ML19339C944
| ML19339C944 | |
| Person / Time | |
|---|---|
| Issue date: | 01/09/1981 |
| From: | Scarano R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Mills L TENNESSEE VALLEY AUTHORITY |
| References | |
| REF-WM-40 NUDOCS 8102120509 | |
| Download: ML19339C944 (2) | |
Text
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JAN 9 1981
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Mr. L. M. Mills, Manager p
9 Nuclear Regulation and Safety Jg2 p
Tennessee Valley Authority 3
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Dear Mr. Mills:
This letter is in response to your letter of November 6,1980, whic ists 20 stipulations for the receipt and temporary storage of radioactive material removed from the offsite areas of Edgemont during the cleanup program which the NRC, through its prime contractor the Battelle Pacific Northwest Laboratories (BPNL), is conducting.
Basically, we have no problems with your stipulations 1 through 15, recognizing that all concerned parties, including Silver King Mines, Inc. (SKM), shall conduct all oper5tions in a reasonable manner in order to minimize the spread of low-levels of contamination due to the off-site cleanup activities.
Stipulation 16 requires that BPNL complete an engineering evaluation of the adequacy of the Cottonwood Creek crossing, but such findings should be documented so that any damage which may occur as a result of BPNL's usage l
of the crossing may be more accurately assessed at that time.
To this end, BPNL has been requested to conduct and to document their f1ndings as to the adequacy of the Cottonwood Creek crossing (see attached letter).
Stipulation 17 requires BPNL to decontaminate its trucks before they leave the mill site; and BPNL has been requested to provide written procedures which detail such decontamination and cleanup activities (see attached letter).
l Stipulation 18 requires stabilization procedures to be developed by BPNL and approved by SKM; however, BPNL has been requested (see attached letter) to provide written procedures detailing the interim and final stabilization procedures which will be reviewed and approved by the NRC.
Stipulation 19 requires that the NRC will be responsible for and shall l
remedy such failures at its expense should BPNL fail to meet any of its responsibilities; however, the NRC shall requi're that BPNL secure payment I
and performance bonds from all subcontractors.
Therefore, the NRC shall not be held liable for any failures on the part of BPNL or any of its subcontractors.
l l
8102120509
r Mr. L. M. Mills JAN 9 1981 Stipulation 20 indicates that TVA may terminate this agreement upon 30 days' written notice to the NRC; however, all concerned parties to this agreement must work together so that no problems will arise so as to create such difficulties that the Edgemont Cleanup Action Program cannot progress to a successful conclusion.
Therefore, until BPNL has had the opportunity to review and coment upon your stipulations regarding the Edgemont Cleanup Action Program, the NRC will not execute the subject letter at this time. Also, for this same reason, the NRC will not execute TVA's indemnification and hold hamless form of November 18, 1980.
Sincerely, Ross A. Scarano, Chief Uranium Recovery Licensing Branch Division of Waste Management
Enclosure:
Letter to N. A. Wogman, BPNL cc:
R. Perkins, BPNL i
l N. A. Wogman, BPNL c
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NUCLEAR REGULATORY COMMISSION 3
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JAN 9 1981 Dr. N. A. Wogman, Manager Radiological and Inorganic Chemistry Studies Battelle Pacific Northwest Laboratories P. O. Box 999 Richland, Washington 99352
Dear Dr. Wogman:
This letter is to provide further guidance regarding the Edgemont Cleanup Action Program (B-2217-0) with respect to the coordination of your activities with the Silver King Mines, Inc. (SKM), TVA's operator at the Edgemont Uranium Mill site, for the cleanup of residual radioactivity at off-site locations and the ultimcte delivery of such material to the existing tailings pile. Also, this letter supplements discussions contained in our letter to you dated October 10, 1980.
You are requested to review the attached letter from the Tennessee Valley Authority to R. A. Scarano, dated November 6,1980; and to provide any written corrents concerning the twenty stipulations as discussed in that letter.
In particular, you are requested to provide written coments for the following stipulations of that letter:
Stipulation 16:
Describe how BPNL will conduct and document the engineering evaluation of the Cottonwood Creek crossing.
l Stipulation 17:
Describe the necessary decontamination procedures as may' be required for personnel, machinery and/or equipment (such procedures were already discussed in the October 10, 1980 lettertoyou).
Stipulation 18: As discussed in the October 10, 1980 letter to you, there is no need for the interim stabilization of indivual loads of removed residual radicactivity so long as all such material is kept in the water wetted-down condition. Therefore, describe the methods to be employed to l
assure that all material is kept in the water wetted-down condition; and also provide a description of the final stabilization procedure which will i
be performed upon completion of the entire cleanup program or more fraquently l
if necessary as based upon your determination.
Stipulation 19:
Provide the procedure which BPNL will use in its subcontracting to secure adequate payment and performance bonds from all subcontractors.
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Dr. N. A. Wogman JAN 9188j As NRC's contractor for this project, BPNL must conduct all of its operations in such a manner so as to assure the health and safety of all participants and must meet all legal responsibilities to preclude any future liability actions against the NRC.
Also, please review and provide written comments on the attached letter from TVA to R. A. Scarano, dated November 18, 1980, which requests that NRC and BPNL execute an indemnification and hold hamless statement.
If you have any questions in this matter or on these requests for written responses to the TVA stipulations, please contact me at 301-427-4103.
Sincerely, Gregory G. Eadie, Project Manager Uranium Recovery Licensing Branch Division of Waste Management
Attachment:
As stated cc:
R. Perkins, BPNL L. M. Mills, TVA l
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5 400 Chestnut Street Tower II Novecher 6, 1980 Mr. Ross A. Scarano United States Nuclear Regulatory Commission Uranium Recovery Licensing Branch Mail Stop SS 483 7914 Eastern Avenue Silver Spring, Maryland 20910
Dear Hr. Scarano:
In the Matter of the
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Tennessee Valley Authority
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Docket No. 40-1341 In response to your Septecber 18, 1980, request to ce concerninC the Edge =ent Cleanup Action Progra=, TVA has developed the following stipulations for receipt and te=porary storage of radioactive caterials removed from the offsite areas of Edge =ont durinS the cleanup program.
fie understand that Battelle Pacific Northwest Laboratories (BPNL) will be !GC's contractor for this program. TVA's operator at the Edgemont uraniu= mill, Silver King Mines, Inc. (SEM), will participate in imple-menting the stipulations.
We alv understand that these stipulations are in accordance with SUA-816 en. the NRC approves of the stabilization approach to be employed.
Th'
".pulations are as follows:
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1.
Only uranium c:ill tailings or c:aterials conta=inated by such tcilings will be accepted for disposal at the Edgemont mill site.
Any additional c:aterial would be accepted by prior approval only and at the discretion of TVA.
2.
EPNL will provide SKM for its approval a schedule for BPNL's cleanup activities, including the number of truck loads per day, their frequency, and the tonnage of taterial expected.
l This should be updated as BPNL's cleanup cperations continue and additional areas are designated for cleanup.
3.
Each truck cust be accepted and logged in by a designated SKM e=ployee.
4 Trucks will be allowed access to the mill site only durinf weather conditions which ai to roads.
DUPLICATE DOCUMENT 5.
Trucks will be required to Entire document previously as determined by SKM. Spee entered into system under:
hour.
ANO 0N W&
No. of pages:
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