ML20246E654
| ML20246E654 | |
| Person / Time | |
|---|---|
| Issue date: | 07/03/1989 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Matthews M ENERGY, DEPT. OF |
| References | |
| REF-WM-68 NUDOCS 8907120335 | |
| Download: ML20246E654 (4) | |
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s GRN/AGR LTR 'JUL 0 81999 Mr. Mark Matthews 1
. Acting Project Manager Uranium Mill Tailings Project Office Department of Energy Albuquerque Operations Office P.O. Box 5400 Albuquerque, New Mexico
Dear Mr. Matthews:
As you are aware, on April 5,1989 NRC and DOE met to discuss the remaining open issues on DOE's proposed remedial action at the Green River UMTRAP site, Green River, Utah. At the conclusion of this meeting both parties signed an agreementwithspecificcommitments(seeattachment1). DOE committed to
' fulfill 12 specific agreements and NRC committed to conditionally concur in the Remedial Action Plan (RAP). Based upon information recently received it appears that two of DOE's commitments have not been satisfied.
Sirce the NRC commitment to ccacur in the RAP was based upon DOE's fulfilling all of the' agreements reached in the above mentioned meeting, we withdraw our commitment.
l Specifically, in agreement no. 4 DOE committed to the following:
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- D0E comits to placing and maintaining contaminated materials in the disposal unit at the specified densities and at average moisture contents that are less than their average steady-stete moisture contents presented in the RAP and, in any case, less than 5% by volume for the tailings and less then 10.2% by volume for tt s windblown and other vicinity property contaminated material;. DOE will place and test at least four lifts of contaminated materials during the trial compaction (first 1,000 cyd of material), which is intended tu develop procedures to ensure compaction of the materials in accordance with material specifications. As part of the submission required under Condition 1 of this agreement, DOE will submit physical properties and compaction data on windblown material and any other data to support compliance with the condition that contaminated materials will be placed and maintained at the specified densities and moisture content."
By letter dated May 16, 1989, DOE submittec data called for in agreement no. 4.
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which included data on the moisture content for the tailings material.
The NRC staff has completed its review of this information, as well as completing an inspection of the Green River site which included additional data on the moisture content in the tailings material. Based on our review, the NRC staff concluded that the data shows the average moisture content for the tailings to be 7.1%, which is significantly in excess of the 5%
moisture content committed to by DOE in agreement no. 4.
An increase in the moisure content of over 40% may cause a significant decrease in groundwater
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travel time to the point of compliance thus impacting DOE's ability to comply l
with the EPA standards.
It should also be pointed out that DOE has yet to notify the NRC that they have not fulfilled agreement no. 4.
The second committment in question relates to agreement no. 1 in which DOE i
commited to the following-1 Given that groundwater travel time through the buffer and unsaturated i
rock beneath the disposal unit may be less than 1000 years but greater than 200 years, and that it is difficult, if not impossible, to estimate the groundwater travel time with accuracy, DOE commits to submitting to NRC within 30 days of this meeting an adequate written justification that the present design of the disposal unit, as modified by the conditions agreed to herein, represents the best design to comply, to the extent reasonably achievable, with EPA's proposed standards in 40 CFR Part 192, Subpart A."
The DOE submittal responding to this agreement was incomplete. Rather than providing a justification that the design selected was the best design to comply with EPA's proposed standards, the submittal provided a discussion and identification of various features incorporated into the design selected by 1
D0E. Therefore, based on our review, DOE has also not fulfilled agreement no. 1.
l To assist in resolving issues in this area an example of the type of I
justification required was prepared by NRC staff. This example, while not in depth technically, consisted of a systematic analysis of the factors impacting the design and was provided to DOE on M4y 25, 1989. The NRC staff is currently awaiting DOE's resubmittal of this justification.
Based on our review, DOE has not fulfilled the commitments necessary for the NRC to conditionally concur with the RAP. Therefore, until the NRC conditionally concurs in the Green River RAP, all on-going work at the Green River site is 4
being conducted at DOE's own risk.
It should also be pointed out that DOE's inability to fulfill the first two agreements that we have received information on (nos. I and 4) does not provide the NRC with confidence that the remaining 10 commitments will be met.
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1 GRN/AGR LTR L p i
Should you have any questions regarding the above information please contact me,.or H. Fliegel of ny staff at FTS 492-0555.
