ML21039A627
| ML21039A627 | |
| Person / Time | |
|---|---|
| Issue date: | 03/04/2021 |
| From: | Kevin Williams NRC/NMSS/DMSST |
| To: | Jasso T US Dept of Energy, Office of Legacy Management |
| Steve Poy, NMSS/MSST | |
| References | |
| Download: ML21039A627 (4) | |
Text
Tashina Jasso U.S. Department of Energy Office of Legacy Management 2597 Legacy Way Grand Junction, CO 81503
Dear Ms. Jasso:
I am responding to your April 29, 2020, submittal requesting our review and comment on the draft Long-Term Surveillance Plan (LTSP) that would become effective upon the license termination of the Western Nuclear, Incorporated Split Rock site (Wyoming Source Material License No. WYSUA-0056) located in Jeffrey City, Fremont County in Wyoming. We appreciate the opportunity to comment on this draft version of the LTSP.
The draft LTSP was reviewed in accordance with the criteria in NUREG-1620 Revision 1, Standard Review Plan for the Review of a Reclamation Plan for Mill Tailings Sites Under Title II of the Uranium Mill Tailings Radiation Control Act of 1978. NUREG-1620 is a standard review plan that provides the staff in the Office of Nuclear Material Safety and Safeguards with specific guidance on the review of reclamation plans and license amendments related to reclamation plans.
If you have any questions or comments, please contact Brian Anderson at 301-415-6799 or brian.anderson@nrc.gov.
Sincerely, Kevin Williams, Director Division of Materials Safety, Security, State and Tribal Programs Office of Nuclear Material Safety and Safeguards
Enclosure:
Comment table cc. D. Adams, WDEQ March 4, 2021 Clark, Theresa signing on behalf of Williams, Kevin on 03/04/21
1 NRC Staff Comments on Western Nuclear Incorporated (WNI)
Split Rock Site Draft Long-Term Surveillance Plan General Comments 1)
Within the Long-Term Surveillance Plan (LTSP), please include a groundwater a) contour map of the bounded site with recent groundwater elevation data.
Additionally, within the LTSPs commitment for future submittals to the U.S. Nuclear Regulatory Commission (NRC), please state whether groundwater plume maps and a groundwater contour map will be included with future groundwater monitoring reports submitted to the NRC.
Within an existing or additional map in the LTSP that displays the locations of all b) wells, please label the point of compliance monitoring wells and display the point of compliance trigger levels for each constituent selected for the long-term groundwater monitoring program and include. Please include a usable scale in all LTSP maps.
Consistent with Appendix D of NUREG 1620, please provide calculations of the c) estimated contaminant plume velocities (i.e., not just groundwater velocities) for the contaminants of concern and use the estimated velocities to further justify the sampling frequency and the evaluation of the length of the time period for the long-term groundwater monitoring program.
It is unclear whether well 5 is included legend of Figure E-38 (Time-Concentration d)
Plot of Uranium for NWV Wells) in the draft LTSP. Please correct this figure and other figures like it so they are legible.
Page E30 2)
Page E-30 of the draft LTSP (Section 3.2) states While [Alternate Concentration Limits (ACLs)] and surface water quality standards are expected to be met, uranium exceedances are possible under long-term management. Apart from this statement, which appears to be the final conclusion on the matter, other descriptions in the LTSP of a potential exceedance of the uranium surface water standard at the Sweetwater River are inconsistent and either describe the potential exceedance as being either likely or unlikely. Within the LTSP, please clarify that the above-referenced quote is the LTSPs final conclusion concerning the likelihood of exceedances of surface water quality standards at the Sweetwater River under long-term management. Additionally, based on all of the research and analysis provided in the LTSP, please provide a summary description of DOEs basis (reasonable assurance) for the final conclusion that the uranium surface water quality standard at the Sweetwater River is expected to be met (i.e., to be unlikely) under long-term management.
Page 6 3)
The LTSP states that land managed by the Bureau of Land Management will not be transferred before the license is terminated. While this is important information now, when the LTSP is accepted by NRC, either the land will have been transferred or other arrangements will have been made to ensure that the site will not be used in a way that could adversely impact the tailings. This statement should be deleted. When the final
2 LTSP is ready for acceptance by NRC, the land ownership should be updated to state the final condition.
Page 42 et al 4)
The following statement appears on pages 42, E-29, E-35, and E-69: Additionally,
[Wyoming Department of Environmental Quality (WDEQ)] communication states that, as the LQD found the ACL acceptable, if noncompliance were to occur, the LQD will actively advocate a solution with WQD, which would not impact DOE (WDEQ 2020). In addition, the following statements appear on page E-69: However, under UMTRCA, DOE, as the long-term custodian, is only authorized to carry out monitoring, maintenance, and emergency measures and no other actions unless expressly authorized by Congress (see UMTRCA, Section 104[f][2]). Therefore, potential response actions are limited. Results of the groundwater and surface water monitoring program will be included in the annual inspection and monitoring report. While these statements may be accurate (note that the citation to the Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA) refers to Title I sites and Western Nuclear Incorporated (WNI) is a Title II site), they could be confusing given actions the Department of Energy (DOE), NRC, and WDEQ may take if exceedances of constituents of concern are observed at the site. Therefore, these statements should be deleted from the LTSP.
Page 29 et seq.
5)
On pages 29, E-16, and E-17, the LTSP refers to the 2016 NRC memorandum summarizing a meeting with WNI as the documentation that the institutional controls (ICs) at the site are adequate. The WDEQ made an independent evaluation of the ICs; as WDEQ is the licensing authority, the DOE should cite the WDEQ conclusion regarding the ICs as its primary rationale. The NRCs 2016 memorandum can be cited for additional support as needed.
Appendix E 6)
Considering a component of groundwater flow from the source areas (e.g., tailings impoundment) is toward well SWAB-4 (LTSP Figures 14 and E-1 on page 24 and page E-3) and acknowledging that (1) Well SWAB-4 is approximately 3000 ft downgradient of the tailings impoundment and provides an early detection point for monitoring any site-related contamination; (2) the area of SWAB-4 is bounded by a granite outcrop to the east and land to the west where groundwater supply wells (e.g. irrigation and domestic wells) may be installed and used outside of the licensed site boundary in the future; and (3) SWAB-22 is approximately 400 ft inside the LTSB, 2000 ft downgradient of well SWAB-4, please include well SWAB-4 in the long-term groundwater monitoring program. During the long-term surveillance period, this well would provide early detection of significant levels of contaminants of concern moving toward points of exposure and would contribute to the monitoring of natural attenuation as well.
Similarly, please include Well 1 and Well 4R in the long-term groundwater monitoring program. These wells are located immediately next to the unlined disposal cells and would provide important monitoring information to track cell performance. Additionally, please document the screened internal of Well 1 and Well 4R in the LTSP.
Ltr ML21039A627 OFFICE NMSS/MSST/SLPB NMSS/DUWP
/URMDB NMSS/DUWP
/URMDB NMSS/DUWP
/URMDB NAME SPoy TLancaster DOrlando RVon DATE Feb 8, 2021 Feb 9, 2021 Feb 10, 2021 Feb 11, 2021 OFFICE NMSS/MSST/SALB NMSS/DUWP NMSS/MSST NAME BAnderson PHolahan KWilliams TClark for DATE Feb 11, 2021 Feb 17, 2021 Mar 4, 2021