ML20052A783
| ML20052A783 | |
| Person / Time | |
|---|---|
| Issue date: | 03/23/1982 |
| From: | Shaffer W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Scarano R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-41 NUDOCS 8204290170 | |
| Download: ML20052A783 (10) | |
Text
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WR 2 3 1982 WMUR r/f WM r/ f 41/WMS/82/02/23/0 NMSS r/f
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4 MEMORANDUM FOR:
Ross A. Scarano, Chief JBMartin
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Uranium Recovery Licensing Branch e
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William M. Shaffer III, Project Manager 8]
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SUBJECT:
MEETING MINUTES - DOE UMTRAP VITRO SITE (SALT LAKE C-PRELIMINARY DRAFT ENVIRONMENTAL IMPACT STATEMENT (PDEIS REVIEW Place and Date January 27, 1982; NRC - Silver Spring, MD.
Purposes The meeting had two primary purposes as follows:
1.
Review of the subject PDEIS to provide DOE with NRC staff coninents on the technical and non-technical content of the document in its currently available form.
2.
Review the current DOE cost estimates for Vitro Site remedial action alternatives.
Attendees Organization Martin Tierney Sandia Natl. Labs - Albuquerque (SNLA),
Division 4514 K.R. Porter Dames & Moore, Denver M.L. Merritt Sandia Natl. Labs - Albuquerque (SNLA)
Division 4514 William M. Shaffer III NRC/NMSS/WMUR Dan E. Martin NRC/NMSS/WMUR DIST:
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MAR 2 31982 41/WMS/82/02/23/0
_2 Giorgio N. Gnugnoli NRC/NMSS/WMUR Frank Anastasi NRC/NMSS/WMUR Donald R. Phoenix Weston Designers & Consultants Ross A. Scarano NRC/NMSS/WMUR D.H. Groelsema DOE - HQ, Nuclear Energy (NE)
Tom E. Flemiri NRC/NMSS/WMUR Mark L. Matthews DOE-Albuquerque, UMTRA-P0
Background
In December 1981 Mark Matthews, Project Engineer of the UMTRAP ' ri ject P
Office, DOE _AL, contacted me and indicated that the Vitro Site PDG S would be available from DOE's contractor in the near future and that they wished to meet with us as soon thereafter as practicable to review its scope, form, and content. The PDEIS was subsequently provided to SNLA by cover letter dated December 17, 1981 from Dames & Moore, Denver (D&M).
In turn SNLA provided it to me by informal letter from Martin Tierney. Mr. Matthews also stated that the preferred course of action in the PDEIS would be relocation of the Vitro Site tailings tox one of several sites that had been reconmended by the state of Utah.
4 These ranged from 50-75 air miles west of Salt Lake City in the westerr Great Salt Lake Desert.
At the time of my discussion with Mr. Matthews and in subsequent discussions, I questioned whether it would be meaningful to have a meeting on the PDEIS since it was the NRC staff's understanding that the preferred course of action for the Vitro Site, for DOE current planning purposes, was stabilization in place. It thus appeared that we would be reviewing a document not prepared on the latest planning basis.
It was subsequently agreed between DOE and NRC staffs, however, to proceed with the subject meeting for the following reasons:
1.
The Vitro Site DEIS was planned for issue by DOE (with NRC and the state of Utah as cooperating agencies) in May 1982 and thus any PDEIS review and input by NRC as early as feasible was deemed meaningful.
2.
The DOE UMTRAP Project Office advised that they intended no subsequent revised PDEIS. Thus the December 17,-1981 version of the PDEIS would be the only one available before DEIS publication.
3.
The DOE had previously directed their Contractors, SNLA and D&M, to raise the level of PDEIS scope detail regarding stabilization DIST:
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in place to be comparable to that for relocation (cost estimates included). Thus the PDEIS would treat them both equally though the preferred course of action identified would not be in -
accordance with the current DOE planning basis for the UMTRAP.
4.
In response to continuing serious NRC concern regarding the high magnitude of_ the LoE remedial action cost estimates for the overall program and for the Vitro Site (particularly if relocated to the western desert sites), it was requested by NRC staff and agreed to by DOE that detailed cost estimates for the various proposed remedial action schemes would be reviewed at the subject meeting. This intent was confirmed to me by both Mark Matthews and Richard H. Campbell, Project Manager, UMTRAP Project Office.
