ML20217Q910

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Matl Recovery Plan
ML20217Q910
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 04/30/1998
From:
CONNECTICUT YANKEE ATOMIC POWER CO.
To:
Shared Package
ML20217Q909 List:
References
PROC-980430, NUDOCS 9805130019
Download: ML20217Q910 (22)


Text

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Attachment 1 4

Haddam Neck Plant Material Recovery Plan April 1998

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9805130019 990429 PDR ADOCK 05000213 W PDR -

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M ATERIAL RECOVERY PLAN Table of Contents Text Paoe l 1.0 Introduction 1 2.0 Project Organization 2 3.0 Quality Assurance 2 3.1 Personnel Qualification and Training 2 ,

l 3.2 Survey Documentation / Records 3 3.3 Instrumentation 3 4

3.4 Off Site Laboratory Quality Control Measures 3 4.0 Health and Safety Plans 4 5.0 Survey Design 4 4 5.1 Site Identification 4 5.2 Scoping Survey 4 5.3 Site Characterization Process 5 5.4 Site Remediation 7 5.5 Site Restoration 7 5.6 Dose Estimation and Final Survey Reports 8 6.0 Instrumentu 7n and Analysis Capabilities 8 6.1 Field Instrumentation 8 6.2 Smear Analysis 8 6.3 Sample Analysis-Field Analysis 8 6.4 Tool Monitoring 8

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MATERIAL, RECOVERY PLAN l ,

. 6.5 Off Site Sample Analysis 9 l

! l 6.6 In-situ Monitoring 9 l

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l 7.0 Material Management 9 t

8.0 Schedules 9 I

9.0 References 10 Tables Table 1 Survey Unit Classification and Survey / Sample Density Table 2 Material Recovery Plan Instrumentation l

Table 3 Typical Instrument MDCRs and MDAs '

Flaures l 1

Figure 1 Material Recovery Process Figure 2 Material Recovery Project Organization I

Figure 3 Off Site Survey Area Questionnaire (Sample) l

MATERI AL RECOVERY PLAN 1.0 Introduction During the historical site assessment of the Haddam Neck Plant (HNP), it was identified that low levels of radioactive materials, in the form of concrete shield blocks, soil and other miscellaneous materials, were inappropriately released from site. Specifically it was determined that a concrete block shield wall around the resin processing area had been l removed from the plant site in 1975. The survey records available were inadequate to J identify if the concrete shield blocks had been appropriately surveyed for unconditional release. On November 26,1997, initial surveys of two former Connecticut Yankee Atomic Power Company (CYAPCO) employee properties, which contained some of the concrete shield blocks, were completed. Low levels of licensed material were detected at each of the properties. As a result of the discovery of licensed material at an off site location, actions j have been taken to identify and recover HNP licensed material and concrete shield blocks I that were inappropriately released to off site locations.

CYAPCO management is com'nitted to recovering all HNP licensed material and recovery of all available concrete shield bocks. To achieve this goal, this Material Recovery Plan will be implemented to complete, as applicable, the following major activities at each identified site !

in a timely manner: l

. Contact former and current employees and selected long-term contract personnel to l determine if materials from the HNP are present on their property or on property previously controlled by them.

. Complete a scoping survey and initial assessment of the off site property.  ;

e Complete an historical property use survey and site characterization survey.

. Complete the recovery of any detected licensed material or CY concrete shield blocks from the property.

. Complete a final site status survey.

. Complete site restoration.

. Complete a dose reconstruction.  ;

e issue a Final Status Survey report.

Figure 1, " Material Recovery Process" illustrates the general process for the Material Recovery Project.

Radiological surveys and historical site assessments associated with the recovery of the HNP licensed material will be designed, planned and performed considering the applicable

. guidance provided by:

. Draft NUREGICR-5849, Manual for Conducting Radiological Surveys in Support of License Termination and e NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM).

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t MATERIAL RECOVERY PLAN The material recovery project will be implemented by this Material Recovery Plan, Safety Procedures, RP Manualprocedures and a Survey / Sampling Work Plan, in accordance with RPM 5.1-2 " Instructions for Scoping and Characterization Surveys", specifically prepared for each property.

