ML20237L562
| ML20237L562 | |
| Person / Time | |
|---|---|
| Issue date: | 07/28/1987 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | James Anderson ENERGY, DEPT. OF |
| References | |
| REF-WM-74, REF-WM-75 NUDOCS 8709080458 | |
| Download: ML20237L562 (3) | |
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S 2 0 NIMM Record Fil I SI?CI N MNo _ M S James R. Anverson, Project Manager Uranium Mill Tailings Project Office U.S. Department of Energy POR #
Albuquerque Operations Office 2i@u tionI--------_.
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P.0 Box 5400
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Albuquerque, NM 87115
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Dear Mr. Anderson:
The NRC staff has completed its review of the final Comparative Analysis of,
Disposal Site Alternative Report (CADSAR) for the Belfield and Bowman, North Dakota sites. Enclosed are three comments that should be addressed in development of the draft Remedial Action Plan (RAP) and/or draft Environmental Assessment (EA),asindicated.
A potentially significant issue has been identified by the staff regarding the preferred disposal option, stabilization at the Bowman site. While shallow ground water is noted as a concern in the CADSAR, it is not apparent that this key issue has been evaluated and considered in the conceptual design for this site. This concern is further addressed in the first of the enclosed comments.
Should you have any questions, please contact Susan Bilhorn of my staff at FTS 427-4145.
Sincerely, I
Pau H. Lohaus, Chief Operations Branch Division of Low Level Waste Management and Decommissioning
Enclosures:
As stated DISTRIBUT70N LLWM SF LLOB RF NMSS RF SBilhorn, LLOB MFliegel, LLOB PLohaus, LLOB MRnapp, LLWM JGreeves, LLWM JStarmer, LLTB JSurmeier, LLTB MTokar LLTB MYoung, LLTB KWestbrook, LLTB JForstrom, LLTB LDeering, LLTB GGnugnoli, LLOB DWidmayer, LLTB
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TATE :07/2K/87
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- 07/2f/87 8709000450 070728
- FICIAL RECORD COPY
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. NRC STAFF COMMENTS ON THE FINAL CADSAR FOR BELFIELD AND BOWMAN SITES, NORTH DAK0TA Comment 1:
Ground Water at the Bowman Site DOE states, in the final CADSAR, that the ground water at Bowman, the preferred disposal site, is very shallow. Tables 3.2 and 7.1 indicate that the ground water lies between 10 to 15 feet, while page 27 states that it lies between 6 to 30 feet, below land surface.
In addition, DOE indicates that hydraulic conductivity in some areas tested at the site averages 5 ft/ day with values as high as 23 ft/ day. The shallow water table and wide range of hydraulic conductivity values suggest the presence of a highly transient aquifer systein, with the possibility of considerable seasonal variability.
These hydraulic conditions need to be considered in design of the disposal operation in order to provide adequate ground water protection.
From information presented in the final CADSAR, it is not apparent that the ground-water issue has been considered in the selection of, and design for, disposal at Bowman.
For example, the CADSAR does not indicate whether the conceptual design incorporates above-or below-grade disposal. The staff is concerned that below-grade disposal may not be acceptable due to the shallow ground water.
If an above-grade design has not previously been considered, the volume and cost of radon barrier and erosion protection materials may be considerably different from those anticipated in the final CADSAR.
In conclusion, DOE must consider what implications, if any, a shallow and possibly transient water table may have on the design (and cost) of the preferred disposal option.
Information from the assessment of ground-water impacts should be provided in the draft EA and/or draft RAP.
NRC staff will carefully review these documents to ensure that the information provided on the proposed remedial action is sufficient to demonstrate adequate protection of the existing ground water.
Comment 2:
Characterization of Contaminated Material Following review of the draft CADSAR, the staff suggested that DOE include characterization of the contaminated material as part of their field characterization activities to be conducted 17 preparation of the final CADSAR (Comment 3, transmitted to James Anderson from Dan Martin in letter dated March 30, 1987).
Based on information presented in the final CADSAR, it is not apparent that this material has been characterized, other than for the presence of specific nonradiological contaminants.
. The contaminated material at both sites (Belfield and Bowman) is lignite ash and may have different physical characteristics than materials encountered at other UMTRAP sites. The contaminated material should be characterized and the results concidered in the design that is presented in the draft RAP.
Comment 3:
Nonradiological Contamination The staff identified two concerns regarding characterization of nonradiological contamination at Belfield and Bowman sites.
Information addressing these concerns needs to be presented in the draft EA and/or draft RAP to support the staff's review of the proposed remedial action, a)
On page 42 of the final CADSAR, DOE identifies the need to determine the contents of drums at the Belfield site. No other information has been provided on these drums. The staff is concerned that nonradiological contaminants may be contained in these drums.
If so, it may indicate the presence of other uncontained contaminants on site.
In addition, DOE will need to determine how to dispose of this material through the appropriate regulatory authority (e.g. RCRA).
b)
On page 18 of the final CADSAR, DOE states that soil samples from both Belfield and Bowman sites were tested for concentrations of specific nonradiological contaminants. This brief discussion does not indicate which contaminants, other than molybdenum, were tested for, nor does it provide any information on the results of these tests. This information is needed to support the conclusion that molybdenum is the only significant nonradiological contaminant to be considered in remedial action.
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