ML23125A067

FOIA-2023-000061 - Resp 2 - Final, Agency Records Subject to the Request Are Enclosed, Part 1 of 2

ML23125A067
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Issue date:	04/26/2023
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FOIA-2023-000061
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Text

U.S. NUCLEAR REGULATORY COMMISSION REGION I II Docket Ho.

030-02640 License No.

34-00293-02 Inspection Report No.

030-02640/96002{0NMS) licensee:

Ohio State University Facility:

Location:

Oates:

Inspectors:

1.

2.

Fawcett Site North Star Site

{Both are closed University ra~ioactive materials burial sites)

Both sites are located in Clinton Township, Franklin County, Columbus, OH Hay 6, 1996 G. M. Mccann, Senior ~adtatton Specialist J. E. House, Senior Radiation Specialist Accompanying Personnel: F. Talbot, Ohio Department of Health Approved By:

J. W. McCormick-Barger, Chief Decommissioning Branch r

9607220003 q60712 PDR AOOCK 030026~0 IIES't1 AVAILABLE COPY C

PDR Page 1 of 47

EXECUTIVE

SUMMARY

Ohio rtate University (OSU)

NRC tnspectton Report No. 030-02540/96002(DN"S)

This was a special, announced inspection lo assess the condition of two 10 CfR 20.304 burial sites (North Star and Fawcett Center Sites) by perfirmin~

limited radiological )Urveys and collecting so;1 and water samples 1nd reviewing records pert,nent to the burial sites.

The purpose of th, surveys and collection of samples wa; to determine the current radiological condition of the sites ar,d to determine 1f there were any in;nediate environmuntal concerns associated with the burial sites.

The NRC inspectors determined that the North Star Burial Site was being adequately maintained tnd secured. Add1tion~lly, a stream diversion project was verified to have been complfted (see NRC Report ~o. 030-02640/96001 (ONMS)).

Th Fowcett Center burial site (approximately S acres) was loc*teci east of Olentangy River R~ad ann north of Lane Avenue in Clinton Town~hip, Franklin County, Columbus, Ohio.

Portions of the former bur1tl st te were covered with grass, an asphalt parking lol, and possibly~ portion of the Fawcett Center for lomorrow buflding (OSU alumni center). The *nspectors did not ob~.ervc any s1gns of intrusion, drainage from, or erosion of the s,~e cover.

Tte NRC inspectors' survey measurements and ana1yses of wat~r and so11 ~amples did not identify any immed1ate radiological or environmental r.o,1cern~.

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1.

2.

DETAILS Persons Contacted f* C. Smith, Ph.D.. Assistant Vice President, Office of Environmental Health and Safety ((H&S), OSU

• R. Peterson, Jr., Radiation Safety Officer (RSO). OSU

• M. St. Clair. Environmental Manager, EH&S, OSU Denotes attendance at the NRC entrance meeting on May 6, 199.

1. • Denotes attendance at the telephone call on June 20, 1996, to discuss results of the samples analyzed at the NRC Region Ill office.

Background

A.

8.

North Star SHe The North Star Site was located approximately 250 yards east of NorU Star Avenue, north of lane Avenue 1n Clinton Township, Franklin County, Columbus, Ohio. This former 10 CFR 20.304 buria1 site was used for the di~posal of low-level radioactive waste generated by OSU. The site was surrounded by a 6 to 8 foot high chain link fence topped with barbed wire which was placarded with radiation hazard sions. A stream ran from the northwest to the southeast through the site. The inspectors observed that a stream diversion project which was in progreS$ dur1ng a previous NRC inspect1~n conducted on January 22, 1996, (NRC Report No.

02640/9600l(DNMS)) had been co~pleted.

The old stream bed contained only small quantities of stan1ing water.

The NRC identified a concern regarding the North Star Burial Site dur1ng a Mar~h 20*2S. 199S, inspection (NRC Report No. 030-02640/95u0l(ORSS)).

In response to the NRC's concern, OSU contracted with two vendor consulting services to prepare the Site Characterjzatfon Plan for the North Star Sjte, C11nton Towns~1p~ franr.1in County, Oh10, dated September 22, J9g6, Fawcett Center Site The OSU Fawcett (enter for Tomorrow building was located east of Ol entangy River Road and north of Lane Avenue in Clinton lownship, Franklin County, Columbus;, Ohio.

In response to an NRC: request, OSU conducted a review of unhersily record~ and determined that porticns of the property currently occupied by the Fawcett Center for Tomorrow were previously used by OSU for 10 CFR 20. 304 burials of laboratory and research rad1oacti\ wastes (m1d 1950s through the earl y 1960s) wh1c conlained lowt levels of byproduct materials.

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3.

The burf 1 site consisted of approxinately S acres.

B15ed on a review of rial photographs and past records, the burial ar a was expected t be located undP.r the east wing of the Fawcett Center, an adjo1n1n east parking area and an adjoining east lawn of the Fawcett Center. Architectural and campus drawings tndir.ated that tt,e site was covered to a depth of approximately 3 to 10 meters with fill material (locally obtained clay and other soils) prior to construction of the Fawcett Cunter for Tomorrow.

Fo11ow1ng the discovery of the burial site, OSU perform d surface radiation surveys and identified no rad;ation 1 vels above background. Additionally, OSU contracted wtth two vendor consultants. These two companies prepared the Workp11n for the

£v1lu1t1on of Current Rad1o1ogfc,1/Environmenta1 Conditions for tht Fawcett Site, Clinton Township, Franklin County. Oh1o for OSU.

The purpose of OSU's evaluations are to identify the location of the burial areas, determine the nature of any releases of radioactive contaminants at the site, evaluate the potential migration pathways, characterize const1tuenls in migration pathways. and determine if the pres~nce of radioactive or hazardous materials poses a threat to human health and the environment.

lhe OSU staff fndicated to the NRC inspectors that OSU intends to start the evaluati~ns and sample collection in June or July 1996.

Independent Measurements The NRC inspectors conducted independent radiological measurements. arid collected soil and water samples in and around the two former burial sites. The radiation survey instrumentation used to conduct the surveys is ident1fied in Table l.

The NRC inspectors collected monitoring well water samples at the North Star Site. and monitoring well water samples and so1l samples fro the Fawcett Center Site. lhese samples were sent lo the NRC Region Ill laboratory for analyses.

survey Results and Laboratory Analyses The NRC inspectors conducted direct radiation survey measurements for beta and gamma radiaHon. lh inspectors did not ident1fy any radiation levels grater than ambient bac ground levels for the OSU campus.

Gamma spectroscopy analyses were performed on all samples and gross beta analyses were performed on the water samples 1n the Region III laboratory. lhe sample analyses results were found to be at the analytical counting system's minimal detectable activity and thus no immediate rad:tological concerns were identified ith the two burial sites.

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Page 4 of 47

s.

hit Meeting The pr liminary inspection findings and results of the RC an1lyses of water and soil samples collected during the May 6, 1996. inspection were discussed during a June 20, 1996. telep'1one conversation between Or.

Cecil Smith and Mr. Mccann.

Attachments: Table 1 - Sur ey Instrumentation Table 2 - Survey Data s

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Instrument Model No.

Ludlum 19 Ludlum 3

TABLE 1 survey Instruments Serial No.

Detector (Typt/Model) 014809 Internal Nal 045632 44-9 Last Calibration 11/ 17/ 95 08/ 14/ 95 The above meters were serviced and calibrated on an annual basis.

Cal:brations were performed with National Bureau of Standards (NBS) traceable sources. Daily source checks were performed during the inspection to verify detector constancy. The background for the Ludlum Model 3 averaged 45 counts per minute. The Ludlum Model 19 meter varied from 4 to S microroentgens per t.our bac ground radiation {µR/h} (l.0 to 1.6 nanocoulombs per kilogram per hour (Nc/kg/h)).

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Ohio State University {OSU)

NRC Inspection Report No. 030-02640/9~002{DN~S)

TABLE 2 Survey Data beta location/Oescr1ption analys fs oCi/ml Fawcett Cefiter Site Monitoring Well No. I (middle of well)

< MOAl ra~cett Center Site Monitoring Well

< MDAl No. l (bottom of well)

Fawcett Center Site Monitoring Well No. 2 (collected from middle of well)

< MOAl Fawcett Center Sile Monitoring Well No. 3 (collected from middle of well)

< MDAl Soil Samples from Fawcett Center Site Sofl Samoles from Fawcett Center S1te Soil Samoles from Fawcett Center S1te So11 Samples from Fawcett Center Site North Star Sile Monitoring Well No. 1

< MDA1 (bottom of well)

North Star Site Monitoring Wel, No. l

< MDAJ (middle of well)

North Star Site Monitoring Well No. 2

< MDAl (bottom of well)

North Star Site Monitoring Well No. 2

< HDAl (middle of well}

North Star Site Monitoring Well No. 3

< MOAl (bottom of well)

North Star Site Mon1tor ing ell No. 3

< HDAl (middle of well)

North Star Site Monitoring Well No. 4

< MOAl (bottom of well)

North Star Site. Monitoring Well No. 4

< MDAl (middle of well) r gamma analysis oC1 /ml oCi/g

< MDA2

< MDA2

< t~DA2

< MOA.'

