Text

Responds to FOIA Request for Documents Re Vitro Umtrap. Forwards App Documents 91-96.All App Documents Available in PDR
	ML20154J454
Person / Time
Issue date:	01/24/1986
From:	Grimsley D; NRC OFFICE OF ADMINISTRATION (ADM)
To:	; ARGEE CORP.
Shared Package
ML20154J457	List: IA-85-843, Requests Reply as to Whether Branch Completed All Assigned Reviews Re Remedial Action Plan for Relocation of Salt Lake City Tailings to Clive,Ut.Proposed Ltr to DOE Transmitting Signature Page & Discussing Conditions for Concurrence Encl; ML20154J454; ML20154J463;
References
	FOIA-85-843 NUDOCS 8603100607
	Download: ML20154J454 (9)
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,s : : g Mr. Garth L. Wilson Project Manager The Argee Corporation P.O. Box 15128 IN RESPONSE REFER Salt Lake City, UT 84115 TO F01A-85-843

Dear Mr. Wilson:

This is in response to your letter dated December 17, 1985, in which you requested, pursuant to the Freedom of Information Act (F0IA), access to certain NRC records concerning the Vitro UMTRA Project.

The records listed on the enclosed appendix as items 1 through 90 are already available for public inspection and copying in the NRC Public Document Room (PDR) located at 1717 H Street, NW, Washington, DC. Documents 91 through 96 are being placed in the PDR in folder F01A-85-843 under your name. We are enclosing a copy of a notice that provides charges and procedures for obtaining copies of records from the PDR.

Sincerely,

&Y N A j Donnie H. Grimsley, Director Division of Rules and Records Office of Administration

Enclosures:

As stated

Re: F01A-85-843 Data / POR WM/NMSS Subject 3 From Refer to Accession # File Code 7*6/16/81 RCampbell RScarann 8107060128 WM-41 R;sponse to 4/29/81 ltr re DOE's proposed method of disposal for small quantities of low-level radioactively contaminated groundwater & stormwater i

2. 6/19/81 RScarano WShaffner 8107100131 Trip Report (5/4-8/81), UMTRAP EIS Scoping Meetings & Site Visits

3. 8/14/81 RCampbell RScarano 8109160159 Issues that NRC staff feel should be addressed in EIS

4. 9/21/81 WShaffner GEadie 8110200013 Prelimina,ry Review of DOE'S " Radiological Control Plan For Umtrap at Salt Lake Off-Site Properties" ,

3,10/6/81 WMUR Staff RScarano 8110190167 NRC Official Docket File For Salt Lake City Umtrap Inactive Uranium Mill Site (Vitro Site)

6. 12/10/81 RCampbell RScarano 8201190275 NRC staff's comments on 6/81 DOE report titled "UMTRAP--Salt Lake Off-Site Properties, Radiological Control Plan" (RCP).

7. 1/4/82 WShaffner DSo11enberger 8202080087 Review of DOE Report " Uranium Mill Tailings Remedial Action Program (UMTRAP)

Salt Lake Off-Site Properties, Health Physics and Safety Plan"

8. 3/23/82 RScarano WShaffner 8204290170 Meeting Minutes - DOE UMTRAP Vitro Site (Salt Lake City) Preliminary Draft Environmental Impact Statement (PDEIS) Review

9. 9/9/82 RCampbqill RScarano 8209280512 Responsp.t.o 6/23/82 request for NRC's review of the final Remedial Action Concept Paper (RACP) for the uranium mill tailings site at Salt Lake City

10. 9/20/82 WMott RScarano 8211060704 Response to request for comment on the intended designation of two additional properties in the vicinity of the Salt Lake City Vitro site

11. 10/8/82 RCampbell RScarano 8211110480 Review of the Preliminary Draft Environmental Impact Statement (PDEIS) dated 8/82 for remedial actions at the former Vitro Chemical Co. millsite in Salt Lake

12. 10/12/82 WMott RScarano 8211110478 Review of information received on 9/9/82 on (SLO 37 and SLO 68)

FOIA 85-843 I

R2: F01A-85-843 Dat;/ PDR WM/NMSS Subject To From Refer to Accession # File Code Environmental Impact Statement (PDEIS) Review 13.10/21/82 RCampbell RScarano 8212010508 l R;sponse to 10/1/82 request for formal concurrence in the final (RACP) 14*10/29/82 File WM-41 CFlory 8212020177 Designation of Salt Lake City Vicinity Properties SLO 37 and SLO 68 15*3/30/83 EHawkins 0 Martin 8304200618 Trip Report - Salt Lake City, UT, March 21-24, 1983 16.5/26/83 _J8aublitz DMartin 8306030470 R; view of the thirty (30) draft radiological survey reports submitted under c ver letter of 3/28/83 -

17,6/20/83 JMorley DMartin 8307050296 R; view of the Seismic Study Report for South Salt Lake City 18.6/24/83 JMorley DMartin 8307190472 R2 view of the Land Value Report for the Salt Lake City site 19*7/21/83 Matthews RPennifill 8308080325 R; view of the section of the Salt Lake City EIS dealing with public and agency comments as requested 20.9/15/83 To File RPennifill 8309270693 Meeting Minutes 21.10/4/83 MKnapp Weber 8310240265 R: port on the NRC-DOE Meeting on the Vitro UMTRAP Site and site visit in 5:uth Salt Lake,"

22,10/12/83 DMar' tin RPennifi11 8311100284 ;

Meeting Notes - Vitro Site _ 9/12/83 -

23.10/17/83 JMorley RPennifill 8311010129 Trip report prepared as result of meetings on 9/26 and 9/27, 1983 24.10/18/83 To Staff Weber 8311100286 Briefing about the Hydrogeology of the Vitro Mill Site, South Salt Lake 25.12/1/83 JMorley DMartin 8312220241 Questions regarding the status of several sections of the DEIS 26.12/23/83 WM-41 Weber 8402020075 Slides of DOE UMTRAP Site - Vitro Chemical Site, South Salt Lake 41 FOIA 85-843 2

9

Re: F01A-85-843 Dat;/ APPENDIX POR WM/NMSS Subject 3 From Refer to Accession # File Code 27.3/15/84 RPennifill TJohnson 8404110034 R; view of Salt Lake City UMTRAP PFEIS 28.3/15/84 DMartin DGillen 8404090178 R; view of preliminary final environmental impacts statement (PFEIS) for the South Salt Lake Remedial Action Plan 29.5/15/84 JBaublitz LHigginbothan 8406110378 Letter responds to letter to Mr. Browning dated 5/4/84 30.3/22/84 RPennifi11 MWeber 8406110070 R; view and comment on hydrogeologic characterization in the PFEIS for ,

remedial actions at South Salt Lake, Utah -

31* 6/1/84 LHigginbotham MKnapp 8407060290 R; view of hydrogeologic and geochemical assessments in the final environmental impact statement for remedial actions at the Vitro Site, South Salt Lake 32.6/6/84 JMorley LHigginbothan 8407030494 Received the Salt Lake City Remedial Action Plan on 5/23/84. Requests that review comments be submitted on 6/13/84.

33*6/6/84 JThemelis RPennifill 8407230319 Confirmation of planned visit to the Clive, Shiprock and Durango sites on 6/25 to 6/27 34* 6/12/84 JBaublitz LHigginbothan 8407110582 R; view of proposed Final Environmental Impact Statement (FEIS) concerning remedial action ,for the abandoned Vitro tailings in South Salt Lake TJohnson 8407120407

35. 6/14/84 - JLPennifill R; view of Salt Lake City draft Remedial Action Plan

36. 6/14/84 RPennifill DGillen/SSmykowski 8407050459 R; view of " Review Draft, Remedial Action Plan and Site Conceptual Design fcr Stabilization of the inactive Uranium Mill Tailings Site at Salt Lake City, Utah" t LHigg nbotham MKnapp 8407120357

37. 6/28/84 R; view and comment on hydrogeologic characterization in the RAP for Salt Lake City, UTAH, Review Draft, May, 1984

38. 6/27/84 JMorley LHigginbothan 8407120464 Review of May 1984 review draft of the " Remedial Action Plan and Site Conceptual Design for Stabilization of the Inactive Uranium Mill Tailings Site at Salt Lake City, Utah" File-41 WFord 8407170166

39. 7/9/84 FOIA 85-843 3

Ra: FOIA-85-843 APPENDIX -

Dite/ PDR WM/NMSS Sub.iect To From Refer to Accession # File Code Jacobs's' dewatering model for Vitro Site, Salt Lake City, Utah

40. 7/9/84 File-41 WFord 8407160328 Pumptest data and analysis, Clive, Utah, March 9 and 11, 1982 41* 7/11/84 JMorley LHigginbothan 8407230408 Receipt of a new evaluation of seismicity for the Clive site 42* 7/11/84 LHigginbotham .RPennifill 8407200275 Trip report for site visits Clive, Shiprock, Durango, Lakeview 43* 7/12/84 _JMorley LHigginbotham 8407200*'24 Visit on June 25, 1984 to the proposed Clive, Utah disposal site and the proposed rip-rap source area -

