:4-224, U-232, 1-126, 1000 dpa/100 cm2 3000_dpa/100cm2 200 dps/100 cm2 131. 1 133 '

l ta ganta cialtters (nucildes 4 th dac ty s: odes other than

i.h4 caission or spontaneous 5000 dpa sy/100 cm2 15,000 dpa sy/100 cm2 1000 dpa sy/100 cm2 ssion) except Sr-90 and

..crs n.)ted above.

nere surface contamination by both alpha- and beta-gamma-emitting nuclides exists, the limits established for alpha- and beta-gasma-emitting

..cildes should apply independently, i t uset 2

in this table, dpa (dlsintegrations per minute) means the rate of emission by radioactive material as detensined by correcting the

,unts per minute observed by an appropriate detector for background, efficicacy, and geometric factors associated with the instruments tion.

asurscents of average contaminant should not be averaged over more than I square mecar. For objects of less surface area, the averatie

.culd be derived for each such object.

2 i .e ca.:Imura contamination level applies to an area of not more than 100 cm2.

ie amount of removable radlo4ctive material per 100 cm2 of surface area should be determined by wiping that area with dry filter or soft-

..scrb.:nt paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate Instrumeit of.

.:..a elficiency. linen removable contamination on objects of less surface area 1. detensined, the pertinent levels should be reduced

.up2rtignally and the entire surface should be wiped. .

I .e average and auximum radiation levels associated with surface contamination resulting from beta-gamma emitters should not exceed i 2 crad/hr at I cm and 1.0 mrad /hr at I cm, respectively, measured through not more than 7 milligrams per square cen~timater of i tal absort,ar.

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TABLE 2 Criteria for Soil Decontamination at the GA Site Exposure Target Other Existing Pathway Criteria Criteria or Guidance External Radiation 10 pr/hr 20 pr/hr indoor D -EPA cleanup 'I '

(whole body) (35 mrem /yr)(,) standard for Inactive Uranium Processing Site: 500 mrem /yr-10 CFR 20; 170 mrem /yr-FRC Guidance; 400-900 mrem /yr-Sur-geon General's Guidance for in-door exposure; 25 mrem /yr-40 CFR 190.

Inhalation of Partic- 1 mrad /yr (l 1500 mrem /yr-10 CFR 20(

ulates (lung, bone) (20 mrem /yr)ygg) 25 mrem /yr-40 CFR 190 3 mrad /yr (bone) 1 mead /yr (lung), 3 mrad (bone)

(60 mrem /yr) EPA Transuranic Guidance (a)This value does not include background , the 35 mrem /yr (realistic dose) includes shielding factor of 0.5 from building a residential home for general population and residence time 80 percent.

(b)40 CFR Part 192 - Federal Register, April 22 , 1980.

(c) Based on quality factor of 20 as originally intended for alpha emitted from the transuranic elements.

(d) Designated in or derived from 10 CFR 20.

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III. Sites to be Released to Unrestricted Use The portions of GA's roughly 430 acre site to be released to unre-stricted use are several small localized areas plus a relatively large area associated with and surrounding the old waste processing area. Their locations are shown in Figures I, II, III and IV.

The underground tanks being deactivated range from 750 gallons to j 1000 gallons capacity. These tanks served as holdup for radioactive liquid effluents from licensed fuel facilities and laboratories uti-lizing radioactive materials. Where needed, alternative above ground effluent storage is being provided to eliminate the under-ground tank monitoring and potential soil contamination problems.

Each of the tank sites are being treated as a potential highly lo-calized discrete source area. (Reference Fig. I)

, The Waste Processing Area (WPA) is an approximately six acre complex i of discrete areas; an incinerator site, solar evaporation ponds, waste processing facility, associated storage yards, and other stor-j age facilities. Their locations are shown in Figure II.

I The canyons below the WPA are a discrete area occupying approxi-mately one. acre through which' run-off from -the WPA goes.

Figure III shows the specific areas associated with and surrounding the Waste Processing Area. This relatively large portion of the GA site ( 80 acres) is the principal area to be released for unrestrict-ed use. Figure IV shows this area in more detail and identifies the affected areas.

A brief description of each of the above is given below:

A. UNDERGROUND RADIOACTIVE LIQUID WASTE HOLDING TANKS

, 1. Building 9 l

The Building 9 Tank is a 750 gallon poured-in-place rein-forced concrete tank. The tank was placed under ground 28 years ago and is part of the Building 9 loading dock. The tank was originally used to dilute non-radioactive acid wastes from a metal plating operation and was later con-verted to a radioactive liquid waste holding tank. The liquid collected in the tank was contaminated with thorium and depleted uranium. At a later time it was used to hold-up liquid contaminated with mixed fission and activation products. The tank has no history of leakage.

