ML20215J325
| ML20215J325 | |
| Person / Time | |
|---|---|
| Issue date: | 04/01/1987 |
| From: | Martin D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | James Anderson ENERGY, DEPT. OF |
| References | |
| REF-WM-58 NUDOCS 8705070365 | |
| Download: ML20215J325 (13) | |
Text
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g gg DRAFT DG/3/31/87 James R. Anderson, Project Manager Uranium Mill Tailings Project Office U.S. Department of Energy P.O. Box 5400 Albuquerque, NM 87115
Dear Mr. Anderson:
' The NRC staff has reviewed the Shiprock, New Mexico, Draft Remedial Action Completion Report and Final Audit Report. Specific coments are enclosed for your use.
As you have noted in the Executive Sumary of the Completion Report, a proposed modification to restrict the use of ground water from the floodplain alluvium remains an open item with the NRC and other concurring agencies.
Ground-water characterization of the floodplain alluvium has been a RAP conditional concurrence issue throughout the performance of remedial actio=.
This issue will remain a hindrance to full concurrence in comp (letion until ongoing characterization is completed and NRC staff conwients letter dated August 8,1986) on the proposed modification are resolved.
Should you have any questions regarding this review, please contact Dan Gillen of may staff at FTS 427-4160.
MIGGIAL Stemo sr Dan E. Martin, Section Leader Uranium Recovery Projects Section Low-Level Waste and Uranium Recovery Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated l
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DRAFT DG/3/31/87
- 0FFICIAL CONCURRENCE AND DISTRIBUTION RECORD LETTER T0:
James R. Anderson, Project Manager Uranium Mill Tailings Project Office U.S. Department of Energy P.O. Box 5400 Albuquerque, NM 87115 FROM:
Dan E. Martin, Section Leader Uranium Recovery Projects Section Low-Level Waste and Uranium Recovery Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
SHIPROCK, NEW MEXICO, DRAFT REMEDIAL ACTION COMPLETION REPORT AND FINAL AUDIT REPORT DATE:
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r-SHIPROCK 1/DG/3/31/87 UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: Shiprock,NM
, Date: March 31, 1987 Document: Remedial Action Completion Report-Final Draft Commentor: NRC Staff /Geotechnical Engineering Comment:
1 Appendix 0, Drawing No. SHP-PS-10-0012'.
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N'ote 1 of this drawing references as-built' drawing No.-SHP-PS-10-0016 which notes that final g.rade contours will be redrawn when aerial photogrammetry data becomes available.
If this information is available, provide it in the Final Completion Report, if not, indicate when it will be available.
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c SHIPROCK~1/DG/3/31/87
. UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: Shiprock, NM Date: March 31,1987 Document: Remedial Action Completion Report-Final Draft Commentor: NRC Staff /Geotechnical Engineering Comment:
2-Appendix D, Drawing No. SHP-PS-10-0018 This drawing shows the locations of several settlement plates installed.
-on the pile. Provide any settlement data that has been collected to date, and include a summary of settlement co.nditions in Appendix H, Post Remedial Action Site Con ~ditions.
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SHIPROCK 1/DG/3/31/87
. UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: Shiprock, NM
, Date: March 31, 1987 Document: Remedial Action Completion Report-Final Draft Commentor: NRC Staff /Geotechnical Engineering-Erosion protection Comment:
3-Appendix E, General Appendix E, Field Test Report Summary, should include summaries of placement moisture contents for tailings, radon barrier, and seepage barrier materials.
In addition, summaries of gradation tests on the radon barrier, seepage barrier, select bedding, and select rock should be included. Gradation results for the radon barrier and seepage barrier, could be summarized in tabular for,m, while results of tests on the bedding and rock materials could be summarited by gradation curves superimposed on appropriate specified gradation bands.
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SHIPROCK 1/DG/3/31/87
.UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: Shiprock, NM.
Date: March 31, 1987 Document: Remedial Action Completion Report-Final Draft Commentor: NRC Staff /Geotechnical Engineering Comment: 4-Appendix E, Select Bedding / Select Rock 1
The RAIP for Shiprock requires that, for each source of riprap and bedding material, the set of durability tests be performed for each 10,000 cubic yards of material placed.. The discussion on page 200 only presents the pre-acceptance test results.
