ML20138G975

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Forwards Comments on Umtrap Vicinity Property Certification Plan.Comments Include Info Re Purpose,Responsibilities, Remedial Action,Certification Decision,Notification & Documentation & Constraints
ML20138G975
Person / Time
Issue date: 09/23/1985
From: Higginbotham L
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Themelis J
ENERGY, DEPT. OF
References
REF-WM-39 NUDOCS 8510280146
Download: ML20138G975 (4)


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- Mr. John G. Themelis, Project Manager DISTRIBUTION R)H SO 7

  • UMTRA Project Office NMSS r/f RDSmith Albuquerque Operations Office WMLU r/f HPettengill U.S. Department of Energy REBrowning EFHawkins Albuquerque, New Mexico 87115 MJBell RBrich DEMartin GGnugnoli

Dear Mr. Themelis:

DSollenberger WM39 W Crow W Nixon Enclosed are comments on the UMTRA Project Vicinity Property Certification Plan.

Should you have any questions regarding our comments, please contact me or Dennis Sollenberger of my staff.

Sincerely, Original signdt by leo B. IlissiN Leo B. Higginbotham, Chief Low-Level Waste and Uranium Recovery Projects Branch Division of Waste Management Office of Material and Safety and Safeguards l

Enclosure:

Specific Comments on the Vicinity Property Certification Plan cc w/ enclosures:

G. White, DOE /AL J. Baublitz, DOE /HQ D. Groelsema, 00E/HQ K. Carlson, DOE /AL 8510280146 850923 PDR WASTE

, WM-39 PDR r

(see previous concurrence)

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___..:. ___ ______: ___________:__ _. _ .. 4 .____..___________.__.,___.,_____. __,,_____,.

NAME :GN Gnugnoli :DM Sollenberge __%.____.,A. hyginbotham  : .: : :

DATE :85/09/ :85/09/ :35/09/ :85/09/23  :  :  :

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, SEP 23 tm Specific Coments on Vicinity Property Certification Plan 1.1 Purpose o The applicable EPA standards' reference should be broadened to include all appropriate sections such as Q192.22 for supplemental standards.

1.2 Responsibilities o It should be made clear that this plan applies to VPs handled by the Grand Junction Project Office as well as those handled by the Albuquerque Project Office, o The NRC must be notified of the certification decision as well as the property owners and states / tribes (see M0V 53.4 last paragraph).

o The " separate" VPs should be defined in this document and elsewhere in the revised VPMIM. Applicable portions of 93.1.3, 3.3 and 3.4 of the MOU should be quoted for the benefit of the reader. It is not made clear what kind of properties require this individual concurrence or by what mechanism NRC concurs in certification in routine VP remedial action.

, o The plan should be revised to indicate that the MOU pertains to conduct of the program between NRC and 00E, not just DOE P0.

2.1 Remedial Action o The adequacy of criteria for measurement of radiological conditions is not clearly described. The criteria should either be listed or referenced.

o Since TAC performs periodic surveillance only on certain properties, the document should refer to the selection criteria.

o It appears advisable to modify the Owner Acceptance Form (in the VPMIM) to be conditional until after the Certification Decision determines the adequacy of the remedial action (or after NRC concurrence in the case of separate VPs).

2.4 Certification Decision o It is not clearly stated that NRC will receive the certification report for separate VPs, as is stipulated in the MOV $3.4 '

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o The basis for deciding whether or not a remedial action contractor's cleanup at a VP requires verification is unclear. If the criteria  !

consists of having a DOE-approved QA/QC program, then that should be .

clearly stated. l, o The wording in the second and third paragraphs seems to imply that DOE i would seek NRC concurrence on certification prior to notifying the RAC and property owner that remedial action still needed to be done. NRC would not fully concur in such a certification, especially in the case of separate VPs, unless the remedial action nad been completed.

o It should be clearly stated that DOE will make a certification decision on any separate VP prior to submitting it for NRC concurrence.

I 2.5 Notification and Documentation o NRC should be added to the list of parties receiving the notification, certification and verification letters.

o All cooperative agreements should be revised to reflect any regulations developed by the DOE Office of the Chief Counsel regarding land record annotations. Since NRC will in most cases not license any further DOE presence at VPs following remedial action completion, it is essential that local authorities perform such record annotation, especially in the cases where supplemental standards are invoked. The NRC may condition I certification concurrence for separate VPs to the annotation of such land records. The VPMIM should also be revised to include these regulations, once they are approved.

o Since the body of the owner notification letter (Figure 3) discusses additional remedial action, the title of the figure should reflect that as well as the need for additional measurement.

3.2 Constraints ,

o Use of new techniques relating to RDC measurements may be in conflict with protocol established in the VPMIM ( App. A&E). Such revisions would need to have NRC concurrence.

Appendices A and B Neither appendix appears to be able to " handle" the separate VP situation, which requires NRC concurrence. For instance, there is no space for any NRC concurrence signature on the certification recommendation form. It is

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1 also not clear that the certification report would address disposal of VP contaminated material in a disposal area other than the processing site's disposal area. Although the separate VPs are expected to be the lesser '

number of cases, the generic forms should be sufficiently flexible to handle these cases as well, i

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