ML20198D038

Informs That DOE Draft Policy Statement on Technical Approach to Proposed EPA Groundwater Standards, for U Mill Tailings Remedial Action Project,Reviewed Per Request

ML20198D038
Person / Time
Issue date:	03/03/1988
From:	Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Arthur W ENERGY, DEPT. OF
References
REF-WM-39, TASK-TF, TASK-URFO NUDOCS 9801080118
Download: ML20198D038 (1)

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W. John Arthur, Project Manager e

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Dear Mr. Arthur In response to your request, we have reviewed the DOE draft " Policy Statemen't i

on the Technical Approach to the Proposed EPA Groundwater Standards" (January i

'28,1988). for the Uranium Mill Tailings Remedial Action Project. Based on our review, we support DOE's intentions to revise its Technical Approach Document te incorporate provisions necessary to implement EPA's proposed groundwater protection standards in Subparts A-C of 40 CFR Part 192.

However we conclude l

thatDOE'spolicystatementisnotconsistentwithSection108(a)3)ofUMTRCA which requires implementation of the proposed standards (Ref: Letter from M.R.

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Knapp to W. J, Arthur dated February 9, 1988). The present version of the DOE policy statement does not describe an approach which will demonstrate i

compliance with EPA's proposed groundwater protection standards.

As we indicated during the meetings with you and your staff on February 10-11, 1988, NRC staff is developing a staff paper on the infomation needed to demonstrate compliance with EPA's proposed groundwater standards. We suggest that this document be used to assist in making modifications to your policy statement, rather than our )roviding detailed comments on the policy statement at this time. ' A draft of tie guidance should be available for your infomation in several weeks.

Further discussion between our staffs are planned in the near future and would also be useful after you have received and reviewed the draft paper.

Shouldyouhaveanyq)uestionsregardingthismatter,pleasecontactmeorDan Gillen(FTS 492-0517 of my staff.

Paul H. Lohaus, Chief Operations Branch

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