ML20006G190
| ML20006G190 | |
| Person / Time | |
|---|---|
| Issue date: | 02/23/1990 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Matthews M ENERGY, DEPT. OF |
| References | |
| REF-WM-72 NUDOCS 9003050314 | |
| Download: ML20006G190 (3) | |
Text
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, Mark Matthews', Acting Project Manager j
- Uranium Mill Tailings Project Office l
LAlbuquerque Operations Office j
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' U.S. Department of_ Energy 1
, :P. 0." Box 5400-
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, Albuquerque, NME 87115 o
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Dear'Mr. Matthew's:
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2We have completed our review of the revised Radiological Engineering Assessment p'i M (REA) for vicinity-property number. SK.001s transmitted.by your letter, dated -
' December 18,1969. :0ur review has identified-several items (ses enclosure) W -
~ o fthat'should be clarified.. We are prepared to concur:with the recommended
%f" remedial action and _ application of supplemental standards once these: items aree
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- 7,'.. faddressed. - Since.you intend to defer groundwater cleanup. associated with.this?
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JQ property,to'a separate phase of the project and will conduct characterization; s ',~ /
4 and evaluation of the groundwater-in conjunction with that of'the Spook. site,{
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+ the concurrence will,be conditional.
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!ShouW you have any questions regarding this review, please contact me or.
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LDen'G111enofinystaff(FTS 4920517) y '., j c
Sincerely.
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37-Paul H. Lohaus Chief-
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Operations. Branch.
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and Decommissioning, NMSS L
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Enclosure:
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>h Review of Revised Radiological Engineering Assessment for Vicinity Property SK-001s 1.
Drawings SPK-PS-10-0201 through SPK-PS-10-0204 are referenced throughout the REA, but were not in this submittal. The REA should be revised to include these drawings.
>2.
There seems to be a discrepancy with the high end of the soil concentrations for Ra-226. Specifically, in Section 3.3 on page 2, the maximum is identified to be 870 pC1/g;.in Section 4.3 on page 6, the T
range is identified to be 1 to 181 pC1/g. Since the data in Table 3.1 support the higher figure, it appears that the 181 pC1/g is a typographical error. The REA should be corrected.
3.
The penultimate )aragraph on page 4 (Section 4.3) contains the statement.
"Therefore, 40 C R 192.21(a) is applicable." This citation is the risk-of-injury supplemental standard. Since DOE's discussion addresses the supplemental standard for high cost relative to benefits, this is apparently a typographical error and the citation should be 192.21(c).
4.-
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The discussion in Section 4.3 on pages 5 and 6 needs to be reworded to make clear the basis for DOE's postulated structure at the site of the
- acid pond. The discussion appears to indicate that the basis is because there is the possibility of a future residence constructed on the site, rather than that the basis is to provide a conservative estimate of radon concentrations in an open land area.
5.
As'part of the discussion regarding the postulated structure, DOE makes allusion to the relatively low cost option of installing a radon vent system, should a structure with a cellar be constructed.
In the Addendum-d-
to-Appendix E, page E-3, the last statement indicates that the deed could be or will be annotated to allow for $2000.00 for installation of a radon vent system._ It is not clear whether such annotation _will take place, or who will be providing for the cost of the installation. This may be a speculative argument on DOE's part, but the resulting working levels and indication-of land annotation would raise additional concerns. Since the structure is hypothetical, this addendum is not necessary and its deletion should be considered.
6.
In Appendix F, on page-1 of the response to NRC's October 19, 1989 comments, DOE.did not address the ALARA provision requirement of 192.22(b). DOE's changes to the text in Section 4.3 merely repeats the requirement of 192.22(b) without indicating that its cleanup activities satisfy the ALARA provisions. We note that the last response on page 3 of the response to comments seems to address the ALARA provision better than the REA text i
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DG/M.MATTHEWS/2/21-does. Similar discussion addressing ALARA should be provided in the REA text.
7.
On page'4 of NRC cossents/D0E responses in Appendix F, the first DOE response indicates that "40 CFR 192.12 is not applicable to open lands."
This is incorrect and should be revised to state that 40 CFR 192.12(b) is not applicable to'open lancs.
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