< MOAJ

< MDA3

< MOA3

< MOA3

< MOA2

< MOAZ

< MDA2

< MOA2

< MDA2

< MDA2

< MOA2

< MOAZ l

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Ohto State University (OSU)

NRC Inipection Report No. 030-02640/96002(DNMS)

NOT£:

1.

The following isotopes were chosen for gamma spectroscopy analyses bas~d on half-lives of the radioactive materials w.th the greatest polenthl for existing at the s1te: Cs-137. Tc-99, fr-90, C-14, and Pm-147

2.

Minimal Detectable Activity (MOA): MOAl was based on liquid scintillation analysis and MDA2 and HDA3 were based on gamma analysis. The MDAs were derived for the isotopes tndtc~ted below:

MDAl (H-3, C-14, Tc-99) 1 pCi /ml. (Sr-90) 0.5 pCi/ml MDA2 (Cs-137) 0.2 pCi/ ml MDA3 (Cs-137) 0.2 pCi/g 2

BEST AVAILABLE COPY Page 8 of 47

Or. C cfl R. Smith, Ph.O Assistant Vic 0 rcsfd nt

£nvironm rtal ~?alth A Saf ty lhe Ohio Stat Univ rsity 1314 'inn r Rod, Room 210 Columbus, OH 43212-1168 0 ar Or. ~mith:

March 7, 1997 lhis is to,c nowledg our r ccipt of your 1 tter, with attachm nts, d led January 15. 1997, in which your soonded to our letter of December 20, 1996, and p,-ovided information cone rning fo, er lo -lev 1 radioactive wast buri 1 sites.

A review of th information you providPd wtl~ be performed and an evaluation conducted to d ter 1n wh ther any further inforr.at1on,s r qu1red. and whether any addit1onal Agency act1on may be necessary.

You will be i11formPrl of the results of our revi wand evaluation.

our coop~,ation w1th us is appreciated.

License No.

34-00293-02 Docket No.

030-02640 cc:

H. Astwood,~ SS J. H1c ey, NMSS PUBU C ( I ( 07)

OOCUMtNT r AME; A:\0HIO.AO' S 1 ncer 1 y, Orfginal Sfgr d by

• cCann or B. L. Jorg nsen, Chief Oeconvn1ss1on1ng 8ranch

,. rM* I... ~,.,, *** 41t<<..-.f!I tlHthe l * '" lM N, '<... - t.., * *u~evt., ** c..,~, *(* * (

OFFICE Rt II RI 11 ANE McCann:ib J

n../(IV DATE ft 0)/97 0

l 9703110030 PO 970307 C

ADOCK 03002640 PDR iTi A UILABtE [OPY

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• H

• l*

OHIO SIAlE U IVERSITY J.muar) 15. :t 97 1r B.L.. Jorgen1;cn. Ch1 11f D l'OnlrtllS!-.luntng Br,111 h Oftur of Ln\lronmrntal Hulth ;and afrt, U.S

'uclca1 Regulalnt") Co111m1~ wn. Region Ill 80 I Wam:nw11lc Ro,1d Lisle. IL 60532-4 ~51 t 14 Kinn ar Road lfoom 210 Columhm, 0114,212 1 lNi l'ho11~ h 14 ~92. 1284 I A t>14 292 1>404 RE:

l>od<d ~o. OJ0-026-'0. Dt>commhsionin~ of Liccns d l.LRW Burial Site">

(k u M1. forgcn,cn:

The Ohw Stnlc lJniH'f!o.ll) has re, IC\\\\ ed th 1-Crc;;cn111g 1,;11tcna rn, fudcd m thl." NRI' Jtra,1t I, 1 ed1111, "' Pou11mr S, rani,,f! M, 1/iodoloi;\ 1)1 A Ht" 1!: !'nor umd Bw 1,11\ oj Radwaun, Wrl\lt Awlu111:.,*cl u11dn Former/() CFR !O 304 a,,ug_ge~red 111 )i)Ur ktlcr dawd Dec ember 20. I 99<> Pei ) our requc!-.t m th 1, letter. ou, pl:ln, fn, the Fa,\ 1,;l!II Cenk 1

• od 'orth Star Rc.l.id,11cs a,e dc,c-11hcd Ill Att *. 11.hm,*nl I and 2 to this letter.

upportmg dr~*u111e11tatmn 111dudc~ rnuiolog1c.tl ch,1r<1cten1.atwn 111lorm,1tmn and us intcrpn:t, 110n q~rlc,rmcd h: Au,1cr & A,,cK:1atcs1. ~rte geological and h:dn1gcvk1gical l'h,1ral1N11.11*on tpcrlorJllt'd h\ Sharp & As,,>e1n1t*,),md,tn.1...,c:"mcn1 ul tltt* e !o.lh!!\ fo, contonnance to NRC 1c::-n111g c111cna pcrl rmcd i11dcpendc111l) h) u\ler & A,,oc1a1c,11, I b) \1t.

An~h*r.:\\\\ K,11:nn, C'IIP, l II our Luff.

Ba ed on 111h.,rnm11on ol'itaincd during,11e 1m esugaunn a, ti\ 11,e, and c,tlculat1ons ~a,cd on that data the Ohio State l nr\ cr,lt) f111ch th,t the LI.KW bur 1al,11e loc.11cd,11 Nntth Star Ruad and at tht* Fnwtctl C't:ntc1 1<'1 Tomoarc,v. m cl the tritena :-('I fouh rn the 1l'lc re need 'RC 81,1ndl 1 cduuc~tl Pu 1110n f r 1elea,c of thl*,c itc*, for unrestricted use.

Ac,.;nrd,ngl). the l llt\('1,it) rrqucs,.. thnt the,c,ue, he rc.>rno\t*d horn NR.. 1aten.il, Li ~n,e 34-0()()~9 02 anc.l from futurt: rcgulu11on h) the NRC Plea.!!c lrd f1l'c I() l:Ont 1c1 me. 1r. Robert Pctcr),on. or 11. 1\nd1c,~ Kamm. Clf P hould

)OU hn,e,lll) lurthcr quc,tll'II regmdmg this lctk'I or ulta~ nmcm,

'IC* s*

2

<~e~ rl Snuth, Dr. P J l.

A !11),Ulnl V1 c Prt':'11cien1 hm 1ronmcru.,I Hrulth.md * :1let) 9703110050 970307 POR AOOCK 03002640 C

PDR Bl~T AVAltABt! [OPY

Tl \ CllMENT 1: F \\\\'CETT Cl: 'Tf.R FOR I OMORRO\~ Sl'I E l"inH~tt Ct*nter

.1111pJ111g pn,g, tlll.,.. a, on<luctcd at tht Fu~ n*tt Cl*ntc:r Ju1ing I l)C 6 lO dt!le1 mme the 11all.J1c ctnd k al1nn of\\\\ aste 11rntcn!ll, tHH;ite a11d the po,,1bl preacJ of rnd1{luc1he 1..11 1.:ht'lllll'ttl < manunaunn lwm 1h1 s11c lo the cm 1ronment. No sample:-. oOLn:ned indK*.ttt'd the p1e,cm:c of r<1d1<)acthe contaminat10n ~m-or olf-qtc ore,ampks lflUl(.'Ull'd the ptc,cn l' of cla~ la) er that were mte, pr ctcd to rep1c-.rnt the landfill cap and ellht*r a hot1om liner or 11:uur.t! clay dt*po It Arca, th )ught to cont~I11 r hcmrcal 01 rw.iioaCll\'e w, "II." \.\.Cft* 1.Cnc1cd "'1th upprrnumatd) l0'-20' ot clean 1111 matert,tl:,, trnc111crato1 ash, 1:on._t,,1ct1on dt!ht is. e1c.)

lite csurnatl."-<.I dn... c lrom huned rad1uuct1\t' 111l1terial t tlu, Ile could not he calrnlatc:d htd1u,e l\t' ev*dl*n~c of radtnactl\ c n1.1tcnal W3s lound and there 1s no record oi rnd1oacll\C material disix1,al at tht:-. Ile Th*' U1 :,~1,it) ha!I m,talled six ground\\\\atc.:r mo111tc,11ng \\\\lcll, on tlm,itc:. t\\\\ i1 up-gradt!!llt anu four tlo" n*grad1cnt nt the w a,tc 01,r,.,t ari.:J.'-.

I he 01111, State lJnl\ CNty intends lO take the tollo\\\\ ing a t,nns "ith 1c,f>ect to the F,t\\\\ccll Ccntc-1 sue*

Rene" da) ca,, <Her portion" of,itc Ren~wmg eroded porunm, ot the c;-)(1,,ing cap v.uh ct mpactcd lay will m1111111i1c mtiltr,1t10n h) ram w t1c1, rcdurrng the potcnti.tl fcir,..t,111.11111nam, hl lca\'c th1 "itc. A ~oo CO\'er "1ll 11Mmt.un the clay c.1p ugamst ern,ion *1 hetl'.trc {IOI)., few. kx.*ntions \\\\here lht acuon 1'\U) be rN.jUircd.

l\lonitor lhe "itc 1 *1c1e arc, urrcntl) 111nc mon,wnng \\\\ells at th 1, '-IIC.

