ML20150E139
| ML20150E139 | |
| Person / Time | |
|---|---|
| Issue date: | 06/23/1988 |
| From: | Hawkins E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Arthur W ENERGY, DEPT. OF |
| References | |
| REF-WM-48 NUDOCS 8807150013 | |
| Download: ML20150E139 (3) | |
Text
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- DISTRIBUTION Docket File WM-48
- PDR/DCS: 1 DBangart, RIV WM-48/SRG/88/06/08/0 SGrace RCPD, C0 LLO Branch, LLWM URF0 r/f 3 23 1988 URF0:SRG Docket No. WM-48 0400WM048880E W. John Arthur, III, Project Manager Uranium Mill Tailings Project Office U.S. Department of Energy Albuquerque Operations Office P.O. Box 5400 Albuquerque, New Mexico 87115
Dear Mr. Arthur:
We have reviewed the February 1988 Draf t Surveillance and Maintenance Plan for Durango, Colorado, transmitted by your February 5, 1988 letter.
As a result of the staff review, we have developed the comments in Enclosure'1.
In summary, these comments note a discrepancy between the text and drawing DUR-DS-10-0337 and comments relating to ground-water monitoring.
We note that the document is not current with respect to the monitoring requirements of EPA's proposed standards.
However, we have made comments on how the monitoring described in the plan relates to the proposed standards.
It should be noted that a surveillance and maintenance plan for Durango may have to ultimately include a monitoring and a corrective action program for ground-water cleanup at the processing site, depending on the final version of EPA standards.
The enclosed comments will need to be addressed bet' ore we can approve the Surveillance and Maintenance Plan, e
If you have any questions, please contact Mr. S. Grace of my staff at FTS 776-2805.
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,o Sincerely, o
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/sl co w Edward F. Hawkins, Chief g
Licensing Branch 1 gg Uranium Recovery Field Office p pb 3
- co Region IV I>c T Io ggg
Enclosures:
As stated cc:
D. Hann, 00E
...........l............l............l............l...........
NAME : SGrace/lv
- EHawkins DkTE k8/06/15 f
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Comments on Draft Surveillance and Maintenance Plan Durango, Colorado Section 2.1 - Monuments, Markers and Signs 1.
There are discrepancies between the text and drawing DUR-SD-10-0337 that need to be addressed.
The text indicates that the three "survey monuments (Section 2.1.1)," the "boundary monuments (Section 2.1.2)" at the four corners of the site, the two "site markers (Section 2.1.3)," and the locations of the "perimeter signs (Section 2.1.4)," are all illustrated on drawing DUR-DS-10-0337.
the referenced drawing, however, shows only the locations of four "site monuments" and six "project survey monuments."
Section 2.2 - Ground-Water Monitor Wells and Section 4 - Ground-Water Monitoring 2.
The document is not current with respect to the monitoring requirements of the proposed EPA standards for the disposal site nor for the processing site.
3.
Well 605 is identified as an upgradient background well for grourd water in the site vicinity.
From the borehole log in the document, it appears that this well is completed below the weathered zone of the Cliff House Sandstone only and not in the alluvium / colluvium.
Therefore, a background well is necessary for the alluvium / colluvium.
However, due to the localized nature of the alluvial / colluvial ground-water system and the fact that the tailings cell covers this localized system, background water quality may have to be derived from pre-construction data.
For example, an appropriate well with pre-construction water quality data might have to be designated as the alluvial / colluvial background well, even though this well was abandoned prior to construction.
4.
Point of compliance wells at the disposal site need to be proposed.
It appears from the data included in the plan that appropriate point l
of compliance wells can be selected from the wells drilled in May 1987.
5.
It is stated in the text that preliminary water level measurements in these wells (the May 1987 wells) generally confirm that ground-water flow directions within the sediments beneath Bodo Canyon basin are topographically controlled with primary subsurface flow northeastward along the ephemeral drainage.
From the borehole logs, only one of the May 1987 wells is completed in the alluvium / colluvium (Well 608) and one well completed in the
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'eathered Cliff House Sandstone (Well 608).
Please clarify how flow w
directions were inferred from the data from these wells.
6.
In Section 4.1, it states that ground-water samples from Wells 605 through 609 will be sampled at least semiannually for several constituents.
In order to be consistent with the EPA prcposed standards, several other Appendix VIII (40 CFR Part 264) constituents should also be monitored.
To guide you in your selection of the appropriate constituents, the following additional constituents have typically been found in tailings solutions:
antimony, barium, beryllium, chromium, cyanide, nickel, lead,
- diethyl phthalate, methylene chloride, acetone, chloroform, carbon disulfide, 2-butanone, naphthalene, 2-methy1 naphthalene and 1, 2-dichloroethane.
Acetone and 2-dichloroethane are not Appendix VIII hazardous constituents, but they may indicate the presence of closely-related compounds in the methylene and acetone families.
7.
There is no reference to ground-water monitoring at the processing site.
In order to meet the requirements of Subpart 8 of the proposed EPA standards, a monitoring program adequate to define the extent of ground-water contamination by the Appendix VIII constituents needs to be addressed.
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