ML20056A723
| ML20056A723 | |
| Person / Time | |
|---|---|
| Issue date: | 08/07/1990 |
| From: | Wastler S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Mann P ENERGY, DEPT. OF |
| References | |
| REF-WM-43 NUDOCS 9008090104 | |
| Download: ML20056A723 (15) | |
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. Mr. Paul Mann Uranium Mill Tailings Remedial 1
ActionProjectOffice U.S. Department of Energy Albuquerque Operations Office P.O. Box 5400 Albuquerque, NM 87115
Dear Mr. Mann:
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Under a cover letter dated July 12, 1990, NFC received for review and signature two copies of the Lowman, Idaho draft Remedial Action Plan (dRAP) meeting minutes. The NRC staff has reviewr.d the draft meeting minutes and l
our comments have been marked on the attched t.,py of the minutes, as requested.
Upon resolution of these comments, the NRC will be prepared to sign revised
- meeting minutes.
I The NRC staff felt that the informal review and site visit / meeting, as proposed in the draft MOU based on streamlining and applied at the Lowman site, was very successful. However, in order to preserve the informal nature of the.sitt, visit / meeting as intended in the MOU, in the future meeting 1. summaries should be completed and signed at the conclusion of the site visit / meeting.
If you have additional questions regarding this information, please contact me at 492 0582.
Sincerely.
ORIGINAL SIGNED BY Sandra L. Wastler Project Manager Operations Branch Division of Low. Level Waste
,g Management and Decommissioning g
Distribution:
Central File fWM43 NMSS r/f Sa RBangart JGreeves JAustin JSurmeier PLohaus g
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SUBJECT AB3TRXCT: LOWMAN SITE VT5TT/ MEETING MINUTES Q
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..L-o001t0W/MTG/ COMMENTS MLit '
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IDMAN DRAFT REMEDIAIHCTICN PIAN MEETIM3
'l BOISE /IDMAN, IDMO, JLNE: 13, 1990 i
'IO DISCUSS NIC CDNENTS CN DRAFT RAP
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me list of attervba is shown as Attachment 1.
Se participants drove to i
the Iowman, Idaho site and spent approximately three hours investigating the present condition of the processing site. W e meeting reconvened in Boise, 1
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Idaho to review the preliminary NFC coments and discuss any changes to the Ws, d#gM P
coments as a result of the site visit.
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he preliminary NRC coments are included as Attachments 2.ri.7 Sardra 4/,
Wastler discussed the Geology Aport ccaments included in Attachment 2 and g
'J-stated that only coment 6 regarding the U.S. Forest Service land upelope of g
the disposal site should be deleted. B is change was nede because the state g pf and DOE: are working to purchase this land to ensure uncontrolled harvesting
$M 7Ml will not occur on this slope.
Sandra Mastler also discussed the next section in Attachment 2 dealing with the use of elevated ocncentrations for verification of cleanup. mese i
comments were usade by G. Gnugnoli who was not in attendance. Comant 6.3.1.
dealing with long-term moisture can be deleted.
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f-s.g ATTACHMENT 2 i
i ItiE9BI6NI URIJCE Ther -^teched commentte o questiuns have rosulted from the IlhC's ruview of t rim L oviun drat t Norr _*di al Action Selection Repor t (RAS).
Undar otreasta ining agrwment 3, NRC is to prova do verbal co:nments on the dratt RAb at a si to v ' ci t mee t. i ng.
Thoso inf ormal comments are being provided t.o DDE an a convenience but should not be considered formally trcnsmi ttod comments, nor sh.s11 t hey be censidered as all
.:ncomg wsing.
Tho.RC utaff does not expoct DOE to pr ovide f ormal rocponsoc t o the it di vidual comments / questions, but to tal e these
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comments into ace. tnt in the preparation of the final RAS.
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- l NRC COMMENTS ON THE LOWMAN DRAFT REMEDIAL ACTION SELECTION REPORT G gmg 41. g l _8g t i ge_ Spi ggi190_ Byp gt t _ r_ G3 t e g b e e01, pa _ Gg ol gg y_ B gg gti 1.
.Soction 3.1.
