ML20151D995
| ML20151D995 | |
| Person / Time | |
|---|---|
| Issue date: | 07/11/1988 |
| From: | Heyer R, Pettengill H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| REF-WM-39 NUDOCS 8807250316 | |
| Download: ML20151D995 (3) | |
Text
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t' DISTRIBUTION Docket File No. 40-WM39
(
-PDR/DCS 40-WM39/RSH/88/06/29/1 DBangart, RIV.
RHeyer URF0 r/f JUL 11 1988 URF0:RSti Docket No. 40-WM039 040WM039120E MEMORANDUM FOR:
Docket File No. 40-WM039 FROM:
Ralph S. Heyer, Project Manager Licensing Branch 2 Uranium Recovery Field Office, Region IV
SUBJECT:
REVIEW 0F JUSTIFICATION FOR APPLICATION OF SUPPLEMENTAL STANDARDS AT VICINITY PROPERTY GJ-97001-0T Backaround By submittal dated April 13, 1988, the Department of Energy (00E) supplied the final Radiological and Engineering Assessment (REA) which requested the application of supplemental st'andards;on the contaminated areas for vicinity property GJ-97001-0T.
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Discussion N
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This application for supplemental standards involves a hi'h pressure g
waterline which is bedded in uranium mill tailings.w It extends for one mile between 28 Road and 29 Road along the north si_de of North Avenue (Colorado State Highway 6) to a depth of approximately six feet.
The assessment data consists of surface gamma exposure rate measurements and surface delta scintillometer radium concentration measurements.
Only a few borehole measurements were taken because of the danger of augering into the high pressure waterline.
The borehole measurements that were taken do indicate that tailings exist in concentrations up to 214 pCi/gm 3
and that the depth of contamination is approximately 72 inches.
00E proposed either (1) partial removal or (2) no removal and the
(
g justifications are as follows:
i 0FC :
8807250316 000711 PDR WASTE NAME :
WM-39 PNU DATE :88/06/30 r
40-WM39/RSH/88/06/29/1 JUL i 11988 1.
Justification for Partial Removal:
The justification for application of supplemental standards is based on criteria "A" and "C".
Complete or partial removal of tailings would pose unnecessary risks to both the general public and the workers involved in the remedial action process.
North Avenue (a four-lane thoroughfare) is one of the main arteries of the city and the process of uncovering the high pressure water line may cause the line to rupture resulting in the possibility of serious injury to the workers and the interruption of utility service to many customers.
The remedial action for partial removal of tailings to a depth of 30 inches for the entire strip from 28 Road to 29 Road will cost $220,051.
The remedia. action for complete removal of tailings to a depth of 82 inches for the same strip will cost
$704,282.
Removal of tailings to a depth of 30 inches and replacement with clean will would essentially reduce the surface exposure rate to background levels.
2.
Justification for No Removal (No Action):
The risk to the general public is the direct gamma exposure from the tailings.
The gamma exposures range from 12 pR/hr to 127 pR/hr, with an average of 66 pR/hr (51 pR/hr above background) for the high end of the ranges.
Leaving the mill tailings in place would increase the dose rate to an individual by an estimated 38 mrem /yr.
(This is based on continuous exposure.)
Therefore, the calculated dose rate for the no action option is more than safe as the general public would not spend more than a couple of minutes in that area per day.
Given that land use for these state-owned rights-of-way is not expected to change, the benefit of removing the contamination is minimal, and the residual radioactive tailings would not pose a significant health hazard to the general public.
Conclusion Based on my review of the subject REA, associated letters and in accordance with Criteria "d" of 40 CFR 192.21 and the NRC's "Guidelines for Justifying the Use of Supplemental Standards, in 40 CFR Part 192",
dated July 3, 1986, DOE satisfied the criteria deemed necessary to apply 0FC :
NAME :
DATE :88/06/30
40-WM39/RSH/88/06/29/1 JUL i 11988 supplemental standards.
It is suggested that the action of no. removal be taken and it is therefore recommended that concurrence be granted for-the application of supplemental standards for the property designated as GJ-97001-0T.
/sr/-
Ralph S. Heyer, Project Manager Licensing Branch 2 Uranium Recovery Field Office Region IV Approved by:
/5!
Harry J. Pettengill, Chief Licensing Branch 2 Uranium Recovery Field Office
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Region IV Case Closed:
040WM039120E i
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DATE :88/06/30 7[/l i
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