2.0 Project Organization Figure 2 is an overview of the reporting and coordination relationship for this project. The Site Characterization Supervisor is responsible for coordinating activities with representatives of the NRC and Connecticut Department of Environmental Protection (CT DEP). Inspectors from the NRC and the CT DEP will be kept informed of off site activities.

The Site Characterization Supervisor reports to the Health Physics Manager and is responsible for the overall direction of work activities associated with the Material Recovery Plan including:

. Identification of properties containing HNP licensed material;

. Design of surveys to obtain required data;

. Remediation and removal of licensed material; e Restoration of the property;

. Notification of the NRC and the CT DEP of work in progress; and

. Preparation of dose estimates and final survey reports.

The functional positions identified on the organizational chart report to the Site Characterization Supervisor. The Scoping Lead, Survey Design and Performance Lead, Construction Services Supervisor and Scheduling Lead are responsible to complete assigned duties.

3.0 Quality Assurance The Material Recovery Plan provides project specific quality elements to be implemented for recovery oflicensed material from off site locations. These project specific quality elements will be used in conjunction with applicable portions of the CYAPCO procedures. The project specific quality controlitems are addressed below.

3.1 Personnel Qualification and Training Personnel assigned to this effort will be selected based upon their previous work experience and familiarity with site characterization, final survey and radiation projects. Personnel will receive training and be qualified in the appropriate procedures, plans and work packages, commensurate with their specific work assignment. All personnel assigned to perform work at off site locations will be qualified Radiation Workers unless exempted by the CYAPCO HP Manager, t

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i M ATERIAL RECOVERY PLAN 3.2 Survey Documentation / Records

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Characterization surveys will be documented following instructions provided in an approved l site specific Survey / Sampling Work Plan. The Survey / Sampling Work Plan and the data

( associated with the Survey / Sampling Work Plan will contain records that may include:

. Survey / Sampling Work Plan which provides the package identification, survey location codes, and specific survey instructions; e Initial Scoping Data; l e Sample Chain of Custody Records;

. Survey unit diagrams or maps of the area;

! . Photographs of the survey areas; e Hard copy printouts of laboratory analysis results; l . Copies of Log book notes or field notes; and

. Download data files.

Completed survey records are reviewed by the personnel performing the survey and by the project engineer assigned to the Survey / Sampling Work Plan. Upon review, if corrections  !

are necessary, the corrections will be made and documented. Survey documentation will be retained as required by the CYAPCO procedures and site record retention requirements.

3.3 Instrumentation Survey instrumentation has been selected which reliably detects the primary radionuclides associated with HNP operations (Co-60 and Cs-137). Survey instrumentation described in this report are calibrated using approved calibration procedures, and with sources and equipment which are traceable to the National Institute of Standards and Technology (NIST).

Upon completion of instrument calibrations, labels showing the instrument identification number, calibration date and the calibration due date are attached to the field instrumentation. Instrumentation will be calibrated or verified to be within calibration prior to use. Instrumentation will be source / response checked prior to use and upon return to the

-issue area or at least daily, Procedures for instrument QC checks, instrument use and instrument operation are controlled by CYAPCO procedures.

3.4 Off Site Laboratory Quality Control Measures i

Quality Control measures to assess off site laboratory analysis results will include split sample analysis and duplicate sample analysis. Approximately 5 percent of the off site sample analyses willinvolve the analysis of split or deplicate samples. Split samples are samples collected from the same location but are suffeiently large to split into two samples.

Duplicate sample analysis involves the repeat analysis cf the same sample at a different time or on a different detector. Sample results will be evaluated for acceptability using the

( criteria in CYAPCO Chemistry Department procedure CHDP 2.0 7, Split Sample Program.

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MATERIAL RECOVERY PLAN 4.0 Health and Safety Plans

" Each work location and planned work activities will be evaluated using procedure ADM 1.1-23, Job Safety Analysis. Pre-job briefings will be conducted as specified by procedure WCM 2.1-8, Pre-Job Briefing. All radiological work at off site locations will be performed and controlled in accordance with the CYAPCO Health Physics Program.

