ML20134F757

Submits Response to Re Radiological Status of Bedrock at Tuxedo,Ny Facility

ML20134F757
Person / Time
Site:	05000054, 07000687
Issue date:	10/29/1996
From:	Weber M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Mcgovern J CINTICHEM, INC.
Shared Package
ML20134F760	List: ML20134F757 ML20134F761
References
NUDOCS 9611080007
Download: ML20134F757 (3)

Text

_. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ - _ - - - _ - _ _ _ _ _ _

l' 30-(pW7

, 'm

. SW y UNITED STATES l

3 j

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20666 4001 i

j i

\...../ October 29, 1996

. Mr. James J. McGovern President / Plant Manager

Cintiches, Inc.

I P.O. Box 816 I

Tuxedo, New York 10987

Dear Mr. McGovern:

? This is in response to Jay Adler's letter to Thomas Dragoun, dated i- July 3,1996, in which Cintichem summarized the radiological status of bedrock i at its Tuxedo, New York, facility, and proposed that the radiological status of the groundwater at one point at the site be determined using the results

from the analysis of groundwater collected from the deeper of two wells i located near the foundation of the hot lab building. The results from the deeper well, MW-2D, indicate that the groundwater meets ghe Environmental

!' Protection Agency's (EPA's) drinking water standard for Sr in 40 CFR 141.16, while the results from the shallower of the two wells, MW-2S, indicage that the groundwater in this well exceeds the EPA's current standard for Sr.

Cintichem used the limited flow from the shallower well as the rationale for excluding it from consideration as an appropriate location for evaluating the q radiological status of the groundwater at the site.

NRC staff h'as reviewed Mr. Adler's letter and has concluded that the

assessment of the radiological status of the bedrock is acceptable as l submitted. However, the NRC staff does not agree with your rationale for excluding MW-2S as an appropriate location from which to determine the

radiological status of the groundwater at the site. Based on NRC staff j discussions with staff of the EPA's Region II office, the Cintichem facility

is located in the Ramapo River Basin Sole Source Aquifer (see enclosed letter 4 from Paul A. Giardina to Dominick A. Orlando, dated September 25,1996). EPA

) considers all groundwater in a Sole Source Aquifer, and therefore all

groundwater at the Cintichem facility, as .a potential source of drinking water. .The New York State Department of Environmental Conservation (NYSDEC)

also considers all groundwater at the Cintichem site a potential source of drinking water. Therefore, unless Cintichem can demonstrate to the NRC staff that both EPA and NYSDEC have concluded that MW-2S is not an appropriate -

sampling location for the Sole Source Aquifer, the NRC staff would consider both MW-2S and MW-20 as appropriate sampling locations for evaluating the status of groundwater at the facility.

Mr. Adler's letter also stated that "Sr concentrations in groundwater obtained from MW-2S during the past year (June 1995 to June 1996) have ranged from 10 picocuries per liter (pCi/1) to 79 pCi/1, witg a mean of 38 pCi/1.

The EPA drinking water standard in 40 CFR 141.16 for Sr is 8 pCi/1. A concentration limit of 8 pCi/1 for "Sr was included in Cintichem's proposed residual radioactive material limits that were submitted to NRC staff in July 1992, and approved by NRC staff in August 1993. In mid-1991, EPA published proposed drinking water standards for radionuclides. These proposed Q-dr. inking water standards, although keeping the same dose basis as the current standard (4 mrem /yr), were converted to effective dose equivalents. This is 961108000T 961029 tr

