ML20212L527

Cimarron Corporation 1999 Final Status Survey Report for Sub-Area I, Part 1 of 7

ML20212L527
Person / Time
Site:	07000925
Issue date:	06/29/1999
From:	Jim Larsen Cimarron Corp
To:	Kenneth Kalman Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML20212L572	List: ML20212L527 ML20212L541 ML20212L543 ML20212L552 ML20212L556 ML20212L561 ML20212L571
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Download: ML20212L527 (63)

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{{#Wiki_filter:CIMARRON CORPORATION P.O . BOX 25861

• OKLAHOMA CITY, OKLAHOMA 73125 June 29, 1999 Mr. Ken Kalman, Project Manager Facilities Decommissioning Section Low-Level Waste & Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Re: Docket No. 70-925; License No. SNM-928 Cimarron Corporation Final Status Sun*ey Report for Sub-Area "I"

Dear Mr. Kalman:

Cimarron Corporation has recently completed the Final Status Survey for Sub-Area "I" in accordance with the previously approved Phase II Final Status Survey Plan. This submittal letter transmits the Final Status Survey Report for Sub*Area "I". Please find enclosed two (2) copies of the report for your review and approval. One ( 1) copy of this report has been submitted to the NRC Docket and one (1) copy has been provided to Mr. Louis Carson with NRC Region IV. Cimarron Corporation requests that Sub-Area "I" be released from License No. SNM-928. Please feel free to contact me if there are any additional questions or concerns. Sincerely,

  ,/'1            i I; L~enJa:-4?/ L--"

Vice President Enclosure A SUBSIDIARY OF KERR-MCGEE CORPORAllDN

FINAL STATUS SURVEY REPORT SUBAREAI rJr Cimarron CorpQration's Former Nuclear Fuel Fabrication Facility Crescent, Oklahoma

• License Number: SNM-928 Prepared for:

Cimarron Corporation Oklahoma City, Oklahoma June 1999

TABLE OF CONTENTS 1.0 PURPOSE .............................................................................................. ....................... .......... . I

2.0 BACKGROUND

.... ........... .. ................................................ .................................................... 1 2.1 Phase I Area .................................... .. ........ f ............................. . ........................................... 2 2.2 Phase II Area ............................................. ;... .............. ........................................................ 2 2.3 Phase III Area ........................................... *;......................................................................... 3 3.0 DECOMMISSIONING ACTIVITIES .......... 1......................................................................... .4 3.1 Identification of Contaminants ................. ............. .... ...................... .................................. 4 1

3.2 Site Background Levels ................ ............ l......................................................................... 4 3.2.1 Soils ..... ........................... ................. .,.. ....................................................................... 4 3.2.2 Exposure Rate ........................................................................................ ..................... 5

3. 3 Characterization Data .......................................................................................................... 6 3.3.1 Affected Area Surrounding Warehouse (TiO 2) Building #4 ...................................... 7 3.3.2 Warehouse (TiO2) Building #4- Interior ................................................................... 8 3.3.3 Warehouse (Ti02) Building #4- Exterior .................................................................. 9 3.3.4 Pu-Plant Building Exterior ................... ......... .............................................................. 9 3.3.5 Affected Area Surrounding Pu-Plant Building ......................................................... 10 3.3.6 Unaffected Areas ...................................................................................................... 11 3.3.7 Emergency Building Interior .................................................................................... 11 3.3.8 Emergency Building Exterior ...... ............................................................................. 11 3.3.9 Affected Area South ofU-Plant Yard ....................................................................... 12 3.4 Environmental Monitoring Data ....................................................................................... 12 4.0 FINAL STATUS SURVEY PROCEDURE .......................................................................... 12 4.1 Survey Method .................................................................................................................. 12 4.1.l Grid Areas ............................................ ..................................................................... 13 4.1.2 Survey Procedure (Open Land Areas) ...................................................................... 13 4.1.3 Soil Sampling Procedure ........................................................................................... 15 4.1.4 Survey Buildings and Structures ............................................................................... 15 4.2 Radiological Guideline Values ......................................................................................... 15

• 4.2. l 4.2.2 Buildings and Equipment .......................................................................................... 15 Volumetric Activity of Soil ....................... .................. ............................................. 16 FSSR SUBAREA I

4.2.3 Gamma Surface Survey (Open Land Areas) ............................................................ 16 4.2.4 Exposure Rate Survey ............................................................................................... 17 4.3 Equipment Selection ............................... .......................................................................... 18 4.3 .1 Equipment and Instrumentation ................................................................................ 18 4.3.1.1 Unshielded 3" x 0.5 Nal Gamm8: Detector.. ........................ ................ ................ 19 4.3.1.2 Shielded 3" x 0.5 Nal Gamma D~tector. ............................................................. 19 4.3.1.3 Micro-R Meters ............................ j......................................................................... 19 4.3.1.4 Gross Alpha/Beta Detector .........:....................................................... ... ... ............ 20 4.3.1.5 Soil Counter (Gamma Spectroscopy) ................................................................... 20 4.4 Procedures/Plans ................................... ...:......................................................................... 21 4.4.1 Organization ....................... ....... ................................................................................ 21 4.4.2 Training .................................... .... .............................................. ............................... 21 4.4.3 Radiation Protection Program ... ....... ......................................................................... 22 4.4.4 Cimarron Quality Assurance Program (QAP) .................................................... ...... 22 5.0 SURVEY FINDINGS ......... ........... ........................................................................................ 23 5.1 Data Evaluation ........ .......................................................................................................... 23 5.2 Comparison with Guideline Values .................................................................................. 24

• 5.2.1 Data Evaluation - Area Surrounding Warehouse (TiO 2) Building #4 ..................... 24 5.2.1.1 Warehouse Building Open Land Area .................................................................. 24 5.2.1.2 Warehouse Building Yard Concrete Pads ............................................................. 25 5.2.1.3 Warehouse Building Yard Drain Lines ................................................................. 25 5.2.1.4 Warehouse Building Yard Fencing ................................. .... ....................... ....... .... 26 5.2.2 Data Evaluation - Warehouse (TiO 2) Building #4 - Interior .................................... 26 5.2.3 Data Evaluation - Warehouse (TiO 2) Building #4 - Exterior.. ................................. 27 5.2.4 Data Evaluation - Pu-Plant Building Yard ............................................................... 28 5.2.4.1 Pu-Plant Open Land Area ................................................................ ... .................. 28 5.2.4.2 Pu-Plant Fencing ........................... ........................................................................ 30 5.2.4.3 Pu-Plant Light Poles ............................................................................................. 30 5.2.4.4 Affected Area Sidewalks ...................................................................................... 31 5 .2.5 Data Evaluation - Unaffected Areas ................................................... ...................... 31 5.2.5.1 "Open Land" Areas ............................... ................................................................ 31 5.2.5.2 Unaffected Area Fencing ...................................................................... ... ............. 33 5.2.5.3 Unaffected Area Light Poles ................................................................................. 33 5.2.5.4 Unaffected Area Paved Parking Lot ..................................................................... 34 5.2.5.5 Unaffected Area Concrete Walkways ................................................................... 34 5.2.6 Data Evaluation - Emergency Building Interior ...................................................... 34
• 5.2.7 Data Evaluation- Emergency Building Exterior ............................ ............. ............ 36 FSSR SUBAREA I ii

5.2.8 Data Evaluation - Affected Drainage Area .............................................................. 37

• 5.3 QA/QC Procedures .. ......................................................................................................... 38 6.0

SUMMARY

........................................................................................................................... 39 7.0 APPENDICES ....................................................................................................................... 40

• FSSR SUBAREA I Ill

APPENDICES

• Appendix 1 Drawings 95MOST-RF3 and 99MOST-RF4
• Appendix 2 Data Tabulation $beets, Statistical Analyses and Drawings for Open Land Area Sµrrounding Warehouse (Ti0 2 ) Building #4
• Appendix 3 Data Tabulation $beets, Statistical Analyses and Drawings for Warehouse (Ti0 2) !Building #4 Area Concrete Pads and Fencing
• Appendix 4 Data Tabulation Sheets, Statistical Analyses and Drawings for Warehouse (Ti0 2) Building #4 Interior
• Appendix 5 Data Tabulation Sheets, Statistical Analyses and Drawings for Warehouse (Ti02)Building #4 Exterior
• Appendix 6 Data Tabulation Sheets, Statistical Analyses and Drawings for Open Land Area Surrounding Pu-Plant Building
• Appendix 7 Data Tabulation Sheets, Statistical Analyses and Drawings for Pu-Plant Area Fencing, Light Poles, and Sidewalks Appendix 8 Appendix 9 Data Tabulation Sheets, Statistical Analyses and Drawings for Unaffected Open Land Areas Data Tabulation Sheets, Statistical Analyses and Drawings for Unaffected Area Fencing, Light Poles, Paved Parking Lot, and Concrete Walkways
• Appendix 10 Data Tabulation Sheets, Statistical Analyses and Drawings for Emergency Building Interior
• Appendix 11 Data Tabulation Sheets, Statistical Analyses and Drawings for Emergency Building Exterior
• Appendix 12 Data Tabulation Sheets, Statistical Analyses and Drawings for Open Land Area South ofU-Plant Yard
• FSSR SUBAREA I iv

REFERENCES

1. Cimarron Corporation Nuclear Materials License, SNM-928 Docket No. 70-0925, issued for possession only March 31, 1983; Amendment No. 14, issued July 7, 1997.

2. Cimarron Corporation Nuclear Materials License, SNM-1174, Docket No. 070-1193, terminated February 5, 1993.

3. Cimarron Corporation letter to USNRC, Aug~st 20, 1990.

4. USNRC letter from Mr. Richard E. CWTI1ingham, Director, Division of Industrial and Medical Nuclear Safety to Dr. John Stauter,!Director of Environmental Services, Cimarron Corporation, dated February 5, 1993.

5. Chase Environmental Group, Inc. "Radiological Characterization Report for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, Oklahoma", October 1994.

6. Chase Environmental Group, Inc. "Decommissioning Plan for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, Oklahoma", April 1995.

7. Chase Environmental Group, Inc. '1Final Status Survey Plan for Unaffected Areas for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, Oklahoma'1, October 1994.

8. USNRC letter from Mr. Michael F. Weber, Chief Low-Level Waste and Decommissioning Project Branch, Division of Waste Management, to Mr. Jess Larsen, Vice President Kerr-McGee Corporation, dated May 1, 1995.

9. Cimarron Corporation Letter from Mr. Jess Larsen, Vice President, Cimarron Corporation to Mr. Michael F. Weber, Chief Low-Level Waste and Decommissioning Branch, Division of Waste Management, USNRC, dated November 13, 1995.

10. Cimarron Corporation, "Final Status Survey Report, Phase I Areas at the Cimarron Facility, License No. SNM-928rr, July 1995.

11. USNRC letter from Mr. R. A. Nelson Acting Chief Low-Level Waste and Decommissioning Project Branch, Division of Waste Management, to Mr. Jess Larsen, Vice President, Cimarron Corporation, dated April 23, 1996.

12. Chase Environmental Group, Inc., "Final Status Survey Plan for Phase II Areas for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility", Crescent, Oklahoma, July 1995.

13. USNRC letter from Mr. Kenneth L. Kalman, Project Manager, Low-Level Waste and Decommissioning Projects Branch, to Mr. Jess Larsen, Vice President, Cimarron Corporation, dated March 14, 1997 .

FSSR SUBAREA I V

14. USNRC letter from Mr. George M. Mccann, Chief, Materials Licensing Section to Dr. John

• Stauter, Vice President, Kerr*McGee Corporation, dated December 30, 1992.

15. Cimarron Corporation, "Final Status Survey Report, Phase II-S ubarea J for Cimarron Corporation's Former Nuclear Fuel Fabric31tion Facility, Crescent, Oklahoma", September 1997. i

16. USNRC letter from Mr. Kenneth L. Kalrhan, Project Manager, Low-Level Waste and Decommissioning Project Branch, to Mr. Jes~ Larsen, Vice President, Cimarron Corporation, dated July 31, 1998.

17. USNRC letter from Mr. Kenneth L. Kahpan, Project Manager, Low-Level Waste and Decommissioning Project Branch, to Mr. Jes~ Larsen, Vice President, Cimarron Corporation, dated December 4, 1998.

18. Cimarron Corporation, "Final Status Survey Report for Subarea H for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, Oklahoma", November 1998.

19. Cimarron Corporation, "Final Status Survey Report for Concrete Rubble in Subarea F, Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, Oklahoma",

March 1998 .

• 20. USNRC letter from Mr. Kenneth L. Kalman, Project Manager, Low-Level Waste and Decommissioning Project Branch, to Mr. Jess Larsen, Vice President, Cimarron Corporation, dated March 1, 1999.

21. Chase Environmental Group, Inc. "Final Status Survey Plan for Phase III Areas for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility", Crescent, Oklahoma, June 1997.

22. USNRC letter from Mr. Kenneth L. Kalman, Project Manager, Facilities Decommissioning Section to Mr. Jess Larsen, Vice President, Cimarron Corporation, dated September 11, 1998

23. Cimarron Corporation, "Final Status Survey Report, Phase III-Subarea L (Subsurface) for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, Oklahoma",

May 1996.

24. USNRC letter from Mr. Kenneth L. Kalman, Project Manager, Facilities Decommissioning Section, to Mr. Jess Larsen, Vice President, Cimarron Corporation, dated August 16, 1996.

25. Cimarron Corporation letter from Mr. Jess Larsen, Vice President Cimarron Corporation, to Mr. Kenneth L. Kalman, Project Manager, Facilities Decommissioning Section, USNRC, dated September 9, 1996 .

• FSSR SUBAREA I VI

26. Cimarron Corporation letter from Mr. Jess Larsen, Vice President, Cimarron Corporation, to Mr. Kenneth L. Kalman, Project Manager, Facilities Decommissioning Section, USNRC, dated October 17, 1996.

27. Cimarron Corporation letter from Mr. Jess L,arsen, Vice President Cimarron Corporation to Mr. Kenneth L. Kalman, Project Manager, .Facilities Decommissioning Section, USNRC, dated November 4, 1996. *

28. USNRC letter from Mr. Kenneth L. Kalma_ri, Project Manager, Facilities Decommissioning Section, to Mr. Jess Larsen Vice President, C1marron Corporation, dated November 8, 1996.

29. Cimarron Corporation letter from Mr. Jess Larsen, Vice President, Cimarron Corporation to Mr. Kenneth L. Kalman, Project Manager, :facilities Decommissioning Section, USNRC, dated July 27, 1998.

30. Cimarron Corporation, "Final Status Survey Report Phase III - Subarea "O" Subsurface for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, Oklahoma",

dated March 1998.

31. Cimarron Corporation, "Cimarron Final Status Survey Report for Phase III - Sub-Area 0 Surface for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, Oklahoma," dated February 1999 .

• 32. Cimarron Corporation, "Final Status Survey Report Phase III - Subarea "M" for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, Oklahoma", dated December 1998

33. Cimarron Corporation letter from Mr. Jess Larsen, Vice President, to Mr. Michael F. Weber, Chief Low-Level Waste and Decommission Projects Branch, Division of Waste Management, USNRC, dated June 21, 1995.

34. ORAU Final Report, "Confirmatory Survey of the Cimarron Corporation Mixed Oxide Fuel Fabrication Plant", January 1991.

35. Kerr-McGee Corporation letter from Dr. Edwin Still to Mr. Gary Comfort, Project Officer, Licensing Branch, Division of Fuel Safety and Safeguards, Officer of Nuclear Material Safety and Safeguards, USNRC, dated July 7, 1993.

36. Kerr-McGee Corporation letter from Dr. Edwin Still to Mr. Gary Comfort, Project Officer, Licensing Branch, Division of Fuel Safety and Safeguards, Office of Nuclear Material Safety and Safeguards, USNRC, dated September 2, 1993.

37. Kerr-McGee Corporation letter from Dr. Edwin Still to Mr. Dave Fauver, Project Officer, Decommissioning and Regulatory Issues Branch, Division of Low-Level Waste Management and Decommissioning, USNRC, dated November 15, 1993 .

FSSR SUBAREA I Vil

38. USNRC letter from W. T. Crew, Section Leader, Uranium Process Licensing Section, to Mr.

• William J. Shelley, Kerr-McGee Nuclear Corporation, December 28, 1979.

39. USNRC letter from William 0. Miller, Cp.ief License Fee Management Branch, to Mr.

William J. Shelley, Kerr-McGee Nuclear Cotporation, March 28, 1980.

40. S. A. Wical, "Interim Report on Confirmafory Survey of Portions of the Sequoyah Fuels Corporation Cimarron Plant, Crescent, Ollahoma', Oak Ridge Associated Universities, January 31, 1989.

41. D. Berger and L. F. Friedman, "Confirmat~ry Survey of the Cimarron Corporation Mixed Oxide Fuel Fabrication Plant, Crescent, dklahoma," Oak Ridge Associated Universities, January 1991.

42. USNRC, HEnvironmental Assessment for License Termination at the Cimarron Corporation's Mixed Oxide Fuel Fabrication Plant", February 1993.

43. USNRC, Federal Register, Volume 58, No. 28, pages 8432 through 8434, February 12, 1993.

44. Kerr-McGee Corporation, "Decommissioning Plan - Groundwater Evaluation Report for Cimarron Corporation's Former Nuclear Fuel Fabrication Facility, Crescent, Oklahoma,"

July 1998 .

• 45. USNRC letter from Mr. Kenneth L. Kalman, Project Manager, Low-Level Waste and Decommissioning Projects Branch, to Mr.

Corporation, dated January 19, 1999. Jess Larsen, Vice President, Cimarron

46. J. D. Berger, Manual for Conducting Radiological Surveys in Support of License Termination"; Draft Report for Comment, Oak Ridge Associated Universities, NUREG/CR-5849, June 1992.

11

47. USNRC, Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of License for By-Product, Source, or Special Nuclear Material'\ August 1987.

48. USNRC, 11 Branch Technical Position on Disposal or On-site Storage of Residual Thorium and Uranium from Past Operations", FR. Vol. 46, No. 205, Page 52061, October 23, 1981.

49. American National Standards Institute, "Radiation Protection Instrumentation Test and Calibration", ANSI N323-1978, Institute of Electrical and Electronic Engineers, Inc.

September 1977.

50. Cimarron Corporation, "Response to NRC Comments on Cimarron's Final Status Survey for Phase II, Subarea J" for Cimarron Corporation~s Former Nuclear Fuel Fabrication Facility, Crescent, Oklahoma", dated May 13, 1998 .

FSSR SUBAREA I vm

51 . USNRC letter from Mr. Ross A. Scarano, Director Division of Nuclear Materials Safety,

• Region IV, to Mr. S. Jess Larsen, Vice President, Cimarron Corporation, dated July 31, 1997.

52. E.W. Abelquist, "Confirmatory Survey for the South Uranium Yard Remediation, Kerr-McGee Corporation, Cimarron Facility, Cirescent, Oklahoma", Oak Ridge Institute for Science and Education, November 1995.

53. USNRC letter from Mr. Michael F. Weber, Chief, Low-Level Waste and Decommissioning Project Branch, Division of Waste Managdnent to Mr. Jess Larsen, Vice President, Kerr-McGee Corporation, dated May 31, 1995.

