ML20202E401

SRP for Umtrap Remedial Actions Plans,Cahpter 4:Water Resources Protection

ML20202E401
Person / Time
Issue date:	09/20/1985
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20198B646	List: ML20198B641 ML20202E401
References
REF-WM-39, TASK-TF, TASK-URFO PROC-850920, NUDOCS 9802180136
Download: ML20202E401 (49)

Text

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STANDARD REVIEW PLAN FOR UMTRAP REMEDIAL ACTIONS PLANS

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CHAPTER 4:--WATER RESOURCES PROTECTION i

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September 20, 1985 GE0 TECHNICAL BRANCH OIVISION OF WASTE MANAGEMENT-

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TABLE OF CONTENTS SECTION PAGE 4.1 :Areasiof' Review 1--

4.2: Acceptance Criteria-- 3

, 4.2.1 Regulatory. Basis 3 4

L 4.2.2 Specific Criteria 3 4.2.2.1 Site Characterization 4

()-' 4.2.2;2 Imp'.-ts of Water Contamination 7 4.2.2.3 Need.for Protective Actions 8 4.2.2.4: Implementation of Protective Actions 9 4.3 Review Procedures 9

4.3.1-- General-9 4.3.2 Site Characterization 9 4.3.3- Impacts of Water Contamination- 11 4.3.4 Need for Protective Actions- 14 4 4.3.5 Implementation of Protective Actions 17

~4.4 Evaluation-Findings 19

- 4.5 -References' 20 6 v I

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Chapter 4 WATER RESOURCES PROTECTION 4.1 Areas of Review Based on-guidance from the Environmental Protection Agency (EPA) in Subpart C of 40 CFR Part 192, the NRC staff has developed a systematic approach to review assessments of the need for and implementation of protective actions for water resources at designated VMTRAP sites.- This review approach is illustrated in Figure 4.1. As components of this approach, the NRC staff has identified four fundamental elements of its review of Remedial Action Plans to verify and concur with the selection and perfomance of protective actions for water resources, including:

(1)- Review of the characterization of processing and disposal sites:

Processing and disposal sites should be characterized to determine the -

-O aeed for Protective actioas and evaivate the imaiementatioa of such actions for water resources. Site characterization includes (1) chcracterization of the inactive uranium processing facility. (2) characterization of human activities and natural processes in the vicinity of sites relevant to the- protection of water resources, and (3) characterization of the hydrogeologic system at the processing and disposal sites.

(2) -Review of potential ;mpacts as'oeiated with water contamination:

Based on the characterization of processing and disposal sites, assessments of existing and potential impacts of water contamination should provide cuantitative and qualitative estimates of the consequences of human and environmental exposure to existing and potential water contamination. These assessments consider economic, aesthetic, and social f

impacts, in addition to adverse effects of contamination on environmental A populations.

V (3) Review of the need for protective actions for water resources; Analyses of the need for protective actions should consider the probabilities of. occurrence of identified adverse impacts potentially caused by water contamination. These probabilities are based on considerations such as present and anticipated water uses in the vicinity M processing and disposal sites; relevant Federal, State and local water quality standards for beneficial uses of water near - the sites; and availability of al ternative water supplies to replace or supplement contaminated water resources.

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Site Characterization Evaluation of Potential Irnpacts of Water Contarnination o

Analysis of Need for No Need Protective - Actions 6 "

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End Analysis of Irnplementation No Action of Protective Actions m End Define Actions to Protect Water ir End Figure 4.1. Systematic Approacts for Reviewing the Selection of Protective Actions for Water Resources at UMTRAP Sites.

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4 9/17/85 4-3 9/17/85 (4) Review of potential implementation of protective actions:

The review of proposed implementation of protective actions considers such factors as the technical feasibility of the actions, value of I potentially-contaminated water resources, benefits and costs of the actions, and compliance with relevant Federal, State, and local laws for water protection. The review determines whether protective actions for water resources have been appropriately selected and implemented. l a.2 , Acceptance Criieria 4.2.1 Regulatory Basis EPA issued standards for remedial actions at inactive uranium processing sites (Subparts A and B of 40 CFR Part 192) pursuant to Section 275 of the Atomic Energy Act (42 U.S.C. 2022). Data available to EPA when the. standards were promulgated supported the decision not to issue general numerical water protection standards. As an alternative, EPA identified factors for fq considera tio.: by implementing agencies (00E and NRC) in deciding whether a Q site-specific water contamination problem exists and, if so, what remedial action is appropriate. Under Subpart C of 40 CFR Part 192 EPA provided that judgements on the possible need for remedial actions should be guided by relevant state and federal water quality criteria for existing and anticipated l*

uses of water hazardous resources waste disposal. and relevant considerations from EPA's standards for Consistent with an optimized cost-benefit approach, i

EPA also provided that remedial action decisions should consider the costs and benefits of the remedial measures, includinn the extent and utility of the aquifer, the availability of altarnative sources of water, and the potential l for human exposure.

l The NRC must find with reasonable assurance that Subparts A and B of 40 CFR Part 192 will be satisfied prior to concurring with DOE's Remedial Action Plans. Because EPA intended that protection of water be considered in the analysis for reasonable assurance of compliance with the provisions of 40 CFR

- Part 192 and because the DOE-NRC Memorandum of Understanding defines the EPA O standards to include requirements for analysis and implementation of water V protection measures as needed, the NRC staff has adopted EPA's approach in Subpart C of 192 as a mechanism to review DOE's Remedial Action Plans with respect to the protection of water resources. Prior to recommending concurrence with DOE's proposed remedial actions, NRC staff must conclude that 00E selected and implemented protective actions for water resou ces in a logical, systematic, and defensible manner consistent with EPA's guidance in Subpart C of 40 CFR Part 192.

4.2.2 Specific Criteria The water resources assessments should provide or reference sufficient infomation to allow the NRC, as an independent reviewing agency, to verify the assessments and to reach comparable, but not necessarily identical, conclusions. Information submitted to support the selection of protective actions must be of sufficiently high quality so as to be verifiable and A_

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representative of site conditions. Table 4.1 summarizes the types of information that are typically considered -in the staff's review of the i selection and implementation of protective actions for water resources. The following sections describe rpecific criteria for soch e rtiw element.

4.2.2.1 Review Element I: Site Characterization Site characterization includes three principal components: facility characterization, vicinity characterization, and hydrogeologic characterization. Information from these component evaluat4ons should be integrated into conceptual and analytical models of the hydrogeologic systems at processing and disposal sites.

4.2.2.1.1 Facility Characterization Characterization of the inactive uranium processing facility- will aid in evaluating existing- and potential water contamination associated with the facility. Facilit characterization is acceptable if it includes such information as (1) ythe description of the uranium recovery process at the O faciiitx. (2) a descriat4ea aad relative ava#tificatioa of rea9ents useo ia the milling process, and-(3) a description of waste management practices (e.g.,

location of waste discharges, retaining structures for wastes, relative amounts of wastes, and history of waste discharges). This infomation should be considered in the characterization of contaminant source terms, opetational effects of the facility on the hydrogeologic system, and background water quality.

4.2.2.1.2 Vicinity Characterization At some sites, human activiv.ies and natural processes may_ significantly affect the hydrogeologic system, thus influencing the selection of protective actions for - water resources. Human activities and natural processes such as crop irrigation, mine dewatering, ore s torage, municipal waste landfilling, geothermal springs, natural concentration of soluble salts by evaporation, and surface water recharge should be considered in selecting and implementing Q

D protective actions for. water resources at UMTRAP sites. Vicinity characterization is acceptable if it demonstrates the significance of vicinity

" activities and processes to the selection of protective actions.

4.2.2.1.3_ Hydrogeologic Characterization Hydrogeologic characterization -includes (1) determination of background water quality, (2) determination of rate (s) and direction (s) of contaminated water migration, and (3) determination of the extent of water contamination.

