ML20154K228
| ML20154K228 | |
| Person / Time | |
|---|---|
| Issue date: | 12/08/1987 |
| From: | Banks E, Bilhorn S NRC |
| To: | NRC |
| Shared Package | |
| ML20154K218 | List: |
| References | |
| REF-WM-72 NUDOCS 8805270296 | |
| Download: ML20154K228 (4) | |
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RECORD OF MEETING NCTTES g
MEE' TING DATE:
DEGMBER 8,1987 REXJORDED BY:
E. Banks /S. Bilhorn PURPOSE:
To discuss joint UMTRA/AML plans for cleanup of the Title I site at Spook, Wyoming, with NBC staff.
ATTENDEES:
See Attached List 1.
AML Backfill Cover TJohnson and JGrim discussed their concerns regarding stability of the backfill material covering the tailings, as previously raised in NRC staff coments GS/1 and SW/1 on the RAP /SCD. TJohnson said that his concern is not so much that long-term erosion will expose the tailings but that erosion may allow ponding in the backfill over the tailings causing a potential g*oundwater problem. EBanks explained that the slope norphology of the backfill surface is expected to result in sheet erosion with a minimum anount of gully erosion. Tnis projection is based on slope vs.
drainage area relationships in the literature. JGrim stated that this relationship is a general one, and may vary on a site specific basis.
TJohnson and JGrim mintained that there would be gullying and that the extent of gullying has not been ade]uately evaluated. To assess the erosion DOE would need to conpare the conditions of the backfill cover with soil type and evaluate the slope stability of the surrounding drainage areas. TJohnson and JGrim agreed that if groundwater nodeling showed that infiltration associated with potential gully erosion and subsequent ponding would not contribute significantly to contamination of the groundwater, further evaluation of the cover's erosion potential would not be necessary. TJ(hnson reconmended that DOE refer to NURB3 4620 regarding possible methodologies for evaluating soil slope stability.
TJohnson suggested that analyses may show the proposed tailings cover system is not needed an:1 that renoval of the low permeability or high permeability layers can be justified. EBanks explained the proposed groundwater nodeling scheme which will be presented in the upcoming draft Environmental Assessment (EA). This nodeling will estimate potential infiltration of water from the backfill material into the tailings pile, then estimate flux from the tailings pile into the groundwater regime in the aquifer. EBanks stated that if modeling shcNed the DOE proposed cover system was not necessary, the cover design would be nodified as appropriate. Dilution calculations will also be perforned to show the constituent concentrations down gradient of the pile area cue to the tailings. EBanks stated that constituent concentrations down gradient of the tailings were also originating in the overburden material.
II.
Definition of LMrRA-related Material EBanks provided DDE's description of the "waste piles" referred te in the Report of Investigation (POI) for the State of Wyoming Abandoned Mined Lands (AML) Program prepared by Hydro-Engineering,1987. AML's terminology indicates that some of these "waste piles" may fall under 8805270296 880523 PDR WASTE WM-72 DCD
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DOE's cleanup responsibility, such as those described as containing
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10w-grade material. DOE plans to clean-up material characterized as tailings, unprocessed ore and low-grade material using 0.05% U-238 by weight fran the definition of source material in 10 CFR 40 as the lower liIrit. EBanks presented a calculation suggesting that if radium and uranium are in equilibrium, a radium level of 167 FCi/gm corresponds to
.05% U-238 (see attached). BFonner, legal council for NRC staff, agreed that if this calculation was correct then material below 167 pCi/gm would not be considered source material under 10 CFR 40 and therefore ney not fall under LMrRA cleanup requirements. EBanks explained that AML characterized the overburden piles as having average radium activities below 167 pCi/gm but with sone "waste piles" having spots with activities higher than this level.
SBilhorn suggested that DOE describe the piles characterized by AML to affirm what material exists therein and identify which piles DOE must clean up under LMrRA. For example, the AML report states that several "waste piles" consist of stockpiled low grade ore and others contain material contaminated by spillage. MScoutaris stated that if the waste pile referenced is determined by DOE to be ore, that the DOE will clean it up.
EBanxs explained that the AML has agreed to layer the overburden, placing the most radioactive overburden material at the bottom of the pit and the cleanest material on top. However, DOE does not intend to rely on this layering strategy to meet licensing requirements since this activity will be conducted by AML without DOE control. DOE stated that the AML design will be provided to NBC to support the design review.
