ML20211D939
| ML20211D939 | |
| Person / Time | |
|---|---|
| Issue date: | 10/01/1986 |
| 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, REF-WM-48, REF-WM-60 NUDOCS 8610220311 | |
| Download: ML20211D939 (5) | |
Text
DISTRIBUTION Docket liils No. WM-041 Docket File No. WM-048 Docket File No. WM-060,
WM-41/RFB/86/09/02/0 PDR/DCS
' DBangart, RIV RBrich OCT 011986 LLW Branch, WMLU URF0 r/f URF0: RFB Docket No. WM-041 Docket No. WM-048 Docket No. WM-060 040WM041120E 040WM060100E 040WM048810E 040WM048820E MEMORANDUM FOR:
Docket File Nos. WM-041, WM-048 and WM-060 FROM:
Randall F. Brich, Project Manager Licensing Branch 2 Uranium Recovery Field Office, Region IV
SUBJECT:
REVIEW 0F SUPPLEMENTAL STANDARDS REQUESTS FOR VICINITY PROPERTIES LOCATED IN SALT LAKE CITY, c
UTAH; RIVERTON, WYOMING; AND DURANGO, COLORADO UTAH The Radiological and Engineering Assessment (REA) which proposed the application of supplemental standards for the commercial vicinity property (SL-061) located at 2850 South 900 West Street, Salt Lake City, Utah, was submitted to NRC/HQ on August 26, 1985.
By letter dated February.26, 1986, NRC/URF0 informed DOE that a justification for the 4
i application of supplemental standards and a copy of the owner comments on the proposed action would be needed before NRC could concur on the application of supplemental standards.
By letter dated August 14, 1986, MK-Ferguson (MKF) submitted the justification and owner comments for this i
l property.
All contaminated areas are-outdoors; no residual radioactive material (RRM) has been identified under or adjacent to the warehouse on the property.
The RRM is in a utility trench along a roadside and extends i
from about 12 inches below the surface to a depth of about 36 inches.
Twelve inches of clean fill overlay the contaminated area.
The total 0FC :
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l DATE :86/10/01 8610220311 e61001 PDR WASTE l
WM-41/RFB/86/09/02/0
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amount of RRM is about 1000 cubic yards, and approximately 300 cubic yards of uncontaminated overburden overlays the area of concern.
The maximum radium-226 (Ra-226) concentration is 20 picocuries per gram (pCi/g).
Contact gamma ray exposure rates made at the boreholes vary from 16 to 20 microRoentgens per hour (microR/h), while roadside measurements approach background.
Exposures measured at 1 meter, along the fence adjacent to the contaminated area, range from 7 to 10 microR/h compared to the Salt Lake City background of 6 to 11 microR/h.
It is estimated that removal of this material would cost approximately
$50,000.00.
DOE requests that supplemental standards under 40 CFR 192.21(c) be applied since the cost of the remedial action would be unreasonably high relative to the benefits, and the RRM does not pose a clear hazard. The RRM either partially or completely encompasses four major utility lines, a security system electrical conduit, a major telephone trunk line, a 14-inch high pressure gas line, and a 30-inch storm sewer drain line.
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Should future repairs to these lines be required, removal of the RRM will not pose a significant hazard since the Ra-226 concentration is close to the EPA standard of 15 pCi/g.
In addition, the owner has stated that he is concerned about the possibility that, at some future date, he may be g
liable for the removal and disposition of-the RRM.
However, he stated that the proposed remedial action seems reasonable.
NRC Recommendation The request for concurrence on implementation of supplemental standards should be granted for vicinity property SL-061 since the owner is in agreement with the proposed remedial action, the situation meets Criterion C of 40 CFR 192.21, and the justification satisfies the NRC
" Guidelines For Justifying The Use of Supplemental Standards in 40 CFR Part 192" (NRC Guidelines) dated July 3, 1986.
In addition, the costs of g
remediating this RRM, estimated at $50,000, is clearly excessive compared to the health benefits.
l WYOMING The REA which proposed the application of supplemental standards for the
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industrial vicinity property (RT-034) located at the corner of South Fourth Street West and West Monroe Avenue in Riverton, Wyoming, was submitted to NRC/HQ on January 22, 1985.
The RRM to be left in place is under or within 10 feet of the railroad tracks owned by the Chicago and l
Northwestern Railroad.
By letter dated February 26, 1986, NRC/URF0 0FC :
3 NAME :
DATE :86/10/01
I WM-41/RFB/86/09/02/0 informed DOE that the REA was deficient in two areas; (1) a justification for the usage of supplemental standards, and (2) owner comments were needed.
By letter dated August 14, 1986, MKF supplied the owner comments and the justification for implementation of supplemental standards.
