ML20008F859
| ML20008F859 | |
| Person / Time | |
|---|---|
| Issue date: | 04/23/1981 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Schaffer W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20008F857 | List: |
| References | |
| REF-WM-52 NUDOCS 8105120198 | |
| Download: ML20008F859 (8) | |
Text
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NUCLEAR R O
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APR 2 31981 bM-52 O
MEMORANDUM FOR:
Docket Files FROM:
William M. Shaffer III, Project Manager Uranium Recovery Licensing Branch
SUBJECT:
NRC STAFF CONCURRENCE IN DOE UMTRAP REMEDIAL ACTION PLAN -
FIRE STATION NO. 1 VICINITY SITE, SALT LAKE CITY, UT BACKGROUND The DOE, by memorandum dated March 5,1981 (Enclosure 1), reodested the NRC staff to review and concur in the DOE proposed Remedial Action Plan (RAP) for the fire station site at Salt Lake City, UT.
This site is a designated high priority UMTRAP vicinity site contaminated with uranium mill tailings from the Salt Lake City designated processing site (the Vitro site).
Because use of the station has been discontinued since 1980 as the administration and communica-tion center for the Salt Lake County Fire Department, as well as an important equipment concentration and dispatch point, response times to fire alarms have increased such that fires double in size during the increased time. The RAP that DOE has developed will restore the fire station to its intended use as rapidly as feasible.
Because of its unique importance to critically needed community services and the extent and characteristics of the contamination at the site, it has been agreed between NRC and DOE staffs that the NRC staff should formally and separately concur in the RAP for this vicinity site with a view to conducting remedial action as early as practicable. Normally, NRC staff concurrence in remedial action at an UMTRAP vicinity site would be obtained as a result of staff participation in the development of the EIS or EA for the associat.ed p ocessing site.
Preparation of the final EIS for the Vitro site will, novever, take place considerably in the future.
It was therefore agreed to proceed in this case in advance of that EIS.
The proposed RAP was defined in the February 13, 1981 Final Radiological and Engineering Assessment (REA) for the fire station that was prepared by Ford, Bacon & Davis Utah (FBDU) Inc., the DOE remedial action AE contractor at Salt Lake City.
Staff review and concurrence in the REA, and thus the RAP, was requested by the previously referenced March 5, 1981 memorandum to NRC from the DOE UMTRAP Project Office (PO).
PROPOSED REMEDIAL ACTION The proposed course of action is to excavate tailings from beneath the fire station buildings themselves, excavate tailings from the site exterior to the buildings, replace all removed tailings with clean fill, and restore the building and site to its existing physical condition. After completion of the 8105120lDe
4 O% 4 N Docket Files 2
remedial action, the radiological environment at the site will meet the EPA April 22, 1980 Proposed and Interim Standards for the Cleanup of Open Lands and Buildings Associated with Inactive Uranium Processing Sites.
Total cost and duration of the proposed remedial action is $740,000 and 140 calendar days.
The fire station owner, Salt Lake County, has proposed that some general building and s'ite improvements be made at the same time the remedial action is conducted, though to be paid for by the county.
In addition, the DOE plans to integrate remedial action at the fire station with that at two adjacant contiguous properties that are overlying the same general area of fill that originated at the Vitro site. This was documented in the March 13, 1981 letter (Enclosure 2) to NRC from the DOE UMTRAP P0. All removed tailings would be interimly stored at the Vitro site and be disposed of as part of the overall remedial action for that processing site.
The presently estimated total quantities of tailings to be removed, including the two adjacent contiguous contaminated properties (a park and a low income housing project) are given in the following table:
Site yd3 of tailings
% of total Fire station site (beneath buildings) 1,840 26 Fire station site (exterior to buildings) 3 55 M,600 El Fire station site (subtotal)
Park site (adjacent) 690 10 Low income housing site (adjacent) 610 9
l Total 3"5T6 I65 ALTERNATE COURSES OF ACTION In addition to the proposed course of action, there are two alternative courses of action that have been considered as feasible:
1.
No action; maintain site in existing state.
2.
Demolish fire station buildings; excavate tailings and replace with clean fill; build new fire station buildings.
