ML19325E779
| ML19325E779 | |
| Person / Time | |
|---|---|
| Issue date: | 11/01/1989 |
| From: | Bangart R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Brown W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-3 NUDOCS 8911080442 | |
| Download: ML19325E779 (5) | |
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MEM0PANDUM FOR: Willard B. Brown, Director j
Special Issues Group Office of Nuclear Material Safety and Safeguards j
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FROM:
Richard L. Bangart, Director i
Division of Low. Level Waste Management i
and Decommissioning, NMSS
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SUBJECT:
ACNW COMMENTS ON STAFF TECHNICAL POSITION REGARDING EROSION PROTECTION COVERS J
We have reviewed comments submitted by the Advisory Committee on Nuclear Waste l
( ACNW) on Oct*er 18, 1989 regarding the draft Staff Technical Position (STP)
" Design of Erosion Protection Covers for Stabilization of Uranium Mill Tailings Sites." Based on this review, we have devel'oped additional information and clarification for each of the three comments. This j
information is enclosed and should be helpful in your preparation of a i
rasponse to the ACNW.
.l If you have any questions, please contact Paul Lohaus (x2 0553) or Ted Johnson (x2 3440).
l ORIGINAL SIGNED BY Richard L. Bangart, Director j
Division of Low. Level Waste Management i
and Decommissioning, NMSS j
Cnclosure:
Information regarding ACNW Conments i
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INFORMATION REGARDING ACNW Co mENTS ACNW Comment 1.
Need to address other desten features.
The statements that were made in the STP were provided only as guidance in dealing with one of the ano11 cable regulations for uranium mill tailings reclamation. The design c/ an erosion protection cover is only a smal part l
of the total reclamation design.
For example,10 CFR Part 40, Appendix A provides several other criteria that must be met and each of these criteria must be considered in developing a complete design.
i Guidance is currently available in many other areas to detemine compliance with other portions of the regulations. We will revise the STP to identify those design areas where guidance is available. We will also revise the STP to identify any long-tem stability design considerations which could make it i
i difficult to meet other portions of the regulations.
We agree with the necessity of using a systems approach to the problem of stabilizing uranium mill tailings. Uranium mill tailings regulations and associated guidance documents, including the subject draft position, were i
developed with a systems approach.
Ea ti regulation or guidance document was i
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pr 3 1 ated with full recognition of the importance of its integration into an overal regulatory framework. This integration was and is achieved through the use of technical staff that are knowledgeable of the total program, peer review within NRC, cosuunts from interested mest>ers of the public, comments from ACRS i
or ACNW, and effective management direction and oversight. We believe that the subject draft position, when placed in context of other regulations and guidance, is appropriately integrated into a systems approach, and into a regulatory program that has placed all important technical issues in their i
proper relationshi). We will revise any text that suggests or implies that this is not tse case.
ACNW Comment 2.
Justification for use of alternate approaches.
We agree with the ACNW that additional discussion is needed in the STP to f
justify the use of alternate design approaches. We will revise the STP to flexibility provided in those regulations, and (3) gulations, (2) the include additional discussions of (1) applicable re the regulatory intent, as provided in the legislative history.
ACNW Corment 3.
Criteria for Radon Releases.
The requirement for a release rate of 20 picocuries per square meter per second for radon-222 is not verified by actual measurements. This requirement is a design standard used to determine the radon barrier configuration and is
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i calculated using specific models. Regulatory Guide (RG) 3.64 (copy enclosed) is currently available to assist licensees and designers in calculating the l
release rate.
