ML22307A222
| ML22307A222 | |
| Person / Time | |
|---|---|
| Issue date: | 11/04/2022 |
| From: | Robert Evans NRC/RGN-IV/DRSS/DIOR |
| To: | Vontill B NRC/NMSS/DDUWP/URMDB |
| Evans R | |
| References | |
| Download: ML22307A222 (9) | |
Text
November 4, 2022 MEMORANDUM TO: Bill VonTill, Chief Uranium Recovery and Materials Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards THROUGH:
Gregory G. Warnick, Chief Decommissioning, ISFSI and Operating Reactor Branch Division of Radiological Safety and Security Region IV FROM:
Robert J. Evans, PhD, Senior Health Physicist Decommissioning, ISFSI and Operating Reactor Branch Division of Radiological Safety and Security Region IV
SUBJECT:
BROKEN ARROW LANDFILL SITE VISIT On October 13, 2022, staff from the U.S. Nuclear Regulatory Commissions (NRC) Region IV Office visited the Broken Arrow Landfill site in Broken Arrow, Wagoner County, Oklahoma. The visit was conducted to observe the U.S. Environmental Protection Agencys (EPA) remediation activities at the former landfill. Enclosed to this memorandum is the NRCs trip report for this site visit.
In summary, EPA was conducting work in accordance with its site-specific work plan. At the time of the site visit, EPA was attempting to quantify the amount of buried radioactive wastes by conducting vertical and lateral excavations across the site. Based on the preliminary information gained through these excavations, EPA planned to reassess the scope of the work project.
Enclosure:
NRC Trip Report cc: M. Broderick, ODEQ D. Robertson, EPA Signed by Warnick, Gregory on 11/04/22
SUNSI Review By: RJE ADAMS Yes No Non-Sensitive Sensitive Publicly Available Non-Publicly Available Keyword:
NRC-002 OFFICE DRSS:DIOR BC:DIOR NAME RJEvans GGWarnick SIGNATURE RJE GXW DATE 11/3/22 11/4/22
2 U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket:
Not Applicable Report:
Not Applicable Licensee:
Not Applicable Facility:
Broken Arrow Landfill Site Location:
Kenosha Street, Broken Arrow Wagoner County, Oklahoma Date:
October 13, 2022 Inspector:
Robert J. Evans, PhD, CHP, PE, Senior Health Physicist Decommissioning, ISFSI and Operating Reactor Branch Division of Radiological Safety and Security Region IV Accompanied by:
Troy Johnson, Health Physicist Decommissioning, ISFSI and Operating Reactor Branch Division of Radiological Safety and Security Region IV Approved by:
Gregory G. Warnick, Chief Decommissioning, ISFSI and Operating Reactor Branch Division of Radiological Safety and Security Region IV
Attachment:
Photographs Taken at the Broken Arrow Landfill Site
3 NRC Trip Report
1 Background
The Broken Arrow Landfill site consists of approximately 80 acres and is located in Broken Arrow, Oklahoma. Coal strip mining occurred in the area intermittently between the 1920s through the 1960s. The site was used as a sanitary landfill from 1973-1976. A section of the property (approximately 7.5 acres) in the northeastern corner was later identified to contain radioactive material, primarily thorium-232 and associated radioactive decay products. The origin of the radioactive material is currently unknown.
The site entered the Oklahoma Brownfields program around 2009.
The Oklahoma Department of Environmental Quality notified the NRC of the contaminated property by letter dated October 3, 2019 (Agencywide Documents Access and Management System [ADAMS] Accession No ML19301C323). Attached to the letter were two survey reports, a limited survey that was conducted in 2012 and an expanded survey that was conducted in 2013-2014. The surveys attempted to identify the areas of the property that contained radioactive material.
In August 2021, the State of Oklahoma requested that the U.S. Environmental Protection Agency (EPA) evaluate the site (ML21250A347). EPA conducted site assessments in December 2021 and March 2022. The EPA hosted a public meeting on August 11, 2022, to inform the public about EPAs planned reclamation activities.