DOE requested that supplemental standards be applied under 40 CFR 192.21(c) which covers RRM placed semipermanently in a location where site-specific factors limit their hazard and from which it is costly or difficult to remove.
The 115 cubic yards of RRM to be left in place has a Ra-226 concentration that ranges from 9 to 30 pCi/g with an associated gross gamma exposure rate of 27 microR/h. The background gamma exposure rate for Riverton has been determined at 13 i 4 microR/h.
Residual radioactive material removal costs, estimated at $20,500.00, do not include compensation to the owner for the required closing down of the tracks during the projected 15-day construction period.
Since the likelihood of any structure being erected in the area of concern as well p
as the chance that people will spend significant periods of time there is extremely small, DOE requested NRC concurrence on the application of supplemental standards as allowed by 40 CFR 192.21(c).
In addition, the owner has stated that no construction will occur within 10 feet of the railroad tracks.
q NRC Recommendation Based on review of the REA, justification and owner comments; it is recommended that the request for supplemental standards be granted because this site qualifies under Criterion "C" of 40 CFR 192.21 and the justification satisfies the NRC Guidelines associated with this criteria dated July 3, 1986.
COLORADO l
DU-055
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The REA which requested supplemental standards for the municipal park vicinity property (DU-055) located on Roosa Avenue in Durango, Colorado, was submitted to NRC/HQ on July 3, 1985.
In accordance with the NRC/URF0 request dated February 26, 1986, for additional justification and owner comments, MKF replied by letter dated August 14, 1986.
00E requests, that if RRM is determined during remedial action to extend under the adjacent hard-surfaced Roosa Avenue, the RRM be left in place as provided for by Criterion "C" of 40 CFR 192.21.
If the contamination is found to exist under the paved road, DOE will quantify it and formally request 0FC :
NAME :
DATE :86/10/01
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WM-41/RF8/86/09/02/0 e
supplemental standards application under a separate property number.
The purpose of requesting supplemental standards in the REA was to positively provide assurance that the materials in question would not be forgotten.
NRC Recommendation If contamination is found to extend under Roosa Avenue, DOE has stated that it will be quantified and a request for application of supplemental standards will be made under a separate property number.
At such time DOE decides to request supplemental standards, NRC will review the request pursuant to the NRC Guidelines dated July 3, 1986.
Concurrence on this request is, therefore, not recommended.
DU-003 The REA which requested application of supplemental standards for the 4
open land vicinity property (00-003) located on a portion of the Durango and Silverton Narrow Gauge Railroad (DSNGRR) tracks was submitted to NRC/URF0 on February 3, 1986.
During the meeting in Albuquerque among DOE, MKF and NRC on June 18, 1986, NRC staff informed DOE of the need for additional justification and owner coments on this property.
By letter 5
dated August 14, 1986, DOE provided the justification and owner coments regarding the proposed application of supplemental standards under 40 CFR 192.21(c).
The 6 cubic yards of RRM possesses an approximate Ra-226 concentration of 18 pCi/g with a gross gama exposure of 14 microR/h.
Background gama exposure for the Durango site is extremely variable and has been determined to be 16 1 5 microR/h.
Removal costs, exclusive of owner compensation for shutting down the railroad, are estimated at $2,100.00.
Certainly, this amount would be negligible compared to the compensation associated with closing the railroad for the duration of the estimated i
construction period of about 5 working days.
The owner is in agreement with the proposed application of supplemental standards.
NRC Recommendation Based on review of the REA, justification and owner coments, it has been determined that the justification is consistent with the NRC Guidelines dated July 3, 1986. Therefore, it is recomended that concurrence be granted on the application of supplemental standards for vicinity property DU-003.
OFC :
NAME :
DATE.:86/10/01
f 6{
WM-41/RFB/86/09/02/0
' 5 - OCT 01 1986 Conclusion Based on my review of the REAs and associated letters, I conclude that concurrence should be granted for the application of supplemental standards to vicinity properties SL-061, RT-034 and DU-003. In addition, I conclude that concurrence should not be granted on vicinity property DU-055.
The reason for the withholding of NRC concurrence is that, if the RRM exists, it is beneath the adjacent paved street.
Conversations with the DOE and MKF staff indicate that the request for supplemental standards was premature and was not intended to be specifically applied
'l to DU-055. Thus, if DOE desires to apply supplemental standards to the paved streets in Durango, NRC would review the requests based on a justification submitted in accordance with the NRC Guidelines dated July 3, 1986. Therefore, the DOE should be notified, in writing, of the staff decisions.
a b
Randall F. Brich, Project Manager Licensing Branch 2 d
Uranium Recovery Field Office Region IV Approved'by:
Harry J. Pettengill, Chief Licensing Branch 2 Uranium Recovery Field Office, Region IV Cases Closed:
040WM041120E 040WM060100E 040WM048810E e
040WM048820E
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