54. USNRC letter from Mr. Ross A. Scarano, Director, Division of Nuclear Materials Safety, Region IV to Mr. S. Jess Larsen, Vice President, Cimarron Corporation, dated November 3, 1998 .

55. American Society of Mechanical Engineers, "Quality Assurance Requirements for Nuclear Facility Applications" ASME NQA-1, 1994 .

• FSSR SUBAREA I IX

FINAL STATUS SURVEY REPORT FOR DECOMMISSIONING

• CIMARRON FACILITY SUBAREA I 1.0 PURPOSE This Final Status Survey Report (FSSR) is bding submitted by Cimarron Corporation to the Nuclear Regulatory Commission (NRC) for an area on the Cimarron site designated as Phase II Subarea I. This subarea is shown on Drawing No. 95MOST-RF3 which is included in Appendix I, and includes both affected and unaffected areas that have been surveyed as part of the ongoing site decommissioning process. This report discusses the initial characterization surveys which were performed to precisely define the extent and magnitude of residual contamination present in soils and on surface structures located within Subarea I. The characterization data generated during the initial surveys were utilized in designing the Final Status Survey (FSS) for this subarea which is included in the NRC approved Phase II Final Status Survey Plan (FSSP).

Based upon the Phase II FSSP, this FSS was performed for Subarea I to demonstrate that the established guideline values for unrestricted release had been met. The results of the Subarea I FSS are presented in this FSSR as justification for release of this Subarea from License SNM-928 for unrestricted use.

2.0 BACKGROUND

Cimarron Corporation, a subsidiary of Kerr-McGee Corporation, operated two plants near Crescent, Oklahoma, for the manufacture of enriched uranium and mixed oxide reactor fuels . The 840-acre Cimarron Facility site was originally licensed under two separate SNM Licenses. License SNM-928 1 was issued in 1965 for the Uranium Plant (U-Plant) and License SNM-11742 was issued in 1970 for the Mixed Oxide Fuel Fabrication (Pu-Plant) Facility. Both facilities operated through 197 5, at which time they were shut down and decommissioning work was initiated. Decommissioning efforts at the Pu-Plant Facility were completed in 1990 and Cimarron Corporation applied to the NRC on August 20, 19903 to terminate License SNM-1174. After confirmatory surveys, the NRC terminated the Pu-Plant License, SNM-1174, on February 5, 1993 4. Decommissioning efforts at the Cimarron U-Plant Facility involving characterization, decontamination and remediation were initiated in 1976 and are nearing completion. The goal of the decommissioning effort is to release the entire 840-acre site for unrestricted use. Based upon historic knowledge of site operations and the characterization work completed to date, Cimarron Corporation completed and submitted the 1994 Cimarron Radiological Characterization Report5 to the NRC. As discussed in that report, the site was divided into affected and unaffected areas. The affected and unaffected areas are shown on Drawing No. 95MOST-RF3 which is included in Appendix 1. For the final status survey the entire 840-acre site was divided into three major areas containing both affected and unaffected areas. Each of these three major areas are shown on Drawing No. 95MOST-RF3 and are designated by Roman Numerals I, II, and III (herein referenced as Phases I, II, and III). These three major areas were i i FSSR SUBAREA J

then further subdivided into smaller "subareas" (Le., A, B, C, D, etc.). The FSSP' s for the Phase

• I, II and III areas have been approved by the NRC and are discussed briefly below:

2.1 Phase I Area As presented in the Cimarron Decommis~ioning Plan6 , the FSSP's (Phases I, II and III) were discussed in general terms, with tM understanding that each of these three phases would be submitted to the NRC under sep~ate cover for approval. The FSSP for the first of these three phases (Phase I7), whic~ includes Subareas A, B, C, D, and E, was approved by the NRC by letter dated Ma~ 1, 1995 8. By letter dated November 13, 1995 9 , Cimarron modified the southern boundary of two Phase I areas (i.e., Subareas C and E) and placed these portions of Subareas C ahd E into Phase II Subareas G and H. With this modification, the Phase I FSSR 10 was submitted to the NRC and confirmatory sampling for the Phase I Subarea was complete~ by the Oak Ridge Institute for Science and Education (ORISE). Cimarron Corporation received Amendment # 13 which released all of the Phase I areas from License SNM-928; the amendment was forwarded to Cimarron by NRC letter dated April 23, 1996 11

• This amendment reduced the licensed facility acreage from 840 to approximately 152 acres.

2.2 Phase II Area The area designated as Phase II on Drawing No. 95MOST-RF3 contains both affected and some contiguous unaffected areas and represents approximate! y 122 of the remaining

• licensed 152-acres. The Phase II FSSP was submitted to the NRC in July 1995 12 and approved on March 14, 1997' 3
• Phase II includes Subareas F, G, H, I and J. Included within Phase II is Burial Area #1 which was released in December 1992 by the NRC 14, subsequently backfilled with clean soil, and then seeded. Also included in Phase II are the East and West Sanitary Lagoons, the Pu-Plant Building exterior and yard area, the Emergency Building, Warehouse Building #4 and surrounding yard, and numerous drainage areas. Cimarron has essentially completed all remediation in each of the Phase II Subareas and final status surveys are currently being completed.

The FSSR for Subarea J was the first Phase II Subarea to be submitted to the NRC for license release; it was submitted in September I99i5. Subarea J is West of Highway

          #74, and represents approximately 7 of the 122 acres in Phase II. The FSSR for Subarea 16 J has been approved by the NRC , and a confirmatory survey was performed by NRC staff during their site visit of September 21-23, 1998. By NRC letter dated December 4, 1998 17 , Cimarron was informed that the NRC staff plans to release Subarea J from license SNW-928 in the near future.

Subarea His the second Subarea included within Phase II where final status surveys have been completed. As discussed above, the East and West Sanitary Lagoons are included within Subarea H, which includes approximately 38.5 acres. The FSSR for Subarea H was submitted to the NRC on November 16, 1998 18 *

• Also included in Phase II is the concrete previously surveyed for release and placed in a drainage way located within Subarea F. These survey results have been reported to the FSSR SUBAREA I 2

19 NRC in the March 1998 FSSR for the concrete rubble located in Subarea F. By letter

• dated March 1, 199920 the NRC informed Cimarron that all NRC staff comments concerning the Subarea F Concrete FSSR have been resolved.

Subarea I is the next subarea included within Phase II where final status surveys have been completed. Included within Sub~a I are both affected and unaffected open land areas, buildings, fences and walkways. : Also included are the recently installed trailers which now house the site offices, charige rooms, and on-site laboratory. The office, restrooms and laboratory were moved to the trailers in April 1997 in anticipation of decommissioning those areas within the U-Plant Building. The open land area under the trailers has been left within Subarea I; tfue trailer interiors will be surveyed prior to final license termination. The results of th~ Subarea I FSS are presented in this Report. Subarea I represents approximately 19.1 ~cres. Final Status Survey Report preparation for Subareas F and G are in progress. 2.3 Phase III Area The area designated as Phase III on Drawing No. 95MOST-RF3 contains only affected areas and represents approximately 30 acres of the remaining licensed 152 acres. This area is designated as Phase III on Drawing No. 95MOST-RF3 . The FSSP for release of this area from the site license, was submitted to the NRC for approval in June 199721

• Phase III includes the former Uranium Processing buildings and yard area, Burial Areas

         #2 and #3, New Sanitary Lagoon, the NRC approved BTP Option #2 On-site Disposal Cell (Burial Area #4), and the Five Fonner Waste Water Ponds, consisting of Uranium Waste Ponds #1 and #2, the Plutonium Waste Pond, the Uranium Emergenc Pond, and the Plutonium Emergency Pond. By letter dated September 11, 1998 2 , the NRC     1 approved the Phase III Final Status Sun,ey Plan.

The FSSR for Subarea L (Subsurface) was the first Phase III FSS to be submitted to the NRC. The Subarea L FSSR (Subsurface) was submitted to the NRC on May 29, 199623 . The NRC, by letter dated August 16, 199624 , sent Cimarron comments concerning the Subarea L FSSR. Cimarron responded to the NRC comments by letters dated September 9, 199625 and October 17, 1996 26 . Additionally, in order to resolve the NRC staff concerns pertaining to the potential presence of subsurface contamination, additional subsurface soil samples were collected for analysis within Subarea L. Cimarron provided the results of this additional subsurface sampling event to the NRC by letter dated 27 November 4, 1996

• Based upon the NRC staff review of these submittals and the additional subsurface sampling data, Cimarron's request to backfill Subarea L was approved by NRC letter dated November 8, 199628 . Subarea L has been backfilled, contoured and vegetated. Subsequently, the FSS for the Subarea L surface soils was completed and the FSSR was submitted to the NRC on July 27, I 998 29
• Subarea L represents approximately 5-acres.

The FSSR for Subarea O (Subsurface) was submitted to the NRC in March 199830 . Subsequent to the submittal of the FSSR for Subarea O (Subsurface), a FSS was performed on the surface soils with the results presented in the February 199931 FSSR. FSSR SUBAREA I 3

20 Subarea O represents approximately 6.4 acres. By letter dated March 1, 1999 , the NRC

• staff notified Cimarron that they have no further questions concerning the Subarea 0 (Subsurface) FSSR. Another subarea recently addressed by Cimarron personnel was Subarea M, which is shown on Drawing No. 95MOST-RF3 and represents approximately 2.5 acres. The Subarea M FSS has been tompleted and the results were presented in the December 1998 FSSR32 .
• Final Status Survey Report preparation fdr Subareas Kand N are in progress.

3.0 DECOMMISSIONING ACTIVITIES The purpose of this section is to discuss briefly the status of the site decommissioning activities for Subarea I and to present the radiological criteria and guideline values utilized throughout the remediation and final status survey. Subarea I includes the former Warehouse Building #4 that was first converted to coal liquefaction research and then to titanium dioxide (TiO 2) research. Additionally, within this subarea are the Emer;gency Building, affected open land areas, and unaffected open land areas. Also included in this section is a discussion of the characterization data and remediation performed in the open land areas and on the buildings located within Subarea I. 3.1 Identification of Contaminants Based upon the knowledge of past site operations, the results of numerous characterization efforts to date, and other independent characterization efforts by regulatory agencies and their respective subcontractors, the radiological contaminants on the Cimarron site have been determined to consist of U-234, U-235, and U-238 with an average enrichment above the naturally occurring level of approximately 2.7 weight percent. Thorium, although not considered a significant contaminant of concern for this subarea, has been included in the soil and sediment analyses and reported on the data summary sheets along with the total uranium sample results. 3.2 Site Background Levels 3.2.1 Soils Natural background levels for uranium in soil have been established through numerous measurements by Cimarron personnel utilizing the on-site soil counter and through independent regulatory review and laboratory analysis. Cimarron personnel collected, analyzed and performed a statistical evaluation on 30 surface soil samples from the perimeter of the Cimarron site during the first quarter of 1995 to further validate background levels. Total uranium ranged from 2.3 pCi/g to 6.6 pCi/g, with the average being 4.0 +/- 2.6 (2cr) pCi/g. These values were obtained using the Cimarron on-site soil counter. This on-site soil counter is calibrated to assume an enrichment of 2. 7 weight percent as this is the average uranium enrichment found throughout the site. When a

• correction factor (0.67/1.5) is applied to these results to convert the values from an assumed 2. 7 weight percent enrichment to a natural enrichment, the converted results FSSR SUBAREA [ 4

ranged from 1.0 pCi/g to 2.9 pCi/g with an average of 1.8 +/- 1.0 (2cr) pCi/g total uranium.

• 3.2.2 This evaluation was submitted to the NRC staff in Cimarron's June 1995 letter . Based upon this sampling event, the average value of 4 pCi/g total uranium for background was adopted and applied when the on-site soil counter sample analytical results were compared to guideline values.

Exposure Rate 33 Background exposure rates have been :established by Cimarron by talcing micro-R readings and pressurized ion chamber (PIC) readings at off-site sample locations in addition to Cimarron site areas which are unaffected by past operations. Exposure rates of approximately 7 to 10 µR/h have been observed in background areas by Cimarron personnel utilizing Ludlum micro-R survey meters. In addition, site back~round exposure rates were measured by ORAU (now ORISE) personnel utilizing a PIC 4, and were determined to be 9 to 10 µR/h. Cimarron personnel performed exposure rate measurements at background locations along the site boundary in 1995 using a Micro-R meter. Confirmatory measurements were obtained at the same locations in 1997 using a Reuter-Stokes PIC. These data are tabulated below in Table 3.1. The average background as measured using the micro-R meter was 7.6 µR/h, and is about 15 percent less than the average for the PIC measurements of 9.0 µR/h. Cimarron had used 7 µR/h as representative of the average background exposure rate for micro-R measurements. Recently, Cimarron began sending their micro-R-meters off-site for calibration by the manufacturer. With this change in calibration procedure, measurements at background locations were taken for comparison to the PIC. This data also is presented in Table 3.1 and illustrates an increase in the average measured background of approximately 2 µR/h. Based upon this data, Cimarron now uses 9 µR/h as representative of background exposure rates for micro-R measurements taken with the off-site calibrated meters. Table 3.1 demonstrates good agreement between the micro-R measurements and the PIC measurements. TABLE 3.1 Sample ID Grid Micro-R Reading PIC Reading Micro-R Reading No. Location (µR/h) (µR/h) µRib* UAF-BKG-1 819W-81N 9 9.8 10 UAF-BKG-7 1600E-120N 7 7.6 7.5 UAF-BKG-11 840W-700S 8 9.5 10 UAF-BKG-13 840W-288S 9 9.8 10.5 UAF-BKG-16 808W-282N 8 9.7 9.5 UAF-BKG-19 640W-700S 9 10.5 11 UAF-BKG-23 1610E-300S 5 7.8 7.5 UAF-BKG-25 1610E-69N 6 7.6 8 UAF-BKG-27 1610E-469N 7 7.8 8.5 UAF-BKG-28 1610E-634N 8 9.6 9.5 AVERAGE 7.6 +/- l.7 (2cr) 9.0 +/- 2.3 (2cr) 9.2 +/- 2.8 (2cr)

         *Background survey results taken with instruments now calibrated off-site by manufacturer.

FSSR SUBAREA I 5

3.3 Characterization Data Throughout the decommissioning process at the Cimarron site, a survey unit was characterized, remediated (if required), and then a final status survey was performed. The description of the decommissioning !activities and final status survey data were then submitted to the NRC for review and approval (i.e. , FSSR). After review of the final status survey report, the NRC either released the unit, performed confirmatory survey with staff personnel, or contracted with ORISE to perform a confirmatory survey. Based upon the confirmatory survey (if requested by the NRC), the NRC would either release the unit or require additional characterization and/or remediation. For discussion and data presentation, Subarea I has been divided into survey units (for reference see drawing 95MOST-RF3) as follows:

• Affected Area Surrounding Warehouse (Ti02) Building #4;
• Warehouse (Ti0 2) Building #4 Interior;
• Warehouse (Ti02) Building #4 Exterior;
• Pu-Plant Building Exterior;
• Affected Area Surrounding Pu-Plant Building;
• Unaffected Areas including; (1) parking lot and grassy areas West and South of the Pu-Plant yard; and (2) the open land area separating Subareas Kand N from Subarea A;
• Emergency Building Interior;
• Emergency Building Exterior; and
• Affected Area South ofU-Plant Yard including:

Surface area soil samples; Drainage way soil samples, and Subsurface soil samples. Since several of these survey units contained both buildings and/or structures (either interior or exterior) and open land areas, further segregation of the survey data was required prior to performing the statistical evaluation for demonstrating that the established release criteria had been met. This segregation is delineated on Drawing No. 99MOST-RF4 included in Appendix I. For example, survey data for fences were evaluated separate from the survey data for an open land area. The segregation of the

• survey data is discussed below and in Section 5.2.1 .

FSSR SUBAREA l 6

3.3.1 Affected Area Surrounding Warehouse (Ti02) Building #4

• The restricted area surrounding Warehouse Building #4 has been extensively characterized and remediated. A random soil sampling program was undertaken in late 1989, with the analysis completed by February 1, 1990. The soil sampling program included corings taken from O to 2 ft. in!this area. In order to further characterize this area, in 1993 an extensive soil sampling !program was completed on a 5m x Sm grid to depths of O to 4 ft. The analytical d~a was included in Section 13 .0 of the 1994 Characterization Report 5 ~ and showed res\dual levels of uranium in soil from background up to 208 pCi/g. This characterizatiof1 data also was submitted to the NRC under 35 separate cover in July 1993 as part qf Kerr-McGee's request to install a titanium dioxide pilot plant on the Cimarron site utilizing the former Warehouse Building and land area north of this Building.

Based upon this characterization data, the area around the Warehouse Building was remediated prior to TiO2 pilot plant construction. Twenty-seven locations were excavated to depths from 1 to 5 feet, with both BTP Option #2 and #4 soils removed. In general, the entire yard area surface was disturbed during the remediation process. Option #2 soils were placed in a stockpile, subsequently tested for total uranium, then placed into the on-site disposal cell. Option #4 soils were packaged and shipped to an off-site LLRW disposal facility. Soil sampling was performed within each excavation and showed residual uranium varying from 5.5 to 32.4 pCi/g with a mean of 16.7 pCi/g. Subsequent to remediation, additional soil sampling was performed on the entire area at a depth of O to 6' at the I Om x l Om grid intersect locations. Seventy-seven soil samples were collected for the I Om x 1Om sampling event, with analytical results varying from 4.2 to 28.9 pCi/g total uranium with a mean value of 14.8 fCi/g. All post remediation data was submitted to the NRC in 3 September 1993 by letter which confirmed a phone conversation between Dr. Ed Still, Vice President, Cimarron Corporation and Mr. Gary Comfort, NRC' s project officer. In this letter Dr. Still stated: "Based on our telephone discussions, we understand this submittal and the data previously provided are adequate for confirming the radiological status of the soil around the Warehouse Building and that future soil borings will not be necessary. Cimarron is therefore proceeding with work related to installation of the titanium dioxide pilot plant we have described in earlier correspondence, to include pouring of concrete pads and walkways." The area was backfilled soon after NRC's verbal approval. After backfilling, the surface soils were randomly sampled and surveyed. The survey data for the backfill soils were 37 sent to the NRC in November 1993 , along with confirmation that the area had been backfilled in preparation for installation of the TiO 2 pilot plant. The former drain lines from the west side of the U-Building to the former East and West Sanitary Lagoons traversed through the Warehouse Building yard area. This drain serviced the U-Plant laboratory, restrooms and change rooms. In 1985, the East and West Sanitary Lagoons were removed frQm service in preparation for decommissioning. Prior to isolation, a new septic tank latera\ field was installed at approximate 21 ON - 20E. i FSSR SUBAREA I 7

The facility's rest rooms were then connected to this septic tank and the original drain

• line was isolated .

