Text

Requests Release of Former Sites of Four Previously Removed Underground Radioactive Liquid Waste Tanks to Unrestricted Use & Deletion of Subject Sites from License SNM-696
	ML20206T414
Person / Time
Site:	07000734
Issue date:	05/17/1999
From:	Asmussen K; GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER
To:	Gaskin C, Wesley D; CALIFORNIA, STATE OF, NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
	696-CAL-3081, NUDOCS 9905240149
	Download: ML20206T414 (4)
	v • d • e

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CENERA ATORNCS l

May 17,1999 696/CAle3081 VIA EXPRESS MAIL SERVICE Mr. Charles E. Gaskin Licensing Section 1/ Licensing Branch i

Division of Fuel Cycle Safety and Safeguards, NMSS l

U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Docket No.70-734; SNM-696: Request to Release the Former Sites of Four Previously Removed Underground Radioactive Liquid Waste Tanks to Unrestricted Use and Delete them from License j

and ATTN: Mr. David Wesley (in Duplicate)

State of California Department ofliealth Services Radiologic Health Branch Mail Stop 178 601 North 7th Street Sacramento, CA 95814-0208

Subject:

Radioactive Materiale License No. 0I45-37: Request to Release the Former Sites of Four Previously Removed Underground Radioactive Liquid Waste Tanks to Unrestricted Use and Delete them from License

References:

Please see attached

Dear Messrs. Gaskin and Wesley:

In a July 1984 letter to the NRC, General Atomics (GA) documented information and plans regarding the removal of several underground radioactive material storage tanks and the decontamination of the sites of those tanks to criteria suitable for release to unrestricted use (Ref.1). In August 1984, GA split soil samples collected from pits excavated during removal of certain of those tanks with the NRC (e.g., Ref. 2). In November 1984, GA reported on the status of the removal of those tanks and submitted its plan for characterizing the residual soil associated with each of the discrete locations of the tanks to I

assure meeting acceptable release criteria (Ref. 3).

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The scope of GA's plans for decontaminating portions ofits site was subsequently expanded to l

include GA's old radioactive waste processing area and surrounding raw undeveloped land areas. Accord-ingly, GA's letter of November 1984 was supplemented by letters dated December 6,1984, December 21, 1984 and October 1,1985. The NRC approved this decontamination plan by a letter to GA (with a copy to the State of California) dated November 26,1985 (Ref. 4). Please note that the approved release criteria are the same as those in GA's more recent NRC-and State of California-approved Site Decommissioning Plan (Refs. 5 and 6).

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9905240149 990517 PDR ADOCK 07000734 C

PDRj 3550 GENERAL ATOMICS CoVRT, SAN DIEGo. CA 92121-1194 PO BOX 85608. SAN DIEGO. CA 92186-5608 (6191 455-3000

b Mr. C. Gaskin, US NRC / Mr. D. Wesley, State of Calif.

May 17,1999 696/ CAL-3081 Page 2 Following its plan, GA removed underground tanks from six locations in 1984 and January 1985.

This letter addresses four of those locations. As discussed below, one of the other two locations (i.e., the one near Bldg 37) was addressed previously. And the second of the two other locations (i.e., the one near lab 307 of Bldg 2) will be addressed in a separate future submittal.

At the time of the tank removals in 1984 and January 1995, GA decontaminated each of the

' discrete excavated areas associated with the tank removals. At the same time, GA performed final radiological surveys and collected and analyzed soil samples to demonstrate that each of those areas meet the approved criteria for release to unrestricted use, in 1984, GA performed final radiological surveys and measurements and shared results and split soil samples with the NRC.

In February 1985, GA documented the results ofits final radiological surveys and mea;urements in a report. However, at that time, GA did not submit its final report and request release of the correspond-ing discrete locations on its site. That is the purpose of this letter.