Original' Si' geed By Paul Lohaus, Chief Operations Branch Division of Low Level Waste Management and Decommissioning
Enclosure:
As stated I
cc:
S. Hann, DOE /HQ J. Baublitz, DOE /HQ L. Anderson, Utah C. Watson, DOE /AL DISTRIBUTION:
y" Central file:f WM.6ffPtohaus,LLOB SWastler,LLOB DGillen,LLOS MBell,LLWM" JAustin,LLRB MFliegel,LLOB RHall,URF0 JGreeves,LLWM RBernero,NMSS JSurmeier,LLTB NMSS r/f PDR Yes /X /
PDR No
/ / Reason:
Proprietary /~/ or CF Only / /
ACNW Yes /X /
No
/ /
SUBJECT ABSTRACT: Green River Agreements of April 5,1989
- See Previous Concurrence OFC :LLDBi
- LLOB*
- LLOS 1 1 1
.....:............:............:.....LA..:...........:............:_...........:...........
NAME :SWastler
- MFliegel
- PLohaus DATE :06/ /89'
- 06/ /89
- @/ 3/89 OFFICIAL RECORD COPY
GRN/AGR LTR 3-i G-i Should you have any questions regarding the above information please contact
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4 me, or M. Fliegel of my staff at FTS 492-0555.
Paul Lohaus, Chief Operations Branch Division of Low Level-Waste Management and Decommissioning
Enclosure:
As stated cc:
C. Watson, DOE /ALs S. Mann, DOE /HQ
'N L. Anderson, Utah
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- Central File: WM.68 PLohaus,LLOB SWastler,LLOB DGillen,LLOB MBell,LLWM JAustin,LLRB MFliegel,LLOB, RHall,URF0 JGreeves,LLWM JJSurmeier,LLTB NNMSS r/f PDR Yes /X /
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PDR No L / Reason: Proprietary /~~/Nor CF Only /-~/
ACNW Yes /X /
No
/ /
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SUDsECT ABSTRACT: Green River Agreements of April 5, 1989 m
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LATE:06fh}h/89
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- 06/ /89
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OFFICIAL TELORD COPY ss x
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UNITED STATES j
NUCLEAR REGULATORY COMMISSION n
5 WASHINGTON. D. C. 20056
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Suunnary Meeting Notes NRC/ DOE Meeting on the Green River Remedial Action April 5, 1989 Locat a : NRC Headquarters, One White Flint North, Rockville, Maryland
Participants:
See attached list
Purpose:
To discuss open issues pertaining to DOE's proposed remedial action at the Green River UNTRAP site, Green River, Utah, and to reach agreement on the conditions of NRC's concurrence with the remedial action.
Agenda:
See attached _ agenda Summary: After an introduction by the NRC staff. DOE and NRC' discussed in detail the technical aspects of each proposed agreement. As a result of these discussions, DOE coassits, by their signature on these meeting minutes, to fulfill the agreements as stated below. Based on DOE's cosuitttment to these, agreements, the NRC, by their signature, commits to conditionally concur on the Remedial Action Plan (RAP).
Agreements:
1.
Given that groundwater travel time through the buffer and unsaturated rock beneath the disposal unit may be less than 1000 years but greater than 200 years' and that it is difficult, if not impossible, to estimate the groundwater travel time with accuraq, DOE commits to submitting to NRC within 30 days of this meeting an adequate written justification that the present design of the disposal unit, as modified by the conditions agreed to herein, represeints the best design to comply, to the extent reasonably achievable, with EPA's proposed standards in 40 CFR Part 192, Subpart A.
2.
DOE commits to assessing whether the contaminated windblown and vicinity property materials are significant sources of hazardous constituents to groundwater by leaching representative samples of the materials using EPA's EP Toxicity Test Procedure (40 CFR Part 261 Appendix II) or comparable NRC-approved procarbre and comparing hazardous constituent concentrations in the leachate with coccertrations in leachate from representative soil samples collected in the vicinity of the site.
3.
DOE commits to performing representative testing of the radon barrier to ensure that its as-built saturated hydraulic conductivity does not exceed 2E-8 cm/s and to assess its unsaturated hydraulic characteristics (tension as a function of moisture content; hydraulic conductivity as a function of moisture content). Samples for hydraulic conductivity tests should be taken at a
' frequency of at least one per 2000 yd of as-compacted radon barrier material, which is estinaled to be 48000 cyd. Sampla locations should be distributed J4mdARmzLoM __ LW AP
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2 evenly over the cover, provided that at least 50% of the samples are collected from the side slopes of the disposal unit. At least 13 of the 14 samples (approximately 905) must exhibit saturated hydraulic conductivities less than or equal to 2E-8 cm/s. Standard geotechnical parameters, such as physical properties, should also be determined for the samples.
4.
DOE commits to placing and maintaining contaminated materials in the disposal unit at the specified densities and at average moisture contents that are less than their average steady-state moisture contents presented in the RAP and, in any case, less than 55 by volume for the tailings and less than 10.65 by volume for the windblown and other vicinity property contaminated materials.
