ML20248C510
| ML20248C510 | |
| Person / Time | |
|---|---|
| Issue date: | 07/14/1989 |
| From: | Hawkins E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Matthews M ENERGY, DEPT. OF |
| References | |
| REF-WM-48 NUDOCS 8908100057 | |
| Download: ML20248C510 (4) | |
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- UNITED STATES.
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NUCl EAR REGULATORY COMMISSION '
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REGION IV o,
URANIUM RECOVERY FIELD OFFICE l-box 2S325
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DENVER, COLORADO 90225 f
JUL I 41989 g
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Docket No. WM-48 040WM048940E E
Mark Matthews, Acting Project Manager Uranium Mill Tailings Project Office
.U.S. Department of Energy P.O.. Box 5400 Albuquerque, New Mexico' 87115
Dear Mr. Matthews:
. We are in receipt of your June 13, 1989 submittal sent in response to our April 28, 1989 letter ~ requesting proposed point of compliance well locations and additional water quality data for the Bodo Canyon Depository Site. We agree with the selection of Wells 606 and 608 as point of compliance well locations.
However, we consider these as temporary point of compliance well locations until such time that it can be determined whether or not another location would be more appropriate.
Based upon the additional site characterization that we understand is to be undertaken, it may be determined that another location will better meet the criteria.
The additional. site characterization data should also verify whether or. not the Cliff House Sandstone should be considered part.of the uppermost aquifer.
The constituents listed in the enclosed table have been found in the ground
!L water at the Bodo Canyon site and are therefore hazardous constituents and should be included in your monitoring program.
You will note standards have been established for four hazardous constituents that you had not proposed to-monitor.
In addition to the constituents listed in the enclosed table,-you should also continue to monitor general chemical paretaters.
-Ground-water protection standards have been established using background water quality data from Well 601 and data from Wells 606 and 608 considered not affected by seepage.
For conservatism, we considered data after September, 1987,.for Well 606 and November,1987, for Wcl1608 to be impacted from the
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depository cell.
The established background water quality was compared with Table 1 (Draft 40 CFR Part 192.02(a)(3)) and ground-water protection stancards (maximum concentration limitr) were established.from whichever value was greater. The' standards established are shown in the enclosed table.
I The NRC finds that the ground-water protection standards for chromium and selenium have been exceeded at the point of compliance.
Therefore, pursuant to Draft 40 CFR 192.02(c), which specifies when the ground-water protection standards established under Draft 40 CFR 192.02(a) are found to be exceeded, a 8900100057 890714 f k
PDR WASTE PNV
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- JUL l 4 1989 corrective action program to restore ground-water is required. As per the draft standard, your corrective action program must be put into operation as soon as is practicable, and in no event later than 18 months after we find that the standards have been exceeded.
Therefore, corrective actions should be implemented as soon as is practicable, but in no event later than January 1, 1991. Accordingly,.please submit to this office, a proposed corrective action program for-review and approval by August 30, 1989.
Plee:e note that the standards consider' appropriate corrective actions to include removal or e
treatment in place of the hazardous constituents.
As part of your proposed program, please provide a discussion on how you will delineate the areal extent and concentration of hazardous constituents that may have migrated downgradient of the point of compliance.
The additional-l characterization program discussed with your staff on July 10, 1989, is encouraged and should provide important information in support of corrective actions at the site.
However, we encourage the addition of surface geophysical' surveys to the proposed characterization program.
Seismic, resistivity, conductivity, radar and other methodologies can provide valuable information in the suspected areas of seepage / ground-water flow that borehole data alone cannot-provide.
The issuance of this letter.was discussed between Mr. Hamp of your staff'and Mr. Grace of my staff on July 6 and July 10, 1989.
If you have questions, please contact Scott Grace of my staff at FTS 776-2805.
Sincerely, H w ins, ranci Chief '
Uranium Recovery Field Office Region IV
Enclosure:
As stated cc:
E. Damler, DOE S. Hamp, DOE E. Bischoff, Colorado Dept. of Health W. Milne, Colorado Dept. of Health Case Closed:
040WM048940E l
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Summary of Ground-Water Protection Standards at Bodo Canyon (all values in mg/l unless otherwise noted) j Ground-Water Values *4 Values q
Table 1*2
Background
Protection Exceeding Exceeding l
Value Value*8 Standard
Background
Standard Arsenic 0.0E 7<0.003 0.05 0.02 Barium 1.0
<0.01 1.0 0.12 Cadmium 0.01 (0.004 0.01
.008 Chromium 0.05
<0.01 0.05 0.13 0.13 Molybdenum 0.1
<0.03 0.1 0.08 Nitrate 10.0 1.38 10.0 6.1 Nickel.
0.04 0.04
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-Seleniuc.
0.01
<0.004 0.01 0.016 0.016 Silver 0.05
<0.01 0.05 0.03 Radium-226/
15.0 0.2 15.0 1.1 228*t Uranium *1 30.0
- 3. 9 30.0 7.4 Gross Alpha *1 15.0 2.4 15.0 12.2 Chloride 21.4 Sulfate 795 TDS-1565 pH 7.1
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- 2 From Table 1, 40 CFR Part 264.92 as cross referenced by Draft 40 CFR Part 192.02.
- 8. Established using the average of early data from wells 601, 606, and 608.
- 4 Where values at point of compliance wells 606 and 608 exceed the established background value, the maximum value is listed in this column to show the amount in which background was exceeded.
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WM-48/940E/SRG/89/06/21/L DISTRIBUTION Docket File WM-48
'PDR/DCS ABBeach, RIV SGrace HRose RQuillin, RCPD, C0 LLO Branch, LLWM URF0 r/f CONCURRENCE:
DATE:
SGrace/URF0 SR (c.
7 93 '
~7 I 4 23 GKonwinski/URF0
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