ML20148E309
| ML20148E309 | |
| Person / Time | |
|---|---|
| Issue date: | 05/27/1997 |
| From: | Joseph Holonich NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rael G ENERGY, DEPT. OF |
| References | |
| REF-WM-62 NUDOCS 9706030063 | |
| Download: ML20148E309 (10) | |
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Mr. George Rael, Director U.S. Department of Energy Albuquerque Operations Office l
ERD /UMTRA l
P.O. Box 5400 Albuquerque. NM 87185-5400 l
SUBJECT:
VICINITY PROPERTY COMPLETION REPORT FOR THE RIFLE, COLORADO.
VICINITY PROPERTY NUMBER RF-493
Dear Mr. Rael:
The U.S. Nuclear Regulatory Commission staff has completed its review of the Vicinity Property Completion Report (VP CR) and the vicinity Property l
Certification Summary and Decision for vicinity property RF-493S (a large open area North of Highway 6 and 24. East of Ash Avenue, and across from the Old Rifle Processing site) in Rifle Colorado.
The RF-493 VP CR was submitted by letter dated October 28, 1996.
NRC concurrence with this VP CR is recuired because the U.S. Department of Energy (DOE) applied supplemental stancards during remediation.
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Supplemental standards were applied in order to leave windblown tailings l
contamination over an area of either 2132 square yards or 2132 square feet (see first editorial comment) in place on some of the steep. almost vertical slopes of the south bluf f above Highway 6 and 24 as well as the bluff along the southwest part of the property.
In addition to the bluffs. RF-493S included a trash dump area, and two dry ponds and surrounding berms on the top of the bluffs, which were remediated.
Certain aarts of the bluffs were determined by DOE to be too steep and too unsta)le either for characterization or remediation.
The VP CR indicates (section 2.1, page 4) that remedial actions were performed according to the Remedial Action Plan (RAP).
The VP CR also states (section i
3.1 and 3.3.2, pages 4-5), that radiological verification survey data were l
acquired according to approved procedures.
The net measured concentrations of l
22 era after remediation as reported in the VP CR in surface and subsurface soil are within the Environmental Protection Agency (EPA) standards.
It appears that, for the areas where DOE remediated, appropriate verification methods were used and the verified areas meet the EPA standards for land cleanup.
This conclusion. however, does not apply to areas te which supplemental standards have been ap) lied.
Based on its review of the VP CR. NRC staff l
cannot conclude that t1e remedial action conducted at VP RF-493S meets the lI Environmental Protection Agency (EPA) requirements for land cleanup.
Thus, at this time, NRC staff cannot concur that the remediation of RF-493 is complete.
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.G.,Rael 2-The issues discussed in the enclosed comments should be resolved or addressed
= by DOE in order for NRC staff to concur in the RF-493 VP CR.
If you have any questions concerning this letter. please contact the NRC Project Manager, Janet Lambert at (301) 415-6710.
Sincerely, (Original signed by) l Joseph J. Holonich. Chief l'
Uranium Recovery Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated.
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V. S. Nuclear Regulatory CommSsion (NRC) Comments on the Vicinity Property Completion Report for the Rifle, Colorado Vicinity Property Number RF 493 s
- 1) A)plicability of the Three Criteria for Supplemental Standards:
T1e VP CR indicates that three criteria for application of supplemental standards can be y glied to the bluff areas of the RF-4935 propert., that were not remediated.
However, it is not clear from the VP CR that the application of all three criteria is either warranted or appropriate.
Discussion:
4 Appendix B of the VP CR describes the application of supplemental standards, under 40 CFR 192.21 and 40 CFR 192.22. to four areas on the bluffs along the south and southwest sides of the property.
Section B.1 of the appendix indicates that the applicable criteria for applying supplemental standards to these areas are (quoted from 40 CFR 192.21, not from the VP CR):
(a) Remedial actions required tc satisfy Subparts A or B would pose a clear and present risk of injury to workers or to members of the public, notwithstanding reasonable measures to avoid or reduce risk.
