ML19347D714
| ML19347D714 | |
| Person / Time | |
|---|---|
| Issue date: | 03/13/1981 |
| From: | Shaffer W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-39 NUDOCS 8103261143 | |
| Download: ML19347D714 (4) | |
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ME:iCRANDUtl FOR:
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Ross A. Scarano, Chief 2
Uranium Recovery Licensing Branch
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FROM:
William M. Shaffer III, Project Manager Uranium Recovery Licensing Branch
SUBJECT:
COE/NRC PROCEDURE FOR OBTAINING NRC CONCURRENCE TO PROCEED WITH REMEDIAL ACTION AT UMTRAP VICINITY PROPERTIES Discussion Cn January 29, 1981, I had a telephone discussion with Richard H. Campbell, Project Manager, UMTRAP Project Office (PO), DOE-Albuquerque, which resulted in tentative agreement on the subject procedure. At that time, we were assuming the NRC staff would have to concur in the selection and performance of remedial actions for individual vicinity properties on a case-by-case basis and were, therefore, interpreting the language of the UMTRCA in a manner which would require such a procedure to be developed ar.d implemented.
Mr. Campbell's attached January 30, 1981 memorandum to Robert W. Ramsey, Jr., Manager, Remedial Action Programs, DOE-HQ, is an accurate representation of our discussion and the tentative procedure agreed upon.
Since that time, we have received confirmation frcm our legal staff (Rebert L. Fonner) that the UMTRCA language regarding this matter could l
be interpreted by us more flexibly such that vicinity properties could be considered as part of the designated processing site they are associated with. Thus, if vicinity properties, as a group or groups, were adequately included and assessed for suitability of applying specific remedial actions as part of the overall Remedial Action Plan (RAP) for their associated processing site, then NRC staff concurrence in that RAP would also consti-tute our concurrence in remedial action plans for the associated vicinity properties.
At our subsequent February 20, 1981 meeting with Mr. Ramsey and Donald H.
Groelsema of his staff, we agreed that this would be the desired approach and could be accomplished by NRC staff concurrence in the RAP for vicinity properties as presented in the processing site EIS (or EA, if a full EIS is not planned for a specific processing site). As you know, we also agreed that exceptions to this approach may be made for unusually significant vicinity properties for which a determination is made that they should receive stand alone treatment from the standpoint of RAP and/or NEPA documentation. Three current potential examples are the PRR Landfill Vicinity Site associated with the Cancnsburg, PA, processing site and the Sewage Treatment Plant and Fire Station Vicinity Sites at Salt Lake City, UT.
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Files MAR 13 19M Conclusion The procedure tentatively developed is thus not required, resulting in a significant savings in anticipated DOE /NRC staff workload while not diminish-ing NRC's role and respcasibility under UMTRCA to concur in the selection i
and performance of remedial actions.
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William M. Shaffer III, Project Manager Uranium Recovery Licensing Branch Division of Waste Management i
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Enclosure:
As stated cc: Robert L. Fonner, ELD /NRC R. G. Page, FCUF/NRC Robert W. Ramsey, Jr., COE Or. William E. Mott, COE Richard H. Campbell, 00E-Albuquerque f i m
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AT*N of Nuclear Regulatory Cennissien Review and Cencurrence in Renedial Action 2:
su s.t cr DiT?a Vicinity Proper-ies R. W. R: sey, Jr., Manager, Ra ;edial Actions Progras, Mail S cp 3107, 1
to CCE -ie dquarters/NEN Tne catter of Nuclear Regulat: y C ::ission (NRC) review and concu rence in recedial cc:icas at LMTRA vicinity Pre erties was discussed via tele:hene with N. Shaffer (NRC fccal point) en January 29,19S1.
Whi'a -b OITRA
?roject Office d:es nct believe that NRC cencu-ence en recedial action plans for each and every vicinity site was a p acti:21 intent of Public Law 95-604, it appears that NRC in:e=re:s the language of the legisla:icn
. s eza that it mus: provide such concurrences.
The p oposed procedure discussed with M. Shaffer which would enable NRC
- 0 cencur on the plan c: acti:n :cr eacn vicinity site includes the foll: wing steps:
1.
The engineering centrac:cr would forward a ecpy of the Radic1cgical nd Engineering Assess =ent (REA) report to NRC at the sa:e time copies a e forwarded to the ALO Proj ect Office (ALC/PC).
2.
% hen the ALO/F0 co eleted its review of the REA, a letter of instructions to the engineer *.ng centrac Or would be draf: :d by the ALO/PO.
The 1e::er of instructi:ns will provide any revisions to the plan of action 2nd will authorize the engineering centrae:cr to prepare detailed engineering and procedures for the vicinity property.
A copy of the draft letter would be telefaxed to NRC.
3.
After reviewing the draft letter, NRC will prc ptly (within a day or two) telephene its concur ence to the ALO/PO.
4.:
NRC will also send a reco to the ALO/PO that ecnfirms its concurrence.
The NRC file ecpy of this ne o decurents their concurrence for N.E Tne official ecpy of the reno documents NRC concurrence for purposes.
the ALO/PO files.
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The A10/PO then finali:es the letter of instructicas and forwards the letter to the engineering centractor (with a ecpy to NRC).
Ycur cc:=:ents on this proposed recedure would be a-c.reciated. You =av. wish r
r to discuss the matter with Mr. Shaffer to dete nine if the precedure desc-ibed e
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c Robert W. Ra:2sey, Jr..
above represents his understanding of what we discussed on tite telephone.
I would also appreciate your views on adapting this procedure to the nrocess of obtaining State / Tribe concurrence on action plans for vicinity properties.
//0 m;,m /v At Rivhard H. Campbell, w
,. Shaffer, NRC W
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