Background water quality is defined as the quality of water that would be expected at a site if contamination had not occurred from the designated facility. The scope of the determination of background water quality should be commensurate with the anticipated magnitude of potential impacts caused by water contamination associated with processing and disposal sites. This determination should include the following types of information, as applicable:

i TABLE 4.1. NOMINAL INFORMATION NEEDS - WATER RESOURCES PROTECTION

1. SITE CHARACTER 12AT10N 1.1. Facility Characterization

• Description of uranium recovery process

• Relative cuantification of process reagents

• Description of waste manageme'nt practices 1.2. Vicinity Characterization

• Description of local human activities that may significantly

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affect the hydrogeologic system

• Description of local natural processes that may significantly affect the hydrogeologic system 1.3. Hydrogeologic Characterization

• Conceptual models of the hydrogeologic system

• Groundwater-Surface Water interrelationships

• Characterization and raonitoring practices and procedures

• Topographic data l

• Climatic data (precipitation, potential evaporation, temperature)

• Geologic data (stratigraphy, structural geology, lithology and mineralogy, geomorphology) l

• Surface hydrogologic data (location, volume, flow rate, channel morphology, current patterns, bed and suspended load fractions, i

t uses, hydrographic modifications) p

• Subsurface hydrologic data (areal extent of aquifers, recharge-

'd discharge relationships, geometries of hydrogeologic units.

hydraulic head distributions and temporal variation, hydraulic properties, historical trends of hydraulic heads, uses, flow rates and directions, travel times)

• Background water quality

• Concentrations of major, minor, and trace constituents, especially those constituents that exceed background concentrations and/or state and federal water quality criteria

• Contaminant transport data (dispersion coefficients, attenuative properties, e#fective porosity, solubility)

TABLE 4.1. *ontinued)

2. IMPACT'A iSSMENT 2.1. Exposure Pathway Assessment

• Existing and predicted distributions of contaminants

• Identification of exposed. populations

• Identification of exposure pathways 2,2. Human Exposure Assessment

• Characteristics of exposed oopulations

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• Appropriate exposure limits or dose-reponse relationships

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• Classification of water resources

• Projected adverse effects of potential contamination r

2.3. Environmental Exposure Assessment

• Characteristics'of exposed populations

• Appropriate exposure limits- or. dose-response relationships

• Independent changes in populations

• Projected adverse effects of potential contamination 2.4 Aesthetic, Economic, and Social Impact Assessment

• Characterization of adverse aesthetic impacts

• Characterization of adverse economic impacts

• Characterization of adverse social impacts

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v 3. -ANALYSIS OF NEED FOR PROTECTIVE ACTIONS 3.1. Probability of Impact Occurrence

• Water use characteristics

• Relevant water quality standards and guidelines

• Classification of groundwater resources based on EPA's Groundwater Protection Strategy

• Availability and characteristics of alternative water supplies

• Institutional controls on water use 3.2. Identification of Needs for Protective Actions

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TACLE 4.1. (Continued)

4. ANALYSIS OF.IMPLEMENTATIOP OF; PROTECTIVE ACTIONS 4.1. _0ptimized Designs of_ Protective Actions 4.2. - Estimated Value of Potentially Affected Water Resources

-4.3. identification, Evaluation, and Comparison'of benefits and-costs 4.4 -Relevant Laws and Regulations for_ Water Protection

- 4.5. - Identification of . Protective Actions for Implementation -

4.6. Engineerino Designs and-Supporting Calculations for Protective .

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(1) maps of sufficient detail showing the location of background monitoring locations; (2) characteristics of background monitoring devices including wells, springs, community water supply sources, suction saulers and other sampling devices; (3) distribution of wastes at and near the site; (4) operational characteristics of the facility; (5) description of historical changes in hydraulic heads, flow directions, and flow rates relevant to the location of monitoring locations; (6) analytical water quality data for l uranium, selenium, molybdenum, arsenic, sulfate, nitrate, ammonia, radium-225, i major cations and anions, total dissolved solids, total organic carbon, total organic halogen (or organic pollutant screens), pH, and other constituents and parameters that may be necessary on a site-specific basis en determine background water quality and extent of water contamination; (7) 6.ssessments of observed variations in background water quality; (8) description of off-site sources of water contamination; and (9) protocols for sampling, analysis, preservation, transportation, and quality control of background water quality samples.

Acceptable characterization of water flow rates and directions should consider n advection of groundwater and surface water, as well as advection and dispersion V of contaminants from processing and disposal sites. The scope of the characterization should be commensurate with the anticipated magnitude of potential impacts caused by water contamination associated with processing and disposal sites, as well as the relative distance of user populations from existing and potential contamination associated with the sites.

Characterization of water flow rates and directions should following information, as appropriate: (1) maps of sufficient detail to show include the the relationships of the sites to major hydrogeologic systems that could affect j

' or be affected by the site; (2) descriptions of the relations of components of the hydrogeologic system (e.g., surface water-groundwater relationships);

(3) climatic characteristics, including precipitation, potential evapotranspirat4n, and temperature; (4) geologic characteristics, including

} stratigraphy, geomorphology, lithology, and structural geology (see Chapter 2--

Geotechnical Stability of the SRP); (5) surface water characteristics including location, volumes, flow rates, channel morphology, current patterns, bed and suspended load fractions, seasonal variations in flow rates, hydrographic C)

V modifications, and uses (see also Chapter 1--Surface water Hydrology and Erosion Protection of the SRP); (6) groundwater characteristics such as areal extent of aquifers, recharge-discharge relationships, geometries of hydrogeologic units, hydraulic head distributions and temporal variations, hydraulic properties of hydrogeologic units, historical trends in hydraulic head variation, uses, conceptual models of flow and transport, flow rates, travel times, and flow directions; and (7) contaminant transport characteristics, including attenuative capacity, dispersion coefficients, contaminants, and effective porosity.

Acceptable characterization of the extent of water contamination should include spatial representations of contaminants observed in groundwater and surface water above concentrations observed in water of background quality. The types and amounts of information for characterization of contamination should be comensurate with the anticipated magnitude of potential impacts of the water contamination and should include the following infomation, as appropriate: (1) the distribution and characteristics of wastes on-site, including wind blown

9/17/85 4-7 9/17/85 contamination areas, tailings piles, raffinate ponds, evaporation ponds, ore storage areas, rubbish heaps and oth9r sources of water contamination; (2) characteristics of the hydrogeologic system, as described above; (3) background water quality, . as described above; (a) identification of constituents that exist at concentratisns above background concentrations and are reasonably expected to have been discharged at processing sites; (5) concentrations and values of indicatory water aaality constituents and parameters, including pH, Specific Corductance, major ions, minor -ions, trace constituents, uranium '

(na tural ), radium-226/228, and thorium-230; (6) distributions of groundwater contaminants (i.e., maps and cross-sections showing constituent concentrations in three dimensions); and (7) monitoring protocol used to characterize water quality, including collection, preservation, transportation, analytical, and quality control procedures.

G 4.2.2.2 Review Element II: Impacts of Water Contamination Acceptable impact assessments should consist of four components: (1)

-ider,tification and characterization of exposure pathways, (2) a human exposure assessment, (3) an environmental exposure assessmen*, and (4) the O 4de#tificatio" of esthetic- soc 4 1 >#d ecoao 4c 4=nacts assoc 4 teo 4ta potential water contamination. The scope of the impact assessment will vary based on site-specific consideration of the nature of potential adverse impacts. Conclusions of one of the component assessments may reduce the scope of the other assessments. For example, a conclusion that no adverse impacts would result from environmental exposure to a particular constituent regardless of its concentration, within practical limits, may reduce the scope of other assessments of risk and exposure.

Impact assessments should begin with the identification and characterization of exposure pathways from contaminant sources to exposed environmental and human populations. The objective of the pathway assessment is to develop conservative exposure estimates based on reasonable projections of contaminant concentrations in groundwater and surface water. This assessment should consider anticipated future events that may significantly perturb exposure pathways and consider transfer of contaminants ' from aqueous media to other G environmental media on a site-specific basis. The exposure pathway assessment U snould include the following information, as appropriate: (1) transport characteristics of contaminants (e.g., sorption, speciation, biodegradation constants, bioaccumulation factors, plant up-take factors); (2) identification of degradation and decay products of the contaminants, including predicted concentrations if decay products are toxic; (3) duration of contaminant migration and statistical representation of the concentrations relevant to I duration of exposure and toxic characteristics of the contaminant (i.e.,

average daily concentration over lifetime for carcinogenic contaminants, mean daily concentration for acutely toxic contaminants, mean annual concentrations for chronically toxic contaminants); (4) temporal variability of contaminant concentrations; (5) spatial distribution of contaminants; (6) water and solid quality monitoring data characterizing existing concentrations used to validate predicted contaminant concentrations; (7) identification of exposure pathways for contaminants; and (8) classifications of affected water rescurces based on the classification scheme discussed under review procedures for Element II.

l 9/17/85 4-8 9/17/85 l Acceptable human exposure assessments should consist of a dose-response assessment of representative populations based on predicted contaminant concentrations, anticipated exposure pathways, and available toxicological and epidemiological . information. The exposure assessments should consider consumption of drinking water from contaminated water resources as the. primary pathway, and ingestion of contaminated food and dermal contact via bathing or recreation pathways as secondary pathways. The assessment should distinguish between the heal th impacts of toxic (threshold) and carcinocenic (non-threshold) contaminants. Other impacts, such as mutagenic, teratogenic, and synergistic impacts, should also be considered in the assessment if they are identified in available literature. The information accompanying human impact assessments should justify significant assumptions invoked in preparing the assessment, as well as assess the significance of uncertainties in the health assessment.