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2. Building 2/540 The Building 2/540 Tank is a 1,000 gallon poured-in-place reinforced concrete tank. The tank was placed underground 28 years ago. The tank was used to hold-up liquid waste l

contaminated with natural uranium and thorium from metallur- '

gical labs. No mixed fission or activation products were used in these laboratories. The tank has no history of leakage.

3 Building 2/307 The Building 2/307 Tank is a 1,000 gallon, poured-in-place, reinforced concrete tank. The tank was placed under ground 28 years ago. The tank was used to hold-up liquid from a shielded research laboratory contaminated with cs-137, Co-60 and Sr-90. The tank has a history of leakage.

4. Building 31 The Building 31 Tank is a 1,000 gallon steel tank. The

, tank was placed under ground 23 years ago. . The tank was. -

used ' to hold-up hand wash ' water contaminated with enriched uranium, thorium, and activation products from the HTGR Critical Facility. The tank has no history of leakage.

5 Building 21 The Building 21 Tank is a 1000 gallon steel tank housed in a concrete cradle and surrounded by gravel. The tank was placed under ground 28 years ago and originally served the TRIGA Reactor Facility. Until establishment of the Fuel Development and Research Laboratory (FDRL), the tank saw little use. After establishment of the FDRL the tank was used to hold-up liquid contaminated with mixed fission and activation products. The tank has no history of leakage.

6. Building 37 The Building 37 Tanks are two one-thousand gallon steel tanks. The tanks were placed underground 20 years ago and serve the Building 37 Change Rooms. Only hand wash water l contaminated with low levels of enriched uranium and l

thorium drains to the tanks. The tanks have no history of leakage, l

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B. Wa ste Processing Area:

1. Solar Evaporation Ponds The Solar Evaporation Ponds consists of four sets of three 20' x 20' concrete ponds one foot deep designed to contain contaminated liquid which in turn is evaporated by solar energy. Three sets of ponds were used for liquid waste containing enriched uranium and thorium. The fourth pond contained liquid waste contaminated with mixed fission and activation products. Through the years there wSs some cross contamination of the ponds necessitated by one or the other set of ponds being full when there was a need to place additional liquid waste in the ponds. Sludge was periodically removed, packaged and disposed of to a lic-ensed radioactive waste disposal site.

2. Radioactive Waste Incinerator Site The incinerator was located on a 20' x 20' concrete pad.

The unit was placed in operation in 1963 and decommissioned and removed in 1980. Qaly the pad now r.emains.- The incin- .

~ erator was ussd to burn solid waste contaminated with en-riched uranium. The incinerator was equippe'd with a parti-culate filter system. The ash was periodically removed from the incinerator and analyzed for U-235 3 Waste Processing Facility The Waste Processing Facility was constructed to process and package solid waste contaminated with enriched uranium and thorium primarily, and small quantities of mixed fis-sion and activation products, and to process and solidify acid waste contaminated with uranium and thorium. The waste processing facility was placed into operation twenty-i eight years ago. The surface of the packaging area was

! asphalt and the solidification area concrete.

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4. Upper Storage Yards l The upper storage yards were constructed fourteen years ago with asphalted surfaces. Only equipment properly packaged for storage, and solid waste packaged in accordance with appropriate regulations and awaiting disposal was stored in these areas.

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5. Other Storage Areas An underground storage facility was located at the east end of the Waste Processing Facility. The storage area was con-structed by placing 10 inch diameter transite pipe under-ground. Slightly irradiated TRIGA fuel elements in capped and gasketed steel pipe containers were stored in the facil-ity from 1960 to 1982. At the time of removal no measur-able contamination was detected on the external surface of the pipe containers nor inside the storage pipes.

The Byproducts Storage Building is a metal " Butler" build-ing located in the Northwest corner of the W' aste Processing Facility. Inside the building are:

a. 4 storage wells 13 feet deep by 3 feet in diameter with removable shield plugs,

b. 6 " lazy susans" located behind a shield wall. The

" lazy susan" can be lowered into individual storage wells 12 feet deep, and

c. ' two levels of shielded' shelf storage. Liquid cesium

chloride was spilled in one of the storage wells several years ago.