Factors such as residual moisture, porosity and thickness of earthen covers are fully integrated in the redon cover design strategy in r
RG 3.64. We will revise the $TP to indicate the availability of this guidance for detemining release rates, j
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CORRESPONDENCE CONTROL TICKET PAPER NUMBER:
CRC-89-1141 i
t IDGGING DATE: Oct 20 89 ACTION OFFICE:
EDO AUTHOR:-
Dade Moeller AFFILIATION:
ADVISORY COMMITTEE ON NUCLEAR NASTE LETTER DATE:
Oct 18 89 FILE CODE: O&M-7 ACNW
SUBJECT:
Draft staff teQbt position on the design of erosion protection covers for stabilization of uranium mill tailings sites ACTION:
Appropriate DISTRIBUTION:
RF SPECIAL HANDLING: None i
I NOTES:
DATE DUE:
"I SIONATURE:
AFFILIATION:
DATE SIGNED:
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October 18, 1989 The Honorable Kenneth M. Carr Chairman-U. S. Nuclear Regulatory Commission Washington, D.C.
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Dear Chairman Carr:
SUBJECT:
DRAFT STAFF TECHNICAL POSITION ON THE DESIGN 0F EROSION PROTECTIO COVERS-FOR STABILIZATION OF URANIUM MILL TAILINGS SITES During its 14th meeting October 11-13 1989, the Advisory Committee on l
Nuclear Waste met with representatives,of the NRC staff to discuss the subject Draft Technical Position (referenced).
On the basis of thne discussions, we offer the following comments:
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1.
. The Draft Technical Position being proposed by the NRC staff acknowl-edges that the procedures for. prevention of erosten (described in the position) may increase -the probability for increased infiltration of water which, in turn, could. lead to groundwater contamination.
While i
L the NRC staff cautions that "The decision to use a particular reclama-t L
tion strategy should consider di the possible failure modes with respect to all applicable EPA anc NRC standards," they also state that "The ' systematic' process to address certain design aspects, other than the surface water erosion considerations for cover designs, is beyond the scope;of this Staff Technical Position and is, therefore, not ad-
' In addition, they state that " addressing only the concerns dressed."
and criteria detailed in this position may not be sufficient to address the other features necessary to comply with other applicable regula-tions and standards."
We find this limited approach disturbing and unsatisfactory.
We believe it would be better to employ a systems approach to the problem of stabilizing uranium mill tailings, wherein all related aspects of regulatory concerns would be taken into consideration. Alternatively, the Technical. Position should identify and limit those activities 1
pertinent to stabilization that could result in violations of other j
regulations.
We believe the Technical Position should be rewritten to reflect these comments.
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2.
There is inadequate justification for the exemptions that the NRC staff is willing to grant for difficulties in meeting the standards for the l
control of uranium mill tailings. For example, where designing for the Probable Maximum Flood or Probable Maximum Precipitation is "imprac-ticable," the staff will accept the Standard Project Flood.
Where the provision of combined stable soil top slopes and/or rock-protected side L
slopes is " excessively costly," other approaches may be acceptable. We believe that additional discussion of and justification for these posi-tions needs to be provided.
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L, The Honorable Kenneth M. Carr October 18, 1989 1
3.
Lastly is the matter of performance assessment and/or the deterwir:. tion of compliance with the hRC regulations.
For example, the Technical Position states that the limit of 20 picocuries per square meter per i
second for redon-222 releases is for a value " averaged over the entire surface of the disposal site and over at least a one-year period, for the control period of 200 to 1000 years." The criteria for determining the numbers and frequency of the required measurements should be spec-i ified.
Additional discussion and clarification of' this and other aspects of the Technical Position to ensure compliance with NRC regula-tions are needed.
In sunnary, while the-Draft Technical Position provides a considerable amount-of explanation with respect to details of the various alternatives for the designs of covers for the control of uranium mill tailings, certain fundamental aspects of the pnilosophy and justification for the approaches being taken are lacking.
We believe that additional discussion of these broader aspects is necessary and justified.
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L Sincerely, OL(
Dade W. Moeller Chainnan
Reference:
D. NucPAr Regulatory Commission, " Draft Staff Technical Position, Design of Erosion Protection Covers for Stabilization of Uranium Mill Tailings Sites," dated August, 1989 (Predecisional)
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