ML20150B930

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Application for Amend to License SNM-928,permitting Onsite Disposition of Contaminated Soil at Facility
ML20150B930
Person / Time
Site: 07000925
Issue date: 06/30/1988
From:
SEQUOYAH FUELS CORP.
To:
Shared Package
ML20150B915 List:
References
0843E, 843E, NUDOCS 8807120249
Download: ML20150B930 (41)


Text

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REQUF.ST FOR AMENDMENT ON-SIH SOIL DISPOSITION CIMARR0N URANIUM PLANT LICENSE SNM - 928 DOCKET NUMBER 70-925 SEQUOYAH FUELS CORPORATION CKLAHOMA CITY, OKLAHOMA June 1988 Revision 1 08 G 8807120249 880629 PDR ADOCK 07000925 C

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CIMARR0N URANIUM PLANT LICENSE SNM 928-AMENDMENT APPLICATION INTRODUCTION This is Sequoyah Fuels Corporation's application for amendment of License SNH-928 to provide for leaving on-site, either in a designated area or

.in-situ, certain materials associated with the Cimarron Uranium Plant decommissioning activities.

The materials to be left will be in accordance with the Nuclear Regulatory Commission's Branch Technical Position (46 Federal Register 52061, October 23, 1981) and will consist of soll containing uranium and thorium that meet Options 1 and 2 concentration limits and conditions.

This application conforms to NRC's standard review plan and will satisfy Condition 2 of the license that requires decommissioning for unrestricted release of the facilities and grounds.

The information in support of this application is detailed in the following sections.

PROPOSED ACTIVITY The proposed activity is a) to leave in place Cimarron Facility site soll containing uranium and thorium in concentrations of 30 pC1/g and 10 pC1/g, respectively, or less (Option 1), b) to relocate to a designated on-site area and cover with four feet of clean backfill such soils located within four feet of the surface with uranium concentrations of 100 pC1/g soluble or 250 pC1/9 insoluble and thorium concentrations of 50 pC1/g or less (Option 2) and c) to leave in place soils with Option 2 criteria concentrations that are located (June 1988/Rev 1) 0843E

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.o more than four feet beneath the surface.

The position criteria prcalde for leaving, under a_ minimum of four feet of cover, concentrations of enriched uranium less than or equal to 100 picocuries per gram (soluble) and 250 picocuries per gram (insoluble) and thorium less than or equal to 50 picocuries per gram.

All materials left onsite will be within the Option 2 concentration requirements.

When left under these conditionn no restrictions are placed on subsequent land use and there is no licensing requirement.

JUSTIFICATION Detailed soll surveys at the burial ground and around the immediate area of the Uranium fuel Plant facilities, including the storage yard, sanitary lagoon and pipelines, have been done.

These surveys indicate a possible 400,000 cubic feet of soil epths less than four (4) feet and 3,000,000 cubic feet at depths more than four feet that meet Option 2 criteria.

Leaving the material on-site in a designated area under a minimum four 'eet of coter or in-situ when present deeper than four feet is justified for these reasons:

No risk is posed to public health or the environment.

NRC's l

comprehensive assessment in the Branch Technical Position demonstrates that the concentrations permitted under Option 2 conditions are sufficiently los that no individual will receive a dose of any concern i

from exposure to the uranium or thorium, even in the event of intrusion beneath the four feet of cover.

Because of the area characteristics, the material will be retained in place and be l

l environmentally secure. Moreover, the detailed soll surveys show that concentrations of uranium and thorium do not exceed Option 2 criterium l

at any location proposed for soll that will be left onsite.

l (June 1988/Rev 1) 0843E

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.., M The estimated volume makes relocation of the Option 2 concentration material to a licensed commercial waste disposal site infeasible.

Commercial sites have limited capacity and have established annual quotas for volume of material received.

Further, even if' capacity were available, relocation would not be justified on the basis of cost. The unit cost for leaving the material at the facility'is approximately $0.11 per cubic foot compared to an estimated $60.00 per cubic foot for relocation to a commercial site.

(Commercial site cost estimate reflects actual cost experience of SFC.)

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No restrictions will'be required to be placed on the area and normal use will be permitted.

DESCRIPTION OF THE MATERIAL The material to be left has been characterized through isotopic analyses of multiple samples obtained by coring to depth the storage yard and other areas around the facility.

The analyses show the composition of the material to be primarily insoluble enriched uranium (hereaf ter "uranium" -. assumed 37. based on the uranium handled at the Uranium fuel Plant and samples analyzed during decontamination activities).

The thorium is thorium-natural and is also insoluble.

Table I summarizes the isotopic analyses of the various samples and includes a background location for data comparison.

The characterization activities have generally identified the areas with uranium and thorium in ' soil that fall within or exceed the Options 1 and 2 concentration criteria.

The uranium and thorium generally are not uniform in concentration or in the distribution within a given location.

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6 In collecting the'soll for consolidation and relocation for cover, additional measurements will be made, including walkover surveys with a gamma-scintillation instrument and soll sample isotopic analyses.

The areas of intere,st will.be_gridded on a 10 meter by 10 meter basis and evaluated for assignment into one of three categories:

Soll to be left in place as is: tne concentration of uranium is not greater than 30 pC1/g; the concentration of thorium is not greater than 10 pC1/g; and if both uranium and thorium are present, the combined fractions-do not exceed unity (Option 1).

Soll to be left with four feet of cover: the concentration of uranium exceeds 30 pC1/g but not 100 pC1/g soluble or 250 pC1/g insoluble; the concentration of thorium exceeds 10 pC1/g but not 50 pC1/g; and if both are present, the combined fractions exceed unity for the lower limit but not the upper limit (Option 2).

Such'soll located within four faet of the surface will be relocated to a designated area and covered; such soll located at depths greater than four feet will be left in place.

Where excavation is required, oackfill will be placed to result in four feet of cover.

Soll requiring relocation to a licensed commcrcial site:

The concentration of uranium exceeds 100 pC1/g soluble or 250 pCl/g insoluble, the e.oncentration of thorium exceeds 50 pC1/g; and if both are present, the combined fractions exceed unity.

(June 1988/Rev 1) 0843E

Since the areas with uranium and thorium are not uniform in concentration, an averaging approach will be'taken in categorizing the soll.

Small, localized areas within an individual 10 meter by 10 meter plot that exceed the Option 2 threshold criteria by up to a factor of 2 may be left in place provided.the average concentration within the gridded survey plot does not exceed the threshold criteria.

Where soll is removed, the removal will have the objective of reducing the residual concentration as low as is reasonably achievable; in no case will uranium concentrations greater than an average of 30 pC1/g or thorium concentrations greater than 10 pCl/g be left in place at depths less than four feet. Where a mixture of uranium and thorium is present, the unity principle will be applied.

Figure 5 is a soll evaluation procedure for the disposition of soils containing elevated levels of uranium and thorium.

Removal and relocation of the material for cover will be on a continuous basis until completion of the activity; the only interruptien will be that caused by adverse weather conditions that prohibit the work to proceed.

No absorbent or other amendments will be mixed with the removed material; however the excavation, loading, unloading and placement activities will distributc the uranium and thorium generally throughout the material volume.

The material is natural soll and earth and since the operational facilities at the facility did not involve hazardous waste constituents as defined by the Environmental Protection Agency, rio such defined hazardous materials are assumed present.

(June 1988/Rev 1) 0843E

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HANDLIdG OF THE MATERIAL

-The material to be consolidated,_ relocated and placed under a minimum of four feet of. cover will be excavated with mechanical. equipment, such as a backhoe or front-end loader, and transported via dump truck in bulk to the relocation site. Fackaging will not be required; the material is natural soll and rock 4

containing uranium and thorium at concentrations sufficiently low that the radionuclides require no special handling.

IN-SITU MATERIAL HANDLING Soll to be left in place under four feet of cover is located in and to the south of the uranium plant yard area, along pipeline routes which were located between the uranium plant and the sanitary lagoon / evaporation pond areas and s.

areas near the sanitary lagoons and evaporation ponds. Areas requiring excavation which contain Option 2 materials to be left in place will be backfilled with at least four feet of clean soll.

This soll will be compacted by traverse of heavy equipment, contoured to the natural topography and seeded with appropriate cover vegetation.

Topographical, geological, hydrological and meterological charactcristics of the areas where soils will be left in-place are typical of those for the entire facility and are described in the section "Relocation Site Features" on page 8 of this application.

(June 1988/Rev 1) 0843E

c-RELOCATION AND COVER SITE The site.to which the material will be relocated for leaving permanently beneath a cover is approximately 1,500 feet northeast of the Uranium Fuel Facility and is well within the more than 1,100 acres of Sequoyah Fuels Corporation property that comprise the facility site.

Figure 1 is a sketch of the facility property, with the relocation site depicted.

The general

"*4 features of the facility property and the surrounding environs are summarized below.

The Cimarron Facility site is in a sparsely populated rural area in Logan County, Oklahoma.

The nearest town is Crescent, OK, some six miles to the north.

The nearest resident is located approximately 2,500 feet to the southwest of the relocation site and is also shown on Figure 1.