A high level storage bunker for 55 gallon drums reading 50 mR/hr or greater at the surface is located in the south east end of the Waste Processing facility. The facility is a three sided open top enclosure constructed of burlap bags filled with a mixture of cement and sand and has an asphalt floor . The drums contained solid waste contaminated with mixed fission and activation products.

C. Canyon Area The canyon area is a one acre area adjacent to the solar evap-oration ponds, Wa' ste Processing Facility and incinerator pad.

A spill in 1972 from the evaporation ponds contaminated part of this canyon area directly below the ponds with approximately 100 gms of e,nriched uranium along with thorium, Cs-134 Cs-137, Co-60 and Sr-90. Water runoff from the Waste Processing l Facility also enters the canyon area.

, D. Principal Area to Be Released to Unrestricted Use The principal area to be released is shown on Figure III.

This area includes the W'a ste Processing Area (Item B above),

the associated canyon area (Item C above), and areas of raw land (mainly hillsides and canyons) surrounding these areas. l l

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l IV. Survey and Sampling Plan for Each Site A. Underground Tank Removal, Survey and Sampling Plan Prior to removal of any tank, the tank will be pumped and the contents sampled and analyzed. The inlet lines will be capped, placarded as appropriate, and a site map marked to indicate the location of the drain lines.

The flow chart for the removal of the tank, the surveys to de-termine contamination levels, if any, as well as decontamina-tion and disposition is shown on the decision tree in Figure V.

The isotopic content for any contamination inside or outside of the tank will be determined. The total quantities will be made from dose rate measurements utilizing information from the meas-ured isotopic content.

After removal of the tank, the hole will be surveyed with an ap-propriate instrument and if no measurable activity above back-ground levels is detected, permission will be requested from the USNRC to backfill the hole. The decision tree for the ac-tivity associated, with any contamination within the tank pit is

'also given on Figure V.

If levels above the acceptable criteria are detected, soil sam-ples will be collected, analyzed and evaluated. If the levels are in excess of the release criteria for the identified iso-tope, the soil will be removed, packaged and shipped to a licensed land burial facility for disposal. In the event the quantity is economically not removable, the profile and total quantity of radioactive material will be determined and a dis-position scenario proposed to the USNRC.

B. Waste Processing Area

1. - Survey Plan In the waste processing area the first part of a survey will be a " walkover" survey. This will consist of random readings taken in the areas with a calibrated meter. This effort will locate any " hot" spots. Readings from this survey will be recorded for any area exceeding 10 pR/hr above background at one meter above the surface.

Upon completion of the " walkover" survey and with " hot" spots removed, the grid survey will be inaugurated. A grid survey will be accomplished by using a 10' x 10' grid in the designated contaminated areas and a 30' x 30' grid in all other affected areas. Measurements at each grid inter-section at a distance of one meter above the surface will i be made using a MicroR meter. If the readings do not ex-ceed 10 pR/hr above the background at one meter above the j surface, the surveyor shall move to the next grid intersec-l tion. If the reading exceeds 20 uR/hr above background at 1

9

l l

l l

1 one meter above the surface, a surface reading shall also be taken.

With a reading of 20 pR/hr or greater at one meter above the surface, and the surrounding 4 grid area average ex-ceeding the 10 pR/hr above background at one meter above

, the surface, that point shall be considered for soil sam-pling. See section on Soil Sample Plan for details.

Survey each of the affected areas as noted below; Solar Evaporation Ponds 10' X 10' grid Radioactive W' a ste Incinerator Site 10' X 10' grid Waste Processing Facility 10' X 10' grid Upper Storage Yards 10' X 10' grid Other Storage Areas 10' X 10' grid C. Canyon Area

1. Survey Plan The canyon area is defined as, that area adjacent to and .

below the solar evaporation ponds,' W'a ste Processing f~acil-ity and incinerator pad. This area is shown in Figure IV.

Because of the activities previously described for the waste processing areas, it is anticipated that there are several locations at which some contamination is expected.

As was done in Waste Processing Area, the first part of the canyon survey will be a walkover survey. It will be done in an identical manner as that described for the Waste Pro-cessing Area. Upon completion of this survey and its asso-ciated decontamination, a grid survey will be performed.