Discussion The meeting was divided into two primary discussions:
1.
Review of the PDEIS document and provision of NRC staff comments on its scope, form and content.
2.
Review of the DOE cost estimates intended for inclusion in the PDEIS for.the currently proposed Vitro Site conceptual remedial action schemes.
PDEIS Document With regard to the PDEIS itself, detailed NRC staff comments on the document were proviJed at the meeting, as shown in Attachment II, whfch was formally provided to DOE at the close of the meeting.
The
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basis for Attachment II is a comparison of the PDEIS against previous NRC staff EIS scope input provided by the August 14, 1981 c-memorandum from NRC to DOE and the DOE's September 16, 1981 response to that memorandum. As discussed at the meeting, the proper technical content of the PDEIS~was largely missing. Thus, it was also emphasized that NRC concurrence in the subsequent DEIS should not be automatically assumed by the DOE because NRC staff review of the appropriate environmental and other technical evaluations was not possible.
Evaluation sections not present in the PDEIS include:
1.
Sec.1 - Summary DIST:
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Sec. 3.1 - Evaluation of Reprocessing 3.
Sec. 3.2 - Overview 2of Environmental Impacts 4.
Sec. 4.6 - Seepage Analysis 5.
Sec. 4.8 - Radiation Environment 6.
Sec. 4.10 - Noise 7.
Sec. 5 - Environmental Consequences 5.1 Radiation Releases 5.2 Air Quality Impacts 5.3 Mineral Resource Impacts 5.4 Water Impacts 5.5 Ecological Impacts 5.6 Sound Level Impacts 5.9 Population / Employment Impacts 5.10 Social Impacts 5.11 Economic Impacts 5.12 Transportation Impacts 5.13 Energy Impacts 5.14 Non Radiological Impacts 5.16 Unavoidable Adverse Impacts 5.17 Resource Commmitments 5.18 Environmental Use/ Productivity 5.19 Mitigation Measures 8.
Appendices B.
Disposal Site Selection C.
Rejected Alternatives D.
Hydrological / Water Quality E.
Socioeconomic Data-F.
Land Use Conflicts G.
Radiological Data The following specific items related to the PDEIS were also discussed during the meeting and agreements are noted where applicable:
1.
Regarding the overall approach to be taken in the EIS, the NRC staff emphasized that, in its judgement, a strictly numerical cost / benefit analysis, by itself, would be potentially misleading. The primary reason is that non-monetary social and political factors will play a prominent role in Vitro Site remedial action decision-making, and this should be openly acknowledged and discussed in the EIS.
Such factors may have already had a significant impact on estimated projecteosts because of the great distance to the disposal sites DIST:
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-5 recommended by the State of Utah. This has resulted in a large difference in remedial action cost if relocation is assumed vs.
stabilization in place. Thus, the decision regarding the ultimate course of action may be made primarily on the basis of the significance of cost (i.e.-whether the project, to be affordable, must be based on stabilization in place) vs. local political will to have the Vitro Site tailings removed from the Salt Lake City metropolitan area. -The health effects benefit difference to be obtained from choosing one course of action over the other is preliminarily judged by the DGE and its contractors to be small.
This appears to be so for all alternatives currently identifed as technically feasible which' also are predicted to meet the proposed EPA 40 CFR 192 disposal standards. The DOE staff and its contractors agreed with the NRC staff view point regarding cost / benefit analysis as discussed above.
2.
The DOE contractor staff indicated that three meters of tailings cover was assumed in the PDEIS (though the Attachment I cost estimate discussed below is based on two meters) because the NRC had determined that particular depth to be acceptable in its 10 CFR 40 active uranium milling regulations issued October 3,1980. The NRC staff stated and re_ emphasized its position, as previously conveyed to DOE, that the NRC active site regulations:do not apply, and will not be applied, by NRC to the UMTRAP sites. NRC concern will be only to assure that the reclamation cover, whatever its ultimate depth, will meet applicable final EPA 40 CFR 192 disposal standards for the designated inactive processing sites.
3.
