ML20138H234
| ML20138H234 | |
| Person / Time | |
|---|---|
| Issue date: | 08/29/1985 |
| From: | Dam W, Weber M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Knapp M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-39 NUDOCS 8510280506 | |
| Download: ML20138H234 (8) | |
Text
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Division of Waste Management IUackson MWeber & r/f FROM: Michael F. Weber, WMGT WDam & r/f Division of Waste Management LHigginbotham DMartin William L. Dam, WMGT Dcillen Division of Waste Management Hildenbrand, URF0 R
SUBJECT:
TRIP REPORT ON SECOND MEETING 0F UMTRA WATER RESOURCES WORKING GROUP IN ALBUQUERQUE, NEW MEXICO During the week of August 5, 1985, we attended two technical meetings with DOE's Technical Assistance Contractor (TAC) in Albuquerque, New Mexico. The primary purpose of the UMTRA Water Resources Working Group meeting was to discuss the TAC's technical approach for selecting protective actions for water resources at UMTRAP sites. Summarizing the results of the first meeting, the participants concluded that the meeting resolved significant hydrogeologic issues that had hampered progress of the UMTRA Project. On August 7, we met with the TAC site hydrologists to review the status of hydrogeologic investigations at the Monument Valley, Mexican Hat, Tuba City, and Ambrosia Lake UMTRAP sites. Based on this second meeting, we recommend that DOE delay preparation of water resources portions of draft Environmental Assessments and Remedial Action Plans (scheduled for NRC review in November and December) for these sites until after the TAC has adequately assessed information that is currently being collected. This trip report summarizes both meetings and justifies our recommendation.
Water Resources Working Group Meeting On August 6, 1985, we attended the second meeting of the UMTRA Water Resources <
Working Group with DOE's Technical Assistance Contractor (TAC) in Albuquerque, New Mexico. Paul Hildenbrand represented NRC's Uranium Recovery Field Office at the meeting. Enclosures I and II provide the agenda for the meeting and list of meeting participants, respectively. The purpose of the meeting was to discuss the TAC's draft Technical Approach Document (TAD) for Water Resources and NRC's draft Standard Review Plan (SRP) for Water Resources Protection. In addition, the participants attempted to identify technical issues that could not reasonably be resolved before the mid-September deadline for completion of both documents.
When we introduced our comments on the TAD, we noted that they were preliminary because we had not had sufficient time to review the document in detail. Our maior comment focused on the lack of a systematic approach f: selection of 8510280506 e50829 PDR WASTE PDR WM-39
r WM-39/MFW/85/08/15 protective actions in the TAD. The document described the TAC's approach for site. characterization in detail, but omitted discussion of how site characterization infonnation would be considered in selecting remedial actions for water resources. Following the discussion of our major comments, we discussed the issues identified at the first working group meeting held in July.
As displayed in the list of consensus items provided as Enclosure III, most of these issues were resolved by the work group participants. The group was unable, however, to resolve two issues: (1) evaluating health and environmental impacts, and (2) forecasting long-term water uses. Recognizing that the Hydrologic Services Group of the TAC did not have the expertise to conduct evaluations of health and environmental impacts, the TAC proposed to evaluate the first issue with health physicists and environmental scientists in other ,
sections of the TAC. The group's inability to resolve the second issue reflects the complexity and controversy associated with accurate prediction of long-term water uses. The work group agreed that water use is a primary consideration in selecting protective actions, but disagreed on appropriate ~
techniques for projecting future uses. We agreed with the TAC to evaluate vtable techniques for water use forecasting.
These same issues were manifested in the TAC's coments on our draft Standard Review Plan (SRP) for Water Resources Protection. Although there was some confusion about the purpose of NRC's Standard Review Plans, the TAC generally agreed with the content of the SRP with the exception of the two issues discussed above. Among their positive comments about the SRP, the TAC was encouraged to see consideration of institutional controls for restriction of water use and revision of the definition of background ' water quality. The TAC requested that we abbreviate the SRP and clarify terms such as " adequate",
" reasonable", and " sufficient." We agreed to attempt to provide examples of approaches that would not be- adequate, reasonable, or sufficient. We cautioned, however, that such examples may not be appropriate based the site-specific nature of remedial action decisions and characterization programs. 1 The TAC also requested that we include two appendices with the SRP: (1) a I glossary for terms such as " background water quality", " verification", and l
" aquifer;" and -(2) a completeness check-list for NRC's review of RAP's.
