ML20150C384
| ML20150C384 | |
| Person / Time | |
|---|---|
| Issue date: | 03/02/1988 |
| From: | Hawkins E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Arthur W ENERGY, DEPT. OF |
| References | |
| REF-WM-63 NUDOCS 8803180217 | |
| Download: ML20150C384 (4) | |
Text
_ _ _ - _ _ _ _ _ _ - - _ _ _ _ _
DISTRIBUTION Docket File WM-63 l
>PDR/DCSs !
DBangart, RIV WM-63/SRG/88/02/29/0 SGrace DJacoby MBrown, RCPD, NM LLO Branch, LLWM b%R 21988 URF0 r/f URFO:SRG Oocket No. WM-67 040WM63700E W. John Arthur, III, Project Manager Uranium Mill Tailings Prolect Office U.S. Department of Energy Albuquerque Operations Office P.O. Box 5400 t Albuquerque, New Mexico 87115
Dear Mr. Arthur:
1 We have completed an acceptance review of the Mexican llat prelimir.ary final Remedial Action Pian (pfRAP), submitt.!d January 29, 1988. Our acceptance review consisted of a cursory review of the LfRAP and the final Desi nC for Review documents transmitted by you on August 18, 1987. '
This review was postponed, at your request, in order to complete our review of the Tuba City UMTRA Project RAP. The areas reviewed included surface water hydrology and erosion protection, ground-water resources .
protection and geotechnical stability. The acceptance review indicated
' that the two sets of documents appear to be complete, except with respect to ground-water protection. To expedite the review, we have enclosed some comments that were generated as a result of the acceptance review, i We recommend that responses to these comments be transmitted as soon as !
available.
As you are aware, the NRC can ne b ger provide conditional concurrences of proposed re:nedial actions absent analysis of ground-water protection measures showing compliance with the proposed EPA ground-water protection standards (52 FR 36000, 9-24-87). The acceptance review indicated that the pfRAP and design documents have not specifically discussed how the remedial action at Mexican Hat will be in compliance with the EPA ground-water protection standards. We realize that the pfRAP and design documents were submitted to us prior to the NRC Headquarters February 9, :
1988 letter to you. However, an evaluation of the Mexican Hat remedial i action must be submitted prior to any concurrence on the proposed l remedial action. At this time, our intention is to provide you with a l 1
' 1 0FC : : * - - - I
..................... 31 g y g80302 , , , j NAME : : : :
- . . . . . . . . . . . . . . . . . . . . . . yM..63 .
1 c DATE :88/03/02 : : : : : : I
WM-63/SRG/88/02/29/0 MAR 21968 i
letter indicating that we are prepared to concur upon resolution of specified open issues.
There was an area of confusion identified in our acceptance review that needs clarification. It concerns the specific borrow area proposed for the radon barrier material. Enclosure 1 addresses our comments.
Please respond to these two items and inform us as to when you plan to '
submit the ground-water protection evaluation. Should you have any questions, please call Scott Grace or myself at FTS 776-2805.
Sincerely, l5~f Edward F. Hawkins, Chief Licensing Branch 1 Uranium Recovery Field Office Region IV
Enclosure:
As stated 1
i cc: D. Mann, DOE l
t I
1 l
I I
0FC :
............. URF0
% ....URf. k.
. .... :....URF0
- DJacoby : EHawkins
.NAME
. . . . .: .SGrace
. . . . . . ./.l . . v. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...........
DATE :88/03/02 : g{fp3 : 9/g/gg. : : : :
Enclosure 1 Mexican Hat ,
Comments on Radon Barrier Borrow Area Preliminary Final Remedial Action Plan and Final Design for Review Documents There is considerable confusion on what borrow area is being proposed for the radon barrier material. For example:
pfRAP (1/88), page 29 - indicates that areas "TZ" and "A" as shown on Figure 3.10 are to be used for borrow material, pfRAP (1/88), Appendix D, page D-178 - indicates that the primary borrow will be "A" and that "TZ" will be used as a backup. It further states that the "vinal design contains information on borrow '
area A."
pfRAP (1/88), Appendix D, Addendum 04 - contains logs of borings HAT 01-501 through -510, with no exploration location maps or borrow
- 10. Laboratory testing on samples from these explorations are summarized in Appendix 0, Borrow Material Characteristics (assumed from area "TZ").
pfRAP (1/88), Appendix E, Drawing HAT-PS-10-0954 (7/87) - indicates the locations of "Radon Barrier Borrow Area RB-4" and "Radon Barrier Borrow Area RB-7." There is no reference to areas "TZ" or "A."
pfRAP (1/88), Appendix E. MKE Document 5325-HAT-R-01-00769 indicates that the radon barrier thickness is based on data from the "TZ" borrow and that the final thickness will be adjusted based on i September 1987 testing of material from "RP-4" and "RB-7" borrow areas (availaole in November 1987). It also indicates that the percentage of bentonite that is to be added to the radon barrier borrow material will be based on a laboratory testing program. It further states that the quantities of materials available in borrow areas "RP-4" and "RP-7" are unknown.
Final Design for Review (7/87), Volume II, Cal. 9-239-05, page 4 -
indicates that soil properties from material from "Borrow #4" were used in the thickness calculation. MKE Document 5025-HAT-R-09-00533-00 is referenced in the text and on the borrow area soil properties summary l sheet on page 27. Our office has no record of receiving this report l
"from Lambert & Associates, dated May 1987,"
l It is assumed that the specification drawings in Appendix E of the pfRAP are correct and that the proposed source of radon barrier material will be areas RB-4 and RB-7. However, there appears to be no data base for this material. Therefore, before any additional review can be performed, i
I l
l r
r i
I the soil testing data from RB-4 and RB-7 should be submitted. Also, it '
would be prudent to clarify which borrow is to be used in all locations !
within the pfRAP and to address how the borrow area change will affect :
the other calculations, such as stability. ,
s 6
i l
l 4
b f
i i
l l 4
4
[
{ l, e n i .
r 1
l i [
! r i
l t
f
. _ _ _ . . , - _ .