ML20137Z201
| ML20137Z201 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 04/30/1997 |
| From: | GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | |
| Shared Package | |
| ML20137Z193 | List: |
| References | |
| NUDOCS 9704240026 | |
| Download: ML20137Z201 (33) | |
Text
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+"inaan GENERAL ATOMICS'
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l SITE DECOMMISSIONING PLAN i
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SEPTEMBER 1996 l
(Revised December 1996) l (Revised April 1997) i
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O AFOANCS o
e APRIL 1997 CHANGES TO GENERAL ATOMICS' SITE DECOMMISSIONING PLAN 1.
Added Buildings 1,7,13,14,15,19, and 29-1 to Table S-1 as non-impacted areas; all buildings are office buildings with no history of use involving radioactive materials, no reasonable potential for contamination and are physically isolated from areas where radioactive materials were used.
2.
Regulatory jurisdiction indicated for Building 25 in Table S-1.
3.
Building 2 - typographical error corrected - 36 labs changed to 33 labs in Table S-1 (only 33 labs in Building 2 remain to be released to unrestricted use).
4.
Added the following new paragraphs (in italics) to section 6.1.3 (page 6-2):
GA will prepare individual detailed survey plans for each facility or group of Isho:utories and will advise NRC of the schedule and the availability of these survey plans for their review upon request.
5.
Corrected Natural Uranium concentration limit on Table 6-2 (changed from 35 pCilg to 10 pCi/g). Added Depleted Uranium concentration limit to Table 6-2 of 35 pCi/g.
6.
Section 6 has minor revisions except for Section 6.1.4 " Classification of Areas by Contamination Potential" which was revised significantly in accordance with the subdivision of categories from 3 categories; (1) scoping or confirmatory survey, (2) unaffected area survey and (3) affected area survey) to 4 categories as follows:
(1)
Non-impacted Areas j
(2)
Scoping or Confirmatory Survey (3)
Unaffected Areas (4)
Affected Areas - Further subdivided into:
Non-suspect Affected Areas Suspect Affected Areas Added information for each category including survey units and specific number of measurements to be conducted for each unit.
7.
Section 4.6 Schedule - changed from 5-10 years to " approx!rnately 5 years".
8.
Table of Contents changed (Chapter 6 revised).
+CENERAL AT0hNCS I
TABLE OF CONTENTS TABLE OF CONTENTS
. ii l
LIST OF TABLES iv LIST OF FIGURES iv INTRODUCTION
.1
SUMMARY
S-1 1.
GENERAL INFORMATION AND
SUMMARY
OF D&D EXPERIENCE.
1-1 1.1 Licensee Name and Address..
1-1 1.2 Licensee Information 1-1 2.
SUMMARY
OF D&D EXPERIENCE 2-1 3
SITE DESCRIPTION 3-1 3.1 Location and Size 3-1 3.2 Topography 3-1 3.3 GA Facilities 3-2 3.3.1 GA's Sorrento Electronics Site.
3-2 3.3.2 Room 049 of Building 9 3-2 3.3.3 Building 10 3-3 3.3.4 TRIGA Reactors Building (Building 21) 3-3 3.3.5 TRIGA Fuel Fabrication Facility (Building 22) 3-3 3.3.6 Hot Cell Facility (Building 23).
3-3 3.3.7 Low-Level Liquid Filtration Facility (Building 25) 3-4 3.3.8 Nuclear Waste Processing Facility (Building 41) 3-4 3.3.9 Experimental Area (Building 27) 3-4 3.3.10 Experimental Area Bunker (Building 27-1) 3-4 3.3. I 1 Linac Facility (Building 30).
3-4 3.3.12 NMA Storage " Vault" (Building 31) 3-5 3.3.13 Inertial Confinement Fusion (Building 33) 3-5 3.3.14 Building 33-1 (Former HP Lab) 3-5 3.3.15 Fusion Building (Building 34) 35 3.316 Test Tower (Building 35) 3-5 3.3 17 Sorrento Valley A (Building 37) 3-6 3318 Fuel Production Process Building - Sorrento Valley B (Building 39).
3-6 3.3.19 Calibration Facility (Building 42) 3-6 3.3.20 Science Laboratories (Building 2).
3-7
)
3.3.21 Underground Storage Tanks -Buildings 9,31,21 & Lab 540 of Bldg. 2 3-8 4.
DECOMMISSIONING ORGANIZATION, TRAINING AND METHODS USED FOR PROTECTION OF OCCUPATIONAL AND PUBLIC HEALTH AND SAFETY 4-1 4.1 Decommissioning Organization and Responsibilities 4-1 4.2 Description of Overall Organizational Structure 4-1 l
4.3 Decommissioning Safety Responsibilities...
4-1 4.3.1 Industrial Safety / Hygiene 4-1 4.3.2 Radiological Safety
. 4-2 4.4 Training 4-2 4.4.1 Radiological Safety / Retraining 4-2 4.4.2 Equipment Operator Training 4-3 l
4.4.3 Safety / Accident Prevention Training
. 4-3 l
4.4.4 Hazardous Material Training.
. 4-4 l
4.4.5 Other Training.
4-5 ii
CENERAL AfDhNCS 4.5 Procedures....
4-5 4.6 Schedule 4-5 4.7 Methods Used for Protection of Occupational and Public IIealth and Safety 4-5 4.7.1 ALARA Program.
4-5 4.7.2 Management Positions Responsible for Radiation Protection and Maintaining Exposures.
4-6 4.7.3 Methods for Occupational Exposure Reduction 4-6 4.7.3.1 Work Authorization Approval..
. 4-6 4.7.3.2 Radiation Work Permits 4-7 4.7.4 Control and Storage of Radioactive Materials
. 4-7 4.8 IIealth Physics Program.
4-7 4.8.1 Project 11ealth Physics Program - General 4-7 4.8.2 Audits, Inspections, and Management Review 4-8 4.8.3 Ilealth Physics Equipment and Instrumentation 4-9 4.8.3.1 Criteria for Selection and Instrumentation for Conduct of Radiation and Contamination Surveys and Personnel Monitoring...
4-9 4.8.3.2 Storage, Calibration, Testing and Maintenance ofIIealth Physics Equipment and Instrumentation 4-9 4.8.3.3 Specific IIcalth Physics Equipment and Instrumentation, Use and Capabilities.
4-10 4.9 Processes & Systems for llandling, Storage, & Disposing of Radioactive Waste 4-10 4.9.1 Conformance to Requirements of 10CFR61,10CFR71, & 10CFR20.2006 4-11 4.9.2 Conformance to Disposal Site Requirements 4-12 4.9.3 Conformance to State Requirements 4-12 4.9.4 Waste Characterization Projections and Volumes.
4-12 5.
ANTICIPATED APPROACilES TO DECONTAMINATION AND DECOMMISSIONING 5-1 5.1 APPROACil A 5-2 5.2 APPROACII B 5-4 5.3 APPROACll C 5-14 6.
FINAL SURVEY 6-1 6.1 Release Criteria for Items, Equipment and Facility.
6-1 6.1.1 Release of items and Equipment 6-1 6.1.2 Release of a Facility 6-2 6.1.3 Description of Final Radiation Survey Plan....
6-2 6.1.4 Classification of Areas by Contamination Potential.
6-4 6.1.4.1 Scoping or Confirmatory Survey 6-4 6.1.4.2 Affected Area Surveys 6-4 6.1.4.3 Unaffected Area Surveys.
6-6 6.2 Soil Sampling Plan.