II "ell.,ppc~r tot enctrutc to the uppcrmo!.t g1ou11dwatcr iHJutfcr Al le:ht l\l,O upgradit*nt nu all do\\\\ ngradicnt \,ell,

,tl(lulJ he momtorcJ tor grc,... s ~la ratl1oa1.:lh it). VOC, un<.I.. VO fl,r m le,t-.t O )Cur<. to 1,enfy \\\\u,ste.111d !'>lie sr.1bllit) Snmphng,twul<.I he perft*rnwd cr111-un11u..ill) fur a penod of 11,e )t*ar and annuull) thea*aftcr In Dtkl1tion, the,itc hn:.1ltl be \I uull) in... pcctcd at lea t annuull) lc.1r tlus,ame time penod V,,uul lll"flC tton,. uo,; a rnin11m1m.,houl<.I note the tollCl\'tlllg:

Cup 111teg1 ii) /e\ idcn c 111 cr<.N c1n E~tdenc~ t)f hum.m IJ\lrll ton E\ 1dcnce of u111111al n II\ ity An) nnal) w.*al rc1,ult-. that exi.:ecd I 00 pCi/1 gro-., bela. 'II\ II} !-,huuld be tunhcr.tnaly ed tu dc1e1mine r )tcnt,al do~e due to ctnnb:111,g this \\\\.iter 1he EP MCL lor ' II 1, 20.000 p< tll l*Hl Cf*K 141 15) und.1 14C concc:ntr.111on ol al)ou15G() l'Ct/1 \\\\111 ghc u d0,t' of upprox1matcl) 4 nuem/)1, the EPA t,111dard 11t11cd m4 )f"fR 141 lh ~onthc111u !ides lrl,,:ely 10 h \C heen ch,pc.1 ed t)I 11 th1, 1'1te hu,c., ulliL* \:IHI) long h,rll-hlL* to rt.:nH1111 BEST AVAILABLE COPY

,-,age 11 of 47

1 l1\c at tl11 llllll' I h,.._,c,ccnmg le,cl I al,o uff1oc11tl) grcatc1 th.in h.1 kground lc,cl to.,,oid lal,c po,111\e rc,uh U.t'~trkt l\l'aHltion acth itie'i ut thi~,itc I n 11,0,d poknll,tl r uturc prohlems. c u, t1on al th1 -.ue liciuld he 1c tnct *<l to drpth ol less 1h,lll Ii, e I eel ht: le)\\\\ 1.: urrent gr.u:.lc ( the '-h,1110,\ t,t ft II th1d:11e s "':i, thh depth)

Any ex 1,a11011 pt."rlormcd at th,,,Ile hould pro t'Cu onl).tiler u>n,ullation ~llh FHS I he Olm1 State l 111,c, it) mlcnd, to pc, lorm no remedial ::ictilm,u 1h1 site bet:au,c there 1s 110 anti 1pau.*d do~ to tht* punhr or the ctn 1wn111ent tl*,uhmg lwm lhl~,,... 111 >l rurr\.'nl cond1t1011. Accon.hngl). thl* n,l.~,t,,t 1a1c<l \.\ 11h l!\1.:,1\ ahem and 1r.111,pon.n1011 of ma1enal lrom thn,,ue c 1:ccd tho'-C Pl the l'llle al prt.*,ent BEST A VAIUBLE COPY

\

Pae12 of47

ATTACtlMFN'J' 2: SORTH STAk ROA l> !,ITE North Star Road A,mnplmg pmgr,1m \\\\u conclu led al lhc North Su.tr Road site du1rng 19~6 10 de1crrnmt*

the nature md loi.;auon of Y.. l tc n1ate11als un*'-lll' ml the JX' s1bk,p1c.1cl ot r.ll.lto,1 11,c oi chenucal comanunauon frnm 1h1 sttl' to the en, m.,11mcn1. S;.1mplc, obt.11nt.:d 1nd1ca11.. *d the prl' cn~l' ol 1H.. ;1d 14 in nee-, of expcc1cd hack *round 11.'.,cl at(, hunul ltenchc~.

M,umum nuclide con cntrat1l1n, \\\\ere 42 1 C1/gm t'H).1nd 79 p "i/gm (14Cl. 0,11..

sample \.\.t'- tound \\\\ ith 14C ac:11\:II} ol 440 p 1/gm; tlu :-.ample" a a d,~uctc pH*ce ol doth,mJ \\\\,Is 1101 (;on~tdcrcd 1cprc~cm,1tl\e of,011 contamtnat1on at tlw, loc11t1on F~1u1 ol th *,e 1<11. at ton, cn111t..1de \\\\.llh l0<.*a11<m:-. ol de\ :.sled t hcrn,cal contam111,1twn { toluene I

,md trenches no1cd 1t1 contain hqu1d,<.*1ntill:.11ien,mt, I he,t11na1cd dose Imm hum:J iad10,1d1,e m,1tc11al.it ttu, -.He wa, cakulatcd tndepcndcmly hy r-\u\1er & A s,x:1ates 1111d hy the Ohm ~lJlC lJnh*cr,il). The LUkulallnm, performed D) Au,1cr & A ")Ci.Jtc, arc dt*-.c.11lxd Ill thl' '"D1,cussi<m or Re,ults/Surnrn.U') **,cction of their rcpoll. 1 hr cakulatil,th pcrh.>rrncd b} the Ohio Stale lJ111, CP*ll) urc cl1,cu.,,ctl in 1'\t!ad1mt'nt 3 ICl tl11 document. lfoth,ct-. of calcul,u1on.,

111d1ca1e chat the maximum e t1matcd do-,<', t tl,i,,11e i, le.. !, than IO mrcml) 1.

l'hr lll\Cr 11) ha'- 111'1.tllcd lour ground..,atl'r rnl)nttu11ng wdt-. 11n th,,,te,,,ne. up gradient and thn:e dov, n-grJd1cnt ol the'-',1,te d1spo,~d are.1,. S, mpk",,btarncd ttl thc~c

\.\ell ind1c.,tc lhc1e 1s lttcly nn rnd1rMl'll\c mu1c1rnl IH,m ttm,uc p,c-.enl in grountl\.\,1te1.

Ont*,umpk* I 1W 4. do,H1grad1ent 1nd1l:,1tcd the pn:,cnt*e ct etc, ated It-, cl-. ol r:rn,, ~ta

.11..:ll\ tty ( I HJ pC' t/1) 'l h,,,ample w,1 fun her arn.1ly7ed, ia gamma 'f>t~clro:,\;opy "here narurall)*l>\:Cllrrlng wd1<1act1,c 1,01opc, v.cr~ 1dcm11led *" corHnhuung fll(h,l ot 1h1, 1c11, II). Borchcile : ;:* ~: th, locallnn,ugge!lt the prc,cncc tit loo, tu1111l~d pom~s,uin-rirh du)' and rh!-t, "hich ma} contnhute tl the~c H.*,ults. 'fh" h.:,cl of 1t.:ti,tty i, le,, 1han the ~lln1111um Dclt:l.:'t:.ihle Acll\ II) ll>1 111 (200 pC1/ll, bur trll1un1,., nor a hkt*I} contdbutoi to th1, rc.,J1ng becau,c the g1<"i,.1lphu/hct,1 un,d)-.ts v.a pcrlorm~d h) ltr I e,aporatrng the,an,ple to Ul)nc" Trun,m 1, u,uall} prc,ent a, 11 l'O 1t11u,11cd,\atcn a11d i <.Jrhcn oft h\: thi... methodology. S1m1lurl~. 1 C,, u.-.uull) p,e-.cnt a!-1 d1s:-1ohe<l CO.: and 1, not u,u.tll} noted tn rro" tx:1,1 unal),e-.: ot th,~ l}f')C. In acldi11nn. the an,il) tic 11 resuh~ tor '"c md1cuted a '-onc:<.'nt,aunn ol le~-. than thl' ~1DA ul 10 pC1/I. rnakmg H,It\ unl1kcl)

C"l)nmhu1u1 to the noted elt~,. led gw, bt*ia radi.111011 kH!f-..

A':.. th,~,nt.* meets the NI< crttr11u for unrc,mcte'-1 u,c a., defined in the 'RC Bumch I r111111ml Po\it1011" Sc1e1*11111i: Me1hodolog, f,11 A \\\\l,w,g /1110, Lar,c/ R111wl\ oj Rmlww r11, \\\\'mu* At11Jw11:.< d w1dc*1 f"otma /0 <TR~() 30.../, the 1a hl1log1cal p<1!1ling~ at th1,,ite ma, he remo\t'-<l and the,uc rcmo, cd from NRC 1,uenal, L11.:cn-.e J4*' 1()293-02 BHT AVAILABtE COPY u~~ 3 of 47

Although no lurther a t1ll) \ ohmt 111)y 111tcnd, to 1ai,,:c llH' I ollo\\\\ rn,,tctton, Fill in d~tch and im,tulJ cla) cup o, er sitl' l*1lltng in the urmnagc ditch runnrng through thu,,,tc v. 111 rcclun* the p1i,,,,1h1hty ol tunhcr ew*.1on fl{lm tlm ource.

