ML20202C416

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Forwards Assessment of Licensee Response to Closeout Survey Findings & Special & Soil Sample Results from Confirmatory Surveys for Lynchburg Research Ctr.Listed Issues Should Be Resolved W/Licensee
ML20202C416
Person / Time
Site: 07000824
Issue date: 06/10/1986
From: Barr K
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Crow W
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
27093, NUDOCS 8607110258
Download: ML20202C416 (15)
v • d • e


Text

i EEiHRN TO 396-SS UNITED STATES gg *

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[ptfo o / 't o NUCLEAR REGULATORY COMMISSION

, 2* ' ' REGloN ll k* 101 MARIETTA STREET, N.W. s

, e ATL ANTA, GEORGI A 30323 e

%*****/ JUN 101936

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  • MEMORANDUM FOR: W. T. Crow, Acting Chief ~

g RECENen Cu _

Uranium Fuel Licensing Branch lg Division of Fuel Cycle and Material Safety f g*fClaen g6 b d2 Office of Nuclear Materials Safety and Safegua Issio[*0er f FROM: Kenneth P. Bar: , Chief p 4

Nuclear Materials Safety and Safeguards Branch w Division of Radiation Safety and Safeguards

SUBJECT:

CONFIRMATORY RADIOLOGICAL SURVEY OF THE BABC0CK AND WILC0X, LYNCHBURG RESEARCH CENTER (LRC), BUILDING C, PHASE I, LYNCHBURG, VIRGINIA, DOCKET 70-824 Our memorandum of February 19, 1986, forwarded Inspection Report No. 70-824/

85-08, which detailed the results of our closecut inspection and confirmatory survey of Phase I of Building C. The licensee's letter to you of March 25, 1986 responded to the six issues we identified in our inspection report relating to the release of Building C. Enclosure 1 contains our assessment of the licensee's position on each issue. As noted in our previous memorandum, certain samples obtained during the confirmatory survey were sent to DOE /RESL in Idaho for analysis. The results of those analysis and our evaluations are attached in Enclosures 2 and 3.

The adequacy of the scope of the licensee's surveys, the disposition of the facility stack and the high background radiation levels in Building C are issues which NMSS should resolve with the licensee. We also feel that NMSS should resolve with the licensee exactly what their objective is, release of Building C for unrestricted use or confirmation a certain level of decontamination has been achieved with the building remaining under licensed control. If the latter is the licensee's objective, we do not believe it would be necessary or useful for Regicn II to conduct any further confirmatory surveys.

' Kid h*

Kenneth P. Barr

Enclosures:

1. Region TI Assessment of Licensee / c- Er Response to Close Out Survey ' 'p 4 Findings g
2. Special Sample Results from p @c ge Confirnatory Survey (
3. Soil Sample Results from Confirma- 7 M {q-tory Survey g

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ENCLOSURE 1 REGION II ASSESSMENT OF LICENSEE RESPONSE TO CLOSE0VT SURVEY FINDINGS

1. Finding A Off gas ducts which are still in service run through the Phase I area. The site effluent stack is shown in the Phase I map as part of the area being released. Release of Building C for unrestricted use would cause the site gaseous effluent release point to be outside of the restricted area I boundary.

Licensee Comment The off gas duct work in the Phase I area services Phase III. This duct work will be removed when decontamination of Phase III is complete. No off gas ducts will run through any released portion of Building C after the decontamination project is finished.

Region II Response Removal of the ducting during Phase III has the potential for recontam-inating Phase I areas and may pose an unevaluated hazard to future occupants until it is removed.

Licensee Comment The stack and fan room will continue to serve the Building B hot cells and release is not being sought. LRC is seeking NRC concurrence that the excavation beneath the fan room has been decontaminated to release levels and can be permanently refilled.

Region II Response The licensee submitted a revised phase boundary map with their response.

The revised map indicates that the stack is excluded from release, but indicates that the fan room is included in Phase III. This needs to be clarified as it is our understanding based on the licensee's comments, that the fan room will continue in service.

