ML20195E380
| ML20195E380 | |
| Person / Time | |
|---|---|
| Issue date: | 11/13/1998 |
| From: | Joseph Holonich NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rael G ENERGY, DEPT. OF |
| References | |
| REF-WM-62 NUDOCS 9811180323 | |
| Download: ML20195E380 (7) | |
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Mr. G:orgs Ratl, Dir:ctor U.S. D:partm:nt of Ennrgy Albuquerque Operations Office ERD /UMTRA
- P.O: Box 5400 Albuquerque, NM 87185-5400
SUBJECT:
ACCEPTANCE OF COMPLETION REPORT FOR RIFLE, COLORADO, VICINITY PROPERTY RF-477S 1
Dear Mr. Rael:
By letter dated October 15,1998, the U.S. Department of Energy (DOE) provided the Rifle, Colorado, Vicinity Property RF-477S Completion Report (VP CR) to the U.S. Nuclear Regulatory Commission (NRC) for review. The NRC staff's review of the VP CR is enclosed.
Concurrence by the NRC on this VP CR is required because special circumstances resulted in Supplemental Standards being invoked during remedial action. The NRC staff concludes that the information provided by DOE in the RF-477 CR provides reasonable assurance that supplemental standards for soil cleanup have been properly applied. Therefore, the NRC staff concurs that the use of Supplemental Standards and the remediation of the vicinity property iNere completed in accordance with the Environmental Protection Agency standards. The signed NRC Review Form for Supplemental Certification of Vicinity Properties, showing NRC concurrence, is also enclosed.
I If you have any questions concerning this letter or the enclosures, please contact the NRC Project Manager, Janet Lambert, at (301) 415-6710.
Sincerely,
[originalsignedby:]
Joseph J. Holonich, Chief I
Uranium Recovery Branch Division of Waste Management l
Office of Nuclear Material Safety and Safeguards
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Enclosures:
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'+9 * * * * *,o November 13, 1998 Mr. George Rael, Director U.S. Department of Energy l
Albuquerque Operations Office i
ERD /UMTRA l:
P.O. Box 5400 l ~
Albuquerque, NM 87185-5400 l
SUBJECT:
ACCEPTANCE OF COMPLETION REPORT FOR RIFLE, COLORADO, VICINITY PROPERTY RF-477S l
Dear Mr. Rael:
By letter dated October 15,1998, the U.S. Department of Energy (DOE) provided the Rifle, Colorado, Vicinity Property RF-477S Completion Report (VP CR) to the U.S. Nuclear Regulatory Commission (NRC) for review. The NRC staff's review of the VP CR is enclosed.
Concurrence by the NRC on this VP CR is required because special circumstances resulted in Supplemental Standards being invoked during rernedial action. The NRC staff concludes that the information provided by DOE in the RF-477 CR provides reasonable assurance that supplemental standards for soil cleanup have been properly applied. Therefore, the NRC staff concurs that the use of Supplemental Standards and the remediation of the vicinity property were completed in accordance with the Environmental Protection Agency standards. The signed NRC Review Form for Supplemental Certification of Vicinity Properties, showing NRC concurrence, is also enclosed.
If you have any questions concerning this letter or the enclosures, please contact the NRC Project Manager, Janet Lambert, at (301) 415-6710.
Sincerely, Joseph J. Holonich, C ief i
Uranium Recovery Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards l-
Enclosures:
As stated cc: F. Bosiljevac, DOE Alb E. Artiglia, TAC Alb i
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U. S. NUCLEAR REGULATORY COMMISSION STAFF REVIEW OF REVISED l
COMPLETION REPORT FOR RIFLE VICINITY PROPERTY RF-477S l
The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the 1998 version of the Vicinity Property Completion Report (VP CR) for the Rifle, Colorado, Vicinity Property (VP) RF-477S, MK-Ferguson Company, dated March 23,1998.
The VP CR describes the remedial actions (radiological cleanup) and verification activities performed at the VP RF-477S. This site is the Railroad right-of-way, north of the New Rifle site and west of the City of Rifle, CO. It contains a section of the Denver and Rio Grande Western Railroad mainline track.