Alternative 1:
No Action This alternative is neither recommended by DOE nor could it be supported by the staff for the same following reason:
The Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA) requires remedial action to be undertaken when EPA Inactive Uranium Processing Site Standards are exceeded. Two of these standards, established by EPA as Interim Standards for Cleanup of Open Lands and Buildings on April 22, 1980 (ref. 45F227366), are for indoor radon daughter concentration (RDC), including background, and for indoor gamma radiation, above background.
i
Docket Files 3
APR 2 31981 i
The following table compares these standards to the current situation at the fire station:
EPA Fire Station (1st Floor)
Standard Low g
M Indoor Gamma Radiation (mR/hr)
.020
.016
.038
.128 Indoor RDC (WL-working levels)
.015
.009
.308
.378 Thus, for both standards, even the average level inside the fire station exceeds the EPA limit by a wide margin. Therefore, under the UMTRCA, remedial action is required, and Alternative 1) would not be permissible.
Alternative 2:
Demolish, Excavate, Rafill, Rebuild This alternative would result in a more simplified approach, in an ease of construction sense, to the actual removal of the tailings themselves than in the p-oposed course of action. However, because of the subsequent cost of constructing a new fire station on the site, the cost to implement this course of action is currently estimated by the DOE at $1,211,000. Since no increased fire control capabilities would result, the proposed course of action is clearly favored because it would provide the same post-cleanup radiological results and restored site capabilities at approximately 40% less cost.
IDENTIFICATION / RESOLUTION OF ISSUES During the course of reviewing the February 13, 1981 REA, as originally submittr.d by DOE, certain issues were identified that the staff felt should be resolved and documented prior to the staff concurring in the proposed remedial action plan. These may be categorized as listed below, and a discussion of each follows along with the issue's resolution or recommendation of an approach to resolution.
1.
DOE internal documentation / decisions 2.
Overall scope of remedial action, and 3.
Specific treatment of groundwater considerations.
DOE Internal Documentation / Decisions A key element of the proposed RAP, allowing for remedial action to proceed at the fire station well ahead (by at least one year) of the Vitro site, is that tailings removed from the fire station would be stored at the Vitro site and disposed of ultimately with the Vitro site tailings.
In order to permit the DOE to do this, a Use Agreement must be developed and signed by DOE and the current Vitro site owner, the Central Valley Water Reclamation Facilities Board (Central Valley), a quasigovernmental water utilities entity.
Meetings to develop the Use Agreement were held between DOE, Central Valley, and the State of Utah on February 25 and March 16, 1981.
1 Docket Files 4
APR 2 31981 As of March 30, 1981, the DOE-VMTRAP Project Engineer, having responsibility for the fire station remedial action project, advised the staff by telephone that it appears both sides have agreed on content of the Use Agreement & it has now been turned over to DOE and Central Valley legal staffs for appr priate wording development.
The DOE thus assumes a signed Use Agreement will exist in the near future.
The staff has no reason to doubt this and therefore assumes that the RAP it is being requested to concur in has a firm basis with regard to relocation of the fire station tailings.
In the area of environmental review documentation and decisions, the DOE had not yet determined its own position regarding:
- 1) whether the fire station could and should be treated from an NEPA standpoint as separate from the Vitro site and other Salt Lake City vicinity sites; 2) if treated separately, what sort of environmental review document was required (and specifically whether Appendix A to the REA could serve this purpose) and 3) whether a Finding of No Significant Impact (FONSI) was warranted based on the environmental analysis to date.
DOE internal resolution of these matters was requested by the February 27, 1981 letter (Enclosure 3) from the DOE-UMTRAP P0 to the DOE-HQ NEPA Affairs Division (NAD).
The March 13, 1981 letter (Enclosure 4) response from DOE-NAD established the DOE positions that:
1.
The proposed fire station remedial action is not a " major federal action" and therefore neither an EA or EIS is required for the proposed RAP.
(The letter did not state. that Appendix A to the REA was specifically an adequate environmental analysis, however.)
2.
Based on urgency of public needs, remedial actions at the fire station could proceed separately in advance of those proposals for the Vitro site, and therefore in advance of issuance of its EIS.
3.
A FONSI is warranted in this case.
These determinations allowed the staff to view the February 13, 1981 fire station REA as containing the final DOE proposed remedial action plan and DOE's analysis and judgment that its environmental consequences have been determined to be negligible.
