ML19093A132

Enclosure 3 - Draft Response to RAI NP-2.6-x with SAR Markups

ML19093A132
Person / Time
Site:	Consolidated Interim Storage Facility
Issue date:	04/01/2019
From:	Consolidated Interim Storage Facility
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML19093A183	List: ML19093A128 ML19093A129 ML19093A132 ML19093A134
References
E-53940
Download: ML19093A132 (43)

Text

Enclosure 3 Draft Response to RAI NP-2.6-x with SAR Markups

RAls and Responses Enclosure X to E-XXXX RAI NP-2.6-1:

Clarify the origin of the circular features as identified in the red circles on Figure 2-3 elow.

Specifically, provide the dimensions of the features and determine whether they

• gh epresent surface deformation at the site due to subsurface dissolution resulting from past or ongoing natural processes or human activities in the site area, as mentioned in WCS IS SAR Section 2.6.1. Also, discuss the potential for similar features to develop at the site *n the future.

This information is needed to determine compliance wit 72.103(f)(2)(ii).

WCS Coosolidot<d lntcrun Storng< F*oliry S.foy An.,IJ"l, Flgtu*e 2-3 Proposed WCS C'ISF 1-tnUe Radius Pag< 2-54 Page 11 of 119

RAls and Responses Enclosure X to E-XXXX Response to RAI NP-2.6-1:

Small circular features in SAR Figure 2-3 began as small erosional depressions on the land surface. These depressions accumulated water, which variably dissolved surficial o near-surface pedogenic calcrete and carbonate. This process enlarged the depr accumulated sediment as the calcretewas dissolved. They are surficial ands collapse and subsidence that would indicate dissolution of the much deeper formations. Analysis of cores and geophysical logs reveal no evidence of dissolution of evaporites that would lead to such collapse. There is no activities initiated these depressions. These features are unrelated and extraction activities in the site area, s discussed belo. The depressions ranges from a few hundred feet to more than 1000 localized features appear to reach a depth of 10 ft. Studies are thousands to tens of thousands of years old and older features will form naturally at the site of the WCS CISF

• Relationship of Features. The features enclosed by t belong to the set of "oriented drainage and depressions confused with the "Ogallala Aquifer," the saturated portion Bachman (1973b [2]). Bachman (1973a [1], 1976 [3]) also re features," "aligned swales and dolines,"

ned drainage."

p. 9 and p. 47 (16]) also use the term "

" because o depressions originated due to the action cally in Texas near the Specia 1

[C site ed small depressions are most prominent re NP-2.6-2-1), smaller areas of pedogenic f the rv'lescalero Ridge, and locally as well at photo from the NAPP 1996 series (Figure es that have been outlined in red in at the Waste o rol Specialists site and WCS CISF is more P aerial photo (Figure NP-2.6-2-2), although swales or aligned t the Waste Control Specialists site and WCS CISF than in some rv'lexico. The smaller depressions are apparently more

("rv'lescalero caliche" or Ogallala "caprock") are at or close i ations. Havens (1966 [7]) reviewed prior discussion of the features the fill of some of the depressions in northern Lea County, New rv'lexico e circle). Havens (op. cit.) found that the pedogenic calcrete (Ogallala as variably affected. Havens discounted deep dissolution, noting (p. F7) ed depressions along rv'lescalero Ridge, however, have no features that if irregular bedding or solution and collapse were the cause of the alinement (sic) of the ressions. Bedding appears to be horizontally continuous, and no rubble zone or recemented rubble is evident beneath the depressions."

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RAls and Responses Enclosure X to E-XXXX Bachman (1973a [1], 1973b [2]; 1976 [3]) also reviews earlier work related to these features, mainly for New Mexico. Bachman generally favors the hypothesis that the depressions and aligned swales formed between longitudinal dunes that are no longer present.

Osterkamp and Wood (1987 [18]) and Wood and Osterkamp (1987 [24]) concluded tn. t shallow depressions or playas on the southern High Plains developed where water could c llect in shallow depressions. They proposed (simplified version) that small depress*ons were initiated by erosion (Wood, 2002 [25]). Water, dissolved/colloidal and fine-grained rganl materials, and clays accumulated in the depression. Recharging ground water tr SQ ft o ganics and clay into the unsaturated zone. Carbon dioxide, from oxidation of organics, diss v i water to form carbonic acid that dissolved the pedogenic calcrete. Voids d pipes develop in t e calcrete that promote further influx. Drainage areas locally were int grated. When m to the calcrete was dissolved, the sediment load began to fill the ba e of the depression. The ~ya formed by this process provide approximately 90% of the, charge to the underlying High ~lains Aquifer (Wood, 2002 [25]).

fusal" by backhoe and mapped in detail by Holt and Powers r edogenic calcrete exposed in the trench are similar to those Page 13 of 119

RAls and Responses Enclosure X to E-XXXX Nov-shaped fractures were observed in the trench (Holt and Powers, 2007a [9]), and this was agreed to by TCEQ during a trench visit at the conclusion of mapping. There is no evidence that the depressions and aligned drainage at the site were caused by dissolution of underlying evaporites. "Calcrete units exposed within the trench show varying degrees of diss ution, erosion, and redistribution of carbonate. Three generations of sediment-filled sol pipes and macropores formed during and following the development of the calcic soils ex in the trench. Relationships between calcic soils, sediment-filled pipes and macro

, and surficial soils indicate that the lineament has been a topographic low since these

• 1s began to accumulate" (Holt and Powers, 2007a [9], p. 15). These observations with other work showing retrograde or altered pedogenic calcretes (e.g., Have s, 1993

[19]; Holliday etal., 1996 [8]; OsterkampandWood, 1987 [18]), a t

iththe origins and processes described in these studies.

Two other studies, not specific to these depressions and Ii Waste Control Specialists site and area for evidence of These are reviewed in greater detail in the response in RAI 2.6-1.

A specific location near chosen to look for evi core from lower Do Salado (Blainey interval thickn across the site and for Ridge (New Mexico).

ithout evidence of es occur as a part of In a peer-reviewed tion and conclusions aste Control Specialists property was stler or upper Salado by taking continuous tion) across the Rustler and into the upper section for additional details). The istent with the regional evaluation (Holt ve g beds with salt and without salt do not sidence.

ional surface at the top of the red beds (top of Dockum Group rocks)

(Blainey et al., 2009 [4]) does not show deviations that lution of the underlying evaporites and collapse of the overlying of the erosional Dockum surface and mapping in different excavations stent with the observations that these depressions and aligned features d processes such as dissolution of evaporites.

phy of excavations at the Federal and Compact facilities do not reveal op of Dockum surface that is related to dissolution of evaporites at depth.

the license that "fractures and other structural features" would be mapped in both exca ns (Holt et al., 2011 [12]). Near-vertical faces at approximately right angles were mapped at deeper intervals as excavations of these two landfill sites proceeded. TCEQ observed most activities.

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RAls and Responses Enclosure X to E-XXXX The mapping in both excavations showed laterally extensive lithologic beds that could also be grouped vertically as cleJ)ost1ona units. Various sedimentary features were observed that included bedding, bioturbation, and desiccation cracks. Pedogenic features were common.