(b) Remedial actions to satisfy the cleanup standards for land.
S 192.12(a),...would notwithstanding reasonable measures to limit damage, directly 3roduce environmental harm that is clearly excessive compared to t1e health benefits to persons living on or near the site. now or in the future.
A clear excess of harm is harm that is long-term, manifest, and grossly disproportionate to health benefits that may reasonably be anticipated.
(c) The estimated cost of remedial action to satisfy 6 192.12(a) at a " vicinity" site (described under Sec.101(6)(B) of the Act) is unreasonably high relative to long-term benefits, and the residual radioactive materials do not pose a clear 3 resent or future hazard.
The likelihood that buildings will
)e erected or that people will spend long periods of time at such a vicinity site should be considered ir evaluating this hazard.
In Appendix B of the VP cps, criterion (c) is the only one for which justification is provided. However, this justification is lacking in a few areas.
Section B.3.1 of A)pendix B describes the method used for the health risk analysis.
T1e only exposure pathway considerM was that of direct external exposure from the contaminated materi d s.
Exposures from inhalation of resuspended particulates, inhalation of radon progeny, and inadvertent ingestion of contaminated soils were not considered.
Thus, the dose assessments performed are not complete.
Sections B.4 and B.S of Appendix B include cost estimates for the various remediation alternatives.
In section B.5. the costs are total costs for all work to be done under the alternative, not just for work on the areas to which supplemental standards were to be
i-4 applied. This is somewhat misleading. since the cost benefit comparison should evaluate cdst.s and Denefits for the supplemental standards areas only.
In addition, it is noted that the cost given in section B.4.2.4 is not the cost for the alternative as indicated:
rather it is the incremental cost for cleanup of the supplemental standards arcas.
From the difference in costs of Alternatives'1 and 2. given in section B.S. the cost of cleaning up the supplemental standards areas
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appears to be about $66.000.
Because of the items described above, information in the VP CR has not clearly demonstrated that such a cost would be unreasonably high relative to benefits.
l Three memoranda from the remedial action contractor, included in the VP CR. indicate that cleanup was not performed in certain areas on the bluffs due to safety concerns of Jeople working in those areas (Fencil circa 1996. Bunney 1995, and Roeder 1996). Such safety i
concerns could be the basis for the aoplication of criterion (a).
However, the text of the VP CR provides no information to support application of this criterion.
In addition, section B.2 of Appendix B (MK-F 1996) and one of the memoranda (Fencil circa 1996) indicate that some hand excavation of Aria I was completed. with personnel tied off with safety ropes.
Such a safety measure would seem to be a reasonable measure to reduce the risk of injury to workers.
If the same safety measure could be applied for all the supplemental standards areas. the safety hazard might be mitigated, and criterion (a) might then be inappropriate as justification for using supplemental standards.
No justification for the application of criterion (b), related to producing environmental harm, has been provided in the VP CR.
From the discussion in the VP CP. it appears that neither criterion (a), (b), or (c) has been sufficiently justified, and it is not clear which criteria are the most applicable to the contamination on the bluffs of this property.
Reconanendation:
DOE should determine which criteria of 40 CFR 192.21 apply to the contamination along the bluffs, and must provide sufficient justification for those criteria that do apply in the RF-493S VP CR.
If criterion (c) of 40 CFR 192.21 is used to allow application of supplemental standards, additional justification must be provided, to clearly demonstrate that costs for cleanup are unreasonably high, relative to the benefits.
DOE may wish to reconsider the applicability of all of criteria (a), (b), and (c) of S 192.21.
That is, justification for some of the criteria may not be feasible or appropriate: if not, such criteria could be eliminated from j
consideration.
