ML20199C685
| ML20199C685 | |
| Person / Time | |
|---|---|
| Issue date: | 11/10/1997 |
| From: | Joseph Holonich NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rael G ENERGY, DEPT. OF |
| References | |
| REF-WM-62 NUDOCS 9711200095 | |
| Download: ML20199C685 (2) | |
Text
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UNITED STATES y*
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NUCLEAR REGULATORY CDMMISSION WASHINGTON, D C, toMHoot November 10, 1997 of
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Mr. George Rael. Director U.S. Department of Energy Albutuerque Operations Qffice ERD /LMTRA P.O. Box 5400 Albuquerque, hM 87185 5400
SUBJECT:
ADDITIONAL COMMENT ON THE RIFLE DRAFT COMPLETION REPORT
Dear Mr. Rael:
By letter dated August 29. 1997. The U.S Nuclear Regulatory Commission staff submitted its draft Com)letion Review Report for the Department of Energy's remedial action at the 11fle. Colorado uranium mill tailings site.
In October 1997. NRC staff identified an additional issue concerning the remediation at Rifle, associated with the cleanup of Thorium 230. This issue has been discussed with Sharon Arp. Site Manager for the Rifle remediaton 3roject, and will be addressed in the response to the draft Completion Review Report that she is currently preparing for transmittal to NRC.
The comment describing the adhtional issue, however, was not formally transmitted to 00E.
NRC is doing so I.t this time to complete the record on the remediation of Rifle.
ADDITIONAL ISSUE FOR RIFLE CR REVIEW Lack of Site Specific Dose Analysis for Th 230 Supplemental Standards I
Application in its approval of the generic Th-230 protocol the NRC imposed additional conditions, one of which is applicable to the Rifle sites.
The NRC's approval letter (Holonich 1994) indicated that Cecause the generic thorium protocol does not consider the volume of Th-230 contamination, or the additional health risk from any residual uranium, implementation of the protocol for each site should include a site-specific analysis of the health risk and should emahasize reducing the Th-230 to ALARA levelt." The NRC also noted that the.
r DOE's dose assessment (to support the generic protocol) included some assumptions that the NRC staff thought may not be conservative for all sites.
oneofwhichwastheassumptionthatthecontaminatedareainvolvedonlyone 100 m grid, g,y The Rifle CR does not contain a site specific dose analysis for the residual levels of Th-230 or a discussion of how the Th-230 contamination has been 4d b jq '0 reduced to levels that are ALARA.
The CR does not contain information about i
-the areas to which the generic Th-230 protocol has been applied.
The NRC staff bri j reviewed the Th-230 verification results in Tables J.4 and J.6 of Appendb. J to the CR (MK-F 1997). and from this review it is clear that s,a
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T makgroundforbackridshadTh230concentrationshC1/gabovebackgroundforreater than 15 p verification ba filled soils or greater than 5 surface soils.
(At Th-230 concentrations lower than these values, comparison to a supplemental standard-for Th-230 from the generic Th-230 protocol would
'not be needed because such concentration levels would be reasonably expected to occur in association with Ra-226 concentrations at the EPA cleanup standards, with the assumption that Th 230 is roughly in equilibrium with Ra 226 in tailings materials.) These were not just isolated verification grids: there are large :. lusters of similarly affected grids in at least two locations at the New Rifle site.
Because of the large clusters of affected grids, the analyses performed by the DOE to support the generic Th 230 3rotocol-(which assumed one contaminated grid) are not applicable to the New lifle site, and a site specific dose enalysis is necessary in order to document that the Th-230 contamination at the site has been reduced ALARA.
To correct this situation, the DOE should provide additional information in the CR. including an indication that Th 230 contamination was.a concern at the Rifle sites and that a supplemental standard (that the 1000 year Ra 226 concentration should be no greater than the EPA Ra 226 standards, from the
. generic Th 230 protocol) was used during the remedial action to determine the adequacy of Th 230 cleanup, a description of the site specific dose analysis-and results, and a brief discussion of how residual Th-230 has been reduced ALARA.
Ho1onich 3.J.
1994. Review of it!TRA Project Thorium-230 Generic Protocol.
Letter to A.R. Cherr.aff, Uranium Mill Taiiings Remedial Action Project Office. U.S. Department of Energy, dated July 5,1994.
U.S. Nuclear Regulatory Commission. Office of Nuclear Material Safety and Safeguards. Division of Waste Management. High level Waste and Uranium Recovery Projects Branch. Washington, D.C.
s Project Manager questions concerning this letter, please contact the NRC If you have any Janet Lambert at (301) 415 6710.
g Sincerely.
(Original signed by Daniel M. Gillen for)
Joseph J. Holonich. Chief
__ Uranium Recovery Branch Division of Waste Management Office of Nuclear Material-Safety and Safeguards cc:
S. Arp. DOE Alb F. Bosiljevac. DOE Alb E. Artiglia. TAC Alb.
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