ML20149D498
| ML20149D498 | |
| Person / Time | |
|---|---|
| Site: | 07000133 |
| Issue date: | 07/11/1997 |
| From: | SEVENSON ENVIRONMENTAL SERVICES, INC. |
| To: | |
| Shared Package | |
| ML20149D496 | List: |
| References | |
| PROC-970711, NUDOCS 9707170155 | |
| Download: ML20149D498 (18) | |
Text
m Remediation Plan For Former CLEVITE CORPORATION SITE East 105 Street, Cleveland, Ohio Submitted For:
GOULD ELECTRONICS INC.
Eastlake, Ohio Submitted Bv:
SEVENSON ENVIRONMENTAL SERVICES, INC.
2749 Lockport Road Niagara Falls,NY 14302 July 11,1997 9707170155 970614 PDR ADOCK 07000133 '
C PDR i s
1, P U R P O S E............................................................. 2 2
SITE DESCRIPTION / BACKGROUND..................................... 2 3
ORGANIZATION AND RESPONSIBILITIES............................... 3 4
TRAINING REQUIREMENTS............................................ 3 -
5 LAB O RATO RIES..................................................... 4 6
CHARACTERIZATION SURVEY........................................ 4 7
BACKGROUND LEVEL DETERMINATIONS............................. 4 8
IN STRUM ENTATION............................................ 4
- 9 9
REM E D I ATIO N................................
\\
10 RADIATION PROTECTION SURVE YS................................. 12 i
.... 12 11 EQ UIPM ENT RE LEA S E.........................................
13 12 ALARA...........................................................
13 D ATA CONVERS ION...............................................
15 14 RE C O RD S........................................................... 1 7 I
i Clevite Page1 Remediation Plan July 11,1997
+
g
l 1
PURPOSE The purpose of this procedure is to:
1.1 provide for work in progress surveying.
1.2 provide the requirements for and methods used in the performance of radiation and radioactive contamination surveys during the remediation activities.
1.3 provide a procedure for the surveying and release of equipment at the Clevite site.
2 SITE DESCRIPTION / BACKGROUND The former Clevite Corporation Facility is located at.<40 East 105th Street, Cleveland, Ohio. This site is presently owned by Neighborhood Progress, Inc.
Clevite Corporation was a manufacturer of nuclear fuel under an Atomic Energy Commission license, including high-enriched uranium fuel for the U.S. Navy and AEC research reactors, as well as Thorium products. The company ceased fuel manufacturing in the 1960's. A closeout radiation survey by the licensee was accepted by the AEC, and the license was terminated. The 160,000 square foot building was sold in 1991 to Neighborhood Progress, Inc., and has been divided into smaller sections for lease.
On May 27,1993, a Region III (Chicago) radiation specialist performed a radiation survey at the site which had been identified as a potentially contaminated site in an Oak Ridge National Laboratory review of former AEC and NRC licenses.
The survey identified low-level radioactive contamination in some cracks and crevices in the concrete floor of one portion of the building now occupied by a machine shop.
The machine shop area was surveyed because blueprints in the AEC license file identified it as a fuel manufacturing area. Other areas of the building were surveyed on a sampling basis, and no contamination was identified. Selected areas outside the building were also surveyed, and no contamination was identified.
Based upon its May 27,1993 survey, the NRC concluded that the first floor machine shop and a few assembly areas were not decontaminated to a residual radiation level consistent with NRC Guidelines. However, the NRC also concluded these radiation levels do not constitute an immediate health and safety problem. Aithough the NRC believes there is no immediate danger, the NRC believes its measurements exceed NRC limits for unrestricted use.
Clevite Page 2 Remediation Plan July 11,1997
~
.3 ORGANIZATION AND RESPONSIBILITIES The survey will be performed by a qualified team of Sevensoa 2nvironmental employees.
Mr. Chris Juliano Site Superintendent. His duties are overall responsibility for work operations.
Mr. Rory Grube Radiological Safety Officer / Health Physicist. His duties are to review and evaluate radiological surveys, and prepare reports.
Mr. Scott Wasmer, Health Physics Technician. Hi:: duties are to perform radiological monitoring, collect environmental samples, assist in report preparation, enforce site safety and health plan.
