ML19323A582
| ML19323A582 | |
| Person / Time | |
|---|---|
| Issue date: | 03/25/1980 |
| From: | Miller H NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Gina Davis ANACONDA CO. (DIV. OF ATLANTIC RICHFIELD CO.) |
| References | |
| REF-WM-38 NUDOCS 8004210416 | |
| Download: ML19323A582 (4) | |
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- %. OQ" hfAR 2 5 Ig Project hM-38 The Anaconda Copper Company ATTN: Mr. Glen Davis 1400 Bank & Trust Tower Corpus Christi, Texas 78477
Dear f1r. Davis:
Pursuant to discussions in our meeting of February 14, 1980, I am enclosing a copy of the meeting summary (Enclosure 1).
I have also enclosed a copy of ?!RC questions (Enclosure 2) on the Anaconda report supplied during the meeting on the proposed mill tailings scheme for the Rhode Ranch project. These questions are asked based I
upon information submitted at the meeting and site visit. We provide these in advance of our review of all information, which is to be submitted by Anaconda, to expedite the review process. These questions are intended to focus Anaconda's attention on NRC's concerns about the proposed i
disposal scheme, some of which have already been discussed during our meeting (see Enclosure 1).
In addition, please note that the Anaconda request regarding the Rhode i
Ranch project has been assigned an !!RC project number, IM-38. Any future transmittals from Anaconda should include reference to this number to facilitate processing.
If you have any questions, please call me or George Wu at (301) 427-4103.
Sincerely,
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b5ubert J.11111er Uranium Recovery Licensing Branch Division of Waste Management
Enclosures:
1.
!!eeting Minutes 2.
HRC questions cc:
E. Bailey, TD0H (w/o enclosure) seem.q/g
ENCLOSURE 1 M "/M,h
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MEMORANDUM FOR:
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THRU:
Hubert J. Miller, Section Leader /
Uranium Recovery Licensing Branch FROM:
George Wu Uranium Recovery Licensing Branch
SUBJECT:
MEETIllG
SUMMARY
FOR VISIT TO ANAC0tt0A SITE, CORPUS CHRISTI, TEXAS Date:
February 14, 1980 Place:
Corpus Christi, Texas'and nearby Anaconda Mill Site Partici:gr.:s :
Meeting between Anaconda Company, Texas State organizations, and NRC Ana :nda:
N Glen Davis Stepr.en Uilliams W dp 8(
Rick tiocre f O33 awo
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.s h.il l:.am Gray Datic Shearer, Camp, Dresser S McKee (CDM.)
- ougias Sethr,ess, CDil Texas:
Edgar Bailey, Texas
- Department of Heaitn (TOH)
John Hay;ood, TDH Jos e n G:rrei, TDH
':V 1:am Mellums, TDH
- t..., (TRRC)-
- 'r.a'.d S: rag; ins, Texas Rail Road Cor aissgen,/ 7 7~,, a.
.t Ker.netn Launius, TRRC Barbara Stanton, Texas General Land Office (IGLO)~../
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- ark Theapson, TGLO F.
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SRC:
Hubert.* iller,1."iUR 35: r;e !!v, '":UR
- 0ber: F:r.ner, OELD E y.:illia9s (Consultant) f r a r.). Ycung, OSP e
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Purcose:
Under the Uranigm P,ill Tailings Radiation Control Act of 1978 (UMTRCA),
ownership of si.es used for permanent tailings disposai is required to be transferred to the Feoeral Government.
Anaconda has proposed to dispose of tailings in underground mined out oits at the Corpus,Christi mill site.
Anaconda states the tailings will be essentially dry and the mines are.at least sixty feet deep.
Anaconda has requested to be exempt from the UMTRCA requirement for transfer of ownership based upon the
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claim that this transfer is not necessary to assure tailings inpoundment stability and a need for continued monitoring.
The State of Texas has requested NRC assistance in evaluating Government ownership of the site.
Under UMTRCA, only NRC can make a determiration that the land ownership requirements of the Act can be dispentEd with.
The purpos; cf the meeting was to discuss the scope of NRC rev'iew and associated schedules, review the porposed Anaconda tailings' disposal program, and to conduct a site visit to the mine and mill areas.
Summary:
The following is a sucrary of the important points discussed and agreements reached during the meeting:
.h 1.
NRC (H. Miller) stated that in making a determination on land ownership, NRC will need to document its independent assessment of the issue; the issue which will ' essentially be addressed is: Will continued monitoring of the disposal site be required following completion of reclamation to protect publ.ic health and safety and the environment?
If not, land ownership by a government agency would not be necessary.
