ML20134F761

Provides Comments Re Ground Water Issues Raised at Cintichem Inc Decommissioning Project

ML20134F761
Person / Time
Site:	05000054, 07000687
Issue date:	09/25/1996
From:	Giardina P ENVIRONMENTAL PROTECTION AGENCY
To:	Orlando N NRC
Shared Package
ML20134F760	List: ML20134F757 ML20134F761
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NUDOCS 9611080008
Download: ML20134F761 (8)

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY IO}

REGION 2 -

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290 BROADWAY NEW YORK, NY 10007 1866 i

L PR06 1

tSEP 2 51995 Mr. Nick Orlando U.S. Nuclear Regulatory Commission Mail Stop T8F37 Washington, DC 20555

Dear Mr. Orlando:

The purpose of this letter is to provide our comments regarding ground water issues raised at the Cintichem, Inc. decommissioning project (Docket #s 50-54,70-687). We have reviewed the report dated July 3,1996 provided by Jay Adler of Cintichem, Inc. Our comments regarding this report are included in the following.

Cintichem, Inc. justifies the levels of radionuclides in the ground water by demonstrating this water can not be used for drinking. However, this is not a valid argument. Therefore, before the Cintichem facility meets free release criteria the bedrock and ground water issues must be resolved. To meet free release criteria, all water at the facility; as stated in the Safe Drinking Water Act and 40CFR141.16; must meet a concentration below which unfiltered water would deliver a total effective dose equivlant equal to or less than 4 mrem /yr to a member of the public.

These conclusions were reached in consultation with members of the Fresh Water Protection

~ Section. The reader may refer to the next page for the methodology used to obtain our conclusions.

Si

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Paul IGiardina, Chief Radiation and Indoor Air Branch Enclosures [2]

cc:

Richard Balla, PSPS 9611'080008 960929 PDR ADOCK 05000054 Enclosure M

PDR Recycled / Recyclable. Printed with Vegetable Of Based inks on 100% Recycled Paper (40% Postconsumer)

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i The Cintichem facility is located within the boundaries of the Ramapo River Basin Sole Source Aquifer (SSA), a groundwater protection designation conferred under the authority of Section i

1424(e) of the federal Safe Drinking Water Act. For your information, we have attached a fact sheet on the Ramapo SSA (Enclosure 2).

1 As a result of this SSA designation, groundwater in both unconsolidated and consolidated 3

(bedrock) formations at the facility are classified as at least Class IIA Current Source of Drinking Water. Consequently, the report prepared by Cintichem concluding that groundwater is unsuitable for use as a water supply, and therefore should not be evaluated using the federal drinking water standards is incorrect.

We have not had access to the full documentation regarding the sophistication of the groundwater monitoring system at the facility or the investigation itself. We, therefore, cannot comment on its worthiness. Nevertheless, please note that groundwater flow in fractured systems is inherently complex. Conta.ainant investigations in fractured systems are, therefore, difficult at best, and generally require investigation utilizing both geophysics and monitoring wells. Even in the optimal case, monitoring wells may not intersect significant fractures in close proximity to the well, and may therefore fail to detect significant contamination. On the other hand, if several fractures are intersected by a relatively long well screen, dilution may mask significant contamination. Caution must be exercised when conducting the investigation, and interpreting the results. Based on the information provided, it appears that additional j

investigation of the sources and extent of the groundwater contamination at the nuclear reactor i

facility may be warranted.

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' J. McGovern methodology and changes the drinking water standard for "Sr from 8 pCi/l t 42 pCi/1.

Recently,thegCstaffhasusedEPA'sproposeddrinkingwater standard of 42 pCi/l for Sr in determining whether sites are suitable r

unrestricted use.

Requiring Cintichem to meet this standard also sati ies the requirements outlined in NYSDEC's Technical Administrative Guida e Memorandum entitled " Cleanup Guideline for Soils Contaminated with adioactive Materials," September 1993, provided the total effective dose equ alent due to all residual radioactive material will not exceed 10 millire per year (above background).

In their recent letter to NRC staff, EPA egion II also indicated that potential doses to the public from groundwate at the site should be evaluated against a total effective dose equival t of 4 mrem / year.

However, please note that EPA has specified that the grou' water sample used to determine the concentration of radioactive material ould not be filtered grior to analysis. Therefore, the NRC staff has conc 1 ed that 42 pCi/l for Sr, as determined using an unfiltered groundwater.s' ple, is the applicable standard for groundwater at the Cintichem site andf 11 be used by the NRC staff in determining whether the residual radioact e material at Cintichem's Tuxedo, New York facility meets NRC's criteria f' unrestricted use and termination of the NRC license.

/

If you have any questions concerning the staff' review of Mr. Adler's letter, please contact Nick Orlando at (301) 415-6749 Development of this letter has been coordinated with the staffs of NYSDEC/ d EPA Region II.

