ML20217N965
| ML20217N965 | |
| Person / Time | |
|---|---|
| Issue date: | 12/13/1994 |
| From: | Bell M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Joseph Holonich NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20217N400 | List:
|
| References | |
| FOIA-99-336 NUDOCS 9910290174 | |
| Download: ML20217N965 (4) | |
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MEMORANDUM T0: Joseph J. Holontch, Chief High-level Waste and Uranium Recovery Projsets Branch Division of Waste Management /M55 t
FROM:
Michael J. Bell, Chief Engineering and Geosciences Branch Olvision of Waste Management / MSS
SUBJECT:
TECM ICAL [ VALUATION OF THE SUPPLEMENTAL STANDARDS APPLICATION f0R THE NATURITA PROCESSING $1TE AREA We have reviewed the Department of Energy's (DOE) Report, 'Propond supplemental itandards Areas for the Naturita Processi Site and Surrounding Vicinity Properties,' datwf October 7, 1994. De Repor is in the Remedial Action Plan (
), but 00E requested a separate response for this Section as chanfles to supp seental standard areas could lapact the Plan. Approval of the RAF s delayed pending a decision on the dispostj site.
Attached are comments on the proposal and a request for additional Information.
In general 00t has not provided adequate justification for application of supplemental standards.
If you have any questions, please contact Elaine Srummett at 415 6604.
Attachment:
As stated 011falsuuGB: (*W/stt)f' Central file
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n' TECHNICAL EVALUATION OF THE SUPPLEMENTAL STANDARDS APPLICATION FOR THE NATURITA PROCESSING' SITE AREA By letter dated October 7, 1994, the Department 'f Energy (DOE) submitted the o
Report, " Proposed Supplesental Standards Areas for the Naturita Processing Site and Surrounding Vicinity Properties." Under the regulations for the Uranium Mill f allings Remedial Action Project, the U.S. Nuclear Regulatory Cosselssion, as an laplementing Agency, should concur with this proposed application of supplemental standards, if one or more of the criteria of 40 CFR 192.21 appites.
In addition, NRC staff should determine that the comes as close to meeting the proposed ree6dlal action (including no action)le under the circumstances, as otherwise applicable standards, as is reasonab required by Section 192.22 (a).
5t0P05AL DOE proposes to leave uranium mill taillnps in ten areas on and around the Naturita processing site. The areas tota, approximately 142 acres and contain about 119,600 cubic yards of contaalnated soll.
The general justification for not excavating these areas is that cleanup would be difficult and costly because of the steep slopes and rocky terrain; workers would be exposed to unsafe conditions; srosion problems could be created; and the windblown satorial (low radium concentration) does not pose a significant health risk.
The application of the supplemental standard of no remedial action for these areas, is based on meeting 40 CfR 192.21 criteria that represent circumstances that would result, due to remedial action required by Part 192, Subparts A and 8.
The criteria applied by 00( tres i
clear and present risk of injury to workers or the pubile a.
b.
environmentalharmthatisexcessive(long-ters,sanifest) compared to the health. benefits high cost relative to long ters benefits at a vicinity property, and c.
the residual radioactive seterials do not pose a clear present or future hatard, The type of area and the above specific criteria applicable to each one are:
Alvor front Wetlands (Areas of former Pile and () - b former Ore Storage, Steep slopes a, b, c Windblown en Steep llepes (Areas I, C, O, t. f, G1, and Gt) - a, b, c High Pressure Ces line a, b, C C0ff1Lllu 00t Indicates that the river front wetlands (3.0 acres) are under the jut sdiction of the U,l, Army Corps of Engineers, and areas with cottonwood t
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'and willow seedlings thak ocent uxt to the T1wr ais to be protected.
Excavation in the area may pose haru 'to these pnitected wetlands. DOE also
' indicates that spillage of contaminated material during excavation could contaelnate the river. DOE did not. address howpartial remediation of this area would cause a clear ' excess of environaeatal harm that is grossly disproportionate to anticipated health effects., as required by criterton b.