.1pp111

• lhc site \\\\Jlh 1.:cnnpactcd la) "di 111111nnizc m11ltrn11on hy r,1111 ".ttcr. lunhc, reducing tbe potentii.41 tor contummani 10 il',l\C tht!, !>IIC A,(,d o\c.:r \\\\ ill rmunurn1 the ch1) up agrun1o;1 ero,1011 lonilor th<',it There :uc cu111:ml~ loui,hall(iv. moni1,,11ng ~elb in,tullcJ near thts ~it(* Ont! udd1Ul11Htl

\I.ell \1.111 he m,talled th.it pe11etrn1c-. to the v..,tcr l,thlc. Thc,c \H*lls.,.:!I be monttorcd lot gro.. s beta r..id1oacth ll), voe. anu S\'OC tor,ll ka,t 50 )'l~ar, to Hrtl) \\\\:1-.tc und,itc tabtlny Sampling~ Ill ht' pcrlonncd cnu-annually 101 a,,cnu I ol ta, c year!\ anu

.innuall) 1hc1~afte1 In,1ddtlmn. the sm* ~111 be q,ually 1rn,pcctcd,1l k*ast annuall} l<>r 1111.. s,ttnt' 111nc p,*11u<l. Visual 111,pcct1r*n:-... 1,.1 1111nimum, ~ill note the f,)IIO\\\\ mg:

Cap mk gnl~ fl", tdcn(c ol cn.Nllfl b 1dcncc ot human 1ntrus1on I., 1dence of.i111111ul dt\,ry Cont111umg d,,er i<>n ol,urfacc "'.tll'r around the,Ile n: a11al)ltlal rL'sult, that l'\Cccd 100 I' tll gro,~ bct,1.11;f1,11y lai-. mcasu1cd on a lit,tuid

,c111t11l.111 111.:vunter "1th.,,., H.le hctn "rndov. I should tx* furthc1 nal\,ed to dc1ern11nc polcntrnl <In ~ due h) dunking 1h1 \\\\.itcr. 'I he l:PJ\ M L for ~II, -0.tX>O ~,Cr/I (40 Ct R 141 15) und u 1.tC co111..t*rnra11on t>I ahoul 5<>0 p 'ill,.. ill gr,c a do,c ol uppturnnatcly 4 rnn.*tnl) r. the l:PA,t,,ndard nokd in 40 CFR 141. 16 'o c1the1 nuclide, hkcl) to ha\C hccn d1,poscd l at tht site lrn\C a,ulhlicnll) long hnll-lilC' to rcm.1111 ad,-.c ut thh ttme 1 t11 creenrng lc-.cl,.,,tho suflil'icntl) greatt.'f thun bad:gr<1um.l li:,cl"' to n,o,d fol,e

,tlarm-.

Rt!,frk t ~'\C11\ ation acth ities at this ~ite

• r o a, m I po1cnt1al tutu re pH,ok*rn!>, t>x1.:a\/Ulton ut this site" 111 be 1c:M1ctctl to dc:pth~ ol lc:!.s than t\\\\O feet below currcm grade (the,h,,llov.e t wnste lound "'a' m 1,kpth {If 2'8"1 1~ 1;U\utton, perfmrncd ~t thi-. site '"II proceed 0111~ attc, con ult.111011 "rth U {S.

Rau1olog1t,tl p<Ntng, :-.houl<I he 11.:m(ned 1tom the tcnC'c at th" slle.

1'h1.: Ohio *1me l 111,crsll) 1r11tmd, to perform no remedial a*-l11111 at tht!o. :-.1tc be.tlt-..C there

,, lt.1\\\\ a111ic1patcd do,c I< 10 mrcm/) r I to the puhh rn lhe em 1ron111cnt rc-.ultmg trorn the

,11c In 11, currctll und1t1,>n Al'curumgl), the 11,k, u,,cK*wwd with cxca\.1111111 and tran,pMlalll)ll < f material from 1h1.. site cxccetl those ol the 11e ut ptescnt BEST AVAILABLE COPY

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Pae14of47

ATl'A<'HMENT 3: DOSE.Al.Cl L\'I I08S R,1d1n11un d<1s(', l the North Srnr Roa I,,te Y.crr. l:alculatcgvfi11 AHt'\WI~ 1'1101 Lcmd /Ju, wl\ of N,1dio11<.t1H \\\\'cl\lt' 11tlio1 i:,rd wuler f om11 r 10 CFH 20.304 Additional calculation, Y.cre pcrlonnrd h} Auxh:r & A,,o<.*rnt,;, tor thl' re,1dential u,l' -.cc11.u10 usmg the Re,R,1d t:omputcr (l1de. All rul uluuom, pcrlormcd mdu:atc,t m,1xirnu111 )Carl) llo~c lll Ir, th<1n 10 mremf}t. The do~e calcula1101h pcrlo1111c<l b) Au>..1er & A s<X'tatcs url.' mt'luck<l in their report (cnclo-.cd),ind will nN be repeated h~re. *1 he {h1se calculm11m, pcrt(,rmcd hy the Oh,o Sime IJ111wr,11. urc,,., folio\\\\ :

Step I hac.:th it~ im cntor) ):

l"i:o r~*u)rd '- pa,1,1~1iv111c~ at thl: 'onh Stal,11e- :ire av:.11lahk. *1 hi.' Ohio Stale l nt\err1ty c t1111a11.*-.. the 1m.1l u ti, 11\ buried ul tlrn. Ile a~ rolll,...,,;

t\ H rn1,;* 1mc/1d1, tiltct ntrntio11 /01 thm" \tm1ple\ g,,*m, r rlum ha, kgro1111ti {1'1,*/\ *

'H = 9 pC1/gm (n=

• o = 13.5 pC1/g111) 14C = ~ I 3 pC1/gni I n=32, o = 7'6.9 p "'i/gm l H,n\ cc1,zta111,d in hll\tt rruuhe\ *

= 02 7 It =.. b.;, IO cm tSh.,rp 6; A-,-.t tuk', 1cpon1

~

~.,

,1 = 1.6 gmfl;m f = 4.2x IO" gm, ot,011 I otal 1111, Jut, c t11Ct!tlfl a1t,,,r 011 \itt'.

1H = 3 1 9x I 07 p.. 1 = 9 9 µC1 1'C = 8 95 I 07 pC1 = 89.5 i1C1 BEST AVAILABLE COPY Page 15 of 47

Step 2 ldMt' from ~round\\\\alt't ):

L ing the l kul 1tcd !>He! ra l10.,1.11\ll) 111,1.::ntof"} 110111.._ lep 1 ab,nc1,md the nh:lhl'<lolog} mi;nt1uncd Ill 1hc NRC 81.tnth 'J'cdu11 ul Pos1IH>n pro'1<.k, thc:,nlln\\\\tng:

• uclidt* drinkinJ! \\\\al~r acli~it) rnnct*ntration tµCi/ml) 11 4.38~ JO 7 14C

~ 84x IO 10 CFR 20 J>p. li

~aim* (µCi/ml)

I\ 10 '

~IO j cakulatt*d dosl' from drinkin~ \\\\Ult-r (mrt:m) 0022 0.4::!

'] he t*qua11on u,ed to, kulnlt* do,L' !' th t p,n, idcd on p,1gc 6 ol the 'RC B1anch

'I cdmacal l'l>'>tllon C µ< "",., 50mtPm I, r

=

\\\\ here X 1, the *. umual rudrnuon du,c.