44* 7/25/84 JMorley LHigginbotham 8408140358 Review of the Radiological and Engineering Assessment (REA) for the Salt Lake property formerly occupied by White Truck (SL-049) 45* 8/1/84 JMorley LHigginbothan 8408230085 Review of the Radiological and Engineering Assessments (REA) for the vicinity property identified and concurs with the planned remedial actions 46* 9/5/84 JMorley LHigginbothan 8410040504 Review of the Radiological and Engineering Assessments (REA) for the vicinity property identified and concurs with the planned remedial actions

-47* 9/7/84 LHigginbothan GGnugnoli 8410030534 Meeting with individuals from the State of Utah, 00E and TAC on tt.e Salt Lake Remedial Action, Plan L

48* 9/17/84 J Morley LHigginbothan 8410030630 Requests concurrence in the Salt Lake City RAP by September 14, 1984 49* 9/25/84 MKnapp/LBarrett GGnugnoli , 8410150512 Meeting to resolve issues on the Salt Lake City and Riverton inactive milling sites

~ 50* 10/5/84 RPennifill SSmykowski/DGillen 8411090439 i Review of " Remedial Action Plan and Site Conceptual Design for stabilization cf the inactive Uranium alli tailings site at Salt Lake City, Utah 51"10/5/85 JMorley/JThemelis GGnugnoli 8412040274 41 UMTRAP - Remaining issues on Salt Lake City and Shiprock RAPS

52. 10/9/84 DMartin MFliegel 8501070288 F0IA 85-843 4

Re: FOIA-85-843

^

Date/ PDR WM/NMSS Subject To From Refer to Accession # File Code R; view and Comment on Salt Lake City R.A.P.

53. 10/12/84 LHigginbotham MKnapp 6411090025 R; vised staff position on groundwater contamination at the Vitro UMTRAP site

54. 10/12/84 LHigginbotham DMartin 8411090002 Lstter received from Mark Day, State of Utah, Dept. of Health, Dated 10/3/84

55. 10/16/84 LHigginbotham RPennifil1 8501040264 Meeting minutes, Salt Lake City, Shiprock and Riverton meeting, 9/29/84

56. 10/18/84 JMorley LHigginbotham 8412040331 41 Comments on the Salt Lake City Remedial Action Plan .

57. 10/22/84 MKnapp LHigginbotham 8412030645 UMTRAP - Salt Lake City Site

58. 10/23/84 MKnapp LHigginbotham 8412030577 UMTRAP - Salt Lake City Site

59. 11/13/84 LHigginbotham RPennifil1 8501070217 Trip report - Salt Lake City Central Valley Water Reclamation Facility PJustus WDam - 8501290661

50. 11/20/84 Geochemistry review of water quality at the Clive, Utah UMTRAP Site JThemelis LHigginbotham 8501070123

51. 11/26/84 Enclosure of the signed signature page for the Salt Lake City Site Remedial Action Plan TJohnsop MWeber 8501040141

52. 11/27/84 Scope of, Sautt} Salt Lake RAP Review LHigginbotham CFlory 8501110318

53. 12/14/84 Meeting on proposed Remedial Action at the Central Valley Wat1er Reclamation Fccility in Salt Lake City, Utah JThemelis LHigginbotham 8501300111

54. 12/14/84 R; viewed the Radiological and Engineering Assessments (REA) for the vicinity property RPennifill DGillen 8501110285

55. 1/2/85 R; view of specifications for Clive UMTRA Project prepared by Utah Dept. of Transportation and Radiation Control FOIA 85-843

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Re: F01A-85-843 APPENDIX 0 te/ PDR WM/NMSS Subject ,To From Refer to Accession # File Code 66.1/4/85 JThemelis LHigginbothan 8501300289 The State of Utah requests concurrence on remedial action on part of the Central Valley Water Reclamation Facility in Salt Lake City 67* 1/11/85 JThemelis LHigginbotham 8503040147 Comments on the specifications and quality control requirements prepared by the Utah Depts. of Transportation and Radiation Control for use at Clive, Utah

68. 1/14/85 JThemelis LHigginbotham 8503040027 41 R; view of the Radiological and Engineering Assessments for the vicinity properties 69*1/17/85 LHigginbotham MKnapp 8502280470 Seismotectonic review of the Salt Lake City Remedial Action Plan

70. 1/24/85 JThemelis LHigginbotham 8502280195 R; view of the Radiological and Engineering Assessments (REA) for the vicinity properties identified in the enclosure and concur with the planned remedial cctions.

71* 1/28/85 DGillen RPennifill PSCR for Salt Lake City - final processing site characterization report for Salt Lake City has been delivered

72. 2/04/85 MMatthews CFlory 8502280652 P5r telephone conversation of 02/01/85, enclosure of a copy of NRC comments on the " Draft Radiological and Engineering Assessment for Central Valley Water Reclamation Faci,11ty."

73.2/20/85 - JIhemel1s LHigginbotham 8504090447 R:; viewing of the Radiological and Engineering Assessment (REA)

74. 2/21/85 JThemelis LHigginbotham . 8504180128 R; view of the Radiological and Engineering Assessment (REA) for the vicinity property identified in enclosure and concurs with the planned remedial action

75. 2/28/85 File 41 LHigginbothan 8504170328 Seismicity of the Remedial Action Site in Clive, Utah

76. 3/4/85 JThemelis LHigginbotham 8504180163 Reference November 16, 1984 letter p oviding conditional concurrence in the Remedial Acton Plan for the site at Clive, Utah 77.3/5/85 JThemells LHigginbothan 8504180186 Concurs with the remedial action recommended in the REA FOIA 85-843 6

Re: F01A-85-843 Dat;/ APPENDIX POR WM/NMSS Subject To From Refer to Accession # File Code 78.3/19/85 LHigginbotham MKnapp 8505060048 Technical evaluation memoranda for Remedial Actions at the Vitro Processing Site, South Salt Lake, Utah

'N.3/20/85 LHigginbothan JGreeves 8505020392 41 Geotechnical Engineering Technical Evaluation Memorandum (TEM) for review of Salt Lake City Remedial Action Plan 80.3/25/85 JThemelis LJiigginbotham 8505070528 R; view of the Radiological and Engineering Assessments (REAs) dated 3/6/85 and 3/15/85 for the vicinity properties in Salt Lake City, Utah, SL-055 and SL-022 _

'81.3/28/85 JThemelis LHigginbotham 8505070019 Receipt of a copy of the State of Utah's responses to NRC comments on specifications and quality control, sent by letter dated 2/27/85 82.4/12/85 JThemelis LHigginbotham 8505030716 Review of the Radiological and Engineering Assessments (REAs) dated March 22 and March 28, 1985 for the vicinity properties in Salt Lake City, Utah 83.4/29/85 LHigginbotham DG111en 8505170318 Trip Report - DOE / State Meetings on Salt Lake City and Grand Junctio.n UMTRA projects 84.6/20/85 JThemelis LHigginbotham 8507080414 Review of the Radiological and Engineering Assessments (REAs) dated April 4 cnd 12.and May 8, 1985 for the vicinity properties in Salt Lake City, Utah 85.06/20/85 JThemelfs LHigginbotham 8507190026 R; view.af t.he. Radiological and Engineering Assessments (REAs) dated March 27 cnd April 25, 1985 for the vicinity properties in Salt Lake City, Utah.

86.9/06/85 LHigginbotham JGreeves . 8510240460 WMEG review of the clive remedial action inspection plan 87.9/18/85 JThemelis LHigginbotham 8510280227 C:ncerning a meeting of August 20, 1985 and the delivery of a draft Remedial Action Inspection Plan (RAIP) prepared by the State of Utah.

38. 9/23/85 DGillen TJohnson 8510280072 Review of construction specifications change for clive erosion proi.ection

39. 10/07/85 JThemelis LHigginbotham 8510280152 Results of our technical reviews of two proposed modifications to the Remedial Action Plan for the Salt Lake City Project

70. 10/22/85 DMartin DGillen 8512110650 Trip report; Meeting with DOE / UTAH on Salt Lake City Project FOIA 85-843

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.' Re: F01A-85-843 APPENDIX

91. 04/30/82 Letter to Ramsey from Scarano w/ Attachments. (6 pages)

92. 03/30/84 Letter to Morley from Higginbotham w/ Addenda. (27 pages)

93. 04/27/84 Optional Form 41 to Pennifill from Mathews (1 page),

w/

Attachment:

Sections 7.0 thru 7.2.10. (4 pages)

94. 11/14/84 Note to Branch Chiefs, WMGT & WMEG from Martin, WMLU,

Subject:

Brarch Concurrences on Proposed Higginboth.'m to Themelis Letter Conditionally Concurring in DOE Plan to relocate Salt Lake City Tailings to Clive, Utah (1 page), w/ attachments (5 pages)

95. 11/21/84 Letter to Themelis from Higginbotham (2 pages) w/ enclosed Staff Comments. (7 pages) -

96. 12/20/84 Memo for Higgenbotham from Gnugnoli

Subject:

Meeting with DOE /AL and DOE /HQ Regarding UMTRAP. (2 pages)

F01A-85-843 . 8

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WM r/f 41/WMS/82/04/15/0 NMSS r/f 1 WSha f fer DEMartin RASca ano BFisher WMUR:WMS JLinehan WM.41 HPettengill REBrowning JBMartin Robert W. Ramsey, Jr. , Program Manager KHamlil Remedial Action Programs Office Office of Nuclear Energy, NE.301 U.S.' Department of Energy Washington, D.C. 20545

Dear Mr. Ramsey:

We have reviewed the DOE Environmental Assessment (EA) for remedial action at approximately 100 Vicinity Properties associated with the UMTRAP Vitro Processing Site in South Salt Lake City, UT. This EA was provided by our copy of the January 27, 1982 memorandum to you from Richard H. Campbell, Project Manager, UMTRAP Project Office, DOE.AL. The primary purposes of our review were to provide you with our comments on the EA and our overall judgement regarding the adequacy of the EA in assessing the environmental consequences of remedial action at all of these vicinity properties. In addition, we wanted to identify those individual vicinity properties specified by the EA which we consider to be unusually significant in the sense that we feel it necessary for the NRC staff to individually review and concur in their remedial action plans. For the remainder of the specified Vitro Site vicinity properties, we feel that our review of the EA coupled with our continuing participation as a NEPA cooperating agency in the preparation of the Vitro Processing Site EIS will suffice to fulfill our UMTRCA Title I responsibilities to review and concur in the selection of UMTRAP remedial actions, provided only that there is no exception from applicable EPA standards.