. GA hereby requests that the four discrete locations on its site that are associated with the following.

former underground tanks be released to unrestricted use and deleted from its NRC SNM and State of California Radioactive Material Licenses SNM-696 and 0145-37, respectively:

Site of former tank near Building 9 (See enclosed Fig.1)

Site of former tank near Laboratory 540 of Building 2 (See enclosed Fig.1)

Site of former tank near Building 21 (See enclosed Fig. 2) e Site of former tank near Building 31 (See enclosed Fig. 3) e The results of GA's radiological surveys and measurements demonstrating that these locations meet the approved criteria for release to unrestricted use are documented in the enclosed report titled

" FINAL REPORT / REMOVAL OF UNDERGROUND LIQUID RADIOACTIVE WASTE STORAGE TANKS," dated i1 February 1985. The enclosed Figures 1-3 supplement the information given in the report with additional detail regarding the locations of the former underground tanks.

Subsequent to issuing the above mentioned final report, the NRC requested additional soil sampling and analyses to confirm that residual soil in the location near Building 31 where the tank had been excavated did indeed meet the criteria for release. On March 7 and 8,1985, Mr. Paul Zurakowski (NRC Region V) observed the collection of core soil samples and their processing; the samples were shared with Mr. Zurakowski. The results of these analyses showed nothing above natural background levels. These results were documented in GA memorandum LRG:85:56 written by Ms. Laura R. Quintana

'(Gonzales), dated March 14,1985. A copy of Ms. Gonzales' memorandum.is also enclosed.

You will note that the final report addresses a location where two tanks were removed from GA's Building 37 (a.k.a. SVA-North). The locations of those two tanks and associated piping have already been released. They were included within the " extended footprint" of GA's SVA North building that was previously released by the NRC and State of California (Refs. 7 and 8).

It should also be noted that the piping associated with each of the four tanks which are the subject of this request has also been previously released or will be addressed in separate future requests. Specifi-cally, the drain lines associated with the Building 9 tank was addressed when Building 9 was released (Refs 9 and 10), and the drain lines associated with the Building 2 Lab 540 tank was addressed when the

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~ Mr. C. Gaskin, US NRC / Mr. D. Wesley, State of Calif.

May 17,1999 696/ CAL-3081 Page 3

' " Group 5" laboratories of Building 2 were released (Refs 11 and 12). The drain lines associated with the Building 31 and Building 21 tanks will be addressed in future release requests associated with those two buildings.

Ifyou should have any questions regarding this request or the enclosed report, please contact Ms.

Laura Gonzales (619) 455-2758, or me at (619) 455-2823. Once again, as in the past, your attention to our

- request is very much appreciated.

Very truly yours, x, c l

Keith E. Asmussen, Ph. D., Director Licensing, Safety and Nuclear Compliance i

Enclosures:

1) GA report titled " FINAL REPORT / REMOVAL OF UNDERGROUND LIQUID RADIOACTIVE WASTE STORAGE TANKS," dated 11 February 1985 j

2) Figures Numbered 1-3 showing former locations of underground tanks

3) GA Memorandum No. LRQ:85:56 dated March 14,1985 cc: Mr. Wayne L. Britz, Fuel Cycle inspector, NRC Region IV Ms. Kathleen Henner, State of California, Department of Health Services, Los Angeles Dr. Ronald Rogus, State of California, Dept. of Health Services, Sacramento Dr. D. Blair Spitzberg, Chief, Nuclear Materials Safety Branch 3, NRC Region IV (letter only) i j

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I Attachment to GA Letter No. 696/ CAL-3081 Dated May 17,1999

REFERENCES:

1)

Mowry, William R., Letter No. 696-6038 to Mr. Ross Scarano,"Information & Plans for Releasing Certain Facility Areas and Equipment to Unrestricted Use," dated July 26,1984

- 2) -

Quintana, Laura R., Letter to Mr. Gerald Hamata, dated August 1,1984.

3)

Mowry, William R., Letter No. 696-6077 to William T. Crow," Release of Certain Activity Sites for Unrestricted Use," dated November 16,1984'

4).. Crow, W.T. letter to Dr. Keith E. Asmussen dated November 26,1985 with copy to Mr. Don Honey (State of California) 5)

Amendment No. 45 to General Atomics' Special Nuclear Material License No. SNM-696, Issued by the NRC on April 29,1998

6). Amendment No.127 to General Atomics' Radioactive Material License No. 0145-37, Issued by the State of California on August 26,1997 7)

Amendment No. 32 to General Atomics' Special Nuclear Material License No. SNM-696, Issued by the NRC on August 1,1995 8)