=

"W NRC FILE CENTER COPY}I

% Lu & M ,

J. McGovern consistent with NRC's dose calculation methodology and changes the drinking water standard for "Sr from 8 pCi/l to 42 pCi/1. Recently,fheNRCstaffhas used EPA's proposed drinking water standard of 42 pCi/1 for Sr in determining whether sites are suitable for unrestricted use. Requiring Cintiches to meet this standard also satisfies the requirements outlined in NYSDEC's Technical Administrative Guidance Memorandum entitled " Cleanup Guideline for Soils Contaminated with Radioactive Materials," September 1993, provided the total effective dose equivalent due to all residual radioactive material will not exceed 10 millirem per year (above background). In their recent letter to NRC staff, EPA Region II also indicated that potential doses to the public from groundwater at the site should be evaluated against a total effective dose equivalent of 4 mrem / year. However, please note that EPA has specified that the groundwater sample used to determine the concentration of radioactivematerialshouldnotbefilteregpriortoanalysis. Therefore, the NRC staff has concluded that 42 pCi/l for Sr, as determined using an unfiltered groundwater sample, is the applicable standard for groundwater at the Cintichem site and will be used by the NRC staff in determining whether the residual radioactive material at Cintichem's Tuxedo, New York, facility meets NRC's criteria for unrestricted use and termination of the NRC license.

If you have any questions concerning the staff's review of Mr. Adler's letter, please contact Nick Orlando at (301) 415-6749. Development of this letter has been coordinated with the staff of NYSDEC.

Sincerely, d N Michael F. Weber, Chief Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards License Nos. SNM-639 R-81 Docket Nos.70-687 50-54

Enclosure:

As stated cc: Cintichem dist. list l ~19

=*sa 9 y ;7., , . , , ,

c. },-' pg

j J. McG vern' ,

j consistent ~with NRC's dose calculation methodology and changes the drinkirg

< water standard for "Sr from 8 pCi/1 to. 42 pCi/1, Recently,jheNRCstaffhas used EPA's propored drinking water standard of 42 pCi/1 for Sr in

determining whether sites ~are suitable for unrestricted use. Requiring 1 Cintiches to meet this standard also satisfies the requirements outlined in i NYSDEC's Technical Administrative Guidance Memorandum entitled " Cleanup Guideline for Soils Contaminated with Radioactive Materials," September 1993,

, provided the total effective dose equivalent due to all residual radioactive i material will not exceed '10 millirem per year (above background). In their

recent letter to NRC staff, EPA Region II also indicated that potential doses 1 -to the public from groundwater at the site should be evaluated against a total effective dose equivalent of 4 mrem / year. However, please note that EPA has specified that the groundwater sample used to determine the concentration of

radioactive. material should not be filtereg prior to analysis. Therefore, the

NRC staff has concluded that 42 pCi/1 for Sr, as determined using an unfiltered groundwater sample, is the applicable standard for groundwater at

the Cintichem site and will be used by the NRC staff in determining whether the residual radioactive material at Cintichem's Tuxedo, New York, facility t' meets NRC's criteria for unrestricted use and termination of the NRC license.

i

. If you have any questions concerning the staff's review of Mr. Adler's letter, i please contact Nick Orlando at (301) 415-6749. Development of this letter has been coordinated with the staff of NYSDEC.  ;

l Sincerely, ,

i [0RIGINAL SIGNED BY:]

! Michael F. Weber, Chief i

} Low-Level Waste and Decommissioning

Projects Branch .

! Division of Waste Management i Office of Nuclear Material Safety i and Safeguards

License Nos. SNM-639  ;

} R-81 <

i Docket Nos.70-687 l 50-54 ,

.g

Attachment:

As stated cc: Cintichem dist list

. DISTRIBUTION: Central File LLDP r/f JRGhapf NMSS r/f PUBLIC

JDavis TDragoun/RI SWeiss MBell JAustin Anat y. ,

l- JustaubWF LBell TCJohnson JGreeves M F,MA  !

l . Ta receive a copy of this document in smett ben en moFC:* tine enter: "C" = copy without attachment /encteeure; "E" = Copy with

attachment /enctenure; 'u= = un copy  ;

• See previous concurrence Path & File Name:s:\dwm\lldp\dao\cntiho ,

[ 0FC LLDP* LLDP* OGC* LLDP* NRR* LLDP l NAME- N0rlando/bg ' JCopel an'd RFonner RNelson TMichaels kMWeber [

l i DATE 10/10/96 10/8/96 10/17/96 10/8/96 10/28/96 10/D/96

] 0FFLCIAL RECORD COPY  !

I ACNW: YES NO V Category: Proprietary or CF Only IG : YES NO /

LSS : YES 'N0 / Delete file after distribution: Yes / No I

( g a-p) i i