ML20248C589
| ML20248C589 | |
| Person / Time | |
|---|---|
| Issue date: | 07/14/1989 |
| From: | Grace S, Hawkins E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| REF-WM-48 NUDOCS 8908100096 | |
| Download: ML20248C589 (13) | |
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., NUCLEAR REGULATORY COMMISSION -i n3 ij , REGION IV
,h ok. URANIUM RECOVERY FIELD OFFICE y .
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DENVER, COLORADO 80226 ,
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JUL 141089 ,
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b ' Docket No..WM-48 :R 040WM48940E- l
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MEMORANDUM FOR: ' Docket' File No. WM-48 h
'FROM: Scott R. Grace, Project Manager j
~ Uranium' Recovery F; eld Office
. Region.IV '
SUBJECT:
ESTABLISHMENT OF GROUND-WATER PROTECTION STANDARDS FOR.THE- i L '
BODO CANYON DEPOSITORY SITE AND NOTICE FOR 00E TO SUBMIT ;
CORRECTIVE ACTION PROGRAM ;
lj iBACKGROUND.- l
'In our January .31,1989 letter, we requested DOE to propose background water l quality (with supporting data), point of compliance well. locations and .j constituents to be monitored for the Bodo Canyon Depository area. In partial '
response to the above request, DOE submitted a Status Report on Hydrological i Conditions at the Bodo Canyon Facility on March 2, 1989. In this submittal, l DOE proposed background water quality for the~ uppermost aquifer, but did not. !
propese point'of compliance'well locations'or constituents to be monitored.
The March' 2,1989. submittal was primarily in .rcsponse io our request for-information as a result of the occurrence'of the saturation of the. relocated tailings at Bodo Canyon.
Relocation of tailings from the Durango processing site to the Bodo Canyon l Depository site began in June of 1987. In October of 1988, a seep appeared on i
? the east face of the disposal cell. The seep was a surface manifestation of )
.tho' saturation
. infiltration fromofconstruction the disposalwatering cell withand water believed toThe precipitation. be aline combination of seepageof l 1s# coincidental to the elevation of the upturned edge of the bottom low- !
permeability layer on tne east face of the' disposal cell. DOE has determined '
that'up to 28 feet of the tailings have saturated and that approximately I 10,000 gallons a day are seeping out the bottom of the disposal cell.
Additionally, they predicted that their proposed ground-water protection j standards would be exceeded.
In th_ire March 2, 1989 submittal, DOE said that the most recent water quality ~
data did not indicate that the leachate had reached Wells 606 and 608. NRC disagreed with their conclusion. The staff noted indications that seepage 8908100096 890714 %- Of. i
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r 2 JUL 1 4 1989 reached Well_606 by the fall of 1987 and Well 608 by_the end of 1987. This was L indicated by increases in Well 608 of arsenic, gross alpha and selenium by orders of magnitude, t as well as increasing concentrations of chloride, nitrate and. uranium by more than 100 percent. On April 28, 1989,'NRC notified DOE that
.they should propose point of compliance well locations and hazardous constituents to monitor so that we could establish ground-water protection standards. We requested this information by May 15, 1989. DOE submitted this information on_ June 13, 1989. The site well,s are shown in Figure 1.
DOE's June 13, 1989 submittal contained additional water quality analysis results, proposed points of compliance and agreement that seepage may be impacting the downgradient wells. DOE proposed wells 608 and 606 as point of compliance well. locations. NRC agrees with this selection of point of compliance well locations. However, as discussed below, the NRC considers these temporary locations until such time tht.t DOE can verify that they are appropriately located. NRC used wells 601, 606 and 608 to establish background, as discussed below. Tables 1 and 2 summarize water quality data for wells 606 and 608, respectively.