The facility site surrounding environs are typical of the plains section of Central Oklahoma, with gentle rolling relief in an otherwise flat setting.

The p1; ins'section is interspersed with relatively shallow stream and river courses located in wide gentle valleys; native grasses are generally abundant but trees are relatively sparse (Tcept for profuse stands along water drainage ways and courses.

The predominant land utilization is for growing of wheat and oti:er small grains and cattle grazing.

Tne grasses are primarily wild pasture types of many varieties that in many instances have been supplemented with bermuda or other improved forage species.

The grasses grow rapidly in the spring, are mainly dormant tr> the summer, with additional growth during the fall season.

(June 1988/Rev 1) 0843E

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This growth pattern is consistent with the rainfall and temperature patterns; most of the annual average 31 inches of rain is received in the spring and fall months.

Summers are typically hot (average July temperature of 82.9'F) and dry.

The features of the approximately 1,100 acre facility site are consistent with those described above. The site is located on a bluff overlooking and immediately south of the Cimarron River flood plain.

The site topography ranges from an elevation of about 940 feet above mean sea level (MSL) at the Cimarron River to the north to about 1,010 feet above MSL on the top of the bluff and promotes rainfall runoff to the north toward the river.

The site vegetation is mainly native grasses; several drainage ways are bordered by heavy stands of scrub trees and brush.

RELOCATION SITE FEATURES The site to which the material will be relocated is shown on figure 1.

The topographical, geological, hydrological and meteorological characteristics are typical of those for the entire facility site and have been documented in previous submissions.

For convenience, pertinent information is summarized

below, i

Topography:

The relocation site is a bluff area that is relatively flat; the topographic relief across the area is less than 10 feet (Figure 2).

The highest elevation (approximatelv 1,010 feet above MSL) is at the south end, the lowest elevation (June 1988/Rev 1) 0843E

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(approximately 1,000 feet above MSL).is near the north end.

Surface drainage is to the east, north and west, away from the relocation site.

There are no major drainages established in the area, which is approximately 50 feet above the 100-year flood elevation of the Cimarron River.

Geology:

The Cimarron site is located in the Central Lowlands of the Great Plains Physiographic Province, a relatively flat, featureless plain developed upon sedimentary formations of Paleozoic and '4esozoic age.1' The portion of.the Central Lowlands that includes the site is locally referred to i; the Central Redbed Plains. Geologic units ranging in age from the Pre-Cambrian basement complex to Permian sandstones and shales underlie the site, but only the Permian deposits are relevant, as the other units occur at depths of several hundreds of feet below ground surface and have no geologic or hydrologic importance for the relocation site.

The Central Redbed Plains in the vicinity are immediately underlain by the Permian Age Garber Sandstone and Hennessey group (shale) of non-marine origin.1' Outcrops of the Garber Sandstone form sharp escarpments over-looking the Cimarron River; outcrops of the overlying Hennessey Shale underlie the more gentle slopes farther south from the river.

These formations dip to the west at a gradient of 20 to 30 feet per mile.2' l'

N.M. Fenneman, 1931, Physlography of the Western United States; McGraw-Hill Book Company, Inc.. New York I'

R.H. Bingham and R. L. Moore, 1975:

Reconnaissance of the Water Resources of the Oklahoma City Quadrangle, Central Oklahoma; The University of Oklahoma, Hydrologic Atlas 4.

l' W. J. Ford, 1954:

The Subsurface Geology of Southwest Logan County, OklaSoma; Shala, Shaker V 5, No. 2, pp. 5-24.

(June 1988/Rev 1) 0843E

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The general geologic structure of the vicinity can be characterized as a gentle, west-southwesterly dipping homocline.

The major structure of the area is the.Nemaha ridge,l' which was formed prior to the Pennsylvanian age and has no significant effect upon the overlying Permlan geologic units.

There are no faults or surface lineations reported in the vicinity.1' The Garber Sandstone at this location consists primarily of red-to gray-colored sandstones interbedded with siltstones and shales.

The sandstones are fine to very fine grained and are loosely cemented.

The sandstone near the relocation site has been characterized by borings to a depth of 16 to 20 feet.

The locations of the borings are shown in figure 3 and descriptions of the corings are in Appendix A.

The shallow bedrock has also been characterized by three additional borings to depths of approximately 30 to 80 feet at an area near the relocation site.

Locations of these borings are also shown on figure 3 and descriptions are contained in Appendix A.

(These latter thr?e borings were completed as groundwater monitor wells.)

The characteristics of the soils underlying the relocation site have been mapped and are of the undifferentiated Renfrow and Zanels series.2' The Renfrow soll, which typically deslops on gentle slopes underlain by shile, consists of a brown silt loam that grades into a dark reddish-brown clay sui:-

soll. The Zanels soll, which typically develops on silty shale interbedded with fine-grained sandstone, consists of loam and fine sandy loam.

l' H. J. Ford, Note 3 supra l'

R.H. Bingham and R.L. Moore, Note 2 supra 2'

H. M. Galloway, et al, 1960:

Soil Survey of Logan County, Oklahoma; U.S. Department of Agriculture, Soll Conservation Service.

(June 1988/Rev 1) 0843E

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Hydrology:

Hater supplies in the vicinity of the Cimarron Facility are derived from local surface water and groundwater sources. The principal source of water for live-stock is small ponds.that impound surface runoff.I' Water for domestic use is generaisy-derived from groundwater sources at depths generally less.than 200 feet'.1' The primary surface water feature in the vicinity of the Cimarron Facility is the Cimarron River, an east-flowing tributary to the Arkansas River.

The Cimarron River has poor water quality due to heavy mineralization derived from natural chloride sources. -The river water is very hard with moderate to high turbidity and pH levels sometimes in excess of water quality standards.

Dissolved oxygen remains at or near saturation levels.

Iron, manganese, lead, silver, cadmium and arsenic are present in the river water in concentrations elevated from typical background valves.

The Garber Sandstone is the principal source of groundwater south of the

-Cimarron River near the Cimarron Facility.2' Permeability values-for the Garber Sandstone range from 2.7 to 4.8 feet per day'2' and attendant storage coefficient values are reported to be in the 10 " range based upon studies in Oklahoma and Cleveland Counties to the south. M '

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H. M. Galloway, Note 6 supra l'

l' R. H. Bingham and R.L. Moore, Note 2 supra l'

Engineering Enterprises: 1973: Hydrological Information in the Vicinity of the Kerr-McGee Facility. Logan County, Oklahoma; Kerr-McGee Corporation Document 18' H. M. Galloway, et al, 1960, Note 6 supra M'

P. R. Wood and L. C. Burton, 1968: Groundwater Resources in Clevelaid and Oklahoma Counties, Oklahoma; The University of Oklahoma Circular i

71.

(June 1988/Rev 1) it 0843E

The Garber Sandstone becomes thinner and progressively more silty and clayey north of Oklahoma County.11' A corresponding decrease in permeability is associated with this facies change to a finer-grained lithology.

Because of the lenticular nature of the Garber Sandstone, water quantity and quality can vary greatly over relatively short distances.12' The effective thickness of the Garber Sandstone aquifer is limited by the presence of brackish and salty connate watert.

The base of the fresh dater in the Garber Sandstone in southwestern Logan County is reported to be at an elevation of approximately 700 to 800 feet above mean sea level.13' At the Cimarron Facility brackish water was encountered at a depth of approximately 200 feet below ground level, confirming the reported freshwater base.11' The depth to water in the vicinity of the relocation site is generally between 20 and 30 feet.

The zone of fresh water saturation at the Cimarron Facility is thus approximately 170 to 180 feet in thickness.

Replenishment of the Garber Sandstone is believed to be restricted to lateral movement of groundwater recharging outcrops located to the east.

Data derived from aquifer tests suggest that there is no significant hydraulic connection between sandstone aquifers separated by intervening shale layers.li' Most recharge to the upper part of the Garber Sandstone in the vicinity of the Cimarron Facility is believed to be derived from subtrops beneath intermittent streams.

t-11' P. R. Wood and L. C. Burton, Note 16 supra ll' Engineering Enterprises, Note 9 supra li' P. R. Wood and L. C. Burton, Note 10 supra 11' Engineering Enterprises, Note 9 supra li' P. R Wood and L. C. Burton, Note 10 supra T

(June 1988/Rev 1) 0843E

Groundwater in the upper units of the Carber Sandstone discharges along en-trenchments in the prairie surface caused by the Cimarron River and its tributaries.

Groundwater in the deeper part of the Garber Sandstone, below the depth of surface entrenchments, is believed to move down dip to the west-southwest towards the Anadarko Basin.

Water from the Garber Sandstone is generaily suitable for drinking.

Locally, the water is hard and high in sulfates, chloride, fluoride, nitrates, or dissolved solids.'

As described earlier, salt water was encountered btneath the Cimarron facility at a depth of approximately 200 feet below ground surface.11' The site specific hydrologic characteristics of the Garber Sandstone have been established fre;n the analysis of several groundwater monitor wells that have been completed at the Cimarron Facility.

The locations and nomenclature of these wells are shown on Figure 4.

