ML20034G631
| ML20034G631 | |
| Person / Time | |
|---|---|
| Issue date: | 02/12/1993 |
| From: | Randy Hall NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Chernoff A ENERGY, DEPT. OF |
| References | |
| REF-WM-64 NUDOCS 9303100269 | |
| Download: ML20034G631 (7) | |
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BOX 25325 DENVER, COLORADO 80225 FEB 121993 Docket No. WM-64 U.S. Department of Energy Albuquerque Operations Office ATIN: Albert R. Chernoff Project Manager P.O. Box 5400 Albuquerque, New Mexico 87115
Dear Mr. Chernoff:
W<.t have completed our review of the September 1992 Final Long-Term Surveillance Plan for the Lakeview, Oregon, Disposal Site. Enclosed are I
review comments which must be addressed before we can accept the LTSP.
If you have any questions, please contact the NRC Lakeview project manager, Ray Gonzales, at FTS (303) 231-5808.
Sincerely, I
e Ramon E. Hall Director
Enclosure:
As stated cc:
S. Hamp, DOE F. Hiera, Oregon D. Stewart-Smith, Oregon l.
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p 9303100269 930212
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1 COMMENTS ON THE LONG-TERM SURVEILLANCE PLAN FOR THE LAKEVIEW, OREGON, DISPOSAL SITE f
T The NRC staff has compared information contained in the Long-Term Surveillance Plan (LTSP) with that in the Final Completion Report (FCR) and in the Remedial i
Action Plan (RAP) as well as with the generic Final Guidance for Implementing the UMTRA Project Long-Term Surveillance Program, September 1992 (guidance i
document).
1.
First paragraph of Section 1.1 on Page 1-1 and Section 4.3 on page 4-1 state that 736,000 tons of dry tailings were relocated to the disposal site. Assuming a unit weight of about 100 lb/cu ft, 736,000 tons of tailings have a volume of about 545,000 cu yd. However, paragraph 4 of Section 2.1 on Page 2-1 of the LTSP and the Final Completion Report state that 926,000 cu yds of contaminated materials were relocated to the disposal site. Although there appears to be a discrepancy in these values, it may be that the 926,000 value includes windblown and other contaminated materials while the 736,000 value does not.
If this is true, then the volume of contaminated material (excluding tailings) is j
about 381,000 cu yds.
Is this correct or is there an error in either the 926,000 value or the 736,000 value?
2.
Jrth paragraph of Section 2.1 on Page 2-1 states that the NRC r
anticipates concurrence (of the Completion Report and Certification Summary) in November 1992. Currently NRC anticipates concurrence pending receipt of additional information from DOE. The November 1992 date should be updated.
i 3.
Page 2-4 of Section 2.2 of the guidance document states that the LTSP t
should identify act Wn levels for initiating corrective action or repair.
Contrary to this, the LTSP does not identify those action levels.
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4.
Fourth line of second paragraph of Section 2.2.4 on Page 2-5.
An open parenthesis should be inserted before 0.5 m.
5.
Eighth and ninth lines of second paragraph of Section 2.2.4 on Page 2-5 i
state that the top slope varies from 2 to 4 percent. Drawing LKV-DS,
1313 of the Final Completion leport also shows the top slope as being 2-4 percent. However, Figure 2.3 of the LTSP shows the top slope as being 3 percent. Please make the appropriate revisions.
l 6.
First parc;,raph on page 2-9 mentions both ditch and ditches. Since there l
is only one ditch at Lakeview, the singular form, should be used.
t 7.
First paragraph on page 2-10 mentions diversion channels. Since the RAP and the As-Built drawings use the term, " drainage ditch," and there is only one ditch, the words " diversion channels" should be changed to
" diversion ditch."
8.
Third paragraph on page 2-10 states that all contaminated materials were placed at around their optimum moisture as opposed to wetter than optimum. This statement does not appear to be supported by the j
information in Section 3 of Appendix E of the Completion Report, which
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2 shows that about 50 percent of the contaminated materials were placed wetter than optimum.
If the statement cannot be supported, it should be i
deleted.
9.
Figure 2.3 on page 2-7 shows the rock / filter layers and the radon barrier
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layer as being 0.3M-15CM thick. This term is confusing in that it appears to mean that the layers vary from 0.3 meter to 15 centimeters.
This is not the case, as the layers are 1-foot 6-inches thick. A more 4
appropriate and understandable notation would be to show layer thicknesses as either 46 centimeters or 0.46 meter.
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- 10. Third paragraph of Section 3.0 on page 3-1 and second paragraph of Section 3.4 on page 3-2 state that, "All drawings, maps, and photooraphs will be archived in the permanent Lakeview site files at GJP0 (See l )."
Since Attachment 6 in the LTSP does not contain any of j
these items, it is not clear whether drawings, maps, and photographs will be included in the LTSP or just at GJPO. Actually, since Attachment 6 is blank, its not clear exactly what will be included in the Attachment.
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- 11. Sections 3.1 and 3.2 on page 3-1 state that the disposal site vicinity map and th> disposal site topographic map can be found in the permanent site atla which is maintained in the permanent Lakeview site file. Will.
the site atlas be included in Attachment 6 of the LTSP?
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- 12. Third paragraph of Section 3.3 on page 3-2 states that the Lakeview i
disposal site map is presented in Plate 1.
First bullet of Section 3.7.1 on page 3-5 states that the Permanent site surveillance features are l
shown in Plate 1.