Amendment No. I 19 to General Atomics' Radioactive Material License No. 0145-37, Issued by the State of California on September 5,1995 9)

Amendment No. 87 to General Atomics' Radioactive Material License No. 0145-37, Issued by the State of California on September 3,1987

10) Montgomery, James L., Letter Ref. 70-734/87-11 to R.N. Rademacher, dated October 1,1987

11) Amendment No. 22 to General Atomics' Special Nuclear Material License No. SNM-696, Issued by the NRC on August 18,1992 1

12) - Amendment No.106 to General Atomics' Radioactive Material License No. 0145-37, Issued l

by the State of California on September August 24,1992 L -

SPECIAL HANDLING CIRCLE WHICHEVER IS (ARE) APPROPRIATE FOR:

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GA TECHNOLOGIES INC.

1 FINAL REPORT REMOVAL 0F UNDERGROUND LIQUID RADIOACTIVE WASTE STORAGE T 11 February 1985 l

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n Table of Contents Summary.

iii 1.

Introduction 1

2.

Description of Tanks and Their Locations Prior to Removai 2

3 Radioactivity Measurement Techniques 4

A

' Decontamination Methodology 6

5.

Data Analysis.

7 6.

Compliance with Option I Criteria 21 References.

23 Tables Table 1 - Soil Sample Results - Building 9 Tank Removal 9

Table 2 - Building 2/540 Soil Sample Results 11 Table 3 - Building 31 Soil Samples 13 Table 4 - Building 21 Soil and Gravel Sample Results 15 Table 5 - Building 37 Soil Sample Results 17 Table 6 - Composite Sample Results - Building 37 18 Table 7 - Building 37 Core Sample Results and Other Samples 19 Figure Figure 1 - Location of Underground Tanks Prior to Removal, i

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SUMMARY

This report provides radiological survey information regarding the removal of six underground radioactive waste storage tanks at the GA Technologies Inc. site.

A description of the locations and the history of each tank is provided.

Radiological surveys were conducted using portable instruments during and after removal of the tanks.

In addition, representative soil samples were i

collected and analyzed to determine the relative extent of any radioactive soil contamination.

If contamination was present above background levels, an evaluation was done to determine compliance with previously established target criteria.

The Buildings 9, 2/540 and 31 tank areas.had no soil contamination above natural background levels. The Building 21 and Building 37 (two tanks at this location) areas showed levels above background, but within the Option 1 target i

criteria.

It should be noted that final data and information on Building 2/307 tank pit was presented separately (Reference 2).

The Building 2-307 tank location is mentioned in this report for completeness and for conformity to our plan-ning document (Reference 1).

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1.0 INTRODUCTION

In accordance with the planning document (Reference 1) submitted to NRC, i

Region V, GA Technologies (GA) has deactivated and removed underground tanks from six locations at GA's site in San Diego, California.

These tanks pre-

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viously served as holdup tanks for radioactive liquid waste effluent from licensed fuel facilities and associated research and development laboratories.

In accordance with the plan (Reference 1), the excavated areas resulting from tank removal have been decontaminated and cleaned, if required, to meet Option I criteria for release of land to unrestricted use.

In establishing the decontamination criteria, GA has applied the ratio-nale that the radiation exposure to individuals using the land must be within the NRC and EPA radiation exposure guidelines for Option I land release, in-cluding the requirements that the. associated exposures be.ALARA.

A descrip-tion of radiation measurement techniques used, ' decontamination methodology, estimates of residual contamination, calculated radiation doses, and their comparison with Option I allowable limits for all applicable locations are presented in this report.

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2.0 DESCRIPTION

OF TANKS AND LOCATIONS PRIOR TO REMOVAL q

l Figure 1 shows the location of the tanks prior to removal.

The following provides a general description of each tank.

I 2.1.