1, 1hc nud1dc ClHIC'CJllr.111,.m 111 "l'il. and B 1s lhc

\,1lul' g1,cn m Append,~ B. Table:~. ulumn 2 t*I IU Cl*R _o.

t mg tht',1s,umpt*ons lrurn ~h.'P I (,,h,~h arc lO!lscr, a11,c) and the mctho<loll,gy outlinc<l in the I RC Branch lcchnicul 1'l)~111on l,,h, h,.., * !so, nscnau,e}. the: radi.111011 Ulhe fwrn dru1krng "'atcr 1:. mud1 k, 1han 100 nucm/),

BES'I1 AVAILABLE {jOPY Page 16 of 47

Stt>J> J (exhumation com rntration J:

T'A o cal ulaunn \\\\ ct c-pcd 01 med ten th1:-. tep,.. ~un,mg a, c1,1gc soil ruumnucltuc-l:01H:e11trat I011" <u'- de, r1hetl rn, tcp I J ud :.b umIng u homogcncciu-. m1xu11,* comammg the maximum 'Ii und I C con entr.it1on" nuu.*tl lnl'ludcd tor cc.1mp.,ri... 0111-. the (hhC cal ulatc-d ny Auxier & As o 1alc m their rcrort 1u1t chcd1 *1 hL' 10ml l.1kula1ed uctl\H) c.:oncl 111niuon \\\\ a, <11, Hird hy four Ill acrn,dancc "1th guid.10 e 1mn 1ded 111 th1: NRC' Brnnch Tel:hntcnl Pu,111011 tn. coc11t for d1luuon "uh C{I\ er rnat~raal and ch:.in

( urwundmg,OIi Nudide J/.a !-.Oil

~ l IU G 15f H~

OS c.akulatl'd A&:A l'akulated acthit)

ApJ>, H,*alul' do~* from do e from conctnlration exhumation

~xhumation

(µCi/mil lµ('i/m))

(mremJ (mrt!m) 4 Mx io-<*

U.14 010 H.,f

.~.l"iU\ JU I

414,10 ° 0.61 H1111u l.o8x 1(1

(

11\t' 850xlo"

_\<, ox I 0--0 348 2 21

"'c 111,0 I 7<., 10 4

'6 ox 10-<>

719 1 h1.* l!qu,1t1on u,~d 1(1 c.1k*tl,1te d,, e I th,11 pro, 1dc-d on page 7 of the RC Bmnd1 re hmcul Po:-.11mn Where X,, the unnual rnc.hallon do,c. C 1, the nudidc.: con cn1ra11on m,,,ti, and 8 1 the

, due g1,cn 111.Nl K *G 15C.X), T 1hlr 8-2.

,rng the a.,,urnptl1_1ns lrnm *1ep t 1"l11ch.ire tOrN*rvau,e) and the mcllwdolog) outlined in the. 'RC B1a11ch Tcd1111cal Po-.11mn l\\\\ h1ch i... aboconi.c1\'at1,c), the rad1a1it111 doc 1ro111 drinking \\\\,1tcr 1s mu~h ll*, than 100 mrcm/)1 undc1 c,cn thl! 1110 I conscf\ut1,c nucllck con ~ntrutu n -.u.-n 110-.

HE~'f AVAILABLE COPY

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ugust 7, 1 7 U JCT "rl ~ LIN SS ULE NOTIFIC TION in o

Inf or n to arm,

r dfol t

Augu t I pl

\

ff, r M C r n, of mv tlon 1h Augu l

n, I y

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~m tot Should vou h V l ( 30) 82 98 n Qu 1

d ng th bo pl cont ct Mr M1

, or Mr Bt g n n t IGS0) 829 61 Lie n No o~c, No 34 002 3 02 030 02 40 C

J M d r, RIii PUBLIC (IE 07)

DOCUMENT NAM

• A.\OSU.C NAME OAlE Ori tna1 Sign d by Rov J. C n no, Act,ng 01, c10, D1 1 on ot Nucl

, M l 11 I S t Iv I II (I ll I 1'11111 111 McC t\n r

Ha re h 2

1998 BEST AVAILABLE COPY Or C cU Sm th Au SI nt 1,c.p, Sid nt En ronm ntal Heal h and Safety The Otuo State Uruv r,ty 1341 nn

, Road Columbus OH o43212*1168 SUBJECT D ar Dr Smith 10 CFR 20 304 LANO BURIALS AT THE OHIO STATE UN1VERSITY S FAWCETT CENTER AND NORTH STAR SITES This r f rs to your Janu ry 18, 1997, and October 27, 1 Q97 subm,ttals 1n r sponse to NRC Inform ton Not c S.7, ~RECORD l'~t.:.EPING, DECOMMISSIONING NOTIFICATfONS FOR DISPOSALS OF RADIOACTIVE WASTE BY LAND BURIAL AUTHORIZED UNDER FORMER 10 CFR 20 304, 20 302, ANO CURRENT 20 2002" Wtt have r vi d your a essmert regarding 1ho t-unal sites, nd have concluded that the potential dose which could result from th se past burials,s below th t~RC dose hmti for unr,tncted releas n s m,t 11 poc1f1ed In 10 CFR Part 20, Subpart E

• Rad1olog1cal Cnten, lor LJcens Torm nation Our conch1s on,s based upon review of past hcensed matenal use r cords rad101og1cal sampling and analys s rad,olog1cal dose prciJect,ons, and NRC's ind p ndent urveys Therehre we agree with T h6 Ohio State Un,vorstty's po 1hon that no further actions r r quired for these former burial sites and we have no obJec.t on to the release of th

,te tor unr strict d use Pl H he awar that the his1onca1 records relahng to th above buoal of ltcensed matenals, and th information usod as a ba I for the dos. 1 sessmenl must be ma ntah,ed pursuant to 10 CFR Part 30, Section 30 35 "Fm:,nc,al As.surance and Recordl<&epmg for Decomm1$sloning*

nd may be subiecl to 1nsp clton by NRC, 1Jnlll The Ohio State Un versny'a hcense is term,nsted Should \'01.1 ha11 ny qu sttons regarding th above, pte11se contact Mr Mike Mccann at (630) 829-9856 or mys If at (630) 829* 615 L,cen o 34-00293'02 Doc~ et No 030-02040 bee J Htc ey NMSS T Hams, NMSS PUBLIC (IE 07)

DOCUMENT NAME G \SEC\OSLI L TR NAME DATE Sincerely, 0 igin 1 Signed hy Bruce L Jorgensen, Ch1or Decomm,ss,onmg Branch 111111111 11 II Ill II p

98030,0204 980302 1FFICIAl RECORD COPY 0

AOOCK 03002040 C

00 Page 19 of 47

July 12, 1996 Cecil R. Smith, Ph.D. Assistant Vice President Office of Environmental Health and Safety 1314 Kinnear Road Columbus, OH 43212-1168

SUBJECT:

SPECIAL INSPECTION OF THE OHIO STATE UNIVERSITY'S FORMER 10 CFR 20.304 BURIAL SITES (NRG REPORT NO. 030-02640/96002(DNMS))

Dear Or. Smith:

This refers to the special inspection conducted on May 6, 1996, at two former OSU burial sites located in Columbus, Ohio. This will also acknowledge Mr. G. McCann's telephone conversation with you on June 20, 1996. During the conversation, Mr. McCann provided the results of the analyses of soil and water samples collected during the May 6, 1996, inspection.

The purpose of this special inspection was to conduct a limited radiological survey and observe the physical conditions of the Fawcett Center and North Star burial sites. The NRG inspectors were assisted by a representative of the Ohio Department of Health. The inspectors did not identify any immediate radiological or environmental concerns.

During the June 20, 1996, telephone conversation, my staff was informed that you were prepared to start the environmental and radiological characterization of the former burial sites and were awaiting our approval of OSU's work plans. In order to facilitate the timely characterization of these sites, verbal approval was provided, since both my staff and headquarters staff had reviewed the plans and found them acceptable. This letter confirms the previous verbal approval of OSU's:

Page 20 of 47

1.

Workplan for the Evaluation of Current Radiological/Environmental Conditions for the Fawcett Site, Clinton Township, Franklin County, Ohio, dated May 17, 1996.

2.

Site Characterization Plan For the North Star Site, Clinton Township, Franklin County, Ohio, dated September 22, 1995.

3.

Supplement to the Site Characterization Plan for the North Star Site, dated May 14, 1996.

4.

Radiological Site Health and Safety Plan, North Star Site, dated May 14, 1996.

Page 21 of 47

Cecil R. Smith,.Ph.D.

-2 In order to insure adequate NRG oversight of your characterization work, I am requesting that you notify this office as you complete each phase of the characterization and surveys described in your plans. Should you have any questions or wish to make changes to the plans, or should you identify any unusual radiological conditions during your characterization surveys, please contact this office.

In accordance with 1 0 CFR 2. 790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRG Public Document Room.

We will gladly discuss any questions you have concerning the inspection. You may contact either Mr. G. Mccann of my staff at (708) 829-9856 or me at (708) 829-9872.

Sine

erely, 0

1216,NAl S1orJfd ~

J. W. McCormtck-Barger,Cohief Decommissioning Branch License No. 34-00293-02 Docket No.

030-02640

Enclosure:

Inspection Report No. 030-02640/96002(0NMS) cc w/encl: R. Vandegrift, Ohio Department of Health (OOH)

F. Talbot, OOH M. Weber, OWM H. Astwood, OWN bee w/encl: C. Pederson. RIii B. Burgess, R.III PUBLIC (1£07)

DOCUMENT NAME:

R: \ INSPRPTS\NONPOWER\OSU96002.0NH T*,_.1- * ~

• ~ tU* --t, t8"11ute I* u,. M& *c-

• c.,.. wtt!Mwt al.h0/-1 -.:* * ~

wttll att.clt/-1._.

• No ~

OFFICE RIii 1,1 RI II rt RI II t...

NAME Mccann cah House DATE 07 1., 96 07 96 07 96 OFFICIAL RECORD COPY Page 22 of 47

U.S. NUCLEAR REGULATORY COMMISSION Docket No.

License No.

Inspection Report No.

Licensee:

Facility:

Location:

Dates:

Inspectors:

REGION Ill 030-02640 34-00293-02 030-02640/96002(DNMS)

Ohio State University

1.

