ML20212J977
| ML20212J977 | |
| Person / Time | |
|---|---|
| Issue date: | 03/16/1992 |
| From: | Randy Hall NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Surmeier J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20212J942 | List: |
| References | |
| FOIA-99-311, REF-WM-63, REF-WM-70 NUDOCS 9910060062 | |
| Download: ML20212J977 (1) | |
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URANtuM RECOV FIELD OFnct DENVER. COLORADO 00225 MAR 16 1992 Docket No. WM-63/70 l
j MEMORANDUM FOR:
John J. S'urmeier, Chief Uranium Recovery Branch ii Division of Low-Level Waste Management and Dec'ommissioning, NHSS FROM:
Ramon E. Hall, Director Uranium Reccvery Field Office Division of Radiation Safety and_ Safeguards Region IV
SUBJECT:
MEXICAN HAT / MONUMENT VALLEY PREVIOUS CORRESPONDENCE Allan Hullins called Ed Hawkins on March 6, 1992, and requested copies of our documentation on Mexican Hat / Monument Valley. Allan said that right now, all you wanted was documents generated by URFO.
They are enclosed.
They discussed the documents we received from DOE, but Allan did not want us to send them at this time.
If you need them in the future, please give us some lead time, as there are about four linear feet of files. We would prefer to send them
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N amon E. Hall Director j
Enclosure:
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Docket No. WM-63/70 9
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Docket File No. WM-63/70 FROM:
Raymond O. Gonzales, Project Manager
SUBJECT:
REVIEW OF THE REMEDIAL ACTION PLAN (RAP) FOR THE MEXICAN HAT / MONUMENT VALLEY UMTRA PROJECT l
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.y In a letter dated Februar 13, 1991, the Albuquerque Operations Office of the Department of Energy was :yadvised by the Uranium Recovery Field Office (URFO that the information provided with the subject RAP was not in a form suitable to enable URF0 to complete its review. 00E was requested to revise the RAP and supporting documentation to reflect the proposed remediation plans for the combined site.
1 URFO's letter of Februaryt13, 1991, inadvertently failed to close the :asework
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number assigned for reviewing the Mexican Hat / Monument Valley RAP.
Therefore, V'
the purpose of this memorandum to Docket File No. WM-63 is to formally close Casework No. 040WM0637000 and the applicable subcases.
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P oject Manager l
I Cases Closed:
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Dear Mr. Matthews:
We have completed our review of your letter dated January 22, 1991, in which you requested our concurrence in your prop'osal to disp'ose of an underground storage tank at the Mexican Hat site. The ta~nk, shich was uncovered du Mng'the removal of tallings from the Monument Valley site, contains radiologically contaminated sludge.
Since EPA has reviewed your analysis and has referred the removal and disposal of the tank back to the Department of Enargy because of the radioactive nature of the sludge, we agree that burying the tank at the Mexican Hat site is appropriate. We therefore concur in your proposal, provided that the tank is disposed of in accordance with the specifications provided in your January 22, 1991, submittal.
Sincerely, 5
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Ramon E. Hall Director cc:
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John J. S'urmeier, Chief Uranium Recovery Branch h
Division of Low-Level Waste Management and Dec'e'mmissioning, NMSS k
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Ramon E. Hall, Director Uranium Recovery Field Office Division'of Radiation Safety and Safeguards Region IV
SUBJECT:
MEXICAN HAT / MONUMENT VALLEY PREVIOUS CORRESPONDENCE Allan Mullins called Ed Hawkins on March 6, 1992, and requested copies of our documentation on Mexican Hat / Monument Valley.
Allan said that right now, all you wanted was documents generated by URFO.
They are enclosed.
They discussed the documents we received from 00E, but Allan did not want us to send them at this time.
If you need them in the future, please give us some lead time, as there are about four linear feet of files. We would prefer to send them regular mail rather than express mail.
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Docket File No. WM-63/70 FROM:
Raymond O. Gonzales, Project Manager
SUBJECT:
REVIEW OF THE REMEDIAL ACTION PLAN (RAP) FOR THE MEXICAN HAT / MONUMENT VALLEY UMTRA PROJECT In a letter dat' d Februar 13, 1991, the Albuquerque Operations Office of the e
Department of Energy was yadvised by the Uranium Recovery Field Office (URFO that the information provided with the subject RAP was not in a form suitable to enable URF0 to complete its review. DOE was requested to revise the RAP and supporting documentation to reflect the proposed remediation plans for the combined site.
URFO's letter of Februaryll3,1991, inadvertently failed to close the :asework
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number assigned for reviewing the Mexican Hat / Monument Valley RAP. Therefore, Vi the purpose of this memorandum to Docket File No. WM-63 is to formally close Casework No. 040WM0637000 and the applicable subcases.
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P oject Manager l
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U.S. Department of Energy ATTN: Mark Matthews Albuquerque Operations Offico P.O. Box 5400 Albuquerque, New Mexico 87115
Dear Mr. Matthews:
We have completed our review of your letter dated January 22, 1991, in which you requested our concurrence in your proposal to disp.ose of an underground.
storage tank at the Mexican Hat site. The'ta'nk, shich was uncovered during'the removal of tailings from the Monument Valley site, contains radiologically contaminated sludge.
Since EPA has reviewed your analysis and has referred the removal and disposal of the tank back to the Department of Energy because of the radioactive nature of the sludge, we agree that burying the tank at the Mexican Hat site is appropriate. We therefore concur in your proposal, provided that the tank is disposed of in accordance with the specifications provided in your January 22, 1991, submittal.
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R.E. HALL Ramor. E. Hall Director cc:
Mike Abrams 00E M. Begaye, Navajo Nation M. Foley, Navajo Nation L. Anderson, RCPD, UT C Tedford, ARRA, AZ PM:UR 00:URF0 0:URFO:RIV RGone les
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t Docket No.(WM-63/70 t 040WM070010E MEMORANDUM FOR:
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RaymondO.Gonzales, Project l Manager
SUBJECT:
DISPOSAL AT THE MEXICAN HAT SITE OF CONTAMINATED I
UNDERGROUND FUEL STORAGE TANK
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Background===
In the process of removing tailings from the Monument Valley site, an underground storage tank was uncovered. A site investigation determined that the tank is over 25 years old and was last in service in 1968.
The tank is approximately 25.5 feet long and.has a diameter of 8 feet. The tank presently contains between 1500 and 2000 gallons of low-level radioactive sludge which has a consistency that varies from tar to solasses.
Discussion SampleanalysisperfbreedbyDOEonthesludgeindicatedthatitismostlyold diesel fuel with trace amounts of benzenes, toluene, and xylene as expected.
The analysis also indicated that the sludge does not contain PCB's and does not exceed any of the applicable EPA limits (see Table 1).
The sludge was also tested for radiological contamination and found to contain Raden-226 at 48 pCi/g, Thorium at 28 pCi/g, and total Uranium at 150 ug/g (see Table 2).
These levels of radiological contamination exceed the UMTRA cleanup levels and thus the tank and sludge have to be disposed of in an acceptable manner.
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2 FEB 201991 Table 1 1
Complies Test Parameter Quantity Value EPA Limit w/ Limit 1.
Ignitability (a) Flash Point, F
>140 140 minimum yes 2.
Corrosivity (a) pH, Units 6.8 2.1 to 12.4 yes (b) Corrosion Rate, mm/yr
<1.0 6.35 yes 3.
Reactivity (a) Reaction w/ Water non-violent non-violent yes (b) Exposure Nature non-violent non-violent yes
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(c) Cyanide, mg/l
<0.10 10.0 yes (d) Sulfide, mg/l
<0.05
- 1. 0 yes 4.
EP Toxicity (a) Arsenic, eg.1 0.44 5.0 yes (b) 8arfum, og/l 0.09 100 yes',
(c) Cadmium, ag/l
<0.02 1.0 yes (d) Chromium, og/l
<0.03 5.0 yes (e) Lead, og/l 0.05 5.0 yes (f) Mercury, og/l
<0.02 0.2 yes (g) Selenium, ag/l 0.22
- 1. 0 yes (h) Sliver, ag/l 0.03
- 5. 0 yes 5.
Additional Testing hstParameter Quantity Value h
8enzene, ppe 64.0 Toluene, ppe 400 Xylene, ppm 1800 Ethyl Benzene, ppm 350 Diesel Fuel, ppe 370,000 PCB's, ppe below detection Ilmit Table 2 UMTRA Cleanup Levels Test Parameter Quantity level (above backaround)
Ra-226 48 pCf/9 5 pC1/g - 1st 15 cm of soll 15 pCl/g - next 15 cm of soil Th-230 28 pCf/g 5 pCf/g - 1st 15 cm of soil 15 oC1/g - next 15 cm of soil Uranium 150 ug/0 1 -l e
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EPA regulations require ' notification of all underground storage tanks that have been used to store regulated substances.
The information is required by the Resource Conservation and Recovery Act (RCRA) as amended.
In complying with this regulation 00E notified the EPA and provided the results of the analysis performed on the sludge.
Due to the radioactive nature of the sludge, EPA referred the removal and disposal management of; the tank back to 00E.
Proposal 00E proposes to relocate the tank from the Monument Valley site to an excay.ation at the southern end of the tallings pile at the Mexican Hat site.
The tank will initially be filled with a stndy material distributed to cover
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the sludge at the bottom of the tank.
The remaining space will then be filled with lean concrete.
The excavation surrounding the tank will be backfilled and compacted to 90 percent of maximura dry density.