The three monitor wells designated 1306, 1309, and 1310 were constructed near the sites of borings IE, 2E, and 3E at the north end of the relocation site

area, inch of these three wells, which are completed to depths of approxi-inately 20 feet, were designed to monitor water in the unsaturated zone. Water appears in these wells only during extended wet periods.

The three wells designated 1311, 1312, and 1313 in figure 4 were constructed at the sites of borings LF-1, LF-2, and LF-3, respectively.

These wells, which were completed to depths of approximately 40 feet, were designed to monitor groundwater within the saturated zone in the bedrock.

1 12' P. R. Wood and L. C. Burton, Note 10 supra 11' Oklahoma Water Resources Board, 1984: Oklahoma's Water Atlas; Publication No. 120, 11' Engineering Enterprises, Note 9 supra (June 1988/Rev 1) 0843F

c Aquifer Permeability - Instantaneous recharge tests were performed on each of the groundwater monitor wells 1311, 1312, and 1313 in 1985.

These tests were conducted by placing a weighted length of PVC pipe into the well, instantaneously displacing the water level upward. Measurements were taken of the residual head and elapsed time during stabilization of the potentiometric surface as water moved into the formation around the well. Data from these tests and calculations of transmissivity and permeability are provided in Appendix B.

The data show a wide range of permeabilities for the Garber Sandstone, indicating anisotropic, nonhomogeneous conditions within the area tested.

This anisotrophy is believed due to variations in unloading fracture density and differences in grain size and the degree of comentation within the Garber Sandstone.

The permeability of the Garber Sandstone at monitor well 1311 was determined to be 1.7 feet per day, and 0.35 foot per day at monitor well 1312. Due to the very slow recovery in monitor well 1313, a permeability was not calculated from the test data.

The test data for monitor wells 1312 and 1313 confirm the slow rate of recovery observed in these wells during the removal of water for sampling purposes.

Average permeabilities in the range of 2.7 to 4.8 feet per day have been reported for the Garber Sandstone in Oklahoma and Cleveland counties to the south. H ' Considering the increase in the silt and clay fraction in the Garber Sandstone northward from Oklahoma Countyd' and the attendant decrease in yields in Logan CountyM', the Garber Sandstone d'

P. R. Hood and L. C. Burton, Note 10 supra n'

P. R. Wood and L. C. Burton, Note 10 supra n'

Oklahoma Water Resources Board, Note 17 supra (June 1988/Rev 1) 0843F

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q permeabilities determined from the tests of wells 1311 and 1312 are reasonable values.

For the relocation site, permeabilities ranging from 0,35 to 1.7 feet per' day are representative of the upper part of Garber Sandstone.

Direction and Rate of Groundwater Movement - Groundwater movement is to the north-northwest towards the Cimarron River.

The difference in potentiometric surface elevation between monitor wells 3011 and 3012 along the direction of groundwater _ movement is 3.3 feet across a horizontal distance of 230 feet, which is equivalent to a hydraulle gradient of

.approximately 76 feet per mile.

This relatively steep gradient is believed due to entrenchment of the prairie surface by the Cimarron River and its tributaries in the immediate vicinity. Calculations presented in Appendix C show the average velocity of groundwater movement through the upper part of the Garber Sandstone to be between 0.03 and 0.12 foot per day. Assuming the maximum velocity of 0.12 foot per day, groundwater would traverse the 230 feet along the hydraulic gradient between monitor wells 3011 and 3012 in approximately 1,917 days (5.3 years).

Meteorology:

f The area climate is characterized by hot summers and moderate winters. July, the hottest month, has an average temperature of 82.9'F and January, the coldest month, averages 38.3*F.

The average annual rainfall is 31 inches, received predominantly in the early spring and late fall months.

The innual net evaporation rate is approximately 30 inches.

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(June 1988/Rev 1) 0843E Y

Summary of Pertinent Relocation Site Features:

The relocation site topography is conipatible with the topography of the general area and the surrounding environs.

The site is a bluff area at the higher elevation within the facility property and will promote drainage of surface water away from the covered area and prevent accumulation or percolation of precipitation on or beneath the cover.

The geological and soll characteristics are such that no fault structures are present, assuring stability of the area and no concern for erosion.

Similarly, the hydrogeologichi charecteristics assure there are no concerns regarding contact

. with groundwater.

HATERIAL RELOCATION AND STABILIZATION PROCEDURE The relocation site will be prepared by excavating with mechanical equipment an area of sufficient size and depth to accommodate the estimated 400,000 cubic feet of material and a minimum of four feet of backfill-cover. All the relocated material will be placed in the single excavation that will have dimensions approximating 200 feet by 500 feet by 8 feet deep.

Thus, there will be a minimum of 10 feet between the lower dimension of the excavation and the occurrence of water bearing strata, which are some 20 to 30 feet beneath the surface.

The material to be placed in the excavation will be transported in dump trucks and will be covered when required to prevent dusting.

The material will be placed_in the excavation in lifts.

The consistency of the material will not produce volds and consolidation will be enhanced by the heavy equipment traversing the lifts. As required, dust suppression methods will be used to prevent dusting. Additional cover will be provided to compensate for any future subsidence.

(June 1988/Rev 1) 0843E

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The material placed in the excavation will be covered with a minimum of four feet of clean soll that will be placed in lifts and compacted.

The cover will 4

be contoured to blend with the area topography and to promote runoff of precipitation.

The surface will be prepared and seeded with a pasture grass mixture.

Following the seeding, the area will be inspected and maintained to assure that.vlable and complete revegetation occurs and no erosion develops.

Any required remediation measures will be.done promptly.

RADIATION SAFETY PROCEDURES The current facility radiation protection and monitoring program will apply for all activities. involved in defining, excavating, relocating and covering the material. Additional procedures will he employed as dictated by good health physics practices and consistent with the ALARA principle.

The essential elements of the radiation safety program are described briefly below Personnel Monitoring:

Radiation detection devices consist of film badges with activation foils for monitoring beta, gamma and neutron exposures.

The badges are chinged monthly and results are reviewed for compilance with permissible dose limits and filed. All personnel working in radiation areas are required to wear a detection device.

Bloassay Program:

Bloassay specimens are obtained and analyzed in accordance with NRC's Regulatory Guide No. 8.11, "Applications of Bloassay for Uranium."

(June 1988/Rev 1) 0843E

'.,C Radiation Surveys:

Radiation surveys are made of all areas where work is in progress and on a routine basis for determining surface levels and exposure rates.

Air Sampling:

Airborne radioactive material is monitored using commercial portable air samplers and analysis of the filter papers for alpha activity.

Contamination Control:

To. guard against spread of contamination, protective clothing will be worn by all personnel when required. Change rooms with locker and shower facilities are available. Monitoring for hand, shoe and clothing contamination shall be done at the work areas, and spot checks made upon exiting the change rooms.

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. Equipment Survey:

Equipment used for excavating, relocating and covering the material will be surveyed. Any contaminated surfaces will be cleaned to meet unrestricted release criteria.

RECORDS A narrative report will be prepared that describes the procedures employed in removing, relocating and covering the material.

The report will include a summation of the volume of material covered, the types and quantitles of radionuclides containcd in the relocated material, the time period over which relocation occurred, the physical characteristics of the relocated material and relocation area identification.

The report will be maintained until termination of the license.

(June 1988/Rev 1) 0843E

-STATE AND LOCAL CONSIDERATIONS All materials relating to this amendment request' have been provided to and dis' cussed with the Oklahoma State Department of Health.

Oklahoma is.a

.non-agreement state and defers to NRC for regulation of licensed material.

The State will'have a representative present during the final site verification survey program.

With regard to non-radiological issues, the State has indicated that they will be the lead agency and establish that a:

appilcable' regulatory requirements are satisfied.

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I (June 1988/Rev 1) 0843E

Figure 5.

Soil evaluation proceditre for the dinnnnit ion nf nnile

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SOIL EVALUATION PROCEDURE ON-SITE SOIL DISPOSITION CIMARRON URANIUM PLANT I

[

M T is m E GREATER THAN 4 FEET l

LESS THAN 4 FEET I

DEPTH TO Soll i

IN QUESTION ?

v

[ nous son. nsurr ] YEs LEAVE Soll IN PLACE g

(

esunnuA T

)

(No COVER REQUIREMENT) j V

LEAVE SOIL IN PLACE l

(FOUR FOOT COVER REQ'D)

V f

RELOCATE TO ONSITE j

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DISPOSAL AREA camsua e SHIPMENT TO OFFSITE DISPOSAL AT COMM. SITE

SEQUOYAH FUELS CORPORATION RESPONSE 'IO NRC REQUEST FOR ADDITIONAL INFORMATION DATED DECEMBER 29, 1987 ON-SITE SOIL DISPOSITION CIMARRON URANIUM PLANT SEQUOYAH FUELS CORPORATION LICENSE NO. SNM-928, DOCKET NO.70-925 1.

NRC Request:

Please provide detailed soil survey data around the Cimarron plant site. For each contaminated area, please provide the estimated volume of contaminated soil; the average concentration of radioactivity; the nature of contamination from past operations; and solubility tests for each category of contaminated area.

