CORPUS CHRISTI ARMY DEPOT 308 CRECY …CORPUS CHRISTI ARMY DEPOT 308 CRECY STREET CORPUS CHRISTI TX...

DEPARTMENT OF THE ARMY CORPUS CHRISTI ARMY DEPOT

308 CRECY STREET CORPUS CHRISTI TX 78419-5260

Office of the Radiation Safety Officer 12 August 2009

RE~C-""E"\ 'E-' 0Corpus Christi Army Depot I" ~j._J / - ._

Directorate of Security Industrial Risk Management (Stop 23) Safety Occupational Health Division Radiation Safety Officer Corpus Christi, TX 78419-5260

SUBJECT: Request for Termination to Nuclear Regulatory Commission Source Material License, STB-1168

Mr. Robert Evans Nuclear Materials Licensing Branch U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064

Dear Mr. Evans,

Enclosed is the Nuclear Regulatory Commission (NRC) Form 314, Certificate ofDisposition of Materials to NRC Source Material License, STB 1168.

Request NRC Source Material License, STB-1l68 is terminated to reflect the cessation of all activities authorized by this license. Enclosed is a copy of the survey results.

The point of contact for this action is undersign (Andrew J. Marks) Radiation Safety Officer, 361.961.6921, email [email protected]. Safety Occupational Health Division, 361.961.3200, e-mail [email protected].

Sincerely,

Enclosure ANDREW J. MA KS NRC Form 314 Radiation Safety Officer CCAD Radiological Survey Report & Final Status Survey Evaluation, 4 Aug 2009

N1472387

APPROVED BY OMB: NO. 3150-0028 EXPIRES: 0813112010NRC FORM 314 U.S. NUCLEAR REGULATORY COMMISSION (4-2008) Estimated burden per response to comply with this mandatory collection request: 30 minutes.10 CFR 30.36U)(1); 40.42Ul(1); 70.38Ul(1); and 72.54(k)(5)(1 )(1) This SUbmittal is used by NRC as part of the basis for its determination that the facility is

released for unrestricted use. Send comments regarding burden estimate to the Records and FOIAIPrivacy Services Branch (T-5 F52), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by intemet e-mail to [email protected], and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0028), Office of Management and Budget, Washington, DC 20503. If a means used to impose an information collection does not display a currently valid OMS control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

LICENSEE NAME AND ADDRESS

CERTIFICATE OF DISPOSITION OF MATERIALS

LICENSE NUMBER IDOCKET NUMBER

STB-1168 040-08177COMMANDER, Corpus Christi Army Depot ~- ~--------LICENSE EXPIRATION DATEATTN: AMSAM-DS-SE

308 Crecy Street, Stop 23, Corpus Christi, Texas 78419-5260 02128/2011

A. LICENSE STATUS (Check the appropriate box)D This license has expired. [l] This license has not yet expired; please terminate it.

B. DISPOSAL OF RADIOACTIVE MATERIAL (Check the appropriate boxes and complete as necessary. If additional space is needed, prOVide attachments)

The licensee, or any individual executing this certificate on behalf of the Iioonsee, certifies that:

D 1. No radioactive materials have ever been procured or possessed by the licensee lI1der this license.

[l] 2. All activities authorized by this license have ceased, and all radioactive materials procured and/or possessed by the licensee under this license number cited above have been disposed of in the following malner.

D a. Transfer of radioactive materials to the licensee listed below:

[Z] b. Disposal of radioactive materials:

D 1. Directly by the licensee:

D 2. By licensed disposal site:

[l] 3. By waste contractor:

Environmental Dimensions, Inc. 710 S. lIIinois Avenus, Suite F-I05; Oak Ridge, TN 37830-9107

[Z] c. All radioactive materials have been removed such that any remaining residual radioactivity is within the limits of 10 CFR Part 20, Subpart E, and is ALARA.

C. SURVEYS PERFORMED AND REPORTED

D 1. A radiation survey was conducted by the licensee. The survey confirms:

Da. the absence of licensed radioactive materials

D b. that any remaining residual radioactiVity is within the limits of 10 CFR 20, Subpart E, and is ALARA.

IZJ 2. A copy of the radiation survey results:

[Z] a. is attached; or D b. is not attached (Provide explanation); 00 c. was forwarded to NRC on: ---~--

D 3. A radiation survey is not required as only sealed sources were ever possessed under this license, and

D a. The results of the latest leak test are attached; and/or Db. No leaking sources have ever been identified.

The person to be contacted regarding the information prOVided on this form: -rADDRESS-------NAME rTLE rEPHONE (Include hea Code)

Andrew J. Marks I Radiation Safety Officer (RSO) (361) 961-6921 f--------- -

Mail all future correspondence regarding this license to:

Corpus Christi Armv Depot. AMSAM-CC-BC-H 308 Crecv St.• MS 23. Corpus Christi. TX 78419 C. CERTIFYING OFFICIAL

I CERTIFY UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT PRINTED NAME AND TITLE ISIGNATURE IDATE

Andrew J. Marks, Industrial Hygienist/RSO i WARNING: FALSE STATEMENTS IN THIS CERTIFICATE MAY BE SUBJECT TO CIVIL AND/OR CRIMINAL PENALTIES. NRC REGULATIONS REQUIRE THAT SUBMISSIONS TO THE NRC BE COMPLETE AND ACCURATE IN ALL MATERIAL RESPECT. 18 U.S.C. SECTION 1001 MAKES IT A CRIMINAL OFFENSE TO MAKE A WILLFULLY FAlSE STATEMENT OR REPRESENTATION TO ANY DEPARTMENT OR AGENCY OF THE UNITED STATES AS TO ANY MAnER WIll"lIN ITS JURISDICTION.

NRC FORM 314 (4-2008) PRINTED ON RECYCLED PAPER

472387

. . . _"'!\? I _ ':~'~=n'E''''I-E''''1M. P . Ii ,,~ P.O. Box 4849, Oak Ridge, TN 37831

Certificate of Disposal

July 8, 2009

ED! Project Number: 902076

The following will serve as documentation for the disposal of the waste received as manifest number 20090527-002. This waste was received by Impact Services Inc. (TRML# R-73024-E-17) and disposed of as solid waste at the Chestnut Ridge landfill after analytical data determined it met the criteria for Volumetric Clearance Disposal. The waste was disposed of at the landfill on 1 July 2009 under manifest number WMNA 10926285.

~i\r"~~'-~-~ Chris Hepler Radiation Safety Officer Impact Services Inc. 865-576-8724

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P.O. Box 4849, Oak Ridge, TN 37831


July 8, 2009


The following will serve as documentation for the disposal of the waste received as manifest number 20090527-002. This waste was received by Impact Services Inc. (TRML# R-73024-E-17) and disposed of as solid waste at the Chestnut Ridge landfill after analytical data determined it met the criteria for Volumetric Clearance Disposal. The waste was disposed of at the landfill on 18 June 2009 under manifest number WMNA 10926277.

~ . \ ~~,.--\\_~

Chris Hepler Radiation Safety Officer Impact Services Inc. 865-576-8724

I I I I I I

DRAFT FINAL

I I I

CORPUS CHRISTI ARMY DEPOT I RADIOLOGICAL SURVEY REPORT AND

I FINAL STATUS SURVEY EVALUATION I I I I AUGUST 4, 2009

I I I I Ih 47 2387

I I I I I I DRAFT FINAL

I I I

CORPUS CHRISTI ARMY DEPOT I RADIOLOGICAL SURVEY REPORT AND

I FINAL STATUS SURVEY EVALUATION

I I I I AUGUST 4, 2009

I prepared by Science Applications International Corporation, Inc. in coordination with Environmental Dimensions, Inc.

I I I

I Corpus Christi Army Depot Radiological Survey Report and Final Status Survey Evaluation

I TABLE OF CONTENTS SECTION PAGE

I LIST OF FIGURES ii

I LIST OF TABLES ii

LIST OF APPENDICES ii

ACRONYMS AND ABBREVIATIONS iv

I 1.0 INTRODUCTION 1

1.1 INTRODUCTION 1

I 1.2 PURPOSE AND SCOPE 1

2.0 SITEBACKGROUN"D 3

I 3.0 SURVEY DESIGN 4

3.1 TIffi DECISION 4

I 3.2 INPUTS TO TIffi DECISION 4 3.2.1 Data Review 4 3.2.2 Background Reference Areas 4

I 3.3 RADIOLOGICAL SURVEYS 5 3.3.1 Study Boundaries 5 3.3.2 Gamma Walkovers 7

I 3.3.3 Soil Sampling and Results 9 3.3.4 Media Sampling and Results 10 3.3.5 Location Surveys and Removable Contamination Evaluations 12

I 3.4 INSTRUMENT USE AND QUALITY ASSURANCE 12 3.4.1 Pre-Operational Checks 13

I 3.4.2 Daily Background Checks 13 3.4.3 Daily Source Check 14 3.4.4 Static and Scan Minimum Detectable Concentrations (MDCs) 14

I 3.5 RADIOLOGICAL CONTAMINANTS OF CONCERN 15 3.5.1 Characteristics of Magnesium-Thorium Alloy Contamination 15 3.5.2 Exceptions 16

I 3.5.3 Characteristics of the Thorium Decay Series 16

3.6 DERIVED CONCENTRATION GUIDELINE LEVELS (DCGLs) 16

I 3.7 DECISION ERRORS 18

3.8 RELATIVE SHIFT 19

I 3.9 TIffi NUMBER OF SAMPLES PER SURVEY lJNIT 19

3.10 CLASSIFICATION OF SURVEY UNITS 20

I 3.10.1 Estimate the Sample/Measurement Grid Spacing 20

3.11 OPTIMIZATION OF DESIGN FOR OBTAINING DATA 21

I 3.12 DATA QUALITY OBJECTIVES (DQOs), QUALITY ASSURANCE AND QUALITY CONTROL (QAlQC) 21

DRAFT FINAL I


I TABLE OF CONTENTS (Continued)

SECTION PAGE

I 4.0 SITE SAFETY AND HEALTH 22

4.1 SAFETY AND HEALTH TRAINING 22

I 4.2 TASK-SPECIFIC PERSNAL PROTECTIVE EQUIPMENT 22

4.3 PERSONNEL MONITORING REQUIREMENTS 22

I 5.0 SAMPLE AND WASTE DISPOSITION 23

6.0 SlTRVEY RESULTS 24

I 6.1 INTRODUCTION 24

6.2 SUMMARY OF SURVEY APPROACH 24

I 6.3 EVALUATION PROCESS OF IMPACTED AREAS 25

6.4 SURVEY RESULTS 25

I 6.4.1 General ~ 27 6.4.2 Building 8 28

I 6.4.3 Building 1727, Room BIOI, Radiation Safety Officer (RSO)

Laboratory 35 6.4.4 Building/Area 339 Former Waste Storage Area 36

I 6.4.5 Former Building 258 Radioactive Waste Storage and Processing

Areas 37 6.4.6 Building 340 38 6.4.7 Building 1825 39

I 6.4.8 Building 132 Radioactive Material Storage and Handling Building .40

7.0 CONCLUSION 41

I 8.0 REFERENCES 42

LIST OF FIGURES

I I Figure 1-1. Location of Corpus Christi Army Depot.. 2

Figure 3-1. Building 8 Impacted Areas 6 Figure 3-2. Gamma Walkover Survey 8

LIST OF TABLES

I Table 3-1. CCAD Soil Sampling Results 9

I I

Table 3-2. CCAD Media Sampling Results 10 Table 3-3. Survey Instrumentation Used at CCAD 13 Table 3-4. Evaluation of Instruments for Use at CCAD 15 Table 3-5. Characteristics of Thorium-Series Radionuclides 17 Table 3-6. Volumetric Dose to Source Ratio (DSR) 18

I Table 3-7. Volumetric Area Factors 18 Table 3-8. MARSSIM "Suggested Survey Unit Areas" (DOD, 2000) 20 Table 6-1. Wilcoxon Rank Sum Tests 25 Table 6-2. Analysis Results for Bead Blast and Grinding Wheel Media 27 Table 6-3. Surveys of the Building 8 Welding Shop, Metal Shop and Bead Blast Area 29

II DRAFT FINAL I


I I Table 6-4.

I Table 6-5. Table 6-6. Table 6-7. Table 6-8. Table 6-9.

I Table 6-10. Table 6-11. Table 6-12.

I Table 6-13. Table 6-14. Table 6-15.

I I Appendix A

Appendix B Appendix C

I Appendix D Appendix E* Appendix F*

I I * CD-ROM

I I I I I I I

LIST OF TABLES (Continued) PAGE

Surveys of the Building 8 Machine Shop 30 Surveys of the Building 8 Magnesium Thorium Room 31 Surveys of the Building 8 Engine Disassembly and Cleaning Areas 32 Surveys of the Haas Mill Area in Building 8 33 Surveys of Building 8, North End Bead Blast Rooms 34 Surveys of the Building 8, Electron Beam Welder Area 34 Surveys of the RSO Lab in Building 1727 36 Surveys of Building 339 36 Surveys of Building 258 38 Surveys of Building 340 38 Surveys of Building 1825 39 Surveys of Building 132 40

LIST OF APPENDICES

Laboratory Analysis Reports MDCs for Radiological Contaminants of Concern at Corpus Christi Army Depot Evaluation of Areas that Are Radiologically Elevated Relative to Background Listing of Surveys Performed and Detailed Survey Information* Quality Assurance and Quality Control (QAlQC) Wilcoxen Rank Sum Tests

BACK COVER

Attachment D-1 and Appendices E and F

iii DRAFT FINAL I


I I I I I I I I I I I I I I I I I

AEC ANSI CCAD COC cm cpm Cs D&D DCGL DSR DOT dpm DQO EDi EMC EPA ft GPS HAZWOPER HSA IDW keV LBGR m rn/s MARLAP MARSSIM MDA MDC MeV mrern/h N/A Nal NAS NIST NORM NRC NUREG OSHA pCi/g QA QC RPM RSO SAIC SSHO SU

ACRONYMS AND ABBREVIATIONS

Atomic Energy Commission American National Standards Institute Corpus Christi Army Depot contaminant of concern centimeters counts per minute Cesium decontamination and decommissioning derived concentration guideline level dose to source ratio Department of Transportation Disintegrations per minute data quality objective Environmental Dimensions Inc. elevated measurement comparisons Environmental Protection Agency feet global positioning system Hazardous Waste Operations and Emergency Response Historical Site Assessment Investigation Derived Waste kiloelectron volt lower bound of the gray region meter meters per second MUlti-Agency Radiological Laboratory Analytical Protocols Manual Multi-Agency Radiation Survey and Site Investigation Manual minimum detectable activity minimum detectable concentration megaelectron volt milIirem per hour not applicable sodium iodide Naval Air Station National Institute of Standards and Testing Naturally occurring radioactive material Nuclear RegiJlatory Commission Nuclear Regulatory Guide Occupational Safety and Health Administration picocuries per gram Quality Assurance Quality Control Radiation Protection Manager Radiation Safety Officer Science Applications International Corporation Site Safety and Health Officer Survey Unit

lV DRAFT FINAL I


I SrY ThI WRS

I ZnS

I I I I I I I I I I I I I I

ACRONYMS AND ABBREVIATIONS (Continued)

Strontium-Yttrium Thorium Wilcoxen Rank Sum Zinc Sulfide

v DRAFT FINAL I


I 1.0 INTRODUCTION

1.1 INTRODUCTION

I Corpus Christi Army Depot (CCAD) is the largest helicopter repair facility in the world consisting of more than 50 buildings that encompass more than two million square feet (ft).

I Facilities include a number of hangars and associated overhaul and testing facilities centered around Building 8, a facility with about one million square ft which serves as the focal point for aircraft overhaul operations. CCAD is a major tenant organization on Naval Air Station (NAS),

I Corpus Christi, a facility in the Flour Bluff area, about 10 miles southeast of the central portion of the City of Corpus Christi (See Figure 1-1).

I CCAD and its predecessor, the United States Anny Aeronautical Depot Maintenance Center,

I have performed mission essential depot level maintenance of army aircraft engines and their associated components since the early 1960s. Some of the aircraft engine components were produced using magnesium-thorium alloys based on the ability of thorium, a naturally occurring

I radioactive material, to increase the high temperature strength of the associated metal alloys. Although magnesium-thorium alloys containing less than 4% thorium can be possessed without a radioactive materials license, a source material license is required for any physical, chemical, or metallurgical treatment or processing. As such, CCAD applied for and was issued Nuclear Regulatory Commission (NRC) Source Material License STB-1168. This license authorized the

I performance of those specific treatment and processing operations that were required to perform mission-essential maintenance and overhaul of the magnesium-thorium alloy aircraft engine components.

I 1.2 PURPOSE AND SCOPE

I This survey was performed as a tool in assessing the radiological status of CCAD; to define the

I nature and extent of radiological contamination present as a result of NRC licensed maintenance operations such that decontamination and decommissioning (D&D) can be developed to address the contamination and ultimately a request for termination of NRC Source Material License STB-1168 and the associated unrestricted release of impacted facilities. The survey effort was to locate areas with gamma count rates that are elevated with respect to relative background by

I walking over the areas and by manual scanning of the walls, overhead areas and floors. Overhead areas include I-beams and related support structures present in a given area and are necessarily dependent on the room or area being addressed.

I Due to the elimination of magnesium-thorium alloy use, CCAD no longer performs maintenance on magnesium-thorium containing engine components. Therefore, they are pursuing final

I cleanup and license termination. Results of radiological surveys performed and included in this report provide essential information for D&D of impacted structures. Consistent with paragraph

I 2.3 of Nuclear Regulatory Guidance-1757 (NUREG), Volume 2, the radiological surveys perfonned achieve data quality objectives such that they can be fully integrated into the final status survey process.

I I I 1 DRAFT FINAL

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Corpus Christi Bay

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6

Mustang Is/a!fd State pEA

Figure 1-1 Location of Corpus Christi Army Depot


I 2.0 SITE BACKGROUND

Established in 1961 as the United States Army Aeronautical Depot Maintenance Center, CCAD

I began as a depot-level maintenance facility for fixed and rotary wing aircraft with the first Bell Helicopter UH-I (Huey) being overhauled in 1962. By 11 March 1964,3600 aircraft engines had been overhauled in the 30 months of such operations and by 1968 repair and overhaul services

I were being provided to approximately 400 helicopters annually. These overhaul services

I included Army T-53, T-55 and T-63 aircraft engines used in AH-1 (Cobra), UH-1 (Iroquois or Huey), Ch-47 (Chinook) and OH-58 (Kiowa) aircraft.