Covering the sludge with sand and lean concrete will minimize the potential for chemicals and radionuclides to leach out of the tank.
If a leachate does develop, it is highly unitkely that it will ever migrate to the uppermost aquifer because the aquifer is geologically isolated from the tailings.
Conclusion The staff concludes that the radioactive sludge in the underground storage tank is residual radioactive material as defined in Section 101(7) of the Uranium Mill Tallings Radiation Control Act of 1978, and therefore disposal at a Title I site is appropriate.
The specifications developed for moving and disposing the tank will minimize, to the extent possible, the potential for i
surface and ground water contamination. The staff therefore concurs with DOE's i
proposal to dispose of the tank and sludge at the Mexican Hat dispu:a1 site, as described in DOE's letter of January 22, 1991.
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nd O. Gonzales ProjectManager Case Closed:
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P.O. Box 5400 A1buquerque, New Mexico 87115
Dear Mr. Matthews:
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We have completed a preliminary review of the Remedfal Action Plan (RAP) and supporting documents for the Mexican Hat / Monument Valley (HAT / MON) UKTRA project which you transmitted with a letter' dated Jandary 20. 1989.
Based on this review, we have concluded that the information you provided is not in a form sultable to enable us to complete our review.
The decision to relocate the MbN tallings to HAT was nqt made until af ter you had issued the RAP for HAT fn July 1988. This decision represented a major change in the proposed remedf al action, since the July 1888 RAP for HAT addressed only the stabf11 ration of the tallings at the NAT site.
In order to address this change you provided Modtfication No.1 to the RAP (RAP Mod.1) in your January 20, 1989, submittal. This modification provided additional Information and discussed changts that have to be made to the RAP; however, it did not provide a design package for the combined site. Some sections of the RAP require renumbering or rep' acement, and pencil changes must be made to the text in the RAP. We also noted that some of the figures in the supporting documents provided with your January 20 1989, letter are incorrect in that they do not reflect the final design. Ihisisapparentlyduetohavingaset of drawings and specifications for HAT and a separate set for MON.
In order that we may complete our revfew of this RAP, we request that you revise your January 20, 1989, submittal to reflect a single up-to-date RAP containing all of the changes in RAP Mod.1, and accurately describe the remediation plans for the combined site. Any drawings:and spectfications that are no longer valid should be deleted.
As your funding and construction for the HAT / MON project has been delayed untti 1992, this request should not adversely n'fect your schedule.
It should provide you an opportunity to provide a MP that is free of ambiguity and PM:UR Pr d sunfoIR!v EHe ns W l' REHall Ior//w/'2
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2 FEB 1 3 1991 uncertainty such that our review can be accurately completed.
The requested information should be provided in time for NRC to review and concur prior to your planned start of work on the project in 1992.
Should you have any questions, please contact me or the Project Manager, Ray Gonzales, at FTS 776-2805.
Sincerely.
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'D6cket No.' 6 63 Docket No. )#f-70 s
MEMORANDUM FOR:
Docket i fle Nor. W-63 and WM-70 FRON:
Raymond O. Conzales ProjectManager
SUBJECT:
MEETING TO DI?CUS$ SEEPAGE AT THE MEXICAN HAT SITE g
DATE:
August 7, 1990
Participants:
10E/ CONSULTANTS Gonzales
- . Daaler Ra Hall J. McBee Gary Konvinskf J. Cercone
,0. Metzler C. Walch R. Claire Summary of Olscussions: D0t requested the meeting with URF0 to present the results of Investigations performed by its consultants to characterize steps s,
which have developed downgradient of the Mexican Hat site.
Status of Profut Funding for b HATAOf p'roject has been cut, and construction has been ters noted. Future funding is uncertain, although construction probably will not be resumed until fiscal year 1991, at the earliest.
Se@sse Investinations:
Several seeps have been identifled downgradient of the HA"/ MON disposal area. 00E's remeflal action contractor han set up a systsee to monitor water quality and quantity of the seeps. Data collected over several months show the total amount of seepage to be esall about 0.5 gpe.
The flow rates in some of the steps are slowing downNE vl'1 continue to monito up once the tallings have been reclafsed.
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1 seeps for at least a full season. A report is currently being prepared that will be subeltted to NRC by the end of August 1990.
A preliminary conclusion reached at the meeting is that because the total flow rate is so small, the seepage does not appear to be a problem even at the present time. However, once reclamation of the plie is complete, the seepage l
will become even less of a probles because the flux through the tallings will I
be greatly reduced.
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URF0:ROG Docket No. t#t 63 Mr. Mark L. Matthews U.S. Department of Energy Alboguerque Operations Office p.0. Con M00 Albuquerque, New MenIce 47115
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Dear Mr. Matthews:
In response to year request, we how revleved the Artlen of the Mexican Hat fInel rap pertafnIng to the rfprep to be t9ed for eresfen protectien. You propese te use the Nielsen Quarry near Bluff,80,* you propese te use the shad litch, for bedding and for riprep types "A' and "S."
For rfprep typee "C" and Mountafn Quarry or the Abejo Peak eeurce. Rock durabi1ity wf11 be detersIned usfng the scering eriterIa shown fn table 022 FIN =A, whIch fa presented fn Velmo II of your January 1909 Modificatten to the Final RAP and lite Desfon.
i For the rock to be acceptabte, the score will be not less than el percent for the bedding and no less than 80 percent fee the Pfgrep types.
The gradations of the rfprap shall be as proposed on page 0227M s of Volume II of yeve January 1989 medIfIcetfen to the Ffnel RAF and SILe Desfgn.
ife have reviewed yevr riprap calculetiens s'nd proposed specIfIcatfens and conclude that they are acceptable.
I If you have any queatiens, please contact. Ray Gentales ef my ataff at Fil 716 2819.
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Uranius Mill.allines Probect Office U.S. Depensent of (nergy
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5'W Dew Mr. Matthew Qt t ', e OnanAprl)6,1999sitevisittotheMexicanHat.UtahIMTRAproject our mes being eeded to the tallings to sentrol winelsen material and to aid Secewe of the problems sew ed by the saturatten of the Durango laplacement.
we are senterned of the potential for a slallar j
tallings at Sees Cariyon,Mealsan Hat., If induced estoration of the Mexican i
situat en developing at Met /Menassent Valley taillnes resulte f a'ecepage fate the perched ground water below and adjetent to the tallinger then reclassification of the perched ground water of the Malpelte Shale weele to considered. As discussed below, this perthed water is not presently considered on equifer, there is the additional probles that escess water introduced into the tellings could result in unenoptable elfferential settlement of.the plie.
As e restit of a revlew of st[Nthe,Apell 8,the upper Helgatte shale 1989 site visit, the NRC f
stoff has censleded that the perched ground veter of The i
is not en 'agelfer and therefore not a portion of the Uppersest Agulfer.
a water was created by the tesis of this contle lse is that the perched Menigen Met arenfue appellent,and Is no evidence to suggest i
l Intersonnu tlen to e na 1 equifer.- 2) espability of discharge to er(3)eteessibility the site boundary. However,be (1) face water lf advised that ev4dente of f ese9ept is eteverine des to addition of Ser esostruttlen water, the perched g +round We e el $ t be intfuse 40$.0 my1ge
/A appevant Agelfer.
c fe ellow es te essess this pegelbill e lease provide for review a water fan the 200,000 Oaltens per day water bedset/belence that teles late senel the spelleetten, Infiltretten late the teillnes, and seepage potential, regneted water budget.sneeld e,lse. tete fate.sentiderati.on the.eter.d.eu aia-o te
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l At this time, we are reqwsting that you propose background and point of compilance wil locations for the Honaker Trail Formation, the Uppermost Aquifer.
If you have any questions, please contact either myself or Scott Grace of my staff at FIS 716 280%.
$1ncerely, 4
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%m therd F. H ine Branc CMhe Uranium Recovery Field of fice Region IV cci
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Docket No.14163 040WO63705E Mark L. Matthews. Acting Project Manager Uranium Mill Tallings Project Office U.S. Department of Energy i
Albuquerque Operations Office P.O. Box 5400 r.
Albuquerque, New M'alco 87115 Dear Mr. Matthewr the Mexican Hat Remedlal Action Inspection Plan RAtP) dated Marc We are in receipt of your March 18,'1989 Based en ear review we concur in the portion of the RAIP dealing with reworking of the taIllnus. Concurrence on a RAIP for all site activities will.
require review of the t'nal' Remedial Action Plan for the site.
If you have any questions, please contact D. L. Jacoby of my staff on FT5 776-2805.
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We are in receipt of your February 20,1989 letter requesting approval to relocate the Monument Valley tallings to the Mexican Hat site prior to our formal concurrence. We see no reason why the Department of Energy cannot proceed with relocation of Monument Vallq tallings to the Mexican Hat site while we continue our review of the, site remedfal action.
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Dear Mr. Matthews:
We are in receipt of your Janus'ry.10,1989 letter which transmits Revision B of the Mexican Hat Remedial Action Inspection Plan (RAIP) dated January 4, 1989.
This revision was to have incorporated all changes previously discussed; however, the modifications proposed in your November 29, 1988 letter are not included in the document. Also ieven though the document was not reviewed in detail, it was noted that changes had been made in Section 5 without change indications. All changes from the previous document should be clearly
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As soon as the procedures discussed {n your letter dated November 29, 1988, are includedintheRAIP{wecanconcurintheRAIPforreworkingofthetallings.
