ML20154J463
| ML20154J463 | |
| Person / Time | |
|---|---|
| Issue date: | 11/14/1984 |
| From: | Martin D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20154J457 | List: |
| References | |
| FOIA-85-843 NUDOCS 8603100611 | |
| Download: ML20154J463 (6) | |
Text
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Distribution D 'i)'y WM 39 s/f/
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NOTE:
Branch Chief, WMGT Branch Chief, WMEG 1
FRON:
Dan E. Martin, WMLU
SUBJECT:
Branch Concurrences on Proposed Higginbotham to Themelis Letter Conditionally Concurring in DOE Plan to relocate Salt Lake City Tallings to Clive. Utah.
Based on available information we believe the proposed letter to DOE (copy attached) is appropriate. Before this step is taken we should have firm agreement that all necessary reviews have been completed and no other t
unresolved issues (except rock size) need to be brought to DOE's attention.
Since the scope, content, results, and basis for conclusions of these reviews i
have not yet been documented. I am requesting each Branch Chief, or Acting Chief, to provide a written answer to the following question, using the form attached for this purpose.
The question is "Has your branch completed all assigned reviews with respect to the Remedial Action Plan for relocation of the Salt Lake City tallings to L
C11ve Utah, and concluded that no unresolved issues exist beyond those mentionedintheWMLU.proposedlettertoDOE(otherthanissuesconcerning ground water at the Salt Lake City site)?"
A prompt yes or no answer is requested. Several staff hours were spent yesterday atterrpting, but failing, to secure appropriate branch concurrences in i
the letter itself. Your cooperation on this matter now is needed to avoid further unnecessary delay.
Dan E. Martin Attachments:
(1)WMLU.ProposedLetter (2)BranchConcurrenceForm I
cc: LB Higginbothan GN Gnugnoli 0603100611 060124 RA Pennift11 0$noh@fg43 pnn
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DATE184/11/ly 1
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Mr. John G. Themelis, Project Manager UMTRA Project Office U.S. Department of Energy Post Office Box 5400 Albuquerque, New Mexico 87115
Dear Mr. Themelis:
Enclosed is the signed signature page for the Salt Lake City Site Remedial Action Plan. As we have discussed in the past, this concurrence is conditional with respect to two issues.
If these conditions are not acceptable to you, plesse contact me irrediately.
The first condition is with respect to the rock size to be used,for the erosion protection cover at Clive. The rock size to be used has not been agreed upon by NRC and 00E.
Prior to the rock cover being placed on the pile, the DOE will receive concurrence from NRC on the size of rocks to be used.
The second condition is that the durability specifications provided in the attachment to ycur letter to me dated October 29, 1984, be provided to Utah with the changes discussed in the second enclosure to this letter.
These changes have been discussed with Ron Rager of the TAC and are editorial and typographical clarifications.
I would also like you to note that the modeling which supports your assumptions of a 2-bar moisture content in the radon cover, which we previously requested, was not sent to us. Therefore, we have not been able to make a detemination if using the 2-bar moisture content will be acceptable at other sites, such as Shiprock.
Our basis for accepting this moisture content at Salt Lake City is also discussed in the second enclosure to this letter.
Sincerely, Leo B. Higginbotham, Chief Low. Level Waste and Uranium Recovery Projects Branch Division of Waste Management
Enclosure:
1.
Signature Page 2.
Resolution of Geotechnical Issues cc:
Larry Anderson, Utah Bureau of Radiation Control b%
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DISTRIBUTION:
i NM55 r/ f BMLU r/f ie WM s/f RE Browning l
WM41/ RAP /84/11/08 MJ Bell JO Bunting
-1 M Knapp L Barrett l
Mr. John G. Themelis, Project Manager D Gillen. WMEG S Smykowski. WMEG UMTRA Project Office M. Weber. WMGT B Ford. WMGT TL Johnson U.S. Department of Energy G Gnugnoli.. WMGT H Blackford, WMGT l
R Pennifill l
Post Office Box 5400 Albuquerque. New Mexico 87115 C Flory D Martin Dwar Mr. Themelis:
l Enclosed is the signed signature page for the Salt Lake City Site Remedial l
Action Plan. As we have discussed in the past, this concurrence is conditional with respect to two issues.