Analogous to the human assessment, acceptable environmental exposure assessments should consist of dose-response assessments of representative environmental populations based on predicted contaminant concentrations, anticipated exposure oathways, and available toxicological and epidemiological O iafor tioa for aavatic eae terrestri i wiioif fe. aia#ts. domesticateo ea4m 1=

(e.g., livestock),andcrops. These assessments should provide (1) inventories of potentially exposed non-human species of terrestrial -and aquatic wildlife.

-agricultural crops and animals, and plants. (2) recommended tolerance or exposure limits for exposed contaminants and populations.- (3)' interactions of contaminants and their cumulative effectc on exposed populations, and (4) anticipated changes in populations independent of exposure. ,

Additionally, the assessments should identify and describe the following impacts potentially caused by water contamination: (1) adverse economic impacts (e.g., increased maintenance costs, decreases in agricultural productivity, land value depreciation), (2) aesthet1c impacts (e.g., changes in water taste and appearance), and (3) social impacts (e.g., social disruption, inconvenience in locating and developing alternative water supplies).

3 4.2.2.3 Review Element III: Need for Protective Actions

'(O Acceptable analysis of the need for protective actions should evaluate the probabilities of occurrence of the impacts identified under Review Element II by considering such factors as existing and anticipated water uses, institutional controls on water use, relevant federal, state, and local water quality standards, and the availability and characteristics of alternative supplies of water. The kinds of infonnation that should be considered varies based on site-specific factors and the conclusions verified under Review Element II. The following information should generally be included, as appropriate: (1) description of impacts identified under Review Element II; (2) characteristics of existing water uses in the vicinity of processing and disposal sites (e.g. , locations, types, intended uses, rates of withdrawal /

injection, statutory and legal restraints on use, etc.); (3) relevant water quality standards and guidelines; (4) classifications of groundwater resources based on EPA's Groundwater Protection Strategy; and (5) availability and characteristics of alternative water resources and comparison of these resources to present water supplies.

9/17/85 4-9 9/17/85 4.2.2.4 Review Element IV: Implementation of Protective Actions if a' need for remedi31 actions to protect water water resources is identified under Review Element III, the review proceeds to evaluate the selection, implementatirin, and enCineering of the actions. Infomation included in an acceptable analysis of implementation of protective actions will vary based on site-specific considerations commensurate with the need defined under Review Element 111. The following information should generally be included, as appropriate: (1) evaluations of a representative range of alternative conceptual designs for protective actions; (2) discussion of characteristics and availability of alternative water supplies potentially needeo to supplement av. replace existing supplies; (3) estimation of the value of water resources to be protected; (4) identification, evaluation, and comparison of benefits and costr of protective actions; (5) federal, state,' and local icws and regulations relevant to water protection; and (6) selection of designs for protective actions. The protective action designs shoulo be accompanied by evaluations of their effectiveness in reducing environmental impacts.

4.3 Review procedure _ss 4.3.1 General The purpose of NRC staff's review of water resources assessments is to verify the selection cf protective actions, rather than duplicate the anessment effort. In conducting reviews of site characterization and selection, the NRC staff focuses its review on technical and procedural aspects supporting decisions about the need for and implementation of protective actions for water resources. As a part of the review, NRC staff may conduct literature surveys, data assessments, and performance evaluations as needed to audit the assessments and independently verify the selection of protective actions.

When preliininary reviews indicate that supporting information is ambiguous, incomplete, inadequate, or incorrect, the staff identifies issues accordingly through the comment process and may proceed independently to review the assessments. In general, the staff focuses its reviews on information that significantly affects the selection and performance of protective actions.

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V 4.3.2 Review Element I: Site Characterization NRC staff reviews the hydrogeologic characterization of sites to determine if the following three criteria have been satisfied:

(1) Has background water quality been adequately established?

(2) Have the rate (s) and direction (s) of contaminated water migration been adequately determined?

(3) Has the extent of water contamination associated with the designated uranium processing site been adequately characterized?

9/17/85 4-10 9/17/85 4.3.2.1- Background Water Quality The reviewer evaluates information relevant to the establishment of background water quality at processing and/or _ disposal sites including, but not limited to, conceptual and analytical hydrogeologic models, water quality data, facility characteristics, monitoring protocol, and vicinity characteristics.

Based on the adequacy of this information, the reviewer detemines whether the assessment reasonably characterizes the background quality of water resources L that may be contaminated by the site.

l The establishment of background water-quality may also be complicated at sites-where existing or potential water contamination may affect water quality in several aquifers or water bodies. The reviewer must determine whether the assessment establishes background water quality for each aquifer potentially l affected by contamination from the processing and disposal sites, and for 1 surface water bodies that receive discharge from aquifers or recharge aquifers potentially affected by the processing and disposal sites.

At sites where water samples representative of background quality cannot be g) collected (e.g., entire aquifer is contaminated by seepage of tailings

\ solutions), the reviewer evaluates (1) the justification for not characterizing L

' background water quality and (2) the assessment that proposes reasonably conservative estimates for appropriate water quality parameters. The reviewer evaluates site information and either confirms the determination of background water quality or determines that the estimates are not reasonably conservative.

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In the latter situation, the reviewer may propose reasonably conservative

' estimates of appropriate water quality parameters depending on- the adequacy of site characterization, availability and quality of appropriate data, and the anticipcted magnitude-of potential impacts associated with water contamination by processing and disposal sites.

4.3.2.2 Rate and Direction of Water Migration In reviewing the characterization - of the rate (s) and direction (s) of contaminated water migratica at processing and disposal sites. NRC staff (7 detemines whether these characterizations are adequate with respect to V relevancy, completeness, reliability, and accuracy of input to support assessments and conclusions regarding the impacts of water contamination, the need for protective actions, and potential implementation of protective actions. The scope of the staff review includes consideration of site-specific and regional (i.e., beyond the immediate zone of influence of the site) infomation on the physical and hydrogeological characteristics of groundwater and surface water systems. In support of this review, the reviewer detemines whether the hydrogeologic characterization techniques, methods, and approaches supporting the determination of water flow rates and directions constitute accepted and defensible hydrogeologic practices. The reviewer also evaluates anticipated and/or potential changes in flow rates and directions of contaminated water migration caused by reasonably foreseeable events, and considers historic changes in flow rates and directions that may have been caused by the processing facility or vicinity activities.

9/17/85 4-11 9/17/85 4.3.2.3 Extent of Contamination in reviewing the characterization of the extent of groundwater and surface water contamination, the reviewer evaluates, as appropriate, sito-specific j information on the physical, hydrological, and chemic31 characteristics of the uranium processing activities, vicinity activities and natural processes, and l the hydroceologic system affected or potentially affected by the site. The

reviewer determines whether this information adequately characterizes the extent of water contamination associated with uranium processing sites. The  !

reviewer confirms that charactstrization of the spatial distribution of l contaminants was conducted in accordance with accepted (sd defensible techniques, appenaches, and practices. The reviewer also veriffas the adequacy i of the characterization with respect to relevancy, completeness, reliability.

l and accuracy of input to the assessments of the impacts of the contaminated water, the need for water protection, and potential implementation of protective actions for water resources.

4.3.3 Review Element II: Impacts of Water Contamination The NRC staff reviews the impact assessment to detennine whether the assessment rJequately identifies and assesses adverse impacts associated with environmental exposure to existing or predicted water contamination. This

< review is divided into component reviews: review of exposure pathway l characterization, reviews of human and environmental exposure assessments, and l*

review of the aesthetic, economic, and social irpacts caused by contaminated f water m ources.

l l 4.3.3.1 Exposure Characterization

!t The reviewer deter *1nes whether the characterization of exposure pathways is adequate with respect to relevancy, completeness, reliability, and accuracy of inpu; to the assessments of human and environmental exposure. The scope of the exposure pathway characterization review includes (1) assersment of existing contaminant distributions (2) prediction of temporal and spatial distributions of contaminant concentrations in the environment, and (3) identification of C)v physical and biological pathways of contaminant migration via groundwater and surface water from the site to exposed populations.

In evaluating exposure characterization, the reviewer verifies the assesanent of existing w ter coatamination based on the spatial and temporal distribution of contaminant concentrations. The reviewer determines whether predicted concertrations are reasonable representations of the anticip. '.ed response of the hydrogeologic system in comparison with existing water vality data and other hydrogeologic infonnation verified under Review Element I. The reviewer verifies that sensitive human and environmental populations have been adeouately considered based on appropriate environmental surveys and available literature. The reviewer also dete, nines whether the assessment adequately chancterizes physical and biological exposure pathways.

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4.3.3.2 Human Exposure Assessment Based on the confirmed characterizations cf exposur pathways, the revit-wer verifies the assessment of the impacts of aater contamination on human health.

The scope of the human exposure assessment review includes (1) classification of affected water resources, (2) evaluation of the detrimental effects associated with human exposure to contaminants, and (3) evaluation of the assumptions and uncertainties associated with the impact assessment.