The LTSP does not contain a Plate 1.
- 13. First line of first paragraph of Section 4.1 on Page 4-1 states that two permanent survey monuments have been installed at the disposal site.
However, the last sentence of the same paragraph states that there La e three survey monuments. (The topographic map in the LTSP also shows three i
monuments.)
Please correct this apparent discrepancy.
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- 14. The hydrostratigraphy for the site is adequately discussed and has been l
previously defined for the site. A similar situation exists for the background water quality. However neither of these discussions fully l
support the programs that will be derived from them later on in this section. The monitored constituents as well as the monitoring frequency should be modified based upon the site-specific characterization work l
that has been completed.
- 15. Table 5.2 indicates that barium, lead, selenium, and silver were not measurable at concentrations above detection limits. However, all of these constituents are defined, in Table 5.3, as long-term monitoring constituents. The likelihood of detecting these constituents at concentrations at or above the MCL's is beyond remote not only because
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the constituents are not in the tailings fluid, but also because the MCL's are in every case at least five times greater than the detection limit.
Barium, lead, selenium, and silver should be deleted from the conitoring program.
- 16. Table 5.3 li.sts mercury, net gross alpha, and total dissolved solids.
All of these constituents should be deleted from the monitoring program.
Mercury is not known to be mobil and has not been identified in the ground water at any mill sites. Gross alpha is accounted for in the measurement of uranium and radium. Total dissolved solids is somewhat redundant when conductivity measurements are made.
- 17. The direct monitoring network in Section S.2.1 consists of 16 wells. It is unclear why four background wells are incorporated into the monitoring program.
Background concentrations at this site assume less importance
- i because higher MCL's define the standards. Due to this, the need to monitor any or all of the background wells should be revisited. The four additional dcwngradient monitor wells (520 to 523) also seem redundant.
The eight point of compliance wells are more than adequate to detect leakage from the cell should it occur.
Due to this, the four additional i
do?qgradient wells could be deleted from the program.
- 18. Section 5.3.1 discusses the frequency of monitoring.
Based upon the projected travel time of tailings fluid, should it leach, it appears that it would be many years before hazardous constituents would reach the point of compliance wells. Consequently, the semiar.nual monitoring through 1994 serves no useful purpose and should be modified to annual.
19.
The term "9-mil" at the end of the first line on Page 7-2 should be "9-mi".
- 20. Section 12.0.
The Quality Assurance Prcgram Plan should be referenced and a copy of the plan provided to NRC.
- 21. Fourth bullet on page 6-2 states that along with the NRC, the State of Oregon's Department of Envircamental Quality, Land Quality Division, will be notified when an inspection is to be conducted. The NRC is not aware j
the State of Oregon has a Land Quality Division.
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- 22. Attachment 3 has copies of letters from DOE to two Federal agencies and one State agency requesting that DOE be notified whenever unusual events such as earthquakes, floods, tornados, etc., occur. There is no indication, however, that the agencies responded to DOE's requests.
Since the attachment is titled, " Agency Notification Agreements," it is suggested that the written agreements from the agencies be included in.
- 23. The topographic map shows that there are five trench drains; two in the l
energy dissipation area (EDA) of the drainage ditch and three at the toe of the slope of the disposal cell (Also see Section 3.7.1).
The NRC is aware of only one trench drain at the EDA (PID 13-S-30) as is shown in 9
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il Drawing LKV-DS-10-1313 of the Final Completion Report (FCR).
Please-
!i discuss the purpose of the other four drains ar.d revise either the LTSP li or the FCR as appropride.
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24.
Note 3 on the topographic map states that the project area is defined by j
a dashed line. However, since roads and other features are shown by i
dashed lines, it is not clear where the project area is-located.
It is suggested that a thicker dashed line or other symbol be used to.
distinguish the project area from other dashed lines.
- 25. Note 4 on the topographic map states that the site boundary.is defined by a solid line. However, since the map has many solid lines, it is not clear where the site boundary is located.
It is suggested that' a thicker solid line or other symbol be used to distinguish the site boundary from other solid lines.
26.
The Boundary Marker shown on the topographic map at Northing 24,723.00,
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Easting 17,778.00, is shown incorrectly as BM-1.
This should be corrected to BM-2.
- 27. The symbol on the topographic map for Boundary Marker BM-I at Northing t
26,667.00, Easting 17,778.00, is shown incorrectly as a small square instead of a small circle with a cross through it.
Please correct.
28.
In the topographic map, the symbols in the Legend for, " Trail or Cleared Line," and " Spot Elevation," are not shown.
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29.
The location of monuments, markers, and settlement plates shown in the topographic map are not the same as they are in the As-Built drawings in-the Final Completion Report. Please make the appropriate corrections.
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!i SUGGESTED REVISIONS TO THE LONG-TERM SURVEILLANCE PLAN FOR THE LAKEVIEW, OREGON DISPOSAL PLAN These suggestions are based on a comparison of the Long-Term surveillance Plan to DOE's Final Guidance for Implementing the UMTRA Project Long-Term Surveillance Program of September 1992 (guidance document), or are merely edi torial. No formal reply is required.
1.
In some instances, measurements are shown in conventional U.S. units (i.e., feet, acres, f t/sec, etc.) with metric units (meters, hectares, cm/sec, etc.) in parentheses.
In other cases, the opposite is shown.
It is suggested that the notation be consistent.
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