As for the excavations under the fan room, our confirmatory surveys were in agreement with the licensee's results. It is our understanding that what the licensee means by " permanently refilled" is that no further sampling of the excavations will be required in the future when the license is terminated. NMSS should consider informing the licensee if this is the NRC position.

Enclosure 1 2 Licensee Comment How the stack and fan room will be physically isolated from all non-use areas remains an open issue. This issue will be resolved as the license conditions for reoccupation of Building C are clarified.

Region II Response Continued use of the site stack in its present location would cause the site gaseous effluent release point to be outside of the restricted area boundary. The ultimate disposition of the stack should be resolved with the licensee.

2. Finding B Background gamma radiation levels from sources outside of Building C may cause unmonitored personnel occupying Phase I, if it were released, to receive an exposure in excess of 500 millirem in a year.

Licensee Comment A lid shield has been designed for the Building J Annex and it is expected that the gamma background will be well below the 500 mr/ year limit. This will be confirmed by surveying all of Building C, and will be reported to NRC in the Phase III report.

Region II Response The concern over the radiation levels in regard to exposures to future building occupants remains valid. Regardless of the source, radiation levels throughout the Phase I area remain in excess of the 10 microrem/ hour release limit. As noted in the confirmatory survey report, the background radiation levels in several areas is also such that adequate beta gamma scan surveys cannot be performed.

3. Finding C No surveys were performed in the fire equipment room. Only fifteen alpha contamination smears were performed in the front portion of the Old Central Stores. No other surveys were made. Throughout the Phase I area, only floors were surveyed for beta gamma contamination and direct radiation.

Licensee Comment The fire equipment room will be surveyed and reported in the Phase III report. Additional random direct and removeable beta / alpha surveys will be performed in the front portion of the Old Central Stores on the floors and walls. Results will be reported as a supplement to the Phase I report.

Enclosure 1 3 Region II Response Region II has no comments.

Licensee Comment The survey plan in Building C called for 100% alpha survey of flocrs, walls, and ceilings in laboratories, and for beta surveys of about 1/3 of floor grids. This plan provides a sound basis for the Building C release surveys.

Region II Response We continue to believe that representative areas of all surfaces should be surveyed to show compliance with all the applicable release criteria.

4. Finding D The licensee did not remove paint from surfaces containing the original coat of paint or in areas where special nuclear material had not been handled (Labs 25, 26, 27, and Old Central Stores).

Licensee Comment This is no evidence from the finding of contamination under the paint on the Lab 44 floor, from the building history, or from the survey of original painted surfaces to suggest that the approach is flawed and that paint chip sampling on the unstripped walls of Labs 25, 26, 27, or Old Central Stores is warranted.

Region II Response Samples of paint and concrete were obtained during our confirmatory survey.

As discussed in Enclosure 2, every sample showed detectable alpha and beta radioactivity. The licensee should make a reasonable effort to survey and decontaminate these painted surfaces.

5. Finding E A smear reading 16 2 dpm of alpha contamination was found on the inside of a pipe in Lab 44. The possibility of residual contamination elsewhere in the pipe and its removal should be evaluated.

Licensee Comment A 24 inch by 6 inch cloth was pulled through the entire length of the electrical conduit with a fish tape. The total activity on the cloth was 60 dpm, or <4 dpm/100cm2 Conventional small area smears were also taken at

Enclosure 1 4 each end of the conduit. One smear read 3 dpm/100cm2 , and the other read 0 dpm/100cm 2 . Based on these findings, LRC does not believe removal of the conduit is necessary.

Region II Response We believe that finding even low levels of contamination in an electrical conduit is significant. The conduit is 9.5 feet long and has at least one 90 bend. Direct surveys of the internals are not possible. This finding also calls into question the licensee's judgement that numerous such items, such as electrical conduits, water lines, service air lines, etc., did not need to be surveyed on the basis that no potential existed for those systems having been contaminated.