To the extent possible, the work area will be controlled and maintained in a neat and orderly manner consistent with the work in progress. Normal housekeeping and cleaning of structures, areas and equipment may be accomplished with the standard decontamination methods and typically manual methods. At completion of work for the day, the affected areas of the site will be left in a safe and secure condition.

5.0 Survey Design A process with appropriate program controls that will allow for identification of licensed l materials, site remediation and restoration and public dose reconstruction will be implemented as shown in Figure 1. The process includes six major phases as follows:

1. Site identification with initial screening and scoping surveys; I
2. Site Characterization Process;
3. Site Remediation Process;
4. Site Restoration; ,
5. Dose Reconstruction; and l
6. Final Status Report, i

5.1 Site Identification The goal of the site identification phase is to identify properties or personnel, which may have received material fror, the HNP The site identification process includes:

  • review of plant personnellists during the time of concern; e review of gate logs for the dates the material was removed; e distribution of questionnaires to past and present CYAPCO personnel; e interviews with persons logged as having removed materials to determine the quantity of material removed and if additional distribution of material had occurred and; e site visits to the current material location point to assess the presence of licensed material.

5.2 Scoping Survey During the property visit, an initial scan of any identified concrete shield blocks, previous

( storage locations and other former material from the HNP will be performed. Items with residual contamination greater than any of the screening criteria provided below will be immediately removed or public access controlled.

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9 MATERIAL RECOVERY PI.AN Initial Screening Criteria:

. Estimated exposure to members of the public of greater than 10 mrem /yr,

. Contact exposure rate of greater than or equal to 0.5 mR/hr or

. Removable beta-gamma contamination greater than or equal to 3000 dpm/100 cm2 Typical actions taken during initial scoping surveys include:

1 Interviews with the property owner to identify current and previous locations of HNP material;

. Photos of property and potential HNP material;

. Sketches of area lay outs; and

. Initial area scans and dose rate surveys.

i Locations, which are investigated for containing material from the HNP, are assigned a unique location code.

5.2.1 Confidentiality During the course of the material recovery process, the privacy and confidentiality of the property owner will be protected to the extent :easonably possible.

5.3 S;te Characterization Process The purpose of the site characterization process is to identify the extent of licensed material from the HNP at a specific site in sufficient detail to develop plans for site remediation and restoration, and to provide data for the dose reconstruction. To accomplish these goals an organized method to document the extent and history of former material from the HNP at the site will be conducted. Additionally, a method to document and control the remediation process is required. The following sections identify specific methods, which will be used.

5.3.1 Survey Unit Classification Survey units at a specific location will be designated as "Affected" or " Unaffected" based on the likelihood that the area may be contaminated as follows:

. Affected Survey Unit - Locations containing material from the HNP, having a history of containing material from the HNP, or areas adjacent to an area, which contained licensed material from the HNP. Affected survey units are evaluated using a program of measurements and samples selected in a non-random manner, considering the expected distribution of radioactivity, to assess the extent and presence of licensed material.

. Unaffected Survey Unit - Locations without a history of containing material from the HNP, these areas are evaluated using a program of curveys and samples selected in a random manner to provide a valid assessment that licensed materials are not present in 5

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M ATERI AL RECOVERY PLAN the area.

If during the survey and sampling program, additional areas containing licensed material from the HNP are identified, area reclassification with the associated Survey / Sampling Work Plan revision will occur.

5.3.2 Survey / Sampling Work Plan Development The Survey /Sampiing Work Plan is developed from information gathered during the Site Identification process, results of the scoping / screening survey and follow up interviews with l the property owner. The current property owner and, if available and applicable, previous  !

property owners, will be interviewed. An interview checklist similar to Figure 3 will be completed for each interview. This checklist will be used as an aid to determine occupancy l and use times for particular areas, and historical locations of former materials from the HNP.

i The Survey / Sampling Work Plan shall be prepared using the guidance provided in CYAPCO procedure, RPM 5.1-2," Instructions for Scoping and Characterization Surveys". Survey units on each property willinitially be classified as Affected or Unaffected. Specific minimum survey requirements for each type of area are summarized in Table 1. Sunteys will be completed for each site location as specified by the applicable Survey / Sampling Work Plan.