The draft regulations (52 FR 36000; September 24, 1987) require standards to be set when hazardous constituents have entered the ground water from the regulated unit-(Draft 40 CFR 192.02(a)(3), which cross references 264.92). If these standards are found or projected to be exceeded, a corrective action program is required to be put into operation (Draft 40 CFR 192.02(c)). j GROUND-WATER PROTECTION STANDARDS Uppermost Aquifer The upper hydrostratigraphic unit in Bodo Canyon is a water table aquifer system consisting of the alluvium, colluvium, and weathered bedrock (the alluvial aquifer). The alluvial aquifer is of limited areal extent. The limited site characterization indicates that flow of this system is north-eastward, discharging out of Bodo Canyon concurrent with surface water drainage to the northeast (this drainage is called South Creek downstream at the Durango processing site). Ground-water flow may also exist to the east in the vicinity of Well B-6 (as shown in Figure 1). The next-lower 4 hydrostratigraphic unit is the confined Cliff House Sandstone. Initial site ;
characterization data indicate that there is no significant hydraulic '
interconnection with the Cliff House Sandstone. However, the DOE should be encouraged to further characterize this unit to determine whether or not it is ;
significantly connected with the water table unit above. DOE intends to further characterize the site this year. Results of this program should verify whether i or not the Cliff House should be considered a part of the uppermost aquifer. j Hazardous Constituents Hazardous constituents are constituents identified in Appendix VIII of Part 261 that have been detected in ground water in the uppermost aquifer underlying a regulated unit ard that are reasonably expected to be in or derived from water -
contained in a regulated unit. The constituents found to meet the above criteria are listed in Tables 1 and 5 of this memo. ,
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6 3'. M I4 E We requested a listing of constituents to be monitored. The June 13, 1989 submittal contained DOE's. proposed list. DOE proposed to monitor arsenic, cadmium, chromium, molybdenum, nickel, combined radium-226.and 228,, selenium, uranium, vanadium and zinc. DOE's proposal did not include several constituents NRC considers to be hazardous constituents as described in the Draft 40 CFR.Part 192.02(a)(3) which references 264.93(a). These additional constituents include barium, nitrate, silver and gross alpha. These constituents have been found to exist in the ground water at other tailings facilities and have been found at the Bodo Canyon site. Therefore, these .
hazardcus constituents should be added to the list to be monitored. The staff
. reviewed the monitoring data and do not find beryllium, cyanide, mercury, lead,
- thallium and thorium-230 in the ground water. Therefore, these.will not be
- . considered hazardous constituents at the Bodo Canyon site. Additionally, DOE should monitor parameters such as chloride, sulfate, total dissolved solids.and pH to provide general indicators of water quality to satisfy NEPA responsibilities.
Background Water Quality In DOE's June 13, 1989 submittal, background water quality was proposed. The proposed values were derived from concentrations of constituents in wells 606 and 608 in the first three sampling events (September 1987, November 1987 and j April 1988). The averages of these values were the proposed standards. These are shown in Table 1. DOE believes these values are pre-impact. For conservation, NRC considers the first two sampling events to be pre-impact and appropriate for use in establishing background. Tables 2 and 3 summarize the water quality analysis for wells 606 and 608, respectively. This data was from the March 2 and June 16, 1989 DOE submittals.
An upgradient background well cannot be located in the alluvial aquifer because the tailings cell covers all appropriate areas. Furthermore, due to the limited size of the drainage basin, cross gradient background wells also cannot be located. Therefore, background must be established using water quality data prior to tailings relocation (one sampling event) and downgradient well data (wells 606 and 608) prior to impact.
Due to the limited ground-water characterization of Bodo Canyon prior to tailings relocation, only one water quality sampling event occurred in the uppermost aquifer prior to start of tailings relocation. This sampling was in Well 601'on January 23, 1985. Wells 606 and 608, completed in the uppermost aquifer, were also used in establishing background water quality. The early data from these two wells are believed not to be affected by seepage.
Therefore, background water quality was established using the Well 601 sampling, the first sampling of Well 606 and the first two sampling of Well 608. This general approach averaging four data points has been used in setting background and. subsequent ground-water protection standards at other sites (Title II). Table 4 of this memo summarizes the establishment of background water quality for the hazardous constituents at Bodo Canyon.
