ML20055D370
| ML20055D370 | |
| Person / Time | |
|---|---|
| Issue date: | 01/11/1985 |
| From: | Pettengill H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Bailey E TEXAS, STATE OF |
| Shared Package | |
| ML20055D365 | List:
|
| References | |
| FOIA-TUYL90-36 NUDOCS 9007060236 | |
| Download: ML20055D370 (3) | |
Text
UNffID STO.Tl6 pe *:
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c'UCLEAR RECULAT2RY C:MMIS$!Dt.
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i Rt oioN IV URANIUM RtCoy FILLo OFFICE otNyan. coLoRApo ems JAN 11 &
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s URFD:GRK SIS 43 040WM176101E Mr. Edgar D. Bailey, Director Division of Licensing, Registration and Standards Texas Department of Health Bureau of Radiation Control 1100 West 49th Street Austin, TX 78756
Dear Mr. Bailey:
Our staff has completed its review of the " Reclamation Plan Concepts" document for the Conquista, falls City, Texas tailings site as requested l
by the Texas Department of Health.
Although we reviewed the complete report, our comnents are very general and cover consideration of the I
conceptual design aspects of the preferred recismation alternatives, and an evaluation of the radon attenuation calculations as presented in the report.
Per my telephone discussion with your staff on January 9,1985 it is my understanding that a more detailed and formal licensing proposal is forthcoming.
Please be advised that I will gladly provide additional technical assistance to.vour staff on reviewing the formal proposal by Conoco if you so desire.
Since the subject document contained very little analytical data our coments should be taken as general observations of potential technical i
problems that the licensee should address in any formal licensing proposal which is any way parallels the preferred alternatives discussed in the report.
l
- Reclamation Plan Concept -
The licensees preferred alternative, Alternative 1A Conforming Surface, is quite different than any final reclamation design the NRC has considered favorably in tr<e past.
Permitting a permanent body of water to be maintained over reclaimed uranium tailings creates the obvious 9007060236 900515 PDR FOIA VAN TUYL90-36 PDR b//
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'a problem of potential recharge and subsequent seepage of harardous constituents into the nearest aquifer.
We noted that page 11 of the report indicates that some seepage is currently present as evidenced by the embankment drain system collecting some water and the high TDS levels alluded to for surrounding wells.
With this type of seepage present it is simply a matter of time before heavy metals, hazardous. constituents or other relatively immobile ions begin to leach and move.
Removing water from the reclaimed surface and preventing recharge by way of doming the pile and/or using diversion channels are the more conventional reclemation designs comonly used to minimize groundwater impacts.
Since no baseline groundwater data was provided it is difficult to statistically evaluate the results of the water quality data, as presented in Appendix 0, Sum) Water Quality.
Similarly, no detail was given on the completion of t1e sumps.
The docunent contains no justification for the claims of long-term stability.
No erosional analysis of the proposed 3:1 outslopes has been presented.
The NRC always evaluates outslopes for the effects of wind erosion, sheet and rill erosion, and gully erosion.
Without these analyses any final reclamation plan would be deficient.
. Cover Required for Radon Attenuation -
Our staff reviewed of the cover thickness required to attenuate radon using Equation No. 9 from Appendix P to the Final Generic Environmental Impact Statement on Uranium Milling, September,1980.
We found the required cover to attenuate radon to be 52.4 cm or 1.7 feet. This was determined in accordance with the 20 pCi/m's EPA limits using a radon flux at the surface of bare tailings of 43.95 pCi/m s and a moisture e
content of 9.2% in the overburden layer.
This amount differs from that l
stated in Appendh A of the document by approximately 30 percent.
This difference results primarily(from the moisture content we used (9.2%) as i
opposed to that used by WL 32'!).
Our staff feels that the 32% figure is a rather high soil moisture content.
l Our staff also makes the observation that the radon exulation rates used by the contr6ctor (WL) seems low compared to that found at most other tailing sites. This should be verified through existing data or actual i
t P
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enents and the resulting cover thickness calculated Harry J, ke D @,1 Licensing Branch 2 Uranium Recovery Field Office, Region IV cc:
Bob Doda, Region IV Don Nussbaumer, State Programs t
i e