ML20206N391
| ML20206N391 | |
| Person / Time | |
|---|---|
| Issue date: | 12/09/1998 |
| From: | Stablein N NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rael G ENERGY, DEPT. OF |
| References | |
| REF-WM-66 NUDOCS 9812170044 | |
| Download: ML20206N391 (5) | |
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Mr. Georg3 Ra:1, Director December 9, 1998 U.S. D:partm:nt of Energy Albuquerque Operations Office
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ERD /UMTRA P.O. Box 5400
' Albuquerque, NM 87185-5400
SUBJECT:
ACCEPTA.NCE OF COMPLETION REPORT FOR NATURITA, COLORADO, VICINITY PROPERTY NT-059S
Dear Mr. Rael:
By letter dated November 5,1998, the U.S. Department of Energy (DOE) provided the Naturita, Colorado, Vicinity Property NT-059S Completion Report (VP CR) to the U.S. Nuclear Regulatory Commission (NRC) for review. The NRC staff's review of the VP CR is enclosed.
Concurrence by the NRC on this VP CR is required because special circumstances resulted in Supplemental Standards being invoked during remedial action. The NRC staff concludes that the information provided by DOE in the NT-059S CR provides reasonable assurance that supplemental standards for soil cleanup have been properly applied. Therefore, the NRC staff concurs that the use of Supplemental Standards and the remediation of the vicinity property were completed in accordance with U.S. Environmental Protection Agency standards. The signed NRC Review Form for Supplemental Certification of Vicinity Properties, showing NRC concurrence, is also enclosed, if you have any questions concerning this letter or the enclosures, please contact the NRC Project Manager, Robert Carlson, at (301) 415-8165 Sincerely, 1
[Signedby]
N. King Stablein, Acting Chief Uranium Recovery Branch Division of Waste Management Office of Nuclear Material Safety i
and Safeguards tJ L I N g,
Enclosures:
As stated LO(YY W cc: L. Woodworth, DOE Alb F. Bosiljevac, DOE Alb E. Artiglia, TAC Alb DISTRIBUTION w/ Encl.:
File Center NMSS r/f URB r/f PUBLIC ACNW CNWRA BSpitzberg/RIV JLusher w/o Enc _l :
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DOCUMENT NAME: S:\\DWM\\ URB \\jhl\\NT059S.LTR OFC 0JF B! J URB URB;frc fson CAhs KS[abl NAME a
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v DATE 12/4 /98 12/cA/98 12/07/98 h21 4
981209' r8AL RECORD COPY
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NUCLEAR REGULATORY COMMISSION 4
WASHINGTON. D.C. 205SS-0001
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December 9, 1998 Mr. George Rael, Director U.S. Department of Energy Albuquerque Operations Office ERD /UMTRA P.O. Box 5400 Albuquerque, NM 87185-5400
SUBJECT:
ACCEPTANCE OF COMPLETION REPORT FOR NATURITA, COLORADO, VICINITY PROPERTY NT-059S
Dear Mr. Rael:
By letter dated November 5,1998, the U.S. Department of Energy (DOE) provided the Naturita, Colorado, Vicinity Property NT-059S Completion Report (VP CR) to the U.S. Nuclear Rogulatory Commission (NRC) for review. The NRC staff's review of the VP CR is enclosed.
Concurrence by the NRC on this VP CR is required because special circumstances resulted in Supplemental Standards being invoked during remedial action. The NRC staff concludes that the information provided by DOE in the NT-059S CR provides reasonable assurance that supplemental standards for soil cleanup have been properly applied. Therefore, the NRC staff concurs that the use of Supplemental Standards and the remediation of the vicinity property were completed in accordance with U.S. Environmental Protection Agency standards. The signed NRC Review Form for Supplemental Certification of Vicinity Properties, showing NRC concurrence, is also enclosed.
If you have any questions concerning this letter or the enclosures, please contact the NRC Project Manager, Robert Carlson, at (301) 415-8165.
. Sincerely, 4
N.
ing Stablein, Acting Chief Uranium Recovery Branch Division of Waste Management Office of Nuclear MaMrial Safety and Safeguards
Enclosures:
As stated cc: L. Woodworth, DOE Alb F. Bosiljevac, DOE Alb E. Artiglia, TAC Alb 4
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NRP Review nf Reviced VP PR for NT n509 Nnvember 100R,
' U. S. NUCLEAR REGULATORY COMMISSION STAFF REVIEW OF THE COMPLETION REPORT FOR NATURITA VICINITY PROPERTY NT-059S The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the 1998 version of the Vicinity Property Completion Report (VP CR) for the Naturita Vicinity Property (VP) NT-059S, MK-Ferguson Company, dated September 17,1998.
