ML20207E548
| ML20207E548 | |
| Person / Time | |
|---|---|
| Issue date: | 11/26/1986 |
| From: | Martin D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Themelis J ENERGY, DEPT. OF |
| References | |
| REF-WM-72 NUDOCS 8701020204 | |
| Download: ML20207E548 (4) | |
Text
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John G. Themelis, Project Manager
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Uranium Mill Tailings Project Office I'
U.S. Department of Energy D N~ ' ' ' '-
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Albuquerque Operations Office P.O. Box 5400
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Albuquerque, NM 87115 7
Dear Mr. Themelis:
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The Nuclear Regulatory Comission (NRC) has completed its review of the Draft CADSAR for the Spook, Wyoming site. Our review consisted of a broad overview to identify fatal flaws, potential issue areas, and omissions. The Draft CADSAR is a very pr~eliminary document, which is produced before much environmental data has been collected and before detailed engineering data is available. '!ith this in mind, we did not see any fatal flaws at this time which would preclude use of the two proposed alternatives. However, NRC concurrence that either alternative will meet Environmental Protection Agency standards cannot be provided until the detailed information discussed above has been reviewed.
The enclosed comments, which identify potential issue areas and omissions, would be useful in improving the quality of the Final CADSAR and should be incorporated where possible. These coments also provide requirements which will be necessary when developing remedial action plans.
It is in this spirit that our coments are provided. We do not feel that there is enough information for the NRC to
" formally agree on a preferred remedial action alternative" as discussed in your September 26, 1986 memorandum on the purpose and scope of a CADSAR. The preliminary final CADSAR will need to provide significantly more data for NRC to come to this type of conclusion.
If you have any questions regarding these coments, please contact Mark Haisfield at (FTS) 427-4722.
Sincerely, I(
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l Dan E. Martin, Section Leader Uranium Recovery Projects Section 8701o20204 861126 Low-Level Waste and Uranium Recovery Projects Branch PDR WASTE PDR wa-72 Division of Waste Management Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated 8FC :WMLU 4J
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i NRC Comments on Deaft CADSAR-Spook, Wyoming
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Groundwhter Issues Although th4 draft CADSAR is designed to aid interested parties in addressing s
potential concerns, this document provides no groundwater information, thereby precluding any specific, technically based comment on groundwater issues _
with respect to the proposed disposal options for the Spook tailings. The final CADSARson Spook alternatives should include results from monitor well installation 2
and preliminary monitoring, such as: a discussion on the thickness and extent of permeable aquifer materials, preliminary indications on the extent of groundwater contamination, flow directions, potential for recharge of the open-pit mine, and c
incorporation of these factors into a preliminary assessment on water resource
!(A4 impacts and potential groundwater contamination resulting from the disposal
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If-the SIP option _is chosen as the preferred alternative, several groundwater concerns will ariset relating to potential interaction of water with the tailings material. Briefly, NRC staff will review the disposal design with several key questions in mind:
i a.
What is the potential for water to percolate through the backfill material and collect in the bottom of the pit (bathtubbing)?
b.
What is,the likelihood that the water table will rise above the s
pit floor?
c.
If the State of Wyoming delays remedial action as part of the AML program, the open-pit may act as a collector for surface water runoff. What effects will this have on groundwater contamination?
d.
If water collects on the pit floor, will it contact waste material? 'What measures will be taken to preclude this contact?
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2.
Surface Water and Erosion Issues l
Additional information is needed on analysis of drainage basins, their past gdomorphic history, and the identification of potential geomorphic hazards such as channel incision, widening, and headcutting.
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c COMMENTS ON DRAFT CADSAR SPOOK Review of FBDU reports indicates that some diversion of surface water may be required for either option. A discussion should be provided regarding the prcposed methods for diverting surface runoff away from the tailings, and any potential problems associated with these diversions.
If diversions are not provided, discussions should be included to indicate how the design will prevent erosion.
If SIP is chosen, the surface of the backfill must rise at least as high as the natural grade and be properly contoured to provide positive drainage to natural surface drainage basins near the site.
Remedial action should include designs to prevent concentration of erosive runoff as well as ponding of surface waters above the buried tailings embankment.
If SOS is chosen, additional field characterization should include selection and testing of locally available rock to estimate its durability and potential need for oversizing if rock quality is poor.
l No topographic maps were provided in the draft CADSAR. A detailed topographic map of the site needs to be prepared before NRC can reach conclusions regarding surface drainage.
3.
NRC Certification If the SIP option is chosen, NRC will not concur in site certification until the State has completed reclamation of the Spook Mine.
If the State's Abandoned Mine Lands Program is delayed, the tailings may become subject to erosion and dispersal due to a lack of~ rock protection. Therefore, the NRC would recommend that placement of overburden fill should begin soon after placement of the tailings and radon barrier, or additional discussion should be provided to explain why the pit design will not require rock protection.
If the SOS option is chosen, NRC may not be able to concur in site certification until the State completes reclamation. This is due to potential instability of the pile when located next to a large open pit.
Also of concern will be the effects of gullies eroding headward toward the pile caused by erosion of the steep pit slopes.
4.
Scope of Work Section 5.0, Exhibit A, Borehole Locations Although the draft CADSAR provides no groundwater information, there appears to be some knowledge available, since well locations and an apparent flow direction were included in the S0W. With specific reference r
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COMMENTS ON DRAFT CADSAR SPOOK 3-3
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to the proposed well locations in the S0W, NRC staff are concerned that the area northwest of the tailings pile will not be adequately monitored since i
well construction is not planned in that area. Although the S0W includes a figure illustrating the reported groundwater flow direction as NE, no evidence has been provided that demonstrates its accuracy. Thus, a significant portion of the proposed disposal area may go unmonitored. To alleviate potential conflicts on groundwater characterization in the future, DOE should include available groundwater information in the final CADSAR demonstrating that the wells were defensibly located during characterization.
Also, the S0W does not indicate in which stratigraphic interval the wells will be completed. NRC staff recognizes that these depths cannot realistically be predicted, but if accurate monitoring is to be achieved, the TR/FTR should have some knowledge of the hydrogeology prior to deciding where the wells should be completed. This hydrogeologic o
information should be presented in the final CADSAR, or referenced accordingly.
Section 3.5, Attachment 1, Anti-Cross-Contamination Measures 4
The 50W indicates that drilling equipment will be cleaned with steam prior to entering the site, then cleaned again prior to leaving.
Thus, steam cleaning will be performed only once during drilling operations (unless hydrocarbons are encountered). Although the equipment will be rinsed off with potable water between each drill hole, it'may be prudent to include in the S0W, a statement indicating
- that additional cleaning may be required if significant contamination sources, other than hydrocarbon, are encountered. This will give the TR/FTR legal latitude when considering additional cleaning of equip-ment.
The TAC should consider using chlorinated water in the drilling fluid.
Research has shown that chlorinated water used in drilling fluids and a follow-up. treatment after casing emplacement were useful in pre-venting bacterial growth known to cause well encrustation and subsequent failure.
This procedure may increase the effective life of the well and improve the quality of the water samples retrieved during characterization and remedial action activities.
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