If these conditions are not acceptable to you, l
please contact me ilmnediately.
The first condition is with respect to the rock size to be used for the erosion protection cover at Clive.
The rock size to be used has not been agreed upon I
by NRC and 00E.
Prior to the rock cover being placed on the pile, the DOE will I
receive concurrence from NRC on the size of rocks to be used.
The second condition is that the durability specificat ans provided in the attachment to your letter to me dated October 29, 1984, be provided to Utah with the changes discussed in the second enclosure to this letter. These changes have been discussed with Ron Rager of the TAC and are editorial and typographical clarif1 cations.
i i
! would also like you to note that the tredeling which supports your assumptions of a 2.bar moisture content in the radon cover, which we previously requested, was not sent to us.
Therefore, we have not been able to make a determination if using the 2.bar moisture content will be acceptable at other sites, such as l
Shiprock. Our basis for accepting this moisture content at Salt Lake City is l
also discussed in the second enclosure to this letter.
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Sincerely, f
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Leo B. Higginbotham, Chief I
Low. Level waste and Uranium Recovery l
l Projects Branch Division of Waste Managertent i
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l U.S. Department of Energy Agreement No. DE-FC04-81AL16309 Append,ix 8 l
l SIGNATURE PAGE l
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The United States of America State of Utah Department of Energy Departme of Health
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By: - M M#
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Theetis v. Hill Kenneth Lee Alkema. DLrector i
Contracting Officer Division of Environmental Health i
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James A. Morley Project Manager UMTRA Albuquerque Operations Office Concurrence:
U.S. Nuclear Regulatory Commission By:
Leo B. Higginbotham Chief. Low-level and Uranium Projects Branch Division of Waste Management i
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NOV 0 9 884 RESOLUTION OF OPEN GEOTECHNICAL ENGINEERING ISSUES SALT LAKE CITY RAP REVIEW 1.
Rock Durability Specifications detailed in Attachment 8 of DOE's response, including those I
pertinent to rock durability criteria, are found to provide an acceptable program for ensuring that the most durable rock that is available in i
sufficiert quantity and is located within a reasonable distance of the i
site will be used for erosion protection.
Note that there are two inconsistencies in the Attachment B specifications.
The absorption criteria given as 10% in the first paragraph should be 1.0% as indicated at a later point in the attachment.
In addition, the reference to ASTM C131 in item 2 on the second page should be deleted to be consistent with I
statements in the first paragraph of the attachment.
It is understood i
that these specifications are to be included in the general specifications l
that will be provided to the RAC (State of Utah) by the TAC.
A copy of these specifications should be submitted to the NRC when they are finalized.
2.
Cover Material Dispersivity The staff will not require further testing to determine the dispersive characteristics of the cover material provided that the RAP's commitment to meeting appropriate filter criteria is strictly adhered to.
Section 6 of Appendix B to the RAP indicates that O g filter /D s base < 5 will be g
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the criterion used in final design.
This is an acceptable criterion for l
design of the filters beneath the cover for this project.
A study by l
Sherard (Ref. 1) has recently concluded that this criterion is l
conservative, employs the appropriate characteristics of the filter and base, and should be continued as the main criterion for judging filter l
acceptability.
3.
Slope Stability l
The staff concludes that the TAC's treatment of the upper clay layer in the dynamic stability analysis is adequately conrervative based on the following facts:
s.
The TAC's August 22, 1984 response to NRC questions incorrectly reported 4 a 34' for this layer, when in actuality 4 = 23' was used in the analysis.
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'l NOV 0 91984
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b.
Whatever remains of this layer at the base of the excavation will be either scarified and compacted to 95 percent of the maximum dry density (ASTM 0698), or removed by overexcavation, moisture conditioned, and recompacted.
Thus, actual strengths of this material would exceed values used in the analysis.
4.