It will be performed in the same manner as the W'a ste Pro-cessing area, except that the grid description is as fol-lows:

Spill area below ponds 10' x 10' grid Other affected areas 10' x 10' grid Canyon floor 30' lengthwise along central axis 10' lateral, parallel to central axis D. Land Surrounding Waste Processing and Canyon Areas Land surrounding the affected areas described above in Sections B and C but within the boundaries of the principal area for release to unrestricted use, shall be surveyed for external radiation by a " walkover" survey at 30 foot intervals. Grids will not be staked out unless readings >10 pR/hr above back-ground at 1 meter above the surface are detected. If this j

level is exceeded, the location will be identified as an ar- 1 fected area and characterized. '

10 f

1 l

E. Soil Sample Plan )

i

1. Prior to Clean-up After the contaminated (affected) areas have been identi- i fied, soil samples will be taken to characterize the site.

Core samples will be obtained in the Solar Evaporation Ponds, the spill area below the ponds, the canyon floor and the radioactive waste incinerator site and other specific areas where there is a high potential for contamination to migrate downward into the soil strata or transport into the soil by erosion.

o Collection

a. The surface vegetation (brush and weeds) will be removed by cutting off at ground level, not up-rotted.

b. Surface samples (0-1") will be collected; approxi-mately 2 kilograms of soil sample.

c. A composite soil sample 1"-6" or 1"-12" will be col-lected based on the area and estimated depth of con-tamination.

d. If subsurface soil contamination is found, then ad-ditional samples (e.g. core samples) will be taken at sufficient depths to provide an estimate of the extent of contamination.

o Preparation

a. The soil samples will be free of vegetation and rocks.

b. The samples will be dried to remove moisture.

c. The sample will be ground to a fine powder with no

" clumping" (clumping would be due to excess mois-ture), or if it can be demonstrated with adequate data that there is no significant difference between the re-sults obtained with samples that have been ground to a fine powder and samples that have not been ground, then subsequent analyses will not require samples to be ground. Samples that are not ground to a fine powder will be crushed and mixed to elimi-nate clumping and to homogenize.

11

o Analysis l I

The samples will be analyzed by gamma ray spectroscopy, gross alpha, gross beta, DNAA or chemical analyses per-formed to written procedures. The option to log the core hole, identify and quantify the nuclides present in-situ with a gamma spectrometer and NaI detector or equivalent instrument may be used in lieu of counting the core samples.

2. During Clean-up During the decontamination phase (removal of soil with con-tamination above Option 1 target criteria) soil samples will be collected and the locations will be marked and iden-tified on a map. The first foot of soil will be prepared, and analyzed as described above to:

a. Verify correlation between the microR/hr readings and the soil radionuclide concentrations or

b. Check compliance with ,the in,halation criteria in. areas where correlation may not exist.

If results indicate contamination levels above the Option 1 criteria, additional decontamination will be conducted in order to meet the target criteria (see Section V).

3 After Clean-up Upon completion of required decontamination, soil samples will be collected as follows:

a. In areas where the microR/ hour readings are the control-ling criterion (i.e., where a correlation between pR meter readings and the results of soil sample analyses has established that both the inhalation and direct radiation pathway limits are met when using the direct reading), random sampling of 5% of the 30' x 30' grids will be conducted,

b. In all other affected areas, samples will be taken as follows:

Representative soil samples shall be collected at each grid (30' x 30') from the first inch (1") of soil.

The samples will be prepared and analyzed as described above.

12

)

V. Target Criteria for Unrestricted Release A. Facility & Equipment Table 1 is taken from USNRC's criteria for releasing facilities and equipment to unrestricted use. It has been incorporated into our SNM-696 license. This table will be used for releas-ing process equipment or buildings to unrestricted use. Ponds ,

tanks, etc. will be treated as process equipment. The above criteria will not be utilized for soils.

B. Direct Radiation External radiation (gamma dose rate in air one meter above <

ground level) shall not exceed 10 p PVhr above background for a diffuse source area (a contaminated area greater than ,,

30' x 30') and shall not exceed 20 p FVhr above background for a <

discrete area (a contaminated area smaller than 30' x 30').

C. Inhalation Pathway Table I contains values of soil contamination (pCi/gm) which if-residing on the surface and could be inhaled would not lead to j

an exposure exceeding the Option I acceptability limit. Soil contaminations above these Table 3 values may be acceptable under unusual circumstances but only if a specifically analyzed intrusion scenario shows that any individual will not be ex-

' posed to radiation levels greater than those appropriate for NRC/ EPA Option I.

D. Ingestion Pathway The GA site is located within a semi arid region zoned for light industry and Research and Development. The area is not, nor will likely be, allowed any residential or agricultural land usage. There is no potable water on the site or its en-virons. A brackish water table is approximately 275-300 ft deep at about the ssame level as the nearby salt water backwater and marshes. Therefore the pathway for ingestion of any resid-j ual contamination via any food or water is highly improbable.