Concurrence on a complete RAIP for al) uite activities will require receipt of
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the final Remedial Action Plan for the site.
If you have any questions, pleaso contact Scott Grace of my staff,on FTS 776-2805.
, Sincerely,
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We are in receipt of your June 22, 1988 letter forwarding respe..ses to our April 14, 1988 letter on the Mexican Hat site.
In this letter you requested our opinion on whether or not resolution of the three open items could preclude you from initiating remedini action at Mexican Hat.
'I After reviewing your responses to our connents, we have concluded that resolution of the three open items (water resources protection, rock 2
source, and radon barrier design) does not preclude the Department of J,
Energy from initiating remedial action at Mexican Hat and proceeding as
'c far as reshaping and consolidating the existing tailings in place.
The resolution of the three open items can proceed independently.
u We also note your intention to subalt a modification to the Mexican Hat RAP to provide details on incorporating the Monument Valley tailings in September, 1988.
If you h o e any questions, please contact Scott Grace of my staff at FTS 776-2805.
Sincerely, pl i.
Edward F. Hawkins, Chief n-
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Dear Mr. Arthur:
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We have received and reviewed the following submittals pertaining to the Mexican Hat site; (1) the preliminary final Remedial Action Plan (pfRAP) submitted January 24,1988, (2)(the final' design for review documents submitted August 18, 1987, and 3)yourMarch 24, 1988, submittal, responding to our March 2, 1988 comments.
In our review to date, we have found the following areas to be in accordance with the NRC Standard Review Plan and therefore acceptable:
erosion protection design (rock (1) site geology and seismology (2)llies and diversion ditches (assuming size) of the pile to), outslopes, gu that oversizing of tie rock is not required)g (3) the design events (ProbableMaximumPrecipitationandProbableMaxtausFlood),and(4)the liquefaction analysis.
These items are detailed.in Enclosure 1.
e Areas reviewed that were found to be incomplete and/or unable to be
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reviewed to date include; (1) water resources information pertaining to w
compliance with the proposed EPA standards, including evaluation of cover inflitrationandjustificationforsupplementalstandardsforthe uppermost aquifer, (2) specific information on proposed rock source includingsizingevaluationandadiscussiononwhythediversiondltch slo does not require a flared outlet, and (3) radon barrier designstability, c These items are also detailed in Enclosure 1.
We understand that it is your intention to classify the ground water in the vicinity of the site as Class !!! ground water. As discussed in the enclosed comments, we are skeptical that the uppermost hydrostratigraphic Q t1 m e u M+
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WM-63/SRG/88/04/13/0 APR I 4 1988 2-i unit can meet the definition of Class III ground water as used in 40 CFR Part 192.11(e).
Additionally, the information presented in the submittals indicates that this upper unit is an aquifer as described in our March 28, 1988 Draft Technical Position. You will also note that we feel it important to establish a ground-water monitoring program at the site in the near future in order to determine a representative background water quality and designate location (s) for pointiof compliance well(s).
These items are also discussed in the attached cominents.
rt Please keep us informed on when additional information can be submitted.
Our review of the proposed remedial action cannot continue until we i
receive the specified information.
We are aware that DOE is considering the possibility of relocating the
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tailings from the Monument Valley site to Mexican Hat. Please keep us informed on the developments of this possibility as it will affect much of our review and conclusions.
I If you have any questions, please contact Scott < / ace of my staf f at FTS 776-2805.
Sincerely, ISl Edward F.'Hawkins, Chief 1.icensing Brar.ch 1 Uranium Recovery Field Office Region IV
Enclosure:
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PRELIMINARdFINALREMEDIALACTION/ PLAN (JANUARY 1988)
AND FINAlt;0ESIGN FOR REVIEW DOCUMENTS (AUGUST 1987) w i
- 1. 0 SITE GE0 LOGY AN0' SEISMOLOGY
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1.1 A review of theigeologic conditions existing at the site preclude the likelihcod 6f poor foundation materials, ground settlement, and hazard due to slope instability or cree'p. A review of the site seismicity data in the final design for review documents (Volume III, Section 9-238-01) indicates little or low probability that ground accelerations at the Mexican Hat site could exceed the design earthquake. Therefore, the section on site seismicity was
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found to be in accordance with the acceptance criteria set forth in the SRP (Reference 1) and therefore ace'eptable.
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WATER RESOURCES
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2.1 The March 24, 1988 submittal contained i brief discussion of how the remedial action'at Mexican Hat will be ifn compliance with the proposed EPA grouthwater standards.
In this discussion is an evaluation of the factors that make the" site suitable for the application of supplemental standards by defining the ground water
'n the vicinity of the site as Class III under 40 CFR Part 192, Subpart B.
The staff agrees that the lddle and lower hydrostratigraphic units could probably' meet the definition of Class III ground water (as specified inI40 CFR Part 192.11(e)) and
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therefore, be applicable to the supplemental standards of Subpart C.
However, additional information is required for the staff to make a determination on whether or not these units are consistent with the definition of Class III ground water. The staff is the upper hydrostratigraphic can meet the definition, skeptical that of Class III ground water or not be considered an aquifer. As discussed in Section 2.1 of the NRC Draft Technical Position (Reference 2), any saturetad zone crected by uranium recov'ery operations should not be constared an aquifer unless the zone is or potentially is (1) hydraulically interconnected to a natural aquifer, (2) casable of discharge to surface water or (3) reasonably accessible Decause of migrationbeyondthevertic,alprojectionoftheboundaryofland transferred for long ters government ownership and care. The staff consider the upper hydrostratigraphic uriit to be an aquifer as this unit is capable of discharge to surface water. As discussed in your submittals, therv are discharges of tailings seepage via the upper Juan River. graphic unit to Gypsus Creek,ively conclude that the hydrostrati and possibly the San Therefore, the staff tentat upper hydrostratigraphic unit is part of the uppersost aquifer, not subjecttoclassificationasClassIIIgroundwater,andaccordingly 1
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Regardless, additional information on site hydrogeo. logy is necessary to adequately evaluate this aspect of the Mexican Hat site.
If DOE wishes to pursueithis issue, they should submit additional information to to address the three criterion in Part 192.11(e) as well as information addressing the thre'e criterion in Section 2.1 of t.he NRC Draf t Technical Position (Reference 2).
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2.2 As the upper hydrostratigraphic unit will probably not meet the h
definition of Class III ground water, additional information will be necessary for NRC to evaluate compliance with proposed EPA t-regulations. Ofcprimary concern for the near term is the implementation of an integrated ground-water monitoring program as required under 40 CFR Part 192.12(c)(1) sand discussed in Sections 2.1, 2.4 and 3.3'of the NRC Draf t Technical Position (Reference 2).
k As part of this monitoring program, a methodology for determination g
of a background Water quality for the uppermost aquifer (upper i
hydrostratigraphie unit) should be deve' loped soon in order to allow setting of concentration limits for the3 hazardous constituents.
The NRC staff are aware that this aquifer was saturated as a result of seepage from the. tailings and that an upgradient background well may be impossible to' locate. Regardless a* method to determine a representative background water quality 4must be developed and proposed. As part of the monitoring program, point of compliance well(s) also need to be located. The staff also note that only limited ground-water data exists for ther Mexican Hat site and that more current site' data say be necessary3to evaluate proposed locations of background and point of compliance well(s).
Therefore.
DOE should propose a ground-water monitoring program that specifies a procedure to determine a representative background water quality as well as locate appropriate point of compliance well(s).
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2.3 The pfRAP contains no evaluation of potettal infiltration, only a conclusion that the stabilized plie will be covered with very low permeability materials which will present a barrier to infiltration.
The staff reviewed the permeability testing on the proposed cover material located in the March 24, 1988 submittal, but note no discussion on which tests are representative of the material to be used for the cover. When the cover design is firalized and a borrow material selected, DOE should submit a discussion on the hydraulic characteristics of the cover material as well as an evaluation of the potential for inflitration through the cover, tailings and the unsaturated portion of the u)permost aquifer.
As part of the evaluation, consideration should ae given to a method (s) to confim the ability to achieve minimum hydraulic conductivity in the cover.
This may be necessary for th'e staff to evaluate whether or not the proposed design will prevent.further leakage and contamination at the point of compilance.
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l 3.1 Thestaffresiewedthematerialpre(entedby00Eandconcludedthat there are nonother credible sourcestbf potential flooding that could adversely affect the reclaimed pilei. The staff also concluded that the design ev;ents (Probable Maximum Precipitation and Probable Maximum Flood; PMP and PMF) meet the criteria outlined in the Standard Review Plan (Reference 1) snd are, therefore, acceptable.
54
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3.2 The staf f ru,iewed DOE's calculation's and performed independent analyses to verify the adequacy of the riprap.
These analyses were performed using procedures discussed in NUREG/CR-4651 (Reference 3).
On the basiscof these independent calculations, the staff concluded that the erosion protection design of the pile top, outslopes and gullies meets'the acceptance criterion of the SRP (Reference 1) and
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is thereforetacceptable.
s 3.3 On the basis of review and independent analysis, using procedures discussed intNUREG/CR-4651 (Reference 3) and the design basis events, the staff has concluded that the riprap sizes proposed by DOE for the key trench of the North. Ditch and for the entire West Ditch and Diversion Ditch are accepiiable. However, if during construction;4 DOE finds that the area where the North Ditch is being excavated does not contain competent rock as was assumed in designing the' ditch or if the surface of the rock is below the PHF level, a newidesign may be required / DOE should submit information confirming the assumptions or submit a new design for review and approval.