Please confirm that each of the wastes proposed for disposal contain no wastes considered hazardous under RCRA for characteristics other than radioactivity.

SPC Response:

Soil Survey Data A comprehensive site soil contamination survey was done and consisted of surface and subsurface rmrasurements established on a gridded pattern, borehole logging, and confirmatory core sample isotopic analysis. A map showing the site and the survey borehole grid pattern for the sanitary lagoon, pipeline and uranium plant areas is attached as Exhibit 1A.

The old burial ground borehole locations are shown on the nap attached at Exhibit 18.

Borehole logging summaries are provided for uranium plant and plutonium plant areas as Exhibits 2A and 25, respectively. Surveyed uranium plant areas are designated as L (sanitary lagoon area), BG (burial ground area) and UPP or UP (Uranium plant yard). Sample analysis results for the plutonium plant survey area, uranium plant crea (including lagoon and pipeline areas), and the burial ground area are attached as exhibits 3A, 3B and ?C.

The survey summaries include the borehole sampling location and field count rate results obtained for each one foot depth interval.

The soil core sanple chemical results include isotopic analysis and solubility character.

Finally, the percent of NRC Branch Technical Position Option 1 and Option 2 criteria for each sample location is noted.

'Ihe percent of Option 1 and 2 concentration was derived by plotting the borehole count rate data against known concentrations of uranium and thorium mixtures prepared and placed in test drums.

These count rates then established a representative threshold for each option level.

The use of several mixtures of isotopes in the reference drums was done because SFC believed such variable conditions may be encountered depending upon activities in each survey area.

Graphs relating count rate versus percent of Option 1 or Option 2 concentration criteria are (June 1988/Rev. 1)

presented for each general area in Exhibit 4.

Specific findings from the conprenensive soil survey are discussed below:

a.) Material Volume and Activity Estimates The site area contaminated soil volumes and activities projected for disposal either at a conrnercial low-level radioactive waste disposal facility (above Option 2) or to be left on-site (Option 1 and 2) is presented in Table 1 below:

TABLE 1 SOIL VOLUME AND ACTIVITY Estimated Average Uranium Activity Location Estimated Volume (ft )

(pCi/g)

On-Site Relocation Area 400,000 70 In-Situ. matt. rials at depth greater than four feet 3,000,000*

70 off-site Disposal at Cournercial Site (Remaining to be Shipped) 10,000 500 Shipped to Off-site Disposal at Commercial Site an of June 6, 1988 85,050 1200

  • The volume of material to be left in place was estimated from a soil contamination survey.

Borehole gar:rna logging results were entered into a computer program to generate Option 2 soil volumes.

The soil to be left in place under Option 2 is located at varying depths over the areas logged and identified in Exhibit lA.

b.) Solubility Tests l

The solubility data are included with the sample analysis results provided in Exhibit 2.

c.) Nature of Contamination l

Plant Area The soil contamination consists of enriched uranium only.

The decree of enrichment, as noted in our original submittal, is approximately 3%.

Surface contamination in the uranium plant yard and surrounding plant areas (June 1988/Rev. 1) t

s resulted from storage of contaminated equipment and recoverable scrap in the yard and spills from the uranium recovery solvent extraction process.

Soil contamination at depth was confined to areas along buried pipelines running from the uranium plant to the process waste evaporation ponds and was the result of leaks in the line joints.

Sanitary Lagoons The existing sanitary lagoons, which contain uranium contaminated sediments built up during the years of facility operation, will be cleaned and sediments above Option 2 levels will be shipped offsite for disposal.

Retraining residual contamination, consisting of surrounding soils containing enriched uranium, will be placed in the proposed onsite burial area.

Scrap, Process Waste Burial Ground There will be no onsite burial of facility generated contaminated wastes such as equipment, scrap or refuse. The old burial site used for disposal of this type material during early plant operations is being excavated and materials shipped off-site. The area will meet NRC Option 2 criteria.

Plutonium Contamination There is no plutonium contamination associated with the soils.

d.) RCRA Evaluation, The contaminated soil either left in place at dept.h or relocated onsite under Option 2 of the Branch Technical Position is not a RCRA hazardous waste.

The soils and associated contamination are neither listed wastes nor do they exhibic the Hazardous Waste characteristics of corrosivity, reactivity or ignitability.

EP toxicity tests have been completed for selected contaminated soil samples and are included as Exhibit 9.

Since the facility fuel fabrication processes consisted ot the use of pure, enriched uranium in solid or gaseous form or as solutions containing ammonium, nitrate and fluoride species there is no reason to believe that the soils would exhibit razardous waste characteristics.

2.

NRC Request:

Please provide a chronology of the past plant operations involving enriched uranium, thorium and plutonium.

Describe the operation process used and the disposal of solid and liquid wastes from past operations that resulted in the various categories of contaminated areas.

SPC Response:

Enriched uranium fuel was produced at the facility uranium plant from 1965 to 1975. Mixed oxide fuel for the FFTF program was produced at the facility plutonium plant from 1970 to 1975.

The contaminated soils, the subject of this application for burial under 10 CTR 20.302 and Branch Technical Position Options 1 and 2, resulted solely (June 1988/Rev. 1) from the enriched uranium fuels production facility which involved the following general process steps:

l

1) Enriched UF6 gas was contacted with an ammonia solution to produce solid amonium dicranate (ADU),
2) ADU was calcineft to produce uranium oxide (U0
powder, 3
3) Uranium oxide powder was mechanically pressed into pellets, and
4) The pellets were converted into ceramic grade UO in reduction furnaces.

2 An ancillary solvent extraction process was used to recover uranium from dissolved processing scrap and nonspecification material.

Uranium plant process liquid wastes were passed through an ion-exchange system to recover uranium and then discharged under permit to the cimarron River.

This treate' process effluent was released along with the overflow from the facility sanitary lagoons from 1965 to 1971.

Beginning in 1971 and continuing through 1975 the treated liquid effluent was routed to process waste evaporation ponds.

Sludges that accumulated in the process evaporation ponds were excavated, solidified and shipped to an offsite comercial low-level disposal facility. This sludge disposal activity occurred in 1976 and 1977 after which the ponds were reclaimed, surveyed and released for unrestricted use.

Previous license submittals for both the U plant (Stel-928) and Pu plant (Stel-ll74) contain detailed information relating to the facility process operations and waste handling techniques.

Please refer to those documents for additional information.

Solid wastes generated from the uranium facility activities were buried onsite at a designated burial ground from 1966 to 1970. After 1970, all solid wastes were shipped to an offsite comercial low-level radioactive disposal site.

The onsite waste burici ground is currently being excavated and its entire contents shipped offsite.

Although not processed at the Cimarron Facility, some thorium-bearing materials were placed in the site burial ground from decomissioning of the Cushing nuclear facilities in 1966.

As noted above, this burial area material, including the thorium, is bei.>g packaged and shipped to an offsite comercial low-level radioactive disposal facility.

There was no onsite disposal of plutonium wastes.

3.

NRC Request:

Are there any radioactive materials buried onsite from past operations?

If so, provide the records on the volumes, locations, and average radioactivity concentrations.

(June 1988/Rev. 1) _____

SFC Response:

Radioactive materials were buried onsite in a designated burial area from 1966 to 1970.

The volume and specific location of materials buried were not designated by trench number.

The burial records provide only the date, type of m terial and total activity of each burial.

This material is belag excavated for offsite disposal, and only snell amounts of soils meeting Options 1 and 2 will result.

Excavation, packaging

{

and shipnent of the entire waste volume to an offsite coninercial low-level disposal facility began in 1985. At this time wastes have been removed from three of the four burial trenches and work continues in the fourth.

SFC anticipates completion of this project during mid-1988.

A total of 6,434 drums of waste have been shipped offsite to date.

4.

NRC Regitest:

Are there any contaminated wastes from the uranium plant operation which contain plutonium? If so, please provide data.

SFC Response:

The sanitary legoons received wash, shower, sanitary and laundry water from both the uranium and plutonium operations.

Average concentrations of uranium and plutonium in sediments renoved from t.he lagoons are 1300 and 11 pCi/g, respeccively. Thi.s material was shipped to an offsite coninercial low-level radioactive disposal facility.

5.

NRC Request:

Please identify in a map with a scale the location of uranium plant yards 19, 128-C, #27-B; lagoon #5 and pipeline #3.

Describe the nature of contamination in these areas.

In Figure 1 of the submittal, sanitary lagoons are identified; has a radiological survey been mde of these lagoons? If so, please provide data.

SFC Response:

Exhibit lA contains a map which includes the locations of samples designated uranium plant yard # 9,

  1. 28-C, 127-B; lagoon #5 and pipeline #3. The nature of contamination in these areas is described in SFC Response to Item 1 of this transmittal.

Borehole logging results and sample analysis for the sanitary lagoon area are included in Exhibit 2.

Underlying soil samples were collected and composited for analysis following removal of lagoon sediments. 7he results are included in Exhibit 5.

6.

NRC Rayuest:

Plear

'rovide groundwater qui.lity data (radiological and chemical), if any, on the wells onsite.

SFC Response: Groundwater monitori-)g data for samples collected during 1987 are attached as Exhibit 6.