6-6 6.2.1 Release Criteria 6-7 6.2.2 Soil Background Concentrations.
6-7 6.2.3 Affected Areas - Open Land Areas 6-8 6.2.4 Unaffected Areas - Open Land Areas 6-11 6.2.5 Sample Collection 6-11 6.2.6 Direct Radiation Measurements 6-11 6.3 Methods to be Employed for Reviewing, Analyzing, and Auditing Data.
6-11 6.3.1 Laboratory / Radiological Measurements Quality Assurance 6-11 iii
d S3pmA&
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- 9 AfDRNCS 6.3.2 Supervisory and Management Review of Results...
6-11 l
6.4 Final Survey Report............................
6-12 l
7.
FUNDING......................
. 7-1 j
8.
PHYSICAL SECURITY PLAN AND SPECIAL NUCLEAR MATERIAL ACCOUNTABILITY 8-1 l
9.
FIRE PROTECTION...............
9-1
)
9.1 Fire Safety...............
. 9-1 l
9.2 Fire Safety Responsibilities......................
9-1 j
9.3 Fire Prevention........
9-1 l
9.4 ' Fire Protection.........
9-1 j
9.5 ' Fire Suppression System Changes 9-2 l
l TABLES 1
ll Table S-1 G A Sites to be Decommissioned................................... S-2 l
i Table 3-1 Status of Labs in Building 2............
3-9 i
I Table 4-1 Typical List of Instruments Used During D&D Projects.
4-14 Table 6-1 Acceptable Surface Contamination Levels 6-3 Table 6-2 Soil and Concrete / Asphalt Rubble Release Criteria.......
6-10 I
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LJST OFFIGURES (notpaged)
Figure 3-1 Main Site and Sorrento Valley Site Figure 3 Sorrento Electronics Site i
Figure 3-3 Sorrento Electronics Manufacturing and Dipporting laboratories and offices i
Figure 3-4 Building 9 " Hot Suite" l
Figure 3-5 Building 10 Figure 3-6 TRIGA Reactors Building 21
. Figure 3-7 TRIGA Fuel Fabrication Facility Building 22 Figure 3-8 Hot Cell l
Figure 3-9 Low-Level Filtration Facility Building 25 I
Figure 3-10 Nuclear Waste Processing Facility Building 41 Figure 3-11 Experimental Area (EA) Building 27 l
Figure 3-12 Experimental Area -l " Bunker" Building 27-1 j
Figure 3-13. Relationship between Building 27-1,27,21,23 and 22 l
Figure 3-14 Building 30/31 Complex Figure 3-15 Building 31 Room 103 NMA Storage Figure 3-16 Inertial Conf'mement Fusion Building 33 j
Figure 3-17 Building 33-1 Former HP LAB 1.
- Figure 3-18 Fusion Site Building 34 Figure 3-19 Test Tower Building 35
. Figure 3-20 Sorrento Valley A Building 37 Figure 3-21 Sorrento Valley B Building 39 i
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Figure 3-22 Calibration Laboratory Building 42 Figure 3-23 Science Laboratory Building 2
[
Figure 3-24 Laboratory B Section Building 2 Figure 3-25 Laboratory C Section Building 2 Figure 3-26 Laboratory A Section Building 2 j
Figure 4-1 Decommissioning Organization l
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+CENERAL i
ATOANCE RCRA Facility Standards Overview Training-This class covers the requirements established under 40 '
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CFR 264.16 for personnel who may handle hazardous wastes within the Facility. The class covers the
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Federal Standards and discusses compliance requirements for generators of hazardous and mixed wastes.
An annual update is provided, l
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4.4.5 Other Training l
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i Waste Accentance Criteria-Training is provided to the rer;uirements established for the disposal site (s).
An annual training update is provided.
GA Emercency Response Training-GA has an " Emergency Plan"(a.k.a. Radiological Contingency Plan), as required by the NRC and the State of California. All facilities in which licensed material is stored or used have specific implementing procedures for this plan. Training on the Radiological Contingency Plan is provided annually to Emergency Response and Recovery Directors (specific to each facility) and their alternates. Emergency Response Team members also receive training specific to their facility's potential hazards / emergencies.
4.S Procedures All decommissioning work will be performed in accordance with written, approved procedures and/or plans.
Revisions to Decommissioning Project procedures are reviewed, approved, and processed in the same manner as the initial document. Field changes to existing approved procedures are made in accordance i
with current procedure cos 01 requirements.
HP procedures are developed by Project and GA HP personnel and approved by GA HP and Licensing, Safety, and Nuclear Compliance (LS&NC) management. Quality Assurance procedures are developed by Project and GA Quality Assurance personnel and approved by GA Quality Assurance management.
4.6 Schedule GA anticipates decommissioning, or the transfer ofjurisdiction to the State of California, of all facilities described in Table S-1 to take approximately 5 years.
4.7 Methods Used For Protection of Occupational and Public Health and Safety 4.7.1 ALARA Program l
4-6
4% CENERAL O ATOANCS
SUMMARY
A summary of the GA sites to be decommissioned is provided in Table S.1, which provides a short description of each facility, the type of activity conducted, the radioactive material used, the status and current activity, the current regulatoryjurisdiction (NRC and/or State of CA), whetherjurisdiction could be transferred to State only, whether ground contaminatian is suspected, the anticipated D&D effort and approach to be used, and the final survey anticipated :o be required.
Additional information on each facility / site listed in Table S-1 is provided in Chapter 3. Detailed information on each approach anticipated for the facilities / sites in Table S-1 is provided in Chapter 5.
Detailed information on the Final Survey anticipated to be required is provided in Chapter 6.
The information provided in this General Decommissioning Plan meets the requirements of 10CFR70.38.
J 1
S-1
"l TABLE S-1: General Atomics' Facilities and Sites to Be Decommissioned (Status as of April 15,1997)
Building No.
Name/
Type of Status and Regulatory Ground Anticipated Description Activity Radioactive Current Jurisdiction (58il) -
Contamination Maternal Activity D&DEbrt Final Survey Required Used N
and Approach Buildings 1,7, Office None.
None Office Use, NRC and No Non-impacted Areas None Required 13,14,15,19 Buildings, Never used for Parking and State 29,29-2 and Parking work involving Recreation No D&D needed (Areas that have no surroundmg Lots and radioactive reasonable potential for Recreational materials or residual contamination Areas radiation do not need any level of machines suncy merage)
Land Raw land on None.
None Steep hillside NRC and No Non-impacted Areas None Required Surrounding hillside Never used for Area not utilized State Bldgs. 37-42 to upgradient of work involving or occupied No D&D needed (Areas that have no r
North, West Bldgs. 37-42 radioactive and South (Between reasonable potential for materials or fence and residual contamination radiation do not need any level of machines suncy merage)
Sorrento Leased Manufacture of Byproduct In operation State No No D&D of facility is Unaffected Area Electronics facility in radiation expected Survey assuming no MIA Mesa monitoring contamination is found.
instrumentation Removal of Sources needed Approach A Room 049 of (ala "E" or TRIGA Fuel SNM No Rad NRC None Moderate D&D Afrected Area Survey Building 9 experimental Fabrication Usage /Telecon expected Building) prior to 1976 Equipment Approach B Storage Only All of Bldg 9 3 'l released except room 049 i
S-2
=
TABLE S-1: General Atomics' Facilities and Sites to Be Decommissioned (Status as of April 15,1997) -
Building Name/
Type of Radioactive Status and Regulatory Ground Anticipated No.
