ML20150D873
| ML20150D873 | |
| Person / Time | |
|---|---|
| Issue date: | 05/05/1988 |
| From: | Heyer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| REF-WM-39 NUDOCS 8807140210 | |
| Download: ML20150D873 (3) | |
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DISTRIBUTION Docket File No. 40-WM039 (PDR/DCS~*
40-WM039/RSH/88/04/19/0 DBangart, RIV RHeyer AHazle, RCPD, C0 LLO Branch, LLWM URF0 r/f ~
DSollenberger, HQ MAY. 5 1988
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URF0: RSH Docket No. 40-WM039 MEMORANDUM FOR:
Docket File No. 40-WM039 THRU:
Harry J. Pettengill, Chief Licensing Branch 2 Uranium Recovery Field Office, Region IV FROM:
Ralph S. Heyer, Project Manager Licensing Branch 2 Uranium Recovery Field Office, Region IV
SUBJECT:
MEETING TO DISCUSS VICINITY PROPERTIES AND SUPPLEMENTAL STANDARDS On April 12, 1988, I met with officials from Department of Energy (DOE),
Colorado Department of Health (CDH) and UNC-Geotech (UNC) to discuss the application of supplemental standards to UMTRA program vicinity properties.
The meeting was held in the DOE Grand Junction Project Office.
The following individuals were in attendance:
Howard Roitman CDH Jon Luellcn CDH Bud Franz CDH Donald MacDonald UNC Michael Gardner UNC Richard Murri UNC Michael Madsen UNC DFo 3 Michael Tucker DOE-GJP0 Joe Virgona 00E-GJP0 I 0 W. John Arthur DOE-Albuquerque L. Tony Brazley DOE-Washington DC The meeting addressed current DOE policies and procedures for preparation M
of Radiological Engineering Assessments (REA's) in support of NRC and OFC :
NAME :
DATE :88/05/05 8807140210 880505 PDR WASTE WM-39 PDC
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40-WM039/RSH/88/04/19/0 MAY 5 1988 State concurrence of the application of Supplemental Standards (SS),
Up to the date of the meeting NRC-URF0 staff have approved three specific requests by 00E for application of SS for which the COH staff have not provided similar concurrence.
CDH voiced several concerns during the meeting.
These concerns are summarized as follows:
1.
The COH believes they need to be involved earlier with 00E contractors in the preparation and development of actual REA's and provided more complete data and information than is currently provided in REA's.
Thus, CDH has not been comfortable in providing concurrence based upon existing data provided in REA's.
2.
The COH expressed concern that once the UMTRA program has been ccmpleted and those areas where SS were applied may be disturbed (beyond the 5 year land use criteria).
COH was concerned that additional monies are not available to clean up those areas that may subsequently be contaminated due to future disturbance.
3.
The CDH stated that, aside from the existing guidelines and regulations, additional information may be needed to justify application of SS on a case by case basis.
I stated that our position remains as described in the MOV between DOE and NRC.
This position was that any information submitted by DOE in the REA's would be reviewed utilizing EPA's 40 CFR 192 Criteria, for adequate application of SS.
I concurred with CDH that insufficient guidance is currently available regarding the application of cost / benefit for SS versus long-term public health and safety implications and that we would continue to weigh heavily on the side of potential health and safety impacts.
A tour was conducted of those VP's where SS have already been requested or will be requested this year.
The DOE contractor stated that a "generic" SS request will be forthcoming which will involve a 3 block area and affect numerous private shop owners in the Shopping Mall Area Downtown Main Street.
In addition, a request for SS to clean up portions of the Lincoln Park Golf Course will also be submitted.
0FC :
NAME :
DATE :88/05/05 n
- L *. f i
40-WM039/RSH/88/04/19/0
) MAY 5 1988 Both of the aforementioned types of extensive SS requests have not been reviewed by the NRC in the past.
Thus, a more rigorous and supportive analyses may be warranted for these cases.
On April 13, 1988, I attended a meeting between DOE, CDH and UNC representatives in which the results of a six-month trial period for excavation control criteria and the performance of an Opposed Crystal System (OCS) was discussed.
Before implementation of the OCS program for UMTRAP VP's any soil data collected was based strictly on the use of hand held scintillometers.
The purpose of the trial period using the OCS van was to determine if the van could be used as a viable means of providing quick and reliable radium-in-soil cor,cetration analyses at UMTRAP VP's.
The meeting focused on the results of that six month trial period and the purpose of developing the OCS pur want to an Agreement between CDH and DOE dated May 18, 1987.
This 0CS system has been put into a van and used in the field for five months.
The statistical, quality control and comparative tests that have been performed during the test period apparently confirm the ability of the CCS to accurately and consistently measure both calculated and true r;dium-in-soil concentrations.
The procedures utilized in the OCS program are clearly defined in the Vicinity Property Management Implement Manual (VPMIM).
Therefore, the need for NRC concurrence on the OCS Program is not needed since we have reviewed and accepted the procedures in the most recent Revision D to VPMIM.
IS/
Ralph S. Heyer, Project Manager Licensing Branch 2 Uranium Recovery Field Office Region IV OFC
_ _ _ _ _ _ _ _U,R F,0,
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b DATE$38/05/05
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