ML21250A188

NRC-2021-000225 - Resp 1 - Final, Agency Records Subject to the Request Are Enclosed, Part 3 of 3

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• QCEG e UNtTED STATES r [ (o,h NUCLEAR REGULATORY COMMISSION J

,, j REGCN V O S ];

e 0 1450 MARIA LANE SutTE 210 g ,p WALm,7 CREEK CALIFORNIA 94588 JAN 2 8 1988  ;

l MEMORANDUM FOR: Ross A. Scarano, Director Division of Radiation Safety and Safeguards Branch l l

FROM: James L. Montgomery, Chief j Nuclear Materials Safety i and Safeguards Branch

SUBJECT:

TRIP REPORT FOR MAKIKI PARK RADIOLOGICAL EVALUATION

1. Introduction At the request of Mr. T. Anamizu, Chief of the Noise and Radiation I Branch for the Hawaii Department of Health (HDOH), J. Montgomery, Chief.

Nuclear Materials Safety and Safeguards Branch, F. Pang, NRC Radiation Specialist and G. Cook, NRC Public Affairs Officer, traveled to Honolulu on November 27, 1987, to evaluate possible elevated radiation levels ,

detected by HDOH in Makiki Park which is owned and operated by the City i of Honolulu. This report is divided into the following sections: l

1. Introduction.

2. History of the Makiki Park site.

3. 1975 NRC decontamination and radiological release criteria.

4. Public and HDOH concern for Makiki Park in 1987. j

5. NRC radiological evaluation November 27 through December 2,1987.

6. NRC Findings.

7. 1987 NRC decontamination and radiological release criteria.

6. Sumary and Recommendations.

Appendix A. NRC Guidelines for Decontamination.

B. Diagram of Makiki Park showing the original Hawaiian Sugar Planters Association (HSPA) buildings.

C. Diagram of areas where radiaiton levels exceeded natural background.

D. Diagram of Sewer Tunnel Project.

E. December 2, 1987 News Release from HDOH 8803030013 880216 h&S - N

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2. History of the Makiki Parh Site.

The five acre piat of land now known as Makiki Park was owned by the HSPA and used as an agricultural research station from the 1940s to 1975. HSPA began to use radioactive materials in some of their research as early as 1947. During 1950-1975, HSPA conducted plant tracer studies '

with radioisotopes and fabricated their own cesium 137 density gauges known as " Bagasse Weighers" for use in sugar mills. These uses of radioactive materials were licensed by the U. S. Atomic Energy Comission (AEC) and its successor the NRC. During these years, HSPA personnel experienced several incidents with radioactive material which resulted in contamination of soil, buildings and equipment at several locations on the Makiki Park site.

In 1975, the City of Honolulu and HSPA negotiated for the site to be ,

acquired by the City for use as a public park. HSPA conducted decontami-nation and low level radioactive waste burial at several locations. See Appendix D. Contaminated soil was also buried at a depth of 6 to 8 feet at the locations shown in Appendix D. The burials were conducted in accordance with NRC regulations in effect in 1975, and contained a total of approximately two millicuries of cesium 137.

In December 1975, an NRC inspector surveyed the site and detemined that all contamination had been removed, buried on-site, or shipped to an NRC authorized low level waste site within the continental U. S. in accordance with NRC regulations. In February 1976, the HSPA radioactive materials license for the Makiki Park site was amended by the NRC to release the area for unrestricted use and the City fomally took possession of the site.

3. 1975 NRC Release Limits and Guidelines.

No specific NRC limits exist for contamination in soil. The NRC considers each contamination case separately and applies an extremely conservative set of assumptions for each case. With the HSPA :;ite, it was decided to use the unrestricted area drinking water standard converted to microcuries per gram of soil. For a large area unifo cesium 137 in soil, the standard (2 x 10~gmly distributed microcuries per source of gram) was calculated to be equivalent to 100 microroentgens/hr. at the ground surface.

