ML20041A881
| ML20041A881 | |
| Person / Time | |
|---|---|
| Issue date: | 01/27/1982 |
| From: | Scarano R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Campbell R ENERGY, DEPT. OF |
| References | |
| REF-WM-39 39-ISK-82-01-27, 39-ISK-82-1-27, NUDOCS 8202220627 | |
| Download: ML20041A881 (14) | |
Text
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Richard H. Campbell, Project Manager
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Dear Mr. Campbell:
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Enclosed are the NRC staff comments, presented to your staff at the January 27, 1982 meeting, on the December 17, 1981 PDEIS related to the Vitro Site remedial action plan.
As noted in the meeting, the subject PDEIS is very preliminary and does not contain the necessary environmental evaluations to support a recommended action.
Therefore, our comments are intended to provide insight to the major technical issues to be evaluated.
The January 27, 1982 meeting provided a useful exchange of technical issues and we look forward to reviewing the completed PDEIS.
Sincerely
/SI Ross A. Scarano, Chief Uranium Recovery Licensing Branch Division of Waste Management 93 c:-ill u g l -,.
cc:
Robert W.
Ramsey, Jr., DOE-HQ Robert J. Stern, DOE-HQ William E. Mott, DOE-HQ DIST:
TICKET NO:
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WMUR WMUR WMUR OFC
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NAME :W f er
- DEMartin
- RScarano 77 82
- l/J7/82 DATE :82/01/27
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8202220627 820127 y, WM-39 PDR WASTE PDR
m NRC STAFF COMMENTS ON DECEMBER 17, 1981 PDEIS FOR SALT LAKE CITY (VITRO SITE)
UMTRAP REMEDIAL ACTION References a.
PDEIS - UMTRAP Vitro Chemical Company Site; by Dames & Moore, Golden, CO. (December 17, 1981).
b.
Letter of NRC staff EIS scope input; Ross A. Scarano (NRC) to Richard H. Campbell (DOE-AL) (August 14, 1981) c.
DOE letter in response to NRC staff EIS scope input; Richard H. Campbell to Ross A. Scarano (September 16, 1981).
Overall Comment:
There is currently too much missing from the 12/17/81 PDEIS for the DOE to assume, without further NRC review of a revised PDEIS (or pre publication version of the DEIS), NRC concurrence in the document as a Cooperating Agency.
General Comments:
1.
There is no Conclusion Section and thus the preferred course of action is not clearly identified in the PDEIS.
2.
Environmental impacts on groundwater hydrology and quality should be assessed for stabilization at Clive, as well as for no action and stabilization in place alternatives.
(Sec. 5.4).
3.
Non-radiological environmental impacts should also be assessed for remedial action normal project operations and following completion of remedial action as well as for accident conditions.
(Sec. 5.14).
4.
There should be a separate section which analyzes and compares the predicted long term stability of the three major disposal alternatives identified.
This section should assess, in particular, the predictive probability of meeting the currently Proposed EPA 40 CFR 192 UMTRAP Disposal Standards for long time periods.
At such time as the EPA issues Final Standards, this section, presumably in the DEIS, would have to be re-developed to an evaluation against these Final Disposal Standards.
1
l-5.
It is not practicable for NRC staff to evaluate the adequacy of depth of technical and sociological information supporting specific conclusions reached in the PDEIS Sections, since supporting Appendices B, C, D, E, F, and G are missing at this time.
6.
The costs of executing each of the three major alternatives should be detailed.
All of this is currently missing from the PDEIS.
As Ref. 6.
indicates, one of the NRC's primary concerns is that the cost for Vitro Site remedial action may prove excessive and thus that cost / benefit comparisons may play a significant role in deciding the final course of action to be pursued.
As an example of these costs, using the cost of $8.50/ ton quoted on P. 3-31 for transportation to South Clive, and 5000 tons / day, as stated throughout the PDEIS for relocation, at 250 days /yr. fur 3 yrs., the transport cost alone for relocation is now roughly $32,000,000.
Specific Comments (Sec.1):
None (Section currently missing).
Specific Comments (Sec. 2):
None.