Fawcett Site

2.

North Star Site (Both are closed University radioactive materials burial sites)

Both sites are located in Clinton Township, Franklin County, Columbus, OH May 6, 1996 G. M. McCann, Senior Radiation Specialist J. E.

House, Senior Radiation Specialist Accompanying Personnel: F. Talbot, Ohio Department of Health Approved By:

J. W. McCormick-Barger, Chief Decommissioning Branch Page 23 of 47

EXECUTIVE

SUMMARY

Ohio State University (OSU)

NRC Inspection Report No. 030-02640/96002(DNMS)

This was a special, announced inspection to assess the condition of two 1 O CFR 20.304 burial sites (North Star and Fawcett Center Sites) by performing limited radiological surveys and collecting soil and water samples and reviewing records pertinent to the burial sites. The purpose of the surveys and collection of samples was to determine the current radiological condition of the sites and to determine if there were any immediate environmental concerns associated with the burial sites.

The NRC inspectors determined that the North Star Burial Site was being adequately maintained and secured. Additionally, a stream diversion project was verified to have been completed (see NRC Report No. 030-02640/96001 (DNMS)).

The Fawcett Center burial site (approximately 5 acres) was located east of Olentangy River Road and north of Lane Avenue in Clinton Township, Franklin County, Columbus, Ohio. Portions of the former burial site were covered with grass, an asphalt parking lot, and possibly a portion of the Fawcett Center,for Tomorrow building (OSU alumni center). The inspectors did not observe any signs of intrusion, drainage from, or erosion of the site cover.

The NRC inspectors' survey measurements and analyses of water and soil samples did not identify any immediate radiological or environmental concerns.

Page 24 of 47

2

DETAILS

1.

2.

Persons Contacted C. Smith, Ph.D., Assistant Vice President, Office of Environmental Health and Safety (EH&S), OSU R. Peterson, Jr., Radiation Safety Officer (RSO), OSU M. St. Clair, Environmental Manager, EH&S, OSU Denotes attendance at the NRG entrance meeting on May 6, 1996. Denotes attendance at the telephone call on June 20, 1996, to discuss results of the samples analyzed at the NRG Region Ill office.

Background

A.

North Star Site The North Star Site was located approximately 250 yards east of North Star Avenue, north of Lane Avenue in Clinton Township, Franklin County, Columbus, Ohio. This former 1 O CFR 20.304 burial site was used for the disposal of low-level radioactive waste generated by OSU. The site was surrounded by a 6 to 8 foot high chain link fence topped with barbed wire which was placarded with radiation hazard signs. A stream ran from the northwest to the southeast through the site. The inspectors observed that a stream diversion project which was in progress during a previous NRG inspection conducted on January 22, 1996, (NRG Report No. 02640/96001 (DNMS)) had been completed. The old stream bed contained only small quantities of standing water.

The NRG identified a concern regarding the North Star Burial Site during a March 20-25, 1995, inspection (NRG Report No. 03002640/95001 (DASS)). In response to the NRC's concern, OSU contracted with two vendor consulting services to prepare the Site Characterization Plan for the North Star Site, Clinton Township, Franklin County, Ohio, dated September 22, 1996.

B.

Fawcett Center Site The OSU Fawcett Center for Tomorrow building was located east of Olentangy River Road and north of Lane Avenue in Clinton Township, Franklin County, Columbus, Ohio. In response to an NRG request, OSU conducted a review of university records and determined that portions of the property currently occupied by the Fawcett Center for Tomorrow were previously used by OSU for 10 CFR 20.304 burials of laboratory and research radioactive wastes (mid 1950s through the early 1960s) which contained low levels of byproduct materials.

3 Page 26 of 47

The burial site consisted of approximately 5 acres. Based on a review of aerial photographs and past records, the burial area was expected to be located under the east wing of the Fawcett Center, an adjoining east parking area and an adjoining east lawn of the Fawcett Center.

Architectural and campus drawings indicated that the site was covered to a depth of approximately 3 to 1 O meters with fill material (locally obtained clay and other soils) prior to construction of the Fawcett Center for Tomorrow.

Following the discovery of the burial site, OSU performed surface radiation surveys and identified no radiation levels above background. Additionally, OSU contracted with two vendor consultants. These two companies prepared the Workplan for the Evaluation of Current Radio7ogical/Environmental Conditions for the Fawcett Site, Vinton Township, Franklin County, Ohio for OSU.

The purpose of OSU's evaluations are to identify the location of the burial areas, determine the nature of any releases of radioactive contaminants at the site, evaluate the potential migration pathways, characterize constituents in migration pathways, and determine if the presence of radioactive or hazardous materials poses a threat to human health and the environment. The OSU staff indicated to the NRC inspectors that OSU intends to start the evaluations and sample collection in June or July 1996.

3.

Independent Measurements The NRC inspectors conducted independent radiological measurements, and collected soil and water samples in and around the two former burial sites. The radiation survey instrumentation used to conduct the surveys is identified in Table 1.

The NRC inspectors collected monitoring well water samples at the North Star Site, and monitoring well water samples and soil samples from the Fawcett Center Site. These samples were sent to the NRC Region Ill laboratory for analyses.

4.

Survey Results and Laboratory Analyses The NRC inspectors conducted direct radiation survey measurements for beta and gamma radiation. The inspectors did not identify any radiation levels greater than ambient background levels for the OSU campus.

Gamma spectroscopy analyses were performed on all samples and gross beta analyses were performed on the water samples in the Region Ill laboratory. The sample analyses results were found to be at the analytical counting system's minimal detectable activity and thus no immediate radiological concerns were identified with the two burial sites.

4 Page 27 of 47

5. ___

E_x~it_M_e~e~t_in__.q The preliminary inspection findings and results of the NRC analyses of water and soil samples collected during the May 6, 1996, inspection were discussed during a June 20, 1996, telephone conversation between Dr. Cecil Smith and Mr. Mccann.

Attachments:

Table 1 - Survey Instrumentation Table 2 - Survey Data Page 28 of 47

5

TABLE I Survey Instruments Instrument Model No.

Serial No.

Detector Last (Type/Model l Calibration Ludlum 19 014809 Internal Na!

11/17/95 Ludlum 3

045632 44-9 08/14/95 The above meters were serviced and calibrated on an annual basis. Calibrations were performed with National Bureau of Standards {NBS) traceable sources. Daily source checks were performed during the inspection to verify detector constancy. The background for the Ludlum Model 3 averaged 45 counts per minute. The Ludlum Model 19 meter varied from 4 to 5 microroentgens per hour background radiation {uR/h) (1.0 to 1.6 nanocoulombs per kilogram per hour (Nc/kg/h)).

Page 30 of 47

Ohio State University (OSU)

NRG Inspection Report No.

030-02640/96002 (D N MS)

TABLE 2 survey Data beta location/Descri ption analysis oCi/ml Fawcett Center Site Monitoring Well No. 1 (middle of well)

< MDAl Fawcett Center Site Monitoring Well No. 1 (bottom of well}

< HDAl Fawcett Center Site Monitoring Well No. 2 (collected from middle of well}

< MDAl Fawcett Center Site Monitoring Well No. 3 (collected from middle of well)

< MDAl Soil Samples from Fawcett Center Site Soil Samples from Fawcett Center Site Soi 1 Samples from Fawcett Center Site So11 Samples from Fawcett Center Site North Star Site Monitoring Well No.

(bottom of well) 1

< MOAl North Star Site Monitoring Well No. 1

< HDAl (middle of well)

North Star Site Monitoring Well No. 2

< HDAl (bottom of well)

North Star Site Monitoring Well No. 2

< MOAl (middle of well)

North Star Site Monitoring Well (bottom of well)

Ho. 3

< HDAl North Star Site Monitoring Well (middle of well)

No. 3

< HOAl North Star Site Monitoring Well No. 4

< MDAl (bottom of well)

North Star Site Monitoring Well No. 4

< MDAl (middle of well) 1 gamma analysis pCi/ ml pC1 / g

< HOA2

< MOA2

< HDAZ

< MDA2

< MOA3

< MDA3

< MOA3

< MDA3

< MOA2

< MDA2

< MOA2

< MDA2

< MDA2

< HOA2

< MOA2

< HDA2 Page 31 of 47

NOTE: 1.

2.

