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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20210T9861999-08-12012 August 1999 Forwards Amend 7 to License SNM-1067,changing Name of License to Abb Combustion Engineering Nuclear Power & Incorporating Into License Date of 990618 for Decommissioning Financial Assurance.Ser,Encl ML20210F6891999-07-29029 July 1999 Forwards Amended Application Pages Which Reflect Change in New Organization.Effective Date of Transfer from Combustion Engineering,Inc to Abb Combustion Engineering Nuclear Power, Inc Was 990629 ML20195D3871999-06-0303 June 1999 Forwards Application for Amend to License SNM-1067 to Transfer All Assets & Liabilities Related to NRC Licensed Activities of Combustion Engineering,Inc to Abb Combustion Engineering Nuclear Power,Inc ML20196J1571998-12-0202 December 1998 Forwards Insp Rept 70-1100/98-01 on 981116-18.No Violations Noted.Insp Consisted of Selective Exams of Procedures & Representative Records,Interviews with Personnel & Observations by Inspector ML20198A9731997-12-10010 December 1997 Forwards Insp Rept 70-1100/97-02 on 971118-20.No Violations Noted.Licensee Maintained Effective Control of Radioactive Matl in Storage & Control of Facility Activities to Maintain Worker Radiation Protection ML20198R0191997-10-29029 October 1997 Forwards Amend 5 to License SNM-1067 & Ser,Including Categorical Exclusion Determination.Amend Removes Bldg 21 & Immediate Environs as Authorized Place for Use of Licensed Matl.License Conditions 6.B,7.B & 8.B,deleted ML20211H7711997-09-30030 September 1997 Forwards Amend 4 to License SNM-1067,deleting Listed Authorized Possession Limits,Ref to All Bldgs Except Bldg 21 & Authorization for All Activities Except Those Related to Decommissioning of Bldg 21 ML20211E0781997-09-19019 September 1997 Requests Further Changes Which Delete Request for Authorization to Possess SNM in Bldg 21.No Source Matl or SNM Has Been Possessed in or Around Bldg 21 Since 960208. Change Pages,Encl ML20217Q3001997-08-21021 August 1997 Submits Response to Questions on Amend Request to Downgrade License SNM-1067.Description of Revs to Submittal in ,List of Pages of Ltr to Be Replaced,Listing of Resulting Effective Pages of Pending Application & Changes,Encl ML20140G6601997-06-10010 June 1997 Forwards Insp Rept 70-1100/97-01 on 970414-17.No Violations Noted.Within Scope of Insp,No Radioactive Contamination or Radiation Levels Above Background Were Measured ML20137D9361997-03-21021 March 1997 Responds to Requesting FY97 Annual Fee for License SNM-1067 Be Assessed Pursuant to Fee Category 14 Rather than Any Other Category.Nrc Agrees That License SNM-1067 Not Subj to Annual Fees for FY97 ML20133A9251996-12-24024 December 1996 Forwards Amend 3 to License SNM-1067 & Safety Evaluation Extending Interim Storage Period of Packaged low-level Radwaste from 5 to 10 Yrs L-96-505, Responds to NRC Request in Ltr Re Amend Request from Combustion Engineering to Downgrade License SNM-1067,1996-12-20020 December 1996 Responds to NRC Request in Ltr Re Amend Request from Combustion Engineering to Downgrade License SNM-1067, ML20132D8131996-12-17017 December 1996 Forwards Amend 2 to License SNM-1067 by Including Methods for Determination of Action Levels for Environ Monitoring Data.Ser Attached ML20135F7471996-12-10010 December 1996 Informs That Mf Weber Branch Chief for Fuel Cyle Licensing Branch,Effective 961118 ML20135E9681996-12-0404 December 1996 Forwards Insp Rept 70-1100/96-02 on 961118-21.No Violations Noted ML20149L7391996-11-0808 November 1996 Informs of Addl Info Needed Before Final Action Can Be Taken on Request for Amend to Delete Windsor Lab Bldgs & Operations,Reduce SNM Possession Limits & Delay Decommissioning Underway on Bldg 17 L-96-504, Requests Extension to Interim Storage Period by Increasing Time from 5 Yrs to 10 Yrs1996-10-31031 October 1996 Requests Extension to Interim Storage Period by Increasing Time from 5 Yrs to 10 Yrs ML20128P3991996-10-15015 October 1996 Ack Receipt of Ltr Dtd 960930,requesting Elimination of Annual License Fees L-96-503, Requests That Annual Fees for FY97 for SNM-1067 Be Assessed Per 10CFR171.16-1,Category 141996-09-30030 September 1996 Requests That Annual Fees for FY97 for SNM-1067 Be Assessed Per 10CFR171.16-1,Category 14 ML20129A7231996-09-0303 