ML19347F767

Forwards Four Comment Ltrs on NRC Draft Soil Decontamination Criteria for Decommissioning Vendor Facility

ML19347F767
Person / Time
Site:	Wood River Junction
Issue date:	03/19/1981
From:	Grant M RHODE ISLAND, STATE OF
To:	Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML19347F763	List: ML19347F762 ML19347F766 ML19347F767
References
NUDOCS 8105260269
Download: ML19347F767 (7)

Text

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e STATE OF RHODE ISLAND G PRovlDENCE PLANTATIONS EXECutivt CHAM 8ER' P R CVIDE NCE J. JOSEPH G Am mANY GovteNoe March 19, 1981 Mr. h'il'11am Crow Nuclear Regulatory Commission Division Fuel Cycle Material Safety

~ Mail Stop 396-SS h*ashington, DC 20555

Dear Bill:

I have enclosed for your consideration comments on NRC's Draft.

Soil Decontamination Criteria for the UNC Recovery Systems.

decommissioning prepared at the request of the Governor and mem-bers of the Citi:: ens Advisory Committee.

I hope you will give

' them your careful consideration in revising the draft criteria.

You should feel free to funnel any questions you have on these comments through me, h'e will look forward to earliest possible

. notice of your final criteria.

Be'st wishes.

Si u rely, Malcolm

. Grant Policy Associate for Environmental Affairs MJG;sp Enclosures I

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STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONb INTER OTFICE MEMO j*

fn: # 6 DATE: 22 January 1981 TO Mr. Malcolm Grant DITT Governor's Office M*N' Mr. James E.' Hickey. Chief TF.CM :

Occupational Health / Radiation Control DETT Community Health Services sus ECT:

Draft Document

" Soil Decontamination Criteria for the Decomissioning of the Uf!C's Facility" This $1emorandum transmits the State Radiation Control Agency's (RCA) coments on the subject document. The RCA review of the document included an independent staff review and a discussion of the document with the State Radiation Advisory Comission, which is the Agency's technical.dvisory body.

The official coments of the Comission are attached in the form of a letter from the Comis'sion Chair-man..The RCA concurs with the Commission's comments as presented and has no further comments on the technical merit of the criteria at this time. Since the Commission and the RCA wish our reviews of this and other matters related to the decc=issioning to be a continuing procass, these comments should not be considered complete or final.

The document indicates that the licensee will submit a detailed plan for demon-strating compliance.with the criteria.

The types and extent of the sampling programs proposed by the licensee in this plan are of critical importance in accurately identifying contaminated areas and adequately demonstrating that any contamination found is brought into compliance with the criteria established.

In regard to the sampling programs, the RCA has identified the following areas which should be reviewed by the state prior to approval of the licensees' plan by f:RC.

1) need for new aerial survey of the site;

2) need'for an independent inventory of potentially contaminated areas of the site;

3) details of the various. sampling programs proposed including: competence of personnel conducting sampling and analysis; types and quantity of samples to be obtained; depth of sampling for soil samples; gross radioactivity and radionuclides to be evaluated on each sample;

4) adequacy of various options for bringing contaminated areas into compliance with the criteria'.

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Dr. Joseph Cannon.

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.lAN 2 6ibbl 'e Dr. Joseph Yacovonne Mr. Frederick Siino

. GOVERN 0R'S OFFICE l.

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.i STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS D

JAN 131981 Depsr: ment of Health

. STATE CEPT. of HRTH

. CANNON BUILDING

. 9 n e Caupanenal 3,3 Dais Street Providence. R.I. 0290S 19 December 1980 Mr. Ja=es Hickey Chief, Cffice of Occupational Health and Radiation Control Rhode Island Department of Health 75 ! avis St.eet Pro tidence, Rhoca island 02908,

Dear Mr. Hickey:

The Rhede Island Radiation Advisory Comnission at its meeting on Decemb er 17, 1980 considered the draft docuhent titled " Soil Decontamination Cri:eria for the Decommissioning of the UNC's Facility" issued recently under Decket No.70-820 by the U. S. Nuclear Regulatory Commission. The Commission fcund the criteria for soil decontamination as stated in the document to be

, adequate, in general, with the following two exceptions:

(a) The present aad future effects on ground water from radioactive materials that might remain in the soil do not appear to be addressed in the document.

