ML20148D403

Forwards Comments in Response to NRC Comments Concerning Clevite Remediation Plan & Clevite Characterization Survey Summary

ML20148D403
Person / Time
Site:	07000133
Issue date:	10/15/1996
From:	Grube R SEVENSON ENVIRONMENTAL SERVICES, INC.
To:	Buckley J NRC
References
NUDOCS 9705300193
Download: ML20148D403 (4)

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'C SEVENSON ENVIRONMENTAL SERVICES

-I l 5 FRANKUN AVENUE MONTCLAIR, NJ 201 744 1221 fax: 201 744 52O3 l

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l October 15,1996 l

l John T. Buckley Nuclear Regulatory Commission Washington, D.C. 20555-0001 l

Mr. Buckley:

l I am writing in response to the comments generated by your office concerning the Clevite Remediation Plan and the Clevite Characterization Survey Summary.

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l have enclosed the comments and I have answered each comment on a table that is also attached.

Please feel free to call me if there is any additional questions or comments.

Thank you, 9

l Rory M. Grube Radiation Safety Officer cc:

Kim Licilield i

J. Cronmiller J. IIouse

}blD D. Moser R. Pierce l

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Comment Comment Response No.

General A new characterization report is being generated for your review. This report will contain how the surveys were performed and how the data will be used to support the remediation.

1.0 N/A 1.1 A characterization report is being generated. All data will be summarized and maximum and average surface activities as well as exposure rates will be included.

1.2 The characterization report will describe the method for collecting characterization data.

1.3 Yes, isotopic analyses have been performed to identify the isotopes comprising building surface contamination. This information will be included in the characterization report. The remediation plan willjustify the applicable release criteria, specifically, in terms of alpha and beta radiation.

1.4 N/A 1.4.1 The unusual alpha to beta ratio can be attributed to the methods used for survey area preparation. Sevenson removed tile, glue, paint, etc. that was added after the time that the facility was originally surveyed. During the course of removal it is believed that all of the surface contamination was removed leaving only contamination in cracks crevices and depressions in the surface. Because of the increased distance from the probe and any residual material it is not unreasonable to have an abnormal alpha to beta ratio.

1.4.2 This is attributed to the techniques of scme of the technicians perfbrming the surveys. During the scan surveys the technicians would scan and determine that the levels were above the release criteria but would not continue to search for the highest reading. When the technicians would return to the grid to perfonn the direct reading they would tearch out the absolute highest reading and perform the direct reading a', that location.

1.4.3 This error is caused by incorrect background information. We have found that background rates vary with different materials found on site. We have established a background rate for each of the different structural materials and we are applying this to the data collected. We will submit this infbrmation with the characterization report.

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1.4.4 It appears that the information has not been disseminated correctly. We have mad < p required changes and will re submit the information.

1.5 This.nfo'mation was included in a change that was submitted. We will resubmit the information.

2.0 N/A 2.1 The characterization report will clarify how the characterization data will support remediation activities. The areas to be remediated will be determined after the new backgrounds have been applied to the original data.

2.2 The remediation plan will clearly identify the applicable cleanup criteria and the comparison between known or suspected contamination levels and the criteria.

The remediation plan will be revised to reflect that unless proven otherwise, the entire site will be remediated and surveyed following the thorium clean-up criteria.

2.3 The site was segregated into affected and unaffected areas survey units for statistical evaluation. This information will be clearly presented in the remediation plan. The final survey section of the remediation plan will describe the survey approach for affected and unaffected areas.

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The remediation plan will clearly designate which areas are to be remediated and therefore require additional final surveys.

2.32)

The remediation plan will delineate the data into survey units for statistical inteipretation and evaluation.

2.33) i he remediation plan will contain quality control procedures for ensuring the validity of the characterization and final survey data.

2.4 The remediation plan will detail the quality assurance measures for data management to ensure the quality of data collection, processing and reporting.

This will include the data management procedures that will ensure appropriate review, correction, validation and approval of the data collected.

2.5 The anomalies noted will be corrected as previously stated. The remediation plan will specify the instrumentation MDA to be used based on the radiologic contaminates present and the detection capabilities of the instrumentation.

