ML20057E847
| ML20057E847 | |
| Person / Time | |
|---|---|
| Issue date: | 09/16/1993 |
| From: | Joseph Austin NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Glenn J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9310130234 | |
| Download: ML20057E847 (6) | |
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W ASHINGTON, D.C. 2055M001 SEP 161993 MEMORANDUM FOR: John E. Glenn, Chief Medical, Academic, and Commercial Use Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS FROM:
John H. Austin, Chief Decommissioning and Regulatory Issues Branch Division of Low-Level Waste Management and Decommissioning, NMSS
SUBJECT:
TECHNICAL ASSISTANCE FOR REVIEW 0F THE U.S. ARMY COMBAT TEST ACTIVITY ENVIRONMENTAL RADIATION MONITORING PLAN I am responding to your memorandum of June 30, 1993, in which you requested technical assistance from the Decommissioning and Regulatory Issues Branch (LLDR) to review the U.S. Army Cembat Systems Test Activity (CSTA)
Environmental Radiation Monitoring (ERM) program for the outdoor firing range at Aberdeen Proving Ground.
LLDR staff has completed the preliminary technical review of the newly submitted technical information and made a site visit (in cocrdination with Region I staff) to the Aberdeen Proving Ground to observe the location of monitoring wells and the generic environmental characteristics of the site.
In addition, during the site visit, LLDR and Region I staff met with representatives from the Army and its consultants and contractors to gain additional information about the ERM and the site.
As a result of our initial technical review, we concluded that the ERM includes appropriate methodologies and approaches to moniter any major potential depleted uranium (DU) migration to the groundwater from the U.S.
Army CSTA's DU firing activities.
Specific comments on the ERM are included in Enclosure 1.
However, we cannot complete our review at tnis time because the infonhatior. Nscribing the ERM was incomplete as descriDed in Enclosure 2 and summarized below:
1.
We could not determine the adequacy of the ERM in terms of the location of the monitoring wells and environmental sampling points (surface water, sediments, air, and soil).
2.
The environmental monitoring information provided by the Army is diffused throughout several reports.
LLDR staff encountered difficulty in tracing technical data. Specifically, information was lacking concerning specifications for the environmental monitoring, sampling, and analysis program.
3.
Although the ERM reports the direction of groundwater flow beneath the DU firing range, it did not include sufficient information and data (e.g., groundwater potentiometric surface map with appropriate
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SEP 161993 Prelimiracy Comments on the Environmental Radiological Monitoring (ERM) Program of the U.S. Army Aberdeen Proving Ground Decommissioning and Regulatory Issues Branch September 1993 i
Based on praliminary review by the Decommissioning and Regulatory Issues Branch (LLDR), LLDR's comments on the " Environmental Radiological Monitoring (ERM)" program of the U.S. Army Combat System Test Activity (CSTA) at the Aberdeen Proving Ground (APG) are as follows:
1.
The ERM should include analysis of the soil and sediments with respect to uranium adsorption capacity and potential for retardation during surface water and groundwater transport. Collection of this information will support environmental pathways analysis of the transport and fate of the depleted uranium (DU) in the humid and aquatic environment at Aberdeen (see comment #2).
2.
The ERM should include an assessment of contaminant transport using conceptual models to predict potential uranium concentrations in groundwater and other environmental media as a function of time.
Such information would supplement and support actual environmental monitoring data and would facilitate any necessary measures to minimize or mitigate DU contamination. Contaminant transport models could also be used in conjunction with dose assessment codes to estimate maximum doses and uranium intake for individual members of the public and environmental species.
These models may be used in estimating radiological impacts from the DU activities to support a determination of whether DU open air testing should continue at Aberdeen.
3.
The licensee should strive to establish good background data on uranium concentrations in groundwater, surface water, sediments, soils, air, and other environmental media. The data generated on background radiological quality should be statistically valid and representative of environmental media that have not been affected by DU testing at the site.
Fluctuations in background due to seasonal changes or due to sampling should be documented to support use of these data in evaluating any future trends in uranium concentrations.
4.
The ERM should define approaches to distinguish sources of contamination from different environmental pathways.
For example, sources of contamination of sediments in the Bay or creek sediments should be identified as resulting from either surface water erosion, air suspension deposition, or from transport via the groundwater pathway.
This would strengthen the ERM by tailoring any essential monitoring to specific pathways in the event that significant contamination is detected in the future.
For example, if significant migration is detected via sediment transport and the source of the contamination can 1
be identified, then the Army may be able to increase the frequency and location of samples for this pathway and source without necessarily increasing the monitoring for other pathways.
5.
The Army should establish a lower action level for uranium in groundwater beneath the site. The revised ERM specified an action level of DU concentration of 30 pCi/l U-238 in groundwater.
The Army's proposed action level was selected on the basis that it is a small fraction of effluent concentration limits in 10 CFR Part 20, Appendix B (Table 2, Column 2). This was in response to Comment No. 6 in Region I's letter to the Army dated February 22, 1993 on the earlier action level of 100 pCi/l U-238 proposed by the Army. However, LLDR staff believes that action levels of DU contamination in groundwater should be based on:
(a) EPA's proposed drinking water maximum contaminant level (MCL) of 30 pCi/l (20 #g/l) natura! U [56 FR 33050],
(b) Background concentration levels in groundwater, including the mean concentration and some function of the standard deviation, and (c) ALARA goals for contaminant releases.
The values listed in Table 2, Column 2 of 10 CFR Part 20, Appendix B are i
typically used for effluent concentrations released from licensed facilities before being diluted into surface water or groundwater.