However, vegetation (brush, weeds, etc) removed from the GA site for unrestricted disposal could possibly enter the in-gestion pathway. Therefore the contamination levels of such vegetation must satisfy the target criteria for ingestion exposure (as well as the target criteria for direct radiation and inhalation exposure) .

The target criteria for food ingestion exposure is 30 mrem / year to the bone (NRC Policy Issue SECY-81-576). The dose commit-ment resulting from ingestion (vegetation, beef, milk) of radio-nuclides from contaminated vegetation are shown in Table 4 These values are based upon a unit concentration of 1 pCi/ gram of each radionuclide in the vegetation.

13

E. Summary of Limiting Concentraticns for Direct Radiation and Inhalation Dose Limits l

Table 5 summarizes the derived limiting concentrations of i

I various groups of radionuclides for the compliance of the direct radiation and inhalation dose limits. Meeting the target criteria in Table 5 will indicate that the residuals satisfy the Option I acceptability criteria.

1 G g 9 14

TABLE 3 Individual Concentration in Soil Resulting in an Annual Inhalation Dose of 20 mrem to the Lung (" and 60 mrem to the Bone Solubility Derived Concentration (pCi/g)

Radionuclide Classification Lung (20 mrem) Bone (60 mrem)

U-238 Y 35( 2 1.2x10" U-238 W 3 2x10 4 3 9x10

• 3 U-238 D 1 9x10 1.2x10 U-235 Y 35 2 1.2x10 3

U-235 W 3 2x10 4 3 9x10 3 U-235 D 1 9x10 1.2x10 i

U-234 Y 30 2 1.0x10 3

, U-234 W 2.8x10 4 3 6x10 3 i U-234 D 1.7x10 1.1x10 2

Th-232 Y 35 2 2.6x10

. Th-232 W. 3 3x10 -

1.0x10 -

Ra-228 W 3 3x10 3 2 9x10 3 Th-228 3 Y 20 1.8x10 2

Th-228 W 1.3x10 3.3x10) 0 Co-60 Y 1.2x10 1.6x10 Co-60 W 1.2x10 5.8x10 5 6 Cs-137" D 9.6x10 1.8x10 Sr-90 Y 1.8x10f 2.6x10f Sr-90 D 1.6x10 2.8x10

(" Pulmonary lung (570 gm); consistent with EPA's Transuranics Guidance.

(2) Bone means osseous tissue. (5.000 gm); consistent with EPA's Transuranic Guidance.

The daughters of 1h-228 and Ac-228 do not contribute significantly to the inhalation dose because of their comparatively short half-lives.

Solubility classifications are based on ICRP-30.

i t 15 i

~

TABLE 4 Dose Commitment Resulting from Ingestion (Vegetation, Beef, Hilk) of Radio-nuclides from Contaminated Vegetation (brush, weeds, etc.). Figures Based on a Unit Concentration of 1 pCi/g of Each Nuclide in the Vegetation.

Radionuclides Bone Dose (mrem /yr)

U-238 1 9E-0 U-235 1.9E-0 U-234 2.2E-0 Th-232 2.1E-0 Th-230 2.0E-0 Th-228 4.0E-1 Ra-228 4.5E-0 Ra-226 8 9E-0 Sr-90 6.1E-0 ,

Cs-137 2 3E-1 Pu-239 5.6E-2 (1)

Reference:

NRC's Docket No.70-820 - United Nuclear Corporation Resources Company " Soil Decontamination Criteria for the Decommissioning of the UNC's Facility." Scrap Recovery

} Junction, Rhode Island.

16

TABLE 5 Derived Limiting Concentrations For Various Groups of Radionuclides Derived Limiting Concentration (pCi/gm)

Direct Inhalation Radiation (I Radionuclide Lung (20 mrem)'~ t Bane (60 mrem) (10 pa/hr)

Depleted uranium U-238 U-234 (Y) 35 2 U-238, U-234 (W) 3 2x10 -- --

2 U-238 U-234 (D) -- --

8.0x10 High-enriched uranium U-234, U-235 (Y) 30 U-234, U-235 (W) 2 2.8x10 -- --

2 U-234 U-235 (D) -- --

8.0x10 Natural Thorium * '