Provide discussion of the results of the additional select bedding durability tests as has been done for the select rock (pages 201,202).
In addition, the discussion of abrasion and soundness test results for select pock and select bedding should. include reference to the number of cycles performed.
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SHIPP.C{K 1/DG/3/31/87
- UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: Shiprock, NM.
Date: March 31 -1987 Document: Remedial Action Completion Report-Final Draft Commentor: NRC Staff /Raciological Caseent:
5-Volume 1;Section III-D;Pages III-10,11
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Inconsistent values of background s' oil ccncentration of Ra-226 should be corrected. Page III-10 reports a value of 1.1 pCi/g, while page III-11
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reports a value of 1.5 pCi/g..
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SHIPROCK 1/DG/3/31/87
. UMTRA DOCUMENT REVIEW FORM
- SECTION 1 Site: Shiprock, NM
,,Date: March 31, 1987 Document: Remedial Action Completion Report-Final Draft Commentor: NRC Staff / Radiological
' Comment: 6-Volume 1;Section III-D;Page III-11 The section on soil verification results states that all verification data (Figure J-1) met the EPA standards of 5.0 and 15.0 pCi/g plus background z
(see comment 5). The figure does not support this statement, since there o
are at least 5 values in excess of 16.5 pCi/g.
The discussion should be modified to accurately describe the data.
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.. SHIPROCK 1/DG/3/31/87 '
UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: Shiprock, NM
, Date: March 31,- 1987 Document: Remedial Action Completion Report-Final Draft Commentor: NRC Staff / Radiological Comment:
7-Appendix J: Page 1 The section on verification measurement methods references the RAP, Appendix C, paragraph C.3.2.a as presenting verification criteria. This reference is improper, since C.3.2.a discusses excavation control monitoring, not verification measurements.
The verification standard requires each 100-square-meter area to have an average concentration of Ra-226 below the 5 and 15'pCi/g plus background limits.
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SHIPROCK 1/0G/3/31/87
. UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: Shiprock, NM
, Date: " March 31, 1987
' Document: Remedial Action Completion Report-Final Draft Commentor: NRC Staff / Radiological Comment: 8-Appendix J: Page 2 The section on quality control of radiological methods states that no QC results exceeded applicable Ra-226 guidelines. It is not clear whether the term " applicable Ra-226, guidelines" refers to certain DOE /RAC QC guidelines
-or to the EPA ~ standards.
The NRC staff review has identified three QC values which are in excess of the 15 pCi/g plus background value.
Please clarify this statement.
s
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. - SHIPROCK 1/DG/3/31/87-
_g-UMTRA DOCUMENT REVIEW FORM SECTION 1 Site:.Shiprock, NM
, Date: March 31, 1987 Document: Remedial Action Completion Report-Final Draft Commentor: NRC Staff / Radiological Comment: 9-Appendix J; Table J.4 The comparison of the OCS system data to the EDA laboratory data indicates that, on the average, the OCS results are over 30% lower than the laboratory values.
The completion report should discuss the significance of this deviation and explain why a correction factor was unnecessary.
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SHIPROCK 1/DG/3/31/87
. UMTRA DOCUMENT REVIEW FORM SECTION 1 Site: Shiprock, NM
, Date: March 31, 1987 Document: Remedial Action Completion Report-Final Draft Commentor: NRC Staff / Radiological Comment:
10-Appendix J; data pages The data p. ages include depth values which are either 0, < 6, or > 6 inches. The NRC staff understand these values to represent the sample t
depth below the excavated surface..To accurately determine which 3
numerical value of the EPA standard applies, the reported depths should be the sample depth below the surface after backfilling.
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- SHIPROCK 1/DG/3/31/07 UMTRA COCUMENT REVIEW FORM SECTION 1 i
Site: Shiprock, NM Date: March 31, 1987 Document: Remedial Action Completion Report-Final Draft Comentor: NRC Staff / Radiological Comment:
11-Apperdix J; data pages The data tables include a significant number-of QC samples with Th-230.
values at least an order of magnitude greater than the Ra-226 values.
This implies disequilibrium between Ra-226 and Th-230. However, the EPA stancards are based on radiologic equilibrium of these radionuclides.
Discuss the significance of these elevated Th-230 concentrations in the context of post-remedial action s.ite ccnditions.
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