ML20134M302

Forwards Comments on RAI Re long-term Surveillance Plan for Gunnison,Co Umtra Disposal Site

ML20134M302
Person / Time
Issue date:	11/21/1996
From:	Joseph Holonich NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Sena R ENERGY, DEPT. OF
References
REF-WM-61 NUDOCS 9611250018
Download: ML20134M302 (4)

Text

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j. C y . .  %- UNITED STATES j s* y.t NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2006tH1001 I

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%g November 21, 1996

,,,,, l Mr. Richard Sena, Acting Director Environmental Restoration Division

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Uranium Mill' Tailings Remedial Action Project t U.S. Department of Energy

} 2155 Louisiana NE, Suite 4000 i Albuquerque, NM 87110

SUBJECT:

.LONG-TERM SURVEILLANCE PLAN FOR THE GUNNISON, COLORADO, URANIUM MILL _

4 TAILINGS REMEDIAL ACTION PROJECT DISPOSAL SITE

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Dear Mr. Sena:

The U.S. Nuclear Regulatory Commission staff has reviewed the U.S. Department

! of. Energy's-(DOE) long-term surveillance plan (LTSP), dated May 1996 for the

- Gunnison, Colorado,. disposal site. The LTSP was transmitted by a letter of 1 ._ June 13, 1996. Comments are enclosed that have been developed based on the staff's review.

i i If you have-any questions regarding this subject, please contact the NRC {

Project Manager, Harold E. 'Lefevre, at (301) 415-6678.

Sincerely, i

4. k M l Joseph J. Holonich,_ Chief-i Uranium Recovery Branch

! Division of Waste Management

! Office of Nuclear Material Safety f

Enclosure:

.-As stated 4

cc: S. Arp, DOE Alb i S. Hamp, DOE Alb

'J. Virgona, DOE GJP0 l- E. Artiglia, TAC Alb

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9611250018 961121 PDR WASTE

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i REQUEST FOR INFORMATION CONCERNING THE

LONG-TERM SURVEILLANCE PLAN

FOR.THE GUNNISON, COLORADO, UMTRA DISPOSAL SITE

1. DISCUSSION: Concerns regarding the potential for the breakdown of.

erosion protection material arose as a result of the staff site' visit of July 10, 1996. The concerns centered on the potential long-term effects

of-freeze-thaw cycles on microscopic fracturing of the larger riprap.

This long-term deterioration, in the staff's opinion, could eventually

, result in the larger riprap not meeting the design specifications. The i May 1996 LTSP does.not address this potential for deterioration in 4

sufficient detail to specifically monitor this larger riprap material.

! Following a series of telephone conversations with the Department of Energy (DOE) on this matter, the DOE Site Manager provided the staff (l _ with a September 5, 1996, draft revision of the applicable portion of i the May 1996 LTSP. This draft revision, which addresses specific l monitoring of the larger erosion protection riprap and would result in i

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the creation of a new section of the LTSP entitled " Site Specific Concerns", has been reviewed by the staff and satisfactorily addresses

! the staff concerns.

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COMMENT

. Revise the May 1996 LTSP to reflect the changes indicated in i the September 5,1996, draft rewrite. In addition, ensure that the locations designated for more detailed, repetitive inspection for each i of the' three specific riprap types (B, C, and D) are shown on Plate 1

! (Baseline map) of the LTSP, as well as on the inspection drawing j' accompanying the completed annual inspection report.

2. DISCUSSION: LTSP page 2-9 (third paragraph of Section 2.4) indicates i that the 1.5-ft-thick radon barrier is designed to reduce the radon flux

! to less that 20 picocuries per square meter per second. This should be

! corrected since DOE's radon attenuation model (see NRC's Final Technical L Evaluation Report, Section 6.2.2) included the 73-inch frost barrier as well as the 1.5-ft-thick radon barrier in order to achieve the long-term radon flux standard.

COMENT: Revise the LTSP to be consistent with the staff's TER l conclusion which is based upon the design and analyses presented in the

Remedial Action' Plan (RAP) and associated documents.

