ML20055C933
| ML20055C933 | |
| Person / Time | |
|---|---|
| Issue date: | 06/28/1990 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Matthews M ENERGY, DEPT. OF |
| References | |
| REF-WM-68 NUDOCS 9007020038 | |
| Download: ML20055C933 (26) | |
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JUN 2 31990 Mr. Itark !!atthews Project Manager UraniumMillTai1IngsProjectOffice Albuquerque Operations Office U.S. Department of Energy P.O. Box 5400 Albuquerque, NM 87115
Dear Mr. Matthews:
WehavereviewedthedraftSurveillanceandMaintenancePlan(S&MP)forthe Green River UMTRA site in Grand County, Utah transmitted under your cover letter dated May 3,1990.
Since many details and specifics of your S&MP have been deferred to the final version, our revicw should be considered preliniinary.
1he comments resulting from the review of the draf t SM&P are enclosed.
I would like to emphasizc a general conenent (Corataent No.1). The surveillance plan, in addition to providing the basis for issuance of a general license, will also establish the detailed )rocedures to be followed at each site to help fulfill terms and conditions of t1at license.
Therefore, the final SLFP must address site specific conditions which must be talen into consideration in each S&MP prepared following the DOE generic document, *Cuidance for UMTRA Project Surveillance erd Maintenance *. Since much of this is lacking in this draft we would suggest that DOE consider submitting a revised draf t S&MP, which includes the required site-specific information for NRC review. This will assurethatthefinalS&MPisacceptableandwillnotdelaybringingtheGreen River site under the purview of the itRC general license.
If you have any questions regarding these comments, please do not hesitate to contact me or Sandra hastler of my staff (FTS 492-0582).
Sincerely, I
(SIGNED) PAULH.LOHAUS Paul H. Lohaus, Chief l
Operations Branch 4
Division of Low-Level Waste Management and Decommissioning, NMSS
Enclosure:
As stated cc:
S. Mann, DOE /HQ P. !! ann, DOE /AL L. Anderson, Utah i
Distribution:WCentralcFilefWMk.aRBangart,LLWM JGreeves,LLWM PLohaus,LLOB JSurmeier,LLTB JAustin,LLRB I MFliegel,LLOB 00111en,LLOB SWastler,LLOB BJagannath,LLTB AFan, LLOB TJohnson,LLOB RHall,URF0 NMSS r/f I j LLOB r/f PDR YES X
ACNW YES X
SUBJECT AUSTTICT:
GREEN RIVER T P REVIEW
- See previous concurrence N //
DTC :LLOB *
- LLOB*
- LLMJ
- LLWM
- LLWM
- NMSS
- NitSS NAkESl$st5e IkF5iege5Ibaus
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Mr. Mark Matthews Project Manager i
UmniutiMillTai1IngsProjectOffice Al uquerque Operations Office U.S Department of Energy P.O. Box 5400 Albuq rque, NM 87115
Dear Mr. latthews:
We have rev owed the draf t Surveillence and Maintenance Plan (S&MP) for the Green River TPA site in Grand County, Utah transmitted under your cover letter dated 3, 1990.
Since many details t.nd specifics of your S&MP have been deferred tt the final version, our review should be considered preliminary.
The consnents resh ting from the review of the draft SM&P are enclosed.
.I would like to re. erate a general consnent (Consnent No.1) made originally regarding the Spook iP review which I believe is applicable to the Green River S&MP review. Th surveillance plan in addition to providing the basis for issuance of a genera license,willalsoestablishthedetailedprocedures to be followed at each sit to help fulfill terms and conditions of that license. With this is mind, care should be taken to consider the site-specific conditions when making genera references to requiren,ents in the DOE generic document, Guidance for UMTRA
'oject Surveillance and Maintenance".
If you have any questions regardir these corments, please do not hesitate to contact me or Sandra Wastler of ray -taff (FTO, 492 0582).
Sincerely, Paul H. Lohaus, Chief Operatio Branch Division Low-Level Waste Management and Decon ssioning, NMSS Enclosurc: As stated cc:
S. Hann, DOE /HQ P. Mann, DOE /AL L. Anderson Utah Distribution:
Central filedWM43 RBangart,LLWM JGreeves,LLWM P haus,LLOB Ulurmeier lITB JAustin,LLRB MFliegei,LLOB DGillen,LLOB SWa ler,LLOB BJagannath,LLTB Afan, LLOB TJohnson,LLOB RHall,URF0 NMSS f
LLOB r/f PDR YES X
ACNW YES X
SUBJECT ABSTREDT:
CREEN ER~IIRP REVIEW DTC :LLOB
- LLOB U :LLOB
- LLWM
- LLWM
- lN55
- NMSS d
l NAME:s
- MFliege
- PLohaus DATE: Mp/90
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e UMTRA DOCUMENT REVIEW FORM SECT 10T1 Site: GREEN RIVER. Utah Document: Surveillance and Maintenance Plan Comentor: Nuclear Regulatory Comission Date:
June _5,_1990 Comment: GEtiERAL 1.