Building 9 Tank The Building 9 Tank was a 750 gallon poured-in-place reinforced concrete tank. The tank was placed underground 28 years ago and was part of the Building 9 loading dock. The tank was originally used to dilute non-radioactive acid wastes from a metal plating operation and was later converted to a radioactive liquid waste holding tank. The liquid col-lected in the tank was contaminated with low levels of thorium and de-pleted uranium. At a later time It was used to holdup liquid contami-nated with mixed fission and activanion products. The tank had no history of leakage.

s 2.2 Building 2/540 Tank The Building 2/540 Tank was a 1,000 gallon poured-in-place reinforced concrete tank. The tank was placed underground 28 years ago. The tank was used to hold-up liquid waste contaminated with natural uranium and thorium from metallurgical labs.

Small amounts of fission or activation products were used in these laboratories. The tank had no history of leakage.

23 Building 2/307 Tank The Building 2/307 tank was a 1,000-gallon poured in-place reinforced concrete tank placed underground 28 years ago. The tank was used to hold liquid from a shielded research laboratory using primarily Cs-137.

Co-60, and Sr-90.

The tank has a history of leakage.

The information on this tank was provided separately to NRC Reference 2.

1 2.4 Building 31 Tank The Building 31 Tank was a 1,000 gallon steel tank.

The tank was used to hold-up hand wash water contaminated with very small amounts of en-i riched uranium, thorium, and activation products from the HTGR Critical Facility.

The tank had no history of leakage.

2.5 Building 21 Tank The Building 21 Tank was a 1000 gallon steel tank housed in a concrete cradle and surrounded by gravel.

The tank was placed underground 28 years ago and originally served the TRIGA Reactor Facility. Until establishment of the Fuel Development and Research Laboratory (FDRL),

the tank saw little use. After establishment of the FDRL the tank was used to hold-up liquid contaminated with mixed fission and activation products.

The tank had no history of leakage.

2.6 Building 37 Tank The Building 37 Tanks were two one-thousand gallon steel tanks. The tanks were placed underground 20 years ago and serve the Building 37 Change Rooms. Only hand wash water contaminated with very low levels of enriched uranium and thorium drains tc the tanks.

The tanks had no known history of leakage.

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30 RADIOACTIVITY MEASUREMENT TECHNIQUES Soil surface beta / gamma radiation surveys (at contact) were done to determine the relative extent of any radioactive soil contamination. Two calibrated, thin window, pancake probe GM counters were used for the radiation survey. The Ludlum Model 3, with model 44-9 pancake probe (GA Tag #15055 2

2 calibrated in September 1984), having a 15.2 cm area and 1.2 mg/cm thin window had a natural background count rate of 150 cpm (counts per minute).

The second, Ludlum Model 14A (GA Tag #84402, calibrated in August 1984) also j

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has-a pancake probe with a 15 2 cm area and 1.2 mg/cm thick window had a natural background count rate of-100 cpm. An alpha counter (Eberline PAC-15A, GA #30356, calibrated 11/84) was also used during removal of the Building 37 tanks.

s Qualitative and quantitative determination of the radioisotopic content of soil was made by laboratory analysis of representative samples obtained from excavated areas. *dhen required, core soil samples were taken to deter-mine the possibility and. the extent of any radioactive liquid waste seepage into the ground. The core samples were generally 4 inches in diameter and were taken at various depths as described in this report.

Representative soil samples from five known clean locations (R -R

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4 8 grounds) were obtained to determine natural radioisotopic content or soil

' background.

Each time approximately 1 kg of soil sample was collected from a given location. The samples were given an identification number. The amount of soil collected in the sample was used for the following:

a.

Analysis by GA b.

Analysis by an independent lab (if needed), and, c.

Historical sample A grinder / crusher was used to grind the soil to a fine powder consistency for quantitative sample analysis.

s Gamma spectroscopy using a Ge(Li) detector and a multi channel analyzer system was utilized to determine the nature and concentration of radioisotopes in the soil.

Calibration standards were prepared by doping clean soil with known amounts of suspected contaminants. As noted in this report (Section 5) and in a previous report (Reference 2), many of the background soil samples were ob-tained and split in the presence of NRC Region V inspectors for their indepen-dent evaluation.

A comparison 'of the soil samples analyzed at GA using the above methods, and split samples analyzed independently by NRC Region V have shown good agreement.

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DECONTAMINATION HETHODOLOGY Each liquid radwaste holdup tank was first emptied of its contents and then removed from its underground location.

