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KCP Summary 1 5286-LT-01-0

SUMMARY OF INDEPENDENT VERIFICATION ACTIVITIES AT THE BANNISTER FEDERAL COMPLEX AT THE KANSAS CITY PLANT

IN KANSAS CITY, MISSOURI

1. INTRODUCTION

The U.S. Department of Energy (DOE) Kansas City Field Office requested that Oak Ridge Institute

for Science and Education (ORISE) serve as the independent verification (IV) contractor for the

clearance of real property within the Bannister Federal Complex (BFC) at the Kansas City Plant in

Kansas City, Missouri. The BFC is illustrated in Figure 1.1. DOE is in the process of

releasing/transferring the property, and IV is required per DOE Order (O) 458.1 when there are

radiological contaminants of concern. During the clearance process, DOE identified uranium

contamination on floor and wall surfaces in some areas within former Department 49X area,

Department 20, and Department 34C of the Main Manufacturing Building (MMB). Uranium

contamination was also identified in soils near Building 59, consisting of both processed natural and

depleted uranium. Finally, site investigators discovered and remediated a localized area containing

low-level thorium contamination in soil east of Building 96. As described in this report, ORISE

performed IV activities by reviewing release plans, reports, and data; deriving authorized limits (ALs)

for uranium in soil; performing on-site IV activities at the MMB; analyzing two sets of split samples

from the soils contamination area, and comparing residual uranium and thorium data to respective

ALs. As a result of these efforts, ORISE concludes that the BFC satisfied radiological requirements

outlined in O 458.1. The following summarizes IV activities related to document reviews, AL

derivations, on-site IV, and split sample analyses.

DOE’s objective is to release the BFC under O 458.1 through the collection and review of quality

data in sufficient quantities to make a confident conclusion for the real property release. DOE

approved the building and subsurface soil uranium sampling plans and methods that were

performed by S.S. Papadopoulos (SSPA) and ANTECH. To determine the sample adequacy, the

areas were identified to be impacted or un-impacted. Based on the site history, the majority of the

building and all the exterior soils were originally assumed to be un-impacted areas. In the MMB, a

few impacted areas were identified, surveyed, and remediated, as needed. After remediation, ORISE

independently verified the areas as described in Section 4 of this report.


Figure 1.1. The Bannister Federal Complex


For the exterior soils, the contractor collected more than 2,000 soil samples over the entire site.

When SSPA identified some potentially impacted areas to the east of the MMB, additional

investigation and sampling were conducted to ensure the soils were below the action levels set by

DOE. Multiple investigations were conducted in these areas, including IV as described in Section 5

of this report.

2. DOCUMENT REVIEWS

ORISE reviewed planning and reporting documents and data associated with the BFC as a whole,

but with emphasis for areas associated with those known to have been impacted by radiological

activities. Included in these reviews were the Auxier and Associates Survey Plan (Auxier 2015) and

Survey Report (Auxier 2016), the ANTECH Radiological Assessment of the MMB (ANTECH

2016a) and soils near Building 59 (ANTECH 2016b), and the SSPA Due Diligence reports (SSPA

2016a, 2016b and 2016c). ORISE also reviewed associated field measurement and analytical data

collected by SSPA from these areas. Figure 2.1 presents the distribution of about 2,000 soil samples

(including multiple depth intervals at some locations) that SSPA collected during three phases of

work. When SSPA identified some potentially impacted areas, additional investigation and sampling

were planned, conducted, and reported to ensure the soil concentrations met O 458.1 requirements.

Comments on these reports were provided to DOE and discussed, as required, and ORISE is

satisfied that planning and reporting was generally adequate for addressing release requirements.

One noted exception is discussed in Section 4 of this report.


Figure 2.1. Distribution of SSPA Soil Sample Locations across the Bannister Federal Complex


3. AUTHORIZED LIMITS

Order 458.1 provides, via O 5400.51, the following pre-approved ALs for uranium on

building/structural surfaces—these apply regardless of isotopic abundance:

Radionuclides Units Average (Total) Maximum Removable Uranium dpm/100 cm2 5,000 15,000 1,000

The Order does not provide pre-approved ALs for uranium in soil, nor had any been derived for the

BFC. Therefore, ORISE was tasked with developing site-specific ALs for uranium in soil using the

requirement presented in O 458.1 Section 4.k(6)(c), which states, among other requirements, that

radiological dose must be calculated “for members of the public most likely to receive the highest

dose for both: actual or likely future use, and plausible future use of the property.” ORISE derived

the following ALs using the RESRAD code version 7.0 (Yu et al. 2001) and the conceptual site

model for industrial-use scenarios presented in the 2015 Baseline Risk Assessment (URS 2015):

• 3,700 pCi/g of U-234

• 150 pCi/g of U-235

• 600 pCi/g of U-238

• 910 pCi/g of processed total uranium (natural)

• 810 pCi/g of processed total uranium (depleted)

Note ALs are presented for individual uranium isotopes as well as for processed natural and

depleted uranium (ORISE 2016c). DOE approved the ALs for BFC soils in June 2016 (DOE 2016).

The final AL document is provided as Attachment 1 to this report.

Pre-approved, generic ALs for thorium are available1 as follows:

• A net concentration of 5 pCi/g averaged over the first 15 cm of soil below the surface

(averaged over 100 m2)

1 Order 458.1 states (emphasis added), “Previously approved guidelines and limits (such as the surface activity guidelines) may continue to be applied and used as Pre-Approved Authorized Limits until they are replaced or revised by Pre-Approved Authorized Limits issued under this Order.” This includes the guidelines listed in Figure IV-1 of Order 5400.5, which are used here.


• A net concentration of 15 pCi/g average over 15-cm-thick layers of soil more than 15 cm

below the surface (averaged over 100 m2)

• Small areas of elevated activity with a net concentration no more that (100/A) times larger

than the generic AL, where A is the “hot spot” area in meters

If mixtures of radiological contamination occurs, the concentrations of individual radionuclides

shall be reduced so that either the dose for the mixtures will not exceed the sum-of-the-ratios of

the soil concentration of each radionuclide to the allowable limit for that radionuclide will not

exceed 1.

4. BUILDING INTERIOR OF MMF

ORISE performed on-site IV in December 2015 (ORISE 2016a) and again in February 2016

(ORISE 2016b). The December effort included extensive surveys of floors and lower walls that had

been scabbled (i.e., a thin surface layer was removed) to ensure residual radioactivity in the former

Department 49X area, Department 20, and Department 34C of the MMB were below the pre-

approved AL. Surveys were performed using hand-held detectors and a floor monitor (all gas

proportional detectors). When suspect contamination was identified during the scan, follow-up static

(one-minute) measurements and smear samples were also collected. ORISE surveyors identified 11

“hot spots” in the former Department 49X area and 16 in Department 20. Of those, none exceeded

the average or removable ALs, though one ~25,000 dpm/100 cm2 result in the former Department

49X area did exceed the maximum pre-approved AL of 15,000 dpm/100 cm2. This area was

subsequently remediated. All results from the December effort are presented in Attachment 2.

As a result of ORISE’s findings in the former Department 49X area and Department 20, the DOE

contractor, ANTECH, re-scabbled or otherwise remediated the 27 locations identified by ORISE

with an administrative guideline of reducing detector responses to below 1,000 dpm/100 cm2.

ORISE returned to the site in February 2016 to assess the effectiveness of remedial activities. All

residual activities were found to be well below ALs, as reported in the Attachment 3 trip report, with

a maximum result of ~1,600 dpm/100 cm2. Note that the maximum level was above the

administrative guideline for remedial action but is still well below the 5,000 dpm/100 cm2 AL.


5. OUTDOOR SOIL

The trip 2 report (Attachment 3) also presents results from 12 soil split samples that ANTECH

collected in March 2016 near Building 59 (see Figure 5.1) and shipped to the ORISE laboratory for

analysis. These locations were selected to assess uranium concentrations in soil where the maximum

historical result of 73 mg/kg (which converts to 37 pCi/g of depleted uranium) had been identified.

While inter-laboratory results are comparable, and low levels of depleted uranium were identified, no

value approaches the 73 mg/kg historical maximum. In all cases, soil concentrations are well below

the most restrictive industrial use AL of 810 pCi/g (for depleted uranium).

Figure 5.1. Location of SSPA Boreholes in the Building 59 Area

In June 2016, the prospective property owner, CenterPoint Properties, had their contractor, SSPA,

collect additional subsurface soil samples in the Building 59 area, as shown in Figure 5.1. Two of

these samples exceeded the AL for U-238 (and one for total uranium), with a maximum uranium U-


238? concentration of 818 pCi/g (971 pCi/g total uranium?). Though the ALs are for large exposure

areas and not for relatively small hot spots (the average in the area is below ALs), DOE instructed

ANTECH to conduct an additional investigation of the area, determine to what extent, if any, the

soil has been impacted by site operations, and remove elevated areas. Figures 5.2 through 5.6,

provided by ANTECH, show the July 2016 exploratory excavations ANTECH performed in three

areas near Building 59.

Figure 5.2. ANTECH’s Exploratory Excavation at Borehole Location 5004


Figure 5.3. ANTECH’s Exploratory Excavation at Borehole Location 5026

Figure 5.4. ANTECH’s Exploratory Excavation at Borehole Location 5027 (1)





Each location is associated with a borehole that had been previously investigated (CP5004, CP5026,

CP5027). A golf-ball-sized clump of soil that exhibited elevated readings during field screening was

removed, and portions of this sample CP-5026-02 were sent to both the ANTECH and ORISE

laboratories for analysis. ANTECH sampled both the surface of the excavation and the soils piles

(which were used to backfill the excavations), collecting a total of 51 samples across the three areas.

Table 5.1 presents a summary of the ANTECH effort.

Table 5.1. General Description of ANTECH’s July 2016 Soils Investigation Borehole Location

Parameter 5027 5026 5004 Area 16-ft by 44-ft 20-ft by 20-ft 6-ft by 7-ft No. Samples in the Base of the Excavation 10 18 11 No. Samples in the Associated Soil Pile 2 6 4

ORISE evaluated the results from the twelve soil split samples in March dataset plus the ten soil

split samples collected in July and compared total uranium concentrations using the Sign test. The

objective of the test was to assess dataset comparability, i.e., to determine if there were noticeable

biases in the ANTECH data that would require additional study. The method is to: (1) take the

difference in the ANTECH and ORISE total uranium results and count the number of positive and

negative differences, and (2) estimate the median of the differences (Gilbert 1987). If the number of

positive and negative differences is similar, and the median of the difference is near zero, then the

datasets are comparable and no biases are assumed. Table 5.2 presents Sign test result, with equal

number of negative (11) and positive (11) differences, and a median or -0.02 pCi/g. This supports

the conclusion that ANTECH and ORISE data are comparable, thus it is concluded that

ANTECH’s dataset adequately represents site conditions.