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' This review generally assumes that the most significant pathway for hetan exposure to waterborne contaminants is through consumption of drinking water, unless scoping assessments indicate that other exposure pathways (e.g., dermal contact, Sod ingestion) may be more important. Consistent with this assumption, the reviewer places each water resource into one of two categories:

potable resources whose value may be significantly degraded by contcmination (Class A) and resources which are not currently considered supplies of potable water (Class B). The staff considers water resourc'es as potable if the total dissolved solids (TDS) concentration does not exceed 3,000 mg/l in water f representative of background quality. Class B resources are defined as

) (o) aquifers and surface water bodies in which the total dissolved solids concentr6 tion equals or exceeds l 3,000 mg/l in water representative of l background quality.

For Class A resources, the reviewer will assume that humans withdraw water from affected aquifers and/or surface water bodies at any point beyond the site boundary in the direction that is hydraulically downgradient from existing contamination or stabilized tailings. This assumption applies unilaterally for Class A resources regardless of present or anticipated use of water resources that may be contaminated by the sites. For Class B resources, the reviewer evduates human health impacts with respect to the location (s) and purpose (s) of the nearest, downgradient, existing or anticipated water use. The staff considers that evaluation of human health impacts is not necessary at those sites where background TDS concentrations exceed 10,000 mg/l in local groundwater and surface water resources, unless such an evaluation is warranted 7 because of existing or anticipated water uses that reasonably could impact human health.

(V The reviewer detemines whether the assessments provide reasonable determinations of potential health impacts to existing and anticipated human individuals near the sites. This detemination is based on comparisons of existing and projected contaminant concentrations with appropriate exposure limits and dose-response relationships from available literature. Where applicable, federal and state drinking water criteria may be considered in lieu of recommended exposure limits and dose-response relationships. In the absence of sensitive human populations, the reviewer assumes each individual has a mass of 70 kilograms and consumes 2 liters of drinking water per day for evaluations of health impacts (cf. Till and Meyer,1983; National Research Council,1977).

The reviewer snsures that the asstssments consider all significant contarinants identified under Review Element I and that the assessments distinguish toxic effects from and carcinogenic non-thresholdi effects. The reviewer also ensures that the exposure asses (sments consider other adverse effects (e.g.,

mutagenic, teratogenic, and s/nergi . tic effects) as identified in available u

9/17/85 4-13 9/17/85 toxicological and epidemiological information. The reviewer confirms that the assessment employs realistic and reasonably conservative assumptions, discusses uncertainties inherent to the assessment, and estimates potential impacts of water contamination on human healt!

4.3.3.3 Environmental Exposure Assessment similar to the review of human health impacts, the reviewer verifies the l assessment of adverse impacts of water contamination on environmental l populations, including terrestrial and aquatic wildlife, plants, and agricultural crops and animals. The reviewer confirms that adverse impacts such as contamination induced biotic changes, loss or reduction of un%

habitats, and jeopardization of endangered or protected species are adequa identified and assessed. The reviewer also confirms that the impc .

I assessments are adequate with respect to relevancy, completeness, reliability,

) and accuracy of input to the assessments of the need for and implementation of protective acticas for water resources. Based on the exposure pathways and contaminant concentrations verified in the pathway characterization, the reviewe generally compares existing and predicted contaminant concentrations O with chronic toxicity levels for plants anc; animals. Bioaccumulation of contaminants and food web interactions may be considered based on available information.

In reviewing impacts of watcr contamination on aquitic life, the reviewer develops reason %1y conservative estimates of dilution potential of surface water bodies. The reviewer generally evaluates aquatic life exposure by comparing contaminant concentrations with relevant federal and state surface water quality criteria.

Review of agricultural impacts considers both direct and indirect exposure pathways, including "op impacts, reduced productivity, and bioaccumulation of contaminants. Sim.' to the review of aquatic impacts, the reviewer compares reasonably conset c .e estimates of existing or potential concentrations wi contaminant agricultural uses

'elevant federal and state water quality criteria for r constituents that are not considered in such criteria, the reviewer evaluates the assessment of agricultural impacts based on available information.

4.3.3.4 Social, Aesthetic, and Economic Impact Assessment The reviewer verifies that the assessment characterizes social, aesthetic, and economic impacts associated with existing or ootential water contamination. In this verification, the reviewer ensures thct significant hydrologic alterations affecting water quality have been identified and that their social, aesthetic, and economie: impacts have been reliably assessed considering the characteristics ::nd duration of the impact. The reviewer enwres that the characterization of these impacts is adequate with respect to relevancy, completeness, and accuracy for cost-benefit evaluations under Review Element IV.

9/17/85 4-14 9/17/85 The reviewer also confirms that water quantity impacts that may accompany water quality impacts have been adequately assessed. The reviewer ensures that those water users currently or potentially impacted by alterations in water quantity and availability have been identified. The reviewer ensures that the assessment considers possible inequalities between water use for remedial action and existing and known future water rights and allocations.

4.3.4 Review Element !!!: Need for prote_ctive Actions NRC staff reviews the analysis of the need for protective actions to determine whether this need has been adequately and objectively analyzed. Based on the environmental impacts verified under Review Element !!, the analysis of the need for protective actions should defensibly assess the probability of contaminant exposure to human and environmental populations by considering such factors as existing and anticipated local water use, existing and anticipated land use, and the distribution of environmental populations in the vicinity of sites. The analysis sh dd identify a need for protective actions when there is a reasonable probabii;.y of occurrence of signf ficant adverse impacts on n human or environmental populations.

V The scope of the staff review includes (1) consideration of the probabilities of adverse impacts of water contamination on domastic, municipal, agricultural, industrial, mining, and recreational uses of water resources; (2) consideration of the probabilities of adverse impacts on environmental (nonhuman) populations; (3) characterization of consumptive and non-consumptive water uses in the vicinity of sites; (4) characterization of adverse impacts on humans and the environment caused by alterations in water quantity and/or quality associated with protective actions at processing and disposal sites; (5) consideration of relevant federal, state, and local water quality standards; and (6) consideration of the availability and chari.:teristics of alternate water resources that may be necessary to replace or supplement contaminated water resources.

For each of the impacts identified under Revbw Element II, the reviewer ensures that the analysis conservatively estimates the probability of impact O occurreace-qualitative defensible such est4 ates are artea cir<4cuit to estauiish avaatitativeix so estimates may suffice in lieu of ouantitative "

determinations. Examples of such qualitative deteminations include reasonably -

likely (i.e., event has occurred in the past or available infonnation indicates the event will occur during the stabilization period), reasonably unlikely ,

(i.e., event has occurred in the past but will probably not occur during the period of stabilization because initial incentives for occurrence have been removed, or available infonnation indicates that no incentives for such occurrence are currently identifiable based on foreseeable technological developments), and uncertain (i.e., available information is insufficient to develop qualitative estimates of the probability of occurrence). .

The review of qualitative determinations of event probabilities considers l' existing and anticipated water uses and the comparison of background water quaiity with appropriate water quality criteria. In general, the reviewer limits consideration of water uses to existing and anticipated uses of wter resources that may be contaminated by the site. Existing use may include

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9/17/85 4-15 9/17/85 past use even though water resources are not presently being used. Anticipated water use includes only those uses that are reasonably sure to occur. At sites where water treatment is necessary prior to water use based on backgrou quality alone, the reviewer confirms that treatment would be effective m protecting exposed populations, in reviewing long-term water use, the reviewer considers aquifer classifications consistent with EPA's Ground Water Protection Strategy (ca.

August 1984) and clarifying guidance pursuant to the Strategy. The reviewer assumes that there is a need for protective actions to prevent or control I

contamination of Class I aquifers. The reviewer may consider unanticipated future uses of Class 11 aquifers, out such uses are not considered for Class

!!! aquifers unless they currently supply water for beneficial purposes.

The reviewer confims the assessment of existing and anticipated water use by comparing background water quality with relevant Federal, State, and local I

water quality standards. Appropriate watec quality standards are selected for comparison based on background water quality, existing and anticipated uses, and legal considerations. When stan<iards are inconsistent, the reviewer O assumes that local and state standards pn.empt federal standards. In addition to information provided in the analysis, the reviewer may use information from such organizations as local water supply companies or agencies, regional water commissions, state agencies, federal agencies, and local water users. Water quality standards relevant to water supplies for human consumption include the NIPDWR (National Interim Primary Drinking Water Regulations) and NSDWR (National Secondary Drinking Water Regulations) maximum contaminant levels in 40 CFR Part 141 and 143, as well as relevant state and local water ouality standards developed under federal or state statutes (e.g., Safe Drinking Water Act). For water resources whose background concentrations exceed the limits provided in the above standards, other water quality standards appropriate for the intended use are considered as relevant criteria. Table 4.2 provides federal water quality criteria that are considered in conjunction with relevant state and local standards. In addition, the reviewer considers water use based on demography of the site vicinity, demographic projections, zoning patterns, and average and maximum projected estimates of population growth.