Mr. Paul Hitcho ClH, Health and Safety Officer. His duties are to develop implement and update as appropriate, and enforce the site specific safety health and emergency response plan.
4 Mr. John Davis CHP. QA/QC. His duties will be to coordinate all interface requirements during the survey process, ensure that all aspects of the QA is adhered to.
Site Supv H&S-Rad Safety QA/QC HP Tech 4
TRAINING REQUIREMENTS The primary purpose of maintaining training requirements is to ensure that all personnel know and understand radiological controls and that all personnel working on the site are aware of their responsibilities in the area of radiation protection to ensure the safe operation of the site and general safety of the public. The best protective measure available to the site is a highly trained and capable work force that employs proper radiological controls in their work environment. Training will meet or exceed all requirements of 10 CFR 19. Specific details of the training requirements are presented in Section 10 of the Health and Safety Plan.
Clevite Page 3 Remediation Plan July 11,1997
1
\\
5 LABORATORIES Analytical services for smears and air work zone air samples will be performed on site by Sevenson. Soil samples and environmental air samples will be analyzed by Barringer.
Laboratories, Inc., Golden, CO. The QA coordinator will monitor in-house and contractors laboratory services.
6 CHARACTERIZATION SURVEY A characterization survey was performed which provided sufficient detail to plan the decontamination effort. The Characterization report was submitted under separate title.
7 BACKGROUND LEVEL DETERMINATIONS Initial background exposure rates were determined for the building interior by taking a minimum of 10 measurements at locations of similar construction but without a history of radioactive materials use. Also, a minimum of 10 locations for area background measurement and sampling were selected within a 0.5 to 10 km radius of the site.
Exposure rate measurements were performed using a micro R meter. A background soil sample was collected. Results of background exposure rate and thorium soil concentrations were evaluated to assure that the averages determined are representative of the true averages, using procedures described in NUREG/CR-5849. Background exposure rates for interior and exterior areas vary based on the material being surveyed. It should be noted that background fluctuates within a given material and higher than average levels can be obtained. Small rooms or areas where more than one wall is made of material with elevated background readings in close proximity can create false readings in j
excess of the guideline value.
8 INSTRUMENTATION Table I lists the instrumentation to be used for the survey activities, along with typical parameters and detection sensitivities for the instrumentation and survey technique.
~
Sensitivities for scanning techniques were based on movernent of the detector over the surface at I detector width per second and use of audible indicators to sense changes in instrument count rate. Experience demonstrates that qualified surveyors can detect the levels listed in Table I with a 90% confidence level. All instruments will be calibrated a minimum of once every 6 mor.ths, using NIST-traceable standards. Calibration will be for the specific uranium radiation energies expected to be present at the site. Operational and background checks will be performed at least once each 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> on instrument use.
Clevite Page 4 Remediation Pkm July 11,1997 c
m
i f
1-The basic equations for determining field instrument detection limits are:
i Surface Activity Measurement for an integrated measurement over a preset time i
i 2.71 + 4.65 /B, t MDA = Activity level in dpm/100 cm 2
ypj,
i A
Bg =
. Bach,oung cpm _
tE 100 t=
count time m mmutes 2
A=
Active probe area in cm 4 -
(1) MDA E=
Detector efficiency Surface Activity Measurement of a Ratemeter Instrument 2
MDA= Activity level in dpm/100 cm 4.65 3 2t Bg=
Background cpm
'MDA=
t, =
meter time constant A
2 E-A=
Active probe area in cm 100 (2) MDA E=
Detector efficiency Scannino MDA I
MDA= Activity levelin dpm/100 cm 2
Bg =
Background cpm E=
Detector efficiency A=
Area of probe 3 B, E,A 100 (3) MDA Scarming Clevite.