Having concluded that the ANTECH data are adequate for use in clearance decisions, ORISE used

judgmental (i.e., non-random) results from the three excavations to conservatively estimate soil

concentrations in the Building 59 area. Table 5.3 presents summary statistics for the entire

ANTECH dataset from the July 2016 investigation, minus results from sample CP5026-02—the

materials associated with sample CP5026-02 were removed from the site and thus do not represent

existing on-site conditions. Included in the summary are calculations of the 95% upper confidence

on the mean concentration (UCL-95) using both normal and non-parametric calculation methods

per ProUCL software.


Table 5.2. Sign Test Results for Total Uranium Concentrations Total Uranium (pCi/g)

ORISE ANTECH

Station Results Results Difference Sign CP5004-9 11.60 13.04 1.44 + CP5026-02 283,900 245,610 -38,290 - CP5026-5 4.98 3.75 -1.23 - CP5026-9 3.44 3.34 -0.10 - CP5026-15 6.11 5.98 -0.13 - CP5026-18 10.22 10.26 0.04 + CP5026-21 3.81 7.11 3.30 + CP5027-2 4.73 5.39 0.66 + CP5027-11 3.23 3.16 -0.07 - CP5027-14 4.22 2.78 -1.44 - BFC 5004 1'-2' 8.82 8.33 -0.49 - BFC 5004 2'-4' 13.91 11.10 -2.81 - BFC 5004 5'-6' 14.68 15.40 0.72 + BFC 5004 7'-10' 9.36 9.60 0.24 + BFC 5006 3'-5' 5.35 6.41 1.06 + BFC 5006 7'-9' 2.79 4.83 2.05 + BFC 5006 13'-15' 2.40 2.04 -0.36 - BFC 5006 18'-20' 2.13 2.36 0.24 + BFC 5007 1'-2' 2.64 2.80 0.16 + BFC 5007 3'-5' 4.41 4.32 -0.09 - BFC 5007 5'-7' 2.89 2.67 -0.22 - BFC 5007 8'-10' 2.38 2.42 0.04 +

Median -0.02

No. negatives 11

No. positives 11

All values in Table 5.3, including maximum and UCL-95 estimates, are well below the AL values

presented in Section 2. Results do, however, demonstrate that Building 59 area soil has been

impacted by site operations, when compared to the ~1.5 pCi/g total uranium background, and low

levels of depleted uranium are present. Specific total uranium results include the mean (7.26 pCi/g),

median (4.27 pCi/g), the non-parametric UCL-95 (12.6 pCi/g), and maximum result (50.5 pCi/g).


Even when considering only judgmental samples, these results demonstrate that concentration-

based clearance requirements for soil have been met.

Table 5.3. Summary Statistics for July 2016 Dataset

Parameter U-234 U-235 U-238 Total Ua Number of Samples 50 50 50 50 Number of Detections 50 48 50 50 Minimum Detection (pCi/g) 0.89 0.05 0.94 1.9 Maximum Detection (pCi/g) 10.8 0.91 40.6 50.5 Mean Concentration (pCi/g) 2.23 0.15 4.88 7.26 Median (pCi/g) 1.64 0.11 2.44 9.33 Standard Deviation (pCi/g) 1.79 0.16 6.87 12.6 UCL-95; Normal (pCi/g) 2.66 0.19 6.51 4.27 UCL-95; Non-Parametric (pCi/g) 3.34 0.25 9.11 8.73

Excludes materials/results from CP5026-02, which were removed. aStatistics calculated by summing results from individual samples then performing calculations.

A DOE contractor identified a localized area of elevated gamma radiation, east of Building 96,

during a walkover survey. Samples were collected and low-level Th-232 contamination was

discovered, with a maximum concentration of 21.4 pCi/g from a blueish golf-ball-size piece of

material. Elevated uranium was not identified in the sample, with maximum U-234 and U-238

concentrations of 1.06 pCi/g and 1.22 pCi/g, respectively. The material and adjacent soils were

excavated and removed and ten confirmatory samples were collected from the excavation

(ANTECH 2016c). ORISE reviewed the confirmatory data plus thorium data from other portions

of the site, specifically from the Phase III and Supplemental reports (SSPA 2016c). The maximum of

1.72 pCi/g was reported from over 200 samples reported for the site, including a maximum of

1.25 pCi/g from the 10 confirmation samples. ORISE concluded that residual thorium

concentrations across the site are consistent with background, sum-of-the-fractions does not apply

(contaminants are not co-located), and all reported values are well below the most restrictive pre-

approved AL for Th-232.

6. CONCLUSIONS

ORISE measurements in the MMB have demonstrated that building/structural surface radiation

levels satisfy pre-approved ALs for uranium. Sign test results described in this report demonstrate

that ANTECH and ORISE soil sample data are comparable, thus it is concluded that ANTECH’s


dataset adequately represents site conditions. Finally, over 2,000 soil samples have been collected

across the site, including 50 samples from residual soils in the Building 59 area, where the highest

historical measurements were collected; and 10 samples from a highly localized area east of Building

96, where low-level thorium contamination was excavated. All residual soil sample results are well

below the applicable ALs, even when considering only judgmental data. ORISE therefore concludes

that surface and soil data satisfy O 458.1 requirements for the clearance of real property at the BFC.

7. REFERENCES

ANTECH 2016a. Radiological Assessment of Former Radiologic Areas at the DOE Kansas City Plant. ANTECH Corporation. Westminster, Colorado. March 29.

ANTECH 2016b. Excavation of Potential Contaminated Area at the Banister Site. ANTECH Corporation. Westminster, Colorado. July 11.

ANTECH 2016c. Supplement II to Radiological Assessment of Former Radiological Areas at the DOE Kansas City Plant Grassy Area Remediation, Draft, ANTECH Corporation. Westminster, Colorado. December.

Auxier 2015. Survey Plan for Select Areas within the Banister Federal Complex. Auxier and Associates, Inc. Prepared for CenterPoint Properties, Inc. Kansas City, Missouri. September.

Auxier 2016. Survey Report for Stage 3 Building Materials. Auxier and Associates, Inc. Prepared for CenterPoint Properties, Inc. Kansas City, Missouri. January.

DOE 2013. Order 458.1, Radiation Protection of the Public and the Environment. Change 3. U.S. Department of Energy. Washington, D.C. January.

DOE 2016. Approval of Authorized Limits Request for uranium in soils at the Bannister Federal Complex in accordance with Order 458.1. U.S. Department of Energy. Kansas City Field Office. June.

Gilbert 1987. Statistical Methods for Environmental Pollution Monitoring. New York, New York.

ORISE 2016a. Report for December 2015 Independent Verification Activities at the Bannister Federal Complex at the Kansas City Plant in Kansas City, Missouri. 5056-SR-01-1. Oak Ridge Institute for Science and Education. Oak Ridge Tennessee. February 2.

ORISE 2016b. Report For February 2016 Independent Verification Activities at the Bannister Federal Complex at the Kansas City Plant in Kansas City, Missouri. 5286-SR-01-0. Oak Ridge Institute for Science and Education. Oak Ridge, Tennessee. April 7.

ORISE 2016c. Authorized Limits for Soil at the Bannister Federal Complex at the Kansas City Plant in Kansas City, Missouri. 5286-TR-01-0. Oak Ridge Institute for Science and Education. Oak Ridge, Tennessee. April 7.


SSPA 2016a. Due Diligence Site Investigation Summary Report, Volume 1 – Report. S.S. Papadopulos & Associates, Inc. Bethesda, Maryland. February.

SSPA 2016b. Due Diligence Site Investigation Summary Report, Volume 2 – Appendices A to M. S.S. Papadopulos & Associates, Inc. Bethesda, Maryland. February.

SSPA 2016c. Due Diligence Site Investigation Stage III Data Report Radiological Parameters for Soil and Groundwater. S.S. Papadopulos & Associates, Inc. Bethesda, Maryland. January.

URS 2015. Baseline Risk Assessment Banister Federal Complex Kansas City, Missouri. Project No. 16530842. Overland Park, Kansas. December.

Yu, C., A. J. Zielen, J. J. Cheng, D. J. LePoire, E. Gnanapragasam, S. Kamboj, J. Arnish, A. Wallo, III, W. A. Williams, and H. Peterson. 2001. User’s Manual for RESRAD Version 6. ANL/EAD-4. Argonne National Laboratory. Environmental Assessment Division. Argonne, Illinois. July.

KCP Summary 5286-LT-01-0

ATTACHMENT 1 AUTHORIZED LIMITS FOR SOIL AT THE BANNISTER FEDERAL COMPLEX AT

THE KANSAS CITY PLANT IN KANSAS CITY, MISSOURI

KCP ALs 5286-TR-01-2

AUTHORIZED LIMITS FOR SOIL AT THE BANNISTER FEDERAL

COMPLEX AT THE KANSAS CITY PLANT IN KANSAS CITY, MISSOURI

Prepared by D. A. King

ORAU

APRIL 2016

FINAL REPORT

Prepared for the U.S. Department of Energy

National Nuclear Security Administration

Prepared by Oak Ridge Associated Universities under the Oak Ridge Institute for Science and Education contract, number DE-SC0014664, with the U.S. Department of Energy.


CONTENTS EXECUTIVE SUMMARY.............................................................................................................................. 1

1. INTRODUCTION ....................................................................................................................................... 1

2. DESCRIPTION OF THE PROPERTY .................................................................................................. 2

2.1 Physical Description ......................................................................................................................... 2

2.2 Current Activities .............................................................................................................................. 4

2.3 Expected End-Use of the Property ................................................................................................ 4

2.4 Expected Radionuclides ................................................................................................................... 7

3. EVALUATED RECEPTOR SCENARIOS ............................................................................................ 8

3.1 Conceptual Site Model ..................................................................................................................... 8

3.2 Primary Sources and Release Mechanism ...................................................................................... 8

3.3 Receptor and Exposure Pathways .................................................................................................. 9

3.3.1 Excavation/Construction Worker ....................................................................................... 10

3.3.2 Indoor Worker ........................................................................................................................ 10

3.3.3 Outdoor Worker ..................................................................................................................... 10

3.3.4 Recreational User .................................................................................................................... 10

4. DERIVATION OF SINGLE RADIONUCLIDE SOIL GUIDELINES ....................................... 10

5. RESULTS AND DISCUSSION .............................................................................................................. 12

6. ALARA ASSESSMENT ............................................................................................................................ 14

6.1 Dose Optimization ......................................................................................................................... 14

6.2. Groundwater .................................................................................................................................... 15

7. IMPLEMENTATION REQUIREMENTS .......................................................................................... 16

8. AUTHORIZED LIMITS .......................................................................................................................... 17

9. REFERENCES ........................................................................................................................................... 18

APPENDIX A. RESRAD INPUTS APPENDIX B. RESRAD OUTPUTS

KCP ALs ES-1 5286-TR-01-2

EXECUTIVE SUMMARY

The U.S. Department of Energy (DOE) is evaluating the potential for transferring the Kansas City

Plant, located on the Bannister Federal Complex (BFC) in Kansas City, Missouri, to a new property

owner. However, elevated concentrations of uranium above expected background concentrations

have been identified in isolated portions of the BFC soils. As specified in Section 4.k(6) of DOE

Order 458.1, authorized limits (ALs) must be established and approved for the clearance of any

property with residual radioactive material to provide reasonable assurance that dose constraints are

as low as reasonably achievable (ALARA).