By Attachment I we are providing our comments on the EA and its adequacy as the required environmental documentation for the proposed vicinity property remedial actions. On Attachment II we have individually identified the unusually significant Vitro Site vicinity properties as discussed above. We thus anticipate receiving the individual remedial action plans for the Attachment II properties for our review and concurrence. We intend on adding to the Attachment II list as appropriate, when the remaining vicinity properties are identified and sufficiently characterized.

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,, APR30 ggy 41/WMS/82/04/15/0 From an overall standpoint, and excluding the Central Valley Water Reclamation Facility (CVWRF) not covered by the EA, we would caution that the DOE should assure itself that the approximately 100 properties covered by the EA encompass the vast majority of tailings relocated by various means from the Vitro Site to vicinity properties. Otherwise a meaningful assessment of environmental consequences may not be presented by such an EA. Provided this is the case, we feel the EA generally to be an adequate environmental review document to assess the consequences of remedial action at those Vitro Site vicinity properties covered by its scope.

Sincerely, r .[

Ross A. Scarano, Chief Uranium Recovery Licensing Branch Division of Waste Management cc: (w/ attachments)

Richard H. Campbell, 00E.AL Dr. William E. Mott, 00E.HQ Robert J. Stern, DOE-HQ i

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,0 41/WMS/82/04/15/1 ATTACHMENT I NRC STAFF COMMENTS ON DOE ~

VITRO SITE VICINITY PROPERTIES ENVIRONMENTAL ASSESSMENT (EA)

1. Sec. 1.2 (p. 2) - To our knowledge, no final and documented

, detennination has been made regarding the environmental impact assessment for the DOE propost.d partial cleanup of the Central Valley Water Reclamation Facility (CVWRF) where an exception from meeting EPA Standards may, and probably will, be required. The NRC staff has reviewed preliminary CVWRF remedial action documentation, advised the DOE that it found it seriously lacking, and the documentation has not yet been resubmitted to NRC in revised fonn for our review and concurrence. We certainly consider the CVWRF to be an unusually significant vicinity property, containing more ,

tailings than any other single vicinity property, and thus would normally have included it on Attachment II. We understand though that this EA has been scoped purposely to exclude it from consideration since its remedial action plan development is already being handled separately.

2. , Sec. 1.2 (p. 4) - The Vitro Site vicinity property cleanup cost estinate provided to NRC staff at the January 27, 1982 DOE /NRC Vitro Site PDEIS meeting was approximately $11M (including engineering).

We do not understand why vicinity property construction costs alone are noted in the EA as up to $25M (apparently even excluding the CVWRF).

3. Sec.1.2 (p. 4) - In our judgement, not all vicinity property materials would have to be already on the Vitro Site before the processing site reme. dial action could begin, even if the processing site tailings were to be stabilized in place. Surely a significant parallel effort Fetween the two activities can be projected even assuming stabilization in place..

4. Sec. 1.3.2 (p. 5) - We feel that Alternative 2 (in effect, a scheme approximating stabilization in phce at each vicinity property) would be inconsistent with the intent of Title I of UMTRCA to minimize, in a conclusive manner, the potential health hazard due to tailings removed from inactive sites. Overall, the thousands of l UMTRAP vicinity properties may subsequently require a permanent l

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41/WMS/82/04/15/1 and inordinately large environmental monitoring and administrative organization to implement and assure that the Alternative 2 radiation control remained "in-place". Alternative 2 also exhibits the potential for each vicinity property being considered as a ~

disposal site, and therefore technically subject to licensing by the NRC.

5. Sec. 3 and Appendix D (in general) - Throughout these two key

, sections it is not clear whether the results presented numerically in the text are risks to worker individuals, to the total of workers, occupants, and residents associated with the vicinity properties, or to the total Salt Lake City area population. This should be clarified at each point where a numerical value is presented.

6. Sec. 3.1 (p. 15) - Because vicinity property remedial actions will be carried out over an extended period (5 yrs assumed for EA calculations), this section should also estimate exposures to the general public in the Salt Lake City area. This would appear even more important considering the EA's characterization of the area as dry and prone to high winds.

The risk to a worker would appear to be a one in 500 chance of a case of lung cancer. We do not view that risk as " highly unlikely",

especially given that these projects may require a large number of workers over an extended period. We note for example that if 1,000,000 remedial action man hours (p. 22) is required over an estimated 5 yr period, this equates to 500 workers for 5 yrs. It would appear therefore that at least one case of lung cancer among the workers is to be expected.

7. Sec. 3.14 (p. 23) - The remedial action operations protocols to be developed should be submitted for NRC review and concurrence. In this manner, we can provide a generic concurrence that will apply to a number of properties and which could then be utilized, modified only by site specific factors, at other UMTRAP sites. This would fulfill part of our UMTRCA Title I requirement to concur in the performance of remedial action at vicinity properties. We are assuming that the protocols are different documents, since they are not yet prepared, from the Salt Lake City generic Radiological Control Plan (RCP) and Health Physics & Safety Plan (HP&SP), on which we previously provided review and comments.

l A91

41/WMS/82/04/15/1

8. Sec. 4.2 (p. 27) - The excess health effect (cancer) to workers is stated as 0.001 (gama) and 0.0012 (radon) here, whereas it appears to be stated as 0.001 and 0.002, respectively, on p. 16. This inconsistency should be explained. ,

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ATTACHMENT II NRC STAFF IDENTIFICATION OF UNUSUALLY SIGNIFICANT VITRO SITE VICINITY PROPERTIES" Tailinss (yd3)

1. Ice Cream Manufacturing Plant (2575 So. 300 W.) 13.c oo

2. Comercial Location (2565 So. 300 W.) 13,000 (a) This list is based only on review of the 23 properties already included on the official list for remedial action (excluding the Fire Station and CVWRF properties). Other vicinity properties may

be added to this list after they are identified and characterized sufficiently.

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41/FP/84/03/19/0 Mr. m es A Lorley DISTRIBUTION Department of Ene'rgy NM55 r/t WMLU r/ f .M s/f cibuquercue Operations Office RPennifill DEMartin KJackson 0.0. Sex 5400 MKnapa JGreeves m'eter Alcuocerque, Nea Mexico 57115 TLJonnson DGillen CFlory/

GNGnugnoli MHaisfield PDR Nr M- Morley: REBecwning MBell JBunting Attached are NRC comments on the PFEIS for South Salt Lake, Utah. The majority

' c r eate are directed to tne subject cf g*ouM ater hyceology at the Vitro site. In our sie., the ground .ater system and state of existing contamination are not yet adecuately characterized in the EIS. Without an adequate definiticn cf the existing contamination and hydrologic flow system, there is not a reasonable casis upon wnich to make a decision on the need for remedial action for ground water at the site. The EIS should be revised to reflect plans for dealing with tre existing contamination, if any, and the basis for this decision. Since these grounc water issues may take some time to fully resolve, we reccmmend that the text of the EIS also include a statement that grounc-water studies are continuing at the site, and that if the results of the studies later indicate major differences frot the impacts or plans for remedial action discussed in the EIS, a supplement to the EIS will be published.

Tne rest cf cur specific co- ents primarily relate to sections of the EIS which have been changed and whicn NRC has not previously had the opportunity to review. When these remaining comments have been considered, we would like to review the changes to the text which DOE would pre; ose.

Tne current version of the PFEIS does not adequately support the decision to move the tailings from South Salt Lake to Clive. The only apparent justifications are that for stabilizaticn in place, the CVkRF might be restrained in their plans for expansion and that if the CVWRF builds a temporary industrial park, the area could derive an 11 million dollar economic cenefit per year. Ho.ever, given the amo';nt and value of vacant land in the area, the industrial park could be built else here and generate similar but icnger term benefits. If CVWRF loses a portion of the Vitro property due to stabilization in place, they could continue their expansion by using other prcperty in the area or by otherwise revising their plans. This would allow them to serve the Salt La.e community well into the future. Given the cifferences in cost cet.een the options it is our view that a stronger rationale should be presented if the option to relocate the tailings to Clive is chosen.

Une possible negative iract cf mosing the tailings has not been acdressec.

Q Given the large vclume of truck or train traffic bet.een South Salt Lake and N 316G L _

J i .

