NWI Breckenridge

1.0 Site Identification

2.0 Site Status Summary

This is an 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 originally 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.Michigan Chemical Company (MCC) operated a rare earth processing plant from 1967 through 1970, at St. Louis, Michigan. The feed-stock materials used by MCC contained licensable quantities of source material. The MCC facility manufactured an array of chemical products. Among the products manufactured were fire retardant materials, insecticides, animal food supplements, and rare earth oxides. The use of licensable materials was authorized until April 1971, when License No. SMB-0833 was terminated.

Between 1967 and 1970, MCC used a small rural plot of land about 4 miles east of downtown St. Louis, in Bethany Township, Michigan for the disposal of its process wastes. The Site is located at 4490 East Madison Road, Breckenridge, MI. The Breckenridge property is a narrow triangular shaped parcel of land that is mostly flat and grassy with scattered large trees. The Site, bounded by Madison Road on the north, by Bush Creek on the east, and by farmland on the west, is approximately 1.25 acres. The nearest residence is located approximately one-quarter mile to the east, across Bush Creek. These disposal activities were performed in accordance with 10 CFR 20.304, "Disposal by Burial in the Soil."

3.0 Major Technical or Regulatory Issues

The buried waste material is a solid waste byproduct, known as filtercake, which originated from the former licensee’s 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. 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. NUREG-1757, Volume 1, Consolidated Decommissioning Guidance, Decommissioning Process for Materials Licensees, Table B.2, Screening Values (pCi/g) of Common Radio nuclides for Soil Surface Contamination Levels, specifies screening levels for thorium-232 of 1.1 picocuries per gram (pCi/g), and uranium 238 of 14 pCi/g.

Based on a remedial work plan prepared by a former contractor SCIENTECH, there were 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 the 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 Custodial Trust had insufficient funds to complete the remediation. Without adequate funding the operation was shut down and all the excavated waste material was transported for offsite disposal on November 19, 2004. Most of the $750,000 previously approved by the Bankruptcy Settlement Agreement had been expended.

In order 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 revised DCGLs. On October 26, 2006, the NRC reviewed and approved the Sampling Program and Dose Model for the Breckenridge Disposal Site. Site sampling was conducted during November 2006.

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, 123 North Wacker Dr., suite 250, Chicago, Illinois 60606, June 2007. (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 contractor’s 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 approve 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.

On November 1, 2007, Region III staff discussed the mixing option with the contractor. The contractor was provided the guidance outlined in NRC NUREG-1757, Volume 1, which discusses intentional mixing. On December 14, 2007, Region III and DWM staff and management held a conference call to discuss the non-licensee’s proposal to perform intentional mixing. DWM management advised Region III management that the mixing options 1 through 3 were feasible. The fourth option (bringing clean fill onto the site to fill the excavations) required Commission involvement and could potentially delay or stop the action.

Because the use of surface/sub-surface DCGLs was considered non-routine, Region III forwarded Environ’s basis for the DCGLs to FSME for review and approval. While the DCGLs were approved, FSME noted the sub-surface DCGLs for Th-232 and Ra-226 exceeded the NRC/EPA MOU trigger level. This required FSME to conduct the required communications with EPA on this issue, which took from March to July before approval was received from FSME to move ahead with the project.

4.0 Estimated Date For Closure

2012