The tank contents and the tank material were handled as radioactive waste and disposed of separately in ac-cordance with the licensing requirements.

Subsequent to tank removal, all surfaces of the excavated pit and the land up to five feet beyond the pit, was surveyed for possible contamination, using a pancake probe GM meter.

The radiation survey data for all excavated pit locations discussed in this report (excluding the Building 2/307 tank area) showed presence of only natural back-ground activity. Therefore soil decontamination was not required, nor was any soil removed from any location for separate disposal.

During excavation /, decontamination, and transport activities, all normal health physics precautions were taken to keep radiation exposure to workers as

" Low As Reasonably Achievable."

All activities were performed in the presence of a health physics technician.

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5.0 DATA ANALYSIS This section describes for each excavated location (1) the rem the tank (2) results of the radiation surveys, and (3) soil sample analyse conducted by Health Physics.

s Where available, the results of independent analysis of samples split with NRC Region V are also provided.

Quantitative measurements of residual radioactivity in wall surfaces of each excavated area were made to demonstrate compliance with Option I criteria for the release of land to unrestricted use.

Representative soil samples were collected and analyzed for their radioactive content.

To ensure that the soil samples were representative, radiation surveys of each excavated site were conducted and relative distribution of radinactivity established.

Radiation surveys were done using a GM counter with a pancake probe.

For the Building 2/540 pit areas to be monitored were divided into 3' x 3' grids and highest surface count rate (cpm) noted for each grid.

Other pits were not as defined and were unsafe to enter since removal of the tank caused a collapse of sur-rounding soil or gravel.

Composite soil samples were collected during removal of the tank.

Individual soil sampling locations were selected to ensure sep-arate sampling for any areas with hot spots.

5.1 Building 9 Tank The Building 9 Tank was removed from its location on October 8,1984 for separate disposal consideration as radioactive waste.

Since removal of the tank the inlet drain lines to the tank have been capped and marked.

The locations of these lines have been highlighted on Engineering Facilities' Map Z-22-4.

The removal of the Building 9 Tank resulted in a pit 8 feet square.

A beta / gamma radiation survey with Ludlum Model 3 GM counter and Model 44-9 pancake probe showed no measurable radioactivity above background level for all four walls and the bottom floor surfaces of the excavated pit.

The background count rate with this instrument was 100 cpm.

Land area surrounding the excavated site also showed no measurable contami-nation.

The radiation survey data showed that the excavated site had even dis-tribution of radioactivity from natural background radiation.

For quantitative analysis, three composite soil samples (DS-70, DS-73 and DS-74) were obtained.

Sample DS-70 was taken from the top 18 inches of all four sides of the pit. Sample DS-73 was taken from all accessible areas of the base of the tank pit. And sample DS-74 was collected from various locations along the bottom of the pit.

The samples were ana-lyzed on a calibrated Ge(Li) detector system in the Health Physics Lab-oratory.

Results for these soil samples and background soil samples are provided in Table 1.

The Table 1 data for samples DS-70. 73 and 74 include contribution from natural background. A comparison with background sample data shows that the residual activity in the excavated Building 9 tank pit walls and floor is that from natural background only.

Concentrations of all iso-topes are within two standard deviation (955 confidence limits) values of the natural background activity.

The site is shown to be free of any radioactive contamination.

No soil decontamination was required.

The open tank pit was in the loading dock area. Therefore health and safety considerations necessitated immediate backfilling of the clean pit. The Building 9 tank pit was backfilled with clean soil on October 12, 1984. '

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5.2 Building 2/540 Tank The Building 2/540 Tank (also called L-540 Tank) was removed from its location on July 26, 1984 for separate disposal consideration.

The inlet drains to the tank were capped on July 6,1984, prior to tank removal', and marked. The locations of the lines have been highlighted on the Engineering Facility Map Z-22-3 The excavation of Building 2/540 tank resulted-in a pit 15'x15'x15' deep. A beta / gamma radiation survey with Ludlum Model 3 ratemeter with a pancake GM probe showed no measurable radioactivity above background' level for all four walls and the bottom floor surfaces of the excavated pit. The background count rate with this instrument was 150 cpm. Land area surrounding the excavated site also showed no measurable contamina-tion.

