ML20040D053
| ML20040D053 | |
| Person / Time | |
|---|---|
| Issue date: | 12/30/1981 |
| From: | Shaffer W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Scarano R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-48 NUDOCS 8201300030 | |
| Download: ML20040D053 (2) | |
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WUR s/ f muR w/f fDR E 3 01981 WMUR r/f WMUR:WMS WM r/f WM-48 PDR NMSS r/f WShaffer DEMartin RScarano MEMORANDUM FOR: Ross A. Scarano, Chief Uranium Recovery Licensing Branc@ Fisher REBrowninE JLinehan JBMartin Division of Waste Management HPettengill MHaisfield FROM:
William M. Shaffer III, Project Manager New Facilities Section Uranium Recovery Licensing Branch Division of Waste Management
SUBJECT:
CLARIFICATION OF NRC STAFF COMMENT ON NOVEMBER 1981 DOE REVISED DRAFT DURANGO REMEDIAL ACTION CONCEPT PAPER (RACP)
NRC staff comments on the subject RACP were provided by your December 18, 1981 letter to Richard H. Campbell, Project Manager, UMTRAP Project Office, DOE-Al buquerque.
During finalization of these comments, you requested clarification and confirmation of the intent of the wording in Comment 3 as finally provided to DOE by your referenced letter. The wording requiring reconfirmation of its understanding to'all parties concerned is underlined on the attached excerpt from our December 1981 comments. Prior to transmitting our comments, I discussed this wording both with David Ball of the DOE UMTRAP Project Office and Robert Fonner of our Office of Executive Legal Director (ELD). Both agree with our view that no implication is considered to be conveyed by that language of any intent on the part of NRC to license any UMTRAP vicinity properties as tailings disposal sites. However, all parties agree that there may be isolated cases where it may be desirable, following completion of remedial action, to place under future restricted use certain,~ yet to be determined, vicinity proparties where an exception frum fully meeting EPA cleanup standards is justified and agreed to by all responsible parties, including the NRC.
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William M. Shaffer III, Project Manager Uranium Recovery Licensing Branch Division of Waste Management cc:
(with attachments)
Richard H. Campbell, DOE-AL pM
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Dr. William E. Mott, DOE-HQ Q
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ATTACHMENT I NRC STAFF COMMENTS ON i,
NOVEMBER 1981 DOE REVISED DRAFT DURANGO RACP 1.
p.3-4 (Sec.1):
The Colorado Cooperative Agreement was executed and was concurred in by the NRC on October 19, 1981. (ref. letter of same date from me to Gene Dixon, DOE-Albuquerque) 2.
- p. 5 (Sec. 2):
It is implied, but probably should be noted specifically, that Ranchers Exploration and Development Corporation (REDCO), as the most recent purchaser of the Durango site, is the current owner.
In addition, the brief discussion of REDCO's plans for the Durango tailings, previously included but now omitted, was useful to understanding the site's background.
3.
- p. 6 (Sec. 3):
We believe the language at this point'should allow for the possibility that ~ circumstances could warrant consideration of' only partial cleanup at some significant but yet to be determined n*<
Durango vicinity properties.
As a basis, we note the current case
(,V at the CVWRF vicinity property in Salt Lake City, UT where potentially up to 120,000 tons of tailings may be left on that property.
This would also clarify,the flexibility in -the. Interim EPA 40 CFR 192 Cleanup Standards as currently promulgated..It is suggested therefore that the following sent.ences would be prudent to' add to the second paragraph of Section 3:
Any vicinity properties whose complete cleanup to EPA Standards may prove te not be reasonably achievable will, as an j
alternate objective, be cleaned up to the maximum extent justifiable es all. owed for under the Interim EPA Cleanup Standards and potentially be placed under long term restricted use.
NRC. concurrence in the approval of any such exceptions from fully meeting EPA Standards will be obtained on an individual property basis."
4.
- p. 7 (Table 1):
The correct title of Table 1 is " EPA Interim Standards For The Cleanup Of Open Lands And Buildings".
They do not apply to just vicinity properties [ref. 40 CFR 192.10(a)].
In addition, our experience has been that much confusion results unless the two sets of EPA Standards (i.e., disposal vs. cleanup) are sa
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