'Ut% Y't*%J U OFC : WEU :WMLU ;WMLU NAME :RPennifill :DEMartin :LHigginDotham . .

DATE :64 03/28 cb :84/03/ 84/03/ -

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41/RP/84/03/19/0 1

i Clise, there is a strong possibility that portions of the transportation route will become contaminated unless appropriate measures are taken to ensure that no spillage of tailings occurs. The EIS should discuss the measures which will l be taken to prevent releases of tailings over the 3 year construction period l along the transportation route.

i l Also, the EIS does not adeouately reflect the recent DOE / Utah agreement and the r ele of centractor to Le piajed by tne State. The agreement estimates the cost of stabilization in place at 540 million versus $30 million in the PFEIS. If l 00E believes that preloading of the site would be necessary for stabilizatten l in place (witn the resulting higner costs), as is stated in the agreement, it l

should be reflected in the EIS. he recommend that the entire agreement be reproduced in the EIS, and that necessary changes to ensure consistency between ;

the EIS and the agreement be made.

The objective of our. review of this EIS is to evaluate the adequacy of tt.

! conceptual designs and the evaluations of their associated environmental j l impacts under NEPA. As we have discussed and agreed in the past, most aspects i of the design will be reviewed in greater detail upon submittal of the remedial action plan.

4 Sincerely, i

c.rigina151sned Bf.

Leo B. Higginbotham, Chief Low-level Waste and Uranium i Recovery Projects Branch Division of Waste Management ;

l I

l cc: Larry Anderson, Utah Bureau of Radiation Control l

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,, NRC Staff Comments on the PFEIS for South Salt Lake i 1 Section 1.3, Page 11, !2: According to informatian presented in Section 1.1, l L the Vitro Chemical Company Site contains approximately 1.9 million dry tons of '

! tailings and over 1 million dry tons of other contaminated materials. The '

l isti ate of 2.5 :ili i.n tcns cf tailings anc c.ner ccatcminated r.cterials in

! this section should be consistent with the estimate in Section 1.1.

ection 1.4, Page 12, Th !nstallation of a liner beneath tne stabili:ed tailings pile in Alternative 2 would also reduce the rate of water movement l from within the tailings into sediments beneath the embankment. This reduction in moisture migration may be expected to increase the effectiveness of l

geochemical processes (e.g., sorption, precipitation, etc.) in reducing the l rates of aqueous contaminant migration from the stabilized tailings.

l !

l The argument that supports constructing the stabilized embankment in j l Alternative 3 without a liner is not that the tailings would be at least 15 t feet above the groundwater system ( i.e., the water table), but rather that the l l not infiltration through a low permeability cover and the tailings at South !

Clive would not be sufficient to substantially degrade groundwater quality beneath the Clive site. This section should be revised to clarify why a liner is not considered to be necessary in Alternative 3.

Section 1.4, Page 15, 14: It should be noted that the temporary industrial park will only produce the economic benefits if it is built. Other vacant land is available such that similar benefits could be obtained under alternatives 1 f or 2 within a several block radium of the site.

l Section 3.1.1, Page 22, Table 3-1: This table does not summarize EPA's guidance for groundwater protection and restoration as detailed in Subpart C of 40 CFR l 192. This guidance should be summarized and incorporated into Table 3-1 l consistently with descriptions of the groundwater protection guidance in the I text.

l

( Section 3.1.1, Page 24, 13: Judgments on the need for aquifer restoration ,

l and/or protection are to be guided by relevant considerations described in

! EPA's Hazardous Waste Management System [47 FR 32274] and relevsnt Feoerai and l State Water Quality Criteria for existino and potential uses of affected acuifers.

These underlined phrases should De inserted into paragraph 3 to accurately summarize r EPA's guidance on groundwater protection at UMTRAP sites.

l

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_-.----- _ _ ~ _ --- .-n.-.,--

Section 3.2.3 ,Page 32, T4: The purpose of the " upper capillary break" is r,ot discussed in the text. Construction of the stabilized embankment with this break may actually increase net infiltration.into and through the einbankment.

By providing a more conductive unit below the low permeability cover, water that infiltrates through the cover may migrate rapidly through the break zone and into the tailings beneath. In comparison, if the cover is underlain by a relatively low permeability unit, infiltration into the tailings embankment w,'i ce impecec, ,.hich incieases the potential for evapor6 tion of this water from the surface of the embankment. Since one of the design objectives for the embankment is to minimize net infiltration into the tailings beneath the cover, ne performance of the emoankment with the upper capillary break should be compared with the performance of the embankment without the break to evaluate which design is more effective in minimizing infiltration.

Section 3.2.4, Page 42, T3: Discussion of placement of contaminated materials at the Clive site indicates that the material will be dumped from trucks or train cars and compacted to form a " dense, stable material." Given the saturated condition of much of this material at the South Salt Lake site, it is highly likely that additional drying, mixing and other working of the material, at the Clive site, prior to its compaction will be necessary to enable a dense, stable pile to be constructed. The need for these activities and/or spec'fic requirements for the moisture control and degree of compaction should be centioned.

Section 3.3.1, Page 46, 15: The conclusion that Alternatives 2 and 3 would not differ in their radiological and non-radiological impacts on groundwater quality is not correct. As reported in this PFEIS, existing groundwater quality at the South Clive site is poor ( greater than 10,000 mg/l TDS).

Groundwater at South Clive is of lesser quality than the groundwater that is beneath the Vitro site. Design and locational differences between Alternatives 2 and 3 will cause differences in the amount of infiltration through the embankments and, therefore, contaminant migration from the stabilized mill tailings. Because background groundwater quality differs and the projected releases of contaminants intuitively differ, the conclusioa that Alternatives 2 and 3 would not differ in their radiological and non-radiological impacts is incorrect.

In addition, the third sentence of this paragraph (on page 47) is incorrect.

Groundwater in the confined aquifer system beneath the Vitro site is potable and an important resource to residents of the Salt Lake Valley as a source of domestic and municipal drinking water, a. ell as industrial and agricultural water. Even in the unconfined aquifer syi:em, water quality in select locations beneath tne Vitro site indicates that the unconfined system coule

$ 2-

sapph water that is of useable quality (see fcr exa p!e sarple analyses from wells V-FS anc TAC 6-A).

These fallacies in ccmparison cf the impacts of alternatives 2 and 3 should be cerc.ed from the text. The ccmpariscn of impacts on ground-ater quality shculd also reflect the conclusions presented in Appendix D, after this appendix has been revised to address specific comments included in this review.

Section 4.2.1, Page 51, 53: Figure 3-2 is not an aerial photograph of the Vitro site as referenced in the text. The 3erial photograph that was included in the

E: 5 ter Soutn Sait Lase snould ce inciucec in the FEIS in idaition ta tne base map of the site that is presently in the PFEIS as Figure 3-2.

Section 4.5.2, Page 59, T5: Geologic cross-secticns of sediments beneath the South Clive site, which were deleted from the DEIS in preparation of the FEIS, should be included rather than referenced in the descripticn of South Clive geology. An appropriate section for their inclusion might be Appendix 0, where they could be used in the conceptualization of the groundwater flow system at South Clive.

Section 4.6.1, Page 69: Synthetic Flood Analysis; and P. A-27: The use of a 1-hr PMP for the 45-square mile watershed at Clive is cuestionable. It appears that a PMP cf longer duration is justified for a watershed of this size.

Section 4.6.1, Page 69: The NRC staff does not support the hypothesis that the PMF has a recurrence interval of once in 10 million years. Any statistical references to a PMF should be deleted.

Section 4.6.1, Page 69: The effects of a PMF on Mill Creek should have been determined, with the peak discharge and velocities presented.

Section 4.6.1, Page 69: Depending on the hydraulic and seismic designs of the cams upstream from the South Salt Lake site, it may be necessary to assume additional failure modes (other than simple gate failure), which could affect the peak flood estimate at the site. The NRC staff does not necessarily agree that the assumptions presented in the PFEIS constitute an adequate basis for the conceptual designs at the site.

Section 4.6.1, Page 70: The scale on Fig. 4-4 should be corrected.

Section 4.6.1, Page 73, il and 4: Total dissolved solids content (TDS) is not regulated by EPA's primary drinking water standards (National Interim Primary Drinv.ing Water Regulations. 40 CFR 141); a Secondary Maximum Contaminant Level for public water systems of 500 mg/l is the recommended limit for TOS under the M"2

- ~

National Secopdary Drinking Water Regulations (NSDWR, 40 CFR 143). Eoron is not a regulated constituent under either the NIPDWR or NSDWR, Section 4.6.1, Page 73, 15: Water quality samples abstracted from Vitro Ditch and South Vitro Ditch (see Page D-63) indicate elevated concentrations of molybdenum, lead, and uranium. Statements that surface water quality was not sampled in the Vitro Ditches in this program should be deleted from the text.

his paragraph snculd be revised to De consistent wit- infor.& tion presented in Appendix 0.

Section 4.6.2, Page 78, 54: Maximum Contaminant Levels for public water systems for chloride, iron, sulfate, and total dissolved solids are provided in EPA's National Secondary Drinking Water Regulations (NSDWR), not in the NIFDWR.

