ML14345A756

Memo to L.Camper, Military Prioritization

ML14345A756
Person / Time
Issue date:	01/13/2015
From:	Richard Chang NRC/NMSS/DDUWP/MDB
To:	Camper L, Norato M Division of Decommissioning, Uranium Recovery and Waste Programs, NRC/NMSS/DDUWP/MDB
References
Download: ML14345A756 (3)

Text

January 13, 2015 MEMORANDUM TO: Larry W. Camper, Director Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards THRU: Michael Norato, Chief /RA/

Materials Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards FROM: Richard Chang, Project Manager /RA/

Materials Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards

SUBJECT:

PRIORITIZATION METHODOLOGY FOR ADDRESSING MILITARY RADIUM SITES As part of the ongoing work related to radium-contaminated sites, the U.S. Nuclear Regulatory Commission (NRC) staff has recommended that the Commission approve a memorandum of understanding (MOU) approach for its involvement at unlicensed military sites being remediated using the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) process. This is described in SECY-14-0082.

This MOU approach has been approved by the Commission, and the NRC staff is working with the U.S. Department of Defense (DoD) to complete the MOU and begin its implementation. To accomplish this, the DoD would provide NRC staff with an annual inventory of sites with confirmed Atomic Energy Act of 1954 radioactive contamination which are being remediated by DoD using the CERCLA process.

Under the MOU, NRC plans on conducting its involvement with DoD remediation using a graded approach that defines the type and amount of NRC involvement based on the priority of the site (determined by the enclosed methodology).

CONTACT: Richard Chang, NMSS/MDB (301) 415-5563

2 Each site will be prioritized and scored using the site-specific information in the DoDs annual site inventory. Each DoD installation, or base, is typically subdivided into a number of sites to manage the remediation process. DoDs site inventory is expected to be organized around the sites within each base. Therefore, NRCs prioritization methodology will prioritize each individual site on a base, and in turn, the entire base.

The first step in the prioritization methodology is to divide the sites into two groups. At sites already under U.S. Environmental Protection Agency (EPA) oversight, NRC staff would rely on EPAs oversight and follow a limited involvement approach to stay informed of site activities (defined in SECY-08-0077). At sites not under EPA oversight, NRC staff would perform monitoring activities, such as reviewing and providing comments on the DoDs remediation plans associated with the CERCLA process.

The second step is to further prioritize the sites for monitoring. The purpose of NRC monitoring is to confirm that DoDs remediation of radioactive material using the CERCLA process would result in an outcome that meets NRC dose requirements and is protective of public health and safety and the environment.

Prioritization of sites would provide the type and amount of monitoring activities to confirm that the DoDs CERCLA cleanups would be protective and meet NRCs 25 millirem per year dose criteria described in SECY-14-0082, Enclosure 6. The enclosed methodology also uses a scoring system to prioritize each site.

As monitoring activities are underway, if NRC staff notes major concerns through monitoring activities at specific sites, the monitoring could be expanded to include the entire base. This expansion of monitoring activities is feasible because it is expected that DoD would use the same cleanup contractors and management teams across an entire base.

The staff expects that DoDs remediation of bases would range from simple to complex. A simple base might only have a few sites with surface soil contamination. In contrast, large bases such as Hunters Point Naval Shipyard or McClellan Air Force Base can be complex with many sites that need remediation over many years. These bases can also have some sites with combinations of surface soil contamination, contaminated buildings, landfills with buried contamination or even contaminated sediment in water bodies. The prioritization methodology gives the priority for each individual site on a base, but the summation of the scores for all sites on a base would also give the priority of the entire base.

NRC staff had initially considered the option for the prioritization of its monitoring by focusing on all aspects of a limited number of high priority DoD bases. However, the staff opted for an approach that would allow the NRC to perform monitoring activities at high priority sites at a larger number of bases.

Any comments or suggestions to this proposed methodology would be appreciated.

Enclosures:

(1) Military Radium Site Prioritization (2) Figure 1: Military Radium Site Prioritization Diagram

2 Each site will be prioritized and scored using the site-specific information in the DoDs annual site inventory. Each DoD installation, or base, is typically subdivided into a number of sites to manage the remediation process. DoDs site inventory is expected to be organized around the sites within each base.

Therefore, NRCs prioritization methodology will prioritize each individual site on a base, and in turn, the entire base.

The first step in the prioritization methodology is to divide the sites into two groups. At sites already under U.S. Environmental Protection Agency (EPA) oversight, NRC staff would rely on EPAs oversight and follow a limited involvement approach to stay informed of site activities (defined in SECY-08-0077). At sites not under EPA oversight, NRC staff would perform monitoring activities, such as reviewing and providing comments on the DoDs remediation plans associated with the CERCLA process.

The second step is to further prioritize the sites for monitoring. The purpose of NRC monitoring is to confirm that DoDs remediation of radioactive material using the CERCLA process would result in an outcome that meets NRC dose requirements and is protective of public health and safety and the environment.

Prioritization of sites would provide the type and amount of monitoring activities to confirm that the DoDs CERCLA cleanups would be protective and meet NRCs 25 millirem per year dose criteria described in SECY-14-0082, Enclosure 6. The enclosed methodology also uses a scoring system to prioritize each site.

As monitoring activities are underway, if NRC staff notes major concerns through monitoring activities at specific sites, the monitoring could be expanded to include the entire base. This expansion of monitoring activities is feasible because it is expected that DoD would use the same cleanup contractors and management teams across an entire base.

The staff expects that DoDs remediation of bases would range from simple to complex. A simple base might only have a few sites with surface soil contamination. In contrast, large bases such as Hunters Point Naval Shipyard or McClellan Air Force Base can be complex with many sites that need remediation over many years. These bases can also have some sites with combinations of surface soil contamination, contaminated buildings, landfills with buried contamination or even contaminated sediment in water bodies. The prioritization methodology gives the priority for each individual site on a base, but the summation of the scores for all sites on a base would also give the priority of the entire base.

NRC staff had initially considered the option for the prioritization of its monitoring by focusing on all aspects of a limited number of high priority DoD bases. However, the staff opted for an approach that would allow the NRC to perform monitoring activities at high priority sites at a larger number of bases.

Any comments or suggestions to this proposed methodology would be appreciated.

Enclosures:

(1) Military Radium Site Prioritization (2) Figure 1: Military Radium Site Prioritization Diagram ML14345A739 OFFICE NMSS NMSS NMSS NMSS NMSS NAME RChang SAchten MNorato DPersinko RChang DATE 12/ 15 /14 12/ 15 /14 1/12/15 1/12/15 1/13/15 OFFICIAL RECORD COPY