The staff will also require that DOE explain and justify the reason for not providing a flared outlet for the diversion
't ditch.
3.4 The rock proposed by DOE to be used as a source of riprap is C
limestone from the vicinity of Alhambra Rock.
The staff in a letter dated October 16, 1987, provided comments to DOE on.their evaluation of the proposed rock but no response has been received.
Therefore, approval of a rock source by the staff will be delayed pending receipt from DOE of a re-evaluation,of the acceptability of a rock source.
If a new rock source is proposed, the riprap designs of the i
pile top, outflopes, gullies and ditches may have to be evaluated to i
assure the adequacy of the design.
If this evaluation indicates j
that the rock has to be oversized, the specifications will have to be changed to reflect the increased! rock sizes.
The staff notes that in designing riprap DOE used a rock specific gravity of 2.64.
Since the specifications call for a; minimum specific gravity of 2.5, this lower value should be used in riprap design, i
c' 4.0 GE0TECHNICALLSTABILITY 4.1 The staff reviewed DOE's liquefaction calculation and performed an independent evaluation to determine'the potential for liquefaction l
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The independent study of the material presented has resulted in the staff position that the soils at the site will not be' susceptible to liquefaction of any consequence.
4.2 The slope stability calculation indicates that the long-term static and pseudo-static stability factors of safety for the reclaimed structurewillmeettherequirementspr(sentedinRegulatory Guide 3.11 (Refe'rence 4). A review of.the supporting data indicated that the calculation is representative of site conditions and meets, k
the general requirements of the SRP (Reference 1).
DOE must submit a discussion of(why a pseudo-static anaIysis is appropriate for this site before the. slope stability analysis will be acceptable.
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4.3 The final radon barrier design has not been submitted, and preliminary designs presented are not based on site-specific soils data from the proposed RB-4 and RB-7 borrow areas.
The "Information d
I for Reviewers" (MKE Occument 5025-HAT-R 01-00769-001 contained in Appendix E) of +.he Remedial Action Plan,h further indicates the currently proposed radon barrier thickness may undergo major design changes.
Additionally, URF0 has not received a complete soil testing package from the RB-4 and RB-7 borrow areas.
The adequacy of the selected soil and the radon barrier design will be reviewed when the information is submitted.
4.4 The construction specifications for the ' radon barr'ter materials will also require revision to reflect the new materici sources and design.
The present material specification is representative of most soils and therefore cannot be considered suppertive of any specific design.. The construction specifications did not include moisture control during construction for uncontaminated fill materials.
This information should also be included in the review.
Additionally, as the stability analysis modeled relocated tailings
<L compacted to 95 percent of the maximum dry density, the specifications should support this design.
4.5 The settlement calculation review is not complete at this time.
The review, including the void reductioti specifications, will be completed and any comments will be forvarded in the near future.
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REFERENCES 1.
U.S. Nuclear Regulatory Commission, " Standard Review Plan for f
UMTRCA Title I Tailings Remedial Action Plan <," USNRC, Division of Waste Management Report, October 1985.
2.
U.S. Nuclear Regulatory Commission, "Information Needs to Demonstrate Compliance with EPA's Proposed Ground-Water Protection Standards in 40 CFR Part 192, Subparts A-C,'
- USNRC, Division of Low-level Waste Mariagement and Decommissioning, Draft Technical Position, March 28, 1988.
3.
Abt, S. R., et.al., " Development of Riprap Design Criteria by Riprap Testing in Flumes: Phase I," NUREG/CR-4651.
4.
U.S. Nuclear Regulatory Commission, Regulatory Guide 3.11 " Design, Construction and Inspection of Embankment Retention Systems for Uranium Mills," December 1977.
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W. John Arthur, III, Project Manager Uranium Mill Tailings Prolect Office U.S. Department of Energy Albuquerque Operations Office P.O. Box 5400 0
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Dear Mr. Arthur:
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We have completed an acceptance review of the HeKican Hat preliminary final Remedial Action Plan, (pfRAP), submitted January 29, 1988. Our acceptancereviewconsistedofacursoryreviewffthepfRAPandthe final Design for Review documents transmitted bylyou on August 18, 1987.
This review was postponed; at your request, in order to complete our review of the Tuba City UMTRA Project RAP. s The areas reviewed included surface water hydrology and erosion protection, ground-water resources protection and geotechnical stability. The acceptance review indicated that the two sets of documents appear to be comp 1.ete, except with respect f,
to ground-water protection. To expedite the review, we have enclosed some comments that were generated as a result of +the acceptance review.
y We recommend that responses to these comments be;. transmitted as soon at;
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available.
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r As you are aware, the NRC can no longer provide conditional concurrences
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of proposed remedial actions absent analysis of ground-water protection measures showing compliance with the proposed EPA ground; water protection
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standards (52 FR 36000, 9-24-87). The acceptance review indicated that c'
the pfRAP and design documents have not specifically discussed how the e
remedial action at Mexican Hat will be in compliance with the EPA Y
ground-water protection standards.N We realize that the pfRAP and design documents were submitted to us prior to the NRC-Headquarters February 9 L
1988 letter to you. However, an evaluation of the Mexican Hat remedial h
action must be submitted prior to any concurrence on the proposed O
remedial action.
At this. time, our intention is to provide you with a L.f
,4.MfxTrHY 1
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letter indicating that we are prepared to concur upon resolution of specified open issues.
There was an area of confusion identified in our acceptance review that needs clarification.
It concerns the specific borrow area proposed for the radon barrier material. addresses our comments.
Please respond to these two items and inform us as to when you plan to submit the ground-water protection evaluation. Should you have any questions, please call Scott Grace or myself at FTS-776-2805.
Sincerely,
/J5Q r'
Edward F. Hawkins, Chief s
Licensing Branch 1 Uranium Recovery Field Office Region IV
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Comments on Radon Barrier Borrow Area Preliminary Final Remedial Action Plan
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and Final Design for Review Documents j
t There is considerable confusion on what borrow area is being proposed for the radon barrier material.
For example:
r pfRAP '.1/88);!page 29 - indicates that areas "TZ" and "A" as shown on Figure 3.10 are to be used for borrow material, pfRAP (1/88),eAppendix D, page 0-178 - indicates that the primary borrow will be "A" and that "TZ" will be used as a backup.
It further states that the " final design contains information on borrow area A."
pfRAP (1/88), Appendix 0, Addendum D4 - contains logs of borings HAT 01-501 through -510, with no exploration location maps or borrow 10.
Laboratory testing on samples from these explorations are summarized in Appendix 0, Borrow Material Characteristics (assumed from area "TZ").
pfRAP (1/88), Appendix E, Drawing HAT-PS-10-0954 (7/87) - indicates the locations of " Radon Barrier Borrow Area RB-4" and " Radon Barrier Borrow Area RB-7."
There is no reference to areas "TZ" or "A."
+
pfRAP (1/88), Appendix E. MKE Document 5025-HAT-R-01-00769 Indicates that the radon barrier thickness is based on data from the "TZ" borrow and that the final thickness will be adjusted based on September 1987 testing of material from "RP-4" and "RB-7" borrow areas (available ir. November 1987).
It also indicates that the
.'Y percentage of bentonite that is to be added to the radon barrier borrow material will be based on a laboratory testing program.
It further states that the quantities of materials available in borrow areas "RP 4" and "RP 7" are unknown.
Volume !! Cal. 9-239 05, pane 4 -
Final Design for Review (7/87),from mater lal from " Borrow #4d were Indicates that soil properties used in the thickness calculation. MKE Occument 5025-HAT-R 09-00593-00 is referenced in the text and on the borrow area soit properties summary sheet on page 27. Our office has no record of receiving this report "from Lambert & Associates, dated May 1987."
It is assumed that'the specification drawings in Appendix E of the pfRAP are correct and that the proposed source'of radon barrier material will be areas RB 4 and'RB 7.
However, there appears to be no data base for this materla1.
Therefore, before any additional review can be performed, t
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E the soll testing data from RB-4 and RB-7 should be submitted.
Also, it would be prudent to clarify which borrow is to be used in all locations within the pfRAP and to address how the borrow area change will affect the other calculations, such as stability.
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Mr. John R. D' Antonio 6
5 Operations Group Leader U.S. Department of Energy 7
Albuquerque Operations Office l'
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-Albuquerque, New Mexico 87115*
Dear Mr. D' Antonio:
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i In a letter dated July 31,1987, you requested that we review a report f
titled, " Evaluation of Rock for Riprap at Mexican Hat. Utah." We have completed our review of your submittal, and our comments are enclosed for g
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your consideration.
In eummary, you have not arovided sufficient information to. justify the use of the proposed Alhamars 11eestone or the oversizing methodology.
Additionally, you have not provided adequate basis:for the conclusions on the other two rock sources which appear to contain batter quality rock.,
i You conclude that the first of,these sources contains gravels that are too small, and the second is too far to be economically feasible. You shouldjustifythattherockfromthefirstsource.fstoosmallby comparing it to the riprap site required for the top and outslopes of the i
plie.
In addition, 'if it is not economically feasible to obtain rock free the second,learly excessive.you should provide additional info'rsat that costs are c A procedure for:doing this is O*
suggested in Reference No. 5 mentioned in Appendix 8 of your riprap report.
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If you have questions, please contact Ray Contales of my staff at
$1ncerely b }1 FTS 776 2818.