Section 4.6.2, Page 79, T2: Baron is not a regulated constituent under EPA's primary or secondary drinking water regulations (NIPOWR or NSDWR).

Section 5.1.2, Page 113, 12: The doses due to suspended particulates need to be quantified. Particulate doses are comparable to radon doses when the incremental impacts of the action alternatives over the no-action alternative are calculated. (The incremental direct gamma dose for the action alternatives is a negative value.) The consideration of incremental impact is lost in the PFEIS because the particulate dose was wrongly judged to be insignificant (see comment for page F-33) and the doses to bone and lung for the action alternatives were calculated by scaling from the no-action alternative radon dose calculation-(see p.F-44 and Table F-14 on p.F-45). Although the particulate source term increased by an order of magnitude from the DEIS to the PFEIS (Ra-226, for example, from 1.9E-2 to 22E-2 Ci/ year) the doses to the bone and lung for the action alternative decreased by two orders of magnitude.

Doses to the general public within and beyond one kilometer (see Table 5-1, p.117) and to the workers (see Table 5-2, p. 119) due to suspended particulates should be included in the FEIS.

Section 5.1.2, Page 113, 12, Last Sentence: The concentration "5 pCi/gm" is used as though it were a de minimis level and that any lesser concentration would contribute insignificant ingestion doses, yet 5 pCi/gm in soil of Ra-226 contributes an adult dose of about 80 mrem / year just from above ground edible vegetables. (A normal background of 2 pCi/gm has been subtracted). The reason for not considering this pathway is the lack of farmland, not the level of contamination.

Section 5.1.3, Page 116, T3: A risk factor of 20 lung cancer deaths for each 1,000,000 person-rem is used for health effects from inhalation of radon daughters. It appears that the PFEIS has selected this risk factor because of M 2--

1 i

tha arcument contained in the Evans et al., 1981 reference; however, the Evans l

refereiice recImmends this risk factor specifically for the general public.

(Also see the last sentence in the second paragraph on page F-8). Evans reccamends that a higher risk factor be used for occupational workers because !

of the different exposure conditions. A greater risk f3cto- should be used for the remedial action worker in the FEIS.

6:.ica E.'..*, Fa;e U.!, T.: Ne 'FE:S ca'c .'.ates r ca: cic h4C n effsets to I

the general population within a six mile radius of the site. This radius ,

i should be extended to include essentially all populated areas in the Salt Lake '

l City :stropolitan cistrict. Tne FEIS snoalc: (1) Conplete the pcpulaticn i l distribution table in Table G-1 on page G-6, and (2) Rerun the MILD 05 code with the completed (out to 80 KM) population distribution or with the portion of pcpulation distribution which accounts for at least 95*. of the population out to 80 kilometers.

l Section 5.1.4, Page 116, %2: The FEIS should calculate the dose from suspended l particulates for the maximally exposed individual, page 120, Table 5-3: The unit for individual backgruund dose should be

mR/ year. The table (footnote C) uses 0.4 pCi/l for radon background; this j contradicts the value of 0.2 pCi/l in Section 4.8 (p. 85) and 0.25 pCi/l at the i

bottom of page F-4.

l Section 5.3.4, Page 127, 15: The discussion on page 127 indicates a cover consisting of 3 feet of soil overlain by 2 feet of rock on the side slopes and ;

1 foot of rock on the top, whereas, the information presented in Appendix A :

, (pages A-23 and A-27, Figure A-7) indicates a cover of 5 feet of soil and 2

! feet of rock on both the side slopes and top. These inconsistencies should be l corrected. ;

i l

Section 5.*.2, Page 129: The information presented in this section about the impacts of Alternative remedial actions 2 and 3 should be revised to be l consistent with conclusions presented in Appendix 0 after revision. Impacts on i l groundwater quality should be asses:;ed by comparing the impacts of Alternatives l j 2 and 3 with those of Alternative 1 as a base case. !

1 l Section 6.6, Page 168, Response 1: Hydrologic studies presented in Appendix D t of this PFEIS are not sufficient to characterize seasonal fluctuations in l hydraulic heads within the unconfined and confined groundwater systems beneath r the Vitro site. The hydraulic heads presented in Appendix 0 describe water i levels within the unconfined system which were measured in April, 1982 and

, September, 1983. Stresses on the unconfined system were substantially '

cifferent between the April and September measurements. In addition, the head l l

h9% l c

l [

l I

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distribution githin the unconfined system has been significantly affected in the last several years by abnormally high snow melts in the Wasatch Mountains east of the Vitro site. The PFEIS does not provide head levels (or the potentiometric surface) within the confined system other than a small scale reconnaissann map for the entire Jordan Valley that is based on heacs measured in February, . 59.

mcc rhte seascnal head r.edsurements within tne unconfined anc confined aquifer systems at the Vitro site e.re essential to understanding groundwater flow from the uranium mill tailings, surface recharge-discharge relationships, and suosurface recharge-discnarge relationships. As discusseo in Section 0.3.4, changes in the surface recharge-discharge relationships between April, 1982 and September, 1983 significantly affected groundwater flow directions and relative water balances within the unconfined aquifer system as simulated. To establish the hydraulic head information necessary to conceptualize existing hydrogeologic relationships beneath the Vitro site and defensibly assess and predict long-term contaminant transport a ay from the site, NRC staff recommends that DOE measure head levels in all of the wells constructed by the TAC, as well as their well points, the Dames and Moore Wells, the piezemeters constructed by Colorado State University, and existing production wells in the SE corner of the Vitro site. These head measurements snould be collected quarterly for a period of at least one year to assess seasonal fluctuations and stresses to the groundwater systems beneath ther site.

Page 172, Section 6.7, Issue 2: A commentor indicates that ponding occurs at the Clive site on an annual basis. DOE responds that this is not unexpected.

If this is the case, the PFEIS should contain a discussion of the frequency, duration and magnitude of this ponding and its potential effects on the staoilized tailings.

Section 6.7, Page 173, Response 3: Although groundwater quality, as reported in the PFEIS, does not satisfy EPA's primarv or secondary drinking water criteria, d0mestic, industrial, and agricultural use of this water is not precluded. The NIPDWR and NSDWR only apply to public water systems. The "therefore" in sentence 4 should be deleted. We agree that the water is not suitable for domestic use but not for the reasons provided.

Pages A-1 and A-65: The reference to the South Salt Lake Remedial Action Plan document, should be changed to indicate that the cocument has not yet been ccmpleted and made available.

Section D: The descriptions of the stratigraphy beneath the Vitro mill site do net adecuately characteri:e the distribution of sediments beneath the site as cbserved in boreholes drilled by Dames and Moore and the TAC. Because the Ah

_g.

cistricution g,f sediments beneath this site is 50 complex and significantly controls groundwater flow and thus contaminant transport beneath the site, COE shoulc interpret existing stratigraphic well logs to develop a defensible representation of sediment types and distributions beneath the Vitro mill area.

As eeamples of the types of geologic illt.strations that the MC staf f find useful and necessary to conceptualize groundwater flo. beneath the Vitro site, Addenda 1, 2, and 3 provide preliminary stratigraphic fence diagrams and

. . 3 a;;i;ci :.,a n d un cata c.. e;tec cy Caces an: L;re and tne TC.

Addendum 1 indicates that the relatively-thick, preccminantly clay layer that c*ists :eneatn tne soutneastern arc soutncentral partions cf *he Vitro site thins to the west. As portrayed in these adcenda, a single clay confining unit does not exist beneath the entire site, the sediments in the unconfined aquifer system are similar in composition and distribution to those of the confinec aquifer system, and relatively thick and extensive layers of sand exist within the unconfined aquifer system hydraulically downgradient from the uranium mill tailings. Such complex stratigraphy challenges the representativeness of the simple layer representation of the units beneath the Vitro site that is used in the hydrodynamic simulations of Section 0.3.4. Careful examination of site stratigraphy may aid investigators in explaining anomalous drawdowns observed curing on-site pumping tests, interpreting variations of groundwater quality within the aquifer systems beneath the Vitro site, delineating the extent and rovement of contaminant plumes, and evaluating the practicability and appropriateness of aquifer restoration in the remedial actions at South Salt Lake. These conceptualizations of site stratigraphy can also be expected to significantly affect other analyses presented in Appendix D.

Section D.2.1, Page 0-2, T2: Characterization of the groundwater within the unconfined aquifer system beneath the Vitro site as brackish with TDS contents greater than 2000 ppm is not accurate. As observed in well clusters 6 and 7 hich are presently hydraulically upgradient from the Vitro site, water quality irproves with depth within the unconfined system (see comment page D-33). In another shallow well located on-site, V-FS, the reported TDS is only 340 mg/1.

Such generalizations of water quality within the unconfined aquifer system beneath the Vitro site should be deleted from the text because, based on the data presented in this PFEIS, water quality witnin this system varies both laterally and vertically.

Section D.2.1, Page D-2, 52: Water cuality information, other than basic water types, should be removed from tnis section and consolidated into Section D.3.5, Analysis of Water Quality, Geochemistry, and Solute Transport. This includes tam es 0-4 through 0-6 and discussions of relevant Feceral (Table 0-1) and Utan State Water Quality Criteria, as wtll as aater quality informaticn presentec in Section D.3.2. The purpose of this consolidation is to eliminate A%.

cr.necessary rg,dundancy of water quality discussions and to facilitate easy referencing to the water quality data and sampling techniques.