I Two magnesium-thorium alloys, HZ-32A and ZH-62A, were used in the production of aircraft engine components incorporated into the above stated Anny aircraft. HZ-32A is a magnesium alloy containing 3.3, 2.1 and 0.75% thorium, zinc and zirconium, respectively. ZH-62A contains 1.8, 5.7, and 0.7% of each of these constituents, respectively. The addition of 3.3 and 1.8% thorium increased the high temperature strength of these metal alloys. Although possession of

I magnesium-thorium alloys containing 4% or less thorium is exempted from licensing by Title 10, Code of Federal Regulations, Section 40. 13(c)(4), the exemption does not authorize any "chemical, physical, or metallurgical treatment or processing". Given the requirement to perform

I such processing of the magnesium-thorium containing engine parts, in 1973 CCAD applied for and was issued Atomic Energy Commission (AEC) (subsequently the NRC) Source Material License STB-1l68. This license authorized CCAD to perform the required maintenance

I processes. Processes performed generally included, but were not limited to removal and reapplication of protective coatings, corrosion treatment, drilling, machine and hand grinding, machining, welding, metal spray application and blasting using a variety of different media (e.g.,

I plastic beads, walnut shells, etc).

I In the late 1980s, Magnesium-Elektron, the Manchester, England company that produced the magnesium-thorium alloy feed stocks for castings, notified Department of the Army that they

I would make one last production run prior to permanently suspending production of the alloys. This last production run was intended to provide sufficient alloys to address needs for a period of time such that the Army could develop alternative alloys. Production was subsequently halted in 1991 and other alloys were developed and introduced into the Army supply system as replacements for magnesium-thorium alloys.

I In addition to replacement of magnesium-thorium alloys with alloys which do not contain thorium, newer aircraft such as the UH-60 (Blackhawk) and AH-64 (Apache) were developed to replace older model aircraft. These aircraft represent the current overhaul workload for CCAD

I and were developed such that they have never utilized magnesium-thorium alloy components.

I I I I I 3 DRAFT FINAL


I 3.0 SURVEY DESIGN

The methodology described in this document has been applied to all accessible areas within the

I project scope.

3.1 THE DECISION

I The decision for each individual area with gamma count rates that are elevated with respect to reference area background is whether the area has radiological contaminants present at

I concentrations that exceed the applicable minimum detectable concentration (MDC). If radiological contaminants exceeding detectable levels were determined to be present, representative samples were collected and analyzed using gamma spectroscopy and alpha

I spectrometry for thorium to identify the specific radionuclides present and to quantify the associated radionuclide concentrations.

I 3.2 INPUTS TO THE DECISION

NUREG 1507 and NUREG 1575 provide methodology for calculation of minimum detectable

I concentrations (MDCs). The MDC is the minimum concentration of the contaminant that can be measured with certainty. The MDC of a scan survey "depends on the intrinsic characteristics of the detector (efficiency, physical probe area, etc.), the nature (type and energy of emissions) and

I relative distribution of the potential contamination (point versus distributed source and depth of contamination), scan rate, and other characteristics of the surveyor" (EPA, 1997). The assumptions used to calculate walkover survey MDCs in the NRC's NUREG-1507, Minimum

I Detectable Concentrations with Typical Radiation Survey Instruments for Various Contaminants and Field Conditions, are appropriate for this survey. Using 2"x 2" sodium iodide (NaI) detectors, the following assumptions apply:

I • NaI 2"x 2" background count-rate of 10,000 counts per minute (cpm).

• NaI 2"x 2" detector count-rate vs. exposure rate values in NUREG-1507, Table 6.3.

I • An observation interval of 1 second (based on a scan rate of 1.6 ftls (0.5 mls).

• A level of performance to yield a d' of 1.38

I I Based on these assumptions, walkover survey scan MDCs applicable at CCAD are 18.3 and 1.8

picocuries per gram (pCi/g) for thorium-232 (Th-232) alone and for the Th-232 decay in equilibrium, respectively. (Given that no alloys have been produced since 1991 and that parts were produced many years prior to that date, assuming equilibrium between parent and progeny is reasonable and the 1.8 pCi/g scan MDC is appropriate.)

I 3.2.1 Data Review

Available existing contamination information was reviewed and the site was visited during initial

I assessment of the area to provide insights into concentrations that may be expected and areas with greater potential for elevated count rates.

I 3.2.2 Background Reference Areas

I Given that thorium-series radionuclides include significant gamma emissions, the presence of magnesium-thorium alloy process residuals can also affect background count rates and thus survey results. To preclude such impacts, each area was subjected to visual inspection prior to the initiation of surveys in an attempt to identify and remove any existing process residuals. Of

I 4 DRAFT FINAL


I special interest were chips and filings in process machines, high-efficiency particulate air

I (REPA) filter-equipped vacuum cleaners, and within bead blasting cabinets including REPA filters for the cabinets. Other radiologically elevated materials including grinding wheels and new/unused bead media were also encountered during the survey.

The concrete floor surfaces were prepared, as necessary, to minimize damage to the sensitive

I window of the Ludlum Model 2224 with a 43-89 dual phosphor alpha/beta scintillation detector; all debris was removed from the floors of the survey unit (SU) prior to initiation of floor surveys.

I I Reference areas were surveyed to establish background conditions. Site background count rates

depend on the radiological characteristics of construction materials (e.g. concrete, steel). To account for background conditions and the associated variability, reference areas were identified consistent with Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM),

I Section 4.5 and subjected to radiological measurements. One reference area is located within the unimpacted portions of Building 8 (CCAD-002) and an additional reference area is located in Bachelor Enlisted Quarters (BEQ) Building-I787 (CCAD-OO1) to provide information relati ve to

I expected background variability. Sixty surface fixed point measurements and smears were collected each day for three days, 30 from concrete reference areas and 30 from steel reference areas to establish background conditions. The Building 8 background measurements for both concrete and steel were compared to survey data obtained in other portions of the facility to determine the levels of contamination at each area.

I 3.3 RADIOLOGICAL SURVEYS

I Radiological surveyslinvestigations were conducted during the period of November 5, 2008

I through June 2, 2009 to investigate the presence of radiological contaminants exceeding background concentrations in the impacted portions of CCAD. Radiological investigations included gamma walkover surveys, beta scan and fixed point measurements and the collection of

I smears. Areas exhibiting count rates that were radiologically elevated with respect to reference area background were subjected to special investigation. Project equipment was also monitored to assure that contamination was properly controlled.

3.3.1 Study Boundaries

I The geographical boundaries for this study include the potentially impacted areas identified in the Historical Site Assessment (HSA) and include the following areas:

I • Portions of Building 8: (See Figure 3-1, Building 8 Impacted Areas):

o The Magnesium-Thorium Machine Room including the roof and ventilation exhaust system;

I o All portions of the Welding Shop including the associated overhead support structures and ventilation exhaust ductwork;

I o Engine disassembly and cleaning areas;

o Temporary waste storage areas;

I o The area of formerly occupied by the Haas Mill;

o Two bead blast rooms at the north end of Building 8 which previously supported engine disassembly and cleaning shops;

I o The electron beam welder area; and

o Grass areas surrounding Building 8.

I 5 DRAFT FINAL

I I~-

I I I I I

r"T METAL SPRAY -.: y & BEAD BLASTING

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I ILASERI

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• Original Impacted Areas

HSA Impacted Areas

1

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Building 8 Impacted Areas

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From Science to Solutions

DRAWN BY DATE

RLH 08/28/2008

Figure 3-1. Building 8 Impacted Areas

-----------------------


I • Building 340 (Room 201)

• Building 1727, Room BIOI, Radiation Safety Officer (RSO) Laboratory.

I • Radioactive Material Storage Buildings and Areas including:

I o Building 132 Radioactive Material Storage and Handling Building (Both

portions of the building and the adjacent grass areas);

o Former Building/Area 339 Waste Storage Area; and

I o Former Building 258 Radioactive Waste Storage and Processing Areas.

I • Building 1825 areas that had been designated for operations involving milling, grinding,

welding, abrasive blasting, assembly, and disposal of thorium components in 1974. (ABBA, 1974)

3.3.2 Gamma Walkovers

I I Relatively small areas of soil exist around buildings in which magnesium-thorium alloy aircraft

engine maintenance is performed. To evaluate such areas for the potential presence of contamination, gamma walkover surveys were performed using 2" x 2" NaI gamma scintillation

I detectors coupled with Global Positioning Systems (GPS) and a data logger. The surveyor advanced at a speed of approximately 1.6 ft per second (0.5 meters per second) while passing the detector in a serpentine pattern approximately 10 centimeters (em) (4 inches) above the ground

I surface. Audible response of the instrument was monitored by the surveyor and locations of elevated audible response investigated. Scanning results are recorded in counts per minute (cpm). Survey results were evaluated based on comparison of count rates of potentially elevated areas

I with the applicable reference area background count rates. As used herein, elevated areas are areas in which the count rate exceeds the applicable background count rate for the media of interest (e.g., soil, asphalt etc) by 2000 cpm. Gamma walkover survey results have been evaluated and plotted on a map of the area using color coding to depict the count rates present (Figure 3-2).

I The most elevated area found during the gamma walkover survey was located at the southwest of

I I

the Hazardous Waste Storage Area, along Crecy (Figure 3-2). Results in this area were found to be between 30,000 and 40,000 cpm using the 2" x 2" NaI gamma scintillation detectors coupled with a GPS and a data logger. Biased sample, CCAD-002 was collected at this location with results yielding 0.2825 pCi/g of Th-228, 0.4547 pCi/g of Th-230 and 0.1475 pCi/g of Th-232 (Table 3-1).

There were no locations encountered such that safety considerations or other restrictions prevented access for normal scanning activities. Reasonable scan coverage was achieved for all

I areas within the scope of the investigation.

I I I • 7 ~IT~L

- - - - --- --- - - - - - - - - -® CCAD

Bldg. L2000, Stop 23 Corpus Christi, 1)( 78419-5260

PREPARED FOR:

DRAWN BY: MP SURVEY PREFORMED BY: MM

SURVEY DATE: 11nl200B• .. .. -.

ENVIRONMENTAL DIMENSIONS INC.

1901 CANDELARIA RD NW ALBUQUERQUE, NM 87107

PREPARED BY:

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ALL READINGS IN COUNTS PER MINUTE (CPM) 2X2- NAIl PROBE WITH LUDLUM 2221 RATE METER

LEGEND

SCALE

~Feet o 70 140 280 420

TITLE

Figure 3-2 BUILDING 8 CLASS 11/ WALKOVER

I I

Corpus Christi Army Depot Radiological Survey Report and Final Status Survey Evaluation

Table 3-1. CCAD Soil Sampling Results

I I I I I I I I I I I

ClientID Date Th-22S' Th230*

Th-232* Location Description

CCADSOIL

001 1/1712009 0.09503 0.4729 0.1684 South of building along Ave D Class 3 Area

CCADSOIL

002 1/1712009 0.2825 0.4547 0.1475

Hot spot location southwest of building along Crecy

Class 3 Area

CCADSOIL

003 1/17/2009 0.3498 0.6623 0.3538

Along yellow brick wall west of building along Crecy

Class 3 Area

CCADSOIL

004 1117/2009 0.2336 0.9497 0.3462

Yellow spot location near drain west of building along Crecy

Class 3 Area

CCADSOIL

005 1117/2009 0.2798 0.7894 0.3683

Yellow spot location just by an western corner of building 8 along

Crecy Class 3 Area

CCADSOIL

006 1117/2009 0.2369 0.3993 0.2734 West of building along Crecy Class 3 Area

CCADSOIL

007 1117/2009 0.2311 0.321 0.2592

Northwest of building near corner of Crecy & Ocean

Class 3 Area

CCADSOIL

008 1/17/2009 0.1224 0.3403 0.1394

North of building along Ocean in high traffic area

Class 3 Area

CCADSOIL

009 1117/2009 0.1805 0.2846 0.3144

Yellow spot location north of building along Ocean

Class 3 Area

CCADSOIL

010 1117/2009 0.07064 0.3079 0.2421 East of building along Fourth Ave Class 3 Area

CCADSOIL-Oll

2/2/2009 0.5248 1.3908 0.497 Near Building 132 Class 3 Area

CCADSOIL

012 21212009 0.07422 0.2914 0.08519 Near Building 132 Class 3 Area

I * Units are pOIg Note: The NRC screening value for Th-232 as specified in NUREG-1757 is 1.1 pCilg thus the above listed results are a maximum of 45% of the screening level inclusive of background.

3.3.3 Soil Sampling and Results

I I Surface soil samples were collected from representative areas with elevated count rates to

evaluate the concentration of thorium decay series radionuclides present. (Although surface soil is generally defined as the uppermost 6 to 12 in, for the purposes of this sampling event, samples

I were limited to the uppermost 6 in interval). Sample collection was in accordance with Environmental Dimensions Inc. CEDi) Health Physics Procedures. A total of twelve soil samples were obtained (Table 3-1) and submitted to Eberline Services Radioanalytical Laboratory for analysis by alpha spectrometry to determine the concentration of thorium radionuclides. Collection and analysis were consistent with the Multi-Agency Radiological Laboratory

I Analytical Protocols Manual (MARLAP) EPA, 2004). Analysis included drying and homogenization of the entire sample volume. Analytical results of these analyses are included in Appendix A and listed on Table 3-1. Concentrations were compared to the NRC screening level

I 9 DRAFT FINAL


I I I I I I I I I I I I I I I I I I

Derived Concentration Guideline Level (DCGL) of 1.1 pCi/g for Th-232 in soil as stated in NUREG-1757. No sample exceeded 45% of the screening level DCGL without regard to background subtraction thus soils were clearly compliant with the stated DCGL. Application of the sign test (Appendix A) clearly indicates that the null hypothesis (i.e., that the area in question exceeds the release criteria) is clearly rejected.

3.3.4 Media Sampling and Results

Media samples were collected for various materials and from areas with elevated count rates, such as terra cotta tile and bead blast material. Sample collection was in accordance with EDi Health Physics Procedures. A total of 23 media samples were collected (Table 3-2) and submitted to Eberline Services' radioanalyticallaboratory for analysis by alpha spectrometry to evaluate the concentration of thorium radionuclides present using procedures consistent with MARLAP (EPA 2004). To the extent practicable, analysis included drying and homogenization of the entire sample volume. Samples were subjected to isotopic separation and analysis by alpha spectrometry for isotopes of thorium. Analytical results of these analyses are included in Appendix A and listed in Table 3-2.

Table 3-2. CCAD Media Sampling Resultsb

Sample Number

Date Collected Th·227· Th·22S· Th·230· Th·232· Location Description

CCAD-001" 11/1012008 233 2540 1080 2120 Magnesium-

Thorium Room

Magnesium-Thorium Room-

Small Metal Plugs

CCAD-002 11/11/2008 0.18 19.6 14.8 20.0 Magnesium-

Thorium Room

Metal filings -down draft area by

Grinding Booth #13

CCAD-003 11111/2008 0.04 2.64 1.95 2.84 Magnesium-

Thorium Room

Shavings from Milling machine (FADAL VMC

4525)

CCAD-004 11/12/2008 -0.04 0.82 0.71 1.07 Magnesium-

Thorium Room Floor tile

CCAD-005 11/12/2008 0.05 0.54 0.62 0.80 Magnesium-

Thorium Room Ceiling Tile

CCAD-006 11112/2008 0.02 0.44 0.21 0.20 Magnesium-

Thorium Room 55 gallon waste

barrel

CCAD-007 11113/2008 0.20 23.1 7.49 22.6 Magnesium-

Thorium Room

Lathe (#55380) formerly involved in fire involving Mg-Th alloys

CCAD-008 11/1712008 0.24 15.0 12.6 14.2 Welding Spray

Area New bead blast

media

CCAD-009 11/1312008 -0.03 2.81 3.07 2.74 Magnesium-

Thorium Room

Overhead dust & fiberglass insulation

CCAD-OlO 11/1812008 -0.03 0.31 0.96 0.26 Building 340

Room 201

Material from bead blast cabinet

#K9640

CCAD-011 11/1912008 -0.04 0.22 0.40 0.34 Building 340

Room 202

Material from bead blast cabinet

#P7058

10 DRAFT FINAL

I I


Table 3-2. CCAD Media Sampling Resultsb (Continued)

I I I I I I I I I I I I I I I I I

Sample Number

Date Collected

Th-227* Th·228* Th·230* Th-232* Location Description

CCAD-012 11/19/2008 0.02 0.03 0.05 0.01 Magnesium-

Thorium Room

Oil sludge from Monarch lathe

#38750-R

CCAD-013 11/19/2008 0.00 0.03 0.14 0.03 Magnesium-

Thorium Room

Oil sludge from Cincinnati milling

machine #4A30SM

CCAD-014 11/19/2008 0.10 0.94 3.67 0.95 Magnesium-

Thorium Room

Oil sludge from Cincinnati milling machine #ZE1091

CCAD-015 11/19/2008 0.04 0.03 0.06 om Magnesium-Thorium Room

Oil sludge from FADAL VMC-4525

Dust from

CCAD-016 1/7/2009 0.00 95 68 130 Magnesium-

Thorium Room

downdraft booth catch basin, model

TB5048 SN SR#96824

CCAD-017 1/7/2009 0.00 74 38 110 Magnesium-

Thorium Room

Metal fillings from inside Giddings &

Lewis machine lathe

CCAD-018 1/7/2009 0.00 5 10 6.3 Magnesium-

Thorium Room Monarch lathe #

38750-R Oil CCAD-018 Duplicate

1/7/2009 0.00 5 10 6.8 Magnesium-

Thorium Room Monarch lathe #

38750-R Oil

CCAD-019 1/7/2009 0.00 0.02 0.01 0.02 Building 340 Barrel of bead blast

media

CCAD-020 1/7/2009 0.00 20 18 29 Building 340

Exhaust ductwork residual dust

material, from inside duct from 201 to exterior of

building

CCAD-021 1/7/2009 0.00 2.4 2.8 4.0 Machine Shop Aluminum Oxide Grinding Wheel

CCAD-022 6/4/2009 0.00 0.2 0.2 0.08 Magnesium-

Thorium Room Terra-Cotta

CCAD-023 6/4/2009 0.00 5 3 4 Building 340 In-use bead blast

media * Umts are pCi/g. • Results are estimated. b All results are rounded to three figures.

Review of radioanalytical results reflect:

1) The presence of over 1000 and 2000 pCi/g of uranium- and thorium-series radionuclides respectively, in and/or on small metal plugs (Media Sample CCAD-OOl). This sample also contained over 200 pCi/g of Th-227, a U-235 daughter product thus indicating the presence of members of each of the three naturally occurring series. These plugs were disposed of as radioactive waste.

2) Metal filings from the floor around the down draft table contained about 15 and 20 pCi/g of uranium and thorium-series radionuclides and were disposed of as radioactive waste (Media Sample CCAD-002).

11 DRAFT FINAL


I 3) Concentrations of uranium- and thorium-series radionuclides in shavings, chips, floor

I tiles, and in dust in overhead support structures and in insulation each was elevated relative to background. All such material was disposed of as radioactive waste.

4) New bead blast media exhibited variable concentrations of uranium- and thorium-series radionuclides that ranged from less than 1 pCi/g for both uranium- and thorium-series

I radionuclides to about 15 and 13 pCi/g for uranium- and thorium-series radionuclides, respectively.

I 5) Concentrations of uranium- and thorium-series radionuclides ranged from 3 pCi/g to about 5 pCi/g for uranium- and thorium-series radionuclides, respectively, for in-use bead blast media.