ALs were derived using the RESRAD computer code, Version 7.0 (Yu, et al. 2001), a conceptual site

model adapted from the site baseline risk assessment (URS 2015) and other site documents, and

considering ranges of possible industrial/recreational receptors that are consistent with site deed and

access restrictions. Because both natural and depleted uranium are known to have been used on the

site, ALs were derived for individual isotopes and for total uranium using natural and depleted

abundances. Calculations demonstrated that an outdoor excavation/construction worker is the most

restrictive receptor producing the following ALs:

• 3,700 pCi/g of U-234

• 150 pCi/g of U-235

• 600 pCi/g U-238

• 910 pCi/g of total uranium (natural)

• 810 pCi/g of total uranium (depleted)

To date, the maximum concentration measured on site is over a magnitude less than the most

restrictive ALs; thus existing concentrations are ALARA. Elevated concentrations of uranium, when

discovered, are isolated to small areas and environmental transport is negligible. Because of the small

extent and magnitude of elevated uranium activity, the public dose is also negligible.

KCP ALs 1 5286-TR-01-2

AUTHORIZED LIMITS FOR SOIL AT THE BANNISTER FEDERAL COMPLEX AT THE KANSAS CITY PLANT IN KANSAS CITY, MISSOURI

1. INTRODUCTION

The U.S. Department of Energy (DOE) is currently evaluating the potential for transferring the

former Kansas City Plant (KCP)—located on the Bannister Federal Complex (BFC), at 2000 East

Bannister Road in Kansas City, Missouri—to a new property owner. However, uranium

concentrations slightly above background have been identified in isolated portions of the BFC soils.

As specified is Section 4.k(6) of DOE Order (O) 458.1, Radiation Protection of the Public and the

Environment (DOE 2013), authorized limits (ALs) must be established and approved for the

clearance of any property with residual radioactive material to provide reasonable assurance that

dose constraint and as low as reasonably achievable (ALARA) requirements are met. ALs may be

preapproved by the Order, be developed for a specific site and clearance pathway, and/or be

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)-process

approved (for real property), provided those remediation criteria meet the requirements of the

Order. Applications for ALs must contain the minimum information specified in Section 4.k(6)(c)

and be submitted to DOE for approval.

As required by O 458.1, and given there are no applicable pre-approved ALs, this technical basis

document (TBD) presents the methods for calculating site-specific ALs for uranium in BFC soils.

The Baseline Risk Assessment Banister Federal Complex Kansas City, Missouri (BRA) (URS 2015) presents a

conceptual site model (CSM) with pathway analyses, exposure pathways, and receptors for exposure

to chemical (i.e., non-radiological) constituents in environmental media. This TBD adopts the BRA’s

CSM with necessary modifications to address radiological constituents using the RESidual

RADioactivity (RESRAD) computer code, Version 7.0 (Yu, et al. 2001). RESRAD is selected

because it meets DOE quality assurance requirements under DOE O 414.1D, Quality Assurance and

is specifically designed for assessing radiological dose from exposure to environmental media.

The overall goal of this analysis is to determine ALs for lands accessible to the public that will

maintain dose at levels that are ALARA and are less than 25 mrem/yr given likely and anticipated

use of the property. The soil and sediment ALs identified in this document were chosen based on

the most limiting soil concentration considering a range of exposure scenarios.

KCP ALs 2 5286-TR-01-2

2. DESCRIPTION OF THE PROPERTY

2.1 PHYSICAL DESCRIPTION

The BFC is a United States Federal Government complex located at 2000 East Bannister Road,

Kansas City, Jackson County, Missouri. The 300-acre complex, which consists of ten main buildings

and numerous small buildings, is bordered on the north by Legacy Park, to the east by the Blue

River and the Blue River Parkway, to the south by Indian Creek and Bannister Road, and to the west

by Troost Ave, as shown in Figure 1 (URS 2015).

Before World War II, the area of the federal complex was mainly farm land. In 1942, the U.S. Navy

built the main manufacturing building at the site to produce aircraft engines. Aircraft engines were

produced by Pratt & Whitney for the U.S. Department of Defense (DoD) between February 1943

and September 1945. Between September 1945 and June 1948, the complex was essentially vacant.

Between 1948 and 1960, Westinghouse occupied a portion of the BFC manufacturing jet aircraft

engines. In 1961, the Westinghouse lease on the BFC was cancelled and that portion of the facility

was transferred to the General Services Administration (GSA) (URS 2015).

During April 1949, the Atomic Energy Commission (AEC) began operations at the BFC

manufacturing non-nuclear components for nuclear weapons. Manufacturing operations continued

at the BFC under the AEC and successor agencies until 2014, when all National Nuclear Security

Administration (NNSA) manufacturing operations were relocated to the National Security Campus

(NSC) in south Kansas City, Missouri (URS 2015).

Beginning in the early 1950s, KCP workers also inspected and assembled natural uranium

components, machined uranium slugs, and handled uranium billets and ingots. Department 49X

(D/49X) was established in 1951 in the far northwest corner of the Main Manufacturing Building

(MMB) to produce 1,000 slugs of natural uranium per day to fuel AEC production reactors. In

conjunction with this operation, uranium components were inspected and assembled in

Department 3A. Department 34C was also used to blend, fabricate, and machine certain radioactive

materials (Auxier 2015).

KCP ALs 3 5286-TR-01-2

Figure 1. The Bannister Federal Complex

KCP ALs 4 5286-TR-01-2

Depleted uranium (DU) components were electrochemically etched in a liquid bath to remove

oxides in Building 96, an outbuilding near the MMB (DCCR 2015). Between 1957 and 1979, KCP

machined and fabricated classified items made of a magnesium thorium alloy. Fabrication and

machining occurred in Department 20 and later in the Model Shop (also known as Department 851,

later renamed Department 823) (ORAU 2014).

Extensive soil sampling has been performed at the site, and Figure 2 presents results of slightly

elevated (relative to background) uranium (in mg/kg units). Radium concentrations slightly above

background have also been identified in these soils.

2.2 CURRENT ACTIVITIES

The property slated for transfer is located to the west of the Union Pacific railroad tracks. The

property is currently owned and operated by GSA and DOE/NNSA. See Figure 3 for ownership

boundaries. GSA currently has a tennent, Marine Corp Data Center, on the eastern side of the

railroad tracks, but has vacated the western portion of the property. Honeywell Federal

Manufacturing & Technologies, LLC, currently manages the site for DOE/NNSA and is

performing two main functions. The first function is site security and long-term stewardship (LTS)

activities. LTS activities include groundwater sampling and groundwater pump and treat. In addition,

activities to address residual fixed radiological contamination from legacy activities have been

conducted as a part of efforts to release the facility under DOE Order 458.1. The second function is

preparing for disposition. Site disposition activities include the removal of real and personal property

in accordance with federal requirements.

2.3 EXPECTED END-USE OF THE PROPERTY

NNSA/Honeywell will occupy the BFC until the property is transferred in 2017. Efforts are

currently underway to mothball the facility and excess surplus equipment. The portion of the site

located east of the rail line will be retained by GSA, while the portion of the site located west of the

rail line will be re-developed. With the exception of a proposed bike (recreational) trail across the

southeast portion of the site, future site use will be restricted to commercial/industrial use;

residential reuse will not be allowed. It is anticipated that buildings currently present in the

redevelopment area will be demolished as part of the redevelopment (URS 2015).

KCP ALs 5 5286-TR-01-2

Figure 2. Soil Sample Distribution and Maximum Detected Uranium Concentrations (S.S. Papadopulos 2016)

KCP ALs 6 5286-TR-01-2

Figure 3. Bannister Federal Complex Ownership

KCP ALs 7 5286-TR-01-2

In addition, exposure controls as outlined in the deed restrictions will be transferred to the new

property owner at the time of property transfer. Residential or other unrestricted use scenarios are

not evaluated, as the site is zoned commercial/industrial, and will remain zoned as such. It should be

noted that the eastern property boundary extends east of the levee to the Blue River, and that deed

and zoning restrictions apply all the way east to the shoreline of the river (URS 2015).

A bike trail is proposed east of the levee on the permitted facility property in the vicinity of the

former landfill, which is a solid waste management unit. The base of the trail has been built from

Indian Creek along the former landfill. At this time, a proposed bridge crossing Indian Creek has

not been placed to allow recreational users to cross Indian Creek, and it is uncertain when the

on-site portion of the trail will be completed.

The NNSA and GSA are currently working with a redevelopment partner to ultimately transfer the

portion of the BFC west of the railroad tracks to the redevelopment company. The conceptual

re-use plan entails demolition of buildings, possible limited removal of contaminated soils,

abandonment of the existing storm sewer network, continued operation of the groundwater pump

and treat system, continued groundwater monitoring, and, where necessary, implementation of

institutional controls (URS 2015).

2.4 EXPECTED RADIONUCLIDES

Figure 2 illustrates the extensive soil sampling effort across the site. Analyses include gamma

spectroscopy, isotopic uranium analysis (via alpha spectroscopy), isotopic thorium analysis (via alpha

spectroscopy), and uranium speciation via inductively coupled plasma mass spectrometry (ICPMS).

Results have identified slightly above background and isolated concentrations of Ra-228 and Ra-226,

and uranium isotopes. Order 458.1 includes pre-approved ALs for radium isotopes of 5 pCi/g

above background; therefore, radium is not considered in this document. However, there are no

pre-approved authorized limits for uranium; thus this TBD derives and presents ALs for uranium

isotopes U-234, U-235, and U-238.

As described above, the process history includes both natural and depleted uranium. Therefore, ALs

are derived for individual isotopes and for total uranium at natural (0.72% weight percent) or

depleted (0.34% weight percent) abundances.

