ML20198B522
| ML20198B522 | |
| Person / Time | |
|---|---|
| Issue date: | 06/22/1989 |
| From: | Grace S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hawkins E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| REF-WM-39, TASK-TF, TASK-URFO NUDOCS 9801060346 | |
| Download: ML20198B522 (5) | |
Text
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N pa esoo UNITED STATES p' i' %, NUCLEAR REGULATORY COMMISSION 5' f REOiON IV
%, / URANIUM RECOVE FIELD OFFICE DENVER, COLORADO 90225 AN 221989
. 0 Gm nep r URFO: SRG
- Title I CFR 1.10.40-192 g MEMORANDuti FOR: Edward F. Hawkins, Branch Chief Uranium Recovery Field Office Region IV FROM: Scott R. Grace, Project Manager h Uranium Recovery Field Office Region IV
SUBJECT:
b COMMENTS ON THE MAY 1989 DOE DRAFT REVISION TO THE TECHNICAL APPROACH DOCUMENT .
I have ieviewed the following sections of the sut' ject document and have developed the comments below. These comments should be forwarded to Headquarters for consideration in their comments +o DOE on the subject document.
Section 5.1 Geology 5.3 Subsurface Investigations 8.0 Water Resources Protection Section 8.0, Water Resources Protection, page 185: The second paragraph specifies that DOE shall provide a demonstration of compliance against the preliminary draft final EPA standards (40 CFR 192) issued March 1989.
NRC notes that these are not the #inal standards and have not been puolished in the Federal Register. The March 1989 version of the standard is before the Office of Management and Budget (OMB) for review. NRC has identified substantive issues with EPA's preliminary draft final standards which are currently under OMB review. Therefore, there may be substantive changes to the March 1989 preliminary draft final EPA regulations. Until the final regulations are issued, NRC considers the Draf t EPA standards (S2 FR 36000) in effect.
OFFICIAL DOCKET COPY 9801060346 890622 PDR WASTE MM-39 PDR
. 9 I
2 J.N 221989 Section 8.2.2, Alternate Concentration Limits, page 204: The second paragraph under this section stater, that the NRC ACL technical position Title II of the UMTRA.has been developed primarily for use at active uranium mills, reg This statement is incorrect.
NRC's June 1988 Draft Technical Position (DTP) on Alternate developed primarily for Concentration Title I, but alsoLimits (ACL) for Title for Uranium Mills was 11 sites.
document is NRC's standard format and content guide, and standard Since this review plan evaluate an ACL for ACL applications, this is the document NRC will use to application. Therefore, the DOE TAD should be clarified to encourage for ACL applications. use of the NRC Draft Technical Position document Section 8.5, Ground-Water Protection Monitoring, page 210: The third O paragraph specifies that the performance monitoring frequency during the remedial action period will be on a semiannual basis. In the event a potential exceedance is detected, quarterly sampling will be done.
NRC considers be conducted, at that during the remedial period, quarterly i a minimum. toring should This provides critical infor period when there is a greater potential of impacts from anstruction.Jion during the The Durango ground water. cell is a good example vi how construction can impact the more often thanWhen seepage is detected, monitoring should be performed quarterly.
Section 8.8.1, Alternate Concentratic, Limits, page 215: This section discusses approaches to ACL applications.
This section should also reference NRC's Draft Technical Position guidanca as well as the following consideration.
p As stated in the DTP, NRC may approve ACLs for contaminants in ground v
water provided these concentration linits are as low as is reasonably achievable (ALARA), considering corrective actions.
In order for NRC to evaluate a proposed the proposed limit is as ALARA. concentration limit, DOE must first demonstrate that The demonstration that a specific concentration is AI. ARA should be determined using data and information derived from the actual implementation of a corrective action program (the Title 11 program, as discussed in 10 CFR 40 Appendix A, Criterion 5B(6) Opecifies that a corrective action program,must address removing the hazardous constituents that have entered the ground water at the point of compliance or treating them in place). Although demonstration of ALARA using predictive calculations or models may be acceptable (3bsent of implementation of corrective actions), this would be a less
3 M 22 I989 defentible method of consideration. This is particularly true consivering the site specific variations and uncertainties in predictive geochemical modeling. Predictive modeling may be useful, however, in evaluating alternative corrective actions, as long as the potentially large margin of error in the predicted concentrations is recognized.