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Q]Sf Edward F.' Hawkins Chief Licenst]BranchI
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EVALUATION OF ROCK FOR RIPRAP AT THE MEXICAN HAT DISPOSAt.' SITE e
UMTRA PROJECT
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MEXICAN HAT, UTAH s
p il The rock you proposed to use for erosion protection, does no( meet 1.
the criteria for good quality rock. However, you conclude that with appropriate oversizing, the rock can be used in occassionally The saturated areas but not in frequently saturated areas.
oversizing methodology you propose to use is the same as that used at the Lakeview site. Although the NRC staff agreed to the use of marginal quality rock at Lakeview, that decision was site specific and the oversizing' methodology was meant to apply only to Pepperling quarry rock at Lakeview. It was not intended to apply to all UMTRA Therefore, if an oversizing methodology is necessary at profects.
In MexLcan Hat, it should be developed specifically for that site.
developing that methodology, you may want to consider additional and/or dif forent durability tests, changes?to the scoring methodology or changes to the oversiting factor.
L You state that because the Mexican Hat site is located in a sentarid 2.
desert climate and the slopes of the ditches provide adequate drainage, all of the areas requiring riprapscan be considered as occasionally saturated. Consequently the rock durability can be It is the NRC tess than required for frequently saturated areas.
staff's position that aprons, natural channels and man-made diversions must be considered to be frequently saturated areas even if they are located in desert c1fsates and are well drained.
Therefore, the rock >you propose to use is not acceptable for use in diversionditcheswithoutfurtherjust{ffcation.
~
Oversizing marginal quality riprap by using the wetoht of the Dso 4
stone as you propose, appears to De a more reasonable approach than 3.
The.probles however, oversizing by using the dieseter of the stone.
I is that at the present tisei there is no accepted procedure forTh oversizing using weight.
is based on rock dfaaeter and thus is not appilcable for oversiting by weight as you have proposed.- Using the procedure from the NUREG This means that you calculated an oversizing factor of 53 percent.the diame 1
the oversfred Oso. You propose to increase weight instead of diameter tr/ 53 percent. This results in an increase in the Oso diameter of only 15 percent, because weight is proportional to the diameter cubed.
The purpose of oversiting marginal quality riprap using weight instead of diameter is so that the asaller rock is oversized by a l
proportionallygreateramountthanthelargerrocktoallow j
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of the maximum, rock size available, which you state is 12 inches.
Therefore, oversizing by 15 percent instead of 53 percent is not acceptable unless you can demonstrate that the rock will provide the erosion protection necessary to ensure stability of the reclaimed tailings pile for 1000 years, but at least 200 years.
4.
You identified two ' sources of rock that appear.to be more durable than the rock you propose to use as a source of riprap. One of these which you identify as the El Capitan source, is located about 40 miles from the Mexican Hat site and the other, identified as the Bluff Holiday Pitc'is about 26 elles fromithe site. You state that the El Capitan sou'rce is considered too distant to be economically feasible and the Bluff Holiday P't contair.s gravels which are not of sufficient size td meet design reystrements.
Of the total volume of riprap required, only about 8 percent will be used in areas where larger, more durable rock is required. You should therefore provide additional information to show that the t
cost of providing 8 percent of the rock from the El Capitan source is clearly excessive..
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5.
You have not provided any information on the size and gradation of the rock available at the Bluff Holiday Pit, except to say that it is too saa11 to meet design requirements.:, The riprap proposed for the plie top, which you oversized by weight using a factor of 15 percent, is small rock having a Oso of 2.0 inches and a Dioo of 3.4 inches. For the plie outslopes, the riprap is a little larger.
having a Dso of 4.3 inches and a D os of 7.3 inches.
Even if the i
riprap was to be oversized by diameter instead of by weight, using a factor of 53 percent, the required rock would att11 be relatively small. You should therefore provide additional information to justify that the rock from the Bluff Holiday Pit is smaller than reqvfred for the top and outslopes of the reclaimed plie.
If it is of sufficient size, but it is not economically feasible to obtain rock from this source, then the costs of obtaining this rock should be discussed and shown to be clearly excessive.
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Docket No. W-63 m
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r MEMORANDUM FOR:
Docket File No. W-63 r
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Scott R. Grace, Project Manager y
FROM:
Licenting Branch 1 p
Uranium Recovery Field Office, Region IV g,
SUBJECT:
STAFF: REVIEW 0F D0E'S JANUARY 22, 1987 RESPONSE 3, '
TO 00R CoWENTS ON MAXICAN HAT'S ORAFT REMEDIAt g k>
ACTION Pl.AN r..
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)f, identified no additional; comments on D0E's responses.
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1 Approved by:
f,t Q Idward F.,Hawalns. Ghler i
ticensino Branch t w iN -
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E case Closed: 040W063W
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MEMORANDUM FOR:
Docket File No iM 63 FROM:
Scott R. Crace, Project Manapr Licensino Branch 1 Uranium, Recovery Field Office.. Region IV 1
STAFF REVIEW 0F 00E's JANUARY 22, 1987 RESPONSE
SUBJECT:
TO OUR ComENTS ON MAX 1CAN HAT'S ORAFT REME0!AL g
ACTION PLAN
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The staff has reviewd the subject esterfa1Ytith particular attention to 00E's responses on the comments that individual staff were responsible comments on 00E's The staff have identified no additional.!.e for.
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W URr0:5RG Docket No. E 063 040lm063401E James Anderson. Project Manager m
Uranium Mill Tallings Project Office
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Department of Energy P.O. hz HM Albuquerque. New Mexico 87115
Dear Mr. Anderson:
f s-Q' We performed a coupleteness review of the requested portions of the pretteinary design documents for the Menfean Hat. Utah. UMTRA site, 1987. The areas that you asked subeltied by your office on January 27,l and surface water hydrology as to miew wre prleartly geotechnicaOur completeness rovfew Indicated that the seisafe portfons were not sufficiently cosplete to warrant a miew byOu related.
the URF0 staff.
final design documents are subaf tted.3 The surface water hydrelogy sections were determined to be complete and the review f t in
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a, Dear Mr. Theself si g
We have counleted eer review of t Draft heaedfal Action plan and lite Conceptual #sfon for Stab 11laatien af the Mexican Met s1te. As we e
agreed, ear rev' ew consisted of a bread everview of the document looking M
for " fatal flaws," unaddressed areas, and sufficiency of basic data and I
infetustion. To scenerf te the enciesed cessents, there appears to be no sujer problems with the preteled resedial action. The cessents tend to address sore spectffe technical guestfons and 1ssees that should not y
drastically affect the overell plan.v At this point, there does not seen y['
to be such value in seettne to ever these comments. If you feel that a meeting would be beneficial lease let et kase.* Mowever, we should
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plan to meet when more detall designs are tuhoitted for review.
WE.MirwmehpulMee' r:
lhould you have any gustfont reger ing ser rettew or the ttees disevsted gf in the enclosure, please contact me at Fil 776 2806 er Howard Rose on w.'
fil 116.fsle.
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- 1. Page 14. Section 3.,t.t'yfd
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Once annual average 101 t!! levels are obtained from the current monitoring program,' provide the results to the NRC. URF0.
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$5 Pep M. Destp Rationale '3W. kn }r b'*
2.
t n &%Cm iten No. 2 Provide substantiation'that using average valus of the p
reson omenating fraction from both the upper and lowr piles is serenate to describe the emanating frettien for the materials reasonably conservative. ge, mill yard and windblown areas a inc1 weed in the ore store The IIRC's SR? directs usaw of a 4
0.M emanating fraction for seterials not specificaLly esatured.
The emenating frattlens from Ra.ftl activities for the upper plie asterial respel fres !!0 330 pC1 and evereges 0.20 t 0.05.
Accordingl ts required for these unmeasured
- 'I*h*y, an E of at least 0,
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- 3. Page St. Dett y Celteria, peregraph 3
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Arview of the reported tilmtelegical; data Indicates that harsh
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winters and perleds of snow cover are infrequent for this region.
for esssele, etterding to the DtA for ebest e 20 year period.
Mrsicen Mat received en enneal averste snowfall of 3.3 laches. In edditten,all nerupt sestaus senthly tauperatures were abeve 4 !
freezing, ahlle only 4 monthly mornal.sinimum taspersteres were
/
telaw freeting. Theti it is entremely alltely that frost will penetrete the rett and beddin seterial and Ineset the redon barrier esterial. Therefore the a laments in the ORAP that ' harsh' winter f
gendillansaddenedittent lafety to the design are not verrestedforthis811 stay pgifM e
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- 4. Page 80
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IM to S 11 and il percent Provide the bar lettlen va set terrnI s terials and discuss. how t
V solltere centents for Ut fruents,p g
corresp ed te the me
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Page B 11 bottom paragraph Discuss the quality control field procedures that will be uttif red to assure that the assumed volume weighted average Ra.226 If field OC procedures will not be used, concentratten is accurate.
then a substantiated conservative Ra 226 concentration must be used.
v 6.
Page 8 14. Section 8.4.3 last paragraph g
Although the material which comprises the three distinct areas of offstte contamination only accounts for about 1 percent of the total volume of contaminated material, it is (sportant to note that this Please N'
noterial is the'vpperanst layer of contaminated material.
refer to cosaurnt no. I for specific required information.
1.
Page 8 11. Winelown material c
e s,
,s Describe the lower permeability esteridis that this layer will be sandwiched between, and provide the respective long term permeabillttes and the ballt for,the assumed value.
