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NWI Breckenridge

1.0 Site Identification

2.0 Site Status Summary

This is a unimproved 3 acre rural agricultural piece of land located in farm land outside St. Louis, Mi The disposal of chemical sludges were done in less than one acre in slit trenches. The site was orginally to be used for the disposal of brine solutions into a deep well on the site by the former chemical company. The deep well was never used. The site is protected by a chain link security fence. A small river runs along one side of the property, one side is bounded by a county road, and the other two sides are bounded by farm land.

Between 1967 and 1970, Michigan Chemical Corporation (MCC) managed the site and used it for the disposal of process wastes from a yttrium recovery operation. These disposal activities were authorized under U.S. Atomic Energy Commission (AEC), License Number, SMB-0833, and were performed in accordance with 10 CFR 20.304, "Disposal by Burial in the Soil." The buried waste material is a solid waste byproduct, known as filtercake, which originated from a rare-earth metal (yttrium) extraction process. Disposal records reported that the filtercake was typically a dense, clay-like material that contained elevated levels of naturally occurring uranium and thorium. After site operations ceased, AEC License Number, SMB- 0833, was terminated. In addition to the buried wastes, thorium and uranium contaminated surface and subsurface soil has been identified at several locations in open land areas on the site. Several radiological evaluations have been performed in recent years. Characterization reports estimated the average thorium-232 and uranium-238 concentrations in the buried waste material to be about 240 picocuries per gram (pCi/g) of thorium-232 and 150 pCi/g of uranium-238. The NRC NUREG 1757, vol 1., Consolidated Decommissioning Guidance, Decommissioning Process for Materials Licensees, Table B.2 Screening Values (pCi/g) of Common Radionuclides for Soil Surface Contamination Levels, specifies screening levels for thorium-232 of 1.1 pico-curies per gram (pCi/g), and uranium 238 of 14 pCi/g.

3.0 Major Technical or Regulatory Issues

Based on a remedial work plan prepared by a former contractor SCIENTECH, there are seven confirmed waste areas (CWA) and two potential waste areas on the site. In October 2004, SCIENTECH completed excavation of waste at CWA-2 and CWA-7. During excavation of CWA-2 and CWA-7, the cover soils were found contaminated and additional veins of the waste were discovered. As a result of the discovery of unexpected increase in the waste volume, it was determined that the Trust had insufficient funds to complete the remediation. ENVIRON shut down the operation and transported all the excavated waste material for offsite disposal on November 19, 2004. ENVIRON has spent $750,000 approved by the Bankruptcy Settlement Agreement. To justify additional funds to complete remediation of the site for the bankruptcy court, the contractor needed to determine the volume of the waste remaining. ENVIRON submitted a Revised Dose Assessment on April 25, 2006 and Supplement Site Characterization Plan on September 19, 2006, which were prepared by a contractor, IEM, Inc. This plan was established to quantify the accurate waste volume based on the revised DCGLs. On October 26, 2006, the NRC reviewed and approved the Environ Sampling Program and Dose Model for the Breckenridge Disposal Site. The sampling was completed during November 2006. Initial findings indicates that more waste exists than believe during 2004, but it is less than their original worst case estimates. On June 2007 a new decommissioning contractor (ENVIRON) submitted a characterization report Velsicol Chemical Corp., Breckenridge Disposal Site, Supplemental Site Characterization Report, Prepared for: The Custodial Trust, Submitted to the United States Nuclear Regulatory Commission, Prepared by: Environ International Corporation. The document is archived under ADAMS Accession No. ML071800466. The purpose of the contractor's report was to document the field activities completed during November 2006, present volume estimates of material exceeding the DCGLs, and to propose a conceptual approach for achieving the NRC's unrestricted release criteria. The contractors supplemental report proposed four alternative approaches for site remediation, which according to the contractor would make the site suitable for unrestricted release. The alternatives were developed according to cost basis, that is a range from a worst case and most expensive basis, dig up and transfer to approved a radiological disposal site, the least costly involving intentional mixing and limited off-site disposal. The contractor's four proposed remediation alternatives are as follows: Alternative 1 - Excavation and disposal at Energy Solution's Clive, Utah Facility Alternative 2 - Excavation and disposal at EQ's Bellville, Michigan Facility Alternative 3 - Intentional mixing and on-site disposal. Alternative 4 - Combination of Alternatives 1 and 3. The contractor is using NRC guidance outlined in NRC NUREG 1757, vol 1, which provides guidance on the various disposal options, which includes intentional mixing. The contractor provided the Region with cost estimates based on the options. On August 14, 2008, NRC Region III, NRC Headquarters, the Custodial Trust Trustee, and the Environ (contractor) will participate in a VTC conferenece to brief the Region and HQ on status of funding and proposed disposal options. NRC Region III legal council and staff will meet with Custodial Trustee to clarify funding amounts, expenditures, current contractual agreements with present contractors, and posssible use of other contractors.

4.0 Estimated Date For Closure

12/31/2009

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Tuesday, November 04, 2008