Section D.2.3, Page D-7, 51: Effective porosity was not analyzed by the field investigations by the TAC and Dames and Moore. Effective porosity should be deleted from the list of parameters analyzed from the last sentence of this paragraph. In addition, because of the construction of monitoring wells 16 and 17, anc com%ications in tne Wmp tesi.ing of ceep ,, ell 15, tne accuracy of vertical hydraulic conductivity estimates is questionable (see comment page D-40).

Section D.3.1.1, Page D-9, Figure D-4: Dames and Moore monitoring wells identified as V-GS and V-HS, which are listed in Table D-3, should be located on Figure D-4 since water quality data have been sampled in these wells and reported in Table D-4.

Section D.3.1.1, Page D-15, Table D-4: Redox potentials of ground ater samples collected by Dames and Moore are provided in Table D-4, yet this table does not provide any measurements of dissolved oxygen (00). Recent literature, in particular Korte and Ealey, 1983, has stated that measurements of redox potential (i.e. Eh) are of minimal value if they are measured in water samples with 00 contents greater than 0.01 ppm. If DO was not measured in these samples, this short-coming of the Dames and Moore sampling program should be acknowledged in discussion of the sample analyses. Eh values are highly significant to evaluations of geochemical equilibria for Eh pH sensitive metals (e.g., U, Fe, Mn, etc.); incorrect evaluations of Eh may siginificantly affect calculations of equilibrium assemblages using computer codes such as PHREEQE (see Section D.3.5).

Section 0.3.1.2, Page D-22, 52: The suggested maximum well yield in the unconfined aquifer system of 10 gpm is not consistent with information presented elsewhere in Appendix D. For example, in the pumping test of shallow well V-CS1, Dames and Moore pumped the well at 11 gpm for 4.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> which resulted in a drawdown of less than one foot (see page D-38). In addition, because sediment units in the unconfined and confined systems are relatively similar, and the confined systems supply wells with appreciable yields, potential yields to wells that are completed in the unconfined system probably exceed the 10 gom maximum suggested in the text.

Section D.3.1.2, Page D-31, 54: The text describes a spring at the head of Vitro Ditch in the east central portion of the Vitro site and provides an explanation for its high rate of discharge as being a damaged artesian well.

Figure D-5 indicates a shallow well, V-GS, near this location, but this well is only completed to a depth of 36.5 feet with a screened interval from 25 to 35 h 9 ~2.-

' set below the land surface. Additional characterizaticn of this feature is necessary prior to the development of a defensible groundwater flow model beneath the site beccuse this spring is a significant discharge point for groundwater from the uncon'ined or confined aquifer systen, or both. If the

'lcw frca this spring is approximately equal to 1 cubic fcc per seccnc (cfs) or 450 gpm, its flow rate exceeds that from the CVWRF excavation (300 gpm). As evaluated in Section D.3.4, groundwater discharge to the CVWRF excavation is

ne c; #nant surfa:e cistnarge ter- 'r;: tr.e er.ccr,'inec a; i fer s, s:Er uncer present conditions. Since the spring discharge is approximately 1.5 times tnat of the excavation, the spring is the cominant discharge tern. The simulations a 5=ction D.3.4 are inccrrect, therEf ore, Decause tney have qct aCCountec for this important discharge term.

If the groundwater is discharging through a damaged well casing, simple field cbservations and review of site records (including those of Dames and Moore) snould be sufficient to verify this hypothesis. If the spring is a natural phenomena, it may be necessary to gauge the discharge frcm the spring, observe seasonal fluctuations in its discharge rate, and install well points or piezometers to characterize the factors that effect this discharge.

p Section D.3.1.2, Page D-32, Figure D-5: Comparison of this figure with geologic logs prepared by the TAC for wells 4, 11, 5, 16, 15, 14, and 9 indicates that Figure D-5 is incorrect. For example, borehole number 5 does not penetrate any layers that are predominantly clay, yet Figure D-5 indicates that this borehole penetrates five such clay layers.

As commented previously, the NRC staff recommends that DOE prepare accurate stratigraphic fence diagrams and cross-sections for the Vitro site using existing data collected in wells established by the TAC and Dames anc Moore. If these diagrams cannot be prepared exactly as recorded in the well logs, the text that accompanies the diagrams should explicitly rationalize the deviations from the recorded data and evaluate potential effects of misinterpreations.

The staff recognizes, however, that the stratigraphic logs provide a resolution no greater than 3.5 feet because 1.5-foot samples were taken down-hole on five-foot intervals. In addition, substantial assumptions about lateral continuity and thickness variations will be required because of a lack of stratigraphic data beneath large areas of the site.

Section D.3.2.1, Page D-32, T1: Collection of groundwater semoles during aostraction of monitoring well water immediately af ter stabilization of Ec and temperature may not ensure that the water sampled is representative of aquifer water quality. Even stabilization of pH, in addition to Ec and T, does not necessarily ensure abstraction of representative aquifer water. As discussed in a letter from M. Knapp to M White dated March 15, 1984, the NRC staff h-

prefers a sama, ling methodology that evaluates the time of pumping after which at least 95% of the water abstracted from the well is aquifer water. This methodology should be based on well intake calculations that are verified by time series chemical sampling.

Section D.3.2.3 and 4, Page D-33: In addressing the second page 0-2 comment above, Tables 0-7, -9, -10, and -11 should be deleted from the text.

c:eeentation of water q;.ality in tnis manner does not clearly delineate tne background groundwater quality or the effects of the u*anium mill tailings at the Vitro site on existing groundwater systems. In place of these tables, the idC staff recommenos tnat DOE develop a combination of maps, lateral chemical profiles, vertical chemical profiles, and other geochemical illustrations to characterize existing grounawater quality at the Vitro site. Addenda 4, 5, 6, and 7 have been included with these comments as examples of the types of illustrations that the NRC staff recognizes as acceptable and useful illustrations to delineate existing groundwater cuality. These illustrations should be considered as an interpretation; similar, but different, diagrams could be prepared using tne same data as were used in preparation of these illustrations. For example, maps of uranium, molybdenum, and sulfate contaminant plumes beneath and hydraulically downgradient from the Vitro site have been prepared using a composite of data collected by GECR (1982), Dames and Moore (1983), and the TAC (1983). Some of the data recorded in these investigations have not been included in these maps, because, upon inspection of the total set of water quality data, these data do not appear to be representative of aquifer water quality or because insufficient data exist to develop concentration contours in the area of observation (e,g,, the reported arsenic concentration of 0.5 mg/l in shallow well 13C). The staff also recognizes that variations in the collection, preservation, and analysis of samples between the different investigators, as well as other variables such as depth of sampling, sediment unit sampled, direction of local groundwater flow, time of sampling, well construction, and antecedent events may affect the results.

As an example of another type of illustration that the NRC staff finds useful in interpreting water quality data, Addendum 7 portrays sulfate concentrations (in meq/1) versus depth of well screen center point (in feet below surface).

Concentration profiles for well clusters 9, 10, and 11 are plotted to compare with the general trend of sulfate concentrations with depth observed in well clusters 6 and 7. The a: proximate solubility limit of gypsum (CaSO4*2H2 O) is plotted assuming a typical calcium concentration of 100 mg/l and an activity coefficient of 50 42 equal to 0.36 (solubility product from Krauskopf, 1979; activity coefficient based on techniques of Davies, 1962),

A92-

l In the evalualions of existing groundwater quality and chemistry, the staff recommends that 00E evaluate the extr.t of perturbation to the hydrogeologic system that probably occurred during operation of the Vitro mill. For example, l

well clusters 7 and 12, which are considered to be background wells in the PFEIS, were probably within the portion of the hydrogeologic system that was perturbed during operation of the Vitro mill. Acceptable analytical techniques for this evaluation range in complexity from conservative and bounding

_d:dations te n=.erics! andar ancly .' cal sci ticn3 (pernaps by n.ccifyin-nunerical models discussed in Section 0.3.4). Available historical data (e.g. ,

observations of seeps and marsh areas by local residents during mill i .per&ticns) snould be factcred into this evaluation. Tne results of these j evaluations are necessary to defensibly delineate background groundwater j quality in monitoring wells close to the site. Although the present i groundwater flow system may approximate the system that existed prior to I

milling, perturbations to rock-water geochemical equilibria may continue to affect groundwater quality within sediments that once were affected by mill tailings leachates but are now hydraulically upgradient from the uranium mill tailings at the Vitro site.

Section D.3.2.5, Page 0-37, 12: Based on information presented in Appendix 0, it is not apparent why the observed elevated concentrations of iron, chloride, TOS, and sulfate within the confined aquifer system were caused by heavy pumping at the mill site during operation. Interpretations of water quality data measured in wells 5 and 15 do not indicate that increases in l concentrations of sulfate, chloride, TOS, and iron were caused by drawdown l within the confined system in response to aquifer pumping. Comparison of water

, quality in wells 5 and 15 (see page 0-27) indicates that iron, chloride, TOS, l~

and sulfate are normally more concentrated in well 15 than in well 5. Changes in water quality within well 15 during the pump test are within the accuracy of the analyses (compare, for example, the changes in all reported cations and anions versus the measured change in TOS in well 15). In addition, the comparison of water quality in wells 5 and 15 is complicated by their l

completion in different sand intervals. Conclusions based on these data and observed drawdowns during the pumping test of well 15 are too weak to argue l that observed increases in TOS, chloride, sulfate, and iron concentrations l witnin the confined system were caused by excessive drawdowns during operation of the Vitro mill.