O At sites where institutional controls may preclude existing and future water uses, the reviewer verifies that-these controls will prevent exposure of human and environmental populations to contaminants and that the controls encompass water contamination water that may cause significant adverse impacts. Tht reviewer confirms that restrictions are accompanied by provisions for monitoring programs sufficient to determine the temination of water contamination huards and that a durable local or state administrative agency has sufficient authority to enforce +.he water use restriction.

If the analysis concludes that there is no need for protective actions and the reviewer verifies this conclusion, then the revie.: teminates with a confirmation that there is no need for protective actions for water resources from existing disposal site(and s). potential contamination However, if protective associated actions with the proce ssing or are selected for implementation, the reviewer proceeds under Review Element IV.

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TABLE 4.2. WATER QUALITY CRITERIA FOR DOMESTIC AND AGRICUL10RAL USES MAXIMUM O!SSOLVED CONCENTRATION LIMIT (mg/1)

DOMESTIC AGRICULTURAL CONSTITUENT USE* USE' Ammonia (asN) 0.05(R) ---

Arsenic 0.05(P) 0.2(L);0.10to2(1) l- Barium 1(P) ---

I Cadmium 0.010(P) 0.05(L)1 0.01 to 0.05(i)

Chloride 250(S) ---

Chromium 0.05(P) 1.0(L)10.1to1.0(!)

'O ceaa r 1(S) 0.5(L) 0.2 ea 5.0(>>

1ron 0.3(S)

Lead 5.0 to 20.0(I)

Manganese 0.05(P) 0.1(L); 5.0 to 10.0(I) 0.05(S) 0.2 to 10(!)

Molybdenum Nickel 0.01 to 0.05(!)

Nitrate (as N) 0.20to2.0(!)

10(P) '100(L)

Selenium 0.01(P) U.05(L);0.02(1) sulfate 250(S) ---

Yanadium ---

0.1(L); 0.10 to 1.0(1)

Zinc 5(S) 25(L); 2.0 to 10.0(!)

-Combined Radium-226 and Radium.228 (pCi/1) 5(P) ---

'-( *NIPOWR and NS0WR standards in 40 CFR Parts 141 and 143; Primary (P) required limits and Secondary (S) recommended limits for public water systems.

Reconnended limit (R) 1Jr ammonia in drinking water is from National Academy

. of Science.

• Water Quality criteria,1972." EPA-R3/73-033,1973.

" Based on National Academy of Science, " Water Qualit EPA-R3/73-033, 1973; recommended limits for Livestock (L)y Criteria 1972 "andIrrigationft) uses.

9/17/85 4-17 g/17/85 1

4.3.5 Review Element IV: Implementation of Protective Actions Based on the needs for protective actions identified under Review Element !!!,

the reviewer verifies the selection and optimization of a reasonable range of alternative protective actions. The reviewer confirms that the actions selected have been designed to optimize their effectiveness in satisfying the needs for protective actions. The reviewer determines that optimization calculations provide representative approximations of the perfomance of the affected hydrogeologic system. The reviewer also ensures that the suite of optimized protective actions represents a range of feasible alternatives.

After review of the seier. tion of alternative protective actions, the reviewer verifies the assessment of the technical feasibility of implementing these actions. Reviews of the technical feasibility of protective actions vary based I on site-specific considerations, such as the characteri, tics of the affected  !

hydrogeologic system, the characteristics of the contamination problem, and the needs to protect human and environmental populations from water contamination.

The reviewer verifies the assessment based on hydrogeologic information l O evaluated under Peview Element I and the optimization calculations discussed  !

'd above.

The reviewer determines whether alternative water supplies would be adequate to replace contr31nated supplies considering the availability and characteristics (e.g., capital and operational costs, suppliable rates, quality) of alternative supplies. The absence of alternative water supplies on a local or regional scale increases the significance of potential contamination of existing supplies, as well as' the potential value of the existing water resources.

The reviewer verifies estimates of the current and projected value of water resources by first confirming that potentially contaminated resources have been identified 'and valued in the analysis. The reviewer confims that the estimates are reliable based on infomation such as appropriated rights to water resources, costs of bottled water, availability of alternative water supplies, and projected water demands. The reviewer generally considers the n value of potentially affected water resources to be equal to the product of the C; safe yield of the potentially affected resource and the unit cost of supplied water depending on its intended purpose (e.g. , cost of potable water for drinking water supplies) or the cost of supplied water required to replace the resource.

The reviewe' confims that the perfomance of remedial actiors under Title I of UMTRCA complies with relevant federal, state, and local regulations and statutes. A commitment in the analysis to comply with these provisions satisfies the reviewer's r2sponsibilities, unless the reviewer is aware of other regulations that have not been specifically identified. In this case, omitted regulations will be idertified through the commenting process.

Authority for detemining compliance with all such regulations and statutes resides with the agency or administrative body charged with implementing these regulatory programs (e.g., the Environmental Protection Agency for NPDES pemitting).

l 9/;7/85 4-18 g/17/85  !

The reviewer confirms that the direct and indirect benefits of protective 9ctions have been objectively compared with the costs of such actions.

Adequacy of the cost benefit assessment will be determined based on completeness of cost and benefit considerations such as capital costs for implementation, operation and maintenance costs for continued operation, and depreciation and c"scount modifications to projected costs, as well as benefits such as avoidance of health effects, prevention of land value depreciation, benefits accruing directly from the perfomance of protective action, and other benefits realized by avoiding the impacts identified under Review Element !!.

The reviewer determines whether protective actions selected for implementation have been designed to satisfy the needs identified under Review Element III.

The scope of the review varies based on the selection of protective actions, characteristics of the affected hydrogeologic system, and needs for protective actions. For example, the review of a proposed slurry wall would include confirmation of the design with respect to compatibility of the slurry wall with anticipated geochemical conditions, barrier wall composition and mixture ratios, design specifications, methods of detemining the effectiveness of the slurry wall, method of trench excavation and sall construction, contact with O eda ceat coafiaias deds. aver uiic aronerties ad 9eocaemic 1 ch racteristics.

and projected changes in-the hydrogeologic system caused by wall construction. -

For an aquifer restoration program, the reviewer would confirm such design aspects as the characteristics of contaminated water treatment, installation and construction of withdrawal and injection wells, projected perfomance of the restoration system, pumping rates and locations, disposal source for treatment wastes (both solid and liquid), characteristics of treatment wastes, methods of detemining system effectiveness, and duration of system operation.

The' reviewer confirms that the selected protective actions cari achieve pr3ctical levels of mitigation and control, including confirmation that'(1) the actions are reasonable (i.e., the actions are appropriate and achievable on a +

site-specific basis), and (2) the actions are specific, clearly documented, and designed such that their implementatien and the results of their implementation '

can be verified through subsequent field observations.

P d When adverse impacts are identified for which no protective actions have been selected, the reviewer verifies that there are no actions that should be further considered in the Remedial - Action Plan. If appropriate protective <

actions can be practically implee"ted to protect water resources, but have not been considered, the revi(wer cecommends that such actions be considered

-prior to concurrence with the Remedial Action Plan.

If, after dt.e consideration of the factors listed under this review element, the assessment corcludes that protective actions for water resources are not appropriate under Title I of UMTRCA, the reviewer concurs or indicates deficiencies with this conclusion. The reviewer must confirm that protective ,

actions selected for implementation are reasonable, that with effective -

implementation the actions have a reasonable probability of achieving their stated objectives, and that the actions have been accurately documented in the Remedial Action Plan for designated uranium processing sites.

9/17/85 4-19 9/17/85

4.4 Evaluation Findings

if the hydrogeologic assessments satisfy the review criteria and procedures under each of the four review elem0nts in this plan, the reviewer concludes that the assessment provides reasonable assurance of compliance with the EPA standards for protection of water resources. Based on this conclusion, the reviewer recommends that NRC concur with the Remedial Action Plan with respect to water resources protection. However, if the reviewer concludes that the review elements have not been satisfied, then the reviewer documents the inadequacies of the assessment in coments that identify the inadequacies of the as.essment, soecify the technical basis for the coments, and describe alternative approaches to resolve the inadequacies.

After the review, the reviewer documents his/her conclusions and the bases for these conclusions in the form of a Technical Evaluation Memorandum (TEM).

