ML20043B136
| ML20043B136 | |
| Person / Time | |
|---|---|
| Issue date: | 05/23/1990 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Matthews M ENERGY, DEPT. OF |
| References | |
| REF-WM-39 NUDOCS 9005240241 | |
| Download: ML20043B136 (8) | |
Text
'
gay 2 3 1990
'. Mark L. Matthews, Proj;ct Manager Uranium Mill Tailings Project Office Albuquerque Operations Office Department of Energy A1)uquerque, New Mexico 8711S 4
Dear Mr. Matthews:
I received your A)ril 24, 1990 letter on draft VPMIM Directives nunbers #E6, fE8, #E9, #E10, fill and (E12. Our response combines the NRC Headquarters and URF0 reviews.
I would like to point out a general concern that I have regarding the purpose of the VPMIM Directives.
In a number of the draf t directives, it appears that wholesale chstges are proposed to the VP;;1M itself.
It was not my understanding that these directives were to supplant the formal revision process of the VPMIM, as mentioned in the Me:aorandum of Understanding.
In any such proposed niodification, DOE should provide a justification that the changes would not jeopardize the NRC generic concurrence for normal vicinity properties. The directives indicate changes in excavation and verification protocols without the basis to support the need and benefit of such a change.
The different directives are related, and it is difficult to see how the VPMIM itself will change as a result of the VPMIM modification by all these directives. In the enclosed response forms to the individual draft directives, NRC staff has suggested, in a nunber of cases, that a formal revision to the VPMlb may be more appropriate.
It is not our intention to burdca the clarificat. ion of VPMIM procedures through the use of the.VPMIM Directives.
If you feel that the charges proposed in thet.e directives are not so sweeping as'they appear to be, I would be pleased to discuss these comments with you.
If you have any specific questions regarding this transmittal, please contact i
me at FTS 492-0553 or Giorgio Gnugnoli, of gy staff, at FTS 492-0578, i
I Sincerel ORlbhAl. SIGNED BY Paul H. Lohaus, Chief Operations Branch Division of Low-Level Waste Management and Decommissioning Office of Hucleur Material Safety I
and Safeguards 1
Enclosures:
As stated cc w/ enc 1: R. Hall, US 1, C. Duran, TAC /AL, P. Mann, DOE /AL o
Distribution: Centra EF.11e?h NHSSISUBJ D 39L.
.P NMSS r/f LLOB r/f Q@
RBangart JGreeves JAustin
~'JSurmeier PLohaus
{
n MF11egel DGillen GGnugnoli EHawkins,URF0 P.Michaud,URF0 t
8 PDR YES X
14 PDR NO Category: Proprietary or CF Only J
mu ACNW YES-X N0 h.
SUBJECT AB5 TRACT: HRC RESRIR5E ON DOE VPHIM DIRECTIVES fE6, E8, E9, E10 Ell & E12
[
gg k
g g-0FC :LL E
- URF0
- LLGB OBp b f
'-*--r--------k
-t*---------------------
-/ --------htM{mic -- M{FIf 6[el omi
- h haus N
NAME:
if i C0 un L
- O DATE6 /25/90
- 5/e3/90
- 5"/290
- $/0/90 Auf QFf]C]/d Rf. CORD COPY
RESPONSE TO VPHIM DIRECTIYC #E6 Date: May 23, 1990 Comment Originator: Giorgio Gnugnoli, Project Manager Paul Michaud, Project Manager Organization / Telephone Number: USNRC/NMSS, Gnugnoli FTS 492-0578 USNRC/URF0,Michaud FTS 776-2805 COMMENTS The NRC staff has reviewed this directive and has the following reconenendations:
1.
The transmittal letter in attachment A should have Paul H. Lohaus on the carbon co)y (cc:) without enclosure.
Internal NRC procedures willinsuret1atthetransmittal(includingAttachmentB)isplaced in the NRC Public Document Room.
2.
The ccnoliance chart in Attachment B has a number of items which query w1 ether compliance criteria or pro)er protocols were followed or not followed.
In some of the cases w1ere the adhered to, the item required explanation (i.e., grotocol was not why not?). The certification requirements should be reviewed to consistently require explanation in case of departure from those requirements.
It is unclear why there are two ap 3.
Attachment C (the NRC review form)parently different forms in 1
, where one would accomplish the same thing.
4.
The certification memo to file (Attachment E) should mention that NRC has concurred in the DOE completion determination individually or else under provisions of the DOE-NRC Memorandum of Understanding, Modification 1 Sections 3.1.4 and 3.4, dated May 12, 1987.