Ohio State University (OSU)

NRC Inspection Report No. 030-02640/96002(DNMS)

NOTES The following isotopes were chosen for gamma spectroscopy analyses based on half-lives of the radioactive materials with the greatest potential for existing at the site: Cs-137, Tc-99, Sr-90, C-14, and Pm-147 Minimal Detectable Activity (MDA): MDA 1 was based on liquid scintillation analysis and MDA2 and MDA3 were based on gamma analysis. The MDAs were derived for the isotopes indicated below:

MDA1 (H-3, C-14, Tc-99) I pCi/ml, (Sr-90) 0.5 pCi/ml MDA2 (Cs-137) 0.2 pCi/ml MDA3 (Cs-137) 0.2 pCi/g Page 33 of 47

2

U.S. NUCLEAR REGULATORY COfitfISSION REGION I 11 Report No. 030-02640/9600l(DNMS)

License No. 34-00293-02 Docket No. 030-02640 Licensee: The Ohio State University (OSU)

Columbus, OH 43212 Inspect1on Condurted:

January 22 1 1996 (On-site inspection) and telephone conference call.s on January 29 and February 1, 1996 Inspection Locations:

OSU Office of Environmental Health & Safety, Room 210 1314 Kinnear Road Columbus, OH 43212 osu North Star Site (closed University radioactive materials burial site}

Cli~ton Township, Franklin County, OH Inspector: A~ ~. 1, ~ l~

George H. Mccann Senior Radiation Specialist

02. '" /c;"

Date Accompanying Personnel : Frank Talbot Bureau of Radiological Services (BRS)

Ohio Department of Health (OOH)

Approved By: J. W. HcCormi

-Barger, Chief Oeco1m11ssitning Branch Inspection surmiary Inspect1on on January 22. 1996 (Report No. 03Q-02640/96Q01CDNMS)l Areas inspecte..d,:

This was an announced, special fnspect10n conducted al the licensee's Office of Environmental Health & Safety, Columbus, Ohio, and the North Star Site (closed OSU rad1uactive materials burial site) located in Clinton Township, franklin County, Ohio. The inspection includ~d discussions regarding the licensee's proposed Charactertzation Plan (S, t~ C~aracterization Plan for the North Stir Sjte Clinton Town;hip, Franklin County, Oh10) and a walk-around inspection of the burial site.

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Results~ Based on discussions with OSU staff, the NRC inspectors determined that the water flowing in the ditch which crossed through the burial site had significantly increased in water flow. That is, 1t had taken on the aspect of being a stream, rather than a drainage ditch with a periodic water flow. This Increased water volume appeared to have been the result of a recent and unusually heavy snowfall followed by rapid melting in the Columbus area. The HRC inspectors identified a waste burial marker irrmediately adjoining the stream that was approx imately one foot from the stream P.dge. The NRC inspectors expressed concern regarding what appeared to be significant erosion. and stated they were concerned that this eros1on may be impinging the buried waste.

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DETAILS Persons contacted

• iC. Smith, PhD., Assistant Vice President, Office of Environmental Health and Safety (EH&S), OSU

• ,J. Allegier, H.S., Certified Health Physicist, Radiation Safety Officer (RSO), EH&S, OSU

• R. Peterson, Jr., Health Physicist, OSU

• H. St. Clair, Environmental Manager, EH&S, OSU

• J. Burkes, Health Physicist, EH&S, OSU

• A. Vest, H.S., Health Physicist, EH&S, CSU

• Denotes attendance at the NRC entrance meeting on January 22, 1996.

@Denotes participation in the telephone conference calls between the NRC and OSU on January 29 and February 1, 1996.

2.

Background

The North Star Site was located approximately 250 yards east of North Star Avenue, north of Lane Avenue in Clinton Township, Franklin County, Columbus, Ohio. The site was owned by The Ohio State University and was formerly used for the disposal of low-level radioactive waste generated by OSU.

The site comprised approximately O.S acres and was surrounded by a 6 to 8 foot high chain link fence topped with barbed wire.

The fence was placarded with radiation hazard signs. A stream ran from the northwest to the southeast through the site.

The licensee indtcated in their proposed Characte:*ization Plan and during the inspection that low-level radioactive waste (LLRW) burials took place at the s1te between May 1963 and February 1971. The licensee indicated that a review of existing information suggested that the nature of the LLRW was limited to radiologically-contaminated solid waste such as plastics, glassware. and metals. Furthermore, that conrnon practice suggested that no sealed sources were buried at the site, but were instead transported to Oak Ridge National Laboratory, Oak Ridge, Tennessee, for disposal/storagf. Radionuclides which were likely to have been associated with the solid waste, and w re buried at the site and may still be exhibiting decay activities, were believed to be limited to tritium ('H) and carbon-14 (uC). However, existing OSU records indicated that other isotopes may have been disposed at the site. lhe OSU staff indicated that inventory records describing what was buried could n~t be found.

The OSU staff ind1cated that they managed the North Star Site in accordance with federal guidelines and that during the operational period of the site, burial procedures met the requirements specified in 10 CFR Part ZO. Further. that trenches were constructed with 6 feet of separation between each trench and waste was buried at a minimum depth of 4 feet below gr.de.

Waste was drunll\ed or bagged, or simply la1d into the trenches. OSU's Byproduct Material License No. 34-00293-02 tnd1c1ted that they were authorized to ma~e up to 26 buria~s per year.

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3.

4.

In response to a March 21, 1995 1 NRC inspection which expressed concern regarding the burial site, the licensee subm1tted their proposed Characterization Plan dated September 22, 1995. The plan was reviewed by NRC Headquarters and NRC Region III staff. This inspection included a d1scussicn regarding the NRC progress in review of this document.

A map of ~he ~ite 1s included as Attachment 1.

Entrance Meeting on January 22. 1996 An entrance meeting was held at OSU with those 1nd1v1duals identified in Section l of this report. The meeting included a briefing by the OSU staff regarding OSU's ongoing activities to characterize the burial site. O~U's staff indicated that they were anxious to receive NRC colffl\ents on the pro~osed Characterization Plan so they could proceed with the project.

The NRC staff inquired if OSU had been able to locate definitive burial disposal records which described, 1n adequate detail, the radioactive materials that had been buried at the site. The OSU staff indicated that burial disposal inventory records had r,ot been found.

The NRC staff asked about the site's future, on,e characterization -as completed. Several options were indic*ted by OSU; however, it was indicated that OSU was leaning tow.rd remediation of the site. They indicated that no toxic materials had been buried with the licensed materials which should fac111tate removal at lower cost.

The inspection included discussion of NRC conwnents in general terms regarding NRC's review of the proposed site Characterization Plan.

Observations of North Star Burial Sfte The burial site perimeter was surrounded by a chain link fence which was topped with barbed wire.

Th fence was also posted with radiation caution signs which ~ere conspicuously posted approximately four feet above the ground.

The site was covered with trees and shrubs making it difficult to see the entire site. The OSU staff indicated that the ground cover had not been cut down, in order to prevent soil erosion.

The NRC inspectors observed that what had been previously referred to as a ditch (assumed to have little water movement) was a stream with significant water movement through it. Additionally, it appeared that significant soil erosion had occurred in the stream bottom and sides.

The stream appeared to be approx~mately four to five feet below the ground surface. The NRC inspectors standing next to the stream on the east side of the s1te observed a steel metal marker, which the OSU staff 4

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indicated marked I radioactive waste burial trench, that was only a few inches away from the stream bank. It appeared that the stream had eroded away the bank and if the erosion was not stopped, the stream would encroach the burial trench.

No violations of NRC requirements were identified.

Exit Meet1og At the conclusion of the onsite inspection on January 22, 1996, and during telephone calls on January 29, 1996, and February 1, 1996, the NRC staff expressed concern regarding the stream impingement on a possible burial trench at the North Star burial site.

OSU was responsive to the NRC concerns and implemented i111nediate steps to perform radiological moritoring of the area and divert the stream flow around the burial site. OSU's pl an for long-term action included considering actions to completely remedilte the burial site.

OSU management and employees did not identify any information provided during the jnspection and telephone calls as proprietary.

Attachment:

Site Map s

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Pa e 40of 47 Pagel of 4 NRC Convnents On OSU,s Characterization Plan The following are co11Ynents concerning our review of osu*s Characterization Plan (Site Character;zation P1an for the North Star Site Clinton Township, Fr3nk1in County, Ohio).

Based on discussions with OSU, we understand that OSU may elect to remediate the site with;n the near future. Therefore, some of the items listed below (specifically, 4, 6, and parts of 7) may not apply.

Additionally, the scope of the other items may also be modified if adequate justification is provided.

General co~~ents:

Please respond to the following comments, provi~ing supporting documentation as necessary.

1.

Confirm th~t OSU has not conducted any other land burials of licensed radioactive materials.

If it should be determined that burials have occurred at other than the North Star site, provide infonnation regarding these sites, including but not limited to the following :

A.

Types and quantity of licensed materials buried.

B.

Dates the burials occurred.

C.

Locations of the burial areas.

0.

Current status of the areas. such as, control, ownership, and cover integrity.

2.

Describe the health physir.s oversight for the characterization, remediation and survey activities to be conducted at the North Star site. The characterization plan indicates that the contractor will be responsible for the oversight and radiation safety for the project.

Typically the establishment and oversight of radiation safety programs is the responsibility of the licensee. Therefore, provide information regarding the following:

A.

The health and safety manual, remediation, survey and sampling procedures to be used for the above projects.

B.

The name and credentials of the contract personnel responsible for the oversight of the above project(s).

c.

A description of osu*s progra~ to aud1t the contractor's work.

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f.nclosure 2 Page 2 of 4 Specific Plan Co(Tlllents:

Please respond to the follow1ng conrnents, and provide documentat,on as necessary.