Description Activity Material Current Jurisdiction (soil)
Used Activity C'*"i"i'"
D&D Elfort Final Survey Required N
and Approach 10 IIP Lab Calibration of Byproduct, In use.
State No No D&D of facility Affected Area Survey (1/97) radiation sealed llealth Physics expected.
Previously detection sources Laboratory (as CalLab equipment and of-12/96)
Remove sources and i
IIP laboratory equipment including hood and ducts Approach B 21 TRIGA Non-power All Mark I reactor NRC To be Major D&D Affected Area Sun'ey Reactor Reactors; license active and State Determined Facility R&D Approach C and Soil Soil Criteria Mark F reactor Cleanup disabled /POLA 22 TRIGA Fuel TRIGA Fuel Predominantly Operations NRC Yes Major D&D Affected Area Sun'ey Fabrication Manufacturing SNM ceased.
Facility Some Approach C and Soil Depleted All equipment Cleanup Soil Criteria uranium removed, ready for D&D 23 110t Cell R&D All Currently in State &
Yes In accordance with NRC and State of CA approved and PIE D&D.
NRC D&D Plan (Refs. NRC SNM-6% license amendment
- 35 dated 5/1/96 and State of CA Radioactive Expected to be Material License 0145-80 amendment # 123 dated completed by 7/566) 1999.
d S-3
TABLE S-1: General Atomics' Facilities and Sites to Be Decommissioned (Status as of April 15,1997)
Building Name/
Type of Radioactive Status and Regulatory Ground Anticipated No.
Description Activity Material Current Jurisdiction boil)
Contamination Used Activity D&D Effort Final survey Required W
and Approach 25 Liquid Treat liquid All In Use.
State &
Yes hioderate D&D expected Affected Area Survey Waste LLW for NRC/
and possible Soil and Soil Criteria Treatment Discharge to To be Remediation Facility sewer transferred to State only Approach C 41 Nuclear Nuclear Waste All In Use.
State &
Yes h1ajor D&D expected and Affected Area Survey Waste (LLW)
NRC/
Soil Remediation and Soil Criteria Processing Processing.
- Baling, To be Facility compacting, transferred Approach C (NWPF) solidification, &
to State only drying repackaging 27 EA Radiochemistry Ai Inactive State &
Possibly hioderate D&D expected Afrected Area Survey (Experimental and Chemistry NRC/
and possible Soil (possibly Soil
^'**)
Labs Shut-down 9/96 To be Remediation Criteria) transferred to State only Approach B 27-1 EA-1 R&D All inactive State &
Possibly Moderate D&D expected Affected Area Survey Bunker associated with NRC/
and possible Soil (possibly Soil Facility radiochemistry Equipment To be Remediation Criteria)
Removed. Ready transferred for D&D.
to State only Approach C Room i18 Linac Irradiated Fuel All In Use.
NRC/
No No D&D of facility Unaffected Area of Building Facility Storage in State, after anticipated Survey if no 30 Casks Storage Only.
the removal contamination is found.
offuel Confirmatory Survey (SNht)
Needed l
Approach A S-4
_. __.. ~.. _ _
TABLE S-1: General Atomics' Facilities and Sites to Be Decommissioned (Status as of April 15,1997).
Building Namie/ -
' Type of Radioactive Status and Regulatory Grened Anticipated j
No.
Descripties Activity Material Current.
Jurisdiction 4*il)
C""''''""
Used Activity D&D Effort Final Survey Required t
N and Approach
{
Bldg.
Linac -
Activation Activation Not in Use.
State No Confirmatory Survey -
Affected Area Survey 30 (except Building Products Products Operations Required room 118) ceased.
Approach A Room 103 Nuclear Radioactive All In use.
State and No Minor D&D,ifneeded Affected Area Survey r
ofBldg.
material Material NRC
^ ]
""Y Storage
- Storage, State, after Approach B
{
31 sampling, and removal of combining.
[
l 33 ICF Fusion Radiation tritum in Use.
State No Remove sources. No D&D Unaffected Area Machines and of facilities expected.
Survey scaled tritium source Approach A -
33-1 Former HP Samples All Inactive State No No D&D of facility was Unaffected Area I
Lab containing needed (survey performed Survey ifno small quantities (SNM in lab after move of HP Lab; no contamination is found.
l ofradioactive under State contamingion detected).
I material license)
[
Approach A i
34 Dill-D Fusion Short-lived in use.
State No No D&D of facility Unaffected Area
-(
Research Activation expected.
Survey Products and Remove sources and Tritium activated equipment.
Afrected Area Survey i
in Dill-D pit 4
l Approach A q
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TABLE S-1: General Atomics' Facilities and Sites to Be Decommissioned (Status as of April 15,1997)-
Building Name/
Type of Radioactive Status and Regulatory Ground Anticipated No.
Description Activity Material Current Jurisdiction (5 oil)
Used Actisity Contamination D&D Effort Finalsurvey Required N
and Approach 35 Test Tower Testing and Mixed fission Operations State No Scoping Survey needed.
Unaffected Area maintenance of and ceased.
No contamination expected.
Suney if no contaminated activation contamination is found.
helium products Approach A circulators (1)
SVA-South Temporary All No rad material State &
No Scoping surveyneeded.
Unaffected Area 37 ste age of usage.
NRC/
Packaged LLW Survey ifno To be Approach A contamination is found.
(Formerly from 37 North Only non-rad transferred d of activities in to State only Building Scaled sources DUIIdI"E-37) for calibration of TRIGA monitoring /
control equipment 39 SVB/ Pilot Pilot Plant -
SNM Operations State and Yes hlajor D&D Affected Area Survey Plant Fuel Depleted U ceased.
NRC and Soil Criteria Development Thorium Approach C (possibly Soil R&D Equipment Remediation)
Removal and Characterization in progress.
42 Calibration Prewiously the Cs-137 In operation.
State No Remove all sources Afrected Area Suney Facility; Industrial Sealed previously Radiography Source, cal Calibration of Approach A Radiography bldg; now standards Instruments Bldg.
calibration facility.
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ll S-6
TABLE S-1: General Atomics' Facilities and Sites to Be Decommissioned (Status as ofApril 15,1997)
Building Name/
Type of Radioactive Status and Regulatory Ground Anticipated No.
Description Activity Material Current Jurisdiction (Scil)
Costamiisseion Used Activity D&D Effort Final Survey Required UI and Approach 2 (2)
Science R&D, Testing, Variable inactive except State and/or None Lab Specific lab Specific Laboratory Experimental for HP lab which NRC/
expected Building is being moved Lab Specific /
to Bldg.10.
To be (a.k.a. "L" transferred or 102 labs have to State only Laboratories been released.
Bldg.)
33 labs to be released.(2)
Bldg 2 Service Services All Inactive State and/or To date,2 To be Determined Afrected Area Survey Service Core and provided to NRC/
drain lines and for Selected Areas Core Drain lines labs plus drain All known one area of lines from radioactively To be concrete Rest ofcore some of the contaminated transferred Unaffected Area labs.
ducts in the core to State only No other were removed in 1994. Allother known accessible ducts contamination.
were surveyed and no contamination found or removed as radioactive waste.
Building 2 lab 307 Temporary Tank State and Soil was D&D effort including soil remediation completed Underground Storage storage of removed and NRC remediated in i1/94. See Report to NRC dated 11/30/94 (letter Tank radioactively soil 1984.
696-6083).
1 contaminated remediated in I
T N[,j'3{"C 1984.