The following Vitro Site NEPA documentation schedule is planned and was presented by DOE at the meeting (assuming publication of Final EPA 40 CFR 192 UMTRAP standards by January 1983):
Milestone Date DEIS Publication 5/82 DEIS Public Meetings 7/82 FEIS Publication 2/83 Federal Register Record of Decision 4/83 4.
The DOE staff stated that the Vitro Site Remedial Action Concept Paper (RACP) in its final form will probably indicate stabilization in place as DIST:
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the preferred course of action. The RACP is the pre-NEPA process remedial action planning document and precurser to the DEIS. The final RACP for NRC concurrence is anticipated to be available in March 1982.
5.
The DOE and NRC staffs discussed whether the DEIS must or should identify a preferred course of action. Our view was that this did not appear necessary, but that it would be acceptable if the DOE chose to identify a preferred course of action and state the basis for that conclusion. The SNLA staff stated that preliminary thinking on their part indicated that stabilization in place should be the preferred course of action. This is based on their preliminary conclusion that environmental benefit comparisons will prove equal between relocation and stabilization in place leaving cost as the deciding factor.
6.
The NRC staff reiterated its continuing view that in depth documentation of candidate alternate disposal sites considered should be presented in the EIS. The appropriate place for this would be the currently missing PDEIS Appendix B. In our view, this documentation should include an overall discussion and evaluation of potential close-in disposal areas as well as details of the process by which the State of Utah finally recommended only three distant l
candidate sites in the western Great Salt Lake Desert in Tooele county.
The DOE staff concurred with this view.
7.
It was confirmed that the DOE technical feasibility study of stabilization in place, a required predecessor to identifying this alternative to be preferred among the available remedial action options, is planned to be completed in March 1982 by D & M in conjunction with SNLA.
Preliminarily, this option appears technically feasible utilizing above-grade disposal with appropriate contouring and armoring to control erosion.
8.
The DOE and its contractors presented their current concepts for stabilization in place and relocation remedial action schemes. The key features of these schemes were discussed a, summarized below:
A.
Stabilization in Place - Two basic alternative approaches are available in the DOE's judgement. One is to excavate relatively deeply (up to perhaps 25_30 feet) over one half the Vitro Site at a time, obtain cover material from uncontaminated subsurface soil, bury the tailings in the excavation and cover DIST:
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WR 2 3 1982 41/Wtts/82/02/23/0 them with the excavated subsurface soils. This approach is not currently favored by DOE because this scheme appears to exhibit:
a) much higher cost than for above grade surface disposal; b) potential difficulty in obtaining uncontaminated subsurface soil for cover; and c) the undesirable feature of placing the tailings directly in the shallow groundwater table present 2-3 feet below grade.
The second option, involving recontouring the existing Vitro Site surface and covering with offsite uncontaminated cover materials, eliminates the disadvantages of the first and therefore appears preferrable to DOE at this time. On the basis of data thus far available to 00E, the NRC staff agreed with this view.
It was futher discussed, regarding the above grade recontouring approach, that some consideration should be given to utilizing the smallest portion feasible of the Vitro Site for the tailings disposal area. This would allow the maximum return of property to the Vitro Site owners, the Central Valley Water Reclamation Facilities Board, for their planned expansion of adjacent already existing sewage treatment facilities onto the Vitro Site. To accomplish this, contaminated materials would be removed from most site areas and concentrated within the ultimate disposal area portion of the Vitro Site. The NRC staff stated that it saw no reason why this approach could not be implemented.
B.
Relocation - The DOE confirmed that, assuming relocation, the basis for considering relocation of Vitro Site materials only to the currently identified distant sites would be established and fully documented in the currently absent PDEIS Appendix B.
This would include documentation of the evaluation of sites proposed by the State of Utah, DOE, and outside groups.
Further assuming that the three candidate western desert sites recommended by the State remain as the recommendation of Appendix B, the evaluation in the EIS text itself would then also establish the rationale for choosing the South Clive Site as preferred among the three. The major decision then would be to choose between truck vs. rail materials transport to the South Clive Site.
Based qualitatively on probable short term environmenta!
impacts during remedial action and potential cost advan; ages, rail transport currently appears most desirable.
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MAR 2 3 1982 41/WMS/82/02/23/0 Remedial Action Cost Estimates Detailed DOE cost estimates based on the current remedial action conceptual schemes were not made available for discussion at the meeting as had been anticipated.