September 1996 Notifies NRC That Address of C-E Changed by Town of Windsor, Without Any Change in Physical Location of Facility ML20129A7001996-07-29029 July 1996 Forwards NRC Comments on DOE Draft Rept, Derivation of Guidelines for Cobalt-60,Ni-63 & U Residual Radioactive Matl in Soil at Combustion Engineering Site,Windsor,Ct. Submitted Per 960322 Request L-93-062, Requests Extension on Completion Date for Next Assessment from 940117 to 0315 Re Fundamental Nuclear Matl Control Plan Due to Extraordinary Workloads of Qualified Independent Individuals Intended to Perform Assessment1993-12-22022 December 1993 Requests Extension on Completion Date for Next Assessment from 940117 to 0315 Re Fundamental Nuclear Matl Control Plan Due to Extraordinary Workloads of Qualified Independent Individuals Intended to Perform Assessment L-93-059, Forwards Proprietary Response to Violations Noted in Insp Rept 70-1100/93-201 Re Matl Control & Accounting Program. Encl Withheld Per 10CFR2.7901993-12-15015 December 1993 Forwards Proprietary Response to Violations Noted in Insp Rept 70-1100/93-201 Re Matl Control & Accounting Program. Encl Withheld Per 10CFR2.790 ML20059M9231993-11-18018 November 1993 Forwards Insp Rept 70-1100/93-201 on 931025-29 & Notice of Violation.Details of Insp Rept & Notice of Violation Withheld,Per 10CFR2.790(d) L-93-052, Provides Request for Addl Info Re Decommissioning Funding Plan Submitted on 9207021993-11-10010 November 1993 Provides Request for Addl Info Re Decommissioning Funding Plan Submitted on 920702 ML20059C3661993-10-29029 October 1993 Forwards Amend 28 to License SNM-1067 & Ser.Amend Decreases Possession Limits & Removes Authorization to Conduct U Bearing Nuclear Fuel Mfg Operations at Facility L-93-045, Provides Revised Organization Chart for License SNM-1067 W/Description for Each Key Position to Safety1993-10-26026 October 1993 Provides Revised Organization Chart for License SNM-1067 W/Description for Each Key Position to Safety ML20059C1801993-10-23023 October 1993 Forwards Insp Rept 70-1100/93-03 on 930915-17.No Violations Noted L-93-040, Informs That Licensee Believes Response to NRC Bulletin 91-001,Suppl 1,is No Longer Required Due to Windsor Facility No Longer Being Fuel Fabrication Facility1993-10-0707 October 1993 Informs That Licensee Believes Response to NRC Bulletin 91-001,Suppl 1,is No Longer Required Due to Windsor Facility No Longer Being Fuel Fabrication Facility L-93-039, Confirms Termination of Nuclear Fuel Mfg Activities at Facility,Per Commitment Made in1993-09-30030 September 1993 Confirms Termination of Nuclear Fuel Mfg Activities at Facility,Per Commitment Made in ML20057C9881993-09-29029 September 1993 Forwards List of Personnel to Be Granted Unescorted Access to Facility ML20057B8921993-09-23023 September 1993 Accepts Proposed Date of 931008 Re NRC Bulletin 91-001,Suppl 1 ML20057C2111993-09-23023 September 1993 Ack Receipt of 930915 Notification of Decision to Terminate, by 930930,commercial Nuclear Fuel Mfg Operations at Windsor Facility.Understands That C-E Plans to Submit Amend Request Reflecting Listed Changes in Sept 1993 L-93-037, Requests That Extension Until 931008 Be Granted for Responding to NRC Bulletin 91-001,Suppl 1,as Result of Discussions W/M Tokar1993-09-17017 September 1993 Requests That Extension Until 931008 Be Granted for Responding to NRC Bulletin 91-001,Suppl 1,as Result of Discussions W/M Tokar RA-93-016, Notifies That C-E Will Terminate,By 930930,commercial Nuclear Fuel Mfg Operations at Windsor Facility.Subj Termination Will Consist of Cessation of Mfg of U Bearing Fuel & Removal of All Inventoried SNM in Bldgs 17 & 211993-09-15015 September 1993 Notifies That C-E Will Terminate,By 930930,commercial Nuclear Fuel Mfg Operations at Windsor Facility.Subj Termination Will Consist of Cessation of Mfg of U Bearing Fuel & Removal of All Inventoried SNM in Bldgs 17 & 21 ML20057A7571993-09-14014 September 1993 Accepts Proposed New Date for Submitting Addl Info Re Decommissioning Funding Plan L-93-034, Submits 30 Day Rept of 930804 Criticality Alarm Sys Inoperability.Caused by Tripped Circuit Breaker Due to Inadvertent Circuit Overload.Circuits Walked Down & Checked by Electrician1993-09-0303 September 1993 Submits 30 Day Rept of 930804 Criticality Alarm Sys Inoperability.Caused