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- 2) Meeting the Supplemental Standards:
For areas of supplemental standards application, the VP CR has not demonstrated compliance with the supplemental standard, which requires that remedial actions come as close to meeting the otherwise applicable standards as is reasonable.
Discussion:
If supplemental standards are applied based on criterion (a).
(b). or (c) of 40 CFR 192.21 tne cleanup is required. by 40 CFR 192.22(a) to "...come as close to meeting the otherwise applicable standard as is reasonable under the circumstances." It has not been clearly demonstrated in the VP CR that this has been done for the supplemental standards areas along the bluffs.
There are four separate areas to which application of su)plemental standards is intended: they are labeled Areas 2
G. H. and I.
Drawing RF-493-034 shows Area F as being above the top of the bluffs by about 50-100 ft.
If this is correct, it is not clear why the contamination was.10t cleaned on.
In addition, in Area I the most contaminated material (based cn High Outside Gamma (H0G) measurements) was removed by hand excavation, with approariate safety precautions taken (section B.2 of Appendix B of t1e VP CR).
It seems likely that a similar approach could have been taken for the other supplemental standards areas.
No other discussion of this was provided in the VP CR.
Recommer4 tion:
DOE must Jemonstrate in the VP CR that remedial actions in the su)plemental standards areas came as close to meeting the otlerwise applicable standards as was reasonable, given conditions in those areas.
3)
Possible Contamination in Two Dry Ponds and Two Areas Along Bluffs:
Information provided in the VP CR for RF-4935 is insufficient to conclude that contamination did not extend to the two dry ponds and to two additional areas along the bluffs Discussion:
There are a few areas of the site for which the extent or possible extent, of contamination has not been thoroughly described in the VP CR.
Since the areas were not characterized or described in the VP CR. it is difficult or impossible to determine if the EPA standards for cleanup of soils have been met in those areas.
The two dry Jonds, on the eastern side of the site. lie within the area of wind] lown contamination.
However. essentially no contamination was noted in the bottoms of these dry ponds, and it is not clear why.
Note 8 of drawing RF-493-020 in the VP CR indicates that a radiological survey would be performed over unexcavated areas of the ponds.
The results of this survey were not included or mentioned in the VP RF-493S CR.
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From information in drawings RF-493-020 and RF-493-030. there are two areas along the bluffs on the west and southwest sides of the property for which no contamination and no remediation were indicated.
The first area is along the property boundary, generally within coordinates 1220-1350 (west) and 400L-700L (south).
The second area is toward the southwest boundary of the site, generally i
within courainates 830-1100 (west) and 630L-920L (south).
Supplemental standards areas F and G are at the edges of this second area.
These may be areas which could not be characterized, but this is not clear from the CR.
A lack of contamination in these areas seems unlikely, as the areas lie within a large area of windblown contamination.
Both areas are within the limit of off-pile contamination shown in Figure D.2.4 of the RAP (DOE 1992).
In addition, it appears that only a small number of characterization samples were obtained in these areas. though the results (which should be in the REA) have not been reviewed.
Recommendation:
Additional information should be provided in the CR to support the conclusion that contamination did not extend to the two dry ponds and two areas along the bluffs.
Results of surveys performed over unexcavated areas should be provided.
Data from the REA should be provided, or referenced, if necessary or helpful.
- 4) Elevated Thorium 230 and Uranium in Trash Dump Area Information provided in the VP CR is insufficient to document 2
investigations of potentially elevated Th and U levels in soil near the trash dump area.
Discussion:
Results of the characterization cf the Old Rifle site performed by Bendix (Allen 1985) included one soil sample in the trash dump area that contained elevated concentrations of 2 Th (211 pCi g") and total U (662 pCi g"), relative to the ma concentration (32 pCi g")
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in the same sample.
This was a surface (0-15 cm) sample from Sorehole 261.
This borehole was roughly 875 ft west and 250 ft north from the center of the northern dry aond.
This may be in the area of boreholes 192 and 193 of the REA.