I 3.3.5 Location Surveys and Removable Contamination Evaluations

I The fixed-point measurements result in units of cpm but have been converted to the units of the surficial release criteria of disintegrations per minute per 100 square centimeters (dprn/100 cm2

with the following equation:

I Calculation performed for beta measurements.

dpm J (Rg) - (Rb )Result = ----'----( 2

100cm (co Xc {Probe AreaJ I

I s\ 100

I where Rg is the static data point gross count rate (cpm) Rb is the instrument field background count rate (cpm)

I Ci is the instrument 21t efficiency (cprn/dpm) Cs is the surface efficiency Probe Area is the open area of the detector face (cm2

)

I The surface efficiency (cs) of a material comes from the absorption characteristics and the backscattering effects of a given material. ISO-7503 recommends using a surface efficiency of 0.5 for radionuclides with maximum beta energies exceeding 0.4 Mega-electron volts (MeV) and

I a surface efficiency of 0.25 for alpha emitters and radionuclides with beat energies between 0.15

I MeV and 0.4 MeV. This provides a more conservative assessment of the surface efficiency.

Removable activity was measured by smearing an area of approximately 100 cm2 with a dry

I filter paper; alpha and beta activity on the smear sample was then measured. Removable alpha and beta surface activity samples (smears) were collected at each fixed-point measurement location. Each smear collected was counted for radioactivity, and documented prior to conclusion of the survey.

Removable contamination levels present on structures were compared with the DCGL-based

I investigation levels. Removable contamination should generally be 10% or less of the total activity.

I 3.4 INSTRUMENT USE AND QUALITY ASSURANCE

Survey instruments used for radiological measurements were:

I • selected based on the survey instrument's detection capability for natural thorium;

I 12 DRAFT FINAL

------------------


I • calibrated in accordance with manufacturers' recommendations and American National

I Standards Institute (ANSI) N323A, Radiation Protection Instrumentation Test and Calibration - Portable Survey Instruments (ANSI, 1997);

• calibrated with a National Institute of Standards and Testing (NIST) source to obtain a quantitative measurement; and

I • operated and maintained by qualified personnel, in accordance with EDi Health Physics

I Program procedures (e.g., physical inspection, background checks, response/operational checks).

Radiological field instrumentation used for this survey has been calibrated in accordance with ANSI-N323A within the past 12 months (or more frequently if recommended by the

I manufacturer). Quality control checks were performed at the beginning and end of each day consistent with EDi Health Physics Procedures. Radiological instruments operated as designed with no quality problems being experienced. All radiation survey data obtained during these

I efforts used radiation measurement instrumentation that achieved all performance requirements.

I The instruments selected for this site included those to be used for the gamma walkover surveys as well as instrumentation to assure compliance with contamination limits applicable to project equipment and analytical samples. Field instrumentation used are presented in Table 3-3.

I Table 3-3. Survey Instrumentation Used at CCAD

I I I I

Measurement Type Detector Type Detector Area Instrument

Model Detector Model

AlphalBeta Scan/Static

Zinc Sulfide (ZnS) scintillator

Active - 125 cm2 Open - 100 cm2

Ludlurn 2224- I Ludlum 43-89

AlphalBeta Smears ZnS (Silver (Ag» Active and Open 20.3 Ludlum 2929 Ludlum 43-10-1 scintillator cm2

Gamma Scan/Static 2"x 2" NaI gamma 2" (5.1 cm) (44-10) Ludlum 2221 Ludlum 44-10 and (44-10) scintillator (44-10) Active - 584 cm2 Ludlum 43-37 AlphalBeta Gas flow Open - 430 cm2 (43-37) Scan/Static (43-37) proportional (43-37) Beta Static N/A N/A Ludlum Model 19 N/A AlphalBeta Geiger Mueller 12 cm' Ludlum Model 3 Ludlum 44-9 Scan/Static

3.4.1 Pre-Operational Checks

I Pre-operational checks were performed prior to each use and whenever instrument response became questionable. Pre-operational steps included:

I • Verifying instrument calibration was current.

• Visually inspecting instrument for physical damage that may affect operation.

I • Performing satisfactory battery check, (manufacturer's operating instructions defined satisfactory battery check).

• Checking cable connection and cable integrity.

I 3.4.2 Daily Background Checks

I • Background checks were performed at the same location in a reproducible geometry at

the beginning and end of each survey day and any time the instrument response appeared questionable.

II 13 DRAFfFINAL


I • Site-specific instrument background was established upon arrival at the site by detennining the mean value of 10 one minute background counts.

I • The acceptance criterion for background was a background count rate within two standard deviations of the mean background value.

I 3.4.3 Daily Source Check

• Radiological field instruments used for gamma walkover surveys were perfonnance checked at the beginning and end of each survey day to confinn acceptance and usability

I of data collected. The established acceptance criterion was instrument background within

I the range of background and source checks within ±20% of the known value. Background count rates more than two standard deviations from the mean would have resulted in appropriate investigation to include recount of background. No deviations were experienced.

I • Source checks were perfonned at the same location in a reproducible geometry at the

I beginning and end of each survey day. There were no occasions during the survey day that instrument response appeared questionable; therefore, additional source checks were not required.

I • The Ludlum Model 2224-1 ratemeterlscaler coupled with a Ludlum Model 43-89 ZnS

plastic scintillator hand held probe and the Ludlum Model 2221 scaler coupled with a Ludlum Model 2221 with a 43-37 gas proportional detector were checked with Th-230 and strontium-yttrium-90 (SrY-90) sources.

I • The Ludlum Model 2929 scaler coupled with a Ludlum Model 43-10-1 smear counter was checked with Th-230 and SrY-90 sources.

I • The Ludlum Model 2221 scaler coupled with a 44-10; 2" x 2" NaI Gamma Scintillation Detector and Ludlum Model 19 MicroR Meter were checked with a cesium-137 (Cs-137) source.

I Sources were stored and handled as specified by EDi Health Physics Procedures and were shipped in accordance with Department of Transportation (DOT) regulations.

I 3.4.4 Static and Scan Minimum Detectable Concentrations (MDCs)

I The minimum detectable concentration is an activity level that a specific instrument and measurement technique can be expected to detect 95% of the time. Site-specific detection sensitivities (Scan MDCs) for CCAD have been calculated in accordance with the approach

I detailed in NUREG-1507. These calculations are provided in Appendix B of this document and are listed below in Table 3-4.

Sample counting times vary in order to obtain desired minimum detectable activity (MDA) or MDC values. The longer a sample is counted, the lower the MDNMDC value. Sample count times are long enough to yield the required sensitivity (DCGL). Discussed in Section 3.7, the

I I DCGL values used for evaluating the areas of concern at CCAD was 300 dprn/lOO cm2 for beta.

The beta DCGL was used in lieu of the alpha DCGL based on detectability, precision and accuracy. The alpha DCGL mathematically equates to 600 dprn/100 cm2

.

I I 14 DRAFT FINAL

I I


Table 3-4. Evaluation of Instruments for Use at CCAD1

I Detector Radiation Model of Interest

Ludlum Beta 43-37

Ludlum Beta 43-89

Ludlum AlphalBeta 43-10-1 Ludlum Gamma 44-10

Reference Area

(Background)

I Count Time

(min) 1

I 2

20

I 1

I

Background (cpm)

Sample Count Time (min)

Total Efficiency (cpmldpm)

ScanMDC (dpml

IOOcm2)

Static MDC (dpml

lOOcm2)

732 (concrete)

1 0.126 136 (beta) 76 (beta)

236 (metal) 244 (concrete)

2 0.12 271 (beta) 218 (beta) 48 (alpha)

Alpha 0.05 Beta 42

1 0.601 N/A 204 (beta) 25 (alpha)

N/A 1 N/A 1.8 pCilg @ 50 cm/s for Th-232 + progeny

N/A

The denvallon of site-specIfic scan MDCs are presented In Appendix B.

I 3.5 RADIOLOGICAL CONTAMINANTS OF CONCERN

Contaminants of concern (COCs) are limited to radionuclides in the naturally occurring thorium

I decay series. Given that thorium is naturally occurring and is present across all portions of the survey area, the survey distinguishes SU radioactivity from activity that is elevated with respect to relative background as precisely as practicable. Such efforts include the determination of

I background count rates for various media (e.g., soil, concrete, steel) in the survey area prior to conclusion of the survey and comprehensive assessment of data as an integral part of the identification of areas of elevated activity.

I 3.5.1 Characteristics of Magnesium-Thorium Alloy Contamination

I Magnesium is a very soft metal; therefore, large particles are generated when magnesium alloys are subjected to grinding or machining. As such, most maintenance operations generate

I I

magnesium-thorium alloy fines (e.g., chips and filings) which are much larger than those commonly associated with most other metals. Such chips and filings offer limited potential to contaminate structural surfaces as they generally collect on surfaces rather than being absorbed into pores, therefore, contamination from this material generally does not become fixed. Any resultant contamination is relatively easy to remove on a routine basis such that very limited

I contamination typically collects on surfaces and residual contamination occurs primarily in areas such as cracks and seams in concrete floors, etc. The fact that magnesium-thorium particles are generally relatively large also results in the ineffective use of smears/swipes as an indicator of

I the presence of removable contamination because such contamination does not readily remain in place on the smear or swipe filter media. Further, given the nature of the removable contamination that results from magnesium-thorium alloy maintenance and the fact that alpha

I emissions are subject to major self-absorption within the alloy, scan and fixed point beta (or gamma) measurements generally must be used for the evaluation of the presence of magnesiumthorium alloy residuals. Although smears may not be fully effective in evaluating removable

I contamination, they can be utilized to augment fixed point and scan measurements. The potential for volumetric contamination is limited to impacted ceiling tiles (CCAD-OI5) in the MagnesiumThorium Machine Room. Given that these ceiling tiles were disposed of as radioactive waste due to the inherent issues associated with their survey and release, contamination is limited to activity on the surface and surveys were limited to evaluation of surface activity.

I 15 DRAFT FINAL


I 3.5.2 Exceptions

I Exceptions to the nature of magnesium-thorium alloy contamination described above include effects from fires, welding, and chemical removal of thin layers of magnesium-thorium surfaces primarily by use of materials such as chromic acid. Although chemical removal of protective coatings and corrosion from magnesium-thorium alloys have not been performed in any existing

I areas of CCAD, welding on magnesium-thorium alloys has been performed in the Welding Shop area and may have been performed in the Electron Beam Welder Area. In addition, site information including anecdotal input from current and former employees indicates that several

I fires have occurred in the Magnesium-Thorium Machine Room as a result of the spontaneous ignition of magnesium metal fines. As such, horizontal surfaces such as I-beams above and adjacent to such operations were subjected to comprehensive surveys to evaluate the potential for

I elevated contamination from smoke/fumes from fires and welding on magnesium-thorium alloys. In addition, ventilation exhaust systems servicing such areas were subjected to comprehensive radiological surveys.

I 3.5.3 Characteristics of the Thorium Decay Series

I Given that all magnesium-thorium alloys were produced prior to 1991, it is reasonable to assume

I that natural thorium and "all of the progeny are in secular equilibrium, that is, for each disintegration of thorium-232 there are six alpha and four beta particles emitted in the thorium decay series" (DOD, 2000). Beta measurements provide a more accurate evaluation of thorium

I contamination on structural surfaces due to the problems inherent in measuring alpha contamination on rough, porous, and/or dirty surfaces. For the thorium series in secular equilibrium, for each beta emission there are approximately 1.5 alpha emissions - a beta to alpha

I ratio of 0.67 (NRC, 2003). For magnesium-thorium alloys, these considerations are compounded in that the thorium is contained within the alloy such that self-absorption of the alphas within the magnesium matrix makes it very difficult to accurately quantify activity based on alpha emissions. As such, beta particle emissions were used as recommended in Section 4.3.2 of MARSSIM and Appendix 0, Section 0.3.3.5, Volume 2, NUREG-1757.

I Given that four beta particles are emitted per disintegration of the thorium-232 parent and that

I many of the betas are relatively energetic, beta particles are used to quantify contamination that may be present from natural thorium. Th-232 progeny (Table 3-5) include several beta-emitters including actinium-228 (Ac), bismuth-212 (Bi) and thalium-208 (1'1) ( with maximum energies

I exceeding 1 Mega-electron volt (MeV) as well as lead-212 which emits betas with maximum energies ranging from 158 to 573 kiloelectron volts (keV) and radium-228 (Ra) which emits betas with a maximum energy of 0.0389 MeV. The Ra-228 betas are difficult to measure given

I their low energy. As such, the emissions of the other beta emitters serve as the basis for activity measurements.

3.6 DERIVED CONCENTRATION GIDDELINE LEVELS (DCGLs)

I The "Screening Values of Common Radionuclides for Building-Surface Contamination Levels" as defined in NRC SECY-98-242 lists "D&D Screening Values". The value specified as representing the 90th percentile of the output dose distribution as being equivalent to 25 milliremI per year (mrem/year) for Th-232 is 7.3 dprn/100 cm2

. NRC guidance in Re-Evaluation of the

I Indoor Resuspension Factor for the Screening Analysis of the Building Occupancy Scenario for NRC's License Termination Rule - Draft Report (NUREG-1720) recommends a resuspension

Ifactor of 1 x 10-6 m- • With technical assistance from members of the NRC Headquarters staff (e.g., Messrs Dwayne Schmidt, Ralph Cady and Chris McKinney), the screening level DCGL

I 16 DRAFT FINAL


I was recalculated using D&D Version 2.1 with the only change being the aforementioned

I I

modification of the value of the resuspension factor. Using a 95% confidence level, this change resulted in an updated screening level Derived Concentration Guideline Levels (DCGL) of 102 dpml100 cm2 for thorium-232. Although thorium-series radionuclides consist of six alphaemitting radionuclides and four beta-emitting thorium progeny (Table 3-5), only three betaemitting thorium progeny have been used to calculate the DCGL given that Pb-212 beta

I emissions are at such a low energy as to be difficult to detect. Consequently, the total alpha and total beta activity of 612 and 306 dpml100 cm2

, respectively, constitute the DCGLs for total alpha and total beta, respectively, with the beta DCGL serving as the basis for decommissioning and license termination decision-making. These DCGL values are rounded to 600 and 300 dpml100 cm2 for alpha and beta, respectively.

I Table 3-5. Characteristics of Thorium-Series Radionuclides

I I I I I I I I I * Primary radlallons and energies of Interest

Isotope" Half-life Radiation* Enere;v Level (MeV)* Frequency % Th-232 1.405 x lOW y Alpha 3.95 23

Alpha 4.01 77 Ra-228 5.75 y Beta 0.0389 100 Ac-228 6.13 h Beta 0.983 7

1.014 6.6 1.115 3.4 1.17 32 1.74 12 2.08 8

Th-228 1.913 y Alpha 5.34 26.7 5.42 72.4

Ra-224 3.66d Alpha 5.45 4.9 5.686 95.1

Rn-220 55.6 s Alpha 6.288 99.9 Po-216 0.15 s Alpha 6.78 100 Pb-212 10.64 h Beta 0.158 5.2

0.334 85.1 0.573 9.9

Bi-212 60.55 m Alpha 6.05 25 6.09 9.6

Beta 1.59 8 2.246 48.4

Po-212 (64%) 305 ns Alpha 8.785 100 TI-208 (36%) 3.07m Beta 1.28 25

1.52 21 1.80 50

Pb-208 Stable N/A N/A N/A ..

• Thorium (Th) ,radium (Ra), actinium (Ac), radon (Rn), polonium (Po), lead (Ph), bismuth (Bi), thalium (Tl)

I Investigation levels of 50% of the DCGL or the instrument MDC, whichever is greater, have been used herein. For the Ludlum Model 2221 with a 43-37 gas proportional detector the investigation level will be 150 dpml100cm2

, which is 50% of the DCGL. The MDC for the I Ludlum Model 2224 with a 43-89 alpha/beta scintillation detector is 218 dpml100cm2, which is

the instrument MDC.

I Small areas of elevated activity that exceed the DCGL will be examined using elevated measurement comparisons (EMC). Using the approach suggested in MARSSIM, area factors were determined using D&D Version 2.1 for the small areas with elevated radionuclide activity

I 17 DRAFT FINAL


I (Table 3-6 and Table 3-7). The area factor is defined as the magnitude by which the

I concentration within the small area of elevated activity can exceed the DCGL while still maintaining compliance with the release criterion. These factors were used to establish DCGLs for elevated measurement comparisons (DCGLEMc) to provide a reasonable level of assurance

I that any small area of elevated residual activity is not significant. The derived concentration guideline level for the EMC is defined as:

DCGLEMC = Area Factor * DCGL

I Table 3-6. Volumetric Dose to Source Ratio (DSR)

I Table 3-7. Volumetric Area Factors

I

Area (m2) 20,000 2,000 100 30 15 10 5 2 1

Th-232 + C 3.04 3.04 3.04 3.04 3.04 3.04 1.52 6.08£-1 3.04£-1

Area (m2 ) 20,000 2,000 100 30 15 10 5 2 1

Th-232 + C 1.0 1.0 1.0 1.0 1.0 1.0 2 5 10

I I During the evaluation of measurement data for each SU, any measurement that is equal to or

greater than the DCGL has been investigated by comparison with the DCGLEMC using the elevated measurement approach to determine if the elevated measurement is acceptable (Section

I 8.5.1 of MARSSIM). Using statistical test it is possible that a SU may pass even though it contains elevated measurements. Using the EMC against the investigation levels is only an assurance that the elevated measurements will receive proper attention and that small areas with elevated results are identified. The EMC is used to flag potential failures in a remediation process, it is not used to determine whether or not a site meets release criterion.

I 3.7 DECISION ERRORS

I There are two types of decision error: Type I (alpha) and Type II (beta). Type I error is described

I as the probability of determining that the median concentration of a particular constituent is below a criterion when it is actually not (false positive). Type II error is described as the probability of determining that the median is higher than criteria when it is not (false negative). The probability of making decision errors can be controlled by adopting an approach called hypothesis testing.

I Ho = the median concentration in the SU exceeds that in the reference area by more than the DCGL.

I I This means the site is assumed to be contaminated above criteria until proven otherwise. The

Type I error, therefore, refers to the probability of determining that the area is below the criterion when it is really above the criterion (incorrectly releasing the SU). The Type II error refers to the probability of determining that the area is above the criterion when it is really below the criterion (incorrectly failing to release the SU).

I Based on the above null hypothesis, lowering the Type I error decreases the probability of residual contamination exceeding site criteria while increasing the Type I error would have the

I inverse effect. By contrast, lowering the Type II error decreases the probability of releasing a SU in which residual concentrations of contamination are below site criteria generally resulting in increased costs for the removal of residuals that actually achieve criteria. Increasing the Type II

I 18 DRAFT FINAL


I error, by contrast, typically results in increased sampling costs but a reduced probability of failing

I to release a SU that actually achieves cleanup criteria.