Th-232. Th-228 (Y) -- --

10 Th-232, Th-228 (W) -- --

10 Cobalt Co-60 (Y) - -

8 Co-60 (W) -- --

8 Cesium Cs-137 (D) -- --

15 Strontium Sr-90 (Y) 1.8x10 3 __

q Sr-90 (D) --

2.8x10 --

(1) GA prefers to use an instrument (microRmeter) to demonstrate compliance of 10 4 R/ hour above background at one meter for diffuse areas.

l 17 L __ _

_ _ .._ . ~ _ _ . - - - - - -- -----

VI. Compliance With the Target Criteria Given below are the target criteria for direct radiction and inhala-tion pathways. Both criteria must be met prior to release of the area for unrestricted use. ,

.-i

~

1 A. Direct Radiation The direct radiation level of 10 4 R/hr above background is in-tended as a target criterion for open land cleanup. The dose )

limit will be measured using calibrated micro R meters accurate enough to differentiate background. N Upon completion of any required decontamination, a final survey will be made of the waste processing and canyon areas. The pur-pose of this survey is to verify all significant contamination has been removed and the area meets the target criteria.

To demonstrate compliance with the direct radiation limit, the affected areas will be divided into grids about 30' x 30' for surveying purposes. In order to meet the target criterien, the following conditions have to be met:

Ix$arnal radiation (gamma dose. rate in air one meter above ground level) shall not exceed 10 4R/hr above background .

for a diffuse source area (a contaminated area greater than 30' x 30') and shall not exceed 20 pR/hr above background 'x s for a discrete area (a contaminated area smaller than N 30' x 30'). s_

Land surrounding the affected areas but within the boundar $' '

of the principal area for release to unrestricted use shall be surveyed for external radiation by a " walkover" survey at 30 s i foot intervals.

B. Inhalation of Particulates m Table 3 summarizes the derived soil contamination limits for each inhaled radionuclide, which results in a committed dose of 20 mrem /yr to the lung and 60 mrem /yr to the bone. It is noted that Table 3 soil limits are for individual radionuclides. If a mixture of these radionuclides exists in soil, the following s' formula will be applied to show compliance:

the sum of Ci/Li < 1 where Ci = the average soil concentration of radionuclide i, and Li = the derived maximum soil limit for radionuclide 1 (from Table 3).

(. .

18

-- y_ ---.- . ._ __.--__,,p - , - . . .

,s, b

) -

To demonstrate compliance with the dose limits established for the inhalation pathway, the following has to be met:

Representative soil aamples shall be collected at each grid (30' x 30') from tne first inch (1") of soil and analyzed for the varioye isotopes. The concentrations of isotopes can be averased by any four adjacent grids to demonstrate

'\ compliance with the target criteria given in Table 3.

The derived concentrations in Table 3 also apply to subsurface soil contamination. Therefore, subsurface

• soil samples will E;':o be collected. After decontamination has resulted in the above condition being met for surface soil, compliance with the subsurface requirement will be demonstrated by analyzing a random 55 of the subsurface soil samples.

If a subsurface random sample exceeds the limit, the four ad-jacent' 30' x 30' subsurface samples will be analyzed and the results averaged. If the average is below the limits, the inhalation dose target criteria will have been met. If the averaged, result is above the limits, further decontamination will,te conducted.

In these affected areas where it can be demonstrated with ade-quate data that meeting the 10 pFVhr above background limit will also meet the inhalation dose limit, direct radiation measurements will be used to demonstrate compliance for both

, ~ pathways . In this case, soil samples of five (5) percent of the grids will be randomly collected and analyzed to confirm compliance.

C. Ingestion of Vegetation (Brush, weeds, etc.)

Table 4 summarizes the derived vegetation contamination limits for f ach ingested radionuclide which results in a committed dose of 30 mrem / year to the bone. The vegetation contamination limits given in Table 4 are for individual radionuclides. If a mixture of these radionuclides are present in vegetation, the following formula will be applied to demonstrate compliance:

. ;'m the sum of Ci/Li < 1.0 where Ci = average concentration of radionuclide i in vegetation Li .= derived limit for radionuclide i in vegetation (from Table 4) l t

,\

"" subsurface soil (tauple" refers to a soil sample taken starting at a depth of 1" and , extending to a depth of 6" or l' depending on the area and estimated dtVth of contamination.

