Text

Responds to 980413 Ltr & Encl Radiological Risk Assessment Performed in Oct 1997 on Property Located in Burbank,Ca. Based on Review,Nrc Believes Comments of G Wong Accurately Characterized Actions & Steps Taken W/Respect to Facility
	ML20236W466
Person / Time
Issue date:	07/23/1998
From:	Bangart R; NRC OFFICE OF STATE PROGRAMS (OSP)
To:	Sharp M; AFFILIATION NOT ASSIGNED
Shared Package
ML20236W468	List: ML20236W466;
References
	SP-97-080, SP-97-80, NUDOCS 9808050300
	Download: ML20236W466 (12)
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UNITED STATES 9 NUCLEAR REGULATORY COMMISSION f WASHINGTON, D.C. 20666-0001 Jaly 23, 1998 Ms. Martha Sharp Loeb & Loeb LLP Attorneys At Law 1000 Wilshire Boulevard Suite 1800 Los Angeles, CA 90017-2475

Dear Ms. Sharp:

This is in response to your letter of April 13,1998, and the enclosed radiological risk assessment performed in October,1997, on the property located at 170 West Providencia Street in Burbank, California. We have conducted a limited review of the radiological risk assessment, and also have considered the comments detailed in an April 20,1998 letter to you from Mr. Gerard Wong,Ph.D, Chief of the Radioactive Materials Licensing Section of the Radiologic Health Branch, California Department of Health Services.

Based on our review, we believe the comments of Dr. Wong accurately characterized the actions and steps which need to be taken with respect to this facility to determine that the property can be released for unrestricted use. As noted in the Nuclear Regulatory Commission (NRC) inspection report summary, the inspector conducted only an independent radiological survey which established the need for further radiological characterization and evaluation. The inspection survey did not fully characterize the radiological contamination at the site, and was ,

not intended to be used as the basis for a complete assessment. For example, while the repo;;

noted that no loose alpha or beta radioactivity above the then current NRC release criteria was identified during the survey, issues such as leaching or mechanical resuspension were not addressed, and pathways such as inhalation or ingestion not considered.

While we note that the State of California does not agree with NRC's position that Agreement States have regulatory authorny for sites with Atomic Energy Commission licenses that were terminated before a State signed an Agreement with AEC/NRC (see enclosed All Agreement States Letter SP-97-080), the State's position would not preclude completion of actual characterization and initiation of remediation efforts at the 170 West Providencia Street property. We will attempt to coordinate with the State to assist you with the development of a remediation plan in the interim while we and California attempt to resolve our jurisdictional issues. NRC and the State of California have exchanged correspondence regarding this position (see enclosed January 20,1998 letter from G. Kimberly Belsh6 to Chairman Jackson and March 20,1998 letter from Richard L. Bangart to S. Kimberly Belshs). As you can see from this correspondence, NRC is committed to a resolution of this issue and will continue to

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I ~. - Martha Sharp 2 work cooperatively with counterparts in the California Radiological Health Branch to address i

regulatory issues associated with the property at 170 West Providencia Street, Burbank, California.

I if you have any questions, please contact me at (301) 415-3340 or Mr. Richard Blanton of my staff at (301) 415-2322, or by e-mail: RLB@ NRC. GOV.

Sincerely, C /Ut l{ .

$s t fit ichard L. Bangart, Director Office of State Programs ,

l cc: D. E. Bunn, CA

Enclosures:

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I ~~- "JUL 2 31998 l- Martha Sharp 2 work cooperatively with counterparts in the California Radiological Health Branch to address regulatory issues associated with the property at 170 West Providencia Street, Burbank, California.

If you have any questions, please contact me at (301) 415-3340 or Mr. Richard Blanton of my staff at (301) 415-2322, or by e-mail: RLB @ NRC. GOV.

l Sincerely, j On+r' et-v! 07 pg.y 73 ( - q l

Richard L. Bangan, Director Offee of State Programs I

cc: D.E. Bunn,CA

Enclosures:

As stated Distribution:

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i# November 14, 1997 ALL AGREEMENT STATES . * .

OHIO, OKLAHOMA, PENNSYLVANIA TRANSMITTAL OF STATE AGREEMENTS PROGRAM INFORMATION (SP-97-080)

Your attention is invited to the enclosed correspondence which contains:

! ' INCIDENT AND EVENT INFORMATION........... -

PROGRAM MANAGEMENT INFORMATION....XX FORMERLY LICENSED SITES AND JURISDICTION FOR !

REMAINING RESIDUAL

, MATERIALS l

TRAINING COURSE INFORMATION................

TECHNICAL INFORMATION.............................

OTHER INFORMATION.................................... 4 l

Supplementary Information: The Nuclear Regulatory Commission (NRC) has been reviewing previously terminated licenses to determine whether there was appivpf.ste documentation that the sites were adequately decontaminated prior to termination of the license and release of the site. This project was initiated in 1977 for licenses terminated prior to 1965. Another effort was initiated in 198g for licenses terminated after 1965, which was subsequently expanded to include all terminated licenses. A number of sites have been identWied for which there is l insufficient documentation to ensure that the site was adequately decommissioned or to account for all sealed sources. NRC regional of5ces are currently working to close these i

l records through additional file searches and, when necessary, site surveys. NRC guidance '

l for conducting these follow-up inspections is documented in Temporary instruction 2800/026 l (Tl 2800/026), and copies were provided to the Agreement States.

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! Radioactive material remaining at a site located withir$ an Agreement State, including material originally licensed by NRC or its predecessors, is the regulatory responsibility of the Agreement

State. Therefore, an Agreement State is responsible for conducting detailed license and l l inspection file reviews, and investigation and remediation of any site, as appropriate, identified l through NRC review of previously terminated licenses for which there is insufficient j documentation to ensure that the site was property decommissioned or which has inadequate l accounting of sealed sources. A number of cases have already been referred to Agreement i t

States for follow up. Additional cases may be referred in the next few months as our contractor completes its review'of old flies.