The Type I error for CCAD has been set at 0.05 and the Type II error has been set at 0.2. This means that there is a 5% probability of erroneously releasing a SU whose true mean is greater than the DCGL and a 20% probability of not releasing a site that has attained the DCGL. This implies

I that if the mean is at a concentration that would produce an exposure at the criterion level, there would be a 5% probability of erroneously finding it below the criterion or a 20% probability of erroneously finding it to be greater than the criterion.

I 3.8 RELATIVE SHIFT

I The relative shift is defined as the No where 11 is the DCGL - LBGR (lower bound of the gray region) and a is the standard deviation of the contaminant distribution. MARSSIM recommends that the LBGR initially be set one half of the DCGL, but should be adjusted if necessary to

I provide a No value between the recommended range of 1 to 3.

I The value for a can be estimated in a number of ways. Sometimes there is data from the site that is sufficient to calculate the standard deviation within the SU, aS (note that for Class 1 units a represents the standard deviation just prior to release and after material above the criterion is thought to be removed). Data may also be available from a reference or background area.

I Reference area data can be used to estimate a standard deviation, Or, if the contaminant is present in background. The larger of as and Or should be used when calculating N.o.

For the CCAD survey areas, the DCGL has been set to 300 dprn/lOO cm2 (Section 3.7), so the I LBGR =DCGU2 =150 dprn/lOO cm2• The value for 11 is, therefore, DCGL - LBGR =300 -150

= 150 dprn/lOO cm2• The standard deviation varies between each SUO

I 3.9 THE NUMBER OF SAMPLES PER SURVEY UNIT

I The calculated value for No can be used to obtain the rrummum number of samples/measurements necessary to satisfy requirements using the MARSSIM equation presented below:

I N =(ZI_" + ZH)2

3(Pr -0.5)2

I The calculated value, N, is the combined number of samples/measurements from the reference area

I and each Su. Zl-a and Zl-~ are critical values that can be found in MARSSIM, or statistics textbooks and handbooks, and Pr is a measure of probability available from MARSSIM Table 5.1.

Typically, NI2 samples/measurements are collected in each SU and NI2 are collected in the reference area. That is, NI2 samples/measurements are conducted in each SU and N/2

I samples/measurements are conducted in the reference (background) area. However, the statistical methods are still valid if there are an unequal number of samples/measurements in the SU and reference areas. A 20% increase in this number is recommended to account for lost or unusable

I samples/measurements. The calculated values apply to each SUO The number of samples required in each SU will vary by area.

I I 19 DRAFT FINAL


I 3.10 CLASSIFICATION OF SURVEY UNITS

I Surveys including scoping surveys were designed so that, to the extent practicable, data collected could be used for final status survey. Because there was limited data available at this time of

I I

initial survey, certain assumptions were made with regard to survey planning based on the contamination potential of each So. These assumptions were used to design the radiological survey so that a sufficient quantity and quality of data is collected for potential future use in a final status survey. The scanning coverage, SU area and random verses systematic measurements are the primary issues considered when classifying a So. Information from the HSA was the primary source for initial "classification" of SUs.

As described in the MARSSIM, SUs are broken into three classes (Table 3-8). A SU is classified

I as a Class 1 SU if it meets anyone of the following criteria:

1. The area is or was impacted (potentially influenced by contamination);

I 2. The area has potential for delivering a dose or risk above criteria; 3. There is potential for small areas of elevated activity; or 4. There is insufficient evidence to classify the area as Class 2 or Class 3.

I A SU is classified as a Class 2 unit if:

1. The area has the potential to have been impacted;

I 2. The area has low potential for delivering a dose or risk above criteria; or 3. There is little or no potential for small areas of elevated activity.

A SU is classified as a Class 3 unit if:

I 1. The area has only minimum potential for being impacted; 2. The area has little or no potential for delivering a dose or risk above criteria; and

I 3. There is little or no potential for small areas of elevated activity.

Table 3-8. MARSSIM "Suggested Survey Unit Areas" (DOD, 2000)

I I I

Classification Su~~ested Area

Class I Structure: up to 100 m2

Land Area: up to 2,000 m2

Class 2 Structure: 100 to 1,000 m2

Land Area: 2,000 to 10,000 m2

Class 3 Structure: No Limit Land Area: No Limit

I 3.10.1 Estimate the SamplelMeasurement Grid Spacing

Class 1 and Class 2 grid spacing in overhead areas is calculated as follows:

B=LF/N

I I B = linear grid spacing between samples on main structural beams (ft)

LF = total linear ft of main structural beams in the SU N = number of samples required in the SU

I I 20 DRAFT FINAL


I The appropriate spacing for each Class 2 grid on the floor level is calculated as follows:

100Om: L - . 0.866 x 9 = 128.3m'l 0.866 x NI -~

I A = area of SU (lOOOm2 is the maximum area for a Class 2 structure SU) L = linear spacing for a triangular grid SU N = number of samples required in the SU (i.e., 9; see Section 3.10)

I Based on MARSSIM, Class 3 SU measurement locations are commonly determined via random number generation.

I In summary, grid spacing for overhead areas/structural steel is dependent upon the total linear

I length of main structural support beams in the SU and the number of samples required to be collected in the SUo The Class 2 spacing on the floor and wall area should not exceed 128.3 m.

3.11 OPTIMIZATION OF DESIGN FOR OBTAINING DATA

I The following actions, methods, and techniques were utilized throughout the data collection process to minimize cost, field effort, and impacts to future associated work.

I • Radiological surveys and collected samples were obtained in a defensible manner. Data was collected and managed so that it will be usable in future area evaluations or investigations, if appropriate.

I • Investigations utilize the graded approach of site investigations. Areas of highest potential were scrutinized the most, with less effort expended in areas less likely to contain the target contaminants.

I 3.12 DATA QUALITY OBJECTIVES (DQOs), QUALITY ASSURANCE AND

QUALITY CONTROL (QAlQC)

I • 95% usable data after validation. All data appears to be usable after validation.

I • All radiological survey instruments were operated and maintained by qualified personnel, in accordance with EDi Health Physics Program procedures

• Gamma walkover data was electronically recorded, subjected to computer-assisted

I assessment and visually displayed in color-coordinated maps. Identified elevated areas were subsequently subjected to additional radiological investigation and sampling as appropriate.

I I • The QAlQC data that would validate both the instrument survey measurements and the

analytical results. QAlQC related data from the analytical laboratory is provided in Appendix E.

• Instruments calibration data along with the results of the daily source and background checks are located in Appendix E.

I I I 21 DRAFT FINAL


I 4.0 SITE SAFETY AND HEALTH

I Site safety and health requirements for site tasks were based on potential physical, radiological, and chemical hazards. The survey team followed the general site safety and health requirements

I documented in EDi safety and health. These documents/procedures were written to comply with the NRC and associated Agreement State, and Occupational Safety and Health Administration (OSHA), requirements.

I 4.1 SAFETY AND HEALTH TRAINING

I All survey team personnel were required to meet the training requirements stated in the Site Safety and Health Plan to include Hazardous Waste Operations and Emergency Response (HAZWOPER) training (40-hour and current 8-hour refresher), medical surveillance, health and

I safety orientation, and radiation awareness training. Safety and health records were kept and maintained according to EDi procedures.

4.2 TASK-SPECIFIC PERSNAL PROTECTIVE EQUIPMENT

I The minimum level of protection for non-intrusive survey activities at this site was Level D Protective Equipment (safety boots and safety glasses). For intrusive activities such as soil sampling and for activities that involve the handling of potentially contaminated objects or soils,

I the minimum level of protection was Modified Level D Protective Equipment. Modified Level D Protective Equipment is defined as:

I • impermeable disposable inner gloves (i.e., nitrile, polyvinyl chloride, or equivalent)

safety boots (ANSI Z41)

I safety glasses with side shields (ANSI Z87.1)

I The designated on-site Site Safety and Health OfficerlRadiation Protection Manager (SSHO/RPM) has the responsibility for determining if an upgrade in Personal Protective Equipment (PPE) requirements was required once the survey team has mobilized to the site.

I 4.3 PERSONNEL MONITORING REQUIREMENTS

I Based on the minimal potential for levels of radiological constituents that could reasonably result in survey team members receiving external or internal radiation doses exceeding 10% of regulatory dose limits (i.e., 100 millirem), therefore dosimetry and routine surveillance was not required.

I There was a slight potential for the transfer of residual contamination from the soil to the hands and/or boots of the investigation team. Hands and feet of all personnel were frisked at the completion of soil sampling and prior to each departure from the field. No personnel

I contamination was detected during the project.

I I I 22 DRAFT FINAL


I 5.0 SAMPLE AND WASTE DISPOSITION

The EDi Project Health Physicist was responsible for proper handling of all collected samples.

I Samples were surveyed, packaged, sealed in strong, tight containers and shipped from CCAD to

I Eberline Services Radioanalytical Laboratory in Oak Ridge, TN. Most samples did not exceed the concentration and total quantity thresholds for classification as a radioactive material as defined in 49 Code of Federal Regulations (CPR) 173.403, Transportation. Samples (e.g. Media

I I

Sample CCAD-001) classified as radioactive were shipped in full compliance with the requirements established in 49 CPR Parts 172 and 173 and 10 CPR 71. In all cases sample containers were verified to be free of loose contamination and the dose rate to the outside of the shipping container verified to be less than 0.5 mrem/hr. Furthermore, no areas contained levels of radiological constituents such that sampling of the areas was deferred due to safety and/or transportation considerations.

Decontamination was performed at each survey area following sampling to preclude the

I possibility of contamination transfer. These efforts included the removal of all visible soils followed by a dry wipe down. After dry decontamination was completed, sampling equipment was subjected to radiological surveys which documented that release was appropriate without

I radiological controls.

I Efforts were used to minimize the generation of Investigation Derived Waste (IDW). Potentially contaminated waste was segregated from other waste materials. Excess soil from soil sampling

I was disposed of at the place of origin by returning it to the shallow hole from where it came. The hole size was minimized to as small as practicable to accomplish the desired task. PPE and other waste items that could not be decontaminated or reused were disposed of as IDW. All waste

I generated was containerized in appropriate drums and was staged, appropriately labeled, and transferred to the Radioactive Waste Storage Building (Building 132) for disposal as radioactive waste by transfer to a properly permitted disposal facility.

I I I I I I I I 23 DRAFT FINAL


I 6.0 SURVEY RESULTS

I 6.1 INTRODUCTION

I This report presents the results of the surveys perfonned in all impacted areas of CCAD (Section 3.3.1). The final status survey was requested by the CCAD Safety Office and by the CCAD Radiation Safety Officer (RSO), Mr. Eduardo Perez. Radiological survey infonnation was

I collected to confinn that no residual radioactive material from licensed activities was present inside any of the areas listed above. The primary COCs are limited to radionuclides in the naturally occurring thorium decay series (Table 3-5). Radiological survey instrumentation was selected so as to maximize the ability to detect beta emissions from these COCs (Table 3-4).

I Appendix D contains detailed survey infonnation from surveys CCAD-OO 1 thru CCAD-088 to include applicable samples locations and background data for each survey. Although equipment within these areas was surveyed, equipment is being addressed independent of building/structure

I surveys.

6.2 SUMMARY OF SURVEY APPROACH

I I Each building/room was surveyed in accordance with guidance provided in MARSSIM.

Background reference areas were established for each different type of material (e.g., concrete, metal, etc.) and in some cases for individual rooms. The preliminary MARSSIM survey indicated that 18 samples were required per area (9 SU measurements and 9 reference area measurements). To ensure compliance with MARSSIM this was increased to 40 (20 SU

I measurements and 20 reference area measurements) for a majority of the areas. Depending upon the potential for contamination in each area, a MARSSIM Class 1 systematic grid, Class 2 systematic grid or Class 3 random grid was established. Removable contamination was measured

I as well as fixed contamination at the systematic and random sample locations.

I All impacted areas of CCAD have been evaluated to ensure compliance with MARSSIM. This includes;

• All measurements are below the DCGLw or, if applicable, small areas of contamination are evaluated against the DCGLEMc.

I • Scan coverage was sufficient for each area.

• Removable contamination measurements are less than 10% of the total activity.

I • A sufficient number of measurements were collected to correctly evaluate the area.

I • The area passes the Wilcoxen Rank Sum (WRS) test, if required. MARSSIM (Table 4,

Roadmap-13) states that if the difference between the maximum SU measurement and the minimum reference area measurement is less than the DCGL then the SU meets the release criterion, therefore a WRS test is not required.

I • All areas have been accurately classified as a MARSSIM Classl, Class 2 or Class 3 SU in accordance with Section 3.10 of this document.

I This report states that all or 100% of the accessible areas of each impacted area were surveyed. For purposes of this report the tenn accessible does not include areas under large immobile machinery or equipment or areas in which safety concerns overrode. If it was not possible to

I collect a fixed or scan measurement at a location, a smear was used to assess the radioactivity (i.e. around edges of large machinery). A 60 ft lift was used to survey all overhead areas to

I 24 DRAFT FINAL

I I I I I I I I I I I I I I I I I I


minimize the potential of an unsafe environment, as such, only areas where safety was a concern were not surveyed. Such areas will be noted throughout Section 6.4.

6.3 EVALUATION PROCESS OF IMPACTED AREAS

This report includes evaluation of all impacted areas located at CCAD. The evaluation process consisted of the following:

• Evaluation in the historical site assessment as to whether individual areas were impacted as defined in MARSSIM.

• Scoping surveys appropriate for each impacted area.

• Remediation of areas which exceeded derived concentration guideline levels.

• Collection of final status survey data to evaluate whether collected data demonstrated compliance with the DCGLw. Areas exceeding DCGLs were subjected to remediation and re-classification as MARSSIM Class 1 areas. Areas exceeding investigation levels (50% of the DCGLw or measurement results greater than the MDA) were classified as MARSSIM Class 2 areas and subjected to systematic sampling. (All impacted areas were subjected to comprehensive scan surveys which to the extent practicable included all accessible areas.

• Each SU was individually evaluated to assure that it achieved the criteria appropriate for the assigned MARSSIM classification. Evaluations included assuring:

• An adequate scan percentage; • That a sufficient number of samples was collected; and • That systematic or rand01Tl: sampling was performed consistent with MARSSIM.

6.4 SURVEY RESULTS

Information provided in this section summarizes survey results. Appendix A contains Laboratory Analysis Reports for media (e.g., terra cotta tile, grinding wheels, and new bead blast media) which exhibited elevated radioactivity but were unrelated to the presence of licensed materials. Appendix B specifies the applicable MDCs for Radiological Contaminants of Concern at Corpus Christi Army Depot. Appendix C reflects elevated radioactivity resultant from elevated concentrations of naturally occuning radioactive materials (NORM) in the specified constituents. Appendix D contains detailed survey information including survey forms, associated maps and information on instrumentation used. Instrument calibration and quality control check information is provided in Appendix E. WRS test results and supporting information can be found in Appendix F for the areas specified in Table 6-1.

Table 6-1. Wilcoxon Rank Sum Tests

Room* Area SU NumberlWRS Reference

Haas Mill Floor SU-A

Metal Spray Walls SU-A

Overheads SU-B

Floor SU-C

Floor SU-D

Floor Hotspot SU-E

25 DRAFT FINAL I

I I


Table 6-1. Wilcoxon Rank Sum Tests (Continued)

I I I I I I I I I I I I I I I I


Building 340 Walls SU-A

Ventilation System SU-B

Overheads SU-C

Floor SU-D

Machine Shop Floor SU-A

Overheads SU-B

Walls SU-C

Walls SU-D

North Bead Blast Floor SU-A

Walls SU-B

Ventilation SU-C

Roof SU-D

Internal Ventilation Sys SU-E

MgThRoom Floors (pre-tile removal) SU-A

Floors (post-tile removal) SU-Al, A2

Overheads SU-B

Roof ventilation SU-C

Roof SU-D

Walls SU-E, El, E2, E3, E4, E5, E6, E7

Ceiling tiles** SU-F

Drains Drains SU-A

EB Weld Floor SU-A, AI, A2

Walls SU-B

Overheads SU-C

Ventilation SU-D

Window vent SU-E

Roof SU-F

Vent pipe SU-G

Building 1825 Breakroom SU-A, AI, A2, A3, A4

Floors SU-B

Overheads SU-C, Cl

Walls SU-D,Dl

Building 1727 Floor SU-A

Walls SU-B, Bl

Ceiling SU-C


Floors SU-B

Office floors SU-Bl, B2

Overheads SU-C

Ventilation SU-D

26 DRAFT FINAL I

I I


Table 6-1. Wilcoxon Rank Sum Tests (Continued)

I I I


Building 258 Floors

Overheads

Walls

Floors

Overheads

Walls

SU-A

SU-B

SU-C

Engine Cleaning SU-AI-A6, BI-B6, CI-C6

SU-B, Bl, B2, B3

SU-C, Cl, C2, C3 .. . .* All areas not specIfyIng a bUIlding number were withIn BUIlding 8.

** For reference only. Ceiling tiles were disposed of as radioactive waste.

I 6.4.1 General

I Surveys of a number of areas were problematic in that elevated radioactivity was present due to the presence of materials containing NORM. These materials include terra cotta tile, red brick, grinding wheels and new bead blast media. The presence of terra cotta tile and red brick were addressed by establishing additional background areas specific to these materials. Bead blast

I material and aluminum oxide grinding wheels were in use in a number of different areas at CCAD and resulted in significant background variation. Investigation of these materials included radiological surveys and the collection of four samples of the bead blast material and one sample

I of the aluminum oxide grinding wheel media. The sampled bead media had not previously been exposed to magnesium-thorium alloys or any other known process material with elevated radioactivity. Bead blast material and grinding wheel residuals were surveyed using a 2"x 2" NaI

I gamma scintillation detector (44-10) with results ranging from 26,000 cpm to 59,000 cpm for the bead media and averaging about 15,000 cpm for the aluminum oxide grinding wheels. Backgrounds, by comparison, were on the order of 6,000 to 8,000 cpm. The samples collected

I were submitted to Eberline Services' Laboratory for analysis (See Table 6-2, Analysis Results for Bead Blast and Grinding Media, and Laboratory Analysis Reports in Appendix A).

I Table 6-2. Analysis Results for Bead Blast and Grinding Wheel Media3

I I I I I . .

Client ID Date Th-228 (pCi/g)

Th-230 (pCi/g)

Th-232 (pCi/g)

Location Description

CCAD-008 11/1712008 15 12 14 Metal Spray Area

New bead blast media

CCAD-OI0 11118/2008 0.5 1 0.5 Building 340, Room 201

Bead blast material from

cabinet #K9640

CCAD-Oll 1111912008 0 0.5 0.5 Building 340, Room 201

Bead blast material from

cabinet #P7058

CCAD-021 11712009 2.4 2.8 4 Machine

Shop Aluminum Oxide Grinding Wheel

CCAD-023 6/412009 5 3 4 Building 340,

Room 201 In-use bead blast

media • Results are rounded to two SignIficant dIgIts.

