ML20245C558
| ML20245C558 | |
| Person / Time | |
|---|---|
| Issue date: | 04/21/1989 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Matthews M ENERGY, DEPT. OF |
| References | |
| REF-WM-39 NUDOCS 8904270223 | |
| Download: ML20245C558 (9) | |
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I APR 21 1999 4
1 Mr. Mark Matthews, Acting Project Manager Uranium Mill Tailings Project Office Albuquerque Operations Office U.S. Department of Energy P.O. Box 5400 3
Albuquerque, New Mexico 87115 l
Dear Mr. Matthews:
j lIn' response to your memorandum to me' and others dated March 23, 1989, we have reviewed DOE's " Final-Policy and Procedures for Classification of Class III
- Groundwater at UMTRA Project Sites." Based on our review, we identified
. several issues' that should be resolved prior to implementation of the policy
- and procedures in classifying groundwater resources at specific sites. Timely J
F resolution of these issues should prevent unnecessary delys in our future j
reviews of Remedial. Action Plans for sites where DOE proposes supplemental o
. standards based on a' Class III groundwater demonstration. The issues are-
' described in the enclosed comments and suggestions.
This review was performed by Michael Weber. Please contact him at telephone R
number FTS 492-0565 if you wish to discuss the enclosed comments and suggestions.
'/
Sincerely, (SIGNEi)) PAUL H.LOHAUS Paul H.-Lohaus, Chief Operations Branch
.O Division of Low-Level Waste Management-
- Q a-and Decommissioning, NMSS q
O
Enclosure:
- Comments and Suggestions IM
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SUBJECT ABSTRACT:
Comments on DOE'liI' Groundwater Classification Policy
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WM-39/MFW/89/04/10/ CLASS III NRC STAFF COMMENTS ON DOE'S
" FINAL POLICY AND PROCEDURES FOR CLASSIFICATION OF CLASS III GROUNDWATER AT UMTRA PROJECT SITES" April 1989 Introduction The NRC staff has completed its review of DOE's " Final Policy and Procedures for Classification of Class III Groundwater at UMTRA Project Sites," March 1989. Based on NRC's review the staff identified several issues that should be resolved in'a timely manne,r to preclude unnecessary delays in future reviews of proposed remedial actions at UMTRA Project sites.
in the comments and suggestions Ifsted below.
The issues are described
_ General Comments i
1.
The Policy and Procedures are unclear about who determines the groundwater classification"of groundwater units at specific sites.
In this respect, the documentisconsistentwithEPA'sproposedgroundwaterprotectionstandards(40 CFR 192, Subparts A-C), which are also unclear about who makes groundwater classification determinations. As described in EPA's interim final groundwater classification guidelines (EPA, 1986), EPA intended implementation of the guidelines by EPA or authorized State and local agencies through established groundwater protection programs.
EPA conferred authority for NRC to discharge the responsibilities of the EPA Regional Administrator in implementing EPA's
. proposed groundwater protection standards for UMTRA sites in 40 CFR Part 192, Subparts A-C.
Thus, NRC is apparently responsible for determining Class III
. groundwater resources under EPA's proposed standards because such determinations would be made by EPA under the analogous hazardous waste management program.
The policy and procedures should be revised to state that DOE proposes Class III groundwater classifications' and that NRC designates Class III groundwater through its concurrence with DOE's ' remedial actions.
2.
The Policy and Procedures need to be integrated with DOE's recently developed policy for groundwater protection.
The Policy and Procedures implement substantial provisions of EPA's Groundwater Protection Strategy.
DOE has been developing a comprehensive agency policy for groundwater protection in response to EPA's Groundwater Protection Strategy and increased public interest about environmental protection at DOE facilities.
Thus, the document should be revised to describe the relationship between DOE's Policy and Procedures for Class III groundwater classifications and DOE's comprehensive policy for groundwater protection.
3.
