ML20033H076
| ML20033H076 | |
| Person / Time | |
|---|---|
| Site: | 07000925 |
| Issue date: | 02/21/1990 |
| From: | Bangart R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Sjoblom G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9004180127 | |
| Download: ML20033H076 (8) | |
Text
,
B:\\CIMLET1.WP MEMORANDUM FOR Glcn L. Sjcbl a, Deputy DirCctor Divicion of Industrici cnd FEB t i 1990.
Medical Nuclear Safety, NMSS FROM:
Richard L. Bangart, Director Division of Low-Level Waste Management and Decommissioning, NHSS
SUBJECT:
REVISED COMMENTS ON CIMARRON FACILITY SITE INVESTIGATION REPORT The LLTB staff have revised their technical comments on the submittal from the Cimarron Corporation entitled
" Site Investigation Report for the Cimarron Corporation Facility, Logan
- County, Oklahoma" by James L.
Grant and Associates Inc.
and additional information provided by the Cimarron Corporation as you requested at the February 7,
1990. meeting with Kerr-McGee.
In addition we have identified some areas of regulatory concern which are discussed in this submittal.
Our basic regulatory concern (addressed in Enclosure 1) is that the Cimarron Corporation license amendment request and site investigation report have not provided an impact-analysis as is required for an option 2 burial.
In addition to. providing technical review comments (Enclosure 2) we have also identified a possible alternative to decommissioning this site for unrestricted release (Enclosure 3) and provided a proposed agenda for the meeting between Kerr-McGee technical people / consultants and NRC technical people (Enclosure 4).
If you have any questions concerning this revised review, we will be pleased to meet with you or your staf f. Original. Sfs,...d By..
ne Richard L. Bangart, Director Division of Low-Level Waste Management and Decommissioning, NMSS
Enclosures:
As Stated cc: R. Davis Hurt Distribution:
Central 1FilesQ/l,,2 LLTB r/f NMSS r/f JSurmeier JParrott JStarmer EShum TCJohnson JGreeves RBangart FRoss PDR Yes :/ ><
/
PDR No:/
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Reason:
Proprietary /
/ or CF Only /
/
ACNW Yes:/
.]
No:/_2f,_/
SUBJECT ABSTRACT:
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9004280127 900221 OFFICIAL RECORD COPY C
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' 1 ENCICSURE 1 Imoact Analysis l
As stated under option 2 of the branch technical position, "Under this option the concentrations of natural thorium and uranium (allowed to be buried) are set sufficiently low so that no member of the public will receive a radiation dose exceeding those discussed under option I when the wastes are buried in an approved manner absent intrusion into the burial grounds."
In other words, the " approved manner" that the contaminated material has to be buried under for all options including option 2 is such that "no member of the public will receive a radiation dose in excess of 1 millirad per year to the lung or 3 millirad per year to the bone from inhalation and ingestion, under any foreseeable use of the material or property."
The only way that NRC LLWM staff believes that the licensee can demonstrate that the waste is buried in an " approved manner" is to do a pathway analysis with the objective being to show what and when the peak doses to any member of the public will be and comparing them to the dose limits outlined in option 1.
As part of the pathway analysis the licensee should look at agricultural pathways if there are agricultural activities on or around the site.
Licensee should also look at any potentially impacted groundwater or surface water that is or might be used at or around the site.
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ENCICSURE 2 Groundwater Imoact Analysis The Grant 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 could be used as a source of drinking or irrigation water at some future time.
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 Cimarron River alluvium are too salty for use as drinking water.
From the groundwater-chemical analysis results given in table 3.4 and 4.2 of the Grant reporu it appears that the upper aquifer of the Garber Formation, identified as sandstone A in the Grant report, may have the best water quality of any of the other aquifers of the Garber formation.
If this is the case the peak concentration of uranium through time in a well tapping the shallow aquifer groundwater directly adjacent to and down gradient from the option 2 burial area should be determined.
Also if groundwater containing leachate from the option 2 burial area would flow through the shallow groundwater and into any site surface
- water, then the peak uranium concentration through time in that water should be determined.
If it is unlikely that the shallow groundwater or surface water impacted from the option 2 burial will be used then a demonstration 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 areas are Former Waste Water Pond #1, Former Waste Water Pond #2, the Former Burial Area and the Uranium Plant Area.
4 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 any residual soil contamination above the water table still exists.
