ML20039B816
| ML20039B816 | |
| Person / Time | |
|---|---|
| Issue date: | 10/22/1981 |
| From: | Scarano R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Ramsey R ENERGY, DEPT. OF |
| References | |
| REF-WM-55 NUDOCS 8112230593 | |
| Download: ML20039B816 (8) | |
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Robert W. Ramsey, Jr., Program Manager g-Remedial Action Programs, HE-301 j
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This letter is to provide, by Attachments I and II,10C staff ceracents on two documents we recently received related to the DOE's planned remedial action project at the Central Valley Water Reclamation Facility (CVWRF) UMTRAP vicinity property in Salt Lake City,IMsh. Attachment I provides our couanents on the August 1981 Ford, Bacon and Davis Utah, Inc. (FBDU) Draft Radiological and Ungineering Assessment (REA) for remedial action at the CWRP as trans-mitted by the September 4, 1981 letter to William M. Shaffer, III of my staff from David Dall, Project Engineer, UMTRAP Project Office, DOE-Albuquerque. By Attachment II, we are also providing cocunents on the August 17, 1981 FLDU pre-pared document entitled " Justification for Exception, Central Valley tiater Reclamation Facility Vicinity Property Pvieting Structures." This document purports to provide justification for granting an Exception from meeting EPA 40 CFR 192 Interim Cleanup Standards in conducting the proposed remedial action alternative involving leaving tailings and other cont minated materials under and around the 16 large concrete CVWRF trickling filter, clarifier, and digester tanks. We anticipate the DOE to request NRC concurrence in this exception in the near future.
Regarding this forthcoming request, our initial reaction is that the moste important issues to be addressed when considoring the exception are a) what are the health and safety impacts of leaving the tailings undar and around the 16 tanks and t) what is the basis and what specific plans and controls will be instituted for assuring the appropriate disposition of the tailings in case of a change in CVWRF land use.
In our judgement theso issues are not adequately or accurately addressed in the referenced August 17, 1981 version of the Justification document.
In our judgement both the REA and Justification, as reviewed and consnented upon here, are lacking in adequate depth, accuracy, and cons &ttency between I
them. To facilitate a meaningful and expeditious review by our staffs, we 9112230593 811022 PDR WASTE WM-55 PDR I
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vb rococrend that the contractor be encouraged to exarcise better quality control of their documents, even in preliminary form.
Both documents referred to in this letter were discussed at the meeting on Septenbar 23, 1981, at NRC-Silver Spring, MD, between my staff, David Ball, and Dorald H. Groelsema of your staff. The coz: rents provided on Attachrents I and II were presented generally to them at that meeting. We look forward to coatincing to work closely with the DOE on the development and scoping of the optimun remedial action plan for the CWRF leading ultimately to NRC concurrence in the final remedial action plan for the project. Any questions you may have on these comments should be addressed to me or William M. Shaffer, III (FTS 427-4538) of my staff.
Sincerely,
/5 Ross A. Scarano, Chief Uranium Recovery Licensing Dranch Division of Waste Manager.ent cc With Attachments Richard H. Campbell, DOE-Albuquerqua David Ball, DOE-Albuquerque Donald H. Groelsama, DCE-HQ Dr. William E. Mott, DOE-HQ Robert J. Stern, DOE-HQ s
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Attachment I 2
NRC Staff Comments On i
August 1981 l
" Draft Radiological and Engineering Assessesnt (REA) for j-Central Valley Water Reclamation Facility (CVWRF)"
1.
Secs.1.1 and 1.2 (p.1-1) - These two sections taken together give the misleading impression that remedial action would be performed to meet EPA Standards under all options considered.
However, the proposed course of action would in fact require an exception from the EPA 40 CFR 192 Interim Standards referenced at 45FR27366.
It would be preferable to simply.
state that these standards are performance goals for.all UFTRAP vicinity properties and discuss later in the REA to what extent they will me met.
for each option.
2.
Sec. 2.1 (p. 2-1) - Beginning at this point, and continuir-g throughout
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the REA, all data derived from the vicinity property boundaries should be
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corrected so that it is related to the actual configuration of.the designated vicinity property alone.
It is our understanding that FBDU prepared this Draft REA on an incorrect basis which included a part of the Vitro site tailings piles themselves as a part of the CVWRF vicinity property.
3.
Sec. 2.1 (p. 2-1) - If the northern CVWRF site boundary is 'open and borders a creek, the site, by definition, can not be adequately " fenced" in our judgement.