Arcuate to hummocky slicken-sided surfaces were large and well developed. Thes interpreted as gilgai (Holt et al., 2011 [12], p. 5). Analysis of mapping data (e.g.,

discontinuity orientations) indicated no preferred orientation. The discontinuiti response to local stress fields and not due to larger or regional structural pr features had been observed while mapping the by-product landfill (Kusz No features indicating collapse, which could be related to dissolution o were observed.

Dimensions of Depressions. Most of the small depressions sh at the Waste Control Specialists site are generally somewh dimension of a few hundred feet. The depression where t Powers, 2007a [9]) appears==1470 ft in longest dimens*

intervals (Figure NP-2.6-2-4). The depth is between of a larger area of closed contours. Vegetative chang NP-2.6-2-4) show a long dimension of==630 ft, while Oli longest dimension as 1,050 ft.

Three additional depressions east of th vegetative changes (Figure NP-2.6-2-5 lower right part of SAR Figure 2-3. The (between closed 2-ft contours and based depression is estimated to have long dime Based on closed contours, the depths of th d based on contours and e large red oval in the 72 ft and 312 ft The larger circled are Figure 2-3) has a s circled area has images. The aste Control Specialists property (SAR ns and the southeastern depression in this d on vegetative changes in Google Earth lower end of size ranges estimated by in the southern igh Plains examined by Holliday et al. (1996 Depths are variable. For the smaller and Linear Swales. The evidence compiled by Holliday et at mos he small playas have existed for thousands of years or

[17V examined the age of sand in mainly eolian sediments at Waste rty and found that sand in drainage systems had similar ages to those period of wind erosion between 30,000 and 50,000 years ago. The drainage may have existed for tens of thousands of years or longer.

n general stability to the surfaces at the Waste Control Specialists site ong periods of time.

s that these depressions and aligned drainages \\!\\re formed by surficial processes. There is no evidence consistent with an origin due to dissolution of the underlying salt, a process that might mask the development of a sinkhole until the near-surface materials collapse. There is, therefore, no expectation that these depressions will develop at the site selected for interim storage.

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RAls and Responses Enclosure X to E-XXXX The small depressions at the Waste Control Specialists site are surficial in origin. Geophysical log analysis and continuous core in CP-975 through the Dewey Lake Formation and into the upper Salado Formation show no evidence of thinning of salt beds or fracturing consistent with post-depositional dissolution of the evaporites at the site. Trench and excavation m ping at the Waste Control Specialists site reveal no collapse or subsided sections that w e

consistent with dissolution of the underlying evaporites. Major regional subs id (San Simon Sink and Monument Draw trough) are clearly related to dissoluf evaporites. San Simon Sink is==23 miles west-southwest of the Waste C and Monument Draw trough trends south-southeast from near the sou Sink.

Three of four drillholes within a 1-mile radius of the WCS CISF evaporites have documents showing plug and abandon acti hole, but public records are not available regarding its sta boundary of the WCS CISF. A fifth drillhole (an active Specialists property but outside the 1-mile radius oft enetrate through e fourth is classified is > 3000 ft from the outer Waste Control sest wells have been plugged and abandoned.

rs (2007b [1 O]J investigated the Waste vidence of dissolution of the evaporite sical logs from oil and gas wells, showed olution, and a modest anticline on the splayed by these formations is not idence of deep dissolution within the halite aste Control Spe 1alists site and WCS CISF. The small igure 2-3 are unrelated to dissolution of underlying evaporites (see

[10]) noted that deeply buried halite has internal fluid es lithos

, meaning that the hydraulic gradient is generally outward than inward. The plastic nature of salt also tends to absorb strain and s, dissolution within the bedded halite is difficult under natural e study by Holt and Powers (2007b [1 O]J were published in a al as Holt and Powers (2010 [11]).

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RAls and Responses Enclosure X to E-XXXX The Texas Commission on Environmental Quality (TCEQ) required Waste Control Specialists to

"*.. verify that salt dissolution will not impact the land disposal facility by placing one (1) boring and collecting core samples near the proposed land disposal facility from the lower part of Dockum formation group and into the salt-bearing section of the Salado Formation" Powers, 2008 [21]). TCEQ reviewers found that geophysical logs from the Lockh No. 1 well (API# 30-025-12112; 660 fnl, 660 fel, section 5, T22S, R38E; well is

• were not sufficiently reliable to determine whether dissolution affected this a Waste Control Specialists site. The borehole was plugged and abandone It was agreed that a borehole near the southwest corner of the Was New 1\\/lexico, near southwest corner of section 33, T21 S, R38E) ul rovide ate dissolution in the area of the Waste Control Specialists site (Po

, 2008 [21 ]J, supp the regional study. CP-975 was drilled and cored to determi eds of the Rustler or overlying Dewey Lake Formation showed evidence of dis and subsidence. Neither Dewey Lake nor Rustler beds exhibited fracturing or ot aence of p t-depositional dissolution (Powers, 2008 [21 ]J. Cores of the upper r member niner) were of particular interest as anhydrite overlying the uppermo ured.

n large features where west-southwest of WCS it in some detail. San

. A corehole near the ntering red beds of 1\\/lexic, 1981 [23]). Solution nee and collapse. Alluvial event in the early 20th 973b [2]) also reported thick alluvial fill a narrow zone that is adjacent to the the Monument Draw trough; south of the t Draw swings west and then follows the g et al. (2012 [6]) provided a map of tier (Figure NP-. 7) revealing that this is a major buried to Texas. San Simon Sink and Swale lie near the northern end of est approach to the WCS CISF is approximately the same eview, r nal to local studies do not indicate structural modifications of

• alists site geology related to dissolution of evaporites underlying the ation these processes will affect the proposed WCS CISF location.

n features along the front of the Capitan Reef in New 1\\/lexico are at 20 miles.

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RAls and Responses Enclosure X to E-XXXX Oil and Gas Related Activity (Wells). Six such wells exist within the 1-mile radius of the WCS CISF (Figure NP-2.6-2-8). A producing oil well (42-003-01811) on the Waste Control Specialists site is outside this radius. The two wells in New l\\/1exico have been plugged and abandoned according to on-line records of the Oil Conservation Division (OCD) oft New l\\/1exico Energy, Minerals, and Natural Resources Department. Texas Railroad C (RRC) online records for 42-003-37908 indicate this was a dry hole, and it was abandoned 05/06/2006. Well 43-003-11054 was plugged and abandoned 0 42-003-01812 was plugged and abandoned by Waste Control Specialists under agreement with TCEQ and witnessed by a representative of the records for 42-003-05031 only list this well as a dry hole. Archived r ISP from the RRC for Well 42-003-05031. These records show t t t Sands Humble-Sims #1) was plugged on January 29, 1960.

Since 1980, there have been six collapses and surface si region (see review by Land, 2013 [15]). Three of these JWS, Eddy County, NM; and Loco Hills sinkhole, Ed mining operations. There are no brine-mining wells a CISF.

The nearest sinkhole as CISF. The adjacent behind the casing damaged, appar cavity which c 2, Winkler County, TX) are casing and cement in Ive Permian salt, and al., 2003 [14];

sinks (Wink #2) is sinkhole, =20 miles southwest of the WCS the Capitan aquifer was not cemented tion (Powers, 2003 [20]). The casing was he annulus, dissolving salt and creating a inkhole is approximately 150 ft.

ssions of Sinkholes at CISF. Existing surficial comment are n rally occurring features unrelated to natural ites or creation of sinkholes around drillholes.

ture to the local collapses not due to brine mining, does not

• ts [

facilities or WCS CISF site. All oil and gas wells and radius e WCS CISF have been plugged according to RRC records ct to collapse.

