ML20217F264
| ML20217F264 | |
| Person / Time | |
|---|---|
| Issue date: | 03/27/1998 |
| From: | Joseph Holonich NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rael G ENERGY, DEPT. OF |
| References | |
| REF-WM-62 NUDOCS 9803310328 | |
| Download: ML20217F264 (4) | |
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UNITED STATES g
g NUCLEAR REGULATORY COMMISSION I 2 WASHINGTON, D.C. 20555 0001
+9 *****,o March 27, 1998 Mr. George Rael, Director U.S. Department of Energy Albuquerque Operations Office ERD /UMTRA P.O. Box 5400 Albuquerque, NM 87185-5400
SUBJECT:
ACCEPTANCE OF COMPLETION REPORT FOR RIFLE, COLORADO, VICINITY PROPERTIES RF-581/587
Dear Mr. Rael:
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the Rifle, Celorado, Vicinity Property Completion Report (VP CR) for properties RF-581 and RF-587, along Highway 13, south of Highway 6 and 24. This VP CR, dated November 6,1996, was submitted by the U.S.
Department of Energy (DOE) under letter dated September 2,1997. Concurrence by the NRC on this VP CR is required because special circumstances resulted in supplemental standards being invoked during remedial action. Because the use of supplemental standards is the reason for the NRC's review, the NRC staff review has been limited to those parts of the VP CR related to the use of supplemental standards.
These VPs are the right-of-way for the Highway 13 railroad overpass, also described as the Rifle interchange with Interstate 70, on the north side of and immediately adjacent to the Colorado River, in Rine, Colorado. Vicinity property RF-581 is the property on the east side of the highway, while RF-587 is on the west side.
The DOE proposes to leave mill tailings contamination in two deposits on the properties. First, on RF-581, a layer of contaminated material was found to continue westward under the highway embankment. Complete remediation of the deposit was not performed. Based on limited characterization of the remaining contamination, the deposit was estimated by DOE to be about 10 inches thick and to have a volume of about 550 yd*. The average Ra-226 concentration was estimated by DOE to be 37 pCi/g. With backfill, the deposit is now covered by a thick layer of uncontaminated material.
A second deposit of contaminated material remaining on the properties was located in a small area below the west side of the embankment, on RF-587. From drawings in the VP CR, it appears that this deposit covers an area of roughly 1000 yd2. The Ra-226 concentration ranged up to 60 pCi/g. The contamination extended from the surface to depths of 6 feet, and the quantity of contaminated material in this deposit was estimated by DOE to be about 1200 yd*.
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D. Rml March 27, 1998 The DOE's justification for the use of supplemental standards to leave these deposits of contamination is the high cost of remediation relative to long-term benefits, as allowed under 40 CFR 192.21, criterion (c). The VP CR included an evaluation of the radiation doses to people who spend time on these sites. If the contaminated material was left on the VPs, the worst case exposures were assumed to be for the case of a person occupying the point of the highest gamma exposure rate, which is on the west side of the embankment (RF-587). In order for a person to receive a dose of 100 mrem in a year, DOE calculated that the person would have to spend 4000 hours0.0463 days <br />1.111 hours <br />0.00661 weeks <br />0.00152 months <br /> in a year at that point. The VP CR indicates that the west side of the embankment is not likely to be occupied or to have a structure built on it, due to the size of the area, relative inaccessibility, and seasonal flooding from the Colorado River. The report then concluded that it is highly unlikely for an individual to be exposed for the amount of time required to receive a dose of 100 mrem in a year, due to the length of time required and the location of the exposure rates. Th3 other deposit of residual radioactive material, under the embankment (RF-581), is inaccessible under a large quantity of soil and pavement, so people in the vicinity of this contamination are shielded from possible exposure. The DOE estimated the costs for complete remediation to be about $110,000 to clean up the deposit on RF-587, and about $850,000 to clean up both deposits.
Because of the relative inaccessibility of th'e remaining contaminated material, the NRC staff
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agrees that it would be very unlikely for a person to spend enough time near the contaminated material to receive a dose that is a significant fraction of 100 mrem per year. The NRC staff agrees that the costs of additional cleanup appear unreasonably high relative to the expected i
long-term benefits of such cleanup. Thus, the staff concludes that information provided by the DOE in the VP CR provides reasonable assurance that supplemental standards for soil cleanup have been properly applied at vicinity properties RF-581 and RF-587. Therefore, the NRC staff i
concurs that the use of supplemental standards and the remediation of these vicinity properties were completed in accordance with the EPA standards. The signed NRC Review Form for Supplemental Certification of Vicinity Properties, showing NRC concurrence, is enclosed, if you have any questions concerning this letter or the enclosure, please contact the NRC Project Manager, Janet Lambert, at (301) 415-6710.