III.
Clean-up Standards EBanks stated that the "standards" for groundwater or radiological cleanup do not apply to AML activities. However, AML has assured DOE that they will attempt to clean up the surrounding site to 20 pC1/gm and will 2
attempt to neet the GfrRA standards for radon flux of 20 pCi/m at the disposal facility. EBanks enphasized that DOE should nog be responsible to cleanup the surrounding site to 5 pCi/gm (or 20 pCi/m ) since this radioactivity originates from material outside afrRA responsibility. NBC reconinended that DOE consult their legal counsel to clarify what DOE's ultirate responsibility is for cleanup of this afrRA site, considering AML/ DOE shared activities. BFonner noted that DOE may want to apply for supplemental standards with the cleanup of this site to reduce the OfrRA liability from 5 pCi/gm radium to 20 pCi/gm, corresponding with the non-LMrRA cleanup criteria.
IV.
Groundwater Issues EBanks discussed the uranium and selenium plurre data from the site area.
l In this data the uranium levels up-gradient of the Spook Pit area were l
above EPA's prop sed standards and the uranium levels down-gradient of the Spook site were higher yet.
It is uncertain how much of this uranium
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contamination is from MfrRA-related naterials; however, MScoutaris stated l
that the plume would still exist if the LMIRA reaterial were renoved.
l EBanks suggested that background be defined within the minino and ore body area, not at a point up gradient of both the ore body and the pit area.
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BFonner stated that the Inna Pits could be UMIRA-related sterial and that t
the area should be characterized. If the Ioma Pits contain UMTRA material, the DOS may be liable for cleanup of that s terial as well as the related contaminant plume. EBanks stated that is is unlikely the pits contain tailings since there was no sign of processing in that area and that if the Inna Pits were backfilled with relatively uncontaminated spoil materials, the s terial should not be DOE's responsibility. MSx>utaris agreed to characterize the material in the Iara Pits through records of the reclam tion, if possible, or by exploration activities.
Raising the issue of to what extent the UNIPA project would be responsible for aquifer restoration, BGlover noted that the groundwater contaminant plume at Spook is related to both processing and mining activity. NRC responded that DOE could ptentially be held responsible for mitigating all groundwater impacts since it may not be feasible to separate impacts from processing and mining activities at this UMTRA site. NRC also stated that co-disposal of the tailings and AML overburden should be conducted so as not to significantly affect future possible aquifer restoration.
BGlover suggested that DOE and NBC staff's meet to discuss DOE's long-term aquifer restoration goals. NRC agreed, but stated that DOE should first consult with their Icgal counsel for an opinion regarding DOE's responsibility for groundwater contamination in the vicinity of the Spook Pit.
BGlover asked for NRC staff to state its position on the proposed EPA groundwater standards. SBilhorn stated that in NRC's opinion, the UMIRA Project is obliged to comply with the proposed stardards until final standards were promulgated. She further stated that in the RAP /EA, DOE should address how the proposed remedial actions are designed to cccply with those standards.
V.
Summry of Comitents o
DOE will characterize material in the previously reclaimed I.oma Pits to determine if tailings kere disposed of therein.
o DOE will obtain legal advice from DOE attorneys regarding DOE overall responsibility for site cleanup, and groundwater restoration (including in spoil areas and the adjacent reclaimed pit).
o DOE will provide a description of the piles characterized by AML, specifying what s terials they contain and which piles fall under DOE responsibility for clean up.
o NRC will review the calculation presented by DOE suggesting that 0.05% U-238 corresponds to 167 pCi/gm. 1
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4 NAME ORGANIZATION PHCNE 3
Susan Bilhorn NBC/IDE (301) 492-0573 Giorgio Gnugnoli NRC/IDE (301) 492-0578 Milt Scoutaris DOE /UMTRA (505) 846-1200 Joel Grian NBC/IDE (301) 492-0569 Banad Jagannath NBC/IDH (301) 492-0593 Bill Glover (MIRA-TAC (505) 846-1250 Eric Ihnks Jm/ TAC (505) 846-4011 Ted Johnson NRC (301) 492-3440 Michael Ibkar NRC (301) 492-0590 Jake Gatrell DOE /HQ/UMIRA (301) 353-3569 Rcbert Fonner
?GC/OGC.____ _
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