Participants in the second meeting of the Working Group on Water Resources <
concluded. that the UMTRA Project progressed significantly by resolving water l resources issues as a result of the working group interaction. Due to the limited number of unresolved issues, the group decided not to convene in late August as . originally planned. - The TAC will forward to NRC comments on the SRP and their draft Technical Approach Document in late August or early September. l Unless mew issues develop, the group proposed to continue infor'nal technical ,
discussions between the TAC and NRC in lieu of'the working group forum. !
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DFC :WMGT :WMGT. : : : : :
JAME:MWeber:mw :WDam : : : : :
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DATE :85/08/ :85/08/ : : : : :
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WM-39/MFW/85/08/15 Status of Hydrogeologic Investigations On August 7, we reviewed the status of hydrogeologic investigations at the Monument Valley, Mexican Hat, Tuba City, and Ambrosia Lake UMTRAP sites with TAC hydrologists. The purpose of the review was to provide NRC with early cognizance of site characterization results and to identify issues for consideration in finalizing NRC's SRP and the TAC's TAD. Groundwater contamination has been identifbd at each of these sites and has prompted DOE to initiate a second phase of drilling and monitoring well installation at three of the sites (Tuba City, Monument Valley, and Mexican Hat). Plans for the second-phase drilling programs were discussed with NRC staff prior to their execution in May and June of 1985, as was the first phase of drilling at Ambrosia Lake.
These characterization prograras, however, have been considerably delayed by contractual complications, which have stalled first_ phase drilling at Ambrosia Lake and second. phase drilling at Mexican Hat and Monument Valley. Second-phase drilling at Tuba City was partially complete when we discussed the status of the site assessments. Collection of site-specific geochemical information (e.g., Cation Exchange Capacities, ferric oxyhydroxide contents, clay mineralogy) has been delayed until after the beginning of the 1986 Fiscal Year because of budget constraints. It appears that these delays may hamper DOE's ability to produce high quality hydrogeologic assessments with the accelerated assessment schedule for these sites. The TAC's preparation of draft hydrogeologic assessments based on insufficient information may waste DOE's resources, which could be more appropriately applied to develop conceptual and analytical models of UMTRAP sites.
Based on our reviews of the status of the site assessments with the TAC, we recommend that DOE delay preparation of water resources portions of Environmental Assessments and Remedial Action Plans for these sites until after the TAC has adequately assessed the information that is currently being collected. These documents are scheduled for NRC review in November and December of 1985; according to the TAC site hydrologists, however, new water quality and geochemical information will probably not be assessed prior to their deadlines for document completion in October. Delaying the preparation of water resources assessments should improve their quality by allowing time for TAC hydrologists to assess new information. Although such action will delay completion of draft assessments, these delays should promote expeditious NRC review of draft and final site assessments.
We suggest that ycu forward our recommendation to WMLU for a decision on scheduling NRC review of these documents and subsequent interaction with DOE, 1
DFC :WMGT :WMGT : :
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WM-39/MFW/85/08/15 if appropriate. Please contact Mike Weber if you would like to discuss the merits of our recommendation or if you have any questions about our recent meetings with DOE's Technical Assistance Contractor.
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'S Michael F. Weber, WMGT Division of Waste Management Original Signed By William L. Dam, WMGT Division of Waste Management
Enclosures:
As Stated DFC :WMGT :
_ _ _'.'!MG_T_ _jh h _ _ _ _ :______:_______ : : : :
NAME :MW;ber:mw :WDam W : : : : .