In 1992, the drain line from the U-Plant building to the former Sanitary Lagoons was removed with the exception of a small s~ction under the north-west corner of Warehouse Building #4. The interior of this drain! line located under the Building and the soils beneath the excavated drain line were : surveyed. The drain line survey results are discussed in Section 15.0 in the Charact¢rization Report. After sampling, this drain line excavation was backfilled. Additionally~ the entire yard area traversed by this drain line was included in the 1993 Sm x Sm depth isampling and remediation event and the follow-up 1Om x 1Om grid sampling. As notedJ with permission from the NRC, the entire yard area was backfilled and graded in 1993. Cimarron considers the subsurface soils released from license. However, for the FSS, these surface soils were surveyed at a frequency equivalent to the guidance contained in NUREG/CR-5849. This survey unit has been treated as an affected area with the FSS data presented in Section 5.2.1. Also, included with this survey unit are the walkways and concrete pads installed at part of the pilot plant studies and the fencing remaining around the perimeter of the Warehouse yard area. The concrete was surveyed as an unaffected structure and the fencing as an affected structure. 3.3.2 Warehouse (TiO 2) Building #4 - Interior

• Warehouse Building #4 is a sheet-metal building (50 ft. x 160 ft.) which was never used to process radioactive materials. However, cladded fuel assemblies were inspected and packaged for a short period of time within this building. Cimarron personnel requested permission from the NRC on September 18, 1979 to use the building for pilot plant coal liquefraction research. Approval was granted on December 28, 1979 by the NRC 38 .

However, a license amendment was not issued. This building remained under Uranium License SNM-928. The NRC's December approval letter stated:

                 "We agree with your proposal to decontaminate the building to below the NRC guidelines for release for unrestricted use prior to using it for non-nuclear activities; however, we will not eliminate this area as a place of use under our license since it is an integral part of the Cimarron facilities".

Final release surveys were completed on the inside surface of this building in 1980. The results of the floor survey showed an average fixed activity of 500 dpm/100 cm 2 gross alpha. The walls, fixtures and other surfaces showed an average fixed activity of less 2 than 500 dpm/100 cm gross alpha with a maximum fixed activity of 2,500 dpm/100 cm 2 39 gross alpha. The NRC gave approval on March 28, 1980 to use the Warehouse Building for non-nuclear purposes. The survey conducted in 1980 was for gross alpha only. Additional surveys were conducted on the inside surface of the building in 1993 for both gross alpha and gross beta-gamma. This survey revealed several small areas with elevated levels of beta activity in the concrete floor which

• required decontamination. The gross beta FSSR SUBAREA I 8

contamination was located at the entrance to the Warehouse Building near the south exit

• door. The contamination was ostensibly tracked into the Warehouse Building from the Uranium Yard Area and from the Uranium Building during site operations. Subsequent to the 1993 survey, the three small areas were decontaminated utilizing a needle gun and then re-surveyed. After decontaminatiqn, the beta-gamma activities ranged from an average of 760 dpm/100 cm2 to a maximum of 1,430 dpm/100 cm 2. The gross alpha I

survey performed at the same time shov{'ed a maximum fixed activity of 500 dpm/100 2 cm2 and an average of 200 dpm/100 cm . i As discussed, this Warehouse Building vras utilized for a bench scale coal liquefraction development project for several years friom 1980 through 1984, at which time it was shutdown. After remediation of the Warehouse yard area in 1993, and with NRC approval, the TiO2 equipment was instal1ed in 1994 inside the Warehouse Building and on concrete pads added just north of the Warehouse. This equipment is still located on site and is in use. As discussed in the NRC approved Final Status Survey Plan for Phase II Areas; the interior of the Warehouse Building will be treated as an unaffected area for this FSS with the exception of the floor area near the south entrance to the warehouse which was classified an affected area. The PSS for this unit is further discussed in Section 5.2.2. 3.3.3 Warehouse (Ti02) Building #4 - Exterior

• The exterior of this building was included in the 1980 gross alpha survey which found several areas on the roof which required decontamination. Additionally, the building exterior was included in the 1993 beta-gamma survey in an effort to further characterize the residual contamination present prior to installation of the TiO2 process. Based upon the 1993 survey data, Cimarron performed additional decontamination on the roof panels and classified a portion of the roof of the Warehouse an affected area. The exterior walls were classified as an unaffected area for the FSS. The FSS for this survey unit is discussed in Section 5.2.3.

3.3.4 Pu-Plant Building Exterior The Pu-Plant was licensed under License No. SNM-1174, which was terminated by the 2 NRC on February 5, 1993 . This license termination was in response to the request submitted to the NRC by Cimarron Corproation3 . The following was stated in the February 5, 1993 NRC letter:

                 "The staff has determined that ( 1) all special nuclear material relating to this license has been properly disposed, (2) reasonable effort has been made to eliminate residual radioactive contamination, and (3) a radiation survey has been perfonned, and confirmed by the NRC, which demonstrates that the premises are suitable for release for unrestricted use."

• FSSR SUBAREA I 9

A detailed confirmatory survey was perfonned on the Pu-Plant and all associated areas by ORAU, and included measurements for both plutonium and uranium in soil samples and surface activities on the building exterior, walkways, and other miscellaneous surfaces. The confirmatory survey included gross alpha and gross beta-gamma measurements of fixed and removable cotitamination levels, exposure rate measurements, and the determination of radionuclide coilicentrations in soil, concrete, and paint samples. The Interim Confirmatory Survey Report was issued by ORAU on January 31, 198940 41 and the Final Confirmatory Survey Report was issued in January 1991 . The final report states the following: "Based on the resµlts of the confirmatory survey, it is ORAU' s opinion that the decontamination efforts bave been successful in satisfying the guideline levels and that the licensee's documentation adequately and accurately describes the final radiological status of the site." Based upon the ORAU survey, the NRC issued an Environmental Assessment and Finding of Significant Impact (FONSI) on February 5, 1993 42 , to support the termination of License No. SNM-1174 for the Pu-Plant and associated areas at the Cimarron Facility. The FONSI and Notice of Opportunity for 43 Hearing appeared in the Federal Register on February 12, 1993 . The following section appears in item (2) and (3) on page 8432 of this Federal Register notice:

                  "(2) There is limited contamination of the surrounding soils. The average uranium content of the exterior soils is two to three times background levels but about two orders of magnitude below NRC soil guidelines for disposition of contaminated soils with no restrictions. The average plutonium content of the exterior soils is indistinguishable from background and over two orders of magnitude below NRC soil guidelines for disposition of contaminated soil with no restrictions.

(3) The surface contamination levels of plant interior and exterior surfaces are, on the average, three orders of magnitude below NRC decontamination guidelines. Based upon the confirmatory survey and finding of no significant impact, License No. 4 SNM-1174 was terminated in 1993 . Cimarron believes that the confirmatory survey, completed as a prerequisite to the termination of License SNM-1174, adequately addressed the residual concentrations of radionuclide, including total uranium, on the exterior of the Pu-Plant. Thus, this building exterior was not included in any additional final status surveys. 3.3.5 Affected Area Surrounding Pu-Plant Building As discussed in Section 3.3.4, the Pu-Plant yard was included in the final ORAU Confirmatory Survey Report issued in January 1991. As noted in Section 3.3.4, the NRC stated in the FONSI that, "[T]he average uranium content of the exterior soils is two to three times background levels but about two orders of magnitude below NRC soil guidelines . . . " Even though the confirmatory survey completed by ORAU in 1988 showed that the Pu-Plant yard soils were acceptable for free release, Cimarron elected to survey the yard as an affected area for this FSS. The reason for classifying this survey unit affected was based upon preliminary characterization data that identified several FSSR SUBAREA I 10

locations with elevated total uranium act1v1ty. Based upon the preliminary survey, several locations within this survey unit were subsequently remediated; the areas remediated and FSS data for this unit are discussed in Section 5.2.4.1. Also included with this survey unit is the[ fencing still remaining around the perimeter of this affected area survey unit. The fencing was surveyed for both gross alpha and gross beta-gamma with the results discussed in Section 5.2.4.2. 3.3.6 Unaffected Areas The open land area which includes the U-Plant parking lot and the grassy areas west and south of the Pu-Plant yard and south of Subareas K and N are classified as unaffected areas. Limited data was presented in the Characterization Report 5 for these areas with the exception of the parking lot west of the U-Plant Building. Data was collected from twenty-six locations in 1990 at soil sample increments of0-6", 6"-1', l'-2', 2'-3' and 3'- 4'. The samples were analyzed for total uranium and showed residual activity varying from 7 to 20 pCi/g with a mean of 12.0 pCi/g. Also, systematic surveys were collected at the 1Om x 1Om grid intersects for the parking lot using both shielded NaI and micro-R meters. This data was discussed in Section 6.0 of the Characterization Report 5

• It should be noted that in 1990, the on-site counter was calibrated to reflect the higher concentrations in soil expected during the remediation phase of site decommissioning.

As remediation has progressed, the computer-based spectrum analysis capabilities for the on-site counter has been enhanced to mirror the lower concentrations in residual activity encountered in performing the final status surveys. A comparison between the 1990 data and the more recent soil analytical data along with the FSS for this unit are discussed in Section 5.2.5. l. The data comparison shows a high bias for the 1990 characterization data. Also included with this survey umt 1s the fencing remammg at various locations throughout the unaffected area. The fencing was surveyed for both gross alpha and gross beta-gamma with the results discussed in Section 5.2.5.2. 3.3.7 Emergency Building Interior This building, during facility operations, housed the site emergency coordinator, records, emergency supplies, and emergency decontamination showers. This unit was surveyed as an affected area in accordance with the Phase II FSSP. The FSS for this unit is discussed in Section 5.2.6. 3.3.8 Emergency Building Exterior This building is surrounded by an unaffected area. Thus the exterior of the building was surveyed as an unaffected area. The FSS for this unit is discussed in Section 5.2.7 .

• FSSR SUBAREA I l1

3.3.9 Affected Area South of U-Plant Yard

• This area received drainage from the U-Plant yard area and thus has been designated an affected area for the FSS. This area rec¢ived limited characterization surveying in 1990 when general area soil samples were collbcted on a ten meter grid to a depth of 4 feet for total uranium analysis. The analytical results which were presented in the Characterization Report showed two surface locations with residual activity at 47 pCi/g total uranium. These two locations at 20N-IO0E and 20N-120E were remediated prior to the FSS. Also, at 20N-130E at a dept of 1' - 2', the sample result showed a residual total uranium activity in soil of 58 pCi/g. This location also was remediated prior to the FSS.

The FSS for this unit is discussed in Section 5.2.8. 3.4 Environmental Monitoring Data As previously discussed with the NRC 's staff, Cimarron Corporation has committed to address groundwater for the site in a separate report. This report is titled, "Decommissioning Plan - Groundwater Evaluation Report", and was submitted to the 44 NRC in July 1998 . This Groundwater Evaluation Report summarizes the site environmental data, presents trending analyses and a dose assessment, and commits to a plan for resolving the issues associated with elevated residual groundwater radionuclide concentrations. Per discussions held at NRC headquarters on January 11, 1999, and by letter dated January 19, 199945 , the NRC approved a groundwater criteria of 180 pCi/l for total uranium. There are four monitoring wells located within Subarea I; the wells are

• 4.0

         #1322, #1323, #1327B, and #1330. None of the wells within Subarea I contain total uranium concentrations in groundwater exceeding the criteria as prescribed in NRC's January 1999 letter.

FINAL ST A TUS SURVEY PROCEDURE The purpose of this section is to discuss the methodology utilized for the collection of the survey and soil sampling data presented as FSS data in this report, and to discuss the radiological guideline values utilized for comparison to the FSS data. The FSS data were used to demonstrate that the applicable radiological parameters (i.e., guideline values) were satisfied for release of Subarea I from License SNM-928. The guideline values utilized for comparison to the FSS data are described in this section. In general, for Phase II areas, Cimarron Corporation has committed to follow the methodology prescribed in NUREG/CR-584946 and as approved in the Phase II FSSP for performing the FSS. This report includes all necessary data to support the FSS for the soils and building contained within Subarea I and the release for unrestricted use of Subarea I from License SNM-928. 4.1 Survey Method In general, survey and soil sampling data were collected utilizing established methods that have been demonstrated through the release of other areas at the Cimarron site. The

• instrumentation available for use by site personnel as well as the minimum detectable FSSR SUBAREA I 12

activity (MDA) and typical efficiency for those instruments are listed in Table 4.1. The

• survey methods are discussed further below:

4.1.1 Grid Areas Subarea I was subdivided into the IOOm x 100m grid pattern shown on Drawing No 95MOST-RF3. The 100m x 100m gtjds were further subdivided for affected area surveys into 1Om x 1Om grids. For sy$tematic surveys, the l Om grids were further subdivided into Sm x Sm grids. The 5m x 5m grids were utilized for locating survey and soil sampling points for this FSS. Cimarr-on employs a Global Positioning Survey (GPS) unit to check pre-established grid points and to locate sample collection and survey positions in the field. This GPS unit is accurate to within less than+/- I m. The 0.0 grid point is located just south and slightly west of the main Uranium Building and has been tied into a permanent marker for future reference. For a building designated as an affected area the interior and exterior were divided into either 1m x Im or 2m x 2m grids for locating survey points. The GPS unit was used only to locate the comers of the building and not for locating the actual surveys on the building surfaces. 4.1.2 Survey Procedure (Open Land Areas) In general, the Subarea I open land affected areas were 100% scanned utilizing a 3" x

• 1/2" unshielded Nal detector. The specific instruments used were selected by the RSO/Health Physics Supervisor.

Each 5m x 5m grid was surveyed by technicians by traversing back and forth within the grid. Each traverse performed by the technician covered an area approximately 2 meters in width. The highest reading found within each grid area was recorded. Survey performance, documentation, and record retention was performed in accordance with the Cimarron Radiation Protection Program. In the event that any of the survey readings exceeded the limits discussed in Section 4.2.3, their location was flagged for additional surveys and/or soil sampling. The survey procedures followed were specified in Cimarron's Special Work Permit(s) and Work Plan(s) for this subarea. Additionally, at the intersect of each 5m x 5m grid location, a systematic survey was completed at ground surface and at 1 m above the surface for ambient radiation using a micro-R meter. Also, a gamma survey at the ground surface, using a shielded or unshielded 3" x 1/2 11 NaI detector was performed and documented .

• FSSR SUBAREA I 13

TABLE 4.1 RADIATION MONITORING INSTRUMENTS INSTRUMENT NUMBER .RACllATION SCALE TYPICAL TYPICAL M.DA 95% TYPE AVAILABLE DETECTED RANGE . ..

• BKG
• EFFICIENCY CONFIDENCE LEVEL 2

Scintillation (Ludlum 2224) 2 Alpha 0-500,000 cpm < 10 cpm 20% 100 dpm/100 cm 2 Sea ler/Ratemete r Beta < 300 cpm 19% 500 dpm/100cm Micro-R Meter (Ludlum 12 & 19) 3 Gamma 0 - 5,000 µR/h 7 µR/h- 9 µR/h NIA 2 µR/h 1" x 1" Nal Detector Ion Chamber (Victoreen) 1 Gamma 0.1 - 300 mR/h <.0 1 mR/h N/A < 0.2 mR/h 3" x 1/2" Nat Scintillation (43-82) 3 Gamma 0 - 500,000 cpm 3,000 cpm avg shielded NIA 250 cpm Digital Scaler (Ludlum 2220/2221} 9,000 cpm avg unshielded 500 cpm 2 100 cm gas flow (43-68) 2 Alpha 0 - 500,000 cpm <10 cpm 20% 100 dpm/100 cm 2 Digital Scaler (Ludlum 2220/2221} 2 2 60 cm gas flow (43-4) 1 Alpha 0 - 500,000 cpm <10 cpm 25% 200 dpm/100 cm

            *Digital Scaler 2

60 cm Count Rate 7 Alpha 0 - 500,000 cpm <100 cpm 50% 350 dpm/100 cm 2 Meter (PRM-6) 2 50 cm Personnel Room 2 Alpha 0 - 500,000 cpm <100 cpm 50% 500 dpm/100 cm 2 Monitor (Ludlum 177) Tennelec LB5100 Computer 1 Alpha 0 - 99,999,999 <0.3 cpm 38% 0.4 dpm Based Auto Sample Counter Beta cpm 1.5 cpm 42% 1.5 dpm Soil Counter - Computer Linked 1 Gamma --- 4 pCi/g Total U 4% 5 pCi/g U (5min. count) 4" x 4" x16" Nal (Tl) Detector 1.5 pCi/g Th (Nat) 15% 0.6 pCi/g Th (Nat) (5min. count) 3 pCi/g U (15min. count) 0.3 pCi/g Th (Nat) (15min. count) 2 2 100 cm gas flow (43-68) 2 Beta, Gamma 0 - 10,000 cpm <300 cpm 20 600 dpm/100 cm Digital Scaler (Ludlum 2220/2221)

• Reuter-Stokes PIC Model RSS-112 1 Gamma 0- 100 mR/h 9- 10 µR/h NIA 0.5 µR/h (10mi n. count)

  *(Cushing Instrument available for Cimarron Use)

FSSRSUBAREA I 14

• 4.1.3 Soil Sampling Procedure The soil sampling frequency was specifi~d in the Cimarron Special Work Permit(s) and Work Plan(s). Where practicable, systematic surface soil samples were collected at each 5m x 5m grid intersect location. All ~oil samples collected were analyzed for total uranium and natural thorium using th¢ on-site soil counter. Any locations found exceeding the soil guideline values for affected areas as discussed in Section 4.2.2 were investigated further.

4.1.4 Survey Buildings and Structures If characterization surveys showed that the upper interior surfaces and exterior surfaces were not expected to contain residual activity that exceeds 25% of the guideline value, then the surfaces were 10% scanned as an unaffected structure for alpha and beta-gamma. Additionally, a minimum of thirty random locations were selected for systematic surveys. In general, for affected surfaces, the interior floors, lower walls, and external roof panels were 100% scanned for alpha and beta-gamma. Areas of elevated activity which were identified during the scan were further surveyed with direct measurements to define the extent and activity levels. Remediation was performed if guideline values (Table 1 of NRC' s 1987 guidance) were exceeded; areas were then resurveyed as necessary.

• Systematic surveys (fixed surveys and smear surveys) for alpha and beta-gamma were performed at a spacing equivalent to a maximum of a 2m x 2m grid on the floor, lower walls, and roof panels. Systematic micro-R measurements also were taken at one meter from the floor at a frequency equivalent to one measurement per every 4 m 2 (i.e., 2m x 2m grid) of surface area.