Projected Climato Variation - With regard to f
temperature and precipitation, DOE has indicated that
...extremo j
ovente encending the ange of historical variability probably have occurred and may recur within the lifetime of a tailings dinposal facility.
The geomorphic stability of surfaccc at the site can ha
-afeccted eithier by entremo events or by brief shifts in average conditione, especi al l y if tho landscape is sensitive to change".
The shallow soil on the upper slope suggects that the l andscape at this oito Au cenr.itive to change.
'.o comply with the EPA standard. DOE
-muut demonutrete that the tailings pile is designed to control the toilings for 1000 years to the extent reasonably achievable and, in cny case, for at least 200 years.
The demonstration of stability for thoco time periods must includo the offect of brief chifts in average conditioon, as well as extreme ovents.
DOE should determine the cffect of theso climatic events on stability.
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2..
Soc.ti on 6.1 and 6.2 - DOE should provide a more detailed diFcuchion of the characteristice which allow definition of the uoicmotectonic provinces in the site area, the characteristics that define the Idaho Suismic Zone (ISZ), the rationale for concidering the I S Z.au a subplato margin, and the inturrelationship of these factora.
DOE uhould include a discucsion of the technical evidence used to define-the couthern boundary of the ISZ au shown on Figure 6.1 and the Platu 1,
including more data on the similarity of north-south extension between the ISZ and the Snake River Plain, the fault plano col u t i on s, and the rationale f or the aseismic nature of the Snake River Plain.
DOE should provide a figure which shown local heat flow measurements, hot cprings, the location of geomorphic evidence, and cny other feature used to define the ISZ.
3.
Section 6.3 - DOE should provide additional information on the the seismic characteristics of the Basin and Range Structure Provinco, 3
including the location of the Borah Peak earthquake, the f ault plane inochani sm f or the Borah Peak event, if avai l ab l e, and a discussion of the difference between the Borah Peak event and other major events in this province.
DOE should also discuss whether this event, since it
' is not characteristic of the Basin and Range earthquakes, is more characteristic of the Intermountain Sei smic Belt or the 'ISZ.
4.
Section 6.4 - DOE should provide cuf ficient data to support the conclunion that the potential for large earthquakes in the Northern Cordillera is low compared to their potential in either the Idaho Batholi th Province or the Basin and Rango Province.
5.
Section 7.2 - DOE has concluded that the potential for volcanic activity is low within the batholith and mcderate to high east of the
. Batholith within the ISZ.
DOE should expand their discussion of the rationale for considering the. geothermal springs in the southern
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le batholith as meteoric and rationale f er :ensiderino the hot sprirgs cast of the batholith as magmatic.
DOE chould give cons 2 deratior in this discussion to the f act that the location of the southern boindary of the ISZ is tenuous, that het springs are related to the ISZ as a ebb-plate margin and that hot springs are located close to the site.
6.
Section 7.3 - DOC has stated in this section that clear cut sjH harvut. ting or harvesting with heavy equipment theyJd not effect the b')A sicpu to the drainage divide immediately above the disposal site.
D;ccuac this is e question of the stability of the tailings pile and 3'I rP4) compliance with the EPA standard, DOE's discussion of the timber ggf3 hcrvesting and the potential offect on the site should be expanded to J determine proci sely whether or not.the clear cut harvesting in areas l, )
outsido the boundary will affect the site.
If the site is impacted, this impact must be considered and mit2 gated by the design.
7.
Section 7.4, Epirentrol comrtlation - DOE indicated that Dewey (1987) relocated the epicentern vor a*1 macroseismic carthquakos in central Idaho from 1944 to 1988.
NOA-data files do not reflect these cpicentral l oc a t i ons.
DOE should provide the justification f or using the relocated epicenters in their analyuis of seismic sources.
DOE thould provide a Table which contains the relocated epicenters of D:way along bide the NOAA date on these earthquakes.
O.
Section 7.4, Effects on ME of other seismotectonic provinces in the' region
. DOE should provido the Justification for the FE dst er mi n'ed for each seinmotectonic province.
The RAS only discusses previous studies by Algermissen, the capable faults within 65 km, and the largest earthquake associated with structures in the Ocismotectante provinces.