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2.6 The remediation plan will clearly specify that the remediation control surveys 4

that are used to direct remediation efforts will not be used as final survey data.

Some areas will only require a resurvey of the remediated area and the adjacent one meter grid blocks. These areas will be identified in the remediation plan.

The areas that have small isolated spots of contamination and the criteria used to determine its classification will be explained in the characterization report. If the contaminated area is not small or if the contamination is scattered throughout the area the entire area will be resurveyed.

2.7 Noted typo. Corrected as stated.

2.8 N/A 2.8.1 This information has been corrected and will be submitted again as stated.

2.8.2 The flow chart has been corrected and will be submitted again as stated.

2.9 Section 3., "ALARA", of the Clevite Remediation Plan Revision, should include an occupational exposure estimate, in man-rem, for each decommissioning activity, and a description of the engineering and administrative controls to keep exposures ALARA.

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August 8, 1996 Mr. Kim W. Lickfield

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Dear Mr. Lickfield:

A The U.S. Nuclear Regulatory Commission has completed its technical review of the Clevite Remediation Plan Revision, dated June 4,1996, and the Clevite Characterization Survey Summary, dated June 14, 1996.

Our comments are attached.

Resolution of these comments should be reached prior to initiating remediation in the West wing of the building.

It may be beneficial to reach verbal resolution during a teleconference prior to submitting a formal written

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response.

This process will reduce the potential for misunderstanding and minimize the delay in remediating the site.

If you have any questions, please call me at (301) 415-6607.

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i hn T. Buckley, Pro ect Manager Low-Level Waste and Decommissioning 4

Projects Branch Division of Waste Management i

Office of Nuclear Materials Safety i

and Safeguards Docket No. 070-00133 (Terminated)

License Nos. SNM-183, C-3692, C-3790, 34-000653-01/02 (terminated) 4 j

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'g U.S. NUCLEAR REGULATORY C0 MISSION'S COMENTS

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ON THE CLEVITE CHARACTERIZATION SURVEY SUMARY AND THE CLEVITE RENEDIATION PLAN REVISION J

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General Cc-nts i

i The Clovite Characterization Survey Summary and select characterization data i

packages were reviewed by NRC staff to evaluate the adequacy of the data as

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characterization survey data and as potential final survey data for those areas that meet the unrestricted release criteria.

The information provided i

in the Clavite Characterization Survey Summary does not sufficiently describe j

how the characterization survey was conducted or how the characterization data will be used to support remediation.

The Clavite Remediation Plan Revision, i

coupled with the last version of the Remediation Plan, does not suffir,iently l-describe the remediation process or the final termination survey.

5 The following comments address staff concerns regarding the adequacy of the informat'on provided in the Site Characterization Summary and Remediati6n i

Plan / Final Survey Plan.

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1.0 characteriration Survev

l 1.1 The information presented in the Characterization Summary does not constitute a Characterization Report.

The Site Characterization Survey / Termination Survey, Remediation, and Health and Safety Plan that was submitted to NRC on May 11, 1995 states that --

j' A report characterizing the site will be submitted to the NRC i

before remediation work commences. This report will summarize all j

data in tabir s... Detailed remediation plans will be submitted

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based on the Characterization Survey"

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The characterization summary does not summarize all survey data; the i

characterization summary outlines survey information on only 24 different areas. The characterization report should characterize the i

extent of contamination in structures and equipment in terms of maximum

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and average surface activities (fixed and removable) per 100 ce and t

exposure rates.

i 1.2 The characterization report should also describe the method for j

collecting characterization data.

For example, it is not clear how the survey data presented in the "[ Beta / gamma) Averaging Survey" data set of j

each data package was obtained or how it is to be used.

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1.3 Have isotopic analyses been performed to identify the isotopes comprising building surface cont %Aination?

If so, please includi in the characterization report. The remediation plan should, justify the l

applicable release criteria, specifically, in terms of alpha and beta radiation.

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1.4 There are a number of anomalies in the characterization survey data.

i Please address each of the items outlined below.

i 1.4.1 The ratio of alpha activity to beta activity as reported in the j

characterization data is unusually low for the ma,jority of data i

p.oints.