Sincerely,
[D.Gillenfor]
Joseph J. Holonich, Chief l
Uranium Recovery Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated cc:
F. Bosiljevac, DOE Alb E. Artiglia, TAC Alb DISTRIBUTION w/ Encl.:
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CNWRA JLambert w/o Encl.:
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NAME DSchmidtME DGille JHol cb l DATE 03/26/98 03/l/1/98 N
03/'2'798 OFFICIAL RECORD COPY
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The DOE's justification for the use of supplemental standards to leave these deposits of contamination is the high cost of remediation relative to long-term benefits, as allowed under 40 CFR 192.21, criterion (c). The VP CR included an evaluation of the radiation doses to people who spend time on these sites. If the contaminated material was left on the VPs, the worst case exposures were assumed to be for the care of a person occupying the point of the highest gamma exposure rate, which is on the west side of the embankment (RF-587). in order for a person to receive a dose of 100 mrem in a year, DOE calculated that the person would have to spend 4000 hours0.0463 days <br />1.111 hours <br />0.00661 weeks <br />0.00152 months <br /> in a year at that point. The VP CR indicates that the west side of the embankment is not likely to be occupied or to have a structure built on it, due to the size of the area, relative inaccessibility, and seasonal flooding from the Colorado River. The report then concluded that it is highly unlikely for an individual to be expostsd for the amount of time required to receive a dose of 100 mrem in a year, due to the length of time required and the location of the exposure rates. The other deposit of residual radioactive material, under the embankment (RF-581), is inaccessible under a large quantity of soil and pavement, so people in the vicinity of this contamination are shielded from possible exposure. The DO_ estimated the costs for complete remediation to be about $110,000 to clean up the deposit on RF-587, and about $850,000 to clean up both deposits.
Because of the relative inaccessibility of the remaining contaminated material, the NRC staff agrees that it would be very unlikely for a person to spend enough time near the contaminated material to receive a dose that is a significant fraction of 100 mrem per year. The NRC staff agrees that the costs of additional cleanup appear unreasonably high relative to the expected long-term benefits of such cleanup. Thus, the staff concludes that information provided by the DOE in the VP CR provides reasonable assurance that supplemental standards for soil cleanup have been properly apphed at vicinity properties RF-581 and RF-587. Therefore, the NRC staff concurs that the use of supplemental standards and the remediation of these vicinity properties were completed in accordance with the EPA standards. The signed NRC Review Form for Supplemental Certification of Vicinity Properties, showing NRC concurrence, is enclosed.
If you have any questions concerning this letter or the enclosure, please contact the NRC
' Project Manager, Janet Lambert, at (301) 415-6710.
Sincerely, t1.
A Joseph J. Holonich, Chief l
Uranium Recovery Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated cc: F. Bosiljevac, DOE Alb E. Artiglia, TAC Alb l
I
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VP No.: RF-581/587 NRC Review Form for Supplemental Certification of Vicinity Properties The Department of Energy (DOE) has determined that the remedial action at the following vicinity property (VP) has been completed and thereby complies with supplemental standards invoked by DOE under 40 CFR, Subpart C, specifically Subsections 192.21 and 192.22.
[]
NRC concunence for the Radiological Engineering Assessment (REA) was requested on:
[X]
Supplementt.1 standards were not in the REA, special circumstances required t sunnlamental standards t invoked during remedial action.
Nb0 W
4 El Fr nTc D. Bosiljevac,'DR C'erYificalIo'n Officer Date
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Sased on the information and certification provided by the DOE, the NRC:
[g Concurs that the remedial action at the subject VP has been competed under its authority provided by the Ura lium Mill Tailings Radiation Control Act (UMTRCA), Section 104 (f)(1) and as described in the Memorandum of Understanding (MOU), Appendix A, Se': tion 3.4.
[]
Concurs, as above, except for the following conditions:
1.
2.
3.
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See attached sheets for any additional provisions.
[]
Needs additional information to make a concurrence decision. This information consists of:
[]
See attached sheets for any additional informational needs.
h M.Y 3
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Joseph J. Holonich, Chief Date Uranium Recovery Branch Enclosure