Page 5 Remediation Plan July 11,1997 i
2.=
Laboratory Analysis of Wipes 2
MDA= Activity levelin dpm/100 cm 2.71 + 4.65dB'a t Bg =
Background cpm V
MDA=
t=E t=
count time in minutes E=
Detector efficiency (4) MDA k
i 4
4 i
- i l
- Clevite Page 6
- Remediation Plan July 11,1997
.i 3
.. 1 3
Ttble 1 INSTRUMENTATION FOR RADIOLOGICAL SURVEYS i
Type of Detector Meter
Background
4n Eff Detector Sensitivity Measurement Surface Activity Ludlum 43-68 Ludlum 2221 I cpm 20 %
37 dpm alpha 100 cm Window 2
Gas Proportional Surface Activity Beta Ludlum 43-68 Ludlum 2221 200 cpm 30 %
228 dom 100 cm Window 2
Gas Proportional Surface Scan Alpha Ludlum 43-65 Ludlum 3 1 cpm 15 %
40 dpm 50 cm Windaw Ludlum 4 2
Scintillation Surface Scan Ludlum 44-9 Ludlum 12 45 cpm 19 %
4584 dpm Beta / Gamma 15.5 cm Window Ludlum 2221 2
Pancake Surface Activity Ludlum 43-65 Ludlum 3 1 cpm 15 %
98 dpm Alpha 50 cm Window Ludlum 4 2
Scimiliation Surface Activity Ludlum 44-9 i "d!um 12 45 cpm 19 %
Ratemeter 1872 dpm Beta / Gamma 15.5 cm Window Ludlum 2221 Scaler 1151 dpm 2
Pancake Surface Activity 43-1-1 Ludlum 2224-1 1 cpm a 27%a 36 dpm a Alpha / Beta / Gamma 75 cm Window 180 cpm py 47%py 185 dpm py 2
Surface Scan 43-1-1 Ludlum 2224-1 1 cpm a 27%a 15 dpm a Alpha / Beta / Gamma 2
75 cm Window 180 com Dy 47%Dy 1532 dpm Dy l
Cievite Page 7 Remediation Plan July 11,1997 l
g-Table 1 INSTRUMENTATION FOR RADIOLOGICAL SURVEYS
[
py Smear Counting Ludlum 120 Ludlum 2000 45 cpm 42%
81 dpm 32 cm Window Scaler 2
Gas Proportional a Smear Cotmting Ludium 43-t>8 Ludlum 2200 1 cpm 20 %
37 dpm 100 cm Window Scaler 2
Gas Proportional Surface Scan Gamma !
LX 1 Nai I.udium 1-97 7 - 10 uR N/A 4nR Clevite i' age 8 Remediation Plan July 11,1997
9,-. REMEDIATION
. Remediation will be carried out in the following manner. The ' paragraphs explaining the flow chart are F
. contained below.
- 4 Para 9.1 h1 ark Area to Be Remediated l
y i
. Para 9.2 i Set Up Containment f
I r-t
- ! Test Ventilation Para 9.3 ~
1 Para 9.4 Remediate
~t I
r-~
t Para 9.5 l Waste Packaging 1
i i
r Works in Progrecs Survey i
i t-c Para 9.6 1
i o
t
.t Para 9.7 -
Survey Evaluation j
t I
l Survey Surrounding Area i '
L
- Pam 9.8 i
l
^
i Para 9.9 I Evaluate Data for Arev i
L J
4.,
d, l.
1 -
1 p.
1 j
1
.c. Clevite Page 9 h
, yj + Remediadon Plan.
- July 11,1997 j
^', \\
_l
- 9. _
[h d $k.
'm'-
.l
9.1 Scan the area to be remediated and mark the boundaries' with paint.
9.2 Containment 9.2.1 Tents will be used for the mest part. Smaller containments may be used in limited circumstances.
92.2 Construction - Tents will be made using frame work and poly. Seams in the poly will be taped shut. The poly will be taped and glued to the floor. Tents will have a vestibule for egress with flaps on either end to minimize the spread of contamination and airborne radioactivity outside the tent.
9.2.3 Ventilation will be used as engineering controls to minimize airbome radioactivity.
- Ventilation will utilize HEPA filters. Ventilation will be one of two methods, HEPA vacuum cleaners or portable ventilation units. HEPA vacuum cleaners will be used to capture the contaminates at the source in conjunction with certain decontamination methods (chipping, etc.). HEPA ventilation will be used to provide negative pressure on enclosures.