by Tripped Circuit Breaker Due to Inadvertent Circuit Overload.Circuits Walked Down & Checked by Electrician L-93-033, Proposes Extension Until 931102 for Response to NRC 930802 RAI Re Decommissioning Funding Plan Submitted on 9207021993-08-26026 August 1993 Proposes Extension Until 931102 for Response to NRC 930802 RAI Re Decommissioning Funding Plan Submitted on 920702 L-93-032, Requests Changes to Windsor Low Level Radioactive Storage Amend Ltrs & 1223 Re Interim Storage of Low Level Radwaste1993-08-20020 August 1993 Requests Changes to Windsor Low Level Radioactive Storage Amend Ltrs & 1223 Re Interim Storage of Low Level Radwaste ML20056G7481993-08-11011 August 1993 Advises That 930628 Changes to Physical Security Plan, Consistent W/Provisions of 10CFR70.32(e) & Acceptable for Inclusion Into Plan ML20056D6861993-08-10010 August 1993 Forwards Amend 26 to License SNM-1067 & Ser.Amend Authorizes Revs to Emergency Plan,Per 910627 Application & Suppl ML20056C3191993-05-0606 May 1993 Responds to 930218 & 0423 Ltrs Re Revs 5 & 6 to Physical Security Plan for Protection of Special Nuclear Matl of Low Strategic Significance.Changes Consistent W/Provisions of 10CFR70.32(e) & Acceptable ML20056H6261993-03-19019 March 1993 Transmits Current CEOG Generic Accident Mgt Guidelines Rev O Documents ML20128M3951993-02-16016 February 1993 Ack Receipt of Informing of C-E Intent to Change Date for Submitting Decommissioning Plan from 921230 to 930330 ML20128G1941993-02-0505 February 1993 Accepts Changes to FNMCP Submitted by Ltrs & 0204 L-93-004, Discusses Encl Proposed Amend to Windsor Fundamental Nuclear Matl Control Plan.W/O Encl1993-02-0202 February 1993 Discusses Encl Proposed Amend to Windsor Fundamental Nuclear Matl Control Plan.W/O Encl L-93-005, Informs That Windsor Decommissioning Plan Will Be Submitted to NRC by 9303311993-02-0101 February 1993 Informs That Windsor Decommissioning Plan Will Be Submitted to NRC by 930331 ML20127H3191993-01-0404 January 1993 Forwards Insp Rept 70-1100/92-202 on 921207-10.One non-cited Violation Noted L-93-001, Advises That Draft Decommissioning Funding Plan in Final Stages of Internal Review & Expected to Be Submitted in Next Few Wks.Licensee Stated That Funding Plan Would Be Submitted by End of 19921993-01-0404 January 1993 Advises That Draft Decommissioning Funding Plan in Final Stages of Internal Review & Expected to Be Submitted in Next Few Wks.Licensee Stated That Funding Plan Would Be Submitted by End of 1992 1999-08-12
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20210T9861999-08-12012 August 1999 Forwards Amend 7 to License SNM-1067,changing Name of License to Abb Combustion Engineering Nuclear Power & Incorporating Into License Date of 990618 for Decommissioning Financial Assurance.Ser,Encl ML20196J1571998-12-0202 December 1998 Forwards Insp Rept 70-1100/98-01 on 981116-18.No Violations Noted.Insp Consisted of Selective Exams of Procedures & Representative Records,Interviews with Personnel & Observations by Inspector ML20198A9731997-12-10010 December 1997 Forwards Insp Rept 70-1100/97-02 on 971118-20.No Violations Noted.Licensee Maintained Effective Control of Radioactive Matl in Storage & Control of Facility Activities to Maintain Worker Radiation Protection ML20198R0191997-10-29029 October 1997 Forwards Amend 5 to License SNM-1067 & Ser,Including Categorical Exclusion Determination.Amend Removes Bldg 21 & Immediate Environs as Authorized Place for Use of Licensed Matl.License Conditions 6.B,7.B & 8.B,deleted ML20211H7711997-09-30030 September 1997 Forwards Amend 4 to License SNM-1067,deleting Listed Authorized Possession Limits,Ref to All Bldgs Except Bldg 21 & Authorization for All Activities Except Those Related to Decommissioning of Bldg 21 ML20140G6601997-06-10010 June 1997 Forwards Insp Rept 70-1100/97-01 on 970414-17.No Violations Noted.Within Scope of Insp,No Radioactive Contamination or Radiation Levels Above Background Were Measured ML20137D9361997-03-21021 March 1997 Responds to Requesting FY97 Annual Fee for License SNM-1067 Be Assessed Pursuant to Fee Category 14 Rather than Any Other Category.Nrc Agrees That License SNM-1067 Not Subj to Annual Fees for FY97 ML20133A9251996-12-24024 December 1996 Forwards Amend 3 to License SNM-1067 & Safety Evaluation Extending Interim