ML20196F329
| ML20196F329 | |
| Person / Time | |
|---|---|
| Issue date: | 11/27/1998 |
| From: | Joseph Holonich NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rael G ENERGY, DEPT. OF |
| References | |
| REF-WM-66 NUDOCS 9812070011 | |
| Download: ML20196F329 (6) | |
Text
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11ovember 27, 1998 Mr. G orge Rael, Dircctor U.S. Dep rtm:nt of En:rgy Albuquerque Operations Office ERD /UMTRA P.O. Box 5400 Albuquerque, NM 87185-5400
SUBJECT:
COMMENTS ON NATURITA, COLORADO, VICINITY PROPERTIES NT-058S AND NT-065S The U.S. Nuclear Regulatory Commission (NRC) received the U.S. Department of Energy's (DOE's)
Vicinity Property Completion Reports (CRs) for NT-058S (State Highway 141 Right-of-Way) and NT-065S (Maupin Property) of the Naturita, Colorado, Uranium Mill Tailings Remedial Action Project site by letter dated July 15,1998. In this transmittal DOE stated only Appendix B, "Recommandation for Application of Supplemental Standards" was provided, but that the complete versions of the Vicinity Property CRs could be provided at a later date if required by the NRC staff. Consistent with current NRC review guidance, only the information pertinent to supplemental standards areas will be reviewed for Vicinity Properties.
DOE provided adequate information in the Vicinity Property CRs supporting its application of supplemental standards to leave tailings contamination on the steep slopes along much of the highway right-of-way (NT-058S) and in areas of wetlands (NT-065S). Specifically, DOE determined that remedial action for these areas would pose a risk of injury to workers, cause excessive harm to the environment, and result in unreasonably high costs relative to the long-term health and safety benefits.
Accordingly, the NRC staff determined DOE's application of supplemental standards meets Criteria a, b, and c of 40 CFR 192.21, and that health and safety and the environment are adequately protected.
Enclosed are signed copies of the "NRC Review Form for Supplemental Certification of Vicinity Properties" for both sites. Additionally, the NRC staff is providing the enclosed editorial comments based on its review of both Vicinity Property CRs. These comments are provided to DOE for inclusion in revisions to the CRs. If you have any questions regarding this subject, please contact Mr. Robert Carlson of my staff at (301) 415-8165.
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Sincerely,
/
oseph J kolo i, Chief
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9812070011 981127 1 Division of Waste Management 66 PDR Office of Nuclear Material Safety and Safeguards
Enclosures:
As stated cc:
R. Cornish, DOE Alb g.431 R. Edge, DOE GRJ a
F. Bosiljevac, DOE ERD E. Artiglia, DOE TAC Alb i
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- ,o November 27, 1998 Mr. George Rael, Director
. U.S. Department of Energy Albuquerque Operations Office ERD /UMTRA P.O. Box 5400 Albuquerque, NM 87185-5400 l
SUBJECT:
COMMENTS ON NATURITA, COLORADO, VICINITY PROPERTIES NT-058 AND 065S The U.S. Nuclear Regulatory Commission (NRC) received the U.S. Department of Energy's (DOE's)
Vicinity Property Completion Reports (CRs) for NT-058S (State Highway 141 Right-of-Way) and NT--
065S (Maupin Property) of the Naturita, Colorado, Uranium Mill Tailings Remedial Action Project site by letter dated July 15,1998. In this transmittal DOE stated only Appendix B,
- Recommendation for Application of Supplemental Standards" was provided, but that the complete versions of the Vicinity Property CRs could be provided at a later date if required by the NRC staff. Consistent with current NRC review guidance, only the information pertinent to supplemental standards areas will be reviewed for Vicinity Properties.
DOE provided adequate information in the Vicinity Property CRs supporting its application of supplemental standards to leave tailings contamination on the steep slope 7 along much of the highway right-of-way (NT-058S) and in areas of wetlands (NT-065S). Specifically, DOE determined that remedial action for these areas would pose a risk of injury to workers, cause excessive harm to the environment, and result in unreasonably high costs relative to the long-term health and safety benefits.
j Accordingly, the NRC staff determined DOE's application of supplemental standards meets Criteria a, b, and c of 40 CFR 192.21, and that health and safety and the environment are adequately protected.
l Enclosed are signed copies of the "NRC Review Form for Supplemental Certification of Vicinity l
Properties" for both sites. Additionally, the NRC staff is providing the enclosed editorial comments based on its review of both Vicinity Property CRs. These comments are provided to DOE for inclusion in revisions to the CRs. If you have any questions regarding this subject, please contact Mr. Robert l
Carlson of my staff at (301) 415-8165.
Sincerely, i-Joseph J. Holonich, Chief Uranium Recovery Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards
Enclosures:
As stated cc:
R. Cornish, DOE Alb R. Edge, DOE GRJ F. Bosiljevac, DOE ERD E. Artiglia, DOE TAC Alb
U.S. NUCLEAR REGULATORY COMMISSION STAFF COMMENTS ON THE U.S. DEPARTMENT OF ENERGY'S VICINITY PROPERTY COMPLETION REPORTS FOR NT-
- 058S AND NT-065S OF THE NATURITA, COLORADO SITE The following U.S. Nuclear Regulatory Commission (NRC) staff comments are in reference to its review of the U.S. Department of Energy's (DOE's) Vicinity Property Completion Reports (CRs) for NT-058S (State Highway 141 Right-of-Way) and NT-065S (Maupin Property) of the Naturita, Colorado, Uranium Mill Tailings Remedial Action Project site, transmitted by cover letter dated July 15,1998. These comments are editorial and are provided to DOE for inclusion in any future revisions of the subject CRs. Comments do not involve health and safety or environmentalissues, nor do they affect compliance determination.