9 Section 7.4, Deadwood Fault, page 64, last paragraph - DOE states that all f aul ts wi thin the east-west trending idaho Seismic Zone should be considered capable".
If this is the case, then based on the definition of a capable fault, those faults entending from the ISZ into the sito area should be considered _ capable.
10.
Section 7.4, Cat Creek Fault, page 66, 1st paragraph - DOE indicated that there are younger fractures that offset the Trans-Challis trending east-west with the South Fork Payette River DOE else implied that this system is the active system of the ISZ in this section and the their discussion of the Deadwood Fault.
DOE should provide a discussion of this active aast-west system in the ISZ.
11.
Section 7.4, Monte:uma Fault - DOE states that there is evidence
'to suggust-that the fault has been active during the Quaternary.
Then concludes that because of an absence of associated seismicity and the l
Icck of evidence of dissected Quaternary deposits, the fault not be L
considered capable.
These statements are contradictory and should be l
clarified.
12.
DOE should provide the f ollowing ref erences, where possibles
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4 K111sgaard, et al, 1970, 1986. 1983 LaForge and Hawkins, 1987 Gilburt, et al, 1983 Witkind, 1975 Deway, 1987
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COMENTS ON THE USE OF ELEVATED CONCENTRATIONS FOR VERIFICATION OF CLEANUP Overall general comment on use of NRC 1981 " Disposal or Onsite Storage of Thorium or Uranium Wastes from Past Operations", in applying supplertental standards under criterion (f) of 40 CFR Part 192, Section 192.21 fo" processing sites in cases of SIP, SOS or relocation disposal:
The DOE keeps referencing the NRC 1981 staff position on guidelinen for concentrations of thorium and uranium wastes in soil. This position is incorrectiy cited.
Its title is: Disposal or Onsite Storage of Thorium or Uranium Westes from Past Operations. This position was written to replace 10 CFR Pat t 20, Section 20.304, which provided general authority for disposal of radioa:tive wastes, under certain conditions, by burial onsite in soil.
It is a position for disposal of radioactive material under certain ccnditions, not a cloanup criterion. The guidan e in 46 FR 52061-52063 states that
... currently licensed operations will be conducted in such manner as to minimizt the possibility of soil contamination and when such occurs the contamilation will be reduced to levels as low as reasonably achievable." Use of the guidelines in this NRC position paper, therefore, does not avoid the requirement in 40 CFR Part 192, Section 192.22(b) that levels be reduced to y
ALARA. Furthermore, this position is now being revisited to determine consistency with the present Deconsnissioning Rule for Nuclear Facilities (53 FR 24108), which became effective on July 27, 1988.
SPECIFIC COM ENTS Section 6.3 RADON BARRIER PARAMETERS gf Lb
.3.1 Long-te7 oisture I
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) ears to b some con usion in th sterminol in th, secti n.
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m moisture dry eight."
6.3.2 Radon diffusion
- 1. The diffusion coefficients do not seem to correspond with the other parameter values cited in section 6.3.
The MK-E calculations (Volume III) indjcate that a least squares fit of measured data yielded a 0.035 cm /s rather than using a 0.058 cm /s calculated value (using other l
measure parameters in section 6.3). The text of the RAP should provide the coefficient of determination for the fit riisplayed in Figure 4.4 (sheet 18) of the MK-E calcult. tion document.
- 2. Likewise, the coefficient of determination should be provided for the fit I
of the diffusibn coefficient of the cover matorials. This value, as in the case of the above consent, provides the render with the level of confidence in the fit.
l 6.3.3 Radon Emanation The NK-E calculations (Volume III) recornend using a emanation rate of 0.037, and the computer runs of the RAECLM code use this value. The text should be corrected to reflect this.
i e.
8 Section 6.5 $1TE CLEANUP 6.5.1 Radiological site characterization The later discussion of elevated values and supplemental standards in section 6.5.3 with regard to natural uranium and thorium (Th-230 and Th-232) raises thr. question on the existence or extent of such contamination.
$1nce DOF is proposing to leave soils contaminated by elevated uranium and thorium levels in place, the RAP should provide information, for instance in Table F.2, relating to the expected extent of this contamination in terins of rasionuclide, radioisotope radioactivity, voluse, areal extent of contamination, cost for ranges, of cleanup criteria, etc....