Specific Comments (Sec. 3):
1.
Sec. 3.1.1 (p. 3-1):
Preceeding Sections should establish the status and relationship of the CVWRF as a vicinity property associated with the Vitro Site and its owners if the CVWRF is to be introduced at Sec. 3.1.1 as a facility with intended expansion plans onto the Vitro Site.
In addition, this Section should explain breifly why the "no action" alternative is inconsistent with the UMTRCA since, in effect, such a statement is a partial evaluation of that alternative.
2.
Sec. 3.1.2 (p. 3-2):
The environmental impacts of relocating the Vitro Site contaminated materials include those resulting from disposal operations as well as transportation.
An advantage of stabilizing in place is thus also partial elimination of these impacts.
The continued contamination of the high ground water level at the Vitro site should also be evaluated and identified as a third major disadvantage to stabilization in place rather than just a major concern.
2
3.
Sec. 3.1. 2.1 (p. 3-3):
The technical implication of proposing covering a recontoured Vitro Site with 10 feet of uncontaminated offsite soil is that 10 feet is the required depth of such cover to meet Proposed EPA 40 CFR 192 Disposal Standards.
We question 2
whether the required depth is that great, even to meet the 2pCi/m sec. originally proposed by EPA for radon flux limit following remedial action.
In addition, current NRC technical criteria in its active uranium mill site regulations correlates 3m (10 feet) of cover to assuring long term disposal site stability and avoidancg of intrusion without ongoing maintenance rather than meeting 2pCi/m sec. radon flux following disposal.
We futher believe that it would be most desirable for DOE and NRC to agree upon a calculational technique to determine required cover thickness only to meet EPA Standards as a performance goal.
Then the question can be addressed as to whether a greater depth should be assumed based upon a decision for or against on going federal government maintenance following remedial action.
4.
Sec. 3.1. 2.1 (p. 3-4 ):
Future land use restrictions following stabilization in place remedial action may have to extend beyond the contruction restrictions noted into the area of basic type of construction permitted and its intended occupanct frequency.
If, also, the tailings were stabilized over a larger area, the proposed 47 acre 50 foot high hill would be reduced to an even more gentle terrain feature conducive possibly to a wider range of future usages of the site.
5.
Sec. 3.1.3. (p. 3-4):
Without Appendix B, we have no way of evaluating whether our previous Ref. 6. comment was accomodated that the site selection procedure should be fully documented leading to identification of the South Clive Site as the prime relocation site.
This comment directly reflects our concern that close in alternate disposal sites be considered and their acceptability or unacceptability fully documented.
6.
Sec. 3.1.3.2 (p. 3-7):
A 20 Ft. burial trench depth at Clive may prove technically unacceptable if the local water table is as high as 21-34 feet.
With this narrow a separation margin, fluctuations of 7
l this table may ultimately result in groundwater contamination, though we l
agree the proposed in-situ clay liner formation (though thin at 6 in.) may be shown to effectively prohibit this from occuring and that preliminarily the local water quality would appear to be very poor in any event.
The technical basis for predicting adequate long 3
l i
term liner performance needs to be documented however.
An extra margin of safety could be realized, though at admitted increase in disposal site surface area, if 15 feet was the trench depth assumed for design and cost analysis.
7.
Sec. 3.1.3.2 (p. 3-7):
Previous sections noted " tailings sludge",
but here " sewage sludge" is referred to.
Does this mean that a portion of the CVWRF would be cleaned up as part of the Vitro Site project? If so, we do not believe this consistent with the distinction in plans for the two sites.
8.
Sec. 3.1.3.2 (p. 3-7):
The technical basis for 1:1 burial trench sideslopes needs to be documented regarding the presumed stability of such slopes at the specific soil conditions of the South Clive Site.
We have encountered such proposed slopes at one active mill where it was subsequently shown that adequate stability could not be predicted.
9.
Sec. 3.1.3.2 (p. 3-8): Assumption 3. appears to be important, but needs rewording and explanation to be clear.
It sounds in error currently.
10.
Sec. 3.1.3.2 (p. 3-9):
Will the conveyors be covered to protect against dispersal of windblown contaminants during operations? If not, they should be covered.