The determination would be conditioned on Anaconda meeting the l
technical design and performance specifications presented in j
their proposal (e.g., moisture content of tailings going into I
the pits) and other conditions determined to be required by NRC'in its assessment. The scope cf the URC technical review
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(ielding to a determination on land ownership) will focus pricarily on gechydrologic aspects of the proposed tailings disposal mode, the final depth of burial (distance frca surface to top of tailings), and the mill process. and tailings disposal methods; broader short-term environmental impacts will be addressed by the mill licensing process.
i;RC stated.one, aspect to be dealt with in its review is the 2.
provision in Section 83 of the UECA that, where there is no government ownership of the disposal site, possession of the If it is determined ailings shall be :ursuant to an lG.C license.
no onitoring and, hence,-no land cunership is necessary, ::RC has an option to fulfill th'is:orovisien by. issuance of a-
- ererai license with essentially fed or.co conditions.
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. NRC (H. Miller /R. Fonner) stated it would need a direct 3.
request.from Anaconda, which it agreed to do, for a determination on the subject issue.
The request should be addressed jointly to the State and t!RC. This should include a title abstract l
including opinion of counsel concerning the ability of Anaconda to transfer title of the tailings area to the government.
NRC stated it would complete an assessment as requested by Anaconda; however, the fact that the applicable section of.
UMTRCA.(Section 83) is not effective until November 1981 will make it necessary for NRC to reaffirm the determination after l
HRC stated that careful and complete documentation November 1981.
of the assessment and its determination, and some opportunity for public commeri, is called for in view of this.
NRC will be con:ulting with the State of Texas in' completing-its assessment and deterMnation.
- RC and the State are working out an arrangament for this consulation.
NRC stated there was, pursuant to 10 CFR Part 170, a p:ssibility' 4.
that a licensing fee be charged of Anaconda for making the determination.
Anaconda presented at the meeting an assessment.of the subject 5.
issue; Anaconda stated that the assessment essentially contained the information promised in the " Work Scope" forwarded to NRC by the State in a letter dated December 12, 1979. Anaconda briefly reviewed for NRC and.the State the major points included in their assessment. Two copies of the assessment report were provided to NRC.
NRC stated that its schedules for making a determination are subject to the report containing the information stated by Anaconda as being provided in the Anaconda " Work Scope." This would include a description of the methods used to establish the parameters which were to be provided under Section 2.1.7.1.of the " Work Scope."
Information regarding mining operations have been described in
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a report submitted by Anacondt in their mining application to-the Texas Rail Road Commission.
Anaconda supplied two copies r
of this report to the NRC following the meeting.
'NRC made the following. technical p0ints and identified the 6.
following information needs, in response to the limited
' presentation by Anaconda:
Anaconda should consider options for dewatering of tailings cther than by belt filtering to achieve the-tailings roist.:re levels preposed (approximately 2E 4
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, by weight). The assessment will be done _ assuming tailings will be dewatered to this degree or the slurry solution be subjected to dissolved solids removal so that contaminated water cannot migrate out of the o.i: via ore zor.e sands.
Informatien available on local wells should be i
provided and should con ain, for example, the following:
Location.
Depth, depth to and elevation of static 'grour.dwater
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levels in wells.
Water quality.
Conceptual al ernative's ts disposal in the pit should ce evaluated; i.e., those alternatives Anaconda states they would have to pursue if the This land ownership disper.sation is not given.
should include disposal below grade at 'a location where Anaconda could obtain control of land.
n Results of permeability tests recently run by Anaconda on the material beneath the ore zone should be e
provided.
Information concer'ning the. test methods used to gather data on tailing, contaminants (raffinate)
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should be provided.
Information concerning the controls.(specifications) which can be placed on' replacement of fill over the tailings to avoid rechar;e of the tailings' from surface runoff flow should be provided. The degree of comsaction and permeabilities which will be obtained for-the tailings cover should be evalua ed.
Information should be or:vided to substantiate the Anaconda statement tha: :ercolation of rainfall does.
not penetrate core than a few feet below the surface at the site.
!;?.C described its ' schedule 'for c: ;1 sting the assessment fc11owing submission cf r.seded te:nnical and lagsl information 7.
- re:stred by Anaccr.datis as-fc'.ite.s:
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Following the submission by Anaconda, approximately three months will be needed for NRC to complete the assessment report, at which time a notice must be l
placed in the Federal Register (FR) for public i
i notification.
There will be a thirty day waiting period following
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the FR notice to provide an opportunity for the i
public to coment on the action, before the determination can become effective.
Therefore, there will be about.a four month period between the Anaconda submission and the effective date of the determination.. In the early phase of
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the assessment (i.e., within roughly the first month following the Anaconda submission), NRC will identify and attempt resolution of comments regarding the Anaconda proposal and supporting information.
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Anaconda stated their current schedule for the mill is as
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follows:
June 1980, Anaconda will complete their feasibility studies on belt filt,ering and mill.
Mid-1981', mill construction begins.
Early 1982, mining.begins.
Early 1983, mill construction complete.
