ML20205F674
| ML20205F674 | |
| Person / Time | |
|---|---|
| Issue date: | 10/23/1985 |
| From: | Knapp M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Higginbotham L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-39 NUDOCS 8511120391 | |
| Download: ML20205F674 (4) | |
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MEMORANDUM FOR:
B. Higginbotham, Chief tha 9
erger TJohnson FROM Malcolm R. Knapp, Chief a dj WMGT 9
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SUBJECT:
WMGT REVIEW 0F PROJECT SURVEILLANCE AND MAINTENANCE PLAN (TAR 85860)
WMGT has completed its review of the Project Surveillance and Maintenance Plan as requested by TAR 85860. A set of detailed comments are attached, while our overall concerns are outlined below.
l In reviewing the current (September, 1985) version of the PSMP, the staff has found that some of our previous comments transmitted to WMLU (May 17, 1985) regarding the March, 1985 version, have not been addressed.
Previous comments l
that the staff still considers to represent valid concerns are reiterated in this review.
Other comments address modifications to the earlier version.
In general, the staff's cancerns still exist regarding: 1) the premature nature of developing license-compliance-verification procedures prior to the development of generic license requirements; and 2) the possible perception that monitoring and maintenance can exist as alternatives to site characterization and design in meeting the EPA standards.
If you have any questions concerning our comments, please contact Mark Larson, of my staff, who coordinated this review with Dave Brooks, Jose Valdes, and Ted Johnson.
M Malcolm R. Knapp, Chief WMGT
Enclosure:
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Section 1.2.1, Pg. 2 h
terize This section contains a list of documents and materials used to c This geologic final site conditions. logs, geophysical logs and geologic cross sections.
i ities.
documentation should already exist from site chara h ld be included to designate contaminated areas.
Section 1.3, Pg._4_
i The PSMP omits certification as a step in the surveillance and remedial action is a critical step in the process becau process at UMTRAP sites.
i that must These isolated areas remain isolated to protect the public and environment.s required in thus become the focus of the surveillance and monitoring prog in the surveillance the PSMP be revised to identify certification as a key step site licenses.
and maintenance process.
Section 1.3, Figure 1.1, Pg. 6 l
i i g an l
The diagram of the Surveillance and Maintenance Plan (Figure 1.1 i
i g) back arrow from block 13 (Resume Phase 1 Inspection a Without this feedback loop, the process would terminate after a prob did not breach site integrity and did not require maintenance or tha l
site.
remediated and certified to NRC.or more sequential problems could n Section 2.3, Pg. 9 ill be a It is indicated in this section that the base for site vicinity maps w As 1:25,000 has been adopted by the USGS 1:24,000 topographic quadrangle sheet.
the USGS as the standard scale for all 73' quadrangle topographic "If USGS quadrangles are not available, the best available PSMP should be changed to reflect this fact.
The concept of what is acceptable as a "bestThe PS this section that:
alternate will be obtained."available alternate" needs to be i
discuss contingency plans to develop the vicinity map in the even reasonably close to a USGS 7)' quadrangle topographic map is a Section 2.3.2, Pg. 9 In its comments on the March, 1985 version of the PSMP, NR scale for site topographic maps was not adequate and indicated 1:24,000
L.
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2 recommended 1:2000 as the minimum scale for the topographic maps. The current version of the PSMP, however, specifies that the scale of the site topographic maps will not be less than 1:200. The latter appears to be a typo.
Section 4.0, Pg. 43 Section 1.1 states that the decision to monitor groundwater at UMTRAP sites i
will be determined by the criteria provided by the PSMP.
Section 4.1, however, does not provide criteria to make such a decision and does not specify the j
party making this decision.
Section 4.1 provides a list of factors for consideration in determining the need for and extent of post-remedial action groundwater monitoring.
To transform these factors into criteria, each would have to be rewritten into a decisional statement.
For example, the consideration listed in the PSMP as
" Background water quality of potential water supplies" would be rewritten into a question like "Would water resources potentially affected by the remedial action be water supplies based on their background qualities?" The PSMP does not provide these criteria and, therefore, cannot be used to determine the need for and extent of groundwater monitoring programs.
Section 4.1. Pg 44 The PSMP does not include sites where tailings have been relocated from as candidates for groundwater monitoring. The responsible agency should consider monitoring at such a site if the RAP indicates that it would be appropriate.
Section 4.2, Pg 46 Continued monitoring and surveillance of UMTRAP sites may generate large quantities of groundwater-quality data.
The PSMP does not describe how this information will be efficiently stored for rapid retrieval and review.
Prior to the initiation of post-remedial action monitoring, DOE should consider establishing a data management system to control the data and facilitate evaluations of the water quality data, as well as other data collected at UMTRAP sites.
Section 4.2, Pg 46 The PSMP states that analyses for some constituents may be eliminated during the establishment of background water quality if those constituents do not appear in all or most of the wells during the first two quarters. This practice could eliminate some critical constituents that are not, however, common.
The PSMP should be revised to include the provision that elimination of any constituents will not compromise the overall monitoring program.
Section 4.4, Pg 59
3 i
f The PSMP states that local water uses and health hazards associated with a particular constituent will be included as factors in defining an excursion of contaminants in groundwater. These factors would be appropriately included in determining the response to an excursion rather than in the determination as to whether or not an excursion has occurred.
Table 6.3, Pg 71 This table suggests the placement of inclinometers or tilt meters as part of custodial maintenance or repair actions that could be needed at sites with unstable slopes.
These types of instruments could be installed earlier as surveillance features (see pg. 7).
l I
As recognized on p. 35, slope creep is subtle and may be difficult to observe.
In many cases it is easier, less expensive, and more efficient to install items like inclinometers during remedial action work.
This would allow baseline data to be established for comparison over a longer period of time and could detect problems early, before any problems became more difficult and expensive to correct.
Details of slope stability surveillance instrumentation could be determined on a site-specific basis. However, NRC recommends that the PSMP be revised to include installation of slope stability surveillance instrumentation at all sites.
Appendix B - Modifying Processes Eolian processes should be included in the discussion of site-modifying processes.
Though wind erosion is mentioned within the section on sheet erosion (Section B.S. p depositional processes.g. B-13), no attention is given in this appendix to wind At some sites the latter could be significant in
.odifying on-site and off-site drainage patterns.
It is reasonable to expect, for example, that sediment deposition within a diversion ditch could eventually significantly affect the ability of tFe design to perform as intended.