11.
Sec. 3.1.3.2 (p. 3-18):
It would appear that, with truck transport, the scheme for handling materials at the Vitro site could only be partially the same since there is no central load out station but rather one for each Vitro Site sector.
12.
Fig. 3-5 (p. 3-15) and Fig. 3-6 (p. 3-21): An obvious difference exists between specific disposal locations at South Clive i
depending on whether truck or rail transport is assumed.
The truck l
disposal area is slightly west of the rail disposal area.
This l
should be noted in Sec. 3.1.3.2 and appropriately documented elsewhere why technically this has no effect on disposal scheme long term stability.
For example, the final mounded configuration of disposal trenches will be directionally E-W in the rail case and N-S in the truck case.
Thus, prevailing winds could be expected to have a l
significantly different erosion potential effect on the disposal area Covers.
I 4
i i
I
13.
Sec. 3.1.4 (p. 3-24):
NRC active mill site regulations do not apply to UMTRAP sites.
All such references and implications throughout the PDEIS should be eliminated.
14.
Sec. 3.1.4 (p. 3- )):
Advantages of the Great Depression should also be presented.
The major advantage of The Great Depression, its extremely good remoteness from population characteristic, should be noted.
Remoteness of disposal areas, a prime goal in tailings disposal, is not even listed among the factors considered by the State of Utah.
We assume this is a correctable oversight since it certainly should have been and was, to our understanding, considered.
It contrast, we do not believe obtaining gravel / rock for surface cov"- to be materially more difficult here compared to the South Clive Site and therefore listed as a disadvantage.
15.
Sec. 3.14 (p. 3-28):
Our understanding is that the Delle Site is about 50 miles from the Vitro Site, not 25.
This leads to the conclusion as stated that the cost advantage of the Delle Site is minimal.
16.
Secs, 3.1.4.4 (p. 3-32):
The reprocessing evaluation is noted as a significant omission.
No comment possible at this time.
17.
Sec. 3.2 (p. 3-32):
Sections missing.
See comments on Section 5 which should be reflected in Environmental Overview Sec. 3.2.
Specific Comments (Sec. 4) :
1.
Sec. 4.1 (p. 4-1):
30% of Salt Lake County would appear to be in public ownership.
The break between State and Federal ownership should be noted for completeness and the same data also presented for Tooele County. We believe adjacent Utah County should also be discussed in Sec. 4 unless Appendix B conclusively rules out any chance at all that disposal areas could be found within its boundaries.
Because of its close in proximity, we definitely feel Utah County to be part of the Regional Setting of potential disposal areas for the Vitro Site remedial action program.
Ref. 6.
clearly reflects this viewpoint on the part of NRC.
2.
Sec. 4.2 (p. 4-2):
To our understanding, the CVWRF is not part of the Vitro Site for the purposes of the UMTRAP.
This Sec. implies that it is part of the 128 acres noted as the Vitro Site area.
All throughout the POEIS, we believe the distinction between the 5
l l
processing site and the CVWRF vicinity property should be clearly maintained.
3.
Sec. 4.21 (p. 4-2): To assess impacts on water, we suggest the source of the South Vitro Ditch and water in the pit excavation be clearly determined.
Further, fig. 2-1 is so unclear we can't relate it to the discussion here, in any event.
4.
Sec. 4.2.1 (p. 4-3):
247,000 yd.3 of material brought in from vicinity properties should be 330,000 tons, not 33,000.
- Further, is there really only 10 ft. surface elevation difference over the whole site? Our impression from visiting the site is that it may be more like 20-30 feet.
Fig. 4-1 and 4-2 tend to support this.
5.
Sec. 4.2.2 (p. 4-3):
This is such a sketchy and poorly worded introduction that it is not understandable.
What embankment? What dikes? Projected for what? By whom? Follow on Section 4 subsections are just as inadequate in depth of detail.
6.
Figs. 4-1, 4-2 (p. 4-4, 4-5): There is no way to locate these profiles on maps.
Are they only presented for general background?
7.