73a, Stability of salt in the Permian salt basin of Kansas, Oklahoma, l\\/1exico: US Geological Survey Open-File Report USGS-4339-4, Denver,

2. Bachman, G.O., 1973b, Surficial features and late Cenozoic history in southeastern New l\\/1exico: US Geological Survey, Open-File Report USGS-4339-8, Denver, CO.

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RAls and Responses Enclosure X to E-XXXX

3. Bachman, G.O., 1976, Cenozoic deposits of southeastern New Mexico and an outline of the history of evaporite dissolution: Journal of Research of US Geological Survey, v. 4, pp.

135-149.

4. Blainey, J.B., Holt, R.M., and Pickens, J.F., 2009, Geostatistical analysis of th Dockum red beds at the Waste Control Specialists site, Andrews County, T J.S., 1966, Recharge studies on the high plains in northern Lea County, Geological Survey Water-Supply Paper 1819-F, Washington, DC.

5. Baumgardner, R.W., Jr., Hoadley, AD., and Goldstein, A.G., 19 Sink, a salt dissolution and collapse feature, Winkler County, 114, Bureau of Geology, University of Texas at Austin, Aus *

6. Ewing, J.E., Kelley, V.A., Jones, T.L., Yan, T., Singh, Sharp, J.M., 2012, Final Groundwater Availability report for Texas Water Development Board.

http://www. twdb. texas. gov/groundwater Im odels/g

7. Havens, J.S., 1966, Recharge studies on the High Pla1 Mexico: Water-Supply Paper 1819-F, US Geological Su

8. Holliday, V.T., Hovorka, S.D., and geochronology of fills in small playa

9.

Bulletin Geological Society of Americ ing o ch through pedogenic neament, Waste Control Specialists 4-1 a, Appendix 28, to Byproduct Material WCS, original date 21 June 2004, last of Halite Dissolution in the Vicinity of s County, Texas. Attachment 4-2 to WCS, Attachmen nterim Storage Partners' License Application, 2-1050, First Request for Additional Information, November 16, I, J.S., Powers, D.W., and Hughes, E.E., 2011, Subsurface discontinuity ral waste disposal facility and compact waste disposal facility landfills:

9/26/2011, response to Radioactive Material License (RML) No.

ment 09 CN600616890, RN101702439.

13. Kusz

, :J.S., Holt, R.M., Hughes, E.E., and Powers, D.W., 2010, Discontinuity mapping in the byproduct material landfill excavation at the WCS site: attachment to letter from William P. Dornsife, WCS, to Susan Jablonski, Texas Commission on Environmental Quality, November 10, 2010.

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RAls and Responses Enclosure X to E-XXXX

14. Johnson, K.S., Collins, E.W., and Seni, S.J., 2003, Sinkholes and land subsidence owing to salt dissolution near Wink, west Texas, and other sites in western Texas and New l\\t1exico, in Johnson, K.S. and Neal, J.T., eds., Evaporite karst and engineering/environmental problems in the United States: Oklahoma Geological Survey Circular 109, pp. 183-195.

15. Land, L., 2013, Evaporite karst in the Permian Basin region of west Texas New l\\t1exico: The human impact, in Land, L., Doctor, D.H., and Stephen Proceedings of the 13th Multidisciplinary Conference on Sinkholes an Environmental Impacts of Karst: National Cave and Karst Researc pp. 113-121.

16. Nicholson, A, Jr., and Clebsch, A, Jr., 1961, Geology and southern Lea County, New l\\t1exico: Ground-Water Repo and Mineral Resources, Socorro, NM.

17. Olig, S., Zachariasen, J., and Forman, S., 2007, assessment of the WCS waste disposal facility, Appendix 28, Byproduct Material Disposal Facility L1 original date 21 June 2004, last revised June 2007.

18. Osterkamp, W.R. and Wood, W.W.,

Texas and New l\\t1exico: Part I. Hy development: Geological Society of pplemental erosion s: Attachment 4-4, on to TCEQ by WCS, southern High Plains of evidence for their

20. Powers, D.W.,

drillholes, an Eva po rite Geologic rn New l\\t1exico: Evaporite dissolution, ent, in Johnson, K.S. and Neal, J.T., eds.,

blems in the United States: Oklahoma of activities to plug and abandon Scratch Royalty #1A (Central cialists Site: report to Waste Control Specialists L (March ratories and University of New l\\t1exico, 1981, Basic data report for aste Isolation Pilot Plant-WIPP): SAND79-0274, Sandia National erque, NM (https://www.osti.gov/servlets/purl/5255439).

Osterkamp, W.R., 1987, Playa-lake basins on the southern High Plains of w l\\t1exico: Part II. A hydrologic model and mass-balance arguments for their t: Geological Society of America Bulletin, v. 99, pp. 224-230.

25. Wood, W.W., 2002, Role of ground water in geomorphology, geology, and paleoclimate of the Southern High Plains, USA Ground Water, v. 40, pp. 438-447.

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RAls and Responses Enclosure X to E-XXXX Impact:

SAR Sections 2.6.1 and 2.8 have been revised as described in the response.

Changed SAR pages included after RAI NP-2.6-Page 21 of 119

RAls and Responses Enclosure X to E-XXXX Figure NP-2.6-2-1 Google E'a h composite photo of part of southeastern New rvlexico and adjoining Texas displaying Ii ear features trending approximately NW-SE as well as depressions (especially northwestern portion of photo). The location of the WCS CISF is indicated (lower right) by a white arrow. Three narrow red arrows indicate the escarpment called the rvlescalero Ridge.

The white circle near Lovington identifies the general area where Havens (1966 [7]) investigated fill of shallow depressions.

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RAls and Responses Enclosure X to E-XXXX Page 23 of 119

RAls and Responses Enclosure X to E-XXXX Page 24 of 119

RAls and Responses Enclosure X to E-XXXX ft contours with closure of 6+ ft. Additional closed contours to at the main depression is within a larger, more linear

, no*n110en contours is==1470 ft long. The lower Google Earth image Page 25 of 119

RAls and Responses Enclosure X to E-XXXX

~n r1

] ft <losuie Figure NP-2.6-2-5 Page 26 of 119

RAls and Responses Enclosure X to E-XXXX I CISF roJ" 5

IOMILES Figure NP-2.6-2-6 Figure 2 from Bachman (1973b [2]) emphasizes the relationship of major salt dissolution features nearest the WCS CISF. See Figure NP-2.6-2-7 for structure (elevation) of the top of Rustler along the front of the Capitan Reef. Outline arrow in lower right indicates north.

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RAls and Responses Enclosure X to E-XXXX

:**~...

Rustler Structure Data Point vation (in feet above mean sea level) of tl1e top of the Rustler Figure NP-2.6-2-7 a, of the elevation of the top of Rustler (Ewing et al., 2012 [6]) showing the elongate N

-SSE depression (arrow) of the Rustler along the front of the Capitan Reef. This feature has also been called the Monument Draw (NM) trough. Solution of halite from the late Permian evaporite formations is the cause of this modification of the regional structure.