Storage Period of Packaged low-level Radwaste from 5 to 10 Yrs ML20132D8131996-12-17017 December 1996 Forwards Amend 2 to License SNM-1067 by Including Methods for Determination of Action Levels for Environ Monitoring Data.Ser Attached ML20135F7471996-12-10010 December 1996 Informs That Mf Weber Branch Chief for Fuel Cyle Licensing Branch,Effective 961118 ML20135E9681996-12-0404 December 1996 Forwards Insp Rept 70-1100/96-02 on 961118-21.No Violations Noted ML20149L7391996-11-0808 November 1996 Informs of Addl Info Needed Before Final Action Can Be Taken on Request for Amend to Delete Windsor Lab Bldgs & Operations,Reduce SNM Possession Limits & Delay Decommissioning Underway on Bldg 17 ML20128P3991996-10-15015 October 1996 Ack Receipt of Ltr Dtd 960930,requesting Elimination of Annual License Fees ML20129A7001996-07-29029 July 1996 Forwards NRC Comments on DOE Draft Rept, Derivation of Guidelines for Cobalt-60,Ni-63 & U Residual Radioactive Matl in Soil at Combustion Engineering Site,Windsor,Ct. Submitted Per 960322 Request ML20059M9231993-11-18018 November 1993 Forwards Insp Rept 70-1100/93-201 on 931025-29 & Notice of Violation.Details of Insp Rept & Notice of Violation Withheld,Per 10CFR2.790(d) ML20059C3661993-10-29029 October 1993 Forwards Amend 28 to License SNM-1067 & Ser.Amend Decreases Possession Limits & Removes Authorization to Conduct U Bearing Nuclear Fuel Mfg Operations at Facility ML20059C1801993-10-23023 October 1993 Forwards Insp Rept 70-1100/93-03 on 930915-17.No Violations Noted ML20057C9881993-09-29029 September 1993 Forwards List of Personnel to Be Granted Unescorted Access to Facility ML20057B8921993-09-23023 September 1993 Accepts Proposed Date of 931008 Re NRC Bulletin 91-001,Suppl 1 ML20057C2111993-09-23023 September 1993 Ack Receipt of 930915 Notification of Decision to Terminate, by 930930,commercial Nuclear Fuel Mfg Operations at Windsor Facility.Understands That C-E Plans to Submit Amend Request Reflecting Listed Changes in Sept 1993 ML20057A7571993-09-14014 September 1993 Accepts Proposed New Date for Submitting Addl Info Re Decommissioning Funding Plan ML20056G7481993-08-11011 August 1993 Advises That 930628 Changes to Physical Security Plan, Consistent W/Provisions of 10CFR70.32(e) & Acceptable for Inclusion Into Plan ML20056D6861993-08-10010 August 1993 Forwards Amend 26 to License SNM-1067 & Ser.Amend Authorizes Revs to Emergency Plan,Per 910627 Application & Suppl ML20056C3191993-05-0606 May 1993 Responds to 930218 & 0423 Ltrs Re Revs 5 & 6 to Physical Security Plan for Protection of Special Nuclear Matl of Low Strategic Significance.Changes Consistent W/Provisions of 10CFR70.32(e) & Acceptable ML20128M3951993-02-16016 February 1993 Ack Receipt of Informing of C-E Intent to Change Date for Submitting Decommissioning Plan from 921230 to 930330 ML20128G1941993-02-0505 February 1993 Accepts Changes to FNMCP Submitted by Ltrs & 0204 ML20127H3191993-01-0404 January 1993 Forwards Insp Rept 70-1100/92-202 on 921207-10.One non-cited Violation Noted ML20126L2741992-12-30030 December 1992 Forwards Insp Rept 70-1100/92-03 on 921116-1201.Ability to Implement EP & EPIPs in Manner That Would Provide Adequate Protective Measures for Health & Safety of Public Demonstrated ML20126J1251992-12-17017 December 1992 Responds to 921119 Request for Exemption from Payment of Annual Fees for Two LEU Fuel Mfg Licenses.Request for Exemption & Base to Annual Fee on Fuel Fabrication Capacity, Denied ML20126A6021992-12-17017 December 1992 Forwards Amend 25 to License SNM-1967,SER & Categorical Exclusion.Amend Incorporates Changes to Radiological Contingency Plan,Per 920903 Application & Suppl ML20062G5211990-11-16016 November 1990 Forwards Insp Rept 70-1100/90-202 on 900806-10.No Violations or Deviations Noted.Rept Withheld (Ref 10CFR2.790(d)) ML20058F3531990-10-31031 October 1990 Forwards Summary of E Scherer 900924 & E Tenerz & H Thornburg 900925 drop-in Visits to Region I ML20059N8221990-10-0101 October 1990 Ack Receipt of Re Violations Noted in Insp Rept 70-1100/90-06 ML20059N2551990-09-28028 September 1990 Offers No Objection to Interior Const in Fuel Mfg Facility to Accommodate New Fuel Pellet & Rod Handling Equipment ML20058M5631990-08-0909 August 1990 Forwards Amend 18 to License SNM-1067,authorizing Mod of Ventilation Sys