ML20214N306
| ML20214N306 | |
| Person / Time | |
|---|---|
| Issue date: | 07/18/1986 |
| From: | Knapp M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Themelis J ENERGY, DEPT. OF |
| References | |
| REF-WM-39 NUDOCS 8609160231 | |
| Download: ML20214N306 (4) | |
Text
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HBel1 MKnapp DMartin DSollenberger PDA Mr. John G. Themelis, Project Mana ;:r UMTRA Project Office Albuquerque Operations Office U.S. Department of Energy Albuquerque, New Mexico
Dear Mr. Themelis:
Enclosed are consnents on draft Revision C of the Vicinity Properties Management Implementation Manual including the UMTRA Project Vicinity Property Certification Plan (Exhibit E-1).
Should you have any questions regarding our comments, please contact Dennis Sollenberger of my staff.
Sincerely, f
Malcolm R. Knapp, Acting Chief Low-Level Waste and Uranium Recovery Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated cc w/ enclosure J. Garcia, D0E/AL WM Record file WM Project 3f J. Arhtur, D0E/AL Docket No.
J. Turi, DOE /HQ PDR V J. Baublitz, 00E/HQ-
_Distributio"n-8609160231 860718
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NAME :DSollenberge ar in :M Knapp DATE :86/07/18
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Specific Connents on Revision C to the
- Vicinity Properties Management Implementation Manual 1.3.1 Vicinity properties responsibilities o
The DOE /NRC MOV is being revised and the appropriate date for the revised M00 should be referenced.
o On the bottom of page 8, the term " unusual or significant properties" is used and then defined. The MOU specifies these properties as " separate properties" and defines them. The VPMIM should be revised to be consistent with the MOU.
1.3.2 Vicinity properties tasks o
On page 14, it states that NRC will receive copies of the RAA's, as appropriate. We.do not see any. conditions which warrant
- sending the RAAs to NRC; therefore, the parenthetical phrase '
including NRC should be deleted.
2.3.2 On-site survey procedures o
On page 24, the spillover number assignment procedure described is unclear. We recommend the following revision:
... Office (GJP0)[. Numbers for Grand Junctien properties will be]
consistent with..."
5.6.2 Land record annotation o
We recommend that the procedure described be agreed to by the States or Tribes through a modification to the respective Cooperative Agreements. Without this type of commitment, it is not clear to us how DOE will meet the reguirement to ensure.the land records are properly annotated.
o It is not clear whether the land record annotation procedure will include th'ose properties which were identified as contaminated but were not cleaned up (e.g., owner refusals).
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- Exhibit E-1 Vicinity Property Certification Plan 1.2 Responsibilities o
Attachment B was not included as part of the package for review.
The technical review form should be included as part of Exhibit E-1.
The previous copy of Attachment B did not appear to be able to handle the evaluation of separate VP completion reports.
o The first paragraph on page 2 should be revised to specifically reference Section 3.2.3 of the MOU.
In addition to the supplemental standards concurrences, the NRC, as required in the MOU, must concur in the completion / certification for all separate vicinity properties. This paragraph should be revised
.to be consistent with the MOU.
Figure Vicinity Property Certification Summary and Design 2.2 o
Figure 2.2 should have a footnote to Item 5 indicating the date of NRC concurrence in the use of supplemental standards.
2.5 Certification Decision o
In those instances where NRC concurrence is necessary, the final distribution of the certification documents should not be made until NRC has concurred in DOE's certification.
NRC will not concur until the appropriate DOE official has signed the Vicinity Property Certification Summary and Decision. This section should be rewritten to clearly identify that DOE must certify the site prior to NRC concurrence in the certification.
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Justification Checklist for the Application of Supplemental Standards To the end of item c) add the word " benefits".
Change the last heading on paga 1 to read
" Brief Condition Description and Justification:".
The last sentence on page 2 should have "or within 10 feet of the" inserted between the words "below" and " structure".
Associated Changes to the VPMIM Revision C 3.2.3 Use of supplemental stanaards Insert the following in paragraph 1 after the word " Checklist".
"which includes a discus.sion of the relevant items required by the respective criteria selected".
Insert after the word " guidelines." and prior to the next sentence starting with "A " Justification..." the following:
"These items should include, but not be limited to, the following: (1) annual gamma exposure rate, (2) annual working level exposure rate, (3) reference table of cost breakdowns, and (4) summary justification statement.".
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