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After review of the files, some cases reiquire on-site inspections to determine whether excessive contaminatum may be present. Up to now, NRC has conducted numerous inspections in Agreement States where the States have indicated resource constraints or have indicated that

they do not b6lieve they have regulatory jurisdiction. However, in light of our own resource .

constraints and our position that Agreement States have jurisdiction over these sites, NRC is phasing out detailed reviews of license files and follow-up inspections. Sites that appee.r to require further investigations or inspections to property assess the sites will be referred to the .

appivpiiste Agreement States for follow up. The States will continue to be responsible for regulation of any needed remediation of any contaminated sites under their jurisdiction. To maintain a complete database on the status of terminated license sites, Agreement States are requested to report resolution of each case to NRC for tracking. To minimize the reporting -

burden on the States, the resolution reports may be in the form of short summaries or copies of pertinent correspondence. These resolution reports should be sent to your respective NRC Regional decommissioning contacts (see Enclosure 1).

Agreement State activities to review and reso e issues associated with terminated licenses referred to them will be examined during Agreement State program reviews conducted using the Integrated Materials Performance Evaluation Program. However, State actions on referred cases will not affect findings of adequacy under the IMPEP unless there appears to be a significant threat to public health and safety resulting from a lack of appropriate State action.

l In an effort to reduce the resource impacts on Agreement States, the Commission has directed the staff to work with the Agreement States to identify mutually acceptable mechanisms, such as 'a general fund appropriation outside the fee base," for providing Federal assistance to affected Agreement States. To identify the magnitude of an appropriation estimate, we are requesting any available information that you might have on how your State is or may be affected, such as the number of sites in your State that may need remediation, the typical regulatory efforts needed to ensure appropriate remediation and their costs, the associated costs of remediation, and any difficulties experienced by the Agreement States in attempting to require further remediation of these sites. For Agreement States that are beginning this activity, please provide general estimates, and the basis for those estimates, for the information needs listed above. Any information available would be most usefulif provided by December 10,1997.

This information request has been approved by OMB, NO. 3150-002g, expiration April 30,1998. Estimated burden per response to comply with this voluntary collection request: 1 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months ,0 minutes. Forward comments regarding burden estimate to the information and Records Management Branch (T-6 F33), U.S. Nuclear Regulatory Commission, Washington, .

DC 20555-0001, and to the Paperwork Reduction Project (3150-0052), Office of Management and Budget, Washington, DC 20503. NRC may not conduct or sponsor, and a person is not

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required to respond to, a collection of information unless it displays a currently valid OMB control number.

if you have any questions about this correspondence, please contact me 'or the individual l named below. .

A CONTACT: Dennis M. Sollenberger TELEPHONE: (301)415 2819 ro FAX:

(301) 415-3502

.lNTERNET: ec 1.DMS4@NRC. GOV

,' lc 4fa( St Richard L. Bangart, Director Office of State Programs

Enclosure:

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l4, . , FORMERLY LICENCED SITES REGIONAL CONTACTS -

Region 1: Craig Gordon/ Tony Dimitriadis U.S. Nuclear Regulatory Commission '

' 475 Mendale Road King of Prussia, PA 19406-1415 610-337-5216/6953 CZG@NRC. GOV /AXD1@NRC. GOV L Region 11: Bryan Parker U.S. Nuclear Regulatory Commission Atlanta Federal Center,23 T85 l 61 Forsyth Street, S.W.

l Atlanta, GA 30303-2415 l

. 404-562-4728 BAP@NRC. GOV Region lil: Bill Snell l U.S. Nuclear Regulatory Commission 801 'Narrenville Road l Lisle, IL 50532-4351 I

630-829-9871 i WGS@NRC. GOV l Region IV: Dean Chaney l U.S. Nuclear Regulatory Commission Walnut Creek Field Office l 1450 Maria Lane, Suite 300 Walnut Creek, CA 94596-5368 510-975-0229 HDC@NRC. GOV l

1 ENCLOSURE 1

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FORMERLY LICENCED SITES REGIONAL CONTACTS -

Ro9 ion 1: Craig Gordon/ Tony Dimitriadis U.S. Nuclear Regulatory Commission '

' 475 Allendale Road King of Prussia, PA 19406-1415 610 337-5216/6953 CZG@NRC. GOV /AXDi@NRC. GOV Region 11: Bryan Parker l

U.S. Nuclear Regulatory Commission Atlanta Federal Center,23 T85 61 Forsyth Street, S.W.

Atlanta, GA 30303-2415

. 404-562-4728 BAP@NRC. GOV Region 11!: Bill Snell U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 50532-4351 630-829-9871 l

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Region IV: Dean Chaney U.S. Nuclear Regulatory Commission l Walnut Creek Field Omce 1450 Maria Lane, Suite 300 Walnut Creek, CA 94596-5368 510-975-02'"

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! I DEPARTMENT OF HEALTH SERVICES

m/m e sneet ca.een u m sacnamewro, ca waspaso l (916) 657-1425 January 20, 1998 l

Shirley Ann Jackson, Ph.D., Chairman i United States Nuclear Regulatory Conunission Washington, DC 20555-0001 l

i Sear Dr. Jackson:

ne California Department of Health Services has received Mr. Richard L. Bangart's letter of November 14,1997, regarding sites fotmerly licensed by the U.S. Atomic Energy Commission (AEC) or the U.S. Nuclear Regulatory Commission (NRC). In that letter, it is stated that radioactive material remaining at a site located within an Agreement State, including material originally licensed by NRC, is the regulatory asponsibility of the Agreement State. In a l separate letter dated December 5,1997, there were 133 previously terminated licenses identified.

California became an Agreement State in 1962. In that agreement, Califomia did not accept regulatory authority over the 133 sites in California formerly licensed by AECMRC. At the present time,60 of the original 133 Califomia sites licensed by AEC/NRC have been identified by your agency as open due to lack of appropriate documentation of site decontamination.

The NRC states that it is transferring responsibility for the site review and closure to Califomia because of your resource constraints and your position that Agreement States have l

jurisdiction over these sites. He current California agreement with NRC does not require the state to accept this workload. The Department also has resource constraints and our radiologic health program does not have the staffing or funding to accept your additional workload. He California Radiologic Health Program is supported by fees paid by users of radioactive materials.

It would be inappropriate to use those fees to support activities which do not directly benefit those fee payers.