As a reminder to DOE, a brief discussion of NRC's approach to ACLS (along the lines of the ACL Workshop) should be included in the NRC comments on the Draft Revision of the TAD. These comments will be discussed with LLWMD next week (June 26) during my visit to OWFN.
If headquarters agrees with this approach, then a discussion of our ACL approach should be included in the NRC comments on the TAD. A consistent approach for both Title I and II needs to adopted.
O lan? W Scott R. Grace, Project Manager c
Uranium Recovery Field Office Approved by: ((//2Mr 1 u Edwird F. Hawkins7fanchThief Uranium Recovery Field Office Region IV cc: D.Gillen, LLWMD/LLOB g M.Webber, LLWMD/LLTB
.=
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U__ SON f,(/))ffdff- $ff DOCUMENT TRANSMITTAL MK-FERGUSON COMPANY P.O. BOX 9136 ALBUQUEROUE, NEW MEXICO 87119 Trans. No. MKF-MP-0498 ntract No, 20 PROJECT: UMTRA 6/12/89 CLIENT: U.S. DETARTMENT OF ENEA0Y Date To: Distribution APPROVED FOR CONSTRUCTION / FABRICATION A INFORMATION ONLY B APPROVAL ACTION REQUESTED C D:SAPPROVAL. RESUBMIT D ATT:
.. APPROVAL WITH COMMENTS E REMARKS ttached is a controlled copy of the Construction Safety and Fcalth Management Plan. Revisions will be issued as they becomo available.
TRANSMITTED Xi HF.REWITH Q UNDER SEPARATE COVER
^oHEM RER NU ER OF COP ES TITLE OR DESCRIPTION .is MKF-UMTRA-4 1 Construction Safety and Health Management Plan O
B. Stearns copy # J26 C. Carville 127 V. Logan 128 M. Garcia 129 A. Griego 130 e ET:Hawkins- 131 ADDRESSEE: SIGN & RETURN COPY NO. 2 TO ABOVE ADDRESS THE ABOVE LISTED DOCUMENTS HAVE MK FERGUSON COMPANY BEEN RECEIVED BY:
COMPANY NAME BY: _I L 11 I [O -.
N AME & TITLE naScmd MgG AL 36& T COPY fp a COPY #1(ORIG TO ADDRESSEE) COPY #2(RETURN COPY) COPY #3 (FILE COPY)
MK FERGUSON DOCUMENT TRANSMITTAL MK-FERGUSON COMPANY P.O. BOX 9136 ALBUQUEROUE, NEW MEXICO 87119 Trans. No. MKF-MP-0498 PROJECT: UMTRA '
CLIENT: U.S. DEPARTMENT OF ENERGY Date 6/12/89 TO. Distribution APPROVED FOR CONSTRUCTION / FABRICATION A INFORMATION ONLY B APPROVAL ACTION REQUESTED C DISAPPROVAL RESUBMIT D ATT:
APPROVAL WITH COMMENTS E REMARKS Attached is a controlled copy of the Construction Safety and Health '
Management Plan. Revisions will be issued as they become available.
TRANSMITTED 16 HEREWITH O UNDER SEPARATE COVER DRA O TEM BE NU ER OF COP ES TITLE OR DESCRIPTION ACTION MKF-UMTRA-4 1 Construction Safety and Health Management Plan B. Stearns copy # 126 C. Carville 127 V. Logan 128 M. Garcia 129 A. Griego 130
~ELHiwkine 131 ADDRESSEE: SIGN & RETURN COPY NO.2 TO ABOVE ADDRESS THE ABOVE LISTED DOCUMENTS HAVE MK.FERGUSON COMPANY BEEN RECEIVED BY:
COMPANY N AME BY; O 2 11 .
- 4D NAME & TITLE mtE .adwaru ( M/ DA1e eeC.
C0PY #1 (ORIG TO ADDRESSEE) COPY #2 (RETURN COPY) COPY #3 IFILE COPY)