4.2 Radiological Guideline Values The radiological guideline values discussed in this section were utilized for comparison with the FSS data in order to confirm that Subarea I can be released for unrestricted use from License SNM-928. 4.2.1 Buildings and Equipment The unconditional release limits for surface contamination on buildings and fixtures are in compliance with Facility License SNM-928, and are identical to the limits specified in Table I of the NRC's "Guidance for Decommissioning of Facilities and Equipment Prior 47 2 to Release for Unrestricted Use"

• Residual activity exceeding 15,000 dpm/100 cm were remediated and follow-up surveys performed. Areas of elevated activity between 5,000 and 15,000 dpm/100 cm were tested in accordance with NUREG-5849, Section 8.5.2, to assure that the average surface activity level within a contiguous 1 m 2 area containing the 2

elevated areas was less than 5,000 dpm/100 cm *

• Unaffected areas that show surface reaping above 25% of the guideline values were evaluated to determine if the general are~ should be reclassified as an affected area. For FSSR SUBAREA I 15

2 example, a survey reading, either from a scan or fixed survey above 1,250 dpm/100 cm (i.e., 25% of the surface guideline value of 5,000 dpm/100 cm 2) would be evaluated . Additionally, the average exposure rate guideline values as measured at l meter from the surface for internal building surfaces is. 5µR/h above background. Subarea I contains three buildings, fencing, and light poles surveyed in accordance with the August 1987 NRC Guidance. 4.2.2 Volumetric Activity of Soil For Subarea I, the unrestricted release guideline value for residual concentrations of total uranium, which may remain in the soil for unrestricted release is specified as BTP 48 Option #1 material. For enriched uranium, as specified in Table 2 of the BTP, the Option

         #1 limit is 30 pCi/g total uranium above background. The average total uranium background concentration has been established at 4 pCi/g 33 . The maximum enriched uranium soil concentration within any l Om x 1Om grid area may not exceed three times the BTP Option # 1 limit (i.e., 90 pCi/g total uranium) above background. Systematic soil sampling was performed within each 1Om x 1Om grid area to determine the average residual total uranium concentration. This systematic sampling equates to four surface samples per 100 m2 area; which is the same sample frequency as one sample collected at the intersect of each Sm x 5m grid intersect. Areas of elevated activity were determined based upon discrete sampling within the grid or were assumed to have a constant value (e.g., 2Sm2 based upon Sm x Sm grid sampling frequency). The average value for the 10m x 10m grid then was compared to the BTP Option #1 guideline value of 30 pCi/g total uranium above background. Remediation or hot spot averaging was performed for each individual location which contained average total uranium concentrations in excess of 30 pCi/g above background as described in NUREG/CR-5849. Areas of elevated activity not remediated between one and three times the ~uideline value were tested to assure that the average concentration was less than (I 00/A) 1 2 times the guideline value, where "A" is the area of elevated activity in m2 .

The Option # 1 unconditional release guideline value for residual concentrations of natural thorium, which may remain in soil per Table 2 of the BTP, is up to 10 pCi/g above background. The average background for natural thorium has been determined to be 1.5 pCi/g for soil analyzed with the on-site counter. 4.2.3 Gamma Surface Survey (Open Land Areas) Cimarron personnel utilize a shielded or unshielded 3" x 0.51' sodium iodide (Nal) detector as a final screening device for qualitative identification of residual contamination in soil. Prior to the commencement of site-wide remediation, Cimarron evaluated several portable survey instruments for performing scan surveys including the 2" x 2" Nal detector. Based upon recommendations from Ludlum Instruments, Inc., Cimarron decided to use the 3" x 0.5 NaI detector for general area scans. This system is one of the more sensitive field detection instruments available to Cimarron.

• Since the inception of Cimarron's site decommissioning, twice background has been used as the guideline for scan surveys when utilizing the 3 x 0.5 Nal detector. Survey FSSR SUBAREA I 16

readings above this guideline indicate an area requiring additional investigation. This

• guideline has been a standard in the nuclear industry for many years. With the submittal and approval by the NRC of numerous plans and reports, twice background also has become the accepted standard for thei' Cimarron Facility as a qualitative screeninf measure. This qualitative guideline was i eluded in the Phase I Final Status Surve Plan ,

11 Phase I Final Status Survey Report 10 , an . the Phase II Final Status Survey Plan just to name a few of the documents where this guideline was addressed and approved by NRC staff for this site. Twice background (as noted in Section 6.4.2 ofNUREG/CR-5849) is at the lower end of the range discemable for scanning instrumentation. During the scan survey the technician, upon noting a "discemable" difference in the audio output from the meter, will stop and attempt to locate the elevated area. It is difficult to discriminate low levels of residual uranium contamination when other naturally occurring isotopes are present which affect the gross count rate of the scan instrument. The guideline value of twice background provides a sufficient margin for technicians when conducting a scan to conclude that residual contamination may be present when a signal exceeds the twice background level (i.e., a discemable audible increase above background). This discemable audible response alerts the surveyor to momentarily stop moving the probe (i.e., 2 to 3 seconds) and to further investigate the area. The survey instruments utilized at Cimarron indicate changes in radioactivity levels via either a higher or lower pitch. These changes in pitch are easier to detect rather than simply noting an audible change in the count rate.

• The unshielded detector was utilized to perform the initial 100% surface scan survey for Subarea I open land areas to identify regions or areas of slightly elevated activity. Also, the shielded or unshielded detector was utilized for systematic surveys at each grid intersect to identify elevated areas. As stated above, this instrument is only utilized for qualitative measurements. Quantitative measurements of residual contamination levels in soil are performed with the Cimarron soil counter. Additionally, daily "background" surveys are taken prior to performing surveys within a survey unit. These average daily "backgrounds" are listed on the data tables and drawings and were used for comparison to the guideline (i.e., twice background).

4.2.4 Exposure Rate Survey The average exposure rate for Subarea I open land areas to be released for unrestricted use is 10 µR/h above background, at 1 meter above the surface. This includes ~aved surfaces and building exteriors. Exposure rates may be averaged over a 100 m grid area as described in NUREG/CR-5849. The maximum exposure rate at any discrete location within a 100 square meter area cannot exceed 20 µR/h above background. Any area with average exposure rates greater than 10 µR/h above background and any discrete location within a 100 square meter area with an exposure rate greater than 20 µR/h above background was delineated and remediated as required. Cimarron has in the past measured 7 µR/h as the average background exposure rate. However, as discussed in Section 3.2.2, since sending their micro-R meters off-site for calibration by the manufacturer, Cimarron has demonstrated that 9 µR/h is representative of the average FSS R SUBAREA I 17

background exposure rate for micro-R measurements. The tables and drawings included

• in the Appendices provide the average background for the micro-R meter used in developing the tabulated survey data. A background of 7 µR/h indicates that the instrument utilized for performing the i survey was calibrated on-site; and likewise a background of 9 µR/h indicates calibratiqn off-site.

The average exposure rate guideline va\ue as measured at 1 meter from the surface for internal building surfaces is 5 µR/h abo~e background. Residual activity which exceeded 3 times the guideline values, resulting; in external radiation in excess of 2 times the guideline values above background at j m from the surface, or resulted in an average activity above the guideline value in any contiguous I m 2 for internal building surfaces was remediated until these conditions were satisfied. 4.3 Equipment Selection Special Work Permits (SWP) and Work Plans (WP) were written and approved prior to commencement of the field work required for this FSS. The SWP and/or WP for Subarea I specified the type of instrumentation to be utilized in performing the FSS. 4.3.1 Equipment and Instrumentation The instrumentation utilized to generate the FSS data discussed herein was calibrated and maintained by site personnel in accordance with the Cimarron Radiation Protection

• Program procedures. These procedures utilize the guidance contained in ANSI N323-1978, "Radiation Protection Instrumentation Test and Calibration49 ".

requirements, as specified by the Cimarron procedures for instrumentation, include Specific traceability of calibrations to NIST standards, field checks for operability, background radioactivity checks, operation of instruments within established environmental bounds, training of individuals, scheduled performance checks, calibration with isotopes of energies similar to those to be measured, quality assurance tests, data review, and recordkeeping. An explanation of how Cimarron's Radiation Protection Program procedures are implemented with respect to instrumentation was discussed in Cimarron's responses to the NRC letter dated May 13, 1998 50 . With the exception of the exposure rate instrumentation (ion chamber, PIC and micro-R meter), Cimarron health physics staff performs in-house calibration on each of the instruments listed in Table 4.1. Portable survey instruments are calibrated on a quarterly basis. The exposure rate instruments are sent off-site for vendor calibration on a semi-annual basis. Where applicable, activities of sources utilized for on-site calibration are corrected for decay. In addition to the periodic calibration requirements, source response checks are performed on a daily basis for all instruments being utilized during characterization, remediation and final status survey work. All calibration and source check records are completed, reviewed, signed-off and retained in accordance with the Cimarron Quality Assurance Program. The instrumentation utilized by site personnel is discussed below: FSSR SUBAREA I 18

4.3.1.1 Unshielded 3" x 0.5 Na! Gamma Detector The 3" x 0.5 detector is a sodium iodide (Nal) crystal gamma detector which is unshielded around all sides. The Nal detector is utilized with a portable scaler/ratemeter that has single channel analyzer capability. Americium-241, Uranium-235, and Natural Thorium sources are utilized to set the instrumentation window and threshold to detect gamma energies in the range of 50 to 2~0 keV. This energy range corresponds to the energies of interest when surveying for uranium and natural thorium contamination. The instrument is normally operated in the w~ndow "out" mode, meaning that the instrument response is for the entire range of detectable energies. 4.3 .1.2 Shielded 3" x 0.5 NaI Gamma Detector The 3" x 0.5 detector is a Nal crystal gamma detector which is shielded with lead around the top socket and sides to improve the directional sensing capabilities of the equipment. Similar to the unshielded detector, the shielded detector is utilized with a portable scaler/rate meter that has single channel analyzer capacity. This instrument is normally utilized in areas where background may be elevated. 4.3.1.3 Micro-R Meters The micro-R meter is a I" x I" NaI crystal gamma detector which measures exposure rates between O and 5,000 µR/h. Background readings are obtained daily at a defined

• location prior to placing each instrument into service. This instrument is utilized, in general, for determination of exposure rates at both systematic and random locations and at locations of elevated radiation identified by area scans.

Confirmatory measurements are obtained routinely to provide information concerning any measurement bias. These comparisons or confirmatory measurements are made using a pressurized ion chamber. Confirmatory measurements for Subarea I are included in Table 4.2 and show results indicative of site background for Micro-R meters calibrated off-site. TABLE 4.2 CONFIRMATORY MEASUREMENTS (Readings 1 Meter Above Grade) Reading Location Micro-R Reading PIC Reading (µR/h) (µR/h) 82N-20N 8.5 8.3 150N-40E 8.5 8.5 180N-45E 8.5 8.8 200N-95E 9.0 8.8 165N-85E 9.0 9.1 135N-105E 7.5 7.9 Average 8.5 8.6

• FSSR SUBAREA I 19

4.3.1.4 Gross Alpha/Beta Detector

• Surface activity measurements for gross beta-gamma were obtained using a Ludlum Model 2221 with a Model 43-68 gas proportional probe, or equivalent (e.g., Ludlum Model 43-89). Gross alpha surface scan~ were obtained using an Eberline Model PRM-6 with an Eberline Model AS-15 probe.

4.3.1.5 Soil Counter (Gamma Spectroscopy) The Cimarron Soil Counter System consists of a 4" x 4" x l 6 11 sodium iodide crystal housed in a shielded chamber which is computer linked to a multi-channel analyzer (MCA). Cimarron's counting system is programmed to determine the total uranium present in the soil sample by calculating the U-234 activity based upon the U-235 activity measured in the soil sample. The U-234 and U-235 activities are summed with the detected U-238 activity to obtain the total U activity. The counter also adjusts for system background. Calibration of this counting system is performed annually and is traceable to NIST standards through contractor laboratory evaluations of the on-site standards. Established quality assurance measures for the soil counter include Cesium-137 centroid checks, Chi-square tests, background determinations, and the counting of soil standards. All of these quality assurance controls are recorded on control cards and are trended on a continuing basis.

• Standards used for calibration and quality assurance checks for the soil counter have been analyzed by outside laboratories and are NIST traceable through these analyses.

Comparisons have been made between the standards as counted using the soil counter and two off-site laboratories. The assigned values for the standards are the average of the results obtained from the off-site laboratories, when the standards were analyzed by more than one laboratory. The standards range in concentration from 4.5 pCi/g total uranium to 292 pCi/g total uranium. Additional information pertaining to these standards and typical MDA calculations for the counting system were included in Cimarron's response to the NRC's comments on Subarea J50 . Cimarron personnel determine uranium and thorium activities in soil based upon the evaluation of net counts from the soil counter. Activities are calculated through the use of efficiency and correction factors obtained using appropriate standards. Soil concentrations are calculated by dividing the net activity by the soil mass. Soil masses are determined on a laboratory scale which is checked on a daily basis (when in use) utilizing NIST traceable standards. Corrections for soil moisture content are also made as necessary. ORISE has been used by the NRC for verification of a majority of the decommissioning work completed to date at the Cimarron site. ORISE has conducted an evaluation of the Cimarron Soil Counting system's ability to measure accurately total uranium concentrations in soil samples. This was done by comparing ORISE sample analysis results obtained by gross alpha pulse height analysis and gamma spectroscopy with the

• results obtained from the use of the Cimarron Soil Counter. ORISE and Cimarron analysis results compared favorably at levels above background as demonstrated by the FSSR SUBAREA I 20

confirmatory analysis performed fo r the On-Site Disposal Cell, Pit #3 (NRC cover letter dated July 31, 1997)5 1* NRC inspection Report #70-925/97-02, which accompanied this letter, states that no significant bias or statistical errors between the licensee's soil results and the NRC's results were identified". Additionally, the confirmatory analysis performed on selected soil samples colletted during ORISE's site visit to investigate the South U-Yard 52 , and DAP-3 stockpile53 verified previously that Cimarron's on-site counter results are statistically identical to ORISE's results. A more recent inspection by the NRC also confirmed Cimarron' s Soil Counting system's ability to accurately measure total uranium. concentrations in soil samples. On September 24, 1998, the NRC collected twelve (12) soils and sediment samples from Subarea J. The samples were first counted on the On-Site Counter by Cimarron and then shipped by NRC to their Region III laboratory for analyses. The November 3, 1998 Inspection Report54 (i.e., Report No. 70-925/98-02) stated the following:

                  "'Overall, the NRC measurements confirmed that Subarea J soil and sediment had less than 30 pCi/g uranium. No significant bias or statistical errors between the licensee's soil and sediment sample results and the NRC's results were identified.           Licensee measurement methods and counting times were found to be acceptable."

4.4 Procedures/PI ans

• As discussed in Section 4.3, SWPs and WPs were written and approved prior to commencement of fieldwork required for this final status survey. These SWPs and WPs are an integral part of this site's radiation protection and quality assurance program.

Project organization and responsibilities, which are a part of the site's quality assurance program, are discussed in this section. 4.4.1 Organization The Subarea I FSS was performed by a survey team consisting of qualified personnel from the Cimarron Facility. The FSS team operated under the general direction of a Project Manager who reports directly to the Site Manager at the Cimarron Facility. The selection of field measurement equipment and sample collection techniques was under the direction of the RSO/Health Physics Supervisor. Actual field measurements and sample collection were under the direction of the Project Manager. The Project Manager was responsible for developing the SWP and WP for Subarea I with input from the RSO/Health Physics Supervisor. The SWP and WP were reviewed and approved by the Cimarron Site Manager. 4.4.2 Training Cimarron Corporation provides continuing training to Cimarron personnel and any other

• personnel (i.e., contractors, visitors, etc.) who are allowed access to the site. All members of the FSS team attended an in-house training session on the SWP and WP prior to FSSR SUBAREA I 21

commencement of work. All FSS procedures and quality assurance requirements were reviewed during this training session . 4.4.3 Radiation Protection Program Cimarron Corporation maintains a radiadon protection program that meets and/or exceeds all of the applicable regulatory requirements associated with activities conducted under Special Nuclear Materials License SNM-928. The Cimarron Radiation Protection Program currently in place for all decommissioning activities is administered through the use of the following documents:

• Cimarron Radiation Protection Procedures
• Cimarron Site Health and Safety Plan
• Cimarron Quality Assurance Plan and Procedures
• Cimarron Emergency Plan It is the policy of Cimarron Corporation to perform all work in strict compliance with applicable regulatory and internal requirements. The goal of the Cimarron decommissioning effort is to conduct all operations at a level of excellence that exceeds regulatory requirements. Cimarron staff will continue to exercise appropriate radiation protection precautions throughout the remaining decommissioning work and final survey process .
• Independent Kerr-McGee Corporate audits for regulatory and internal requirements are conducted on a periodic basis and include the review of the Cimarron Radiation Protection Program and associated programs. Assessments of program effectiveness are also performed periodically by the Cimarron RSO/Health Physics Supervisor. Additionally, the Cimarron Radiation Protection Program is inspected for compliance with applicable rules and regulations by NRC Region IV and NRC Headquarters staff.

4.4.4 Cimarron Quality Assurance Program (QAP) The Cimarron Corporation QAP is an integral part of the Cimarron Radiation Protection Program. A principal component of the QAP is the confirmation of the quality of project work performed during decommissioning by assuring that all tasks are performed in a quality manner by qualified personnel. The Program ensures that samples are collected, controlled, and analyzed in accordance with applicable quality controls to provide confidence in the resulting data accuracy and validity. Cimarron's QA/QC program is structured to generate data that can be verified through independent review should they desire to perform an audit of the data. The Cimarron QAP is implemented and maintained in accordance with written policies, procedures, and instructions. This Program is administered under the direction of the Quality Assurance Manager. Periodic surveillance and reviews are conducted to ensure that all aspects of the Program are addressed. The Cimarron QAP satisfies the applicable requirements of ASME NQA-t 55. FSSR SUBAREA I 22

Written procedures designated as SWPs and WPs, are prepared, reviewed and approved

• for activities involved in carrying out the decommissioning process. The Subarea I Survey SWP and WP were written in accordance with the Cimarron QAP. These documents designate the type of surv~ys to be performed, samples to be collected, frequency of sample collection, and the type of field instrumentation required for the tasks required.