In summary, we deem our Agreement State status as not including regulatory authority or responsibility for regulatory oversight over facilities in the state formerly licensed and released by NRC. In order to properly protect public health, it is requested that your agency take inunediate action to notify the present owners of the 60 California license sites which you have identified as open. De C+ Luent will assist NRC to the extent possible in closing these sites, but Califomia will not accept responsibility on sites previously licensed and termi*ad by your agency.

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If you have any questions, please contact me or James W. Stratton, M.D., M.P.H., State Health Officer and Deputy Director, Prevention Services, at (916) 657-1493

! Sincerely, l

. 3 . 5 S & d uj $ l l S. Kimberly Belsh6 Director cc: Governor's Office State Capitol Sacramento, CA 95814

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,,,,, March 20, 1998 .

Ms. S. Kimberty Bolshe, Director Department of Health Services Health and Welfare Agerwy 714/744 P Street P. O. Box 742732 Sacramento, CA 94234-7320

Dear Ms. Bolshe:

Thank you for your letter of January 20,1998, to Chairman Jackson regarding formerly licensed Atomic Energy Commission / Nuclear Regulatory Commission (AEC/NRC) sites.

We recognize the importance of the jurisdictional and other issues you and other Agreement States have identified regarding such sites. To assess a number of the issues further, the Commission has directed the NRC staff to complete the actions identified in the SECY-98-011 Staff Requirements Memorandum (SRM) dated March 3,1998 (Enclosure 1). SECY-98-011, Potential Funding Assistance for Agreement States for Closure of Formerty Terminated NRC Licensees, is included as Enclosure 2. In order to respond to the first item in the SRM, we are requesting Agreement States, such as Califomia, to advise us if they believe the initial site surveys and assessments to determine the scope of the problem are themselves so significantly expensive and difficult as to preclude the State from undertaking this preliminary step in the cleanup process. Your position on this issue is reqyested. This request is in addition to the !

information requested in All Agreement States letter SP-97-080, Formerty Licensed Sites and l Jurisdiction for Remaining Residual Materials, dated November 14,1997. SP-97-080 requested any available information about how your State is affected by the Commission decision, such as the number of sites that may need remediation, regulatory effods needed to ensure appropriate l remediation and their costs, the associated costs of remediation, and difficulties experienced in i attempting to require remediation. This information is necessary to identify mutually acceptable mechanisms, such'as a general fund appropriation outside of the fee base, to reduce resource impacts on Agreement States. We will provide a mere complete response to the issues and concems identified in your letter after we have received and evaluated the requested information. )

We also plan to provide Agreement States with additional information on the criteria NRC used to identify previously licensed AEC/NRC sites which should be subjected to further evaluation.

This information will be forwarded to you in the near future and may be of assistance in i

S. Kimberly Belshe 2 0W narrowing the number of sites that may have poiential onsite contamination and thus, require l more extensive onsite surveys. ] 1 if you have any questions, please contact Tom O'Brien of my staff on (301) 415-2308.

l Sinc 9 rely t i klia fy. /fa t Richard L. Bangart, Director ~

Office of State Programs v l

Enclosures:

As stated cc: E. D. Bailey, Chief j Radiological Health Branch Food, Drugs & Radiation Safety Division l l l

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1 MEMORANDUM TO: L. Joseph Callan )

Ex ive ' rector for Operations

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FROM: . Hoyle, cretary I

l SUSJECT: STAFF REQUIREMENTS: SECY-98 011 - POTENT!AL l FUNDING ASSISTANCE FOR AGREEMENT STATES FOR CLOSURE OF FORMERLY TERMINATED NRC LICENSES l The Commission approved the staff's approach of monitoring the Agreement State's progress !

( in closing out the case files associated with sites located in Agreement States that were )

l formerly licensed by the NRC or its predecessor, and collecting additional information from i I

individual Agreement States regarding the associated costs and potential funding mechanisms to provide Federal assistance. in implementing this monitoring and information collection program, however, the staff should also undertake the following additional measures:

. inquire of the States during the further consultation on funding mechanisms proposed in SECY 98-011 whether the initial site surveys and assessments to determine the scope of the problem are themselves so significantly expensive and difficult as to preclude the States from undertaking even this preliminary step in the cleanup process, in the absence of other funds or some other form of resource assistance from the NRC,

. ensure that the fWe review being conducted by the Oak Ridge National Laboratory is completed in March 1998, that the files are subsequently transferred to the States promptly, and that milestones are established on when NRC needs to receive information from Agreement States. The staff should make an initial recommendation on whether NRC should request a general fund appropriation, to cover the associated Agreement State costs for those States providing a response consistent with the FY 2000 budget cycle.

. consider the merits of an altamative approach to providing financial assistance to individual Agreement States by developing a narrowly focused amendment to the Atomic Energy Act that would allow the Agreement States to retum their regulatory authority and responsibility for formerly licensed sites to the NRC If the licenses in question had been terminated before the State became an Agreement State and permit the NRC to receive appropriations off the fee base to cover the costs associated with closure of these sites.

(EOG) (SP) SECY Suspense: 94V98) 9700277 8/25/98 SECY NOTE: This SRM, SECY 98-011, and the related Voting Record will be made publicly available 5 working days after the date of the final SRM.

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l POLICY ISSUE January 22. 1998 SECY-98-011 Ent: The Commissioners EIg,!!!: L Joseph Callan Executive Director for Operations fyMid: POTENTIAL FUNDING ASSISTANCE FOR AGREEMENT STATES FOR l CLOSURE OF FORMERLY TERMINATED NRC LICENSES 1

Purpose:

To provide a status of staff efforts to satisfy Staff Requirements Memorandum SRM SECY 97-l 188, dated November 7,1997 and to obtain Commission approval for future actions regarding potential funding assistance for Agreement States for closure of formerly terminated NRC licenses.

