ML20135B014
| ML20135B014 | |
| Person / Time | |
|---|---|
| Issue date: | 08/21/1985 |
| From: | Hawkins E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Higginbotham L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-48 NUDOCS 8509100358 | |
| Download: ML20135B014 (6) | |
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pen UNITED STATES
[ NUCLEAR REGULATORY COMMISSION E
- E REGION IV e C NT RANIUM RECoV FIELD OFFICE DENVER, COLORADO 80225
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@ b 040WM175201E' cg.;3-7 MEMORANDUM FOR: Leo B. Higginbotham, Chief Low Level Waste and Uranium Recovery Branch Division of Waste Management FROM: Edward F. Hawkins, Chief Licenisng Branch 1 Uranium Recovery Field Office, Region IV
SUBJECT:
COMMENTS ON THE UMTRAP PRELIMINARY FINAL EIS AND THE DRAFT RAP, SCR AND DSCR FOR INACTIVE URANIUM MILL TAILINGS SITE AT DURANGO. COLORADO Attached are URF0's comments on the Durango draft RAP, SCR and DSCR. The coments on surface water hydrology will be provided to you separately by Ted Johnson. In addition, the URF0 staff reviewed the Durango preliminary Final EIS concertrating on assessing the adequacy of DOE's response to DWM's comments rn the Draft EIS. No comments resulted from the review of the preliminary Final EIS for Durango.
Of significant importance is our concern that the Bodo Canyon site is a very poor site. We have serious doubts that DOE will be able to submit a design that we will find to be acceptable and meets the standards. These concerns are specifically addressed by Ted Johnson and the comments prepared by Pete Garcia regarding the suitability of soils for the radon barrier. In spite of these concerns, which have been conveyed to DOE numerous times, it appears that DOE is committed to the Bodo Canyon site and feels that somehow they will overcome the problems we have noted. We do not share this optimism. We recommend that DOE be notified again that we do not believe Bodo Canyon can be found acceptable by NRC.
8509100358 850821 PDR WASTE WM-40 PDR i
AUG 211985 If you have any questions, please contact Sandra L. Wastler of my staff at FTS 776-2811.
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Edward F. Hawkins, Chief Licensing Branch 1 Uranium Recovery Field Office Region IV
Attachment:
As stated
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NRC COMMENTS - DURANG0 SITE Geology and Seismology DSCR
- 1. Page 6, Section 2.5.1; The DSCR should provide the field reconnaissance, low sun reconnaissance and trenching data to support the conclusion that the " Ridges Basin Fault" dries out south of the site.
- 2. Page 8; The DSCR states that the zone of crustal extension bounding the Colorado Plateau appears to be growing and that the marginal zone of increased seismicity associated with it is increasing as well. Is the increase in seismicity an increase in areal extent of the zone.of seismicity, an increase in the size of the earthquakes occurring in the zone, or both. How was this increase of seismicity taken in account in the determination of the MCE for the Durango site considering the 1000 year criteria. Similarly, is the maximum earthquake defined for the Dulce, New Mexico area sufficient considering the potentially increasing effect of the Rio Grande Rift into the Colorado Plateau over the next 1000 years.
Geohydrology DSCR
- 3. Page 37, Section 5.2; The second and third paragraphs of this section should be revised to be consistent with the last paragraph on page 26 of the DRAP (i.e., the DSCR should be updated to reflect the findings of the recent sampling program of the shallow Menefee and Cliff House aquifers).
- 4. Page 35, Section 5.1; The hydraulic conductivities presented here should have negative signs in the exponents. Additionally, in order to adequately evaluate the aquifer hydraulic properties derived by the TAC, a discussion should be provided detailing the types of tests performed and the aquifer analysis methods used to determine the hydraulic conductivities.
DRAP
- 5. It is evident from Sections 4.4 (page 30) and 4.5.2 (page 32) that the proposed remedial action for contaminated ground water underlying the processing site is natural flushing to the Animas River. Please provide a discussion of the time that will be required for contaminants to be flushed from the system.
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! Additionally, provide a discussion detailing what protective I measures will be utilized during this period of time to prevent -
usage of the water.