KCP ALs 8 5286-TR-01-2

3. EVALUATED RECEPTOR SCENARIOS

3.1 CONCEPTUAL SITE MODEL

The conceptual site model (CSM) is a fundamental and critical component of AL development. The

CSM describes the source of potential contamination, release mechanisms, exposure pathways, and

potential human receptors. The following discussion describes components of each CSM diagram

that leads from the primary source (origin) to an exposure pathway to a human exposure.

3.2 PRIMARY SOURCES AND RELEASE MECHANISM

As discussed in Section 2, the BFC is a large facility with a long industrial history. Industrial

operations have now ceased, and the majority of the site is now largely unoccupied. The remaining

tenants include site security personnel, office personnel in a few isolated locations, and maintenance

personnel. Buildings associated with previous industrial activities are still present. None of the site is

currently open to the general public, and site access is restricted. While residential areas are located

in the general vicinity of the BFC, no residential properties are likely to be directly impacted by site

contaminants. The closest residential area is located due west of the site, immediately across Troost

Avenue. Residences are also located south of the site, across Indian Creek, east of the site, across the

Blue River, and north of the site. Residences to the north and west are upgradient of site

groundwater or surface water flow. Surface water bodies, Indian Creek and the Blue River, intercept

groundwater and surface water flow to the south and east (URS 2015).

Post-closure plans for the BFC include redevelopment of large portions of the site. Representatives

of the NNSA and GSA are actively engaged with the site redevelopment partner that has been

identified to work towards ultimately redeveloping the BFC for commercial/industrial use. It is

anticipated that the GSA will retain ownership and use of the eastern portion of the property located

between the railroad tracks and the Blue River. This includes the former Internal Revenue Service

(IRS) Building and the DoD Landfill. The majority of the site, located west of the railroad tracks,

will be developed as commercial real estate. It is anticipated that, as part of this development,

current buildings will be demolished, and site contamination will be addressed through a

combination of remedial actions and property use controls to ensure site protectiveness. Site

demolition activities will include the abandonment of the existing storm sewer

KCP ALs 9 5286-TR-01-2

network.Abandonment of the storm sewer network should negate the storm sewer system’s current

role as an off-site migration pathway conduit (URS 2015).

3.3 RECEPTOR AND EXPOSURE PATHWAYS

Current site receptors could include site workers (indoor and outdoor workers), construction

workers, or others who might inadvertently come into contact with contaminated surface or

subsurface soils, groundwater, or soil gas. Future receptors could include any of the current

receptors, as well as any hypothetical receptors associated with changes in land use. Given that

future land use will remain similar to current use, restricted to commercial/industrial use, with the

possible exception of a hypothetical bike trail, the same exposure scenarios were used to evaluate

both current and potential future on-site property use (URS 2015).

Residential land use is not realistic under current or likely future land use conditions, either on site or

in impacted off-site areas. As such, no residential scenarios are evaluated. Site groundwater is not

currently used as a potable water source due to the presence of naturally-occurring arsenic. In

addition, the aquifer yield is generally too low to support such a use. Specifically, the flow rate

(15–45 ft/year) and yield (1–2 gal/min from a fully penetrating well) of the contaminated alluvial

aquifer is very low, precluding beneficial use. In addition, the regional area is supplied by a municipal

water source. As such, it is considered highly unlikely that site groundwater would ever be used as a

potable source in the future (URS 2015).

Therefore, receptors considered in this TBD are as follows:

• An excavation/construction worker

• An indoor worker

• An outdoor worker

• A recreational user

These receptors are described in more detail in the following subsections. Note that complete

exposure pathways for all receptors includes external gamma, fugitive dust inhalation, and incidental

soil ingestion.

KCP ALs 10 5286-TR-01-2

3.3.1 Excavation/Construction Worker

The excavation/construction worker (E/CW) scenario assumes a longer (full work-year) exposure

duration than assumed for the excavation scenario at BFC, based on the likelihood that the site will

undergo extensive excavation/construction activities as part of site redevelopment. Note the BRA

also considers a utility worker, though only the E/CW is considered here. This is because the

scenarios are nearly identical for on-site exposures.

3.3.2 Indoor Worker

The indoor worker (IW) scenario considers full-time indoor workers at either current or

hypothetical future buildings.

3.3.3 Outdoor Worker

The outdoor worker (OW) scenario is similar to the indoor worker but is assumed to spend most of

a work-year outdoors on site.

3.3.4 Recreational User

The possibility exists for a recreational user (RU) to use bike trails or to trespass on site. Though the

BRA considers adult and child receptors, only a child receptor is considered here because 1) the fish

and incidental surface water ingestion (an issue for chemical contaminants of concern [COCs]) are

not relevant for on-site exposures, and 2) the child receptor has a larger incidental soil ingestion rate

than the adult (URS 2015). That is, the child is the more conservative receptor.

4. DERIVATION OF SINGLE RADIONUCLIDE SOIL GUIDELINES

Appendix A presents exposure parameters used as RESRAD input, consistent to the extent possible

with the BRA Tables 3-3 and 3-4 for the receptors described in Section 3. Note the BRA addresses

chemicals only, which are often associated with a dermal exposure pathway and are not associated

with an external gamma radiation exposure pathway. To address these differences, the dermal

pathway is excluded (there are not dermal pathway dose factors), and the external gamma pathway is

added using standard default inputs as defined by the U.S. Environmental Protection Agency’s

(EPA’s) Exposure Factors Handbook (EPA 2011a). Other inputs not explicitly provided in the BRA are

KCP ALs 11 5286-TR-01-2

taken from the Exposure Factors Handbook of the supplement to RESRAD, the Data Collection

Handbook (Yu et al. 2015); otherwise the RESRAD default values are used.

RESRAD often requires inputs in per year rates (e.g., mg/yr or L/yr), though the BRA and other

literature sources are listed as per day or per hour rates. Because of the averaging method used by

RESRAD, the per year values in Appendix A are converted assuming there are 365 days per

standard year and 24 hours per standard day.

RESRAD considers potential exposures over a 1,000-year evaluation period. Therefore, it is possible

for one radionuclide to produce a maximum dose at (for example) year 0 and another radionuclide

to produce a maximum dose at year 1,000. It is impossible for a human receptor to receive both

maximum exposures, and the COCs in this case are considered together as either natural or depleted

uranium. Therefore, ALs are derived assuming the maximum year of exposure to all COCs

combined.

All COC concentrations are modeled at unit concentrations (i.e., 1 pCi/g) so the results can be

interpreted as dose-to-source ratios (DSRs) in unit mrem/year per pCi/g. If, for example, the dose

limit is 25 mrem/yr and a DSR is 10 mrem/yr per pCi/g, then the associated AL is calculated as

follows:

AL (pCi/g) = 𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷 𝐿𝐿𝐿𝐿𝐿𝐿𝐿𝐿𝐿𝐿 (𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚/𝑦𝑦𝑦𝑦)𝐷𝐷𝐷𝐷𝐷𝐷 (𝐿𝐿𝑦𝑦𝐷𝐷𝐿𝐿/𝑦𝑦𝑦𝑦/𝑝𝑝𝑝𝑝𝐿𝐿/𝑔𝑔)

= 25/10 = 2.5 pCi/g

Though unit concentrations are entered, output for natural or depleted uranium is most applicable

for assessing site conditions. Table 4.1 presents the activity fractions dependent upon isotopic

abundance. When the ALs are determined for each isotope, the total uranium AL is estimated using

the following sum of the reciprocals equation:

AL for total uranium (pCi/g) = 1

∑�𝐴𝐴𝐴𝐴234𝐴𝐴𝐴𝐴234 + 𝐴𝐴𝐴𝐴235𝐴𝐴𝐴𝐴235

+ 𝐴𝐴𝐴𝐴238𝐴𝐴𝐴𝐴238�

Where, for example, AF234 of the activity fraction for U-234 (unit-less) and AL234 is the AL for

U-234 (pCi/g).

KCP ALs 12 5286-TR-01-2

Table 4.1. Uranium Activity Fraction by Enrichment Uranium SA Mass Activity Activity Isotope (Ci/g) Fraction (Ci) Fraction U-234 6.19E-03 Negligible 1.90E-07 0.3596 U-235 2.14E-06 0.0034 7.28E-09 0.0137 U-238 3.33E-07 0.9966 3.32E-07 0.6266

U (Depleted) 5.30E-07 U-234 6.19E-03 Negligible 3.29E-07 0.4877 U-235 2.14E-06 0.0072 1.54E-08 0.0228 U-238 3.33E-07 0.9928 3.31E-07 0.4895

U (Natural) 6.75E-07 SA = specific activities from Decommissioning Health Physics - A Handbook for MARSSIM Users (Abelquist 2014). From Health Physics Manual of Good Practices for Uranium Facilities (INEL 1988) assuming the mass fraction for U-234 is

about 0 and assuming 1 gram of pure uranium: CiU = MassU*(0.4+0.38*[Mass Fract235*100]+0.0034*[Mass Fract235*100]2)*0.000001 Ci235 = SA235 x Mass Frac235 Ci238 = SA238 x Mass Frac238 Ci234 = CiU - Ci235 - Ci228

5. RESULTS AND DISCUSSION

Table 5.1 summarizes ALs by receptor (all pathways combined), with each value associated with a

dose limit of 25 mrem/yr. Appendix B presents output files from RESRAD “Summary Reports.”

All AL values are rounded to two significant digits. Table 5.1 results show the most restrictive ALs

are associated with the E/CW, who spends the work-year outdoors actively participating in

construction-related activities. Table 5.2 presents the pathway-specific dose contributions (per unit

concentration), the combined (summed) DSRs, and isotope-specific ALs. The external gamma is the

primary exposure pathway for all receptors although all isotopes are alpha emitters.