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The results of GA and NRC Region V analysis, along with a description of the sampling location, are pre-sented in Table 2.

The average of the R -R background soil samples is 4 g given in the Table. Any sample result less than this average background plus two standard deviations is considered natural radioactivity.

A background _ soil sample was also taken by the NRC Region V inspector.

The result of for this background sample is also shown in Table 2.

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e The results of GA analysis and the NRC Region V independent analysis (Reference 3) confirmed presence of radioactivity at or near background levels. There was small amounts of Cs-137 seen in the soil samples, primarily Ds-30, a composite collected from the north and east side of the tank during removal. Since they were composites some top soil con-taining fallout Cs-137 could have been the cause. Therefore Building 2/540 tank pit did not require soil decontamination.

With the concurrence of NRC Region V, the pit was backfilled on 9/5/84.

53 Building 2/307 Tank Data and information for this excavated location is reported separately in Reference (2).

5.4 Building 31 Tank The Building 31 tank was removed from its location on 8/13/84 for separate disposal consideration.

The inlet drains to the tank were removed and capped on 7/31/84, prior to tank removal, and marked. The locations of the lines have been highlighted on the Engineering Facility Map Z-22-1.

A beta / gamma radiation survey of the soil surface, (contact readings) soil samples collected during removal of the tank, and the tank surface itself showed no evidence of radioactive contamination.

Three composite soil samples were collected during removal of the tank for quantitative and qualitative radioisotope analysis.

Sample DS-38 (top soil) DS-39 (sides of tank) and DS-40 (bottom). Results are reported in Table 3 All results were less than the average background plus two standard deviations of the average. Therefore, the Building 9 tank pit did not require decontamination.

The pit was backfilled a few days after removal of the tank.

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5.5 Building 21 Tank The Building 21 (also called TRIGA Building) tank was removed from its location beginning November 10, 1984. The tank was removed on November 14, 1984.

The inlet lines to the tank were removed, capped and marked.

The location of the lines have been highlighted on Engineering Facil-ity's map Z-22-5.

Gravel was checked during removal of the tank using a GM counter with a pancake detector (GA #30309, calibrated 12/84).

When the drain lines were cut, low level contamination (up to 1000 counts per minute) resulted in soll surrounding the pipe.

The pipe and surrounding contaminated soil was collected, and transferred to the Waste Processing Facility for disposal as radioactive waste.

Levels were cleaned to background GM counter levels.

Soil and gravel samples were collected from the site when the tank was first exposed and after the tank was removed.

The tank was in a bed of gravel, therefore when the tank was removed, no defined pit remained.

The Ge(Li) scans of these samples showed several short-lived radio-isotopes in concentrations less than 1.5 pCi/ gram.

These were Sb-124 which has a 60.2 day half-life, Xe-133 which has a 5.2 day half-life and Np-239 which has a 56.3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months half-life.

The concentration of these isotopes will be insignificant after a short period of time.

The re-sults of the other radioisotopes are shown in Table 4.

To ensure the tank did not leak, several large area wipes using Masslins were taken from the bottom surface of the tank and all four sides. These were counted with a GM counter and/or a Ge(Li) detector fo radioactivity. No levels above background were detected.

A chip sample was removed from the side of the tank under the hold down strap.

A one-hour Ge(Li) scan showed no contamination.

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i The pit was backfilled on November 15, 1984.

5.6 Building 37 Tank The removal of building 37 tanks was initiated on January 4,1985. The tanks were removed on January 8,1985, for disposal as radioactive waste.

The inlet drain lines to the tanks were removed, capped and marked.

The locations of the lines have been highlighted on the engineering Facility Map Z-22-6.

A beta / gamma and alpha radiation survey of the surrounding area showed only background levels of radioactivity.

Representative soil samples were collected from top of the tank and the pit for quantitative analy-sis for possible contaminants. The results of the analysis of samples DSV-1 through DSV-12 (Table 5) confirmed levels well within Option 1 i

levels.

After counting each sample separately for 15 minutes each, I

samples DSV-1 through DSV-5 which were taken around tank #1 were com-posited and samples DSV-6 through DSV-10 taken around tank #2 were com-posited.