EPA Region 6 subsequently issued a removal action memorandum on August 29, 2022.
The memorandum authorized EPA and its contractors to commence with excavation and disposal of the radioactive material. EPA and its contractors started onsite activities during the week of October 3, 2022. The work was scheduled to take approximately 8-10 weeks and would include a final status survey after completion of site remediation.
2 Site Status The 7.5-acre property is relatively flat, and the surface consists primarily of grassland with some areas of brush and woodlands (Figure 1). Based on the results of the December 2021 and March 2022 assessments, EPA estimated that the volume of soil to be excavated and disposed was approximately 1,100 cubic yards. This estimate assumed that the radioactive material would be found at depths of approximately 0.5 feet over a surface area of approximately 1.4 acres. The planned work included excavation of the radioactive material, loading of the material into transport containers, and transporting the material to an authorized disposal site. As noted above, EPA and its contractors planned to conduct a final status survey after completion of the removal action.
The EPA developed a removal assessment report dated April 2022, in part, to help support the removal efforts. The report included a proposed site-specific soil removal action level (in units of picocuries of radioactivity to grams of soil) and an associated scan survey investigation level (in units of counts of radioactivity emissions per minute).
These limits would be used, in part, to guide the remediation activities.
The EPA and its contractor commenced with onsite remediation work during the week of October 3, 2022. The early activities included setting up of four perimeter air samplers to
4 monitor for air particulate radioactivity and industrial dust, constructing boundary fencing, training of workers, and staging of excavation equipment. Lapel air samplers were to be issued to workers (at least one per work crew) to monitor for potential inhalation of radioactive material.
3 Site Observations and Findings The inspector toured the Broken Arrow Landfill site on October 13, 2022. The inspector observed the work in progress and observed radiological measurements using equipment provided by EPA and its contractors (Weston Solutions and Environmental Restoration). The work in progress included various excavations using backhoes to identify the surface area and depth of the buried material. The results of early excavations were mixed but the general trend appeared to be that the radioactive material was buried about 1-foot below the surface and was found to be up to 4-feet deep (Figures 4 and 5).
The inspector observed the air samplers in service (Figure 2) and noted that contractor staff closely monitored the excavation work using calibrated survey instruments. The workers were covering excavated material with plastic sheets if the material was not immediately replaced (Figure 3). The covering was meant to protect the material from the environmental elements including wind and rain. Temporary fencing and barriers were noted around the site, to protect workers and the public from moving equipment, excavations, and excavated material.
At the time of the site visit, the gamma radiation cleanup action level was 27,890 counts per minute (cpm). One excavation near the front entrance measured 116,000 cpm, a second excavation measured 184,000 cpm, and a third excavation measured 200,000 cpm. A fourth excavation near the western boundary contained only landfill debris but no radioactive material. The highest measured site value was reported as 360,000 cpm.
Based on the preliminary investigation results, the EPAs representative indicated that EPA may temporarily suspend work to reassess and update the site work plan and original soil estimates as needed. EPA planned to cover the exposed material and upgrade the site boundary as needed while it reassessed the site work plan.
4 Conclusions In summary, EPA was conducting work in accordance with its site-specific work plan. At the time of the site visit, EPA was attempting to quantify the amount of buried radioactive wastes by conducting vertical and lateral excavations across the site. Based on the preliminary information gained through these excavations, EPA planned to reassess the scope of the work project.
5 Meeting Summary The NRC inspector participated in a safety briefing prior to the site visit. During this meeting, the NRC and EPA discussed topics such as site status and potential physical hazards. The inspector discussed the final site observations with EPA and contractor staff at the conclusion of the onsite visit.
5 6
Persons Contacted D. Robertson, EPA, On-scene Coordinator S. Cheek, Weston Solutions, Inc., Technical Manager
Attachment Figure 1: Broken Arrow Landfill Site with exploratory excavations in progress Figure 2: Air sampling at site perimeter
2 Figure 3: Excavated material covered for protection from environment Figure 4: Exploratory excavation near front entrance to site
3 Figure 5: Exploratory excavation showing soil cover over buried material