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'3. . DISCUSSION: Although LTSP page 2-18 indicates that existing well GUN-p 08-0609 (which is to serve as one of the two background ground water 4

monitor wells) is plotted on the Baseline Map (Plate 1), this is not the j- case.

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CoWENT: Designate the location of well GUN-08-0609 on LTSP Plate 1.

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3 Enclosure i

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I '4. ' DISCUSSION: The proposed concentration limits for hazardous

constituents presented in Table 2.3, page 2-21, included some values that have increased substantially from those that were proposed in the i RAP and reiterated in the Staff's TER, i.e., arsenic, net gross alpha, 1 radium-226/228, antimony, tin, vanadium, and zinc.

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i COMMENT: Discuss the basis for these increased limits, including clarification of what additional background data was used to modify the 1

i values. This information does not have to be included in the LTSP. It I should be provided as additional information supporting changes from j what was presented in the RAP.

i 5. DISCUSSION: The TER in?lcated that in the LTSP, DOE should address the need for sampling any observed water along the existing gullies. The 1

LTSP did not include any discussion on this subject.

j COMMENT: The LTSP should be revised to include, either in the checklist e or in the " site-specific concerns" section, discussion on checking i adjacent gullies for seepage and sampling any seepage observed.

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6. ' DISCUSSION: The LTSP (page Al-1) acknowledges that: (1) the final

disposal site will consist of approximately 92 of the roughly 115 acres 1- transferred on June 15, 1992, to the DOE by the Secretary of the Interior by means of 43 CFR Public Land Order 6931, and (2) that the i legal description of the final disposal site will be included in the i revised LTSP subsequent to completion of the final site survey.

COMMENT

Provide the legal description of the final disposal site in

. the revised LTSP.

7. DISCUSSION: The LTSP Baseline Map (Plate 1) indicates that the map is in draft form pending completion of the final site survey.

COMMENT: Provide the final Baseline Map in the revised LTSP.

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j. 8. DISCUSSION: LTSP Section 3.6.2 (Site inspection maps) indicates that the map (Plate 1) will be annotated by the inspection team to include i traverses made during the course of the annual inspection.

COMMENT: Revise the LTSP to ensure that the locations of the traverses I' are indicated on the inspection drawing accompanying the completed i annual inspection report.

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Mr. Richard Sena, Acting Director i Environmental Restoration Division Uranium Mill Tailings Remedial Action Project U.S. Department of Energy l

4. 2155 Louisiana NE, Suite 4000 3

Albuquerque, NM 87110

SUBJECT:

LONG-TERM SURVEILLANCE PLAN FOR THE GUNNISON, COLORADO, URANIUM MILL

TAILINGS REMEDIAL ACTION PROJECT DISPOSAL SITE Dear Mr. St u -

The U.S. Nuclear Regulatory Commission staff has reviewed the U.S. Department of Energy's (DOE) long-term surveillance plan (LTSP), dated May 1996 for the Gunnison, Colorado, disposal site. The LTSP was transmitted by a letter of June 13, 1996. Comments are enclosed that have been developed based on the staff's review.

If you have any questions regarding this subject, please contact the NRC Project Manager, Harold E. Lefevre, at (301) 415-6678.

1 Sincerely, j l

Joseph J. Holonich, Chief Uranium Recovery Branch Division of Waste Management Office r,f Nuclear Material Safety and .ca feguards

Enclosure:

As stated I

cc: S. Arp, DOE Alb S. Hamp, DOE Alb J. Virgona, DOE GJP0 E. Artiglia, TAC Alb i DISTRIBUTION:

• File Centerf URB r/f NMSS r/f PUBLIC DRom CCain RIV Mlayton TLJohnson EBrummett CNWRA w/o Encl.: JSurmeier DOCUMENT NAME: S:\DWM\ URB \HEL\GUNNISON\LTSPREVU\ FINAL.N16 URBv~ CM/ 6 0FC URB f NAME HLefevreN/a* DGillen DATE II/,f/ /96 H 11pJ/96 N OFFICIAL RECORD COPY

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