The current NRC staff review of the 1975 decontamination effort and application of the above guidelines indicates that HSPA and NRC had not detected any radiation levels above these guidelines, and based their decision to amend the license on accurate radiological data which was below the applicable standard described above.

4. Public and HD0H Concern for Makiki Park in 1987.

The Makiki Park Neighborhood Association expressed concern about radioactive material located in the park and the possib'P adverse effect which may result from the proposed construction of a a wage tunnel beneath the park (see Appendix D). The City of Honolulu informed the HDOH of the concern, and in November 1987, HDOH personnel perfomed radiation surveys of certain portions of the park and detected several small areas of slightly elevated readings. The survey instruments used were more sensitive than those used in 1975. The detected radiation 'evels at one centimeter above the ground surface ranged 2 to 10 times natural background.

Following the discovery of these small radiologically elevated areas HD0H notified the NRC and requested assistance. NRC specialists quickly responded by dispatching three personnel with equipment to Honolulu on November 27, 1987.

5. NRC Radiological Evaluation Novemner 27 through December 2, 1987.

Upon arrival in Honolulu, the three NRC officials visited Makiki Park, conducted brief preliminary surveys and met with city and state officials.

A plan of extensive radiation surveys, soil sampling, and analyses were described by the NRC representatives. Plans were also made to interview persons on the Island of Oahu who had direct personal knowledge of the HSPA decontamination operations in 1975 On the following day, Saturday, November 28th, more extensive radiation surveys at ground level were made in and around two HSPA areas known in 1975 as the " Rat House" and ";nstrument Shop" (see Appendix B). Using a-soil coring tool especially fabricated by the city at the NRC's request, three core samples were taken to approxim tely two feet depth within the two radiologically elevated areas (see Appendix C). The core samples were surveyed for contamination.

Following core samplins, the NRC and city personnel began to excavate a small 3' x 4' area where elevated radiation readings had been detected.

The excavation extended down to approximately 18." Each shovel full of soil removed was surveyed. The soil was deposited on the ground several yards from the excavation and the hole was monitored on several occasions.

November 29th was a rainy day and no excavation or survey work was performed. The excavated soil was covered with plastic sheets to prevent dispersal by wind and water and the hole was covered with plywood boards.

On November 30th, the NRC personnel interviewed individuals at the HSPA and HDOH offices who were knowledgeable about the decontamination and waste disposal activities in 1975. A meeting was held with city and state officials to report the findings. Four soil samples from the excavated area were taken to the University of Hawaii for anclyses by gamma spectroscopy. The NRC team also surveyed areas around the sewer tunnel excavation project including the soil excavated from the 50' vertical shaft located at the Northeast corner of Makiki Park.

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On December 1st, the NRC team and HDOH personnel surveyed all areas within a 15 x 25 meter rectangle encompassing the " Rat House" and i

" Instrument Shop". The surveys were taken at both ground and waist i level (1 meter) (see Appendix C). All readings above natural background l were recorded. j Finally, random surveys were conducted at the buried " greenhouse" site, tennis and basketball court areas, and the vegetable gardens.

1 On December 2nd, the NRC team met with city i.nd state officials, assisted in the preparation of a press release and responded to new  !

media inquiries regarding the final results of the Makiki Park l evaluation. '

6. NRC Staff Findings Appendix C illustrates the survey areas and radiation survey results. I Unless otherwise noted, all survey meter readings contained in this. .

report include the natural background level of 6 microroentgens per hour. I The elevated readings at ground level ranged from 7 to 60 microroentgen per hour. The waist high reading (1 meter) never exceeded 12 microrcentgen per hour. Natural background was measured at 6 microroentgen per hour at both ground and one meter. Seven separate elevated areas were located, i all in the vicinity of the rat house and instrument shop. Two areas on I the North side of the " Rat House" and " Instrument Shop" respectively measured approximately 3' x 4' and gave ground level readings between 8 and 60 microrcentgen per hour. The remaining five areas were very small (a few inches in diameter) and ranged from 10 to 20 microroentgen per hour.