It was stated at the meeting by DOE and its contractors that more refined conceptual designs would first have to be prepared from which to derive those estimates. This effort would be completed in time for incorporation of both the conceptual designs and cost estimates in the DEIS to be issued in May 1982.
In the interim, Attachment I does, however, present the current DOE pre-liminary estimate for one specific scheme to stabilize the Vitro Site in place, above grade. This data was provided at the meeting by Mark Matthews.
The basis for this scheme is the now dated concept proposed originally by Ford, Bacon & Davis Utah, Inc. (FBDU) wherein the entire 128 acre Vitro site would be recontoured and covered. As discussed previously, this does not appear to be the optimum choice if stabilization in place was to be chosen.
The DOE staff did feel however that the $34 million ($1981) estimate shown on Attachment I was sufficiently accurate to establish the magnitude of expected cost to stabilize in place at between $35-45,000,000,considering inflation.
In comparison, the DOE and its contractors presented an order of magnitude estimate that relocation to the western desert would probably range from $95-105,000,000 in 1981$. A breakdown comparable to that shown on Attachment I was not available, however, for the relocation cost estimates.
The cost estimate for the Vitro Site remedial action in the DOE UMTRAP Project Schedule and Cost Estimate Report (UMTRA-00E/ALO-166) planned to be issued in March 1982, will be based on stabilization in place regarding the Vitro Site and therefore will be approximated by the $34 million figure of Attachment I.
Post-Meeting NRC Cost Analysis Of the total estimated Vitro Site remedial action cost of $34 million, as shown in Attachment I, $5.7 million is pure contingency, $7.5 million is for engineering, and $8.5 million is for cleanup of associated vicinity properties. Only $10.6 million, or 31% of the total cost, is for actually performing the remedial action. This is based on applying an imported clean fill reclamation cover over the entire 128 acre site.
If cover is required over only half that area, by grading the contaminated materials 4
into a single smaller part of the site for reclamation, it would appear that the actual remedial action costs could be reduced to perhaps $5 million to $6 million.
Furthermore, it would seem cost-effective to utilize some of the lightly contaminated materials (e.g., soils mixed with windblown DIST:
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41/WMS/82/02/23/0 M2 2 tailings or sub-soils) to form the base layer of the cover, thus reducing the need for imported clean fill. Reclamation costs, on this basis, should amount to no more than about $3 million to $5 million.
In addition, under such a simple reclamation scheme we can hardly envision any_need for large contingency or engineering costs and are convinced that the cost for adequate in place reclamation can be kept under about $5 million overall.
On this basis, we believe the DOE cost estimates being used at this time to very likely be severly over-inflated. During the cost estimation process, for planning purposes, some level of pessimism reflected in higher than minimum predicted costs would be properly justified.
However, we fail to understand the rationale for cost estimates as exaggeratedly high as those currently presented by DOE for the Vitro Site remedial action.
William M. Shaffer III, Project Manager New Facilities Section Uranium Recovery Licensing Branch Division of Waste Management cc:
Robert W. Ramsey, Jr., DOE-HQ Richard H. Campbell, DOE _AL Robert J. Stern, DOE-HQ William E. Mott, DOE-HQ l
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ATTACHMENT I Preliminary DOE Vitro Site Remedial Action Project Cost Estimate
' Basis:
Recon 60ur entire Vitro Site (128 acres) and stabilize in place above, grade.
Cleanup vicinity properties and dispose of contaminated materials from them on the Vitro Site.
Project Cost Element 5 1981 I.
Construction Processing Site Preparation 1,227,000 Cover (2m)/61n. Topsoil (Proc. Site) 8,945,000 408,000 Surface Reclamation / Fencing (Proc. Site)
Subtotal (Pr6d. Site Base Cost) 10,580,000 Growth Allowance Factor (15%)
1,587,000 Total (Proc. Site Base Cost) 12,167,000 Vicinity Property Cleanup 8,460,000 Project Total (Construction)_
$20,627,000 II.
Engineering -
Processing Site (30% of Total Proc. Site Base Cost) 3,830,000 Vic. Properties (43% of Vic. Prop. cleanup) 3,640,000 Project Total (Enginee~ ring)
$7,470,000 i..
