ML20030D763
| ML20030D763 | |
| Person / Time | |
|---|---|
| Issue date: | 08/14/1981 |
| From: | Scarano R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Campbell R ENERGY, DEPT. OF |
| References | |
| REF-WM-41 NUDOCS 8109160159 | |
| Download: ML20030D763 (4) | |
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Dear Mr. Campbell:
!M As part of the NRC's participation, as a cooperating agency under the NEPA of 1969, in the DOE's preparation of the EIS for remedial action at the Vitro site (and associated vicinity properties) in the Salt Lake City, UT metropolitan area, we are providing the significant issues identified on Attacha.ent I that the NRC staff feels should be addressed in depth in that EIS.
It is our recommen-dation that all of these issues should be evaluated in the Draft FIS (DEIS) as well as the Final EIS (FEIS) though we recognica that only.m eliminary or tentative resolution and documentation of them may be possible at the DEIS stage.
It is our current, understanding that the Vitro Site DEIS will be available for public review and comment at the end of CY-1981.
Our identification of these significant issues is based on evaluation of:
1.
The April 1981 Draft Vitro Site Remedial Acticn Concept Papar (RACP).
2.
Inpot received as a result of NRC staff participation on the panel at the public EIS scoping meetings held May 5, 1981 and May 6, 1981 in Salt Lake City, UT and Tooele, UT respectively.
3.
The April 13, 1981 COE Notice of Intent (NO 3 to prepare the EIS.
4.
The May 5 and 7, 1981 visits by NRC staff to the Vitro site, candidate disposal sites recommended by the State of Utah, and selected Salt Lake City vicir.ity properties.
j 5.
The April 1981 Ford, Bacon & Davi-Utah Inc. (FBDU) Vitro Site Engineering Assessment Report (00E/UMT-0102, FBDU-360-00).
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In addition, a discussion and preliminary NRC staff evaluation of these signiti-cant issues was previously provided to you by copy of the June 19, 1981 cemorandum to me from William M. Shaffer III v my stsff summarizing the NRC staff site visits and participation in the public meetings noted previously.
Our primary concern at this time regarding Vitro site remedial action is in assuring that scoping of the EIS will result in fully evaluating all feasible remedial action alternatives.
This concern, reflected in Attachment I, stems bR h9810834 WM-41 pg NA
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Mr. Richard H. Campbell 2
Jiffi 14 19 81 predominantly from, in our judgment, the very high cost estimate associated w[th the currently proposed Vitro site tailings relocation to far distant disposal sites, up to 50-75 air miles (60-90 road miles), from their present location.
As shown on Attachment II, we note that tie FB00 Engineering Assess-ment states the overall project cost for these relocation alternatives will range from $78.1 M to $91.0 M as opposed to $36.4 M for stabilization in place.
We further note that the included tailings transportation cost alone for far distant relocation ranges from $22.2 M to $36.1 M with all costs given in constant CY-1980 dollars.
Tha transportation cost for far distant relocation is thus in the 35-50% range as a fraction of base project cost (exclusive of r.ontingency).
Since these costs are all in CY-1980 dollars, the actual outlays may well increase their magnitude by 100% over the life of the project through FY-1988.
In our judgment, the proposed transport cost is excessive compared to poten-tially achieving the same magnitude of tailings isolation from the populace and the environment at much lower cost by stabilization in place or more close-in relocation.
We believe therefore that a full evaluation should be given it the JEIS of more cost effective close-in disposal sites should stabilization in place not prove desirable or practical as the ultimate proposed course of action from technical, environmental, or other considerations.
Any questions you may have on this matter should be addressed to myself or William M. Shaffer III (FTS 427-4538) of my taff.
We look forward to a similar continuing narticipation with the DOE in th'. scoping and preparation of this EIS and future EISs and EAs for the remainder of UMTRAP inactive mill tailings sites.
Sincerely, 04 iginal Signed by:
R. A. Scarano Ross A. Scarano, Chief Uranium Recovery Licensing Branch Waste Management Division cc (w/ attach):
Robert W. Ramsey, Jr., DOE-HQ Dr. William E. Mott, DOE-HQ Robert J. Stern, DOE-HQ Dane L. Finerfrock. Utah Department of Health Robert Fonner (ELD)
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Attachment I
. NRC Identified Significant Issues
- Vitro Site Remedial Action EIS Scope 1.
Documentation of the technical basis of the need for remedial action at the Vitro site.
2.
Comparative health effects analysis of stabilization-in place vs.
relocation.
3.
Comparative conceptual engineering feasibility analysis of stabilization-in place vs. rele:ation.
4 Comparative cost analysis of st:bilization-in place vs. relocacion, i
l S.
Comparative cost analysis of c?ose-in relocation (10-15 air miles from Vitro site) vs. far-distant relocation (50-75 air miles from litro site).
6.
Radiological and.on-radiological impact analysis for the Proposed Course of Action during normal project operations, accident conditions, and j
following completion of remedial action, focusing on windblown l
contamination and groundwater contamination potential.
7.
Documentation of disposal site selection procedure and its results.
8.
Comparat've analysis of DOE vs. non-DOE remedial action proposals.
i l
l 9.
Analysis of the impact of the locally perceived " negative social stigma" l
associated with Tooele County, UT on future county development and i
general psychological well-being of residents.
10.
Impacts on land-use plans and policies of Salt Lake, Tooele and Utah counties.
11.
Impacts on transportation networks of tailings transport by rail, truck, I
conveyors, or combinations of the three, both for close-in vs. far distant l
relocation.
l
Attachment II Tailings transpirtation cost vs. proposed disposal alternatives (constant CV-1980 $, millions) nasis:
DOE /UMT0102, FBDU 360-00 Stabilization Far Distant Relocation
~
In Place Paime Area 1st Alternate 2nd Alternate y
Area Area Taflings Transport Mode None Rail Truck Rail Rail Tailings Transportation Cost ($M) 0.0 25.7 36.1 22.2 22.2 m eainder of Project Cost ($M) 28.0 37.8 33.9 39.7 37.9
.otal Project Cost ($M) 28.0 63.5 70.0 61.9 60.1 (Exclusive of Contingency)
Transp. Cost as % of Total Project
'0%
40%
52%
36%
37%
i Cost (Exclusive of Contingency) 30% Contingency ($M) 8.4 19.0 21.0 18.6 18.0 Total Project Cost ($M) 36.4 82.5 91.0 80.5 78.1 (Including Contingency)
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