Per agreement, Supplemental Standards have been applied to residual radioactive material left in place along the railroad tracks. As part of that agreement, no remediation was performed within 15 feet of the centerline of the main tracks and the railroad track and ties were not replaced. These conditions, including the application of Supplemental Standards, were pre-approved by the owners of the Denver and Rio Grand Western Railroad Company, the State of Coloredo, the Department of Energy (DOE), and the NRC via their concurrence with the remedial action plan (RAP) for the Rifle Site. After completion of the RAP, other areas on the site were identified that also required the application of Supplemental Standards.
It was necessary for DOE to apply Supplemental Standards to several entical areas around an MCI fiber optics telecommunication line that was buried within the railroad right of way north of the main track after the RAP was approved. Appendix A, Radiological Survey Data for the Supplemental Standard, and Appendix B, Supplemental Standards Recommendation of the VP CR, provide documentation of the application of Supplemental Standards to the remaining areas of contamination and their current radiological conditions.
Because the reason for the NRC's review of this VP CR is that the Supplemental Standards were used at the VP, the NRC staff review has been limited to areas related to the use of the Supplemental Standards for the VP.
The radiological conditions within the Supplemental Standards areas are summarized as follows:
a.
Exposure rate range at a level of one foot over contaminated areas - 12 to 45 gR/hr Exposure rate range at ground level over contaminated areas - 16 to 72 R/hr b.
Average exposure rate at a level of one foot over contaminated areas - 19 R/hr Average exposure rate at ground level over contaminated areas - 27 R/hr c.
Range of Ra 226 concentrations in Supplemental Standards areas - 0.85 to 434.4 pCi/g. Average recorded Ra-226 concentration - 15.7 pCi/g Background for the Rifle locale is an exposure rate of 13 uR/hr and 1.6 pCi/g of Ra-226. The data presented include background.
In conducting the health risk analysis of the long term exposure of 100 mrem per year, and i
l ENCLOSURE 1
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j short term unusual exposure of 500 mrem per year for the application of Supplemental Standards, the VP CR considered three exposure scenarios each for the 100 mrem and 500 mrem doses. The risk analysis concluded that for the worse case scenario, an individual would have to lay down on the point of highest gamma on the site for 3.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> every day for an entire year, for a total of 1,389 hours0.0045 days <br />0.108 hours <br />6.431878e-4 weeks <br />1.480145e-4 months <br />, in order to receive the 100 mrem dose. For the short i
term unusual 500 mrem dose, the worse case analysis assumed an occupational scenaiio l
where a worker would be exposed to elevated levels during future maintenance and repairs on l
the railroad tracks and utilities. The VP CR analysis determined that workers would have to be I
in proximity to contaminated material at the site for approximately 6,944 hours0.0109 days <br />0.262 hours <br />0.00156 weeks <br />3.59192e-4 months <br /> or 289 working days, to receive the 500 mrem dose. Thus, the VP CR health risk analysis determined that a person would have to be in direct contact with the surface of the site or working on the site for very lengthy periods of time to receive those levels of exposures. The analysis concluded that i
given the location of the site and these areas on the site, such exposures would be highly unlikely.
The VP-CR provides a cost benefit analysis which indicates that cost of full removal of the low level contaminated material at the site is unreasonably high relative to the long term benefits.
NRC STAFF CONCLUSIONS NRC staff considers the health risk analysis for the Pifle VP 477 CR to be conservative in that it compared the dose rates measured at ground level at the site with the recommendations from the Intemational Commission on Radiological Protection (ICRP) and DOE for waist high exposures. Thus, the NRC staff agrees that based on the information and data provided in the VP CR, the doses and exposures resulting from the application of Supplemental Standards at the site should be quite low. The NRC staff has concluded that there is reasonable assurance that the remediation of Rifle VP 477 and the use of Supplemental Standards were completed in accordance with EPA standards.
NRC staff also notes that the area around the location of the 434.4 pCi/g Ra-226 sample has an average sample concentration of 4.95 pCi/g, with a dose rate reading of 20 R/hr. With an average area reading of 18 gR/hr for the site, this may indicate that there was a minor area of l
higher activity which could have been removed during the sampling procedure.
l REFERENCES f
DOE (U.S. Department of Energy) Letter to J. J. Holonich, Chief, Uranium Recovery Branch, Division of Waste Management, Nuclear Materials Safety and Safeguards, U.S.