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4 JUL 141989 Establishment of Ground-Water Protection Standards Ground-water protection standards (concentration limits), are set as required by Draft 40 CFR 192.02(a)(3) which references 40 CFR 264.94(a). The standards were established as either the background water quality or Table 1 of Draft 40 CFR 192.02, whichever is greater. Table 5 of this memo summarizes the ground-water protection standards established.
Point of Compliance DOE proposed Wells 606 and 608 as point of compliance well locations in their June 13, 1989 submittal. The staff find that these wells would make adequate temporary point of compliance well locations, as they generally meet the criteria established by Draft 40 CFR 192.02 which references 40 CFR 264.95.
The NRC considers these locations as temporary locations until such time that DOE can verify that they are appropriately located. That is, the point of compliance well location should be situated such that they provide prompt indication of ground-water contamination on the hydraulically downgradient edge of the waste management area. There is some uncertainty that these wells are located to provide the earliest indication of seepage. The staff considers the best location to be a well completed in the upper transmissive zone of the lowermost portion of the paleo-drainage channel. This would be a location in the transmissive zone of the lowermost weathered bedrock in the vicinity of the current drainage. DOE intends to further characterize the site later this year. However, Wells 606 and 608 are designated as temporary point of compliance wells until such time that DOE verifies the appropriateness of their locations.
Standards Exceeded Based upon the standards established, two hazardous constituents, chromium and selenium, are found to be in excess of the designated standard at the point of compliance well locations.
CORRECTIVE ACTION PROGRAM As required by Draft 40 CFR 192.02(c), if the established ground-water standards are found or p*ojected to be exceeded, a corrective action program must be put into operation as soon as is practicable, and in no event later than 18 months after NRC finds that the standard has been exceeded. Therefore, the staff recommend > that DOE submit a proposed plan for review and approval by August 30, 1989. The plan must be f ully in operation no later than January 1, 1991. The corrective action program should include a discussion of how the areal extent and concentration of hazardous constituents will be delineated, as well as how the hazardous constituents exceeding the standard are to be removed or treated in place.
On July 10, 1989, NRC met with DOE to provide verbal comments on their proposed additional characterization of Bodo Canyon. DOE's proposed program includes drilling additional boreholes, conducting aquifer testing, and -
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conducting don'nhole geophysical logging of new and old boreholes. New boreholes are planned for both the alluvial and Cliff House aquifers. NRC encouraged DOE to proceed with the proposed program but with the addition of a surface geophysics program, specifically seismic profiles. However, other surface geophysical methods (resistivity, conductivity, side scanning radar, etc) should t.so be considered.
SUMMARY
Due to indications of seepage from the Bodo Canyon Depository site, ground-water protection standards we. c established using background or Table 1 of Draft 40 CFR 192.02(a)(3). Stcadards for chromium and selenium are exceeded at the point of compliance wells. As a result, DOE must put into operation a corrective action program, as required by Draft 40 CFR 192.02(c). In their proposed plan, DOE should follow the guidance presented in (1) NRC's Staff Technical Position entitled " Standard Format and Content for Documentation of Remedial Action Selection at Title I Uranium Mill Tailings Sites," cated February 24, 1989, and (2) NRC's Draft Technical Position entitled "Information Needs to Demonstrate Compliance with EPA's Proposed Ground-Water Protection Standards in 40 CFR Part 192, Subparts A-C" dated June 1988.
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Scott R. Grace, Project Manager Uranium Recovery Field Office Approved by: h//L .