Backaround:

The Commission previously approved the staff's proposal (1) for the discontinuance of detailed reviews by NRC staff of license files and inspections for follow up on formerty NRC licenseo sites identified for further investigation in Agreement States, (2) for the referring of identified cases directly to the Agreement States for follow-up investigation, and (3) to hold the Agreement States responsible for addressing remediation of those sites where excessive contamination is confirmed by inspection (see Staff Requirements Memorandum, SRM SECY 97188, dated November 7,1997). SRM SECY 97188 also directed the staff to work with the Agreement States to identify a mutually acceptable mechanism to provide Federal assistance to the i Agreement States, such as a general fund appropriation outside the NRC fee base, in dealing with these cases. In that regard, the staff was directed to consider how similar funding was made available to Agreement States in the Uranium Mill Tallings Radiation Control Act of 1978 (UMTRCA) and seek input from the Agreement States on the degree to which they would support such an appropriated funds approach. The Commission requested tiat in presenting ,

the options the staff should also provide any available information regarding M estimated l number of sites and the Agreement States affected, the typical regulatory effons to ensure I appropriate remediation and the associated costs, and any difficulties experienced by NRC and i the Agreement States in attempting to require further remediation of these sites.

l CONTACT: Denn!s Sollenberger, OSP NOTE: TO BE MADE PUBLICLY AVAILABLE WHEN 415-2819 THE FINAL SRM IS MADE AVAILABLE I

___ ENCLOSURE 2

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The Commissioners 2 Discussion-The staff prepared and sent (see Attachment 1) an All Agreement States letter informing the Agreement States that the NRC has determined that they are responsible for any radioactive material remaining at a site in an Agreement State, including material originally licensed by NRC or its predecessors, where the license was terminated prior to the State becoming an Agreement l State. The letter also requested any available information or estimates on the impact of these responsibilities on the States' resources. Only a few States (AZ, CO, GA, IL, NC, TN, TX, WA) have responded to date. Califomia has previously corresponded with NRC on the question of regulatory responsibility for such sites located in Agreement States. The States' comments can be summarized as follows: (1) the State does not agree with NRC's position that this is an Agreement State responsibility, however, they will protect the citizens in the State, (2) this effort is unbudgeted wo* for the State and no funds are available, (3) the State cannot provide any estimates at this time since they have not yet received the files from NRC to begin a resource estimate, and (4) the State would expect NRC to pay for any remediation and/or source disposal costs not covered by former licensees. Additionally, Arizona stated that they were not informed of this potential liability when they signed their Agreement, they do not have any resources to address this liability, and they requested that the NRC, as the responsible Federal agency, take the necessary actions to protect the public health and safety of Arizona citizens. Seme States have indicated they would take responsibility for the public health and safety and the protection of the environment by conductmg the remedial action once funding is provided.

The numbers of sites that may be contaminated and need follow-up are listed in Attachment 2.

The number of States with a significant number of sites is relatively small with only two States (New Yo* and Califomia) having ten or more sites with loose contamination and four States (New Yo*, Tennessee, Califomia, and Texas) having ten or more sealed source shes pending.

The Commission should note that NRC's contractor, Oak Ridge National Laboratory, is still in the final stage of reviewing formerly terminated licenses. Thus, additional Agreement State sites that may contain unacceptable levels of contamination or unaccounted for sealed sources will j likely be identified. Agreement States will be informed of these sites as information becomes j available to NRC staff.

Although the transfer of files will result in some unplanned wo* being transferred to the Agreement States, it appears from the generallack of comment about the appropriated funds l approach that a number of States may be able to accommodate this regulatory effort. The most impacted States (Califomia and New York) did not respond and, along with a few other States, may need assistance in both remediation and regulatory effort. However, the resources required by the States to do this wo* are still uncertain. The States will need a period of time to evaluate the number and type of sites that remain to be followed-up and to make reasonable estimates for the regulatory effort needed. The significant expense of this wo* transfer is the field survey, site characterization, remedial action planning and the actual remediation of any contaminated alte identified. Additional costs will be for Agreement State reguintory oversight and review of proposed remedial actions. Cost estimates will not be available until each Agreement State l completes the file review and conducts an initial site survey or assessment, or requires the !

responsible party, if known, to conduct the survey or assessment.

This process may take a few States up to a year or more to identify which sites are actually contaminated and the status of the site owner or former licenses and whether it may be possible ,

for the State to seek remedial action under the Comprehensive Environmental, Compensation, !

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i The Commissioners 3 and Liability Act of 1980 (CERCLA), as NRC has considered for a few of its contaminated sites.

In some cases, additional costs associated with site characterization and remediation may have to be funded by the State, especially if cleanup under CERCLA is not requested or if CERCLA cleanup is requested and denied. The remediation costs will not be known until the extent of contamination is known for the individual sites.

As the Agreement States complete their evaluation of the files transferred from the NRC Regional offices, NRC staff will request that information be provided to NRC on the number of sites that may need remediation, the regulatory efforts necessary to ensure appropriate somediation and their costs, and difficulties likely to be encountered in requiring further remediation. This continuing communication with the Agreement States will be as-T@shed through our routine program of All Agreement States letters and the routine exchange of '

information process between NRC and Agreement States. Through this process, staff will .

identify if funding support is needed and the magnitude of the funding need. Until the Agreement States supply this infonnation, staff believes it is premature to pursue any request to the Administration and Congress for either authorization or appropriation of funds. Information available to staff by January 1999 will be assessed to determine if the need is sufficient to support a request for funds for the purpose of providing support to Agreement States for costs associated with evaluation and remediation of these formerty licensed sites. One approach could be to include the authorization for such funds in the NRC legislative package for the 106th Congress, and include an appropriation for this purpose in the NRC appreoriation request for FY 2001.

Appropriated Funds Approach 1

Per Commission direction, staff evaluated how funding was made available to Agreement States in UMTRCA. In Title 11 of UMTRCA, Congress expressly authorized up to $500,000 to be appropriated (for fiscal year 1980) to the Nuclear Regulatory Commission for maklag grants to Agreement Ctates to aid in the development of State programs to regulate uranium recovery I

' operations under the new requirements of UMTRCA. The House of Representatives' report accompanying NRC's FY 1980 appropriation billindicated the House Appropriations Committee provided this $500,000 for grants to States under Section 207 of UMTRCA of 1978. Each Agreement State involved had to submit information that was evaluated prior to the grant being I approved. The costs were associated with required infrastructure changes such as legislation, regulations, laboratory equipment, and survey equipment. The funding was provided to the State prior to entering into the amended Agreement, so that the State could meet the new requirement under UMTRCA. In addition, Title I of UMTRCA provided for a Federal / State cost sharing where the Federal govemment (through the Department of Energy) funded ninety percent and the State funded ten percent of the remedial action costs for oestain processing sites at which uranium was produced for sale to any Federal agency prior to January 1,1971. I