It had previously been agreed between the NRC staff and the DOE-HQ UMTRAP staff, at the February 20, 1981 meeting at Silver Spring, MD, that the fire station was an unusually significant vicinity property warranting separate consideration from the Vitro site.
Based on its independent review and analysis of the situation, the staff agrees with DOE positions 1-3 as noted above.
Overall Scooe of Remedial Action (marked up " Figure 5" extracted from the REA, p. 26), shows that at this geographic location, tailings from the Vitro site are present not only on the fire station property but on adjacent park and low income housing properties.
It was felt by the staff that:
- 1) remedial action at the fire station should be integrated as much as feasible with that at adjacent properties since, in effect, all three were one " vicinity site"; 2) the REA did not clearly convey what DOE had planned, if anything, with a view to achieving
Docket Files 5
APR 2 3 381 such integration; and 3) it would be preferable to concur in an RAP that, at least conceptually, if not in detail at this time, did achieve the suggested integration.
The staff had telephone discussions with the UMTRAP PO on this matter that resulted in the previously referenced March 13, 1981 letter (Enclosure 2) to NRC from DOE.
It is felt by the staff that the letter adequately clarifies the matter and documents the basis for the integrated remedial action planning that it also had felt was desirable.
The letter can be looked on as a clarifying amendment to the REA and is appropriate to note in the ultimate letter to DOE responding to its REA concurrence request.
Specific Treatment of Groundwater Considerations The REA did not discuss any potential impacts that the tailings at the fire station may have had on any groundwaters in the vicinity.
It is, however, recognized that removal of the tailings can only have a beneficial long-term impact on groundwater in the event there had been contamination present due to the tailings being used as fill at that location.
In considering this matter, though, the folicwing points were noted:
1.
The major quantities of tailings have been there for an extended 24 year period since the original part of the fire station was completed in 1957 (REA p. 2).
2.
The original character of that location, prior to filling with tailings, was swampy (REA p. 4).
3.
Tailings on the fire station property have been found in borehole tests to extend down as far as 90 inches (REA p. 31, A-1).
4.
The water table at the site is generally considered to be 9 ft (108 inches) below grade (REA p. A-4).
5.
One borehole test showed tailings down to 110 inches (REA p. 32) though this hole is on the low income housing property and not the fire station property (confirmed by telephone with DOE-AL on March 17,1981).
l The above, taken together, seemed to indicate the possibility that groundwaters in the vicinity have likely become contaminated over the years.
The staff I
therefore discussed this matter with Richard H. Campbell, Project Manager, and David Ball, Project Engineer, of the DOE UMTRAP P0 to gain further information and to determine to what extent remedial action planning for the fire station i
would consider potential groundwater contamination.
l The following was indicated:
1.
No contact of tailings with water was discovered in boreholes on the fire station property.
2.
Water was contacted in the one hoie on '.he low income housing property that contained tailings down to 110 ini.es.
l i
APP. 2 3 E61 Docket Files e
3.
All prope.rties in that section of the metropolitan area are connected to city water mains.
4.
There are no known users of the groundwater, which is of low quality, downstream of the fire station.
However, there has been no survey to confirm this and none has been planned.
5.
The "Plens and Specs." for the remedial action bid package to potential DOE remedial action contractors will specify that if a contractor were to encounter water seeping into excavations, the water should be pumped out, collected, contained in tank trucks, and transported to the Vitro site for disposal.
Tne same provisions are to apply for any significant quantities of surface water runoff into excavations.
As a result of the discussion the following was agreed to which the staff believes should alleviate any concerns it may have had regarding this matter:
1.
At the staff's suggestion, any such water so collected as in 5. above, will be sampled to determine types and levels of contamination.
2.
The NRC staff will be involved in the formulation and concurrence of any mitigation plans that acy be required should such water be encountered in tailings excavations.
3.
Unless groundwater is enc'ountered during excavation, the need for any specific mitigating plan will not exist.
l RECOMMENDATION l
The staff recommends that concurrence be provided to the DOE in the proposed remedial action plan to clean up the Fire Station No.1 Salt Lake City vicinity i
site based on the above discussion and with the following conditions:
1 1.
The proposed remedial action is within the remedial action scope as defined in the February 13,1981 REA.
2.
Integrated project planning be implemented to incorporate the park and low income housing remedial actions to the maximum extent achievable into the remedial action plan for the fire station property as discussed in the DOE's March 13, 1981 letter (Enclosure 2).