Section 0.3.3.2, Page 0-40, 14 - 6: The text does not describe corrections made to drawdown data that were collected during pumping tests of the confined l aquifer system. These corrections would account for the effects of natural l aquifer recharge-discharge trends, off-site water use, barometric response of l the aquifer, and aquifer boundaries. Such corrections are generally necessary l to defensibly characterize the transmissivities and storativities of aquifers.

D

These corrections may have accounted for the anomalous recovery and dra-down

~

responses observed in monitoring wells during the pump tests of the confined and unconfined aquifer systems at the Vitro site. For example, the slight recovery cbserved in six shallow wells may have been caused by natural trencs in head levels which were only mcdified in response to the pumping of well number 15.

? ccc# tion, the c;n:t N ti0n details cf m:n't!. ring wells 16 and 17 present defensible characterization of the vertical hydraulic conductivity of the clayey silt layer in which the wells are completed. As portrayed in Addendum 5, ::o.n of these wells are ccepleted in units above the production interval cf pumping well 15. Unfortunately, stratigrapnic information was not collected in borehole 17. Assuming that the units observed in well 15 are laterally continuous to borehole 17 (assumption supported by comparison with stratigraphic information from borehole 14), the filter packs of wells 16 and 17 extend into the same sand layer above the silt layer in which the wells are completed. Extension of the filter packs for wells 16 and 17 into this sand layer will result in the monitoring of composite head levels across the filter packed intervals.

Complications in monitoring well construction, as well as the absence of head corrections discussed in paragraph 1 of this comment, have precluded defensible characterization of vertical hydraulic conductivity of the sediments in the unconfined and confined aquifer systems beneath the Vitro site. The effects of these uncertainties may aid investigators in explaining the range of six orders of magnitude in vertical hydraulic conductivities as documented in Table D-15.

Appendix D should be amended to include a discussion of the significance of the uncertainties discussed in this comment.

Section D.3.4, Page D-42. T3: The Prickett-Lonnouist finite difference cooe referred to in this paragraph is a " pre qualified" code of the Nuclear Regulatory Commission. Code pre qualification does not imply that the computer ccde has been generally approved by the Commission, but rather that the cooe

, satisfies several evaluation criteria established by the NRC staff. This section should be revised to eliminate the phrase "has been approved by the United States Nuclear Regulatory Commission." Reference to NRC code pre qualification in place of this phrase is appropriate.

The introduction to the Prickett-Lonnauist code on pages D-42 through D-45 is a commendable inclusion in the PFEIS because it provides readers with generai aspects of the code and describes modifications to the code for ease of application.

A%

Sec-icn D.3.4.1 Page D-45: Ccmments on the hydrodynamic mcdels described on pages 0-45 th7ou,gh 0-57 have been consolidated into this ccmment. In general these models appear to oversimplify the hydrogeolcgic system beneath the Vitro site. The purpose of the flow models.in Appendix D is not explicitly discussed in the text. Specific ccaments on the models in:iude the fellcwing:

Page D Calibration of heads to within 14 feet within the un;;r" .sf sp am % 4: co ::nside ule e-r:r in the s: 4tica sircs the head differential across the site is less than seven feet (see Figure D-3). A calibration error of three feet could locally reverse groundwater floo, thus procacing errcneous results. It is difficult for readers to evaluate the success of the calibration simulations, because the text does not provide maps of the calibrated heads for comparison with maps of cbserved heads.

Page D The calibrated models of the unconfined system and confined system do not account for discharge to the spring at the head of Vitro ditch.

Page D Assessments of surface recharge-discharte relationships do not account for seasonal variation in observed heads. In addition, discharge to South Vitro Ditch, Vitro Ditch, f/ill Creek, and the drain below the railroad underpass may not be adequately represented in the models. In the calibrated models for existir.g conditions, it is assumed that shallow groundwater does not discharge into South Vitro .

Ditch. Comparison of heads measured in the shallow system (Figure D-10) with, topographic cross-sections in FBDU (1981, see page 2-8) ,

indicates that the observed heads may be above the free surface in South Vitro Ditch. Descriptions of the boundary conditions do not explicitly discuss how the underpass drain is incorporated into the model of the unconfined system under present conditions.

Page D The text does not justify differences in the analytical techniques used to calculate recharge-discharge to Mill Creek and the Vitro Ditches compared with those techniques used to calculate discharge to the Jordan River in establishing stream leakage relationships.

Page D The text does not justify the assumption that the aquifer systems beneath the Vitro site are isotropic or that the heterogeneity of hydraulic conductivities accurately reflects the distribution of sediments as discussed in comment number 21. As modeled in these simulations, the units do not account for vertical heterogeneity or

&L

~ _ _ _ _ _ _ _ _ _ _ _ _ _ _

16 -

anisotropy as observed in boreholes beneatn the site.

Page D Conclusions based on fluxes into and out of the unconfined system in the calibrated present case model must be assumed by the reader to estimate net fluxes in Table D-18. The conclusion that more water flows out of tne CVWRF excavation (54,718 3ft /d) than into the ,

model boundaries (52,062 ft2 /d) is questionable, even though the model l nas been caiioratec to witnin a fe. percent relative errer in tctal water balance.

Section D.3.4.2, Page D-58, 51: As commented previously, the Vitro site ;

contains approximately 1.9 million dry tons of uranium mill tailings (see Section 1.1). Increasing the estimate of 1.7 million tons provided in this section to 1.9 million dry tons, the calculated average abstraction rate of groundwater from the confined aquifer system should be 215 gpm. It is doubtful that sustained abstraction of groundwater at this rate could effectively reverse the hydraulic gradient between the unconfined and confined systems at the Vitro site. No pumping wells were observed by NRC staff members Verma and Weber during the September,1983 site visit; at least five, large diameter, flowing, artesian wells were observed during this site visit in the southeast '

corner of the Vitro site. These observations suggest that water was produced at the mill site during operations from flowing artesian wells, whose flow rates would reduce if the hydraulic gradient between the unconfined and confined systems reversed. In addition, artesian wells with average abstraction rates up l to 1294 gpm are documented in Table D-12; reversal of the upward hydraulic gradient between the confined and unconfined systems has not been documented near these wells. Therefore, it should not be concluded that on-site pumping of production wells during operation of the Vitro mill induced a local reversal of the hydraulic gradient between the confined and unconfined aquifer systems.

Section D.3.5.1, Page D-58, %2: Specific comments on the evaluations of i existing groundwater quality, geochemistry, and solute transport away from the Vitro site are not provided in this review. NRC staff considers such predictive assessments premature until the extent of existing groundwater contamination has been delineated beneath the Vitro site. Once this contamination has been delineated, which will include addressing specific comments in this review about site stratigraphy and hydraulic characterization of the Vitro site, investigators will be able to calibrate their assessments !

against historical conditions prior to prediction of future impacts. '

As portrayed in Addenda 4 and 5, contaminant plumes exist beneath and ;

hydraulically downgradient from the Vitro site. The extent of contamination !

downgradient toward the Jordan River has not been established. Unless shallow !

wells and well points exist in this area near the River which are accessible l

fer water cuality and hydraulic head monitoring, installation cf additional shallow well 'c'lus-ters may be necessary between monitoring wells 4 anc 10 and the Jordan River. Tne delineation of contaminant plumes downgradient from the site requires water quality data in both lateral and vertical spatial

& ensicns, and depencirg up;n seasonal fluctuations in the groundwater flow system, also temporal monitoring data. NRC staff recommends that DOE assess the need for installation of additional monitoring wells in the unconfineo

. 1.c l' e 7 de'e si:1c W 'et ticr cf ta:kground grcora.atcr qcalitj.

Collection of additional data in existing wells (monitoring water quality in

caticns sampiec by tne TA: , Ca.es and Moore, and GECR) as well as in ar.j new wells will likely affect the assessments and predictions of contaminant transport in the unconfined groundwater system downgradient from the Vitro site. Because of these impacts, and those mentioned previously, detailed ccmments on the geochemical assessment presented in this section have not been provided.

Section 0.5, Page D-73 through D-77: Because of the succinctness of the description of hydrogeology at South Clive, specific comments on the description have been consolidated into this comment.

Descriptions of the stratigraphy beneath the South Clive site, which were included in the DEIS for South Salt Lake but were deleted in preparation of the PFEIS, should be included to conceptualize groundwater flow and potential contaminant transport away from the South Clive site.

The text should provide the analytical techniques used by investigators to determine the transmissivities of sediments beneath the South Clive site. Preliminary results of these analyses are provided in the text in paragraph 1 of page D-76.

The text should provide the locations of the off-site wells that are referenced in Section D.S.4 on page D-76. The well locations could be provided in Figure 4-4 on page 70.

In describing the hydrogeology at South Clive, the text would be improved by explaining why the hydraulic gradient beneath the site is cpposite the gradient that would be expected beneath the site; recharge occurs east of the site, and the topographic gradient is to the southwest so that the expected hydraulic gradient would be generally to the west-southwest.

hD

I

).