In addition, to help clarify the overall picture regarding boundarios, the location of all associated ditches and creeks l
should be presented on a summary plot plan of significant features at the i
site.
4.
Fig. 2-1; This Figure would benefit from appropriate highlighting to clearly show the relationship of the CVWRF to the Vitro processing wite.
5.
Figs. 2-2 and 2-5; It would be beneficial to have these Figures marked i
with the CVWRF vicinity property boundaries.
p 6.
Fig. 2-7; This Figure is potentially very useful in that it should show the relationship of Central Valley's planned expansion on the CVWRF vicinity property site itself to their planned expansion onto.the Vitro processing site.
However, it is currently so difficult to read that one area can't be easily distinguished from others.
In addition, it would i
appear to incorrectly show some incorporation of the Vitro site into the i
CVWRF boundaries assumed for study in the REA.
7.
Sec. 3.1 (p. 3-1) - This section should summarize the gamma survey data l.
for the higher gamma level readings taken as well as the lower levels l
noted. We believe gamma surveys should also have been done in the area-of the sludge drying beds, unless technically unfeasible, because they t
cover a large area and appear to be bordered by hot spots or areas of l
.approximately 100 pR/hr gamma radiation.
As a consequence, it may i
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2 ultimately prove unreasonable to have assumed contamination in excess of 5 pCi/gm in the soil under these beds to a depth of only one foot.
8.
Sec. 3.3 (p 3-2) and Fig. 3-4; This section inadequately discusses the boring programs implemented to characterize contamination depths.
A table should be provided, keyed to Fig. 3-4, presenting the data for both tha FBDU and the Oak Ridge National Laboratory '0RNL) programs.
Related also to Comment 7, we note from Fig. 3-4, three apparent ORNL bore holes bordering the sludge drying beds contaminated in excess of 5 pCi/gm down to levels of 3, 4, and 5 feet.
However, contamination denth for the beds is assumea by FBDU to be only 1 foot.
In addition, since 5B00 did not drill directly in the areas most related to the potential request for exception from EPA Standards, we infer that the ORNL results are satis-factory to DOE and were used for the purposes of estimating the tailings present.
If that is the case, it should be so stated.
If a mixture of data was used to scope and evaluate the options, then that aspect should also be discussed.
9.
Sec. 3.4 (p. 3-3) - This section should present and discuss the soil sample data obtained by FBDU.
It would also be beneficial if some discus-sion of any available ORNL soil sample data war, presented.
This would be particularly so if the ORNL data was directly used in estimating the scope and cost of remedial action optiont.
10.
Sec. 3.5 (p. 3-3) and Table 3-1; We note that the radon working levels measured inside buildings on the site are extremely low and were taken over only one 4-hour period in the middle of sumi r.
Any comparable data used to designate the property by the DOE Environmental and Safety Engineer-ing Division (ESED) should also be considered and presented particularly if taken over a more widespread time period.
Table 3-1 and the discussion should also reflect and present background working levels. We are concerned because, to our understanding, background working levels at the relatively nearby Salt Lake City Fire Station No. 1 vicinity property have been quoted at.00" WLs, yet apparent total WLs measured in buildings much closer to the Vitro site are in the.001.002 WLs range.
11.
Sec. 3.6 (p. 3-4) - The discussion of potential tailings and other materials quantities to be moved appears inappropriate at this point in the REA and should be deleted from this section. To our knowledge, they are inaccurate as presented in any event.
This section should, however, clearly charac-terize with adequate discussion, map references, and numerical data, the quantities and activity levels of tailings associated with each of the various major areas on the CVWRF site.
Considering Fig. 3-4, we do not agree that contamination around the existing structures should be charac-terized as 3 feet in depth.
The ORNL data would appear to show, for the areas of most concern on the site (the 170 foot diameter filters), depths more closely approximating 4-11 feet on both sides of the site.
In addition, if there is a significant and distinctive 100 x 900 foot strip of contaminated land on the west vicinity property border, it should be clearly located on the appropriate Figure and its relative significance to the total quantity and activity level of tailings on the site discussed.
3 12.
Sec. 4.4 (p. 4-4 to p. 4-13) - This section should present a clear, consistent, and comprehensive description, evaluation, and comparison of all remedial action options considered. We understand that the calculated cost and " quantities moved" data presented for all options and suboptions is currently in error due to an incorrect data base assumed by FBDU regarding the CVWRF vicinity property bourdaries to be considered in the REA.