L FOR UMTRA PO USE ONLY
[
COMMENTS REVIEWED AND INCORPORATED
[
COMMENTS REVIEWED AND NOT INCORPORATED
] COMMENT ORICINATOR CONTACTED DATE:
/
/
] WRITTEN RESPONSE JSSUED DATE:
/_/
i
?
i RESPONSE TO VPMIM DIRECTIVE dE8 i
Date: May 23, 1990 Corment Originator: Giorgio Gnugnoli, Project Manager Paul Michaud, Project Manager Organization / Telephone Number:
USNRC/NMSS, Gnugnoli FTS 492-0578 USNRC/URF0, Michaud FTS 776-2805 COMMENTS TheUraniumMillTailingsRadiationControlAct(UMTRCA),TitleI as amended, stipulates DOE with the responsibility of designating VPs.
Specifically, Section 102.(e) addresses DOE's responsibility to include VPs. The NRC's role is one of consultation in this regard. This directive does not require NRC concurrence, but rathe; consultation.
With that understanding, the NRC staff provides the following recommendations:
1.
If tnis is a generic problem, then it is appropriate to deal with it in the VPHIM procedures.
If this is a ?roblem only at one or two s,tes, it would be more appropriate to landle these tituations on a case-by-case basis.
2.
The DOE should clearly describe what constitutes oiwturbed" versus
" undisturbed" areas.
" Range lands" appears to imply open areas; will DOE rely solely on visual identification of man-made drainage areas and rubble piles?
r l
t 3.
The DOE should clarify what is envisioned by the phrase "special attention." How will DOE be able to give an anomaly any special attention, unless it is detected? NRC staff is not convinced that driving along an access road with hand-held equipment will provide a reliable survey protocol.
4.
NRC experience with mobile van screening in and around the Edgemont vicinity properties underscored the need for walk-over surveys with hand-held survey meters in many situations.
FOR UMTRA PO USE ONLY f
COMMENTS REVIEWED AND INCORPORATED.
[
l COMMENTS REVIEWED AND NOT INCORPORATED 1 COMMENT ORIGINATOR CONTACTED DATE:
/
/
)
l j HRITTEN RESPONSE ISSUED DATE:~~~/
/~~~
1 i
I i
a" RESPON3' TO VPMIM DIRECTIVE #E9 Date: May 23,1990 Comment Originator: Giorgio Gnugnoli, Project Manager Paul Michaud, Project Manager Organization / Telephone Number: USNRC/NMSS Gnugnoli FTS 492-0578 USNRC/URF0 Michaud FTS 776-2805 COMMENTS This directive appears to alter the benchmarks set under the NRC concurrence l
with Revision D of the V NIH ud with the discussions surrounding the revised soil sampling protoccis o'uring tiie end of 1987. There is no argument that the 3
5-15 pCi/g standard is the appropriate EPA cleanup criterion, but the field.and lab cut-off values may need to be lower to assure confidence that the candidiate property and the associate cleanup are properly characterized, i
If the DOE believes that the sampling protocols need to be revisited, the proper approach is to propose a formal modification of the VPMIN with the accompanying justification.
FOR UMTRA P0 USE ONLY
~
Jl l COMMENTS REVIEWED AND NOT INCORPORATED COMMENTS REVIEWED AND INCORPORATED ~
I[
] WRITTEN RESPONSE ISSUED DATE: ~ / ~ /
COMMENT ORIGINATOR CONTACTED DATE:
/
/
l 1
i 1
l-
RESPONSE TO YPMIM DIRECTIVE dE10 i
Date: May 23, 1990 Comnent Originator: Giorgio Gnugnoli, Project Manager Paul Michaud, Project Manager Organization / Telephone Humber: USNRC/NMSS Gnugnoli FTS 492-0578 USNRC/URF0 Michaud FTS 776-2805 i
COMMENTS This directive appears to be eliminating the 25 mR/hr criterion for automatic inclusion. Likewise, for verification purposes, anomalies are identified by a 30% above-background criterion, as opposed to the 50% above-background 4
criterion being used now.
It is unclear how the VPHIM procedures will change; e.g, will the Net Estimate Area-Weighted Average (NEAWAj still be used; will i
one standard deviation-(if, calculable) be an available option?
i The elimination of the use of ganum survey reasurements for specifying Ra-226 soil concentrations is ambiguous. The wording of the directive inplies that the change has resulted, because of unreliability of the gamma measurements.