I It is notable that the results for the grinding wheels are consistent with results recently obtained by the Department of Energy which resulted in publication of an advisory entitled Use of Grinding Wheels Containing Uranium Safety Advisory, U.S. DOE Office of Health, Safety and

I 27 DRAFT FINAL


I Security (HSS 2009). This advisory noted that "Certain use of these materials may result in the

I production of airborne radioactive material or generation of surface contamination." Given the wide spread use of grinding wheels within some machining areas in CCAD Building 8, elevated radioactivity in areas with grinding wheels was reasonably attributable to the presence of the wheels and associated residue.

I Bead blast media from cabinets used for the processing of magnesium-thorium alloys was disposed of as radioactive waste. Media from cabinets not used for the processing of magnesiumthorium alloys, although radiologically elevated, will be disposed of consistent with laboratory

I results confirming the presence of NORM constituents but will not be disposed of as licensed material.

I 6.4.2 Building 8

6.4.2.1 Welding Shop (including the adjacent Metal Spray and Bead Blast Areas)

I Bead blast material and aluminum oxide grinding wheels discussed in Section 6.4.1 which

I I

exhibited elevated radioactivity were in use in the Welding Shop (including the Metal Spray and Bead Blast Area) at the time of the survey. Given that elevated count rates are attributable to new/unused bead blast media, aluminum oxide grinding wheels and to any magnesium-thorium residues that may be present, increased emphasis was placed on decontamination efforts and additional surveys were performed to evaluate the nature of background in areas believed to

I contain only NORM constituents. Fixed point readings initially indicated the existence of elevated radioactivity in 32 locations with the highest being about 1300 dpm/100cm2

•

Measurement results exhibiting elevated activity relative to the DCGL included 27 floor location

I and 5 from areas within the overhead superstructure. (These areas included the floor area identified by the NRC representative during a site visit on April 9 - 10,2009.) The area with the highest count rate was subjected to extensive investigation, decontamination, and resurvey to

I

address the elevated count rates. Initial decontamination efforts consisted of the use of wet wipes and a scraper to remove surface activity. These actions reduced the count rate from about 1300 dpm/100cm2to 870 dpm/lOOcm2

. Subsequently, the area in question was subjected to wire I brushing with a corresponding reduction in count rates to less than 500 dpm/100cm2 and to scabbling which removed up to v.a inch of the concrete surface material. Scabbling reduced the size of the area exhibiting elevated radioactivity to less than 15 cm by 15 cm and resulted in a I fixed point measurement of about 460 dpm/100cm2

. As additional scabbling produced no change in activity, it was concluded that the area in question contained concentrations of naturally occurring activity within the concrete which were elevated relative to the concrete background area used. Given that activity was less than the elevated measurement comparison value, no further decontamination was performed and the residual activity value for this location

I was incorporated into the data set for the survey unit. Although the acti vity present in other portions of the welding shop were reasonably attributable to NORM and was not related to magnesium-thorium alloys, each of the values was included in the data set for the survey unit

I which was subjected to the Wilcoxon Rank Sum (WRS) Test. Given that residual radioactivity was reasonably attributable to the presence of NORM and that the area in question passed the WRS test irrespective of the presence of these materials (see Appendix F), it was determined that

I additional remediation was not required for the Welding Shop, (including the Metal Spray, and Bead Blast Areas). Information pertinent to the measurements collected in the Welding Shop (including the Metal Spray and Bead Blast Area) is presented in Table 6-3 with detailed

I analytical results contained in Appendixes C and D.

I 28 DRAFT FINAL

I I


Table 6-3. Surveys of the Building 8 Welding Shop, Metal Shop and Bead Blast Area

I I I

Location Area(m2)a

Number ofMeasurement

Locationsb Survey #

Walls 60 20 CCAD-005Overhead Support

1,600 19 CCAD-008

Structures 55 CCAD-085Floor (43-37) 5,500 42 CCAD-021

49 CCAD-00525 CCAD-070

Floor (43-89) 400 26 CCAD-070a22 CCAD-070b25 CCAD-071

. .I . Area measurements are rounded to two slgmficant dlgtts.

I b Locations from CCAD-003 through CCAD-066 include both fixed point and removable

measurements.

6.4.2.2 Machine Shop

I Bead blast material and aluminum oxide grinding wheels were regularly being used in the Machine Shop. Accordingly, these areas exhibited radiologically elevated survey results due to

I the presence of naturally occurring radioactive material in this media. One sample of the aluminum oxide grinding wheel media was collected from the Machine Shop and sent to Eberline Services for analysis (Table 6-2). Aluminum oxide grinding wheels and associated

I I

residuals were surveyed using a 2"x 2" NaI gamma scintillator (44-10) with results averaging 15,000 cpm. Use of Grinding Wheels Containing Uranium Safety Advisory, U.S. DOE Office of Health, Safety and Security (HSS 2009) notes that "Certain use of these materials may result in the production of airborne radioactive material or generation of surface contamination." In addition, in late-2008 elevated radioactivity was also determined to be present in four different metal polishing materials commonly used in vehicle manufacturing.

Grinding wheel residuals in the Machine Shop were subjected to additional investigation beyond

I the aforementioned surveys and collection and laboratory analysis of grinding wheel materials. As noted in survey CCAD-082, six measurements were made taken from an inside wall of the Machine Shop from locations in which grinding wheels were in use. Six measurements were also

I obtained from the opposite side of the same wall from locations in which no grinding wheels were in use. Results indicate that areas where the grinding wheels were in use have a beta background disintegration rate three times that where no grinding wheel is in use. Although five

I locations within the Machine Shop exhibited elevated radioactivity at up to 490 dpm/lOOcm2, these results have been demonstrated to be the result of grinding wheels and associated residues containing elevated concentrations of NORM and not related to magnesium-thorium.

I Nonetheless, evaluation of residual radioactivity measurements was performed using the WRS

I Test. This test was performed without regard to the elevated background resulting from the presence of the materials containing elevated concentrations of NORM. Given that the test statistic (Wr) equaled the table (critical) value, any consideration for the increased background would clearly disprove the null hypothesis that the area exceeded DCGLs.

I Information pertinent to the measurements collected in the Machine Shop in Table 6-4 with detailed analytical results contained in Appendixes C and D.

I I 29

I I


Table 6-4. Surveys of the Building 8 Machine Shop

I I

Location Area (m2)3

Number of Measurement

Locationsb Survey #

Floors 2,050 75 CCAD-057 Machine Shop

Overheads 2,050 67 CCAD-058

West Wall 500 50 CCAD-056 10 CCAD-082

. . I a Area measurements are rounded to two slgmficant dlgtts. b Locations from CCAD·OO3 through CCAD·066 include both fixed point and removable

measurements.

I 6.4.2.3 Magnesium-Thorium Machine Room

I The floor, after tile removal, was classified as a MARSSIM Class 3 area during the scoping survey. This survey noted that fixed point measurements collected on the floor, after tile

I removal, exceeded the investigation level. Therefore, this area was re-classified as a MARSSIM Class 2 SU subject to systematic sampling. The walls and ventilation of the Magnesium-Thorium Room were initially classified as MARSSIM Class 2 SUs. Scoping survey results reflected that

I seven fixed measurements collected from the walls and all fixed measurements collected from the internal ventilation had results exceeding the DCGLw. These SUs were remediated and resurveyed as MARSSIM Class 1 SUs.

MARSSIM states that if the difference between the highest SU measurement and the lowest reference area measurement in the SU is less than the DCGLw a WRS test is not required and

I these SUs meet the release criterion (MARSSIM; Table 4, Roadmap). As such, WRS test were not performed for all SUs in the Magnesium-Thorium Room.

I Sufficient information exists for the floor (pre-tile removal) and the overhead (post ceiling tile

I removal) of the Magnesium-Thorium Room to demonstrate compliance with the DCGLw. A MARSSIM classification of Class 3 was appropriate for these areas and sufficient information has been collected to reject the null hypothesis, that the areas in question exceed the DCGLs.

I The floor, after tile removal; the roof; and internal and external portions of the ventilation system were classified as MARSSIM Class 2 areas. Sufficient data were collected to demonstrate compliance with the DGCLw. A WRS test was performed for these areas. All areas passed the

I WRS test. A MARSSIM classification of Class 2 was appropriate for these areas and sufficient information has been collected to reject the null hypothesis that the areas in question exceed DCGLs.

I A MARSSIM Class 2 systematic grid was initially used to evaluate the Magnesium-Thorium Room walls. As results of the scoping survey reflected six areas on the walls that exhibited

I activity exceeding the DCGLw, these areas were re-evaluated after remediation as MARSSIM Class 1 areas. MARSSIM Class 1 systematic grids were centered on each such location that exhibited elevated sampling results. Post remediation, sufficient data were collected to demonstrate compliance of the DCGLw for all locations. A WRS test was not required for four of these areas. WRS tests were performed for two of the areas. These areas passed the WRS test.

I The MARSSIM classifications of Class 1 and Class 2 were appropriate for these areas. Sufficient information has been collected to reject the null hypothesis that the area in question exceeds DCGLs.

I A 100% scan was performed on all accessible interior portions of the Magnesium-Thorium Room as only one machine in this area was unable to be moved to facilitate surveys. Although

I 30 DRAFT FINAL


I I portions of the roof of the Magnesium-Thorium Room were unable to be surveyed due to

concerns on cave-in, sufficient access was obtained to confirm the absence of contamination. All scan and fixed measurement results from this area were below the DCGLw. Smears were

I collected for removable contamination at the same locations that fixed measurements were taken. There were no detectable results from any removable measurement collected in the MagnesiumThorium Room.

Information pertinent to the measurements collected in the Magnesium-Thorium Room is presented in Table 6-5 with detailed analytical results contained in Appendixes C and D.

I Table 6-5. Surveys of the Building 8 Magnesium Thorium Room

I I I I

I

.

Location Area(m2)8

Number ofMeasurement

Locationsb Survey #

Floors 250 10 CCAD-032Floors - tile removed 23 CCAD-034

(43-89) 75 28 CCAD-067

Floors - tile removed (43-37) 75 23 CCAD-034

Overhead 250 30 CCAD-0195 CCAD-015

RooflVentilation 250 30 CCAD-01840 CCAD-07420 CCAD-084

Internal Ventilation 50 20 CCAD-068100 CCAD-016

Walls 250 50 CCAD-06816 CCAD-On

. . I Area measurements are rounded to two slgDlficant digIts. b Locations from CCAD-003 through CCAD-066 include both fixed point and removable measurements.

I 6.4.2.4 Engine Disassembly and Cleaning Areas

All areas of the Engine Disassembly and Cleaning Areas were classified as MARSSIM Class 3 SUs during the scoping survey. Results of the scoping survey determined that areas with results

I exceeding the investigation levels be re-classified as MARSSIM Class 2 SUs and areas with results exceeding the DCGLw be re-classified as Class 1 SUs.

I A 100% scan was performed on all accessible areas of the Engine Disassembly and Cleaning Area. All scan and fixed measurement results from SUs in the Engine Disassembly and Cleaning

I Areas were below DCGLw. There were no detectable results from any removable measurement collected in the Engine Disassembly and Cleaning Area.

MARSSIM states that if the difference between the highest SU measurement and the lowest reference area measurement in the SU is less than the DCGLw a WRS test is not required and the

I SU meets the release criterion (MARSSIM; Table 4, Roadmap). As such, WRS test were not performed for all SUs in the Engine Disassembly and Cleaning Area.

I I The floors of the Engine Disassembly and Cleaning Area include areas in three rooms with six

Class 2 SUs in each room. These areas were subject to MARSSIM Class 2 systematic sampling. Sufficient data were collected to demonstrate compliance with the DGCLw. A WRS test was performed for these areas. All areas passed the WRS test. A MARSSIM classification of Class 2 was appropriate for these areas and sufficient information has been collected to reject the null hypothesis that the area in question exceeds DCGLs.

I 31 DRAFT FINAL


I During the scoping survey the overhead areas in the Engine Disassembly and Cleaning Area was

I classified as a MARSSIM Class 3 area. However, there were three areas on the overhead that had results greater than the DCGLw. These areas were remediated and re-classified as MARSSIM Class 1 SUs. MARSSIM Class 1 systematic grids were centered around each location that

I exhibited elevated sampling results. Utilizing systematic grid sampling, sufficient data were collected to demonstrate compliance with the DGCLw. A WRS test was performed for the two of these SUs. These SUs passed the WRS test. A WRS test was not required for the remaining SUO

I The MARSSIM classification of this area was appropriate and sufficient information has been collected to reject the null hypothesis that the area in question exceeds DCGLs.

The walls of the Engine Disassembly and Cleaning Area were divided into four survey units, the south wall, the north hallway wall, the south hallway wall and the east hallway wall. The west

I wall has been removed since the scoping survey. All areas were classified as MARSSIM Class 2 SUs and systematically sampled. Sufficient data were collected to demonstrate compliance with the DGCLw. These SUs required WRS testing, all areas passed. A MARSSIM classification of

I Class 2 was appropriate for these areas and sufficient information has been collected to reject the null hypothesis that the area in question exceeds DCGLs.

I Information pertinent to the measurements collected in the Engine Disassembly and Cleaning Areas is presented in Table 6-6 with detailed analytical results contained in Appendixes C and D.

I Table 6-6. Surveys of the Building 8 Engine Disassembly and Cleaning Areas

I I

Location Area (m2)8


Locationsc Survey #

Floors 15,000b 43 CCAD-061 33 CCAD-077

Overhead 13,000 35 CCAD-064 42 CCAD-076

Walls to 6 ft 1,800 55 CCAD-060 40 CCAD-079

I . .• Area measurements are rounded to two Significant digits .

I b Each of the three rooms had floor areas of approximately 5,500 m2

.

e Locations from CCAD-003 through CCAD-066 include both fixed point and removable measurements.

6.4.2.5 Fonner Temporary Waste Storage Areas

I Temporary waste storage areas were previously utilized for magnesium-thorium alloy waste in the immediate area in which the waste was being generated (e.g., the waste for the bead blast

I area is located within the bead blast area). Such areas were very limited in size (typically a small area capable of storing not more than two 55 gallon drums). Temporary waste storage areas were evaluated as an integral part of the survey of the associated areas. Survey data has been evaluated within each area.

I 6.4.2.6 The Area Fonnerly Occupied by the Haas Mill

I The Area Formerly Occupied by the Haas Mill is a small area located within a larger machine shop. There are no walls or overheads included in the Haas Mill impacted area. Information pertinent to the measurements collected in the Haas Mill area is presented in Table 6-6.

I Sufficient information exists for the floor of the Haas Mill area to demonstrate compliance with the DCGLw. A 100% scan was performed on all accessible floor areas adjacent to the Haas Mill. All scan and fixed measurement results from this area were below investigation levels and the

I 32 DRAFT FINAL

I

I


I DCGLw. Smears were collected for removable contamination at the same locations as fixed measurements. There were no detectable results from any removable measurement in this area.

I Table 6-7. Surveys of the Haas Mill Area in Building 8

Location Area (m2)3


Locationsb Survey #

Floor 100 9 CCAD-009

I ..a Area measurements are rounded to two significant digits.

b Locations from CCAD-003 through CCAD-066 include both fixed point and removable measurements.

I For the floor of this area the difference between the highest SU measurement and the lowest reference area measurement was less than the DCGLw, therefore a WRS test is not required and

I this SU meets the release criterion (MARSSIM; Table 4, Roadmap). A MARSSIM classification of Class 3 was appropriate for this area and sufficient information has been collected to reject the null hypothesis that the area in question exceeds DCGLs.

I 6.4.2.7 Two Bead Blast Rooms at the North End of Building 8 Which Previously Supported Engine Disassembly and Cleaning Shops

I All areas of the North End of Building 8 except the ventilation were classified as MARSSIM Class 2 areas during the scoping survey. This classification was sufficient for all areas with the exception of the ventilation. Results of measurements collected from the ventilation of this area exceeded investigation levels, thus the ventilation was re-classified as a MARSSIM Class 2 SUo

I A 100% scan was performed on all accessible areas of the Bead Blast Rooms at the North End of

I Building 8. All scan and fixed measurement results from these areas were below the DCGLw. Smears were collected to assess for removable contamination at the same locations as which fixed measurements were taken. There were no detectable results from any removable measurement in this area.

I MARSSIM states that if the difference between the highest SU measurement and the lowest reference area measurement in the SU is less than the DCGLw a WRS test is not required and the SU meets the release criterion (MARSSIM; Table 4, Roadmap). As such, WRS test were not

I performed for all SUs in the Blast Rooms at the North End of Building 8.

I The floor, walls, roof, exterior and interior ventilation and duct work of the Two Bead Blast Rooms at the North End of Building 8 were classified as MARSSIM Class 2 areas. Utilizing systematic grids sufficient information was collected for these areas to demonstrate compliance with the DCGLw.

I For the floors, walls, internal ventilation and duct work of this area, WRS tests were not required and these SUs meet the release criterion. The roof SU and the external ventilation SU required WRS tests. Both areas passed the WRS test. A MARSSIM classification of Class 2 was

I appropriate for these areas and sufficient information has been collected to reject the null hypothesis that the areas in question exceed DCGLs.

I Information pertinent to the measurements collected in the North End Bead Blast Rooms is presented in Table 6-8 with detailed analytical results contained in Appendixes C and D.

I I 33 DRAFT FINAL

I I


Table 6-8. Surveys of Building 8, North End Bead Blast Rooms

I I I

Location Area (012)3


Locationsb Survey #

Floor (43-37) 40 20 CCAD-059 Floor (43-89) 40 10 CCAD-049

Walls 100 20 CCAD-049 18 CCAD-049

Vent Ducts 1 20 CCAD-073 22 CCAD-075

Roof 100 20 CCAD-073 . . . Area measurements are rounded to two slgDlficant dIgits.

I b Locations from CCAD-003 through CCAD-066 include both fixed point and removable measurements.

6.4.2.8 The Electron Beam Welder Area

I I Results of measurements collected during the scoping survey indicated that portions of the

Electron Beam Welder Area exceeded investigation levels. Per the Corpus Christi Army Depot Radiological Survey Plan (SAIC, 2008) the ventilation exhaust and adjacent roof areas are were

I required to be surveyed due to collection of samples in the interior ventilation exceeding investigation levels. All areas of the Electron Beam Welder Area were re-classified as MARSSIM Class 2 areas for the final status survey evaluation. A 100% scan was performed on

I all accessible areas of the Electron Beam Welder Area. All scan and fixed measurement results from this area were below investigation levels and the DCGLw. Smears were collected to assess for removable contamination at the same locations at which fixed measurements were taken. There were no detectable results from any removable measurement in this area.

Per MARSSIM, systematic sampling grids were utilized to ensure sufficient data were collected

I for each SU in the Electron Beam Welder Area. A MARSSIM classification of Class 2 was

I appropriate for the floors, walls, overhead, roof, exterior and interior ventilation and duct work of the Electron Beam Welder Area. Sufficient information has been collected in these SUs to reject the null hypothesis that the areas in question exceed DCGLs.