Table 5.1. Summary of Authorized Limit Results (pCi/g)

COC E/CW IW OW RU U-234 3,700 20,000 9,900 51,000 U-235 150 220 170 1,500 U-238 600 970 730 6,100 U (Natural) 910 1,600 1,200 9,500 U (Depleted) 810 1,400 1,000 8,400

All ALs are rounded to two significant digits. All ALs shown are for exposure year 0.0. E/CW = excavation/construction worker IW = indoor worker

KCP ALs 13 5286-TR-01-2

OW = outdoor worker RU = recreational user

Table 5.2. Pathway-specific Dose-to-Source Ratios and Authorized Limit Results

Ext. Gamma Inhalation Soil Ing. DSR AL Receptor COC mrem/yr mrem/yr mrem/yr mrem-g/pCi-yr pCi/g E/CW U-234 7.93E-05 1.54E-03 5.05E-03 6.67E-03 3,700

U-235 1.61E-01 1.39E-03 4.81E-03 1.67E-01 150

U-238 3.52E-02 1.32E-03 4.90E-03 4.14E-02 600

IW U-234 5.55E-05 4.55E-04 7.68E-04 1.28E-03 20,000

U-235 1.13E-01 4.10E-04 7.31E-04 1.14E-01 220

U-238 2.46E-02 3.89E-04 7.45E-04 2.58E-02 970

OW U-234 7.24E-05 1.04E-03 1.40E-03 2.51E-03 9,900

U-235 1.47E-01 9.35E-04 1.34E-03 1.49E-01 170

U-238 3.21E-02 8.88E-04 1.36E-03 3.44E-02 730 RU U-234 8.28E-06 1.61E-04 3.21E-04 4.90E-04 51,000

U-235 1.68E-02 1.45E-04 3.05E-04 1.72E-02 1,500

U-238 3.67E-03 1.38E-04 3.11E-04 4.12E-03 6,100 AL = authorized limits; all values rounded to two significant digits; 25 mrem/yr/DSR DSR = dose-to-source ratio; all COCs input at 1 pCi/g; sum of pathway-specific doses COC = contaminant of concern All values for year = 0

KCP ALs 14 5286-TR-01-2

6. ALARA ASSESSMENT

For the release of real property with residual radioactive contamination, the ALs must be:

1. Selected and approved by DOE on the basis of an assessment under the ALARA process.

The process will optimize the balance between risks and benefits, including costs and

collective doses. The process will also ensure that individual doses for plausible exposures to

the public are less than the 25 mrem/yr constraint with a goal of a few mrem/yr over the

next 1,000 years and unlikely exposures to the public over the 100 mrem/yr dose limit

during the next 1,000 years.

2. Evaluated to ensure that groundwater will be protected in a manner consistent with the

objectives of the site’s Groundwater Protection Program objectives and applicable federal

and state requirements.

6.1 DOSE OPTIMIZATION

Site stakeholders have determined that the site will remain industrial for the foreseeable future

(URS 2015); thus the evaluation of a residential receptor (and subsequent comparison to the

100 mrem/yr limit) is not required for the BFC. Therefore, only the industrial or recreational

scenarios are considered for comparison to the 25 mrem/yr limit. Doses tabulated in Section 6

reach maximums at year 0.0, though RESRAD was allowed to consider exposures over a 1,000-year

period. Therefore, the AL for the E/CW receptor, at year 0, considering a 25 mrem/yr dose

endpoint is the starting point for this ALARA analysis.

To date, the maximum soil concentration measured at the site is 73 mg/kg—this is a total uranium

result. The conversion from mg/kg to pCi/g depends on whether the uranium is natural or

depleted. According to the Good Practices Manual for Uranium Facilities (INL 1988), the conversion

factor is 0.7 (pCi/g per mg/kg) for natural uranium or 0.4 for depleted uranium. Therefore, the

maximum measured concentration of 73 mg/kg converts to about 50 pCi/g if natural uranium or

about 30 pCi/g if depleted. Either value is more than an order of magnitude less than the more

restrictive AL of 810 pCi/g. Because the AL is protective by definition, remediation of materials

over an order of magnitude below the AL is unnecessary. The forward calculation is also relevant for

ALARA consideration. Authorized limits are linearly scalable; thus, the maximum concentration of

73 mg/kg equates to about 1.4 mrem/yr if natural uranium or 0.9 mrem/yr if depleted uranium.

KCP ALs 15 5286-TR-01-2

Uranium concentrations in soil are isolated and spatially separated, reasonably precluding exposures

to one individual from multiple sources. There is no evidence of off-site migration via airborne or

waterborne pathways, or from the intentional or environmental transport of bulk contaminated

materials (Papadopulos 2016). Additionally, the expected land use will be light industrial with a

limited number of individuals’ exposures to relatively low and isolated concentrations of uranium.

It is, therefore, concluded that population doses are negligible.

6.2. GROUNDWATER

Numerous reports (e.g., DOE-BFEC 1985, 1986, DOE-ORNL 2000, and DOE 2010) have

demonstrated that the KCP subsurface is dominated by a silty-clay matrix. For example, most

measurements have indicated that the hydraulic conductivity is typically in the range of 10-6 or

10-7 m/s. Clay soils have a very high capacity for limiting metal mobility both because of the slow

transmission of water but more so because of the many sorption sites where metals can be

immobilized by precipitation/sorption. In addition, decades of groundwater sampling have

demonstrated the groundwater has a near-neutral pH with reducing conditions (low dissolved

oxygen). The latter statement is supported not just by direct measurements of dissolved oxygen but

by examining what constituents are found in the water. Many wells contain tens of mg-per-liter of

dissolved iron and manganese. Both metals will only dissolve under anoxic conditions, or conditions

described as anaerobic and mildly reducing (Hounslow 1995, p172). Indeed, their dissolution has

been shown to be linked to the naturally-occurring reduced arsenic also found at the site

(Korte 1991, Korte and Fernando 1991). Specifically, neutral pH and reducing conditions, as at the

KCP, cause most metals to be non-mobile both by triggering them to precipitate directly and by

providing precipitated iron and manganese oxides which are powerful sorbents (Jenne 1968). It is

noted that, in the appropriate oxidation state, the metals or metalloids arsenic, selenium, chromium,

vanadium, and uranium can be mobile at neutral pH; but except for reduced arsenic, they are not

mobile under reducing conditions.

The Due Diligence Investigation Summary Report (Papadopulos 2016) presents groundwater data and

compares results to EPA’s maximum contamination levels (MCLs). This was performed even

though 1) groundwater is non-potable due to the presence of a high concentration of

non-radiological constituents, 2) yields are too low for production, and 3) municipal water supplies

are readily available. While some gross alpha measurements are above the 5 pCi/L limit, no gross

KCP ALs 16 5286-TR-01-2

beta measurement exceeds the limit and uranium results are below the MCL. The weight of evidence

suggests that alpha activity is due to natural constituents (many naturally-occurring radionuclides

emit alpha radiation) and is not due to site-related uranium. Given the isolation of slightly elevated

uranium in site soils, the absence of potable groundwater, and the low levels of measured

radioactivity, groundwater concentrations of uranium are concluded to be ALARA.

7. IMPLEMENTATION REQUIREMENTS

Order 458.1 requires a description of the procedures and radiological monitoring or surveys to be

used to demonstrate compliance with proposed ALs. S.S. Papadopulos, the contractor to the

prospective property owner CenterPoint Properties (CCP), executed a characterization effort that

included a systematic triangular grid with provisions for judgmental sampling. DOE/NNSA also

employed the Oak Ridge Institute for Science and Education (ORISE), managed by ORAU for

DOE, as the independent verification contractor (IVC), as required by O 458.1. Figure 2 presents

the resulting sample locations and noteworthy soil concentrations from the CCP investigation.

ORISE reviewed the analytical data and received split samples collected to confirm the presence of

uranium near those locations with maximum uranium concentrations (most noteworthy,

CP-5004-A). The split samples were collected at multiple depth intervals to a maximum depth of

20 feet. Relatively low levels of depleted uranium were measured, and the highest total uranium

result was less than 15 pCi/g: 3.64 pCi/g U-234, 0.237 pCi/g U-235, and. 10.8 pCi/g U-238. The

73 mg/kg (~30 pCi/g) maximum result could not be reproduced during confirmation sampling.

The characterization approach is consistent with those described in the Multi-Agency Radiation Survey

and Site Manual (MARSSIM) (DOE 2000) for an industrial use facility. The characterization produces

a large sample population with maximum concentrations well below the ALs presented in this plan.

It is concluded, therefore, that procedures and radiological monitoring described in

S.S. Papadopulos 2016 and as reported by ORISE (report pending) are adequate for demonstrating

compliance with O 458.1 (AL) requirements.

KCP ALs 17 5286-TR-01-2

8. AUTHORIZED LIMITS

DOE is evaluating the potential for transferring portions of the KCP located on the BFC in Kansas

City, Missouri, to a new property owner. However, slightly elevated concentrations of uranium (see

Figure 2) have been identified in isolated portions of the BFC soils. As specified is Section 4.k(6) of

O 458.1, ALs must be established and approved for the clearance of any property with residual

radioactive material to provide reasonable assurance that dose constraint and ALARA requirements

are met.

This TBD presents the methods for calculating site-specific ALs for uranium in BFC soils using

inputs from the site’s BRA (URS 2015), the prospective property owner’s characterization report,

and other supporting documentation. ALs were derived using the RESRAD computer code,

Version 7.0 (Yu, et al. 2001), for a range of possible industrial/recreational receptors. Because both

natural and depleted uranium are known to exist in portions of the site, ALs were derived for

individual isotopes and for total uranium using natural and depleted abundances. Calculations

demonstrated that an outdoor excavation/construction worker is the most restrictive receptor

producing the following ALs:

• 3,700 pCi/g of U-234

• 150 pCi/g of U-235

• 600 pCi/g U-238

• 910 pCi/g of total uranium (natural)

• 810 pCi/g of total uranium (depleted)

The maximum concentration measured on site is over a magnitude less than the most restrictive

ALs, and existing concentrations are ALARA. Elevated concentrations of uranium, when

discovered, are isolated to small areas and environmental transport is negligible. Because of the small

extent and magnitude of elevated uranium activity, the public dose is also negligible.

KCP ALs 18 5286-TR-01-2

9. REFERENCES

Abelquist, Eric W. 2014. Decommissioning Health Physics – A Handbook for MARSSIM Users. Second Edition. Taylor and Francis. Boca Raton, Florida.

Auxier 2015. Survey Plan for Select Areas within the Bannister Federal Complex. Auxier & Associates. Prepared for CenterPoint Properties Trust. Kansas City, Missouri. September.

DOE 2000. Multi-Agency Radiation Survey and Site Manual (MARSSIM). U.S. Department of Energy. Washington, DC. August.

DOE 2010. Annual Groundwater Monitoring Report for Calendar Year 2009. U.S. Department of Energy. Kansas City Office. Kansas City, Missouri.

DOE 2013. Order 458.1, Radiation Protection of the Public and the Environment. Change 3. U.S. Department of Energy. Washington, DC. January.

DOE 2015. “Description of Current Conditions Report for the Bannister Federal Complex (Draft).” Section 7: Depleted Uranium and Beryllium, Revised. U.S. Department of Energy and General Services Administration.

DOE-BFEC 1985. Hydrogeologic Site Characterization of the Department of Energy Kansas City Facility. Interim Report. prepared by N. Korte, P. Kearl, H.L. Fleischhauer, and J. M. Sewell. Bendix Field Engineering Corporation. Grand Junction, Colorado. April.

