ML20127N192
| ML20127N192 | |
| Person / Time | |
|---|---|
| Issue date: | 11/25/1992 |
| From: | Surmeier J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Chernoff A ENERGY, DEPT. OF |
| References | |
| REF-WM-72 NUDOCS 9212010059 | |
| Download: ML20127N192 (3) | |
Text
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'Mr. Albert R. Chernoff, Project Manager
. ' Urarflum Hill Tailings Remedial Action Project Office li0V 1' 5 1932 U.S. Department of f.nergy Albuquerquo Operations Office P.O. Box 5400 t ouquerque, New Mexico 87115
Dear Mr. Chernoff:
Your letter to me of October 22, 1992, transmitted, for Nuclear Regulatory Commission review, the Long Term Serveillance Plan (LTSP) for the Spook, Wyoming, Uranium Mill Tailings Remedial Action Project site. Our comments are detailed in the enclosure. Since the NRC staff has concurred in completion of the Spook remedial action, licensing will occur once the comments are resolved and the staff provides written acceptance of the LTSP.
If you have any questions regarding these comments, please feel free to contact rne at FTS 8-301-304-3439 or Allan Mullins of my e.taff at f15 8-301-504-2578.
Sincerely, Of0f!NAf etf9n't)OV John J. Surmeier, Chief Uranium Recovery Branch Division of low-Level Waste Management and Dnommissioning Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated cc: P. Mann, DOE Alb R. Edge, DOE Alb Distribution: Central File # NMSS r/f AMullins R8angart WBrach JAustin JSurmeier MFliegel DGillen DRom MLayton LtVR r/f RHall,URF0 LJCallan, RIV PDR YES )( NO Categery: Proprietary ~~~ or CF Only ACNW YES X NO Z SUBJECT ABSTRACT: NRC REVIEW 0F LTSP FOR SP0OK, WYOMING !
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COMMEllTS ON LONG-TERM SilRVEILLAflCE PLAN j SPOOK, WYOMING SITE i
f 1 Pg. 1. Section 1.0. In the 7th line of this section, the words "on i j Hovember 30, 1990' should be deleted and replaced with "and became !
j effective on November 29, 1990."
l The 7th and 8th lines of this tection incorrectly indicate that i Attachment 1 is 55 fB 45591. Attachment 1 is an NRC letter of
) concurrence on the Remediai Action Plan (RAP), which is incorrectly i referenced (on page 23 of the I. TSP) as Attachment L 1hese errors should j 00 corrected, in addition, it would be more appropriate if the letter of_
j concurrence that prese tly is included as Attachment 1 (sco comment 6) is l l replaced by the flRC staff's March 4, 1992, letter of concurrence in.the
! completion of remedial action, if changes are made to the attachments,
- 00E should ensure that the attachments reflect the order presented in the j text.
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- 2. Pg. 1. Section 1.2. In the 1st line of the 2nd paragraph, "40" should be changed to "40 H" to more accurately identify the sppropriate rulemaking.
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l 3. Pg. 3, Section 1.2. The last sentence in the 2nd paragraph states that i the general license for the Spook site will not become effective until
- the approval to exempt the Spook site from groundwater restoration has i become final. The NRC staff has not been requested to concur in such an exemption. The NRC's letter of March 4,1992, approved the remedial actions r.t the Spook site with the exception,0f " selection and performance of a groundwater cleanup program." Groundwater cleanup j remains an open issue, i
l However, the general licensing action will.not be delayed because of i
- groundwater restoration decisions and activities. The fact that NRC i
licensing under 10 CFR 40.27 will be a two-step process needs to be t considered.- ibis twstep process was established for sites where the i tailings are being 9tabilized in-place and groundwater remediation has l_ not been addressed. Groundwater restoration at the Spook. site has been i deferred to a later project phase and will be evaluated during the l Programm tic Environmental Impact Statement (PEIS) required under NEPA.
1 Since the Niu, staff has concurred in completion of the Spook remedial action,. licensing will occur once the staff accepts the LTSP. The LTSP i
may be modified at a later time if groundwater restoration is required, as a result of the PEl$ process. DOE should remcve the reference to the
- i. general license not becoming effective until an exemption from groundwater restoration is approved.
l 4. Pg. 3, Section 1.3. In the 1st line, 2nd paragraph, "40" should_be -
- changed to "40.27(b)",
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! 5. Pg. 3 Section 1.3. The 3rd bullet on the lef t should be changed from j " Site inspections" to " Site. inspection procedures and personnel."
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l l Enclosure--
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1 6. pg . 5, Section 2.1. The 4th line from the bottom incorrectly gives a
} date of February 19, 19?0, for NRC concurrence on the_ RAP. An NRC j concurrence letter was dated December 4, 1989, and was followed by a 1 tiarch 15, 1990, letter transmitting formal concurrence with completed
! signature pages. . The letter presently included as Attachment 1 is a i compilation of the two. This section should be revised to reflect the i correct concurrence date, and should also include a reference to the NRC
} staff's com urrence in completion.
- 7. Pg. 7, Section 2.2.1. The discussion of site conditions incorrectly l
indicates that the minitoum Winter temperatures are 7 to 11 degrees f for I i the Spook site area. These numbers come from DOE's Spook Environmental !
! Assessment (EA) of 1989, and are the ponthly averug minimum ,
! temperatures. The minimum monthly temperature shown in the FA is -30 '
degrees F.
l 8. Pg. 23 Section $.0, 10 CfR 940.27(b)(2) requires a detailed description
! of the final site conditions, including existing groundwater 1
characterization, which can be in the form of a reference (specific
! citations) to documents previously submitted to the NRC. DOE should l
provide an adequate general description of the existing groundwater j characterization (water quality and flow conditions) and an appropriate l reference to detailed information provided in the RAP.
The NRC staff concurred in the use of supplemental standards at the Spook disposal site and the exemption of compliance monitoring requirements, i
The staf f also concurred in the exemption of groundwater monitoring for
! the purpose of demonstrating cell performance because of the unique circumstances of disposal at the Spook site. The LTSP shodid be revised to reflect both the compliance and pr formance elements of groundwater
! monitoring when discussing the exemption.
J l 9. Pg. 30, Section 7.2.1. This section indicates that "a report of intrusion by humans or livestock" might be a trigger event for a l contingency inspection. The site is not fenced and such intrusion couN
, be common. Given the deep burial condition at this site, livestock L
i-intrusions _would not likely be of concern. The section should be reviv !
to consider the site-specific conditions in presenting the trigger e'.wt l
for contingency inspections.
j 10. Pg. 49, Section 14.0. In the 2nd reference, change " Revision A, Draft.
to " Revision 1, final."
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! 11. Attachment 2. The mining claim description and recording information needs to be provided.
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