ML20045D656
| ML20045D656 | |
| Person / Time | |
|---|---|
| Issue date: | 01/14/1993 |
| From: | Horn M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Koninski G, Nalluswami S, Vasquez G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20045D643 | List: |
| References | |
| FOIA-93-197 NUDOCS 9306290270 | |
| Download: ML20045D656 (1) | |
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JAN 141993 MEMORANDUM FOR:
Sam Nalluswami Decommissioning and Regulatory Issues Branch Division of Low-Level Waste Management and Decommissioning, NMSS Gary Konwinski Region IV Gerard Vasquez Region IV FROM:
Merri Horn Uranium Fuel Section Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, NHSS
SUBJECT:
SEQUOYAH FUELS CORPORATION (SFC), DRAFT ENVIRONMENTAL ASSESSMENT Our contractor has provided the enclosed Draft Environmental Assessment on Sequoyah fuels Corporation. The schedule for providing comments on the draft is very tight.
You have 2 weeks to review the document and provide comments.
Comments must be received b_y February 2, 1993. Comments should be
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provided to me; a marked-up copy is acceptable.
The comments should ng1 be placed in the Public Document Room.
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Merri Horn Uraniurr, Fuel Section Fuel Cycle Safety Branch Division of Irdustrial and Medical Nuclear Safety, NMSS
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Enclosure:
Draft SFC Environmental Assessment cc: w/o encls:
R. Bangart, LLWM R. Cunningham, IMNS J. Greeves, IMNS T. Johnson, LLWM.
J. Austin, LLWM J. Callan, RIV 9306290270 930415 ppR FOIA CURRAN 93-197 PDR j4
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MEMORANDUM FOR:
John W. N. Hickey, Chief Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS FROM:
Tim C, Johnson, Section Leader-j Materials Decomissioning. Section Decomissioning and Regulatory Issues Branch Olvision of low-level Waste Management and Decomissioning, HMSS
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REVIEW COMMENTS ON THE DRAFT-ENVIRONMENTAL ASSESSMENT
SUBJECT:
SEQUOYAH FUELS CORPORATION My staff reviewed the Draft Environmental Assessment on Sequoyah fuels Corporation facility near Gore, Oklahoma, transmitted on January 14, 1993 by Merri Horn of the Uranium Fuel Section.
The enclosed comments and questions pertain mainly to the ground water issues and radiological parameters.
e in addition to the enclosed coments and questions, the items /in John H.
Austin's (Branch Chief) memorandum dated September 9,1992, should also be taken into consideration. The September 1992 Memorandum was in response to l
the Ground Water Monitoring Plan dated March 31, 1992.
John H. Austin, Chief, Decomissioning and Regulatory Issues Branch, is recusing himself from the review of this draft evnvironmental assessment.
If you need additional information, please contact Sam Nalluswami of my staff on 504-2502.
gg yg y Tim C. Johnson, Section Leader
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Materials Decomissioning Section Decomissioning and Regislatory Issues Branch i
03O100 Division of tow-tevel vaste Management and Decomissioning, NMSS l
Enclosure:
As stated WBrach DISTRIBUTION:
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ENCLOSURE Review coments on the Preliminary Draf t Environmental Assessment (EA 508-1010, Occket No.'
January 1993, for Renewal of Source Material License' Ho.
40-8027.
Pace 2-25. Section 2.3 Decomissioninn l.
The decomissioning cost estimate of $ 5,374,790 appears to be low considering the significant soll and ground water contamination.
i 2.
Pace 3-18. Floure 3.6 Please include the ground water elevations in both the cross sections.
for shallow and deep aquifers.
Pace 3-23. Section 3.6 2.1 Uranium levels in SFC Site Soils i
3.
1 The EA should explain the basis for the SFC Envirormental Action level What is the proposal for handling (EAL) of 40 pg/g for uranium in soll.
the contaminated soll listed in this section?
1 boe 3-25. Section 3.6;3 Extent of Contamination in Utility Trench 4.