3.
Collection, sampling, and disposal of any ground or significant quantities of surface waters encountered during tailings excavations will be as described in the section of this memorandum entitled " Specific Treatment of Groundwater Considerations."
I 4.
The DOE will provide prompt notification to the NRC staff of any groundwater contamination encountered, and participation by NRC staff will be solicited
l Docket Files 7
APR 2 31981 in formulation of any mitigation seasures to alleviate consequences of such contamination as may be deemed necessary.
WhAE N.
K William M. Shaffer III Project Manager Uranium Recovery Licensing Branch Approved:
4-e
'Ross A. Scarano, Chief Uranium Recovery Licensing Branch Case closed 33000052M01E
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U.S. DEPARTMENT OF ENERGY
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kO-ALBUQUERQUE OPERATIO S OFFICE oATe EEB 2 7.1981 IRemOZGndum
,m,1, ATTN OF:
UMTRA:DB susacT:
IEPA Determinations for the Salt Lake City, Fire Station No.1 Vicinity Property TO:
Robert J. Stern, NEPA Affairs Division /EV-12, Mail Code 4G-064, DOE Headquarters Attached is the Radiological and Engineering Assessment (REA) for the proposed
- )
remedial action at Fire Station #1 in Salt Lake City, Utah, pursuant to and in accordance with the Uranium Mill Tailings Radiation Control Act of 1978. Fire Station #1 is a high-priority vicinity erocertv. so denienated by ASEV on December 10, 1980. which is contaminated with uranium mill tailings derived from the Vitro inactive uranium mill tailings pile (hereinafter referred to as the " Vitro Site").
Appendix A of the REA, " Analysis of Environmental Effects," identifies and evaluates the potential environmental effects-and appropriate alternative courses of action in connection with the proposed remedial action. The REA, Appendix A, and.the information contained in this memorandum are submitted to your office for vour determination on: Q} the a c-e n
- nM ii ty of evaluating the environmental effects of remedial action on f
this vicinity oronerty on an individual basis rather than in a single, com-l prehensive environmental document evaluated for the Vitro Site and vicinity
- l-property remedial actions, (reference your letter dated September 23, 1980, to Robert W. Em=ney, regarding UMIRA NEPA compliance); and (2) the appropriate
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form of the envi~~~-*= ' -*'A av dar ment required.
It is i-,erative that we nroceed with this specific remedial action g
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before an Q), can be preparec and made final on the total UMTRAP activity in Salt Lake City, i.e., the remedial actions required on the Vitro Site and all other vicinity properties.
Your letter dated September 23, 1980, to Robert W. Ramsey states that "in those limited instances where it can be shown that there would be a substantial public benefit by taking early action on a vicinity property, the property may be treated in a separate environmental document." Early remedial action on Fire Station #1 will certainly have a substantial public benefit.
Fire Station #1 was built on land brourbt up to e-ade with emiline= from the vitro m e.
as a result, radioactivity measurements in Fire Station f1 show average gansia radiation levels of 0.034 mR/ hr and radmn ds"eh***
Tevels of up to 0.378 WL, well above the - **d EPA standards (46 FR 2256, January 9, 1961) of 0.02 mR/hr and 0.015 WL, respectively. The crocosed action is to excavate and remove the uranium mill tailings from under and around the build-Ing and replace them witn clean till.
. tem-yorartAy scoreo on the Vitro Site until all of the tailings at the Vitro Site
-are staotitzec or reioca cu.
As the enclosed REA states, approximately 6.330 cubic vards of tailings material vill have to be moved to the main tailines site. This will add less than 11 to the volume of tailings that must eventually be moved to a permanent s
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l disposal site or be stabilized in place.
Since this is a small volume, as compared to the main tailings pile, this separate remedial action should not limit or prejudice subsequent actions or alternatives on the overall site decision.
Environmental effects outside of this vicinity property will be minimal.
- b = H an e center for the Sal _t Fire Station #1 was the administrativ.
=a d Lake County Fire Department as well as a station from which fire suppression equipment was dispatenea. As a result of these radiation levels, the county has had to discontinue the full-time use of this station.
It is presently insed only for vehicle maintenance. As a result, the fire protection in this portion of the city, and countv. has been significantly recuce_a.
mesponse
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-"-k rhat a fire v111 almost double in size mees w atarms u.
durim en u extended response time.