I A WRS test was not required for the overhead or the roof SUs as the difference between the highest SU measurement and the lowest reference area measurement was less than the DCGLw (MARSSIM; Table 4, Roadmap). These SUs meet the release criterion. WRS tests were required for the floors, walls, duct work and internal and external ventilation. All SUs passed the WRS

I test.

I Information pertinent to the measurements collected in the Electron Beam Welder Area is presented in Table 6-9 with detailed analytical results contained in Appendixes C and D.

Table 6·9. Surveys of the Building 8, Electron Beam Welder Area

I I I

Location Area (012)3


Locationsb Survey #

Floor (43-89) 100 20 CCAD-009 10 CCAD-083

Floor (43-37) 100 21 CCAD-028 Walls 130 30 CCAD-009

I 34 DRAFT FINAL

I I


Table 6-9. Surveys of the Building 8, Electron Beam Welder Area (Continued)

I I I

Location Area (m2)3 Number of

MeasurementLocationsb

Survey #

OverheadSupport

Structures 350 24 CCAD-014

Roof 300 20 CCAD-078 10 CCAD-013

Ventilation 4 20 CCAD-08320 CCAD-07820 CCAD-081 . .I a Area measurements are rounded to two slgmficant dIgits.

b Locations from CCAD-003 through CCAD-066 include both fixed point and removable measurements.

I 6.4.2.9 Floor Drains and Drain Traps

I Sewers including floor drains and drain traps were investigated as an independent SUo Ten floor drains from the Metal Spray Area, the Electron Beam Welder Area, the Magnesium-Thorium Machine Shop, Building 132 and from the North End Bead Blast Area, were subject to

I investigation using the Ludlum Model 2221 with a 43-37 gas proportional detector and smears. One additional floor drain was inaccessible using the floor monitor but was investigated using a smear. A 100% scan was performed on all accessible areas of the drains and drain traps. All scan

I and fixed measurement results from this area were below the DCGLw. There were no detectable results from any removable measurement taken from any drain or drain trap. Sufficient information has been collected to reject the null hypothesis that the areas in question exceed DCGLs.

I 6.4.2.10 Grass Areas Surrounding Building 8

Grassy areas surrounding Building 8 were combined with other potentially impacted soil areas

I and were surveyed in accordance with Section 3.4.3 of this survey plan. Analytical results of these analyses are included in Appendix A and listed on Table 3-1. Concentrations were compared to the NRC screening level Derived Concentration Guideline Level (DCGL) of 1.1

I pCi/g for Th-232 in soil as stated in NUREG-1757. No sample exceeded 45% of the screening level DCGL without regard to reference area measurement subtraction thus soils were clearly compliant with the stated DCGL. Application of the sign test (Appendix A) indicates that the

I null hypothesis (i.e., that the area in question exceeds the release criteria) is rejected.

6.4.3 Building 1727, Room BIOI, Radiation Safety Officer (RSO) Laboratory

I All areas in Building 1727 were surveyed as MARSSIM Class 3 areas during the scoping

I surveys. Results indicated several areas that exceeded the DCGLw. These areas were subsequently re-classified as MARSSIM Class 2 areas and surveyed with background levels more appropriate for the area.

The floor, walls and ceiling of Building 1727 were classified as MARSSIM Class 2 areas.

I Sufficient data exists for these areas to demonstrate compliance with the DCGLw. A 100% scan was performed on all accessible floor, wall and ceiling areas in Building 1727. All scan and fixed measurement results from these areas were below the DCGLw. Smears were collected for

I removable contamination at the same locations that fixed measurements were taken. There were no detectable results from any removable measurement in this area.

I 35 DRAFT FINAL


I I For the ceiling of this area the difference between the highest SU measurement and the lowest

reference area measurement was less than the DCGLw, therefore a WRS test is not required and this SU meets the release criterion (MARSSIM; Table 4, Roadmap). The floor and the walls of

I Building 1727 required WRS tests. Both areas passed the WRS test. A MARSSIM classification of Class 2 was appropriate for these areas and sufficient information has been collected to reject the null hypothesis that the area in question exceeds DCGLs. Information pertinent to the measurements collected in Building 1727 is presented in Table 6-10 with detailed analytical results contained in Appendixes C and D.

I Table 6-10. Surveys of the RSO Lab in Building 1727

. . . Area measurements are rounded to two slgmficant digits .

b Locations from CCAD-003 through CCAD-066 include both fixed point and removable

I measurements.

6.4.4 Building/Area 339 Former Waste Storage Area

I Although Building 339 currently serves as a motor pool, historical records indicate that it was used for the storage of radioactive waste. Therefore, it was surveyed as a radiologically impacted area. Information pertinent to the measurements collected in Building 339 is presented in Table

I 6-11. The overhead areas of the offices and break room were not considered impacted and thus· were not evaluated.

I I

Location Area (m2)a Number of

Measurement Locationsb

Survey #

Floor 50 16 CCAD-041 Walls 100 27 CCAD-041

Ceiling 50 14 CCAD-041

I Table 6-11. Surveys of Building 339

I I I

Location Area (m2)a

Number of Measurement Locationsb Survey #

Walls 1,100 36 CCAD-054 Floors (43-37) 1,100 25 CCAD-055

Break Room and 7 CCAD-054 Office Floors

(43-89) 400

10 CCAD-086

Overhead 1,100 11 CCAD-054 10 CCAD-086

Ventilation 27 20 CCAD-086 . .

• Area measurements are rounded to two Significant digits. b Locations from CCAD-003 through CCAD-066 include both fixed point and removable measurements.

I I All areas in Building 339 were surveyed as MARSSIM Class 3 areas during the scoping surveys.

Results indicated several areas that exceeded the DCGLw. These areas were subsequently reclassified as MARSSIM Class 2 areas and surveyed with background levels more appropriate for the area.

I A 100% scan was performed on all accessible areas of Building 339. There was a vent located on the ceiling of this area in which safety concerns made it not possible to collect scan

I measurements. All scan and fixed measurement results from this area were below the DCGLw. Smears were collected for removable contamination at the same locations that fixed measurements were taken. There were no detectable results from any removable measurement in this area.

I 36 DRAFT FINAL


I I MARSSIM states that if the difference between the highest SU measurement and the lowest

reference area measurement in the SU is less than the DCGLw a WRS test is not required and the SU meets the release criterion (MARSSIM; Table 4, Roadmap). As such, WRS test were not performed for all SUs in the Blast Rooms at the North End of Building 8.

I The walls of Building 339 were classified as MARSSIM Class 2. MARSSIM states that the maximum area for a Class 2 survey unit is 1000 m2 plus 10%, thus the walls in this area have been treated as a single survey unit. A classification of Class 2 was appropriate for this area. Sufficient information has been collected to reject the null hypothesis that the areas in question

I exceed DCGLs. A WRS test was not required for the walls of Building 339.

I The floors of Building 339 were classified as MARSSIM Class 2. MARSSIM states that the maximum area for a Class 2 survey unit is 1000 m2 plus 10%, thus the floors in this area have

I been treated as a single survey unit. This excludes the floors of the break room and office areas which were surveyed as a separate Class 1 or Class 3 Su. Sufficient information exists for the floors of Building 339 to demonstrate compliance with the DCGLw A classification of Class 2 was appropriate for this area. A WRS test was not required for the floors of Building 339.

A portion of the floors located in the break room and offices of Building 339 was surveyed as a

I MARSSIM Class 3 area. During the scoping survey results indicated that certain areas of the

I break room and office floors exceeded the DCGLw. These areas were subject to re-survey as a MARSSIM Class 1 areas. Sufficient information exists for the office and break room floors of Building 339 to demonstrate compliance with the DCGLw. WRS tests were required for these

I areas. All areas passed the WRS test. Appropriate MARSSIM classifications were used for these areas and sufficient information has been collected to reject the null hypothesis that the areas in question exceed DCGLs.

I During the scoping survey the overheads in Building 339 were surveyed as a MARSSIM Class 2 area, a small portion of this area exceeded the DCGLw. This portion of the overhead was re

I classified as a MARSSIM Class 1 su. These SUs did not require a WRS test. Sufficient information was collected from the overheads of Building 339 to demonstrate compliance with the DCGLw. A classification of Class 1 and Class 2 was appropriate for this area.

I The ventilation in Building 339 was surveyed as a MARSSIM Class 2 area. Sufficient information exists for the ventilation of Building 339 to demonstrate compliance with the DCGLw. A WRS test was not required for the ventilation of Building 339.

I 6.4.5 Former Building 258 Radioactive Waste Storage and Processing Areas

I Sufficient information exists for all areas of Building 258 to demonstrate compliance with the DCGLw. A 100% scan was performed on all accessible areas of the floor, walls and overheads. All scan and fixed measurement results from this area were below the DCGLw. Smears were collected for removable contamination at the same locations that fixed measurements were taken. There were no detectable results from any removable measurement in this area.

I For the floors and the overhead support structure in this area, the difference between the highest

I SU measurement and the lowest reference area measurement was less than the DCGLw. Consistent with MARSSIM (Table 4, Roadmap) this area does not require a WRS test and the SU meets the release criterion. The only portion of this room that required a WRS test was the

I walls. The wall area passed the WRS test. A MARSSIM classification of Class 2 was appropriate for these areas and sufficient information has been collected to reject the null hypothesis that the areas in question exceed DCGLs. Information pertinent to the measurements collected in the

I 37 DRAFT FINAL

I

I


I North End Bead Blast Rooms is presented in Table 6-12 with detailed analytical results contained in Appendixes C and D.


I . . . Area measurements are rounded to two sIgnIficant dIgIts.

I b Locations from CCAD-003 through CCAD-066 include both fixed point and removable

measurements.

6.4.6 Building 340

I Sufficient information exists for all portions of Building 340 to demonstrate compliance with the

I DCGLw. A 100% scan was performed on all accessible areas of the floor, walls and overheads. All scan measurement results from this area were below the DCGLw. Smears were collected for removable contamination at the same locations that fixed measurements were taken. There were

I no detectable results from any removable measurement in this area. Four fixed point sample locations from Building 340 had results that exceeded the DCGLw. Two of these areas are located on the floor and two are located on the outside of ventilation ducts which are a part of the overhead support structure Su. The area represented by each sample located on the ventilation duct is less

2 2 2than 5 m while the areas represented by the elevated Hoor locations are 5 m and 6 m ,

respectively. These areas were evaluated utilizing the DCGLEMC (Section 3.6). The area factor for I an area of 5 m2 is two (2) thus the DCGLEMC equates to 600 dpm/100cm2. The area factor for 6

m2 has been conservatively estimated to be 1.5 resulting in a DCGLEMC of 450 dpm/100cm2.

I Given that sample results for these areas are less than the DCGLEMC. and that the survey units pass the WRS test, each of the associated survey units achieves DCGLs and is suitable for release.

I Information pertinent to the measurements collected in Building 340 in Table 6-13 with detailed analytical results contained in Appendixes C and D.


Location Area (m2)a Number of

Measurement Locationsb

Survey #

Floors 550 30 CCAD-046 Overheads 550 30 CCAD-047,047a

Walls 84 20 CCAD-047,047a

I I

Location Area (m2)a


Locationsc Survey #

Walls 1,500 40 CCAD-042 Ventilation 190 6 CCAD-053 Overheads 150 20 CCAD-038

200 CCAD-023 Floors 150 200 CCAD-027

13 CCAD-048I . . • Area measurements are rounded to two sIgnIficant dIgits .

I b Smears only, IDW from sampling events were stored in this location. Additional removable

measurements were taken as a precautionary measure. C Locations from CCAD-003 through CCAD-066 include both fixed point and removable

measurements.

I I 38 DRAFT FINAL


---~--------------

I 6.4.7 Building 1825

I A 100% scan was perfonned on all accessible areas of the break room, floors, overhead and walls of Building 1825. All scan and fixed measurement results from these areas were below the DCGLw. Smears were collected for removable contamination at the same locations in which fixed measurements were taken. There were no detectable results from any removable

I measurement in this area.

I Consistent with MARSSlM (Table 4, Roadmap), if the difference between the highest SU measurement and the lowest reference area measurement for a SU is less than the DCGLw a WRS test is not required for the SU to confinn that the release criterion is achieved.

The break room floors, walls and overhead were classified as MARSSlM Class 2 areas. Utilizing

I systematic grids sufficient infonnation was collected for each of these areas to demonstrate compliance with the DCGLw. A MARSSlM classification of Class 2 was appropriate for these areas and sufficient infonnation has been collected to reject the null hypothesis that the areas in

I question exceed DCGLs.

I The floors of Building 1825 were classified as a MARSSlM Class 3 area. Sufficient infonnation was collected for this SU to demonstrate compliance with the DCGLw. A WRS test was not required for the floors of Building 1825.

After results from the scoping survey exceeded investigation levels, the overhead of Building

I 1825 was re-classified as a MARSSlM Class 2 area. Sufficient information was collected for this SU to demonstrate compliance with the DCGLw. A WRS test was not required for the overhead areas of Building 1825.

I I Results of the scoping survey indicated that the initial MARSSlM Classification of Class 3 for

the walls of Building 1825 was insufficient due to measurements that exceeded the investigation levels and the DCGLw. The majority of the walls were re-classified as a MARSSlM Class 2 area

I with a portion re-classified as a Class 1 area. Sufficient infonnation was collected for these areas to demonstrate compliance with the DCGLw. These SUs did not require a WRS test. Sufficient information was collected for these SUs to demonstrate compliance with the DCGLw.

Information pertinent to the measurements collected in Building 1825 is presented in Table 6-14 with detailed analytical results contained in Appendixes C and D.

I Table 6-14. Surveys 0 f Building 1825

I I I I I

Location Number of Measurement Survey #

Area (m2)a L ocationsb

Break room 50 13 CCAD-051 21 CCAD-088

Floor 480 20 CCAD-052

Overhead 480 22 CCAD-051 21 CCAD-088

Walls 480 29 CCAD-051 10 CCAD-088

• Area measurements are rounded to two significant digits b Locations from CCAD-003 through CCAD-066 include both fixed point and removable measurements.

I 39 DRAFT FINAL


I 6.4.8 Building 132 Radioactive Material Storage and Handling Building

I Results of the scoping survey indicated radiation levels above investigation levels for portions of Building 132. All areas of the building were re-classified as MARSSIM Class 2 areas for the final status survey evaluation. Systematic grids were utilized to ensure sufficient information was collected for each area as such to demonstrate compliance with the DCGLw. The wall area of

I Building 132 was divided into 2 SUs in order to comply with the requirements of a MARSSIM Class 2 area. A 100% scan was performed on all accessible areas of the floor, walls, overhead and ventilation. All scan and fixed measurement results from these areas were below the

I DCGLw. Smears were collected for removable contamination at the same locations that fixed measurements were taken. There were no detectable results from any removable measurement in this area.

I I For the walls, and overhead of Building 132, the difference between the highest SU measurement

and the lowest reference area measurement was less than the DCGLw. Consistent with MARSSIM (Table 4, Roadmap) a WRS test was not required and these SUs meet the release

I criterion. The floor and ventilation of Building 132 required WRS tests. Both areas passed the WRS test. A MARSSIM classification of Class 2 was appropriate for these areas and sufficient information has been collected to reject the null hypothesis that the areas in question exceed

I DCGLs. Information pertinent to the measurements collected in Building 132 is presented in Table 6-15 with detailed analytical results contained in Appendixes C and D. (Note: This survey confirmed that operations involving unsealed sources have not resulted in residual contamination of this facility. Given the continued use of Building 340 for storage of material not generally subject to leakage, the structure will be subjected to confirmatory resurvey by the RSO

I concurrent with license termination.

Table 6-15. Surveys of Building 132

I I I

Location Area (m2)3 Number of

Measurement Locations'

Survey #

Floor 75 28, 40 additional

smears b CCAD-025, 026,

033, 050, 066, 10 CCAD-069

Walls 1,500 30 CCAD-066 Overhead 150 16 CCAD-066

Ventilation 20 60 CCAD-069 . .

I a Area measurements are rounded to two sIgnIficant dIgIts . b Smears only, IDW from sampling events were stored in this location. Additional removable

measurements were taleen as a precautionary measure. C Locations from CCAD-003 through CCAD-066 include both fixed point and removable

measurements.



I 7.0 CONCLUSION

Sufficient data exists for all impacted portions of CCAD to demonstrate that residual

I concentrations of thorium-232 series radionuclides from magnesium-thorium alloy aircraft

I engine maintenance operations achieve the derived concentration guideline level of 300 dpm/100cm2. This is demonstrated in that the null hypothesis, that the areas in question exceed DCGLs, is rejected. All SUs contain an adequate number of samples, a sufficient percentage of

I each area has been scanned and each area has been appropriately classified consistent with MARSSIM requirements using the process noted in Section 3.10. All scan and fixed measurement results collected from CCAD impacted area were below the DCGLw with the

I I

exception of those measurements collected from areas where naturally occurring radioactive material from new bead blast media and from aluminum oxide grinding wheels are in use. There were no detectable results from any removable measurement collected at CCAD. As surveys confirm the lack of residual contamination associated with the performance of NRC-licensed aircraft engine maintenance of magnesium-thorium alloy at CCAD, termination of CCAD NRC License STB-1168 and the unrestricted release of impacted facilities is appropriate.

I I I I I I I I I I I I 41 DRAFT FINAL


I 8.0 REFERENCES

I AEHA, 1974. Radiological Survey Report.

ANSI, 1997. Radiation Protection Instrumentation Test and Calibration - Portable Survey Instruments, N323A.

I EDi, 2007. Procedure Number 1.00; Radiation Protection Plan, Rev. 4. January.

EDi, 2008. Health and Safety Plan, Rev. 9. March.

I EDi, 2008. Activity Hazard Analysis for the "Corpus Christi Anny Depot, Corpus Christi, Texas;

I Magnesium Thorium Radiological Survey and Decontamination and Decommissioning Project"

EPA, 2000. EPN540-R-00-006, Soil Screening Guidance for Radionuclides: Technical Background Document. August.

I EPA, 2004. Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAP). July.

I ISO, 1999. Evaluation ofSurface Contamination. ISO-7503. December.

NRC, 1996. Transportation, 49-CFR, Section 173.403. March.

I NRC, 1998. Minimum Detectable Concentrations with Typical Radiation Survey Instruments for Various Contaminants and Field Conditions. NUREG/CR-1507.

NRC, 1998. Unimportant Quantities ofSource Material, lO-CFR, Section 40.13 (c)(4).

I I NRC, 2000. Re-Evaluation of the Indoor Resuspension Factor for the Screening Analysis of the

Building Occupancy Scenario for NRC's License Tennination Rule - Draft Report for Comment (NUREG-1720). June.

NRD, 1998. Minimum Detectable Concentrations with typical Radiation Survey Instruments for Various Contaminants and Field Conditions, NUREG-1507.

I NRC, 2006. Consolidated Decommissioning Guidance: Characterization, Survey, and Determination ofRadiological Criteria, NUREG-1757, Volume 2, Revision 1.

