ML20005E937
| ML20005E937 | |
| Person / Time | |
|---|---|
| Issue date: | 12/15/1989 |
| From: | Randy Hall, Jacoby D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| REF-WM-48 NUDOCS 9001120081 | |
| Download: ML20005E937 (4) | |
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URFO:DLJ Docket No. WM-48.
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1 ll MEMORANDUM FOR:
Docket File No. WM-48 FROM:
Dawn L. Jacoby Project Manager j
SUBJECT:
SUPPLEMENTAL STANDARDS APPLICATION FOR SLOPES OF SMELTER MOUNTAIN AT-THE DURANGO-PROCESSING SITE (RAP MODIFICATION #2) i BACKGROUND-The EPA' standards, under 40 CFR Part 192.12(a) require that the concentration-of radium-226 in-land averaged over any area of.100 square meters shall not exceed the background level by more than 5 pCi/g, averaged cyor the first 15 cm
'of soil below the surface, and 15 pCi/g averaged over 15 cm thick layers of soil more than.15 cm'below the surface.
The radon flux standard, 40 CFR 192.02(b)(1), requires that the release of radon-222 not exceed an average release rate of 20 pCi/m2s.
On-October 17, 1989, DOE-applied for supplemental standards for two steeply-sloping hillside areas on Smelter Mountain.
The slopes of Smelter Mountain are contaminated with windblown material.
The proposed remedial action will leave the contamination in place.
Supplemental standards were applied for based on the obvious risk to workers and the resulting environmental harm which would result from removal of the material.
DISCUSSION During.a site visit conducted September 6, 1989, the proposed area was observed and.the proposal discussed with DOE and the State of Colorado.
The two areas identified are located (1) on the slopes of Smelter Mountain above the footprints of the old tailings piles and the tailings pile access roads, with a small area just to the south of the old tailings piles, between the UMTRA haul road and the Animas River, and (2) on the slope of Smelter Mountain above the UMTRAP haul road, just above the area of the raffinate ponds.
These areas are shown on Figure 1.
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Radiological Survey Assessment Outdoor gamma surveys were conducted on the accessible portions of areas.
Field personnel established generalized gamma radiation levels of 25-30 microR/hr with " hot spots" of up to 60 microR/hr.
264 soils samples were also taken in accessible areas with the test reporting activities of less than 1.3 to over 600 pC1/g.
No average value was reported.
The DOE report concluded that supplemental standards should be applied to the 308,958 square yards delineated on Figure 1.
They describe the area as
" sporadically contaminated in the top 6 inches of soil with steep, washed areas I
at or near background Ra-226 concentrations while more level and vegetated areas have higher activity."
NRC review indicates that the data presented supports the DOE conclusion.
Supplemental Standards Criteria for applying supplemental standards (40 CFR 192.21) include (1) posing a clear and present risk of injury to workers, and (2) directly producing environmental harm that is clearly excessive compared to the health benefits of achieving primary standards.
The area is steep enough that the possibility of human intrusion is remote.
Cost is not a consideration for applying supplemental standards at the processing site.
CONCLUSIONS The staff finds that due to the steepness of the areas, the locations met two supplemental ~ standard criteria (40 CFR 192.21(a) and (b)).
These include posing a clear and present risk of injury to workers and directly producing
-environmental harm that is excessive compared to health benefits.
Also, the overall remedial action design meets the intent of the. low as reasonably achievable philosophy of 40 CFR 192.22.
Therefore, the staff recommends approval of supplemental standards for the area requested.
abzwvl Dawn L. J coby l
Project anager Approved by:
h 4 Ramon E. Hall u
Director i
Case Closed:
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CONCURRENCE:
DATE:
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