It is well known that a prime considers-l tion in fire suppression is early action. Due to this potentially dangerous situation, we are pressed by city, county, state and local officials, and the general public, to act as soon as possible to return Fire Station #1 to its intended use.
eThe reason for planning to cover Fire Station #1 in a separate document in
- advance of the EIS is to enable remedial action on.L'.
property to commence fat an earlier date.
If we are required to wait for the preparation of an FEIS enan a vear's time vill ba on the total Salt Lake City remedial actions, more lost. The Vitro Site is one of the two highest priority sites in the UMTRA Sect, mainly because it is in one of the major metropolitan areas of the West. The 20, 1980, Table 3-5) g preliminary DEIS (proposed standards of August attributes about 40% of the health effects exeected from all the tailines piles in the country (if no action is taken) to this oile and its associated vicinity properties. The great bulk of this radiation exposure is to the estimated.iol,uvo people within six miles of the main pile.
Immediate remedial action for this vicinity property is essential for implementing the whole project on schedule.
We request that you provide us with the appropriate NEPA determinations as soon as possible. For the reasons discussed above, we believe it is critical that we implement remedial action in the near future, that Appendix A to c5 REA is a sufficient environmeatal review document, and tnat there would be a isubstantial puonc genenc dy cau..g early action on Fire Station fl.
If you have any questions regarding any of the above, plea'se contact David Ball at FTS 344-3941.
Sincerely, y
' chard H. Campbell Project Manager bp:02-24/0226C Uranium Mill Tailings Project Office Attachment See Page 3 for distribution
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FEE 2 71981 ec:
L. Anderson, Dept. of Health, State of Utah, w/att.
L W. Ramsey, NE-301, DOE HQ, w/att.
W. E. Mott, IV-14, DOE HQ, w/att.
4 J. W. McKiernan, SNL 4542, w/att.
Y Shaffer, ERC, w/att.
E A. Earquez, OCC, DOE-ALO, w/o att.
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NEMORANDUM FOR ROBERT W. RAMSETKEMEDIAL ACTION EROGRAM j
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ROBERT J. STERN, DIRECTOR 8
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NEFA AFFAIRS DIVISIC2 MATIONAL ENVIRONMENTAL POLICY ACI (REPt.T '
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SUBJECT:
DETERMINATION FOR THE SALT LAXE CITY, '
FIRE STATION NO.
VICINITY PROPERTT 3 -
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. 'ife have reviewed your February 27,1981, memorr.ndum reqisenting a determination under the National Envird::::=utc1 Policy Act (42 U.S.C. 4321) for the proposed remedial action at the
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Salt Lake City; Firo Station No.1, vicinity property.
l infortantion provi ed d in your memornaduna and Desod on th2 odditional background inatocials contained in ttc radio-the fire 1;
logical and onginearing assessment prepared foiafter cor.saltatica with
'.7 station property, wo have determined,
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the Office of the Concral Counsel, that the prc posed uctiou clearly is not a r...'or Federal nation signifienntly affonting the quality of the human environacat.
Thereform, no unvirutt.
mental nasessment or environnaental impact stattaient is-required.
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,,y Discussion The proposed action in to remove approximately 6,33h ouble yards of contaninnted materials fecz under and cround the fire station and.storago bi:11 dine, and replace it with cicTs fin.
The coatrainatud mate.*ials Pt.mov.d i' rom the fire stat na propoety would be terinsported by truck and retaned for(The Vit.'o sita is the temporary stornge. to the Vitro sito.the Salt Luxc City nroe.
nain uranium mill es111ngs pile it, The contaminscod matcrials at the tire station ut.ro renoved from tho Vitro uite during the pericd from 1953 1957 at:d u s e d-i hJ for fill.)
l The proposed action would procede completion of the writrond
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11tro.:ite and montal impach statetaaat being prepared for the We have previously
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romainin6 associated vicinity properties.
f 23, 1980) sjainst improper
. advised Olemorandum dated Septemberso6 mentation of related actio In this case, the proposed interim action is tased on tt.e nood n-,
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- 9 to return ths' fire Justion to its intended use as soon as '
.t As a ru sult, of elotat.ed gamma radiation leJola and radon dtunhter *
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(average of 0.034 isill:.rcentnens/ hour)the county ol' salt L.tha.-
.2 levels (up to 'O.378 workinn IcVels),
0 has had to diacontinuo the full tine una of the f:.re stationi
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iI and currently uses tito station only for vehicla Haintenance.