III. Maintainence & Surveillance
$ 250,000 f
IV.
Project Co'ntingency (20% of I + II + III)
$5,700,000 l
V.
Project Total
$34,047,000
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Specific Bases for costs:
1.
1.
2 meters Cover =.1,377,000 cy. @ $5.98/cy 2.
6" Topsoil = 103,000 cy @ $6.88/cy 3.
Surface Reseeding = 128 acres @ S1000/ acre I
kMfM"3C Distribution; WMUR s/f EkN g. I m-WMUR w/f WMUR r/f 39/ISK/82/01/27/0 WM r/f
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DEMartin RScarano BFisher JLinehan WMUR:WMS HPettengill WM-39 REBrowning JBMartin Richard H. Campbell, Project Manager UMTRAP Project Office Albuquerque Operations Office U.S. Department of Energy P.O. Box 5400 Albuquerque, New Mexico 87115
Dear Mr. Campbell:
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.
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Sihterely
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Ross A. Scarano, Chief Uranium Recovery Licensing Branch Division of Waste Management cc:
Robert W. Ramsey, Jr,100E-HQ Robert J. Stern, DOE-HQ William E. Mott, DOE-HQ
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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 EI5 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 ths DEIS), NRC concurrence in the document as a Cooperating Agency.
General Comments:
L 1.
There is no Conclusion Section and thus the preferred course of action is not clearly identified in the PDEIS.
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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).
s.
3:
Non-radiological env4.ronmental. 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 Idng term stability of. the..three major disposal alternatives l
identified.
This section should assess; in particular, the l
predictive probability of meeting the currently Proposed EPA l
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.
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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 actica to be pursued.
As an example of these costs, using the cost of 58.50/ 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. for 3 yrs., the transport cost alone for relocation is now roughly $32,000,000.
Specific Comments (Sec.1):
None (Section currently missing).
SoecificComments(5et.
):
None.
Specific Comments (Sec. 3T:' ~ "" --
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1.
Sec. 3.1.1 (p. 3-1): ' Preceeding SEctrons shB01'd 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 Sect,3.1.1 as.a, facility with intended expansion plans onto the Vitro Site.
In additf6n, this Section should explain breifly why the "no action"~Elternative is inconsistCnt with the UMTRCA since, in effect', such a statement is a partial evaluation of that alternatives 2.
Sec. 3.1.2 (p. 3-2):
The environmental impacts of relocating the Vitro Site contaminated-materials' include those resulting from
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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.
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3.
Sec. 3.1. 2.1 (p. 3-3):
The technical implication of proposing covering a recontoured Vitro Site with 10 feet of ancontaminated 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 intrusio'n 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 oe 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 ac' ion may have to extend beyond t
the contructibh 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-notsibly 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 bf the' South-Clixe S.ite as the prime relocation site.
This comment -directly reflects our concern that close in alternate disposal sites be considered and their acceptability or unacceptabi,lity ful,1y documented.
6.
Sec. 3.1.3.2.(p. 3-7):
A 20 Ft. burial trench depth at Clive may prove techn'ically unaccep. table if..the local water table is as high as 21-34 feet.
With this narrow a separation margin, fluctuations of this table may ultimately result.in groundwater contamination, though we i
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 l
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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 Clivs 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 neecs rewording and explanation to'be clear.
It sounds in error currer.tly.
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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 _tha.t with truck ~
2 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 rathe,r one for each Vitro Site sector.
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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 depending o,n whether truck or rail transport is assumed.
The truck dispose 1 ar'ea is slightly west of the rail disposal area.
This should be noted in Sec. 3.1.3.2 and appropriately documented
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i elsewhere why techni_cally,_this has,n.o effect on disposal scheme j
long term stability.
For example., the final mounded configuration l
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 significantly different erosion potential effect on the disposal area covers.
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--s 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. 3-25):
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 cover 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.
Sees. 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 reflecte1..in.. Environmental Overview Sec. 3.2.
Specific Cocments (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 comple~t'entss 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 a]l tnat disposal areas could be found within its l
boundaries.
Because of its close in. proximity, we definitely feel Utah' County to be part of the Regional Setting of potential disposal areas.for.tbe. 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 PDEIS, we believe the distinction between the 5
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 impressi6n 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 di kes? Projected for what? By whom?