Backfill 1
Provide the name of the disposal facility used for the t
l soil.
contamination, if any.
l b ge 3 41. Section 3.8.1 Hydroneoloov of the SFC Site i
5.
What is the permeability of the uppermost sandstone which Paragraph 3:
appears to act as an impermeable barrier between the shallow and the Please show in a map the potentiometric surfaces (water deep aquifers?
table elevations) of the shallow and deep aquifers, and provide Also, please explain the significance or references for the data.
effect of the potenthmetric surface of the' deep aquifer being at a higher level in some areas than the shall.a aquifer.
Provide references to the ground water flow rates and Paragraph 4:
Compare the ground water velocities with hydraulic conductivity values.those in the ground water monitoring pla feet / year (Page 10) and 27 feet / year (Page 12), respectively for the shallow and deep aquifars.
No analytical data are presented for the well Paragraph 2. Page 3-43:
directly north of the site on Route 10, and the two wells directly south If data are available, it should be presented in the EA.
of U.S. 40.
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h oe 3-45. Section 3.8,2.2 The SFC facility Environmental investication Paragraph 3:
The EA should provide well numbers for the wells described in this section or a reference. The EA should also explain the basis j
for the Environmental Action Level of 225 pg/1. Provide a reference for i
the highest level of uranium detected in the shallow grou,nd water.
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j Paragraph 4: Which wells in the deep sandstone / shale ground water-i system show uranium levels above the SFC EAL7 It is very important to investigate whether uranturn has migrated in ground water beyond the~ SFC i.
property boundary.
7.
Pace 3-50. Section 3.8.2.3 'Jtility Trench Groundwater Samoles j
The EA should provide a reference for the uranlun levels in the water up to 1,200,000 pg/1, which is significantly above the EAL of 225 pg/1.
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8.
P_aoe 4-2. Section 4.1.1 Hydrolooy i
1 Paragraph 6:
The EA should provide a reference for preliminary modeling l
analyses.
Why is this preliminary? When will the model analyses be i
finalized? What is the basis for the ground water flow paths shown on figure 4.1 (Page 4-3)7 i
9.
Pace 4-5. Section 4.2.1 Dose Evaluation Methods 1
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Paragraph 1:
The EA should provide a reference for the risk assessment i
model and environmental monitoring data used for dose estimates.
I Page 4-6. Paragraph 4:
Please explain the applicability and appropriateness of GENIl code for this site.
i 10.
Pace 4-10. Section 4.2.4 Evaluation of Cumulative Radiolooical Impact for Deutine Operations Please provide the values of the estimated doses and compare thee with the applicable limits.
11.
Pace 4-15. Sectian 4.4 Radioloalcal Imoacts on $lte Hydrolooy Paragraphs 1 & 5:
Briefly explain the type of ground water model used j
to Jetermine the mobility of uranium and the extent'of its migration.
i What are the results?
s Page 4-16, Paragraph 2:
Please verify that 100,000 pg/l is equal to 7E-3 pC1/ml for uranium and 1.2E6 99/1 equals 8.4E-2 pC1/ml.
Using'a specific activity of 7.06E-7 Cl/g, we calculate 7.06E-5 pC1/ml and 8.47E-4 uCl/mi respectively.
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Page 4-16. Paragraph 3:
j bplain the inconsistency between the modelWhen will the model a U
detection of elevated levels of uranium in deep g 4ssumption of no h
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Page 4-17, Paragraph 1:
preliminary modeling analyses.Please justify the conclusions based on the opposite results, what will be the impact on the concluIf the fina water inonitoring My be required.our corroents on the groun frequent ground l
September 3. 1992 to John Hickey.
Please refer to our memorandum date 12.
Pace 5-21. Sect ion 5.2.1.3 Groundwater Radiolooic Paragraph 1:
Please provide a referenc* to the well design c I
5.1.
monitoring well construction.
Page 5-22. Table 5-13:
j 5.2. This also applies to Table 5-14 on Page 5-25.The n
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