Consistent with the four review elements in this plan, the reviewer documents the following conclusions in the TEM before recommending complete concurrence with a Remedial Action Plan:

O (2) aroc >4a9 ad disao i sit > aav 6 a d au t ix c* ract r41 d.

including characterization of the uranium processing facility, vicinity activities and processes, background water quality, rate and direction of contaminated water flow, and extent of existing water contamination; (2) Human health and environmental impacts potentially caused by water contamination have been adequately identified and characterized; (3) The Med for " protective actions for . water resources has been adequately identified and assessed; and (4) Potential implementation of protective actions for water resources has been adequate 1; evaluated and the : protective actions selected for implementation have been appropriately described in the Remedial Action Plan.

O V

Based on these four conclusions, the reviewer concludes the Water Resources Protection TEM with a statement that the proposed remedial actions comply with reasonable assurance with the EPA standards in 40 CFR Part 192. In' addition to this conclusion, the ' TEM will identify aspects of the review that were emphasized, deviations of the review from the review criteria and procedures detailed in this plan, justifications for these deviations, and any unresolved issues that require confirmatory assessments at the conclusion of the water resources review.

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I 9/17/85 4-20 9/17/85 4.5 References This section lists references that .are typically used by the reviewer in reviewing the preposed-actions for water resources protection. .

i Bear, J. 1979. Hydraulics of Groundwater. New York, New York: McGraw-Hill  ;

International Book company. 567 p. '

Canter, L. W., and Knox,- R. C.- 1985. Ground Water Pollutio., Control. '

Chelsea Michigan: Lewis Publishers, Inc. 526 p.

Freeze, R. A. , and Cherry, J. A. 1979. Groundwater. Englewood Clifts, New Jersey: Prentice-Hall, Inc. 604 p.

Korte, N. , and Ealey, D. 1983. Procedures for Field Chemical Analysis of l

Water Samplet Grand Junction, Colorado: Bendix Field Engineering Corporation, GJ/TM-07. 48 o. .

.O Korte, N. , and Kearl, P. 1984. Procedures for the Collection and Preservation V of- Groundwater and Surface Water Samples and for the Installation of

• Monitoring Wells. -Grand Junction, Colorado: Bendix Field Engineering Corporatius, GJ/TC-08, 58 p.

Krauskopf, K. B. 1979. Introduction to Geochemistry. New York, New York:

Meiraw-Hill r Book Company. 617 p.

Lohman,. -S. W. 1972. Ground-Water Hydraulics. U. 3. Geological Survey, ,

Professional Paper 708. 70 p.

Mercer, J. W., Jhumas, S. D., and Ross,.C. 1982. Parameters and Variables Appearing in Repository Siting Models. U. S. Nuclear Regulatory

' Commission, NUREG/CR-3066. 244 p.

Merritt, R. C. :1971. 'The Extractive Metallurgy of Uranium. Golden, Colorado:

Colorado School of Mines Research Institute. 576 p.

Montet, G. 1.. , and- Benioff, P. A. (Eds.). 1979. Descriotions of United States Uranium - Resource Areas. U. S. Nuclear Regulatory Comission, NUREG/CR-0597.

Morrison, R. D. 1983. Ground Water Monitoring Technology. Prairie du Sac, Wisconsin: Timco Manufacturing, Inc. 111 p.

National Academy of Sciences. 1972. Water Quality Criteria, 1972. U. S.

Environmental Protection Agency, EPA R3/73-033. 594 p.

National -Research Council. 1977. Drinking Water and Health, Volume 1.

Washington, District of Columbia: National Academy Press. 939 p.

National -Research Council. 1983. Drinking Water and Health, Volume S.  ;

Washington, District of Columbia: National Academy Press. 157 p.

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9/17/85 4-21 9/17/95 Rogoshewksi. P., Bryson, H., and Wagner, K. 1983. Remedial Action Technology for Waste Disposal Sites. Park Ridge, New Jersey: Noyes Data Corporation. 496 p.

Scalf, M. R., McNabb, J. F., Dunlap W. J., Cosby, R. L., and Fryberger, J.

-1981. Manual of Ground-Water Sampling Procedures. Worthington, Ohio:

National Water Well Association. 93 p.

Stallman, R. W. 1976. Aquifer-Test Design, Observation, and Data Analysis.

U. S. Geological Survey, Techniques of Water Resources Investigations, Scok 3. Chapter 81. 26 p. .

Stumm, W., and Morgan, J. J. 1981. Aquatic Chemistry. New York, New York:

John Wiley and Sons, Inc. 780 p.

Till, J. E. , and Meyer, H. R. (Eds.). 1983. Radiological Assessment. U. S.

Nuclear Regulatory Commission, NUREG-3332.

Todd, D. K. 1970. The Water Encyclopedia. Port Washington, New York: Water O Information Center.

Todd, D. K. 1980. Groundwater Hydrology. New York, New York: John Wiley and Sons, In:, 535 p.

U. S. Bureau of Reclamation. 1977. Ground Water Manual. U. S. Depirtment of -

Interior. 480 p.

U. S. Department of Interior. 1985 (updated). National Handbook of Recomended Methods for Water-Data Acquisition.

U. S. Environmental Protection Agency. 1982. Final Environmental Impact Statement for Remedial Action Standards for Inactive Uranium Processing Sites (40 CFR 192), EPA 520/4-82-013-1 and 2.

U. S. Environmental Protection Agency. 1983. Final Environmental Impact Q Statement . for Standards for the control of Byproduct Materials from Uranium Ore Processing (40 CFR 192), EPA 520/1-83-008-1 and 2.

U. S. Environmental Protection Agency. 1984 (updated). Test Methods for Evaluating Solid Waste, SW 846.

U. S. Environtr. ental Protection Agency. 1984. Proposed guidelines for exposure assessment. Federal Register, v. 49, n. ?27, pp. 46304 - 46312.

U. S. Environmental Protection Agency. 1985. Draft Alternate Concentration Limit Guidance baseo on 1264.94(b) Criteria: Information Required in ACL Demonstration.-

U. S. Geological Survey (asserted authors and dates since 1978). Summary Appraisals of the Nation's Ground-Water Resources. Professional Paper 813.

9/17/85 4-22 9/17/85 U. S. Nuclear Regulatory Comission. 1980. Final Generic Environmental Impact Statemert on Uranium Milling, NUREG-0706.

Walton, W. C. 1970. Groundwater Resource Evaluation. New York, New York:

McGraw-Hill Book Company. 664 p.

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O APPENDIX 4.As C'.0SSARY OF WATER RE501' ACES PROTECTION TER.5 O-L 1

GLOSSARY OF-WATER RESOURCES PROTECTION 1ERMS Aquifer - A formation, group of formations, or part of a femation thet  :

contains sufficient saturated permeable material' to yield significant quantities of water to wells and springs.

Background Ouality - The chemical and physiochemical characteristics of a material (generally water or soil) that would exist independent of the effects of the designated facility.

Bedload - Sediment that moves on or near the stream bed and is in almost continuous contact with the bed.

O aracuish water water that contains more than 2,000 but ies, thaa 10.000 milligrams per liter of dissolved solids.

Brine - Water that ccitains more than 35,000 'n1111 grams per liter of dissolved solids.

Cation exchange s.apacity (CEC) - the number of mil 11 equivalents of cations that can be exchanged from solution to a solid with a dry mass of 100 grams.

Confined - The condition in which the static water levei or potentiumetric surface in a hydrogeologic unit is above the top of the unitt artesian.

Confined Aquifer - An aquifer bounded above and 1,elow by hydrop,eologic units of distinctly lower permeability than that of the aquifer.

/~T V Confining Unit - A hydrogeologic unit with distinctly low permeability above or below one or more aquifers.

Contaminent Plume - A contaminated area or volume of a stream or aquifer.

l Desorption - Release of gas molecules, ions, or molecules into solution that

! had previously adhered to a solid surface.

Discharge Area - That portion of a subsurface drainage basin or hydrogeologic system in which the net saturated flow of groundwater is directed toward the water table.

Dispersion Coefficient - A measure _of the spreading of a flowing fluid, which equals the sum of the coefficient of molecular diffusion and the product of dispersivity times the average interstitial velocity in a porous medium.

WM-39/MFW/85/09/03/ GLOSS Dispersivity - A proportionality constant that describes the mechanical mixing of solutes and heat during advective transport, which equals the ratio between the coefficient of mechanical dispersion and the average interstitial valocity along a flow path.

Distribution Coefficient - The equilibrium sorption ratio of the amount of solute Sorbed by the solid per unit weight of solid and the quantity of solute dissolved in solution per unit volume of solution.

Effective Porosity - The ratio of (1) the total volume of voids that conduct fluid flow and advective solute and heat transport to (2) the total volume of the porous medium, p Evapotranspiration - The amount of water discharged to the atmosphere as a d result of evaporation from earth materials and surface-water bodies and transpiration from plants.

Flow Path - The subsurface, macroscopic course a water molecule or solute would follow in a given water velocity field.

Freshwater - Water that contains less than or equal to 1,000 milligrams per liter of-dissolved solids.

