ML20206Q010
| ML20206Q010 | |
| Person / Time | |
|---|---|
| Issue date: | 01/06/1999 |
| From: | Stablein N NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rael G ENERGY, DEPT. OF |
| References | |
| REF-WM-66 NUDOCS 9901140010 | |
| Download: ML20206Q010 (5) | |
Text
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Mr. Grorgo Ratl, Director January 6,1999 U.S. D partm:nt of Ennrgy Albuquerque Operations Office i ER'D/UMTRA l P.O. Box 5400 Albuquerque, NM 87165-5400
SUBJECT:
ACCEPTANCE OF COMPLETION REPORT FOR NATURITA, COLORADO, VICINITY PROPERTY NT-067S
Dear Mr. Rael:
By letter dated November 3,1998, the U.S. Department of Energy (DOE) provided the Naturita, Colorado, Vicinity Property NT-067S 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-067S 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 the Environmental Protection Agency standards. The signed NRC Review Form for Supp' mental Certification of Vicinity Properties, showing NRC concu rence,is also enclosed.
, If you have any questions concerning this latter or the enclosures, please contact the NRC l Project Manager, Robert Carlson , at (301) 415-8165 Sincerely,
[ Signed by]
l N. King Stablein, Acting Chief Uranium Recovery Branch Division of Waste Management 7
Office of Nuclear Material Safety /
and Safeguards 1
Enclosures:
As stated cc: L. Woodworth, DOE Alb l F. Bosiljevac, DOE Alb nob J. Hylko, TAC Alb DISTRIBUTION w/ Encl.: File Center NMSS r/f URB r/f -PUBLIC ACNW 4 b//[
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- .* January 6,1999 Mr. George Rael, Director U.S. Department of Energy
. Albuquerque Operations Office ERD /UMTRA P.O. Box 5400 Albuquerque, NM 87185-5400 j
SUBJECT:
ACCEPTANCE OF COMPLETION REPORT FOR NATURITA, COLORADO, j VICINITY PROPERTY NT-067S
Dear Mr. Rael:
By letter dated November 19,1998, the U.S. Department of Energy (DOE) provided the Naturita, Colorado, Vicinity Property NT-067S 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-067S CR provides reasonable assurance that supplemental standards for soil cleanup have been properly apolied. Therefore, the NRC staff
, concurs that the use of Supplemental Standards and the remedial action of the vicinity property
( were completed in accordance with the Environmental Protection Agency standards. The signed NRC Review Form for Supplemental Certification of Vicinity Properties, showing NRC concurrence, is clso enclosed.
If you have any questions concerning this letter or the enclosures, please conta::t the NRC l Project Manager, Robert Carlson, at (301) 415-8165.
l j Sincerely, I
N.Ki Stablein, Acting Chief Uranium Recovery Branch Division of Waste Management Office of Nuclear Material Safety
.and Safeguards f
Enclosures:
As stated cc: L. Woodworth, DOE Alb F. Bosiljevac, DOE Alb j J. Hylko, TAC Alb i
1
o U. S. NUCLEAR REGULATORY COMMISSION STAFF REVIEW OF THE COMPLETION REPORT FOR NATURITA VICINITY PROPERTY N7-cL7S i
The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the 1998 version of the Vicinity Property Completion Report (VP CR) for the Natt,rita Vicinity Property (VP) NT-067S, MK-Ferguscn Company, dated September 28,1998.
The VP CR provides the U.S. Department of Energy's (DOE's) radiological verification activities i and application for supplemental standards at VP NT-067S. This site is located within l Montrose County, Colorado, adjacent to the Naturita processing site and west of State Highway l 141, 1
DOE did not perform remedial action on VP NT-067S. DOE's justification for not performing !
, remedial action was the following: Instability of the steep slopes at the site; the likely potential j of severe surface erosion once all vegetation is removed from the hillsides; the high risk of injury to personnel performing the remedial action due to the rugged terrain; and the excessive cost of remedial action would far outweigh the long-term health benefit received from the removal of the windblown contaminated materials. Appendix A " Radiological Suivey Data," and l Appendix B -Supplemental Standards Application" of the VP CR serve as supporting ,
l documentation for DOE's use of supplernental standards at VP NT-067S to leave remaining '
areas of radiological contamination and their current radiological conditions in place.
Consistent with current NRC review guidance, only the information appurtenant to supplemental l standards areas is reviewed for VPs.
The radiological conditions within the Supplemental Standards areas are summarized as !
follows:
- a. Exposure rate range at ground level over the contaminated arems) - 9 to 70 R/hr l
- b. Average exposure rate at ground levol over the contaminated area (s) - 24 gR/hr
- c. Ra-226 concentration range for contaminated soils - 2 to 96 pCi/g
- d. Average Ra-226 concentration for contaminated soils - 21 pCi/g Background readings for the Naturita locale are an exposure rate of 13 R/hr and 1.5 pCi/g of Ra-226. The data presented above include background figures.
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, and demonstrates that a person
- would have to be in the area (s) for extremely lengthy periods of time to receive these types of exposures. Thus, DOE conc {udes that it is highly unlikely for an individuat to be exposed for the
- amount of time necessary to exceed the recommended annual maximum dose due to both the
- length of time required and the remote location of the exposure.
! 1
- Enclosure i
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. l 2 l The VP CR also provides a thorough cost analysis for the remedial action, which indicates that the health benefit derived from full removal of the low level contaminated material is )
inconsequential compared to the prohibitively high cost of completing such an action.
NRC Staff Conclusion The staff concludes that the information provided by DOE in its VP CR for NT-067S and other l supporting documents provides reasonable assurance that the use of supplemental standards are appropriate in accordance with EPA regulations set forth in 40 CFR 192.21.
REFERENCES DOE (U.S. Department of Energy) Letter to J. J. Holonich, Chief, Uranium Recovery Branch, i Division of Waste Management, Nuclear Materials Safety and Safeguards, U.S. Nuclear Regulatory Commission, dated November 19,1998, with enclosed copies of the Naturita, Colorado, UMTRA project site VP NT-069S completion report. U.S. Department of Energy, Albuquerque Operations Office, Environmental Restoration Division, Uranium Mill Tailings Remedial Action Team, Albuquerque, New Mexico.
1 i
i i
VP No: NT-067S NRC Review Form for Supplemental Certification 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, Subpa't C, specifically Subsections l 192.21 and 192.22.
l
[] NRC concurrence for the Radiological Engineering Assessment (REA) was requested on:
[X] Supplemental standards were not in the REA, special circumstances required that supplemental standards be invoked during remedial action.
/
p h a c1Azt.c /' // /
l Frank D. Bosiljevac, DOE C rtification Officer Dite f I =======================
Based on the information and certification provided by the DOE, the NRC:
i 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),
Section 104 (f)(1) and as described in the Memorandum of Understanding (MOU),
Appendix A, Section 3.4.
l
[] Concurs, as above, except for the following conditions:
1.
2.
3.
[] See attached sheets for any additional provisions.
[] Needs additional information to make a concurrence decision. This information consists of:
i h
l
- [] See attached sheets for any additional informational needs.
&M AkWGdita NRC Cono6rring4fficial and T[d ibl11 i / / Dirie i
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