ML20023E103
| ML20023E103 | |
| Person / Time | |
|---|---|
| Issue date: | 05/13/1983 |
| From: | Gnugnoli G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Matthews M ENERGY, DEPT. OF |
| References | |
| REF-WM-39 NUDOCS 8306140325 | |
| Download: ML20023E103 (2) | |
Text
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Di/tribution: WM-83322 h ject File WM-39 PDR WMLL r/f NMSS r/f GNGnugnoli gg 13 1983 DEMartin
.EFHawkins WMLL:GNG DLSiefken WM-39 REBrowning LBHigginbbtham Mr. Mark L. Matthews Project Engineer WM Record File WM Project 39 Uranium Mill Tailings Docket No.
Project Office PDR
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Albuquerque Operations Office U.S. Department of Energy Distribution-P. O. Box 5400 Albuquerque, NM 87115 (Return to WM,623 SS) er z
Dear Mr. Matthews:
I have reviewed the draft copy of the UMTRAP Technology Development Plan (TDP) which I received on May 4, 1983. The document provides a good general description of the UMTRAP Research and Development Program.
The following comments on the TDP are being provided as you requested:
The TDP focuses on three major areas:
- 1) Radon attenuation,
- 2) groundwater contamination, and 3) long-term stability. There is no clear explanation for the choice of these three particular topics (i.e., required by regulations), among the rest of the key areas of concern.
If the criterion is to achieve remedial action goals at the least cost, one could certainly look at sampling strategies for verifying that remedial action has been achieved. This is not to suggest that these three topics should be modified, but it would be more helpful to the reader if the rationale for their choice were more definitively explained.
A number of phrases indicated that this plan was prepared prior to the release of EPA's Final Inactive Site Standards, and it would be helpful to the reader if the TDP would be updated to include explicit references to these standards, especially on p. 10.
Moreover, it would improve the TDP significantly, if the EPA i
standards were summarized in an appendix to the TDP.
l The groundwater contamination narrative doesn't mention the principal objective of identifying mitigation measures meeting environmental protection goals at the least cost. Some discussion on cost-effectiveness in the area of groundwater contamination would 8306140325 830513~
r Mr. Mark L. Matthews MAY 13 1983 be helpful.
Perhaps, this could be done by reorganizing some of the discussion involving reconditioning and/or liners.
The narratives in the three areas do not clearly indicate which efforts constitute the Special Studies nor what the TAC's role will be in FY84. Since these efforts constitute the only expenditure for FY84, some separate discussion would cid in understanding FY84 efforts in this area.
As has been discussed in the past two UMTRAP Technology Steering Committee Meetings, a " systems" approach is being taken in order to fully evaluate radon attenuation / groundwater protection /long-term stability implementation scenarios.
In order to more precisely perform a cost-effectiveness study of a remedial action option, an evaluation of earth covers, liners, rock covers, and revegetation as interacting components of a system is a highly advisable approach.
This " systems" approach is not mentioned in the TDP. Unless this approach has been abandoned, it would be extremely useful to reflect the " systems" concept in the TDP.
As part of the NRC's ongoing participation in the UMTRAP Technology Steering Committee, it would be desirable to have a copy of each of the reports on p. 36 of the TDP.
I would appreciate it, if you could have a copy of each report sent to me.
Should you have any questions on these comments, please contact me at FTS 427-4115.
~
Sincerely, l
l Giorgio N. Gnugnoli, Project Manager Uranium Recovery Licensing Section Low-Level Waste Licensing Branch l
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