No solid radioactive objects, such as wood or concrete, were found in the soil. The contamination appears to be evenly distributed in the upper 1 - 2 feet of soil. Liquids used in decentaminating areas or 4 objects appear to have been poured or washed into the soil at these '

seven locations.

4 The placement of lead around the survey instrument allowed only gama radiation emanating beneath the instrument to be detected. Lead cellimated meter readings at the 18" bottom of the 3' x 4' excavation indicated natural background levels. Prior to excavation, this area showed elevated readings _ of 8 to 60 microroentgen per hour. The readings became lower as

, each shovel of dirt was removed.

Soil and core samples analyzed by the University of Hawe.fi e im a germanium-lithium detector and gamma spectroscopy analyces re ca n.I the following cesium 137 concentrations:

Composite sample from 3' x 4' excavation

25.67 pC;'gm 4

Core sample: 4.57 pC1,cm Core sample composite: 24.60 pCi/gm Background sample: 0.42 pCi/gm

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I The samples were also analyzed for cobalt 60 ano no levels above natural background were present.

The surveys of the neighborhood garden plots, tennis and basketball areas, " greenhouse" burial area, and tunnel excavation areas revealed no readings above natural background.  ;

1 Two small non-soil contamination areas were identified by NRC personnel  ;

on wooden shelves located inside the " Instrument Shop" building. These i

" spots" appear to have been spills or leakage of small quantities of radioactive material. These spots exceeded the NRC surface contamination limits. These spots were removed by the licensee. i 1

7. 1987 NRC Decontamination and Radiological Relea'se Criteria. l 1

The NRC criteria for small areas (less than 20 square meters) of soil j contamination is 20 micro R per hour above natural background at 1 meter  ;

above the ground. This is an extremely conservative number and is based  ;

on the " worse case" assumption that a person would be continuously present on the contaminated soil. The highest one meter levels measured at Makiki Park were 4 microroentgens per hour above h ekground.

To use an even more conservative " worse case" example the NRC staff l calculated what the total' radiation dose would be to a child eating one  !

kilogram (about 2 pounds) of the contaminated soil at Makiki Park. This '

would result in a whole body dose to the child of approximately 0.83 millirem and a total dose to the liver of 8.3 millirem. These low doses  ;

can be compared to the dose from one chest X-ray of 14 millirem. A person would have to lie on the ground at the highest Makiki Park reading for more than 347 days before exceeding the NRC's maximum permissible ,

radiation exposure to the general public (i.e., 500 millirem per year). l

8. Summary and Recommendations.

1 Surveys and decontamination of the HSPA facility twelve years ago were I conducted in accordance with NRC regulations and guidelines. Several small areas of soil are present where radiation levels are slightly above natural background, and in no case exceed twice the natural background at one meter above the surface. The radiation ievels pore no hazard to the public even under the most extreme examples of exposure i such as ingesting the soil or continuously living in the park at the

, elevated sites.

] The low levels (approximately 2 mil 11 curies of cesium 137) of radioactive j material properly disposed of by burial on the site should remain undisturbed and pose no health hazard to the public, including workers who are excavating a sewage tunnel beneath the park.

i The two small areas of contamination found by the NRC staff on shelves within the " Instrument Shop" building were decontaminated to! natural background level by HSPA personnel on December 4,10R'-

The NRC staff recommends that no action need be taken with the soil anywhere in Makiki Park. Prior to any future excavation of areas within Makiki Park, it is recommended'that the.NRC and HDOH be consulted regarding any potential disturbance of the original burial sites.

)

James L. Montgomery, Chief i Nuclear Materials Safety .  !

and Safeguards Branch ]

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Enclosures:

Appendices A through E 0

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'.. . Appendix A  !

