ML20101N026

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Requests Permission to Change Two Issues in Decommission Order Re Type of Protective Clothing Worn by Workers & Sequence in Which Major Tasks Are Performed
ML20101N026
Person / Time
Site: 05000047
Issue date: 06/23/1992
From: Naughton J
ARMY, DEPT. OF, MATERIALS TECHNOLOGY LABORATORY
To: Alexander Adams
Office of Nuclear Reactor Regulation
References
NUDOCS 9207090126
Download: ML20101N026 (3)


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WATERTOWN, MASSACHUSETTS 02172 o001 llSE o, 23 June 1992 Base Realignment and Closure Office Docket No. 50-47 Mr. Alexander Adams Non-Power Reactors, Decommissionis v

arvi Er.vironmental Project Directora e Division of Reactor Projects Office of Nuclear Rea" tor Regulation OWFN M4: 11B20 Washington, D.C. 20555

Dear Mr. Adams:

We have encountered two issues in implementing the Decommissioning Order that are best resolved by improving our Decommissioning Plan.

One issue has to do with the type of protective clothing to be worn by the workers and the other deals with the sequence in which major tasks are performed. Each issue is outlined below and we request permission to pursue these changes.

Section 2.1.5.1 of the Decommissioning Plan specifies the use of disposable protective clothing. The specification was made with the intent of communicating that we would rot be generating liquid radioactive waste through an on-site laundry facility.

In order to improve worker comfort during the summer months and, at the same time, reduce the volume of solid radioactive l

waste generated during the decommissioning, we would prefer to use launderable protective clothing provided by an off-site contractor.

The contractor would be appropriately licensed and all transportation would be in accordance with governing Nuclear Regulatory and Department of Transportation regulations as well as state and local regulations.

Section 3.3.1 of the Decommissioning Plan specifies that the cistern will be removed as one of the first activities performed under the Decommissioning Order. The intent was to communicate that immediate subsurface conditions beneath the cistern would be compiled and applied to the remaining excavation work. Removal of the cistern requires excavating more than ten feet out on all sides of the structure.

The ten feet limit comes close to the double doar access in the south wall, which is the primary access for equipment and material. We would prefer to remove the cistern at a later stage during the decommissioning effort. Subsurface information will still be gathered ectly, as part of installing protective sheet piling around the cistern.

In order to ensure the absence of bedrock and rock in the vicinity of the sheet piling, auger holes will be drilled from which soil will be isotopically analyzed to determine if 5

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. gross contamination is present.

Additionally, monitoring wells have been installed downgradient of the cistern and no groundwater contartination has been detected.

For further information on this request, contact Laura Rodman in the Base Realignment and Closure Office at 617-923-5320 or Peter Cornetta in the Risk Management office at 617-923-5225.

Since rely,,

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4gamesT.Na)ighton AJ, OD eputyDirecltorand ommander CC:

Commande" U.S. Army Toxic and Hazardous Materials Agency

~j ATTN CETHA-BC (Mr. Salvatore Torrisi)

Aberdeen Proving Ground, MD 21010-5401 Commander, U.S. Army Corps of Engineers, New England Division ATTN: CENED-PD-L (Mr. Dennis Waskiewicz) 424 Trapelo Road Waltham, MA 02254-9149 Headquarters, Department of the Army ATTN: SAILE-ESOH (COL Chris Conrad)

Washington, D.C. 20310-0110 Mr. Rcbert Hallisey, Director Radiat. ion Control Program Depar: ment of Health Commor. wealth of Massachusetts 150 Tremont Street i

Boston, MA 02111 Ms. Anne Fenn I

Environmental Frotection Agency JFK Federal Building (PAS)

Boston, MA 02203 1

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Ms. Anne Malewicz Department of Environmental Protection Bureau of Vaste Site Clean-Up 1 Winter Street 5th Floor Boston, MA 02108 Mr. Thomas Dragoun Nuclear Regulatory Commission Region 1 King of Prussia, PA 19406

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