ML20149D476
| ML20149D476 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 06/27/1997 |
| From: | Elliott G FRAMATOME COGEMA FUELS (FORMERLY B&W FUEL CO.) |
| To: | Lamastra M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| TAC-L30746, NUDOCS 9707170149 | |
| Download: ML20149D476 (8) | |
Text
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1 O
F RAM ATOM E COG EMA F U E LS June 27,1997 Mr. M.X. Lamastra Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety & Safeguards, NMSS United States Nuclear Regulatory Commission Washington, D.C. 20555
SUBJECT:
WET-WEATHER STREAM RELE/.SE (TAC NO. L30746) DOCKET NO.
70-1201, SNM 1168
Dear Mr. Lamastra:
This letter is in response to your NRC memorandum to Michael F. Weber from M.X. Lamastra dated February 18,1997, entitled " Summary of February 5,1997, Meeting With B&W Fuel (Framatome Cogema Fuel)". This memorandum, in addition to the correspondence dated November 5,1996, requested additional information to support the final action of FCF's request to free release the wet-weather stream, in accordance with the meeting between Framatome Cogema Fuel (FCF) and NRC on February 5,1997, Attachment 1 addresses the plan to be performed which will enable submittal of the additional information requested by the NRC in the above mentioned correspondence.
Should you have any questions or comments, please feel free to contact me at (804) 832-5202.
Sincerely, g
FRAMATOME COGEMA FUELS Lynchburg Manufacturing Facility 9707170149 970627 hDR Gayle F. Elliott ADOCK 0700 1
Manager, Safety & Licensing rr.m.iom. cos.m. ru.i.
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4 ATTACHMENT 1 Page 1 of 6 Rannonna to NRC Carament #1:
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Comment:
1 Two of the contiguous areas averaged 30 pCi/g and one contiguous
[
area averaged 31 pCi/g NRC staff understands that the background was not subtracted from the original measurements and that the net 4
values may be lower than the data reported. Please provide the results of background soil measurements and describe how background measurements were obtained.
Response
i Although the regulations allow background to be subtracted from
}
sample results, FCF did not take credit for this. As part of the final action plan, it was intended that background samples would be coHected and analyzed. This, however, was not performed.
SoH samples (500 grams each) are collected annuaHy by FCF at the locations ident/Redin Table 1. FCFproposes to use the average of the soH samples for the year in which the wet-weather stream samples were taken and use this value as the background (i.e.1991 average soH results 16r the 1991 characterization survey, and 1994 average soH results for the 1994 investigation survey and 1994 post-r remediation ver/Rcation survey). Note in Table I that Locations A, B, D, F and H wlH be used, upon approval, for the background average.
Location G wlH not be used since this location is in the wet-weather stream area.
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ATTACHMENT 1 i
Page 2 of 6 Comment.
l One problem with your approach is that the (100/A) 5 formula used 2
to derive a release limit based on an area of 16.8 m was compared to the average concentration of the entire grid; this is not an appropriate application of this formula. The derived limit using (100/A)' 5 should be compared to the average concentration over area
'A'.
For all data points with concentrations above 67 pCi/g, you should obtain additional measurements to determine the area extent of elevated activity or use previous data, if available, to evaluate compliance with the hot spot criteria.
Response
i FCF understands the approach previously used to derive a release
{
Mmit based on an arsa of 16.8 m' compared to the average concentration of the entire grid was not appropriate.
FCFis in the process of reviewing aH data points with concentrations above 67 pCl/g to determine the area extent of elevated activity using previous data. At this time it does not appear that additional i
measurements willhave to be taken.
- Comment:
It is still not clearly evident from the data summary as to which data points are from the 1991 characterization survey and which are from the 1994 post-remediation survey. A comparison of the data summary provided June 7,1996, with the original report dated December 1,1994, Indicates that the 1994 post remediation activity levels are higher than the 1991 characterization data. Please explain why activity at certain data points increased after remediation.