This information would need to be available to DOE before considering use of less stringent standards than those in Subparts 8 and C of 40 CFR Part 192.
Clearly, concentrations of uranium or thorium above background levels could result in total Ra-226 concentrations in excess of the Subpart B criteria, depending on the soil concentration of Ra-226 above background, which is left in place.
6.5.2 Standards for cleanup This section appears to be inconsistent with the discussion in the second paragraph of section 6.5.3.
DOE needs to request NRC concurrence with such use of standards as part of the NRC concurrence with selection of remedial action. The verification discussion should consist of the mechanisms to be used by DOE to verify that the standards, whether supplemental or primary.
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are met.
6.5.3 Verification of cleanup i
- 1. It appears that the DOE is contemplating the use of the same criteria used for the Rifle, Colorado processing site remedial action excavation as generic criteria for leaving elevated levels of uranium and thorium in place, in lieu of meeting the primary EPA standards for onsite cleanup at UMTRA sites.
Is there any evidence, other than elevated gamma measurements in Table 6.2, that such contamination exists? MK-E Calculation 12-622-01-00(VolumeII)providesnoinformationotherthan Ra-226.
- 2. The last sentence of the first paragraph implies that DOE may leave contamination in place if some 100-square meter areas averaged values in excessofthesoilconcentrationsinSection192.12(a)? DOE needs to clarify this statement, since it appears to say that DOE will not comply with the standard,ideration of such actions is addressed in Section if construction constraints dictate it. Some allowance for cons 192.21, and some further explanation should be provided.
- 3. In light of the general comunent on using the NRC 1981 reference, the DOE should key the application of supplemental standards under criterion (f) of 40 CFR Part 192, Section 192.2'..
This should be addresses in section 6.5.2.
- 4. If DOE proposes using a generic urotocol for cleanups in areas around the l
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q e-waste encapsulation or at processing sites, where the~ tailings are relocated, this should be proposed as a generic procedure in the DOE Health Physics Procedures Manual.
However, using the NRC 1981 onsite disposal position in a generic fashion is not appropriate. Residual radioactive material in Title I of UMTRCA is not included in any of the four options discussed in the NRC position. However, the cleanup standards for UMTRCA Title I cleanups. This is not
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EPA in the draft criteria are consistent with the cleanup levels cited.
that 10, 30, or 35 pC1/g are not legitimate cri+.eria for cleanup vated levels of uranium and thorium in specific situations, but to or justification on an NRC staff position related to a different situat on is not in and of itself sufficient.
d,. In order to resolve what appears to be a pervasive problem at UMTRA sites I
with regard to elevated uranium and thorium soil concentration levels, a meeting should be held to attempt to establish a protocol, which will be both protective and consistent with the intent of the EPA cleanup standards in Subpart B of 40 CFR Part 192, as well as being sufficiently flexible for the contractors' use within the framework of the construction effort.
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Infomal Review of Losanan. Idaho Draft RAP Geotechnical tagineering ft[p-g 1.Section3.ibof'theBenedialActionSeixtionBeportindica that FigureLl.
. Volume.1 of the informatica;3er, Ridders shaus.~
location of test last e
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~.'-Although '
i these berities"are ameociated with the etetamination tion', they provide important inforination (material descriptions, blow oounts) and should be included on the borehole location plan.
- 2. All of the samples of the radioactive sands were collected from.the top 2.5 feet of the piles.
Evidence should be provided to demonstrate that these L
zurface samples are representative of the entire depth of the piles, i
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- 3. The slope stability analysis (short-term with earthquake loading case) l moulted in a factor of safety squal to the minimum allowable. h failure l
surface occum in the foundation colluvium, h colluvium layer strength parameters used in the analysis are hamad on an average of only two UU l
tests.
In order to obtain e better basis. for the strength parametere for l
this critical layer, consideration should be given to performance of I
additional lateratory stranrth tests.
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- 4. h sodel for the slope stability analysis included a thin, partial layer of i
colluvium on the steep slope above the disposal cell. What is the basis for l
the characterization of the thickness and extent of this layer? What are the results of a shallow surface failure analysis applied to this layer? If the resulta indicate potential for failure, what would be the impact to the disposal cell, i.e.
ditch clogging, oover disruption?
