ML20203L548
| ML20203L548 | |
| Person / Time | |
|---|---|
| Issue date: | 09/13/1989 |
| From: | Randy Hall NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Lacker D TEXAS, STATE OF |
| Shared Package | |
| ML20203L517 | List: |
| References | |
| NUDOCS 9803060115 | |
| Download: ML20203L548 (2) | |
Text
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David K. Lacker, Chief Bureau of Radiatioi. Control 1100 West 49th Street Austin, Texas 78756-3189
Dear Mr. Lacker:
Our office is in receipt of your August 15, 1989 letter discussing waste disposal options available to Texas in-situ uranium recovery facilities in the process of decoenissioning.
You have raised a number of questions concerning soil mixing, cleaning and burying materials, as well as soil blending.
It is the NRC position that elevated levels of radionuclides, in this case radium-226, represent byproduct materials.
If the radium-226 concentrations in soil exceeds 5 pCi/g in the first 15 centimeters above background the material is to be removed and placed in an approved disposal facility.
The NRC does not consider it appropriate for the 5 pCi/g to be used as a soil mixing or soll blending criteria, with the purpose of allowing the byproduct material to i
remain in place.
Similarly, your second and third points involve soil miking and fail to include disposal in an approved facility; therefore, they cannot be considered as appropriate disposal methods of byproduct materials.
It is our understanding that cultivation practices are utili;:ed in waste water (byproduct material) disposal areas.
Further, we understand that sufficient design has taken place in the form of barium chloride treatment to reduce Ra-226 levels to avoid soil loading in excess of the prescribed standards throughout the design life of the disposal area.
Therefore, cultivation practices are of agronomic value rather than radiolooically significant..lf the site allows Ra 226 loading to exceed the standards, then it is improperly designed and in need of design adjustments to prevent unacceptable levels of Ra-226.
In addition soil that has excess Ra-226 should be removed and disposed of in an app, roved disposal facility.
Contaminated materiala include all items related to uranium recovery operations that do not meet decontamination limits for unrestricted use as specified in
" Acceptable Surface Contamination Levels," as attached to a source material license.
If materials are decontaminated to these icvels, then they may be released for unrestricted use.
However, contamination exceeding these levels 9903060115 900206 PDR STPRO ESGNY PDR r
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SEP 1319ES will identify the materials as contaminated, resulting in their being treated as byproduct materials.
In this caso, appropriati! disposal methods will be required.
The soil blending that has been proposed does not represent an acceptable disposal option.
As has been previously discussed, well field and other soils with elevated levels of radium-226 represent byproduct materials and must be appropriately disposed.
However, if no viable disposal option exists, a licensee may apply for onsite disposal of byproduct materials.
Such an application would be required to meet the siting criteria radon exhalation rates and long-tem stability requirements stated in 10 CER 40. Appendix A.
Similarl dollars)y, lend title to the eppropriate governroent including $250,000 (in 1978 1
would be required for long-term maintenance and surveillance of the site. This would mean that the disposal site would have to be licensed by the State, at its option, or the U.S. Government.
Please note that Criterion 2 of 10 CFR Part 40, Apoendix A, discusses avoiding the proliferation of small waste disposal sites.
T1erefore, the establishment of onsite disposal sites at each solution mining facility would not appear to be in compliance with Criterion 2.
We understand that disposal of contaminated materials and byproduct materials, associated with solution mining, is becoming an increasingly difficult Froblem.
However, as shown above, solutions do exist.
If we can be of further assistance, please contact our office.
Sincerely, nE 1
Director cc:
R. J. Doda, RIV l
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