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Agreement State complation of the work required to review formerfylicensed sites does not require the infrastructure changes that the UMTRCA action required. However, the potential costs that the State may encounter to address these sites does have the potential for a significant financialimpact on a State. Following the example of UMTRCA in assuming l responsibility for sites formerly licensed by the NRC, Agreement States may be accepting a responsibility such that the Federal govemment may want to provide financial relief. However, NRC has allocated no funds for this purpose and effectuation of the progmm may require approval by the Congress (and, for practical purposes, by the Office of Management and

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.:.. l The Commissioners 4 Budget), depending on the scope of the program and the size of the amounts involved. The amount needed for such support would be dependent on the number of contaminated sites without responsible parties stillin existence, the number of responsible parties without sufficient resources to fund cleanup, and the additional costs for the States to conduct regulatory reviews and oversight.

Only one Agreement State (IL) responded with comments on the concept of NRC requesting appropriated funds. The Illinois comments addressed the potential funding for work already completed by a State and that NRC should work closely with individual States to coordinate the Federal funding with each State's appropriation process. Two additional Agreement States (TN, WA) have indicated in their response to NRC's All Agreement States letter that they would seek i

funding from NRC because NRC or its predecessor agency terminated the licenses for these '

contaminated ' sites. One State (WA) was informally notified that NRC is currently not funding cleanup costs associated with contaminated sites located in Agreement States. Califomia has not yet responded, but that State may also request funding because previous correspondence indicates it believes Agreement States should not have the regulatory responsibility for these sites.

Thus, it appears there may be a need for the Commission to seek an appropriation to assist Agreement States in carrying out their responsibilities with respect to formerly licensed sites.

Authorization for such an appropriation could be requested when information is known about the number of sites, the potential costs to Agreement States, and the amount of financial assistance needed by Agreement States. Money would not be requested to fund costs associated with approved CERCLA cleanups, or cleanups by current site owners or other responsible parties. If the Congress grants NRC this authority, the annual appropriation process would be used for requesting the anticipated funding. This approach could provide NRC the specife information

, needed to support the authorizing legislation request.

If the contaminated sites are cleaned up by the current site owner or the former licensee, or cleanup is authorized under CERCLA, the need for NRC to make a funding request may not arise. In such a case, the costs to an Agreement State may be small or modest, since those costs would be limited to regulatory review and oversight. The State of lilinois supplied some information for the sites that they have closed out. This information indicates Agreement State costs for regulatory review and oversight of a number of transferred sites may be modest. For the thirty two sites that did not require site visits or surveys, they expended approximately 150 hours0.00174 days 0.0417 hours 2.480159e-4 weeks 5.7075e-5 months . For the other twenty two sites, they have expended 300 hours0.00347 days 0.0833 hours 4.960317e-4 weeks 1.1415e-4 months . Only one site required limited remedial action which the site owner completed. The State has yet to perform the final survey before releasing the site for unrestricted use. The State's estimated cost for the ,

total regulatory effort including the final survey is $51,500. This would close all the formerly 1 licensed sites that NRC has identified, to date, in the State of lilinois.

Recommendation:

1 The staff recommends that the Commission:

1. Endorse the staffs approach of monitoring the Agreement State implementation of the i closure of these cases and collection of information on the costs to trie Agreement States. l l

i*.

7. . .

The Commissioners 5

2. Note that, upon Commission Poproval, the staff will consult with the Agreement States on funding mechanisms. After the information needed is gathered and the consultation is completed, the staff will present its recommendations, including an assessment of legislative needs.

Resources-The resources for transfer of the files to the Agreement States and initial coordination with the Agreement States were addressed in SECY-97-188. The ongoing coordination with the i

Agreement States will be conducted as part of the routine actMties of the Office of State l

l Programs. Therefore, at this time, no additional resources are required to implement the actions discussed in this paper. Staff notes that before Agreement States complete their assessments j of the transferred files, it is premature to assess the costs to States of remediation, the costs of associated Agreement State program regulatory activities, and the need for Federal funding assistanc.. I i Coordination:

j The Office of General Counsel has no legal objection to this paper. The Office of the Chief l

Financial Officer has reviewed this Commission paper and has no objection.

{

l l L Jo[phCallan

', Executive Director for Operations

! Attachments:

l 1. All Agreement States Letter dated November 14,1997

! 2. Table of the Number of Potentially Contaminated Sites in Agreement States l

I l

l L_____-_-____-_-__________________________ _ .______ ___ __ _

~~

MISSION

= , ,

November 24,1997 ALL AGREEMENT STATES OHlo, OKLAHOMA, PENNSYLVANIA TRANSMITTAL OF STATE AGREEMENTS PROGRAM INFORMATION (SP-97-080)

Your attention is invited to the enclosed correspondence which contains:

INCIDENT AND EVENT INFORMATION.. ..

PROGRAM MANAGEMENT INFORMATION. .XX FORMERLY LICENSED SITES AND JURISDICTION FOR REMAINING RESIDUAL '

MATERIALS TRAINING COURSE INFORMATION........ ....

TECHNICAL INFORMATION..... . ............. ...

OTHER INFORMATION......... . . .. ...

Supplementary information: The Nuclear Regulatory Commission (NRC) has been reviewing previously terminated licenses to determine whether there was appropriate documentation that the sites were adequately decontaminated prior to termination of the license and release of the site. This project was initiated in 1977 for licenses terminated prior to 1965. Another effort wat initiated in 1989 for licenses terminated after 1965, which was subsequently expanded to include all terminated licenses. A number of sites have been identifed for which there is insufficient documentation to ensure that the site was adequately decommissioned or to account for all sealed sources. NRC regional offices are currently working to close these records through additional flie searches and, when necessary, site surveys. NRC guidance for conducting these follow-up inspections is documented in Temporary Instruction 2800/026 (Tl 2800/026), and copies were provided to the A0reement States.