4
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Response
A comparison of the data summaryprovided June 7,1996, with the originalreport dated December 1,1994 and the 1991 characterization data determined that the data had been inadvertently reversed. FCF Is in the process of developing a table which clearly identifies the results of the surveys and the year in which the surveys were taken.
1 l
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ATTACHMENT 1 Page 3 of 6 t
Rannonna to NRC Comment #2:
Comment:
Pages 2 and 30 of the survey report do not state that the Reuter Stokes instrument was used to scan the surface of the wet-weather stream. The report states that "A Reuter Stokes instrument was used to obtain radiation levels at the sample point location." As mentioned in the previous NRC staff comment, the scan surveys are an important part of a final survey. NUREG/CR-5849 recommends that affected outdoor areas receive a surface scan of 100 percant of tho affected area using instrumentation with appropriate detection sensitivity. A Reuter Stokes instrument is appropriate for exposure rate measuremer which are also recommended as part of a final survey. However PICS are not the most appropriate instruments to conduct surface scans. Surface scans are conducted prior to direct measurements to identify areas of elevated activity and direct measurements are then performed at these elevated areas to define the extent and activity, in the absence of sufficient surface scans, the staff is concerned that you have not adequately identified areas of elevated activity.
8 l
Response
A Router Stokes instrument was used to obtain radiation levels at the sample point locations as previously stated on pages 2 and 30 of the survey report. A surface scan of 100 percent of the affected areas using Instrumentation with appropriate detection sensitivity was not performed. FCF is presently searching the market to obtain or lease a sodlum lodide instrument or an equivalent piece of equipment to j
perform the scan.
4 4
ATTACHMENT 1 Page 4 of 6 Rannonne to NRC Comment #3:
Comment:
You have not demonstrated that the wet-weather stream is suitable for unrestricted release. As indicated in our original comment, the issues listed below need to be addressed before any confirmatory survey of the area should be conducted.
(1)
In the absence of adequate surface scans, the NRC staff is not confident that you have sufficiently identified all elevated areas of activity (see Comment #2).
Response
See Response to NRC Comment #2.
1 Comment:
(2)
You have not appropriately evaluated hot spots (see Comments
- 1 and #8).
Response
See Response to NRC Comment #1.
Comment:
(3)
The survey does not include exposure rate measurements as recommended in NUREG/CR 5849.
Response
FCF is presently gathering exposure Information for Individuals who worked as part of the wet-weather stream remediation effort. This information w/M be submitted to NRC upon approval of plan.
.er e
6 ATTACHMENT 1 Page 5 of 6 Comment:
1 (4)
The highest points on the data summary appear to be taken from the 1994 post remediation survey. This indicates that contamination is still present.
Response
Sec Response to NRC Comment #1.
Resnonne to NRC Comment #6:
Comment:
in response to the second part of this comment, you state,
... extensive surveys were conducted which concluded that the contamination was limited to the 0-6"' depth. Please provide the information or data to illustrate and validate this statement.
Response
FCFis presently obtaining background information and data regarding the process used to conduct the surveys. Work Instructions andJob brieHngs were provided to the operators obtaining the samples, however, a formalprocedure dictating the requirements was not provided. Upon approvalof this plan, FCF willsubmit the work instructions andJob briefings to the NRC.
(
Rannonse to NRC Comment #8; Comment:
As with Comment #1, NRC Comment #8 reiterates that the survey j
data presented in the original report does not demonstrate compliance with hot spot criteria. You responded to this comment stating that additional samples collected in 1994 around certain data points support your assumption that contamination did not spread beyond 2
the 16.8 m areas. The NRC staff did not reach the same conclusion after a second review of your original report...As stated in Comment
- 1, you should obtain additional measurements to determine the extent of elevated activity around those data points that exceed 67 J
ATTACHMENT 1 Page 6 of 6 pCl/g (the derived hot spot limit for 16.8 m' contaminated areas) or use previous data, if available, to evaluate compliance with the hot spot criteria.
Response
See Response to NRC Comment #1.
9 l
TABLEI Page 1 of 1 l
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.a A SOIL, AIR, VEGETATION,TLD C,* Soll. VEGETATION, TLD CjeAIR,TLD ',
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