ML20236N479
| ML20236N479 | |
| Person / Time | |
|---|---|
| Issue date: | 07/09/1987 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | James Anderson ENERGY, DEPT. OF |
| References | |
| REF-WM-62 NUDOCS 8708110514 | |
| Download: ML20236N479 (2) | |
Text
l E'
WM-62/GCP/87/07/09
_1 JUL 9 1997 l
Mr. James R. Anderson, Project Manager Uranium Mill Tailings Project Office U.S. Department of Energy Albuquerque Operations Office J
P.O. Box 5400 Albuquerque, NM 87115
Dear Mr. Anderson:
The Nuclear Regulatory Commission has completed its review of the draft Remedial Action Plan (DRAP) and the draft Environmental Impact Statement (DEIS) for the former Union Carbide Corporation Uranium Mill Sites at Rifle, Colorado.
Enclosed are our comments on those documents in the areas of surface water l
hydrology, groundwater hydrology, geology, geomorphology and seismology.
Our comments on geotechnical stability will follow under separate cover.
As you will note, the comments are quite lengthy. This attribute reflects not only the fact that the staff found significant inconsistencies and voids in the technical data supporting the remedial action, but more importantly, that the staff has serious reservations about the ability of the proposed design to meet the long-term stability requirements of 40 CFR 192. As noted in a telephone conversation between members of our staffs and the Technical Assistance Contractor on June 30, NRC's concerns focus on both the characteristics of the proposed Estes Gulch disposal site and the resultant extensive and elaborate design measures necessary to provide stability to the reclaimed tailings.
Erosion protection of the reclaimed tailings may be difficult because of steep slopes adjacent to and upgradient from the disposal site and the need to divert upstream surface water flows around the site. The design also incorporates steep, heavily-armored diversion ditches whose satisfactory performance may not be able to be demonstrated without relying on periodic maintenance. Our comments also note that the design basis for the disposal site does not appear to be consistent with the site geologic setting.
Based on the items mentioned above and the more detailed comments enclosed, we conclude that the proposed remedial action for the Rifle sites has not been shown to provide control of the reclaimed tailings for the period specified in 40 CFR 192 (200-1000 years). Although you may choose to modify the RAP and design of the Estes Gulch site in accordance with our comments to provide reasonable assurance of long-term stability, it may be more prudent to reexamine the site selection process to determine if less costly and more viable disposal alternatives exist. Our review of the DEIS suggests that better sites than Estes Gulch may indeed be reasonably available near Rifle.
M Reccd File E l Preiett _. b b D a d Mc. _ _
PDR #
LPDR _._
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8708110514 070709 PDR WASTE l.
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J WM-62/GCP/87/07/09
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If you have questions regarding these comments, feel free to contact me at FTS j
427-4799 or George Pangburn of my staff at FTS 427-4160.
Sincerely, M
Paul H. Lohaus, Acting Chief Operations Branch Division of Low-Level Waste Management and Decommissioning l
Enclosures:
As stated DISTRIBUTION:
l LLWM7 NMSS r/f LLOB r/f Originator Section Leader PLohaus, LLOB JStarmer, LLTB MKerney, LLRB JGReeves, LLWM MKnapp, LLWM MTokar, LLTB KWestbrook, LLTB MYoung, LLTB JGrimm, LLTB MWeber, LLTB DWidmayer, LLTB GGnugnoli, LLOB 1
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