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RAls and Responses Enclosure X to E-XXXX Page 29 of 119

RAls and Responses Enclosure X to E-XXXX RAI NP-2.6-2:

Describe the origin and extent of the red-bed ridge mentioned in Attachment F, incl ing: the relationship of the ridge to structures such as the inferred anticline and Mescalero i e escarpment described in Attachment F, or other local and regional geologic str s, including folds, faults of lineaments. Provide a figure showing the location of the red b e relative to the WCS site. Provide an estimate of the depth to the crest and flanks oft d ridge and the estimated slope gradient from the crest to the flanks of the red-bed

• CS site, including a geotechnical stability analysis, if appropriate.

WCS CISF SAR Section 2.6.1 does not discuss the red-bed rid or its potential association with local and regional geologic s to SAR Chapter 2 also notes that the red-bed ridge is par the Mescalero Ridge in New Mexico. Attachment F con result of halite dissolution, but a "structural high exist and is likely the eastern limb of a north-northwest tre coincide with the red-bed ridge." Previous site investiga (ML041910475) and February 2004 (ML041910489) descr paleotopographic divide between the Ogallala Aquifer and th subsurface structure associated with a r lineament that jointing direction (300-310°). The NRC t based on b wells, the slope gradient of the top of re site may while the February 2004 report notes that vary t3 percent.

The red bed ri beneath the the southern H1 iassic Dockum Group. The ridge is buried oped on all pre-Quaternary formations on 1che is the remnant Cretaceous Antlers ed in bore ho t the WCS CISF, and the Quaternary alluvial Ogallala, Gaturia, and Blackwater Draw Formations, which are in f recent windblown sand. Waste Control Specialists site and ve followed the convention suggested by Hawley (1993 [7]) to ry formations south of the red bed ridge as Gaturia and as Oga

. As a consequence, Gaturia is not present at the WCS the top of red beds at the WCS CISF is approximately 50 to 80 feet, ngs shown on Figures 2-15, 2-16, and 2-17 of the SAR. The northward of the red beds across the WCS CISF ranges from approximately d elevations between TP-64 (3435 ft msl) and PZ-46 (3414 ft msl)J and ed elevations between TP-65 (3437 ft msl) and PZ-47 (3414 ft msl)J. At um apparent slope on the late Pliocene erosional surface of the red beds is P-84 (3432 ft msl) and PZ-36 (3419 ft msl).

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RAls and Responses Enclosure X to E-XXXX In the immediate vicinity of the Waste Control Specialists facilities, the axis of the red bed ridge occurs from approximately the northwest corner of the byproduct landfill to the southeast corner of the Compact Facility, continuing southeastward beyond the Waste Control Specialists landfills ( i ure 1. The axis is not located under the WCS CISF area. The nearest ocation of the crest of the buried ridge to the WCS CISF is approximately 1200 ft south alon te Line Road. At this location the depth to the crest of the red beds is about 34 ft, bas he log of boring B-1 in Figure 5-4 from WCS (2007 [11]). In this response, the elevati the top of red beds are estimated from Figures 2-16 and 2-17 in the SAR, with location d from SAR Figures 2-15 and 2-35.

The red bed ridge is the position of a drainage divide that has se~

systems throughout late Cenozoic time (Hawley, 1993 [7]; Falli uplifted at the start of the Laramide Orogeny when the Creta late Paleocene to near the end of the Pliocene, the area of the Cretaceous deposits. The relatively resistant lim Cretaceous Antlers Formation on the crest of the rid ridge, maintaining the ridge as a mesa or inter-draina remains coincident today with a local topographic high, drains to the Colorado River, and IVlonument Draw New River. In Andrews County, the buried red bed ridge plunges to 10 feet per mile, similar to the surfac aphy, and the er drainage divide is virtually coincident w the underlyin The low-relief ridge is structurally stable, erosion-resistant caprock caliche, which is partially stabilized by Chihuahua desert veg oak, creosote, mesquite, not subject to slope erosion or mass anted. The ridge extends for approximately and native grasses. As

• s buried, s wasting, a geotechni 100 miles, from no a local phenom

p.

Ector counties, demonstrating that it is not ossible coincidental structural elements.

t F to the WCS CISF SAR) demonstrates formation has o ed the late Permian sediments beneath the

• te and WCS CISF area, with fold axes trending northwest, ctural grain and preferred jointing direction noted in inwater, 2000 [9]) and ML041910489 (WCS, 2007 [11]). The is also reflected in the alignment of lineaments and playas graphs on the Hobbs, Big Spring, and Pecos maps of the Geologic 76 [4]; Big Spring, 1974 [5]; and Pecos, 1975 [6]). The anticlinal t trending fold axes in the Permian Tans ill, Salado, and Rustler neath the Waste Control Specialists [

facilities igure ) are t with the axis of the overlying red bed ridge on the buried surface of the and Powers in Attachment F of the SAR also demonstrates that the observed structure o e surface of the red beds is unrelated to deep dissolution of Permian salts.

Figures 17 to 19 (op. cit.) use Waste Control Specialists site-specific isopachs of the Salado and Rustler Formations, and the thickness of the interval from the top of the Tans ill to the base of the Salado, to show that the Permian salt beds do not rapidly thin or thicken away from the facility.

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RAls and Responses Enclosure X to E-XXXX Although Lehman and Rainwater (2000 [9]) suggest the ridge may be related to large-scale Cenozoic structural deformation associated with subsidence further to the west and south, there is no suggestion of a lowering of the base level of rv'lonument Draw, New rv1exico, the closest surface water drainage feature west of the buried ridge. Monument Draw is an und 1t stream with a very low gradient, overloaded with eolian deposits and aggrading.

In Lea County, the buried red bed ridge is approximately coincident with an rv1escalero Ridge (Nicholson and Clebsch, 1961 [1 OJ; Ash, 1963 [1 ]; Croni prominent escarpment defined by the erosional edge of the caprock ca

• Tertiary/Quaternary pedogenic caliche that developed on all pre-Ou southern High Plains. The rv1escalero Ridge, which defines the b Plains in Lea County, is retreating eastward following late Terti River. Although the red bed ridge is somewhat parallel to th inspection may seem to be a buried southeasterly extensi the caprock caliche over the crest of the buried red bed sides of the crest indicates that it is not the buried er SAR Chapter 2, Section 2.6.1 has been updated to inclu of the red-bed ridge, and SAR Section 2.8 has been updat the changes to SAR Section 2.6.1.

References:

1. Ash, S.R., 1963, Ground-Water Cond Geological Survey Hydrologic lnvestig w rv1exico: U.S.

2. Cronin, J.G., 1969, G Texas and New rmation in the Southern High Plains of Hydrological Investigations HA-330, 9 p.

3.

4.

5.

ceous Strata under the Southern High e 10, No. 1, February 1988, pp. 6-9.

exas Bureau of Economic Geology.

and Gatuna Formations in the Southeastern New rv1exico ew rv1exico Geological Society Guidebook, 44th Field rs D.W., 2007. Evaluation of Halite Dissolution in the Vicinity of Waste Disposal Site, Andrews County, Texas. Attachment 4-2 to WCS, 2007:

C as Attachment F to Interim Storage Partners' License Application, cket No 72-1050, First Request for Additional Information, November 16,

9. Lehman, T.M. and Rainvvater, K., 2000. Geology of WCS - Flying "W" Ranch, Andrews County, Texas, November 2000, 95p. In WCS, 2007, as Attachment 2-1.

