ML20138D218
| ML20138D218 | |
| Person / Time | |
|---|---|
| Issue date: | 01/29/1993 |
| From: | Surmeier J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Chernoff A ENERGY, DEPT. OF |
| References | |
| REF-WM-54 NUDOCS 9302160147 | |
| Download: ML20138D218 (4) | |
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UNIY2D S1 ATES 1
NUCLEAR kEGULATORY COMMISSION WASHINGTON, D.C. 20565
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yN Mr. Alber' R. Chernoff, Project Manager Uranium Mill Tailings Remedial Action
.'roject 0ffice U.S. Department of Energy g
Albuquerque Operations Office P.O. 90x 5400 Albuquer'ue, New Mexico 87115 h
Dear Mr. Chernoff:
We have recently reviewed and concurred in Project Interface Document-.(PID)
- l 05-S-47, REV 2, which satisfactorily addressed surface-water open issues pertaining to remedial action at the Grand Junction Urantur Mill Tailings Remedial Action Project site.
The Nuclear Regulatory Commission staff review of the Department of Energy's< response to Remedial Action Plan (RAP)'open issur2 had been on hold pending this PID review.
This review has now been completed and issues st:" remain open.
Open issues in the discip ines of water resources protection and radon 7
attenuation / site <.aanup remain to be resolved. The enclosure to this letter provides ths details of these issues. One of the areas still needing resolution i the radon barrier design. -A proposed revised ' sign has been submitted (Plc SS S-4f.), and has been commented on-by the.RC staff.
Because the RAP and PID reviu, are oath.ctill in progress, they should be finalized and concurred in together to avoio problems with confi cting designs. The RAP should reference finalization of the design through the PID process. Timely resolution of this issue is necessary, given plans for starting the radon barrier placement this construction season.
On satisfactory resolution of the enclosed issues, we will be in a position to complete the final Technical Evaluation Report.
If yea have any questions l
I 110035 p
p; 9302160147 930129 PDR WASTE lc WM-54
-PDR
/
e Albert R. Chernoff 2
regarding the information in the enclosure, please contact me at FTS 8-301-504-3439 or the NRC Project Manager, Daniel Rom at FTS 8-301-504-2573.
Sincerely,
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WCND).T d l. c 4
John J. Surmeier, Chief Uranium Recovery Branch
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+s Division of Low-level Waste Management-4 and Decommissioning Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated cc:
J. Stelmach, DOE /AL S. Hamp, DOE /AL O. Leske, DOE DISTRIBUTION:
Central-File #'
NMSS r/f RBangart WBrach JAustin MFliegel ~
LLWM r/f RHall,URF0 LCallan,RIV SWastler TLJohnson EBrummett LHamdan SUBJECT ABSTRACT:
REQUEST FOR ADDITIONAL INFORMATION, GRJ RAP
- Mark Small: BoxeLinTC'oncurrence1 Block::to1 Define:DistributionTCopy;Preferenss in small Box on "0FC:" line place a: C = Cover E = Cover & Enclosure.
N = No Copy
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DATE:
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S:\\LLWMTYPE\\EDIE\\GRJSUP.DSR OFFICIAL RECORD COPY In sma77 Box on "DATE:" line place a: M = E-Mail Distribution Copy H = Hard Copy PDR :
YES X
NO Category:
Proprietary or CF Only ACNW:
YES X
NO Delete file after cistribution Yes No IG:
YES NO _L
- -- 4 WATER RESOURCES PROTECTION 1.
TER hsue 12:
In our February 18, 1992, letter, Issue 12 addressed four information needs related to the DOE demonstration that postponemen of groundwater cleanup will not adversely affect pub'ic health and safety.
The following aspects of this issue remain to be resolved:
12.a.
Verification that the Colorado River water sampling was conducted during a low-flow period was provided. However, the sampling.
results indicate that gross alpha exists in concentrations that exceed the EPA's MCLs. The presence of these concentrations of gross alpha may represent a health risk to the water users in the vicinity of the processing site and should be addressed in the RAP.
12.c.
DOE has provided infwmation on their well inventory; however, the NRC staff concludes that the information provided to date is insufficient to assess the potential impacts on existing water users. To evaluate the potential impacts of contamination on the existing wells and current and prospective water users in the vicinity of the processing site, the well inventory needs to be expanded to include e)isting nearby wells located downstream from the processing site. At 12 Jt one well on the south side of the Coloradn River shou'.d be included.
The inventory may initially include downstream wells that are closest to the processing site, but may progressively expand to include other wells further downstream, unless the collected data indicata conclusively that the existing and potential water users further downstream will not be adversely impacted by contamination from the processing site.
The NRC staff considers the protection of the existing and potential water users in the processing site area as an open issue to be resolved before the RAP can be approved.
2.
TER issue 17:
Issue 17 identified the staff's request that the RAP include some form of cell performance monitoring to ensure there is no movement of contaminants to the neaby paleochannels. The DOE response did not provide this information, nor were the arguments presented adequate to resolve this issue.
For the reasons previously discussed in the February 18, 1992 letter, tht: staff concludes that a commitment to monitor the cell performance is necessary. Details of the plan can be provided in the Long-Term Surveillance Plan.
Enclosure 1l l
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RADON ATTENUA7 ION AND SITE CLEANUP 3.
TER lssue 20:
The RAP sSould be revised to indicate that a PID will be submitted which includes a detailed site-specific procedure for the cobbly soil analysis (bulk radionuclide determination in cobbly soil). The revised Remedial Action Selection Report (RAS), Section 6.5.3 (page 58),
oerely states that the Ra-226 concentration would be corrected using a site-specific application of the approved procedures.
The DOE response to NRC comments that was dated August 18, 1992, stated that the site-specific procedure will be issued as a Class 11 PID.
NRC staff has not received such a P!D, even though most of the excavation at the processing site is complete. The possibility exists that a Class 1 PID, requiring NRC concurrence, may be justified.
The PID should be submitted now, and should contain detailed information on the site-specific procedure including:
- 1) any proposed modifications to the generic procedure; and
- 2) discussion of the options chosen.
Examples of options that should oe discussed include whether tests pits or running average will be used for the statistical mass partition function, and whether grid-specific or statistical methods will be used for site verification.
4.
IER Issue 21:
The RAP needs to indicate the frequency of thorium analysis required during verification.
The RAS revised Section 6.5.3 (page 60) indicates that four percent of all verification samples will be sent to an independent laboratory for verification of the Th-230 concentration.
Based on ongoing Th-230 issues at other sites, NRC staff considers 4 percent tn be inappropriate for the necessary level of confidence for sites which are known to have elevated Th-230 concentrations deeper than th3 rad a contamination.
NRC staff is aware that DOE is preparing a generic policy paper on thorium. Th-230 cleanup policy and procedures will be established for this and other sites through NRC's review /
concurrence of that document.
5.
By letter dated July 21, 1992, DOE submitted PID 05-S-46 providing a revised radon barrier design.
NRC staff comments on this PID were issued by letter dated August 21, 1992, and as yet remain unresolved.
Because of the uncertainty of the radon barrier design, and the fact that it is already being reviewed by PID process, the RAP should be revised to indicate that a final radon cover design will be submitted as a Class I PID for NRC review and concurrence when the final material parameters and configuration are known.
The submittal should be made prior to any placement of cover material.
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