ML20002B707

Comments on Section 3 Re Summary of Conclusions & Recommendations of Analysis of Currently Approved & Proposed Procedures for Establishing Eligibility for Remedial Action

ML20002B707
Person / Time
Issue date:	10/23/1980
From:	Scarano R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Dix G ENERGY, DEPT. OF
References
NUDOCS 8012220513
Download: ML20002B707 (3)

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NMSS r/f WMUR c/f Mr. George P. Dix, Director 3j)) f$1e Operational and Environmental

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Department of Energy GGEadie Washington, DC 20545 HJMiller j

RAScarano*

Dear Mr. Dix:

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• We have reviewed the revised copy of the report, " Analysis of Currently Approved and Proposed Procedures for Establishing Eligibility for Remedial Action," by K. Schlager (dated July 11,1980) as requested in your l

letter of September 1,1980. This report is a valuable sumary and evaluation of the vaMous methods used in the Grand Junction Remedial Action Program for the detemination of indoor radon daughter concentrations.

We appreciate the opportunity to review this repcrt, and we support the development of a simpler, less drawn out procedure for determining annual average radon daughter concentrations (expressed as Working Levels) than have been utilized in the past.

With respect to the subject report, the following coments are provided concerning Section 3, "Sumary of Conclusions and Recomendations":

1.

3.1 Calibrations The importance of completing, and documenting, daily calibration tests of all air sampling and detector systems cannot be overemphasized.

For those systems such as track etch films, the vendor should be required to document calibration procedures and results, and to participate in a coeprehensive quality assurance program to assure the user that the desired accuracy of measurement is achieved during field use of the detector.

2.

3.2 Recomended Alternative Eligibility CMteMa At this time, based on the data analysis of the alternative methods evaluated in this report, it does not appear that an adequate envirical data base exists from which the long-tem average RDC on the order of the EPA's proposed value of 0.015 WL may be confidently determined. Therefore, we agree with the need stated on page 75 that no alternative method should be accepted without a fim, empiHcal data base to establish confidence in the method. Furthemore, we consider the recomended confidence level of 80% (based on the six sanple RPISU measurement as the reference) is a reasorable c,

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) oo Mr. George P. Dix 2-OCT : 3 18C Also, since from Table 21, only grab radon sampling, " radon profile" sampling, and net average sacr.a exposure rate measurecents are listed, it would seem that other alternative methods such as grab Working Level sampling, similar to those precedures being concucted for Edgemont, SD (see Enclosure 1), may be a better technique and should be further evaluated.

3.

3.3 Limitations and Conditions of Use for Alternative Measurement Methods There is complete agreement that detailed written procedures should be developed for each of the measurement methods, and such procedures should be standardized as much as possible. All radiological survey measurements should be taken in the same manner, and written records of all sampling locations and specific conditions of masurement should be adequately recorded for each structure or location surveyed.

4.

3.4 Conclusions This report does not specifically reconnend any one particular method to replace the six sample RPISU method currently being used in the Grand Junction Program. In order to avoid confusion, the selection and standardization of just one alternative method should be undertaken. We request the opportunity to review and coment upon the specific, detailed Working Level measurement precedures that you develop before such procedures are finalized or implemented.

As you are aware, the NRC is pnsently involved in a remedial action / cleanup program for uranium mill tailings in Edgemont, South Dakota; and we are conducting extensive radiological surveys including grab-Working Level measurements inside structures. Also, the NRC has initiated an interagency agreement with the Battelle Pacific Northwest Laboratory to review and assess the various alternative methodologies for completing radiological surveys to determine compliance to the EPA's environmental cleanup standards (see Enclosure 2).

Since both the NRC and the DOE are interested in finding an altamative Working Level measurement method for use in the remedial action programs, it would seem appropriate to have our staffs meet to discuss this problem I

area and to establish a unifonn program which may be used at all remedial sites. We suggest that this meeting might be held in connection with meetings that our staffs have previously agreed to conduct concerning the manner in which the NRC will carry out its P.L.95-604 responsibilities l

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m 3-OCT 2 3 ISSC Mr. George P. Dix regarding the review of CCE's methods for designating off-si:e structures requiring cleanup and the NRC's concurrence in proposed remcdial actions at such structures. Attached is a proposed agenda which the staff has prepared to focus the discussion at such a meeting (see Enclosure 3).

Please contact Gregory Eadie of v staff (427-4541) to arrange for such a meeting between our staffs, and if you have any questions regarding our concents on this report.

Sincerely,

r - cinal h.;

sd by :

. ::aranc Ross A. Scarano, Chief Uranium Recovery Licensing Branch Division of Waste Management

Enclosures:

1.

Edgemont Cleanup Action Program 2.

BPNL's Schedule 189 for Environmental Cleanup Standards 3.

Proposed Agenda cc: Dick Perkins, BPNL l

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