ML20023E242
| ML20023E242 | |
| Person / Time | |
|---|---|
| Issue date: | 05/31/1983 |
| From: | Martin D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | White M ENERGY, DEPT. OF |
| References | |
| REF-WM-39 NUDOCS 8306150233 | |
| Download: ML20023E242 (3) | |
Text
V\\
/w { Vf*]
e / Distribution:
s Y (,31 cord file Y!Il ?r$c!__N b
Dcocii;o, WM:P_roject Fil^.WM_39
=,
pgp' g
WMLL r/f K
NMSS r/f bEU'
_DJsltj)ubon; DEMartin CAF1ory
, ~
MAY 31 1983 GNGnugnoli (Retum la'IdGf3'S5)~p-EFHawkins r' #
PHLohaus WMLL:CAF LBHigginbotham WM-39 REBrowning Dr. Maiy G. White Division of. Remedial Action Projects Office of Nuclear Energy US Department of Energy Washington, DC 20545
Dear Dr. White:
The draft document " Surface Gama-Ray Measurement Protocol for Small Parcels on Open Lands dated April 1983 was reviewed and we have enclosed comments. Because the procedures and techniques described in this document may become part of a remedial action plan (RAP) for an UMTRCA designated site, we would appreciate the opportunity to review and concur with the final version prior to issuance.
Please contact Mr. Claude A. Flory of my staff at FTS 427-4648 should any clarification of these comments or other information be necessary.
Sincerely, Original Sigied By,'
8306150233 830531 PDR WAST ~
WM-39 PDR Dan E. Martin, Section Leader Uranium Recovery Licensing Section Low-Level Waste Licensing Branch
(
Enclosure:
Comments on DOE Manual for Gama_ Ray Measurement Protocols s
3 39/mab/83/05/10/0 DiC :WMLL{q
- WM1
- WMLL
____:-_gignli_ _ _ _ : - -g,-f,_ _ _ _ : _ _ _ _ _ _ _ _ _ _ _ _ : - _ _ _ - - _ _ _ -
- G h
- DEMartin NAME.:CAFlory:mb DATE' :03/05 /?,F(0 :83/05/ g
- 83/05/g.7 t
ENCLOSURE A.
General Comments 1.
These protocols are limited to surface measurements on open lands and are intended to be applied only at vicinity properties. Other measurements which are normally made on vicinity properties include those for detecting and removing contamination located below the 15 centimeter surface layer of soil and beneath buildings.
For the sake of completeness, protocols for these other type measurements could either be referenced or incorporated in this document.
2.
Section 4.4 This section states that " firm requirements for site verification have not been adopted" and that "the procedure...may be modified when final verification requirements have been received from the Remedial Action Program Office." In order to support NRC's concurrence role in remedial action verification, final procedures for verification surveys should be reviewed by the NRC prior to implementation of remedial action.
3.
Quality Assurance (QA) is also an important part of remedial action. Because the section on QA, Section 6, was not included in the draft document, we would like to be able to comment on a draft copy of this section.
B.
Specific Comments 1.
(Section 3.5) It appears that the disequilibrium factors for the calibration facility pads are not well known. What uncertainty does this imply in the calibration factor derived from using the pads?
2.
(Section 4.0) Guidance should be given for determination of l
soil moisture and radon disequilibrium to be used as correction factors. Soil moisture and radon disequilibrium factors for each site, which are fairly representative of the whole site, should be obtained for valid in-situ measurement results.
3.
(Section 4.3.3) Several soil samples should be taken at the bottom and sides of completed excavations for the purposes of verification. Restoration of the site would not necessarily have to wait on the analysis of these soil samples.
4.
(Section 4.4.2) A minimum of three soil samples for each representative soil type should be taken and correlated to the equivalent Ra-226 determinations at the same sample location.
.t
' W [?&
hf gA
-.j.,-..,
T 2
4 These same soil samples could also be used to verify potassium and thorium background and moisture and disequilibrium correction factors. Soil samples taken in the excavated hole could be used for verification of cleanup.
If any of. these samples exceed the standard then subsurface measurements (borehole logging or soil core analysis) should be done at the-location.
4 5.
(Section5.5) The equation used for LLD, Equation 5-4, should be applied to determining the lower level of detection of an instrument based on the standard deviation of the count rate when counting a blank sample..It cannot be used for calculating the confidence level of soil in the presence of a variable background unless the background data is transformed from a log-normal distribution to a normal distribution.
t Y
e a
k
,~;
~;,
' w l,
'N
's, p_"L'll - *l.
j$ 2 5.
Nh5
_