A handwritten version of this meeting sumary.was completed by the 1
parties involved before adjournment.
The summary was read and understood by G. Davis of Anaconda, H. Miller of NRC, and E. Bailey of Texas.
Copies of the handwritten meeting summary were distributed to Anaconda, i
Texas Health Department, and IiRC at the meeting.
9.]'[('
George Wu '
Uranium Recovery Licensing Branch Division of Waste Managementement e
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ENCLOS'JRE 2 l
4
'l' COMMENTS ON ANACONDA MILL TAILINGS DISPOSAL REPORT il 9
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In general, statements about site characteristics of the mine area made l
in the report appear to be consistent overall with the visual observations made by the NRC staff during the site visit; however, the data upon which these statements are based are not specific eno. ugh to support the l
claims made.about the hydrogeological aspects of the site. Generalized summary remarks in the report should be substantiated by more specific l
i infomation. The following are specific data that are needed for the analysis of.the proposed tailings disposal scheme.
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-Page 12, para. 2 & 3 The first three statements are not substantiated by any data in the report. Visual inspections confirm the existence of various types.
of rocks at various depths in the exploratory pit. However, no grain size distribution data and no mineralogical data are available.
Such data should be provided, for example, from boreholes or cores in various locations, before these statements can be substantiated for the overall area.
It is the staff's understanding, through conversations between R. Williams (NRC consultantl and E. Reed (hydrogeological contractor of Anaconda), that the relevant data is currently being gathered.
-Figure RRA-2:
The figure indicates core tests hav'e been conducted, but no data on the grain size and mineralogical parameters are given from these tests. Such data should be provided. Similar to the above item, the staff has been informed that such data gathering is currently 4
being done.
-Page 13, bottom para.:
The statements made in this paragraph are based on the data in.
Table 3-1, which has not been provided. The report indicates the table will be supplied by Anaconda. The data in this table must be given to substantiate the statements.in the paragraph.
The Anaconda " Work Scope" presented before the February site visit-indicated that various data on groundwater would be given. The parameters that were listed in the Work Scope but not presented in the report include the' following: potentiometric contour maps, hydraulic gradients,' permeabilities, porosities, storage coefficients, and thicknesses of the hydrostratigraphic units. These data should be provided.
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ENCLOSURE 2
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-Page 17:
Discussions about the properties of the Oakville sands on this page are based on data gathered from wells located more than two miles i
from the proposed the area. Further, the data from these wells i
appear to be sparse.14 ore def.initive hydrological data about the i
mine areas should be provided. As discussed in the meeting (see
! ), information on local wells (e.g., Jug Well). should be provided and should contain, for example, the following t
-Locat'on.
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-Depth, depth to and elevation of static groundwater levels in wells.
-Water Quality.
-The NRC staff, in making an assessment of the Anaconda tailings disposal scheme, is concerned with any possibility of groundwater -
contamination by the tailings. The staff considers that any significant occurrences of recharge or infiltration in the area may encounter the tailings and can become a potential for groundwater j
contamination. Anaconda should, therefore, provide site characterization i
data to substhntiate its claim that infiltration of precipitation cannot penetrate more than a few feet into the grou'nd and that, consequently, there is little potential for infiltration to reach the tailings. More specifically, any infiltration that may be occurring currently at the site shou'.d be evaluated. For example.-
there are several local farm ponds in the vicinity of the proposed mine site; this may provide an opportunity for Anaconda to substantiate the claim that no significant infiltration of precipitation (e.g.,
surface water) will occur.
In addition, any seepage of moisture or contaminant migration from the tailings may potentially lead to contamination of groundwater.
Anaconda should, therefore, provide physical property data (such as grain size distribution, storage coefficient, and conductivity) of the overburden rocks, which will serve as backfill, and the rocks underlying the disposal zone, to allow an assessment of any potential-for seepage from the tailings or recharge of water through these rocks. Such an analysis is needed to allow the staff to determine whether or not the Anaconda tailings disposal scheme meets the requirement of this case that.no significant seepage or contaminant l
migration will occur from the tailings impoundment during operation or over the long term.
-Other specific information that should be provided are as follows:
-The surface drainage contour for the area following reclamation (a surface drainage map). indicating the amounts and directions
.of drainage should be provided;.
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I ENCLOSURE 2 e
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-An evaluation of the potent ai l for human use of the groundwaters in the Oakville and the Catahoula formations in the area should be provided
-A delineation of the methods or techniques used to determine the concentrations of contaminants in the tailings leach filtrate from the pilot plant test should be given (Page 30 of thereportl.
-A more detailed analy' sis of the potential for migration of the mobilized constituents of the tailings should be provided (e.g., arsenic, selenium, and radium). Anaconda's claim on the presence of H2S in the sands and its effects on the innobilization of such constituents should be evaluated with definite data and a more detailed evaluation should be provided (Page 31 of the reportl.
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