- 6. Section 4.5.2 (page 32) indicates that the potential need for deep i aquifer restoration beneath the raffinate ponds cannot be determined i'
until additional water quality data become.available. It is recommended that the final RAP contain a characterization of the ground-water contamination within the _ Menefee and Point Lookout formations _together with a proposed remedial action plan. Proposed remedial action should take into consideration present and future use of the ground water, availability and characteristics of alternative water supplies, institutional controls on use, and the ,
value of the resource evaluated against the cost of proposed remedial actions.
- 7. -Page 53 of the DRAP indicates that the ground water systems underlying the Bodo Canyon alternative site are presently being i
utilized upgradient. It must therefore be assumed that at some time
'in the future, these systems could also be utilized at some point j downgradient from the proposed disposal site. The goal of the DOE i
should be zero degradation of the Bodo Canyon ground-water regime.
- The worst case estimate for- ground-water contamination at Bodo Canyon (pp. B B-89) is too conservative. Even. concentrations that are 200% less- than indicated in Column 3 of Table B-3-5 (p. B-88) would result-in unacceptable concentrations of some
, hazardous constitutents. The estimate:should be revised-taking into account the permeabilities and attenuative capacities of the clay liner and cover and the unsaturated subsurface materials.
Radon Barrier and Radiological Safety DRAP
, 8. Page 51, Section 5.5.4, first paragraph, second to last sentence; The actual value for the radon barrier cover thickness must be ~
supplied ~to'the NRC for. concurrence prior to cover' construction (see related comment No. 2). In any event, the' adverse effects of frost 4 on the integrity of the clay cover should be addressed,
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-9. Page B-33, Section B.1.3.1, first paragraph; Quantification of the i actual site parameters needed to accurately estimate the required radon barrier cover. thickness must be supplied to the NRC and
- concurrence received prior to cover construction.
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- 10. Page B-38 and Table B.1.6; The emanating _ fraction, as estimated for the contaminated material, appears to be low. For estimating purposes, a default value of 0.35 should be used.
- 11. Page B-44, Section(s) B.1.3.3. and B.1.3.5; Is the long term
' moisture content of the material obtained from Bodo Canyon the same i for both materials (see related conment No.1 on Bodo Canyon DSCR)?
l Please compare the long term moisture content to the equivalent bar i water retention value.
- 12. Last paragraph of Section (b); Please clarify which radionuclide(s) l would be analyzed for during a whole body count. Also, is it not necessary to conduct the baseline whole body counting of all employees prior to working in a controlled area. Those employees
- that exhibit high urinalysis values during remedial action could '
then be whole body counted upon employment termination and the results compared- to the baseline previously determined. It would probably be most meaningful to whole body count for radium-226.
DSCR
- 13. . Page 83, first full paragraph; Please provide the actual calculations performed to obtain the long term moisture _ contents as
, estimated via the conceptual procedures outlined in this paragraph.
l Please compare this estimate to the 15 bar water retention value.
Geotechnical DRAP-l
- 14. Page.50; Table 6.5 of NUREG/CR-2642 indicates that a petrographic examination provides the better overall assessment of rock quality than standard rock durability tests such as the freeze-thaw test.
- The information provided by the petrographic examination, such as I
chemical composition and fracture density, is especially important when the long-term durability of the rock is being evaluated. The
, rock durability testing should therefore' include a petrographic examination.
- 15. Page 63; The radiological survey plan indicates that excavation of
~ contaminated soil underlying the existing site would continue until the EPA radium. standard was_ met. While this'is necessary, it should be noted that excavation depths may need to be determined based on chemical contamination (i.e., arsenic, etc.). The survey plan r should be revised to state that an evaluation of the extent of
- chemical contamination will also be performed.
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- 16. Page B-40; It is proposed to add lime to the onsite soils to be used for the radon barrier to attampt to compensate for serious deficiencies of the soil with regard to dispersivity and swell potential. The proposed approach raises several critical concerns which must be addressed. First, the longevity of the soil-lime matrix can remain effective for at least 200 years. It is hard to imagine the lime remaining effective for such a long time period due to dissolution. Infiltration of rainfall will occur and will in fact be increased due to the presence of the rock layer. Further, the onsite soils are expected to have a rather high residual moisture content which may affect the lime. Second, it is difficult to envision a mixing and quality assurance program which will assure that the required pertentage of lime is consistently attained for all radon barrier material. This is extremely important as even small areas not meeting specifications could seriously impact the stability of the cover. These critical issues could result in a need to identify an alternative borrow source. This comment also appears to the DSCR, pages 80-82.
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