Selection, calibration and use of radiation detection instrumentation used for final status survey release at Cimarron are directed by the Radiation Safety Officer (RSO). The RSO is responsible for the calibration perfotmed by Cimarron Health Physics staff or by contract services. The RSO maintains a file for each technician on staff as to their qualifications and training. The facility performs its own radiological soil analysis in accordance with written procedures and QA/QC protocols. Field data are gathered and maintained in logs for all samples in accordance with the Cimarron QAP. Necessary data are transferred to the on-site laboratory sample log when the sample is brought to the on-site laboratory for analysis. The sample logs provide a record of sample collection and transport (chain of custody) and are incorporated into the facility quality assurance records. In addition, off-site independent radiological analysis of split samples (samples are first counted on site and then sent to an off-site independent laboratory) is an integral part of the Cimarron QAP. Samples sent to an off-site independent laboratory for analysis are accompanied by a chain of custody form in accordance with the Cimarron QAP. These forms provide documentation for all aspects of sample control and are maintained by the Quality Assurance Manager as permanent records. Sample and survey data are reviewed by the Health Physics Department for accuracy and consistency and to determine if further characterization or remediation is required or if the data is acceptable. Additionally, the data are compared to the guideline values on a regular basis. The data review process verifies that approved QA/QC procedures have been followed. When identified, corrections to recognized deficiencies are performed in accordance with the Q AP. 5.0 SURVEY FINDINGS As discussed in Section 1.0, FSS data were generated for Subarea I to justify the release of this subarea from License SNM-928. The survey findings, including the statistical methodology employed to evaluate the data for Subarea I, are discussed in this section. 5.1 Data Evaluation As discussed in NUREG/CR-5849, the guideline values for soil activity concentrations, surface activity, and exposure rates are average values (above background) established for areas of survey units. In order to compare the analytical and survey data developed for the final status survey with guideline values; idata at each individual survey grid location were compared to the appropriate guideline v~ues discussed in Section 4.2. i FSSR SUBAREA I 23

Comparison with Guideline Values 5.2 The FSS data for Subarea I was compared to the guideline value criteria and are discussed separately in this section. This section e'{aluates the data collected from both the scan and the systematic surveys performed at thel grid intersects for open land area and building surfaces for Subarea I which is shown on Drawing No. 95MOST-RF3 (Appendix 1). 1 For Subarea I, daily average Nal detectbr backgrounds were determined for comparing either scan or systematic survey results jto the guideline values. The detectors average background values for both Nal and micro-R detectors are listed for the systematic surveys on the data tables and on the drawings. For discussion and comparison purposes the FSS data for Subarea I were divided into the survey units outlined in Section 3.3. Additionally, several of the survey units had distinct features that were surveyed as a sub-unit separate from the base survey unit. For example, the unaffected open land area was surveyed and the data evaluated separate from the walkways included within the unaffected area survey unit. The specific features are shown on Drawing 99MOST-RF4. The sub~units are discussed separately in the following sections. 5.2.1 Data Evaluation - Area Surrounding Warehouse (Ti02) Building #4

• 5.2.1.1 Warehouse Building Open Land Area The subsurface soils in this area were characterized, remediated, final surveyed and then backfilled and graded in 1993 prior to the installation of the TiO2 pilot plant. As discussed in Section 3.3.1, based upon verbal permission from NRC staff in 1993, the remediated areas were released for backfilling. Thus only the surface soils were surveyed per NUREG/CR-5849 as part of the FSS of this unit. Prior to collecting the soil samples for the FSS, a 100% scan was performed on this survey unit with a shielded NaI detector; no locations were found that exceeded twice background. Surface soil samples were collected at each 5m x 5m grid location and analyzed for total uranium.

A total of 230 FSS surface soil samples were collected for analysis with soil sample analytical results ranging from 1 to 26 pCi/g total uranium. The mean value for all surface soil samples was 10.5 pCi/g total uranium, with a standard deviation of 4.8 pCi/g. The 95% confidence level value was 11.1 pCi/g, which is below the guideline value for total uranium. The soil sample locations and analytical results for total uranium are shown on Drawing No. 99POSIWASS-0. This drawing, the statistical analyses, and data tables are included in Appendix 2. Also, the soil sample analytical results for this survey unit showed natural thorium ranging from 1 pCi/g to 2 pCi/g. The mean value was 1.1 pCi/g natural thorium, with a standard deviation of 0.3 pCi/g thorium. The statistical analyses and data tables for the natural thorium soil sample data also are included in Appendix 2. In summary all soil measurements were below the Option #1 guideline for uranium and

• thorium .

FSSR SUBAREA I 24

Systematic surveys were performed during the FSS at the 230 grid intersects with 3" x 0.5 shielded NaI detectors and the ~tR meter. The exposure rates at the surface and at one meter above the surface, as measured using a µR/h meter, ranged from 6 to 13 µR/h, with the mean being 9 µRib and from 6 to 1~ µR/h, with a mean of 9 µR/h, respectively. All measured exposure rates were below th~ guideline value of 19 µR/h (i.e., 10 µRib above the average background of 9 µR/h) .

• The exposure rate data tables are included in Appendix 2. The ground level shieldeq Nal detector survey results for the grid intersect sample locations ranged from 1,500 td 4,820 CPM. All survey results were less than twice background with background at i ,500 CPM. The survey results are presented in tables included in Appendix 2. 1 This survey unit also includes a section ' of open land area less than Sm in width that was not sampled initially for the FSS because no 5m x 5m grid locations fall \vithin the area.

This area is located between 90N and ll 8N as shown on Drawing No. 99POSIWASS-0. As a separate sampling event, Cimarron did collect and analyze 15 soil samples from this small area. The analytical results showed a total uranium average of 15 pCi/g. This data was not included in the Appendix 2 tables for the Warehouse Building Open Land Area Survey Unit. 5.2.1.2 Warehouse Building Yard Concrete Pads Numerous concrete pads were installed as part of the coal liquefaction and TiO2 installations to provide access and foundation support of process equipment located within the open land area of the former Warehouse Building. These pads were surveyed as unaffected structures as part of the FSS since they were installed after U-Plant shutdown. A scan survey was completed on l 0% of the concrete surfaces and systematic surveys were performed at thirty-two locations for gross alpha and beta-gamma surface activity. The beta-gan1ma scan survey results averaged 750 dpm/100 cm2 with a maximum of 3,500 dpm/100 cm 2 and the systematic surveys ranged from 715 dpm/100 cm2 to 1,991 dpm/100 cm2 with a mean of 1,252.3 dpm/100 cm 2. The systematic alpha survey results 2 ranged from 10 dpm/100 cm2 to 700 dpm/100 cm2 with a mean of 83.8 dpm/100 cm

• 19 Background for concrete was established for the March 1998 FSSR for Subarea F Concrete had an average gross beta-gamma surface activity ranging from 278 dpm/100 cm2 to 1,199 dpm/100 cm2 with a mean of 800 dpm/100 cm2 . The maximum gross beta-gamma activities ranged from 649 dpm/100 cm2 to 3,212 dpm/100 cm2 with a mean of 1,520 dpm/ 100 cm2
• The average gross beta-gamma surface activities for these concrete pads are considered representative of background for the Cimarron Site. Micro-R survey results collected from the thirty-two random locations averaged from 5 µR/h to 12 µR/h which are representative of natural background. The survey locations are shown on Drawing No. 99POSIWAS-1. The statistical analysis and data tables for this unit are included in Appendix 3.

5.2.1.3 Warehouse Building Yard Drain Lines As discussed in Section 3.3.1, the sanitary drain lines within this survey unit, that were an integral part of the U-Plant, have been. removed from service, excavated and surveyed (both the drain lines and the excavationJitself). One small section of the original sanitary FSSR SUBAREA I 25

drain line (no longer in use) is still located beneath Warehouse Building #4. All excavations and surveys performed during the drain line removals involved sampling and surveys to demonstrate that Option #1 levels were achieved. The one small section of sanitary drain line located beneath Warebouse Building #4 has been decontaminated and surveyed for free releases. The survey \Nas completed in March of 1993 and all of the survey results were below 2,000 dpm/100 cm2 gross alpha. The sanitary drain line to the new septic drain field is currently in use. 5.2.1.4 Warehouse Building Yard Fencing The chain link fence surrounding this :survey unit was surveyed as an affected area structure. The vertical and horizontal support poles were 100% scanned for both alpha and beta-gamma surface activity with the recorded activity ranging from O to 4,646 dpm/100 cm2 and the average surface activity recorded as 1,500 dpm/100 cm 2* Next, systematic measurements for surface activity including direct and smears were performed with measurements collected at one meter intervals along all fence supports, as noted on the

         'Typical Survey Pattern for Fencing" Figure included in Appendix 3. The general arrangement drawing for the fences surveyed, Drawing No. 99POSIWAS-2, is included in Appendix 3. A total of 510 locations were surveyed with the direct gross alpha measurements ranging from Oto 1,738 dpm/100 cm2, with a mean of 321.6 dpm/100 cm 2 and a standard deviation of 271.3 dpm/100 cm 2. The direct beta-gamma survey results ranged from Oto 4,646 dpm/100 cm2, with a mean of 1,159.4 dpm/100 cm2 and a standard deviation of 883.4 dpm/100 cm2 . All survey results were below the guideline value of

• 5.2.2 2

5,000 dpm/100 cm . The survey results for removable activity were all below the guideline value of 25 dpm/100 cm 2

• The survey data are included in tables located in Appendix 3.

Data Evaluation- Warehouse (TiO 2) Building #4 - Interior As discussed in Section 3.3.2, this Building has been released by the NRC for non-nuclear purposes and thus is being treated as an unaffected area. For the FSS, scans and random systematic surveys for gross alpha and gross beta-gamma were performed on the interior walls and floors. A 10% gross beta-gamma scan was performed on accessible areas of the floor and lower walls up to two meters in height. The survey results for the inside wall scan averaged less than 532 dpm/100 cm2 which is the MDA for the instrumentation used. The maximum surface activity recorded was 950 dpm/100 cm2

• For the interior walls, thirty random locations were systematic surveyed with the fixed alpha results varying from 0 to 90 dpm/100 cm2, with a mean of 10.0 dpm/100 cm2 and the beta-gamma results varying from 0 to 950 dpm/100 cm2 with a mean of 134.0 dpm/100 cm2 . The survey results for removable activity were all at or below 10 dpm/100 cm2 . Additionally, micro-R surveys were taken at the 30 random locations at one meter with results ranging from 5

         µR/h to 7 µR/h. The general arrangement drawing, Drawing No. 99POSIWAS-3, showing the location for the systematic surveys, is included in Appendix 4. The survey results are also included in tables located in Appendix 4.

• Initially the floor of the Warehouse Building was scanned as an unaffected area with average beta-gamma survey results ranging from 650 dpm/100 cm2 to 800 dpm/100 cm2
• FSSR SUBAREA I 26

2 The maximum beta-gamma surface activity ranged from 1,000 dpm/100 cm to 5,500

• dpm/100 cm 2
• With the detection during the scan survey of the elevated beta-gamma activity (i.e., 5,500 dpm/100 cm2 ) near the south entrance to the Warehouse, Cimarron elected to further investigate this floor section and classify it an affected area. The area was 100% scanned with a beta-gamma detector and 85 locations were surveyed for fixed alpha and beta-gamma and for removable activity. The grid spacing for this survey was Im x 1m, as shown on Drawing No. 99POSIW AS-4, included in Appendix 4. The fixed gross alpha survey results ranged from 0 to 380 dpm/100 cm 2 with a mean of 88.1 dpm/100 cm\ the gross beta-gamma survey results ranged from 120 dpm/100 cm 2 to 3,450 dpm/100 cm2 with a mean of 1,427.3 dpm/100 cm2 . For the scan location that showed a beta-gamma survey result of 5,500 dpm/100 cm2 , an additional investigation of the area floor was performed. Systematic surveys for beta-gamma surface activity were taken around this location and "hot spot" averaging was performed. The resulting average was 3,573 dpm/100 cm2
• All final survey results when "'hot spot" averaged were below 5,000 dpm/100 cm 2. The survey results for removable activity were all at or below 12 dpm/100 cm2
• These FSS results are listed in tables included in Appendix 4.

As part of the remaining unaffected area survey of the building interior, thirty floor locations were systematically surveyed for alpha, beta-gamma, and micro-R. The survey locations are shown on Drawing No. 99POSIWAS-5. The fixed gross alpha results varied from Oto 60 dpm/100 cm2, with a mean of 19.7 dpm/100 cm2 and the gross beta-famma results varied from 0 to 1~804 dpm/100 cm 2 with a mean of 703.8 dpm/100 cm . The survey results for removable activity were all below 5 dpm/100 cm 2. Micro-R surveys

• 5.2.3 were taken at each of the fixed locations with results ranging from 5 µr/h to 8 µr/h. These FSS results are listed in tables included in Appendix 4.

Data Evaluation - Warehouse (TiO 2) Building #4 - Exterior As discussed in Section 3.3.3, the exterior of Warehouse Building #4 was treated as an unaffected area with the exception of the original roof panels. The high bay section of the Warehouse, including a new roof section, was installed after cessation of plant operations as part of the coal-liquefraction testing program. This section of the roof was not surveyed. The other larger section of the roof was surveyed as an affected areas and 100% scanned. The preliminary scan survey on the roof panels showed several locations of residual contamination in excess of 5,000 dpm/100 cm2 . For the scan survey, the average activity was recorded at 2,000 dpm/100 cm 2 with a maximum surface activity of 8,000 dpm/100 cm2 . A total of eleven locations were identified with surface activity greater than 5,000 dpm/100 cm2

• Cimarron reclassified this roof section as an affected area. Additional surveys and follow-up decontamination was performed prior to the systematic surveys.

After being classified as an affected area, a 100% scan was completed on the lower roof and systematic gross alpha and gross beta-gamma direct surveys (with corresponding smears) were performed on a 1m x 1m grid. The general arrangement for the grid survey locations are shown on Drawing No. 99POSIWAS~6 included in Appendix 5. FSSR SUBAREA I 27

For the systematic survey of the roof panels, a total of 646 grid locations were surveyed for gross alpha and gross beta-gamma, both direct and smear readings were collected. The 2 direct alpha surveys ranged from 30 dpm/100 cm 2 to 2,460 dpm/100 cm with a mean of 2 715.3 dpm/100 cm 2 and a standard dev~ation of 421.7 dpm/100 cm . The beta-~amma surveys ranged from O to 5,900 dpm/100! cm2 with a mean of 2,529.9 dpm/100 cm and a standard deviation of 902.1 dpm/100 cnt:i.2. The measured removable activities were all below I 00 dpm/100 cm2 . The FSS result~ are listed in tables included in Appendix 5. Four systematic survey locations had b~ta-gamma survey results greater than the 5,000 dpm/100 cm 2 guideline value and were "hot spot" averaged. The grid numbers, the initial survey results, and the "hot spot" aver~ge are shown in Table 5 .1. All four locations 2 averaged below the guideline value of 5,000 dpm/100 cm . The statistical evaluations for these locations are included in Appendix S TABLE 5.1 Initial Survey "Hot Spot" Average 2 Grid No. (dpm/100 .cm 2) (dpm/100 cm ) 119 5,380 3,063 205 5,900 3,258 239 5,030 3,218 307 5,160 3,217 For the unaffected building side panels, a 10% beta-gamma scan was performed on the

• exterior walls up to two meters in height with all readings recorded as less than MDA.

Additionally, systematic surveys for the side wall panels were performed at thirty random locations on the exterior wall panels for gross alpha and beta-gamma. The survey locations are shown on Drawing No. 99POSIWAS-7 included in Appendix 5. The fixed gross alpha survey results varied from 0 to 190 dpm/100 cm2 with a mean of 64. 7 and the 2 fixed gross beta-gamma results varied fr.om O to 530 dpm/100 cm with a mean of 44. 7 2 dpm/100 cm . For the scan and systematic surveys all readings were below 1,250 dpm/100 cm2, which is 25% of the guideline value for an unaffected surface area. The micro-R survey results ranged from 4 µR/h to 9 µR/h. The survey results for removal activity were 2 all at or below 12 dpm/100 cm

• The micro-R survey results from the thirty random systematic locations were all below the gµideline value of 19 µR/h (i.e., 1OµR/h above the average background of 9 µR/h). The survey results are listed in tables included in Appendix 5.

5.2.4 Data Evaluation - Pu-Plant Building Yard 5.2.4.1 Pu-Plant Open Land Area As discussed in Section 3.3.4, confinnatory surveys were performed on this unit in support of license tennination for the Pu-Plant. The FONSI and Notice of Opportunity for Hearing included this statement:

• FSSR SUBAREA I 28

                                                                         **** * * * -*-** - - - - - - - - - - - - - - ~
                 '"(2) There is limited contamination of the surrounding soils. The average uranium content of the exterior soils is two to three times background levels but about two orders of magnitude below NRC soil guidelines for disposition of contaminated soils with no restrictions. The average gamma dose rate at 1 meter above the soil is indistinguishable from background.

Although confirmatory surveys were performed by the NRC contractors for this survey unit, Cimarron elected to perform system~tic surveys including surface soil sampling and surveys with portable instrumentation for verification of the previous results. These surveys were performed on a 5m x Sm grid. The 100% scan survey performed with the shielded NaI detector and completed prior to the FSS, identified eight isolated locations with elevated surface activity that were further investigated. The residual contamination was located on the surface along the southeastern boundary of this survey unit and required remediation. The locations remediated, pre-remediation analytical results and post remediation final analytical results are tabulated below. Table 5.2 Affected Area Pu-Plant-Yard Sample Location Pre-Remediation Post-Remediation Analytical Results Analytical Results (pCi/g Total-U) (pCi/g Total-U) --------i 5E-220N 49 9 1SE-200N 32 5 20E-210N 43 5 15E-199N 31 8 20E-209N 44 9 20E-209N 32 8 21E-210N 197 5 21E-2ION 66 5 With the remediation completed a total of 241 FSS surface soil samples were collected for analysis with soil sample analytical results ranging from 3 to 27 pCi/g total uranium. Toe mean value for all subsurface samples was 8.5 pCi/g total uranium, with a standard deviation of 3.1 pCi/g. The 95% confidence level value was 8.9 pCi/g, which is below the guideline value for total uranium. These survey results are presented on Drawing No. 99POSIPUSS-O and are listed in tables included in Appendix 6. Also, the soil sample analytical results for this survey unit showed natural thorium ranging from I pCi/g to 3 pCi/g. The mean value was 1.3 pCi/g natural thorium~ with a standard deviation of 0.5 pCi/g thorium. The statistical analyses for the natural thorium soil sample data also are included in Appendix 6. Systematic surveys were performed during the FSS at the 241 grid intersects with 3" x

• 0.5 unshielded Nal detectors and the µR meter. The exposure rates at the surface and at one meter above the surface were measured using a µR meter, both ranged from 5 µR/h to FSSR SUBAREA I 29

10 µR/h with the mean being 8 µR/h and from 4 µR/h to 9 µR/h with the mean being 7

         µR/h respectively. All measured exposure rates were below the guideline value of 19
         µR/h (i.e., IO µR/h above the average background of 9 µR/h). The exposure rate data tabulation is included in Appendix 6. rhe ground level unshielded Na! detector survey results for the grid intersect sample locations ranged from 4,418 to 10, 4 70 CPM. All survey results were less than twice average background with background recorded at 6,850 CPM. These survey results are included in Appendix 6 For the subsurface sampling, soil samples were collected at the locations and depths shown on Drawing Nos. 99POSIPUSS-l thru 99POSIPUSS-5. Samples were collected and composited at intervals of 0-6", 6'~-1 ' , 1'-2', 2'-3' and 3'-4'. A total of 303 FSS subsurface soil samples were collected i for analysis with soil sample analytical results ranging from I to 25 pCi/g total uranium. The mean value for all samples was 9.3 pCi/g total uranium, with a standard deviation of 3.5 pCi/g. The 95% confidence level value was 9.6 pCi/g, which is below the guideline value for total uranium. The sample analytical results are shown on the drawings and are listed in the tables included in Appendix 6. Also, the soil sample analytical results for this survey unit showed natural thorium ranging from 1 pCi/g to 2 pCi/g. The mean value was 1.5 pCi/g natural thorium, with a standard deviation of 0.5 pCi/g thorium. The statistical analyses for the natural thorium soil sample data also are included in Appendix 6.