A map showl.ig monitoring well locations is included. Prior annual data should be available in the Docket file.

7.

NRC Request:

Provide a quality assurance program on the radiological l

(June 1988/Rev. 1) [

surveillance to irrplement the proposed action. The program should include a description of the instrumentation and methodology used for radiological measurements ' with quality controls on calibration, interlab checking, and data evaluats.on.

SFC Response:

The comprehensive quality assurance program associated with exacavation, sorting and disposal of contaminated soil includes the.

appropriate selection, calibration, and use of survey instrumentation. The program is comprised of the following elements:

a.

Instrumentation contamination with depth analysis is done with probes consisting of NaI detectors mounted in 2-inch PVC pipe with cone shaped metal points used for insertion into drum standards, boreholes or into loose soil being excavated and sorted. The detectors, which measure gamma radiation, are interfaced with Ludlum Model 2220 portable scalers.

Micro-R meters are used for locating surface contamination.

These instruments are used for detection only and not for measurements relative to Option 1 and 2 cleanup criteria, b.

Calibration The counting system for borehole gamna logging is calibrated with a series of specially prepared drums containing known uniform concentrations of uranium and thorium.

A three-inch diameter access pipe was installed in each drum to provide a portal for the NaI(Tl) scintillation probe prior to placement of uranium or thorium materials into the drum.

The probe is placed into each drum and a relationship ettablished between the instrument response in epm versus the cmcentration of uranium and thorium.

Samples of each calibration drum contents were collected, split and submitted to four analytical laboratories for determination of uranium and thorium concentrations.

Exhibit 7 contains the results of these reference drum analyses.

Graphr, of the probe count rate results versus percent of Branch Technical Position Options 1 and 2 are included in Exhibit 8.

Probe response is checked daily using at least one of the drum standarde and results recorded and evaluated prior to use.

c.

Excavation and Soil Sorting The soil excavation and sorting procedure for the uranium facility consists of the following:

I 1.

Calibration of the NaI probe system is checked daily against at l

least one drum standard.

l l

(June 1988/Rev. 1) l

. c */4,,

. q.,-

e 2.' The: top six inches of soil is removed from areas showing. surface contamination, such as the uranium plant yards. Soil which has been removed is sorted by probing each front end loader bucket,with the -

probe.

Based.upon the; reading, which is calibrated to the standards,- the material is ca.tegorized for offsite ' comercial

' disposal, onsite stabilization below four feet of cover, or onsite use as backfill if less than Option 1 criteria.

3.

The Borehole Survey will be performed on a ten-foot grid pattern to a depth of four (4) feet and the results compared to standards for categorization of the material.

4.

Soil excavation is performed as indicated by the surwy results and the material sorted either for packaging in preparation for offsite disposal or storage for onsite stabilization. Those soils at depths greater than four feet and meeting Option 2 criteria will be left in place.

5.

Micro-R meters are used during the excavation process to identify additional amall areas located between boreholes.

All material sorting is done using the NaI/Ludlum 2220 system.

6.

As a further quality assurance measure, additional soil samples will be collected as excavation and sorting proceeds..The' sample results will be evaluated to ensure tne probing technique and calibration are accurate.

8.

NRC Request:

After cleanup to Option 1 criteria, will the cleaned area ground-surface also be restored to blend with the area topography and to promote precipitation runoff, and be seeded, etc?

SFC ' Response:

The cleaned area ground surfaco will be restored to blend with the area topography while also pronoting precipitation rtinoff.

The uranium plant yard area will be graveled.

Soil areas outside of the yard l

area will be sprigged with bermuda grass and seeded with nurse cover grasses

'such as fescue to prevent erosion until the bermuda grass becomes established.

9.

NRC Request:

Provide additional data on measurements and sanpling of soil, l

including:

field and laboratory instrumentation; sampling and analysis techniques and procedures; averaging proceduros; and surveying procedures.

SFC Response:

Field instrumentation used consists of microR-meters and NaI Probe / Scaler systems.

Laboratory instrumentation includes equipment (June 1988/Rev. 1) 4 1.-

r necessary for alpha and gama pulse height analysis and fluorimetric analysis.

The majority of the - borehole sampling was performed by drilling :to the desired depth with an air rotary ' drilling rig and cleaning away the drillings by blowing out the hole. _ The drillings were sampled and in some cases, resampling was performed with borehole techniques using a' split spoon sampler.

The averaging procedure applied to areas being considered for exacation at the uranium facility is based on small, localized areas within an individual 10 meter by 10 meter plot.

Where localized spots exceed the option 2 threshold criteria by up to a factor of 2 they may be left in place provided the average concentration for the 10 by 10 grid, as determined by the gama logging, does not exceed the threshold criteria. The average concentration within the 10 meter by 10 meter area will be determined from the 10 foot by

'10 foot gama logging results for each one foot depth interval. Where soil is removed, the removal will have the objective of reducing the residual concentratioon as low as is reasonably achievable; in no case will concentrations greater than option 2 criteria, as determined by the NaI probe /Ludlum 2220 system, be returned to the excavated crea(s). E:ach bucket load of excavated soil will be probed in three places to decermine if the bucket of material is to be buried onsite, drumed for offeite disposal or returned. to _ the excavation as backfill.

The average value obtained f:som these three measurements will be used for this determination.

The sampling procedure is described in the response to Question 7.

(June 1988/Rev. 1)

. lT.

c j

w.

EXHIBIT 9 EP Toxicity Data 11

' Representative soil samples have been collected and analyzed to demonstrate that l

l Cimarron Facility' soils are not classified as RCRA'. hazardous materials.

l1 Analysis results for these sanples are attached. Sample locations are described

-below:

l f

t

- Sample '-

Location CS-14 Background Hole -

mile south of facility

-CS-17_

North of uranium plant / South of Coal process (UPP 9):

CS-15 Southeast 7f old waste pond No. 1 (Pipeline No. 3 Hol '

CS-16 Southwest corner of west' lagoon (Lagoon No. 5 Hole)

CS-64 Bottom Sediments of sanitary lagoons CS-18 South of uranium plant (UPP 28C)

CS-19 South of uranium plant (UPP 27C)-

(

I

l?

Y.

INTERNAL CORRESPONDENCE a

TO Ron Fine DATE May 16, 1988 Technology paou J. R. Jay SUBJECT Cimarron: Analysis of Soil Samples for 'IOPO or DOPE (UNIT)

Four soil samples were analyzed for the presence of 'IOPO or DOPE.

1) CS-14
2) CS-17
3) CS-15, 16, 64 Composite
4) CS-18,19 Composite Ten grams of each sample were extracted with three 40ml portions of hexane.

Next the solvent was evaporated at room temperature and the residue from each sample was transferred to a KBR plate. Each sample was analyzed by Fourier transform infrared spectroscopy.

'I+.e spectrum acquired for each sample corresponds to a mixture of vax and a large amount of plasticizer which may have come from the plastic sample container.

No 'IOPO or DOPE were detected.

s J. R. Jay JRJ:pc cc:

Kirk A. Saffell File: Chron Charge 8-4076 Project 8 42 04 t

$c

,o INTERNAL CORRESPONDENCE cm TO Ron Fine DATE May 26, 1988 Technology pacy Jim Jay SUBJECT Cimarron: Analysis of Soils, (UN:T)

Metals and HSL Org mics Four soil samples were analy::ed for metals and HSL crganics.

The sarples were submitted to 'mA,morcal and were analy::ed by EPA Publication SW 846 Methods.

1)

Cs-14

2) Cs-17 l

3)

Cs 15, 16 Corp.

i

4) Cs 18, 19 Corp.

See attachment for results.

The results of analyses for TBP and DOPE were reported to you previously.

Jim Jay JIC tT ;

cc:

Kirk Saffell Don Ward File: Chron Charge Cirarron, 8-4076 Project 8 42 04

i TMA ThEnn3 Analytic:Iinc.

RECEIVED APR 8 1988 wAfuore.,

2030 wngnr ^ venue DON WARD P O, Box 4C 40

- R :ntnond. C A 94904-0040 1415) 235 2633 Kerr McGee Technical Ctr.

March 28, 1988 3301 N.W.150th Street Samples Received:

2/22/88 oklahoma City, OK 73125 TMA/Norcal Lab No.: 2373-26 Attention: Don Ward ANALYSIS REPORT Sanple Identification CS-15,16,64 CS-18,19 CS-14 CS-17 Comp Comp.

Analysis (mg/L) 2373-26-1 2373-26-2 2373-26-3 2373-26-4 Arsenic 0.004

<0.005 0.005

<0.005 Barium 0.097 0.083 1.53 2.02 Cade.ium

<0.005

<0.005 0.010 0.006 Chromium

<0.01

<0.01

<0.01

<0.01 Lead

<0.1

<0.1 0.43 0.64 Mercury

<0.001

<0.001

<0.001

<0.001

!!ickel

<0.02

<0.02

<0.02

<0.02 Selenium

<0.01

<0.01

<0.01

<0.01 Silver.

<0.02

<0.02

<0.02

<0.02 Tnallium

<0.005

<0.005

<0.005

<0.005 Note: Rest.lts for semivolatile analysis attached.