Once the NRC rulemsking is complete, the general license will contain a condition that requires care for the site in accordance with the provisions ofthesurveillanceandmaintenanceplan(S&MP).
Therefore, the provisions of the S&MP will become license conditions.
Because of the eventual incorporation of the S&MP provisions into the license, care should be taken to consider the site specific conditions when making wholesale references to requirements in the DOE generic guidance document. References should be specific, direct, and qualified if necessary.
When revising the draf t S&MP, DOE should review all references to the generic document to insure that all referenced requirements are appropriate for and consistent with the S&MP. Deviations from the generic procedures in the Guidance Document should be justified.
In addition, although it may be appropriate for this early draft to be written in terms of proposed or present conditions, the final form of the S&MP should be written in terms of post-licensing conditions.
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.. ' S, UMTRA DOCUMENT REVIEW FORM 5ECTION 1
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1 Site: GREEN RIVER, Utah Docurent:
Surveillance and Maintenance Plan Commentor:
Nuclear Regulatory Commission Date: June EI 1990 Comment:
Page 5. 5ection 2.1. first paragraph 2.
DOE states that "The surveyed legal description of the Green River disposal site is provided on Figure 2.2".
However, Figure 2.2 provides no legal description of the site.
A legal description is provided on the last un-num>ered figure in the S&HP.
DOE should correct this discrepancy.
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UMTRA DOCUMEliT REVIEW FORM SECTION 1 Site: GREEN RIVER, Utah Decument:
Surveillance and Maintenance Plan Commentor: Nuclear Regulatory Commission Date: June 5, 1990 Comment:
Page 5. Section 2.1, second paragraph 3.
00E states that the State of Utah will transfer title of the six-acre permanent disposal site over to the federal government upon completion of renedial action. Since this transfer should be con.plett prior to the submittal of the final S&MP, DOE should provide the appropriate docunientation to 1
dercnstrate completion of this transfer.
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e UMTRA DOCUMENT REYlEW FORM 5ECTION 1 Site:- GREEN RIVER, Utah Document: Surveillance and liaintenance Plan Commentor:
Nuclear Regulatory Consniss4fj Date: June 5, 1990 Comnenti' Page 10, Section 2.3 I
4 DOE states that eight boundary manunents and three survey monuments will define the eleven corners of the legal boundaries of the unfenced, irregular shaped permanent disposal site. However, DOE's Guidance Document states on page 11 that three survey monuments are the minimum established.
DOE should provide the basis for determining that the minimum number of survey monuments was sufficient to define the site boundary.
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< s UMTRA DOCUMENT REVIEW FORM-SECTION 1 Site: GREEN RIVER, Utah Document: Surveillance and Maintenance Plan Comentor: Nuclear Regulatory Cunmission Date: June 6, 1990
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Coment: Page 26 7.
The interim concentration limits for Gross Alpha in the final TER is 24.5 pCi/1, not 195 pC1/1.
DOE should modify the S&MP to show the correct
- value, s
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UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: GREEN RIVER, Utah Document: Surveillance and Maintenance Plan
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Commentor: Nuclear Regulatory Commission Date: June 6, 1990 Comment:
Page 2T 8.
In the RAP DOE committed to the monitoring of the moisture content of the radon barrier, residual rcdioactive material, and the buffer layer in order to estimate water flux.
There is no discussion in the S&MP of monitoring the soil moisture as previously cor.mitted in the final RAP. The neutron access tubes have already been installed. The effort to provide additional msnitor ng of soil moisture is minimal in comparison to other monitoring requirenents..
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UMTRA DOCUMENT REVIEW FORM ECTTDN 1 Site: GREEN RIVER, Utah Document: Surveillance and Maintenance Plan Commentor: Nuclear Regulatory Commission
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Date: June 6, 1990 Comment:
Page 31, Section 4.0 5.
In Section 4.0, DOE has stated that the procedures for conducting Phase I and II inspections are in the Guidance Document and that the procedures outlined in the S&MP are guidelines for conducting these inspections.
DOE also indicated that a detailed,-site-specific Phase I inspection plan, a site inspection check list, procedures for a Phase II inspection, and procedures for conducting contingency inspections will be established at some latter date. These statements appear contradictory.
Based on a lack of any site-specific data and the implication that what is in Section 4.0 will be changed, the liRC has only conducted a very cursory review of this section. NRC will conduct a detailed review of the final S&MP.
However, DOE should note the following:
IIRC and the State of Utah should be provided with an up-to-date copy of the site file.