It is poscible that the Nuclear Regulatory Commission intends to address these items separately in another document. The Commission feels, however, that it should point out this exception and its feeling that the issue should be addressed.

(b) The appropriateness of the data upon which the Nuclear Regulatory Commission based its calculation of the criteria for the inhalation of radon daughters in Table 2; specifically, why an effective removal rate of 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (see Table 4) was used in these calculations.

1:~ is further recommended that the Agency. and the Commission retain a continuing rela in the review of the decommissioning process. ' The Commission is appreciative of having hcd the opportunity to review the document.

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Ac s.: gectei, ~ provide herewi,h ny questions conce=in ; t' is dec=ent:

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Ochio 1 cnd nor.;t subsequent tables: Ohis is a listing cf the Characteristics of.'a_ioactive "uclides fron 7.%:'s Operati:n.

_.le inclucien in this table of.12_TO cnd C3-137 indicates the recc:; nit'.cn of nuclices fres irradiated fuel. Alwayo included with irradiated fuel is 'Ju-239 21s nuclide should be '.ncluded in all tables, ve.ere appropriate.

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S is, by the way, is 1/10th a generally cceepted ac'c:.owle:ge=ent of a lethal lose (c o= ing to abcut 10 microgrc=s of h). 3e questien of " point cou=e" ve=us ifhcle body radiction" has been the r oject of centroversy for sone time.

I e~ncle::e herewith a copy of the Aerial ::ecsurin-Systens (A1.*S) report of

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RODR ORIGINAL

UNITED STAT 25 ENVIRONMENTAL PROTECTION AGENCY oh c

• Tchruary 5, 1981 sacatt n Su=ary of Review on Soil Cacontamination Criteria for the Deco =missioning of the UNC'S Facility (by the Nuclear Regulatory Cc: mission Staff) vncu Dr. Frank Lowman TdRU:

Dr., Donald Phelps 7

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NOTE: The cO=ments made in this su=ary reflect the individual expertise of Dr. Frank 'ow.an and Donald K. Phelps and in no manner are intended to convey a policy or statement reflecting the position of the laboratory (Environ = ental Research Laboratory, Narragansett, Rhode Island) or the Environmental Protection Agency concerning the subject centained herein.

[ADt 2g.1. Paragraph 1, A review of cond bens and requirements as they exist.

Pg.1, Paragraph 2, Description of U recovery frem nuclear fuel scap, including description of toe recovery steps. Not pertinent to the decen problem except as background information.

Pg. 2, Continued sentence from page 1.-Continuation of description of recovery process.

Pg.2, Five (5) categories of scrap.

1. 1,2,3,4,5.

Descriptions of types of scrap processed and types of wastes produced. Not directly pertinent to clean-up.

Pg.2, B Potential Pathways for Land Centa.ination of the UNC Site and the characteristics of Nuclides involved.

Paragraph 1.

Description of gas and liquid contaminents.

Descriotions of radionuclides Pg,3, Paragraph 1andgbsectgons12,3.

23 23 2

contaminating soil. U

,U U

, Th

, Ra Th

, Mixed Fission 90 13 products of which Sr and Cs are considered important.

Pg.3 C Proposed interim criteria for Soil decon. Generally good with acceptable criteria for decontaminating.

. Question? Who determines what is as low as reasonably achievable.?

Pg.4. Paragraph 2. O.K.

Pg.4 Paragraph 3, D.

Natural background consideration.

'Pg.4 Paragraph 4-Describes conditions, as found. O.K.