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GUIDELINES FOR DECONTAMINATION OF FACI'., TIES AND EQUIPMENT  ;

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PRIOR TO RELEASE FOR UNRESTRICTED USE OR TERMINATION, OF LICENSES FOR BYPRODUCT, SOURCE. , ...... l OR SPECIAL NUCLEAR MATERIAL I

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i U.. S. Nuclear Regulatory Comission l Division of Fuel Cycle'and Material Safety j Washington. 0.C. 20555 J

July 1982

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i The instructions in this guise, in conjunction.with Table 1 specify the

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• radionuclides and radiation exposure rate limits which should be used in i

/ decontaniqation and survey of surfaces or premises and equipment prior

.to abandonment'or release for unrestricted use. The limits in Table 1 do not apply to premises, equipment, or scrap containing induced radio-activity for which the radiological considerations pertinent to their one may be different. The. release of such facilities or items from regulatory contro') is considered on'a case-by-case basis.

1. The licensee shall make.a reasonable affort to eliminate residual contamination. ,

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~2 . Radioactivity on equipment or surfaces shall not be covered by paint, plating, or other covering material unless contamination levels, as determined by a survey and documented, are below the limits specified in Table 1 prior to the application of the  ;

covering. A reasonable effort must be.made to minimize the * '

coptamination prior to use of any covering.

3. The radioactivity on the interior surfaces of pipes, drain lines, or ductwork shall be determined by asking measurements at all traps, and other appropriate access points, provided that contam-J ination at these 19 cations is likely to,be representative of-contamination on the interior of the pipes, drain lines, or i

, ductwork. Surfaces of premises, equipment, or scrap which are

. 1.ikely to.be co.a.taminated but are of such size, construction, or i

. location as to make the surface inaccessible for purposes of ~ '

sensurement shall be presumed to be contaminated in excess of

. the limits. -

4. Upon r'equest, the Connission say authorize a licen. tee to relinquish possession or control of premises, equipment, or s: rap having surfaces contaminated with materials in excess of the limits specified.

, This may include, but would not be limited to, sp'!cial circumstances weh as razing of bui.1 dings, transfer of premises to another organization i

continuing work with radioactive materials, or crenversion of facilities to a long-tem storage or standby status. Such requests must:

a. Provide detailed, specific information describing the premises, equipment or scrap, radioactive contaminantss and the nature, extent, and degree of residual surface contamination.

i b. Provide a detailed health and safety analysis which reflects j that the residual. amounts of materials on surface areas, , ,

together with other considerations such as prospective use of

. the preises, equipment or scrap, are unlikely to result in an-unreasonable risk to the health and c.fety of the public.

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5. Prirr to release of premises frr unrestricted use, the licensee

! '. shall make a comprehensive radiation survey which establishes that

. contas.ination is within the limits specified in Table 1. A copy of i

. the survey report shall be filed with the Division of Fuel Cycle

- and Material Safety. USNRC, Washington, D.C. 20555, and also the  ;

Administrator of the NRC Regional Offi:e having jurisdiction. The '

report shou 1( be filed.at least 3D days prior to the planned date  ;

. of abarcdonment. The survey report shal): i

a. Identify the premises. )

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b. Show ?. hat reason'able effort has been made to eliminate ~

residual contamination.

c. Describe the scope of the r;~rvey and general procedures -

followed.

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, . d. State thre findir.gs of the survey in units specified in  !

the ir,struction. ,

Following review of the report, the NRC will consider visiting the facilities to confirm g

the survey.

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, ACCEPTA0LE SURFACE CONTNil mil 0N LEVEL 5 . .

m gipqunb d f ngsgyAOLEbef HUCL10E5a , AVERAGEbcf U-net. U-235. U-236, and associated decay prodvt.ts 5.000 dpa e/100 cm2 . 15.000 dra e/100 cut 1.000 dra e/,100 cm2 ,

Trcaswranics. Ra-226. na-228 -

Th-230. Th-228. Fa-231, 100 dpe/100 cmI 300 dpm/100 cm2 ,20 dpm/100 cm2 Ac-227. 1-125. 1-129 .

