ML20248L190
| ML20248L190 | |
| Person / Time | |
|---|---|
| Issue date: | 03/06/1998 |
| From: | Joseph Holonich NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rael G ENERGY, DEPT. OF |
| References | |
| REF-WM-62 NUDOCS 9803190075 | |
| Download: ML20248L190 (5) | |
Text
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. George Rael, Director March 6' 1998 U.S. Department of Energy.
- . c
'* t Albuquerque Operations Omce ERD /UMTRA i 4
- P.O. Box 5400
- Albuquerque, NM. 87185-5400
SUBJECT:
. REVIEW OF COMPLETION REPORT FOR RIFLE, COLORADO, VICINITY PROPERTY RF-480
Dear Mr. Rael:
The U.S. Nuclear Regulatory Commission staff has reviewed the Rifle, Colorado, Vicinity Property Completion Report (VP CR) for property RF-480, a railroad right-of-way south of Highway 6 West. This VP CR, dated May 28,1997, was submitted by the U.S. Department of Energy (DOE) under letter dated September 11,1997. 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. The staff's review comments on the VP CR are presented in the enclosure.
. The NRC staff concludes that additional information is required to determine whether compliance with the U.S. Environmental Protection Agency cleanup standards has been achieved. Of particular importance, the text and/or drawings of the VP CR must be revised to clarify the location and extent of contamination remaining at the VP. Also, additional justification for the applicability of criterion (a) of 40 CFR 192.21 for the use of supplemental standards must be provided, unless this criterion is eliminated as a reason for using i
supplemental standards. These and other issues of concem related to the use of supplemental -
standards are more fully described in the enclosure.
If you have any questions conceming this letter or the enclosure, please contact the NRC I
- Project Manager, Janet Lambert, at (301) 415-6710.
Sincerely,
",$. Hol nN, bief' If J
Uranium Recovery Branch T
l Division of Waste Management
.j Office of Nuclear Material Safety yL L
and Safeguards I
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- ,o March 6, 1998 George Rael, Director U.S. Department of Energy Albuquerque Operations Office ERD /UMTRA P.O. Box 5400 Albuquerque, NM 87185-5400
SUBJECT:
REVIEW OF COMPLETION REPORT FOR RIFLE, COLORADO, VICINITY PROPERTY RF-480
Dear Mr. Rael:
The U.S. Nuclear Regulatory Commission staff has reviewed the Rifle, Colorado, Vicinity Property Completion Report (VP CR) for property RF-480, a railroad right-of-way south of H;ghway 6 West. - This VP CR, dated May 28,1997, was submitted by the U.S. Department of Energy (DOE) under letter dated September 11,1997. 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. The staff's review comments on the VP CR are presented in the enclosure.
The NRC staff concludes that additional information is required to determine whether compliance with the U.S. Environmental Protection Agency cleanup standards has been achieved. Of particular importance, the text and/or drawings of the VP CR must be revised to clarify the location and extent of contamination remaining at the VP. Also, additional justification for the applicability of cderion (a) of 40 CFR 192.21 for the use of supplemental standards must be provided, unless this criterion is eliminated as a reason for using supplemental standards. These and other issues of concem related to the use of supplemental standards are more fully described in the enclosure.
l If you have any questions conceming this letter or the enclosure, please contact the NRC Project Manager, Janet Lambert, at (301) 415-6710.
Sincerely, i
l M
A Joseph J. Holonich, Chief Uranium Recovery Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated j
cc:
F. Bosiljevac, DOE Alb E. Artiglia, TAC Alb i
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U.S. NUCLEAR REGULATORY COMMISSION STAFF REVIEW OF l
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COMPLETION REPORT FOR RIFLE VICINITY PROPERTY RF 480 NRC staff reviewed the Vicinity Property Completion Report (VP CR) (MK F 1997) submitted to the NRC. This VP CR describes the remedial actions (radiological cleanup) and verification activities performed at the Rifle vicinity property (VP) RF-480. This VP is the railroad right-of-
_ way along the south side of the Old Rifle processing site. The VP is between the Old Rifle site and the Colorado River.
Contamination at the VP extended under the ballast of the railroad tracks. This material and other contaminated material were left in place, with supplemental standards used as
_ justification. Appendix B of the VP CR describes the application of supplemental standards, under 40 CFR 192.21 and 40 CFR 192.22, to contamination remaining under and next to the railroad tracks, around the buried fiber optic cable, and around the bases of 11 utility poles.
Section B.1 of the appendix indicates that the applicable criteria for applying supplemental standards to these areas are (quoted from 40 CFR 192.21, not from the VP CR):
(a) Remedial actions required to satisfy Subparts A or B would pose a clear and present risk of injury to workers or to members of the public, notwithstanding reasonable measures to avoid or reduce risk.
(c) The estimated cost of remedial action to satisfy $ ig2.12(a) at a " vicinity" site (described under Sec.101(6)(B) of the Act) is unreasonably high relative to long-term benefits, and the residual radioactive materials do not pose a clear present or future hazard. The likelihood that buildings will be erected or that people will spend long j
periods of time at such a vicinity site should be considered in evaluating this hazard....