Atra n t decontaminated to Option 1 Release Criteria Sr-90 S-7
r b
TABLE S-1:.' General Atomics' Facilities and Sites to Be Decommissioned (Status as of April 15,1997)
~
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l Building Name/
Type of Radioactive Status and Regulatory Ground Anticipated
[
i No.
Description Activity -
Material Current Jurisdiction 4*il) i Contaimiestion Used Activity D&D Effort Final Servey Required N
and Approach Under.
Bids 9 Tank Temporary Various Tanks Removed State and No GA report dated 2/11/85 shows soil concentrations l
ground B'[d[]
storage of in 1984 W NRC below the Option I release criteria. Soil Samples i
Storage Bldg 2 Lab radioactively Obtained by the NRC during removal of the tanks.
Tanks )
540 Tank contaminated t
I liquids.
Formal Release Not Yet Obtained.
t l
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W The north end of Building 37 (IITGR Fuel Fab Facility) was released in 1995 and the north end of the building dismantled (no longer exists).
(2)
Building 2 Summary: Total of 142 labs; of these 33 labs Have Not Yet Been Released to Unrestricted Use and 109 labs have been released to i
unrestricted use in Groups I through 8C (Groups 8B and 8C release anticipated in 1996 and included in total number oflabs released.
I Labs notyet releasedare as foilows:
L.aboratory B Section: Labs 202,204,206,208/210,216,218,238/240 and 242 (10 labs)
Laboratory C Section: Labs 325 (mezzanine released), 401,403,405,407,409/411 and mezzanine,413 and mezzanine,415 and j
mezzanine),441,443/445 and mezzanine (12 labs) j Laboratory A Section: Labs 511,513,517,605,607,615,617,619/ 621 and mezzanine,623 and 645 (11 labs).
W The.nalerground storage tanks were removed in 1984. A report dated 2/11/85 provides the results ofsoil samples collected in each area where tan ks v ere removed. Official release to unrestricted use from the NRC and the State of CA has not been obtained (as of 9/25/96).
j i
W Summary of Approaches:
{
Approach A:
Removal of radioactive material sources Only. No contamination expected or likely. Confirmatory or Scoping Survey needed. If no contamination is found, no further action is needed.
Approach B:
Minor facility cleanup required including scabbling a small area of concrete.
Approach C:
Major cleanup required including aggressive D&D oflarge areas. Facility contamination is widespread.
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+CEM!RAL AT10MN"5
- 6. PLANNED FINAL RADIATIONSURVEY The purpose of a Final Radiation Survey is to demonstrate that the radiological condition of the Site and Facility are at or below established release criteria in anticipation of State and NRC approval of license amendments removing a facility as a location to handle licensed materials and remove restrictions from use of a facility or property and permit its unrestricted use.
The Planned Final Radiation Survey discussed in this chapter deals with release of the facility and any facility yard areas to unrestricted use following removal of extraneous equipment and removal of identified contamination through the most cost-effective means necessary. Specific l
release criteria for surface contamination, soil and other bulk materials are included in this chapter. The anticipated final survey needed for each facility was provided in the summary Table S-1. During actual decommissioning the classification may change based on characterization survey results. GA has developed the Final Survey Plan using the guidance presented in the NUREG/CR-5849. '
6.1 Release Criteria foritems, equipment and Facility This section provides the specific criteria for release of items, materials and equipment and the facility. These criteria are shown in Table 6-1. The beta / gamma emitter release criteria shown in Table 6-1 can be applied for Sr-90 if it is in mixed fission products that has not been technologically enhanced above what would be expected to be present due to fission yields and
,adioactive decay.
6.1.1 Release of items and Equipment All materials leaving a facility Restricted Area will be surveyed to ensure that licensed materials are not inadvertently released from the Facility. Applicable decommissioning project and GA HP procedures will be adhered to in performing these evaluations. These evaluations will include the following types of evaluations.
Materials and Eouioment-Direct frisk (p-y and a) with portable detectors and/or indirect survey for smearable activity will be conducted as needed using appropriate instrumentation typical of those provided in Table 4-1. Materials and equipment will be released in accordance with GA and Project HP procedures in accordance with criteCa specified in GA's NRC (SNM-696) and
~
j State of California (0145-80) licenses. Those criteria are summarized in Table 6-1.
Items painted with other than original manufacturer's paint will be reviewed on a case-by-case basis. Normally, the item will be assumed to be contaminated unless process knowledge demonstrates that the paint was applied to a clean, non-radioactive surface prior to use in the Restricted Area or an acceptable survey (i.e., paint sampling and analysis and/or fixed readings before and after paint was removed) demonstrates that levels are below the release criteria.
If the potential exists for contamination on inaccessible surfaces, the equipment will be assumed to be internally contaminated unless (1) the equipment is dismantled allowing access i
j NUREG/CR-5849, Manual for Conducting Radiological Surveys in Support of License Termination, Draft for Comment, June 1992.
2 6-1
CENERAL MEMWes for surveys, (2) appropriate tool or pipe monitors with acceptable detection capabilities are utilized that would provide sufficient confidence that no licensed materials were present, or (3) it may readily be concluded that surveys from accessible areas are representative of the inaccessible surfaces (i.e., surveying the internal surface from both ends of a straight pipe from a non-radioactive process system with cotton swabs could be representative of the inaccessible areas).
6.1.2 Release of a Facility The acceptable surface contarnination levels (above background levels) for facilities are provided in Table 6-1. Appropriate background levels for each type of surface will be established.
GA may apply the soil release criteria for asphalt, concrete, or other similar construction media that have been reduced to rubble.
6.1.3 Description of Final Radiation Survey Plan Once all identified affected areas are evaluated and cleaned up as necessary, a final radiation survey must be performed to demonstrate compliance with the release criteria.
Each handling area (or group of handling locations) will have a formal survey plan developed prior to initiating final release survey. The survey plan will describe the survey design in detail. A well-documented survey plan will be the basis for meeting these objectives and will be prepared prior to performing the final survey. The plan will vary for each facility and will be based upon the physical characteristics of the facility, site, or laboratory being surveyed. These characteristics include the number and size of buildings, type of building construction, building or lab condition, total area, and structures (including overhead structures) in each room. Features such as ceiling height, ducts, piping, lights, drain lines and walls surfaces will be considered in determining the number and type of sampling required to demonstrate compliance with the release criteria.
The plan will include, (1) a list of the types, numbers, and locations of measurements and samples to be obtained; (2) information on the equipment and techniques to be used for measuring, sampling, and analyzing data; and (3) the methods to be used to interpret and evaluate the survey data.
An example of a survey plan completed for the General Atomics Group 8B labs N provided at the end of this chapter and is representative of what is prepared for release ofInoratories.
GA will prepare individual detailed survey plans for each facility or group oflaboratories and will advise NRC of the schedule and the availability of these survey plans for their review upon request.