in Nuclear Fuel Mfg Facility & SER ML20058L3501990-08-0101 August 1990 Revises Amend SG-3 to License SNM-1067 Re Chapters 1.0-8.0 of FNMCP ,per Util 900608 Submittal of Revs to FNMCP ML20058M3931990-08-0101 August 1990 Forwards Insp Rept 70-1100/90-06 on 900613-14.Insp Performed to Review Addl Info Provided Re Violations in Insp Rept 70-1100/90-03.Two Violations Noted Withdrawn ML20055J2811990-07-26026 July 1990 Forwards Amend 17 to License SNM-1067,authorizing Organizational Changes,Deleting Condition 30 & Incorporating Revised Section 4.2.4A, Moderation Control. Safety Evaluation Also Encl ML20055H2371990-07-20020 July 1990 Forwards Safety Insp Rept 70-1100/90-05 on 900604-08 & Notice of Violation ML20059C0541990-07-19019 July 1990 Forwards SALP Rept 70-1100/88-99 on Jul 1988 - Mar 1990. Public Meeting Scheduled to Discuss Assessment.Licensee Should Be Prepared to Discuss Plans to Improve Performance ML20055C7181990-06-14014 June 1990 Forwards Insp Rept 70-1100/90-201 on 900507-10 & Notice of Violation ML20248H8671989-10-0404 October 1989 Forwards Amend 15 to License SNM-1067,adding Conditions 30 & 31 Re Production Manager & Emergency Director Having Bachelor Degrees,Terminating Conditions 11 & 12,deleting Conditions 28 & 29 & Correcting Typos in 9,20 & 22 ML20248J2621989-10-0303 October 1989 Forwards Insp Rept 70-1100/89-06 on 890823.No Violations Noted.No Evidence Found to Substantiate Alleged Improper Disposal or Storage of Radwaste at Either Site ML20248J2481989-10-0202 October 1989 Forwards Insp Rept 70-1100/89-80 on 890828-29 & 0905-08 & Notice of Violation.Licensee Should Be Prepared to Discuss Areas of Nuclear Fuel Integrated Improvement Program at 891005 Meeting ML20246H4241989-08-22022 August 1989 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1100/89-01 ML20246D9881989-08-16016 August 1989 Forwards Insp Rept 70-1100/89-04 on 890717-21 & Notice of Violation ML20247N3991989-07-25025 July 1989 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1100/89-01. Actions to Assure B-25 Waste Boxes Sealed to Preclude Possible Spread of Contamination Appear Inadequate ML20247A0071989-07-14014 July 1989 Responds to AB Scherer Re 890511 Notice of Violation,Per Insp 70-1100/89-200.Not Clear Why Eight Subparts of MFG-16-15xx Signed & Dtd & Five Not.Notice of Violation Withdrawn ML20246J1061989-07-12012 July 1989 Forwards Comments Re Review of 890420 Updated Rev 4 to Physical Security Plan,Entitled Physical Security Plan for Protection of SNM of Low Strategic Significance Used within Bldgs 5/17/21. Encl Withheld ML20246K0501989-07-0707 July 1989 Forwards Mgt Meeting Rept on 890627.Historical Info Provided Re Status of Completion of Facility Mods & Programmatic Upgrades at Facility Informative & Useful 1999-08-12
[Table view] |
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~ - ..
July 29, 1996 Dr. W. Alexander Williams EM-421 Cloverleaf Building U.S. Department of Energy
- 19901 Germantown Road Germantown, Maryland 20874-1290
SUBJECT:
' DOE DRAFT S0ll CLEANUP GUIDELINES i
Dear Dr. Williams:
l This is in response to your letter of March 22, 1996, requesting NRC comments on DOE's draft report entitled, " Derivation of Guidelines for Cobalt-60, Nickel-63, and Uranium Residual Radioactive Material in Soil at the Combustion Engineering Site, Windsor, Connecticut." This report was prepared by Argonne l National Laboratory for remedial action as a part of the Formerly Utilized i Site Remedial Action Program. The NRC staff has reviewed this document and ;
our comments are enclosed.
I The DOE draft report presented approaches and methods, in derivation of radionuclide soil guidelines, similar to those used by the NRC in !
decommissioning and cleanup activities of the Site Decommissioning Management .
Plan sites. However, in this report DOE has adopted different dose criteria '
from those used by NRC, and selected incomparable exposure pathways, scenario l parameters, and site physical parameters. These differences could result in significantly less conservative dose limits.
If you have any question on this matter, please call Mr. Sean Soong of my staff at (301) 415-8155.
Sincerely, Original signed by:
Robert C. Pierson, Chief itcensing Branch Givision of Fuel Cycle Safety and Safeguards, NMSS
Enclosure:
As stated Distribution: w/ encl..