The Policy and Procedures need to be revised to incorporate the uppermost aquifer conce Review Area (pt into the designation of groundwater units in the Classification CRA). Although the Policy and Procedures describe the designation
-of groundwater units within the CRA, it does not integrate the designation of groundwater units with the designation of the uppermost aquifer.
EPA's proposed groundwater protection standards in 40 CFR Part 192 provide for the
WM-39/MFW/89/04/10/ CLASS III' -,.
k estab'ishment of site-specific Groundwater Protection Standards for the upperuost aquifer at UNTRAP sites.
Groundwater protection: efforts at most sites will focus on the uppermost aquifer because its protection should also protect hydraulically-connected groundwater units and surface water bodies.
Thus, the designation of groundwater units within the CRA should also focus on the uppermost aquifer.
The Policy and Procedures should be revised to reflect this focus..
4.
Although DOE's procedures for groen hecer classification are consistent with EPA's guidelines for grem 'ater classification (generally),
EPA, 1986 slight revisions of the format of the doce.ent would help to ensure consistency with the guidelines and the definition of Class III groundwater in EPA's proposed groundwater protection standards. As presently written, the format of the. document implies that groundwater treatability can be assessed independently of the extent of ambient contamination as the basis for designating Class III groundwater.
In addition, the document omits detailed
- procedures for evaluating compliance with the 10,000 mg/l Total Dissolved
- Solids (TDS)criterionforClassIIIgroundwater. Therefore, the format of the Policy and Procedures should be revised to provide procedures for evaluating each of the Class III~ criteria: TDS, treatability, and sufficient yield. The
-treatability procedures should include the evaluation of whether contamination
. is widespread and ambient, which is currently discussed in section 3.2 of the
. Policy and Procedures.
Specific Comments 1.
Executive Summary The paraphrased definition of Class III groundwater in the Executive Summary,is-inconsistent with EPA's definition in proposed 40 CFR Part 192.11(e) because the:second criterion omits provisions that contamination in the groundwater be ambient.and widespread.
The definition should be revised to ensure consistency with EPA's definition.
2.
Executive Summary The seventh paragraph of the Fr.mi:ive Summary states that poor quality groundwater can be classified as Class III if chemical concentrations in the groundwater are above drinking water standards.
This statement is inconsistent with EPA's definition of Class III groundwater in proposed 40 CFR Part
-192.11(e) because it does not include provisions for assessing the reasonableness of treatment using methods used in public water supply systems.
The Executive Summary should be revised to paraphrase the definition of Class p
III groundwater correctly.
3.
Purpose, pg. 1 The purpose states that three supplemental standard criteria apply to groundwater at UMTRAP sites.
This description omits three other applicability 4
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[
l WM-39/MFW/89/04/10/ CLASS III criteria for supplemental standards that could apply for groundwater, including:
1 (1) Remedial actions required to satisfy Subparts A or 8 would pose a clear and present risk of injury to workers or to members of the public, notwithstanding reasonable measures to avoid or reduce risk [40 CFR 192.21(a)];
(2) There is no known remedial action [40 CFR 192.21(e)]; and (3) Radionuclides other than Radium-226 and its decay products are present in sufficient quantity and concentration to constitute a significant radiation hazard from residual radioactive materials [40 CFR 192.21(h)J.
The Policy and Procedures should be revised to include the three additional criteria listed above.
In addition, the description of the applicability criteria should correct the typogra hical error in the citation for the third criterion from 192.21(9)to192.21().
4.
Purpose, pg. 1 The last sentence of the first paragraph states that EPA's standards provide for DOE's creation of supplemental standards in the form of site-s>ecific numeric groundwater standards. EPA's proposed groundwater protect wn standards i
do not restrict supplemental standards to numerical standards. NRC staff anticipates that supplemental groundwater protection standards, if established, may be narrative standards or performance objectives rather than numetic j
standards.
NRC's Standard Format and Content Guide (NRC, 1989) provides j
specific guidance on the types of information DOE should submit in a supplemental standards application, including types of acceptable supplemental standards for' groundwater protection.