• t \

\

l s' 3 19 l

• l . _ _ _ _ . _ _ _ _ . _ _

_ _ _ _ _.t __ . . _ _ . _ _ . _ _ _ _ _ _ _ _ __ __. __ __ _ _ _ _ _ _ _ .

l VII. Disposition of contaminated Soil and Vegetation Soil Soil with contamination levels above the Option 1 target criteria will be appropriately packaged and shipped to an authorized radioactive waste disposal facility. l Vegetation Vegetation (brush, weeds, etc.) with contamination levels above the target criteria for external radiation or inhalation exposure or

, ingestion exposure (See Sections V and VI) will be appropriately packaged and shipped to an authorized radioactive waste disposal facility.

Vegetation with contamination levels below the target criteria for external radiation, inhalation exposure and ingestion exposure may be removed from the GA site for unrestricted disposal, e.g. sent to a local land fill facility.

20 >

I

..,_ ,- __ _ - . ~ - . _

VIII. Protective Measures and Survey Equipment

1. W' o rk performed in controlled areas will be done using proper protective measures to comply with 10 CFR 20 and accepted health physics practices.

Safety equipment on site that will be available for use at the work location includes but is not limited to:

a. Anti-contamination clothing

b. Personnel monitoring devices

c. Respiratory protection equipment (supplied air hoods)

d. Air samplers

e. High Efficiency Particulate Air (HEPA) filtered vacuum cleaners. -

f. Calibration standards for instrumentation.

g. Health Physics Instrumentation o MicroR/hr meters (Ludlum mod 19 or equivalent) o GM meters (Ludlum mod 3 with a Model 44-9 pancake probe or equivalent) o Alpha survey meters (Eberline PAC 1-SA or equivalent) .

, o ' Gas proportional sample counters (Ludlum mod 2200 '

or equivalent) o Gamma analyzers with NaI and Ge(L1) detectors (Davidson pulse Height Analyzer mod. 4106 or equivalent)

Personnel will be surveyed upon exiting a controlled area.

Equipment will be surveyed and decontaminated if required prior to removal frem the controlled area.

The project will be performed in such a manner to minimize radiation exposure and comply with the " As Low As Reasonably Achievable" ( ALARA) philosophy.

Soil samples will be analyzed for uranium content and the results will be the basis for an evaluation / analysis to verify criticality safety is assured.

21

l

^

l 1

IX. Schedule for Release to Unrestricted Use The schedule of activities leading to the release of contaminated sites are shown on Tables 6, 7, and 8.

A. Underground Tanks Table 6 lists underground tanks, the status /date of tank re-moval, status of any surrounding soil contamination, the dates of Region V verification, the release date authorizing backfill and final survey of environs of the tank site. Where the USNRC staff can be on site during or immediately after tank removal, they will verify absence of soil contamination and sample soils.

The pits will be backfilled immediately thereafter if contami-nation levels are below the criteria for release.

B. Principal Area to be Released to Unrestricted Use Contaminated soil removed during decontamination efforts will temporarily be piled in staging areas within the boundaries of the area to be released to unrestricted use. A meaningful survey cannot be completed for the entire area to be released

, . prior. to removal,of this contaminated' soil. Inasmuch as the *

, packaging and shipment of the contaminated soil will be time consuming tasks, and because of the need to prepare (e.g. grade and seed) certain areas (where contaminated soil has been removed) in order to control soil erosion, the NRC confirmatory surveys of the total area to be released will be performed in two phases. The areas associated with Phase I and Phase II are identified on Figure IV. The first phase will involve a NRC confirmatory survey of essentially the entire area except those areas occupied by or influenced by the piles of contaminated soil and one small area containing buried asphalt. Following the NRC confirmatory surveys demonstrating that the Phase I area meets the target criteria for release, this area may be re-graded.

After the contaminated soil has been removed from areas as-l sociated with Phase II, NRC will be requested to perform the final confirmatory survey.

Table 7 lists the schedule for equipment removal and appropriate cleanup. Table 8 gives the target schedule for completion of soil and surface surveys and for Region V/0RAU independent

( verification surveys.

1 1

I l i i

22

TABLN,6 SCllEDULE FOR UNDERGROUND RADIOACTIVE WASTE IIOLDING TANKS Projected USNRC Removal GA Confirmatory Backfill Area Inste Clean-up Survey Survey Release Date

