ML20056G065
| ML20056G065 | |
| Person / Time | |
|---|---|
| Issue date: | 07/15/1993 |
| From: | Fliegel M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Chernoff A ENERGY, DEPT. OF |
| References | |
| REF-WM-39 NUDOCS 9309010245 | |
| Download: ML20056G065 (3) | |
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UNITED STATES
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WASHINGTON. D C 20555 0001 J
J'A 15 B33 Mr. Albert R. Chernoff, Project Manager Uranium Mill Tailings Remedial Action Projett Office U.S. De;artment of Energy l
Albuqilerque Operations Office i
P.O. Bok 5400 l
Albuquerque, New Mexico 87115 j
Dear Mr. Chernoff:
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We have reviewed the following Project Interface Documents (PID's) which were sent under cover letter dated June 10, 1993:
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1.
05-S-46 (Rev. 2), dated March 11, 1993 - 00E Class I 2.
05-S-48, dated August E. 1992 - DOE Class II 3.
05-5-54, dated December 12, 1992 - DOE Class II l
4.
05-5-55, dated April 22, 1993 - DOE Class I 5.
05-S-56, dated April 2,1993 - DOE Class I l
PID 56, which concerned a reconfiguration of the tailings embankment top slope l
and addition of a transition layer, was previously submitted by the Department
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of Energy (DOE) and concurred in by letter from our office dated May 27, 1993.
PID 54, which revises the processing site final grading plan, is appropriately i
identified as Class II and, therefore, requires no concurrence.
PID 55 proposes revised procedures for the burial of asbestos-contaminated material (ACM) and ACM stored in metal drums. We concur with PID 55, as submitted.
PID 48 proposes methods for the disposal of highly-contaminated oversize l
demolition material. We are prepared to concur with PID 48 if it-is reissued l
as Class I, and if the resubmittal includes guidelines for minimum lateral I
separation of crushed tanks. The minimum separation limits are desirable to assure that concentrations of non-soil buried matter can be bridged properly, thereby preventing excessive settlement and cover cracking above.
PID 46 (Revision 2) proposes elimination of requirements preventing material with a diameter greater than 6 inches within 100 feet of the embankment side slopes. Attachment A to this PID explains that the previously proposed radon barrier change in Revision 1, based on altered contaminated material sequencing, is no longer needed.
This reestablishes the original 2-foot radon barrier. We concur with the PID as proposed. However, our review noted Ij certain items in Attachment A that require clarification when the final RAECOM analysis is presented in the Completion Report. These concerns are discussed j
in the enclosure.
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9309010245 930715 7
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i Albert R. Chernoff -
If you have any questions regarding the above, please contact me at i
(301) 504-2155 or the Nuclear Regulatory Commission Project Manager, Mr. Daniel Rom at (301) 504-2573.
Sincerely, 1
OhlG!NAL S;GNED W Myron H. Fliegel, Acting Chief Uranium Recovery Branch Division of Low-level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated cc:
S. Hamp, DOE /AL C. Cormier, DOE DJSTRIFUTION: Central File #
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NO Category:
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NO Delete file after distribution Yes No i
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l NUCLEAR REGULATORY COMMISSION STAFF COMMENTS ON PID 46 REVISION 2
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Attachment A to Project Interface Doucment (PID) 46, Revision 2, explains that the previously proposed change in Revision 1, based on altered contaminated L
material sequencing, is no longer needed. This is because the uppermost 10 feet of contaminated material will be icw-level vicinity property i
material, as ut iginally phnneri in the Remedial Action Plan (RAP). Therefore, the original design with a 2-foot-thick radon barrier layer is still adequate.
Attachment A, in part, provided information pertinent to the Nuclear Regulatory Commission staff's comments on the radon barrier design presented 1
- n Revision 1.
Revision 2 no longer includes a revised radon barrier; therefore, this information does not require NRC review. However, it did i
include a RAECOM analysis with some revised input values. The following e
comments are provided for Department of Energy's (DOE's) consideration when l
preparing the final RAECOM analysis for the Completion Report:
1.
Apparently DOE has reversed the thickness values of the two contaminated material layers presented in the RAECOM analysis. Table 2 of Attachment A indicates that the remaining million cubic yards of contaminated material is low-level material (weighted average 32 pCi/g Ra-226).
The RAECOM analysis in Table 3 indicates that this material is the top layer and is 1220 cm (40 ft.) thick.
However, the in-place contaminated material (about 3-million cubic yards) is shown only as 305 cm (10 ft.) thick. This, of course, would result in a lower flux rate than if the low-level material was 10-feet thick.
I 2.
The deeper contaminated material layer has a moisture input value of i
1.7 percent.
In the RAP calculation, the deeper layer had a moisture content of 18 percent.
Even if this material was pure sand, had little moisture added, and had little cover, one could still expect at least 5 t
percent moisture content. Adequate justification for long-term moisture values will need to be provided in the Completion Report's analysis.
i The staff ran the RADON code, correcting these probable errors and using 2
calculated diffusion coefficients. The resulting radon flux was 6.6 pCi/m /s.
5 Using the avep/s.
age parameter values and their SEM, the flux was calculated to be 11.8 pCi/m The radon flux, based on the model in Table 3 of i
Attachment A, apparently will meet the Environmental Protection Agency standard; however, the Completion Report needs to provide sufficient data to i
substantiate the final RAECOM analysis and the radon barrier "as-built" design.
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Enclosure
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