T1ere is no indication in the VP CR that 2 Uh and U contamination have been investigated in this area.
If significant contamination of 2 Th and U exists, the l
supplemental standards provisions of 40 CFR 192 must be applied.
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Recommendation:
Additional information should be provided to document investigations j
2 of the elevated Tn and U levels near the trash dump area.
Data from the REA should be provided, or referenced, if necessary or helpful.
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- 5) Potential Contamination Remaining Under Tree Root Systems:
The extent of potential contamination remaining under root systems 4
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i of tree; has not been adequately described.
Discussion:
Note 12 of the "as-built" drawing of excavation and restoration, drawing RL 493-020 in the VP CR (MK F 1996). indicated that excavation arounu large trees was to be done in a manner that wouid preserve the root systems of the trees.
This seems to indicate that some contamination may have been left under and within the root systems of trees.
The VP CR provided no other information about the potential for this type of contamination.
If 22 era contamination has been left at concentrations above the standards, this may be a situation where supplemental standards should be applied.
Recommendation:
Additional information should be provided to document what is known about contamination that may remain under the root systems of large trees on the property.
If contamination remains with 22sRa concentrations above the EPA standards, supplemental standards may need to be applied.
- 6) Extent of Contamination Remaining in Area I:
The extent of contamination remaining in supplemental standards Area I has not been clearly described.
l Discussion:
The extent of remediation and residual contaminatiori in supplemental i
standards Area I are not clearly shown in the VP CR.
Section B.2 of Appendix B to the VP CR indicates that some remediation of Area I was performed in October 1995.
One of the memoranda included in the d CR l
(Fencil circa 1996) seems to indicate that not all of the contamination 1
l of Area I was cleaned up.
However. Area I is not delineated on the l
drawing showing the extent of the other supplen.2ntal standards areas l
(Drawing RF-493-034 in the Vf CR).
In addition, section B.3 of Appendix B of the VP CR indicates that 22sRa l
concentrations in supplemental standards areas ranges up to 178.6 l
pCi g", and Table B.T3 of the same appendix indicates that the highest concentration is in Area I.
However. Table B.T5 of the appendix shows 22 era concentrations only up to 16.7 pCi g". though two samples shown in 4
this table exceed 5 pCi g above background (the standard for surface soils). There is no indication in Table b.T5 as to whether the samples reported are com30 site samples, as are usually obtained for verification l
i samples, or if t1ey are single-point samples.
l From the information provided in the VP CR. described here. the extent of contamination remaining in Area I is not clear.
Recommendation :
The extent of contamination remaining in supplemental standards Area I j-should be more clearly described.
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of trees has not been adequately described.
Discussion:
Note 12 of the "as-built" drawing of excavation and restoration.
drawing RF-493-020 in the VP CR (MK-F 1996), indicated that excavation around large trees was to be done in a manner that would preserve the root systems of the trees.
This seems to indicate that some contamination may nave been left under and within the root j
systems of trees.
The VP CR provided no other information about the i
i potential for this type of contamination.
If 22 era contamination has been left at concentrations above the standards, this may be a situation where supplemental standards should be applied.
Recommendation:
Additional information should be provided to document what is known about contamination that may remain under the root systems of large trees on the property.
If contamination remains with 22 era concentrations above the EPA stan M 3, supplemental standards may need to be applied.
- 6) Extent of Contamination Remaining in Area I:
The extent of contamination remaining in supplemental standards Area I has not been clearly described.
Discussion:
The extent of remediation and residual contamination in supplemental standards Area I are not clearly shown in the VP CR.
Section B.2 of Appendix B to the VP CR indicates that some remediation of Area I was performed in October 1995.
One of the memoranda included in the VP CR (Fencil circa 1996) seems to indicate that not all of the contamination of Area I was cleaned up.