1. Building 9 10/8/84 NR 10/8/84 Open 10/18/84

2. Building 2/540 7/26/84 NR 7/26/84 10/5/84 10/5/84 i

3 Building 31 8/13/84 NR 8/13/84 Open 11/16/84

4. Building 2/307 6/28/84 6/28/84 6/28/84 10/5/84 12/6/85 7/23/84 7/24/84 8/14-15/84, 8/18/84 8/23/84 9/12/84

5. Byproducts Storage Bldg. 11/16/84 11/17/84 11/19/84 open (storage pits) 2/85

6. Building 2 11/14/84 NR 11/14/84 Open 11/15/84

7. Building 37 1/8/85 NR 1/8/85 Open 1/9/85 NR - None required.

e

TABLE 7 SCHEDULE FOR DECONTAMINATION OF PRINCIPAL AREA TO BE RELEASED Remove Complete Equipment Cl ean-up*

1. Waste Processing Areas

a. Solar Evaporation Ponds 8/31/84 10/15/85

b. Incinerator Site N/A 11/85

c. Waste Processing Facility 11/84 3/86 11/85

d. Upper Storage Yards 11/15/84 3/86

2. Canyon N/A 11/85 3 Sur. rounding raw land.

N/A -

K/A' *

• tentative, subject to change due to weather conditions, etc.

24

TABLE 8 l Schedule for Final Surveys of Area- to Be Released to Unrestricted Use Request USNRC Confirmatory GA Survey

• Final Report

• Survey **

Phase I Area (s) 10/24/85 11/15/85 11/15/85 Phase II Area (s) 3/1/86 4/1/86 4/1/85

1. Dates are tentative, subject to weather conditions.

• • Tentative target dates for requesting NRC confirmatory survey. It is anticipated NRC confirmatory survey would commence about two weeks after request. .

25

X. Background Levels The background for the general area was established by taking soil samples from five (5) selected locations (Figure I) agreed to by GA Technologies Inc. (GA) and the U.S. Nuclear Regulatory Commission (USNRC) . Surface samples (0-1") and composite samples from between 1' to 2' depth were taken from each of the five locations.

Samples were assayed by gamma ray spectroscopy by GA, the USNRC and Oak Ridge Associated Uhiversities. The results were compared and the following background levels will be utilized.

Isotope Conc pCi/gm K-40 21.81 Co-60 0.003 Cs-137 0.09 U-238 1.5 U-235 0.09 U-232 1.50 Th-228 1 32 .

• Ra-226 0.84 Ra-228 1 37 Background external radiation levels will be established for the work site by taking readings in the adjacent non-contaminated areas and averaging them to obtain an overall background reading for the area.

l i

l 26

)

APPENDIX A QA PLAN 1.0 Pur pose The purpose of the QA Plan is to establish an acceptance plan for the survey, evaluation and release of descrete locations on GA Technologies property in order to meet the U.S. Nuclear Regulatory Ccmmission regulations for release to unrestricted use.

2.0 Scope The scope will include examination and review of; statistics and procedures, instrumentations and calibration, data and evaluation documentation and verification.

3.0 Statistics and Procedures Statistics that are used shall be checked for accuracy.and appli- ,

The. procedure used shall be current.

, .cability. ,

4.0 Instrumentation and Calibration All instruments shall be mechanically and electronically stable,

' The calibration shall be with applicable standards and be traceable l

to NBS Standards.

5.0 Data, Evaluation, Documentation and Verification All data and its documentation shall be maintained as to be retrievable and traceable.

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4 e-Figure V." Decision Tree Associated utili lindergrounit Tank fleinoval, l Deteristnation of Containination, nuit Sul> sequent Hispostl.lon Remove Tank Tank rtt sf

Survey Sur i; Activity level ,

Anl.tvi ty l evel in pit ilo mensuralite activit.y aliove liankground aliove liaokground aliove limokground inside and/or outside I I d /

Soll S] ample u.

Id enti f yhpianti f y Olitain tairestricted ac t iv i t.y release frose ilRC Deteral e if h I.evel exceeds criteria lilent.t ry/4unnti fy llank fill for tinrestricted relenso an t i v ll.y Yea llo

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IIRC Ileseove contaminated Cannot meet opl.lon I

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_ - _ - - a

r-FIGURE VI Flow Chart Associated with Contaminated Areas in Waste Processing and Canyon Areas Waste Processing and Canyon Areas l

Y Initial Walkaround Survey I

Y Remove " Hot" Spots i

Y Map and Grid Survey i

Y Meter Reading > Acceptance Criteria Y .

Soil Sample or Well Log" I

Y Identify /Cuantify Activity i

Y Level Exceeds Criteria for Unrestricted Release Y

Remove Contaminated Material (Meet Option I Criteria)

I Y

Final Survey I

Y Notify NRC for Verification and Subsequent Release t

Y Release to Unrestricted Use l

, - . - . .- - . _ _ . - . -