However, even if this were corrected such that the revised cost data presented in the August 17, 1981 FB90 " Justification For Exception" for the CVWRF were incorporated, we would still have the comments noted from this point through Comment 16.
This is because the narrative discus-sion of options would remain the same and the options themselves would continue to have the same relationship to each other in a cost / benefit sense.
Consequently, for each option or suboption, we believe the 2.
following data should be provided in the REA to compare them fully:
a.
Quantity of tailings and other contaminated materials to be removed.
b.
Quantity of tailings and other contaminated materials to be left in t
place.
c.
Revised and updated costs.
d.
Maps or plot plans' showing each individual area, if any, where EPA Standards would be exceeded following completion of remedial actiin.
P e.
For each of the areas identified in d.,
the quantity of tallings and other contaminated materials to be left there and the incremental residual long term radioactivity releases that would result.
f.
For each of the areas identified in d., the expected incremental residual radon flux and gamma radiation level.
g.
Predicted health effects to both population and workers on a basis 4
which is independent of those due to the adjacent Vitro processing site, such that the effects are incrementally due to the CVWRF alone, and accounts for the normal environmental transport distances and routes of released radon gas (i.e., more than 0.5 miles).
If, as is stated however, the 0.5 mi distance is significant as a break point beyond which health effects drop dramatically then the data should also be presented for that distance specifically.
13.
Sec. 4.4.2 (p. 4-5) - Option 2 incorrectly assumes, to our current understanding, no cleanup under buildings built on tailings.
Also, if sloping truncated cone shaped bases of tailings are to be left under these or other structures, then at least the target slopes should be identified which would result in the minimum quantity of material to.be left in place.
In addition, the quantities to be left as a result should be estimated and presented for each typical structure.
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4 14.
Sec. 4.4.4.1 (p. 4-7 to P. 4-8) - The basic reconstruction cost of the existing CVWRF is given for Option 4A as $2,480,000 in CY-1981 dollars.
It appears this may be low in comparison to Central Valley's expansion program which we understand may approximate $100,000,000. While we have no basis to dispute the DOE's estimates for the reconstruction cost, we do suggest that you assure that these widely differing estimates can be rationalized.
15.
Sec. 4.5 (p. 4-10) and Table 4-3 (p. 4-13) - It is our understanding that the presented public health benefits or health effects saved which have been calculated to be due to the various remedial action options become lost or masked in tne health effects due to the Vitro processing site itself.
Thus, the health benefits as presented in Table 4-3 appear to be the same no matter which remedial action option is chosen.
The health risks and benefits of each option should be calculated independently of the Vitro site. Then an incremental value of dollars expended / health effects faved could and should be calculated for each option to compare them.
Fart of this section on comparative evaluation of options should also include a comparison of total quantities of residual radioactive materials left in place, and resultant incremental radon flux and release levels and gamma radiation levels following completion of remedial action.
Without this, the effects of the degree to which EPA Standards would be achieved by the various options would not be adequately documented.
As currently written, the REA gives no explicit indication that EPA Standards will not be achieved for some of the options.
The REA should openly discuss, and distinguish between the options, the aspect of which ones would require a joint DOE /NRC_ exception from meeting the Standards, and give calculated estimates evaluating by how much the Standards would be exceeded and the full effects resulting.
This should include a def tintive discussion of what long term physical / legal controls would have to be instituted, anoulo en exception be approved, to prohibit future improper use of the site, 16.
Table 4-3 (p. 4-13) - This table comparing cost and benefits is the crux of the case presented by the REA.
Thus, it should also present complete summary information for each option, as noted in Comments 12 nd 15, to i
allow a realistic overall comparison of options.
Currently the table does not present this information adequately or completely.
17.
Table 4-3 (p. 4-13) - We believe the REA should provide enough detail, currently absent, to enable an independelt check to be made of the health risk estimates for workers and populations for the various options.
For example:
What occupancy factor = are used? How are differences in' numbers of exposed people, duration of exposure, and breathing rates accounted for? Answers to these and similar questions should be provided prominently.
18.
Sec. 5 (p. 4-10) - A detailed analysis of the effects on groundwater of the various options is necessary, in our opir. ion, but missing throughout the REA.
Groundwater impacts must be analyzed in sufficient detail to support this conclusion section of the REA and this section should then also summarize the conclusions reached from the standpoint of groundwater impacts.
I Attachment II M C Staff Comments On August 17, 1981
" Justification for Exception:
Central Valley Water Reclamation Facility Vicinity Property Existing Structures" 1.
