ML20249B144
| ML20249B144 | |
| Person / Time | |
|---|---|
| Issue date: | 06/16/1998 |
| From: | Joseph Holonich NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rael G ENERGY, DEPT. OF |
| References | |
| REF-WM-62 NUDOCS 9806220107 | |
| Download: ML20249B144 (4) | |
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June 16, 1998 Mr. George Rael, Director U.S. Departrnent of Energy Albuquerque Operations Office ERD /UMTRA P.O. Box 5400 Albuquerque, NM 87185-5400
SUBJECT:
ACCEPTANCE OF COMPLETION REPORT FOR RIFLE, COLORADO, VICINITY PROPERTY RF-474
Dear Mr. Rael:
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the Rifle, Colorado, Vicinity Property Completion Report (VP CR) for property RF-474, north of the Old Rifle processing site.
This VP CR, dated May 12,1997, was submitted by the U.S. Department of Energy (DOE) under letter dated October 21,1997. 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.
This VP is north of and across U.S. Highway 6 & 24 from the Old Rifle processing site and includes the area between Ash Avenue and U.S. Highway 6 & 24. The property consists of a sloping field atop a bluff overlooking the Old Rifle processing site.
Appendix B of the VP CR describes the proposed use of supplemental standards for part of the VP. The DOE proposes to leave mill tailings contamination on the steep slope of the bluff, which is on the south side of the VP, on the north side of U.S. Highway 6 & 24. Due to the steepness of the slope, only limited characterization of the remaining contamination was feasible. The extent of contamination was estimated to be approximately 1400 yd8, covering an f
area of about 8100 yd'. Based on the limited characterization, the external exposure rates j
measured ranged from 10 to 30 prem/ hour. Measured concentrations of Ra-226 in soil ranged up to a maximum of 187.2 pCi/g, though more than 95 percent of the results were less than 40 pCi/g. The contamination is at the surface of the soil and the depth of contamination was estimated to be generally 6 inches, with some small areas extending to 42 inches.
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The DOE's justification for the use of supplemental standards to leave the contamination is based on (1) the clear and present risk of injury to workers during remediation of the material,
[dk1 as allowed under 40 CFR 192.21, criterion (a); and (2) the high cost of remediation relative to long-term benefits, as allowed under 40 CFR 192.21, criterion (c). The risk of injury to workers is indicated to be due to the steepness of the bluff and the character of the soil on the bluff, which was stated to be an overburden of fine-grained soils on a thick lens (6-10 feet) of unconsolidated river cobbles.
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PDR WASTE i
G. Rael The potential benefit to complete remediation of the remaining material would be the reduction in potential radiation doses to people occupying or visiting the VP. The VP CR included an evaluation of the radiation doses to people who spend time on this site. If the contaminated material was left on the VP, the worst-case exposures were assumed to be for a person occupying the point of the highest gamma exposure rate. In order for a person to receive a dose of 100 mrem in a year, DOE calculated that the person would have to spend about 3300 hours0.0382 days <br />0.917 hours <br />0.00546 weeks <br />0.00126 months <br /> in a year at that point. The VP CR conclud:d that it is highly unlikely for an individual to be exposed for the amount of time required to receive a dose of 100 mrem in a year, due to the remote location of the remaining contaminated material and the steepness of the slope, which inhibits access to the material. From the VP CR, it appears that the additional cost to remediate the remaining contamination would be about $110,000.
The NRC staff agrees that if the contaminated material on the steep slopes was remediated, there would be a risk of injury, to workers, that could not be completaly avoided. Because of the relative inaccessibility of the remaining contaminated material, tne NRC staff agrees that it would be very unlikely for a person to spend enough time near the contaminated material to receive a dose that is a significant fraction of 100 mrem per year. The NRC staff agrees that the costs of additional cleanup appear unreasonably high relative to the expected long-term benefits of such cleandp. Thus, the staff concludes that information provided by the DOE in the VP CR provides reasonable assurance that supplemental standards for soil cleanup have been properly applied at vicinity property RF-474. Therefore, the NRC staff concurs that the use of supplemental standards and the remediation of this vicinity property were completed in accordance with the EPA standards. The signed NRC Review Form for Supplemental Certification of Vicinity Properties, showing NRC concurrence, is enclosed.