These composites were split with NRC Region V for their in-dependent analysis. Thc composites were counted for twelve (12) hours each on a Ge(Li) detector system in the Health Physics Laboratory.

Results are presented in Table 6 which shows levels equivalent to background soil values.

During removal of the tanks, it was observed that the tanks had developed small corrosion holes. Wet soil directly under these holes (three 55 gallon drums full) was collected.

Representative samples were analyzed (Table 7) and results were well within Option 1 levels.

l TABLE 5 BUILDING 37 SOIL SAMPLE RESULTS These samples were collected during removal of the two underground tanks.

I.D.

Location Cs-137 Co-60 U-235 Th-228 1

DSV-1 Tank #1, North side M

M M

M DSV-2 Tank #1, South side M

M M

M DSV-3 Tank #1, West side M

M 0.2 M

DSV-4 Tank #1, East side M

M M

M DSV-5 Tank #1, Bottom M

M M

M DSV-6 Tank #2, North side M

M M

M DSV-7 Tank #2, South side M

M M

M DSV-8 Tank #2, East side M

M M

M DSV-9 Tank #2, East side M

M M

M DSV-10 Tank #2, Bottom M

M M

M DSV-11 Tank #1, Top M

M M

M DSV-12 Tank #2, Top M

M M

M (1) M Minimal means:

<0.1 pCi/g Cs-137

<0.1 pCi/g Co-60

<0.4 pCi/g U-235

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Even though the radiation survey of the pit floor and soil sample re-suits (DSV-1 through 12, DS-12 and wet soil sample) showed no evidence of radioactive contamination, five core samples were taken to determine if there was any migration of radioactivity.

The core samples were collected starting at about three to four feet below the location of the tanks and identified as DS-250, 251, 252, 253 and 254.

Several of the core samples (i.e. DS-251, 5.5'-6.5') were recounted for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months on the Ge(Li) detector.

Levels were at background after this long count.

Results (Table 7) were less than the value given for a 15 minute count The results are all less than four times background and well within Option 1 levels.

No decontamination was required.

The tanks had been used only for hold up of very low level 11guld waste originating only from hand wash water from the men's and women's change rooms.

This was the reason soil contamination was at a minimum.

1 6.0 COMPLIANCE WITH OPTION I CRITERIA

)

In evaluating the soil sample results to ensure compliance with Option 1 levels, the following was considered.

1.

Target Criteria (Option 1) for Soil Decontamination i

Option levels for soil contamination are specified in Reference 1 and are summarized below.

Radionuclide Concentration (pCi/ gram U-238 35 U-235 and U-234 30 1h-232 10 Co-60 8

Cs-137 15 or combinations thereof where the sum of the fractions do not exceed one.

2.

Natural background level in soil was determined by analyzing the soil samples collected around GA.

These were identified as R -

4 through Rg soil samples.

The average and standard deviation (two) for these results is given in Tables 1 through 6.

A sample result I

greater than the average background plus two standard deviations was considered positive.

The results given to us by the NRC on the analysis of these samples by Oak Ridge Associated Universities were in good agreement but generally were somewhat higher than our results.

3 soil samples collected at the building 9, Building 2/540 and Build-ing 31 tank locations during and after removal of the tanks were analyzed.

Results were not distinguishable from natural background i

levels.

These areas have no soil contamination and are therefore within Option 1 levels.

4 i

4.

Soil samples collected at the Building 21 and Building 37 locations (Tables 4-7) showed some contamination above background levelsThe Building 21 soil levels were just slightly above background due to some contamination released from the drain pipe after cutting.

The Building 37 soil concentrations were above background levels but well within the Option 1 criteria.

This small amount of contamina-tion is reasonable because the tanks were used only for holdup of wash water from the men's and women's change room.

i I

)

.i' REFERENCES

1. " Release of Certain Activity Sites for Unrestricted Use,"

GA letter 696-6077 dated 16 November 1984.

' 2.

" Request for Approval ~ to Backfill L-307 Pit." GA letter 696-6083 dated 30 November 1984.

l 3

NRC letter' Docket No.70-734 dated 5 October 1984 signed by F. A.

Wenslawski.