5.2.4.2 Pu-Plant Fencing

• The chain link fence surrounding this survey unit was surveyed as an affected area structure. The fencing included with this survey is shown on Drawing No. 99POSIPUS-l, included in Appendix 7. This Drawing also was used to reference the survey locations included in the data tables. The vertical and horizontal support poles were 100% scanned for gross beta-gamma surface activity with the average surface activity recorded as 1,500 2

dpm/100 cm and the maximum recorded activity at 3,174 dpm/100 cm 2 . Additionally, systematic measurements for surface activity were taken at one meter intervals along all fence supports. A total of 962 locations were surveyed with the direct gross alpha measurements ranging from Oto 2,808 dpm/100 cm 2, with a mean of 317 dpm/100 cm 2 and a standard deviation of 256. 7 dpm/100 cm 2 . The direct gross beta-gamma survey results ranged from O to 4,209 dpm/100 cm2, with a mean of 800.4 dpm/100 cm 2 and a standard deviation of 645.3 dpm/100 cm2

• All survey results were below the guideline value of 5,000 dpm/100 cm2 . The survey results for removal activity were all below 25 dpm/100 cm 2
• The survey locations and data are included in tables located in Appendix 7.

5.2.4.3 Pu-Plant Light Poles The light poles located within the Pu-Plant yard were surveyed as affected structures with 100% scans and systematic surveys being performed for the FSS. The location of these light poles are shown on Drawing No. 99POSIPUS-2. The 100% scan was performed for gross beta-gamma with the average surface activity recorded as 1,500 dpm/100 cm2 and 2 the maximum recorded activity at 2,585 dpm/100 cm

• These results are below the 2

guideline value of 5,000 dpm/100 cm

• For the systematic survey, fixed and removable surveys were performed at 77 locations on the light poles. The survey locations on the FSSR SUBAREA I 30

light poles are as noted on the "Survey Pattern Location" Figure included in Appendix 7. 2 The fixed gross alpha survey results ranged from 0 to 3 72 dpm/100 cm with a mean of 122.2 dpm/100 cm2 and the gross beta-gamma results ranged from 0 to 2,587 dpm/100 cm2 with a m~an of 428.4 dpm/100 cm 2* Removable activity measurements were all at or below 12 dpm/100 cm2

• The survey locations result are presented in tables included in Appendix 7.

5.2.4.4 Affected Area Sidewalks The sidewalks designated as affected areas located within the Pu-Plant yard and also the Warehouse yard were surveyed as affected open land areas and as one survey unit. The sidewalks included with the survey are shown on Drawing No. 99POSIPUS-3, included in Appendix 7. The sidewalks were 100% scanned for beta-gamma with the average surface activity recorded as 2,000 dpm/100 cm2 and the maximum recorded activity at 2,900 dpnv'IOO cm 2. Next, systematic surveys were performed at 102 locations for fixed alpha and beta-gamma activity, removal activity and micro-R exposure. For the systematic 2 survey, the fixed gross alpha survey results ranged from O to 300 dpm/100 cm with a mean of 54.4 dpm/100 cm2, and the fixed gross beta-gamma survey results ranged from 2 624 dpm/100 cm to 1,610 dpm/100 cm 2 with a mean of 1,076.5 dpm/100 cm 2 . 2 Removable activity measurements were all at or below the 10 dpm/100 cm

• Micro-R readings collected at each of the fixed locations ranged from 8 µR/h to 10 µR/h. The survey locations and results are presented in tables included in Appendix 7.
• 5.2.5 Data Evaluation - Unaffected Areas 5.2.5.1 "Open Land Areas The unaffected open land areas are shown on Drawing No. 95MOST-RF-3 included in Appendix 1. For this survey unit, the open land areas received a survey scan with the unshielded Nal detector which included 10% of all land surfaces. The results of this survey showed results from 4,890 CPM to 9,316 CPM with no reading in excess of the guideline value of twice background with background recorded at 6,200 CPM.

Additionally, thirty random surface soil samples (0 to 6 inches depth) were collected for analysis for total uranium, and the thirty random soil sample locations received systematic surveys with Nal and micro-R meters. The soil samples locations are shown on Drawing No. 99POSIUNSS-0 included in Appendix 8. The soil analytical results show total uranium varying from 3 .4 to 11.1 pCi/g; all were below the guideline value for an unaffected area of 11.5 pCi/g total uranium. The sample mean for this data set is 7.2 pCi/g with a standard deviation 2.1 pCi/g total uranium. Appendix 8 includes the analytical results which are presented in tables and shown on Drawing No. 99POSUNSS-O. Systematic surveys were performed during the FSS at the 30 grid intersects with the 3" x

• 0.5 unshielded Nal detectors and the µR meter. The exposure rates at the surface and at one meter above the surface, as measured using a µR meter, ranged from 5 to 10 µRib FSSR SUBAREA I 31

with the mean being 8 µR/h and from 6 to IO µR/h , with a mean of 8 µR/h respectively.

• All measured exposure rates were below the guideline value of 19 µR/h (i.e., IO µR/h above the average background of 9 µR/h). The exposure rate data tabulation is included in Appendix 8. The ground level unshielded Nal detector survey results for the grid intersect sample locations ranged from 5,676 to :9,696 CPM. All survey results were less than twice background with background redorded at 7,578 CPM. The survey results are included in Appendix 8.

As discussed in Section 3.3 .6, numerous unaffected area locations were cored and soil sampled in 1990 for the characterization survey. The data was reported in the Characterization Report. Several of these previously sampled locations were again sampled for this FSS for comparison to' the on-site counter analytical results. The data comparisons are shown below in Table 5.3. Table 5.3 Grid Location Depth Original 1999 Samp]e Results Sample Results (pCi/g Total-U) (pCi/g Total-U) 50N-20E 0-6" 15 8.1 6"-1' 9 7.0 l '-2' 12 4.9 2' -.),.,,, 10 6.7 3'-4' 12 5.9 50N-30E 0-6" 16 10.4

• 5.2 6"-1' 15 l '-2' 9 6.5 2'-3' 14 4.9 3'-4' 10 5.4 70N-OE 0-6" 16 4.9 6"-1' 15 8.4 l '-2' 11 5.7 2' -.). . , 11 5.4 3'-4' 11 2.2 120N-0E 0-6" 16 4.8 6"-1' 11 7.2 I '-2' 11 2.0 2' -.),.,, 13 2.6 3'-4' 10 2.6 120N-10E 0-6" 17 4.8 6"-1' JO 1.7 1'-2' 13 5.5 2'-3' 15 4.0 3'-4' 12 4.5 180N-30E 0-6" 20 21.3 6"-1' 13 16.4 I '-2' 13 11.1 2'-3' 15 10.6 3'-4' 10 7.8 AVERAGE 12.8 6.6
• FSSR SUBAREA I 32

These results indicate that the soil counter, as anticipated, was biased high in 1990 when the original characterization survey was completed. In 1990, the on-site counter was calibrated to reflect the high concentrations in soil expected during the remediation phase of site decommissioning. As noted, the average high bias at the low uranium concentrations in soil was approximately 100%. The location at l 80N-30E, upon resamplet still showed residual activity in soil above 25% of the guideline value. At this level, unaffected areas require further investigation. This location was included within a small "grassy" area just west of the Warehouse yard area as shown on Drawing No. 99POSIUNSS-1 in.eluded in Appendix 8. Because of the slightly elevated activity, Cimarron decided to perform extensive sampling of the small "grassy" area located between the rock drive and the asphalt parking lot and to classify it as an affected area. A total of 30 soil samples were collected from the surface and to a depth of 4 feet. The analytical results are shown on Drawing No.99POSIUNSS-1 and show total uranium varying from 3 to 29 pCi/g with a mean of 12.1 pCi/g. Since all results were below the affected area guideline of 34 pCi/g (i.e., 30 pCi/g + 4 pCi/g background) total uraruum, no further sampling was performed. These survey results are included in Appendix 8. This survey unit also included the paved parking lot, concrete walks, several light poles and fencing that were surveyed as unaffected. These survey results are discussed in the next four sections.

• 5.2.5.2 Unaffected Area Fencing This unaffected area survey unit includes various fencing structures which were surveyed as part of this FSS. The fencing included with this survey are shown on Drawing No.

99POSIUNS-1, included in Appendix 9. The vertical and horizontal support poles were 10% scanned for gross beta-gamma surface activity. Additionally, systematic measurements, including direct and smears were collected at 322 locations on the support 2 poles. The direct gross alpha measurements ranged from O to 473 dpm/100 cm with a 2 mean of 113.0 dpm/100 cm and the gross beta-gamma survey results ranged from O to 1,541 dpm/100 cm2 with a mean of 649.0 dpm/100 cm2* All final survey results were 2 below the guideline value of 1,250 dpm/100 with the exce~tion of two locations with 2 survey results of 1,311 dpm/100 cm and 1,541 dpm/100 cm . These two locations also were identified during the scan survey and further evaluations showed them to be isolated locations. The survey results for removal activity were all below 30 dpm/100 cm 2 . The survey locations and data are included in tables located in Appendix 9. 5.2.5.3 Unaffected Area Light Poles The two parking lot light poles were surveyed as unaffected structures, a third pole had previously been removed. The locations of these light poles are shown on Drawing No. 99POSIUNS-2, included in Appendix 9. The light poles were scanned for gross beta-gamma and 26 random locations were systematically surveyed for surface activity. The

• systematic surveys consisted of fixed readings for gross alpha and gross beta-gamma and smears for removable surface activity. The general locations for the surveys are shown on FSSR SUBAREA I 33

the " Survey Pattern Location" Figure included in Appendix 9. The fixed alpha survey 2 results varied from 10 dpm/100 cm2 to 820pm/100 cm with a mean of 232.8 dpm/100 2 2 cm . The fixed beta-gamma survey results varied from Oto 1,242 dpm/100 cm with a mean of 603 .2 dpm/100 cm2 . The survey results for removable activity were all below 20 dpm/100 cm 2. All survey results were below the guideline value for an unaffected structure. The survey data are included in tables located in Appendix 9. 5.2.5.4 Unaffected Area Paved Parking Lot The parking area is located outside of the controlled area and was used by employees during site operations and is still in use. The parking lot was scanned as an unaffected area with an unshielded NaI detector; the: survey results ranging from 4,518 CPM to 6,032 CPM, with all readings less than twice background. At the completion of the scan survey, 35 random systematic surveys were performed on the surface areas. The locations for the random surveys are shown on Drawing No. 99POSIUNS-3 included in Appendix 9. The systematic surveys consisted of fixed readings for gross alpha and gross beta-gamma and smear samples for removable surface activity. The fixed alpha survey results varied from 2 0 to 72 dpm/100 cm with a mean of 21.9 dpm/100 cm 2 and fixed beta-gamma survey 2 2 results varied from 80 dpm/100 cm to 680 dpm/100 cm with a mean of 428.3 dpm/100 2 cm

• The survey results for removable activity were all below 10 dpm/100 cm2*

Additionally, NaI and micro-R readings were collected for each of the systematic survey locations. The shielded Nal survey results varied from 1,320 CPM to 2,480 CPM, with a mean of 1,989 CPM. Background was recorded at 1,400 CPM. The micro-R survey

• results ranged from 6 µR/h to 9 µR/h at the surface and from 6 µR/h to 10 µR/h at one meter. All survey results were below the guideline value. The statistical evaluation, data tables and drawing showing the location of the paved areas are included in Appendix 9.

5.2.5.5 Unaffected Area Concrete Walkways These walkways are located at various locations throughout the unaffected area and were scanned and systematically surveyed as unaffected structures. The walkways included with this survey are shown on Drawing No. 99POSIUNS-4, included in Appendix 9. The sidewalks were scanned for beta-gamma surface activity with the average recorded activity ranging from 750 dpm/100 cm2 to 1,100 dpm/100 cm 2. Next, thirty locations were randomly selected for performing srstematic surveys. The fixed gross alpha survey results varied from Oto 140 dpm/100 cm with a mean of 72.7 dpm/100 cm2 and the fixed beta-gamma survey results varied from 730 dpm/100 cm2 to 1,180 dmp/100 cm2 with a mean of 925.7 dpm/100 cm 2 . The survey results for removable activity were all at or below 10 dpm/100 cm2

• The micro-R survey results ranged from 8 µR/h to 11 µR/h at one meter. All survey results were below the guideline values for an unaffected survey. The statistical evaluation, data tables and drawing showing the location of the walkways are included in Appendix 9.

5.2.6 Data Evaluation - Emergency Building Interior

• This building was used to house the on-site soil counter and to store records and soil samples at varying periods since the suspension of site operations. This survey unit was FSSR SUBAREA I 34

surveyed as an affected area. The floo rs and walls (up to 2 meters in height) were 100% scanned for gross alpha and gross beta-gamma. The entire surface areas where radioactive materials were stored and/or handled, including coW1ter tops, sinks, drains, and shelving were scanned. The coverage for ceilings was dependent upon the number of locations of elevated activity (exceeding the guideline values) identified within the lower scanned areas. Since no areas of elevated activity were found, the upper walls and ceilings were 10% scanned and thirty randomly selected locations received systematic surveys. In general, systematic measurements wer¢ performed on a lm x lm grid spacing on floors and lower wall with measurements recorded for both gross alpha and gross beta-gamma. Smears for removable surface activitjy were obtained at locations where direct measurements were taken. The FSS locations are shown on Drawing Nos. 99POSIEMS-1 thru 99POSIEMS-14 which are included in Appendix 10. For the floor, a total of 166 grid locations were surveyed for gross alpha and gross beta-gamma, both direct and smear readings were collected. The direct alpha surveys ranged 2 2 from 0 to 36 dpm/100 cm with a mean of 8.0 dpm/100 cm and a standard deviation of 2 11.0 dpm/100 cm

• The beta-gamma survey results ranged from 0 to 891 dpm/100 cm2, 2

with a mean of 204.4 dpm/100 cm and a standard deviation of 176. 7 dprn/100 cm 2 . The measurements of removable activity were all less than IO dpm/100 cm 2 . For the lower walls, a total of 399 grid locations were surveyed for gross alpha and gross beta-gamma, both direct and smear reading was collected. The direct alpha surveys ranged 2 2 from Oto 72 dpm/100 cm with a mean of 9.3 dpm/100 cm and a standard deviation of 2 9.9 dpm/100 cm

• The beta-gamma surveys ranged from Oto 378 dprn/100 cnl with a 2

mean of 9.4 dpm/100 cm and a standard deviation of 27.9 dpm/100 cm 2

• The measurements for removable activity were all less than 25 dpm/100 cm2 .

For the upper walls and ceilings a total of 30 random locations were surveyed. The direct alpha surveys ranged from 0 to 36 dpm/100 cm2 with a mean of 10.9 dpm/100 cm 2 and a standard deviation of IO.I dpm/100 cm2

• The beta-gamma surveys ranged from Oto 288 dpm/100 cm2 with a mean of 24.3 dpm/100 cm 2 and a standard deviation of 56.9 dpm/100 2

cm

• The measurements for removable activity were all less than 12 dpm/100 cm 2.

The emergency building fixtures, which included counter tops, sinks, ventilation ductwork, and storage cabinets were surveyed as affected area structures. Both scan sun1eys and systematic surveys were collected. The I 00% scan survey identified no locations exceeding the guideline value of 5,000 dpm/100 cm2

• For the systematic surveys, 116 locations were surveyed with direct alpha survey results ranging form 0 to 80 2

dpm/100 cm with a mean of 6.5 dpm/100 cm2 and the direct beta-gamma survey results ranging from 0 to 2,070 dpm/100 cm2 with a mean of 81.0 dpm/100 cm 2 . Removable activity survey results were all less than 25 dpm/100 cm2. Tabulation of all the survey results and the statistical evaluations are included in Appendix I 0 .

• FSSR SUBAREA I 35

5.2.7 Data Evaluation - Emergency Building Exterior The exterior of this building was treated as an unaffected area. The exteriors of building surfaces typically have a low potential .for residual contamination; however, there were several building exterior surfaces which iwere scan surveyed. The building roof, drainage points, window ledges, ventilation points, and entry doors were included in the 10% scan of the exterior surface. Systematic surface measurements would be performed at any elevated locations discovered during the scan surveying or at a minimum of thirty locations randomly selected on the roof, sides, and walls. Since no elevated locations were found during the scan, thirty random locations were selected for systematic surveys. The FSS locations for this unit are 'shown on Drawing Nos. 99POSIEMS-15 and 99POSIEMS-16, which are included in Appendix 11. For the exterior walls and roof, a total of 30 random locations were surveyed for gross alpha and gross beta-gamma; both direct and smear readings were collected. The direct 2 alpha survey results ranged from 18 to 162 dpm/100 cm with a mean of 85.9 dpm/100 cm2 and a standard deviation of 46.6 dpm/100 cm2* The beta-gamma survey results ranged 2 from O to 459 dpm/100 cm with a mean of IO 1.8 and a standard deviation of 145. 7 2 dpm/100 cm

• The measurements of removable activity were all less than 25 dpm/100 2

cm

• The FSS data for the random locations are tabulated in Appendix 11 .

For both the exterior and interior of the Emergency Building µR surveys were taken at one-meter form the floors and walls. The survey locations and survey results are shown on Drawing No. 99POSIEMS-17, included in Appendix 11. The survey results ranged from 4 µR to 9 µR, with all results being below the guideline value. The Emergency Building also had several small underground tanks that were associated with emergency decontamination and emergency site operations. These tanks were:

• Fresh Water Tank - supplied wash water for personnel decontamination purposes;
• Discharge Collection Holding Tank - used to collect discharge from personnel decontamination;
• Septic Tank - used by personnel manning the Emergency Building during periods when the building was occupied.

The Fresh Water Tank and Discharge Collection Holding Tank have been excavated and removed. The surveys performed on the interior of the tanks and the sludge sample collected from within the tank showed survey results representative of background. Also, five soil samples each were collected from within the excavated pits and showed total uranium ranging from 5.7 pCi/g to 8.7 pCi/g for the Fresh Water Tank and from 6.0 pCi/g to 13.1 pCi/g for the Holding Tank. These excavations have been backfilled. The Septic Tank is still in operation. However, a sludge sample was collected from the tank and analyzed for total uranium. The analytical results show total uranium at 10. 7 pCi/g. FSSR SUBAREA I 36

5.2.8 Data Evaluation - Affected Drainage Area

• This survey unit received drainage from the south U-yard area during plant operations.

For this reason it has been surveyed as ajl1 affected area and has been divided into three data sets for FSS data presentation. The t~ee data sets are listed as:

• Surface Area Survey Data;
• Drainage Way Survey Data; ruid
• Subsurface Survey Data.
• For this survey unit, a 100% scan was performed on the open land area with an unshielded NaI detector for locating any area exceeding twice background. No reading exceeded the twice background guideline.

The Surface Area Survey included a total of 456 FSS soil samples collected for analysis with soil sample analytical results ranging from 3 pCi/g to 34 pCi/g total uranium (including background of 4 pCi/g total uranium). The mean value for all surface samples was 10.4 pCi/g total uranium, with a standard deviation of 4.2 pCi/g. The 95% confidence level value was 10.8 pCi/g, which is below the guideline value for total uranium. The soil sample analytical results are shown on Drawing No. 99POSISS-0 and in tables included in Appendix 12. Also, the soil sample analytical results for this subarea showed natural thorium ranging from 1 pCi/g to 2 pCi/g. The mean value was 1.4 pCi/g natural thorium, with a standard deviation of 0.5 pCi/g thorium . Systematic surveys were performed during the FSS at the 456 grid intersects with 3" x 0.5 shielded Nal detectors and the µR meter. The exposure rates at the surface and at one meter above the surface, as measured using a µR/h meter, both ranged from 5 µR/h to 10

         µR/h, with the mean being 8 µR/h. All measured exposure rates were below the guideline value of 19 µR/h (i.e., 10 µR/h above the average background of 9 µR/h). The exposure rate data tabulation is included in Appendix 12. The ground level unshielded Nal detector survey results for the grid intersect sample locations ranged from 4,980 to 10,624 CPM.