9.3 A negative pressure test using smoke will be performed on each containment prior to use.
9.4 Remediation The remediation will be carried out ttsing the proper technique for the type of contaminate present.
9.5 Waste Packaging Waste will be collected in 55 gal. drums. The drums will be lined with poly ~oags. An inventory of the drum's content will be maintained. This will be used to aid in the estimation of the activity concentration of the drum.
i 95.1 Non contaminated material will not be added to contaminated waste.
9.5.2 No free standing liquid will be permitted in the drums.
9.5.3 Drums will be numbered, marked with the date closed, and estimated curie content and isotope.
9.5.4 Drums will be stored in designated radioactive material storage areas when removed from the controlled areas. Drums will be labeled as radioactive material.
t i
Clevite Page 10 Remediation Plan July 11,1997 O
1 1
9.6 Work In Progress Sampling Work in progress sampling will be conducted within the work zone containment structure to evaluate the decontamination process. When a surface has been removed, placed in a waste container and the area vacuumed, a survey will be performed to determine the degree of contamination remaining.1000 dpm/100cm py for naturally occurring uranium will be used as 2
the local control level to determine if further remediation is required.1000 dpm/100cm was 2
chosen as a conservative number based on the maximum alpha to beta ratio experienced when dealing with naturally occurring uranium. This will ensure that the alpha is below 5000 dpm/100cm even where problems with alpha surveys exist. Where thorium or other isotopes of 2
concem are present alpha surveys will be performed and compared to the applicable limit. The decontaminated area will be scanned for alpha (when needed), beta and gamma radiation and direct surveys will be conducted for alpha (when needed) and beta gamma. Wipes will be taken using cloth wipe material. If the area exceeds the limit for contamination, see table 2 and table 3, the decontamination process will continue. Ifit is found to meet the criteria for release the containment tent will be removed. The decontaminated area and the surrounding one square meter areas will be surveyed to the same criteria used in the previous rtrveys as specified in the Site Characterization Survey / Termination Survey.
Table 2 Type of Limit Contamination Removable 20% of Guideline Fixed See guidelines in Table 3 Table 3 2
2 Isotope Average over M Maximum <100 cm Removable 2
2 2
Thorium 1000 dpm/100 cm 3000 dpm/100 cm 200 dpm/100 cm 2
2 2
Urar.ium 5000 dpm/100 cm 15,000 dpm/100 cm 1000 dpm/.100 cm 2
2 Radium 100 dpm/100 cm.2 300 dpm/100 cm 20 dpm/100 cm
)
9.6.1 All contamination surveys will be conducted using instruments listed in table 1.
9.6.2 Values will be adjusted for contributions from natural background.
9.7 -
Survey Evaluation i
Clevite Page11 Remediation Plan July 11,1997 i
.4 r
d h-*
m.
y g
If the area exceeds the limit for contamination, see table 2 and table 3, the decontamination process will continue. Ifit ir found to meet the criteria for release the containment tent will be removed. The decontaminated area and the surrounding one square meter areas will be surveyed to the same criteria used in the previous surveys as specified in the Site Characterization Survey / Termination Survey.
9.8 Survey Of Surrounding Area
- The surrounding one meter square areas will be surveyed to insure that contamination was not transferred from the contaminated area.
9.9 Evaluation Of Data For The Survey Area If there are no further locations within the survey area to be remediated the survey data for the area will be evaluated to determine ifit meets the release criteria If the release criteria is met the survey data and its evaluation will be filed. If the release criteria is not met then further sampling will have to be accomplished.
10 RADIATION PROTECTION SURVEYS Radiation surveys will a. made to protect the remediation workers, and the environment.
10.1 Removable contamination surveys will be made of the area surrounding a contamination containment, sample preparation and counting room areas, and waste storage area on a daily or end of shift basis if there is more than one shift.
10.2 Continuous air samples will be taken inside and outside of the contaimnent structure while remediation is taking place. If more than one work shift is employed then the samplers will be stopped at the end of the first shift and the filters removed for analysis and new filters put on the samplers.