FolloG on Section 4 subsections are just as inadeauate in depth of detail.
6.
rigs. 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 cbtained?
Sec. 4.5.1.2 (p.~4-i2):
Detailed-subsurface-geologic data must be 8.
obtained for the Vitro Site as well as the South Clive Sitd to~
estabilish its basic suitability as a disposal. area.
Is this data being obtained? qThis. qnd_following sections are confusing in regard to the dati comparisch"tetween 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 exampie?
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.
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 i's 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 subta-ilings water. is in fact contaminated?
18.
Sec. 4. 6. 2. 6 (p. 4-41):
The entire seepage analysis needs strongly expanded in detail.' Gr'oun~diater contamination potential is of
-o paramount NRC concern.
The conclusion that chemical barriers inhibit contaminant migration at-the Vitro Site, in particular,,needs -full explanation.
Especially in view of potential " hazardous" seepage.
i j
19.
Sec. 4.7.1.I (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 performance as a liner.
7 i
~
k 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 f ar if this section truly cannot be prepared in preliminary form at thi,s time.
It is not clear from the stated intents that off site measurements will be made in the vicinity of the' Vitro Site.
If they are not planned, they should be.
23.
Sec. 4.9 (p. 4-52): Salt Lake County agricultural land available is portrayed as being essentia44y.non-existent, yet 58,000 acres are present and an obvious question can arise in the reader's mind as to why severaT hundFed 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'ieiocation of Vitro Site materials to
~
Tooele County, simply ~by the.way data is presented, and that is unwarranted in our judgement.
24.
Sec.4.7.1.5(p.4-56):
The sewage p.lant vicinity property has a-been and con,,tinues to be commonly referred to in this program as the CVWRF.
Figure 4-S giuas the-impression-that part of the CVWRF
- ~
will be cleaned up as part of the Vitro' Site; We would like i
confusion surrounding this point to be cleared up and categorically eliminated all throughout the PDEIS.
Further ca 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 t.o building new facilities on Vitro Site tailings.
l l
l 8
l l
6 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 term 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, MILD 05, 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): Jt would appear that the ingestion pathway is ignored, ostensibly because of the lack of data in this regard.
This is more of an indicati_on that a_comput._er. analysis s_hould be performed for the no action alternative to give perspective'to'the ingestion pathway results which will be obtained for the other alternatives.
t l
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 mjght' not be "a substantial contribution, but some discussion shou'ld be presented.
Further,'is milk considered an insignificant pathway?
It doesn't appear to be addressed.
Note also that NRC 7
~
-RG-1.109 -has -been revised tc-add'ress primari-ly-rcactors, and cany of
'^
l -
I 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 l
be at least to the extent needed to document that such impacts may be minimal.
j 9
I
4 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 t 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 "collisio,n".
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.-l. 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 "t.mponery-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'.I '('p. 'S-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.
~
l 13.
Sec. 5.4.2.1<and 5.4.2.2.(p. 5-10,11):
See above Comment 12.
Same comment applies.
l 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 effect 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 de'cisions 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, s'tating 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 (Accendix A):
1.
Sec. A.1 (p. A-1):
The NRC has no specific UMTRAP stabilization standards in the s.ense of direct applicability of its active uranium mill site regul'atio'ns'to Uf4 TRAP 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 C)ive Site.
2.
Sec.~A.1 (p. A-2):
Final selection of the remedial action option can anticipste but.no.t precede publication of the FEIS.
TheFBDUCVdRFRadiologicalandEngineering 3.
Sec. A.2.2 (p. A-6):
Assessment (REA) is for a partial cleanup of the CVWRF vicinity property and not for CVWRF expansion.
However Ref. 1981b. is, even 11
_.. -- ~.--. - - --. -
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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 need t 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.
foot high hill by making greater use of the area availableThis 6.
Sec. A.3.3.2 (p. A-18):
referred to as needed firmly planned by DOE?Are the additional subsurface 7.
Sec. A. 3. 4. 2 (P. A-20,21,22):
changes to make them correct.
These tables (A-3, A-4) need detail NRC' comments were previously provided to DQE on these tables with the same errors present.
8.