All survey results were less than twice ~ackground which was recorded at 7,160 CPM. The survey results are included in Appendix 12. For the Drainage Way Survey, a total of 30 FSS soil samples were collected for analysis with soil sample analytical results ranging from 5 pCi/g to 14 pCi/g total uranium. The mean value for all surface samples was 9.1 pCi/g total uranium, with a standard deviation of 2.1 pCi/g. The 95% confidence level value was 9.7 pCi/g, which is below the guideline value for total uranium. The soil sample locations and analytical results for total uranium are shown on Drawing No. 99POSISS-l, which is included in Appendix 12. Also, the soil sample analytical results for this subarea showed natural thorium ranging from 1 pCi/g to 2 pCi/g. The mean value was 1.2 pCi/g natural thorium. The soil sample analytical results are listed in tables included in Appendix 12 .

• FSSR SUBAREA I 37

For the Subsurface Sampling Survey, soil samples were collected at Sm x 5m grid

• intersects where possible based upon field conditions. Samples were collected and composited at intervals of 0-6", 6" -1 ', 1'-2', 2' -3 ', and 3 '-4'.

A total of 90 FSS subsurface soil samdles were collected for analysis with soil sample analytical results ranging from 2 to 29 pCi/g total uranium. The mean value for all subsurface samples was 9.0 pCi/g total ~ranium, with a standard deviation of 4.0 pCi/g. The 95% confidence level value was 9.p pCi/g, which is below the guideline value for total uranium. The sample analytical re~ults are listed in tables included in Appendix 12. The soil sample locations are shown onl Drawing No. 99POSISS-2 which is included in Appendix 12. Also, the soil sample aijialytical results for this subarea showed natural thorium ranging from 1 pCi/g to 2 pCi/gi The mean value was 1.4 pCi/g natural thorium, with a standard deviation of 0.5 pCi/g th<l>rium. The statistical analyses and data tables for both total uranium and natural thorium ate included in Appendix 12. 5.3 QA/QC Procedures Cimarron Corporation's Quality Assurance Plans and Procedures are an integral part of the overall site decommissioning program and include off-site independent isotopic analysis of split samples. For the soil activity ranges that apply to this final status survey and for soil samples collected during the time frame that the survey data was being generated, a total of fourteen soil samples were split and sent off-site for analysis. The soil samples were first analyzed using the on-site counter prior to being packaged and sent

• off site for analysis at an independent laboratory. The independent laboratory for this project was Core Laboratories and they participate in a national inter-comparison quality assurance program. The results for both off-site and on-site analysis are listed in Table 5.4. These sample results show good agreement.

Table 5.4 Area I - QAIQC Comparisons Cimarron Core Lab Sample ID No. (pCi/g Total-U) (pCi/g Total-U) IU-02 6.Q +/- 3.6 2.1 +/- 1.6 IU-27 4.Z+/- 3.7 1.4 +/- 1.4 IA-905 184~0 +/- 3.5 194.9 +/- 22.5 IA-884 28.2 +/- 2.9 27.0+/- 7.1 IA-899 42.1 +/- 2.6 32.5 +/- 7.9 IA-900 26.4 +/- 2.4 26.6 +/- 7.3 IA-906 54.2 +/- 2.9 51.4+/- 10.8 IA-1217 78.9 +/- 3.3 76.5 +/- 15.3 IU-69 5.6+/-2.1 7.8+/-2.7 IU-75 4.1 +/- 1.6 4.1 +/- 1.7 IU-88 2.6 +/- 2.1 1.3 +/- 0.9 IU-93 3.4+/-2.l 1.9 +/- 1.3 IU-94 22.5 +/- 2.2 27.5 +/- 6.3 IU-95 17.4 +/- 2.4 20.0 +/- 4.7 FSSR SVBAREA I 38

6.0

SUMMARY

A FSS was performed in accordance with the NRC approved Phase II FSSP and the SWP and WP approved by Cimarron Management for Subarea I. This report presents a comparison of the FSS results to the guideline values for affected ahd unaffected areas at the Cimarron site. The comparisons presented herein demonstrates thai all guideline values for unrestricted release have been met and thus Subarea I can now be releasid from License SNM-928. Therefore, this report is being submitted to the NRC in conjunction jwith a request to release Subarea I from License SNM*928 for unrestricted use .

• FSSR SUBAREA I 39
• 7.0 APPENDICES
• Appendix I Drawings 95MOST-RF3 and 99MOST-RF4
• Appendix 2 Data Tabulation Sheets, Statistical Analyses and Drawings for Open Land Area Surroulnding Warehouse (Ti02) Building #4
• Appendix 3 Data Tabulation I Sheets, Statistical Analyses and Drawings for Warehouse (Ti0 2) Building #4 Area Concrete Pads and Fencing
• Appendix 4 Data Tabulation
• Sheets, Statistical Analyses and Drawings for Warehouse (Ti0 2) Building #4 Interior
• Appendix 5 Data Tabulation Sheets, Statistical Analyses and Drawings for Warehouse (Ti02) Building #4 Exterior
• Appendix 6 Data Tabulation Sheets, Statistical Analyses and Drawings for Open Land Area Surrounding Pu-Plant Building
• Appendix 7 Data Tabulation Sheets, Statistical Analyses and Drawings for Pu-Appendix 8 Appendix 9 Plant Area Fencing, Light Poles, and Sidewalks Data Tabulation Sheets, Statistical Analyses and Drawings for Unaffected Open Land Areas Data Tabulation Sheets, Statistical Analyses and Drawings for Unaffected Area Fencing, Light Poles, Paved Parking Lot, and Concrete Walkways
• Appendix 10 Data Tabulation . Sheets, Statistical Analyses and Drawings for Emergency Building Interior
• Appendix 11 Data Tabulation Sheets, Statistical Analyses and Drawings for Emergency Building Exterior
• Appendix 12 Data Tabulation Sheets, Statistical Analyses and Drawings for Open Land Area South ofU-Plant Yard
• FSSR SUBAREA I 40

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J{IJ/N 1/J,lrl SCHt I ll llfTttS CIJJARRON CORPORATION 5(t/n tt/ffltl CIMARRON FACILITY FINAL STATUS SURVEY PLAN PHASES I, II AND 111 ewe NO. REI/. CHCI).  :!OU:

                                                                                                                                                   ,,,    IR                                                    95t.tOST-RF3        15

300 80 70- 50 40 30 20 SUB-AREA H 10 0 10 20 30 60 70 80 90 100 11 0 120 130 140 160 300 SUB-AREA E 290 SUB - AREA H 290 jis9N, ~*w>. (789N:1W)~ , (289N, 21E) BURIAL 280 AREA #2 /

                                                                                                                                                                                                                                                                  /      -- -... '---

280 (NORTH '- FIELD) / '-, 270 ......._ I 270 I I I WEST 260 260 I SAN ITARY

                                                                                                                                                                                '-- - -- --- - - - ..J                                       I                       LAGOON 250 I                     (BAC Kfl LLED I                                                                   250 PUJTONIUM                                                                                                    SUB- AREAL                                                       I                             1993)
                      -,l44N, * $W)                                                                                                                                                                                                    \

240 8Ul60tNG 240

                                                                                                     ' (,ZJsH.          z1~t

• 230 230 220 220 210 210 100 ~--.;.....,,,....,.:,...-..;;,,,_;,, (202N, i1*E)G 200

                    *"""1s~N,  s*w)                                                                                                                                      GRAVEL .DRIVE*

190 -. ...t: AT~ LOCATION IN 190 UNAFf't CT£1r ARa - -. __. 180 PAVED I. _-.--.. -> Ai:.~ 180

• f . A~EA I: - --~,-..r-----:_-::i... '. OVERH(t\D PIPE RACKS 170 w I1 * & CATWALK 170

                                                                                                                                                                                     - - ..J 160 lsua~AREA *1                                                                                                                                                                                                                                                          160 I

I . PAVED I ~(15~. 17Vf) CONCRETE PADS 150 AREA 150

• GRASS 140

                                            ' ' I~f<f~~                                                                  t                                                                                                                   SUB-AREA K                                                      140
                                              .                *..                         l     '.-HP TRAIUR 130
                                                           '\                                                                                                                                                                                                                                                130 120
                                                                           ' I

c.R. TRAl~ER OFFICE 120

                           /         FRESH WATtR                                                                                                                                                                                                                                                             110 110                                                                                       I                                                                                         TRAILER 00 o' _.       TANK 100 I

GRASS URANIUM I BUILDING #1 90 90 80 70 HOLOtN.<f . I . I

                                                                                               ;l* _GRASS
                                                                                                         ~ S~DeWAL!(

(82N. 16E). I 80 70 TANK

• so-* - _,_ * ~ PAVto'.'- "'"" --.---/ 60 AREA1 *

                              - - -....                     f               ....,.               '

50 SUB- AREA K I 50 40 I. i 40 30 J..,...,.,..J..,........,.....,.....,....,.....-..,..,...,,.......,..._.__.,..__...-....,....,.....,,.........J.- + - ---.;,t..- - - -..iJ',.,,-,- - - , . , - --.i",;--r-,""--..;i.;-----:---,ii.------,.......,.--- -f-30 20 20 10 10 0 -*--r ~- 0 t 10 10 SUB-AIREA I 1

                                                                                                                                                                                                                                            ~ - - - - - - - - - - - --20 20-. \

30'1 f 30

                                                                                                                                                                                                                         ;                                    SUB-AREA A 40                                                                                                                                                                                                                                                                                                         4'0 50
                                                                                                                                                                                                                      ~ CIMARRON CORPORATION 60 I

CIMARRON FACILITY 25 0 l2s PHASE II - SUB-AREA I Q

                                                                                                                                                                  ~I 70 FEATURES MAP S C A L E I N MET                                                     E~S                      4~

80 REV. I DESCRIPTION ORWN. BY JE I DATE 5 99 SCALE: AS SHOWN t-:::--r:::-::=-::::--:::-=:-:::::::------ - - - -- + - - - + - - - + - - - + - ---IJOB NO. DRAWING NO. REV 90-l,. o oAAwiNG ,ssum. JE WR Jl 6/21;99 99MOST- RF 4 o* 80 70 60 50 40 30 20 ... SUBAREAI\FEATURES\99MOST-RF4

05/11/99 CIMARRON FACILITY SOB AREA "I" PHASE II AFFECTED TlO2 AREA SURFACE

• INSTRUMENTS:

LUDLUM U:LO, 11 1 LUDLUM MICRO R1 METER - SHIELDED 3 X 1/2" Nal DETECTOR

 !CIMMARON ~UIL MIN 19 SIN 138420 48395 RESULTS IN BAc.;KGROUND
                                                                 µr/hr CPM 9

2500 ITotal U 4 MDA NIA 2 10 COUNTER 4" X 4 X 16" Nal DETECTOR 1 i pCi/G Th (Nat) 1 1 BAl,;l\uROUND NU f SUBTRACTED REVIEWED BY: !1t),cc~-- ~ ~ DATE: > r c;,

3" M'lc.;H.U MICKU LN GRID LOCATION D~TECT R' R' O" - 6'

     #                                   C.P.M . SURF      1 METER        Total-U      Th (Nat) 1       30        E -   190    N   .: 330        10           g            13              1 2       30        E -   195    N    : 930        11          11            17              1 3       30        E -   200    N    :910         12          10            15              1 4       30        E -   205    N    ~940          8           8            11              1 5       30        E -   210   N     i820         11          11            13              1 6       35        E -   190    N    :160          9           9            18              1 7       35        E -   195   N     3730         10          10            12              1 8       35        E -   200    N CO~CRETE CONCRETE CONCRETE           CONCRETE       CONCRETE 9       35              205   N     ~040         12          12            13             1 E -

10 35 E - 210 N 4\710 12 12 6 1 11 40 E - 120 N 3460 7 7 7 1 12 40 E - 125 N 3540 7 6 1 2 13 40 E - 130 N 3710 7 7 6 1 14 40 E - 135 N 4170 7 7 5 2 15 40 E - 140 N 3480 7 7 2 1 16 40 E - 145 N 3020 9 9 6 1 17 40 E - 150 N 2640 9 9 5 1 18 40 E - 155 N 3030 8 9 13 1 19 40 E - 160 N 2850 8 9 4 1 20 40 E - 165 N 3520 10 10 8 1 21 40 E - 170 N 3700 10 11 11 1 22 40 E - 175 N 4510 11 11 19 1 23 40 E - 180 N 3240 9 9 21 2 24 40 E - 185 N 2!970 9 9 13 1 25 40 E - 190 N 2430 9 8 15 1 26 40 E - 195 N 2820 9 9 10 1 27 40 200 3070 10 8 19 1 E - N 28 40 E - 205 N 3560 10 10 15 1 29 40 E - 210 N 3020 10 10 16 1 30 45 E - 120 N 4080 7 7 8 1 A:\DATASURF.WB2 1

05/11/99 CIMARRON FACILITY SUB AREA "I" PHASE II AFFECTED Tl02 AREA SURFACE

• S/N RESULTS IN BAC~GROUND MDA INSTRUMENTS:

LUDLUM MICRO 'R' METER - MIN 19 138420 µr/hr 9 2 LUDLUM 2220, SHIELDED 3" X 1/2" Nal DETECTOR 48395 CPM 2500 N/A r_** 11 n_.1 l\~UN ~UIL Total U 4 10 COUNTER 4" X 4" X 16" Nal DETECTOR pCi/G Th (Nat) 1 1 B.A. -~.'..::~~aJ"ID NOT SUt:HRA(.; I t:D REVIEWED BY: 1,J, d. <:.-r-=. . ~ DATE: S---/2..-97 3" MIUHO MICRO LN GRID LOCATION DI :TECT R' R' O" -6'

         #                                        C.P.M.        SURF           1 METER      Total-U       Th (Nat) 31            45     E -    125        N   :,610            7               7           5             1 32             45     E -    130        N   :~960            6               7           3             2 33             45     E  -   135        N   :~840            7               7           7             1 34             45     E -    140        N   ~ 010            7               6           4             1 35             45     E -    145        N   :~160            9               9           6             1 36             45     E -    150        N   :W30             9               9           9             1 37             45     E  -   155        N   ~~890            9               8           5             1 38             45     E  -   160        N   ~~230            9               8          10             1 39             45     E -    165        N   :~270            9               9          17             1

• 40 41 42 43 44 45 45 45 45 45 E -

E - E - E - E - 170 175 180 185 190 N N N N N

                                                  ~ 400

420 4520 3110 2260 10 10 10 10 9

10 9 9 8 9 13 7 9 14 15 1 1 1 1 1 45 45 E - 195 N 3550 9 10 11 1 46 45 E - 200 N 3170 i 10 10 7 1 47 45 E - 205 N 4060 12 10 9 1 48 45 E - 210 N ~720 11 11 9 1 49 50 E - 120 N 4170 8 7 9 1 50 50 E - 125 N 3840 6 6 4 2 51 50 E - 130 N 3640 7 7 4 2 52 50 E - 135 N 3700 7 7 10 2 53 50 E - 140 N 4040 6 6 4 1 54 50 E - 145 N 3360 10 9 8 1 55 50 E - 150 N 2650 10 9 8 1 56 50 E - 155 N 3050 10 9 9 1 57 50 E - 160 N CO~CRETE CONCRETE CONCRETE CONCRETE CONCRETE

• 58 59 60 A:\DATASURF.WB2 50 50 50 E -

E - E - 165 170 175 N N N CO~CRETE CONCRETE CONCRETE

                                                  ~970

,140

2 10 9

9 9 CONCRETE 9 11 CONCRETE 1 2

05/11/99 I CIMARRON FACILITY SUB AREA nin PHASE I I AFFECTED TI02 AREA SURFACE

• LUULUM 2220, INSTRUMENTS:

LUDLUM MICRO 'R' METER - SHIELDED 3" X 1/2" Nal DETECTOR Cl",~11..~/\~UN ~UIL M/~ 19 SIN 138420 48395 RESULTS IN BACKGROUND

                                                                            µr/hr CPM 9

2500 Total U 4 MDA 2 N/A 10 i COUNTER 4" X 4" X 16" Nal DETECTOR pCi/G Th (Nat) 1 1 BACKuROUNU NU J SUts fRAc; J t:.U REVIEWED BY: 'LJ~ CL /4) ,,J>-" ~ ~ DATE: .J--; ).._- 7 r 3' MICl-(CO Ml<.;KO LN GRID LOCATION m TECT R' R' O" - 6'

      #                                    C.P.M.         SURF            1 METER      Total-U         Th (Nat) 61          50     E -    180    N    ~

1 690 8 9 11 1 62 50 E - 185 N :1000 10 10 15 1 63 50 E - 190 N  ;?940 10 10 3 1 64 50 E - 195 N  : 720 11 11 10 1 65 50 E - 200 N ~ 010 10 10 2 2 66 50 E - 205 N ~ 900 12 12 12 1 67 50 E - 210 N ~720 12 10 10 1 68 55 E - 120 N L2QQ 6 7 6 1 69 55 E - 125 N :aso 7 6 6 1

• 70 71 72 73 74 55 55 55 55 55 E

E E E - E - 130 135 140 145 150 N N N N N

530 4040 3840 7

7 8 BLIPG.# 4 BLDG.#4 BLDG.# 4 supG.#4 BLDG.#4 BLDG.# 4 6 7 7 7 9 3 BLDG.#4 BLDG.#4 2 1 1 BLDG.#4 BLDG.#4 75 55 E - 155 N BL~G.# 4 BLDG.#4 BLDG.# 4 BLDG.#4 BLDG.#4 76 55 E - 160 N COfiCRETE CONCRETE CONCRETE CONCRETE CONCRETE 77 55 E - 165 N 3910 8 8 19 1 78 55 E - 170 N ~350 9 9 21 1 79 55 E - 175 N 2660 8 8 12 1 80 55 E - 180 N 3420 9 9 9 1 81 55 E - 185 N 3240 8 8 7 1 82 55 E - 190 N 3070 8 8 13 1 83 55 E - 195 N 3100 10 9 4 1 84 55 E - 200 N 3470 9 9 6 1 85 55 E - 205 N 4090 10 10 11 1 86 55 E - 210 N ~360 10 10 8 1 87 60 E - 120 N :710 7 7 9 1 88 60 E - 125 N  : 890 7 6 8 1 89 60 E - 130 N 3900 i 8 6 5 1 90 60 E - 135 N 760 8 8 7 1 I A:\DATASURF.WB2