Cover Moisture Content Using correlations proposed by Rawls (Ref. 2), the staff has independently i
calculated the long-term, 15 Bar, moisture content of the proposed cover material to be approximately 13%.
However, the TAC's use of 18% in the cover thickness calculations is determined to be acceptable for the following reasons:
a.
In-situ, near-surface moisture contents of the cover naterial at the site have been shown to range between 21% and 35% (ave. of 29%) in l
both February and August.
The cover material therefore exhibits high I
moisture retention with little seasonal fluctuation.
b.
The staff recognizes that the filter and rock layers over the soil
. cover will significantly improve the cover's moisture retention capab ility.
l l
1 l
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Ref. 1 Sherard, J.
L., Dunnigan, L. P., and Talbot, J. R., " Basic Properties cf Sand and Gravel Filters," Journal of Geotechnical l
Engineering, ASCE, Vol. 110. No. 6, June, 1984, t
Ref. 2 Rawls, W. J., and Brakensiek, D. L., " Estimating Soil Water Retention from Soil Properties," Journal of the Irrigation and i
Drainage Division, ASCE, Vol. 108, No. IR2, June, 1982.
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NOV 211934 oistribution:
WR41 s/f, PDR RE Browning WMLU r/f MJ Bell NMSS r/f.
GN Gnugnoli Mr. John Themelis, Project Manager
.CA Flory Uranium Mill Tailings Project Office
'0E Martin Albuquerque Operating Office RA Pennifill V. S.-Department of Energy JO Bunting P. O. Box 5400 Albuquerque, New Mexico 87115
Dear Mr. Themelis:
My staff has reviewed the document " Health, Safety and Monitoring Plan for the Vitro Tallings Remedial Action in Salt Lake City, Utah" which was submitted to us by the State of Utah. We are sending you our response to this document as previously agreed. Please disregard our coments to the contrary in my letter to Jim Morley of October 18, 1984. We will also send our responses on the Radiological Support Plan and the Quality Assurance Plan for the Salt Lake City Vitro remedial' action directly to your office.
At this time we cannot give the health and safety plan the concurrence which is required by the Remedial Action Plan for the Vitro tailings site (UMTRA-D0E/AL-0141). Additional details and some modifications to the health and safety plan are needed before we can concur. Staff coments on the plan are enclosed.
The first three coments are major comments. Coment one addresses possible revisions to the health and safety program and coments two and three identify two major omissions in the health and safety plan.
In addition, because of the unique conditions of this planned remedial action, a " Transportation Health and Safety Plan" should be developed as an appendix to this site health and safety plan. A transportation health and safety plan is needed because a large quantity of contaminated material will be translocated from the midst of a densely populated area, over heavily traveled routes, to a distant disposal area. Sections of this health and_ safety plan, as identified in the comments, could be used-in the transportation health and safety plan.
-In otscussion with the Utah staff, my staff has learned that the health ano safety plan is a general guidance document to guide contractors in development of specific health and safety procedures. Because of the general nature of the
- plan my staff, in order to resolve some of our coments, may need to review some contractor _ plans and procedures and/or make a health and safety site visit at the comencement of remedial action prior to our full concurrence.
fl fE OFC :WMLU
- WMLU
- WMLU
- WMLU NAME :CA Flory:rb :RA Pennifill DE Martin
- LB Higginbotham DATE :84/10/
- 84/10/
- 84/10/
- 84/10/
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WM41/CAF/84/10/30 D 2 l 1994 My staff is available to work with your staff and Utah staff toward completion of an adequate health and safety program.
Please contact Mr. Dan E. Martin (301-427-4694) or Mr. Roger A. Pennifill (301427-4160) concerning our concurrence on the health and safety plan. Questions on staff health and safety coments should be directed to Mr. Claude Flory (301-427 4554).
Sincerely,
'Drf guial Wg:1 o ay Jeu 13, liigg.Lboth.uu Leo B. Higgint,otham, Chief Low-Level Waste and Uranium Recovery Projects Branch Division of Waste Management
Enclosure:
Staff coments cc: Larry Anderson - Utah (w/ enclosure)
Gerald Ripley - Utah (w/ enclosure)
John Arthur - DOE, Albuquerque (w/ enclosure)
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1 Comnents on the " Health, Safety and Monitoring Plan for the Vitro Tailings Remedial Action in Salt Lake City, Utah."