Sec. A.-3.4. 2 (p. A-22):
of NRC in evaluating an application for an UMTRAP disposal site will be geare'd however,only,to assuring that the results of remedial action performed by the DOE meet EPA 40CFR192 disposal standards as f.inally. promulga.ted by tha.EPAc"---In-No. 3 of the list time periods (thousands of years)".that follows that paragraph ch See also previous NRC comments on the wording of this list, particularly to correct the language of No. 6. N.
- 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):
It is no't until p. A-59 that the total quantity and distribution of materia.ls..to be-dealt with are mentioned.
front of the EIS. Basic summaryf data such_as this belongs far to the
~
We assume it will eventually be presented in the l
summary and earlier. appearing Vitro Mill Site characterization
)
sections.
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Additional Comments APPENDIX A VITRO 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-acti'an 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.
The location of cros's section A-A and 3-B should be 4.
Sec. A.2.3.1: _,
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 amaiguou,s 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.o{ 3ailings to the South Clive Site in the PDEIS should afso 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 'n the PDEIE.
i 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 l
programs.
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' 10.
Sec. A.3.4.4 (p. A-50): ' The last paragraph' discusses the general rise of ground. water on the site.
What is the actual maximum rise in the water table? Will the tailings be below the water table at any time and, if they will, what could the effect be?
11.
Sec. A.3.4.5~(pg. A-54): The PDEIS states that additional. costs incurred for the increased excavation requirements for complete burial would be significant. This statement is abiguous in that significant is not defined.
12.
Sec. A.3.4.6 (pgs. A-62,A-68): What will be-done with the contaminated water which wo'uld come from dewatering?
13.
Sec. A.3.4.6 (pg. A-67):
"4 cubic-foot front end loaders" should be changed to 4 cubic-yard front end loaders.
14.
Sec. A.3.4.6'(pg. A-67): How are the tailings loaded onto the stacker?
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WM-41,PDR WMartin JJLinehan Richard H. Campbell, Project Manager UMTRAP Project Office U.S. Department of Energy Albuceerque Operations Office P.O. Box 5400 Albuquerque, NM 87115
Dear Mr. Campbell:
a 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 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 th_es.e 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.-ofJRC staff participation on the panel at the public EIS scoping mgetings held May 5~,1981 and May 6,1981 in Salt Lake City, UT and Tooele, UT respectively.
3.
The Apri.1 l'3,1981 DOE Notice of Intent (NOI) to prepare the EIS.
. v.
4.
The May 5 and 7,1981 visits by NRC staff to the Vitro site, candidate disposal sites recom5endeTby trie~'Sta'te of Utah, and selected Salt Lake City vicinity properties.
5.
The April 1981 Ford, Bacon & Davis Utah Inc. (FEDU) Vitro Site Engineering Assessment Report (DOE /UMT-0102, FBDU-360-00).
l 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. Shaf fer III of my staff summarizing the NRC staff site visits and participation in the public meetings noted previously.
Our crimarv concern at this time recardinc Vitro site remedial action is in assu' ring that scoping of the EIS will resiit in fully evaluating all feasible remedial action alternatives.
This concern, reflected in Attachment I, s*
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, Mr. Richard H. Campbell 2
f.llii ! 4 19 8; r.
~
predominantly from,'in our judgment, the very high cost estimate associated with 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 the FBDU Engineering Assess-ment states the overall project cost for these relocation alternatives will range from S78.1 M to 591.0 M as opposed to 535.4 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-2980 dollars.
The 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 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 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, envir'onmental, or other considerations.
Any questions you may have on this matter should be addressed to myself or William M. Shaffer III (FT5 427-4538) of my staff.
We look forward to a similar
-(
continuing participation with the DOE in the scoping and preparation of this
(
EIS and future EISs and-EAs-fon the remainder of UMTRAP inactive mill tailings sites.
Sincerely,
- 'L L=31 Signed by.
G E. A. Scarazo
~
~~
Ross A. Scarano, Chief Uranium Recovery Licensing Branch l
Waste Management Division cc (w/ attach):
^
Robert W. Ramsey, Jr., DOE-HQ l
Dr. William E. Mott, DOE-HQ l
Robert J. Stern, DOE-HQ Dane L. Finerfrock, Utah Department of Health Robert Fonner (ELD) 1
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Shaffer 1/E Gn CjERrein RASc ano gJps/81 e/11/S1 8/r:5 /El 8/g/81 1
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f' Attachment I m
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 op.erations, accident conditions, and following comp contamination,letion of remedial action, focusing on windblown and groundwater contamination potential.