Th-nat. Th-232. Sr-90, i 1000.dpe/100 cm2 i

. na-223. Ra-224. U-232. 3-126 3000" dem/100 'cm2 ' 200 dem/100 c 2 1-131. 1-133 Beta-gance emitters (nucIldes with decay modes other than '

alpha emission or spontaneous 5000 dpa sy/100 cm2 15.000 dpm sy/100 cm2 1000 dre /100 cut fission) except Sr-go and others noted above. ,

awhere surface contamination by both alphe- and beta-gemes-weltting nutildes exists, the Ilmits estabelshed for alphe- and Nta-gamme-enf ttin nuclides should apply independently.

bAs used in this table, dpa (dtsintegrations per minute) means the rate of emission by redlooctive meterial as determined by correcting the counts per minute observed by an appropriate detector for background, efficiency. and geometric factort associated with the instrumentation.

CMeasurements of average contaminant should not be averaged over more then 1 square meter. For objects of less surface arte, the eveg

' should be derived for each such object. ,

dfhe maximum contamination level applies to an area of not more then 100 cm2 4

'The amownt of muovable radioactive meterial per 100 cm2 of surface area shov14 ee determined by wiping Utet aroe with dry filter or soft chssrbent paper, applying moderate pressure, and assessing the amount of radioactive meterial on the wipe with an appespriate instrument of 4

known efficiency. When removable contamination on objects of less surface area is determined, the pertinent levels should be reduced 1 proportionally and the entire surface should be wiped. ,

l fihe average and monimum radiation levels associated with surface contamination resulting from beta-gamme emitters should not escoed i

0.2 mrad /hr at 1 cm and 1.0 mrad /hr at I cm. respectively. measured through not more then 7 milligrams per sqvare centimeter of l tstal absorber. ,

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JOHN WAIHEE Governor

Contact:

Bruce Anderson, DON NEWS RELEASE or 54 -4u, Greg Cook, NRC Decenber 2,1987 548-2076 67-35 Dr. John Lewin, Director of Health, today announced that an investigation has been conducted in response to public concern over radioactivity in Makiki Park. "The Department is relieved to learn that no health hazard exists in the park," said Dr. Lewin.

The investigation was conducted by representatives of the State Department of Health and the U.S. Nuclear Regulatory 4

Commission. The NRC is the federal agency responcible for the i licensing and regulation of most uses of radioactive material in Hawaii.

Initial surveys of the park showed slightly elevated levels

); of radioactivity at ground level in several spots in one section of the park. Further investigation disclosed that radioactivity in these spots is below very conservative limits established by the Nuclear Regulatory Commission and does not pose a ris'k to the public.

i The Makiki Neighborhood Board had reported concerns over the

' health risk posed by burial of radioactive material by Hawaiian Sugar Planters Association after an agricultural research station on the site was closed in 1975. The Neighborhood Board expressed particular concern that a sever tunnel project might create a pathway for release of radioactive material from the site.

"After careful investigation, we have no question that the actions taken during decontamination were proper, and that Makiki park is safe for continued unrestric'ted use," said Janes

' L. Montgomery, Branch Chief, Nuclear Materitis Safety and Safeguards for NRC Region V, Walnut Creek, California. "We have no indication or reason to believe that the. radioactive material l buried on the site is anywhere other than where it should be.

The tunneling will not encounter any radjoactive material and is 1

radiologically safe for the workers and the public."

Areas surveyed in the neighborhood garden plots in the park showed no radioactivity above natural background levels.

Vegetables grown in soil on the park will not pose a health hazard.

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NRC inspectors did identify two locations of radioactivity l l

above NRC re' .ase limits inside a locks.d wooden shed at the l park. Die tw spots, each about three inches in diameter, will I be removed by the Hawaiian Sugar Planters Association. Although these spots did exceed NRC limits, they did not pose a risk to the public.

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