While phase II inspection plans must be tailored to the specific situation that would cause them to be initiated, it is possible to provide some information in the S&MP. At a minimum, the most likely situations or circumstances that may require a phase II inspection at Green River should be discussed and general discussion of elements of the phase II inspection plans should be provided.
3ECTION 2
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s' UMTRA DOCUMENT REVIEW FORM l
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SECTION 1 Site: GREEN RIVER, Utah Document:
Surveillance and Maintenance Plan Commentor: fluclear Regulatory Commission Date: June 6, 1990 Comment:
Page 24, Figure 3.1 6.
The new background wells are to be located near the upgradient toe of the disposal cell. The reason for locating them so close to the disposal cell is not clear. The NRC staff is concerned that these wells at the proposed locations may be inpacted by the tailings due to the following circumstances:
(a) The use of construction water might create a transient ground-water raound thatpushedtheleachateupgradient,and(b) surface runoff and other constructicn activities might spread the contaminants beyond the upgradient toe of the disposal cell.
If the POC wells are found to be tainted during inonitoring due to unforeseen circumstances, there is a good chance the new background wells at the proposed locations may also be tainted.
DOE should consider relocating the new background wells further away from the disposal cell.
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f UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: GREEN RIVER, Utah Document: Surveillance and Maintenance Plan Commentor: Nuclear Regulatory Connission Date: June 7, 1990 Comment:
Page 28 9.
Where possible, the S&M Plan should provide sufficient information to denionstrate that the proposed S&M monitoring will not impact the postponed groundwater cleanup and restoration.
The Plan should, as a minimum, indicate that when the grcundwater cleanup and restoration plans are developed, that the S&MP will be reviewed and modified as necessary to insure no impact.
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' gI e-UNTRA DOCUMENT REVIEW FORM SECTION 1 Site: Green River, Utah Document:
Surveillance and Maintenance Plan Commentor: fluclear Regulatory Commission Date: June 12,1990 Comment: Figure 2.3 - Final Site Plan enlarged copy in the final;:ert is illegible; please provide a legible and
- 10. This figure in thc i+
report.
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i UFURA DOCUMENT REVIEW FORM SECTION 1 i
Site: Green River, Utah Document:
Surveillance and Maintenance Plan Commentor:
Nuclear Regulatory Commission Date: June T27 1990 Comment:
Page 10, paragraph 1
- 11. The last sentence is not clear; a line seems to be missing. Please
- I verify this.
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.r UMTRA DOCUMENT REVIEW FORM
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SECTION 1 Site:
Green River, Utah Document: Surveillance and Maintenance Plan Commentor:
Nuclear Regulatory Commission Date:
June 12, 1990 Comn,ent:
Secticn 2.3.3 Permanent Site Marker, Page 12
- 12. Site marker SMK-1 is set in a bed of concrete that extends to a depth of 36 inches below the ground surface.
Section 2.6.3 of the DOE guidance document requires the site markers to be set in concrete that extends below the frost line.
The frost depth at this site is 39 inches; therefore, the foundation of the site marker should be extended down to a depth of at least 39 inches.
The same is true for marker SMK-2.
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UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: Green River, Utah i
Dc'cunent: Surveillance and Maintenance Plan Commentor: Nuclear Regulatory Commission
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Date: June 12, 1990 Comment:
Figure 2.8 - Site Markers, page 16
- 13. The dimensions shown in the details for SMK-2 are inconsistent.
Please verify the dcmensional details of this sketch.
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't UMTRA DOCUMENT REVIEW FORM SECTION 1 Site:
Green River, Utah Document: Surveillance and Maintenance Plan Commentor: Nuclear Regulatory Commission Date: June 12, 1990 Coninent:
Section 2.5 - Aerial Photography
- 14. This section indicates that an aerial photo of the site will be taken to document the final site conditions after remedial action at the site is conipleted. There are no plans for subsequent aerial photos of the site, say at intervals of 5 years or so. The Generic Draf t Survt111ance and Haintenance Guidance Document, July,1988, prepared by the DOE subsequent to the guidance document of 1986 for UMTRA projects, requires aerial photos to be repeated at 5 years from start of surveillance (Sununary Table and Section 5.1.1, PaSe 65).
This would help in detecting any gradual occurring t.hcnge at the site.
The DOE should justify why only one set of aerial photos will be used to evaluate the gradual changes at the Green River site.
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UMTRA DOCLMENT REVIEW FORM SECTION 1 Site: Green River, Utah Date: June 19, 1990 Document: Draft Green River Surveillance and Maintenance Plan (SMP)
Commentor: U.S. Nuclear Regulatory Connission Comment: Section 1.1, Page 2, Second full paragraph starting with: "As l
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a result of the Amendments Act..."
- 15. The only case where a "two-phased" approach to licensing occurs is when either SIP or SOS involves aquifer restoration.