6. Finding F Soil and concrete samples collected in the U-233 process area were not analyzed by the licensee for U-233 content.

Licensee Comment Soil was assayed for U-233 activity using an indirect method.

Region II Response We concur that the assay for U-233 was adequate based on the clarification provided in their response and review of the results of our confirmat'ory surveys.

ENCLOSURE 2  ;

i SPECIAL SAMPLE RESULTS FROM CONFIRMATORY SURVEY Appendix G to inspection report number 70-824/85-08 contained a description of 15 special samples that were obtained during the confirmatory survey (Table 1). l The samples were forwarded to the Department of Energy's Radiological Environ- I mental Sciences Laboratory (RESL) for analysis. All samples were initially l counted for gross alpha and beta radioactiv.ty and isotopic identification by gamma spectroscopy (Table 2). Two of the samples were then processed by chemical separation and counted on a surface barrier detector (Table 3).

All of the samples revealed detectable alpha and beta radioactivity. The findings also suggest that many items or systems which the licensee assumed to have no potential for contamination, were in fact contaminated. We suggest that the licensee be required to perform representative surveys of all items and systems in areas to be released.

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TABLE 1 SPECIAL SAMPLE LOCATIONS AND DESCRIPTIONS Sample No. Date Location Description 1 11/20/85 Pit under Lab 50, grid 1778 Sludge from pit sump 2 11/20/85 North wall of Lab 44 Paint from backside of electrical conduit 3 11/20/85 South ceiling of Lab 44 Paint from exterior of water pipe 4 11/21/85 Southeast corner of front Cloth wipe inside hallway of ventilation duct 5 11/21/85 Ventilation portal between Approximate 4" X 4" Labs 27 and 50 patch from furnace filter 6 11/21/85 West side of Lab 43 Cloth wipe inside of ventilation duct 7 11/21/85 Ceiling of Lab 43 Sediment from dead-leg of sprinkler header - approxi-mately one pint of water filtered through a #41 filter 8 11/21/85 Front hallway wall east of Concrete and paint door 6, grid 377 9 11/21/85 Office 1, east wall, grid II Concrete and paint 10 11/21/85 Lab 43, north wall, east of Concrete and paint door grid 1059 11 11/21/85 Lab 44, south wall, east of Concrete and paint door, grid 1291 12 11/21/85 Lab 27, north wall, grid 832 Concrete and paint 13 11/21/85 Lab 25, north wall, grid 501 Concrete and paint 14 11/21/85 Lab 52, north wall, grid 1571 Concrete and paint 15 11/21/85 Lab 53, floor, grid 1678 Concrete from around sump

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i TABLE 2 SPECIAL SAMPLE ANALYSIS foci /am)

I Sample No. Gross Aloha Gross Beta CO-60 U-235 Pa-243m Am-241 Cs-137 1 1714 1215 ND ND ND ND 0.0810.12 2 412 714 ND ND ND ND 0.310.2 3 3817 1116 ND ND ND ND 0.0310.08

, 4a 3516 4816 ND ND ND ND 814 Sa 320140 158114 ND ND ND ND 313 l ND 313 6a 2114 2614 ND ND ND

! 7a 1312 311 ND ND ND ND 1.110.05 8 2014 3315 ND ND ND ND O.2010.15 9 1413 2315 ND ND ND ND 0.0910.15 10 712 1214 ND ND ND ND 0.0910.09 11 1012 2515 ND ND ND ND 0.0510.10 12 2114 2915 ND ND ND ND 0.1610.13 13 1614 3816 ND ND ND ND 0.0710.10 14 1013 813 ND ND ND ND 0.1310.22 15 1914 1114 ND ND ND ND 0.1310.09

a. Results a re reported in pCi/ Sample
b. ND = None Detected i

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TABLE 3 ,

PROCESSED SPECIAL SAMPLE ANALYSIS .