Page 32 of 119

RAls and Responses Enclosure X to E-XXXX

10. Nicholson, A, Jr. and A Clebsch, Jr., 1961, Geology and Ground-Water Conditions in Southern Lea County, New Mexico: New Mexico Bureau of Mines and Mineral Resources Ground-Water Report 6, Socorro, New Mexico, 123 p.

11. Waste Control Specialists LLC, Andrews, Texas, 2007. Application for Licens Near-Surface Land Disposal of Radioactive Waste. License R04100, Rev 1 Impact:

SAR Sections 2.6.1 and 2.8 have been revised as described in the r Page 33 of 119

RAls and Responses Enclosure X to E-XXXX Page 34 of 119

RAls and Responses Enclosure X to E-XXXX t

, 1ro i;~, Rustler

• ,w t

173&

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..._b N

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,§l Page 35 of 119

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 2.6 Geology And Seismology 2.6.1 Basic Geology This section discusses the regional geology and site-specific geology. E' presented to identify the geologic formations of the region. This str adopts the nomenclature of Lehman (1994a[2-17], 1994b[2-18])

Group and includes the entire stratigraphic sequence typical of Platform of the west Texas Permian Basin (Bebout and Me 2-14 presents the Hobbs Sheet of the Geologic Atlas of Te map shows surficial lithologic exposures, geologic de, tions of the form are exposed, topography infrastructure and govern ii boundaries in the ar surrounding the Waste Control Specialists perm*

Site Specific Geology Two cross sections in the vicinity of the WCS from former site investigations. The locations o Figure 2-15. Two cross sectio in the vicinity of tn Figure 2-16 and Figure 2-17 ociated boring included in Attachment C.

IS comprise, from oldest ate gallala Formation, the ter Draw Formation, and Holocene e pedisol, termed the Caprock caliche, s before the Blackwater Draw sands were formed in portions of the upper k caliche, the Blackwater Draw caliche is mn of the WCS CISF area for the above units is provided in Figure ite-specific stratigraphic column was developed from data collected The boring logs are presented in Attachment C.

'ties are located over a geologic feature referred to as the red e red be ridge is an expression of the top of the Triassic Dockum ge is buried beneath the late Tertiary caprock caliche, which developed ternary formations on the southern High Plains. Beneath the caprock remnant Cretaceous Antlers Formation, which is not observed in bore CISF, and the Quaternary alluvial and windblown sands of the Ogallala, nd Blackwater Draw Formations, which are in turn covered by 10 to 20 feet ent windblown sand. WCS site investigations have followed the convention s

gested by Hawley (1993) to refer to the late Tertiary to Quaternary formations south of the red bed ridge as Gatufia and those north of the ridge as Ogallala (Hawley, 1993(2-51]).

Page 2-34

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 interim As a consequence, Gatufia is not present at the CISF site. The depth to the top of red beds at the CISF is approximately 50 to 80 feet, based on the logs of borings shown in Figure 2-15, Figure 2-16 and Figure 2-17. The northward slope gradient of the top of the red beds across the CISF ranges from approximately 0.98% (based o d bed elevations between TP-64 (3435 ft msl) and PZ-46 (3414 ft ms!) and 0 red bed elevations between TP-65 (343 7 ft ms!) and PZ-4 7 (3414 ft the maximum apparent slope on the late Pliocene erosional surfa 1.77%, between TP-84 (3432 ft ms!) and PZ-36 (3419 ft ms!)

In the immediate vicinity of the WCS facility, the axis o from approximately the northwest corner of the Bypr corner of the Compact Facility, continuing southe The axis is not located under the CISF area. T buried ridge to the CISF is approximately 12 this location, the depth to the crest of the r boring B-1 in Figure 5-4 from WCS (Waste The elevations of the top of red beds are estima with locations estimated from Figure 2-15 and Fig

5.

tate Line Road.

ased on the log of s LLC, 2007 [2-43]).

ure 2-16 and Figure 2-17, eparated two major I]; Fallin, 1988 ny when the The red bed ridge is the posi fluvial systems throughout lat

[2-53]). This area was uplifted Cretaceous seas retreated. From e end of the Pliocene the us deposits. The relatively 1ed Cretaceous Antlers Formation on the pped the red bed ridge, maintaining the ridge of the red bed ridge remains coincident n Monument Draw Texas, which drains to ew Mexico, which drains to the Pecos bed ridge plunges to the south/southeast at r mile, sim1 a e surface topography, and the crest of the nage divide is virtually coincident with the crest of the underlying F is located over the north-central portion of a prominent subsurface re known as the Central Basin Platform. The Central Basin Platform is horst-like structure that extends northwest to southeast from ew Mexico to eastern Pecos County, Texas. The Central Basin flanked on three sides by regional structural depressions known as the re Basin to the southwest and the Midland Basin to the northeast, and by the erde Basin to the south.

Page 2-35

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim From the Cambrian to late Mississippian, west Texas and southeast New Mexico experienced mild structural deformation that produced broad regional arches and shallow depressions (Wright, 1979[2-37]). The Central Basin Platform served intermittently as a slightly positive feature during the early Paleozoic (G 1958[2-9]). During the Mississippian and Pennsylvanian, the Central uplifted between ancient lines of weakness (Hills, 1985(2-13]), and Midland, and Val Verde Basins began to subside, forming separ Late Mississippian tectonic events uplifted and folded the by more intense late Pennsylvanian and early Permian d fo and faulted the area (Hills, 1963 [2-12]). Highly defo local structures ranges of mountains oriented generally parallel to in axis of the platfor (Wright, 1979(2-37]).

This period of intense late Paleozoic defor gradual subsidence and erosion that strippe structures to near base-level (Wright, 1979[2-3 expanding sea gradually encroached over broad er of previously deposited sedim strata. New lay conglomerate and shale dep ated as erosio and on the flanks of both regi Th the Permian, the Permian Basin carbonates, and shales.

ceous, there was relatively little tectonic al uplifting and downwarping. During the ed and slightly eroded. These conditions e downwarping formed a large land-locked ckum Group accumulated in alluvial eposits (McGowen, et al., 1979(2-21 ]). In t to erosion.

time, a large part of the western interior of North America and southeastern New Mexico) was submerged by a large hick sequence of Cretaceous rocks was deposited over most

ocally, retaceous sequence of sediments was comprised of a basal e Trinity, Antlers, or Paluxy sands) and overlying shallow marine Page 2-36

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Uplift from the west and southward and eastward-retreating Cretaceous seas were coincident with the Laramide Orogeny, which formed the Cordilleran Range west of the Permian Basin. The Laramide Orogeny uplifted the region to essentially its present position, supplying sediments for the nearby late Tertiary Ogallal The major episode of Laramide folding and faulting occurred in the la There have been no major tectonic events in North Americas since Orogeny, except for a brief period of minor volcanism during th northeastern New Mexico and in the Trans-Pecos area. Hills that slight Tertiary movement along Precambrian lines of joint channels which allowed the circulation of ground te to Permia layers. The near-surface regional structural controls e locally modifie differential subsidence related to groundwater dis n of Permian salt depo (Gustavson, 1980(2-1 OJ).

formations. Analysis of cores depositional dissolution of eva There is no evidence that human an as small erosional d water, which variably rbonate. This process e calcrete was dissolved (Holt igns of collapse and evaporite-bearing ence of post-lapse (Attachment F).

ressions. These features traction a ities in the site area. The a few hundred feet to more than 1000 feet es appear to reach a depth of 10 ft. Studies of nds to tens of thousands of years old and

• s no indication that these features will n the near geological future.

atform is an f moderate, low intensity seismic activity ained from the U.S. Geological Survey (USGS) Earthquake Data the National Earthquake Information Center Typical of the central U.S., there is a marked absence of and few of the known earthquakes can be associated with a gic stru re. In the 2014 U.S.G.S. National Hazard Maps, the site area

• zed as one ofrelatively low seismic hazard.