6-2
i CENERAL AFOAWCS Table 6-1: ACCEPTABLE SURFACE CONTAMINATION LEVELS '
Nuclides' Average Maximum *"
Removable **'
6d 2
2 2
(dpm/100cm )
(dpm/100cm >
(dpm/100cm )
U-nat, 2"U, 23 U, & associated decay 5,000 a 15,000 a 1,000 a products Transuranics, 226Ra,22:Ra, 2"Th, 22 Th, 100 300 20 23'Pa, 227Ac '25g,12,g Th-nat, 222Th, "Sr, 22'Ra, 22'Ra, 2'2U, i2*l, 1,000 3,000 200
"'!,"'I Beta / gamma emitters (nuclides with decay 5,000 15,000 1,000 modes other than alpha emission or spontaneous fission) except "Sr and other noted above.
a Where surface contamination by both alpha-and beta / gamma-emitting nuclides exists, the limits established for alpha-and beta / gamma-emitting nuclides should apply independently, b As used in this table dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appropriate detector for background, efficiency, an geometric factors associated with the ir.; rumentation.
c Measurements of average contaminant should not be averaged over more than I square meter. For objects of less surface area, the average should be derived for each such object.
d The maximum contamination level applies to an area of not more than 100 cm,
2 e The amount of removable radioactive material per 100 cm of surface area should be determined by wiping 2
that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency. When removable contamination on objects ofless surface area is determined, then pertinent levels should be reduced proportionally and the entire surface should be wiped.
f The average and maximum radiation levels associated with surface contamination resulting from beta-gamma emitters should not exceed 0.2 mrad /hr at I cm and 1.0 mrad /hr at I cm, respectively, measured through not more than 7 milligrams per square centimeter of total absorber.
Guidelines For Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses For byproduct, Source, or Special Nuclear Material USNRC, July 1982, incorporated into GA's SNM 696 license.
6-3
i: a ~
A CEUNRAL 1
T AFUfMICS 6.1.4 Classification of Areas by Contamination Potential i
l The survey will be designed so that areas with higher potential for contamination receive a higher degree ofsurvey effort, the process will be both effective and eflicient. Four (4) classifications of the types of surveys anticipated for each facility have been identified and provided for each facility in Table S-1.
s These are (1) "non-impacted areas", (2)" scoping or confirmatory survey", (3) " unaffected area survey",
l and (4)"affected area survey" which is subdivided into "non suspect affected area survey" and " suspect l
affected area survey". These classifications are defined as follows:
i i
4j' 6.1.4.1 Non impactedArea Areas that have no reasonable potential for residual contamination do not need any level of survey coverage and have been designated as non-impacted areas in Table S-l. These areas have no radiological impact from site operations, have never been used for work involving radioactive materials and are isolated from areas where any activities involving radioactive materials were conducted.
i Background reference areas are typically selected from non-impacted areas.
i i
6.1.4,2 Scoping or Confirmatory Survey 4
The scoping or confirmatory classification is intended for locations where there is no present use of 8
radioactive material or known contamination (see Table S-1 for facilities / sites where a scoping or confirmatory survey is needed). The type of survey needed will vary with each facility and must be done on a case-by-case basis.
1 1,
l 6.1.4.3 UnafectedArea Survey Definition-All areas not classified as "affected"(including "non-suspect affected" and " suspect
}
affected") are considered " unaffected." These areas are not expected to contain residual radioactivity based upon a knowledge of site history and survey.information. Table S-1 shows the facilities / sites i
anticipated to be classified as unaffected areas. An area's classification may require changing based on j'
accumulated survey data.
1 j
Gridding - Unaffected areas do not require gridding for the purposes of establishing measurement or l
l sampling locations; however, grids systems may be used in order to facilitate referencing of survey locations in those areas to a common site reference system.
j-Scanning - Unaffected area surveys will include a scan of approximately 10% of the accessible surface 1
area comprising floors and walls below 2 meters.
?.
l Measurements - A measurement is either (1) a ")lxed" measurement representing total activity or (2) a i
wipe representing removable activitv. The number of measurements will be based in part on the size of
'[
the area being surveyed. The minimum number of measurements per survey unit will be:
I i
i 6-4 l
i i
1
i A camsurm.
o aronnes Survey units < 1500 m A minimum of 30 measurement locations 2
Survey units 21500 m2 A minimum of 1 measurement for each 50 m 2 Identification of activity levels in excess of 75% of the guideline, as determined by measurements, will require investigation for possible reclassification of the area to the "affected"(non-suspect affected or suspect affected) category.
Exoosure Rate Measurements - Exposure rate measurements will be performed at approximately evenly-spaced intervals throughout the lab or facility. The number of measurements will be determined by the size and history of the area. At a minimum, an exposure rate measurement will be performed every 10 2
m floor area, i
Outside Surveys for Unaffected Areas (Concrete or Asohalt Surfaces)- Outside surveys for unaffected concrete or asphalt surfaces will be uniformly scanned for radiations from the radionuclides ofinterest.
Spacing intervals between scanning paths will be such that a minimum of approximately 10% of the surface is scanned. Exposure rates are not to exceed 10 micro-R/hr above background at I m above the surface (concrete or asphalt surfaces). For open areas, exposure rates (measured at 1 m above the surface) can be averaged over 100 m grid areas. The maximum exposure rates over any discrete area 2
may not exceed two times the limit above background.
6.1.4.4 AffectedAreaSurvey An affected area is any area which has the potential for radioactive contamination based on plant operating history, known radioactive contamination or previous radiological surveys. Affected areas are further subdivided into non-suspect affectedand suspect affected areas.
Non-Sumect Afrected Area Survev Definition - This designation is assigned to ceiling and wall surfaces above 2 meters within an affected survey unit where it was not expected that the average removable or total surface activity would exceed 75% of the guideline values. This designation may also be assigned to other surfaces (such as the outer walls of buildings, external piping of a building, and roofs) unless the surface meets the criteria for a suspect affected survey unit. This classification may also be assigned to areas where licensed materials were used in the past but contamination is not likely due to the types of activities and preliminary surveys performed in the area. For example, a laboratory in Building 2 which has not been used for work involving radioactive materials in over 10 years and where surveys indicate the lab is not contaminated.
Gridding - Non-suspect affected areas do not require gridding for the purposes of establishing measurement or sampling locations; however, grids systems may be used in order to facilitate referencing of survey locations in those areas to a common site reference system.
I Scanning - Non-suspect affected area surveys will include a scan of approximately 10% of the accessible surface area comprising floors and walls below 2 meters. Scanning above 2 meters (upper walls and ceilings) is not necessary because direct and removable measurements will be performed as described j
below.
6-5
+ ggpassarmt t
N Measurements - A measurement is either (1) a " fixed" measurement representing total activity or (2) a wipe representing removable activity. The number of measurement locations will be based in past on the size of the area being surveyed. The minimum number of measurements per survey unit will be:
For survey units 5 600 m A minimum of 30 measurement locations 2
For survey units > 600 m A minimum of 1 measurement location for each 20 m2 I
2 Identification of activity levels in excess of 75% of the guideline, as determined by measurements, l
will require investigation for possible reclassification of the area to the " suspect affected" category.
l
' Exoosure Rate Measurements - Exposure rate measurements will be performed at approximately evenly-l spaced intervals through the lab or facility; the number of measurements will be determined by the size l
and history of the area. At a minimum, an exposure rate measurement will be performed approximately 2
every 10 m floor area.
I l
Outside Survevs for Non-Susoect Affected Areas (Concrete or Asohalt Surfaces)- Outside surveys for l
non-suspect atTected concrete or asphalt surfaces will be uniformly scanned for radiations from the radionuclides ofinterest. Spacing intervals between scanning paths will be such that a minimum of approximately 10% of the surface is scanned. Exposure rates are not to exceed 10 micro-R/hr above background at I m above the surface (concrete or asphalt surfaces). For open areas, exposure rates (measured at I m above the surface) can be averaged over 100 m grid areas. The maximum exposure 2
rates over any discrete area may not exceed two times the limit above background.
?