DOE-BFEC 1986. Hydrogeologic Site Characterization of the Department of Energy Kansas City Facility. Second Interim Report. prepared by H. L. Fleischhauer, N. Korte, S. Sturm, S. Wagner, and J. M. Sewell. Bendix Field Engineering Corporation. Grand Junction, Colorado. January.

DOE-ORNL 2000. Lower Northeast Area Characterization and Iron Wall Evaluation Report. Prepared by Oak Ridge National Laboratory, Grand Junction Office. Grand Junction, Colorado. June.

Hounslow, A. 1995. Water Quality Data: Analysis and Interpretation. CRC Press. Boca Raton, Florida.

INEL 1988. Health Physics Manual of Good Practices for Uranium Facilities. EEG-2530. Idaho National Laboratory. Idaho Falls, Idaho. June.

Jenne, E.A. 1968. “Controls on Mn, Fe, Co, Ni, Cu, and Zn Concentrations in Soils and Water: the Significant Role of Hydrous Mn and Fe Oxides, IN: Trace Inorganics in Water.” Chapter 21, pp. 337–387. Advances in Chemistry. Vol. 73. American Chemical Society. Washington, D.C.

Korte, N. 1991. “Naturally occurring arsenic in groundwater of the Midwestern United States.” Environmental Geology and Water Sciences. 18:137-141.

Korte, N., and Q. Fernando 1991. “A review of arsenic-III in groundwater.” Critical Reviews in Environmental Control. 21(1):1-67.

KCP ALs 19 5286-TR-01-2

ORAU 2014. SEC Petition Evaluation Report. Prepared by Pat McCloskey. Oak Ridge Associated Universities. January 7.

Papadopulos, S.S. 2016. Due Diligence Site Investigation Summary Report, Volume 1 – Report. Draft. S.S. Papadopulos & Associates, Inc. Bethesda, Maryland. February.

URS 2015. Baseline Risk Assessment Banister Federal Complex Kansas City, Missouri. Project No. 16530842. Overland Park, Kansas. December.

Yu, C. Loureiro, A. J. Zielen, J. J. Cheng, D. J. LePoire, E. Gnanapragasam, S. Kamboj, J. Arnish, A. Wallo, III, W. A. Williams, and H. Peterson 2001. User’s Manual for RESRAD Version 6. ANL/EAD-4. Argonne National Laboratory. Environmental Assessment Division. Argonne, IL. July.

Yu, C., S. Kamboj, C. Wang and J.J. Cheng 2015. Data Collection Handbook to Support Modeling Impacts of Radioactive Material in Soil and Building Structure, ANL/EVS/TM-14/4, Argonne National Laboratory. Environmental Science Division. Argonne, IL. September.


APPENDIX A RESRAD INPUTS

RESRAD Table of Input Parameters for the Bannister Federal Complex Input Parameter Units Default Receptor Input Justification and References

COC concentration pCi/g 100 All 1 Unit concentrations input used for each COC: U-234, U-235, and U-238

Distribution coefficients cm3/g Nuclide-specific All 1,600

URS 2015 indicates the site is underlain by silty clay soils. Yu et al. 1993 provides values for sand, loam, clay, and organic soil types, but not silty clay. Because groundwater is a medium of interest, it is more conservative to assume COC do not readily leach from surface soils. Therefore, the distribution coefficient for clay is selected.

Area of CZ m2 10,000 All 10,000 The default value is used to derive base AL, though a range of areas may be considered, if necessary, to more accurately assess small areas of elevated activity.

Thickness of CZ m 2 All 2 The default is conservatively assumed given some elevated activity was measured in subsurface soils.

Cover depth m 0 All 0 No cover is conservatively assumed.

Inhalation rate m3/yr 8,400

IW OW

8,400 Assumes the RESRAD default, which is more conservative than the average inhalation rate of 15.2 m3/day recommended by EPA for long-term exposures (EPA 1997).

E/CW UW RU

11,400 Assumes an elevated hourly average worker inhalation rate of 1.3 m3/hour for short period of activity.

Mass loading for inhalation g/m3 1.00E-04 All 2.00E-04 Default assumed to account for short periods of high mass loading (Yu et al. 1993).

Indoor time fraction — 0.5 IW 0.23 Assumes 250 work days (URS 2015), 8 hours/day indoors; rounded to two digits.

All others 0.0 All other receptors are assumed to spend time outdoors while exposure to potential site contaminants.

Outdoor time fraction — 0.25

IW 0.0 The industrial worker is assumed to spend all time on-site indoors.

E/CW 0.23 Conservatively assumes 250 work days (URS 2015), 8 hours/day all outdoors; rounded to two digits.

OW 0.21 Conservatively assumes 225 work days (URS 2015), 8 hours/day all outdoors; rounded to two digits.

UW 0.027 Assumes 30 days per year (URS 2015), 8 hours per day while exposure to potential site contaminants (URS 2015); rounded to two digits.

RU 0.024 Assumes 52 days per year (URS 2015), 4 hours per day while exposure to potential site contaminants (URS 2015); rounded to two digits.

KCP ALs A-1 5286-TR-01-2

RESRAD Table of Input Parameters for the Bannister Federal Complex Input Parameter Units Default Receptor Input Justification and References

Soil ingestion rate g/yr 36.5

E/CW UW

120 Assumes 330 mg/day for 365 days/year (URS 2015)

OW 36.5 Assumes 100 mg/day for 365 days/year (URS 2015)

IW 18.25 Assumes 50 mg/day for 365 days/year (URS 2015)

RU 73 Assumes 200 mg/day (child) for 365 days/year (URS 2015)

COC = contaminant of concern CZ = contaminated zone (the source) E/CW = excavation/construction worker IW= indoor worker OW = outdoor worker RU = recreational user UW = utility worker

KCP ALs A-2 5286-TR-01-2


APPENDIX B RESRAD OUTPUTS


EXCAVATION/CONSTRUCTION WORKER


INDOOR WORKER


OUTDOOR WORKER


RECREATIONAL USER


ATTACHMENT 2 REPORT FOR DECEMBER 2015 INDEPENDENT VERIFICATION ACTIVITIES AT

THE BANNISTER FEDERAL COMPLEX AT THE KANSAS CITY PLANT IN KANSAS CITY, MISSOURI

KCP Report 5056-SR-01-1

REPORT FOR DECEMBER 2015 INDEPENDENT VERIFICATION ACTIVITIES AT THE BANNISTER FEDERAL COMPLEX AT THE

KANSAS CITY PLANT IN KANSAS CITY, MISSOURI


ORAU

FEBRUARY 2016

REVISED FINAL REPORT



Prepared by Oak Ridge Associated Universities under the Oak Ridge Institute for Science and Education contract, number DE-AC05-06OR23100, with the U.S. Department of Energy.

KCP Report 1 5056-SR-01-1

REPORT FOR DECEMBER 2015 INDEPENDENT VERIFICATION ACTIVITIES AT THE BANNISTER FEDERAL COMPLEX AT THE


1. INTRODUCTION

The Kansas City Plant (KCP) is a National Nuclear Security Administration (NNSA) facility

managed and operated by Honeywell Federal Manufacturing & Technologies (HFMT). Property

within the Bannister Federal Complex (BFC) of the KCP, including the Main Manufacturing

Building (MMB) and Building 96, have been identified for radiological clearance and independent

verification (IV) as required as part of the clearance process, per U.S. Department of Energy (DOE)

Order (O) 458.1 (DOE 2013). The DOE Kansas City Field Office requested that Oak Ridge

Institute for Science and Education (ORISE), managed by ORAU for DOE, serve as the IV

contractor (IVC) for the BFC clearance action.

On-site IV activities were performed from December 9 to 11, 2015, with the main survey effort on

December 10. The objective was to ensure that DOE O 458.1 clearance surface activity

requirements have been satisfied. This report documents the magnitude and location of elevated

activity discovered primarily on concrete floor surfaces in the 49X and Department 20 areas. Surveys

of 49X, Department 20, and Department 34C (see Figure 1.1) areas were performed while on site.

These areas were selected because they represent the highest potential for exceeding authorized

limits (ALs).


Figure 1.1. Location of Radiologically Impacted Areas within the BFC


2. METHODS

ORISE personnel initiated surveys by scanning general areas using a Ludlum Model 44-10 2-inch by

2-inch (2×2) sodium iodide detector. The objective of this scan was to identify elevated gamma

radiation levels that could be due to residual contamination. One IV surveyor followed with a

thorough (~100%) survey of the scabbled and adjacent floors using a Ludlum Model 43-37 gas

proportional floor monitor. The objective was to locate elevated alpha-plus-beta radiation on the

target surface—these data were qualitative and were not used to compare in situ activity to ALs. If

and when elevated radiation levels were detected, a second IV surveyor used a Ludlum Model 43-68

hand-held gas proportional detector to collect alpha-plus-beta fixed-point measurements and

scanned the adjacent area, thus delineating the contamination. The 43-68 was also used to scan

lower walls. The 43-68 data were quantitative and were used to compare in situ activity to ALs.

Finally, smear samples were collected from some small areas of elevated activity (i.e., “hot spots”) to

quantify the removable fraction. All results were compared to the following ALs, applicable to

natural or depleted uranium.

Radionuclides Units Average (Total) Maximum Removable Uranium dpm/100 cm2 5,000 15,000 1,000

The average AL is assessed over an area of 1 m2, and maximum and removable ALs are assessed

over an area of 100 cm2.

Gross detector responses in counts per minute (cpm) were converted to net disintegrations per

minute per hundred square centimeters (dpm/100 cm2 ) values using the 43-68 efficiencies

calculated using weighted efficiencies specific to natural uranium (in 49X) or depleted uranium (in

Department 20), as applicable.

3. RESULTS

Figure 3.1 presents 49X area locations with a gross activity above 1,000 cpm, noting that site-specific

background for the 43-68 is about 450 cpm. The cpm values associated with each location are

presented in Table 3.1, and Attachment 1 presents cpm and dpm/100 cm2 results for all

measurement locations. Several small hot spots were identified on the floors and lower walls, with a

maximum of 11,126 cpm (~25,000 dpm/100 cm2). It is noted that all identified hot spots are small


and do not result in average activity above the 5,000 dpm/100 cm2 AL (i.e., over 1 m2). However,

Location 9, pictured in Figure 3.3, is estimated to exceed the maximum AL of 15,000 dpm/100 cm2.

