ML20217E826
| ML20217E826 | |
| Person / Time | |
|---|---|
| Issue date: | 06/02/1988 |
| From: | Heyer R, Pettengill H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| REF-WM-39, TASK-TF, TASK-URFO NUDOCS 9707030261 | |
| Download: ML20217E826 (6) | |
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7 F DISTRIBUTION Docket Fil; No. 40-WM039" PDR/DCS DBangart, RIV WM-039/RSH/88/06/02/0 RHeyer l RCPD, CO LLO Branch, LLWM URF0 r/f URf0:RSH Docket No. WM-039 040WM039130E MEMORANDUM FOR: Docket File No. WM-039 FROM: Ralph S. Heyer, Project Manager Licensing Branch 2 Uranium Recovery Ffeld Office, Region IV
SUBJECT:
REVIEW 0F JUSTIFICATION FOR APPLICATION OF ,
SUPPLEMENTAL STANDARDS FOR VICINITY PROPERTIES O LOCATED AT P0MONA ELEMENTARY SCHOOL (GJ-90072-SC)
U
Background
By submittal dated May 4, 1988, the Department of Energy (DOE) supplied the final Radiological and Engineering Assessment (REA) which requested the application of supplemental standards (SS) on the contaminated areas for vicinity properties (VP) identified as GJ-90072-SC, located at 588 - 25\ Road in Grand Junction, Colorado.
Discussion The VP at the Pomona Elementary School contains 24 areas that have residual radioactive contamination. The r. lean up of these areas will be conducted in two phases of construction. Phase I includes Areas B f_) through K, 5, 1 and U and will be constructed from June 13, 1988, to V August 1, 1988. Phase !! includes all remaining areas, L through R, V, W and X and will be constructed from November 1, 1988, to March 16, 1989.
The cost esu mate to perform remedial action on the VP with SS applied is estimated at J219,954 (5109.7 cu. yds.). The estimated cost for material to be removed as a result of remedial action without SS applied is estimated at $262,057 (5,835 cu. yds.). The area that apparently will not be cleaned involves, in part, material and labor costs for a temporary sewer line, sewer line plugs, temporary pumping and site OFC : : : : : : :
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security, and fencing. This is estimated at $42,103 (725.4 cu. yds.) or :
19 percent difference in the application of SS. !
Radioactive tailings were located around a sanitary sewer line at depths ;
of 81 inches in Areas L. M N and 0; 66 inches in Areas S T and W; and ;
90 inches in Area V. The 18-inch reinforced concrete pipe runs approximately 1500 feet through the Pomona Elementary School property, i The line serves the area commonly called Horizon Drive and enters Pomona property in the northeast corner near F Road and runs approximately 900 feet south, where it turns southwest and runs the remaining 600 feet ,
to the southwest corner of the property. $
-DOE stated that its preferred action is to remove tailings to a depth of
.66 inches or to the spring line of the pipe, whichever is encountered first. This would leave tailings below the spring line of the pipe at ;
depths of 15 inches in Areas L, M. N and 0, and 24 inches in Area V. The i p, requirements-for complete tailings removal include the shutdown and ?
U shoring of existing lines,-temporary-line design, construction, activation, maintenance and removal of the temporary line, as well as reactivation of the lines and checking for damages.
The exposure rate at ground level over the contaminated areas ranges from 14 pR/hr to 37-pR/hr, and averages 19 pR/hr. Radium concentrations in 3 soil in contaminated areas ranged from 4 to 54 pCi/g, with-average concentrations reported as 16 pCi/g.
By letter dated March 14, 1988, DOE informed the Associate Superintendent ;
of Schools and agreement was received on March 15, 1988, to proceed with t proposed application for SS.
-Conclusion Due to the limited extent of excavating the additional 725.4 cu. yds, and ,
the minimal-increase in cost of $42,103 (or 19 percent) associated with
'{N removing the tailings underlying the sewer line and the fact that it will not pose a hazard to workers, the benefits of removing the tailings is more_ appropriate for long-term considerations. .
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i i Therefore, based on the review of the subject REA, associated letters and ;
in accordance with 40 CFR 192.21 and 192.22, it is recommended that !
concurrence not be granted for the application of supplemental standards i for the property designated as GJ 90072-50.
L MI i Ralph S. Heyer, Project Manager Licensing Branch 2 j Uranium Recovery Field Office- t Raoion IV Approved by: l3 I i
Harry J. Pettengill, Chief t Licensing Branch 2 Uranium Recovery Field Office, Region IV O Case C ased: ==039u0E i 1
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URANIUM RECOVERY FifLD OFFICE DENVER. L Do IDI3s AM TIM URFO:RSH Oocket No. WM-039 040WP039130E MEMORANDUM FOR: Docket File No. WM-039 FROM: Ralph S. Heyer, Project Manager Licensing Branch 2 Uranium Recovery Field Office, Region IV
SUBJECT:
REVIEW OF JUSTIFICATION FOR APPLICATION OF SUPPLEMENTAL STANDARDS FOR VICINITY PROPERTIES i' n LOCATED AT POMONA ELEMENTARY SCHOOL (GJ-90072-SC)
U
Background
By submittal dated May 4, 1988, the Department of Energy (00E) supplied the final Radiological and Engineering Assessment (REA) which requested )
the application of supplemental standards (SS) on the contaminated areas for vicinity properties (VP) identified as GJ-90072-SC, located at 588 - 251: Road in Grand Junction, Colorado.