S* role No. Am 241 Pu-2)$ Pu-239/240 Th-228 Th-230 Th-232 U-234/233 U-235 U-238 1

3(pci/gm) 10.610.3 0.8710.05 30.910.9 0.5810.06 0.5510.06 0.6410.06 3.7210.14 0.1910.03 1.2310.07 5(pCl/ sample) 6.310.14 0.7010.2 32.111.2 1.7010.3 0.9010.4 1.5010.3 85.0012 3.7010.3 35.9011.2 4

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ENCLOSURE 3 SOIL SAMPLE RESULTS FROM CONFIRMATORY SURVEY Appendix H to inspection Report 70-824/85-08 contained a description of 14 soil samples collected within the excavations under Phase I of Building C. Appendix I of the report contained a description of 9 samples taken from drums of soil which the licensee had previously analyzed and two background soil samples. All samples were forwarded to DOE /RESL for analysis. All samples were initially counted for gross alpha and beta radioactivity and isotopic identification by gamma spectroscopy (Table 1). Eight of the simples were then processed by chemical separation and counted on a surface barrier detector (Table 2). A comparison was then performed of the results of the latter analysis for six of the drum samples and licensee results (Table 3). As a final check of the licensee's analytical techniques, DOE /RESL prepared a spiked sample and forwarded it to the licensee for analysis. The licensee's results were compared to the spiked values (Table 4) using the criteria in Table 5. Based on a review of the spiked and split sample results it was determined that the licensee's sample analysis had been performed in an acceptable manner.

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TABLE 1 .

EXCAVATION. DRUM AND BACKGROUND Soll SAMPLE ANALYSIS ,

Camma Isotopic l Sample ID Gross Alpha Gross Beta Co-60 U-235 Pa-243m Am-241 Cs-137 "

pCi/qm pCi/qm pCi/qm pCi/qm pCi/qm pCi/am pCI/qm

SN1132 (Soil #1) a-813 a512 ND .091.06 -1.312.1 ND .011.04 i SN1133 (Soil #2) a-311 a613 ND -

.091.06 514 ND .051.04 SN1134 (Soil #3) a-712 a1115 ND 101.07 515 ND .091.05 SN1135 (Soil #4) a-311 a4t2 ND .071.06 814 ND .151.05 j SN1136 (Soil #5) a-712 a814 ND .001.07 016 ND .041.05 SN1137 (Soil #6) a-010.3 a1015 ND .101.06 -314 ND .151.05 SN1138 (Soil #7) a-211 a814 ND .211.07 515 ND .151.05 SN1139 (Soil #8) a-211 a914 ND .051.04 515 ND .221.06

$ SN1140 (Soil #9) a-1.010.3 a312 ND -

.021.07 915 ND 101.04 i SN1141 (Soil #10) a-1.010.3 a713 ND .011.07 -515- ND .021.05  :

i SN1142 (Soil #11) a-912 a1015 .691.09 -

.011.05 -113 ND 251.07 4 SN1143 (Soil #12) a-1.0io.3 a412 ND .0516 -214 ND .011.05

  • SN1144 (Soil #13) a-8i3 a814 ND .141.06 015 ND 101.08 SN1145 (Soil #14) a-411 a814 ND -

.041.06 513 ND .051.05 SN1146 (Soil PDPD 308) a2116 a713 ND .291.06 -1.513.9 1.791.16 .001.05 SN1147 ( So i l PDPD 383) a3218 a1516 ND .291.07 015 2.91.2 .011.02 SN1148 (Soil PDPD 542) a-712 a713 ND -

.051.06 -114 ND .101.04 SN1149 (Soil PDPD 836) a215 alliS ND -

.011.06 414 ND 161.05 SN1150 (Soil PDPD 1834) a0.010.3 a1215 ND .211.06 --1.613.3 ND .021.03 SN1151 (Soil PDPD 1917) a2015 a713 ND .271.06 614 1.531.14 .121.04 SN1152 (Soit Backg round 2214 1215 ND .011.06 -614 ND 0.91.05 23-5-2) .331.06 l SN1153 (Soil Background) 1914 1415 ND .071.07 -215 ND SN1154 (Soil PDPD 312) a96124 a1918 ND .491.06 1115 4.910.2 .041.04 SN1155 ( Soi l PDPD 420) a126131 a1717 ND .461.07 -214 8.513 .041.05 SN1156 (Soil PDPD 1173) a-211 a814 ND .081.06 114 1.071.16 .051.05 l

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} a. Soil background gross alpha and beta levels have been subtracted.