Sec. 4.3.2 (p. 4-8):
While Wendover, UT met data may be useful to broadly scope climatic conditions at South Clive, Wendover is 50 miles futher west in the NV state line area.
Should some data specific to South Clive be obtained?
8.
Sec. 4.5.1.2 (p. 4-12):
Detailed subsurface geologic data must be obtained for the Vitro Site as well as the South Clive Site to estabilish its basic suitability as a disposal area.
Is this data being obtained? This and following sections are confusing in regard to the data comparison between the two sites.
9.
Sec. 4. 5.1. 4 (p. 4-15):
The nature of the groundwater at South Clive should be noted.
Is it a perched water formation, for example? Is it considered likely to communicate with the Great Salt Lake?
10.
Sec. 4.5.1.5 (p. 4-16):
What is " rapid downward movement of ground-water?" This is too qualitiative and needs definition, yet the implied conclusion (i.e., groundwater contamination will not be a problem) is significant.
6
l-11.
Sec. 4.5.2 (p. 4-16):
Likelihood of mineral resource production at South Clive needs to be addressed.
12.
Table 4-2 (p. 4-21, 4-22):
Relocate to an Appendix.
13.
Sec. 4.5.3.2 (p. 23):
Earthquake tendency relative to the Vitro Site should also be documented.
This section also poses questions rather than providing answers relative to underlying sediments at South Clive.
14.
Sec. 4.6.1.1 (p. 4-30):
If disposal stability for long time periods at the Vitro Site is to be properly assessed, watershed characteristics should also be utilized to define potential surface water flows.
In other words, can one be reasonably assured that the interconnecting canals will be present for thousands of years?
15.
Sec. 4.6.1.2 (p. 4-31):
Background on the 1964 tailings dike break needs to be presented.
16.
Sec. 4.6.2.2 (p. 4-38):
Groundwater flow at both the South Clive and Vitro Sites needs more explanation to be understandable to the general public reader who may be expected to comment on the DEIS.
17.
Sec. 4.6.2.4 (P. 4-40):
The conclusion that false data was obtained from Vitro Site monitoring wells needs to be fully assessed and rectified.
Otherwise, what should one believe with regard to the extent to which subtailings water is in fact contaminated?
18.
Sec. 4.6.2.6 (p. 4-41):
The entire seepage analysis needs strongly expanded in detail.
Groundwater contamination potential is of l
paramount NRC concern.
The conclusion that chemical barriers l
inhibit contaminant migration at the Vitro Site, in i
particular, needs full explanation.
Especially in view of potential " hazardous" seepage.
19.
Sec. 4.7.1.3 (p. 4-45):
The implication is that compacted South Clive Site soil can form a perfect and lasting radon seal. This is the wrong impression to convey.
Retarded release rate of radon would be a more correct implication.
Similar comments would apply to its l
performance as a liner.
7 l
l l
l
20.
Sec. 4.7.2 (p. 4-45):
This subsection may be cited as a good example of a basic fault of the PDEIS throughout.
Here, all manner of vegatative detail, esoteric to the general reader, is presented.
Yet, important sections such as 4.2.2 and following sections on Vitro Site tailings and soils don't explain to the reader whether the materials are moist and what the moisture content is quantatively.
21.
Sec. 4.7.4 (p. 4-48):
This section is so sketchily worded in jargon regarding the Vitro Site and transportation corridor that one cannot understand what it says.
22.
Sec. 4.8 (and follow on subsections) (p. 4-49 to p. 4-52):
This Section is critical to establishing the baseline radioactive environment at the Vitro Site against which the worth of remedial action will be established.
We don't understanding how any meaningful radioactive release data could have been fed into conceptual designs thus far if this section truly cannot be prepared in preliminary form at this time.
It is not clear from the stated intents that off site measurements will be made in the l
vicinity of the Vitro Site.
If they are not planned, they should l
be.
L 23.
Sec. 4.9 (p. 4-52): Salt Lake County agricultural land available is portrayed as being essentially non-existent, yet 58,000 acres are present and an obvious question can arise in the reader's mind as to why several hundred acres on a county fringe could not be considered as a tailings disposal area.