I MARSSIM 2002. Multi-Agency Radiation Survey and Site Investigation Manual (Revision 1). Nuclear Regulatory Commission NUREG-1575 Rev. 1, Environmental Protection Agency EPA 402-R-97-016 Rev. 1, Department of Energy DOE EH-0624 Rev. 1,

I August.

SAIC, 2008. Corpus Christi Army Depot Radiological Survey Plan. August.



I I I I I I I I I APPENDIX A

I LABORATORY ANALYSIS REPORTS

I I I I I I I I DRAFT FINAL

- - - - - - - - - - - - - - - - - - -Appendix A - Laboratory Analysis Reports

CCAD Soil Sampling Results

ClientID Date Th-227 Th-228 Th-230 Th-232 Location Description Units

CCAD-SOIL-OO I 1117/2009 • 0.09503 0.4729 0.1684 South ofbuilding along Ave D SOIL from Class 3 Area pCilg

CCAD-SOIL-002 111712009 · 0.2825 0.4547 0.1475

Hot spot location southeast of buildmg along Crecy

SOIL from Class 3 Area pCi/g

CCAD-SOIL-003 1117/2009 · 0.3498 0.6623 0.3538

Along yellow brick wall east ofbuilding along Crecy


CCAD-SOIL-004 III 7/2009 • 0.2336 0.9497 0.3462

Yellow spot locatIOn near drain east of building along Crecy


CCAD-SOIL-D05 1117/2009 • 0.2798 0.7894 0.3683

Yellow spot location just by an eastern comer ofbuilding 8 along Crecy

SOIL from Class 3 Area

pCi/g CCAD-SOIL-006 111712009 • 0.2369 0.3993 0.2734 East ofbuilding along Crecy SOIL from Class 3 Area pCi/g

CCAD-SOIL-007 1/1712009 • 0.2311 0.321 0.2592

Northeast ot bUllding near corner 01

Crecy & Ocean SOIL from Class 3 Area

pCi/g

CCAD-SOIL-008 1/17/2009 • 0.1224 0.3403 0.1394

North of building along Ocean in high traffic area


CCAD-SOIL-009 1/17/2009 • 0.1805 0.2846 0.3144

Yellow spot locatIOn south ofbUllding along Ocean


CCAD-SOIL-O I0 1/17/2009 • 0.07064 0.3079 0.2421 West of building along Fourth Ave SOIL from Class 3 Area pCi/g

CCAD-SOIL-Oll 2/2/2009 • 0.5248 1.3908 0.497 Near Building 132 SOIL from Class 3 Area pCi/g

CCAD-SOIL-O 12 2/2/2009 • 0.07422 0.2914 0.08519 Near Building 132 SOIL from Class 3 Area pCilg

lof3


Sign Test, CCAD Soil Samples

Ho: Residual radioactivity in the survey unit exceeds the release criteron

Th-228 data (pCi/g)

'NRC Screening

Value Th-228 I ;n ...

DCGL (pCi/g)

Sign (S) Th-230

data (PCi/g) 'NRC Screening

Value Th-230 DeGL (PCi/g) Sign (S)

Th-232

data (PCi/g)

'NRC Screening Value

Th-232 in . .

DeGL (pCi/g)

Sign (S)

0.09503 4.7 4.60497 + I 0.4729 1.8 1.3271 + I 0.1684 1.1 0.9316 + I

0.2825 4.7 4.4175 + I 0.4547 1.8 1.3453 + I 0.1475 1.1 0.9525 + I

0.3498 4.7 4.3502 + I 0.6623 1.8 1.1377 + I 0.3538 1.1 0.7462 + 1

0.2336 4.7 4.4664 + I 0.9497 1.8 0.8503 + I 0.3462 1.1 0.7538 + 1

0.2798 4.7 4.4202 + I 0.7894 1.8 1.0106 + 1 0.3683 1.1 0.7317 + I

0.2369 4.7 4.4631 + 1 0.3993 1.8 1.4007 +1 0.2734 1.1 0.8266 +1

0.2311 4.7 4.4689 + I 0.321 1.8 1.479 + 1 0.2592 1.1 0.8408 + I

0.1224 4.7 4.5776 + I 0.3403 1.8 1.4597 + I 0.1394 1.1 0.9606 + I

0.1805 4.7 4.5195 + 1 0.2846 1.8 1.5154 + I 0.3144 1.1 0.7856 + I

0.07064 4.7

4.7

4.7

4.62936 + I 0.3079 1.8 1.4921 + 1 0.2421 1.1 0.8579 +1

0.5248 4.1752 + I 1.3908 1.8 0.4092 + 1 0.497 1.1 0.603 + I

0.07422 4.62578 + 1 0.2914 1.8 1.5086 + I 0.08519 1.1 1.01481 + 1

Number of positive differences, S+ =12 Number of positive differences, S+ =12 Number of positive differences, S+ = 12

Since S + = 12 is greater than the Critical Value of9, the null hypotheses that the survey unit exceeds the release criterion is rejected

Alpha Error (Type 1 error) is .05, thus the Critical Value for the Sign Test is 9, (MARSSIM, Appendix

1, Table 1.3)

'NRC Screening Values are from The NRC Federal Register Notice, December 7, 1999

2 of 3


CCAD Media Sampling Results.

ClientID Date Th-227 Th-228 Th-230 Th-232 Location Description

CCAD-OOI' 11/10/2008 233.40 2539.15 1076.67 2123.29 Mg Th Room MgTh Room - Small Metal Plugs

CCAD-002 11/1112008 0.18 19.55 14.83 19.97 MgThRoom Grinding Booth #13 metal filings from down draft area CCAD-003 11/1112008 0.04 2.64 1.95 2.84 MgThRoom Milling machine (FADAL VMC-4525) shavings CCAD-004 11/12/2008 -0.04 0.82 0.71 1.07 MgThRoom Floor tile chips CCAD-005 11/12/2008 0.05 0.54 0.62 0.80 Mg Th Room CelingTile CCAD-006 11/12/2008 0.Q2 0.44 0.21 0.20 MgThRoom 55 gallon waste barrel CCAD-007 11113/2008 0.20 23.14 7.49 22.58 MgThRoom Lathe #55380 (lathe had fire during process)

CCAD-008 11/17/2008 0.24 14.96 12.56 14.18 Welding Spray Area New bead blast media

CCAD-009 11113/2008 -0.03 2.81 3.07 2.74 MgThRoom Overhead dust & fiberglass insulation

CCAD-OIO 11/18/2008 -0.03 0.31 0.96 0.26 Building 340 Room 201 Bead blast material from cabinet #K9640

CCAD-OII 11/19/2008 -0.04 0.22 0.40 0.34 Building 340 Room 202 Bead blast material from cabinet #P7058

CCAD-012 11/19/2008 0.02 0.03 0.05 0.01 MgThRoom Monarch lathe #38750-R oil sludge

CCAD-OB 11/19/2008 0.00 0.03 0.14 0.03 MgThRoom Cincinnati milling machine #4A30SM-5 oil sludge

CCAD-014 11/19/2008 0.10 0.94 3.67 0.95 MgThRoom Cincinnati milling machine #ZEI091 oil sludge

CCAD-OIS 11/19/2008 0.04 0.03 0.06 0,01 MgThRoom FADAL VMC-4525 oil sludge

CCAD-016 1/7/2009 0 95 68 130 MgThRoom SR#96824

CCAD-017 1/7/2009 0 74 38 110 MgThRoom Metal fillings from inside Giddings & Lewis machine lathe

CCAD-018 1/7/2009 0 5 10 6.3 MgThRoom Monarch lathe # 38750-R Oil

CCAD-O 18 Duplicate 1/7/2009 0 5 10 6.8 MgThRoom Monarch lathe # 38750-R Oil

CCAD-019 1/7/2009 0 0.02 0.01 0.02 Building 340 Room 20 I Barrel of bead blast media

CCAD-020 1/7/2009 0 20 18 29 Building 340 Room 20 I to exterior ofbuilding

CCAD-021 1/7/2009 0 2.4 2.8 4 Machine Shop Aluminum Oxide Grinding Wheel

CCAD-022 6/1/2009 0 0.2 0.2 0.08 MgThRoom Terra-Cotta

CCAD-022 Duplicate 6/1/2009 0 5 3 4 MgThRoom Terra-Cotta

CCAD-023 6/1/2009 # 5.35 3.30 3.94 Building 340 In-use bead blast media

# Not analyzed

, Estimated Results. Disposed of as radioactive waste.

,MDA < 0.3 for all results except CCAD-OO I

3 of 3


I I I I I I I I I APPENDIXB

I MDCs FOR RADIOLOGICAL CONTAMINANTS OF CONCERN

AT CORPUS CHRISTI ARMY DEPOT



I SCAN MDCs FOR RADIOLOGICAL CONTAMINANTS OF CONCERN AT THE CORPUS CHRISTI ARMY DEPOT

I I NUREG 1507, Minimum Detectable Concentrations with Typical Radiation Survey Instruments

for Various Contaminants and Field Conditions (NRC, 1998), and NUREG 1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) (DoD, 1997) provide methodology for calculation of minimum detectable concentrations (MDCs). The following details the approach for calculating site specific MDCs for Thorium-232 for use in the scoping survey

I process at the Corpus Christi ARMY Depot.

I The steps utilized for calculating MDCs for the CCAD follow the approach detailed in NUREG 1507. The steps include:

1. Calculating the minimum detectable count rate (MDCR) by selecting a given level of performance, scan speed, and background level of the detector; and

I 2. Selecting a surveyor efficiency, if applicable.

The observation interval (i) is defined as the width of the probe dived by the time that 25% of the

I probe is over a 4"x4" area of interest (scan speed).

i =(probe width) / (scan speed)

I The observable background counts (bD is defined as is the number of background counts that occur during an observation interval.

I b j =Background (B) x (i/60)

I The minimum detectable number of net source counts in the interval is given by Sj. Therefore,

I for an ideal observer, the number of source counts required for a specified level of performance can be arrived at by multiplying the square root of the number of background counts by the delectability value associated with the desired performance (d) as shown below:

s. = d' r;:;I

I "Vi

or

I Sj = d' ~B( i )60

I The MDCR is defined as the increase above background recognizable during a survey in a given period of time. The variable, d', is defined as the index of sensitivity and is dependent on the selected decision errors for Type I (alpha) and Type II (beta) errors. A true positive error (l-~)

I of 95% and a false positive error (alpha) of 60% were selected to be consistent with NUREG 1507. The value of 1.38 was obtained from Table 6.1 in NUREG 1507 (Table 6.5 in MARSSIM).

I MDCR = Sj x (60/i) = cpm

I I B-1 DRAFT FINAL


I Finally, the scan MDCs for structure surfaces may be calculated:

I MDC = MDCR (e )(eo)(prObe area)

5 I 100 cm2

where

I MCDR =minimum detectable count rate Es =surface efficiency

I Ej =instrument efficiency p = surveyor efficiency

I The static MDC for structure surfaces may be calculated:

I I I where

Rb or B =background count rate (cpm) Es =surface efficiency Ej =instrument efficiency I Tg =sample count time (min) Tb =background count time (min)

I The MDC results are presented in dpm/lOOcm2 for comparison purposes. Thus the MDC calculation was corrected using total efficiency and probe area. For determining the CCAD

I MDCs, average background values were used, these numbers were determined from reference area levels taken at CCAD.

I I I I I I I B-2 DRAFT FINAL

I I


Ludlum 2224-1 with a 43-89 detector

I Alpha

Tg

I 3 + 3.29 (Rb )(Tg )1 +~

Static MOC = (TG)(E1) (Es)(PTO~~~Tea)

I I I I I I I

(cpm)

(in)

(in/sec)

(minutes)

(minutes)

(decimal)

(cpm/dpm)

j =12.9 MDCR=45

Beta Scan MDC = 274 dpm/100cm2

2

2

0.5

118

125

12.9

0.377Instrument Efficiency (Ei)

Background count time (Tb)

Background count rate (Rb or B)

Probe area (PA)

Sample count time (Tg)

Probe width (w)

Source Efficiency (E,)

Scan Speed (s)

Alpha Scan Probability = 1.00

(greater than 0.85)

(-G)(W)(Ee )

Pen ~ 1) =1 e 60(S)

Background count rate (Rb or B) 1.5 (cpm)

Background count time (Tb) 2 (minutes)

Sample count time (Tg) 2 (minutes)

Instrument Efficiency (Ei) 0.373 (cpmldpm)

Source Efficiency (E,) 0.25 (decimal)

Probe area (PA) 125 (cm2)

Probe width (w) 12.9 (in)

Scan Speed (s) 1 (in/sec)

Index of detectability (d')

Surveyor Efficiency

1.38

0.5

Alpha Static MDC= 48 dpm/100cm2

Static MOC =

I Alpha

Beta Static MDC = 41 dpm/10Ocm2

(cpm) Background count rate (Rb or B) 42 (cpm)

(minutes) Background count time (Tb) 20 (minutes)

(minutes) Sample count time (Tg) (minutes)

(cpmldpm) Instrument Efficiency (Ej) 0.601 (cpmldpm)

(decimal) Source Efficiency (E,) 1 (decimal)

(cm2) Surface Smear 100 (cm2

)

Investigation Level (Beta)

5 dpm/100cm2

20

100

0.05

0.740

T 3 + 3.29 (Rb )(Tg )1 +t (TG)(El)(Es)(sme~~~Tea)

Static MOC =

Instrument Efficiency (Ei)

Background count rate (Rb or B)



Source Efficiency (Es)

Surface Smear

I I I

I I

I I

Ludlum 2929 with a 43-10-1 detector

Alpha Static MDC=

B-3

Static MOC =

Beta

T 3 + 3.29 (Rb )(Tg )1 +t -----'-----;~T"":"-:-__

(TG)(Ei)(Es)(PTO~~~Tea)

Beta

T 3 + 3.29 (Rb )(Tg )1 +t (TG)(EI)(Es)(sme~~tea)

Beta Static MDC = 158 dpm/100cm2

DRAFT FINAL

I I I I I I I I I I I I I I I I I I I


Ludlum 2221 with a 43-37 detector

Beta

Beta Static MIX: =

Beta Scan MDC = 136 dpmllOOcm'

.

w i= MDCR = d' JB X~X(~)s 60 I

Background count rate (Rb or B) 732



Instrument Efficiency (ti)

Source Efficiency (t,)

Probe area (PA)

Probe width (w)

Scan Speed (s)

Index of detectability (d')

Surveyor Efficiency

I

0.623

0.5

545

6.26

2

1.38

0.5

76 dpmllOOcm"

i =3.1 MDCR= 163

(cpm)

(minutes)

(minutes)

(cpm/dpm)

(decimal)

(cm')

(in)

(in/sec)

B-4 DRAFT FINAL


I I I I I I I I I APPENDIX C

I EVALUATION OF AREAS THAT ARE RADIOLOGICALLY ELEVATED RELATIVE

TO BACKGROUND



I The following survey locations represent areas which are elevated as a result of the presence of

I bead blast media containing elevated concentrations of NORM (See Laboratory Analysis Report located in Appendix A).

Table C-l. Survey Locations Exhibiting Elevated Radioactivity Due to NORM Constituents

I I I I I I I I I I I I I I I

Survey # Area I Description DPMllOOcm:':

CCAD-008 Weld,Grind,BB Area I

Overhead SS 528

CCAD-008 Weld,Grind,BB Areal

Overhead SS 376


Overhead SS 320


Overhead SS 331


Overhead SS 354


Comer 477


Cold Joint 433


Floor @ Blaster 385


Floor @ Entry 306


Cold Joint @ Crack 327


Cold Joint 332

CCAD-021 Weld,Grind,BB Area /

Cold Joint 503

CCAD-021 Weld,Grind,BB Area I Cold Joint WI holes

365


Floor 302

CCAD-021 Weld,Grind,BB Area I Cold Joint @ Crack

317

CCAD-021 Weld,Grind,BB Area I Cold Joint @ Crack

385


Floor 336


Crack 373


Crack 463


Crack 386




Crack 457

CCAD-021 Weld,Grind,BB Area I Hot

Spot 1296



I C··l DRAFT FINAL

I I


Table C-l. Survey Locations Exhibiting Elevated Radioactivity Due to NORM Constituents (Continued)

I I I I I I

Survey # Area / Description DPM/IOOcm2


Anchor Bolt 761


Cold Joint 405


Cold Joint 302


Cold Joint 328


Cold Joint 317

CCAD-005, CCAD-070B Weld,Grind,BB Area / Floor Right (Hot Spot)

1385 - 461#

CCAD-038 Building 340/ Overheads 319 CCAD-038 Building 340 / Overheads 312 CCAD-048 Building 340/ Floor 300 CCAD-048 Building 340/ Floor 316 CCAD-048 Building 340/ Floor 300 CCAD-048 Building 340/ Floor 316

I , Bead Blast matenal eXhibiting elevated radioactivity in use. # Location underwent 3 rounds of decontamination and area is still elevated.

The following survey locations represent areas which are elevated as a result of the presence of

I grinding wheel media containing elevated concentrations of NORM (See Laboratory Analysis Report located in Appendix A).

I Table C-2. Survey Locations Exhibiting Elevated Radioactivity Due to NORM Constituents

I I , ... . .

Survey # Area / Description DPMIlOOcm" CCAD-056 Machine Shop / West Wall 308 CCAD-056 Machine Shop / West Wall 319 CCAD-056 Machine Shop / West Wall 314 CCAD-056 Machine Shop / West Wall 356 CCAD-056 Machine Shop / West Wall 325

Gnnding Wheel exhlbltlllg elevated radlOacliVlty III use.

I I I I I I C-2 DRAFT FINAL



APPENDIXD

LISTING OF SURVEYS PERFORMED AND

DETAILED SURVEY INFORMATION

(Attachment D-l Detailed Survey Information on the CD-ROM attached to the back cover of this report.)