Figure 3.2 presents Department 20 locations with a gross activity above 1,000 cpm. The cpm values

associated with each location are presented in Table 3.1, and Attachment 1 presents cpm and

dpm/100 cm2 results for all measurement locations. As with the 49X area, several small hot spots

were identified on the floors, with a maximum of 5,512 cpm (~10,000 dpm/100 cm2). It is estimated

that none of the identified hot spots result in average activities above the 5,000 dpm/100 cm2 AL

(i.e., over 1 m2), and no value exceeds the maximum AL of 15,000 dpm/100 cm2. However, two line

sources (Locations 17 and 18, see Figure 3.3) warrant consideration.


Figure 3.1. Location and Magnitude of Elevated Gross Alpha-plus-Beta Activity in the 49X Area


Figure 3.2. Location and Magnitude of Elevated Gross Alpha-plus-Beta Activity in Department 20


49X Location 9 with a gross result of 11,126 cpm and a converted result of ~25,000 dpm/100 cm2

Department 20 Line Source 17 with a maximum gross activity of 1,920 cpm and a net converted result of ~3,000 dpm/100 cm2

Department 20 Line Source 18 with a maximum gross activity of 2,074 cpm and a net converted result of ~3,300 dpm/100 cm2

Figure 3.3. Photos of Select Small Areas of Elevated Activity


Table 3.1. Measurement Location Matrix for Figures 3.1 and 3.2 Measurement Location No. Activity (cpm)a

49X (Figure 3.1) 1 1,115 2 5,000 3 1,544 4 1,442 5 3,108 6 1,792 7 4,603 8 3,631 9 11,126 10 4,197 11 5,206

Department 20 (Figure 3.2) 12 1,110 13 1,193 14 3,099 15 2,346 16 1,238 17 1,504–1,920 18 1,535–2,074 19 1,569 20 1,234 21 2,372 22 1,806 23 3,560 24 5,512 25 4,777 26 1,681 27 4,359

aThe background 43-68 activity is ~450 cpm.

4. CONCLUSIONS

ORISE performed on-site IV surveys in the 49X, Department 34C, and Department 20 areas in

December of 2015. Multiple hot spots were identified but only one exceeds an AL. This location on

the 49X area floor, with a result of ~25,000 dpm/100 cm2, exceeds the maximum AL of 15,000

dpm/100 cm2. Several locations exceed 5,000 dpm/100 cm2, but likely do not cause the 1 m2 area to

exceed the 5,000 dpm/100 cm2 avearge limit.


5. REFERENCES

DOE 2013. Order 458.1, Radiation Protection of the Public and the Environment. U.S. Department of Energy. Washington, DC. January.


ATTACHMENT 1

KCP Meas. Gross Bkg Totals Result Smear

Area Loc. No. (cpm)* (cpm) (dpm/100 cm2) No. Alpha Beta Medium/location description49X 2 5,000 474 10,684 38 20.23 11.32 Scabbled concrete

500 474 61 Scabbled concrete3 1,544 474 2,526 Scabbled concrete7 4,603 474 9,747 39 20.23 19.9 Scabbled concrete

470 474 -9 Scabbled concrete11 5,206 474 11,170 36 1.92 0.29 Scabbled concrete

504 474 71 Scabbled concrete962 474 1,152 Scabbled concrete497 474 54 Scabbled concrete

10 4,197 474 8,788 Scabbled concrete473 474 -2 Scabbled concrete601 474 300 Scabbled concrete482 474 19 Scabbled concrete

9 11,126 474 25,144 37 -0.37 2.75 Scabbled concrete492 474 42 Scabbled concrete430 474 -104 Scabbled concrete750 474 652 Scabbled concrete473 474 -2 Scabbled concrete

8 3,631 474 7,452 Scabbled concrete430 474 -104 Scabbled concrete

5 3,108 474 6,218 Scabbled concrete451 474 -54 Scabbled concrete

6 1,792 474 3,111 Scabbled concrete501 474 64 Scabbled concrete647 474 408 Scabbled concrete484 474 24 Scabbled concrete442 474 -76 Scabbled concrete

4 1,442 474 2,285 40 -0.37 1.52 Painted cinderblock wall1 1,115 474 1,513 Painted cinderblock wall

429 474 -106 Painted cinderblock wall481 474 17 Painted cinderblock wall470 474 -9 Painted cinderblock wall

1,010 474 1,265 Scabbled cinderblock wall1,080 474 1,430 Scabbled cinderblock wall403 474 -168 Painted cinderblock wall550 474 179 Painted cinderblock wall592 474 279 Painted cinderblock wall422 474 -123 Painted cinderblock wall485 474 26 Painted cinderblock wall458 474 -38 Painted cinderblock wall451 474 -54 Painted cinderblock wall

Dept. 34C 280 410 -307 Scabbled concrete400 410 -24 Scabbled concrete

Attachment 1. Preliminary Measurement Results for the December 2015 KCP IV EffortRemovable (dpm/100 cm2)

Page 1 of 2

KCP Meas. Gross Bkg Totals Result Smear

Area Loc. No. (cpm)* (cpm) (dpm/100 cm2) No. Alpha Beta Medium/location description

Removable (dpm/100 cm2)

Dept. 20 409 417 -16 Painted concrete; line near pipes18 1,535 417 2,242 Painted concrete; line near pipes

1,770 417 2,713 Painted concrete; line near pipes2,042 417 3,258 Painted concrete; line near pipes

18 2,074 417 3,322 Painted concrete; line near pipes493 417 152 Painted concrete; line near pipes

15 2,346 422 3,858 Scabbled concrete442 422 40 Scabbled concrete

14 3,099 422 5,367 45 -0.37 2.75 Scabbled concrete16 1,238 422 1,636 Scabbled concrete

353 422 -138 Scabbled concrete356 422 -132 Scabbled concrete


12 1,110 422 1,379 Scabbled concrete21 2,372 422 3,910 Scabbled concrete

485 422 126 Scabbled concrete22 1,806 422 2,775 Scabbled concrete

629 422 415 Scabbled concrete27 4,359 422 7,894 44 1.92 5.2 Scabbled concrete

390 422 -64 Scabbled concrete26 1,681 422 2,524 Scabbled concrete

586 422 329 Scabbled concrete410 422 -24 Scabbled concrete


19 1,569 422 2,300 Painted concrete353 417 -128 Painted concrete417 417 0 Painted concrete386 417 -62 Painted concrete

23 3,560 417 6,302 41 1.92 5.2 Painted concrete387 417 -60 Painted concrete

24 5,512 422 10,205 42 -0.37 -0.93 Scabbled concrete372 422 -100 Scabbled concrete408 422 -28 Scabbled concrete

25 4,777 422 8,732 43 -0.37 1.52 Scabbled concrete366 422 -112 Scabbled concrete399 422 -46 Scabbled concrete423 422 2 Scabbled concrete412 422 -20 Scabbled concrete420 422 -4 Scabbled concrete512 417 190 Painted concrete; line along joist

17 1,504 417 2,179 Painted concrete; line along joist1,579 417 2,330 Painted concrete; line along joist900 417 968 Painted concrete; line along joist

1,918 417 3,009 Painted concrete; line along joist17 1,920 417 3,013 Painted concrete; line along joist

841 417 850 Painted concrete; line along joist728 417 624 Painted concrete; line along joist377 417 -80 Painted concrete; adjacent to joist

*43-68 in alpha plus beta mode, 0.4 mg/cm2 MylarBoxes indicate measurements from the same immediate area or line of measurements.Bold red indicates a value above the maximum authorized limit of 15,000 cpm.

Ceated by: Approved by:

Page 2 of 2

King, DavidDigitally signed by King, David DN: dc=net, dc=orau, ou=Standard Accounts, ou=UserAccts, cn=King, David, [email protected] Date: 2016.01.12 10:00:40 -05'00'

Smillie, FleurDigitally signed by Smillie, Fleur DN: dc=net, dc=orau, ou=Standard Accounts, ou=UserAccts, cn=Smillie, Fleur, [email protected] Date: 2016.01.12 10:06:22 -05'00'


ATTACHMENT 3 REPORT FOR FEBRUARY 2016 INDEPENDENT VERIFICATION ACTIVITIES AT

THE BANNISTER FEDERAL COMPLEX AT THE KANSAS CITY PLANT IN KANSAS CITY, MISSOURI


REPORT FOR FEBRUARY 2016 INDEPENDENT VERIFICATION ACTIVITIES AT THE BANNISTER FEDERAL COMPLEX AT THE



ORAU

APRIL 2016

FINAL REPORT



Prepared by Oak Ridge Associated Universities under the Oak Ridge Institute for Science and Education contract, number DE-AC05-06OR23100, with the U.S. Department of Energy.


REPORT FOR FEBRUARY 2016 INDEPENDENT VERIFICATION ACTIVITIES AT THE BANNISTER FEDERAL COMPLEX AT THE KANSAS CITY PLANT IN

KANSAS CITY, MISSOURI

1. INTRODUCTION

The Kansas City Plant (KCP) is a National Nuclear Security Administration (NNSA) facility

managed and operated by Honeywell Federal Manufacturing & Technologies (FM&T). Property

within the Bannister Federal Complex (BFC) of the KCP, specifically the Main Manufacturing

Building (MMB) and Building 96, have been identified for radiological clearance and independent

verification (IV) as required as part of the clearance process, per U.S. Department of Energy (DOE)

Order (O) 458.1 (DOE 2013). The DOE Kansas City Field Office requested that Oak Ridge

Institute for Science and Education (ORISE), managed by ORAU for DOE, serve as the IV

contractor (IVC) for the BFC clearance action. ORISE investigated 49X and Department 20 areas

of the MMB that represent the highest probability of exceeding pre-approved authorized limits

(ALs) to conservatively represent radiological conditions across the BFC.

On-site IV activities were performed February 17–18, 2016 as a follow-up to the December 2015

effort. The December effort, as documented in the February 2016 report (ORISE 2016a), identified

several small areas of elevated activity on scabbled surfaces, primarily on concrete floor surfaces in

the 49X and Department 20 areas of the MMB (see Figure 1.1). These areas were re-scabbled by the

remediation contractor ANTECH, and DOE requested a return IV trip to determine whether or not

residual activity, if any, exceeds pre-approved ALs. ORISE verified that residual activity levels on

concrete surfaces are well below ALs.

The DOE contractor ANTECH also shipped 12 split soil samples for laboratory analysis and

intercomparison. Inter-laboratory results are comparable, based on qualitative review1, and also

show that soil concentrations of site isotopes of concern are well below preliminary soil ALs (soil

ALs have not been approved as of the issuance date of this report). A historical maximum of

73 mg/kg of total uranium had been reported from over 2,000 samples collected across the site by

site contractors. ANTECH’s February 2016 sampling event (from which the splits were provided)

was intended to confirm the presence, magnitude, and isotopic distribution of uranium in the area

that produced the historical maximum (S.S. Papadopulos 2016). 1 Had obvious deficiencies or biases been identified during the qualitative review, or had results been a large fraction of the preliminary ALs, ORISE would have performed a statistical analysis.