Also, the same data, presented in the same way, should be given for Salt Lake County as well as Tooele County.
This Section is very heavily biased towards on implied decision for relocation of Vitro Site materials to Tooele County, simply by the way data is presented, and that is unwarranted in our judgement.
24.
Sec. 4.9.1.2 (p. 4-56):
1.ie sewage plant vicinity property has been and continues to be commonly referred to in this program as the CVWRF.
Figure 4-9 gives the impression that part of the CVWRF will be cleaned up as part of the Vitro Site. We would like confusion surrounding this point to be cleared up and categorically eliminated all th;oughout the FDEIS.
Further on P. 4-58, to our understanding, the CVWRF Board is not currently building on the Vitro Site and, if they were, this would inhibit effective remedial action due to building new facilities on Vitro Site tailings.
8
This reasoning is also supported by Sec. 4.9.1.3 as currently worded.
Specific Comments (Sec. 5):
1.
Sec. 5 (overall):
Appendix G is essential to a truly valid assessment of the overall approach taken to evaluate environmental consequences.
It is, of course, omitted at this time.
2.
Sec. 5.1 (p. 5-1):
It should be stated that radiation doses to the public following completion of remedial action will also be calculated.
This is critical to evaluation of the long tert benefit to be derived from the proposed remedial actions.
3.
Sec. 5.1.1 (p. 5-1):
The no action alternative will be evaluated using current exposure (measured data) and dose information.
However, the other alternatives will be evaluated by using generic models (RG1.109, MILDOS, etc).
It has been our experience that the comparison of measured vs. estimated impacts vary significantly.
If choosing a preferred course of action is dependent on a basic comparison with the no-action alternative, and we believe it is, an estimated radiological impact analysis for the no action option should also be performed by computer.
4.
Sec. 5.1.1.1 (p. 5-1):
It would appear that the ingestion pathway is ignored, ostensibly because of the lack of data in this regard.
This is more of an indication that a computer analysis should be performed for the no action alternative to give perspective to the ingestion pathway results which will be obtained for the other alternatives.
5.
Sec. 5.1.2.1 (p. 5-2,3): Analysis of radiological impacts from expected dispersion of tailings offsite, as a result of stabilization operations onsite aren't specifically indicated.
This might not be a substantial contribution, but some discussion should be presented.
Further, is milk considered an insignificant pathway?
It doesn't appear to be addressed.
Note also that NRC RG1.109 has been revised to address primarily reactors, and many of the parameter (generic) values applicable to uranium mills have been excluded in the revision.
In addition, will continental radiological impacts of Rn-222 releases be addressed? They should be at least to the extent needed to document that such impacts may be minimal.
9 vww
6.
Sec. 5.1.2.3 (p. 5-4):
Whether the single container accident is currently considered trivial or not, the discussion of it should fully document its consequences.
7.
Sec. 5.1.2.4 (p. 5-4):
An assessment should also be made of external gamma exposure to the public to compare to the no action alternative.
8.
Sec. 5.1.3.1 (p. 5-5,6):
See above Comment 5.
Same comments apply to this subsection also.
9.
Sec. 5.1.3.3 (p. 5-7):
See above Comment 6.
Same comment applies to this subsection also.
In addition, we assume the worst case transportation accident includes a major derailment and overturn of a fully loaded 50 car unit tailings transport train.
This is not clear because of the use of the work " collision". At the public EIS scoping meeting in May 1981, it was apparant that at least some local Tooele residents and officials are seriously concerned, because of past such accidents, regarding a major tailings train accident in their area.
10.
Sec. 5.1.3.4 (p. 5-8):
See above Comment 7.
Same comment applies.
11.
Sec. 5. 2.3 (p. 5-8):
Temporary or not, the air quality impacts of stabilization at Clive should be calculated and assessed.
The wording does not indicate this will be done. We feel this important because the definition of " temporary" in this case encompasses 3 continuous years of heavy earth moving activities at South Clive.
12.
Sec. 5. 4.1.1. and 5. 4.1. 2 (p. 5-9,10):
These Sections should summarize and quantify the impacts on water of no action.