Groundwater - Water which occurs below the surface of the earth, including water within the unsaturated and saturated zones and excluding primordial water and waters. bound within crystal lattices.

Groundwater Divide - A ridge in the water table or potentiometric surface from which groundwater flows in opposite directions.

O Groundwater Mound - A rise in the water table or other potentiometric surface V created by groundwater recharge.

Head Static - A measure of the potential of water represented as the height above a standard datum of the surface of a column of water that can be supported by the static pressure at the point of measurement; the sum of the elevation head and pressure head.

Hydraulic Conductivity - A proportionality constant that relates hydraulic gradient to specific discharge, which may be expressed as the volute of water at an existing kinematic viscosity that will move in unit

. time under a unit b /draulic gradient through a unit area measured nonnal to the direction of flow for an isotropic medium and homogenous fluid.

WM 39/MFW/85/09/03/ GLOSS

- 3-Hydraulic Gradient - The change in static head per unit distance in a given direction, which is generally assumed to coincide with the direction of maximum rate of decrease in head.

Hydrodynamic Dispersion - The spreading of a solute or themal energy during transport caused by mechanical dispersion and molecular diffusion as described on a macroscopic scale.

Hydrogeologic Unit - Any discrete and continuous porous medium or porous zone that influences the storage or movement of groundwater because of its porosity or permeability.

Infiltration - The downward entry of water into soil, sediment, or rock.

O tea *ase - The oncontroiied transrer of ater from one aquifer to another.

Matric Fotential - The energy required to extract water from a porous medium against capillary and adsorptive forces of the medium, Mechanical Dispersion - Physical mixing of solutes or themal energy during advective transport caused by variations of flow velocities at the microsecM c scale.

Moisture Content - The ratio, expressed as a percent =ge, of (1) the weight of water to (2) the weight of solid particles in a given volume of a

, porous medium.

Perched Groundwater - A. saturated body of unconfined groundwater separated from an underlying saturated body of groundwater by an unsaturated zone.

O d Piezometer - A device emplaced in the subsurface to measure accurate changes in groundwater levels.

Porosity - The ratio of the total volume of voids to the total volume of a porous medim.

Potentiometric Surface e An imaginary surface representing the static head of groundwater described by the level to which water would rise in a piezometer.

Protective Action - Any action implemented to prevent, control, or mitigate water contamination.

Recharge Area - That portion of a drainage basin or discrete hydrogeologic system in which the net saturated flow of groundwater is directed away from the water table.

w. ._.m. , _ . . - , 4-

WM-39/MFW/85/09/03/ GLOSS t

Saline Water - Water that is generally considered unsuitable for human consumption or for irrigation because of its high centent of dissolved solids ranging from 10,000 to 35,000 milligrams per liter.

Seep - An area where water percolates to the land surface at flow rates less than 1 liter per minute per square meter.

Semiconfined Aquifer - An aquifer that is partially bounded above or below by a confining unit.

Sole-Source Aquifer - As determined by the U. S. Environmental Protection Agency, an aquifer that supplies at least 50 percent of the drinking water for an. area.

O Sorat4ea ane or more physioc*emicai aro: esses. e ciedin, aveciaitatio, of stochiometric (fixed composition) niid phases. .in which solutes are removed from a liquid or gas phe w by interaction with a solid phase or phases.

Specific Discharge - The rate of discharge of groundwater per unit area of a 4 porous medium measured perpendicular to the direction of flow.

~

Specific Storage - The volume of water released from or taken into storage per unit volume of the porous medium per unit change in head.

Specific Yield *The ratio of the volume of water that a saturated porous

medium will' yield by gravity flow to the total volume of the porous.

medium.

Spring - A discrete area where groundwater discharges naturally onto the land I

\ -

surface or into a body of surface water at flow rates greater than or equal to 1 liter per minute per squa-e meter.

- Storage Coefficient - The volume of water an aquifer releases from, or takes into storage per unit surface area of the aquifer per unit change in head; storativity.

Total Dissolved Solids - The total concentration of dissolved consF uents in solution, which is generally expressed in milligrams per 1".,r.

Transmissivity - The rate at which water of a given kinematic tiscosity is transmitted through a unit width of an aquifer under a unit hydraulic gradient.

Unconfined - The condition of water in the zone of saturation whose upper surface is the water table.

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

_ . - . . ._ _ _ . . .-_ _ _ . _ . .. _._._._ _ . _ . . ~.._ _ _ _ _ _ . _ _ . . _

s -

WM-39/MFW/85/09/03/ GLOSS

- 5-Unsaturated Flow - The movement of water in a porous medium whose pores are l not completely filled with water.  :

' Unsaturated Zone - The portion of hydrogeologic systems between the land surface 'and the deepest water table,'which includes the capillary ,

fringe and may contain zones in which water pressure is locally greater than atmospheric pressuret vadose zone. ,

Velocity Average Interstitial - The average rate of groundwater flow through  ;

pore spaces expressed as the product of hydraulic conducto.ty and -

hydraulic gradient divided by the effective porosity.

Water Table - The upper surface of the zone of saturation at whi ter A prese're in the porous medium equals atmospheric pressure.

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WM39/GG/85/01/08 a 1 -

M, John G. Theme 11s. Project Manager -

Uranium Mill Tailings Project Office Albuquerqu. Operations Office U.S. Department of Energy P.O. Box 5400 Albuquerque, New Mexico 87115

Dear Mr. Theme 11s:

We have reviewed the DOE Project Licensing Plan for Uranium Mill Tallings RemedialActionProjectSites(UMTRA.00E/AL.150524). We had not earlier O provided rormai commeats to you, because of the paadiag suppiement oa maintenance and surveillance (M&S) which was to constitute a major portion of the licensing plan. However, D. Groelsema (DOE /HQ) and J. Arthur (DOE /AL) indicated on December 12, 1984 that the M&S supplement was to be considered a separate document, which has not yet been completed by 00E. Therefore, our comments are of a preliminary nature and should not be construed as sufficient for obtaining NRC concurrence with the proposed DOE licensing process for UMTRAP. Concurrence will be an issue only upon completion of the M&S plan and

,q any necessary revisions of the licensing plan.

V One other point should be made clear. The PRC will not consider licensing for

.any sites, until it has reviewed and ev.ured in the certiftration report determining that the remedtU action is '.ampleted at that site. This appears tobeoutofsequenceinthelicensingplan(seep.79). We bring this up, because certification is discussed in the licensing plan. It would be to NRC's and DOE's advantage to wrap up all aspects of the remedial action at the FC t WK.U :WMLU :WMLU :WMLU :0 ELD :WMLU  :

AME 3GN Gnugnoli: DM Sollenberger CA Flory :DE Martin :R Fonner :LB Higginbotham : : :

ATE :85/01/ :85/01/ :85/01/  ::85/01/ :85/01/ :85/01/

. - - . _ . _ _ . - _ - - - .- . -- -. . - _ _ . _ - . - - . ~

=.

l WM30/GG/85/01/08 2-certificationstagI,andturntofuturecontolsandact ins at the licensing stage.

In addition to these general observations, we have enclosed specific comnents ,

regarding certification of completion and licensing. Should you have any questionsregardingthesecomments,pleasecallGiorgioGnugnoli(FTS) 427 4788 of my staff.

(])

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

Enclosure:

As stated cc: J. Baublitz, 00E/HQ w/ enclosure D. Groelsema. DOE /HQ w/ enclosure J. Arthur, DOE /AL w/ enclosure 73

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ATE :85/01/ :85/01/ :85/01/  : :85/01/ :85/01/ :85/01/

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I HRC Coments on the DOE Project Licensing Plan for UMTRA Sites ,

i Certification

1. NRC must concur in the certification report on completion of remedial I aution at any disposal site prior to considering any license application '

I for the custody, maintenance, monitoring or any appropriate emergency l measures.

2. The licensing plan lis's. 7 topics to be covered by DOE in the I certification report. These are:

O o De,cription of remediai action.  ;

o Pre-remedial action site conditions, o Post-remedial action site conditions.

o Specifications and calculations, o As-built drawings o Field test results.

o Verification measurements results There is no discussion about the scope and detail of the above items.

Some are self explanatory, such as-built drawings, others are not. To more clearly indicate what NRf will need to make the decision on certification of completion, ti,e following items are suggested to augment the above list:

A. There needs to be a provision for NRC QA checks to be coordinated wi';h DOE. At the NRC's discretion, visits would be C coordinated with key milestones in the construction phases.

Some prior notification of these milestones should be provided to the NRC, if possible up to one month in advance. Examples would be the riprap placement milestone, the point of confirmatory gama survey following excavation completion, and so forth. However, this would require advance notification of such milestone dates. The pre-certification procedure and project design should include such a provision.