In general, tr,e staff does not recognize disposal of the Vitro tailings at South Clive as having significant impacts on groundwater quality beneath the site because the quality of this groundwater, as documented in this PFEIS, is naturally poor (greater than 10,000 ppm TDS). The poor quality of groundwater at South Clive will effectively preclude practical use of this resource.

Section F.3.2.2, Page F-21, Table F-3: Tne value for the lower limit of c:.=cticr,(LLD) shci d tse recu cea . hen the measured value is oeica :ne LLO.

When the zero values are averaged with radionuclide concentrations the sampling site average is less than the true average. There are typographical errors in tne orcer of magnitude for tne average Ra-226 and Pb-210 values at tne Southeast Clive location.

Section F.4.2, Page F-33: The PFEIS, after calculating the 50 year particulate dose commitment to the lung from Ra-226, Th-230, and U-238 for the remedial action worker, concludes that the resultant doses are insignificant 5. hen compared to radon and direct gamma doses. However the total of the three doses, 23 mrem / year or 69 mrem over the life of the project, is larger than the direct gamma dose. Furthermore, the dose commitment from particulate Pb-210 should be added to the total inhalation dose. Therefore the FEIS should calculate the particulate inhalation dose to the remedial action worker. This comment supports the comment for Section 5.1.2.

General: Inconsistencies that exist within the PFEIS with regard to the maximum seismic accelerations should be corrected. The maximum potential seismic acceleration at the Clive site is consistently reported in the PFEIS as 0.6g. However, the maximum seismic acceleration at the South Salt Lake site is given as 0.2g on page 10, while on pages 63 and H-12 it is reported to range between 0.3g and 0.55g.

General: A statement should be added to the PFEIS to indicate that the designs presented are preliminary designs and could be modified based on detailed reviews of final designs, supporting calculations, and assumptions.

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ADDENDUM 9 REFERENCES Davies , C. W . ,1962. Ion Association (London, England: Butterworth

.) Company) .

00E,1983. Draf t Environmental Impact Statement for Remedial Actions at the Former Vitro Chemical Company Site, South Salt Lake, Salt Lake County, Utah. 00E/E!S-0099-D.

Ford, Bacon & Davis Utah, Inc.,1981. Engineering Assessment of Inactive Uranium ltill Tailings: Vitro Site, Salt Lake City, U ta h . 00E/UMT-0102.

Korte, N. and D. Ealey,1933. Procedures for Field Chemical Analyses of Water Sanples. Bendix Field Engineering Corporation, GJ/TMC-07(83).

Krauskopf, K. B. ,1979. Introduction to Geochemistry (New York, New York: McGraw-Hill Book Company) .

Markos, G. and K. . Bush,1982. Data for the Geochemical Investigation of UMTRAP Designated Site at Salt Lake City, Utah. 00E/UMT/0236.

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l 7.0 RESPONSIBILITIES OF PROJECT PARTICIPANTS l I

l

7.1 INTRODUCTION

The following defines the various responsibilities of the Department r of Energy (00E) UMTRA Project Office, the Nuclear Regulatory Commission !

l (NRC), and the State of Utah during Title ! design, remedial action, and !

through the initiation of custodial maintenance and surveillance. Respon.

I sibilities are divided into major categories to be performed by the par- !

I ties. The 00E will be assisted by its Technical Assistance Contractor i (TAC) and Reedial Action Contractor (RAC), but all assigned responsibili- !

ties will remain the ultimate responsibility of the DOE. In general, the TAC will assist the DOE in the preparation of concept designs and remedial I action plans and will provide quality assurance, audits, and recommenda-tions for final certification. The RAC will prepare detailed designs and ;

manage field construction activities for the vicinity property remedial :

actions. .

The State of Utah will be responsible for engineering design and reme- [

dial actions for the processing site and the CVWRF vicinity property, t Their responsibilities will be administered and coordinated by the Departrient of Health, l Major areas of responsibility for future actions by the DOE, the i State of Utah, and the NRC are sumarized as follows: (

1. 00E (including TAC RAC):

Provide data required to prepare detail design.

Provide funds. [

Audit remedial action. :

prepare licensing plan and submit Ilcense application. l Prepare maintenance and surveillance plan. !

Receive Itcense. l Conduct maintenance and surveillance, l Certify remedial action. l

2. State of Utah Concur in RAP. l Transfer site to 00E. t Manage and coordinate projects. i Obtain permits and approvals. !

Prepare detailed designs and specifications, f prepare quality assurance plan.

Prepare and implement pubite participation and information plan. !

Conduct remedial action. l Provide funds. ;

l I

3. NRC:

Review and concur in RAP. I Review and concur in maintenance and survelliance plan.

f I

SLC CLIVE RAP, Oraf t, Apell 1944 bD l

e l

Audit renedial action construction.

Review and concur in final certification report.

Issue license for long-term monitoring and maintenance of the dis-posal site.

7.2 DETAILED RESPONS!BILITIES Detailed responsibilities of project participants in the areas of per-mitting, licensing, land acquisition, detailed design, construction, health and saf ety, public inf ormation, radiological support, quality as-surance, and custodial maintenance and surveillance are defined in the fol-lowing text.

7.2.1 Regulatory compliance Requirements for regulatory compliance, previously identified by Federal and State agencies ( Agencies), will be incorporated in.

to the final design specifications, as needed, by the State.

The State will submit permit applications, and supporting de.

tails to the Agencies for permit issuance.

During the remedial action, the DOE and NRC will audit con.

struction activities for compliance with provisions in the permits and approvals. (Permitting Agencies may independently audit rel.

evant activities consistent with normal practice.)

Upon completion of the permitted action, the NRC will conduct a final review and will prepare a close out report for submittal to the Agencies. Permits will then be terminated.

7.2.2 Licensing As part of the licensing task and prior to completion of the remedial action, the DOE will prepare a Itcense application includ.

ing a site maintenance and surveillan:e plan. The application will be submitted to tne NRC for review and concurrence.

Revisions resulting from this review will be incorporated into the final application which will be submitted af ter the 00E and NRC has certified tnat remedial action is complete.

' Any final revisions required will be added and the license will be issued by the NRC to the DOE (or responsible designated F ederal agency).

7.2.3 Land acquisition DOE is granted permanent right of. entry to the disposal siti tnrough Article 3 Acquisition, 01sposition and Use of Property of the cooperative agreement. The State will acquire the Inter.

40 SLC.CLivE RAP, Oraft, April 1984 /q92$

i e

i ests of permittees, lessees, and sublessees of, or other individ-uals with property interests in the disposal site. Upon comple-tion of the remedial action, legal title to the residual radioactive materials will be conveyed to the Federal Government.

7.2.4 Detailed design The State will prepare preliminary and final engineering draw-l ings, specifications, and bid packages. Once finalized and ap-l proved by the DOE and NRC, the bid packages will be issued to prospective bidders pursuant to Federal regulations and a construc-l tion subcontractor selected.

l 7.2.5 Construction The State will prepare guideline documents to comply with j

health and saf ety, security, quality assurance, public informa-tion, and other regulatory requirements.

The State will acquire the necessary permits and approvals from the appropriate agencies.

Construction activity audits will be performed by the 00E.

l Revisions to the remedial action resulting from site audits will be incorporated into the record drawings and the remedist action plan by the State as necessary.

Upon completion of the remedial action, the site will be cer-tified by the 00E.

7.2.6 Health and safety The State will prepare an environmental health and safety plan. As part of the implementation procedures, the State will in-stitute radiation control and environmental monitoring, and will develop response procedures for severe weather and medical emergencies.

Construction contractors will :omply with approved procedures and file rsdiological saf ety reports with the State that record the results of monitoring, and report accidents and illnesses.

l Records will be maintained by the State following remedist action construction.

Employee and public complaints will be investigated by the State.

7.2.7 Public information l

l The State will estabitsh a local site manager who will pro-vide information to tne pub 11c and local media.

l St.C CUVE W. Draf t April 1984

t

' Prior to and during construction, the State will conduct pub. !

lie inforrration meetings to inform the interested public of key as-l pects and current progress of the remedial action.

Concurrent with the public meetings, the State will provide r status and progress reports for other agencies (e.g., 00E, NRC, !

EPA). [

7.2.8 Radiological support The State will prepare and implement a radiological support l After remedial action, the State will prepare a completion re.

port, conduct a final certification survey, and provide a recom-mendation for site certification. The NRC will review and concur in the final certification report.

I 7.2.9 Quality assurance ,

The State will prepare a quality assurance plan. The DOE vill audit tne construction activities.

I 7.2.10 Maintenance and surveillance l The 00E will prepare and submit to NRC the site Maintenance l and Surveillance Plan. The NRC will review and concur with the i plan, and the DOE (or responsible Federal agency designated) will assure that the plan is implemented. t l

I l

l !

\

1 r

i St.C C1.!VE RAP, Draf t, April 1984 [D I

ML20154J454

Contents

Text

Dear Mr. Wilson:

Enclosures:

Attachment:

Subject:

Subject:

Dear Mr. Ramsey:

7.1 INTRODUCTION

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ML20154J454

Text

Dear Mr. Wilson:

Enclosures:

Attachment:

Subject:

Subject:

Dear Mr. Ramsey:

7.1 INTRODUCTION

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