During the implementation of the survey, the Project Engineer may modify the survey and sampling approach, based on results obtained and other relevant information. These changes and basis will be documented in the Survey / Sampling Work Plan 5.3.3 Background Determination Background radioactivity levels will be determined from areas and materials unaffected by plant operations. A background determ'ination technical basis document has been developed and may, during the course of the Material Recovery project, be updated. During the CYAPCO Site Characterization Program, average background concentration levels for Cs-137 in disturbed soils (areas disturbed or changed since weapons fall-out occurred) was determined to be 0.15 pCi/g with a standard deviation of 0.12 pCi/g. The range of Cs-137 activity detected in disturbed soils was 0.02 to 0.54 pCi/g. Average Cs-137 background concentration levels in undisturbed soils was determined to be 0.70 pCi/g with a standard deviation of 0.32 pCi/g. The range of Cs-137 activity detected in undisturbed soils was 0.11 pCi/g to 1.69 pCi/g. The range of values (i.e., maximum) obtained during the unaffected area survey will be used to establish background limits at a particular site. Based upon conditions at a site, site specific backgrounds may be established with the approval of the site characterization supervisor. Background radioactivity levels for construction materiais, such as concrete, brick and asphalt or other materials such as glacs, wood ar.d metals will be established from published data or by using guidance provided in RPM 5.1-6, Decommissioning Scoping and Characterization Radiological Background Assessment Surveys.

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M ATERIAL RECOVERY PLAN

,5.4 Site Remediation 5.4.1 Remediation Process '

The successful remediation and restoration of the property is viewed as a major responsibility of CYAPCO management. Prior to property restoration all detectable licensed material and concrete shielc: blocks will be removed from the site. The site remediation process involves:

The removal of all concrete shield blocks which were previously obtained from tho HNP ;

e Removal of soils or other material containing detectable licensed material; e Maintenance of a controlled, safe and neat work place and; e Verification that remediation was completed.

Acceptable methods for the removal of the licensed materialinclude excision of concrete shield blocks, associated structures and soil by hand, with hand equipment or with power equipment. If removal methods capable of generating airborne radioactivity, such as concrete scabbling, are needed, or if an item can not be removed without destruction of the facility, the Survey / Sampling Work Plan will be revised and the methodology for remediation of the site will be coordinated with the CT DEP and the NRC.

5.4.2 Regulatory interface The NRC and CT DEP will be contacted aileast 3 business days but normally 5 business days prior to commencing work on the site specific Survey / Sampling Work Plan to allow for appropriate oversight at the locations.

5.4.3 Remediation Acceptance Criteria Acceptable remediation is considered to be achieved when no Co-60 is detected, and the level of Cs-137 activity is less than 0.54 pCi/g for disturbed soils, or the level of Cs-137 activity is less than 1.6 pCi/g for undisturbed soils. Other Cs-137 background values may be used if site specific backgrounds are established and approved. For gross counting equipment, the beta / gamma radioactivity is less than the mean background activity at the 95% confidence level.

5.5 Site Restoration Restoration and/or replacement of facilities and components will be completed to the satisfaction of the property owner. This activity is considered to be normal maintenance.

Unless a major addition or structural modification is required, construction permits are not anticipated to be required.

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. .. N MATERI AL RECOVERY PLAN 5.6 Dose Estimation and Final Survey Reports A Final Survey and Dose Reconstruction Report will be completed for each location, w, Oh contained licensed material from the HNP. The summary report willinclude survey data and those factors and assumptions used to allow the dose reconstruction to be accomplished.

Currently, it is planned that the annual dose to the maximally exposed individual at each location will be calculated for all years of exposure. The current property owner will receive a report that demonstrates that all licensed materials from the HNP have been removed.

6.0 Instrumentation and Analysis Capabilities 6.1 Field Instrumentation The Eberline E-600 digital survey instrument will be used and is capable of being connected to a variety of survey detectors, storing the applicable detector calibration information and storage of survey readings. Survey readings and QC checks can be down loaded to a computer database. The various detectors used are listed in Table 2. Typical instrument sensitivities are listed in Table 3.

