ML20234C639
| ML20234C639 | |
| Person / Time | |
|---|---|
| Issue date: | 11/20/1987 |
| 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-64 NUDOCS 8801060282 | |
| Download: ML20234C639 (3) | |
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DISTRIBUTION l Docket File #40-WM064 PDR/DCSL S 1 DBangart,-RIV J 40-WM064/RSH/87/08/18/l RHeyer j MBRown, RCPD, NM i LL1 Branch, WMLU I URF0 r/f f i
NOV 2 01987 UPF0: RSH ,
Docket No. 40-WM064 040WM064850E MEMORANDUM FOR: Docket File No. 40-WM064 ;
FROM- Ralph S. Heyer, Project Manager Licensing Branch 2 Uranium Recoverv Field Office Region IV
SUBJECT:
REVIEW OF JUSTIFICATION FOR APPLICATION OF SUPPLEMENTAL STANDARDS AT VICINITY PROPERTIES LK-004S and LK-0095-
Background
By submittals dated July 10 and September 18, 1987, the Department of Energy (DOE) supplied the final Radiological and Engineering Assessments (REA's) which requested the application of supplemental standards under Criteria C of 40 CFR 192.21 to two of the contaminated areas. These areas consist of a railroad right-of-way identified as LK-004S and railroad spur line identified as LK-0095. 4 i
Discussion l l
The surface gamma readings for vicinity property LK-0045 range from 31 to 193 pR/hr. A complete gamma survey by grid was performed on the property. The elevated readings confirmed borehole readings in identifying contaminated areas of the property. Borehole survey results identified contamination in 31 of 62 outdoor holes augered, with measurements ranging from surface to 30 inches depth. Neither the inclusion survey nor the RAC's surveys showed any habitable structure ,
within the property boundaries of LK-004S, a railroad right of-way. l The surveys results indicated that the contamination identified in the {
rail yard property was uranium ore which was handled at the rail yard. '
0FC : 88010602B2 872120
:------- PDR WASTE ---------- :--------~~- :------------:--~~--~~~--
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DATE :87/11/19 : : : : -
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40-WM064/RSH/87/08/18/1
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NOV 2 01987 The proposed remedial action is to excavate all areas except for the area directly under the new railroad track. The additional cost of removal of !
residual radioactive material (RRM) and replacement of railroad track is i 544,600, which is excessive relative to the potential health benefits associated with removal of the RRM. In addition, there are no structures involved and there is no land use change anticipated for the foreseeable future.
Vicinity property LK-0095 has surf ace gamma readings on the property ranging from 11 to 515 pR/hr. The only structures identified on the property were lumber storage roofs used to keep rain off the lumber.
Because these structures are not enclosed, DOE does not consider them to be habitable structures. Borehole survey results identified contamination in 111 of the 208 outdoor holes augered, with measurements ranging from surface to 42 inches depth.
The railroad spur line running through LK-0095 is located within the I
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northern area. The railroad tracks on the property are used i about once a week by the existing saw mills in the vicinity. Because of the economic impact upon the saw mills, that would result from closing the railroad, in addition to costs of removing contamination from under I the tracks and the low health hazards, the use of supplemental standards are to be applied per 40 CFR 192.21 (c). The estimated cost without the application of supplemental standards is $73,600, which is excessive in ,
comparison to the potential health benefits which would be accrued if the tracks and material were to be removed. In addition, no land use change is anticipated for the foreseeable future. i j
Conclusion 00E has justifie~d the implementation of supplemental standards in i accordance with Criterion C of 40 CFR 192.21 and the NRC's " Guidelines ;
for Justifying the Use of Supplemental Standards, in 40 CFR Part 192," i dated July 3, 1986. During the review of owner concurrence in the ;
application of supplemental standards for the LK-0095 property it was )
determined that additional information would be required prior to concurring with the need for implementing supplemental standards.
Based on several telephone conversations with DOE-Albuquerque staf f and l the Remedial Action Agreement (RAA) dated September 18, 1987, the RAA adequately reflects the owners agreement with the final plan for remedial action including the application of supplemental standards.
OFC . . . :
NAME : : -
_____.____________.__~_________.____________.____________.____________.___.________:___________
DATE :87/11/19 .
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40-WM064/RSH/87/08/18/1 NOV 2 01987 l
Therefore, based on my review of the subject REA, I recommend that concurrence be granted for the application of supplemental standards for the commercial vicinity properties identified as LK-004S and LK-0095.
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Ralph S. Heyer, Project Manager Licensing Branch 2 Uranium Recovery Field Office Region IV l Approved by: /5/
Harry J. Pettengill, Chief j
Licensing Branch 2 Uranium Recovery Field Of fice, Region IV Case Closed: 040WM064850E l
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DATE$87/11/19
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