Because the reason for the NRC's review of this VP CR is that supplemental standards were used at the VP, the NRC staff review has been limited to areas related to the uce of supplemental standards for the VP.
COMMENT 1, DESCRIPTION OF REMAINING CONTAMINATED MATERIAL l
There are' discrepancies between the text and drawings of the VP CR regarding the location of i
and extent of contamination remaining on the VP.
l Comment 1 Discussion l
Section 2.4 of the VP CR (page 5) describes residual radioactive material left in place with the use of supplemental standards. No remediation was performed within 15 feet of the centerline of the main railroad tracks and railroad track and ties were not replaced. Thus, residual radioactive material remains in this area. Prior to remedial action, a fiber optic telecommunications line was buried within the railroad right-of-way north of the tracks. Residual material was lei in critical areas around the fiber optic cable. Residual material was also left i
around the bases of 11 utility poles which support railroad operations.
j However, the drawings in the VP CR which show the limits of remaining contamination seem to differ with the narrative description, given above. A number of drawings show the areas where i
contamination remains, with drawings RF-480-030 and RF-480-031 providing the most detail.
NRC Review of VP CR for RF.480 1
March 1998 Enclosure
_e
' On these drawings, the utility poles around which contamination remains are shown clearly.
f
~ However, the location of contamination around the fiber optic cable is not shown and the fiber optic cable is not shown. Also, the contamination is shown on these drawings to extend significantly farther than 15 feet from the track centerline. Thus there appears to be a discrepancy between the description of the extent of contamination given in the text, versus that given in the drawings.
Recommendation 1-The DOE must revise the text and/or drawings to clarify the location of the fiber optic cable and contamination remaining around it, and to clarify the extent of contamination under and next to the railroad tracks.
i COMMENT 2, APPLICABILITY OF CRITERlON (a) OF 40 CFR 192.21
)
Appendix B to the VP CR does not provide justification for the applicability of criterion (a) of 40 CFR 192.21 for using a supplemental standard.
Comment 2 Discussion Criterion (a) of 40 CFR 192.21 allows a supplemental standard to be used when remedial action would result in a clear and present risk of injury, notwithstanding reasonable measures to avoid or reduce that risk. It appears that the only discussion of risks of injury occurs in Section B.4.1.1 of Appendix B to the VP CR. In this section it is stated that for completa remediation it would be necessary to shut down the railroad to reduce the risk of worker injuries and the risk.
of train derailment. That action seems reasonable to mitigate risks of injury. The same section also indicates that damage to the stability of the railroad tracks in the area could further endanger railroad employees and passengers. However, no additional support is provided for this statement. It appears to the NRC staff that reasonable precautions during excavation and restoration would ensure the stability of the railroad tracks, so there should not be any additional risks to railroad employees and passengers.
I Based on the very limited information discussing risks of injury to workers and the public, the NRC staff concludes that there is insufficient justification for the applicability of criterion (a) for l
the use of supplemental standards.
Recommendation 2 DOE should determine which criteria of 40 CFR 192.21 apply to the contamination remaining on the VP, and must provide sufficient justification for those criteria that do apply. DOE may wish to reconsider the applicability of criterion (a) of f 192.21. That is, justification for this i
criterion may not be feasible or appropriate; if not, this criterion could be eliminated from l
consideration, l
l' COMMENT 3, JUSTIFICATION FOR APPLICABILITY OF CRITERlON (c) OF 40 CFR 192.21 l:
Appendix B to the VP CR does not provide a discussion and conclusion to support the use of l
criterion (c) of 40 CFR 192.21 as justification for using a supplemental standard.
Comment 3 Discussion i
Appendix B of the VP CR (page B-7) summarizes the dose assessments performed for the contaminated material to remain in place. These assessments indicate that it is unlikely that j
NRC Review of VP CR for RF-480 2
March 1998 J
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-. members of the public, including railroad workers, would receive doses greater than 100
- mrem / year from routine exposures or doses greater than 500 mrem / year from nonroutine exposures (for a single year). Appendix B also shows that the cost of complete remediation of '
the contamination would be very high. From the information presented, it appears that complete l
remediation would be unreasonably costly compared to the limited benefit. Thus, it appears that
~
criterion (c) is applicable. However, the text of Appendix B does not appear to include a conclusion about the reasonableness of the cost of complete remediation versus the benefits.
L Recommendation 3 L
The DOE should add discussion to Appendix B of the VP CR to make conclusions, as L
appropriate, about the cost of complete remediation versus the benefits.
1 COMMENT 4, TYPOGRAPHIC,' ERROR There is a typographical error in Table 3.2 of the VP CR. The heading "UREM/HR" should be "prem/hr." The DOE may wish to make this correction.
-REFERENCES MK-F (MK-Ferguson Company and Rust Federal Services, Inc.).1997. Vicinity Property Completion Report at RF-480, Railroad Right-of-Way South of the Old Rifle Site, Rifle, CO.
May 28,1997.
l 1
l l
l.
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s NRC Review of VP CR for RF 480 3
March 1998
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