6.2 Smear Analysis Gross analysis of smears for beta and alpha activity will be performed. Sample count times and the minimum detectable activity (MDA) for alpha and beta activity will be established in accordance with CYAPCO procedure RPM 2.3-8,"Ludlum 2200 Operating Procedure", or equiva!ent.

6.3 Sample Analysis-Field Analysis Samples of soil and debris will be screened in the field with a High Purity Germanium HP(Ge) or similar detector using appropriate computer hardware and software. Sample sizes, sample geometry and sample count times have been selected to achieve an a priori MDA of less than 0.15 pCi/g for Co-60 and 0.18 pCi/g for Cs-137: the environmental lower limits of detection for the radio nuclides of primary concern.

6.4 Tool Monitoring Tools or equipment identified as formerly belonging to CYAPCO will be analyzed for radioactivity using methods identified in RPM 2.2-22, Vehicle and MaterialRelease from Radiologica!Iy Controlled Areas and Restricted Areas. To the maximum extent practical, tools will be surveyed using small article monitor (SAM-9) type equipment. Typically, tools that are too large to fit into the SAM-9 will be surveyed with smears and the E-600 with the SHP-360 or 100 CGS probe.

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a M ATERIAL RECOVERY P12AN 6.5 Off Site Sample Analysis -

Samples of soil and debris, to verify remediation effectiveness, will be analyzed by vendors on the CYAPCO approved suppliers list. Sample sizes, sample geometry and sample count times to achieve an a priori MDA of less than 0.15 pCi/g for Co-60 and 0.18 pCi/g for Cs-137 i will be utilized.  !

6.6 in-situ Monitoring in-situ soil monitoring will be used to supplernent soil sample analysis for release of off site areas. The In-situ measurement process involves the establishment of an HP(Ge) detector at a location and the accumulation of a spectra, detection of Co-60 willindicate the presence of licensed material at unacceptable levels.

The use of in-situ monitoring will provide a quality control check to ensure the site has been adequately temediated. in-situ measurements are under the control of an approved procedure, DE&S Procedure No. 510, Identification and Quantitative Determination of Radionuclides in Soil By Gamma Ray In Situ Spectrometry. This procedure will ensure that the instrument's sensitivity and calibration will be maintained under field use. These measurement methods have demonstrated detection capabilities approaching the a priori  !

MDA associated with soil sample analysis for soils with uniform activity levels. l 7.0 Material Management Materials recovered from off site locations will be packaged and returned to the HNP using guidance provided in procedure RPM 3.10-00, Radioactive Material Shipping Program. The materials will be received, controlled and dispositioned at the HNP using guidance provided in procedure RPM 3.2-00, Radioactive Material Contro/ Program. Transfer of any licensed material to licensed off site processing or disposal facilities will be completed using guidance in RPM 3.10-00 and will comply with the requirements of 10 CFR 20,10CFR61 and 10CFR71, as applicable.

Licensed material collected during work will be packaged and returned to the HNP.

Packaging and shipping of licensed materials will be made in compliance with DOT regulations using CYAPCO procedures and qualified personnel.

8.0 Schedules A schedule for the implementation of the Material Recovery Plan for the locations identified to date has been developed. Scheduling information for each of the phases of the Material Recovery Project are included in the schedule. The scheduling of this project will be dynamic due to weather conditions, property availability, and extent and condition of licensed materiallocated on a site. The schedule will be updated periodically to status progress.

Updates to the schedule will be provided to the Senior Resident Inspector or assigned Region l Inspector. <

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.- - I MATERIAL RECOVERY PLAN 9.0 References 9.1 Draft NUREG/CR-5849, Manual for Conducting Radiological Surveys in Support of License Termination.

9.2 NRC Letter, dated March 24,1998, from A. Randolph Blough to Russ A. Mellor, Offsite Remediation Plans.

9.3 RPM 5.1-2, Instructions for Scoping and Characterization Surveys.

9.4 ADM 1.1-23, Job Safety Analysis.

9.5 WCM 2.1-8, Pre-Job Briefing.

9.6 CHDP 2.0-7, Split Sample Program.

9.7 RPM 3.10-00, Radioactive Material Shipping Program.

9.8 RPM 3.2-00, Radioactive Material Control Program. l 9.9 RPM 5.1-6, Decommissioning Scoping and Characterization Radiological Background Assessment Surveys.

