ML20195E365

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Forwards M Weber Summary of 880526 Meeting W/Doe Re Alternate Concentration Limits at Umtrap Sites
ML20195E365
Person / Time
Issue date: 06/15/1988
From: Lohaus P
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Arthur W
ENERGY, DEPT. OF
References
REF-WM-39 NUDOCS 8806240025
Download: ML20195E365 (3)


Text

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~ JUN 151988 W. John Arthur, III, Project Manager Uranium Mill Tailings Project Office Department 01 Energy Albuquerque Operations Office P.O. Box 5400 Albuqueique, New Mexico 87115 Dt.or Mr. Arthur:

At the request of Denise Bierley of your Technical Assistance Contrar. tor (TAC),

Mike Weber met with your staff ano contractors on May 26, 1988, to discuss use of alternate rencentration limits (ACLs) at the UMTRAP sites. Enclosed for your information is Mr. Weber's sunnary of his meeting with Hs. Bierley, Don Leske (DOE) and Larry Coons (TAL).

Should you have any questions regarding this sunmary, please contact Mike Weber at FTS 492-0565.

Sincerely, Paul H. Lohaus, Chief Operation:: Branch Division of Low. Level Waste ManagcLent and Decommissioning

Enclosure:

As stated cc: Don Leske, DOE /Alb DISTRIBUTION:

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SU*ARY MEETING NOTES Date:

May 26, 1988 Time:

8:15 11:45 a.m.

Location:

Room 589, White Flint North, Rockville, Maryland

Subject:

ALTERNATE CONCENTRATION LIMITS AT UMTRAP SITES

Purpose:

To respond to specific questions from the Department of Energy i

(DOE)anditscontractor(Jacobs-Weston)aboutimplementationof alternate concentration limits (ACLs) at Uranium Mill Tatlings RemedialActionProject(UMTRAP) sites.

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Participants:

Michael Weber, NRC/LLTB Don Leske. DOE /UMTRA Lynn Deering, NRC/LLTB Denise Bierley, Jacobs-Weston Larry Coons, Jacobs-Weston

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Suma ry:

NRC opened the meeting by sumarizing the status of the NRC staff's draft technical position on ACLs for uranium mill tailings sites and by providing DOE with infora tion about EPA's Integrated Risk Information System and an upcoming EPRI workshop on contaminant transport modeling. DOE stated that it would i

probably separate ACL applications from Remedial Action Plans (RAPS) to avoid delays in RAP preparation and concurrence.

NRC and 00E agreed that DOE could reference other documents that i

containinformationtosupportACLapplications(e.g.ferenc

RAPS, EISs,EAs). However, NRC consnented that extansive re may slow reviews.

DOE and NRC discussed the amounts and types of information that are likely to be necessary to demonstrate the acceptability of proposed ACLs at UMTRAP sites.

NRC emphasized the importance of site-specific characteristics in determining the amounts and j

types of information needed to demonstrate ACLs.

In comparison i

to existing DOE assessments of UMTRAP sites NRC stated that additianal information may be needed in the areas of leaching characteristics, effective porosity, contaminant transport characteristics (dispersioncoefficients, distribution I

coefficients), water uses (both existing and possible),

transport assessment, and risk assessment.

i NRC also stated that the following information contained in existing UMTRAP assessments should generally be adequate to justify ACLs:

i groundwater flow directions, hydraulic gradients, i

hydrostratigraphy, hydraulic conductivity, physiography, climate, and surface water characteristics.

Specific information needs should be assessed by DOE once it formulates site-specific strategies to justify ACLs.

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DOE and NRC also discussed application of supplemental standards at UMTRAP sites under proposed portions of Subpart C of 40 CFR Part 192. NRC stated that NRC staff does not intend to develop additional guidance about supp hoental standards and institutional controls.

In addition, NRC commented that applications for supplemental standards may be more extensive than ACL applications because DOE would need to (1) justify why the primary standards should not be applied, (2) select and justify appropriate supplemental standards, (3) select appropriate remedial actions to comply with the supplemental J

standards,(4)demonstratethatDOEcomesascloseasreasonable j

under the circumstances to meeting the primary standards, and (5) demonstrate that DOE's actions are adequate to protect human health and the environment. NRC stated that items (4) and (5) would probably be similar to ACL applications in their form and content.

Action items: DOE (Leske) will inquire as to whether DOE intends to coseent on NRC's draft technical position on cospliance with the proposed groundwater protection requirements of 40 CFR Part 192, J

Subparts A-C.

Contact:

Michael Weber, LLTB, x20565 J