(
7.
Documentation of disposa} site selection procedure and its results.
8.
Cemparative analysis of~ DOE-vs. non-DOE remedial action proposals.
~
9.
Analysis of the irc5act of the lor:a'lly percelWd "negativ~e social stigma" associated with Tooele County, UT on future county development and general psychological well-being of res'idents. -
-~ -
~~~.
10.
Impacts on land-use. plans and pol 1cies of Salt Lake, Tooele and Utah
~
counties.
1 l
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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1 i
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,8 At[tachmentII Tailings transportation cost vs. proposed disposal alternatives (constant CY-1980 $, millions)
Basis:
DOE /UMT0102, FDDU 360-00 Stabilization Far Distant. Relocation
~
In Place Prime Area 1st Alternate 2nd Alternate I
Area Area
'('
Tailings Transport Mode l
tione; Rail Truck Rail Rail t
4 Tailings Transportation Cost.($M) 0;0 l 25.7 36.1 22.2 22.2 RemainderofProjectCost($M)I:
28.0 37.8 33.9 39.7 37.9
^
Total Project Cost ($M) 0.0 63.5 70.0 G1.9 60.1 (Exclusive of contingency) i Transp. Cost as %'of Total Project
'0%
40%
52%
36%.
37%
Cost (Exclusive of Contingency) t t
4 l 8.4 19.0 21.0 18.6 18.0 30% Contingency ($M)
. Total Project Cost ($M) 36.4 82.5 91.0 80.5 78.1 (Including Contingency) 9 f-9
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s Department of Energy g i gg Albuquerque Operations Office q
N P.O. Box 5400 Albuquerque, New Mexico 87115 SEP 15 1981 g
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% L%52:vo.r Mr. Ross A. Scarano E
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Chief, Uraniu: Recovery License Branch U.S.NuclearRegul'atoryCommissi{
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4cifoy Mail Station 483-SS Ocg U
Washington, DC 20555 N
- ti &
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 in the draft EIS will be to relocate the tailings at the site that is directly south of Cli.ve.
Also, equal e=phasis and study will be given in the EIS to the stabilization-in-place option and the price relocation option.
Regarding your eleven issues, our co==ents to en@. of your points are as follows:
1.
" Documentation of the technical basis of the need for remedial action at
~ ~~
~
~
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~
the Vitro site."
This will be included in the EIS.
- m... ~
- 2. - "Co=parative health effects analysis of' stabili:ation-in-place vs.
relocation."
This will be' included in the EIS.
m 3.
"Co=parative ' conceptual. engineering. feasibility analysis of stabilization-in-place vs. relocation."
This will be included in the EIS.
"Co=parative cost analysis of stabilization-in-place vs. relocation."
4.
l This will be incorporated in the EIS.
"Co=parative cost analysis of close-in relocation (10-15 air miles from g'
5.
Vitro site) vs. far-distant relocation (50-75 air miles fro: Vitro site)."
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'r y.Mr. Ross A. Scarano,
Since there are no reasonable close-in relocation sites, a co=parative 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 Cou;se of Action during normal project operations, accident conditions, and following co=pletion of remedial action, focusing on windblown contamination and groundwater' contamination potential."
l Inis will be incorporated into the EIS.
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7.
"Locumentation of disposal site selection procedure and its results."
This issue will be included in sufficient detail.inithe EIS.
8.
"Co=parative 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 stigra' associated with Tooele County UT on future county development and l
general phychological well-being of residents."
Tnis will be includedlin.the_EIS.
20.
"I= pacts on land-use-plans an.d polisies of, Sal _t, Lake, Tooele, and Utah
~
counties."
This issue will be, included in.the EIS for' Salt Lake and Tooele counties, but not Utah county.
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11.
"I= pacts on transportation ne'tworks of tailings transport by rail, truck conveyors, or co=binations 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;
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We look forward to your continued participation in the EIS process.
Sincerely, 38
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N &a/
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ichard H. Ca=pbell, Proj ect Manager Uranium Mill Tailings Project Office
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