ML18212A329
| ML18212A329 | |
| Person / Time | |
|---|---|
| Site: | 04008903 |
| Issue date: | 07/31/2018 |
| From: | Whited J A NRC/NMSS/DDUWP/MDB |
| To: | Wohlford T Homestake Mining Co of California |
| JWhited 301-415-4090 | |
| References | |
| EA-16-114 | |
| Download: ML18212A329 (3) | |
Text
From: Whited, Jeffrey To: "Wohlford, Tom"
Subject:
RE: NRC DRAFT RAI-Land Application Areas Date: Tuesday, July 31, 2018 4:16:00 PM Attachments:
Homestake DRAFT Land Application RAIs.pdf Mr. Wohlford, By letter dated July 2, 2018, the Homestake Mining Company of California (HMC) submitted its Final Status Survey Report for the land application areas as required by Conditions 14 and 15 of the U.S. Nuclear Regulatory Commission (NRC) Confirmatory Order (EA-16-114) that was issued by letter dated March 28, 2017.
After a review of the Final Status Survey and following conversations with HMC, the NRC staff determined that the attached additional information request is necessary to complete its review.
The RAIs are attached in DRAFT form. Please review these RAIs and let me know if you would like to hold a clarification call with the NRC to ensure the RAIs are clear, the responses to the questions aren't readily available, and that the information hasn't previously been docketed. Following this discussion I will issue a letter providing the RAIs.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this e-mail and its attachment will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRC's document system ADAMS.
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Please contact me with any questions or concerns.
Sincerely, Jeffrey Whited Project Manager Materials Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission (301)415-4090 jeffrey.whited@nrc.gov
REQUEST FOR ADDITIONAL INFORMATION HOMESTAKE MINING COMPANY OF CALIFORNIA REVIEW OF FINAL STATUS SURVEY FOR THE LAND APPLICATION AREAS Docket Number: 040
-08903 License Number
- SUA 1471 Confirmatory Order: EA 114 By letter dated September 25, 2017, 1 the Homestake Mining Company of California (HMC, the licensee) submitted its Land Application Report as required by Conditions 14 and 15 of the U.S. Nuclear Regulatory Commission (NRC) Confirmatory Order EA 114 that was issued by letter dated March 28, 2017.
2 In this letter, HMC detailed the impact assessment of its Land Application Program, which involved irrigating areas ranging from 100 to 394 acres with water containing elevated levels of groundwater constituents between 2000 and 2012. By letter dated November 14, 2017, 3 HMC submitted its Final Status Survey Plan for release of the former land application areas. This letter provided the NRC with the detailed plans of HMC's Final Status Survey. By letter dated July 2, 2018, 4 HMC submitted the results of its Final Status Survey.
During its review, the NRC staff noted that in the licensee's letter dated December 31, 2014, 5 HMC provided details on the closure plan for the land application areas for the State of New Mexico to review. Section 3.1, Irrigation Equipment, of the report attached to the above stated letter notes that the HMC plans to dismantle the equipment used in the irrigation areas and remove it in accordance with HMC's NR C License Conditions. Additionally, this section notes that a survey plan to assess the presence of contaminated materials will be written in accordance with HMC procedures so as to ensure the equipment can be dispositioned appropriately.
No details regarding the above mentioned procedure s were noted in the Final Status Survey Plan or the Final Status Survey Report. During conversations, the NRC staff asked HMC how the pipes within these areas were dispositioned. HMC stated that
, as shown in Memorandum dated June 16, 2017, 6 some pipes remain in the land application areas associated with the Land Application Program. 1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML17270A066.
2 ADAMS Accession No. ML17061A455.
3 ADAMS Accession No. ML17321A075.
4 ADAMS Accession No. ML18186A577.
5 ADAMS Accession No. ML15006A082.
6 ADAMS Accession No. ML17328A507.
While the pictures in the above referenced memorandum show pipes associated with the Land Application Program, the memorandum does not specifically note the status of these pipes. Additionally, no details on any conducted surveys were provided.
After a review of these documents and following conversations with HMC, the NRC staff determined that the requests for additional information (RAIs) below are necessary to complete its detailed technical review.
Technical Basis for RAIs Condition 14 of the Confirmatory Order requires the licensee to demonstrate that discharge of byproduct material did not impact and will not impact members of the public or the environment. To ensure that no additional impacts need to be considered, the NRC staff needs to understand the current status of the equipment associated with the Land Application Program, which may contain byproduct material.
RAI 1 Please provide information regarding the disposition of the pipes associated with the Land Application Program. Specifically, verify where the pipes associated with the Land Application Program are currently stored. RAI 2 Please provide any details regarding any surveys of the pipes currently in place or following removal from the land application areas. RAI 3 Please provide any details regarding any surveys of the soil around the pipes associated with the Land Application Program. RAI 4 The NRC staff additionally notes that, as can be observed in the pictures in the Memorandum, the center pivot irrigation equipment appears to still remain on the land application areas. The NRC cannot complete its review of Conditions 14 and 15 of the Confirmatory Order until this equipment, and all pipes associated with the Land Application Program, are removed. Please provide the details regarding the disposition of the center pivot irrigation equipment.