M Lawrence /f. Johnson Program Manager LU / dss 1

  • f 1C CLIENT ID SEMIVOLATILE ORGANICS ANALYSIS DATA SHEET l -

I i

i CS-14 Lob Name:

TMA/NORCAL Contract:

1 I

Lob Code:

Case No.:

SAS No.:

SDG No. :

Matrix: (soil / water) SOIL Lab Sample ID:

2373-26-1 Sample ut/vol:

10.4 (g/mL) G Lab File ID:

A26562 Lovel:

(Iow/med)

LOW Date Received:

02/22/89

7. Moisture: not der

?,

dec.

Date Extracted: 03/03/89 E x trac tion:

(SepF, F.a/Sonc)

SONC Date Analyzed:

03/25/89 GPC Cleanup:

(Y/N) LL_

pH:

Dilution Factor: 2 880 CONCENTRATION UNITS:

CAS ND.

COMPOUND (ug/L or ug/Kg) UG/KG G

1 1

I I 99-09-2---------3-Nitroaniline 1

4600 IU l

! 83-32-9---------Acenaphthene 1

950 IU 1

51-28-5---------2,4-Dinitrophenol I

4600 IU 1

1 100-02-7---- ---4-Nitrophenol I

4600 IV l

132-64-9--------Dibenzofuran I

950 IU l

121-14-2--------2,4-Dinitrotoluene 1

950 IU l

! 84-66-2---------Diethylphthalate.

I 950

!U l

! 7005-72-3-------4-Chloropheny*-phenylether i

950

!U i

B6-73-7---------Fluorene 1

950

!U l

i 100-01-6--------4-Nitroaniline 1

4600

!U 534-52-1--------4,6-Dinitro-2-Methylphenol,__t 4600 IU l

! B6-30-6---------N-Nitrosodiphenylamine (1)

I 950 IU l

101-55-3--------4-Dromophenyl phenylether 950 IU l

i 118-74-1--------Herachlorobenzene 1

950 IU l

I 87-86-5---------Pentachloropheno(

l 4600 (U

l I 85-01-8---------Phenanthrene 1

950 IU l

1 120-12-7--------Anthracene 1

950 IU l

I 84-74-2---------Di-n-Butylphthalate 1

950 IU I 206-44-0--------Fluoranthene 1

950 IU l

129-OO-O--------Pyrene 1

950 IU l

! 85-68-7---------Butylbenzylphthalate 1

950 IU l

91-94-1---------3 3'-Dichlorobenzidine i

1900 IU l

56-55-3---------Denzo(a) Anthracene 1

950 IU l

i 218-01-9--------Chrysene 1

950

!U l

1 117-81-7--------bis (2-Ethylhexyl)Phthalate 1

950 IU I

l I

117-84-0--------Di-n-Octyl Phthalate 1

950 IU l

i 205-99-2--------Benzo (b)Fluoranthene 1

950 IU l

i 207-09-9--------Denzo(k)Fluoranthene 1

950 IU l

I 50-32-8---------Benzo (a) Pyrene 1

950 IU 193-39-5--------Indeno(1,2,3-cd) Pyrene 1

950 IU l

I 53-70-3---------Dibenz(a.h) Anthracene 1

950 IU l

i 191-24-2--------Benzo (g h,1) Perylene 1

950

!U l

l I

I I

Csnnot be separated from Diphenylamine (1)

Analyzed for but not detected U

Present but below detection limit J

Present in Diank l

D Exceeds calibration range E

FORM I SV-2 1/87 Rev.

l l

t i

1B CLIENT ID SEMIVOLATILE ORGANICS ANALYSIS DATA SHEET I

l CS-14 i

Lab Name:

TMA/NORCAL Contract:

1 Lab Code:

Case No.:

SAS No.:

SDG No.:

Ma tr i x : (soil / water) SOIL Lab Sample ID:

2373-26-1 Semple wt/vol:

10 4 (g/mL) O Lab File ID:

A26562 Level:

(low /med)

LOW Date Received:

02/22/89

% Moisture: not dec. O dec.

Date Extracted: 03/03/89 E r trac tion:

(SepF/ Cont /Sonc)

SONC Date Analyred:

03/25/99 G.:C Cl eanup:

(Y/N) N pH:

Dilution Factor: 2 890 CONCENTRATION UNITS:

CAS NO.

COMPOUND (ug/L or ug/Kg) UG/KG G

l l

I i

i 108-95-2--------Phenol I

950 IU l

111-44-4--------bis (2-Chloroethyl) Ether i

950 IU l

I 95-57-8---------2-Chlorophenol I

950 IU l 541-73-1--------1,3-Dichlorobenzene 1

950 IU l

1 106-46-7--------1,4-Dichlorobenzene i

950 IU l

1 200-51-6--------Benzyl Alcohol I

950 IU l

i 95-50-1---------1,2-Dichlorobenzene 1

950

!U l 95-48-7---------2-Methylphenol 950 IU I

108-60-1--------bis (2-Chloroisopropyl) Ether __!

950 IU 1

1 106-44-6--------4-Methylphenol 950 IU 621-64-7--------N-Ni tr o s o-D i-n-P r o p y l ami n e 1

950 IU i

! 67-72-1---------Hexachloroethane 950

!U l 98-95-3---------Nitrobenzene 950

!U l

I 78-59-1---------Isophorone I

950

!U l

! 88-75-5---------2-Nitrophenol 950 IU i 105-67-9--------2,4-Dimethylphenol 950 IU 1

1 65-85 --------B e n z o i c A c i d l

4600 IU l

111-91-1--------bis (2-Chloroethory) Methane 1

950 lU I 120-83-2--------2,4-Dichlorophenol l

950

!U l 120-82-1--------1,2,4-Trichlorobenzene 1

950 IU l

I 91-20-3---------Naphthalene 950

!U

! 106-47-8--------4-Chloroaniline 950 IU l

I 87-68-3---------Hexachlorobutadiene 1

950 lU l

I 59-50-7---------4-Chloro-3-Methylphenol I

950

!U l

! 91-57-6---------2-Methylnaphthalene 1

950 lU l

! 77-47-4---------Hexachlorocyclopentadiene 1

950 IU 1

i BB-06-2---------2,4,6-Trichlorephenol 950

!U l

I 95-95-4---------2,4,5-Trichlorophenol

__I

.4600 IU 1

i 91-58-7---------2-Chloronaphthalene 1

950 lU l 88-74-4---------2-Nitroaniline 1

4600

!U i

1 131-11-3--------Dimethyl Phthalate 1

950 IU l 208-96-8--------Acenaphthylene 1

950 lU

! 606-20-2--------2,6-Dinitrotoluene 1

950

!U l

l l

U

- Analy2ed for but not detected J

- Present but below detection limit D

- Present in Blank E

- Exceeds calibration range FORM I SV-1 1/87 Rev.

l.

1C CLIENT ID c'

SEMIVOLATILE ORGANICS ANALYSIS DATA SHEET I

i CS-17 i

Lab Name:

TMA/NORCAL Contract:

1.

Lab Code:

Case No.:

SAS No.:

SDG No.:

Ma tr i x :

(soil / water) SOIL Lab Sample ID:

2373-26-2 Sample wt/vol:

10 4 (g/mL) O Lab File ID:

A26563 Level:

(low /med)

LOW Date Received:

02/22/83

% Moisture: not dec. O dec.

Date Extracted: 03/03/89 Extraction:

(SepF/ Cont /Sonc)

SONC Date Analyzed:

03/25/98 GPC Cleanup:

(Y/N) N pH:

Dilution Factor: 2 880 CONCENTRATION UNITS:

C AS NO.

COMPOUND (ug/L or ug/Kg) UG/KO O

i l

I i

! 99-09-2---------3-Nitroaniline 4600 IU l 83-32-9---------Acenaphthene 1

950 IU l

I 51-28-5---------2,4-Dinitrophenol I

4600 IU l

! 100-02-7--------4-Nitrophenol 4600 IU l

! 132-64-9--------Dibenzofuran 950 IU l

i 121-14-2--------2,4-Dinitrotoluene 1

950 IU l

! 84-6e-2---------Diethylphthalate 950 IU l

1 7005-72-3-------4-Ch l or op h e n y l p h e ny l e t h e r 950

!U 86-73-7---------Fluorene 1

950

!U l

i 100-01-6--------4-Nitroaniline i

4600 IU

! 534-52-1--------4,6-Dinitro-2-Methylphenol I

4600 IU i

! B6-30-6---------N-Nitrosodiphenylamine (1)_

l 950 IU l

! 101-55-3--------4-Bromophenyl-phenylether 950 IU l

i 118 '4-1--------Hexachlorobenzene 1

950 IV l

l l 87-86-5---------Pentachlorophenol 4600

!U l

! 85-01-8---------Phenanthrene 1

950 IU l

l i 120- 12-7-------- An t h r a c e n e 1

950 IU

.I

! 84-74-2---------Di-n-Dutylphthalate I

950 IU l

I 206-44-0--------Fluoranthene 950

!U i

i 129-OO-0--------Pyrene 1

950

!U l

I 85-68-7---------Butylbenzylphthalate 1

950 IU l 91 1---------3, 3 '-Di c h l or o b e n r i d i n e i

1900

!U l

I 56-55-3---------Benzo (a) Anthracene 1

950 IU

! 218-01-9--------Chrysene 1

950 IU

! 1 17-81-7--------b i s ( 2-E t h y l h e x y l ) P h t h a l a t e 1

950 IV I

i 117-84-0--------Di-n-O c t y l P h t h a l a t e 1

950 IU l

1 205-99-2--------Benzo (b)Fluoranthene 1

950 IU 1 207-08-9--------D e n z o ( k ) Fl u o r a n t h e n e 1

950 IJ f

1 50-32-8---------Denzo(a) Pyrene 1

950

!U I

193-39-5--------I n d e n o ( 1, 2, 3-c d ) P y r e n e 1

950 IU i

1 53-70-3---------Dibenz(a.h)Anthrtcene 1

950

!U l

i 191-24-2--------D e n z o ( g, h,1 ) P e r y l e n e 1

950 IU l

I I

I (1) - Cannot be separated from Diphenylamine U

- Analyzed for out not detected J

- Present but below detection limit D

- Present in Blank E

- Exceeds calibration range FORM I SV-2 1/87 Rev.