However, Area I is not delineated on the i
drawing showing the extent of the other supplemental standards areas (Drawing RF-493-034, in the VP CR).
j In addition, section B.3 of Appendix B of the VP CR indicates that 22 era concentrations in supplemental standards areas ranges up to 178.6 4
pCi 9, and Table B.T3 of the same appendix indicates that the highest concentration is in Area I.
However. Table B.T5 of the appendix shows 22 era concentrations only up to 16.7 pCi g", though two samples shown in this table exceed 5 pCi g' above background (the standard for surface soils).
There is no indicEtion in Table B.T5 as to whether the samples reported are com30 site samples, as are usually obtained for verification samples, or if t1ey are single-point samples.
From the information provided in the VP CR, described here, the extent of contamination remaining in Area I is not clear Recommendation :
The extent of contamination remaining in supplemental standards Area I should be more clearly described.
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- 7) QA Analyses for 22sRa:
Results of offsite QA analyses for 22 era in soil samples were not documented in the VP CR.
Discussion:
UMTRA Project Standard Operating Procedure OP-003-1 for verification sampling (Lewandowski 1993) requires. as a quality control measure, that 4% (at least) of verification soil samples analyzed onsite are also 22 analyzed offsite (at another laboratory) for Ra.
The VP CR did not provide results for these quality control analyses.
Recommendation:
228 If the 4% 0A/0C analyses of Ra in soil samples have been performed for RF-493S. the results should be documented or discussed in VP CR.
EDITORIAL COMMENTS Two editorial errors are noted:
1.
Sections B.2 and B.2.1 in Appendix B to the VP CR. indicate that the areal extent of contamination left in supplemental standards areas is
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2 2132 ft.
However, in Drawing RF-493-034 of the VP CR. the areal extent 2
is indicated to be 2132 yd It appears that the latter is correct.
Clarification is necessary in order to accurately reflect the extent of contamination remaining in supplemental standards areas on the property.
2.
In the table of Appendix A. the heading should indicate "Ra-226" instead of "Ra-266."
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l REFERENCES Alien J.H.1985. Radiologic Characterization of the Rifle. Colorado.
Uranium Mill Tailings Remedial Action Sites. Rep. GJ-29. Bendix Fie1d Engineering surporation, urand ounction. Colorado. Incorporated as Addendum D1 to: U.S. Department of Energy.1991. Remedial Action Plan and Site l
Design for Stabilization of the Inactive Uranium Mill Tailings Sites at l
Rifle. Colorado. Final. Volume IV - Addenda D1 through D5 to Appendix D.
August 1991.
Bunney S.1995. RF-493 Supplemental Standards Applications. Internal memorandum to file, dated January 19. 1995. MK-Ferguson Company. Rifle.
DOE (U.S. Department of Energy).1992. Remedial Action Plan and Site Design for Stabilization of the Inactive Uranium Mill Tailings Sites at Rifle.
Colorado, Final. Volume II - Appendices D and E. February 1992.
Fenci1 R.R. Circa 1996. Supplemental Standards Request. Rifle UMTRA Project. Rifle. Colorado. Property I.D. RF-493. dndated report.
Hamp S.C.1996. Vicinity Property No. RF-493. North of Highway 6 & 24. East of Ash Avenue. Rifie, Colorado. Letter to J.J. Holonich, dated October 28.
i
- 1996, i
Lewandowski M. 1993. Health Physics Standard Operating Procedure.
Verification Soil Sampling. Procedure number OP-003-1 revision 1. approved October 22. 1993, MK-Ferguson Company anc' CWM Federal Services. Inc MK-F (MK-Ferguson Company and Rust Federal Services. Inc.).1996. Vicinity Property Completion Report at RF-4935, North of highway 6 & 24. East of Ash i
Avenue. Rifle. Coloraao. September 12. 1996.
Roeder J.1996. Application of Supplemental Standards Vicinity Property l
RF-493. Internal memorandum to file, dated March 13, 1996. MK-Ferguson l
Company. Rifle. Colorado.
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