. Radioactive material remaining at a site located within an Agreement State, including material originally licensed by NRC or its predecessors, is the regulatory responsibility of the A0reement

State. Therefore, en Agreement State is responsible for conducting detailed license and inspection file reviews. and investigation and remediation of any site, as appropriate, identl6ed through NRC review of previously terminated licenses for which there is insufRcient documentation to ensure that the site was property decommissioned or which has inadequate accounting of sealed sources. A number of cases have already been referred to AGroement States for follow up. Additional cases may be referred in the next few months as our contractor completes its review of old nies.

i ATTACHMENT 1

., l '

SP-g7- 080 2 EDY I4 SlfT After review of the files, some cases require on stte inspections to determine whether excessive contamination may be present. Up to now NRC hos conducted numerous inspections in Agreement States where the States have indicated resource constraints or have indicated that they do not believe they have regulatory jurisdiction. However, in light of our own resource constraints and our position that Agreement States have junsdiction over these sites, NRC is phasing out detailed reviews of license flies and follow-up inspections. Sites that appear to require further imestigations or inspections to property assess the sites will be referred to the appropriate Agreement States for follow up. The States will continue to be responsible for regulation of any needed remedstion of any contaminated sites under theirjurisdiction. To maintain a complete database on the status of terminated license sites, Agreement States are requested to report resolution of each case to NRC for tracking. To minimize the reporting burden on the States, the resolution reports may be in the form of short summaries or copies of pertinent correspondence. These resolution reports should be sent to your respective NRC Regional decommissioning contacts (see Enclosure 1).

Agreement State activites to review and resolve issues associated with terminated licenses referred to them will be examined during Agreement State program reviews conducted using the Integrated Materials Performance Evaltstion Program. However, State actions on referred cases will not affect findings of adequacy under the IMPEP tmiess there appears to be a significant threat to public health and e Cety resulting from a lack of appropriate State action.

In an effort to reduce the resocco impacts on Agreement States, the Commission has i directed the staff to work with the Agreement States to identify mutually acceptable l

mechanisms, such as 'a gerwral fund appropnation outside the fee base,' for providing Federal j assistance to effected Agreement States. To identify the magnitude of an aw#,stion estimate, we are requesting any evallable information that you might have on how your State is or may be affected, such as the number of sites in your State that may need remediation, the typical regulatory efforts needed to ensure appropriate remediation and their costs, the associated costs of remediation, and any difficulties experienced by the Agreement States in attempting to require further remediation of these sites. For Agreement States that are beginning this activity, please provide general estimates, and the basis for those estimates, for the information needs listed above. Any information available would be most useful if provided by December 10, igg 7. -

This information request has been approved by OMB, NO. 3150002g, expiration April 30,1gg8. Estimated burden per response to comply with this voluntary collection request:

3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months , O minutes. Forward comments regarding burden estimate to the information and Records Management Sranch (T 6 F33), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, and to the Paperwork Reduction Project (3150 0052), Office of Management and Sudget, Washington, DC 20503. NRC may not conduct or sponsor, and a person is not

t. ;

Vf SP 080 3 NOV 14 E required to respond to, a collection of.5 formation unless it displays a currently valid OMB control number.

If you have any questions about this correspondence, please contact me or the individual named below.

CONTACT: Dennis M. Sollenberger TELEPHONE: (301)415 2819 FAX- (301)415 3502 INTERNET: DMS4@NRC. GOV j c &if Richard L Bangart, Director Office of State Programs l

Enclosure:

. As atsted l

l l

I l

l l

l

~

1

, . 1 s'

l.

FORMERLY LICENCED SITES REGIONAL CONTACTS Region 1: Crain Gordon/ Tony Dimitriadis U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 610 337-5216/5953 CZG@NRC. GOV /AXD19NRC. GOV Region 11: Bryan Parker U.S. Nuclear Regulatory Commission Atlants Federal Center,23 785 61 Forsyth Street, S.W.

Atlanta, GA 303C3 2415 404 562 4728 BAP@NRC. GOV Region Ill: Bill Snell

. U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle,IL 50532 4351 630-829-9871 WGS@NRC. GOV Region IV: Dean Chaney U.S. Nuclear Regulatory Commission

, Walnut Creek Field ONice 1450 Maria Lane, Suite 300 Walnut Creek, CA 94596 5368 510 975-0229 HDC@NRC. GOV l

l ENCLOSURE 1 l

'~.". .

1

? .

l TERMINATED LICENSE SITES IN AGREEMENT STATES (UPDATED 9/18/97)

Agreement State Sites Sites Sites Sealed Scaled Sealed identifled Closed Review Sources Sources Sources I by ORNL Pending identified Closed Pending by ORNL Region i

1. Maine 2 2 0 1 1 0

2. Maryland 31 31 0 14 7 7

3. Mass. 49 49 0 17 17 0

4. New Hampshire 1 1 0 0 0 0

5. New York 36 26 10 37 18 19

6. Rhode island 4 4 0 4 4 0 l

Region il

7. Alabama 3 2 1 14 10 4

8. Florida 3 2 1 5 2 3

9. Georgia 3 3 0 2 0 2

10. Kentucky 3 1 2 5 3 2 i 11. Mississippi 0 0 0 4 3 1

12. North Carolina 2 2 0 3 0 3

13. South Carolins 3 3 0 1 0 1

14. Tennessee 9 6 3 10 0 10 Region ill

15. liinois 35 34 1 22 22 0

16. Iowa 0 0 0 3 3 0 l Attachment 2

m- .

n .'

TERMINATED LICENSE SITES IN AGREEMENT STATES (UPDATED 9/18/97)

Agreement State Sites Sites Sites Sealed Sealed Sealed identified Closed Review Sources Sources Sources by ORNL Pending identified Closed Pending by ORNL Region IV

17. Arizona 4 0 4 1 0 1

18. Arkansas 1 1 0 5 4 1

19. California 95 55 40 43 27 16

20. Colorado 13 9 4 5 0 5

21. Kansas 6 6 0 5 0 5

22. Louisianna 1 0 1 1 0 1

23. Nebraska 2 1 1 1 1 0

24. New Mexico 6 6 0 5 2 3

25. Nevada 4 2 2 4 2 2

26. North Dakota 3 3 0 1 0 1

. 27. Oregon 2 2 0 2 2 0

28. Texas 10 7 3 27 9 18

29. Utah 6 4 2 5 3 2

30. Washington 6 6 0 7 5 2 2 Attachment 2

\.