, e 3e 8.
PageB17.RadonBarrfer.(smanended)~p
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r Since only)one sample wel used(from th'o winelown, re (unasended respectlye long. term solltere content. It seems reasonable to assume a sore conservative long ters mellture content eveer for the unanPeded red 6n barrier cover layer. The NRC's SRP requires a value that terrelates to the all Sar settfon vales theeld be vled for the (i
The value long term politere testent of the reden herrier meterf al.
proposed in the DBAp (65) terresponds sore elesely to the 2 bar valee, while f.65 terresponds to the all her vales. Accordingly, reelle the design to conllder the proper Rolltere content.
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- 9. Page 519. Settlen B.l.f,'first sentente
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Please clarifr and esplefn the notereJef the esterlat referred to in thefirstsentence, P{.
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- 10. Page 8.fl tecend perefreph
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gm the design thould t
Altheegh w agree that the' standard il f6 pCl/m't.d not necessarily he based on ressenably tenervettre allumptient an i
en mean valget of a few A Niersetell.
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- 11. Page t-71, third paragraph, first sentence e The NRC does not agree with the statement that the long-tenn smisture content is a conservative estimate of the motsture content of the lower unamended TZ 1ayer of cover mater {al (see coppent No. 8 above),
- 12. Pap B 23. Radon diffrtion coefficients State whether any site specifle 80' measurements intended for the offpilematerial(layer 3). If not, demonstrate that assumed values will be reasonably conservative.
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- 13. Pay 8 30. Section 3.5.6 No information is provided en a sensitivity (analys 2
ts.
Revisethissectiontoprovidethenecessary,ana paw 6 33. Section 5.5.7 sixth paragraph, second sentence 14
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A qualification should be added to this statement that 11 percent If corresponds to f 2 material amended with 7 percent bentonite.
ammdation of 72 material is willited appropriate diffusion coef ficient seasurements will be required. p
(( *f Geotechalcal pay 53. Conceptual deity ff.k (, I
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15.
A detailed analysis of differentist lettlaarnt will be required befere final concurrente in the,propeled dellp.
U'h
- 16. pap 69, first lentence LY-Provide a evality asserence p1m that will altere entform alming of the top i foot of~raden herrle tellt with bentonite.
,o w.9 if, pay 60. Dette R4tienste GbQ y
a w:
The dlicellion of Remedfal Attlen Alternatives for ground water 15 it lette se esplantlign of the bellt ans/or supportive i
defielent.
data to properly define e peritteler pelltfen en groved water i
b, retteratten, go there 15 no ballt shown for not laplantatik physical or sechanical 7
reglerationpreceduretfortheliteey.Ifthepelltlenonrettoration p
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r is for natural flushing of the hydrostratigraphic units impacted, more explicit information is necessary to explain the geochemical basis for why nAturaliflushing w{ll be adequate. This must include geochemical mechanisms specific to the site as well' as a thorough description of estimated time frames for natural flushing and how estimates were derived. Also, more explicit information is needed to properly describe dilution, natural buffering and estimates of concentration with time.
J
- 18. Page D-58. Site Geology Discuss in esplicit detail how the bedrock base existing beneath the f*.
pile will effect integrity and stabiltration. The effect of thermal contraction and expansion due to seasonal conditions needs further explanation with regard to creep and heaving of plie contents and cap.
i
- 19. Page D 58. Impact of Natural Resource Development It is stated that the top of the lower hydrostatic unit contains hydrocarbons. Discuss in detail economic aspects of the local area, with regard to mineral rights, possible petroleum withdrawal (presentandfuture),subsidenceandassociatedaquiferimpacts.
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- 20. Page 0 97. Strength ~
(
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s,
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A new test or tests will have to be conducted on siltstone existing at the site. Valid results for strength test (s) must be submitted.
it is not sufficient to relate the propertfes.cf other materials.
only valid tests conducted on rock meterial from the site will be accceptable.
ry a-y 21, pa 3 49. Settlement Effects on' Cover.Integlty and D 98 r
ygl{p De a Needs sult be conducted at the site to establish Coophysical survey (l)f the bedrock base existing beneath the site.
entent and geometry o
!! is possible that the rock geometry beneath the plie could jeopardfre integrity and stabilitation of the tallings and cover.
Surface Water Hydrotoey and froston Proteetten M
4
- 22. Page il f,
Provide addltIonal IMorsetton regardlag the erosion proteetion designs that are proposed to prevent'headcutting and erosion of the numerous evilles and arroyos at the lite. At the present time it I
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n is not clear what: types of designs will be used and how these designs will be implemented. Provide preliminary designs that show depth to bedrock and the general configuration of the erosion protection as it'is keyed into the rock.' These preliminary designs are needed in order to detennine the overall feasibility of the remedial action,Jparticularly for the gullies and arroyos that have large drainage arpas and/or have very steep slopes.
Include the following infonnationt l'
a.
gully configuration and cross-section b.
drainage area b
c.
riprap design to be used d.
depths to bedrock at each gully.
4
- 23. Page 51 c
i Provide preliminary designs regarding the proposed diversion channels and other natural channels at the site.
Information is needed for each channel, as follows:
1 a.
channel width, shape, and/or cross section b,
channel slope c.
drainage area d.
PW peak flow estimate U
i e.
PMF velocities f.
riprap requirements
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e g.
riprap toe requirements
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h.
exit velocity, exit design, and depth to bedrock at exit point.
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- 24. Page 61, Design Criter!a a rgy, < s, -
The NRC staff does not necettarily agree with the rock durability criterfs outlined in DOE's Technical Approach Document (TAD), and does not agree that these criteria are acceptable.
In general, the criteria in the RAD are much 1 ell stringent than other normally acceptable criteria, such as the USBR criteria for good quality rock, However, we do agree that oversiting may be a viable alternative and can only be, evaluated after additional durability J
"'" '" "' Mas #W Based on the prelfalnary' data proyldedff t does not ap ir that the
@d rock will meet US8R criteria for even poor quality roce. We suggest that additionalsefforts be perfomed to: locate rock of botter
'r qualfty, If such rock cannot be foundi 00E should indicate the methods and criteria that will be used ;to overstre the poor quality rock that il evallable. W 3$
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RBrich MAY 141956 EHawkins LLW Branch. WMLU
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- t U.S. Department of Energy %dV M
Mr. John Themelis
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-J Albuquerque Operations Office ji-P.O. Box 5400
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Albuquerque, New Mexico, 87115 M.
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Dear Mr. Themelis:
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b This will confirm our phone conversah,1on indicating that the Mexican
^
Hat / Monument Valley DRAP reviews are now scheduled to be completed by May 29, 1986. This extension is consistent with the recent realignment of priorities on the UMTRAP sites.uW;N. 3 t,
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E Should you have any questions %HR..i.Please contact me on FTS i
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,f.. Sincerely, 4
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Mit?@' l Howard'D. Rose, Project Manager
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'1.icensing Branch 2 Uranium Recovery Fie s
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Dear Mr. Themelis:
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Raymond 0. Gonzales Project Manager o e. <c t. fw:n.
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SUBJECT:
DISPOSA!. AT THE MEXICAN HAT' SITE'0F CONTAMINATED
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UNDERGROUND' FUEL STORAGE TANK 3i
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underground storage tank was uncovered.7A's{te'jnvestigation determinedjthat.",,
the tank is over 25 years old'and'Wis;1aisin service (in 1968. 2.Thei.tankais.4 :' -
r contains between 1500 and 2000fga$ds'sPdtamater:'bf St.fbet.it T approximately 25.5 feet.long'and has a consf atency that vhries.fromfthe~to:dow-level;lridioactive llo*ns:of, molasses.% 4 P. M t P3tst,q.tfj '
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- I6dicated tha't it is'most1[old diesel fuel with trace amounts of benzenes',jteluenebjand xylene as expectedd -
.t{.M The analysts also indicated that'the' sludge does'not contain PC8's and does not exceed any of the applicable EPA Italts (see Table 1).4 The sludge was also g# 9 tested for radfological contamination and found to contain Radon-226 at p*V i 48 pCf/g, Thorium at 28 pCf/g,'iand' total Uranium at<150.ug/g (see Table 2).-
These levels of radiological.contaafnation. exceed the UMTRA cleanup levels and thus the tank and sludge have to be' disposed.cf 11 an acceptable manner.
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In complying with this regulation. DOE notified the EPA and provided the results of the analysis performed on the sludge. Due to the radioactive nature of the sludge, EPA referred the removal and disposal management offjthe tank back to 00E.
6 Proposal e
DOE proposes to relocate the tank from the Monument Valley site to an excavation at the southe'rn end of the tailings pile at the Mexican ifat site.
The tank will initially.be filled with a sandy material distributed to cover the sludge at the bottom of the tank. The remaining space will then be filled with lean concrete. The excavation surrounding the tank will be backfilled and compacted to 90 percent of maximum dry density.,,
Covering the sludge with sand and lean concrete will minimize the potential for chemicals and radionuclides to leach out of the tank.
If a leachate does develop, it is highly unlikely that it will ever migrate to the uppermost aquifer because the aquifer is geologically isolated from the tailings.
Conclusion The staff concludes that the radioactive sludge in the underground storage tank is residual radioactive material as defined in Section 101(7) of the Uranium Mill Tallings Radiation Control Act of 1978, and therefore disposal at a Title I site is appropriate. The specifications developed for moving and disposing the tank will minimize, to the extent possible, the potential for surface and ground-water contamination. The staff therefore concurs with DOE's proposal to dispose of the tank and sludge at the Mexican llat disposal site, as described in DOE's letter of January 22, 1991.