The expected alpha to beta activity ratio for thorium and uranium contamination is generally greater than one and will vary depending on the percent enrichment of uranium.

The results from Room #6, West wing show beta activity measurement as high as 265,g30 dps/100 and a corresponding alpha measurement as icw as 710 dpe/100 Either the beta measurements are biased higt j

or the alpha measurements are biased low.

1.4.2 Assuming every area received 100% surface scans for alpha, beta, and gamma activity, it seems unusual that for 8 of the 24 areas l

sumoarized in the characterization summary,, the highest systematic direct measurement for alpha activity was higher than the maximum j

scan survey measurement for alpha. One would expect that a sygtematic alpha activity measurement as high as 4,280 dpa/100 i

cm, as measured in Room #1 of the S.E. Wing for example, would have been detected during the 100% alpha surface scan (the maximum 2

scan measurement for this area is 850 dpm/100 cm ).

NRC staff realizes that surface scans are not necessarily capable of detecting all elevated areas of activity, even for 100% surface 1

coverage. However, for five of the 24 areas presented in this j

summary, the highest systematic alpha measurements are at least 5 times greater than the maximum measurement identified from the g

i scan survey for the same area.

1.4.3 The average net value for survey units considered " clean" or j

unaffected should approximate zero. However, the data for a number of the unaffected survey units indicate an average that is negative. One example of this would the direct beta measurements obtained in Room 5-A on the 1st floor of the West Wing.

The ma,jority of the 53 beta measurements for Room 5-A are either above j

1000 dps/100 cm or negative values. Only five of the direct beta 1

I measurements are between 0 and 1000 dpm/100 cm'. The average of the grid blocks in this room, that yielde than 1000 dpe/100 cm', is -108 dpe/100 cs'p beta measurements less I

This may indicate i

either an error in the measurement technique, an error in data conversion, or a background value that is too high.

1.4.4 During previous reviews of the " Site Characterization i

survey / Termination Survey, Remediation, and Health and Safety Plan", the NRC staff requested that the remediation plan 1)

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demonstrate that the MDA of.the instruments ligted in Table 2 are j

capable of detecting less than 1000 dpe/100 cm (the thorium release limit), 2) provide the procedures for determining i

background, and 3) ensure that the equations for calculating MDA i

are appropriate. These items have not been addressed in the 3

Remediation Plan Revision or the characterization summary.

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ensure appropriate review, correction, validation and approval of the

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data collected.

1 2.5 As stated in Comment #1.4. there are a number of anomalies in the characterization survey data which result in questions regarding the validity of the data. These questions must be addressed before the characterization data is accepted as final survey data for those areas that appear to meet the unrestricted release criteria.

Th plan should also be revised 'in response to these concerns.e remediation the remediation plan should specify the instrumentation MDA to be usedFor exam j

during final termination surveys and the anticipated alpha to beta ratio i

based on the radiological contaminates present and the detection j

capabilities of the instrumentation.

l Soecific Comments i

2.6 Clovite Remediation Plan Revision, Page 1, Paragraph "d" of Section 2.

l Remediation Control Surveys:

This section states, " The [ post work; survey of the work area will include the adjacent 1 meter grid.

i Th's information will be used as the termination survey of the area."

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description does not sufficiently describe the termination survey i

approach that will be conducted of remediated areas. The remediation j

plan should clearly specify that remediation control surveys that are used to direct remediation efforts will not be used as final survey i

j data. Resurveying only the remediated areas and the adjacent one meter grid blocks may be acceptable for areas with a few isolated location of contamination. This approach is not acceptable, however, for areas w

!V many locations of centamination scattered throughout the survey area.ith NRC's position on remediation control surveys is stated in " Manual for i

Conducting Radiological Surveys in Support of License Termination",

NOREG/CR-5849.

It states that a remediation control survey "is intended j

for expediency and do not provide thorough or accurate data describing j

the final radiological status of the site."

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2.7, Asterisk note at the bottom of the page: Should this read i

" Weekly surveys to be every I i 2 days" instead of "t i 2 days"?

i 2.8 Outstanding issues from previous review effort of the " Site Characterization survey Safety Plan" which were/ Termination Survey, Remediation and Health and not addressed in the remediation plan revision.