DOE will place and test at least four lifts of contaminated materials during the trial compaction (first 1,000 cyd of material) which is intended to develop procedures'to ensure compaction of the materials in accordance with material specifications. As part of the submission required under Condition 1 of this agreement, DOE will submit physical properties and compaction data on windblown material and any other data to support compliance with the condition that contaminated materials will be placed and maintained at the specified densities and moisture contents.
5.
00E commits to mixing %nogeneously no less than 65 by weight sodium bentonite into the radon barrier materici and compacting the radon barrier to 100% of standard Proctor density within 0 to +35 of Optimus Moisture Content.
6.
DOE couaits to using a minimum gradation specification for the radon barrier material of greater than 70% of the material passing the no. 200 selve for the first lift and 50% of the material passing the no. 200 selve for the 1
remaining lifts.
7.
DOE commits to evaluating whether beryllium is a hazardous constituent in the contaminated materials at Green River by determining its concentration in representative samples of the tailings or pore fluid within the tailings.
If present at elevated concentrations in the contaminated materials, DOE will include beryllium in the list of hazardous constituents for the Green River disposal site.
8.
DOE commits to including arsenic, lead, and methylene chloride in the list of hazardous constituents for the disposal unit.
9.
DOE commits to the concentration limits listed in the enclosed table as the appropriate interim concentration limits for hazardous constituents in groundwater in the u.ppermost aquifer at the Point of Compliance. NRC may revise these interim limits based on new monitoring data to be collected during and following construction of the disposal unit.
- 10. DOE commits to collecting and analyzing representative samples of groundwater from monitoring wells 807, 812, 813, 818, and 823 on a quarterly basis during construction of the disposal unit; DOE commits to collecting and analyzing representative samples of groundwater from these monitoring wells and new wells at the Point of Coupliance and background locations on a quarterly
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basis for two years after completion of the disposal unit. DOE will establish
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details of the monitoring program in the Surveillance and Maintenance Plan or another appropriate document upon NRC concurrence with the Plan or other document.
- 11. DOE commits to a Point of Compliance that is as close as reasonable to the disposal unit and extends along the entire northwest and northeast edges of the unit.
12.
DOE commits to demonstrating compliance with EPA's groundwater cleanup standards of Subpart B and C of 40 CFR part 192 after EPA finalizes them.
Signatures:
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Paul Lonaus,' RE Richard Richeiy, UUr.
Q y n F1TegelfRRC Signed this 5th day of April,1989, in Rockville, Maryland.
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DOE /NRC Meeting on Green River April 5, 1989 NAME AFFILIATION PHONE Michael Weber NRC/LLOB FTS 492-0565 Banad Jagannath NRC/LLTB FTS 492-0593 P. K. Chen, Morrison-Knudsen Enviro.
(415)442-7487 Ronald E. Rager TAC FTS 846-1329 Larry Coons TAC /SNB FTS 846-1250 Dave Mathes DOE /NE-22 FTS 353-2799 Richard Richey 00E/tMTRA FTS 846-1210 Sandra Wastler NRC/LLOB FTS 492-0582 Myron Fliegel NRC/LLOB FTS 492-0555 Michael Tokar NRC/LLTB FTS 492-0590 Paul Lohaus NRC/LLOB FTS 492-3345 l
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J AGENDA NRC/00E GREEN RIVER MEETING April 5, 1989 White Flint North - Room 6-8-11 8:00 am Introduction 8:30 am Discussion of Issues
- Travel Time
- Geotechnical/ hydrological
- General 11:30 su Lunch Whita Flint Pgrth - Room 6-B-13
' 12:30 pm Preparation of Meeting Minutes / Agreements 1:00 pm Close-out Discussion with J. Greeves 1:30 pm Conclusion of Meeting t
,s Table 5.1 Hazardous Constituents and Concentration Limits for Disposal at the Green River UMTRAP Site (unf ts in mg/1, unless noted otherwise) k Constituent 00E Proposed Limits Interim Concentration Limits 1
Arsenic i
0.05(MCL)
Chromium 0.09 (Background) 0.05 (MCL)
Methylene Chloride x
0.005 (Background)
Molybdenum 0.24(Background) 0.1 (McL)
Nickel 0.09 (Background) 0.06(Background)
Nitrate 180 (Background) 60 (Background)
Selenium 2.50(Background) 0.66 (Background)
'dantum 234/238 0.146(Background) 0.644(MCL)
Vanadium Pentoxide 0.38 (Background) 0.09 (Background)
Radium-226/228 5.0pC1/1(MCL) 5.0pCf/1(McL)
Gross. Alpha (exc1'uding U and Rn) 195pC1/1(Background) 24.5pCf/1(Background)
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