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Dear Mr. Matthews:
you requested our concurrence in your proposal +to disp'osa We have completed our review of your' letter' dated January. 22,'.1991, f
I storage tank at the Mexican Hat sited The tank, whic1 kasluni:ovirediduring't i
removal of tailings from the Monument Valley. site', contains radiologically contaafnated sludge.
Since EPA has reviewed your analys{s' and,has.referre6the. removal.and disposal -
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of the tank back to the Department'of Energy.because;of!thCradioactive #ature we agree that burying the tank at.the! Mexican:Hatisite isi.
of the sludge,We therefore concur in your proposal, provided3that theitank 'is' appropriate.
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disposed of in accordance(with the specifications';provjdedhinfyour, January 22' a
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{0o,cket No., WM-70, MEMORANDUM FOR:
' Docket File Nos. WM-63 and WM-70 FROM:
'Raymond O. Conzales ProjectManager
SUBJECT:
' MEETING TO DISCUSS SEE AGE AT THE MEXICAN HAT SITE DATE:
August 7, 1990,
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E E 00E/ CONSULTANTS PartIcfpants:
HRC Rai Conzales E. Damler iRay Hall J. McBee J. Cercone Gary Konvinskt D. Metzler
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t-Summary of Olscussions 00E requested the mesting with URF0 to present the results of investigations performed by its consultants to characterize seeps h.
which have developed downgredient of the Mgxican Het site, cpm.A+. : u and Status of Projects Funding far the HAfhtNI pro ect has been cut,lthough construction has been ters noted. Future fundt is uncertain, a construction probably wl11 not be resumed until (scal year 1991, at the earliest.
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leveral seeps have been identiffed downgradient of the pepsoeJnvestinatfons 00E's remedial actfen contractor has set up a system to MT/ MON disposa area.
monitor water quality and quantity of the steps. Data collected over several about 0.5 gps. The flow months show the total enount of eeepage to be small rates in-some of the steps are slowing down..and 00I expects that they will dry up once the tallings have been reclaimed., DOE will continue to monitor the PM:URf PM i
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E seeps for at,least a full season. A report is cui 9tly being prepar.'d that will be submitted to NRC by the end of August 199
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A preliminary conclusion reached at the meeting is
.t because the total flow rate is so small, the seepage does not appear to be. problem even at the present time. However, once reclamation of the pile is complete, the seepage will become even less of a problem because the flux through the tailings will be greatly reduced.
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URFO:SRG Docket No. W-63 U
Docket No. WM-70 i
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Mark L. Matthews, Acting Project Manager Uranium Mill Tallings Project Office U.S. Department' of Energy Albuquerque Operations Office
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Dear Mr. Matthews:
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We are in receipt of your February 20's 1989 letter requesting approval tc relocate the Monument Valley tailings to the Mexican Hat site prior to our formal concurrence. We see no reason why,the Department of Energy cannot proceed with relocation of Monument Valley tallings to the Mexican Hat site while we continue our review of the' site remedial. action.
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's If you have any questions, please contact.ne'at FTS 776-2805.
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Docket No. WM.70 040WM070301E r
John G. Themelis. Project Manager Uranium Mill Tailings Project Office U.S. Department of Energy Albuquerque Operations Office P.O. Box 5400 Albuquerque, New Mexico 87115
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Dear Mr. Themelis:
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In accordance with your request dated March 21, 1986, we have reviewed the draft Remedial Action Plan (dRAP) for the Monument Valley site. The staff's questions and coments!are enclosed..,,,,.
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Based on staff review, we conclud that'the proposed remedial action plan is uhacceptable. Because of serious flooding and erosion conditions and potential foundation problems at this site, it will be difficult to provide a design which meets EPA standards and serious consideration should be given to moving the pile to,an alternate location.
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Should you have any questions' please contact either Randy Brich of my
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Our review of surface wat~r hydrology and erosion protection aspects e
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of the proposed design indicates that the site is, located in an extremely flood-prone area and that the proposed crosion protection ray not be adequate.
'I (a) The apron and crosion protection along the southern and northern portions of the pile tre designed with fairly steep t
slopes (inthedirectionofflow).
It is doubtful that the proposed 4-inch (average Drn) rock can resi'st velocities produced by a Probable Max bum Flood (PMF). Regardless of the size of the watersheds, the times of concentration for these portions of the apron will be very short and the PMF will likely be larger than expected due to the steepness of the terrain. Your conclusion that there will b'e no significant
- flooding impacts (page B-45) is not supported by any infomation regarding natural bedrock conto'urs or flow velocities.
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For the purposes of a draft RAP, provide do;cumentation on the f
ability of the apron to resist a PMF...Such; documentation shouldinclude(1)apronwidth,(shape,'andcross-sections, including location of bedrock; 2) apron slope (in the
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direction of flow); (3) drainage area (s); (4)- PMF peak flow (s);
(5) PMF velocities at critical points along the apron; (6) details of exit of riprap and riprap toe requirements 1"(7) depths to bedrock at the includ{ng' ditch to natural topography, hic maps and cross-sections of the exitpointiand(8)topograp area showing washes, channelsr'and design. features.
The apron and erosion protection,piNN;@,nalong the eastern port M4y (b) the pile should be designed to resist a PMF in Cane Valley Wash, assuming that a shift in the main channel occurs.
Geomorphic evidence indicates'that there i's a potential for The proposed major channel changes in the alluvial flondplain.
design, which allows for undercutting of the rock toe and rock is not' acceptable, apron (with subsequent collapse), key the erosion protection particularly if it is possible to into bedrock. The erosion erotection should be designed assuming that the altered ciennel is very close to the pile, unless it can be conclust,vely documented that such a phenomena g.
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keyed into bedrock, if pos'sible.
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4 (c) The erosion protection for the east side (and possibly the south side) of the pile ".hould also beidesigw to resist flooding and lateral erosion in the small tributaries which parallel and di.scharge to Cane Valley W' ash. The information provided is not-sufficient to establish what effects these steep washes wil1 have on the pile.
Iri order to document the effects of these channels, provide des'ign infomation similar to that requested in 1(a), above. Additionally, provide information on the potential effects of lateral crosion and headcutting for these channels considering, PMF velocities and bedrock elevations..
11 w
n (d) The erosion protection for the west side of the pile may need to be designed to withstand flooding and erosion since it appears that significant potential exists for lateral erosion and/or gullyings Provide information on this potential, also.
Overall, the NRC staff concludes a significant amount of additional documentation and design changes need to be'provided in order to demonstrate the acceptability of the site remedial action design.
Because of the site *10 cation in a floodplain at the base of steep, highly-eroded slopes and the potential for,significant geomorphic changes to occur, it is likely that the erosion protection design will require significant modifications, which may prove to be very costly to implement and, in fact, may be very difficult to design.
(
We conclude that strong consideration shou 1~d be given to moving the pile to a more stable location, especially;in light of the measures that will be needed to providt, adequate flood protection.
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.o The NRC staff does not necessarily agree with the rock durability v
2.
criteria outilned in D0E's Technical Approach Document (TAD), and does not agree that these criteria are acceptable.
In general, the
.0 criteria in the TAD are much less stringent than other nonna11y 1.
acceptable criteria, such At the United States Bureau of Reclamation e
(USBR) criteria for good quality rcekW However, we do agree that
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overstring may be a' viable alternative and can only be evaluated
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after additional durability tests are perfonned.
pp itkdoes not appear that the Based on the preliminary data provided rock from the Alhambra Rock source wi1I meet USBR criteria for eve i
poor quality rock. ' We suggest that additional efforts ce made to locate rock of better quality,'., If such rock cannot be found, 9
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I Radon Barrier 1
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Page 62, paragrsph 6 -
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N Review of reported c:limatological data indicates that harsh winters and periods of snow cover are infrequent for, this region.
For t
example, according to the DEA, for about a 20-year period, Mexican llat received an annual average snowfall of 3.3 inches.
In additicn.
Y Ca all normal maximum monthly temperatures were above freezing, while only 4 monthly normal minimum temperatures were bnlow freezing.
W Although the Monument Valley site is situated at a slightly higher elevation than Mexican Hat, the climates should be similar. Thus, it is extremely unlikely that frost will penetrate the rock and bedding material and impact the radon barrier material. Although the statements in th'e draft Remedial Action /PIsn (dRAP) may be partially true,, blanket incorporation in tHe d1AP is not considered appropriate for thisiclimate. '-
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Papa 63, Bullet No. 2 -
Please justify the use of average heap leach pad emanating fraction and E and rubble and roads.
values for the pond area and areas C, D,l10be measured for these Specify whether the emanating fraction w other areas during subsequent site preparation.
If not, the emanatin fraction value to be used will beias specified in the (0.35) for'these materials, or justify the use of the heap
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leach pad's average svalue as representative for the materials of S.
P ge 63, Bullet No.'3 i;
Please justify the 'use of a diffusion coefficient determined from the heap leach pad material for describing' areas C, 0, and E and rubble and roads. Review of the dRAP does. net indicate if the df(fusion coef fletent was determined for the pond material.
If the pond material's diffusion coefficient was estimated from the heap leach pad material,' please state this in the dRAP and justify its l,[
qdqq use.