None of the limited wording present currently indicates clearly that this will be done.
13.
Sec. 5.4.2.1 and 5.4.2.2 (p. 5-10,11):
See above Comment 12.
Same comment applies.
14.
Sec. 5.4.3 (p. 5-4):
See General Comment 2 above as well as Comment 12. above.
15.
Sec. 5.5.3.1 (p. 5-13):
Though the key points appear valid, the ef fect on soil structure is worded so highly emotionally that it 10
sounds as if this is the most important aspect of the entire proposed remedial action.
We do not agree.
The language here, treating the analagous benefits accruable to the Vitro Mill Site, is much more reasonably worded.
16.
Sec. 5.6.3 (p.5-18,19):
Note is made of the fact that the tailings disposal site at South Clive cannot apparently be estimated in size.
Considering the trenching assumptions made-why not?
17.
Sec. 5.10.3.2 (p. 5-25):
If Tooele community leaders were truly isolated from decisions affecting their community in as direct a manner as is implied here, we suggest that it be documented and the rationale disclosed as to why this was the case.
18.
Sec. 5.15.2 (p. 5-29):
A legal question may arise concerning whether or not the CVWRF Board, by moving Vitro Site tailings, would not in fact be performing remedial action as envisioned and mandated by the UMTRCA without public involvement in assessment of environmental impacts and decisions therefrom.
Is this area under study by DOE legal staff? Further, if this statement is true, then how can Sec. 5.15.3 also be true, stating that expansion of the CVWRF is contingent on Vitro Site tailings removal?
19.
Sec. 5.16 and 5.19 (p. 5-30):
Omission of these sections prohibits the NRC from a current meaningful evaluation of Sec. 5 in its entirety.
Specific Comments (Appendix A):
1.
Sec. A.1 (p. A-1):
The NRC has no specific UMTRAP stabilization standards in the sense of direct applicability of its active uranium mill site regulations to UMTRAP sites.
The standards to be met are those of the EPA.
Further, stabilization in place should be evaluated and cost estimated to the same detail as relocation to the South Clive Site.
2.
Sec. A.1 (p. A-2):
Final selection of the remedial action option can anticipate but not precede publication of the FEIS.
3.
Sec. A.2.2 (p. A-6):
The FBDU CVWRF Radiological and Engineering Assessment (REA) is for a partial cleanup of the CVWRF vicinity property and not for CVWRF expansion.
However Ref. 1981b. is, even 11
so, not that report, but the CVWRF Environmental Report (ER) and not the REA.
4.
Sec. A. 2. 5 (p. A-11,14):
materials below the tailings / subsoil interfaces requiresThe nee documentation in the EIS since this significantly affects quantities to be moved and therefore project cost.
5.
Sec. A.3.3.2 (p. A-17):
stabilized slopes as opposed to say 5:1?What is the basis for selecting 10:1 We believe that 5:1 slopes are a reasonable goal and have proven to be stable in use at active mills.
This could allow for a reduction in height of the 50 foot high hill by making greater use of the area availabl e.
6.
Sec. A.3.3.2 (p. A-18):
referred to as needed firmly planned by DOE?Are the additional subsurf 7.
Sec. A. 3. 4.2 (P. A-20,21,22):
These tables (A-3, A-4 changes to make them correct.
NRC comments were prev)ously need detail provided to DOE on these tables with the same errors present i
8.
Sec. A.3.4.2 (p. A-22):
of NRC in evaluating an application for an UMTRAP disposal will be geared however only to assuring that the results of standards as finally promulgated by the EPA." remedial actio time periods (thousands of years)".that follows that paragraph to "long See also previous NRC comments on the wording of this list, particularly to correct the language of No. 6.
9.
Sec. A.3.4.3 (p. A-26 through A-31 equipment sketches are unnecessary.):The soil sample diagramatic 10.
Sec. A.3.4.7 (p. A-59):
quantity and distribution of materials to be dealt with areIt is not u mentioned.
front of the EIS. Basic summary data such as this belongs far to the summary and earlier appearing Vitro Mill Site characterizatio sections.
12
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7 Additional Comments APPENDIX A VITR0 SITE PDEIS 1.