NOTE:Several of the comments are related to comments on deficiencies noted in DOE's UMTRA Environmental, Health, and Safety Plan. A copy of NRC's connents on the DOE's plan is attached and referred to at the end of the related connents.
1.
In several places the Health, Safety and Monitoring Plan (The Plan) states that the radiological safety program could be changed based on available data.
(p.1, Introduction,13; p.4, External Dosimetry,11; p.5, Bioassay, 12; p.7, Occupational Exposure to Radon; p.8, Environmental Monitoring.11)
The Plan should explain the specific conditions which allow a procedural change and should oescribe the optional program procedures. Any change in the radiation safety program should be accompanied by an appropriate revision to The Plan. Any substantial revision to The Plan would need NRC review and concurrence.
In many cases a plan revision would not be needed if the program options and the conditions which allow implementation of the options are adequately explained.
2.
The Plan should contain a section on radiological staff organization.
This section would explain the organizational structure and staff qualifications, authorities, and responsibilities which would ensure an adequate radiological safety program.
(See UMTRA Plan connent 1.)
3.
The Plan does not identify any inspection and audit program.
(See UMTRA Plan connent 2.).
4 NRC reconnends that The Plan contain an appendix which lists the types and approximate number of radiological safety equipment.
5.
P.1,51:
Is this plan also intended for use at the Central Valley Water Reclamation Facility (CVWRF)? If not, there should be a section, possibly an appendix, which describes radiological safety during remedial actions at the CVWPF.
6.
P.3, Access Control:
(1) This section describes measures to control access to the site at a control point.
It should also require measures to prevent inadvertent or intrusive entries at other parts of the site boundary. Also, will there be more than one control point of entry and kW
2 2
will the same degree of access control be applied at all entry points?
(2) The term " restricted area" should be defined.
Is it intended to be the same as a " controlled area" as defined in the 00E plan? (See UMTRA Plan coment 3.).
(3) The Plan should explain the conditions "under which personnel and equipment may enter restricted areas".
7.
P.3, Training:
(1) The workers should receive annu:21 reorientation training. Safety meetings which include radiological concerns should be conducted at least monthly.
(2) This section states that persons receiving safety orientation training will be asked to sign a statement.
The legality of having a worker sign a statement that he understands the safety training may be questionable. NRC recomenos that the worker be required to pass a test.
8.
P.4, External Dosimetry:
(1) Transport personnel will not be badged after initial readings verify " anticipated" exposures. The Plan should specify the exposure levels at which transport personnel would not be required to wear badges. Also, this section is not clear about the status of badges on other personnel throughout the life of the project. To remove this uncertainty the woro " initially" in the third sentence should be deleted and a more posit 1ve statement about the requirement to wear badges should be added.
(2) Several suggestions are offered. First, the badges should not be worn above the waist because the worker will usually be standing upon the source. A badge worn at the waist would then accurately measure the dose to the organ that probably will receive the dose of greatest significance--the gonads. Second, there will probably be a badge contamination problem. This can be combatted by wearing the badge covered dnd by washing the badge at the end of each shift.
9.
P.4, Bioassay:
(1) The Plan should specify action levels and follow-up procedures.
(2) The Plan states that "the need for bioassay will be predicated on the results of air monitoring" and that the bioassay program may be revised. The conditions which would allow revisions and the proposed alternate program should be explained. A bioassay program should never be revised based on air monitoring results alone; nor should bioassay monitoring be completely eliminated. Because air monitoring does not precisely measure internal doses some level of bioassay monitoring is needed.
(3) The Plan states that a seven pound intake of Vitro tailings in one year would yield the ALI for Ra-226 as specified in ICRP 30, Part 1.
This is based on an oral intake; the inhalation ALI for Ra-226 would limit the intake to two pounds of Vitro tailings annually. The limit for Th-230 inhalation intake is about one ounce.