Sinc' ely, Mi ael F. Weber, Chief w-Level Waste and Decommissioning Projects Branch Division of Waste Management f

Office of Nuclear Material Safety c

and Safeguards License Nos.

SNM-639

/

R-81

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Docket Nos.70-687 50-54

Attachment:

As stated cc: Cintichem dist list /

TICKET:

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DISTRIBUTION: Central File /

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' J. MdGovern (mrem) per year), were converted to effective dose equivalents.

This is consistent with NRC's dose calculation methodology and changes the drinking water standard for ' Sr from 8 pCi/l to 42 pCi/1.

Recently the NRC staff as used EPA's proposed drinking water standard of 42 pCi/l for ' Sr in determining whether sites are suitable for unrestricted use.

Requirin Cintichem to meet this standard, also satisfies the requirements outl' ed in 7

NYSDEC's Technical Administrative Guidance Memorandum entitled "Cle up Guideline for Soils Contaminated with Radioactive Materials." Sep mber 1993, provided the total effective dose ecuivalent (TEDE) due to all r idual a

radioactive material will not exceec 10 mrem per year (above b kground).

In their recent letter to NRC staff. EPA Region II also indicat that potential doses to the public from groundwater at the site should be aluated against a TEDE of 4 mrem per year.

However. please note that EPA ha specified that the groundwater sample used to determine the concentration o radioactive material i

should not be filtered prior Therefore, t NRC staff has concluded that 42 pCi/l for,to analysis.y Sr. M determined using. unfiltered groundwater sample, is the app 11caMe standard for g undwater at the Cintichem site. This standard will be med by the RC staff in determining whether the residual radioactive material at Cint' hem's Tuxedo. New York i

facility meets NRC's criteria for unrestricted e and termination of the NRC i

license.

The preparation of this letter has been coord' ated with NYSDEC and EPA Region-II staffs.

If you have any question concerning the staff's review of

~

1 Mr. Adler's letter, please contact Nick Or ndo at (301) 415-6749.

Sin rely, chael F. Weber. Chief ow-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards Docket Nos.70-687 50-54 License Nos.

SNM-63 R-81

Enclosure:

As stated cc: Cintichem dist l'st TICKET:

N/A DISTRIBUTKd: Central Fil LLDP r/f DWM r/f NMSS r/f PUBLIC JSurmeier TDragoun/

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J. McGovern methodology and changes the drinking water standard for "Sr from 8 pC1/1 to 42 pCi/1. Recently,thegRCstaffhasusedEPA'sproposeddrinkingwater standard of 42 pCi/1 for Sr in determining whether sites are suitable for unrestricted use.

Requiring Cintichem to meet this standard also satisfi the requirements outlined in NYSDEC's Technical Administrat1ve Guidance Memorandum entitled " Cleanup Guideline for Soils Contami,nated with Ra oactive Materials," September 1993, provided the total effective dose equiv ent due to all residual radioactive material will not exceed 10 millirem r year (above background).

In their recent letter to NRC staff, EPA R ion II also indicated that potential doses to the public from groundwater t the site should be evaluated against a total effectiye dose equivale of 4 mrem / year.

However, please note that EPA has specified' that the grou ater sample used to determine the concentration of radiopc'tive material s uld not be filtered grior to analysis.

Therefore, the NRystaff has concl ed that 42 pC1/1 for Sr, as determined using an unfiltered groundwater s ple, is the applicable standard for groundwater at the C fitichem site and ill be used by the NRC staff in determining whether t e) residual radioac Tuxedo,NewYorkfacilitymeet)sNRC'scriteria ve material at Cintichem's r unrestricted use and termination of the NRC licen'se.

If you have any questionsconcerning the st f's review of Mr. Adler's letter, please contact Nick Orjando at (301) 415-6 9.

Development of this letter has been coordinated with'the staffs of NYSD and EPA Region II.

S cerely, Michael F. Weber, Chief j

Low-level Waste and Decommissioning

/

Projects Branch

/

Division of Waste Management Office of Nuclear Material Safety

/

and Safeguards License Nos.

SNM-639

/

R-81 Doc'ket Nos.

70-6

/

50- 4

Attachment:

As sta d

/ cc: Cintichem dist ist TICKET:

N/A DISTRIBUTION: Central F e LLDP r/f DWM r/f NMSS r/f PUBLIC JSurmeier TDragoun I

SWeiss MBell JAustin JHolonich LBell TCJohnson T3 receive a copy of this t in smelt box on "0FC:" line enter:

"C" = Copy Without attactunent/ enclosure; "E" = copy With cttachment/ enclosure; "W" copy Path & File Name: :\\dwm\\lldp\\dao\\cntiho LLDP OGC LLDP4h LLD[

NRR LLDP 0FC N0r[ando/bg JCopeland RFonner RNeYsN TMichaels MWeber NAME

[0/ /96 10/ /96 10/ /96 10/M/96 10/ /96 10/ /96 DATE 0FFICIAL RECORD COPY ACNW:

S NO Category:

Proprietary or CF Only IG YES N0 LSS. YES NO Delete file after distribution:

Yes No

J. McGovern at the Cintichem site and will be used by the NRC staff in determining I er the residual radioactive material at Cintichem's Tuxedo, New Yprl(facili meets NRC's criteria for unrestricted use and termination f4 he NRC li ense.