Pg.4 E Compliance with the proposed' interim target cri*.eria.

P00R ORIGINAL

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External radiation 5th paragraph. Describes measuring with instruments.

O.K.

- Exterr.al radiatica 6th paragraph. Details of making instrument measurements. Acceptable procedure. O.K.

Pg.5, Paragraph 1 under item 2 Inhalation of Radon and its daughters.

Based on an NRC technical position for Interim Land Clean-up Criteria for Uranium Sites. O.K.

Pg.5, Paragr 7h 2 under item 3.

Inhalation of particulates.

O.K., meets NRC and EPA standards.

Pg.5, Paragraph 3 under item 3.

Requirement O.K.

Pg.5, Paragraph 4 under item 4.

Ingestion of Radionuclides. Assumes food is grown on the land. O.K.

.Pg.5, Paragraph 5 under iten 4.

Describes approved soil sampling. O.K.

Pg.6 Summary Paragraph 1.

Summaryc[NRCtargetcriteriaforlandclean-up at the UNC site.

O.K.

Pg.6 Summary Paragraph 2.

Requirements on documentation requirements, by NRC and NRC verification survey. O.K.

Table I O.K.

Table 2 O.K.

Table 8 0.K.

Table 9 0.K.

Table 10, O.K.

Table 11, O.K.

Table 12, O.K.

Table 13, O.K.

Table 14, O.K.

Table'15, O.K.

Table 16, O.K.

APPENDIX A, Decontamination-decommissioning Plan for UNC'S Scrap Recovery Facility and Site.

Letter from NRC to UNC.

No comment. O.K.

Decommissioning schedule. Appears' feasible.

NRC' Decontamination Program. Appears feasible and cost effective.

UNC Decc=missioning Program. O.K.

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APPC: DIX B_

O.K.

AP7D DIX C.

Radiological concentrations in water samples, collected and analyzed by !!RC in UNC'S lagoons, storage tank and monitoring wells.

o.r.., all at lease 100 times lower that MP'C for 168 hour0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> week.

Review based on NBS HB 59.

The guidelines and plans outlined, of themselves appear acceptable and reascnably censervative, in relation to environ = ental considerations.

Hcwever, the important consideration is effecient implementation and a final survey check as proposed by NRC.

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UnC P.ECOVERY SYSTEMS o.o<>m 2o s 3.m.o -s CEB 80-88 s-Dmsien cf United Nuclear Co ; cts: son One Narra;;3nse:t Trait Telephone 461t364 7701 A UnC resources Company Wood River Junction. Anc:e Istand 02294 April 29, 1980

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W. T. Crow, Section Leader

.{ g y*^g(,J i,gg Uranium Fuel Fabrication Section e,,,,,"'

.j Fuel Processing and Fabrication Branch Q if 40 Division of Fuel Cycle and Material Safety D

Washington, DC 20535

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Dear fir. Crow:

UNC Resources has decided to terminate recovery of highly enriched uranium.

Present planning calls for reprocessing of the small quantity of scrap on hand by about July 1, 1980, followed by a concentrated program of site decontamination.

Total SNM inventory, with the exception of process lagoon residues, should be below five kilograms by early fall, 1980.

Lagoon processing and decontamination are scheduled for completion by April 1, 1981.

Under thcse circumstances, it is our understanding that license renewal and revision for the upgrade rule are not required.

Accordingly, we are formalizing decontamination-decommissioning plans for discussion with you.

In addition, we have been in contact with other former licenseholders with decommis.eioned facilities in an effort to develop an effective and coherent program.

Overall decommissioning planning, including nuclear safety l

and health physics aspects, is presently the responsibility l

of Mr. Robert Gregg; security acpects are under Richard

-Gigliotti.

Either cf these gentlemen or I will be happy to neet with you and your staff at your early convenience, to discuss NRC requirements and UNC planning.

Very truly yours, UNC RECOVERY SYSTEMS M

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