10.3 A radiction dose rate survey will be made of the waste storage area and the counting laboratory on a daily basis.
i 11 EQUIPMENT RELEASE I 1.1 There is a potential for equipment used on the site especially that equipment used in the fuel manufacturing process to be contaminated. In order for the site to be released all contaminated equipment will have to be decontaminated, disposed of as radioactive waste or put on a radioactive materials license. Equipment located on the Clevite site will be Classified in the in the following manner:
Equipment in place before radioactive material work ceased.
Equipment placed in service after operations with radioactive material ceased but is located in an affected area Equipment placed in service in tmaffected area.
Clevite Page 12 Remediation Plan July 11,1997
11.2 All equipment in the first category will have to be 100% surveyed for fixed and spreadable contamination. This includes internal parts of the equipment. If the item to be surveyed is a closed vessel it will have to be opened to check the inside. The limits to be used for all equipment is the guideline value for the average value, and the removable value. If contaminated, the removable must be cleaned down to 20% of the guideline value and the fixed down to the guideline value.
I 1.3 Equipment in the second category should receive a 100% scan survey of all outside surfaces and if the survey show the item to be contaminated above the release limits it will have to be 100%
scanned as shown in the first example.
11.4 Equipment in the third category will receive a 10% scan of external surfaces and a minimum three smears and direct surveys. If the outside surface has an area of contamination above the guidelines a spot check will be made ofinternal surfaces.
I 1.5 If the item cannot be decontaminated it will have to be disposed of as radioactive waste, or transferred to a licensee who is licenced for those isotopes. Ifit meets the criteria for release it will be tagged by the surveyor showing that it is not contaminated and the release survey will be filed.
12 ALARA Exposure control will be maintained As Low As Reasonably Achievable (ALARA) by the use of engineered controls and personal breathing devices. There is expected to be no problem with external exposures.
12.1 TLDs will be worn by all employees involved in the remediation process.
12.2 Respirators will be worn by personnel when required by the RWP primarily when airbome causing evolutions are in progress.
j 12.3 Air samples will be continually taken during any work.
12.4 Use Of Protective Clothing 12.4.1 Donning -
There is no set order to put on protective clothing but the following sequence is recommended.
Low-cut booties or High top booties (if used) need to be inside coveralls.
Cotton liners, Coveralls.
a Rubber shoes or Low-cut booties.
1 Clevite Page 13 Remediation Plan July 11,1997 a
Respiratory protection (if used).
Hood.
Rubber gloves.
(1)
You may be required to tape seams and openings depending on the contamination levels present and the work activities you have to perform.
(2)
Wear dosimetry inside coveralls unless directed otherwise.
12.4.2 Doffing -
The removal of protective clothing is important. You must take precautions to prevent the spread of contamination outside the controlled area. You must take care to prevent contaminating skin and personal clothing. You will remove items that have the potential for higher levels of contamination first, such as boots and outer gloves. Items oflesser contamination will be removed until you have crossed over from the contaminated area to the clean area using the step-off-pad. Place all items removed in the proper containers at the step-off-pad. The following undress sequence must be followed.
Rubber boots or low-cut booties.
Rubber Gloves - Remove outer gloves by turning them inside out leaving inner gloves on.
Hood - Use cautions to prevent contaminating your face and head. Remove the hood in an upward motiou away from your head and back.
Respiratory protection (if used) - Bend at the waist, grab the respirator with both hands at the filter (s)and pull away from the face and body.
Remove coveralls - Do not touch the outer surfaces of the coveralls. This is done by slowly turning them inside out and rolling them down your body. Carefully step out of each leg keeping the coveralls inside out.
Shoe covers - Remove one shoe cover and step across the control boundary. onto the step off pad. You take one shoe cover off, stcp across the boundary, remove the other shoe cover and step on the pad. You are now completely outside the contaminated area.
Inner gloves (1)
Keep inner gloves on to har.dle and/or transfer items from the contaminated area.
(2)
Remove inner gloves by turning inside out.
Clevite Page 14 Remediation Plan July 11,1997
12.4.3 Proceed to the frisking station and perform monitoring as required.
12.4.4 Equipment control - Tools and other material in the tent will be considered contaminated until proven otherwise. Tools and materials leaving the controlled area will be surveyed to prove they are free of contamination to below the limits or contained and labeled as radioactive material.