Thus, the Policy and Procedures should 4
be revised to state that EPA's proposed standards provide for the establishment
)
of site-specific supplemental standards, including narrative standards, performance objectives, and numeric standards for hazardous constituents.
5.
The EPA Groundwater Classification System, pg.1 DOE's Policy and Procedures state that EPA's groundwater classification system will be used for groundwater classification rather than State and local classification systems.
However, the text does not provide an adequate rationale for why State and local classifications will not be used or considered.
In developing its Groundwater Protection Strategy, EPA recognized i
that anticipatory groundwater classifications are best perfomed by State and i
local authorities with control over land use. EPA also stressed the importance of State classification systems in its guidelines and stated that State systems may be adopted in place of Federal guidelines if they are at least
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WM-39/MFW/89/04/10/ CLASS III as stringent as EPA's system (EPA,1986).
Thus, EPA is sensitive to the prerogative of State and local authorities to classify groundwater resources as they see fit. This sensitivity appears to conflict with DOE's decision not to consider or use State and local groundwater classification systems.
Therefore, 5
the Policy and Procedures should be revised to provide procedures for considering State and local groundwater classifications and concerns or to demonstrate why State and local classifications cannot be considered in proposing Class III designations.
6.
The EPA Groundwater Classification System, pg. 2 The paraphrased definition of Class III groundwater is inconsistent with EPA's definition in proposed 40 CFR Part 192.11(e).
EPA's definition states that all Class III groundwater is not a current or potential source of drinking water, as opposed to the text's definition that indicates that only untreatable groundwater is not a current or potential source of drinking water. As written in the Policy and Procedures, for example, DOE would be able to propose that a low-yielding aquifer is Class III groundwater even though people are currently using the aquifer as a source of drinking water.
The definition should be revised to ensure that it is consistent with the defintion provided in EPA's proposed standards.
7.
Figure 2.1, pg. 4 The two lower ovals on the right-hand side of Figure 2.1 identify Class IIIA and B groundwater that are "untreatable." The figure should be revised by deleting the word "untreatable" from these two ovals because the logic of the figure dictates that groundwater with TDS concentrations greater than 10,000 mg/l would be included in these subsets regardless of their treatability.
8.
Information Requirements, pg. 7 The text states that DOE typically collects sufficient information to assess regional water quality and the interconnection of adjacent groundwater units and surface water bodies. Based on previous NRC staff reviews of hydrogeologic characterizations of UMTRAP sites, the staff considers that DOE may need to collect more information than has been collected at UMTRAP sites to assess aquifer recharge-discharge relationships and water quality. Although j
information needs are determined on a site-specific basis considering the characteristics of the hydrogeologic system and DOE's compliance approach, additional information needs in support of Class III designations may include:
(1) vertical hydraulic conductivities, effective porosities, compressibilities, and storage characteristics of confining units; (2) detailed stratigraphy and structure of confining units; (3) location and quantification of discharge locations; (4) regional boundary conditions; (5) calibrated, numerical regional flow models; (6) detailed stream gaging to assess groundwater-surface water interconnection; (7) extended, multiple well aquifer testing; (8) water budgets; (9) flow nets; (10) analysis of regional water quality data using established data bases; and (11) water quality monitoring outside of the
'i WM-39/MFW/89/04/1C/ CLASS III immediate vicinity of the disposal / processing site. The text should be revised to indicate these potential, additional information needs or to describe how DOE will assess aquifer recharge-discharge relationships and regional water quality without acquiring additional information.
9.
Boundary Types, pg. 8 -
Although the text provides a relatively thorough discussion of boundary types, the text does not describe how boundary types influence decisions on groundwater classification.. Interconnection of relatively poor quality groundwater beneath disposal sites with higher quality waters downgradient could significantly restrict the flexibility of the supplemental standards for
-groundwater protection. The text should be revised to describe the importance of boundary types-in determining groundwater classifications and provide procedures for considering aquifer interconnection in classifying groundwater and demonstrating compliance with EPA's proposed groundwater protection standards.