10 CLIENT ID 4

SEMIVOLATILE ORGANICS ANACYSIS DATA SHEET a

I I

CS-17 Lcb Name:

TMA/NORCAL Contract:

I Lob Code:

Case No.:

SAS No. :

  1. 70 No. :

Matri:: (soil / water) SOIL Lab Sample ID:

2373-26-2 Scmple wt/vol:

10.4 (g/mL) O Lab File ID:

A26563 Lovel:

(low /med)

LOW Date Received:

02/22/89

% Moisture: not dec. O dec.

Date Extracted: 03/03/89 E x trac tion:

(SepF/ Cont /Sonc)

SONC Date Analyred:

03/25/09 GPC Cleanup:

(Y/N) N pH:

Dilution Factor: 2.890 CONCENTRATION UNITS:

CAS NO.

COMPOUND (ug/L or ug/Kg) UG/KO G

I I

i 108-95-2--------Phenol I

950 IU l

i 111-44-4--------bis (2-Chloroethyl) Ether 950 IU i

I 95-57-8---------2-Chlorophenol I

950 IU l

I 950 IU l

! 541-73-1--------1,3-Dichlorobenzene i 106-46-7--------1,4-Dichlorobenzene 1

950 IU l

i 100-51-6--------Benzyl Alcohol I

950

!U l

! 95-50-1---------1,2-Dichlorobenzene 1

950 IU l

I 95-48-7---------2-Methylphenol I

950 IU l

1 108-60-1--------bis (2-Chloroisopropyl) Ether __t 950 IU l

1 106-44-5--------4-Methylphenol 950 10 I 621-64-7--------N-Nitroso-Di-n-Propylamine 1

950 IV

! 67-72-1---------Herachloroethane t

950 IU l

I 98-95-3---------Nitrobenzene i

950 IU l

! 78-59-1---------Isophotone 1

950 IU l

! R8-75-5---------2-Nitrophenol 950 IU l

105-67-9--------2,4-Dimethy?. phenol I

950

!U l

I 65-85-0---------Denzoic Acid I

4600 IU I

111-91-1--------bis (2-Chloroethoxy) Methane 950 IU 1 120-83-2--------2,4-Dichlorophenol 950 IU I 120-82-1--------1,2,4-Trichlorobenzene 1

950 IU l

I 91-20-3---------Naphthalene 1

950 IU l

i 106-47-8--------4-Chloroaniline i

950 IU l

1 87-6t3-3---------H e x a c h l or o b u t a d i e n e 1

950

!U l 59-50-7---------4-Chloro-3-Methylphenol I

950 1U l

I 91-57-6---------2-Methylnaphthalene 1

950 IU l

I 77-47-4---------Hexachlorocyclopentadiene 1

950 IU i

! 88-06-2---------2,4,6-Trichlorophenol I

950 IU l

! 95-95-4---------2,4,5-Trichlorophenol 4600 IV I

I 91-58-7---------2-Chloronaphthalene t

950 IU

! BS-74-4---------2-Nittoaniline 1

4600 IU l

1 131-11-3--------Dimethyl Phthalate 1

950 IU 1 200-96-8--------Acenaphthylene 1

950 IU i

,1 606-20-2--------2,6-Dinitrotoluene 1

950 IU 1

1 I

i

__I Analyzed for but not detected U

Present but below detection limit J

B

- Present in Blank E

- Exceeds calibration range FORM I SV-1 1/87 Rev.

t,.I 1C CLIENT ID SEMIVOLATILE ORGANICS ANALYSIS DATA SHEET I

I I

CS-15_16_64_Cl Leb Name:

TMA/NORCAL Contract:

I Lob-Code:

Case No.:

SAS No.:

SDG No.:

Metrix: (soil / water) SOTL Lab Sample ID:

2373-26-3 Semple wt/vol:

10.6 (g/mL) G Lab File ID:

A26565 Leveli (low /med)

LOW Date Received:

02/22/88

7. Moisture: not dec. O dec.

Date Extracted: 03/03/88 Ex trac tion:

(SepF/ Cont /Sonc)

SONC Date Analy r ed:

03/25/98 GPC Cleanup:

(Y/N) N p H:

Dilution Factor: 2,830 CONCENTRATION UNITS:

C AG NO.

COMPOUND (ug/L or ug/Kg) UG/KG G

I I

i l

I 99-09-2---------3-Nittoaniline 1

4500 IU l 03-32-9---------Acenaphthene i

930 IU i

1 51-28-5---------2,4-Dinitrophenol I

4500 IU l

i 100-02-7--------4-Nitrophenol 1

4500 IV I 132-64-9--------Dibenzofuran 930

!U 1

1 121-14-2--------2,4-Dinitrotoluene 1

930 IU l

I 84-66-2---------Diethylphthalate 1

220 IJ i 7005-72-3-------4-Chlorophenyl phenylether I

930 IU 1

! B6-73-7---------Fluorene 1

930 IU l

i 100-01-6--------4-Nittoaniline 1

4500 IV

! 534-52-1--------4,6-Dinitro-2-Methylphenol 4500 IU l

! 86-30-6---------N-Nitrosodiphenylamine (1) 930

!U l

! 101-55-3--------4-Bromophenyl phenylether I

930 IU 1

! 118-74-1--------Herachlorobenzene 1

930 IU l

I 87-86-5---------Pentachlorophenol 4500 IU

! B 5-01 --------P h e n a n tis t e n e 1

930 IU 1

1 120-12-7--------Anthracene 1

930 IU l

I 84-74-2---------Di-n-Dutylphthalate 1

930 IU I 206-44-0--------Fluoranthene 1

930 IU l

I 129-OO-O--------Pyrene 1

930 IU l

I 85-68-7---------Butylbenzylphthalate 1

930 IU l

I 91-94-1---------3,3'-Dichlorobenridine i

1900 IU l

I 56-55-3---------Denzo(a) Anthracene 1

930 IU l

1 218-01-9--------Chrysene 1

930 IU

(

1 117-81-7--------bis (2-Ethylhexyl)Phthalate 1

5000 1

I i

117-84-0--------Di-n-Octyl Phthalate 1

930 IU l

1 205-99-2--------Benzo (b)Fluoranthene 1

930 IU l

l l 207-08-9--------Denzo(k)Fluoranthene 930 IU l

l I

50-32-8---------Benzo (a) Pyrene 1

930 IU 1

1 193-39-5--------Indeno(14 2,3-cd) Pyrene 930 IU 53-70-3---------Dibenz(a,h) Anthracene, 930 IU i

i 191-24-2--------Benzo (g h,1) Perylene 1

930 IU l

i I

I I

(1) - Cannot be separated from Diphenylamine i

U

- Analyred for but not detected 1

J

- Present but below detection limit l

D

- Present in Blank E

- Exceeds calibration range FORM I SV-2 1/87 Rev.

l l

't.

1B CLIENT ID SEMIVOLATILE ORGANICS ANAL,YSIS DATA SHEET 2

1 I

CS-15_16_64_Cl Lob Name:

TMA/NORCAL C ontrac t:

I

J Lob Code

Case No.:

SAS No.:

SDO No. :

J Ma tri r: (soil / water) SOIL Lab Sample ID:

2373-26-3 Sample ut/vol:

,10.6 (g/mL) G Lab File ID:

A26565 Lovel:

(low /med)

LOW Date Received:

02/22/83 7 Moisture: not dec. O dec.

Date Extracted: 03/03/93 Er trac tion:

(SepF/ Cont / Sone)

SONC Date Analyzed:

03/25/EB GPC Cleanup:

(Y/N) N pH:

Dilution Factor: 2 830 CONCENTRATION UNITS:

CAS NO.