9.10 State of Connecticut Letter, dated March 5,1998, from Denny GP.lloway to Russell A. Mellor, no title.

9.11 RPM 2.2-22, Vehicle and Material Release from Radiologically Controlled Areas and Restricted Areas. .

9.12 NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MA9SSIM).

9.13 L %S procedure 510, Identification and Quantitative Determination of Radionuclides in doil By Gamma Ray In Situ Spectrometry 9.14 RPM 2.3-8, Ludlum 2200 Operating Procedure.

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i l Table 2 Material Recovery Plan Instrumentation l Instrument / Detector Radiation Use Detector Type Detected E-600/HP-300 Compensated GM tube Gamma Gamma Exposure Rates E-090/ SPA-3 2" by 2" Na(l) detector Gamma Gamma Surface Contamination E-600/SHP-360 15.5 cm2 GM detector Beta Total Surface Contamination E-600/100 CGS 100 cm2 gas flow Beta Total Surface proportional detector Contamination Ludlum 2200 ZnS and HP210 Alpha & Beta Removable Surface

! Contamination in-situ /HP(Ge) High Purity Germanium Gamma Volumetric Land Assay j 1

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MATERI AL RECOVERY PLAN Table 3 Typical Instrument MDCRs and MDAs GROSS PROBE Typical NET MDCR MATERIAL INSTRUMENT AREA MODE BKG MDCR + BKG MDA 2

(CM ) (CPM) (CPM) (CPM) (DPM)

J CONCRETE HP360 15.5 PEAK 169 63 232 1235 i TRAP BLOCKS HP360 F.5 SCALER 39 32 71 500 HP100 100 PEAK 599 117 716 967 TRAP HP100 100 SCALER 322 86 408 577 GENERIC HP360 15.5 PEAK 146 59 205 8 1157 i TRAP HP360 15.5 SCALER 34 30 64 469 HP100 100 PEAK 549 112 661 926 TRAP HP100 100 SCALER 244 75 319 503 BRICKS HP360 15.5 PEAK 302 84 386 1647 )

TRAP HP360 15.5 SCALER 87 46 133 719 HP100 100 PEAK 2171 220 2391 1818 TRAP HP100 100 SCALER 681 124 805 832 l SOIL SPA-3 2X2" PEAK 11367 3410 14777 341000 TRAP uR/h pR/h uR/h SOIL l HP-300 l N/A l SCALER l 11.3 l 4.8 l 16.1 l n/a l MDCR = Minimum Detectable Count Rate MDA = Minimum Detectable Activity 13

MATERIAL RECOVERY PROCESS - FIGURE 1 IDENTIFY SITES

- Perform Historical Site Assessment

- Contact Current / Former CY Personnel i

v Potential No for - > Closeout Investigation Licensed Material J

Yes PERFORM SCOPING SURVEY

- Remove Materials > Screening Criteria

/  ;

Detectable Licensed No Material or CY Concrete > Closecut Investigation Shield Blocks Yes u

DEVELOP CHARACTERIZATION / RESTORATION PLAN

- Classify Areas

- Complete Questionnaire

- Obtain Homeowner Agreement to Scope of Work u

IMPLEMENT CHARACTERIZATION / RESTORATION PLAN

1) Complete Characterization
2) Remove Suspect Materials
3) Perform Final Status Survey
4) Restore Site u

PREPARE FINAL STATUS REPORT

- Complete Dose Estimates <

- Issue Letter to Property Owner

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Figure 3 (Example) j OFF SITE SURVEY AREA QUESTIONNAIRE The following are questions to be asked of the owner / occupants of the off site survey areas to ,

determine the following; materials involved, the material present and previous locations, who had cccess to the materials and/or locations and for how long.

What CY materials are present on the property?

When did the material arrive on the property?

WhereI,: the material presently located on the property?

Where was the material previously located on the property?

I What has been the use of the material at the different locations? .

Who has had access to the material or locations where the materialis or has been?

What is the nature of the access to the materials or locations?

What has been the duration of the access to the materials or locations?

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