If the disposal site is relocated, then two phases are not necessary. The disposal r,ite will be
. licensed upon proper stabilization and completion of remedial action.
If the processing site requires additional time to complete aquifer restoration, the NRC completion concurrence would be conditional, until restoration is achieved.
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.j UMTRA DOCUMENT REVIEW FORM j
I SECTION 1 Site: Green River, Utah Date: June 19, 1990 e
Document:- Draf t Green River Surveillance and Maintenance Plan (SMP)-
Connentor: U.S. Nuclear Regulatory Commission Comment: Section 1.2 Page 2,
- 16. Add the underlined text:
o Disposal site ownership....
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,e UMTRA DOCUMENT REVIEW FORM
_SECTION 1 Site: Green River, Utah --
Date: June 19, 1990 Document: Draf t Green River Surveillance and Maintenance Plan (SMP)
Commentor: U.S. Nuclear Regulatory Consission Ctmment: Section 2.1 Page 5.
17.
This section should refer to Attachn.ent 7 as the legal description of the land (containin Utah to DOE; i.e., g the disposal site) to be transferred from the State of clearly indicate what 6 acres are being transferred.
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,i OliRA DOCUMEliT REVIEW FORM j
SECTION 1, Site: Green River, Utah Date: June 19,1995~
Document: Draft Green River Surveillance and Maintenance Plan (SMP)
Commentor: U.S. Nuclear Regulatory Commission Connent: Chapter 2.0 Pages 5-9.
18-a.
The baseline data maps in the SMP do not appear to convey the information described in the DOE " Guidelines for UMTRA Project Surveillance and Maintenance" document (January 1986).
For example, land ownership is not clearly-indicated in the vicinity map, the site area map nor in the Attachment 7 map.
18-b. Furthermore, the site map scale is less than 1:200, as specified in the DOE generic guidance document.
18-c. Figure 2.3 is not legible.
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,e UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: Green River. Utah Date: June 19, 1990 Document: Draft Green River Surveillance and Haintenance Plan (SMP)-
Comnientor: U.S. Nuclear Regulatory Commission
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Consaent: Section 2.3.2 Page 12.
19.
This claims that there are eleven Model A-1 boundary monuments.
The map indicates only 8, as well as does Table 2.1.
It appears that the survey monuments also serve as boundary monunents, but A-1 and 1
RT-1 markers.are dif ferent.
This needs to be clarified in the final SMP.
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fr 4 Q' UMTRA DOCl#4EllT REVIEW FORM SECTION 1 Site: Green River, Utah Date: June 19, 1990 Document: Draft Green River Surveillance and Maintenance Plan (SMP)
Consnentor: U.S. Nuclear Regulatory Consission Consent: Section 3.3 Page 25-27.
20-a. The two-year quarterly sampling program should also investigate the existence of other hazardous constituents, because of the limited background-ground-water quality data upon which it whs based.
20-b. The statistical procedures should be consistent with EPA interim guidance on statistical analysis of ground-water monitoring data at RCRAfacilities(April 1989).
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UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: Green River, Utah Date: June 19, 1990 Document: Draft Green River Surveillance and Maintenance Plan (SMP)
Commentor: U.S. Nuclear Regulatory Comission Coment: Section4.132Page32,
- 21. The S&MP indicates that the UMTRA site files will be held in the DOE Albuquerque office, but that the S&M inspections will be conducted by the Grand Junction office.
If this is the case, it seems more appropriate for the GRJP0 to have the site files or a copy of the files.
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.w UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: Green River, Utah Date: June 19, 1990 Docunent: Draf t Green River Surveillance and Maintenance Plan (SMP)
Commentor: U.S. Nuclear Regulatory Commission Concent: Section 5.0 Custodial Maintenance. Page 37.
- 22. The S&MP states that "It is anticipated that activities described above (custordial maintenance) could be conducted without the need for an annual inspection." NRC regulations, however, require, at a minimum, an annual inspection of the site to confirm integrity and to determine any need for maintenance and nonitoring.
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.. e UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: Green River, Utah
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Date: June 24, 1990 1
Document: Draf t Green River Surveillance and Maintenance Plan (SMP)
Commentor: U.S. Nuclear Regulatory Commission Comn.ent: Page 19 23, A phase II inspection should be conducted long before gullies become 7 feet deep at the apron. We su99est that the need for a phase II inspection be determined when any gully of about 2-3 feet in depth occurs within about 200 feet of the apron, i
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UMTRA DOCUMENT REVIEW FORM SECTION l' Site: Green River, Utah Date: June 24, 1990 Document: Draft Green River Surveillance and Maintenance P16n (SMP)
'Commentor: U.S. Nuclear Regulatory Commission Comnent: Page 32
-24 Gullies should be included in the field inspection, along with any other signs of erosion, i
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