ML20205D508
| ML20205D508 | |
| Person / Time | |
|---|---|
| Issue date: | 05/27/1986 |
| From: | Gillen D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Martin D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-39 NUDOCS 8608180069 | |
| Download: ML20205D508 (4) | |
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WM39/DMG/86/05/19 MAY 2 7 y ?
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-=19 r/f J GN Gnugnoli WMLU r/f M Weber NMSS s/f W Ford MEMORANDUM FOR:
Dan E. Martin J0 Bunting M Fliegel WMI,U MJ Bell P Justus
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RE Browning E Hawkins FROM:
Daniel M. Gillen MR Knapp WMLU DM Gillen
SUBJECT:
MEETING REPORT; DOE DRAFT PLAN FOR UMTRAP WATER PROTECTION STANDARDS Enclosed for your information is a summary of the May 8,1986, meeting with DOE. The meeting was held at DOE's request to discuss aspects of their proposed plan to provide interim definition of their implementation of water protection standards for the UMTRA Project until EPA promulgates revised standards in 40 CFR 192.
Daniel M. Gillen WMLU
Enclosure:
As stated WM Record file WM P p'get 37
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cc: Jim Turi (D0E Headquarters)
John G. Themelis, (DOE Albuquerque)
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StanLichtman(EPA)
PDR LPOR Djstribution:
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l0 ATE :86/05/91
s WM39/DMG/86/05/19 MEETING REPORT Date:
May 8, 1986 Location:
Silver Spring, MD NRC Willste Building Room 763
Purpose:
To discuss programmatic and technical aspect.s of " Draft Plan for Water Protection Standards" being developed by DOE to provide interim definition of their implementation of water protection standards for the UMTRA Project until EPA promulgates revised standards in 40 CFR 192.
Attendees:
See attached list.
Background:
To date, the Uranium Mill Tailings Remedial Action Program (UMTRAP) direction for developing water protection measures has been the final Title ! EPA Standards (40 CFR 192.20). However, recently the U.S. Tenth Circuit Court of Appeals has rendered a decision which sets aside these standards and instructs EPA to re-promulgate' standards of more general application. DOE has elected to develop a plan that provides interim definition of their implementation of water protection standards until EPA promulgates revised standards.
By note from J. Turi (D0E Headquarters) to D. Martin (NRC) dated April 29,1986, copies of the subject document were transmitted to the NRC for review. The note also confirmed the date and time for a meeting to discuss the document. Prior to the meeting date, copies were distributed to appropriate WMGT staff, and a preliminary review was performed so that the NRC staff's initial impressions could be discussed.
In addition, DOE had scheduled a similar meeting with EPA staff that was to be held on the afternoon following the NRC meeting.
i Meeting Summary:
Following an introduction of attendees, D. Martin opened the discussion of the subject document by questioning DOE as to why they feel a need for its preparation.
J. Turi responded that DOE feels vulnerable in light of the
" limbo" status of EPA ground water standards, and thus their goal'is to issue an acceptable, more-specific plan that would bridge the gap between the present
e WM39/DMG/86/05/19 operations and possible future requirements.
D. Martin indicated that NRC staff's chief concern was that the pending EPA rulemaking not cause program delay or need to retrofit completed sites.
J. Thackston proceeded to summarize major aspects of the proposed plan comparing it to the existing Title II standards for active sites. He indicated that certain aspects of the Title II standards were not considered by DOE to be appropriate for Title I sites, such as compliance monitoring and lack of allowance for judgement of what remedial action is needed based on site specific conditions, including ground water quality and local use patterns.
The NRC technical staff raised some of their concerns based on the preifminary review of this document. The major points made were:
- 1) that the plan as presented appears to remove some of the NRC's review flexibility, such as in consideration of organics and other constituents not on DOE's proposed constituent list, and 2) that the plan is inadequate in terms of description of-the implementation process.
==
Conclusions:==
The concluding remarks of both DOE and NRC indicated agreement that the way we have been conducting ground-water evaluations / reviews is acceptable and should not be compromised in whatever future plans and standards are developed. The meeting closed with NRC committing to send comments informally to DOE upon completion of our technical review.
Note that NRC's comments were sent to J. Themelis and J. Turi (DOE) on May 22, 1986. Appropriate EPA staff were provided with an early draft of our comments for their information.
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