ISF lies in a region with crustal properties that indicate minimum risk due ng and seismicity. Crustal thickness is the most reliable predictor of seismic 1ty and faulting in intracratonic regions. Crustal thickness in the vicinity of the CS CISF is approximately 30 miles (50 km), one of the three thickest crustal regions in North America (Mooney and Braile, 1989[2-22]). In comparison, the crustal thickness of the Rio Grande Rift is as little as 7.5 miles (12 km) in places.

Page 2-37

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 2.8 References 2-1 Bally, A.W., C.R. Scotese, and M.l. Ross, 1989, North America; Plate-Tectonic Setting and Tectonic Elements in The Geology of North America-An Over Volume A, Decade of North American Geology, p. 1-15, Geological S America, Boulder, Colorado.

2-2 Bebout, D.G., and K.J. Meador, 1985, Regional Cross Sections Platform, West Texas: The University of Texas at Austin, B Geology, 4 p., 11 plates.

2-3 Blandford, T.N., DJ. Blazer, K.C. Calhoun, A.R. Dut B.R. Scanlin, 2003, Groundwater Availability oft Texas and New Mexico Numerical Simulations Development Board Draft Report, 160 p.

2-4 Bomar, G.W., 1995, Texas Weather, 2nd e 2-5 2-6 2-7 2-8 2-9 Texas.

Cronin, J.G., 1969, Ground Plains of Texas and New Mex e Southern High logical Investigations HA-330, 9 p.

Hydrogeochemistry and Water Resources of exas Panhandle and Eastern New Mexico:

onomic Geology Report oflnvestigations an e Permian Basin of Texas and New Mexico, erican Association of Petroleum Geologists, p. 395-446.

80, Faulting and Salt Dissolution, in Geology and Geohydrology Texas Panhandle, A Report on the Progress of Nuclear Waste

• es (1979): The University of Texas at Austin, Bureau of ular 80-7, p.83-87.

., and R.J. Finley, 1985, Late Cenozoic Geomorphic Evolution of the le and Northeastern New Mexico: The University of Texas at Austin, onomic Geology Report of Investigations No. 148, 42 p.

., 1963, Late Paleozoic Tectonics and Mountain Ranges, Western Texas to n Colorado, American Association of Petroleum Geologists Bulletin, vol. 47, 09-1724.

2-13 Hills, J.M., 1985, Structural Evolution of the Permian Basin of West Texas and New Mexico, in Structure and Tectonics of Trans-Pecos Texas: West Texas Geological Society, Field Conference Publication 85-81, p. 89-99.

Page 2-46

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 2-14 Holzworth, G.C. "Mixing Heights, Wind Speeds, and Potential for Urban Air Pollution Throughout the Contiguous United States." U.S. Environmental Protection Agency, Office of Air Programs. January 1972.

2-15 Jones, J.C., 2001, Cenozoic Pecos Alluvium Aquifer, in Aquifers of We Texas Water Development Board Report 356, ed. R.E. Mace, W.F.

E.S. Angle, p. 120-134.

2-16 Lea County Solid Waste Authority. "Lea County Solid Waste http://www.leacounty.net/SWA.html (Accessed 2/16/2016 2-17 Lehman, T.M, 1994a, The Saga of the Dockum Group Mexico Boundary Fault: New Mexico Bureau of Mi Bulletin 150, p. 3 7-51.

2-18 Lehman, T.M, 1994b, Save the Dockum Gro Bulletin 34(4), p. 5-10.

2-19 Louisiana Energy Services (LES). "National Report." Revision 4. NRC Docket No. 70-3103.

2-20 2-21 2-22 2-23 2-27 Mace, R.E., 2001, Aquifers of Texas Water Development Aquifers of West Texas:

W.F. Mullican III, and E.S. Angle, p. 1-16.

Mooney, and Upfl Over A

e Seismic Structure of the Continental Crust e Geology of North America - An erican Geology: Geological Society of tent of Cenozoic Faulting in Trans-Pecos Geology oft e ans-Pecos Volcanic Field of Texas, p 19-21.

N.D. Johns, and A.E. Fryar, 1997, Playas and Recharge of the e Southern High Plains of Texas -

An Examination using he University of Texas at Austin, Bureau of Economic 1gations No. 242, 72 p.

8, Hydrogeology and Hydrochemistry of the Ogallala Aquifer, Southern exas Panhandle and Eastern New Mexico: The University of Texas at u of Economic Geology Report ofinvestigations No. 177, 64 p.

d G.N. Gutierrez, 1988, Hydrogeology and Hydrochemistry of Cretaceous

, Texas Panhandle and Eastern New Mexico: The University of Texas at

, Bureau of Economic Geology Geological Circular 88-3, 32 p.

NEF. (2005). National Enrichment Facility. URENCO Environmental Report.

Published in April 2005.

Page 2-47

WCS Consolidated lnterim Storage Facility Safety Analysis Report Revision 3 Interim 2-28 Nicholson, A., Jr., and A. Clebsch, Jr., 1961, Geology and Ground-Water Conditions in Southern Lea County, New Mexico: New Mexico Bureau of Mines and Mineral Resources Ground-Water Report 6, Socorro, New Mexico, 123 p.

2-29 Permian Basin Materials. Personal communications between B.J. Oden Basin Materials, and J. Caldwell, Waste Control Specialists LLC Feb 2-30 Sundance Services, Inc. Personal communications between A. C Basin Materials, and J. Caldwell, Waste Control Specialists L 2-31 Issued in December 2015.

2-32 Texas Commission on Environmental Quality R05807. Amendment 09. Issued in January 2 2-33 Texas Commission on Environmental Qua Permit for Industrial Solid Waste Manageme 2-34 Texas Commission on Environmental Quality Ra Permit for Industrial Solid Wa Management Site.

2-35 Title 10, Code of Federal Re 2-36 2-37 2-38 2-39 iew Plan for Spent Fuel Dry Cask Storage

. 200 Regulatory Commission, Office of r Spent Fuel Dry Storage Facilities,"

ommission, Office of Nuclear Material Safety Guide 1.145, "Atmospheric Dispersion Models for Potential ssessments at Nuclear Power Plants," Revision 1, November inimum Design Loads for Buildings and Other Structures," American ii Engineers (20 I 0).

Regulatory Commission, "Memorandum and Order CLI-01-22 in the dependent Spent Fuel Storage Installation," 2001.

clear Regulatory Commission, "NUREG-0800, 3.5.1.6 Aircraft Hazards, R4,"

2-44 "FAA Airport Data and Contact Information." [Online]. Available:

https://www.faa.gov/airports/airport_safety/airportdata_5010/. [Accessed: 12-Feb-2019].