Page B 25, Emanatin'g Fraction,=,, ' V:-
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J-s The statement discussed in Coment No. 6 epparently contradicts the discussion on emanating fraction. Clarify whether pond material emanating fraction measurements were prforMd.
If they were not, 4
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Page 62, paragraph 6*-
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.J Review of reported c:limatological data indieptes that harsh winters For and periods of snow cover are infrequent fort this region.
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example, according to the DEA, for about a 20-year period. Mexican l
l, Hat received an annual average snowfall of 3.3 inches.
In addition.
all nonnal maximum monthly temperatures were above freezing, while t
1 Ig only 4 monthly normal minimum temperatures were below freezing.
Although the Monument Valley site is situated at a slightly higher
- Thus, elevation than Mexican Hat, the climates should be similar.
it is extremely unlikely that frost will pefnetrate the rock and e
Although bedding material and. impact the radon barrier material.
the statements in the draft Remedial ActionfPlan (dRAP) may be partially true, blanket incorporation in ttfe dRAP is not considered appropriate for thisiclimate.
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Page 63, Bullet No. 2 -
Please justify the use of average heap' leach pad emanating fraction and E and rubble and roads.
values for the pond area and areas C, D,i10be measured for these Specify whether the emanating fraction w other areas during subsequent site preparation.
If not, the emanating fraction value to be used will betas specified in the NRC's SRP (0.35) for'these materials, or justify the use of the heap (I
1each pad's average value as representative for the materials of g'g g Concern.
5.
Page 63, Bullet No.'3 -
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k Please justify the use of a diffusion coefftetent determined from the heap leach pad materid for describing' areas C, 0, and E and rubble and roads. Review of the dRAP does not indicate if the j
diffusion coefficient was detemined for tfie pond material.
If the pond material's diffusion coefficient was estimated from the heap leach pad material, please state this in the dRAP and justify its
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Page B 25. Emanatin'g Fraction =[*
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a The statement discussed in Coment No, 6 apparently contradicts the discussion on emanating fraction Clarify whether pond material emanating fraction measurements were performed.
If they were not.
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h the NRC's SRP directs the implementation of an emanating fraction velue of 0.35 for; materials in which it was not detemined.
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Page B-32 r
i Justify the use of9the heap leach pad's diffusion coefficient as representative for'ethe diffusion coefficthnt value for areas C, D, G
and E and rubble and roads.
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8.
Page B-38 Sectiori B.5.6 g
Substantiate why ai-5 bar suction is a better estimate of the h,
long-term moisture value for the radon barrier material.
Please Also. -15 bar provide a reference that sup1 orts this statement.
suction is not necessarily t1e lowest long-term moisture content for soils as evidenced by rece**, literature reviews; however, according to NRC's SRP, -15 bar suction has been se3ected as being representative of :the long-tem moisture ' content for radon barrier l
material. Therefore, please edit this section appropriately.
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9.
Page D-224 Section 0.7.2.5 second paragraph -
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Chemical and physical characterfration ofithe onsite soils is necessary to allow verification of estimated attenuative properties; however, review of this section is not possible until the data is provided. Therefore, please infom URF0 'regarding soil
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characterization plans.
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i Page D-49, Section 0.3.1.5 - Site $pecific UMTRA Project Geologic _
10.
- Yfr, Please discuss seasonal variations'and/or. trends that occur in ground water at the site and vicir.f ty. Also, explain in detail the i gact seasonal variations Will hate on the ground water regime with respect to continued contaminant production, plume migration, attenuation and restoration processel. I
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- 11. Page 51
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The inadequate strength of foundation soils at the site presents a very serious concern. We are very doubtful that this basic flaw can j
j be adequately alleviated through the use of deep dynamic compaction An extremely thorough testing program will have to bc techniques.
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- 12. Page 62
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The long-tem moisture conte' t of 18 percent for the 1-foot thick n
cover layer is questionabic based on the very dry environment which exists at the site and the thickness of the layer. Picase justify the use of this value for the _long-term,motsture content.
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- 13. Page B-9, B-10 The analysis performed indicates that the relative density of foundation soils would have to increase from 46 to 57 percent in We g
order to provide a factor of safety of 1.5 against liquefaction.
are doubtful that adequate assurance of such a gain in relative densitycanbeprovided(seeNo.11above). Even if this assurance can be provided, it appears that cyclic mobility could still cause a t
significant disruption of the cover. A thorough analysis of the
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potential for disruption of the cover due to cyclic mobility must bc performed.
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NUCLEAR REGULATORY COMMISSION a
8 WASHINGTON, D. C. 2050s
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MEMORANDUM FOR:
Edward F. Hawkins, URF0 y
MyronH.F11egel.SectionleaderG'"**"["%g @
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WMGT REVIEW 0F N0hviENT VALLEY ORAFT REMEDIAL ACTION PLAN
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SUBJECT:
ly In accordance with your recent request. Ted Johnson has completed a review of the subject remedial action plan.. Our surface water hydrology and erosion
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protection coments and questions,are enclosed, w
In general, we conclude that the' proposed remedf al action plan is unacceptable.
Due to serious flooding and erosion conditions at this site, we consider that it may be difficult to provide a design which meets EPA standards and that serious consideration should be given to moving the pile to an alternate location.
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If you have any questions, please contact Ted Johnson at 427-4490.
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i v. Myron H. F1tage1 *Section Leader
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Enclosure:
As Stated
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T Monument Valley DRAP Surface Water Hydrology i$
Questions and Consnents
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Our review of surface water hydrology and erosion protection aspects of e
the proposed design indicates that the site is located in an extremely m
flood-prone area a'nd that the proposed erosion protection may not be h,'
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adequate.
The apron and erosion 'rotection'along the southern and northern
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portions of'the pile are designed with fairly steep slepes (in the direction of flow).'s.It is doubtful that the proposed 4" (average D n) rock can resist velocities produced by a PMF.
l Regardless 5f the size of the watersheds, the times of concentration 5
for these portions of the apron wil.it be very short and the PMF will Itkely be larger than possibly expected due to the steepness of the terrain. Your conclusion that there will be no significant flooding impacts (page B-45) is not supported by any infonnation regarding natural bedrock contours or flow velocities.
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For the purposes of a draft RAP.'3. !infonnation should be provided to document the ability of the a >ron to resist a PMF. Such infomation pron width shape, and cross-sections, including shouldinclude(1)k V
(3) drainage area (s I (4) pron. slope (in the direction of location of.bedroc (2)aPMF peak flow (s): (5)PMFvelocitiesat
,-'j variouspointsalongtheapront(6)riprapandripraptoorequirements; (7) details of exit of ditch to natural topography, including depths
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cross sections of the area showing washes, graphic maps tobedrockattheexitpointsand(8)topo i
channels, and design t
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- features, The apron and erosion protection along the e& stern portion of the (b) pile should be designed to resist a PMF in cane Valley Wash, assuming that a shif t in the main channel occurs. Geomorphic y,
erfdence indicates that there is t' potential for mejor channel changes e, -
fa the alluyfal floodplain. 'We do not agree that the proposed design, which allows for undercutting of the rock toe and rock apron (with subsequent collapse). il acceptable, particularly if it is 7
The erosion possible to key the erosion protection into bedrock.
protection should be designed assuming that the altered channel is Fl~
very close to the pile, unless it can be conclusively documented that The erosion protection such a phenomena could not reasonably occur.
should be sufficient to withstand PMF channel velocities and should be keyed into bedrock, If possible.
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l (c) The erosion protection for' the east side (and possibly the south side) of the pile should also be destgrfed to resist flooding and q
lateral.erosionoin the small tributaries which parc11e1 and discharge s
toCaneValley# ash. The infomation provided is not sufficient to establish what ' effects these steep wash'es will have en the pile.
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order to docume'nt the effects of thesefchannels. It will be necessary
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to provide design infomation similar to that requested in 1(a).
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above. Additionally, the potential effects of lateral erosion and headcutting for these channels may need to be considered, depending on velocities and bedrock elevations. 0-i; h
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p (d) The erosion prot'ection for'the west side of the pile may need to be designed to withstand flooding and erosion since it appears that significant potential exists for latepa'l erosion and/or gullying.
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Overall, the NRC staff concludes a si nf ficant amount of additional documentation and design changes may e nee'ded in order to demonstrate the acceptability of the site remedial action deston. Because of the site location in a floodplain at the base of steep, highly. eroded slopes and the potential for significant geomorphic changes to occur, it is Ifkely that the erosion protection design will require s'tgnificant modtfIcations, which may prove to be very costly to implement and, in fact, may be very difficult to design. We also conclude that:. strong consideratton should especially in be given to moving the pile to a more stable location,dequato flood Ifght of the measures that will.be needed to provide a i
protection.
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The NRC staff does not necessarily agree wf th the rock durability criteriaoutlinedin.00E'sTechnicalApproachDocument(TAD),anddoes not agree that these criterla are acceptable. In general, the criteria in the TAD are much less stringent than other normally acceptable criterf a, such as the U58R criterla for good. quality rock. However, we do agree that overtirftg may be a viable alternative and can only be evaluated after additional durability tests are perforved.
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s; Baseo n the prelfalnary data provided it does not appear t. hat the rock
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from 1e Alhambra Rock source will meet U$8R crf teria for even poet.uality rock. We suqgest that additional efforts be made to locate rock of better quality, f such rock cannot be found, DOE should indicate t.
the methods and criteria that will be used to overstre the poor. quality rock that 15 available.
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