ML20215C494
| ML20215C494 | |
| 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 NUDOCS 8610100307 | |
| Download: ML20215C494 (3) | |
Text
_
DISTRIBUTION Dockst F.ile WM-041
'PDR/DCS DBangart, RIV WM-041/RFB/86/09/17/1 RBrich LLW Branch, WMLU L
OCT 011986 URF0 r/f URF0:RFB Docket No. WM-041 040WM041130E MEMORANDUM FOR:
Docket File No. WM-041 FROM:
Randall F. Brich, Project Manager Licensing Branch 2 Uranium Recovery Field Office, Region IV
SUBJECT:
REVIEW 0F SUPPLEMENTAL STANDARDS REQUEST FOR VICINITY PROPERTY SL-628
Background
The original Radiological and Engineering Assessment (REA) was disapproved by the Department of Energy (DOE).
The final REA, Revision 1 was submitted on June 16, 1986, for the municipal vicinity property (SL-628) located at 4500 South Street, Salt Lake City, Utah.
The REA requested application of supplemental standards to a portion of the area containing residual radioactive materials (RRM).
During a meeting in Albuquerque among DOE, MK-Ferguson (MKF) and NRC on June 18,'1986, we informed DOE of the need for additional justification regarding supplemental standards application and owner comments concerning the proposed action.
By submittal dated August 28, 1986, MKF supplied the following additional information:
justification for supplemental y
standards, cost estimate for not applying supplemental standards, MKF letter dated March 18, 1986, which documents the owner's agreement with the proposed remedial action, and a sketch of the property showing the location of the RRM to be left under supplemental standards.
Discussion As a result of the widening of South Street along the southern edge of vicinity p.operty SL-528, which included a portion of the property contaminated with RRM, the property ownership changed to the new owner, the Utah Department of Transportation (UDOT). Subsequently, a new I
0FC :
NAME :
DATE :86/10/01 8610100307 861001 PDR WASTE WM-41 PDR
~
WM-041/RFB/86/09/17/1 g
1 property number, SL-628, was assigned since the ownership of the contaminated property changed.
During preparatory work on utilities to accomodate the street widening, it was discovered that approximately six feet of RRM underlie the widened area.
The decision was made to remove as much RRM as possible during this initial construction phase.
After removal of about four feet deep of RRM, it was learned that the remaining RRM encompassed a 12-inch water line and an 8-inch hiah pressure gas line. Accordingly, RRM was excavated to nearly the top of the lines, with the remainder left in place because of safety concerns involved with excavating around the gas line.
In addition, excavation costs associated with removing the remaining RRM are estimated at $3,300.00, which does not include the cost of purging the lines.
The proposed action is to leave about 17 cubic yards of RRM, which possesses a maximum and average Ra-226 concentration of about 115 pCi/g and 45 pCi/g, respectively, permanently beneath a paved street at a aepth of about four feet.
Exposure measurements over the buried RRM are 13 microR/h compared to a Salt Lake City background of 6 to 11 microR/h.
Thus, DOE recommends the application of Supplemental Standards under Criterions A and C of 40 CFR 192.21.
Criterion A addresses the risk of worker injury, while Criterion C involves excessive cost relative to 5
expected health benefits.
Review of MKF's submittal dated August 28, 1986, indicates that the justification of application of supplemental standards is in accordance with the NRC " Guidelines for Justifying the Use of Supplemental Standards in 40 CFR Part 192" dated July 3, 1986.
Conclusion Based on my review of the REA, justification and owner comments, I conclude that concurrence should be granted for the application of supplemental standards to vicinity property SL-628.
Therefore, DOE g
l l
i
' 0FC :
' NAME :
i _ __.:-___________.______..____....._______....._________.____________.______....__.___________
DATE :86/10/01 l
i s
I
1 WF041/RFB/86/09/17/1 5 OCT 011986 should be notified, in writing, of our decision to concur on their proposed application of supplemental standards for vicinity property SL-628.
9/
Randall F. Brich, Project Manager Licensing Branch 2 Uranium Recovery Field Office Region IV Approved by:
i Harry J. Pettengill, Chief Licensing Branch 2 Uranium Recovery Field Office, Region IV j
J Case Closed:
040WM041130E e
N OFC :
_ _ _ __. U_R_F_0_ _ _ _ _ _ _ _ _ '. U_R_F_0_
,,[RBrigh((s_,,[yPgt,gngill:
/0 j DATE :86/10/01 4