A95'
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3 10.
P.5, Protective Clothing and Change Facilities:
(1) The Plan requires transport personnel to remain in their cab while loading. This requirement may be difficult to enforce; it would be more reasonable to give transport workers shoe covers and allow them to leave their cab if necessary. (2) The Plan should specify wash basins and showers for the change facilities.
11.
P.6, Occupational Exposures to Radioactive Particulates in Air: The Plan states that area samples will be used to collect work area air particulate samples. " Area samples" ncrmally are fixed environmental samples. The Plan should be more specific when requiring sampling in the work area.
The primary consideration should be to obtain a sample that is as representative as reasonably achievable of the actual worker exposure condition. Airborne radionuclide concentrations can vary considerably over time and space. The Plan should address this variability by stating conditions by(which the frequencies and locations of air samples are to be determined.
See UMTRA Plan Comment 5) Initial studies should be conducted to evaluate the effectiveness of the work area sampling.
Studies of the breathing zone air should be conducted to detemine if the area samples are adequately representative of work exposure conditions.
Multiple samples during the work day could be taken to investigate variations of air quality during the day and to correlate air sample results with work and meteorological conditions. The frequency and locations of routine work area sampling could be based on the results of the initial studies. These studies could be repeated when there are significant changes in work or meteorological conditions.
12.
P.7, Occupational Exposure to Radon: There is no provision in The Plan for measuring worker exposures to radon and radon daughters. The Plan calls for area monitors, not personnel dosimeters.
Initial studies, such as those described in the previous content, are needed before personnel dosimetry can be replaced by area monitors. If area radon monitors are used, based on initial studies, The Plan should explain the action levels which will be used to limit worker exposures below applicable standards.
13.
P.10, Equipment Monitoring:
(1) This section should be subdivided. One subsection should accress vehicles and equipment being used continually for handling of tailings; the other subsection should address vehicles and equipment being released for unrestricted use. The second class of vehicles and equipment would require more stringent contamination control procedures and action levels.
(2) The criteria for release of equipment or vehicles for unrestricted use are too high (See UMTRA Plan Comment 4).
An isotopic characterization of the Vitro tailings may be needed to determine the appropriate decontamination criteria levels Aw
=
4
- 14. Transportation health and safety: The sections entitled " Accidental Spillage" (p.2), " Transport Vehicle Hauling" (p.10), and the second bullet item under " Equipment Monitoring" (p.10) should be placed in a
" Transportation Health and Safety Plan." This transportation plan should address all the hazards and health considerations in transporting the tailings from the Vitro site to Clive.
A95
OM 3 gy, 1
UMTRA Project Environmental, Health, and Safety Plan (The Plan) Deficiencies 1.
Lack of a clearly defined organizational structure.
Plan Contents:
Section 2.0 cescribes responsibilities of the UMTRA Project Office (2.1) andcontractors(2.2,2.3). Section 4.1 describes organization and staffing.
Identified Shortcomings:
Ine neastn ano safety responsibilities of the Project Office, the Remedial Action Contractor (RAC), and the Technical Assistance Contractor (TAC) are listed with no explanation of the organizatienal structure which is neeced to effectually fulfill these responsibilities.
The Plan only requires that the contractor have a qualified respcnsible individual hith adequate staff.
It is recommended that the internal structure of the Project Office, RAC, ano TAC be explained and diagrammed.
Then the persons responsible for health and safety can be readily identified and lines of authority can be established within and between the Project Office, RAC, and TAC. Without clearly defir.ed, independent lines of authority for health and safety personnel, the UMTRA health and safety functions can be overshadowed by seemingly more important operational concerns. This can be especicily taportant if there are future tire and budget constraints.
Ir. accition, staff oualificatior.s should be specified in terms of education and experience.
2.
Lack of an acequate inspection and audit program.
Plan Centents:
item c in Section 2.1 ano item g of Section 2.3 icentify the Project Office and TAC responsibilities for the Health and Safety Survey Reports (HSSR). Section 4.7 describes the internal audit program to be conducted by the RAC.