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o INTERNAL CORRESPONDENCE B-IN REPLY FROM:

L. R. Quintan REFER TO: LRQ:85:56 TO:

F. O. Boid/W. R. Mowry DATE: March 14, 1985

SUBJECT:

Results of Core Samples Collected March 7, 1985 Near Bullding 31 On March 7, 1985, core samples were collected near Building 31 from the same location where the underground tank had been removed in August,1984.

These samples were collected as a result of a request made by Region V NRC inspectors after they analyzed a soll sample (composite) they received from GA in October,1984.

Their results showed the presence of Cs-137, Co-60 and U-235, at levels exceeding Option 1 limits.

Our results had shown only natural background radioactivity levels.

The results reported to me by Paul Zurakowski and Buddy Brock, from the NRC Region V Office, were similar to the results we had obtained of the analysis of the sludge collected from Innfde the tank.

Buddy Brock was the first to see the correlation. There is a strong possibility that the sample sent to them was a sludge sample and not the soll samples.

The NRC requested that core samples be collected to assure and confirm that the soll remaining af ter removal of the tank was i

indeed " clean". Paul Zurakowski' observed the core sampiing and processing. and Table 1 provide data on th,e collection, analysis and results of the core sampiing.

LRQ:ms Table 1.

i 1

]

7 e

,. 6 ATTA0iMENT 1 Building 31, Qm Samole Results Core. samples were collected near Building 31 on 3-7-85 from the same location where the underground tank was removed.

The core samples were collected by Southern California Soll and Testing Company.

Three core samples were collected at depths from 15' to 23', for Core No.1,13.5' to 23' for Core No. 2, and 13.5 to 18.5' for Core No. 3.

AlI three samples were collected as to ensure the sampling of both fill soll and natural undisturbed soll.

Paul Zurakowski, a Region Y NRC Inspector, observed the collection and preparation of the samples.

Beta / gamma radiation measurements were conducted on the core samples af ter collection, using a GM (Model 14A) counter, serial number 85587 calibrated 11/28/84. No radiation above natural background levels was detected.

The samples were given an identification number and processed on 3-7-85 and 3-8-85.

The samples were dried and ground to a fine powder consistency for quantitative sample analysis.

The samples were shared with Paul Zurakowski.

The idontifIcation number and Iocation colIacted are provided beIow:

)

lo.LJ..TEDa JD LOCATION

}

Fill Soll 05-268 Composite from Core #1 15-18 feet depth Natural Formation 05-269

" 18-21 feet depth Natural Formation DS-270

" 21-23 feet depth j

Fili Soit DS-271

" Core #2 13.5-17.5 feet depth Natural Formation DS-272

" 17.5-20.5 feet depth Natural Formation D5-273

" 20.5-23 feet depth Fill Soll DS-274 Core #3 13.5-15.5 feet depth Natural Formation 05-275

" 15.5-18.5 feet depth j

r-Table 1 Catt Samnie Results - Building il Concentration (pCI/ gram) 1.D.

Os-137 Co-60 U-235 0S-268 0.08 0.02 ND*

0.08 ! 0.04 DS-269 0.07 t 0.02 ND 0.14 0.06 i

DS-270 0.06 0.03 ND 0.12 I 0.06 05-271 0.05 ! 0.02 0.02 ! 0.02 0.04 ! 0.03 05-272 0.07 0.03 ND 0.13 I 0.06 05-273 0.05 0.03 0.01 1 0.01 0.13 0.06 DS-274 0.06 t 0.02 ND 0.06 0.04 05-275 0.07 0.03 ND 0.11 0.06 Average of DS-268 through DS-275 0.06 0.03 0.04 0.02 0.10 0.06 R -R8 4

backgrounds (average) 0.09 t 0.18 0.03 ! 0.02 0.09 ! 0.05 Average of backgrounds plus two standard deviations 0.27 0.023 0.14 i

Net result -

I average of DS-268 through 05-275 minus average of backgrounds plus two t

standard i

deviations 5

9

ND - Not detectable

.

ML20206T414

Text

Subject:

Subject:

References:

Dear Messrs. Gaskin and Wesley:

Enclosures:

REFERENCES:

SUMMARY

1.0 INTRODUCTION

2.0 DESCRIPTION

SUBJECT:

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