I I I I I I I DRAFT FINAL

I I


Table D-l. List of Surveys

I I I I I I I I I I I I I I I I

Survey # Room3 Area

CCAD-OOI BEQ Reference Area concrete

and metal BEQ

CCAD-002 Building 8 Reference Area concrete and metal

Building 8

CCAD-004 Reference Area concrete Building 8

CCAD-005 Welding Shop, Metal Spray

and Bead Blast Floors, walls, grind booth 13

and weld booth 6


and Bead Blast Bead Blaster Model #: 4800,

Serial #: 4800-3-12-82-25


and Bead Blast Overhead support structures

CCAD-009 Electron Beam Welder Area Floors, Walls and Weld

Chamber

CCAD-013 Electron Beam Welder Area Ventilation

CCAD-014 Electron Beam Welder Area Overhead ceiling tile and

support structure

CCAD-015 Magnesium-Thorium Room Ceiling tile and air vents

CCAD-016 Magnesium-Thorium Room Walls

CCAD-018 Magnesium-Thorium Room Roof and ventilation

CCAD-019 Magnesium-Thorium Room Overhead support structure

CCAD-020 Building 340 Floor


and Bead Blast Floor







CCAD-028 Electron Beam Welder Area Floor

CCAD-029 Haas Mill Floor

CCAD-032 Magnesium-Thorium Room Floor


CCAD-034a& 034b

Magnesium-Thorium Room Floor

CCAD-035 Reference Area; Ceiling and

Overhead Building 8

CCAD-037 Machine Shop Aluminum Oxide Grinding

Wheel

CCAD-038 Building 340 Overhead


and Bead Blast Aluminum Oxide Bead Blast

Media

CCAD-041 Building 1727 Floors, walls and ceiling

D-l DRAFT FINAL I

I I


Table D-l. List of Surveys (Continued)


Survey # Room3 Area

CCAD-042 Building 340 Walls


CCAD-047 Building 258 Overhead and walls


CCAD-049 North End Bead Blast Area Floor, ventilation and walls


CCAD-051 Building 1825 Overhead, walls and break

room


CCAD-053 Building 340 HEPA exhaust pipe

CCAD-054 Building 339 Overhead, walls and break

room


CCAD-056 Machine Shop West wall

CCAD-057 Machine Shop Floor

CCAD-P58 Machine Shop Overhead

CCAD-059 North End Bead Blast Area Floor

CCAD-060 Engine Cleaning and

Disassembly Walls

CCAD-061 Engine Cleaning and Disassembly

Floor


Disassembly Exhaust hoods


Disassembly Overhead


and Bead Blast HEPA unit from the Metal

Spray Booth #7

CCAD-066 Building 132 Floor, walls and overhead

CCAD-067 Magnesium-Thorium Room Floor

CCAD-068 Magnesium-Thorium Room WaIls


CCAD-071 Welding Shop, Metd Spray


CCAD-On Magnesium-Thorium Room Walls

CCAD-073 North End Bead Blast Area Roof and Ventilation

CCAD-074 Magnesium-Thorium Room Roof and Ventilation

CCAD-075 North End Bead Blast Area Interior duct work


Disassembly Overhead

I I D-2 DRAFT FINAL

I I


Table D-l. List of Surveys (Continued)

I I I I I

Survey # Room3 Area

CCAD-On Engine Cleaning and

Disassembly Floors

CCAD-078 Electron Beam Welder Area Ventilation pipe and Roof


Disassembly Walls

CCAD-080 Building 132 Drain Traps

CCAD-081 Building 258 Ventilation

CCAD-082 Machine Shop West Wall

CCAD-083 Electron Beam Welder Area Floors

CCAD-084 Magnesium-Thorium Room Ventilation

CCAD-085 Welding Shop. Metal Spray

and Bead Blast Overhead

CCAD-086 Building 339 Overheads and Floors

CCAD-088 Building 1825 Overheads. Floors and Break

RoomI . . . . 3 Areas not refemng to a specific bUlldmg are located within mlpacted areas of BUlldmg 8. Surveys 3, 7,10, II, 12, 17,30,31,43,44,45,63,70, 70a and 70b represent equipment surveys which are

I beyond the scope of this survey report. Surveys 36, 40 and 76 were skipped and are thus not included in this Appendix. CCAD-024 contains data from

the floor of the Compressor Housing Area which is beyond the scope of this report.

I I I I I I I I I I D-3 DRAFT FINAL


I I I I I I I I I

ATTACHMENT D-l

DETAILED SURVEY INFORMATION

I (On the CD-ROM attached to the back cover of this report.)



I I I I I I I I APPENDIXE

I QUALITY ASSURANCE AND QUALITY CONTROL (QA/QC)

(On the CD-ROM attached to the back cover of this report.)

I I I I I I I I I DRAFT FINAL


I I I I I I I I I

APPENDIXF

WILCOXEN RANK SUM TESTS

I (On the CD-ROM attached to the back cover of this report.)


I I


Table F-l. Wilcoxon Rank Sum Tests



Haas Mill Floor SU-A

Metal Spray Walls SU-A

Overheads SU-B

Floor SU-C

Floor SU-D

Floor Hotspot SU-E


Ventilation System SU-B

Overheads SU-C

Floor SU-D

Machine Shop Floor SU-A

Overheads SU-B

Walls SU-C

Walls SU-D

North Bead Blast Floor SU-A

Walls SU-B

Ventilation SU-C

Roof SU-D

Internal Ventilation Sys SU-E

MgThRoom Floors (pre-tile removal) SU-A

Floors (post-tile removal) SU-AI, A2

Overheads SU-B

Roof ventilation SU-C

Roof SU-D

Walls SU-E, El, E2, E3, E4, E5, E6, E7

Ceiling tiles** SU-F

Drains Drains SU-A

EB Weld Floor SU-A, AI, A2

Walls SU-B

Overheads SU-C

Ventilation SU-D

Window vent SU-E

Roof SU-F

Vent pipe SU-G

Building 1825 Breakroom SU-A, AI, A2, A3, A4

Floors SU-B

Overheads SU-C, CI

Walls SU-D, DI

I I F-l DRAFT FINAL

I I


Table F-l. Wilcoxon Rank Sum Tests (Continued)

I I I I I


Building 1727 Floor SU-A

Walls SU-B, Bl

Ceiling SU-C


Floors SU-B

Office floors SU-Bl, B2

Overheads SU-C

Ventilation SU-D

Building 258 Floors SU-A

Overheads SU-B

Walls SU-C

Engine Cleaning Floors SU-AI-A6, BI-B6, CI-C6

Overheads SU-B, Bl, B2, B3

Walls SU-C, Cl, C2, C3 I . . * All areas not speclfymg a bUilding number were within BUIlding 8. ** For reference only. Ceiling tiles were disposed of as radioactive waste.

I I I I I I I I I I I P.-2 DRAFT FINAL

l;C ( 2 3 8 7


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10/6/09

Jl~ ~

Surve Meets Re uirements set fourth in Re . Guide 1.86. Smear locations numbered and circled Fixed contamination readings numbered inside square, General area dose rates underlined, Contact dose readings listed and accompanied by *. Removable survey results attached, YES-X- NO_

-', .

iTS 30 sec

~IC WPC-9550 Nu~ber 1

I----------------ALPHA-----------------I----------------BE'i'A------------------1 I Eff: 25.40 %Bkg: 0.34 LLD: 32.061 Eff: 29.11 %Bkg: 2.14 LLD: 45.091

I-----ID----I-CARRIER-I-RPT-I-RCT-I--COUHTS-I-NET CPK-I---DPK---I-LIMITS-I--COUNTS-I-KET CPK-I---DPM---I-LIKITS-I---DATR---I--TIKE-301.006.084 1 1 0 0 -0.34 -1.35 1 -U5 -2.23 06-25-2009 02:04:28

2 1 0 0 -0.34 -1.35 3 3.35 11. 51 06-25-2009 02:05:18 3 1 0 0 -0.34 -1.35 0 -2.65 -9.10 06-25-2009 02:06:08 4 1 0 0 -0.34 -1.35 0 -2.65 -9.10 06-25-2009 02:06:58 5 1 0 0 -0.34 -1.35 0 -2.65 -9.10 06-25-2009 02:07:49 6 1 0 0 -0.34 -1.35 2 1.35 4.64 06-25-2009 02:08:39 7 1 0 0 -0.34 -1.35 2 1.35 4.64 06-25-2009 02:09:29 8 1 0 0 -0.34 -1.35 1 -0.65 -2.23 06-25-2009 02:10:19 9 1 0 0 -0.34 -1.35 1 -0.65 -2.23 06-25-2009 02:11:09

10 1 0 0 -0.34 -1.35 2 1.35 4.64 06-25-2009 02:11:59 11 1 0 0 -0.34 -1.35 0 -2.65 -9.10 06-25-2009 02:12:49 12 1 0 0 -0.34 -1.35 3 3.35 11.51 06-25-2009 02:13:39 13 1 0 0 -0.34 -1.35 2 1.35 4.64 06-25-2009 02:14:29 14 1 0 0 -0.34 -1.35 0 -2.65 -9.10 06-25-2009 02:15:19 15 1 0 0 -0.34 -1.35 1 -0.65 -2.23 06-25-2009 02:16:10 16 1 0 0 -0.34 -1.35 1 -0.65 -2.23 06-25-2009 02:17:00 17 1 0 0 -0.34 -1.35 2 1.35 4.64 06-25-2009 02:17:50 18 1 0 0 -0.34 -1.35 2 1.35 4.64 06-25-2009 02:18:40 19 1 0 0 -0.34 -1.35 4 5.35 18.38 06-25-2009 02:19:30 20 1 0 0 -0.34 -1.35 0 -2.65 -9.10 06-25-2009 02:20:20 21 1 0 0 -0.34 -1.35 2 1.35 4.64 06-25-2009 02:21:10 22 1 0 0 -0.34 -1.35 2 1.35 4.64 06-25-2009 02:22:00 23 1 0 1 1.66 6.53 1 -1.20 -4.11 06-25-2009 02:22:50 24 1 0 0 -0.34 -1.35 4 5.35 18.38 06-25-2009 02:23:41 25 1 0 1 1.66 6.53 1 -1.20 -4.11 06-25-2009 02:24:31 26 1 0 0 -0.34 -1.35 1 -0.65 -2.23 06-25-2009 02:25:21 27 1 0 0 -0.34 -1.35 3 3.35 11. 51 06-25-2009 02:26:11 28 1 0 0 -0.34 -1.35 1 -0.65 -2.23 06-25-2009 02:27:01 29 1 0 0 -0.34 -1.35 0 -2.65 -9.10 06-25-2009 02:27:51 30 1 0 0 -0.34 -1.35 2 1.35 4.64 06-25-2009 02:28:42 31 1 0 1 1.66 6.53 4 UO 16.50 06-25-2009 02:29:32 32 1 0 0 -0.34 -1.35 1 -0.65 -2.23 06-25-2009 02:30:22 33 1 0 0 -0.34 -1.35 0 -2.65 -9.10 06-25-2009 02:31:12 34 1 0 0 -0.34 -1.35 4 5.35 18.38 06-25-2009 02:32:02 35 1 0 0 -0.34 -1.35 2 1.35 4.64 06-25-2009 02:32:52 36 1 0 0 -0.34 -1.35 0 -2.65 -9.10 06-25-2009 02:33:43 37 1 0 0 -0.34 -1.35 3 3.35 11.51 06-25-2009 02:34:33 38 1 0 1 1. 66 6.53 2 0.80 2.76 06-25-2009 02:35:23 39 1 0 1 1.66 6.53 4 4.80 16.50 06-25-2009 02:36:13 40 1 0 0 -0.34 -1.35 2 1.35 4.64 06-25-2009 02:37:03

P.O. Box 4849, Oak Ridge, TN 37831


July 8, 2009


The following will serve as docmnentation for the disposal of the waste received as manifest nmnber 20090528-001. This waste was received by Impact Services Inc. (TRML# R-73024-E-17) and disposed of as solid waste at the Chestnut Ridge landfill after analytical data determined it met the criteria for Volmnetric Clearance Disposal. The waste was disposed of at the landfill on 19 June 2009 under manifest nmnber WMNA 10926280.

~~\\~ Chris Hepler Radiation Safety Officer Impact Services Inc. 865-576-8724


Tr~cking#:301- c:::cJ'i-ooB Technician: 3, ~ (~ ,4 ------------------------------------------------------------------,

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® Date: 7;'1 /c; <1 Time: 0 rbt!:>cJr ,

Reason for Survey: _-..!-F~re"'e-"'R"'e:!'le"'as"'e'---HSWP#(s):, -::--':O-";-1,:::/012.9'----__ Type of Survey: __....R""a"'d"-I-"C"'o-"n _


Model: S' BKG I~ BKG WPC9550 Serial# -/:-:d~7~t:>--=-~-::;;15""'--- 01614~ A.L Cal Due: /2,{4!t''l 10/6/09

Surve Meets Re uirements set fourth in Re . Guide 1.86. 'It::: Smear locations numbered and circled Fixed contamination readings numbered inside square, General area dose rates underlined, Contact dose readings listed and accompanied by +. Removable survey results attached, YESJ- NO_

US 30 sec

PIC WPC-9550 Number 1

�----------------ALPHA-----------------�----------------BETA------------------I

I Eff: 25.40 t Bkg: 0.34 LLD: 32.051 Eff: 29.11 , Bkg: 2.73 LLD: 45.011 I-----ID----I-CARRIER-I-RPT~I-RCT-I--COUHTS-I-NET CPK-I---DPN---I-LINITS-I--COUHTS-I-NET CPK-I---DPN---I-LINITS-I---DATE---I--TIKE301.007.008 1 1 0 0 -0.34 -1.34 -0.63 -2.17 07-07-2009 08:16:3

£DI T2 J2UE If5£. 2 3

1 1

0 0

0 0

-0.34 -0.34

-1.34 -1.34

1 3

-0.63 3.37

-2.17 11. 57

07-07-2009 08:17:2 07-07-2009 08:18:1

5 1 0 0 -0.34 -1.34 0 -2.63 -9.04 07-07-2009 08:19:~

6 1 0 0 -0.34 -1.34 0 -2.63 -9.04 07-07-2009 08:19:5 7 1 0 0 -0.34 -1.34 2 1.37 4.70 07-07-2009 08:20:4 8 1 0 0 -0.34 -1.34 2 1.37 4.70 07-07-2009 08:21:3 9 1 0 0 -0.34 -1.34 0 -2.63 -9.04 07-07-2009 08:22:2

10 1 0 0 -0.34 -1.34 2 1.37 4.70 07-07-2009 08:23:1 11 1 0 0 -0.34 -1.34 1 -0.63 -2.17 07-07-2009 08:24:( 12 1 0 0 -0.34 -1.34 2 1.37 4.70 07-07-2009 08:24:! 13 1 0 0 -0.34 -1.34 1 -0.63 -2.17 07-07-2009 08:25:4 14 1 0 0 -0.34 -1.34 2 1.37 4.70 07-07-2009 08:26:l 15 1 0 0 -0.34 -1.34 2 1.37 4.70 07-07-2009 08:27:; 16 1 0 0 -0.34 -1.34 1 -0.63 -2.17 07-07-2009 08:28:1 17 1 0 0 -0.34 -1.34 6 9,37 32.18 07-07-2009 08:29:( 18 1 0 0 -0.34 -1.34 0 -2.63 -9.04 07-07-2009 08:29:! 19 1 0 0 -0.34 -1.34 1 -0.63 -2.17 07-07-2009 08:30:( 20 1 0 0 -0.34 -1.34 0 -2.63 -9.04 07-07-2009 08:31:l 21 1 0 0 -0.34 -1.34 2 1.37 4.70 07-07-2009 08:32:: 22 1 0 0 -0.34 -1.34 0 -2.63 -9.04 07-07-2009 08:33:: 23 1 0 0 -0.34 -1.34 5 7.37 25.31 07-07-2009 08:34:( 24 1 0 0 -0.34 -1.34 0 -2.63 -9.04 07-07-2009 08:34:! 25 1 0 0 -0.34 -1.34 2 1.37 4.70 07-07-2009 08:35:1 26 1 0 0 -0.34 -1.34 0 -2.63 -9.04 07-07-2009 08:36::

27 1 0 0 -0.34 -1.34 0 -2.63 -9.04 07-07-2009 08: 37:: 28 1 0 0 -0.34· -1.34 0 -2.63 -9.04 07-07-2009 08:38:: 29 1 0 0 -0.34 -1.34 2 1.37 4.70 07-07-2009 08:39:1

In 4 7 2 3 8 7

ACCEPTANCE REVIEW MEMO (ARM) Licensee: Dept of Army (Corpus Christi) License: 8T8-1168

Docket: 040-08177 Mail Control: 472387

Type of Action: Term Date of Requested Action: 8-19-09

Reviewer ARM reviewer(s): Torres Assigned:

Response Deficiencies Noted During Acceptance Review

[ ] Open ended possession limits. Submit inventory. Limit possession. [ ] Submit copies of latest leak test results. [ ] Add IC L.C./Fingerprint LC, add SUNSI markings to license. [ ] Confirm with licensee if they have NARM material. [ ] Change of contact information (RSO), send request to update IC database.

Reviewer's Initials: Date:

DYes DNo Request for unrestricted release Group 2 or >. Consult with Bravo Branch.

DYes DNo Termination request < 90 days from date of expiration

DYes DNo Expedite (medical emergency, no RSO, location of use/storage not on license, RAM in possession not on license, other)

DYes DNo TAR needed to complete action.

Branch Chiefs and/or HP's Initials: Date:

/ SUNSI Screening according to RIS 2005-31

DYes ~o Sensitive and Non-Publicly Available if any item below is checked General guidance:

__RAM =or> than Category 3 (Table 1, RIS 2005-31), use Unity Rule __Exact location of RAM [suite #, bldg. #, location different from mailing address] (whether =or > than Category 3 or not) __Design of structure and/or equipment (site specific) __Information on nearby facilities __Detailed design drawings and/or performance information __Emergency planning and/or fire protection systems

Specific guidance for medical, industrial and academic (above Category 3): __RAM quantities and inventory __Manufacturer's name and model number of sealed sources & devices __Site drawings with exact location of RAM, description of facility __RAM security program information (locks, alarms, etc.) __Emergency Plan specifics (routes to/from RAM, response to security events) __Vulnerability/security assessment/accident-safety analysis/risk assess __Mailing lists related to security response

AIJ "IZ-- SEP - 4 Branch Chiefs and/or HP's Initials: /f'/'V Date:

9-tJ9-o9 This Is to acknowledge the receipt of your letter/application dated DATE

~ - /<1 - <2 '7 .and to Inform you that the Initial processing, which includes an administrative review, has been performed.

There were no administrative omissions. Your application will be assigned to a technical reviewer. Please note that the technical review may identify other omissions or require additional information.

o Please provide to this office within 30 days of your receipt of this card:

The action you requested is normally processed within 9D days.

o A copy of your action has been forwarded to our License Fee & Accounts Receivable Branch, who will contact you separately if there Is a fee issue involved.

Your action has been asslQned Mall Control Number ¥ 7~ 3f~ When calling to inqUire about this action, please refer to this mail control nurn r. You may call me at 817-860-8103.

Sincerely,

~~ NRC FORM 532 (RIV) licensing Assistant (10-2008)

(FOR LFMS USE)INFORMATION FROM LTS

BETWEEN:

License Fee Management Branch, ARM Program Code: 11800 and Status Code: 0

Regional Licensing Sections Fee Category: 2C Exp. Date: 20110228 Fee Comments: 2C IS THORIUM

,. Decorn Fin Assur Reqd: N . .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. '" .. '" .. '" '" '" '" .. '" '" '"

LICENSE FEE TRANSMITTAL

A. REGION

1. APPLICATION ATTACHED Applicant/Licensee: ARMY, DEPARTMENT OF THE Received Date: 20090819 Docket No: 4008177 Control No.: 472387 License No.: STB-1168 Action Type: Termination

2. FEE ATTACHED=/-=Amount: Check No.:

3. COMMENTS

~:l;'d~ B. LICENSE FEE MANAGEMENT BRANCH (Check when milestone 03 is entered /--I) 1. Fee Category and Amount: ___

2. Correct Fee Paid. Application may be processed for: Amendment Renewal License

3. OTHER

SignedDate

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