ML20198E254
| ML20198E254 | |
| Person / Time | |
|---|---|
| Site: | 07100527 |
| Issue date: | 07/24/1985 |
| From: | Bernard Thomas INTERNATIONAL NUTRONICS, INC. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20198E259 | List: |
| References | |
| NUDOCS 8605270322 | |
| Download: ML20198E254 (2) | |
Text
I INTERNATIONAL NUTRONICS, INCL O
u m77 July 24, 1985
. -D Dr. Thomas Murley Regional Administrator NRC Region I 631 Park Ave.
King of Prussia, Pa.
19406 RE: Plan of action with regard to proceeding with facility building remediation at INI's Dover site.
l Dr. Murley,
)
In keeping with our best efforts to complete the decommissioning of INI's Dover Facility in a technically ethical manner and as timely as possible, we wish to inform you of our approach to continuing operations regarding remediation of building components. Possible delays attributable to obtaining approval of a soil release concentration value may have serious impact upon the overall schedule to complete the facility decommissioning.
In light of many considerations and discussions held at a meeting regarding the project status on July 17, 1985, a decision to proceed with building remediation was generally agreed upon by those attending.
(Clark Burnham/Lexington Insurance Co., Greg Parker /INI, Bruce Thomas /INI, Ted Weeks / Chem-Nuclear Systems, Gary Benda/ Chem-Nuclear Systems, Norm Hilbert/Hilbert Associates) Additional input from Chem-Nuclear staff members Mark Whittaker, corporate RSO, and John Till, CHP, supports the approach to proceed prior to having an NRC approved soil release concentration value.
Chem-Nuclear staff members are currently developing an environmental site specific evaluation for proposed maximum concentration values for soil in pico curies / gram. This evaluation will be finalized and submitted to NRC Region I by August 9, 1985.
It will encompass all necessary assessments and evaluations to generate an acceptable value. Prior even to this submission, decontamination programs will proceed using a value of 10 pico curies / gram as a working guideline.
In areas where replacement of building structural components are necessary, the above value will be the restricting criteria prior to restructuring.
g 2 g g gj h 27 RETURN ORIGINAL M PDR REGION I C
ll"d. h V
U.S. HIGHWAY 46 AND SCHLEY STREET, DOVER, NEW JERSEY 07801 (201) 361-0583
INTERNATION AL NUTRONICS, INC.
The above course of action is necessitated by the following:
- There is no published regulatory guide or precedent for a similar situation for NRC Licensees.
- Delays related to a slow down of operations in waiting for final approval would have serious impacts on: retention of trained, qualified contractor personnel / safety considerations related to any postponement of tasks /and cost escalation of the entire project.
- Many of the related tasks are connected either in parallel or series functioning. Replacement of the building foundation af ter removal is an example of the interelation of tasks.
Proceeding by the above approach will not compromise the integrity of the final soil concentration value nor the ability to perform final close-out surveys for release of the entire facility.
Excavations will remain open to permit MRC corroborating surveys and sampling analysis will be compleLcd cad demonstrated as below the value of 10 pico curies /
gram average concentration prior to restructuring of building components such as the foundation. This course of action will have no detrimental impacts on the overall decommissioning of the facility.
Should you have any comments or questions related to the above, please do not hesitate to contact us.
Sinc rely, h
//Wh Bruce' thomas cc. Greg Parker, INI Ted Weeks, CNSI Dr. John Glenn, NRC Norman Hilbert,Ililber*. Associates Clark Burnham, Lexington Insurance