Discussion The VP at the Pomona Elementary School contains 24 areas that have residual radioactive contamination. The clean up of these areas will be conducted in two phases of construction. Phase I includes Areas B O through K. S. T and U and will be constructed from June 13, 1988, to August 1, 1988. Phase II includes all remaining areas. L through R. V, W and X and will be constructed from November 1, 1988, to March 16, 1989.
The cost estimate to perform remedial action on the VP with SS applied is .
estimated at $219,954 (5109.7 cu. yds.). The estimated cost for material to be removed as a result of remedial action without SS applied is estimated at $262,057 (5,835 cu yds.). The area that apparently will not be cleaned involves, in part, material and labor costs for a temporary sewer line, sewer line plugs, temporary pumping and site l
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2- J.N 21900 security, and fencing. This 's estimated at $42,103 0 25.4 cu. yds.) or 19 percent differenc.. In the applicction of SS.
Radioactive tailmgs were located around a sanitary sewer line at depths of 81 inches in Areas L, M, N and 0; 66 inches in Areas S, T and W; and 90 inches in Area V. The 18-inch reinforced concrete pipe runs approximately 1500 feet through the Pomona Elementary School property.
The line serves the area commonly called Horizon Drive and enters Pomona property in the northeast corner near F Road and runs approximately 900 feet south, where it turns southwest and runs the remaining 600 feet to the southwest corner of the property.
DOE stated that its preferred action is to remove tailings to a depth of 66 inches or to the spring line of the pipe, whichever is encountered first. This would leave tailings below tho spring line of the pipe at depths of 15 inches in Areas L. Hj N and 0, and 24 inches in Area V. The q requirements for complete tailings retaoval include the shutdown and V shoring of existing lines, temporary line design, construction, activation, maintenance and removal of the temporary line, as well as reactivation of the lines and checking for damages.
The exposure rate at ground level over the contaminated areas ranges from 14 pR/he to 37 pR/hr, and averages 19 pR/hr. Radium concentrations in soll in contaminated areas ranged from 4 to 54 pC1/g, with average concentrations reported as 16 pC1/g.
By letter dated March 14, 1988 DOE informed the Associate Superintendent of Schools and agreement was received on March 15, 1988, to proceed with proposed application for SS.
Conclusion Due to the limited extent of excavating the additional 725.4 cu. yds, and
(") the minimal increase in cost of $42,103 (or 19 percent) associated with V removing the tailings underlying the sewer line and the fact that it will not pose a hazard to workers, the benefits of removing the tailings is more appropriate for long-term considerations.
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i Therefore, based on the review of the' subject REA, associated letters and in accordance with 40 CFR 192.21 and 192.22, it is recommended that )
concurrence not be granted for the appitcation of supplemental standards for the property designated as GJ-90072-SC. ,
t Ralph S. Heyer roject Manager r Licensing Bra 2
- Uranium Recovery Field Office Region IV t
' Approved by: - D" HarryJJ. Pettep @ D , Chie' Licensing BrarM 2 t
> Uranium Recovery Field of fice, Region IV '
h Case Closed: 040WM039130E 8
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N - DISTRIBUTION f Docket File No. 40-WM039 !
PDR/DCS :
WM-039/RSH/88/06/02/1 h""p '
RCPD, CO l LLO Branch, LLWM ;
URF0 r/f i JLN 919BB .
URf0 RSH Docket No. WM-039 :
040WM039130E Joseph E. Virgona. Project Engineer GrandJunctionProjectOffice U.S. Department of Energy P.O. Box 2567 Grand Junction, Colorado 81502-2567 Dear Mr. Virgonal j We have completed our review of the Radiological and Engineering ;
._.) Assessment dated May 4, 1988, for the commercial vicinity property i designated as GJ-90072-SC, Pomona Elementary School, located at 588_- 25 Road in Grand Junction, Colorado, >
In order to ensure th t no future potential exists for spread of ,
tailings, it would be appropriate to clean up those areas of identified contamination (down to 15 inches in Areas L M..N and 0, and 24 inches in .
Area V) below the spring line of the pipe. The difference between applying or not applying supplemental standards (19 percent) is minimal, ,
in addition, there appears to be no undue risk to workers in either instance.
Therefore, based on our review, we cannot concur with the proposed remedial-action for the vicinity property which includes the application of supplemental standards as authorized by 40 CFR 192.21 and 192.22.
" O Should you have any questions on this concurrence, please contact Mr. Ralph S. Heyer of my staff on FTS 776-2811.
S!ncerely.
- lsi R. Dale Smith, Director Uranium Recovery Field Office Region IV cc: Bud Franz, G_ rand Junction, C0 Mgg Case-Closed: 040WM039130E -
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