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Edward F. lidwkin5, Branch Chief Uranium Recovery Field Office l
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Table 1 - Proposed Ground-Water Protection Standards (from DOE's submittal dated June 13, 1989)
(All values in milligrams / liter (mg/1) unless otherwise noted)
Mean Mean Proposed Background Source MCL*2 As .004 .243 .05 Cd 002 .035 .01 Cr .01 .067 .05 Mo .077 1.95 .1 Ni .02 .04 -
Ra-226 & 228*1 .522 6.8 5 Se .0051 .1726 .01 U .005 7.4 .004 V .04 10.4 -
Zn .0185 2.12 -
Constituents with no proposed standard Barium Nitrate Silver Gross Alpha
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l Table 4 - Summary of Bodo Canyon Uppermost Aquifer Background Water Quality (from 00E data) l (all units in mg/l unless otherwise noted) j 601 606 608 608 1/23/85 9/13/87 9/18/87 11/23/87 Background l
Arsenic <0.01*2 <0.001 <0.001 <0.004 <0.003 Barium <0.01 - - -
<0.01 )
Beryllium - - - - - "
Cadmium <0.001 <0.005 <0.005 <0.005 <0.004 Chromium <0.01 - - -
<0.01 Cyanide - - - - -
Mercury <0.0002 <0.0002 <0.0002 <0.0002 <0.0302 Molybdenum <0.01 <0.01 .02 .09 <0.03 l Nitrate - - - -
1.38*3 Nickel (0.04 - - -
.04 Lead <0.01 - - -
<0.01 Selenium <0.005 <0.001 .001 .009 <0.004 Thallium - - - - -
Silver <0,1*2 <0.01 <0.01 <0.01 <0.01 !
' Radium-226/228*2 <1.0*2 -
.212.1 .211.3 .211.7-Thorium-230*2 <1.0*2 -
.212.1 .31.5 .31.5 Uranium *2 .0104 .0096 .0009 .0021 .0058 Uranium 7.0 6.5 .6 1.4 3.9 Gross Alpha *2 - - - -
2.4*3 Chloride 36 12 18 23.7 21.4 l Sulfate 1800 726 524 731 745 TOS 2180 1370 1270 1440 1565 pH 7.6 7.1 6.9 6.8 7.1
^1 pCi/l C8 Value not used in background computation due tn LLO being too high.
23 Oue to a limited set, background was established using the mean plus two standard deviations from the five data sets of the 4/7/88 data. Although some indications of seepage impact are noted for this sampling date, there are no obvious indications of l impact on nitrate and gross alpha. For nitrate, the five analysis for 4/7/88 averaged 1.12; standard deviation of 0.13; for an established background of 1.38. For gross alpha, the five analyses for the 4/7/88 data averaged 0.6 1 11.0; standard deviation of 0.89 1 0.7; for an established background of 2.4.
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Table 5 - Summary of Ground-Water Protection Star >dards at Bodo Canyon (all values in mg/l unless otherwise noted)
Ground-Water Values *5 Values Table 1*2 Background Protection Exceeding Exceeding Value Value*3 Standard Background Standard Arsenic 0.05 <0.003 0.05 0.02 -
Barium 1.0 <0.01 1.0 0,12 -
Beryllium *4 - - - *4 - -
Cadmium 0.01 <0.004 0.01 .008 -
Chromium 0.05 <0.01 0.05 .13 .13 Cyanide *4 - - - *4 - -
Mercury *4 0.002 <0.0002 - *4 - -
Molybdenum 0.1 <0.03 0.1 0.08 -
Nitrate 10.0 1.38 10.0 6.1 -
Nickel -
0.04 0.04 - -
Lead *4 0.05 <0.01 - ^4 - -
Selenium 0.01 <0.004 0.01 0.016 0.016 Thallium *4 - - - *4 - -
Silver 0.05 <0.01 0.05 0.03 -
Radium-226/ 15.0 0.2 15.0 1.1 -
228*1 Thorium-230*1*4 -
- 0. 3 - *4 - -
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
-~~
^2 pCi/l n2 From Table 1, 40 CFR Part 264.92 as cross referenced by Oraft 40 CFR Part 192.02.
as From Table 4 of this memo.
- 4 Not detected in ground water at reasonable detection limit; therefore, not a hazardous constituent at this site.
- 5 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 background was exceeded.
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WM-48/940E/SRG/89/06/21/M DISTRIBUTION Docket File WM-48 LPDR/DCS'
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HRose RQuillin, RCPD, C0 LLO Branch, LLWM URF0 r/f
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CONCURRENCE: DATE:
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