ML20203G822
| ML20203G822 | |
| Person / Time | |
|---|---|
| Issue date: | 07/03/1986 |
| From: | Brich R, Hawkins E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20203G818 | List: |
| References | |
| REF-WM-1 NUDOCS 8608040083 | |
| Download: ML20203G822 (6) | |
Text
'
DISTRIBUTION yt Docket File WM-192
~
PDR/DCS DBangart, RIV WM-192/RFB/86/06/19/0 RBrich EHawkins DMartin, WM LLW Branch, WMLU M 0 31966 URF0 r/f URF0:RFB WM-192 040WM192201E 040WM192301E 040WM192401E MEMORANDUM FOR: Docket File No. 40-WM192 FROM: Randall F. Brich, Project Manager
- Licensing Branch 1 Uranium Recovery Field Office, Region IV
SUBJECT:
MEETING MINUTES ON VICINITY PROPERTY SUPPLEMENTAL STANDARDS AMONG NRC, DOE AND CONTRACTORS At the request of the Department of Energy's Albuquerque Operations Office (DOE) the individuals listed on Attachment No. 2 met on June 18, 1986, at the UMTRA project office to discuss NRC's " Draft O Guidelines for Justifying the Use of Supplemental Standards."
Attachment No. 1 provides the final, revised guidelines agreed to by the meeting participants.
Items discussed during the meeting included the following:
- 1. 40 CFR 192.21 Criteria for Applying Supplemental Standards.
- 2. 40 CFR 192.22 Supplemental Standards.
- 3. NRC Draft Cuidelines.
- 4. Specific examples of application of Supplemental Standards.
- 5. Annotation of land records.
OFC : : : : : : : I
_____:____________:____________:____________: ___________: PDR 8608040083 860703 ----
N . . . MISC E_AME[,________________i____________i___________[___________: 8 6 0 s o 4 0 0 7,9 , , , , , ,p p p , , , ,_ _ _ _ , , , , ,
DATE :86/06/19 : : : : : :
WM-192/RFB/86/06/19/0 JUL 0 3 Iges i
Discussion of the draft guidelines on a criteria-by-criteria basis resulted in the following agreements:
- 1. DOE agreed C at the concentration of radium-226, volume of the deposit, garaa ray exposure rate, and exposure potential would be submitted in the Radiological and Engineering Assc.ssment (REA) specific to the property for which supplemental standards were requested. This information will be used by NRC in its detennination of concurrence for the supplemental standards requests. As a result of this agreement, population dose assessments discussed in the draft guidelines associated with criteria B, C and D were deleted. The general consensus is that it would be extremely difficult to accurately describe i population dose comitments due to many unpredictable factors, such as exposed population, residency times, etc.
- 2. DOE agreed that the general determination for all locations with specified characteristics as required by 40 CFR 192.22(c) would be submitted to NRC for review and approval. Specific locations would be handled on a site-specific basis. The degree of detail that is required should be sufficient to allow NRC to independently arrive at the same conclusion as D0E. As an example, a general determination would be developed for all
? buried street deposits. Following a characterization of the extent of contamination residing under streets, an REA would be submitted whit.h describes the deposit on a site-by-site basis.
The characterization would be based primarily on a gamma scan in. conjunction with monitored, periodic boreholes to estimate b the depth of the deposit.
- 3. In addition, DOE agreed that the supplemental standards i requests for properties RT-034, DU-003, D0-055, and SL-061 l would be resubmitted in a format that follows the specific guideline related to the criterion requested. Also, DOE will supply a telephone log which will be accepted as adequate documentation of the required land owner or occupant notification. Future properties will include an owner / applicant notification letter which will be accepted as adequate documentation.