13 DATA CONVERSION Radiological survey data is obtained in units, such as counts per unit time, which have no intrinsic meaning relative to the guideline values. Therefore, the survey data from field and laboratory measurements are converied to units which will enable comparisons. Standard units used for expressing survey findings are:
Surface Contamination dpm/100cm (disintegrations per minute per 100 cm )
2 2
Soil Radionuclide Concentration pCi/g (picoeuries per gram)
Exposure Rate pR/hr (microroentgens per hour)
In performing the conversions, it is neces:ary to know several factors; these are:
c total integrated counts recorded by the measurement c/m total count rate from an analog (rate) instrument t
time period (minutes) over which the count was recorded B
count during recording period, due only to background levels of radiation B/m background count rate on an analog instrument E
detection efficiency ofinstrument in counts per disintegration A
active surface area of the detector in cm2 M
mass of sample analyzed in grams 2.22 factor to convert a disintegration rate to activity units of picoeuries, i.e. dpm/pCi These factors are used in the equations in the remainder of this section.
13.1 Surface Activity A measurement for surface activity is performed over an area, represented by the sensitive surface area of the detector. If the instrument display is in count rate, i.e. counts per minute, the conversion to dpm/100 cm is performed by:
2 dpm
, (c/m -em) ' 100' 100 cm E
A, r
Clev':c Page 15
' Remediation Plan July 11,1997
For a technique using an integrated count on a digital instrument, the conversion is:
l dpm
, (c -B) ' 100' 2
1 E A,
100 cm r
The level of removable activity collected by a smear is calculated in the same manner, except, the detector area correction factor,100/A, is dropped from the equation because the smear is performed over a 100 cm area and the detector area correction is usually considered when determining the efficiency, 2
leaving:
dpm (c - B) 2 f.E 100 cm 13.2 Soil Radionuclide Concentration To determine the radionuclide concentration in soil in units of pCilg, the calculation performed is:
(c-B) pCilg = t E 2.22 M
If the analytical procedure includes a wet chemistry separation it will also be necessary to correct for the fractional recovery (R), determined by a spike or tracer added to the sample.
(c-B) pCilg = tE 2.22 M R
{
13.3 Exposure Rate If an instrument such as a pressurized ionization chamber or a " micro-R" meter is used for measuring exposure rate, the instrument reading will be directly in the desired exposure rate units of R/h. A gamma scintillation or GM detector with a count rate or digital scaling instrument provides data in units of counts per minute or per some preset time, respectively. Conversion to R/h is accomplished using calibration factors developed for the specific instmment and survey site. The background exposure rate is then subtracted from the total to determine the net level, attributed to residual activity from licensed operations. This net level is compared with the guideline value.
'I" pRlh =
or clm c/m
.pRlh
, pRlh j
- Site Specific Calibration Factor for Detector Clevite Page 16 Remediation Plan July 11,1997
13.4 Measurement Uncertainty Each reported value will include an assessment ofits uncertainty. The rate of radioactive decay is not I
constant with time and is therefore described by a Poission probability distribution. Based on such a distribution, the best estimate of the standard deviation (s) on a number of counts C is the square root of the counts, i.e.
l s = {d and the standed deviation in a count rate over time (t) is therefore:
s' = E I
For the majority of measurements conducted during a final status survey, the number of counts due only to background will be a significant portion of the total count. The background also has an uncertainty associated with it which is taken into consideration by:
f+
S
- t e
Where: to is the time period over which the background count was determined.
The standard deviation or uncertainty in the count or count rate will be converted to the same standard l
units used to express the measurement value by use of the equations provided above. The uncertainty will be given at the 95% confidence level which requires multiplying the standard deviation value by a factor ef 1.96.
i 13.5 Minimum Detectable Activity l
l Less than or equal to minimum detectable activity (MDA) levels will be reported but will only be used j
for averaging sit activity levels when the value for (MDA) <10% of the guide'ine value. For all other e
l calculations, actual values will be used.
14 RECORDS All original survey data is being retained at the Clevite site until the completion of the remediation and l
final status surveys. The original survey data will be forwarded to and archived by Gould Electronics Inc. and will be held until such time as authorized by the NRC for disposal.
3 i
Clevite Page 17 Remediation Plan July 11,1997 i
d j