Next, the contaminant plume at each of these areas should be defined in terms of concentration and distribution.
of contamination.
Statements made in the Grant report about a change 1
in aquifer geochemistry down gradient 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.
-(
t Site Concentual Model As part of a complete groundwater impact analysis at this site certain site characteristics will have to be better determined and these figured into a site conceptual model. The following comments i
l are about specific points from the current site investigation l
report which need to be clarified before the site investigation l
report can be considered adequate.
l Joints The presence of joints in the Garber Formation is mentioned on page 5-9 of the Grant report.
The presence of joints in saturated porous media can increase the migration rate of radionuclides through that media.
Licensee should make a determination as to the effect of these joints (if any) on the hydraulic conductivity and I
contaminant transport rate in the Garber Formation, specifically
+
l sandstone A.
Perched Aquifers Comments made by Cimarron Corporation on page B-7 of their october 9, 1989 submittal (response to State of Oklahoma and NRC questions on amendment request) state that perched water develops on the shale layers in the unsaturated zone after periods of heavy rain.
The geologic cross-sections through the area of the option 2 burial ground, figures 5.1 and 5.2 in the Grant report, show the presence of mudstone (shale) lenses above the elevation of the groundwater table in sandstone A.
The potential for mudstone lenses to produce perched aquifer conditions at the location of the proposed option 2 burial and the possibility that perched water may intrude the burial cell and increase contaminant transport away from the option 2 burial site is not addressed in the Grant report.
l Groundwater Flow Direction Figure 7.5 of the Grant report shows the pathline.of the presumed groundwater flow away from the proposed option 2 burial cell.
However, analysis of the shallow water table. equipotential lines shown on figure 5.4 and also on figure 7.5 show that a groundwater i
divide can be drawn, see attached figure, through the area of the proposed option 2 disposal cell.
This indicates that most if not all of the uranium that leaches out of the option 2 disposal cell would flow towards reservoir No. 3.
Why wasn't this considered in the conceptual model of groundwater movement through the site?
e Groundwater and Land Use The groundwater and land use on and around the site should be j
described.
This will help to determine potential receptors and how
. _ _. _ _ _. ~.
o they may be impacted if contamination leaves the site.
For example, if crops are grown and cattle are grazed and watered on the cimarron River flood plain adjacent to the site, this should be determined.
This should also be done for the site itself.
Also all groundwater users within a 2 mile radius of the site should be identified.
Determine which aquifer they obtain their water from especially if it is the water table or cimarron alluvium aquifer.
This should be done not so much to see who might be impacted from contamination on the site, but rather to determine what potential future use might be made of the site and vicinity groundwater if the site is releaned for unrestricted use.
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.
Volume Estimate and Justification For Burial In light of the new information as to the revised uranium concentration and distribution in the contaminated soil that is around the uranium plant and other areas a new estimate for the volume of contaminated soil above option 1 limits should be provided.
i
4 ENCLOSURE 3 Alternative to Unrestricted Release Kerr-McGee has already agreed to place a deed restriction on the Cimarron Corporation property to prohibit excavation.in the area of the option 2 burial.
If the groundwater contamination that already exists onsite cannot be remediated cost effectively and if the option 2 burial contaminates groundwater above acceptable levels, it may be necessary for Kerr-McGee to put further deed restrictions for groundwater use on this property before it can be decommissioned and:the license terminated.
^
Since the idea of deed restrictions goes against the NRC General Requirements for Decommissioning Nuclear Facilities (53 FR 24018) which states that
"[t]he Commission's objective is that decommissioned facility sites would ultilnately be available for unrestricted use for any public or private purpose" then Kerr-McGee will have to request an exemption in order to be released from this license.
l
4 4.
ENCLOSURE 4 PROPOSED AGENDA FOR MEETING BETWEEN KERR-MCGEE TECHNICAL PEOPLE / CONSULTANTS AND NRC TECHNICAL PEOPLE TO DISCUSS ISSUES RELATED TO THE SITE INVESTIGATION REPORT OF THE CIMARRON CORPORATION FACILITY 1.
Groundwater Imoact' Analysis'
~
Potential pathways 2.
Areas of Known Groundwater Contamination Plans for characterization 3.
Site Conceotual Model Joints Perched aquifers' Groundwater flow direction Groundwater and land use Erosion Computer simulations 4.
Volume Estimate for Ootion 2 Burial New estimate i
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