NRC File Center ()cdtti) NMSS R/F FCSS R/F FCLB R/F
[G:\ltrdoe.ss] v N' PUBLIC
- See previous concurrence OFC FCLB* 2E FCLB* E FCLB* E ef ,
NAME SSoong PShea MTokar RPiers El DATE 7/24/96 7/24/96 7/24/96 1/14 %
C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY .-
16 QQ 7f; b.
9609190023 960729 i DR ADOCK 0700 0 HETURIl TO RE LE
cea reru
- ,y i UNITED STATES j j NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20066 0001 o
% ..,+ / July 29, 1996 Dr. W. Alexander Williams EM-421 Cloverleaf Building U.S. Department of Energy 19901 Germantown Road Germantown, Maryland 20874-1290
SUBJECT:
DOE DRAFT SOIL CLEANUP GUIDELINES
Dear Dr. Williams:
This is in response to your letter of March 22, 1996, requesting NRC comments on DOE's draft report entitled, " Derivation of Guidelines for Cobalt-60, i Nickel-63, and Uranium Residual Radioactive Material in Soil at the Combustion Engineering Site, Windsor, Connecticut." This report was prepared by Argonne I National Laboratory for remedial action as a part of the Formerly Utilized l Site Remedial-Action Program. The NRC staff has reviewed this document and our comments are enclosed.
The DOE draft report presented approaches and methods, in derivation of radionuclide soil guidelines, similar to those used by the NRC in decommissioning and cleanup activities of the Site Decommissioning Management Plan sites. However, in this report DOE has adopted different dose criteria from those used by NRC, and selected incomparable exposure pathways, scenario parameters, and site physical parameters. These differences could result in significantly less conservative dose limits.
If you have any question on this matter, please call Mr. Sean Soong of my staff at (301) 415-8155.
Sincerely,
( '
Robert C. Pierson, Chief Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS
Enclosure:
As stated
4 NRC Comments on DOE's Draft Report Entitled,
" Derivation of Guidelines for Cobalt-60, Nickel-63, and Uranium Residual Radioactive Material in Soil at the Combustion Engineering Site, Windsor, Conneticut" l
Background:
The U.S. Department of Energy (DOE) designated a portion of the Combustion Engineering Inc. (CE), Windsor, Connecticut, site for remedial action as a l part of the Formerly Utilized Sites Remedial Action Program (FUSRAP). That portion of the site was used previously for production of high-enriched uranium fuel and is currently under DOE's jurisdiction. Other portions of the CE site were used for commercial nuclear activities and are currently licensed by the U.S. Nuclear Regulatory Commission (NRC). ,
l Prior to developing its remedial action plan, DOE typically establishes soil cleanup guidelines for FUSRAP sites as an initial step. Pursuant to DOE Order 5400.5., Chapter IV, DOE uses the Residual Radioactivity (RESRAD) computer code to determine soil cleanup guidelines for FUSRAP sites.
DOE sponsored a study by Argonne National Laboratory (ANL) on derivation of )
soil guidelines for Co-60, Ni-63, and uranium (natural / enriched) radionuclides at the CE site. In this study, ANL employed RESRAD code to derive soil ,
guidelines using three different scenarios. ANL reported the results of the i study in a draft technical report entitled, " Derivation of Guidelines for !
Cobalt-60, Nickel-63, and Uranium Residual Radioactive Material in Soil at the i Combustion Engineering Site, Windsor, Connecticut."
DOE requested NRC (in a letter dated March 22,1996) to provide comments on ;
ANL's draft report. DOE stated in its letter that "it is possible that the i draft guideline report might be useful to NRC in addressing regulatory issues i at the site." In other words, DOE contemplated a possible use of the ANL :
report in establishing residual activity guidelines for the NRC's licensed portions of CE site.
This report presents a brief comparative outline of NRC's approach in developing site specific guidelines versus DOE's approach. It also provides staff comments on the draft ANL document regarding the use of multiple scenarios and RESRAD analysis in derivation of guidelines for Co-60, Ni-63, and U in soil at the CE site.
i 1
Enclosure
- i
, 2 General Comments:
l 1. Similarities Between NRC and ANL Approaches Employed In Derivation of )
Soil Activity Guidelines: j
\
Currently, NRC uses interim radionuclide residual soil contamination l 3
limits (e.g, soil activity concentration pCi/g) from existing guidance j i documents to demonstrate adequacy of site decommissioning actions. In some situations, however, the residual soil contamination limits for certain radionuclides have not been established yet.
In other situations, an NRC licensee may attempt to justify alternate criteria (above or below the existing interim criteria) on the basis of ,
"as low as is reasonably achievable" (ALARA) or on the basis of a unique j site-specific condition. The NRC staff commonly evaluates the acceptability of alternate residual contamination levels in such situations by considering potential doses to individuals from exposure to the contamination. In this context, NRC staff commonly uses the exposure scenarios in Policy and Guidance Directive P&GD-8.08 (NRC, 1994) that are applicable to the site. Subsequently, the staff conducts pathway analysis and dose impact assessment to derive soil concentration '
l limits. The derived soil concentration limits are typically based on a peak annual dose to an average member of the exposed critical group at l the specific site. The critical group typically has a life style and !
diet habits compatible with the selected scenario. The annual peak dose i is evaluated over a period of 1000 years after waste placement. In most l cases, the derived guideline peak dose, for unrestricted use, represents l a small fraction of the public dose limit in 10 CFR 20.1301 '
(e.g., 10 mrem /y). NRC staff commonly uses several dose assessment codes in its risk impact analysis.