Sec. A.2.1 (pg. A-3):
Subtitle " Subsurface Conditions" should be Surface Conditions.
2.
Sec. A.2.2 (p. A-6):
The Central Valley Water Reclamation Facility expansion plan is presented in the PDEIS but there is no evaluation of the effect or inter-action between this plan and the three disposal alternatives proposed.
3.
Sec. A.2.2 (p. A-6):
Central Valley's and the communities long range future plan in relation to the the three disposal alternatives should be discussed. This discussion should include a feasibility evaluation.
4.
Sec. A.2.3.1: The location of cross section A-A and B-B should be shown on a plan view of the Vitro Site.
5.
Sec. A.3.3.2 (p. A-17):
It~is stated in the PDEIS that although no cost analysis was performed for the below grade in-place stabilization alternative the expense would be high. This statement is ambiguous in that high is not defined.
6.
Sec. A.3.3.2 (p. A-16):
Cover material sources should be investigated. Transportation methods and schemes such as that done for the transportation of tailings to the South Clive Site in the PDEIS should also be provided.
7.
Sec. A.3.4.4 (p. A-48): The proposed evaluation of tailings covers should be included in the PDEIS.
8.
Sec. A.3.4.4 (p. A-49):
Seepage and liner evaluations should be provided in the PDEIS.
9.
Sec. A.3.4.4 (p. A-50):
It appears that there is a duplication of work effort in that both Battelle Pacific Northwest Laboratory and Oak Ridge National Laboratory are preparing publications titled
" Liner Evaluation for Uranium Mill Tailings". A more detailed description would be useful to understand the difference in these programs.
pis8ribu8 ion:
Project file HJPettengill
~
PDR RAScarano Mill fi.le REBrowning WMUR c/f JBMartin WMUR r/f BPFisher At16 14 1981 GWKerr
.]
NMSS r/f WM r/f WMSha ffan WM-41,PDR Thartin JJLinehan Richard H. Campbell, Project Manager UMTRAP Project Office U.S. Department of Energy Albuquerque Operations Office P.O. Box 5400 Albuquerque, NM 87115
Dear Mr. Campbell:
As part of the NRC's participation, as a cooperating ager:y 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 provioing the significant issues identified on Attachment 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 EIS (DEIS) as well as the Final EIS (FEIS) though we recognize that only preliminary 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 t.he end of CY-1981.
Our identification of these significant issues is based on evaluation of:
1.
The April 1981 Draft Vitro Site Remedial Action Concept Paper (RACP).
2.
Input 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 DOE Notice of Intent (NOI) to prepare the EIS.
4.
The May 5 and 7, 1981 visits by HRC staff to the Vitro site, candidate disposal sites recommended by the State of Utah, and selected Salt Lake City vicinity properties.
5.
The April 1981 Ford, Bacon & Davis Utah Inc. (FBDU) Vitro Site Engineering Assessment Report (00E/UMT-0102, FBDU-360-00).
In addition, a discussion and preliminary NRC staff evaluation of these signifi-cant issues was previously provided to you by copy of the June 19, 1981 memorandum to me from William M. Shaffer III of my _ taff summarizing the NRC staff site visits and participation in the public meetings noted previous'y.
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
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predominantly from, in our judgment, the very high cost estimate associated with the currently proposed Vitro site tailings relocation to far distant I
disposal sites, up to 50-75 air miles (60-90 oad miles), from their present location.
As shown on Attachment II, we note that the FBDU Engineering Assess-ment states the overall preject cost for these relocation alternatives will range from $78.1 M to 591.0 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 contingency).
Since these costs are all in CY-1980 dollars, the actual outlays t.ay 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 in the DEIS 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 staff.
We look forward to a similar
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continuing participation with the DOE in the scoping and preparation of this
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EIS and future EISs and EAs for the remainder of UMTRAP inactive mill tailings sites.
Sincerely, Originni Si ned by:
S B 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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l 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. relocation.
4.
Comparative cost analysis of stabiliza-ion-in place vs. relocation.
5.