- 5. h slope stability analysis does not appear to have considered a potential failum surface through the alluvium on the Clear Creek embankment at the toe of the tailings cell.
This case should be analysed.
- 6. h Pa== Mal Action Plan dm==ntation contains no dinoussion relative to the protection of the redon barrier from the effects of frost degradation.
Diammaion on the potential for damage due to frost should be provided.
- 7. Typos:
- Pamadial Action Selection Report Table 3.1; Data for the in situ tailings, rulocated tailings and radon barrier are all under the wrong colusna and'the unit weight data is missing.
- Remedial Action Selection Report. Section 3.3.5; Paragraph 1 reference to Section 3.2.2 should be 3.3.3.
Paragraph 5 reference to Detail 1 should be Detail 3.
- Calculations, Vohane II, 17-624-01-00 Material Properties, Summary of Colluvial Test Resulta; !baple 027-5 classification is wrong - OC should be SC.
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= J.2 LOWMAN PRELIMINARY RAP
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QUESTIONS ON GROUNDWATER j
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4es.uspermeettaquifer is a localized unit with limited
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DOE should attempt to delineate the boundary of this aquifer by mapping'the elevation contours of the alluvaum/ bedrock
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interface.
2.
Is there a deeper regional aquifer and what is the depth?
3.
The conclusion that the on-site tailings pore water and groundwater are superior to the background soil pore water and groundwater is contradictory to common sense.
The site physiography is no different from the neighboring background areas and the tailings could not have improved the groundwater.
If it can be proven beyond scientific doubt that the above conclusion is valid, then the need for groundwater cleanup. surveillance monitoring and infiltration control may no longer be warranted.
4.
There are two upgradient lysimeters (613, 614) but only one was sampled.
There is no upgradient backgroand well.
None of the background wells are within the same hydrogeologic unit, though they are affected by similar physiographic
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The data are insufficient to prove, conclusively, the on-site water quality is superior to the background quality.
Additional background lysimeters and at least one L
upgradient well should be installed.
Toxic characteristics
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leach tests (EP toxicity) can be conducted on background and l
on-site soil samples, and tailings, for comparison purposes.
I S.
Wells 577 and 584 may be used s cross-gradient background
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wells but no water quality data were presented.
Why?
The O20 series wells were utilized to construct the water table contours, yet no water Quality data were presented.
Why?
6.-
What are the flow conditions (high, low or normal) when the surface water samples were collected.
Why no stream sediment samples were collected?
7.
The water quality data are presented as final products without any descriotfan an_tew_sampli_n_g activities and QA/QC procedures." It is difficult to judge the validify~71 tht
' data.
There should be an anoendix to include a der.ription of the sampling procedures. GA/DC methodology, sampisng and GC logs, and other relevant information.
The tabulation of the water quality data should include a synopsis of the QC i
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a parameters, such as, ionic balance calculations, blank or z:
spike sample data, and other relevant information.
Unusual.
- - ( p' circumstances that may affect the sample results should be
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noted, including but not limiting to the followingt T
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(alin' ability to purge the well and obtain recovery, syn.?;/, --
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(b) difficulty in filtering the samples due to excessive sediment, (c) suspect of cross-contamination, (d) suspect a contamination by filter sand, bentonite, cement grouts or~
well casing, and (e) interference by well construction mothedF47'N and lab environment.
Leach tests should be conducted on
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filter sands and grout materials for comparisen purposes.
t 8.
By definition of the Act the term " tailings" means the 44:
remaining portion of a metal-bearing ore after some or all of such metal, such as uranium, has been extracted.
- Thus, the need to distinguish " radioactive sand" from " tailings" may not be justified.
i 9.
The radon barrier is only 1.5 feet thick.
DOE must demonstrate that it is sufficient to withstand biotic 4
intrusion, desiccation cracking,.and freeze / thew weathering.
L What is.the frost depth in this region?
10.
The following information is missing:
Well ID number in Table 3.5, pH values in Table 3.6 spring sample ID in Table 3.16, location of background wells 557 and 559 in Figure 3.2 and other similar site maps.
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