In contrast, the MCL is used by EPA for drinking water and in EPA's groundwater protection programs as a reference level in monitoring, corrective actions, and health assessments. Contamination of groundwater in excess of the MCL could result in the need for corrective action to mitigate the contamination.
For example, NRC is currently using EPA's MCLs as radiological criteria for decommissioning [57 FR 13389].
The licensee should establish an action level for uranium in groundwater less than the MCL value in order to minimize groundwater contamination before it reaches the maximum allowable concentration levels.
In other words, the licensee should establish the action level based on background levels including background standard deviation, and an ALARA goal level above background (e.g., around 20% of the maximum contamination level) to control and minimize any significant groundwater contamination from DU activities. The action level may also be based on contamination level that is close to the anticipated levels developed from the transport modeling.
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SEP 161933 Additional Information Needs Based on Review of the Environmental Radiological Monitoring (ERM) Program of the U.S. Army Aberdeen Proving Ground Decommissioning and Regulatory Issues Branch September 1993 The following technical information and data are needed to complete the technical review of the " Environmental Radiobgical Monitoring (ERM)" program of the U.S. Army Combat System Test Activity (CSTA) at the Aberdeen Proving Ground (APG):
1.
There is a need for larc,e-scale maps showing clearly the monitoring well and environmental sampling point locations (requested in previous review).
LLDR has requested this information from Region I.
2.
LLDR staff needs the technical report prepared by CSTA's contractor Pacific Northwest Laboratory (PNL).
LLDR understands that this report describes the technical rationale and basis for the selection of the number of monitoring wells and their locations.
LLDR has requested this information from Region I.
3.
Specifications and descriptions for the ERM are distributed throughout a series of documents.
Because these details have not been consolidated in one section of the ERM description, it is difficult and cumbersome to ensure that ERM is sufficiently comprehensive and appropriate to detect significant migration of DU at the site.
The disperse nature cf the specifications may also impede implementation of the ERM. Therefore, the Army should submit a summary table that lists information on the following attributes of the ERH:
. Number of samples to be collected,
. Location of sample,
. Type of analysis to be performed,
. Frequency of sampling and analysis, and Schedule for completion of the analysis.
4.
The licensee should submit information which includes a summary of the methods and equipment to be used in the environmental surveillance, monitoring, and analysis activities.
5.
Although the ERM reports the direction of groundwater flow beneath the DU firing range, it did not include sufficient information and data (e.g., groundwater potentiometric surface map with appropriate scale) to elucidate the relationship between the monitoring well locations, discharge / recharge areas, and groundwater flow. A groundwater
potantiometric map is necessary to ensure that the monitoring wells and surface water sampling points have been appropriately located to determine background water quality and detect potential contaminant transport. Therefore, the licensee should provide a map of the groundwater potentiometric surface of appropriate scale to enable NRC to complete the assessment of the ERM.
6.
LLDR staff understands that the licensee has already carried out some environmental monitoring activities.
The licensae should provide NRC with periodic reports from the ERM to assess any potential migration of uranium contamination and to determine the adequacy of the ERM program.
Such information will also be useful in determining whether the Aberdeen site should remain listed in the NRC's Site Decommissioning Management Plan.
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- John E. Glenn SEP 10'1h3 s
scale) to elucidate the relationship between the monitoring well locations, discharge / recharge areas, and groundwater flow.
We also identified another issue based on our review of the ERM and site visit regarding whether Aberdeen Proving Ground should remain listed in the Site Decommissioning Management Plan (SDMP). At the site visit exit briefing with Mr. Jim Kelton, CSTA Technical Director, Mr. Kelton questioned the basis and criteria used by NRC for listing the Army Aberdeen facility on the SDMP.
Mr. Kelton also indicated that APG has no near-term intention of discontinuing firing DU or other ordinance at this range.
Considering these remarks and our understanding of the status of the Aberdeen site, we believe that NRC should consider differentiating between a licensed facility, with contamination, that plans to continue operations (such as the case of Aberdeen Proving Grounds) and a facility that is no longer operational and in the process of decommissioning for unrestricted public use. As was indicated by Mr. Kelton, the Army has no intention of discontinuing firing DU rounds or other ordinance at this range.
In addition to the hazards posed by l
DV contamination, the outdoor range also contains a large quantity of unexploded ordinance.
Although the site meets the criteria for listing on the SDMP (e.g., large volume of contaminated soil in a " burial ground"), the range is still active and the Army has no plans to decommission Aberdeen any time soon.
The Amy is using the ERM for monitoring potential contamination from DU test firing in the open range.
In this situation, once the comments in Enclosure 1 (and other possible comments that may be made after reviewing the additional information in ) are resolved, the ERM program should be adequate to monitor any future contamination by DU from past and future testing activities. Thus, Region I agrees, Aberdeen should be considered for removal from the SDMP on the basis that the extent of DV contamination is sufficiently known, the ERM program will be adequate to detect any significant environmental migration outside the testing range, the Army plans to continue use of the open range to DU firing, and NRC has no reason to question the financial viability of the licensee. We may need to consult with the Commission in removing the site 1
from the SDMP prior to the next update to the list of sites in 1994.
This review was prepared by Boby Eid, Jack Parrott, and Michael Weber.
If you have any questions, please call Boby Eid of my staff at 504-3446.
OrighdSignedBy John H. Austin, Chief Decommissiening and Regulatory t
Issues Branch Division of low-level Waste Management and Decommissioning, NMSS
Enclosures:
Distribution:
Central File NMSS r/f JGreeves PLohaus MBell MFliegel MWeber TCJohnson LBell EUlrich DWhite JKinneman
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