ML20059D198
| ML20059D198 | |
| Person / Time | |
|---|---|
| Issue date: | 08/30/1990 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Matthews M ENERGY, DEPT. OF |
| References | |
| REF-WM-73 NUDOCS 9009060146 | |
| Download: ML20059D198 (14) | |
Text
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N $ 0 1999
. Mr. Mark Matthews Project Manager UraniumHillTai1IngsProjectOffice Albuquerque Operations Office U.S. Department of Energy P.O. Box 5400 Albuquerque, NM 87115
Dear Mr. Matthews:
The NRC staff has completed its review of the draft Surveillance and Maintenance Plan (SMP) for the Tuba city UMTRA site in Tuba City, Arizona transmitted under your cover letter dated February 7,1990. Since many details and specifics of the SMP have been deferred to the final version, our review should be considered preliminary. 1he comments resulting from the review of the draft SMP are enclosed.
I would like to emphasize a general connent (Comment No.1). The surveillance plan, in_ addition to )roviding the basis _ for issuance of a general license, will also establish t1e detailed procedures to be followed at each site to help fulfill tenns and conditions of that license. Therefore, the final SMP must address site specific conditions which must be taken into consideration in each SMP prepared following the DOE generic document, " Guidance for UMTRA Project Surveillance and Maintenance". Since much of this is lacking in this draf t we would suggest that DOE consider submitting a revised draf t SMP, which includes the required site. specific information, for NRC review. This will assure that the final SMP is acceptable and will not delay bringing the Tuba City site under the purview of the NRC general license.
If you have any questions regarding these connents, please do not hesitate to contact me or Sandra Wastler of my staff (FTS 492 0582).
Sincerely, (SIGNED) PAUL.H.LOHAUS Paul H. Lohaus, Chief.
Operations Branch Division of Low. Level Waste Management and Decommissioning, NMSS
Enclosure:
As stated cc: S. Mann, DOE /HQ M. Abrams, DOE /AL M. Begaye, NAVAJO / HOPI o
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UMTRA DOCLMENT REVIEW FORM SECTION 1 Site: TVBA CITY. Arizona Document surveillance and Maintenance Plan Commentor: Nuclear Regulatory Commission Date: August 8, 1990 Comment: _ GENERAL 1.
Once the NRC ruleecking is complete, the general license will contain a condition that requires care for the site in accordance with the provisions of the surveillance and maintenance plan (SMP). Therefore, the provisions of the
$1P will become license conditions.
Because of the eventual incorporation of the SMP provisions into the license, care should be taken to consider the site specific conditions when making wholesale reference to requirements in the DOE generic guidance document.
References should be specific, direct, and qualified if necessary. When revising the draft SMP, DOE should review all references to the generic document to insure that all referenced requirements are appropriate for and consistent with the SMP.
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 SMP should be written in terms of post-licensing conditions.
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i tMTRA DOCUMENT REVIEW FORM
\\
SECTION 1 Site: TUBA CITY, Arizona Document:
Surveillance and Maintenance Plan Commentor: Nuclear Regulatory Connission Date: August 8,1990 Comment:,Page 7, Section 2.3 f
2.
DOE states that one boundary monument and three survey monuments will define the four corners of the disposal site.
DOE's Guidance Document does state on page 11 that three survey monuments are the minimum allowed.
This minimun is not 4 default number; it requires justification.
DOE should, therefore, provide the basis for determining that the minimum number of survey monuments is sufficient to define the site boundary.
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UNTRADOCUMENT;LcQEWFORM SECTION 1 Site: TUBA CITY. Arizona Document:
Surveillance and Maintenance Plan Commentor: Nuclear Regulatory Consission Date: August 8. 1990 Comment:
Page 29. Section 4.0 3.
Section 4.0, Site Inspections and Corrective Action, indicates that the site-specific Phase I inspection plan, the site inspection check list, the procedures for Phase II inspection, and the procedures for conducting contingency inspections will be established at a later date and provided in the final SMP. This section also indicates that in lieu of a Phase I inspection, an l
interim site inspection will be conducted at Tuba City in the tall of 1990, and the first annual Phase I inspection is scheduled for spring 1991.
Based on the lack of site-specific information and the ' implication that Section 4.0 will change significantly, the NRC has only conducted a cursory review of this section.
NRC will review this section in detail in the final SMP. DOE should also provide justification for conducting an interim site inspection in lieu of a Phase I inspection, as required by DOE's Guidance document.
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j UNTRA DOCUMENT REVIEW FORM SECTION 1 Site: TUBA CITY Arizona Document:
Surveillance and Maintenance Plan Commentor: Nuclear Regulatory Cossnission Date: August 8. 1990 Comment: Page 19. Section 2.5 4.
This section indicates that aerial photographs will be taken to document the final site conditions after remedial action at the site is complete and that the need for additional aerial photographs will be determined as site conditions warrant.
The DOE Guidance Document (1988), however, requires serial photographs to be reseated at 5 year intervals from the start of surveillance.
DOE should justify tieir deviation from this requirement, SECTION 2
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UMTRA DOCUMENT REVIEW FORM SECTION I Site: TUBA CITY, Arizona Document: Surveillance and Maintenance Plan Commentor: Ruclear Regulatory commission Date: August 22. 199)
Comment: Page 25. Section 3.4 5.
DOE makes the statement that the groundwater samples analyzed for hazardous constituents indicated that no organic hazardous constituents were present that were tit result of the uranium milling process at Tuba City.
This statement indicates that organics were actually found. DOE should clarify this statement by providing a list of the organic constituent found in the groundwater sample ar.d provide a justification for determining that they are not related to uranium milling.