Nuclear Regulatory Commission, dated October 15,1998, with enclosed copies of the Rifle, Colorado, UMTRA project site VP RF-477S completion report. U.S. Department of Energy, Albuquerque Operations Office, Environmental Restoration Division, Uranium Mill Tailings Remedial Action Team, Albuquerque, New Mexico.
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VP No: RF-477S i
NRC Review Form for Supplemental Certification of Vicinity Properties l
The Department of Energy (DOE) has determined that remedial action at the above vicinity property (VP) has been completed and thereby complies with supplemental e
standards invoked by DOE under 40 CFR, Subpart C, specifically Subsections 192.21 and 192.22.
[]
NRC concurrence for the Radiological Engineering Assessment (REA) was l
requested on:
[X]
Supplemental standards were not in the REA, special circumstances required that supplemental stanpards be invoked during remedial action.
/$
' ' Frank D. Bosiljevac, D ertification Officer Dafte l
===========================
l Based on the information and certification provided by the DOE, the NRC:
Concurs that the remedial action at the subject VP has been competed under l
Its authority provided by the Uranium Mill Tailings Radiation Control Act (UMTRCA),
Section 104 (f)(1) and as described in the Memorandum of Understanding (MOU),
Appendix A, Section 3.4.
[]
Concurs, as above, except for the following conditions:
1.
2.
3.
I1 See attached sheets for any additional provisions.
[]
Needs additionalinformation to make a concurrence decision. This information consists of:
I1 See attached sheets for any additional informational needs.
l
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/
/4 $f ARC Concurring / Official and Title Date l
l l
EHCLOSURE 2 l
L
P O*
VP No: RF-477S s
NRC Review Form for Supplemental Certification of Vicinity Properties The Department of Energy (DOE) has determined that remedial action at the above vicinity property (VP) has been completed and thereby complies with supplemental standards invoked by DOE under 40 CFR, Subpart C, specifically Subsections 192.21 and 192.22.
[]
NRC concurrence for the Radiological Engineering Assessment (REA) was requested on:
l
[X]
Supplemental standards were not in the REA, special circumstances required that supplemental standards be invoked during remedial action.
- b l& l h
Frank D. Bosiljevac, D Certification Officer Dyfe
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l Based on the information and certification provided by the DOE, the NRC:
1
]
Concurs that the remedial action at the subject VP has been competed under l
its authority provided by the Uranium Mill Tailings Radiation Control Act (UMTRCA),
Section 104 (f)(1) and as described in the Memorandum of Understanding (MOU),
Appendix A, Section 3.4.
[]
Concurs, as abm, except for the following conditions:
1.
2.
3.
[]
See attached sheets for any additional provisions.
[]
Needs additionalinformation to make a concurrence decision. This information consists of:
I)
See attached sheets for any additional informational needs.
$1)AllY l-NhC Concurring Official and Title Date i
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VP No: RF-477S l
I NRC Review Form for Supplemental Certification of Vicinity Properties The Department of Energy (DOE) has determined that remedial action at the above vicinity property (VP) has been completed and thereby complies with supplemental standards invoked by DOE under 40 CFR, Subpart C, specifically Subsections 192.21 and 192.22.
[]
NRC concurrence for the Radiological Engineering Assessment (REA) was requested on:
IX]
Supplemental standards were not in the REA, special circumstances required that supplemental standards be invoked during remedial action.
/m) l0 i
Frank D. Bosiljevac, DOE rtification Officer Dt/e
===========================
Based on the information and certification provided by the DOE, the NRC:
[]
Concurs that the remedial action at the subject VP has been competed under its authority provided by the Uranium Mill Tailings Radiation Control Act (UMTRCA),
Section 104 (f)(1) and as described in the Memorandum of Understanding (MOU),
Appendix A, Section 3.4.
[]
Concurs, as above, except for the following conditions:
1.
2.
3.
[]
See attached sheets for any additional provisions.
I1 Needs additionalinformation to make a concurrence decision. This information consists of:
[]
See attached sheets for any additionalinformational needs.
SVM JVr'V
[1 n
v NKC Co6 curring Officist and Title Date