I 05/11/99 CIMARRON FACILITY i SUB AREA "I" PHASE II AFFECTED Tl02 AREA SURFACE SIN RESULTS IN BACKuRUUND MDA INSTRUMENTS: LUDLUM MICRO 'R' METER - MIN 19 138420 µr/hr 9 2 LUDLUM 2220, SHIELDED 3'1 X 1/2" Na! DETECTOR 48395 CPM 2500 NIA r ,......~.".. ~UN t;UIL Total U 4 10 11 COUNTER 4" X 4 X 16" Nal DETECTOR pCi/G Th (Nat) 1 1

  ~.:A~~-G~U!..!~D NOT SUBTRA(; I t:U REVIEWED BY:       1,J,a_, ~ . , , ,- ~ __,       DATE:     .5---JJ-.- 9r 13'        MICR(l)       MICRO LN                    GRID LOCATION          DETECT           R'             R'           O" -6'
      #                                         c '. P.M. SURF        1 METER       Total-U         Th (Nat) 91             60        E -   140    N    :600            7               6         11                1 92             60        E -   145    N BL DG.#4 BLDG.#4 BLDG.#4                 BLDG.#4        BLDG.# 4 93             60        E -   150    N BL DG.#4 BLDG.#4 BLDG.#4                 BLDG.#4        BLDG.# 4 94             60        E -   155    N BLI DG.#4 BLDG.#4 BLDG.#4                BLDG.#4        BLDG.# 4 95             60        E -   160    N cm ~CRETE CONCRETE CONCRETE             CONCRETE        CONCRETE 96             60        E -   165    N    L 220          11              11         13               1 97             60        E -   170   N     ~030            9              10         13               1 98             60        E -   175    N    :710           10              10         12               1 60        E -   180         ~ 860                          10                          1 99                                    N                   10                         11 100             60        E -   185   N     :ogo            9               9         15               1 101             60        E -   190   N     ~ 610           9               9          9               1 102             60        E -   195   N     3020           10              10          6               1 103             60        E -   200   N     ~350            9               8          6               2 104             60        E -   205   N     3520           13              12         16               1 105             60        E -   210   N     3600 I

11 11 10 1 106 65 E - 135 N ~360 i 7 7 5 1 107 65 E - 140 N 2820 8 8 6 1 108 65 E - 145 N BL[PG.#4 BLDG.#4 BLDG.#4 BLDG.#4 BLDG.#4 109 65 E - 150 N BLDG.#4 BLDG.#4 BLDG.#4 BLDG.#4 BLDG.#4 110 65 E - 155 N BLOG.#4 BLDG.#4 BLDG.#4 BLDG.#4 BLDG.#4 111 65 E - 160 N CONCRETE CONCRETE CONCRETE CONCRETE CONCRETE 112 65 E - 165 N 2920 9 9 17 1 113 65 E - 170 N 4570 9 10 18 1 114 65 E - 175 N 3770 10 10 10 1 115 65 E - 180 N 4290 10 10 19 1 116 65 E - 185 N 3680 11 11 21 1 117 65 E - 190 9 N 4390 9 12 1 118 65 E - 195 N ~970 9 9 6 1 119 65 E - 200 N  : 390 11 11 13 1 120 65 E - 205 N ~380 10 10 9 1 A:\DATASURF.W82

05/11/99 I CIMARRON FACILITY SUB AREA "I" PHASE I I AFFECTED Tl02 AREA SURFACE S/N RESULTS IN BAGKGROUND MDA INSTRUMENTS: LUDLUM MICRO 'R' METER - M/~ 19 138420 µr/hr 9 2 LUDLUM 2220, SHIELDED 3" X 1/2" Nal DETECTOR i 48395 CPM 2500 NIA ICIMMARON ~UI  ! 1otal U 4 10 COUNTER 4" X 4" X 16" Nal DETECTOR pCi/G Th (Nat) 1 1

   ~"C~.GROUND Nu I SUts fRAt.; I t:U REVIEWED BY:      ~-a, A--
                                           . 3" u     =,
                                                            ""Y - - *
                                                                     ~        DATE:     ~--;~- 77 MICRC7            MICRO LN            GRID LOCATION           D~TECT         R'               R'           O" - 6'
      #                                   C.P.M.      SURF          1 METER       Total-LI      Th (Nat) 121       65      E -     210     N   :~820        10                 9         10             1 122       70      E -     135     N   :~670         7                 7          4             1 123       70      E -     140     N   :>390        10                10          7             1 124       70      E -     145     N BL JG.#4 BLDG.#4 BLDG.#4               BLDG.# 4       BLDG.# 4 125       70      E -     150     N BL )G.#4 BLDG.#4 BLDG.#4               BLDG.# 4       BLDG.#4 126       70      E -     155     N BL G.#4 BLDG.#4 BLDG.#4                BLDG.# 4       BLDG.#4 127       70     E -      160     N   : 380 1

9 8 7 1 128 70 E - 165 N  : 870 1 9 9 15 1 129 70 E - 170 N :_,500 9 9 8 2 130 70 E - 175 N l760 10 9 18 1 131 70 E - 180 N 3360 9 10 19 1 132 70 E - 185 N ~340 9 9 13 1 133 70 E - 190 N 3180 9 9 6 2 134 70 E - 195 N 3340 10 10 4 2 135 70 E - 200 N 2810 8 10 7 2 136 70 E - 205 N 2720 10 10 7 1 137 70 E - 210 N 2680 11 10 9 1 138 75 E - 135 N ~460 8 7 10 1 139 75 E - 140 N CONCRETE CONCRETE CONCRETE CONCRETE CONCRETE 140 75 E - 145 N BLOG.#4 BLDG.#4 BLDG.#4 BLDG.#4 BLDG.#4 141 75 E - 150 N BLOG.#4 BLDG.#4 BLDG.#4 BLDG.#4 BLDG.#4 142 75 E - 155 N BLOG.#4 BLDG.#4 BLDG.#4 BLDG.#4 BLDG.#4 143 75 E - 160 N 3460 10 10 16 1 144 75 E - 165 N 2830 8 8 18 1 145 75 E - 170 N 2610 9 9 12 1 146 75 E - 175 N 4000 10 10 11 1 147 75 E - 180 3840 N 12 11 12 1 148 75 E - 185 N 2940 12 11 13 1 149 75 E - 190 N ~!990 10 10 8 1 150 75 E - 195 N  :~540 11 10 9 1 A:\DATASURF.WB2 5

05/11/99 CIMARRON FACILITY SUB AREA "I" PHASE I I AFFECTED TI0 2 AREA SURFACE S/N RESULTS IN BAc.;K.GRUUND MDA INSTRUMENTS: LUDLUM MICRO 'R' METER - M/~19 138420 µr/hr 9 2 LUDLUM 2220, SHIELDED 3" X 1/2" Nal DETECTOR 48395 CPM 2500 NIA 1c11w.~_Al-{QN ~UIL Total u 4 10 COUNTER 4" X 4" X 16" Nal DETECTOR pCi/G Th (Nat) 1 1

 ,!3.'\'-*!'l'.:""'..'_*i_l~D NUT SUts fRAc.; I t:.U REVIEWED BY:          i ~. 6 .      /2,;_~  ,  _,

DATE: .5-~1)....-97 j 3tl MICKCY MICRO LN GRID LOCATION DaTECT R' R' 0 11 - 6' *

       #                                                  dP.M.         SURF      1 METER          Total-U            Th (Nat) 151                  75     E -      200         N     :220          10             10             9                  1 152                  75     E -      205         N     2280          11             11            15                 2 153                  75     E  -     210         N     2140           9              9            11                 1 154                  80     E  -     135         N     ~350           8              8            7                  1 155                  80     E -      140         N  COi   JCRETE  CONCRETE    CONCRETE        CONCRETE           CONCRETE 156                  80     E -      145         N BLI )G.#4 BLDG.#4 BLDG.# 4                BLDG.#4            BLDG.#4 157                  80     E -      150         N BU >G.#4 BLDG.#4 BLDG.#4                  BLDG.#4            BLDG.#4 158                  80     E -      155         N BLI )G.#4 BLDG.# 4 BLDG.#4                BLDG.#4            BLDG.#4 159                  80     E -      160         N    '4 ,640        11             10           12                  1

• 160 161 162 163 164 80 80 80 80 80 E -

E - E - E - E - 165 170 175 180 185 N ~700 N N N N 3630 3000 3190 3260 11 9 10 11 9 11 10 10 9 9 21 17 13 6 13 1 1 1 2 1 165 80 E - 190 N 3260 11 9 5 1 166 80 E - 195 N ~310 10 10 11 1 167 80 E - 200 N 3060 10 8 5 1 168 80 E - 205 N 3410 11 11 13 1 169 80 E - 210 N 3140 11 9 5 1 170 85 E - 135 N 2570 8 8 7 1 171 85 E - 140 N CONCRETE CONCRETE CONCRETE CONCRETE CONCRETE 172 85 E - 145 N BLDG.# 4 BLDG.#4 BLDG.#4 BLDG.#4 BLDG.# 4 173 85 E - 150 N BLDG.# 4 BLDG.#4 BLDG.# 4 BLDG.#4 BLDG.#4 174 85 E - 155 N BLDG.# 4 BLDG.#4 BLDG.#4 BLDG.#4 BLDG.#4 175 85 E - 160 N 3330 10 9 17 1 176 85 E - 165 N 3750 9 9 10 1 177 85 E - 170 N 3870 11 11 10 1

• 178 179 180 A:\DATASURF.WB2 85 85 85 E -

E - E - 175 180 185 N N N 2870

                                                           ~~70 2770 6

10 10 9 9 9 10 10 4 10 1 1 1

05/11/99 CIMARRON FACILITY SUB AREA "I" PHASE II AFFECTED TI02AREA SURFACE

• INSTRUMENTS:

LUDLUM MICRO 'R' METER - LUDLUM a:,w, SHIELDED 3" X 1/2" Nat DETECTOR CIMMARON t;OI M/~ 19 I I i S/N 138420 48395 RESULTS IN BACKGROUND

                                                                            µr/hr CPM 9

2500 Total U 4 MDA 2 NIA 10 COUNTER 4" X 4" X 16" Nal DETECTOR i pCi/G Th (Nat) 1 1 BA<.;KGROUNU NOl SUBTRA(.; I t:U REVIEWED BY: i~Lu. /

                                                       ,.,fl_~

Z/ 7T

                                                                - . ~ ., ,        DATE:     5--/2-7?

l 3" MICI-K) MICRO LN GRID LOCATION DdTECT R' R' O" - 6'

     #                                   C.P.M.      SURF             1 METER         Total-U       Th (Nat) 181      85      E -     190    N    :570           10                   10          10            1 182      85      E -     195    N    ~590           10                   10          16            1 183      85      E -     200    N    2420           11                   11          17            1 184      85      E -     205    N    ~120           10                    9          14            1 185      90      E -     135    N    ~ 340           8                    8           8            1 186      90      E -     140    N cm CRETE CONCRETE              CONCRETE      CONCRETE        CONCRETE 187      90      E  -    145    N BU >G.#4 BLDG.#4 BLDG.# 4                     BLDG.#4        BLDG.#4 188      90      E -     150    N BU >G.#4 BLDG.#4 BLDG.# 4                     BLDG.#4        BLDG.#4 189      90      E  -    155   N BU ~G.#4 BLDG.#4 BLDG.# 4                      BLDG.#4        BLDG.#4

• 190 191 192 193 194 90 90 90 90 90 E -

E - E - E - E - 160 165 170 175 180 N N N N N COI\CRETE CONCRETE CONCRETE 3400 3070 2570 2530 9 11 9 10 9 10 8 10 CONCRETE 10 7 26 14 CONCRETE 1 2 1 1 195 90 E - 185 N 3760 10 9 18 1 196 90 E - 190 N 2830 10 9 8 1 197 90 E - 195 N 2720 9 9 16 1 198 90 E - 200 N 3,440 9 10 18 2 199 90 E - 205 N 2'930 g 9 11 1 200 95 E - 135 N 2530 8 7 8 1 201 95 E - 140 N CONCRETE CONCRETE CONCRETE CONCRETE CONCRETE 202 95 E - 145 N BLDG.#4 BLDG.#4 BLDG.# 4 BLDG.#4 BLDG.#4 203 95 E - 150 N BLOG.#4 BLDG.#4 BLDG.# 4 BLDG.#4 BLDG.#4 204 95 E - 155 N BLDG.#4 BLDG.#4 BLDG.# 4 BLDG.#4 BLDG.#4 205 95 E - 160 N CONCRETE CONCRETE CONCRETE CONCRETE CONCRETE 206 95 E - 165 N 2$50 9 8 8 1 207 95 E - 170 3~00 N 10 9 9 1 208 95 E - 175 N 3~30 9 9 18 1 209 95 E - 180 N 3530 10 10 10 2 210 95 E - 185 N 3800 10 10 23 1 A:\DATASURF.WB2 7

05/11/99 i CIMARRON FACILITY

• SUB AREA "I" PHASE I I AFFECTED TI02 AREA SURFACE
• INSTRUMENTS:

LUDLUM MICRO 'R' METER - LUDLUM 222U, SHIELDED 3" X 1/2" Nal DETECTOR GI MAHUN :::;ulL MIN 19 SIN 138420 48395 RESULr::;IN BACKGROUND

                                                                                     µr/hr CPM 9

2500 Total U 4 MDA 2 N/A 10 COUNTER 4" X 4" X 16 Nal DETECTOR i pCi/G Th (Nat) 1 1

  ~-"'.C~GROUND NU I SU~ I RACTED REVIEWED BY:    i k/(1., ~-D~-                                    DATE:      ~--;J--J?

3" ,.., ic Qi("_) MICRO LN GRID LOCATION DE TECT R' R' O" - 6'

     #                                   C P.M.        SURF                       1 METER        Total-U       Th (Nat) 211        95     E -     190   N    3l260              9                         10             9             1 212         95     E -     195   N    3Q50              10                         10            16            1 213         95     E -     200   N    3930              11                         10            16            1 214         95     E -     205   N    4Q10              12                         11            17            1 215        100     E -     135   N    2~80              7                           7             7            1 216        100     E -     140   N    2500              6                           7             3            1 217        100     E -     145   N  COi\ CRETE CONCRETE CONCRETE                           CONCRETE        CONCRETE 218        100     E -     150   N  COi\ CRETE CONCRETE CONCRETE                           CONCRETE        CONCRETE 219        100 E -     155   N CON CRETE CONCRETE CONCRETE                             CONCRETE        CONCRETE 220        100     E -     160   N CO~CRETE CONCRETE CONCRETE                              CONCRETE        CONCRETE 221        100     E -     165   N 2p40                 9                           9            19            1 222        100     E -     170   N    31140            10                           9            8             1 223        100     E -     175   N    3110              9                           9             7            2 224        100     E -     180   N    3080             11                           9            4             1 225        100     E -     185   N    3p40             10                           9            11            1 226       100      E -     190   N    3~40             10                           9             5            1 227       100      E -     195   N    2790               9                          9            14            1 228       100      E  -    200   N    3551             10                          10             8            2 229       100      E  -    205   N    3170             10                           9            12            1 230       105      E  -    135   N    2940              8                           8             6            1 231       105      E  -    140   N    2380               8                          8            11            1 232       105      E  -    145   N    2670               8                          8             5            1 233       105      E  -    150   N    2560               9                          8             8            1 234       105      E -     155   N    2740               9                          9             6            2 235       105      E -     160   N    2830             10                          10             9            1 236       105      E -     165   N    2*550             9                           9            14            1 237       105              170        3330             10                          10 E -           N                                                               17            1 238       105      E -     175   N    3120             10                          10             9            2 239       105      E -     180   N    3210               9                          9             9            1 240       105      E -     185   N    3!720            11                          11            17            1 A:\DATASURF.WB2                                8

05/11/99 I CIMARRON FACILITY SUB AREA *In PHASE I I AFFECTED TIQ2 AREA SURFACE

• LUDLUM 2220, INSTRUMENTS:

LUDLUM MICRO 'R' METER - SHIELDED 3" X 1/2" Nal DETECTOR

  ,_~ ,..... /\.~ON SOI M/~ 19 S/N 138420 48395 RESULTS IN BACKGROUND
                                                                              µr/hr CPM 9

2500 Total U 4 MDA 2 N/A 10

                                                                                                --;2--:rr COUNTER 4" X 4" X 16" Nal DETECTOR                                        pCi/G  Th (Nat) 1          1
  ~.A.!:~GROUND NOT SUts fRAt; I t:D REVIEWED BY:   , '2Ja, * / /Ju 7.....,....
                                                                  ~--                DATE:     ~

i 3" MICRO lvHCRO LN GRID LOCATION D~TECT R' R' O" - 6'

        #                                    C.P.M.       SURF             1 METER       Total-U     Th (Nat) 241           105    E  -   190    N    : 340          10                 10          19            1 242           105    E  -   195    N    ~ 560          11                 10          11            1 243           105    E -    200    N    ~470           11                 11          15            1 244           105    E -    205    N    : 870          11                 11          10            1 245           110    E -    135   N     2500            8                  8           5            1 246           110    E -    140   N     L210            6                  7           6            1 247           110    E -    145   N     ~560            8                  8           8            2 248           110    E -    150   N     2740            8                  8           7            1 249           110    E -    155   N     2860            9                  9          11            1

• 250 251 252 253 254 110 110 110 110 110 160 165 170 175 180 31050 4250 3:170 3560 2690 10 7

11 9 9 6 11 9 10 8 7 7 9 17 15 2 2 2 1 1 255 110 185 3040 10 8 10 1 256 110 190 2720 10 8 12 1 257 110 195 3680 11 10 16 1 258 110 200 3270 9 9 12 1 259 110 205 3060 10 10 18 1 260 114 135 1680 7 7 5 1 261 114 140 1800 7 6 3 1 262 114 145 1500 7 6 3 1 263 114 150 1510 7 7 2 1 264 114 155 1650 8 7 8 1 265 114 160 2360 9 9 5 2 266 114 165 2~60 10 9 12 1 267 170 114 2950 9 10 10 1 268 114 175 2680 10 10 6 1 269 114 180 2~30 9 8 18 1 270 114 185 2~50 8 8 9 1 A:\DATASURF.WB2 9

05/11/99 CIMARRON FACILITY

• SUB AREA "I" PHASE II AFFECTED TI02AREA SURFACE S/N RESULTS IN BACKGROUND MDA INSTRUMENTS:

LUDLUM MICRO 'R' METER - M/Ni19 138420 µr/hr 9 2 I I IULI 11\,, 222U, SHIELDED 3" X 1/2" Nal DETECTOR 48395 CPM 2500 N/A ICl~.1".~.A~UN ~UI Total u 4 10 COUNTER 4" X 4 11 X 16" Nal DETECTOR pCi/G Th (Nat) 1 1 BA'-~-*-=-~*-*!..!~n NO I SUts IRAL; I 1:U REVIEWED BY: 'tJ - CL / 4 ~ DATE: j-*12-Jr

3" MIGH~ MICRO LN GRID LOCATION D~TECT R' R' O" -6'

       #                                       C P.M . SURF   1 METER       Total-U     Th (Nat) 271            114             190         3610        10       11           18           1 272            114             195         3~80        10       10           20           1 273            114             200         3190         9       10           16           2 274            114             205         2580        10        g           15           1

• A:\DATASURF.WB2 10}}