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LMTRA DOCUMENT REVIEW FORM i
1 5ECTION 1 Tuba City, Arizona
, Date: Au 22, 1990 Site:
Draft Tuba City Surveillance and Maintenance Plan (gust SMP)
Document:
Comnentor: U.S. Nuclear Regulatory Commission Comment: General
- 6. Requirements from 55 FR 3970 (Proposed rule for custody and long-term care of uranium mill tailiiigs sites) include:
- 1. A legal description of the disposal site to be licensed.
- 2. A detailed description of the final disposal site conditions, including ground-water conditions and activities.
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- 3. A description of the long-term surveillance program, including frequency, inspection and reporting of necessary activities.
- 4. The criteria for follow-up inspections in response to anomalous conditions.
- 5. The criteria for instituting maintenance or emergency measures.
It appears that DOE has postponed 1, 4, 5 and parts of 2 and 3.
The NRC staff will expect this information, either explicitly or in the form of references to other UMTRA documentation, in the next revision of the SMP.
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LMTRA DOCUMENT CEVIEW FORM l
SECTION 1 Tuba City, Arizona Date: Au 22, 1990 Site:
Draf t Tuba City Surveillance and Maintenance Plan (gust l
SMP)
Document:
Commentor: U.S. Nuclear Regulatory Commission Coment:
Section 1.2, page 2.
7.
Since this SMP preceded the Green River SMP (April 1990), NRC staff comunents regarding the Green River SMP should be reviewed for their applicability to the Tuba City SMP. For example, the Tuba City SMP references the 53 FR 32396 advanced notice, which was superseded by the 55 FR 3970 notice.
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UMTRA DOCUMENT REVIEW FORM i
SECTION 1 Site: Tuba City Arizona
. Date: August 22, 1990 Document: Draf t Tuba City Surveillance and Maintenance Plan (SMP)
Commentor: U.S.. Nuclear Regulatory Commission Comment: Section 2.1, page 3.
8.
In the legal description of the disposal site, the DOE must include or reference the Navajo Nation and Hopi Tribe executed waivers holding the United States harmless against any claim arising from the performance of the remedial action, as well as other withdrawal agreements. (UMTRCA Title I, Section105(a)).
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LMTRA DOCLMENT REVIEW FORM SECTION 1 Site: Tubk City, Arizona
. Date: August 22, 1990 Document:
Draft Tuba City Surveillance and Maintenance Plan (SMP)
Commentor: U.S. Nuclear Regulatory Commission Comment: Section 3.0, Ground-water Monitoring, General Comment.
9.
The text implies that there has been enough ground-water characterization at the processing / disposal site to determine aquifer quality and degree and direction of contamination.
This seer.s to be in conflict with the discussions in sections 3.3.1, 3.3.2, and 3.4, which imply that more monitoring and characterization is needed.
It is unclear why further monitoring of this same aquifer is needed before concentration limitt e.an be
- proposed, i
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UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: Tuba City, Arizona
, Date: August 22, 1990 Document:
Draf t Tuba City Surveillance anu Maintenance Plan (SMP)
Comnentor: U.S. Nuclear Regulatory Commission Connent: Sections 3.3.4, 3.4 and 3.S. page 25.
10.
The SMP does not appear to address how the performance modeling of ground water will factor the influence caused by any aquifer restoration activity.
Specifically, the aquifer restoration may alter the ground-water regime, and this needs to be addressed in the final Long-Term Surveillance Plan.
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UMTRA DOCUMENT REVIEW FORM SECTION 1 l
l Site: Tuba City, Arizona Date: August 22, 1990 Document: DraftTubaCitySurveillanceandMaintenancePlan(SMP)
Commentor:
U. S. Nuclear Regulatory Commission Comment: Section-3.6, Excursion Criteria and Corrective Action, page 28, 11.
In addition to aquifer restoration, there are requirements in 3ubpart B for ground-water monitoring to indicate performance of the stabilized pile.
Although the ground-water monitoring of the reclaimed pile should factor the impacts of the aquifer restoration program, this does not give license to ignoring the performance of the ground-water protection design until the restoration is completed. Should the design fail to minimize additional contamination, the DOE should have a procedure in place to address this eventuality. The SMP implies that DOE will monitor the ground water, but l
will not take action to prevent additional contamination until the aquifer restoration issue is resolved.
UMTRCA requires that proposed standards i
apply, if final standards are not yet in place. DOE must demonstrate compliance with the standards in 52 FR 36000 until final standards are issued.
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LMTRA DOCUMENT REYlEW FORM l
SECTIM,1 Site. Tuba City, Arizona
, Date: Au 22, 1990 Draf t Tuba City Surveillance and Maintenance Plan (gust SMP)
Docuz3t:
Commentor? U.S. Nuclear Regulatory Cosmission Comment: Sectica 3.7, Reporting, page 28
- 12. Criterion 12 of the proposed NRC Rule on Custody and Long-Term Care has been revised to require annual reporting of results of sites' inspections to the NRC within 90 days of the last site inspected in that calendar year (55 FR 3970).
However, reports are required within 60 days of any site inspection where unusual damage or disruption is discovered during an inspection. The TAD, Guidance Document and the SMPs should incorporate these reporting requirements.
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UMTRA DOCUMENT REVIEW FORM L
l SECTION 1 l
Tuba City, Arizona
, Date: Au 22, 1990 Draft Tuba City Surveillance and Maintenance Plan (gust Site:
L Document:.
SMP)
Commentor: U. S. Nuclear Regulatory Commission l
Comment: Section 5.0 Custodial Maintenance, p. 35.
- 13. The second paragraph implies possibly dispensing with annual inspections.
Criterion 12 of 10 CFR Part 40, Appendix A will require, at a minimum annual inspections. SuchadeparturefromtheannualinspectionrequIrement i
would require an exemption to the standards.
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