Identified Shortcomines:
7ne sccpe and centent of the health and safety survey, which appears to be an audit by the Project Of# ice with TAC assistance, is not specified. The Plan should specify the scope and contents of the survey in 'arder to i
identify to the RAC specific areas of health and safety cone. erns. A b
W 5 E4 2
procedure for corrective action should be outlined as part of this survey (audit) program.
The above coments on the Project Office survey are applicable to the RAC's audit program. The Plan should also clarify how the RAC's audit findings will be reviewed and acted upon during the Project Office surveys (audits). Other, higher order aucits, such as those by 00E-Headquarters and the RAC's corporate office, should be identified.
The Plan fails to specify any on-site inspection programs. The RAC shculd be required to conduct daily, weekly, and monthly inspections of the work site.
Inspection respcnsibilitics and sccpe; should be outlined and procedures for corrective actions shculd be specified.
3.
The allo tance cf up to 2C0 pCi/gm of Ra-225 soil centeminaticn in uncontrolled areas.
Plan Contents:
Section o.1 cefir.es controlled areas.
Centrolled areas include any area where "significant portiens of the exposed surface contamination exceeds 200 pC1/gm of Ra-226." These areas are to be centrolled to prevent ir. advertent exposure to contaminated caterials.
Identificc Shortconir.cs:
Tne Plan asiows for tne possibility that the general public cculd gain access to lancs with surface contamination of up to 200 pCi/gm.
Limits imposed by the plan en external garrea dose and airborne concentratiens in uncontrc11ed areas nay lessen the public health threat, but the spread of ccrtamint.tien is still pcssible.
It is reco:r.unced that all of the designated processing and disposal sites be controlled to scme degrec.
Controlled areas, as now defined in The Plan, should be restricted areas within the centrolled areas.
Designation of centrolled areas at vicinity properties wculd have to be judged on a case-by-case basis.
4 The inapprcpriate use of ANSI N13.12 Table 2 limits for uncenditicnal release of decontaminated equipcent.
plan Contents:
Section 5.1 specifies that equiptrent released for unconditional use should be decentaminated to the levels in ANSI N13.12, Table 2.
It also states hW
CCI 3 g3e 3
that "an extensive effort shall be made to reduce contamination levels as low as reasonably achievable."
Identified Shortcomings:
The activity limits of 1000 DPM removable and 5000 DPM total, cbtained from Table 2 of ANSI N13.12, are applicable for natural uranium in equilibrium with its decay products. Because the radiological hazard in tailings is predominately from Th-230 and Ra-226 more restrictive limits are needed. These more restrictive limits can be derived frcm the levels specified in Table 1 of the ANSI standard. Note one of Table 1 recommends that the activity limits of the radionuclides cceprising the contamination be weighed to determine the appropriata overall activity limit.
If the tailings are assumed to be 10% U-nat, 45% Th-230, and 45% Ra-226 the apprcpriate allcwable activity limits would be 120 CPM removable and 500 DPM total. (Note that the 500 DPit total is the U-nat contribution. Table 1 recommends nendetectable levels of fixed Ra-226 ana Th-230 where roncetectable is defined as activity less than 100 pCi per 100 cm'.) The requiremant in the plan, to reduce centamination levels as low as reascrably achievable, will probably not be followed at the UttTRA site because the ANSI N13.12 Table 2 values are listed as acceptable levels for release of equiprent.
5.
An inadepuate raciological air monitoring program.
Plan Contents:
Section 6.c requires representative air sampling in areas where soils average greater than 50 pci/gm of Ra-226 and in poorly ventilated areas.
Section 7.1 and 7.2 describes the environmental (uncontrolled areas) air ncnitoring program.
Identified Shortcomings:
The environmental air monitoring prcgram is adequate; the werker protection air rchitoring program is not.
The Plan should contain some specifications for the air monitoring prcgram.
Type and frequencies of r:nitoring, special conditions, expcsure detereirations, vicinity prcperty applicaticas, action levels, ar.d corrective responses should be specified.