COMPOUND (ug/L or ug/Kg) UO/KG G

l i

I i

108-95-2--------Phenol I

930 IU l

1 111-44-4--------bis (2-Chloroethyl) Ether i

930 IU l

I 95-57-B---------2-Chlorophenol 930 IU l

I 541-73-1--------1,3-Dichlorobenzene 1

930 IU l

i 106-46-7--------1,4-Dichlorobenzene 1

930 IU l

l 100-51-6--------Benzyl Alcohol I

930 IU l

I 9 5 1 --------- 1, 2-D i c h l o r o b e n z e n e 1

930 IU

! 95-48-7---------2-Methylphenol I

930

!U l

i 108-60-1--------bis (2-Chloroisopropyl) Ether __t 930 IU l

i 106-44-5--------4-Methylphenol 930

!U l

621-64-7--------N-Nitroso-Di-n-Propylamine 1

930 IU l

1 67-72-1---------Hexachloroethane 1

930 IU l

! 98-95-3---------Nitrobenzene 1

930

!U l

! 78-59-1---------Isophotone 1

930 IU l

i BB-75-5---------2-Nitrophenol I

930 IU l

! 105-67-9--------2,4-Dimethylphenol I

930 10 1

65-85-0---------Benzoic Acid i

4500 lU l

l 111-91-1--------bis (2-Chloroethoxy) Methane 930 IU l

i 120-83-2--------2,4-Dichlorophenol C30 IU l

120-82-1--------1,2 4-Trichlorobenzene 1

930

!U 1

1 91-20-3---------Naphthalene 1

930

!U

! 106-47-8--------4-Chloroaniline 1

930 IU l

I 87-68-3---------Hexachlorobutadiene 1

930 IU l

! 59-50-7---------4-Chloro-3-Methylphenol I

930 IU l

I 91-57-6---------2-Methylnaphthalene 1

930

!U l 77-47-4---------Hexachlorocyclopentadiene 1

930 IU l

! 88-06-2---------2,4,6-Trichlorophenol I

930

!U l

! 95-95-4---------2,4,5-Trichlorophenol 4500

!U l 91-58-7---------2-Chloronaphthalene 1

930 IU l

! 88-74-4---------2-Nittoaniline 1

4500 IU 131-11-3--------Dimethyl Phthalate 1

930 IU l

t 208-96-8--------Acenaphthylene 1

930 IU l

! 606-20-2--------2,6-Dinitrotoluene 1

930 IU l

I Analyred for but not detected U

Present but below detection limit J

Present in Diank B

Exceeds calibration range E

FORM I SV-1 1/87 Rev i

1C CLIENT ID SEMIVOLATILE ORGANICS ANAL'YSIS DATA SHEET I

i t

s 1

. C S-18_19_C OMP !

Lab Name:

TMA/NORCAL Contract:

1 I

Lab Cod e:

Case No.:

SAS No. :

SDG No. :

Ma tr i x : (soil / water) SOIL Lab Sample ID:

2373-26-4 Sample wt/vol:

10.7 (g/mL) O Lab File ID:

A26564 Lovel:

(low /med)

LOW Date Received:

02/22/88 7,

Moisture: rot dec. O dec.

Date Extracted: 03/03/98 E x trac tion:

(Sep~/ Cont /Sonc)

SONC Date Analy r ed:

03/25/89 GPC Cleanup:

(Y/N) N pH:

Dilution Factor: 2 800 CONCENTRATION UNITS:

CAS NO.

COMPOUND (ug/L or ug/Kg) UO/KG G

I I

99-09-2---------3-Nitroaniline 1

4500 IU l

l 83-32-9---------Acenaphthene 1

920 IU l

I 51-28-5---------2,4-Dinitrophenol 4500 IU l

i 100-02-7--------4-Nitrophenol I

4500 lU l

i 132-64-9--------Dibenzofuran i

920 IU i

i 121-14-2--------2,4-Dinitrotoluene 1

920 IU l

1 84-66-2---------Diethylphthalate 1

920 lU l 7005-72-3-------4-Chlorophenyl-phenylether i

920 IU l

i 86-73-7---------Fluorene 920

!U l

! 100-01-6--------4-Nitroaniline 4500 IU 1

i 534-52-1--------4,6-Dinitro-2-Methylphenol 4500 IU I B6-30-6---------N-Nitrosodiphenylamine (1)

I 920

!U I 101-55-3--------4-Bromophenyl-phenylether l

920 IU i

i 118-74-1--------Herachlorobenzene 920

!U

! 87-86-5---------Pentachlorophenol 4500 IU l

! 85-01-8---------Phenanthrene 1

920

!U I

120-12-7--------Anthracene 1

920

!U

84-74-2---------Di-n-Butylphthalate 920

!U

! 206-44-0--------Fluoranthene 920 IU

~~

I 129-OO-0--------Pyrene 920

!U I B5-68-7---------Dutylbenzylphthalate 920 IU 91-94-1---------3,3'-Dichlorobenzidine i

1800 IU l

I 56-55-3---------Benzo (a) Anthracene 920

!U i

1 218-01-9--------Chrysene 920 IU 137-81-7--------bis (2-Ethylhexyl)Phthalate 920 IU l

117-84-0--------Di-n-Octyl Phthalate 920 IU i I 205-99-2--------Benzo (b)Fluoranthene 1

920 IU l

1 207-08-9--------Benzo (k)Fluoranthene 920

!U l

50-32-8---------Benzo (a) Pyrene 920

!U l

i 193-39-5--------Indeno(1,2,3-cd) Pyrene 920

!U i

1 53-70-3---------Dibenz(a,h) Anthracene i

920 IU i

191-24-2--------B e n z o ( g h,1 ) P e r y l e n e 1

920 IU l

I I

I i

Cannot be separated from Diphenylamine (1)

Analyred for but not detected U

Present but below detection limit J

Present in Blank B

Exceeds calibration range E

1/87 R'ev FORM I SV-2

SEMIVOLATILE ORGANICS ANA(ySIS DATA SHEET I

CS-1B_19_COMPI

?

Lot Name:

TMA/NORCAL Contract:

l l

Leb Cod e:

Case No.:

SAS No.:

SDG No.:

I Matrix: (soil / vater) SOIL Lab Sample ID:

2373-26-4 l

Semple ut/vol:

10.7 (g/mL) G Lab File ID:

A26564

(

Level:

(low /med)

LOW Date Received:

02/22/89

7. Moisture: not dec. O dec.

Date Extracted: 03/03/89 E x trac t ion:

(SepF/ Cont /Sonc)

SONC Date Analy z ed:

03/25/88 GPC Cleanup:

(Y/N) N pH:

Dilution Factor: 2 900 CONCENTRATION UNITS:

CAS NO.

COMPO JND (ug/L or ug/Kg) UG/KG G

108-95-2--------Phenol I

920 IU l

i 111-44-4--------bis (2-Chloroethyl) Ether 920 IU l

I 95-57-8---------2-C h l o r o p h e n o l I

920 IU l

! 541-73-1--------1,3-Dichlorobenzene 1

920 IU l

1 106-46-7--------1,4-D4 chlorobenzene 1

920 IU l

i 100-51-6--------Denzyl Alcohol 920

!U l

! 95-50-1---------1,2-Dichlorobenzene 1

920

!U 1

I 95-48-7---------2-Methylphenol 920 IU l

i 108-60-1--------bis (2-Chloroisopropyl) Ether __l 920 10

! 106-44-5--------4-Methylphenol.

I 920 IU l

I 621-64-7--------N-Nitroso-Di-n-Propylamine 920 IU l

! 67-72-1---------Hexachloroethane 1

920 IU l

I 98-95-3---------Nitrobenzene_.

t 920 10 1

I 78-59-1---------Isophotone_

l 920

!U i

I 88-75-5---------2-Nitrophenol I

920 IU l

i 105-67-9--------2,4-Dimethylphenol 1

920 IU l

! 6 5-85-0---------D e n z o i c A c i d i

4500 IU l

i 111-91-1---~----bis (2-Chloroethoxy) Methane 920 IU l

i 120-83-2--------2,4-Dichlorophenol 920 IU

! 120 1 -------- 1, 2, 4-Tr i c h l o r o b e n z e n e __.

I 920 IU l

! 91-20-3---------Naphthalene 1

920 IU

! 106-47-9--------4-Chloroaniline 1

920 IU 1

1 87-68-3---------Hexachlorobutadiene 1

920 IU l

I 59-50-7---------4-Chloro-3-Methylphenol I

920 IU l

! 91-57-6---------2-Methylnaphthalene 1

920

!U l

! 77-47-4---------Hexachlorocyclopentadiene 1

920 IU 1

1 88-06-2---------2,4,6-Trichlorophenol 920

!U i

I 95-95-4---------2,4,5-Trichlorophenol l

4500 IU l

! 91-58-7---------2-Chloronaphthalene 1

920 IU l

I 88-74-4---------2-Nitroaniline 1

4500 IU I 131-11-3--------Dimethyl Phthalate 1

920 IU l

i 208-96-8--------Acenaphthylene 1

920 IU l

! 606-20-2--------2,6-Dinitrotoluene 1

920 IU l

I U

- Analyzed for but not detected J

- Present but belcw detection limit B

- Present in Diank E

- Exceeds calibration range FORM I SV-1 1/87 Rev.

_ _ ____J