1 The RESRAD code is one of the
< computer codes frequently used in dose assessment and in derivation of soil concentration limits.
'f I
l The draft ANL report presented generic approaches for establishing soil residual activity guidelines at the CE site similar to those approaches !
commonly used in developing residual soil contamination limits for NRC sites listed under the Site Decommissioning Management Plan (SDMP). The similar approaches included the following aspects:
(a) The use of dose impact analysis is based on specific scenarios applicable to the site. For example, the ANL study employed dose assessment exposure scenarios A (industrial worker), B (resident),
and C (subsistence farmer), in a similar fashion to NRC staff use of scenarios A, B, and C listed in P&GD-8.08.
(b) The ANL study used the RESRAD code in a dose impact assessment and in derivation of soil guidelines at the CE site. This approach is j i similar to current NRC staff practices of using the RESRSAD code in the dose impact analysis and in the derivation of alternate interim soil guidelines for decommissioning sites. Further, ANL used the peak dose over a period of 1000 years to derive soil guidelines which is similar to NRC's current decommissioning practice.
i
1 i
3 Based on the above discussion, the generic ANL approach (e.g., with !
respect to use of scenarios, pathway analysis, peak dose in 1000 years, and the use of the RESRAD code) is in harmony with NRC's common approaches and practices used in decommissioning.
~
- 2. Inconsistencies With NRC's Dose Analysis and Derivation of Guidelines: l Although the generic scenario and dose assessment approach outlined in )
the ANL report appear to be consistent with those of NRC, there are ,
significant differences between the ANL and NRC approaches. These i differences include the following aspects: i (a) Selection of the dose limit: The dose limits selected by ANL l (e.g., 30 mres/y for scenarios A and B and 100 mres/y for scenario l C) are inconsistent with current NRC dose criteria for the unrestricted site release (e.g., a significant fraction of the public dose limit, in 10 CFR 20.1301, which is approximately 10 mrem /y).
(b) Selection of multiple scenarios for the site: NRC staff commonly selects the " residential farmer scenario" for derivation of soil-activity guidelines under the unrestricted site release conditions. I In the case of a licensee's request for exemption from the unrestricted site release criteria, the staff may select an alternative scenario based on the type of restrictions to be imposed upon site release. Therefore, typically, a scenario is selected which is applicable to site specific conditions and to future land use. The dose assessment and pathway analysis are typically performed based on the applicable scenario using site specific
{ conditions. Certain environmental pathways might be eliminated when selecting the applicable scenario. However, the estimated dose to
! the public, using the applicable scenario, still remains a small i fraction of NRC's public dose limit (e.g., approximately 10 mrem /y).
j In some cases selection of soil activity guidelines may be dependent i
on cost / risk analysis. For example, if the cost of cleanup is
- prohibitive, compared to the potential risk, the staff may select an !
l alternate scenario for the remedial action. In such a case, the i site may be qualified for an exemption from the unrestricted release
{ criteria. Subsequently, the site may go through the National l
! Environment Policy Act process for selection of an appropriate l decommissioning alternative.
) In its dose impact analysis, ANL selected scenarios A, B, and C.
ANL reported that scenarios A (Industrial Worker), and B (Resident, i without water use) were selected because they are consistent with
- the current land use and are likely future use scenarios. The ANL report indicated that scenario C is a less likely scenario; however, the report emphasized that it is a plausible future scenario. As was indicated above, ANL selected two dose limits (e.g., 30 mrem /y for scenarios A and B and 100 mrem /y for scenario C) for the same L site. Thus, ANL selection of more than one dose limit may not be i consistent with the current NRC approach for decommissioning. Staff i
4 suggests that DOE should select a prudently conservative scenario based on analysis of an exposed critical group which is consistent with the site specific conditions and its surrounding environs.
(c) Scenario Pathways: The applicable exposure pathways selected by ANL for scenario A and B are inconsistent with NRC's scenario A and B of P&GO-8.08. Under scenario A, the NRC accounted for three pathways, external exposure, inhalation, and radon. ANL's A scenario, however, accounted for a soil ingestion pathway in addition to the three pathways listed under NRC's A scenario. Concerning scenario 8, the NRC accounted for three more pathways (e.g., water ingestion, vegetable ingestion, and soil ingestion) in addition to those pathways listed in NRC's scenario A. ANL, however, included only plant ingestion, and fish ingestion pathways, in addition to the four exposure pathways listed under its A scenario. Therefore, it is apparent that there is a lack of consistency between NRC and ANL in-selecting exposure pathways. The lack of inconsistency could result in significant differences in dose calculations.