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WM S/ f' DEC 201984 WMLU NM5S r/f JO Bunting WM39/WM41/WM58/GG/84/12/13 MJ Bell f.-
1 RE Browning O
GN Gnugnoli DE Martin CA Flory MEMORANDUM FOR Leo 8. Higginbotham, Chief RA Pennifill 9j Low-Level Waste ana Uranium ME Knapp Recovery Projects Branch
'i A 1**
j D Divistor et Waste Management
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FROM:
Giorgio N. Gnugnolt, Project Manager Low-Levei Waste and Uranium n
Recovery Projects Brancn Duison at Waste Management
SUBJECT:
MEETING ',JITH DCE/AL AND 00E/HQ'REGARDING UMTRAP i5 PLACE:
Si ner Spring, MD offices ct NRC DATE.
Cecareer 12, 1984 ATTET.C EES:
NRC COE C7Flory Artnur ( AL) v.
M. haisfield*
D. Groelsema (HO)*
G. Gnugr.oli M. Knapp*
R. Pennif111
- Partial attendance Summa ry: Arthur provided a revised schedule for delivery of 00E products for NRC reviews. He pointed out that the forecast completion dates should be modified by adding 2 weeks to account for DOE /AL turn around. NRC staff underscored the importance of adhering to a dependable schedule; becausc failure to do so wculd significantly affect the NRC's ability to provide the reviews to 00E in a t1mely fashion.
Groelsema and Arthur incicated that the Canonsburg Remedial Action had reached a point where guidance regarding certification and licensing was necessary.
NRC Input on tne DOE UMTRA Licensing Plan had oeen delayed pending receipt of the DOE Maintenance & Surveillance (M&S) Supplement, whicn was the major part of the Licensing Plan. Groelsema stated that DOE will publish the M&S Supplement as a separate plan which will be referenced by the Licensing Plan.
Since NRC will be concurring on the completion report and licensing the sites.
Arthur and Groelsema indicated that NRC should provide to DOE a list of the necessary documentation and other information, which NRC would require for certification and licensing decisions.
I recuested tnat John Arthur provide to me a cescription of tne information that tne DOE and its subcontractors had for ib 0FC :WMLU
- WMLU
- WMLU
- WMLU
- WMLU NAME :G Gnugnoli:ro DE Martin :CA Flory
- RA Pennifill MR Knapp DATE :84/12/
- 84/12/
- 84/12/
- 84/12/
- 84/12/
Ag NY NP
e DE.C 2 0 W WM39/WM41/WM58/GG/84/12/13 2-Canonsburg, as an example of the information being gencirated.
Inis descriptico will be useful to the NRC in cetermining whether the available information for certification anc for licensing is adequate.
I also indicated that I would provice the mill package, whicn is sent out to applicants in tne ccmercial uranium recovery incustry to guice tnem in cbtaining an NRC license.
I incicated to Groelsema ar.c Artnur tnat I would contact them during the week of Decen cer 17, 1984 on wnetner we would develop guidance specific to UMTRAP licensing or wnetner we tnougnt it woule first ce cetter to arrange a meeting with DOE to cactue what woule ce appropriate to support a licensing decision.
Prior to Groelsema's departure, we oriefly discussed the Central Valley Water Reclucation Facilit/ anc tnt. relationsnip of 00E, NRC and the State or utan.
Artnur and I met witn M. Knapp (hPGT) to discuss tne NRC geotechnical reviews of UMTRAF documents.
C. Flory, R. Pernit ti i, s. Artnur and I then discussed Health anc Safety (H&S).
Artnur proviced a revisec craf t H&S Plan for tne Sniprock site. Generic questions were ciscussea ragarding tna concentration limit criteria (200 pCi/g) for controlled areas, levels of allowable surface ccntamination, and protective clotning. Artnur incicated tnat DGE will oct revise ene Generic H&S Plan until tne spring of 1985.
Giorgio N. Gnugnoli, Project Manager Low-Level Waste and Uranium Recovery Projects Branch Division of Waste Management OFC :W
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NAME :G g$li:roO r tin :CA Flory
- RA Pennifill MR Knapp DATE:84/12/[{
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