B. Any site-specific performance criteria as discussed in the Remedial Action Plan (RAP) and the final ecnstruction design should be itemized in the certification report, along with a description of how the criteria were achieved with detai _

sufficient for determination of the degree of success. It wo'uld

.y(fot be,suff1q.iehrto pdicate ihac EPA syndards yere achieved, r}l dinerspuu hduve N MS A**l A*)7*/ W Q r Jnl ceknis mil nul MMc wa4 g' -

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2 ift/ecriteri as achieved.fdinthe wer(notfully. descri AP and/f the ffal des /gn '

h C. Documentation that the vicinity properties (VPs) associated with a site were cleaned up would be required. This documentation would include description of any VPs where supplementary f

standards were utilized and/or where large volumes of materials wereidentified(greaterthan10,000cubicyards). Information should detail the levels of remaining contaminatio

• t deed restrictions and record controls were invoked, and affidav V t g' completed as-that actions stipulated. TheasVPdescribed audit reports in that would REAsby were%useful in aiding NRC 0)UF O coacurreac -

L -

t D. Any significant modification of the RAP and design at the processing, disposal or any significant vicinity property shocid have been reviewed and concurred in prior to the completion of remedial action. Therefore, any such modification discovered I which had not been previously reviewed and concurred in by should be fully described by written notice to NRC prior to consideration of NRC concurrence, conditional or otherwise, with

, the certification.

E. DOE audits and reports relating to the performance of the remedial action should be made available to the NRC, as they become available, either in detailed or in summary fashion.

These reports, audits and summaries are discussed in sections 4.2.2 and 4.2.3 of the licensing plan. These would be far more p useful in support of the certification concurrence than for the V licensing decision.

F. The certification report would need to address details of unexpected conditions and problems encountered in construction, as well 45 the methods employed to resolve these problems. It should also itemize the appeal to supplemental standards and the extent of contamination which is lef t in place. This wculd be used as a description of the prel'aensing environment for which maintenance, monitoring and emerf icy measure license conditions would be developed. It is the NRL's position that the certification stage is the step at which NRC and DOE agree on the condition of the site which will be licensed.

. l 1

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l G. Attached is an April 2,1984 transmittal to the DOE UMTRA office relating to a March 1984 presentation on UMTRA quality assurance. We feel that it is still applicable to our needs for certification as well as for licensing.

Lice _nsing I

1. At present the license apol1 cation precedes the completion of remedial .

action and certification report. This appears to be out of sequence with .#

the purpose of licensing the site. It would be more appropriate te / /

establish the condition of the site at the completion of remedial action.

O V

in order to address the monitoring, maintenance, surveillance and other appropriate medsures needed to protect the public health and safety. A number of diagrams and chronological lists in the licensing plan display (

this peculiar sequence of events.

2. According to the licensing plan, the license application will contain, but not be limited to:

o Legal description of the site.

o Ownership information (surface and sub-surface).

o Reporting and recordkeeping requirenents.

o Site maintenance and surveillance plan (SMSP),

o Destgn elements for SMSP.

Furtherrore, the SMSP, which is intended to ensure that the design continues to meet the " standards", may include provisions for:

O) o Aerial photo analysis.

o Site inspections.

o Water monitoring.

o Maintenance (Custodial).

o Contingency repair.

Again, the scope and detail of the above items have not been established.

In order to more clearly identify what the NRC needs for a licensing decision, the following information should be provided:

A. The need for, extent and (sampling) frequency of environmental monitoring to be conducted (accompanied by maps with well locations). This should include descriptions of the location, equipment type, sensitivity, etc... pertinent to identifying background and contamination levels at or near disposal site.

_ . - _ - - - = . _ _- . _ - . _ - -

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l B. The procedures, frequency and scope of periodic site ,

surveillance should be clearly described. In addition to aerial I photoanaly(sis,siteinspectionsshouldconsistofachecklist procedure tobeincludedasalicensecondition)for determining whether the designed, Nclaimed disposal impoundment is behaving in the manner stipulated in the remedial action plan and final design. The inspections should be perforned by n xperienced prosessiona'Is3horoughly s familiar with the

/ titTg m on, design and construction of uranium mill tailings

. impoundments. Areas to be included in these inspections would include, but should not be limited to:

O -

o o

Embaakment settiemeat Embankment slope conditions o Slope protection o Special inspections following unusual events, such as, floods, earthquakes, tornadoes, intense rainfalls, o Infiltration into the erosion protection layer causing cracks, sloughing and erosion defects, o Post-construction changes such as land development, upstream dam construction, watershed area modifications, etc... which could affect the erosion events such as PMP, AMF, and other considerations which were used in developing the final design. [

C. Mechanisms and procedures to assure the prompt identification and application of needed emergency measures Lk should also be addressed.

p liners or slurry walls fail, as Should design may be measures indicated by thesuch as )

d 7 monitoring program, the DOE should have listed in the license appitcation what repair, restoration and emergency measures would be used to protect any heavily used aquifer.d ,

Other considerations should include unscheduled inspections following severe unexpected events specifying time intervals between the event and the site inspection as a function of the severity.

3. Where supplemental standards are invoked for a disposal or processing site and/or associated vicinity properties, the license application should include conditions and precautions to minimize impacts to the environment and public health and safety.

i

~,_. . _ .-._M , .

4 1

4. In those cases where oeed restrictions, other real estate or legal environmental use restrictions are applied, the recordkeeping portion of the license application should detail these.

5.

W Thelicensingplanshouldaddressthe%proceduresDOEwillestablishinthe case that mineral recovery is pursued y an independent party or if subsurface mineral rights are leased or sold. The NRC-issued license to .

DOE or other federal agency would address the issues associated with maintaining. cals of UMTRCA Title 1.

6. In the >=a mM4 . .izationinplace(SIP)oftailingsonIndianLand, i

the NRC wil.L4,'1 cense DOE (or any properly designated federal agency) for

- O- undertaking monitoring, maintenance and emergency measures for the post-remedial action care of the site (s). However, the DOE should provide to NRC by written notice the custody status of the site with proper legal 7

justificationgsuchstatus. g(

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Document Names i 4

WM39/GG/65/01/08

-r Requestor's 10:  !

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Author's flau:  !

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Document Coments: i 406.1.2 - John G. Themelis  !

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Mr. James A. Morley Department of Energy  :

Albuquerque Operations Office  ;

P.O. Box 5400 j Albuquerque, NM 87115 ,

Dter Mr. Morley:-

a We would like to_ thank DOE personnel and your contractors for the presentation i on quality assurance for the UMTRA Project. The presentation was both informative and useful for ny staff. Based on this presentation, we beli' eve that DOE is developing a comprehensive quality assurance program that should i Q adequately assure that remedial actions will be carried out as planned and approved.

We feel that the following actions, as were discussed, would be beneficial to the NRC review, concurrence, and licensing process for the UMTRA sites. These are as follows:

'( 1. Generic QA and QC procedures, where appropriate, (for example, construction testing, grotmdwater sampling, and radiological monitoring) should be submitted by DOE to simplify and expedite NRC s reviews. If ,

these procedure: have been deternined, the-NRC staff needs to review and coment on them. The NRC can then focus on site specific parameters and programs which need to be developed.

- 2. There are certain construction features, such as placement of rip rap, placement of the capillsry break on base materials, and placement of cover

. Q:- materials, etc., that the NRC staff would like to observe during actual -

construction. Requirements will be. site specific, and we plan to notify you of the 'tems at each site that.we would like to observe when we give finsi cone- 'nce to the M.P or specific sections of the final design. We *

.would like ce notified at least one month prior to this work.

!- 3. NRC concurrence is required for all major changes (as defined in NQA-1,

Supplement 65-1, 1983 edition) in the RAP and the sections of the final a e design which the NRC has reviewed. Since we are concurring in the design, major changes to the tesign will therefore require our concurrence.

~

4. In order to assist us in obtaining data necessary to support our future -

licensing requirements, we would like to receive all audit and i constrvction reports. The construction reports should include at least j ,

the following: -

. _ . - - - - - . , , - , , - _ _ . . . . - - - , , , ~ _ - - _ - . _ .-_. _ - _ _ _ - , _ , , . _ __ _ _-__. -_ .

0,.

2

-- as built drawings and cross sections, 3 .

-- details of construction proceduftFs sunenary of material test result /s (compaction, moisture content, gradation rock durability, specific gravity, penneability, etc. .

cetails of unexpected conditions and problems encountered in E --

construction, and the methods emplofed to resolve these

] problems, and

'h --

proposal for long-term periodic monitoring and maintenance.

We would appreciate your consnents on these suggestions. If we can be of further assishnce please contact Mark Haisfield at 427-4111.

, Orimm1 m- M Leo B. Higginbotham, Chief Low-Level Waste and Uranium Recovery Projects Branch Division cf Waste Management cc: Don Groelsema DOE-HQ O

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