(p. 1) - The standards referred to should be noted as EPA 40 CFR 192 Interim Cleanup Standards for Open Lands and Buildings. The specific exceptions paragraphs mentioned should also be referenced as 192.20(a) and 192.20(c) though at the September 23, 1981 DOE /NRC CVWRF meeting it was discussed that the bases for exception seemed more ap; ropriately to be paragraphs M and (c).
We take note in this regard, that the cost /
benefit criteria exceptions paragraph [192.20(c)] cxplicitly states that it can anly be used when certain numerical values for radon WLs and gamma radiation (both indoor) are anticipated to be exceeded only slightly as a result of providd ig an exception.
We agree that the Standards do not appear to specif*cally address such facilities as sewage plant filter tanks. While the CVWRF tanks and other such structures could in fact reasonably qualify as buildings, they cannot reasonably be thought of as occupied or occupiable structures.
Therefore, in coming to a final conclusion regarding tne extent to which the CVWRF site should be decontaminated, we are in agreement that the remedial action should be targeted, within the latitude provided by the Standards, to accomplish only that which is reasonably achievable.
- However, the Justification should specifically identify the paragraph (s) of Part 192.20 under which an exception is sought, and document how the specific grounds for such exception, as specified by the named paragraph (s), are satisfied.
In addition to this, the Justification should characterize in detail the location, volume, activity content, extent, ar.d consequences of tha tailings and other contaminated materials for which the ca.ception cauld be applicable. We emphasize the need to provide a full and thonough evaluation of the totality of health and safety impa:ts of materW to be left in place under the exception.
Another major consideration, in our perspective, is long term land use and ownership controls.
Effective mechani ms to prohibit future misuse of the site must be provided and should be documented in the Justification in a definitive way.
2.
Fig.1 - The areas proposed to be excepted should be clearly indicated by boundaries specific to each tank and other structure, as snculd the overall vicinity property boundaries.
The trickling filter / clarifier exception areas are currently marked such as to lead one to believe the DOE will not attempt cleanup closely around or between the tanks or in the chlorine pond area.
In addition, the Justification and the REA are inconsistent because the REA Option 2 description excludes cleanup under all site buildings.
The Justification does not mention any exception request for the Administration and other site buildings.
Therefore, we assume, from it, that such cleanup will be undertaken as required to meet the EPA Standards.
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2 3.
Fig. 2 - A best current estimate of the slope for each type structure should be given along with the quantity of tailings to be left in place as a result and the radioactive source term they would represent.
A slope should at least be specified as a target which would result in the minimum quantity of materials to be left in place.
4.
(ps 2) - The predicted residual values for EGR and Radon-222 flux should be given as cilculated numerical estimates rather than just stating the EGR would be less than.020 mR/hr and that Radon-222 flux would be reduced.
The residual radon release due to tailings materials left as a result of any exception, should be spec'fied in terms of Ci/yr and incremental population exposure (both regional and long range).
5.
(p. 2) - The Justification must contain a definitive rather than a "such as" plan for physical / legal / administrative controls to prevent future misuse of the property should tailings be left there.
In order for NRC legal staff to concur, we would expect the DOE legal staff to have previously concurred in such a plan prior to its inclusion in the Justification.
The plan should also form a part of the REA since it becomes part of the total remedial action plan for the CVWRF site.
6.
(p. 3) - The potential loss of municipal water treatment capacity resulting from Options 3 and 4 is not odequately discussed.
Reasons why this might happen and any analyses of potential impacts of this occurrence en Salt Lake City citizens and the environment are absent from discussion. We consider inc?usion of such detailed analysis of this aspect vitally important ter both the REA and Justification because it may eventually form the centrat basis of a judgment regarding what remedial action scope is reasonable to attempt at the CVWRF.
7.
(p. 3) - We do not consider the CVWRF vicinity property to be " unique" any more than any other unusually significant vicinity property in Salt Lake City or others that may be associated with other UMTRAP sites.
Each will have its own set of unusual problems to be solved as they are decontaminated.
8.
Table 1 - The table shceld be expanded and modified in accordance with Comments 2, 12, 15, and 16 of Attachment I.
9.
A conclusion with respect to there being no potential significant impact on gruundwater due to the proposed remedial action seems to be implicit in the Justification.
The effects of the exception on groundwater resources-should, hawever, be clearly analyzed in appropriate detail to provide an adequate oasis for reaching an explicit conclusion.
Such explicit conclusion should then be documented in the Justification.
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