ML20006G034

Forwards Review & Comments on Site Investigation Rept, for Cimarron Facilities Submitted on 801009.Rept Does Not Contain Adequate Model of Groundwater Movement Onsite or Analysis of U Concentrations in Groundwater Pathways

ML20006G034
Person / Time
Site:	07000925
Issue date:	02/23/1990
From:	Haughney C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Stauter J CIMARRON CORP.
References
NUDOCS 9003010507
Download: ML20006G034 (6)

Text

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FEB 2 81993 Docket No. 70 925 Cimarron Corporation ATTN:

J. C. Stauters Direttor

• Nuclear Licensing and Regulation P.O. Box 25861.

Kerr.NcGee Center Oklahoma City, OK 73125

Dear Dr. Stauter:

s We have reviewed the Site Investigation Report for the Cimarron facilities that you submitted on October 9,1980.

Our main concern is that the report does not contain an adequate model of groundwater movement on the site or an analysis of the uranium concentrations that might reach members of the public by groundwater pathways.

Our detailed comments on this and other points i

are enclosed.

We look forward to meeting with you and your consultants on March 1,1990, to discuss the issues raised in our enclosure.

Sincerely,

,U U Charles J. Haughnev, Chief 1

Fuel Cycle Safety Branch

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Division of Industrial and Medical Nuclear Safety

Enclosure:

NRC comments on Cimarron Site Investigation Report cc: Dale McHard Oklahoma State Department of Health Jame.t Berger Oak Ridge Associated Universities Distribution:

NRC File Center PDR IMNS Central File IMAF R/F NMSS R/F IMSB R/F JSwift DHurt FBrown GSjoblom Beveridge/ Cornell 1-23 e

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ENCICSURE i

GISgudwater Innact Analysis The Crant report has provided an incomplete groundwater impact

analysis, only one point on the groundwater pathline was analyzed, however one could argue that the shallow aquifer anywhere onsite 3

could he used as a source of drinking or irrigation water at some i

future time, i

i Section 4.3 of the Grant report states that the principal source of groundwater in the area of the Cimarron facility is the Garber/ Wellington formation and that the Cimarron River and 4

Cimarron River alluvium are too salty for use as drinking water.

I From the groundwater chemical analysis results given in table 3.4 and 4.2 of the Grant report it appears that*the upper aquifer of the Garber Formation, identified as sandstone A in the Grant report, may have the best water aquifers of the Garber formation.

quality of any of the other i

If this is the case the peak concentration of uranium in a well tapping the shallow aquifer groundwater direc,through time tly adjacent to and down gradient from the option 2 burial area should i

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determined.

Also if groundwater containing leachate from the J

option 2 burial area vould flow through the shallow groundwater l

and into any site surface

water, then the peak uranium concentration through time in that water should be determined.

it is unlikely that the shallow groundwater or surface water If i

l impacted from the option 2 burial will be used then a demonstration L

of that needs to be given.

Areas of Known Groundwater Contamination The Grant report identifies numerous areas on-site where groundwater contamination currently exists.

Specifically these the:Former Burial Area and the Uranium Plant Area. areas are Form Each of these areas was only briefly described in the Grant report.

Because these areas may have to be subjected to a groundwater impact analysis before the site can be decommissioned they should be fully characterized.

The characterization of these areas should include determining if j-any residual soil contamination above the water table still exists.

i Next, the contaminant plume at each of these areas should be defined in terms of concentration and distribution of contamination.

in aquifer geochemistry down gradientStatements made in the Grant report a from some of these areas should be validated.

Finally, impacts for water use pathways should be considered including contaminated groundwater discharge to site surface water.

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Site ceneantual Model As part certain site characteristics will have to be bette these figured into a site conceptual model.

are about specific points from the current site investigation The following comments

<c report can be considered adequate. report which need to be cla Joints The presence of joints in the Garber Formation is mentioned on 5-9 ' of the Grant report.

The presence of joints in caturated ge porous media can increase the migration rate of radionuclides through that media.

effect of these joints (if anyLicensee should make a determination as to t contaminant transport rate in )the Gerber Formation, spe sandstone A.

Perched Aquifers k

Comments made by Cimarron corporation on p 9,

r on amendment request) shale layers in the unsaturated zone after periods of heav ground, figures 5.1 and 5.2 in the Grant report, of mudstone (shale) table in sandstone A. lenses above the elevation of the groundwater perched aquifer conditions at the location of the propose 2 burial and the possibility that perched water may intrude th burial cell and increase contaminant transport away from the opt e

2 burt:1 site is not addressed in the Grant report.

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Groundwater Flow Direction groundwater flow away from the proposed option 2 F med However analysis of the shallow water table equipotential lines burial cell.

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.shown on, figure 5.4 and also on figure 7.5 show that a gro j

proposed option 2 disposal cell. divide can be drawn, see attach would flow towards reservoir No. 3.all of the uranium that lea the conceptual model of groundwater movement through the sitWhy w e.

Groundwater and Land Use The groundwater and land use on and described.

around the site should be This will help to determine potential receptors and how p

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they may be impacted if contamination leaves the site.

For I

example, the cimarron River flood plain adjacent to the site,if-cr6ps1 be determined.

this should This should also be done for the site itself.

all groundwater users within a 2 mile radius of the site should be Also identified.

especially if it is the water table or cimarron alluvium aqu This should be done not so much to see who might be impacted from contamination on the site, but rather to determine what potential the site is released for unrestricted use. future use might be ma Erosion The erosion history of the site needs to be characterized and the licensee needs to assess the potential for erosional processes to breach the disposal cell and provide risk to a member of the public.

Computer Simulations For any computer simulations of site performance a print out of the input file, as well as the output file generated from it, should be provided so that an analysis can be made of all the input parameters and independent calculations made from them.

Y.21uma Estimate and Justification For Rurial In light of the new information as to the revised uranium.

concentration and distribution in the contaminated soil that around the uranium plant and. other areas a new estimate for the is volume of contaminated soil above option 1 limits should be provided.

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1 PROPOSED AGENDA FOR MEETING BETWEEN KERR-MCGEE TECHNICAL PEOPLE / CONSULTANTS AND NRC TECHN TO DISCUSS ISSUES RELATED TO THE SITE INVESTIGATION REPOR OF THE CIMARRON CORPORATION FACILITY 1

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Groundwater Imnact Analysin Potential pathways L

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Areas of Known Groundwater Contamination Plans for characterization sita corm entual Model 3.

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Joints Perched aquifers Groundwater flow direction Groundwater and land use b

Erosion h'

Computer simulations i

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Voluna Estimate for Ontion 2 Burial New estimate l

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JAMES L. GRANT & ASSOCIATES

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N. CN FOR SATURATED ZONE SNULATIONS

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