Figure 1.1. Locations of Radiologically Impacted Areas within the MMB of BFC

Department 20

49X


2. METHODS

2.1 BUILDING SURVEYS

During the initial December 2015 IV effort, ORISE performed general area scans with a Ludlum

Model 44-10 2-inch by 2-inch (2×2) sodium iodide detector, a thorough (~100%) survey of the

scabbled and adjacent floors using a Ludlum Model 43-37 gas proportional floor monitor, wall scans

targeting scabbled surfaces with a Ludlum Model 43-68 gas proportional detector, and static

1-minute measurements with the 43-68 at judgmental locations, where elevated direct radiation

levels were indicated by surface scans. Though no elevated measurements were expected, ORISE

identified 27 locations in the 49X and Department 20 areas of the MMB with a gross response over

1,000 cpm, compared to a background of 400–500 cpm. This value roughly equates (using ORISE

instrumentation) to about 1,200 dpm/100 cm2.

DOE instructed ANTECH to re-scabble any location identified during the December 2015 ORISE

effort with a gross response above 1,000 cpm. For the return trip, the subject of this report, ORISE

focused only on those areas that had been re-scabbled by ANTECH. The ORISE February

verification included a targeted scan and static 1-minute measurement at each remediated location.

Smear samples were not collected during this effort because there was negligible removable activity

identified during the December 2015 effort (i.e., the activity is dominated by the fixed fraction with a

maximum reported removable activity of 20 dpm/100 cm2). All 1-minute measurement results were

compared to the following pre-approved ALs, applicable to natural or depleted uranium.

Radionuclides Units Average (Total) AL

Maximum AL Removable AL

Total Uranium dpm/100 cm2 5,000 15,000 1,000

It is noted that the average AL is assessed over an area of 1 m2, and maximum and removable ALs

are assessed over an area of 100 cm2; thus the 1,000 cpm action level should be more than sufficient

to meet the Order requirements.

2.2 SOIL SAMPLES

DOE requested that the ORISE laboratory analyze split soil samples collected by ANTECH that

contained potentially elevated concentrations of uranium near sample Station CP-5004-A

(ANTECH 2016). A total of 12 samples were shipped to ORISE and analyzed by gamma

spectroscopy and isotopic uranium via alpha spectroscopy (ORAU 2015).


3. RESULTS

3.1 BUILDING SURVEYS

Figure 3.1 shows 11 locations in the 49X area, identified by ORISE during the December 2015

effort, with a gross response above 1,000 cpm (background is in the 400–500 cpm range). These

locations were re-scabbled by ANTECH and resurveyed by ORISE in February 2016. The

December 2015 and February 2016 cpm values associated with each location are presented in

Table 3.1. Final dpm/100 cm2 results, using the February 2016 measurement data, are also presented

for comparison to the AL. The maximum measured value, over Location 3, is 1,150 cpm or

~1,600 dpm/100 cm2 and well below the 5,000 dpm/100 cm2 AL.

Figure 3.2 shows 16 locations in Department 20, identified by ORISE during the December 2015

effort, with a gross activity above 1,000 cpm. The December 2015 and February 2016 cpm values

associated with each location are presented in Table 3.1. Final dpm/100 cm2 results, using the

February 2016 measurement data, are also presented for comparison to the AL. The maximum gross

and highly localized value, over Location 21 is 694 cpm or 545 dpm/100 cm2, which is well below

the 5,000 dpm/100 cm2 AL that applies over 1 m2. Note that Location 25 was resurveyed but the

quantitative measurement value was inadvertently omitted from the logbook, though the ORISE

staffer recalls a background detector response.

3.2 SOIL SAMPLES

Table 3.2 presents analytical results for isotopic uranium, via alpha spectroscopy, for the twelve split

soil samples that were collected by ANTECH to confirm and delineate the maximum historical

result of 73 mg/kg uranium metal (~30 pCi/g) at Station CP-5004. Figure 3.3 shows the location of

the maximum and other noteworthy results (S.S. Papadopulos 2016). Tabulated ORISE and

ANTECH results show the presence of depleted uranium at Station BFC 5004, though all results are

well below the historical maximum.

As a parallel effort, ORISE is assisting DOE in the derivation of site-specific ALs for uranium in

soil. The preliminary AL for total uranium is approximately 800 pCi/g (ORISE 2016b); an order of

magnitude above the historical maximum or split sample results.


4. CONCLUSIONS

ORISE re-surveyed 27 isolated concrete floor locations in the 49X and Department 20 areas that

had been re-scabbled after elevated radiation levels were identified during the December 2015 IV

effort. These areas represent the highest probability of exceeding ALs based on process knowledge

and historical data (Auxier 2016). ORISE concludes that by demonstrating that the 49X and

Department 20 areas meet pre-approved ALs for surfaces, all BFC facilities meet pre-approved

authorized limits for surfaces. The new measurements verify that residual activity was adequately

remediated, with a maximum and highly localized single result of 1,600 dpm/100 cm2, compared to

the 5,000 dpm/100 cm2 pre-approved AL that is averaged over 1 m2.

ORISE also analyzed 12 split soil samples, collected by ANTECH at and in the vicinity of Station

CP-5004 where the maximum historical uranium result was produced. While inter-laboratory results

are comparable and low levels of depleted uranium were identified, no value approaches the

historical maximum. In all cases, soil concentrations are well below the preliminary AL of

~800 pCi/g.

5. REFERENCES

ANTECH 2016. Map emailed to David King/ORISE titled “Uranium Concentrations in Soil (A) and Soil Sample Locations with Elevated Uranium Concentrations (B).” draft.

Auxier 2016. Survey Report for Stage 3 Building Materials. Auxier and Associates, Inc. Prepared for CenterPoint Properties, Inc. Kansas City, Missouri. January.

DOE 2013. Order 458.1, Radiation Protection of the Public and the Environment. U.S. Department of Energy. Washington, DC. January.

Papadopulos, S.S. 2016. Due Diligence Site Investigation Summary Report, Volume 1 – Report. Draft. S.S. Papadopulos & Associates, Inc. Bethesda, Maryland. February.

ORAU 2015. ORAU Radiological and Environmental Analytical Laboratory Procedures Manual. Oak Ridge Associated Universities. Oak Ridge, Tennessee. August 8.

ORISE 2016a. Report For December 2015 Independent Verification Activities at the Bannister Federal Complex at the Kansas City Plant in Kansas City, Missouri. 5056-SR-01-1. February 2.

ORISE 2016b. Authorized Limits for Soil at the Bannister Federal Complex at the Kansas City Plant in Kansas City, Missouri. 5286-TR-01-Draft. March 15.


Figure 3.1. Measurement Locations >1,000 cpm in the 49X Area


Figure 3.2. Measurement Locations >1,000 cpm in Department 20


Figure 3.3. Location of Split Samples near Station CP-5004-A (S.S. Papadopulos 2016)


Table 3.1. Measurement Results for Figures 3.1 and 3.2 Measurement Loc. 2015 Gross Detector

Response (cpm)a 2016 Gross Detector

Response (cpm)a 2016 Surface Activity

Levels (dpm/100 cm2) 49X (see Figure 3.1)

1 1,115 671 470 2 5,000 680 490 3 1,544 1,150 1,600 4 1,442 616 340 5 3,108 449 -59 6 1,792 482 19 7 4,603 472 -4.7 8 3,631 398 -180 9 11,126 457 -40 10 4,197 440 -80 11 5,206 497 54

Department 20 (see Figure 3.2) 12 1,110 630 420 13 1,193 630 420 14 3,099 585 330 15 2,346 522 200 16 1,238 286 -270 17 1,504–1,920 450 56 18 1,535–2,074 664 490 19 1,569 426 8 20 1,234 591 340 21 2,372 694 550 22 1,806 647 450 23 3,560 473 100 24 5,512 474 100 25 4,777 Not recorded Not recorded 26 1,681 522 200 27 4,359 522 200

aThe 43-68 background response is estimated at 474 cpm for 49X and 422 cpm for Department 20. All dpm values rounded to two significant digits or nearest whole number.


Table 3.2. Comparison of Split Soil Sample Alpha Spectroscopic Results Result (pCi/g) Result (pCi/g) Station/Depth Analyte ORISE ANTECH Station/Depth Analyte ORISE ANTECH BFC 5004 1'-2' Uranium-233/234 2.45 2.55 BFC 5006 13'-15' Uranium-233/234 1.21 0.93 Uranium-235/236 0.196 0.19 Uranium-235/236 0.075 0.04 Uranium-238 6.17 5.59 Uranium-238 1.11 1.07 Total U 8.82 8.33 Total U 2.40 2.04 BFC 5004 2'-4' Uranium-233/234 3.58 3.04 BFC 5006 18'-20' Uranium-233/234 0.98 1.20 Uranium-235/236 0.228 0.16 Uranium-235/236 0.036 0.05 Uranium-238 10.1 7.90 Uranium-238 1.11 1.11 Total U 13.91 11.10 Total U 2.13 2.36 BFC 5004 5'-6' Uranium-233/234 3.64 3.83 BFC 5007 1'-2' Uranium-233/234 1.23 1.18 Uranium-235/236 0.237 0.37 Uranium-235/236 0.065 0.08 Uranium-238 10.8 11.20 Uranium-238 1.34 1.54 Total U 14.68 15.40 Total U 2.64 2.80 BFC 5004 7'-10' Uranium-233/234 3.55 2.40 BFC 5007 3'-5' Uranium-233/234 2.06 2.05 Uranium-235/236 0.216 0.20 Uranium-235/236 0.105 0.09 Uranium-238 5.59 7.00 Uranium-238 2.24 2.18 Total U 9.36 9.60 Total U 4.41 4.32 BFC 5006 3'-5' Uranium-233/234 2.55 3.04 BFC 5007 5'-7' Uranium-233/234 1.33 1.17 Uranium-235/236 0.160 0.17 Uranium-235/236 0.076 0.07 Uranium-238 2.64 3.20 Uranium-238 1.48 1.43 Total U 5.35 6.41 Total U 2.89 2.67 BFC 5006 7'-9' Uranium-233/234 1.33 2.37 BFC 5007 8'-10' Uranium-233/234 1.14 1.18 Uranium-235/236 0.088 0.10 Uranium-235/236 0.056 0.06 Uranium-238 1.37 2.36 Uranium-238 1.18 1.18 Total U 2.79 4.83 Total U 2.38 2.42

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