The VP CR describes the remedial actions (radiological cleanup) and verification activities performed at VP NT-059S. This site lies within Montrose County, Colorado, approximately two miles east of the Naturita processing site on State highway 141. This highway traverses NT-059S from east to west on the north side aM borders it on the east side Per agreement with the property owner, in conjunction with MK-Ferguson site safety personnel concerns regarding work on the hillside / steep slope, supplemental standards have been applied to residual radioactive material left in place on the hillside / steep slope just east of areas '8' and '8.1.' Due to the instability of the slope, once disturbed, the likely potential of surface erosion once all vegetation is removed from the hillside / steep slope and the possiblity erosion could cause damage to the landowners road, it was determined that the cost of remediation would far outweigh the benefit received from the removal of the windblown contaminated materials. Appendix A, Radiological Survey Data for the Supplemental Standard, and Appendix B, Supplemental Standards Recommendation, serve as documentation of the application of supplemental standards of the remaining area of contamination and the current radiological conditions.
J Because the reason for the NRC's review of this VP CR is the use of supplemental standards at the VP, the NRC staff review has been limited to the area where j
supplemental standards have been applied.
The radiological conditions within the Supplemental Standards area are summarized as follows:
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Exposure rate range over the contaminated area (s)- 15 to 22 uR/hr b.
Average exposure rate range over the contaminated area (s) - 18 uR/hr c.
Maximum recorded Ra-226 concentration in accessible area (s) - 22.3 pCi/g d.
Average recorded Ra-226 concentration - 17.8 pCi/g Background for the Naturita locale is an exposure rite of 13 uR/hr and 1.5 pCi/g of Ra-226.
The data presented include background.
The VP CR provides a complete health risk analysis of the long term exposure of 100 mrem per year, and short term unusual exposure of 500 mrem per year. The analysis demonstrated that a person would have to be in the supplemental standards area for a very lengthy periods o' time to receive exposures at those levels..
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e NRP Review nf Revked VP PR fnr NT.Gi4R 1 Nnvember 100R The VP-CR also provides a thorough cost analysis for the remediation. Results of the cost analysis indicate that the benefit to be received from full removal of the contaminated material is prohibitive. Therefore, application of the U.S. Environmental Protection Agency (EPA) 40 CFR 192.21 (c) Criterion is more applicable than Criterion 192.21 (a).
NRC Staff Conclusion
- The NRC staff concludes that the information provided by the DOE in the VP CR for the Naturita Vicinity Property NT-059S and other documents provide reasonable assurance that remediation of this VP and the use of supplemental standards were completed in accordance with EPA standards.
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REFERENCES DOE (U.S. Department of Energy) Letter to J. J. Holonich, Chief, Uranium Recovery Branch, Division of Waste Management, Nuclear Materials Safety and Safeguards, U.S. Nuclear Regulatory Commission, dated November 5,1998, with enclosed copies of the Natarita, Colorado, UMTRA project site VP NT-059S cortpletion report. U.S. Department of Energy, Albuquerque Operations Office, Environmental Restoration Division, Uranium Mill Tailings Remedial Action Team, Albuquerque, New Mexico.
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j' VP No: NT-059S
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NRC Review Form for Supplemental Certification i
of Vicinity Properties The Department of Energy (DOE) has determined that remedial action at the above vicinity property (VP) has been completed and thereby complies with supplemental standards invoked by DOE under 40 CFR, Subpart C, specifically Subsections
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192.21 and 192.22.
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NRC concurrence for the Radiological Engineering Assessment (REA) was requested on:
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Supplemental standards were not in the REA, special circumstances reqtired that supplemental standards be invoked during remedial action.
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p" Frank D. Bosiljevac, DOE C6rtification Officer Date l
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i-4 Based on the information and certification provided by the DOE, the NRC:
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(l Concurs that the remedial action at the subject VP has been competed under its authority provided by the Uranium Mill Tailings Radiation Control Act (UMTRCA),
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Section 104 (f)(1) and as described in the Memorandum of Understanding (MOU),
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Appendix A, Section 3.4.
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Concurs, as above, except for the following conditions:
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See attached sheets for any additional provisions.
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Needs additionalinformation to make a concurrence decision. This information consists of:
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See attached sheets for any additional informational needs.
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,h UfK l2-N N$ Concurring Offidial andfitle Dat'e
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