2 b. Resul ts a re reported in pCi/ Sample, i c. ND - none detected.

j d. Other isotopes identified in some samples by galoma spectroscopy were Ac-228, K-40, Pb-212, and Pb-214. ,

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TABLE 2 PROCESSED SAMPLE ANALYSIS foci /om) .

Am-241 Pu-238 Pu-239/240 Th-228 Th-230 Th-232 U-234/233 U-231 U-2JA

  • SN1146 1.491.05 111.01 4.501.14 1.131.05 1.131.05- 1.111.05 6.461.17 .271.02 1.771.06 SN1147 2.421.08 .261.02 9.0 .3 .941.05 .931.05 .971.05 9.li.2 .361.02 3.481.10 SN1151 1.371.05 .181.01 6.81.2 .931.05 .911.05 .911.05 8.81.2 .421.03 3.611.10 SN1152 .00171.0035 .01.002 .0021.002 1.041.04 .991.04 1.13 .05 1.111.04 .041.01 1.05t.03 SN1153 .0061.004 .0021.002 .0141.003 1.211.05 1.241.05 1.111.05 1.281.04 .071.01 1.241.04 SN1154 4.21.2 .471.06 13.81.5 1.391.12 1.421.14 1.241.12 9.61.3 .381.06 4.41.2 SN1155 7.51.3 1.121.09 40.111.2 2.031.16 1.431.13 1.711.13 13.81.4 .781.08 4.51.2 SN1156 .931.03 .061.01 3.801.11 1.001.04 .971.04 1.001.04 1.361.04 .071.01 1.281.04

TABLE 3 .

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B&W LRC/NRC COMPARISONS DCl/am .

4 Am241 Pu (239.238.2f0) 4 Th232 U (233. 234. 235) .

1 Sample M HR9 M N3Q M HRQ M NRQ SN1154 3.08 4.2 16.57 14.27 .99 1.24 17.04 9.98 SN1155 5.74 7.5 30.89 40.22 1.14 1.71 22.58 14.58 SN1156 1.28 .93 6.92 3.86 .95 1.00- 3.44 1.43 SN1146 .95 1.49 4.09 4.61 1.76* 1.11 4.21* -1.73 SN1147 1.71 2.42 7.38 9.26 1.76* .97 2. 01 * . 9.46 SN1151 .95 1.37 4.10 6.98 1.76* .91 4.98* 9.22 T

  • Includes mean background i

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TABLE 4 .

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NRC SPIKED SOIL SAMPLE .

Ratio

  • Comparision Istone B&W. DCi/am NRC. pCi/am Resolution Licensee /NRC Compa ri son Pu-239 <3520* 7.3 1 51 14 NA No Compa rison Am-241 6.6 4.7 i .33 14 1.41 Ag reement Nb-94 97.8 71 1 5.0 14 1.37 Ag reement
  • Licensee used indirect methods to account for plutonium during decontamination surveys.

Split sampling between licensee and NRC showed thei r indi rect methodology to be adequate.

TABLE 5 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS This table provides criteria for comparing results of capability tests and verification measurements. The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this program.

In these criteria, the judgement limits are variable in relation to the comparison of the NRC's value to its associated uncertainty. As that ration, referred to in this program as_ " Resolution," increases, the acceptability of a licensee's measurement should be more selective. Conversely, poorer agreement must be considered acceptable as the resolution decreases.

RATIO = -LICENSEE VALUE NRC REFERENCE VALUE Resolution Agreement ,,

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