ML20206R734

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Forwards Review of Completion Rept for Naturita,Co Vicinity Property NT-225,which Was Submitted with .Nrc Staff Concurs That Use of Suppl Standards & Remedial Action of Vicinity Property Completed IAW Us EPA Standards
ML20206R734
Person / Time
Issue date: 05/11/1999
From: Stablein N
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Rael G
ENERGY, DEPT. OF
References
REF-WM-66 NUDOCS 9905200192
Download: ML20206R734 (5)


Text

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May it, 1999 Mr. George Rul, Director U.S. Departm:nt of En:rgy -

Albuquerque Operations Office ERD /UMTRA.

P.O. Box 5400 Albuque,rque, NM 87185 5400

SUBJECT:

ACCEPTANCE OF COMPLETION REPORT FOR NATURITA, COLORADO, VICINITY PROPERTY NT-225

Dear Mr. Rael:

By letter dated March 17,1999, the U.S. Department of Energy (DOE) provided the Naturita, Colorado, Vicinity Property NT-225 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 NRC on this VP CR is required because special circumstances resulted in Supplemental Standards being invoked during remedial action. NRC staff concludes that the information provided by DOE in the NT-225 CR provides reasonable assurance that supplemental standards for soil cleanup have been properly applied. Therefore, NRC staff concurs that the use of Supplemental Standards and the remedial action of the vicinity property were completed in accordance with the 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,

[Signedby]

N. King Stablein, Acting Chief l

Uranium Recovery and Low-Level Waste Branch Division of Waste Management

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May 11, 1999 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-225 Dear Mr. Rael-By letter dated March 17,1999, the U.S. Department of Energy (DOE) provided the Naturita, Colorado, Vicinity Property NT-225 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 NRC on this VP CR is required because special circumstances resulted in Supplemental Standards being invoked during remedial action. NRC staff concludes that the information provided by DOE in the NT-225 CR provides reasonable assurance that supplemental standards for soil cleanup have been properly applied. Therefore, NRC staff concurs that the use of Supplemental Standards and the remedial action of the vicinity property were completed in accordance with the 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, s

N. Kin ablein, Acting Chief Uraniu Recovery and Low-Level Waste Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards

Enclosures:

As stated cc: L. Woodworth, DOE Alb F. Bosiljevac, DOE Alb J. Hylko, TAC Alb

- NRP Review VP FR fnr NT m T ehnmrv 1044 U. S. NUCLEAR REGULATORY COMMISSION STAFF REVIEW OF THE COMPLETION REPORT FOR NATURITA VICINITY PROPERTY NT-225 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-225, dated July 30,1998.

The VP CR states that no remedial actions were taken and verification activities were performed at VP NT-225. This site is the State Highway 90 right-of way south of the intersection with State Highway 141, Naturita, Colorado.

In the spring of 1998, while characterizing Vicinity Properties, contaminated materials were suspected of " spilling over" on to State Highway 90 right-of-way (ROW). After receiving owners' consent to access the property, an inclusion / exclusion survey was performed and subsequent recommendation for inclusion was made to the U.S. Department of Energy (DOE).

DOE formally included the property, identified as NT-225, into the Vicinity Property program on June 12,1998.

During discussions between DOE and the Colorado Department of Transportation (CDOT) about State Highway 141 work, CDOT imposed certain restrictions and requirements on how work would be performed within the ROW. The restrictions and requirements imposed by CDOT resulted in the application of Supplemental Standards in the Highway 141 ROW. The application of Supplemental Standards (VP NT-058) for the Highway 141 ROW was approved by NRC on December 01,1998. CDOT also stated that the same restrictions and requirements that were discussed for the Highway 141 ROW, would apply to the Highway 90 ROW. Based on the work restriction and requirements mandated by CDOT and the high cost versus the low long-term benefits, DOE proposed to apply Supplemental Standards to the contaminated materials left within the State Highway 90 ROW.

Because the reason for NRC's review of this VP CR is that the supplemental standards were used at the VP, NRC staff review has been limited to areas where supplemental standards were applied.

The radiological conditions within the Supplemental Standards areas are summarized as follows:

a.

Exposure rate range over the contaminated area (s) - 13 to 48 pR/hr b.

Average exposure rate range over the contaminated area (s) - 18 R/hr 0

c.

Ra 226 concentration range over the contaminated areas (s) - 0.2 to 179.1 pCi/g d.

Average recorded Ra-226 concentration over the contaminated area (s) - 8.7 pCi/g Background for the Naturita locale is an exposure rate of 13 pR/hr and 1.5 pCi/g of Ra-226.

Enclosure l

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NRP Revieur VP FR fnr NTMM Fehriinrv 1000 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 (s) for a very lengthy period of time to receive exposure at those levels.

The VP CR also provides a thorough cost analysis for the remediation, which indicates 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 applicable.

NRC Staff Conclusion NRC staff concludes that the information provided by DOE in the VP CR for the Naturita Vicinity Property NT-225 and other documents provides reasonable assurance that remediation of this VP and the use of supplemental standards were completed in accordance with EPA standards.

REFERENCES U.S. Department of Energy Letter to Mr. N. King Stablein, Acting Chief, Uranium Recovery Branch, Division of Waste Management, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, dated February 9,1999, with enclosed copies of the Naturita, Colorado, UMTRA project site VP NT-225 completion report. U.S. Department of Energy, Albuquerque Operations Office, Environmental Restoration Division, Uranium Mill Tailings Remedial Action Team, Albuquerque, New Mexico.

i 2

f VP No: NT-225S NRC Review Form for Supplemental Certification of Vicinity Properties T.he 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 192.21 and 192.22.

[]

NRC concurrence for the Radiological Engineering Assessment (REA) was requested on:

[X]

Supplemental standards were not in the REA; special circumstances required that pplemental standa ds be invoked during remedial action.

A sMM

' Frank D. Bosiljevac, DOE C fication Officer Dgte /

===========================

Based on the information and certification provided by the DOE, the NRC:

[]

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.

[]

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:

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See attached sheets for any additional informational needs.

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3'///l99 c/ NRC Concurrir6 Offiefdl and Title Date/

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