ML20005F039
| ML20005F039 | |
| Person / Time | |
|---|---|
| Issue date: | 12/22/1989 |
| From: | Randy Hall NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Matthews M ENERGY, DEPT. OF |
| References | |
| REF-WM-64 NUDOCS 9001120213 | |
| Download: ML20005F039 (3) | |
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UNITEo STATES NUCLEAR REOULATORY COMMISSION
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- URANIUM RECOVERY FIELD OFFICE
- DENVER, D 0 00225 DEC 221989 URFO:GRK 3
Docket No. WM '
040WM064870E U'.S. Department of Energy l
' ATTN:
Mark L. Matthews
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. Albuquerque' Operations Office P.O. Box 5400 Albuquerque,'New Mexico 87115
Dear Mr. Matthews:
This is in response to your letter dated October 31, 1989, concerning.
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. construction and. monitoring of the Lakeview disposal site as well as monitoring at the Lakeview processing site.
-It is our_ understanding that DOE'is proposing to determine ground-water compliance at the point of compliance wells.
This proposal is consistent with
.the draft standards, even though such monitoring will not fulfill your original
. commitment of determining if the drain is functioning as designed.- We feel that all parties-involved understand that installing wells to monitor the drain -
will result in' data that could be subject to varying interpretation.
Due to this,:we have concluded that your proposal to " remotely" monitor the drain performance at the point of compliance wells is a reasonable' solution to the problem.
Your proposed installation and construction techniques for the point of compliance wells appears to be adequate.
We strongly. recommend that the northeast well be installed first to determine = the direction of ground-water flow.. Following this, the remaining three wells can be easily sited.
'The modification to the energy dissipation area, as previously discussed and depicted in PID.13-S-30, certainly minimizes the potential for runoff water to pond in an upgradient location, and thereby unnecessarily recharge the relocated tailings.
Such a minor modification helps to minimize ground-water concerns to levels that'are as low as reasonably achievable.
Monitoring the ground-water at the site must consider those anions, cations, and hazardous constituents that can reasonably be expected to be in or derived from the isolated materials.
Critical to this decision is consideration of reliability of the data, economics of analysis, as well as generation of large amounts of data that may not be representative of the site.
We trust that your choice of long-term ground-water monitoring parameters will include a minimal DFo*
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2 DEC 221989 number of anions, cations,- and indicator species, as well as applicable hazardous constituents.
We are pleased to see that DOE has been able to fund well installation and associated analysis at the Lakeview processing site.
These data will be very useful in determining the extent of ground-water remediation that has resulted due to removal of the tailings, as well as the remaining work that is necessary. We recommend that DOE seriously consider the same kind of program for other UMTRAP sites where surface remediation is essentially complete.
In summary, we concur in the installation of point of compliance wells and your proposal to not install drain monitoring wells.
As we have discussed with your staff, the list of constituents you propose to sample is probably more extensive than is necessary.
Concurrence in your ground-water program, as discussed in the RAP, must await promulgation of the final Title I ground-water standards by the Environmental Protection Agency.
Should you have questions or wish to further discuss these matters, please feel free to contact Gary.Konwinski of my staff on (303) 236-2805.
Sincerely.
4e Ramon E. Hall Director cc: David Stewart-Smith, Oregon Department of Health Case Closed:
040WM064870E
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