ML20209G274
| ML20209G274 | |
| Person / Time | |
|---|---|
| Issue date: | 08/28/1986 |
| From: | Brich R, Pettengill H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| REF-WM-41 NUDOCS 8609120412 | |
| Download: ML20209G274 (3) | |
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DISTRIBUTION Docket File No. 40-WM041 PDR/DCS DBangart, RIV RBrich 40-WM-192/RFB/86/08/01/2 HPettengill MBrown, RCPD, NM AUG 28 1986 URF0 r/f LLW Branch, WMLU i
UFRO:RFB Docket No. 40-WM041 040WM041110E MEMORANDUM FOR:
Docket File No. 40-WM041 FROM:
Randall F. Brich, Project Manger Licensing Branch 2 Uranium Recovery Field Office Region IV
SUBJECT:
REVIEW 0F JUSTIFICATION FOR APPLICATION OF SUPPLEMENTAL STANDARDS AT VICINITY PROPERTY SL-053-S
Background
By submittal dated July 1, 1986, The Department of Energy (DOE) supplied the final Radiological and Engineering Assessment (REA) which requested the application of supplemental standards on a portion of the contaminated area for vicinity property SL-053-S. On July 1, 1986, DOE was informed during a telephone conversation that the owner coments l
wouldbeneededpursuantto40CFR192.22(c)beforeNRCcouldmakea i
detennination on the application of supplemental standards.
By letter dated July 15, 1986, MK-Ferguson Company (MK-F) submitted a copy of the owner comments together with a copy of the MK-F letter dated June 2,1986, which informed the owner of DOE's intention of applying supplemental standards to a portion of the contaminated area. By letter dated June 10, 1986, the landowner stated that he concurred with the recomendation for application of supplemental standards contained in the HK-F letter dated June 2,1986.
1 Discussion Vicinity property SL-053-5 contains four areas contaminated with residual radioactive materials. One area in the main process building, beneath the foundation of the smokehouse, contains contaminated material as deep
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40-WM-192/RFB/86/08/01/2 AU G 2 8 1986 as 60 inches. The estimated volume is 240 cubic yards and the Ra-226 concentration ranges from 15 to 150 pCi/g with an average of 80 pCi/g.
Indoor ganum ray exposure rates inside this portion of the smokehouse vary from 17 to 40 micro R/h on contact with the brick floor. Background gamma exposure is about 8 micro R/h. Radon daughter concentrations of 0.003 and 0.006 WL were measured in the building during March, 1985 and are below the DOE action limit of 0.01 UL.
In accordance with criteria "d" of 40 CFR 192.21 and the NRC's
" Guidelines for Justifying the use of Supplemental Standards, in 40 CFR Part 192", dated July 3,1986, DOE satisfied the criteria deemed necessary to apply supplemental standards. However, the REA incorrectly referenced this section as 40 CFR 1292.1(c). This was brought to MK-Fs' attention by telephone conversation on July 25, 1986, and MK-F stated that an edited page would be sent in the near future. By submittal dated August 12, 1986, MK-F supplied the edited page for incorporation into the REA.
Presently, DOE is considering possible rulemaking)in order to satisfy the land records annotation required by Section 104(d of Public Law 95-604.
Revision C to the Vicinity Property Management Implementation Manual, which is currently undergoing review by all affected parties, discusses land records annotation. Therefore, until such time that DOE develops and implements the annotation procedures NRC should provide conditional concurrence. The condition would be considered satisfied upon demonstration by DOE that the land records annotation requirement is met.
Conclusion Based on my review of the subject REA and associated letters I recommend that conditional concurrence be granted for the application of i)FC :
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40-WM-192/RFB/86/08/01/2 AUG 23 1986 supplemental stan&rds for the property designated as SL-053-S contingent upon implementation of a land records annotation procedure by DOE.
8 Randall F. Brich, Project Manager Licensing Branch 2 Uranium Recovery Field Officel Region IV
/
Approved by:
liarry J. Pettengill, Chief Licensing Branch 2 Uranium Recovery Field Office Region IV Case Closed:
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