DATE :85/08/y) :85/08/ M : : : : :
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- SECOND MEETING OF THE UMTRA WATER RESOURCES WORKING GROUP August 6, 1985 8:00 - 9:00 NRC Comments on 1st Draft TAC Approach 4
1 9:00 - 10:00 TAC Comments on SRP 10:00 - 11:00 NRC Comments on 2nd Draft TAC Approach 11:00 - 12:00 Health Impacts & Water Resource Economics LUNCH 1:00 - 2:30 Points of Agreement l
2:30 - 4:30 Points of Disagreement 4:30 - 5:00 Closing Remarks & Plans for Follow-up i
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WM-39/MFW/85/08/15/ATT SECOND MEETING OF THE UMTRA WATER RESOURCES WORKING GROUP August 6, 1985, Albuquerque, New Mexico Working Group Participants Name Organization Telephone Number Michael Weber NRC/WMGT FTS 427-4746 Bill Dam NRC/WMGT FTS 427-4543 Paul Hildenbrand NRC/URF0 FTS 236-2812 John Thackston TAC /Jacobs FTS 846-1250 Jim Kam RAC/MKE (415) 442-7604 Other Participants Name Organization Telephone Number George Rice TAC /SHB FTS 846-1250 John Price TAC /SHB FTS 846-1250 Jim Brinkman TAC /SHB FTS 846-1250 Bill Deutsch TAC /Jacobs FTS 846-1250 Bob Moran Corsultant to Jacobs (303) 526-1405 Jim Keithley PAC /MKE (415) 442-7502 Don Phoenix TAC FTS 846-4030 John D' Antonio DOE /ABQ FTS 844-3941
. WM-39/MFW/85/08/15/ATT CONSENSUS ITEMS SECOND NEETING 0F THE UMTRA WATER RESOURCES WORKING GROUP .
August 6, 1985 TAC Agreements
- 1. DOE or the TAC should develop a document that describes DOE's systematic approach for selecting protective actions for water resources. Discussion 3 of this approach in the TAC's Technical Approach Document (TAD) is not appropriate because the TAC does not select protective actions for water d
resources and such selection considers factors outside of the TAC's expertise.
- 2. Where practical, pre-remedial action monitoring wclls will be preserved for groundwater monitoring during and after remedial actions.
- 3. Geochemical models using such codes as PHREEQE and WATEQF will not be routinely developed for UMTRA site assessments, but may be developed to address specific issues.
- 4. When developed to address site-specific issues, geochemical and solute transport models will be calibrated using historical data and validated to the extent practical.
- 5. The most reasonable approach for characterizing the quality of pore fluids discharging from unstabilized and stabilized tailings is to measure the quality of tailings pore fluids and shallow groundwater immediately downgradient from the tailings.
- 6. Groundwater samples will be screened for priority pollutants at a limited number of monitoring locations; if priority pollutants are present at significant concentrations, monitoring programs will be expanded to sample for these constituents at more locations.
- 7. Institutional controls for restricting water use at UMTRA sites deserve consideration as alternative protective actions for water resources.
i Revisions to the TAD
- 8. The TAD will be revised to remove textbook-type information about alternative protective actions and to identify factors for consideration in selecting protective actions.
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WM-39/MFW/85/08/15/ATT i-l 9. The TAD will be revised to identify quarterly groundwater monitoring for at least one year as a goal of site characterization, recognizing that site-specific considerations may justify reducing the scope of the monitoring program.
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- 10. The TAD will be revised to identify and justify preferred approaches in addition to listing alternative approaches for site characterization and for selecting protective actions, a 11. Section 3.3.1.3 of the TAD will be revised to discuss only characterization of existing conditions, rather than predicting performance of stabilized tailings embankments after remedial actions.
- 12. The TAD will be revised to clarify that values of effective porosities and dispersion coefficients will be selected to develop conservative estimates of contaminant transport on a site-specific basis.
4 l 13. The TAD will acknowledge the potential significance of contaminant i desorption in assessing groundwater contamination and will discuss the >
4 TAC's preferred methodology for considering desorption when such a methodology is selected.
NRC Agreements
- 14. NRC will revise the SRP for Water Resources Protection to clarify the meaning of such terms as " acceptable" and " adequate"; NRC will also
- consider including a glossary and completeness checklist for NRC's review
] of RAP's as appendices to the SRP.
- 15. NRC will provide information, as available, to the TAC about economic considerations of aquifer restoration; this information is tentatively scheduled for development by PNL under NRC contract DE-AC06-76RL01830.
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