ML20248C799
| ML20248C799 | |
| Person / Time | |
|---|---|
| Issue date: | 07/12/1989 |
| From: | Randy Hall NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Preusse M TEXAS, STATE OF |
| References | |
| REF-WM-43 NUDOCS 8908100146 | |
| Download: ML20248C799 (3) | |
Text
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URANIUM AEc0VERY FIELD OFFICE '
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,x JUL 121989 URFO:GRK
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040WM043220E' Marilyn T. Preusse, Ph.D.
Bureau of Radiation Control Texas Department of Health 1100 West 49th Street Austin,' Texas.-78756-3189 L
Dear Ms. Preusse:
Our;cffice is in. receipt of your June 28, 1989 letter transmitting the
' decommissioning' plan for the Palengana facility.
The plan discusses aquifer q
restoration, well abandonment, decontamination, soil cleanup, surface
'I reclamation 'and radiation protection.
Each of these areas will be addrc2 sed below.
It is enr experience that restoration of a mined area that utilized an ammonium-basad lixiviant has been a difficult task. ;Due to absorption onto clay minerals'it'is doubtful'that-ground-water sweep will be succsssful in adequately reducing ammonium levels.
Although Chevron considers this restoration technique as an " industry wide accepted pr.ocedure", the ulti,nate
. approval will be from the Texas Water Commission.
We trust in their judgment to' determine when adequate restoration has taken p%ce and the environmental
. impact of the remaining ammonia is acceptable.
The well abandonment procedures for the wellfield, and the dispasal well, appear to be adequate.
It 6,s recommended that all exploration holes and monitoring wells' be similarly abandoned to assure aquifer isolation.
The decontamination procedures should be adequate to determine residual contamination.
TM use of gamma readings is important due to the non penetrating nature of alpha particles.
We recommend that the Health Department require Chevron to specify acceptable release limits for gamma radiation,.in those $nstances where alpha contamination is difficult or impossible to detect.
The soil clean-up procedure is assumed to cover the well fields, irrigation disposal area, trunk line to the disposal well, evaporation ponds as well as road. ways and other land surface areas suspected of haviQ contamination.
Utilization of twice gamma background for an action limit may or may not be appropriate.
As we are sure you are awaPe, the site may only be released based upon' verification of acceptaole radium concentrations in the soil.
It has been our experience that utilizirtg a threshold gamma value for an action levelf is appropriate.
This level is usually set at 5 to 10 micro rem /hr above 8908200146 890712 E *'
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background.
Considering background values may be in the range of 15 to i
30 micro rem /hr, twice background may not be acceptable.
It is recommended that background radium values be adequately determined and that based upon this value, e gamma level be established for soil remediation.
The surface reclamation discussion centers upon seed mixtures, fertilizer i
rates and land shaping techniques that are best addressed by the appropriate State agencies.
Therefore we will not comment on this issue.
It has been our experience that radiation protection during decommissioning is ofte'1 an overlooked issue. Although yellowcake_ drying was never performed at this site there still remains a need to verify particulate concentrations during the work efforts.
It is doubtful that standard operating procedures exist for the work to be performed.
Therefore, we would recommend that all decommissioning work be conducted under the direction of a radiation work permit.
Simply utilizing TLD badges and conducting monthly bioassays may overlook daily intake of radi6nuclides.
As discussea in 10 CFR 20 breathing zone or general area air samples for appropriate radionuclides will need to be utilized, to determine potential exposures.
We are pleased to have the opportunity to comment on the proposed plan.
Should you have any further questions, please contact Gary Konwinski of my staff at (303) 23-6-2805.
Sincerely, l
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amon E. H1.11, Diredtor Uranium Recovery Field Office Case Closed:
040WM043220E l
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