ML20059E401
| ML20059E401 | |
| Person / Time | |
|---|---|
| Issue date: | 08/27/1990 |
| From: | Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Matthews M ENERGY, DEPT. OF |
| References | |
| REF-WM-48 NUDOCS 9009100172 | |
| Download: ML20059E401 (4) | |
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AUG 27 i990 '
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- URF0:DLJ Docket No. WM-48 I
U.S. Department-of Energy "i;.
' Albuquerque Operations' Office a
ATTN:' Mark L.-Matthews-P.O.'. Box 5400
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- Albuquerque, New Mexico 87115 s
Dear Mr. Matthews:
L As a result of the-meeting with the Colorado' Department"of Health and thei l'
Bureau of Reclamation on. August 7, 1990, we: understand'that the1 Bureau of
' Reclamation has requested a Restricted Use' Permit from the' State of Colorado i
for:a'part'of.the Durango UMTRA Project processing. site.- NRC.will need; 3
assurance that the proce sing. site surface has'been cleaned'up in accordance.
' with applicable EPA standards, and can therefore be released for unrestricted use.
Since access-to the area-by DOE may be necessary to complete ground-water
- restoration sometime>in-the future, it will _ also be necessary for DOE to ;
. provide assurance that such activitiesLwill not be hindered.
This~ assurance
- should be containtd in a legally binding and enforceable contract which.
includes the following:
1.'
The land user should provide DOE access to the site for ground-water restoration activities.
2.
DOE must restrict the' land user from conducting activities that would prejudice the completion of ground-water restoration.
L 3..
The land user's site-activities should be limited to those which will not-
.i aggravate the present ground-water contamination.
4.
The land user must not disturb or alter any wells ~or monitoring devices installed by DOE, unless DOE agrees to the modification.
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i AUG 271990 U.S. Department of Energy-2-
We are also enclosing the comments resulting from our review of the draft Restricted Use Permit application prepared by-the' Bureau of Reclamation for-your informationt-The document was reviewed by our office at the request of-
..the Colorado Department of-Health.
If-you have any questions, please contact D L.-'Jacoby of my staff on FTS 776-2805.
Sincerely,-
js{
s L. A. Yandell
+-
Acting Director
Enclosure:
<C As-stated cc:
'Mi Abrams S..Hamp bec:... 1 U PDR/DCS
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LLO Branch, LLWM DJacoby.
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d CO MENTS ON THE DRAFT APPLICATION-FOR s
RESTRICTED USE OF THE_DURANGO. PROCESSING SITE l
i 1._
There are two topics considered in the proposed application which are' currently _ under policy review by the NRC.
a.
Recovered Ground-Water Discharge:
Current NRC poli'cy is that recovered ground water from NRC licensed mill sites is byproduct material and therefore cannot be discharged to the environment.- This-_
interpretation is currently.being discussed with NRC headquarters, and a policy determination _ should beifor.thcoming shortly.;, ny"?
' pa,3c... ;g _ ug&m.$/M.. ; 7. MI;.,
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b.
Sludge Disposal: D Sludgefresultinglfrom treatmentzofirecoveredi,groundy wateriis 'alsol considerediby' roouctimater.f al.%0niththba'sisitittssuld F E
p require disposal _lii'etther an' existing'm'1114tsil.ings7fac111tydir?in? "
an approved disposal sitelauthor.izeduto.'accepthbgro'ductiImagi,a,1,M,1 g
< S u d;Q %.T X $ $: K @ "O k s % m.n g " * % -
'2.
Should excavation result ~ in trecovery*of contaminated? earth?abovetnorma
@'7 acceptance limits, dilution by blending.with?outsideVsourcestsh60ld.
'iL considered permissible. -If a; localized deposit:of> cohtaminated na tal" r is mixed with other material from the:same excavation %and the.resulting.
contamination level is below acceptable limits, that:would be consistent-with normal site cleanup criteria.
Concentration of contaminated mater,tal-7
-in one central. location,should be avoided.%
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v-J' Under the heading 1" Environmental,;Healthuandisafetscons b A.i.a.
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3.
Provisions'are included for: monitoring $for!the possible:spreadiof-contamination during: site construction. 'It.statesrthat an Industrial' Hygienist would be onsite.
It is sugested that' this section should be strengthened to require that a Health Pttysicist, trained'and experienced
. i in radiological protection, be available to monitor excavated materials and'to perform personnel surveys of potentially contaminated site workers l
1 as necessary.
1 Even though not explicitly stated in this section, it is asr.'med that normal construction site security will be in place. ' This smid be sufficient for prevention of uncontrolled site access and the potential for undetected contamination of intruders.
To assure that there is no undetected contamination of site workers, routine exit surveys may be
. necessary should excavation result in exposure of contaminated soils.
I This < kind of data may prove useful if there are.any future questions related to the potential for contamination of site workers.
Frequencies for radiation protection and health and safety training should be defined.
The scope of personnel to be so trained should also be
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stated.- Training may ir.:1ude identification of possibly contaminated material.
The applicability of the State of Colorado's equivalent of 10 CFR 19 and 10 CFR 20 regulations applicable to this site may bear emphasis.
4.
Under the heading " Handling Ground Water," the application should indicate that some water associated with raffinate disposal will be encountered.
5.
To be consistent with UMTRCA, 1978, the phrase " contaminated materials" should be changed to " residual radioactive materials."
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