If you have any questions concerning this letter or the enclosure, please contact the NRC Project Manager, Janet Lambert, at (301) 415-6710.
Sincerely, m)" dh Y Joseph J. Holonich, Chief Uranium Recovery Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated cc:
F. Bosiljevac, DOE Alb E. Artiglia, TAC Alb
, G. Rwl June 16,1998 The potential benefit to complete remediation of the remaining material would be the reduction
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in potential radiation doses to people occupying or visiting the VP. The VP CR included an j
evaluation of the radiation doses to people who spend time on this site. If the contaminated material was left on the VP, the worst-case exposures were assumed to be for a person occupying the point of the highest gamma exposure rate. In order for a person to receive a dose of 100 mrem in a year, DOE calculated that the person would have to spend about 3300 hours0.0382 days <br />0.917 hours <br />0.00546 weeks <br />0.00126 months <br /> in a year at that point. The VP CR concluded that it is highly unlikely for an individual to be exposed for the amount of time required to receive a dose of 100 mrem in a year, due to the i
remote location of the remaining contaminated material and the steepness of the slope, which i
inhibits access to the material. From the VP CR, it appears that the additional cost to remediate the remaining contamination would be about $110,000.
The NRC staff agrees that if the contaminated material on the steep slopes was remediated, there would be a risk of injury, to workers, that could not be completely avoided. Because of the relative inaccessibility of the remaining contaminated material, the NRC staff agrees that it would be very unlikely for a person to spend enough time near the contaminated material to receive a dose that is a significant fraction of 100 mrem per year. The NRC staff agrees that the costs of additional cleanup appear unreasonably high relative to the expected long-term benefits of such cleanup. Thus, the staff concludes that information provided by the DOE in the VP CR provides reasonable assurance that supplemental standards for soil cleanup have been properly applied at vicinity property RF-474. Therefore, the NRC staff concurs that the use of supplemental standards and the remediation of this vicinity property were completed in accordance with the EPA standards. The signed NRC Review Form for Supplemental Certification of Vicinity Properties, showing NRC concurrence, is enclosed.
If you have any questions concerning this letter or the enclosure, please contact the NRC Project Manager, Janet Lambert, at (301) 415-6710.
Sincerely,
[0riginal signed by]
Joseph J. Holonich, Chief Uranium Recovery Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated cc:
F. Bosiljevac, DOE Alb E. Artiglia, TAC Alb DISTRIBUTION w/ Encl.:
File Center NMSS r/f URB r/f PUBLIC
.ACNW CNWRA JLambert BSpitzberg/RIV w/o Encl.: MFederline MLayton CAbrams DOCUMENT NAME: S:\\DWM\\ URB \\DWS\\RF-474.COV OFC URB E
URBrs, k 6 URk 9
Jhnich NAME DSchmidb DGill DATE 06/is/98 06/p /98 N
06/\\h98 OFFICIAL RECORD COPY
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l VP No.: RF-474 l
l NRC Review Form for Supplemental Certification of Vicinity Properties The Department of Energy (DOE) has determined that the remedial action at the following vicinity property (VP) has been completed and thereby complies with supplemental standards invoked by DOE under 40 CFR, Subpart C, specifically Subsections 192.21 and 192.22.
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NRC concurrence for the Radiological Engineering Assessment (REA) was given on:
[X)
Supplemental standards were not in the REA, special circumstances required that supplemental standards be invoked during remedial action.
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' Frank D. Bosiljevac, DOE C ication Officer
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D' ate
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Based on the information and certification provided by the DOE, the NRC:
DQ Concurs that the remedial action at the subject VP has been competed under its authority provided by the Uranium Mill Tailings Radiation Control Act (UMTRCA),
Section 104 (f)(1) and as described in the Memorandum of Understanding (MOU), Appendix A, Section 3.4.
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Concurs, as above, except for the following conditions:
1.
2.
3.
[ ] See attached sheets for any additional provisions.
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Needs additionalinformation to make a concurrence decision. This information consists of:
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See attached sheets f any additional informational needs.
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i NRC Con' curring Official and Title Date Joseph J. Holonich, Chief Uranium Pecovery Branch i
Division of Waste Management 1
Office of Nuclear Material Safety and Safeauards-