Comparative cost analysis of close-in relocation (10-15 air miles from Vitro site) vs. far-distant relocation (50-75 air miles from Vitro site).
6.
Radiological and non-radiological impact analysis for the Proposed Course of Action during normal project operations, accident conditions, and following completion of remedial action, focusing on windblown contamination and groundwater contamination potential.
(s 7.
Documentation of disposal site selection procedure and its results, 8.
Comparative analysis of DOE vs. non-DOE remedial action proposals.
9.
Analysis of the impact of the locally perceived " negative social stigma" associated with Tooele County, UT on future county development and 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, conveyors, or combinations of the three, both for close-in vs. far distant relocation.
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At.tachment II Tailings transportation cost vs. proposed disposal alternatives (constant CY-1980 $, millions)
Basis:
DOE /UMT0102, FBDU 360-00 Stabilization Far Distant Relocation
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In Place Prime Area 1st Alternate 2nd Alternate Area Area Tailings Transport Mode None Rail Truck Rail Rail Tailings Transportation Cost ($M) 0.0 25.7 36.1 22.2 22.2 Remainder of Project Cost ($M) 28.0 37.8 33.9 39.7 37.9 Total Project Cost ($M) 28.0 65.5 70.0 61.9 60.1 (Exclusive of Contingency)
Transp. Cost as % of Total Project 0%
40%
52%
36%.
37%
Cost (Exclusive of Contingency) 30% Contingency ($M) 8.4 19.0 21.0 18.6 1G.0 Total Project Cost ($M) 36.4 82.5 91.0 80.5 78.1 (Including Contingency)
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Mr. Ross A. Scarano E-h h J*
Chief, Uranium Recovery SEP p 3 1
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Dear Mr. Scarano:
Thank you for the August 14, 1981, letter which identified eleven issues that NRC feels should be included in the Salt Lake City EIS.
Before I address each of the issues, I wish to first emphasize that the preferred course of action ir. the draft EIS will be to relocate the tailings at the site that is direct 1: south of Clive.
Also, equal emphasis and study will be given in the EIS to the stabilization-in-place option and the prime relocation option.
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Regarding your eleven issues, our comments to each of your points are as follows:
1.
" Documentation of the technical ba.;is of the need for remedial action at the Vitro site."
This will be included in the EIS.
2.
" Comparative health effects analysis of stabilization-in-place vs.
relocation."
This will be included in the EIS.
3.
" Comparative conceptual engineering feasibility analysis of stabilization-in-place vs. relocation."
This will be included in the EIS.
4.
" Comparative cost analysis of stabilization-in-place vs. relocation."
This will be incorporated in the EIS.
S.
" Comparative cost analysis of close-in relocation (10-15 air miles from C'
Vitro site) vs. far-distant relocation (50-75 air miles from Vitro site)."
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.r Mr. Ross A. Scarano Since there are no reasonable close-in relocation sites, a comparative cost analysis is not considered appropriate.
Issue 7 below will address the reasons that no close-in relocation site exists.
6.
" Radiological and non-radiological impact analysis for the Proposed Course of Action during normal project operations, accident conditions, and following completion of remedial action, focusing on windblown contamination and groundwater contamination potential."
This will be incorporated into the EIS.
7.
" Documentation of disposal site selection procedure and its results."
This issue will be included in sufficient detail.in~;the EIS.
8.
" Comparative analysis of DOE vs. non-DOE remedial proposals."
This will be in the EIS.
9.
" Analysis of the impact of the locally perceived ' negative social stigma' associated with Tooele County Ur on future county development cnd general phychological well-being of residents."
This will be included'in the EIS.
10.
" Impacts on land-use plans and policies of Salt Lake, Tooele, and Utah counties."
This issue will be included in the EIS for Salt Lake and Tooele counties, but not Utah county.
11.
" Impacts on transportation networks of tailings transport by rail, truck conveyors, or combinations of the three, both for close-in vs. far distant relocation."
While a detailed design will not be included, the transportation system will be discussed in the EIS.
We look forward to your continued participation in the EIS process.
Sincerely, j.
ichard H. Campbell, Project Manager C'
Uranium Mill Tailings Project Office s
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