The first comment pertains to both Vicinity Properties NT-058S and NT-065S, and the second two comments apply to only Vicinity Property NT-058S.
VICINITY PROPERTIES NT-058S and NT-065S 1.
COMMENT: Correction for Internal Dose Measurements and Missing Information Concerning Potential for Future intake of Residual Radioactivity l
DISCUSSION:
l Section B.3.1, " Health Risk Analysis," second paragraph, states that the " maximum gamma dose at waist level recommended by the International Commission on Radiological Protection (ICRP)(1977,1978) and DOE order 5400.5 (1990) is 100 mrem /[yr] dose." The NRC staff notes that the ICRP in 1977 recommended the summation of the external and internal exposures for the general public be 100 mrem /yr, and that in 1990 recommended this l
exposure limit be reduced to "as low as reasonably achievable" (ALARA). The current version l
of DOE order 5400.5 (1993) also uses the effective dose equivalent (sum of external and l
internal dose), not just the external (gamma) dose to meet the 100 mrem limit. Additionally, DOE Orr.f 5400.5 indicates that realistic dose modeling should be performed.
Section B.3.1 further indicates that the health risk scenarios presented therein are unlikely, but possible. This section then says that the worst case scenario is based on zero background radiation and maximum surface gamma rates. The NRC staff considers this scenario unrealistic (hours of exposure to reach 100 mrem /yr). Conventional practice is to provide the j
estimated dose for likely future exposures so that it can be compared to the fraction of 100 mrem /yr standard commonly used in radiological reclamation projects (e.g., DOE 30 mrem, NRC 25 mrem, and the Environmental Protection Agency 15 mrem). Because the NRC staff has determined that exposure rates would most likely be low given the location and volume of residual material, doses in excess of 25 mrem /yr are unlikely.
RECOMMENDATION:
in any revisions to the CRs, DOE should indicate that the 100 mrem /yr limit includes any internal dose from the contamination as well as the external (gamma) dose, and address the i
i Enclosure i
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potential for future intake of residual radioactivity on contaminated properties. DOE should also conduct realistic risk assessments to compare with the acceptable fraction of 100 mrem /yr limit.
VICINITY PROPERTY NT-058S l
2.
COMMENT: Discrepancy in Data Concerning Ra-226 Values DISCUSSION:
Section B.3, " Radiological Data," paragraph e indicates that within the Supplemental Standards Recommendation areas the Ra-226 levels range from 7.1 to 912 pCi/g; however, the highest Ra-226 value in the data table attached to the CR (i.e., see page 1 of data table labeled " Radiological Data for Highway 141 Right-of-Way (NT-058) From Calamity Bridge to Intersection of Highway 90") is 117 pCilg.
RECOMMENDATION:
DOE should correct this discrepancy in data concerning the highest Ra-226 value in the supplemental standard area.
3.
COMMENT: Missing Information Conceming Width of Highway Right-of-Way and Extent of f
Contamination i
DISCUSSION:
1 J
Vicinity Property NT-058 consists of a portion of the Highway 141 right-of-way which has steep i
slopes and a " clear zone" (i.e., the area within 20 feet of the outside white stripe on the road).
However, Appendix B does not mention the width of the right-of-way.
RECOMMENDATION:
In revisions of the CRs, DOE should indicate the width of the highway right-of-way and indicate if contamination extends beyond this property to other vicinity properties.
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VP No: NT-058S l
NRC Review Form l
for Supplemental Certification l
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.
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NRC concurrence for the Radiological Engineering Assessment (REA) was requested on:
[X]
Supplemental standards were not in the REA, special circumstances required that su piemental standards. invoked during remedial action.
$ /d/ f i
Frank D. Bosiljevac, DOE Cert ation Officer Dat6
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Based on the information and certification provided by the DOE, the NRC:
I]
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.
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Concurs, as above, except for the following conditions:
1.
2.
3.
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See attached sheets for any additional provisions.
[]
Needs additionalinformation tn make a concurrence decision. This information consists of:
[]
See attached sheets for any additional informational needs.
Yua$b
- M / FIT f
NRC Concurring O'fficialgnd'TitM
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Date
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VP No: NT-065S l
NRC Review Form l
for Supplemental Certification i
of Vicinity Properties The Department of Energy (DOE) has determined that remedial action at the above l
vicinity property (VP) has been completed and thereby complies with supplemental l
standards invoked by DOE under 40 CFR, Subpart C, specifically Subsections 192.21 and 192.22.
[]
NRC concurrence for the Radiological Engineering Assessment (REA) was requested on:
[X1 Supplemental standards were not in the REA, special circumstances required that pplemental standards be invoked during remedial action.
4/AAG
// //
Frank D. Bosiljevac, DOE Certif Ation Officer Daty
/
===========================
l Based on the information and certification provided by the DOE, the NRC:
11 Concurs that the remedial action at the subject VP has been competed under its authority provided by the Uranium Mill Tailings Radiation Control Act (UMTRCA),
Section 104 (f)(1) and as described in the Memorandum of Understanding (MOU),
Appendix A, Section 3.4.
!1 Concurs, as above, except for the following conditions:
l 1.
2.
3.
[]
See attached sheets for any additional provisions.
[]
Needs additionalinformation to make a concurrence decision. This information consists of:
l i
il See attached sheets for any additional informational needs.
i I
hdi!tbw$U)d(Ill b/V-2'l /FSS
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NRC Concurring 6fficiaflan(Tim
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