2.

3.

4.

s.

6.

Page 6. Sect1on 1.3.2 This page states that split spoon samples from boreholes will be screened using a field survey meter C-14 and H-3 are very difficult to detect using a survey meter. Borehole samples should be taken at regular intervals.

Table 1 Th1s table indicates that only gross alpha and beta measurements will be done on soil and sediment samples. Typically, licP.nsees perform ganrna analysis to identify radionuclides if the gross counts exceed a specified administrative limit, such as, ten percent of the NRC unrestricted release limits for the most restrictiv~

radionuclide. Please specify your administrative limit after which garrma analysis will be performed or justify why this analysis is not necesSiry.

Page 11. Sectjon 2.3,4 It is stated that records indicate that there are resideutial wells in the area but it is not known if they are in use. It will be important to detennine if these wells are in use if contamination is found,n the groundwater.

A sampling of these wells may also be necessary.

Page 14. Sect1on 3.2 It is stated that the site will be cleared of vegetation. Representative samples of this vegetation should be analyzed to detennine if any of the radfonuclides have ~een absorbed into the plant tissue.

Page 15, Section 3.4 This section implies that there are areas of the site whi ch will be consider unaffected areas.

From the information, ft appears that the buri a covers approximately 0.5 acres and is considered the entires Ir this is the case it is highly un11kely that any portion of tht.S acres can be considered an unaffected area.

A map that clearly outl1nes the burial site boundary and the boundary of the Ohio State property should be included in the site characterization report. The site characterization maps did not include this information.

Page 22. Section 3.6.l This section states that no samples will be taken directly from the trenches. This means that there w1ll be no sampling of the waste material and therefore, no 1nd1cat1on of the types or quantities ot isotopes left in the waste.

The activities and concentrations of rad1onuc11des in the trenches IDUst be evaluated before any determination can be made on the acceptability of the burial.

Sampl~s collected next to the trench will give an indication of the r

BES1 1 AVAILABLE COPY Page 42 of 47 Page 3 of 4 concentration of isotopes that have migrated out of the trencht but do not give an inoication of the concentrations of radioactive material left in the trench. This information must be provided either through review of detailed historical records of types, volumes, and activit1es of isotopes disposed, direct measurement of the waste materials. or another method which would give an indication of the types and concentrations of isotopes in the trenches.

7.

Page 23. Sectjon 3,6.2 This section states that boreholes will only be drilled to a depth of 40 feet but groundwater could be at depths from 35-90 feet. It is therefore possible that no groundwater samples would be taken from the site. It is also stated that 1f soil contamination around the trench does not extend past 40 feet that groundwater contamination is not a problem. The following are several issues wh1ch must be considered when characterizfng possible groundwater contamination: there 1s a possibility that the contamination does extend below 40 feet and no groundwater samples would be taken; if no groundwater samples are taken how would 1t be shown that the gr~undwater is not contaminat~d; the fact that the groundwater is de~per than 40 feet where the wells ar2 drill~d does not indicate the jepth of groundwater under the trenches; it is possible that contamination is migrating straight down out of the bottom of the trenches into the groundwateri and the off-site wells are placed so far away from the burial ground that there could be gt*oundwater contamination close to the s1te which is not seen in these wells {see coment below).

8.

fjgure 10 This figure indicates that the wells which are being proposed are going to be located up to 4000 feet from the burial location. This would not appear to 91ve a good indication of possible groundwater contamination. The wells should be placed closer to the source of the contamination.

9.

Page 42. Sectjon 7,0 This section and the prelfmfnary schedule indicate that long term monitoring will be implemented tf the doses to the public as a result of the burial are unacceptable. It should be noted that monitoring is only one of the possible future actions for the site. The site may require complete or partial remedi at f on of the contaminated material. The ultimate disposition of the waste will be determined after characterization is completed.

IO.

Page 21. Footnote below Table 5 Clarify the statement that soil sample volumes can be combined for analys1$. Typically, soil samples should be analyzed as discrete samples.

Analytical results can be used in averaging for release.

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EnclosurE: 2 Page 4 of 4

11.

Page 18. Section 3.1 Clarify what 10 CFR Part 20 and 30 limits will be used as guidelines for establishing soil contamination limits.

Acceptable guideline values are specified in the attachment, Acceptable Soil Contamination Levels of the NRC's Policy,nd Guidance Dfrectfve FC 83-23, Oivfsfon of Industrf11 ind Hedic11 Nuclear Safety, November 4, 1983 (Revised August 1987). If it is determined that residual radionuclides exist other than those specified in the attachment, then site specific release values must be determined on a case-by case basis.

Attachment:

Po11cy and Gufdanc~ Directive FC 83-23, Division of lndustri11 and Nea,c11 Nuclear Safety, November 4, 1983 (Revised August 1987) r BEST AVAILABLE COPY Page 44 of 47

At achment to Page 1 of 1 S011 Conccnlrat1or, L'vel t 1nd of Matcnal for unr stricted area

1) Natural Uranjum (U-238 4 U-234) w1th daught.;ers present and in equilibriura ii) D@pleted Uran1u.m or Natural Uranium that has been separated from its daughters Soluble or Insoluble ii1) Natural Thorium (lh-232 ~ Th-228) w1th daughters pr~sent and in equi l 1 bri um 1v) Enriched Uranium Soluble or Insoluble v) Pl uton, um O) or (W) co.11pounds vi) Am-241 (W),ompouod~

vii) All Byproduct Material vi11) Cxtr.rnal Radiation 10 (fC1/gn of so1l) 3~ (pCi/gm of soil) 10 (PCi/grn of s011) 30 (pC1/gm of sotl) 2S {pCi/gm of so1l) 30 (pCi/gm of so1l)

Soil concr.n~rat1on$

sha 11 be detcnnincd on a case by case llas1s 10 ~icroroentgcn~/hr

~bove bac~ground mf>asured at one meter t rom the gr'Ound sur: ac BEST AVAILABLE COPY Page 45 of 47

Cecil R. Smith. Ph.D.

Assistant Vice President July 12, 1996 Office of Environmental Health and Safety 1314 Kinnear Road Columbus. OH 43212-1168

SUBJECT:

SPECIAL INSPECTION OF THE OHIO STATE UNIVERSlTY 1S FORMER 10 CFR 20.304 BUPIAL SITES (NRC REPORT NO. 030-02640/96002(0NMS)}

Dear Dr. Smith; This refers to the special inspection ccnducted on Hay 6, 1996, at two former OSU burial sites located 1n Columbus, Ohio.

This will also acknowledge Hr G.

McCann's telephone conversation with you on June 20, 1996. During the conversation, Mr. Mccann provided the results of the analyses of soil and water samples collected during the May 6, 1996, 1nspection.

The purpose of this special 1nspect1on was to conduct a limited radiological survey and observe the phys1cal conditions of the Fawcett Center and North Star burial sites. The NRC inspectors were assisted by a representative of the Ohio Oep~.-tment cf Health.

The inspectors aid not identify any 1nwnedlate rad1ol0gical or env1ronmental concerns.

During the June 20, 1996, telephon~ conversation, my staff was informed that you were prepared to start the environmental and radiological characterization of the former burial sites and were awaiting our approval of osu*s work plans.

In order to facilitate the timely characterization of these sites, verbal approval was provided, since both my staff and headquarters staff had reviewed the plans and found them acceptable.

rhis letter confirms the previous verbal approval of OSU's:

1.

Workplan for the Evaluation of Current Radio1ogica1/Environment,1 Cond;tions for the Fawcett Sjte, C1fnton Township. Frank1in County, Ohio, dated May 17, 1996.

2.

Sfte Characterization Plan for the North Star Site, Clinton Township, franklin County, Ohio, dated September 22, 1995.

3.

Supplement to the Sfte Characterizat1on Plan for the North Star Site, dated May 14, 1996.

4.

Radiologfr.al Site Health and Safety ~1an, North Star Site, dated May 14, 1996.

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Cecil R. Smith, Ph.O. ln order to 1nsure adequate NRC oversight of your characterization work. I am requesting that you notify this office as you complete each phase of the characterization and ~urveys described in your plans. Should you have any questions or wish to make changes to the plans, or should you identify any unusual radiological condtt1ons during your characterization surveys. please contact this office.

In accordan~e with 10 CFR 2.790 of the Corrrnission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC Publ1c Document Room.

We will gladly discuss any questions you have concerning the inspection.

You may contact either Mr. G. McCann of my staff at (708) 829-9856 or me at (708) 829-9872.

Sincerely, 0 ' 16 11\li'\I ~16rJf cl ~

J. W. HcCormick-Barger,(Ohief Oeconmissioning Branch License No. 34-00293-02 Docket No. 030-02640

Enclosure:

Inspection Report No. 030-02640/ 96002(DNHS) cc w/ encl : R. Vandegrift, Jhio Oepart111ent of Health (OOH)

F. Talbot. ~:::.,1 M. Weber. OWH H. Astwood, OWM bee w/er.cl : C. Pederson, Rill B. Burgess, RIil PU~UC (1(07)

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