Susvect Affected Area Survev Definition - This designation is assigned to the floors and wall surfaces below two meters if they are j
known or suspected to be contaminated. It is also assigned to other surfaces known or suspected to be l
l contaminated. This would normally include areas where radioactive materials in a form which could become airborne was used, where liquid radioactive materials were handled, and where records indicate spills and other unusual occurrences that could have resulted in spread of contamination. This could also
{
include areas immediately surrounding, or adjacent to, these areas because of the potential for inadvertent spread of contamination.
Gridding - A grid consists of a system ofintersecting lines, referenced to a fixed site location or bench j
. mark.- Grids are established at the site to (1) facilitate systematic selection of measuring / sampling locations, (2) provide a mechanism for referencing a measurement / sample back to a specific location so that the same survey point can be relocated, and (3) provide a convenient means for determining average l
activity levels. Gridding is required in suspect affected areas unless it is not feasible. For example, interior structural surfaces, system piping, portions ofinterior walls, where interferences exist and are i
not expected to be removed and for small areas, i.e., a 3m by Sm lab (unless decontamination was l
necessary to meet the guideline values).
For surveys of structures the basic grid system for affected areas is a lm by im grid. For surveys of l
outside areas, the basic grid system is 10m by 10m or 5m by Sm. Gridding inside structures may be r
6-6 i
1
+CENERAL ATOMICS limited to the Door and lower (up to 2 m height) walls. Survey locations are referenced to the grid system; surveys of ungridded surfaces are referenced to the door or to prominent building / area features or landmarks. The grids described above are intended primarily for reference purposes, and although grid intersections are the locations where measurements or samples are normally collected, they do not necessarily dictate the spacing of survey measurements or sampling.
Scannine-Scans of approximately 100% of the accessible suspect affected area (normally the floor and 2 m up the wall) will be performed for all radiations which may be emitted from the radionuclides of interest. Locations of areas of elevated activity will be identified and direct measurements will be taken at these locations. Residual activity above the release criteria will be remediated until the release criteria is satis 0ed.
For upper walls and ceilings that are classi0ed as suspect affected areas, a reasonable effort will be made to survey at least 25% of the suspected contaminated surfaces. Additional survey coverage is needed if levels detected are 2 75% of the limits is detected on any of the surfaces. Survey coverage may also be modined based on as assessment of the situation. For example, if contamination has been detected only on I-beams or other Hat horizontal surfaces and generally not on vertical surfaces, then a reasonable effort to survey approximately 100% of the dat horizontal surfaces will be made and an attempt to survey at least 10% of vertical surfaces will be made.
Measurements - A measurement is either (1) a " fixed" measurement representing total activity or (2) a wipe representing removable activity. The number of measurement locations will be based in part on the size of the area being surveyed. The minimum number of measurements per survey unit will be:
For survey units < 20 m A minimum of 30 measurement locations 2
For survey units 2 20 m A minimum of I measurement location for each 20 m:
2 In addition, in suspect affected areas, the survey plan must incorporate additional sampling points specific to each area and developed on a case-by-case basis. This will include consideration for survey of overhead structures (including lights,1-beams, piping, ducts, vents, and other structures), survey of drains, etc.
Exnosure Rate Measurements - If gamma emitting radionuclides are among the potential contaminants, exposure rate measurements will be taken approximately every 4 m of accessible Door 2
area. If potential contaminants did not include gamma emitters, exposure rate measurements will be performed at a minimum spacing of 1 measurement per 10 m,
2 Outside Surveys for Affected Areas (Concrete or Asohalt Surfaces)
Exposure rates are not to exceed 10 micro-R/hr above background at I m above the surface (concrete or asphalt surfaces). For open land areas, exposure rates (measured at I m above the surface) can be averaged over 10m by 10m grids. The maximum exposure rates over any discrete area may not exceed two times the limit above background. It is GA's intent to remediate all areas where micro-R readings exceed 10pR/hr at I m above the surface. However, in the event that reasonable efforts have been made and measurements continue to remain elevated, GA may apply the averaging criteria described above to determine compliance.
6-7
4 CENERAL o AFOANCS 6.2 SoilSamplingPlan The objective of soil sampling is to demonstrate compliance with approved soil release criteria. This plan was developed using the guidance in NUREG/5849.2 6.2.1.
Release Criteria l
Soil Concentration Limits Table 0-2 shows release criteria based upon the most limiting pathway for a variety of radionuclides that may be encountered on the GA site (or those that conceivably could be encountered). Decommissioning projects at GA over the past 12 years have shown that the predominant contaminants on the GA site are Cs-137, Co-60, enriched uranium and thorium.
The soil concentrations are acceptable values above normal background levels.
if additional nuclides are encountered during the remediation or Final Release Survey activities, their respective release criteria would be determined in the same manner as the values provided above.
i If more than one radionuclide exists, the sum of the fractions must be less than one in order for the soil to meet the release criteria. The sum will be calculated as follows:
C E" d L,
- s.,
C, The average soil concentration of radionuclide 1.
=
l L,
The maximum soillimit for I (pCl/g).
=
Exoosure Rate Limits Exposure rates are not to exceed 10 microR/hr above background at 1 m above the surface.
For open land areas, exposure rates (measured at 1 m above the surface) can be averaged over 100 m grid areas. The maximum exposure rates over any discrete area may not exceed two times the limit above background.
6.2.2 Soil Background Concentrations t
2 Manual for Conductirig Radiological Surveys in Support of License Termination (Draft for Comment), NUREG/CR-5849, ORAU-92/C57, Oak Ridge Associated Universities, June 1992.
6-8
i CmlMRAL m
Typical soil concentrations are provided in the table below which represent the average results t
. of seventeen (17) surface soil samples and ten (10) concrete samples collected in undisturbed j
areas from the region surrounding the GA site.
1 Media Type Cs 137 U-238 U-235 Th-232 (pCilg)
(pCilg)
(pCilg)
(pCilg) l Soil 0.21
- 0.20' 1.26
- 0.78 0.0810.04 1.72 i 0.92 l
Concrete 0.04 iO.02 4.27 *0.63 0.12 i 0.03 3.62 10.24
{
6.2.3 Unaffected Areas - Open Land Surveys Unaffected open land area will be uniformly scanned for radiations from the radionuclides of l
interest. Spacing intervals between scanning paths will be such that a minimum of 10% of the 4
l-surface is scanned.
i identification of hot-spots or individuallocations with activity levels in excess of 75% of the guideline value requires reclassification of the area as "affected".
t 1
6.2.4 Affected Areas - Open Land Surveys i
i j
Grounds and open land areas classified as affected areas are gridded at 10 meter intervals.
As with structure surfaces, GA will perform approximately 100% coverage of affected open land areas (soil). Scanning will be performed to identify locations of elevated activity levels, i
Areas of suspected elevated activity, identified in this manner, are evaluated by sampling and analyses to determine their activity level and extent of contamination, and results are compared j
with criteria, cleanup is performed, as required, and scanning repeated. After scanning has i
indicated the guidelines and conditions have been satisfied, systematic soil sampling of each i
affected area grid block is performed at locations equal distant between the center and each of j
the four grid block corners or on a 5 meter triangular grid system recommended by EPA i
procedure (EPA 1989) for a 95% assurance that elevated areas in excess of 10 m surface 2
area are identified.
If scanning is not capable of detecting surface areas with activity levels s 75% of the guideline i
values for the radionuclides ofinterest, the 5 meter triangular grid system will be used.
4' l
}
Exposure rates are measured at 1 m above the surface on the grid pattern.
