ML20197B905
| ML20197B905 | |
| Person / Time | |
|---|---|
| Issue date: | 10/14/1986 |
| From: | Rich Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hazle A COLORADO, STATE OF |
| References | |
| NUDOCS 8610310026 | |
| Download: ML20197B905 (4) | |
Text
DISTRIBUTION Docket File WM-193
'PDR/DCS-DBangart, RIV WM-193/CCJ/86/10/06/0 RDoda, RIV s PGarcia EHawkins 00T 141986 HPettengill LLW Branch, WMLU URF0 r/f URF0:CCJ Docket File WM-193 040WM193120S Albert J. Hazle, Director Radiation Control Division Department of Health 4210 E. lith Avenue, Room 355 7
J' Denver, Colorado 80220
Dear Mr. Hazle:
The staff of the USNRC Uranium Recovery Field Office (URF0) has reviewed O
your specific responses dated September 17 and September 18, 1986 to our letter to you dated August 26, 1986 regarding our review of Section 4 of a previous draft Uravan Remedial Action Plan (RAP) dated July 30, 1986.
Your responses adequately address the issues raised in our August 26th letter.
C Additionally, per your telephone call on October 6,1986, you indicated a need for an " acceptance" type of review of the entire Uravan RAP.
In order to initiate this assistance, you agreed to provide to the URF0 a current version of the Uravan RAP and Colorado's staff analysis of the -
entire RAP as it relates to the requirements of 10 CFR Part 40 and 40 CFR Part 192.
Both of the above described documents were delivered to URF0 on October 7, 1986.
We have completed our initial review at this time. This review focuses on completeness of.the plan (that is, were all pertinent parts of a plan-C addressed), the appropriateness of the criteria used to meet the prescribed standards and looking for " fatal flaws" (that is, errors or omissions of significance to cast doubt on the overall plan).
Accordingly, this review is not a full detailed, independent analysis.
In; general, we are able to conclude the proposed remedial action appears to utilize design criteria which would enable it to meet the pertinent Federal regulations.
However, to allow a reader to clearly understand what State or Federal standards were used in designing the proposed remedial action, we would recommend the addition of a concise section (two or three pages) which specifies the standards used in the design and l
1 l OFC :
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DATE :86/10/09 8610310026 861014 d
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.5 OCT 141986 how the design meets those standards. We wish to emphasize that the level of detail presented in the RAP is not adequate to enable us to conclude that the specific design proposed would meet the Federal standards.
We would plan to complete a detailed review at a later date, given appropriate time and the necessary level of detail.
Specific comments noted during the course of our initial review are given for your consideration, and are attached.
Please feel free to call if you have any questions concerning our comments.
Sincerely, S
R. Dale Smith, Director Uranium Recovery Field Office Region IV
Attachment:
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Enclosure STAFF COMMENTS i
URAVAN RAP Non-Proliferation of Sites 1.
It is not clear what the rationale is for establishing an additional byproduct disposal site by disposing of raffinate crystals from the Club Ranch ponds and Club Mesa Spray area.in the Burbank Quarry.;
Surface Water Hydrolony and Erosion Protection
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1.
The criteria used to determine the PMP and resulting PMF are not provided. However, the runoff-rainfall ratio, the depth of runoff, and the PMF peak flow all appear to be unconservatively low. The g#
PMF should be determined using PMP and' rainfall distribution values from NOAA's "Hydrometeorological Report No. 49."
2.
Riprap thicknesses and median sizes are given, but no information e
is provided regarding how the riprap layers were designed.
In C
addition, Figure 4.4.2.2-1 shows that riprap will be placed directly on trie embankment.
Information should be provided to demonstrate that the gradations of the riprap layers and the underlying soils are such that a filter blanket is not necessary; otherwise, the design would have to be modified to include a filter blanket graded to prevent migration of the underlying soils into the riprap. Finally, information should be provided regarding durability criteria to be used for the rock as well as procedures to be used to oversize the rock if the durability specifications cannot be met.
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3.
Runoff from the top of the pile, the face of the embankment, and contributing drainage areas will discharge into diversion channels.
Typical sections and dimensions for the channels are provided, but i
no information is provided regarding criteria and methods used to design the channels. The information needed includes design discharges, channel water depths, water velocities, and roughness coefficients.
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2 Radon Attenuation 1.
The thickness and general composition of the soil layers to be placed over the pile are provided, but no information is provided regarding how the soil cover was designed.
Although previous correspondence from the State of Colorado to the NRC states that a design standard "better than 20 pCi/m /sec" was used to determine the cover thickness, no information is provided regarding specifics of the design.
This information should include emanating coefficients, long-term moisture contents, source terms used in the calculations and the bases for the values utilized.
Site Cleanup 1.
It is stated on p. 167 that " materials found to be uncontaminated may be disposed on the tailings piles or elsewhere..."
Contamination levels which define " uncontaminated" materials should be specified.
Geology and Seismology 1.
The design earthquake used in evaluating the potential for seismic u
disturbance of the reclaimed pile was determined in a 1978 Dames &
Moore report.
NRC review criteria utilize the methodology presented in the 1982 Lawrence Livermore National Laboratory publication
" Assessments of Active Faults for Maximum Credible Earthquakes of the Southern California - Northern Baja Region," for determining the design earthquake. A comparison of the design earthquake as determined in the Dames & Moore report with the earthquake calculated using the NRC-endorsed methodology should be provided.
2.
Information provided indicates that old mine workings are present 20 to 30 feet below the ground surface on the southeast portion of the site. The specific location of the reclaimed pile or associated features with respect to the mine workings, however, is not clear.
An evaluation should be made of the potential for subsidence to affect the integrity of the reclaimed pile.
Ground-Water 1.
A proposed ground-water restoration plan based on geohydrologic features of the tailings area, including the potential for seepage migration into fractures, should be provided.
In addition a geohydrologic investigation of the river ponds area is required to enable a conclusion to be reached regarding the need for ground-water restoration measures.