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Concequently, the fire proccction in this portica of tho and responaa ecunty and city has boon significantly roduced, he becofits of tines to alargs have increasod.
He agree that t
{ l puompt action justify procaoding in advance of tho completion of the environuuntal impact statement.
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I The Council on Environmental Quality NEPA resulttioun (Seo' tion l
1506.1) upecify enah imtil on agency issucs a ecoord ar-docision (follouing preparation of on environeettc1 inpoet 1l states it), "no action concerning tha proposal ::. hall bo taken (1) hase an adversa env.'.ronicental impact; or (2)
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which would:
- 'he proonsed limit the choloc of reasonable altecrnativos."
action uould produce ueglinible effects on the human caviro.uaunt; it would not limit or prejudice subsequent actions or alterns-i tives, which wf11 be fully ansessod in tho environmental j
impact statewns for the Vitro site and associated vicinity
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,e properties.
A copy of thiJ Ef.Rornudum should bo retained in your prn.inct file no n record of the flEl'A revicu pceformed for thia aleti m.
Should you require additional informt. tion or i'u.'ther sagtistauce 3
on this action, p). esso contact Mr. Itobart Stric.tler (252-4510)
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Department of Energy I '~#".!!l. j9 4 Albuquerque Operations Office \\b Fr 1 ca A.
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Ross A. Scarano, Chief Uranium Recovery Licensing Branch Office of Nuclear Materials, Safety l
and Safeguards (>5 SS483)
U.S. uclear Regulatory Commission fiash. ;gton, DC 20555
Dear Mr. Scarano:
CONCURRENCE FOR REMEDIAL ACTION AT THE SALT LAKE COUNTY FIRE STATION #1 On February 27, 1981, a copy of the Radiological and Engineering Assessment (REA) for the subject property was submitted to William Shaffer of your organization.
Please provide us your concurrence or coments on this remedial action as soon as possible. We are telefaxing a copy of this memorandum to you to expedite the concurrence process for this property.
Ford, Bacon 6 Davis Utah (FBDU) has been instructed to provide you two additional copies of the REA to facilitate your concurrence.
?;ith respect to future remedial actians on vicinity properties in Salt Lake City and other UhfrRA locations, re expect to follow the concurrence procedures being developed at this time.
If you have any questions regarding this matter, please contact David Ball of my staff at FTS 844-3941.
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Sincerely, p
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dhard H. Campbell, Project Manager MAR f 3 IO81 >
7 Uranium Mill Taliings Proj ect Office
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,r, W. Shaffer, NRC
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Y W. Mott, ESED, EV-14, D'JE 'HQS' D. Groelsema, RAPSO, MS B107,. DOE HQS/NEW gipsztds77 FP" c
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.g Department of Energy Albuquerque Operations Office P.O. Box 5d00 Albuquerque, New Mexico 87115 g.g,
Ross Scarago, Qaisf Ursalum Recovery I.icensing Branch Office of Nuclear Materials, Safety
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and Safeguards (MS SS483)
- 5. S. helear Regulatory Cosmaission Washington, DC 20555 Dear Boss thia letter is to confirm some information which was diactsaed between. William Shaffer of your organization and David Ball of g staff.
Le s'bject of the u
conversation was the remedial actica for the Salt Iake Cotney Fire Station and the adjacent properties.
We are scing to issue the Invitation for Bida in the near future for the l
implementation of remedial action at the Fire Station and Erracey Park, an adjacent property south of the Fire Station.
It. is anticipa.ted that a con-trast for this work will be averded in May.
At the present time, Ford, Bacon and Davis, Utah, under our direction, is performing the engineering for another designated property (Iow income hous-ing) just north of the Fire Station.
Upon completion of this engineering effort, this remedial action will probably be performed at an addition to the aforementioned contract for the Fire Station and Harmony Park.
If this work cannot be negotiated reasonably with the Fire Station remedial action contrac-tor, then it will have to be performed as a separate procurteent as soon as possible, so as to take advantage of the radiological and security facilities already in the area.
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rd B. Campbelf Project Manager aj:03-13/0350C Uranium Mill Tallin3s Project Office i
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