OFC : : : : : : :
,NAME : : : : : : :
DATE :86/06/19 : : : : : :
l
WM-192/RFB/86/06/19/0 JUL 0 31986
- 4. DOE agreed tnat in those routine cases where material in excess of the standtrds is left behind, DOE will submit, on a timely basis, a letter and rough sketch which describes and delineates the nature and amount of material left behind. Following this submittal DOE will prepare and submit a supplemental standards request which satisfies the guidelines associated with the criteria selected.
Discussion of the procedure for annotation of the land records as proposed in Revision C to the Vicinity Property Management Implementation Manual indicated that a discrepancy existed in the procedure whereby
- properties contaminated but not cleaned up would not be noted in the land records. Resolution of this inconsistency should be addressed in DOE's response to NRC's specific comments on Revision C.
hl4!?&
Randall F. Brich, Project Manager Licensing Branch 1 Uranium Recovery Field Office Region IV Approved by: isl
- Edward F. Hawkins, Cilief a Licensing Branch 2 Uranium Recovery Field Office, Region IV
__f____0 h , ,URF0
,,,,,,,,,,,,,l,,,,,,,,,,,,,,,,,,,,,,,,j,,,,,,,,,,,,],,,,,,,,,,,
> MAME : RBrich/lv : EHawkins DATE :86/06/19 : g /3M : : : : :
\
4 JUL 0 31986 4
ATTACHMENT NO. 1 GUIDELINES FOR JUSTIFYING Tile USE OF SUPPLEMENTAL STANDARDS 4 IN 40 CFR PART 192 ,
i l
The following guidelines identify documentation necessary to obtain NRC concurrence for the use of supplemental, standards in preparing a vicinity property remedial action plan. They are organized according to the criteria listed in 40 CFR 192.21, which have been incorporated by reference in 10 CFR Part 40. In addition, guidelines concerning the application of 40 CFR 192.22(c) to general and specific locations are also presented.
Criterion A: Supplemental standards'are ' justified when the remedial
' action would pose a risk of injury to workers or the general public, and
. there is no reasonable mea'ns for avoiding or reducing the risk.
Guidelines: The remedial action plan should document the risk by describing one or more scenarios, by identifying the person or persons at risk, and by estimating the likelihood of injury. The plan should explain how the probability of injury exceeds the probability for a similar injury at operations which are similar to the proposed remedial action. The remedial action plan should describe one or more possible
- protective measures, including alternative remedial actions where possible, and;should explain why the protective measures are not reasonable.
Criterion B: Supplemental standards are justified when cleanup of land contaminated in excess of the~ standards in 40 CFR 192.12(a) would produce environmental dataage that is clearly excessive when compared to the health benefits derived from such- remedial action.
Guidelines: The remedial action plan should identify the environmental damage, the specific remedial action operation which would produce the environmental damage,- and the health benefits which would be lost by not performing the remedial action. When identifying environmental damage, i
! the plan should describe the environmental media at risk, the potential changes to the environmental media caused by the remedial action, and the detrimental effects of the changes. The plan should describe one or more alternatives to the operation or mitigative measures which would limit i the damage and should explain why these alternatives or mitigative measures would not be reasonable. The potential for future public exposures should be included where there is a reasonable chance of a change in land use. The plan should then justify the use of supplemental standards based on a comparison of the environmental damage and health benefits.
o
?
ATTACHMENT NO. 2 MEETING ON APPLICATION OF SUPPLEMENTAL STANDARDS June 18, 1986 ATTENDEES Name Representing Number
? Jolene Garcia DOE 846-1238 Richard Sena DOE 846-1207 M.K. Tucker DOE-GJP0 Michael E. Madson Bendix-GJ Donnis Price Bendix-GJ 322-9476 Randy Brich NRC/URF0 776-2811 Dan Martin NRC/NMSS 427-4607 John Pepin MK-F 766-3076 Ed Hawkins NRC/URF0 766-2805 Carol Moore TAC 322-4030 Bob Kurz Chem-Nuclear 766-8244 3 Don Barg CNSI 766-8243 b
e