Page 2-48

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 2-45 "FAA IFR Enroute Aeronautical Charts and Planning." [Online]. Available:

https://www.faa.gov/air _ traffic/fl ight_info/aeronav /digital _products/ifr/. [Accessed:

12-Feb-2019].

2-46 "FAA AIS Open Data, MTR IR 128/180 Segment Location." [Online].

http://ais-faa.opendata.arcgis.com/datasets/Oc6899de28af447c801231 ed7ba

8. [Accessed: 12-Feb-2019].

2-47 "Air Route Traffic Control Centers (ARTCC)." [Online].

https://www.faa.gov/about/office _ org/headquarters _ offi es c_services/artcc/. [Accessed: 14-Feb-2019].

2-48 "GRC AirportIQ 5010 Airport Master Records a https://www.gcr1.com/501 Oweb/default.cfm.

2-49 2-50 "Air transport, passengers car

• https://data. worldbank.org/in 2019].

2-51 the Southeastern New al Society Guidebook, 44th 2-52 Texas, 2007. Application for License to adioactive Waste. License R04100, Rev 2-53 er Cretaceous Strata under the Southern 2-56 ico Geology, Volume 10, No. 1, February ers,D.W., 2007a, Report on mapping of a trench through

• che) across a drainage and possible lineament, Waste Control isposa Andrews County, TX. Attachment 4-la, Appendix 2B, to terial D posal Facility License Application to TCEQ by WCS, original 004, last revised June 2007.

., Hovorka, S.D., and Gustavson, T.C., 1996, Lithostratigraphy and y of fills in small playa basins on the Southern High Plains, United etin Geological Society of America, v. 108, p. 953-965.

et. al., 2005, Play analysis and leading-edge oil-reservoir development ods in the Permian basin: Increased recovery through advanced technologies.

AAPG Bulletin, V.89, No. 5 (May 2005), pp. 553-576.

Page 2-49

RAls and Responses Enclosure X to E-XXXX RAI NP-2.6-3:

Provide justification for why soil boring to depths greater than 45 feet are not neede WCS CISF SAR Section 2.6.4 states that the WCS CISF subsurface condition with eighteen soil borings. Among the eighteen borings, four borings encoun conditions at depths ranging from 37 to 45 feet below ground surface (bgs borings were terminated at 25 feet bgs. General industrial guidance for investigations, such as US Army Corps of Engineering, and FHWA2 recommends the boring depth, for example, (1) be at least to a de th ere the in stress due to the estimated footing load is less than 10% of the

• ng effective over stress, (2) be 1.5 times the minimum dimension of footing be e base of the footing, penetrate a minimum of 3 meters into the bedrock, if bedr encountered before other required depths.

References:

1. US Army Corps of Engineers "Geotechnical lnvestigati 2001).

2. FHWA "GEOTECHNICAL ENGINE Properties" (April 2002)

This information is needed to determine c 72.103(f)(2)(iv).

2 responses Impact:

sed as described in the response.

Page 36 of 119

RAls and Responses Enclosure X to E-XXXX RAI NP-2.6-4:

Provide the following information with respect to the laboratory investigations:

a. Justify how the soil strength and deformation properties of the cohesive soi determined and how the settlement potential of the clay stratum can be evaluated given the absence of consolidated undrained triaxial tests a

b. Provide results from the California Bearing Ratio (CBR) testing.

c. A description of the laboratory tests (including the test result submittal of the Geotechnical Exploration Report (Attach WCS CISF SAR Section 2.6.4 states the following tests Atterberg Limits; Natural Moisture Content; Particles*

Consolidated Undrained Triaxial Test; Standard Proc Bearing Ratio; and Consolidation. However, Subsection Geotechnical Exploration Report (Attachment E to SAR) s triaxial tests and consolidation tests were not conducted bee samples could not be obtained due to th

• che. These tests testing results were

" f the Geotechnical shear strength parameters and consoli subsection ISP indicated that one CBR summary enclosed in Attachment E, App not reported. Additionally, Subsection 2.2, Exploration Report (Attachment E to SAR) time ort was prepared, some of the laboratory testing wa oing." In o e NRC staff to perform a complete evaluation of the labor tions, IS Id provide a complete description of the laboratory tests, inc ults.

ith 10 CFR 72.103(f)(1) and 10 CFR Page 37 of 119

RAls and Responses Enclosure X to E-XXXX RAI NP-2.6-5:

Provide the basis for using 20% of the dynamic modulus for the static elastic modul values are considerably higher for similar soils.

Appendix D of the Geotechnical Exploration Report (Attachment E to SAR) calculated static elastic moduli used for the design and analysis for a dept calculated static elastic moduli are based on derived dynamic moduli fr determined by the refraction micro-tremor (ReMi) method. Specifical dynamic modulus as the static elastic modulus for design and ana moduli exceed the typical range of values for similar soils repo I iteratu res.

This information is needed to determine compliance wit 72.103(f)(2)(iv).

Response to RAI NP-2.6-5:

Impact:

Or Page 38 of 119

RAls and Responses Enclosure X to E-XXXX RAI NP-2.6-6:

Provide the following information regarding the slope stability evaluation:

a. Water resources in the site vicinity along with a description of its location; s natural or manmade ponds and how the stability of their embankments

b. When referring to the natural or manmade slopes, define the words "

to the WCS CISF facilities and justify why the failure of these slo affect WCS CIFS facilities for phase 1 or for the total area oft e applies.

WCS CISF SAR Section 2.6.5 provides general informatio site. Also, SAR Section 2.7 provides additional informaf site. SAR Section 2.7 states: "There are no slopes, n proposed WCS CISF facilities that their failure would This information is needed to determine compliance with 72.103(f)(2)(iv).

Response to RAI NP-2.6-6:

a.

ral non stria! water springs, and drainage ave embankments d drainage features do not have eluded from impacting the WCS CISF due ources in the site vicinity are limited to Specialists LLRW and RCRA facilities tion control and evaporation. These Figure 1-1. The maximum elevation of mbankment overflow structures is 3,454 ft.

of any struc t the WCS CISF is 3,488 ft. Therefore, the 10n of any WCS CISF structure is over 30 feet higher than any of cialists pond embankment elevations. In addition to the five te Control Specialists property, there are a series of manmade ew rv'lexico owned by Sundance Services, Inc., used for their

• sposal tion. The nearest of these ponds is approximately 4,000 ft WCS CISF OCA Boundary. The maximum elevation of all of the approximately 3,475 ft. SAR Section 2.4.4 is revised to include op of pond embankment elevations being lower than the WCS CISF Page 39 of 119

RAls and Responses Enclosure X to E-XXXX

b. The WCS CISF site is generally flat with no significant embankments. The final grading of the WCS CISF site will include excavation to smooth out uneven features and promote overall grading and drainage as indicated in the Flood Plain analysis referenced in SAR Chapter 2. There are two significant embankments in the general ar a of the WCS CISF. Both embankments are soil material stockpiles created from ruction of existing Waste Control Specialists landfills. These stockpiles consist of silty sand or caliche gravels. The stockpile areas vary in elevation a sections within each area.

The first stockpile area is to the northeast of the WCS CISF a PA Boundary for Phase 1 and approximately 785 ft from t possible future phases. Elevation at the highest point o which is approximately 50 ft higher than the surroun

• identified as Item 8 on SAR Figure 1-1.