For areas of steep slopes',00E indicates that there are relatively flat portions, but that the extra cost to gain acccas with equipment would exceed the long ters benefits. However, the benefits are not discussed. Note 2 on Figure 3, indicates that relatively flat esas on the steep banks will remain unexcavated because distu'rbance may cause orcsion ytroblems and the areas will get contaetnt,ted again fr'on the steeper slopea above.
The erosion and recontastaatton probleas' had the cott of soluttou are not discussed. DOE mentions that alternatives to conventional remedial actions, presumably to i
reduce risk to workers, would elevate costs, but the costs are not di :ussed relative to benefits.
The windblown steep slopes of Areas B, C, and 0 border the east side of the highway. Figure 3 indicates that, typically, a'50 foot wide strip beside the highway will nct be excavated. Area 1 covers 114.5 acres on the west side of the highway. Bassd on the NRC site visit, it appears that some portions of these areas could be remediated without tacess cost or risk, assuming that the elevated readings are not due to natural deposits. Since final excavation limits for all areas are determined by the 00E contractor in the field, there should be guidance (possibly a restnder on the extent of excavation map) indicating that the remediation Ull come et close to meeting the otherwise applicable standards as is reasonable under the circumstances.
Area G2 is designated a steep windblown area. The average Ra 226 10 samples), with a range of 11 to concentrattenfortheareaisilPCf/g(6to!!inchdepthyielded96)C1/g 206 pCl/g. The one sample taken at the (Appendix A). DOE should Indicate why the Ra 226 level in Area G2 is afgher than typical windblown areas, and discuss the potential long tors health benefits if the area is remediated.
For the gas line. 00( preposes that a 5 foot wide area on either side of the line rossin unescavated. Conversatten notes indicate that an employee of the Nateral Gas Ceepany said that estavation must be by hand for 3 feet on either side of the line. 00( indicates in discussion of the gas Ifne, that the cost and time for hiring speciallied workers or providing workers extra training and special equipment, say not be warranted because of the low risk of public DOC does not adequately address the fact that radiation espesure.
Sectlen 192.!! criteria a and b indicate that the risk and harm be considered, M talthstanding reasonable measures to aveld er reduce the risk of injury or environmental hars.
Notes of a conversallen with a representative of the Natural Gas Company is Reference is made to negotiations with the only land owner ceanent provided.
the other owners being documented in the Remedial Action Agreement, but NRC staff does not have a copy of these agreements. DOE should provide all the land owner comments en the proposed application of supplemental standards to pertlens of their property.
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i Rf00f5T FOR INFORMATION J
Address how partial remediation of this area w:rd14 tusse a clear excess 1.
of environmental harm that is grossly 1/spr$3rthste to anticipated health effects.
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For the steep areas, provide a dhcussion of"the long ters benefits if 2.
the areas were remediated, on the potential erosion problems and alternative remediation osthods, and the cost of solutions.
Provide infonsation on the possible future use of the ore storage area, 3.
the cost to remediate the moderately steep portions, and the potential health benefits if the'saterlal is removed.
Provide guidance to the contractor indicating that the rseediation will 4.
come as close to weting the otherwise applicable standards as is reasonable under the circumstances.
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Indicate why the Ra 226 level in Area G2 is higher than typical 5.
windblown areas, and discuss the potential long tern health benefits if the area is remediated.
Indicate the long ters plans for the gas line, cleanup costs of 6.
remediation with equipment within 3 feet of the line and excavation by hano of the top foot of contaalnated soll over the line relative to health benefits, and why Ra 226 k ia for the area was not provided.
7.
Provide the land owner comments on the troposed application of supplemental standards to portions of their property.
MINOR COMMEMf1 on Annandir A. Calculatten 17 710 02 (no significant impact)
Duplicate Ra 226 samples were averaged for the ore storage area, and le AreasI,0(favrpairs),I(steep),andF.
four Area D As 226 sample locations either have a typopraphical error in 2.
the north co ordinate (M49500 and M49200), or the saap es were not taken in Area D.
AtlocationN64200/[49315, there is either a typographical error on the east ce drdinate, or the sample was not taken in Area D.
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