ML20214J131
| ML20214J131 | |
| Person / Time | |
|---|---|
| Issue date: | 05/11/1987 |
| 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 8705270659 | |
| Download: ML20214J131 (3) | |
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.n DISTRIBUTION Docket. File wm-041
- PDR/DCSt WM-041/RFB/87/04/02/1 DBangart, RIV RBrich GGnugnoli, WMLU LLW Branch, WMLU URF0 r/f M Y 111987 t
URFO:RFB Docket No. 40-WM041 040WM041140E MEMORANDUM FOR:
Docket File No. 40-WM041 FROM:
Randall F. Brich, Project Manager Licensing Branch 2 Uranium Recovery Field Office Region IV
SUBJECT:
REVIEW 0F JUSTIFICATION FOR APPLICATION OF SUPPLEMENTAL STANDARDS AT VICINITY PROPERTY SL-0995, SL-115S, AND SL-116S
Background
By submittal dated March 2, 1987, the Department of Energy (DOE) supplied.
the final Radiological and Engineering Assessment (REA) which requested the application of supplemental standards under Criteria C of i
40 CFR 192.21 on a portion of the contaminated area which consists of the railroad right-of-way for the combined commercial vicinity property identified as SL-0995, SL-1155, and SL-1165.
DOE submitted a copy of the MK-F letters ' dated October 13, 1986, and January 6,1987, for SL-099S; November 25, 1986, and January 6, 1987, for SL-116S_and November 25,1986, for SL-115S, which informed the respective owners of DOE's intention of applying supplemental standards to a~ portion of the contaminated area.
By letters dated December 18-1986, and January 19, 1987, two of the landowners (SL-115S and SL-116S) stated they were in agreement with the proposed action. The third landowner, SL-099S, did not respond to the letters but was reached by telephone on March 3, 1987, and indicated that application of supplemental. standards was acceptable.
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I WM-041/RF8/87/04/02/1 MAY 111987 Discussion Vicinity property SL-0995 has contamination in excess of the EPA standards in seven areas. Both interior and exterior contamination in i
areas A through G will be removed. However, the inactive railroad spur, which is contaminated to the edge and underneath the railroad ties, will be excavated to the edge of the ties and clean fill used to replace the residual radioactive material (RRM).
The surface contamination extends 1291 linear feet.
Radium-226 concentrations range from 8.9 to 269 pCi/g.
Ambient direct gamma ray exposure rates range from background (about 10 microR per hour) to 136 microR per hour (microR/h). The estimated volume is 798 cubic yards and the average Ra-226 concentration is about 288 pCi/g.
U-238 values are in approximate equilibrium with Ra-226 which indicates the material is natural ore.
The additional cost of removal of the RRM and replacement of the railroad spur is $122,000, which is e
clearly excessive relative to the potential health benefits associated with the removal of the RRM, since no structures are involved and there is no anticipated land use change for the foreseeable future.
Vicinity property SL-1155 contains RRH scattered along and under the tracks of a very active railroad spur. The RRM averages 6 inches deep with a maximum of 12 inches at the north end.
Radium-226 concentrations range from 7.5 to 786 pCi/g with a maximum of 76,220 pCi/g for an isolated piece of natural ore (which was removed).
Gamma ray exposure rates range from 11 micro R/h to 112 micro R/h.
Supplemental standards are requested for the same reasons as above.
The cost of removal of the a
RRM and replacement of the railroad line, estimated at $519,300, is clearly excessive compared to the potential adverse health effects associated with leaving the material in place. There are 4400 linear feet and approximately 4786 cubic yards of RRM.
l.
Vicinity property SL-116S contains surface contamination mixed with ballast, primarily along the eastern portion of a very active railroad i
spur for a length of 4500 feet and a volume of 5580 cubic yards.
Activities range from 18.7 to 745 pCi/g with isolated pieces of natural ore registering 36,000 pCi/g Ra-226 (which were removed).
The gamma ray exposure rate ranges from 11 to 250 micro R/h.
Supplemental standards were requested.
The cost of removal of the RRM and replacement of the railroad line, estimated at $549,000, is clearly excessive in comparison to the potential health benefits which would be accrued if the material were to be removed.
OfC :
NAME :
c WM-041/RF8/87/04/02/1 RAY 111987 Conclusion DOE has justified the implementation of supplemental standards in accordance with criterion C of 40 CFR 192.21 and the hRC's " Guidelines for Justifying the Use of Supplemental Standards, in 40 CFR Part 192,"
dated July 3, 1986.
In addition, the landowners have indicated that they agree with the proposed action.
Therefore, based on my review of the subject REA and associated letters, I recommend that concurrence be granted for the application of supplemental standards for the commercial vicinity property identified as SL-099S, SL-115S, and SL-1165.
Izl Randall F. Brich, Project Manager Licensing Branch 2 Uranium Recovery Field Office
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Approved by:
Harry J. Pettengill, Chief Licensing Branch 2 Uranium Recovery Field Office, Region IV D
Case C1'osed: 040WM041140E A
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- URF NAME : RBric /1 HPetten -11 :
DATE :87/05/0
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