~

Martha Sharp 2 7 work cooperatively with counterparts in the California Radiological ch toHealth addressBran /

regulatory issues associated with the property at 170 West Providencia Stre6t, Burbank, California.

If you have any questions, please contact me at (301) 415-3340 or Mr/ Richard Blanton of my staff at (301) 415-2322, or by e-mail: RLB@ NRC. GOV.

Sincerely, Richard L. Bapgart, Director Office of State Programs cc: D.E. Bunn,CA

Enclosures:

As stated I

Qighibution:

! DIR RF (8S-121) DCD (SP08) l SDroggitis PDR (YES_f__ NO )

California File l DOCUMENT NAME: G:\RLB\8S121LTR.WPD *SEE PREVIOUS CONCURREN0E.

l r,r m . e o r o,ini. ooeumtnt. incie.i. in in. box: c - copy witnout ett cnm nt/ neio.ui , e scopy witn ett.cnment/.nciosur. w No copy l OFFICE OSP l OSP:DD \ bGi f/l NMSS l OSP:D NAME RLBlanton:kk/nb/gd PHLohaus FCarheroV V MKnapp RLBangart DATE 05/28/98

05/29/98* / 06/15/98* 06/ /98 07 q98 I

06/12/98* ~

OSP FILE CODE: SP-AG-4 i

i

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I

... l

. Martha Sharp 2 l

l cooperatively with counterparts in the Califomia Radiological ealth Branch to address 1 regulatory issues associated with the property at 170 West Providencia Street, Burbank, Califomia.

l If you have any questions, please contact me at (301) 415-3340 or Mr. Richard Blanton of my staff at (301) 415-2322, or by e-mail: RLB@NRC. GOV. '

Sincerely, i

l Richard L. Bangart, Director l Office of Stat Programs l cc: D. E. Bunn, CA l

Enclosures:

As stated l

l l

I Distribution: l DIR RF (8S-121) DCD (SP08) !

SDroggitis PDR(YES / NO ) )

California File

]

i DOCUMENT NAME: G:\RLB\8S121LTR.WPD f

SEE PREVIOUS CONCURREN0E.

l 7 me.w. . cop , w th= oocum.nuneceh in the box: *C" a Copy w@puhuchmenUedchure T a Copr we auchmenUencMure Y a No copy OFFICE OSP l OSP:@l/1 / OGC NMSS , l l OSP:D l NAME RLBlanton:kk/nb/gd PHLohaud W/\ FCameron MKnC RLBangart DATE 05/28/98

05/29/98* 06/12/98 / 06/ /98 06//ff98 06/ /98 OSP FILE CODE: SP-AG-4 1

L---------------

. . . r l ". " " Martha Sharp 2 l

cooperatively with counterparts in the California Radiological H lth Branch to address regulatory issues associated with the property at 170 West Pro idencia Street, Burbank, California.

If you have any questions, please contact me at (301) 415-3 0 or Mr. Richard Blanton of my staff at (301) 415-2322, or by e-mail: RLB@NRC. GOV.

Sincerely, l

Richard L. Ba gart, Director 1 Office of Stat Programs I cc: D.E. Bunn,CA

Enclosures:

l As stated l

i l

l 1

l l

Distribution:

DIR RF (8S-i21) DCD (SP08)

SDroggitis PDR (YES_/__ NO ) ;

California File DOCUMENT NAME: G:\RLB\8S121LTR.WPD f *SEE PREVIOUS CONCURRENCE.

Ta receive a cop r of this document. Indicate in the box: "C" = Copy withput idadhment/ enclosure "E" = Cop f with attachment / enclosure "N" = No copy i OFFICE OSP _

OSP:$lj'; / OGC NMSS l OSP:D l _NAME RLBlanton:kk/nb/gd PHLohaud W/\/ FCameron MKnapp RLBangart DATE 05/28/98

05/29/98* 06/j2198 06/ /98 06/ /98 06/ /98 OSP FILE CODE: SP-AG-4 s

--_7__-

I Ms. Martha Sharp . >

Loeb & Loeb LLP Attomeys At Law . _

1 L. 1000 Wilshire Boulevard, Suite 1800 j

!' Los Angeles, CA 90017-2475 l

l .

Dear Ms. Sharp:

l The Commission staff has reviewed your letter of April 13,1 98,' and the attached radiological l risk assessment performed in October,1997, on the prope located at 170 West Providencia

' Street in Burbank, Califomia. The staff also considered the comments in the letter to ycu from Mr. Gerard Wong, Ph.D., Chief of the Radioactive Material Licensing Section of the Radiologic Health Branch, California Department of Health Services.

! In summary, NRC staff concurs with the comments of Dr. Wong. As noted in the NRC

~

inspection report summary, the inspector conducted onlyj an independent radiological survey I l which established the need for further radiological characterization and evaluation. The i inspection survey did not fully characterize the radiological contamination at the site, and was not intended to be used as the basis for a complete as ' sament. For example, while the report

! noted that no loose alpha or beta radioactivity above t then current NRC release criteria was identified during the survey, issues such as leaching mechanical resuspension were not addressed, and pathways such as inhalation or inges ion not considered.

l - With regard to the letter of April 7,1998, from Mr. D9nald Bunn, Chief of the Compliance and Enforcement Section of the California Radiological lpealth Branch, it should be noted that while the Commission is considering the Califomia positi n on sites formerly licensed by NRC, the State still has the option to assert regulatory autho y over the sites.

If you have any questions, please contact me or r. Richard Blanton of my staff at i j (301) 415-2322, or by e. mail: RLB@NRC. GOV..

l Sincerely, l.

Richard L. Bangart, Director Office of State Programs l

Distnbution !

- DIR RF (SP-121) DCD (SP08) !

SDroggitis . PDR (YES.f_, NO ) !

Califomia File j l

DOCUMENT NAME: G:\RLB\88121LTR.WPDf *SEE PREVIOUS CONCURRENCE. l Ta receive a cor of thes document, isNlicate in the box: "C" mA% ytwijout ment / enclosure "E"in Cop ' with attachment / enclosure "N" = No copy ')

OFFICE OSP l 07%/l OGC NMSS l OSP;D l l NAME RLBlanton:kk/nb PHLothbd l/ FCameron MKnapp RLBangart i DATE- 05/28/98

05E/98' 06/ /98 06/ /98 06/ /98

{ OSP FILE CODE: SP-AG-4 l

( .-

[ .