These issues are:

2.8.1 Health and Safety Plan, Page 30: The occupational and effluent concentration limits listed for Thorium 232 in 10 CFR 20, Appendix B are 5E-13 uti/ml and 4E-15 uC1/ml, respectively.

The plan states that the action levels for air sampling results are 10% of the limits, but the listed action levels are not lot of the above

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concentrations.

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2.8.2 As stated in the June 1,1995 letter from Lentz to Lickfield, NRC wishes to express concern over the flow chart which is untitled i

and identified only as " Figure 4-1."

Without a title, the p.;rpose and scope of the chart is unclear, and there are no direct references in the text of the plan to clarify these issues. We do not believe the chart is terminated properly, in that the

" Identification of Additional Measurements in Each Unit" can be no I

more than a sub-objective at best; completion of site i

characterization, completion of remediation, or completion of the i

temination survey would appear to be more appropriate final 1

objectives for the chart. Also, there is no provision for j

activities if the statistically necessary additional measurements i;

identify previously undiscovered contamination.

Further, we are confused by the decision box " Activity 3 x Skg". NRC knows of no significance to be attached to activity measurements that are i

greater than 3 times background as long as the guideline value is l

not exceeded. Moreover, the box 1s incomplete in that it offers no choice for the condition that measurements do exceed 3 times background.

I The criteria proposed in Figure 4-1 for deciding when remediation

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is required need to be expanded. The criteria which require i

remediation, as cited in NUREG/CR-5849, page 4.13 are:

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Residual activity which exceeds 3 times the guideline value, results in external radiation in excess of 2 times i

the guideline value above background at 1 m from the j

surface, or results in an average actjvity above the i

guideline value in any contiguous 1 m' area (refer to e

i Section 8.5.2 for averaging procedures) should be t

J remediated until these conditions are satisfied.

1 The entirety of these criteria must be reflected in the decision j

box leading to conduct of remediation.

j 2.9 Section 3., "ALARA", of the Clevite Remediation Plan Revision, should include an occupational exposure estimate, in man-rem, for each decomissioning activity, and a description of the engineering and administrative controls to keep exposures ALARA.

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In addition, the MDA values listed in Table 2 do not appear to correspond to the actual MDAs of the instruments used to conduct the characterization survey.

1.5 The characterization report should detail the quality assurance data collection, pro (ce/QC) for data management to ensure the qu/

control procedures QA ality of ssing and reporting.

j 2.0 Ramadiation Plan / Final Survey Plan 2.1 The remediation plan / final survey plan should describe how the i

characterization data will support remediation activities and the 4

procedures for incorporating the characterization data into the final i

j tomination survey. As stated in the NRC staff letter dated June 1, 1995, the criteria pro)osed in Figure 4-1 for deciding when remediation is required, needs to )e expanded (see comment #2.8.3)., It is not clear to NRC staff which areas will be remediated (comment #1) c how each r

area will be remediated based on the characterization data.

i 2.2 The remediation plan should clearly identify the applicable cleanup i

criteria and the comparison between known or suspected contamination i

levels and the criteria.

The remediation plan should be revised to i

reflect Sevenson's position that the entire site will be remediated and j

surveyed following the thorium clean-up criteria.

2.3 The remediation plan should segregate affected areas from unaffected areas and delineate the site into survey units for statistical evaluations.

The final survey section of the remediation plan should i

describe the survey approach for affected and unaffected areas.

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the characterization data submitted, it appears that every survey area

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received 100% alpha, beta, and gamma surface scans and systematic measurements (direct and removable) at 1 m intervals which is the approach for conducting final termination surveys of affected areas.

Before NRC staff can determine the adequacy of the characterization survey data as final survey data for those areas that meet the unrestricted release criteria, the remediation plan must contain the i

following information; l

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1) A clear designation of which areas are to be remediated and therefore require additional final surveys,

2) How characterization data will merge with additional final survey i

data,

2) Delineation of data into survey units for statistical interpretation and evaluation, and i

3) Quality control procedures for ensuring the validity of the characterization and final survey data.

I 2.4 The remediation plan should detail the quality assurance measures for i

data management to ensure the quality of data collection, processing and i

reporting.

This includes the data management procedures that will i

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