ML20244E188
| ML20244E188 | |
| Person / Time | |
|---|---|
| Issue date: | 07/24/1986 |
| From: | Hawkins E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Themelis J ENERGY, DEPT. OF |
| References | |
| REF-WM-66 NUDOCS 8608190291 | |
| Download: ML20244E188 (3) | |
Text
s DISTRIBUTION Docket File WM-066
~
-->PDR/DCS -
DBangart, RIV WM-066/HDR/06/07/21/0 HRose LLW Branch, WMLU DGillen, WM URF0 #bV M I4 M RGonzales URF0:HDR Docket No. WM-066 040WM066301E John G. Themelis, Project Manager U.S. Department of Energy Albuquerque Operations Office P.O. Box 5400 Albuquerque, New Mexico 87115
Dear Mr. Themelis:
The NRC has completed its re~ iew of the.Oraf t CADSAR for the Naturit.a.
v Culorado site. As we agreed cur review consisted of a broad overview of the document looking for " fatal flaws" aild unaddressed areas or omissions. To summarize the encloced coments, stabilization in place, stabilization on site and relocation to the Slick Rcck site all involve significant problems associated with their location within the ficod plains of the San Miguel or Dolores Rivers. Several other areas, such as seismic activity at the Slick Rock site, actual data on the concentration of potentially hazardous constituents present in windblown tailings areas, and field studies on radon source term have not been addressed in sufficient detail.
Once you have reviewed our coments, we can determine if a meeting to discuss these issues is necessary. As a result of our recent reorganization, Mr. Ray Gonzales (FTS 776-2811) will assume project management responsibilities for the Naturita Site.
Please contact Ray or myself if you have any questions or coments.
Sincerely, Isl Edward F. Hawkins, Chief 860S1W291 860724 Lice'nsing Branch 1 QR-66 PDR Uranium Recovery Field Office Region IV
Enclosure:
As stated 0FC
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NRC COP 91ENTS ON NATURITA DRAFT CADSAR 1.
The proposed Naturita Stabilization in Place (SIP) and Stabilization on Site (SOS) options would result in tailings being situated on and within the flood plain of the San Miguel P.iver. The close proximity of the San Miguel River may eventually cause encroachment, cutting and the eventual rupture of the disposal cell. Explain how these concerns will be resolved.
2.
High precipitation periods and seasonal changes combined with the fact that the ground water is near the surface provide the possibility of ground water impeding on the dispasal cell in the SIP and SOS options.
Explain how this concern will be resolved.
3.
The proposed SIP and SOS disposal cells would be situated on alluvium resting on the Mances Shale which overlies the Dakota Sandstone. Significant problems with this situation include:
Fluctuatiens of ground-water levels within the alluvium.
An alluvial zone which is already contaminated.
Possible contamination into the sandstone aquifer for the 505 option.
The prcximity of ground water to the surface.
Explain your approach to resolving these problems.
4.
The proposed Coke Oven disposal site is situated on the 14ancos Shale which overlies the Dakota Sandstone. This c6uld pose the possibility of contamination of the Mancos Shale (clays) lying l
beneath the proposed site. However, these shalo beds are fairly tight and exhibit less than desirable water quality thereby limiting l
potential for ground-water impacts. Provide additional geologic detail on this area. Alto provide substantiation for your conclusions on ground-water quality.
i 5.
The Slick Rock site is located in an area where seismic activity (a fault exists near site) could potentially be a problem in design and siting. Discuss the implications.
6.
Relocating the tailings to the Slick Rock site would place the tailings cell in the flood plain of the Dolores Rlver, which would I
make it difficult for the design to meet longevity requirements.
N 5
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O 2
(Erosion protection measures would probably be quite expensive.)
Secondly, the alluvial zone at the site is already contaminated, making the establishment of ground-water background concentrations extremely difficult. Ground-water fluctuations could also pose a problem for siting and the design of the proposed disposal site.
Explain how these problems will be resolved.
7.
Page 5, last paragraph Provide additional documentation on the concentration of potentially hazardous constituents present in the windblown tailings areas.
Substantiation that the materials do not pose a present or future health risk and justification for the use of supplemental standards in accordance with the NRC's ' Guidelines for Justifying the Use of Supplemental Standards in 40 CFR Part 192," dated July 3,1986, is necessary prior to NRC concurrence.
8.
Page 11, Table 3.3 The Durita Site is not affected by the maximum historic discharge of Dry Creek.
Compare this discharge tc the PMF.
9.
Page 33, first paragraph of Section 5.2 This paragraph states that studies were made to determine the volume of flow.
Volume of flow is not as important as the PMF peak flow.
Design calculations must include the determination of peak flows resulting from a PMP event.
10.
Page 33, Section 5.4 This paragraph states that if rock larger than 24" is required, another source will have to be located.
It is doubtful that 24" riprap will resist the boundary shear from 20 to 30 fps velocities.
Therefore, assuming that you are correct that stream velocities will be in the 20-30 fps range, it is almost certain that larger rock will be required. This will have an impact on cost. Clarify the assumptions.