4 f
Underneath a concrete slab 1
In cases where contamination is suspected undemeath a concrete slab, biased samples will be collected from undemeath the concrete slab (under cracks and/or drains where the soil appears i
affected; i.e., discolored, odiferous or otherwise abnormal or suspected of contamination).
i Scanning (along the surface of the soil) will be performed to identify locations of elevated 1-4 i
6-9
~
CENERJiL ATDMWK activity levels. Areas of suspected activity, identified by scanning or visual inspection, will be evaluated te determine their activity levels and the extent of contamination. Cleanup will be performed, as required, and the scanning repeated until remediation is accomplished as demonstrated by additional soil sampling, analysis and comparisons with the guidelines.
I After scanning and remediation of known contaminated areas, systematic soil sampiing will be performed on a triangular grid with a sampling interval of 5 m on a side. Additional reme will be conducted if release criteria are not met. If elevated area (areas above are identified during the Unal survey, they will be evaluated for acceptability using NUREG/CR-5849 averaging methods, regardless of whether or not remediation will be conducted.
Underneath drain ling.ti If underground drain lines are removed and samplir'g is needed (i.e., in trenches created durin removal of potentially contaminated drain lines), biased samples will be collected as follows:
Soil samples will be collected from underneath and around any drain lines which 1) appear broken, corroded or otherwise deteriorated.
Soil samples will be collected whenever exposure rates are elevated (measured 2) using microR meters and/or Nal (TI) detectors /ratemeters).
Soil sampes will be collected if the soit appears affected, i.e., discolored, 3) odiferoue or otherwise abnormal.
In addition, systematic samples will be collected approximately every 5 m (about every 15 fee from underneath the drain lines.
Lubsurface Samoles Remediation of soil will continue to a depth required to reduce the concentrations to levels below the release criteria. A final sample (s) after remediation will demonstrate that residual activity is below the release criteria.
Subsurface samples underneath the concrete slab may be collected to a depth of three (3) fe Subsurface samples will be collected in biased locations and will include: 1) each location (larger than 5 m ) where soil contamination above the guide:ines was discovered and remediated and 2) any location where exposure rate measurements were elevated (greater than two times the extemcl radiation exposure limit, above background). These measuremen will be made using a microR meter or Nat (TI) detector /ratemeter.
Subsurface samples may also be collected undemeath drain lines as necessary to assure th subsurface contamination above the release criteria does not exist. Normally, subsurface sampling in affected areae where drain lines were removed will be conducted every 20 f depth of 2 feet. Additional sampling at further depths and/or at other locations will be conducted, if contamination above the release criteria is present or suspected.
6-10
+SENWIFAL N
i
~'.
Subsurface aamples may a!so be collected in other suspect locations, if warranted by exposure rate me,asu cments or remediation efforts.
r Outside Areas of f;uildinas Scanning (along tt e surface of the soil) will be performed in all exposed soil locations to identify locations of elevated activity levels. Spacing intervals between scanning paths should be such that approximately 100% of the surface is scanned.
6-11 a
&o CENERAL
~
AFOANCE Table 6 2-Soil and Concrete / Asphalt Rubble Release Criteria' Isotope Release Criteria Based upon Release Criteria Based upon External Exposure Limitations Internal Exposure Limitations (pCi/g)
(pCi/g)
'"Co 82
'3*Cs 10 "7Cs 152 n2Eu 11 l
"*Eu 10
'"Eu 635
N b 7.5 i2*S b 37
'"Sr 18002 j
23'Pu 26*
23'Pu 27' 24uPu 2 74 24'Pu 4326*
242Pu 28*
244Pu 28' 2*'Am 2 54 4
Natural Uranium 1 02
)
Depleted Uranium 35' Enriched Uranium 3 02 1
(234U & 2"U)5
)
Thorium (232Th & 22'Th) 10)
' The release criteria shown in this table without annotation by footnotes 2,3, or 4 were calculated by the licensee using RESRAD version 5.18 adhering to the same assumptions that were provided in the correspondence listed in note 2, below. This corresponds to conservative calculation of the homogenous concentration of an isotope in the soil that by itself would give approximately 10 R/hr external exposure rato above background for the maximum year of exposure. It is the licensee's intent to apply criteria from this table to concrete, asphalt, or similar construction media materials that have been ground to a coarse l
rubble. These criteria were approved by the NRC for the Hot Cell Decommissioning project by letter dated May 1,1996, Robert C. Pierson to K. E. Asmussen.
' These reka:e criteria are based upon past precedent through NRC and State of California approved release limits for the GA site. See Correspondence K. E. Asmussen to W. T. Crow, dated October 1,1985, j
correspondence identification 696-8023,
Subject:
" Docket 70-734: Plan for Obtaining Release of Certain i
Areas to Unrestricted Use."
I 3 These release criteria are based upon past precedent established by NRC through NRC Policy issue SECY-81-576, dated October 5,1981,
Subject:
" Disposal or on-site storage of residual thorium or uranium (either as natural ores or without daughters present) from past operations."
- Numbers were established using the most limiting oflung dose (20 mrem /yr) or bone dose (60 mrem /yr) using Dose C onversion Factc s from NUREG/CR-0150, Volume 2, with an alpha quality factor of 20, where applicable, lung mass of $80 grams, and AMAD of 1.0.
' For enriched uranium, GA shall determine the U-234:U 235 ratio by uranium isotopic analysis and then use gamma spectroscopy results of U-235 to demonstrate compliance with the release criteria for enriched uranium.
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1 A C2NHAL r
T ATOMICS 6.2.5 Sample Collection A 15 cm " surface" soil sample will be collected with a sample size of approximately 1 kilogram.
The sampling locations will be identified on drawings. The samples will be properly logged, labeled, packaged and tracked. All debris (grass, rocks, sticks, and foreign objects) will be removed from the sample. Samples will be dried and counted by gamma spectroscopy.
Results will be reported in pCi/g for each radionuclide.
Shallow sampling may be conducted using manual equipment (post-hole diggers, small-diameter split barrel or Shelby tube samplers, and portable hand-operated or motorized j
augers). For depths below several meters, heavier equipment, such as a drill rig with an auger and/or a core sampler will be required.
i 6.2.6 Direct Radiation Measurements To determine compliance with the external radiation limit of 10 microR/hr at 1 m above the surface, exposure rate measurements will be taken at 1 meter at all systematic soil sampling locations (after soil remediation has been completed). The results will be compared with the release criteria shown in Table 1 (and discussed above).
A calibrated microR meter will be used to determine exposure rate measurements in microR/hr.
It is GA's intent to remediate areas containing elevated activity levels in the soil. However, in the event that reasonable efforts have been made and soil concentrations continue to remain elevated, GA may establish the guideline that areas of residual activity exceeding the guideline value, known as " elevated" areas, are acceptable, provided they do not exceed the guideline value by greater than a factor of (100/A)'d, where A is the area of residual activity in m, and 2
provided the activity level at any location does not exceed three times the guideline values. In addition, radionuclide concentrations will be averaged to demonstrate the average is at or below guideline values, established as acceptable to NRC. Averaging will be based on a 100 2
m (10 m x 10 m) grid.
6.3 Methods to be Employed for Reviewing, Analyzing, and Auditing Data 6.3.1 Laboratory / Radiological Measurements Quality Assurance During decommissioning survey activities, many direct and indirect measurements and sample media samples will be collected, measured, and analyzed for radiological contaminants. The results of these surveys will be utilized to evaluate the suitability of the material or item for release to unrestricted use, or whether decontamination of structures, components, and the surrounding site have achieved the desired result. Sample collection, analysis, and the associated documentation will adhere to written procedures and meet the guidance of the NRC.
