ML20215H167
| ML20215H167 | |
| Person / Time | |
|---|---|
| Issue date: | 05/21/1987 |
| From: | Starmer R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Fliegel M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-72 NUDOCS 8706240022 | |
| Download: ML20215H167 (7) | |
Text
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r MAY 911987 MEMO FLIEGEL !
MEMORANDUM FOR: Michael Fliegel Operations Branch Division of Low-Level Waste Management and Decommissioning FROM:
R. John Starmer, Section Leader Technical Branch Division of Low-Level Waste Management and Decommissioning
SUBJECT:
COMMENTS ON THE SP0OK COMPARATIVE ANALYSIS OF DISPOSAL SITE ALTERNATIVES REPORT (CADSAR)
SPo0L, memorandum transmits the Siting Section (LLTB) comments o Thjs
-~W-diMm_E_f.... _; to the Uranium Recovery Section ~(LLOB).
CRQ I have reviewed the comments and have identified needed changes. Due to tight time constraints, the comments are being forwarded without incorporating my changes.
Kristin Westbrook of my staff and your P.M., George Pangburn, have discussed my comments with me and will be working with the individual technical reviewers to ensure that my comments are addressed.
Original Signed by R. John Starmer, Section Leader Technical Branch Division of low-Level Waste l
Management and Decommissioning
Enclosure:
Comments VlM Record file WM Pcirt - -
DacLei K1 8706240022 870521 PDR V WASTE Lp r,,a
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UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: Spook, Wyoming
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Document: Preliminary Final CADSAR Commentor: NRC Comment:
1 Page: General As requested by NRC staff following review of the dCADSAR, DOE has presented available ground water information to support the preferred alternative of stabilization-in-place (SIP). NRC~ staff have reviewed and have several questions regarding this information and future ground water conditions.
- 1. DOE acknowledged that "high ground-water levels may flood the pit floor and the stabilized tailings" (page 22). The CADSAR does not give details how a second-phase hydrologic drilling program will be designed to 4
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accurately ascertain the liklihood of this problem.
For this analysis NRC j
staff suggest DOE's second phase characterization plan include construction of cored monitor wells in the mine pit floor in order to collect the following data: a) close identification of the water table or multiple aquifers, b) detailed stratigraphic logs of bedrock below the pit, c) lithology, grain-size and porosity of the bedrock, and d) fractures or other small scale structures with potential affects on ground water movement.
- 2. The ground-water flow directions illustrated in the CADSAR appear to contradict assertions made by DOE that flow direction is generally northeastward. Figure 3.7 depicts ground water flowing southeast, south of the pile. This results in " background" wells 902 and 903 actually being located downgradient of the pile.
It is unknown what effect the open pit has on regional ground water flow, but it appears significant from the figure provided in the CADSAR. Although this discrepancy between the text and figure may not affect remedial action plans, it may affect future characterization plans. NRC staff suggest that DOE take this radial flow into account when developing future well construction plans.
Further, NRC staff commented on the Scope of Work for ground-water characterization at the Spook site that the area west of the pit was unmonitored. The staff conclude that monitoring this area could provide an explanation for the apparent radial flow east of the pit, and again suggest that it be considered if future characterization work is intiated.
- 3. DOE mentioned in the CADSAR (page 9) that mine tunnels extend from the pit wall at the NW and SW areas of the pit.
In the draft EA and/or RAP, DOE should fully evaluate the significance of these tunnels on recharge of the pit during high water table conditions, on the potential for preferential flow of contaminants through the tunnels during lower water table conditions, and on ground-water flow directions.
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VMTRA DOCUMENT REVIEW FORM SECTION 1
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Site: Spook, Wyoming
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Document: Preliminary Final CADSAR l
Commentor: NRC j
i Comment:
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DOE presented preliminary ground-water quality data in Table 3.2 of the CADSAR for samples taken from pre-existing water wells located in the vicinity of the i
tailings, and mentioned that "in most cases the well completion data (i.e.
total depth and screened intervals) for these six existing wells are incomplete or missing". NRC staff will likely have difficulty accepting these data from wells without completion data. DOE should obtain completion data if reliance is to be placed on these sample results.
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4 UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: Spook, Wyoming
, Date:
Document: Preliminary Final CADSAR Commentor: NRC Comment:
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22 DOE mentioned in the CADSAR that if a Phase II drilling program is considered necessary to characterize ground water in the vicinity of the pile, t; hen it may not be-possible to include complete results in the draft EA or RAP tcheduled L
for issuance in July,1987. NRC staff are concerned that an adequete review of the draft EA and RAP will necessarily require these additional dai,a, especially if D0E. feels it important enough to collect the data in the first place.
Therefore, the staff take the position that if additional drilling is considered necessary by DOE, then the information resulting from this work should be included in the draft EA and RAP, regardless of when the documents are scheduled for issuance.
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UMTRA DOCUMENT REVIEW FORM SECTION 1 i
Site: SP0OK
, Date: 5/14/87 Document: Final CADSAR Commentor: HRC Comment: Surface Water and Erosion Issues Page: General In response to a comment on the draft CADSAR, DOE provided a topographic map of the site vicinity in the final CADSAR. This map is not of sufficient detail to
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evaluate surface water drainage and geomorphic features of the proposed disposal site. Subsequent documentation should provide maps of greater detail.
In response to a comment on the draft CADSAR, DOE indicated that diversion of surface water will not be required for the SIP option because the pit will be backfilled to natural grade. However, surface water diversion may be required during remedial action and reclamation activities to prevent surface water flow from entering the pit before backfilling is completed. This possibility should be considered in the remedial action program and discussed in subsequent documentation.
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6 Potential geomorphic hazards, such as mass wasting, channel incision, headcutting, and backfill subsidence (which may lead to surface water ponding),
are not discussed in the final CADSAR. These hazards should be fully assessed and their potential impacts considered in the project design. Subsequent documentation should include a discussion of these hazards and their mitigation.
Coordination and scheduling between the AML Program and the UMTRA Project should be considered in the design of the low-permeability barrier that will be placed over the tailings pile. A substantial time lapse between tailings stabilization and initiation of reclamation may require that the barrier be thickened or incorporate an erosion protection layer to prevent crosional breaching.
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