The second stockpile area is to the southwes the PA Boundary of Phase 1 and the possible highest point of this stockpile is 3,560 ft, which is is over 2,100 ft from elevation of the 100 ft above the surrounding natural grade. This stockpile is identifi 7 on SAR Figure 1-1.

of 1 :1 in some locations.

or the material when it eir creation, and the uld pr ude any settlement or port of this conclusion,

Joseph

. owles has been revieood.

ngle of internal friction for various soil a, loose silty sand, a value of 20 to 22 in a comfortable slope inclination of slope height of 50 ft at an inclination of n stockpile, the maximum horizontal o

result in a lateral spread of approximately ile, based on a maximum slope height of 100

1V, which curre tly exists, the maximum horizontal distance pe failure would result in a lateral spread of approximately 150 ese potential lateral spreads are far short of having any impact on tion 2.6.5, "Slope Stability," is revised to include distances from ISF.

Design Fifth Edition by Joseph E. Bowles, Table 2-6 (1988).

, 2.4.4, 2.6.5, and 2.7 have been revised as described in the response.

Page 40 of 119

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 2.1 Geography and Demography of Site Selected The WCS CISF is situated in northwest Andrews County on the southwestern edge of the Southern High Plains. The entire Waste Control Specialists site is ap ximately 14,000 acres with all acreage being controlled by Waste Control Speci The nearest population center of 25,000 or more is Hobbs, NM about 20 of the WCS CISF.

Land uses within a few miles of the WCS CISF include agr*

drilling for and production from oil and gas wells, quarr enrichment, municipal waste disposal, and the surface oil field wastes. Surface quarrying of caliche, san Mexico, approximately one mile west of the W facility is adjacent to this quarry. The Lea C waste landfill is located adjacent to the sta the WCS CISF. Uranium Enrichment Com technology, uranium enrichment facility about 50397 RCRA landfill location.

The 15-mile radius area arou industry and mostly ranch Ian Environmental Report, Appen 2010 Census data and Figure 1.

mile radius of the WCS CISF.

municipal solid south and west of erates a centrifuge e southwest of the HW-ulation with some

• n population. In the area approximately 5.5 km (3.3 mi) from the ico Highways 234 and 18, there are no deral parks within 8 km (5 mi) of the WCS rces are located in the proposed WCS CISF d on the adjacent quarry property owned by Permian Basin

, 2016[2-29]).

ring, a rmittent surface-water feature situated about 2,500 feet west S CISF that contains water seasonally.

tile-watering holes where groundwater is pumped by windmill and aboveground tanks.

ent Draw, a natural shallow drainageway situated several kilometers hwest of the WCS CISF. Local residents indicated that Monument Draw only ontains water for a short period of time following a significant rainstorm (LES, 2005(2-19]).

Page 2-2

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 lnterim "The local PMP [probable maximum precipitation] floodplain analysis yielded the PMF elevation near the CISF site of 3488.9 ft msl. Elevations of the storage pads vary from 3490 ft msl to 3504 msl. Elevations of the foundations of the security/administration building and the Cask Handling Building are 349 3493 ft msl, respectively."

The finish floor elevations of the Security and Administration bu*

Handling Building are 7 feet and 4 feet, respectively, above t will not be impacted by the PMF. The detailed calculation level elevations in the playa can be found in Attachment B.

2.4.2.3 Effects of Local Intense Precipitation 2.4.3 2.4.4 The Flood Plain Study in Attachment B inclu year frequency storm event and the limits additional storms that were modeled descri6 wide that is too distant from the WCS CISF to There are no streams or river Draw, an ephemeral stream, is miles west of the WCS CISF in by flooding on streams of rivers.

nage and is about 3 would be unaffected ent typically dry, the maximum hist per second 0, 1972 and measured 36.2 cubic meters o

The Waste Control urrently have five (5) manmade evaporation mentation contro and evaporation. In addition to the WCS ponds, f manmade ponds to the southwest in New Mexico. As indicated in ximum elevation of the embankment structure of any of these inimum elevation of any structure at the CISF. If a seismic failure, the inherent topography would preclude any adverse eiches are typically observed on lakes or seas. There are no surface water on or near the WCS CISF where such a phenomenon would be a concern at the WCS CISF. There are currently five evaporation ponds at the te Control Specialists site and they are designed with spillways on the south side so any seiche or surge would flow south away from the WCS CISF.

Page 2-27

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 2.6.5 Slope Stability The WCS CJSF site and surrounding area is nearly flat, so there is little possibility of landslides. Settling or slumping is unlikely because the geologic strata ar ell consolidated and surface soils have low moisture content. The semi-ar*

• ate helps maintain low moisture content of the soils. Except for sedimentatio ponds, surface water is absent except during infrequent rainston As indicated in Sections 2.1 and 2.4, there are several noni near the CISF. These include ponds, basins, springs, and d and basins are depressions and do not have embankm escaping. The spring and drainage features do not ephemeral and precluded from impacting the CI The WCS property has five manmade pon evaporation. The maximum elevation of an structures is 3,454 ft. The minimum elevation Because the WCS pond embankment elevations a elevation of the CISF structure lope failure of any would not adversely affect t n control and embankment overflow re at the CISF is 3,488 ft.

0 feet lower than the ground WCS pond embankments erty, the e a series of Sundance Services, Inc.

t of these ponds is CS CISF OCA Boundary. The points is approximately 3,475 feet. Because s are located at a substantial distance from e ground elevation of any CISF structures, nts would not adversely affect the CISF.

e area,

southwest and one to the northeast of the g construction of existing WCS landfills. The closest stockpile eet from the WCS CISF Phase 1 PA Boundary. This distance is any lateral spread from a potential slope failure from having any al seismic and no volcanic activity near the WCS CISF. There is no ctonic or volcanic activity near the WCS CISF in the recent past.

Page 2-44

WCS Consolidated interim Storage Facility Safety Analysis Report Revision 3 interim 2.7 Summary of Site Conditions Affecting Construction and Operating Requirements The WCS CISF site is located on the southwestern edge of the Southern High Plains, approximately 32 miles northwest of the City of Andrews. This part of County is a gently southeastward sloping plain with a natural slope of feet per mile. The finished grade of the WCS CISF is expected to b with an anticipated elevation of 3,485 feet above msl. The WCS undeveloped and the existing land surface is fairly flat with a percent(%). The existing maximum and minimum elevati 3520 feet and 3482 feet msl, respectively. The cover ty e I esert shruB.

existing Waste Control Specialists railroad is general I ned parallel wit of the proposed WCS CISF site boundary.

The entire WCS CISF, including the access r elevation. The northern most limit of the 0-year flood proximately 4,000 of the 500-year and feet southeast of the WCS CISF while then PMP floodplains are 3965 feet and 3895 feet so e WCS CISF, respectively.

A probabilistic seismic hazard ground motion at the WCS return period is 0.26 g.

termine the design basis

• n for a 10,000 year conventional foundations under both the static potential for Ii oadin itions. There is no ive settlement of these soils. As described i the prop facili

• opes, natural or manmade, close enough to ir failure would adversely affect these isters containing spent fuel and GTCC re ra 1quid prior to being shipped to the WCS CISF.

el eases cannot result from operation of the WCS CISF.

bearing zone is about 225 feet deep at the WCS CISF. The ask), the nature of the storage casks, the extremely low d clay and the depth to groundwater beneath the WCS CISF ossibility of groundwater contamination from the operation of the WCS Page 2-45