(d) Scenario' Parameters: The ANL scenario parameters associated with the critical group life style, dietary habits, and site default values are different from those of NRC's. For example, the NRC considered the outdoor time fraction for scenarios A, B, and C, respectively, as five percent, 10 percent, and 21 percent. ANL however, considered outdoor time fractions for A, B, and C scenarios as six percent, 25 percent, and 25 percent respectively. NRC's indoor shielding factor was selected 33 percent whereas the ANL's shielding factor was selected 70 percent. The fraction of diet (e.g.,
vegetables, grains, and fruits) for NRC's scenarios B and C were selected 25 percent and 50 percent, respectively, whereas ANL's fractions of diet were approximately, 10 percent and 50 percent, respectively. Selection of physical parameters such as soil density, distribution coefficients, porosity, and hydraulic i
conductivity were also different. These differences in scenario
! physical parameters would also result in significant differences in i the estimated doses.
- Specific Comments:
l
! 1. Non-Conservative Selection of Erosion Rate:
l j The ANL source term model assumed having no cover above the contaminated i zone. In addition, the model assumed no surface erosion activity exists
- at the site-(e.g., zero surface erosion rate). This assumption is not
- technically defensible and non-conservative. The zero erosion rate assumption is non-conservative because it elf ninates dust inhalation pathways and subsequently reduces the dose impacts in scenarios A and B.
ANL should adopt a defensible and conservative assumption regarding the source term erosion conditions.
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- 2. Distribution Coefficient: j ANL reported uranium distribution coefficients (K g 's) at the CE site in the range of 82 to 59,000. ANL selected the maximum Kg value U .e. , l 59,000) representing the average site specific condition. ANL l contemplated that such a value, based on sensitivity analysis, would result in more restrictive (conservative) guidelines. It should be noted that this assumption may be true for scenarios A and B because ANL 1 disregarded groundwater pathways for these two scenarios. For scenario 1
C, however, the high Kg value would tend to lower radionuclide releases and hence underestimate doses associated with drinking water and food ingestion pathways. The RESRAD manual listed typical uranium Kd values for different soils (Yu et. al. 1993). These values were in the range of 11 to 4,400, with a geometric mean of 45. Most Kg values for clay soils were in the range of 270 to 4,400. ANL indicated in its draft document that the soil type at the CE site is a sandy loam. Sandy soil is expected to have less radionuclide retention in the solid phase than clay soil. Based on the above discussion, ANL should review Table 6 data in the draft report and conduct a dose impact sensitivity analysis based on conservative Kd values accounting for the groundwater pathways for scenarios B and C.
- 3. The Derived Radionuclide Guidelines for the CE Site:
ANL listed in Table 7 the derived residual radioactive material guidelines for the CE site. These guidelines are inconsistent and less restrictive than NRC's interim guidelines and the NRC's proposed decommissioning guidelines (based on NUREG-1500 dose conversion factors). For example, the interim NRC guidelines for residual uranium (natural) in soil is 10 pCi/g for option 1 and 40 pCi/g for option 2.
ANL derived guidelines were 700, 210, and 560 pCi/g, for scenarios A, B, and C, respectively. The proposed NRC's soil concentrations (pCi/g) corresponding to a total dose of 15 mrem /y were listed in NUREG-1500 as 22.1 pCi/g for the drinking water scenario (e.g., similar to l P&GD-8.08 scenario B) and 19.3 pCi/g for the residential scenario (e.g.,
similar to PG-8.08 Scenario C). Comparison of NRC's interim and proposed soil guidelines with those of ANL indicates a sigriificant difference between these two guidelines. Further, NRC staff conducted dose impact assessments using the RESRAD code for calculation of uranium residual activity (corresponding to 10 mrem /y) for unrestricted site release. In most cases, uranium soil guidelines, necessary to meet NRC levels for unrestricted release, were determined to be in the range of 10 to 20 pCi/g. Considering the " dose to source-concentration" ratio derived by ANL, it appears that the ANL dose assessment is significantly less conservative than NRC's. This may be related to the non-conservative ANL approach in selecting exposure pathways for each scenario and to the non-conservative parameters selected for the site.
Therefore, NRC staff suggests that ANL revise the selection of the exposure pathways and the associated life-style, and physical parameters employed in the dose assessment.
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Conclusions:
l The draft ANL report presented approaches and methods, in derivation of radionuclide soil guidelines, similar to those adopted by NRC in decommissioning and cleanup activities of SDMP sites. In this context, ANL employed scenarios and codes similar to those used by NRC and selected a compliance time period which was identical to that used by NRC. However, ANL selected dose criteria, exposure pathways, scenario parameters, and site specific physical parameters that were inconsistent with those commonly used by NRC staff. Due to these inconsistencies the ANL derived guidelines are not directly comparable to NRC's cleanup guidelines for decommissioning of sites with residual soil contamination.
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