ML20236N030
| ML20236N030 | |
| Person / Time | |
|---|---|
| Issue date: | 07/02/1987 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | James Anderson ENERGY, DEPT. OF |
| References | |
| REF-WM-58 NUDOCS 8708110344 | |
| Download: ML20236N030 (3) | |
Text
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DGIL 6/30 M2 ANDERSON James R. Anderson, Project Manager Uranium Mill Tailings Project Office
{
U.S. Department of Energy l
P.O. Box 5400 Albuquerque, NM 87115
Dear Mr. Anderson:
The NRC staff has reviewed DOE's May 6, 1987, responses to our review comments on the Shiprock, New Mexico Draft Remedial Action Completion Report. Our review of these responses included telephone conversations between appropriate NRC and DOE Remedial Action Contractor technical staff. Based on this review, we have enclosed a discussion of the status of each comment to facilitate the preparation of the Final Completion Report.
Should you have any questions regarding these issues, please contact Dennis Sollenberger of my staff at FTS 427-4789.
l b/
Paul Lohaus, Acting Chief Operations Branch Division of Low-Level Waste Management and Decommissioning
Enclosure:
As stated i
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i DGIL 6/30 M2 ANDERSON / ENCL i l Status of NRC Comments on the Shiprock Draft Remedial Action Completion Report Comment 1:
The DOE response is acceptable; final grade contours based on aerial photogrammetry data are to be provided in the Final Report.
Comment 2:
The DOE response incorrectly stated that the settlement plates had not been installed.
Subsequently, the data from existing settlement plates was j
submitted by letter dated June 2, 1987. A summary of settlement conditions should be included in Appendix H of the Final Report.
Comment 3.
j l
l The DOE response is acceptable.
I Comment 4:
j The DOE response is acceptable.
Comment 5:
The DOE response is acceptable.
Comment 6:
The DOE response is acceptable.
Comment 7:
The DOE response implies that a 25 pCi/g level is acceptable under the EPA standards.
Based on a telephone discussion between D. Sollenberger (NRC) and J. Turner (RAC), the sentence beginning, "Such results are acceptable based upon..."
should be deleted, and discussion on the location and ownership of the elevated grids should be added (pg.2, Appendix J).
Comment 8:
The staff still considers the DOE response ambiguous, and recommends that the applicable sentence of the report (pg. 4, Appendix J) be modified to read, "No QC results exceeded applicable Ra-226 analysis performance criteria guidelines requirements in the above referenced QA7QC documents."
1 l
1 DGIL 6/30 M2 ANDERSON / ENCL l l
i Comment 9:
The DOE response has not adequately identified why a correction factor was not.
applied to the OCS or EDA data.
J. Turner indicated (telephone discussion with D. Sollenberger) that the TAC had taken split samples during an audit, I
and that the resultt of the analyses agreed well.with the RAC data.
He further indicated thot the EDA labs had analyzed the calibration standards used by the RAC and ttat the EDA analyses were in very good agreement with those standards. This would seem to indicate that EDA's sample preparation is the major area introducing bias in the QC sample. analyses.
The staff recommends that discussion of these audit checks should be added to the report 1
as replacement for Table J.4.
The statistic used in the report (average i
of all values for OCS and QC) hides all possible statistical significance.
In 1
order to assess the need for a correction factor, DOE should perform additional j
analyses (e.g., paired sample test) to determine whether there is a statistical difference in the data, or otherwise demonstrate why statistical analyses is inappropriate or unnecessary.
l Additionally, a more generic issue was raised during the telephone discussion; i.e., what action is required when a QC sample value is significantly different from the routine sample analysis (OCS)? Many of the QC values varied by as much as 100% from the corresponding OCS values, and no follow-up reanalysis was performed. The report should include a description of generic QC requirements for comparison of data and reaction to significant variances, and how they were applied at the Shiprock site. Alternatively, discuss other aspects of-the QC program which were used in lieu of specific reaction to variances between the OCS and EDA data.
Comment 10:
The DOE response is acceptable.
Comment 11:
1 The DOE response indicated that a report on the Th-230 residuals at the Shiprock site is being prepared. This report should either be referenced in the Final Report or included as an appendix to the report.
In addition, J.
Turner indicated that the areas with identified elevated Th-230 levels are within the restricted site boundary and as such would not be disturbed during the design _ life of the pile.
This information should be added to the report where appropriate,
,