[ ,

l '. "

Ms. Martha Sharp

! Loeb & Loeb LLP Attomeys At Law 1000 Wilshire Boulevard, Suite 1800 Los Angeles, CA 90017-2475

Dear Ms. Sharp:

The Commission staff has reviewed yourletter of April 13,1998, and /t e attached radiological risk assessment performed in October,1997, on the property locatep at 170 West Providencia Street in Burbank, California. The staff also considered the comments in the letter to you from Mr. Gercrd Wong, Ph.D., Chief of the Radioactive Materials Lice sing Section of the Radiologic Health Branch, Califomia Department of Health Services.

In summary, NRC staff concurs with the comments of Dr. V /ong. As noted in the NRC inspection report summary, the inspectorj conducted only e)n independent radio '

which established the need for further radiological charpeterization and evaluation. The inspection survey did not fully characterize the radiological contamination at the site, and was i '

not intended to be used as the basis for a completej dssessment. For example, while the report noted that no loose alpha or beta radioactivity abcpe the then current NRC release criteria was l

identified during the survey, issues such as leaching or mechanical resuspension were not addressed, and pathways such as inhalatio ingestion not considered.

With regard to the letter of April 7,1998, frpm Mr. Donald Bunn, Chief of the Compliance and l

Enforcement Section of the California RWiological Health Branch, it should be noted that while the Commission is considering the Ca/I' ornia position on sites formerly licensed by NRC, the i State still has the option to assert reg 6tatory authority over the sites and require decontamination to lower levels th required by NRC regulations.

If you have any questions, ple, e contact me or Mr. Richard Blanton of my staff at (301)415-2322, or by e-mail RLB@NRC. GOV.

Sincerely, ;

1

Richard L. Bangart, Director Office of State Programs Distribu ' n- '

DIR R (SP-121) DCD (SP08)

SDrp[gitis PDR (YES.f_ NO )

Cahfornia File DOCUMENT NAME: G:tRLB-8S121LTR.niPD Ts receive a cop f of this document. Indicate in the box: "C" a Copy without attachment / enclosure "E" = Cop t wrth attach,mnt/ enclosure "N" = No copy j OFFICE OSP l E. OSP:DD l OGC NMSS l OSP:D l NAME RLBlanton:k)(JA PHLohaus FCameron MKnapp RLBangart DATE 05/fB9NW 05/ /98 06/ /98 G6/ /98 06/ /98 OSP FILE CODE: SP-AG-4 l \

l L_ _ .. _

ROUTING AND TRANSMITTAL SLIP DATE: JULY 6,1998 l PARALLEL CONCURRENCE REQUESTED INITIALS DATE 1

F. CAMERON, OGC 7/ /98 !

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4 hp)npcl/6$ ic w-YYasp l

LETTER TO: MARTHA SHARP j LOEB & LOEB LLP l FROM: RICHARD L. BANGART, DIRECTOR j OFFICE OF STATE PROGRAMS I

SUBJECT:

RADIOLOGICAL RISK ASSESSMENT PERFORMED IN OCTOBER,1997, ON PROPERTY AT 170 WEST PROVIDENCIA STREET, BURBANK, CA (NOTE: REVISED LETTER) l YOUR COMMENTS / CONCURRENCE ARE REQUESTED BY C.O.B. JULY 10.1998.

l l

OSP CONTACT: RICHARD BLANTON (415-2322) l PLEASE CALL KATHALEEN KERR (415-3340) FOR PICK UP. j ROUTING AND TRANSMITTAL SLIP DATE: JUNE 12,1998

l

[. " ROUTING AND TRANSMITTAL SLIP i

l DATE: JUNE 12,1998 1

1 PARALLEL CONCURRENCE REQUESTED INITIALS DATE I

F. CAMERON, OGC 6/ 19 8

--M.-KNAPP,-MMSS-

(([ ' 7$f 6/ 198 LETTER TO: MARTHA SHARP LOEB & LOEB LLP FROM: RICHARD L. BANGART, DIRECTOR OFFICE OF STATE PROGRAMS

SUBJECT:

RADIOLOGICAL RISK ASSESSMENT PERFORMED IN OCTOBER,1997, ON PROPERTY AT 170 WEST PROVIDENCIA STREET, BURBANK, CA t

(NOTE: REVISED LETTER) l YOUR COMMENTS / CONCURRENCE ARE REQUESTED BY C.O.B. JUNE 26.1998. '

OSP CONTACT: RICHARD BLANTON (415-2322)

PLEASE CALL KATHALEEN KERR (415-3340) FOR PICK UP.

I

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ROUTING AND TRnNSMITTA SLIP DATE: May 29,1998 PARRALI FL CONCURRENCE REOUESTED l

1.

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F. CAMERON-CONCURRENCE ~ d. . g _ _.jty , ,,,,gsjd h-k & G-b&dr-

2. M. KNAPP - CONCURRENCE g LETTER TO: MARTHA SHARP MOI 9 5 h, '

LOEB & LOEB LLP gg

@ Geo FROM: RICHARD L. BANGART, DIRECTOR OFFICE OF STATE P DGRAMS

SUBJECT:

RADIOLOGICAL RISK ASSESSMENT l

YOUR COMMENTS / CONCURRENCE ARE REOUESTED l

BY C.O.B.. JUNE 12.1998 OSP CONTACT: DICK BLANT N,415-2322 PLEASE CALL KATHALEEN KERR (415-3340) FOR MCk UP.

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ML20236W466

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Text

Dear Ms. Sharp:

Enclosures:

Enclosures:

Enclosure:

Dear Ms. Bolshe:

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Enclosures:

Enclosures:

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Dear Ms. Sharp:

Dear Ms. Sharp:

SUBJECT:

SUBJECT:

SUBJECT:

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Dear Ms. Sharp:

Enclosures:

Enclosures:

Enclosure:

Dear Ms. Bolshe:

Enclosures:

Purpose:

Enclosure:

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Dear Ms. Sharp:

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