- 10. Characterizing Background Water Quality, pg. 15 The text states that specific UMTRA Project quality control procedures provided in Section 7 of DOE's Technical Approach Document (TAD; DOE,1988) are probably adequate unless more rigorous statistical analyses are required.
This statement is confu!;ing because Section 7 of the TAD does not provide adequate 4
quality control procedures and because it is unclear why " rigorous statistical I
analyses" would require significantly different quality control procedures than the standard analyses performed by DOE. The TAD does not provide or reference adequate quality control procedures for collection, preservation, transportation, analysis, and assessment of water samples.
The quality control procedures in Section 7 of the TAD (pg.149) merely provide for analysis of ~
standard samples to assess analytical accuracy and replicate samples to assess analytical precision. These procedures do not appear to have been integrated with DOE's Quality Assurance Plan for the UMTRA Project.
The TAD does not even reference standard procedures for collection, handling, and analysis of water samples. Thus, the quality control procedures provided in Section 7 of the TAD do not appear adequate.
In addition, the text states that these procedures may need to be revised if more rigorous analysis of the data is required, but does
)
not explain why or how the quality control procedures would need to change in
{
support of the more rigorous analyses. The text should be revised to explain I
why and how the quality control procedures would need to be revised for more rigorous analysis of the water quality data and to delete statements about the 6dequacy of the procedures.
In addition, DOE should revise the quality control procedures provided in Section 7 of the TAD by (1) expanding them to cover significant aspects of sample collection, handling, and analysis, (2) integrating them with the QA Plan for the UMTRA Project, and (3) referencing standard procedures for sample collection, preservation, transportation, analysis, chain-of-custody, and assessment.
WM-39/MFW/89/04/10/ CLASS III u
- 11. Widespread Ambient Contamination and Elevated Background, pg. 15 The current description of widespread,' ambient contamination is incomplete and out of-place.
The description also unnecessarily introduces the concept of elevated background.
The concept of widespread, ambient contamination is only relevant in determining the applicability of the treatability criterion in EPA's definition of Class III groundwater.
Thus, it should be discussed in the context of evaluating the applicability of the treatability criterion in Section 5 of the Policy and Procedures.
In addition, the current description of widespread, ambient contamination is incomplete because it does not provide specific procedures to evaluate whether contamination is widespread and ambient.
DOE should consider revising the Policy and Procedures by including subordinate criteria for determining widespread, ambient contamination.
Such criteria could include:
(1) Widespread contamination is contamination (i.e., elevated concentrations of constituents) that extends in the groundwater unit across a substantial proportion of the Classification Review Area (e.g.,
10 square miles).
(2) Ambient contamination is contamination that surrounds the disposal / processing site and is representative of the composition of the groundwater within the unit.
(3) The source of the contamination has been reasonably identified and is not from the discharge of tailings fluids or leaching of solids or liquids associated with uranium processing (e.g., ore storage, reagent storage, raffinate recycling).
Further, the text implies that elevated background concentrations of constituents should be considered independently of widespread, ambient contamination.
However, the text does not explain why DOE distinguishes between widespread, ambient contamination and elevated background concentrations.
Elevated background concentrations in groundwater over a substantial fraction of the Classification Review Area and surrounding the processing / disposal site would be considered widespread, ambient contamination.
Contamination either qualifies as widespread, ambient contamination or it does not.
Thus, there is no need for a separate category for elevated background concentrations.
Elevated background concentrations that do not qualify as widespread, ambient contamination do not satisfy EPA's definition of Class III groundwater regardless of treatability.
Therefore, the Policy and Procedures should be revised to eliminate discussion of elevated background concentrations as a separate category of contamination.
- 12. Sufficient Yield, pg. 16 The text's description of the sufficient yield criterion should be revised to provide specific criteria and procedures for evaluating whether groundwater
i WM-39/MFW/89/04/10/ CLASS III,
units satisfy the criterion.
For example, the text should state that wells used in the analysis should be completed in the most permeable, saturated portion (s) of the groundwater unit to increase the probability that the unit yields greater than 150 gallons per day (gpd).
