ML20199B660
| ML20199B660 | |
| Person / Time | |
|---|---|
| Site: | 05000054 |
| Issue date: | 10/02/1997 |
| From: | Mcgovern J CINTICHEM, INC. |
| To: | Youngberg B NEW YORK, STATE OF |
| References | |
| NUDOCS 9711190052 | |
| Download: ML20199B660 (2) | |
Text
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CINTICHEM, INC.
P.O Boxeis.
.. TUXhDO. NEW YOAK 10907 -
l914)351 2131 t
October 2, 1997 Hs. Barbara Youngberg New York State Dept. of Environmental Conservation Division of Solid & Hazardous-Materials Bureau of Pesticides and Radiation i
50 Wolf Road.
Albany, New York "12233-7255 RE:
Order on Consent-#D200059005
Dear Ms. Youngberg:
t All on-site remediation work has been comrleted per the
_Cintichem decommissioning project plan, final surveys have been completed and a
satisfactory Final Survey Report has been submitted.
We would like to reduce staffing in the low-level gamma spectroscopy laboratory and, in order to do so, relief from some monitoring requirements that are specified in the subject order would help us to accomplish this.
Paragraph V.A.(1) requires that the retention pond (S-12 )
be monitored for gamma-emitting radionuclides prior to release of pond-water off site.
Paragraph V.A.(2) requires that, during periods of continuous pumping, the pond water must be sampled and analyzed for gamma-emitting radionuclides at 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> intervals.
Under each of these circumstances each sample must be analyzed for Sr-90 within 15 working days from the day the water was discharged.
These provisions require a staff member either to be present on-site or to be.on-call to-perform these analyses for the gamma-emitting. radionuclides.-
In-view of the low probability of having gamma-emitting radionuclides present in the retention pond at-this stage of the decommissioning project and the recent history of the quality of e the effluent at the retention pond (S-12), we request that the order be amended to_ allow for a--delay in the analysis of water samples g
from S-12 for gamma emitting radionuclides as is currently done with the analyses for' Sr-90. Specifically, we request that the current ; pre-discharge sampling requirements for S-12 water be continued,
-but-the analysis of S-12 Water samples shall be
{' O completed within 7 working days after the date of discharge.
Whenever:more than one sample is taken per day a single composite 1
daily sample shall' be analyzed within the above-stated t'ine period.
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97111900S2 971002 k
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We believe that this requested change to the Order is reasonable and it will-not compromise the effectiveness-of our radiological control program by reason of the fact that gamma-emitting radionuclides have not been detected in retentior.-pond water for nore than three years.
4 1
Very truly yours PhY James /J. McGovern President / Plant Mgr.
JJM128
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