If you have any questons concerning the staff's revjew of Mr. Adler'

letter, please contact Nick Orlando at (301) 415-6749. Jevelopment of thi etter has been coordinated with the staffs of NYSDEC a 1PA Region II.

Sinc rely,

/

Michael F. Weber, Chi Low-Level Waste and ecommissioning

[/

Projects Branch Division of Wast anagement Office of Nucle Material Safety and Safeguar s i

License Nos., '

SNM-639 R-81 Docket Nos.'70-687 50-54 p

b Cintichem dist list cc:

TICKET:

DISTRIBUTION: Central File LLDP r/f DWM r/f NMSS r/f PUBLIC JSurmeier TDragoun/RI SW ss M8 ell JAustin JHolonich LBell Johnson Ta receive a copy of this document in smatt tm on c:= Line enter:

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RECORD COPY ACNW: YES NO

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Category:

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LSS : YES NO Delete file after distribution:

Yes No

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UNITED STATES y

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2065M001

\\....l Mr. James J. McGovern President / Plant Manager Cintichen, Inc.

P.O. Box 816 Tuxedo, New York 10987

'De 6 McGovern:

f w-is-in= response-toJ a-I m Pf' ""

fr This er's letter to Thomas Dragoun, dated Y

s _JuTy 37199E,' Tn which Cintichem summarized the radiological status of bedrock at its Tuxedo, New Yor acility,. and proposed that the radiological status of T

the groundwater at one-int at the site be. determined using the results from the analysis of groundwater collected from the deeper of two wells located near the foundation of the hot lab building. The results from the deeper well, MW-20, indicate that the groundwater megts the Environmental Protection

' Agency's-(EPA's) drinking water standard for Sr in 40 CFR 141.16, while the results from the shallower of the two wells, MW-2S, indicate tha groundwaterinthiswellexceedstheEPA'scurrentstandardforgthe Sr.

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Cintichem used the limited flow from the shallower well as the rationale for excluding it from consideration as an appropriate location for evaluating the radiological status of the groundwater at-the site.

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NRC staff has reviewed your letter and has concluded that the asses'sment of X

the radiological status of the bedrock is acceptable as submitted. However, the NRC' staff does not agree with your rationale for excluding MW-2S as an appropriate-location from which to determine the radiological status of-the

. groundwater at the site.

Based on NRC staff discussions with staff of the EPA's_ Region II office, the Cint.ic fac2 m, 9 etter-from. Paul A. Giardina toility is located in th

- Basin Sole Source Aquifer.(see it X

Dominick A. Orlando, dated September 25,1996).

EPA considers all groundwater

in.a Sole Source Aquifer, and therefore all groundwater,at the Cintichem facility, as a potential source of drinking water. The New York State

' Department of Environmental Conservation (NYSDEC) also considers all groundwater at the Cintichem site a potential. source of drinking water.

.Therefore, unless Cintichem can demonstrate tAthe NDC. taff that both EPA and NYSDEC have concluded that MW-2S is not an apppropriate sampling location for

. the Sole Source Aquifer, the NRC staff wouTd consiaer Doth MW-2S and MW-2D as appropriate sampling locations for evaluating the status of groundwater at the facility.

kcww Mr. Adler's letter also stated that "Sr concentrations in groundwater

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obtained from MW-2S during the past: year (June 1995 to June 1996) have anged I.

from 10 picocuries per liter (pCi/l) to 79 pCi/1, witg a mean of 38 p /1.

. ThegAdrinkingwaterstandardin40CFR141.16for Sr is 8 pCi/1. 8 pCi/1' -r d for Sr was. included in Cintichem's proposed residual radioactive material limits that were submitted to NRC staff in July 199 *and approved by NRC st'aff g

in August.1993.

In mid-199MPA published proposed rinking water standards-for. radionuclides.

These pMposed drinking water standards, although keepin.g X

the same dose basis as the current standard (4 mrem /yr), were converted to effective dose equivalents. This is consistent with NRC's dose calculation-t

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ROUTING AND TRANSMITI'AL SLIP DATE: 06/14/95 INITIAL DATE 1.D.ORLANDO,LLDP M//e/Pf

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TICKET NO.:

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LETTER TO:

James McGovern FROM:

M. Weber

SUBJECT:

REVIEW OF GROUNDWATER LIMITS Originator: D. Orlando d'hg np'l Room No./ Bldg.: TWFN 8F 37 Secretary: Betty Garret j

Phone No.:

415-7441 A

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