Reasonable measures should be employed to enhance yield from a well. DOE should assess reasonsbieness based on practices and techniques currently employed by water well drillers in the region surrounding the site. The text should also state that well yield must i
be sustainable at the 150 gpd level throughout the year.
In addition, the l
procedures should caution that well yield should be substantially less than 150 gpd (e.g.,130 gpd rather than 148.5 gpd) to demonstrate clearly that a unit may be considered Class III groundwater.
- 13. Determination of Reasonable Treatment, pg. 17 the paraphrased definition of Class III groun&ater provided in the first paragraph of this section should be revised se % is consistent with EPA's definition in 40 CFR Part 192.11(e).
DOE's pa.
. rased definition appears more stringent than EPA's definition in the standw As presently written, DOE's definition excludes consideration of reasonables, in assessing whether the water can be treated for consumptive use.
This coach may unnecessarily restrict DOE in proposing Class III groundwater s.signations.
Thus, the definition should be revised to ensure consistency with EPA's definition in the proposed groundwater protection standards.
14.
Table 5.1, pg. 18 The table should be revised to correct the typographical error for the number of water supply systems using chlorination in EPA Region X from 35 to 55 (see pg. 119 of EPA, 1986).
- 15. Determination of Reasonable Treatment, pg. 19 Step 2 of the procedures to evaluate treatability should be revised to provide specific procedures for selection of acceptable concentrations for contaminants. The procedures should include guidance on which values to select (e.g,, Maximum Contaminant Levels, Maximum Contaminant Level Goals, etc.), how to select acceptable concentrations, how to justify selected concentration limits, and how to develop concentration levels when such levels have not yet been established.
- 16. Determinat. ion of Reasonable Treatment, pg. 19 Step 3 of the procedures to evaluate treatability should be revised to rectity the incorrect statement that Table 4-10 of EPA (1986) includes all of the methods listed in Table 5.1.
Table 4-10 does not include chemical precipitation, chlorination, fluoridation, and flotation, even though these methods are listed in Table 5.1 of DOE's Policy and Procedures.
WM-39/MFW/89/04/10/ CLASS III 17. Determination of Reasonable Treatment, pg. 19 Step 4 of the procedures to evaluate treatability should be revised to state that " common treatment technologies" includes the methods listed in Table 5.1 that are used in all regions and those used in the particular region in which the site is locat J.
Tor example, an assessment of treatability at a site in Colorado (EPA Region VIII) would consider desalination and ion exchange in addition to the technologies applied in all regions because desalination, ion exchange, and the other technologies are used in EPA Region VIII to treat water for public consumption.
- 18. Determination of Reasonable Treatment, pg. 20 In addition to the procedures provided in this section to evaluate treatability, the Policy and Procedures should be revised to state that the evaluator may need to follow the procedures provided in Appendix G of EPA (1986) as an alternative approach to assessing the reasonableness of water treatment. Based on qualitative assessment of water treatment using only the procedures in the current Policy and Procedures, the evaluator may conclude that contaminated water can be cleaned up using treatment methods reasonably employed in public water-supply systems. However, semi-quantitative assessment of water treatment using EPA's procedures in Appendix G may indicate that contaminated water cannot be cleaned up. A finding based on the procedures in Appendix G would supersede a qualitative finding because Appendix G's procedures are more defensible and robust. Therefore, DOE should revise the Policy and Procedures to state that the procedures provided in Appendix G of EPA (1986) may be used as an alternative to the procedures described in Section 5.
References U.S. Department of Energy, 1988, " Technical Approach Document," UMTRA-DOE /
AL-050425.0001.
U.S. Environmental Protection Agency,1986, " Guidelines for Ground-Water Classification under the EPA Ground-Water Protection Strategy," final draft.
U.S. Nuclear Regulatory Commission,1989, " Standard Format and Content for Documentation of Remedial Action Selection at Title I Uranium Mill Tailings Sites."
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