Outside (i.e., non-GA) laboratories selected to analyze facility decommissioning samples will be approved by the GA Quality Assurance organization and listed on the Non Safety-Related QA Suppliers List or other similar document maintained by the GA Quality Assurance Department.
Quality control records for laboratory counting systems will include the results of measurements of radioactive check sources, calibration sources, backgrounds, and blanks. Records relating to overall laboratory performance willinclude the results of the analysis of quality control samples such as analytical blanks, replicates, and other quality control analyses.
6.3.2 Supervisory and Management Review of Results 6-13
cannnEAL AFOANCE 4
Radiological surveys are conducted by HP Technician staff members who are trained and qualified in accordance with General Atomics
- SNM and State of California Byproduct Material License. In addition, radiological surveys and sample results are reviewed by the HP Management or designated Health Physics Technician (other than the individual that performed the survey).
6.4 Final Survey Report All survey results will be documented and provided to the Nuclear Regulatory Commission and the State of California in a final report. Nole: For areas where remediation was conducted, the i
report will include the results of surveys conducted prior to the area being remediated as well as the final survey results.
4 l
}
s S
d 1
i 4
6-14
~
,~
t Example Survey Plan (from Group 8B Labs Final Report) 635/637/639 Type of 506 506A 508 508A 515 5191521 523 530/532 635 6371639 Mezzanine Survey 144 ft' 132 ft 2 144 ft' 121 ft 2 2ss ft:
576 ft2 2
1ss rt 576 ft 312 ft2 648 ft2 663 ft2 X-ray diffraction and electron Two gamma lon Ar-41 gas. Sealed Pu-238 sources.
microscopy of samples containing U.
No history of ca ibration No history of accelerator U-235, U-238 and/or thorium in the History of 235, U-238, thorium and/or depleted radioactive sources used to radioctive calibrate used. Last form of metal, fuel particles and/or Use uranium. Last used 12/95 material mtedal gamma r b t used in fuel compacts. Used for rad work u e-use-g ggg, l upM 1982-used for rad work unta 1986.
g _
Floor 100%
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No a scan Floor 100%
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No pscan Lower Walls Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes (boMom 2m) 100% 0 scan Upper Walls Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
-10% D scan
- of Fixed 32 15 27 10 28 12 27 28 (2 min)
(2 min)
(5 min)
(2 min)
(5 min)
(5 m;n)
(5 min)
(5 min)
- of Paint 4
None 4
4 4
None 4
4 2
None None Samples (original (original or no (original (original or no p int)
- 1-4 ain)
(#9-12)
(#5-8)
(#13-16)
- 17-20
- 21-24
- 25-26 pa n )
- of Smears 72 26 56 36 60 28 60 64 (see List)
ON 6-15
i l
635/637/639 Type of 506 506A 508 508A 515 5191521 523 530/532 635 637/639 g,
Survey 144ft' 132 ft 2 144 ft*
121 ft 2ss rt*
576 ft2 2
a 168 ft 576 ft:
312 ft:
648 ft2 663 ft2 X-ray diffraction and electron Two gamma non Ar-41 gas. Sealed Pu-238 sources microscopy of samples containing U-No history of calibration No history of l ata,eleratorU-235, U-238 and/or thodum in the History of 235, U-238, thorium and/or depleted radioactive sources used to radioctive used. Last form of metal, fuel particles and/or Use uranium. Last used 12/95 material c librate tenai gamma robot l used in fuel compacts. Used for rad work 9 e' ue f fnt 1 1986.
until 1982.
- of MicroR 4
4 4
4 8
16 6
16 8
16 16 Readings
& Scan entire surface Floor Above None None None None None None None None None None Drains?
Gy,"d drain Floor Concrete Surface
- % concrete Concrete unoieum unoieum concrete concrete Wood Sur' ace
-% iinoleum Total # of 104 41 83 46 88 40 87 92 ueasurements (Fixed Measurements &
smears) l l
+
ll 6-16
. = -
~_.
j e
& CENERAL
\\
j t ATOMICS l
l Example Survey Plan (Detailed Locations of Fixed Measurements and Smearsl Laboratory Fixed Measurements Smears Labs 506, 506A, Fixed Measurements (32)
Smears (72) 508 and 508A 12 Floors - 3 in each room 20 Floors - 5 in each room 16 Walls - 1 on each wall (4) of each 16 Walls - 1 on each wall (4) of room (4) each room (4) 1 Inside Square Duct in Lab 506A 10 Blinds in 508 1
Inside Round Duct in Lab 508 8
Light fixtures (2/ room) 1 inside Square Duct in Lab 508 4
Ducts in 506A 1
On top of drain in 506 (drain is above 2
Ducts in 508 ground) 6 Ducts in 506A 2
1-beams in 306 1
Above ground drain in 506 3
Exhaust Vents 4
Lab 515 Fixed Measurements (15)
Smears (26) 5 Floor 10 Floor 4
Walls (1 on each wall) 8 Walls (2 en each wall) 4 Lights (2/ light) 4 Lights (2 on each lignt) 2 l-Beam 2
1-Beam 1
On Vent 1
Top of the closed duct Labs 519/521 Fixed Measurements (271 Smears (56) 10 Floor 20 Floor 8
Walls (2/ wall) 16 Walls (4 per wall) 3 Each opening of the duct 6
Duct (one in each of 3 4
Lights (one on each) penings and 3 on top of the ditet) i box (on wall) 8 Lights (2 perlight) 1 Round exhaust duct in wall) 3 Wall exhaust ducts ( square duct, round duct and exhaust vent out) 3 l-beam l
l l
6-17
e e
A smummu r.
o aranses i
Example Survey Plan (Detailed Locations of Fixed Measurements and Smears)
Laboratory Fixed Measurements Smears l
Lab 523 Elstd Measurements fic)
Smears (361 4
Floors 12 Floors 4
Walls (one per wall) 4 Walls (one per wall) 2 Lights (one per light) 4 Lights (one per light) 8 l-beams 8
Window ledge Labs 530/532 Fixed Measurements (28)
Smears (60) 16 Floors 20 Floors 4
Walls 16 Walls 2
I beams 4
l-beams 2
Inside ducts 8
Light Fixtures 4
Lights (1 each light) 10
' Hood Umbrella" 2
Roof Drain (drain goes through the lab only - no entrance or exit to lab)
Lab 635 Fixed Measurements (12)
Smears (28) 5 Floor 10 Floor 4
Walls 8
Walls (2 per wall) 1 Inside the large duct 6
Ducts (2 inside each duct) 1 Square duct 4
Ducts (top of ducts) 1 Inside the open vertical duct Labs 637/63g Fixed Measurements (27)
Smears (60) 16 Floor 20 Floor 8
Walls (2 per wall; 1 on unpainted 16 Walls (4 per wall) area,1 on painted area - no paint 10 Stairway samplas are needed) 2 Handrail 1
Top of the electrical panel 12 Inside of ducts 2
Ducts l
l 6-18
A CENERAL T AFOASES Example Survey Plan (Detailed Locations of Fixed Measurements and Smears)
Laboratory Fixed Measurements Smears 635/637/639 Fixed Measurements (281 Smears (64) enanine 20 Floor 20 Floor 4
Walls (2 per wall) 4 Walls (2 per wall) Note: one 1
Duct wallis windows and the other wallis part oflowerlabs.
2 l-beams 4
Railing i
Lights 4
16 Blinds (4 on each of the 3 i
large blinds; 2 on each of the 2 small blinds) 8 l-beams 4
Lights 4
Inside ducts l
4 Top of ducts 6-19