The directive doesn't state what will replace the gamma neasurements in the situation of uncertain depth profiles of contamination.-
J Prior to concurring with these changes, it would be helpful to see how they change the VPMIM arotocols.
It would also be useful to understand what has motivated these c1anges, which, at first glance, appear to make the process more time and resource intensive.
FOR UMTRA PO USE ONLY
] COMMENTS REVIEWED AND INCORPORATED
] COMMENTS REVIEWED AND NOT INCORPORATED
] COMMENT ORIGINATOR CONTACTED DATE:-
/
/
] WRITTEN RESPONSE ISSUED DATE:
/
/
1 l
I
4 g
4 RESPONSE TO VPMIM DIRECTIVE fell Date:. May 23, 1990 i
Comment Originator: Giorgio Gnugno'.i, Frcject Manager Paul Michaud, Project Manager Organization / Telephone Number:
USNRC/NMSS G. Gnugnoli FTS 492-0578 USNRC/URF0 P. Michaud FTS 776-2805 i
COMMENTS The NRC staff had the following questions, concerns and observations regarding this change of protocols in using the Opposed Crystal System (OCS) for excavation control and soil sampling:
1.
It is not clear why this change does not affect section 4.5
" Excavation Control" or section E.2 " Pre-restorative Ganna Survey and Soil Sampling" of the VPMIM, as well.
2.
It is not clear whether DOE is just making section A.3 "On-site Survey Procedures" consistent with section 4.5 or whether the intent is to dispense with the option of using hand-held scintillometers.
It is not clear why DOE intends to eliminate the flexibility and the additional quality control of using the hand-held scintilloneters in certain situations.
3.
NRC had previously concurred with DOE cost-reducing strategies in late 1967, because hand-held scintillometer surveys and the RTRAK system, among other mechanisms, would supply additional coverage, r
when the 21-plug sampling protocol was modified to reduced it to a 9-plug grid system.
DOE's use of the OCS as a screening and verification method for both excavation and verification, using the same sample, could im>act the confidence of the DOE's characterization of tie extent of contamination at VPs.
4.
The directive does not address the statistical confidence criterion for the best-fit correlation between the initial-(quick count) and thefinal(lab)concentrationdata. Without the confidence of the hand-held scintillometer confirmattiry screening data, the best-fit calibrat{on would need to have a greater coefficient of determination (e.g.,r valueatleast0.9). Another alternative is to use an upper (or lowr, if more conservative) confidence limit for the best-fit calibration.
5.
Due to the apparent scope and extent of the change to the VPMIM protocols, a formal modification, with justification, to the VPMIM would be a better vehicle for this directive.
5
]
Comments on VRMIM Directive fell (continued):-
6.
As written it appears that the DOE intends to use a quick count screening approach, using DCS without an additional and separate sampling for verification purposes. The DOE should clearly indicate how the revised procedure would impact the verification sanpling and analysis. -
FOR UMTRA PO USE ONLY S COMMENTS REVIEWED AND INCORPORATED ll COMMENTS REVIEWED AND NOT INCORPORATED
) COMMENT ORIGINATOR CONTACTED DATE:
/
/
] WRITTEN RESPONSE ISSUED DATE:
/___/ _
P i
F i
9 I
r
=
)
RESPONSE TO VPMIM DIRECTIVE fE12 Date: May 23, 1990 Project Manager Comment Originator: Giorgio Gnugnoli, ject Manager Paul Michaud, Pro Organization / Telephone Number:
USNRC/NHSS G. Gnugnoli FTS 492-0578 USNRC/URF0 P. Michaud FTS 776-2805 COMMENTS The NRC staff agrees with the DOE directive to remove exterior deposits, while remedial action is being performed, as opposed to following completion of remedial action. Since access to a disposal area may be a problem after the processing site is reclained and closed, it would appear essential to complete all vicinity property cleanups, prior to that closure.
This directive is consistent with tt.at approach.
However, it is not clear where the directive is going to be placed in the VPMIM, Section 4.3.1.
It is not clear that the wording of this directive shall i
be used as an insert or whether the existing text will be revised.
The final directive should explicitly indicate how the VPMIM will be changed.
FOR UMTRA PO USE ONLY Fl COMMENT ORIGINATOR CONTACTED DATE:
/
/
COMMENTS REVIEWED AND INCORPORATED COMMENTS REVIEWED AND NOT INCORPORATED WRITTEN RESPONSE ISSVED DATE:
/
/
t t
?
-_.