ML22286A178
| ML22286A178 | |
| Person / Time | |
|---|---|
| Site: | WM-00058 |
| Issue date: | 10/14/2022 |
| From: | Bolz B NRC/NMSS/DDUWP/URMDB |
| To: | Kautsky M US Dept of Energy, Office of Legacy Management |
| Bolz B, 415-3285 | |
| References | |
| Download: ML22286A178 (3) | |
Text
October 14, 2022 Mark Kautsky, Site Manager U.S. Department of Energy Office of Legacy Management 2597 Legacy Way Grand Junction, CO 81503
SUBJECT:
NRC STAFF REVIEW OF DRAFT SAMPLING AND ANALYSIS PLAN FOR THE SHIPROCK EVAPORATION POND DECOMMISSIONING PROJECT AT THE SHIPROCK, NEW MEXICO, DISPOSAL SITE (Docket Number WM-00058)
Dear Mark Kautsky:
I am writing in response to the U.S. Department of Energy (DOE) report entitled Draft Sampling and Analysis Plan for the Shiprock Evaporation Pond Decommissioning Project at the Shiprock, New Mexico, Disposal Site dated September 2022 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML22257A266).
The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the report and had the following comments:
- 1. In Section 2.5 Sample Collection Method the report states,
- a. If an intact core cannot be obtained of the sediment layer, the sampler will apply a modified collection approach that will include a scoop type method
- b. The mobility of the samplers in the pond may be hindered due to the sediment, which can impede movement similar to soft material encountered in shallow natural ponds and wetlands.
- c. Samplers will have the latitude to adjust locations locally, based on access and mobility, to keep worker safety a priority.
NRC staff would like to verify whether these samplers are human or machine. If human, what safety protocols will be in place to ensure their safety? Additionally, what measures will be taken to keep the samplers from damaging the pond liner and possibly causing a leak, as the samplers would likely be wearing heavy boots.
- 2. NRC staff would like to revisit several relevant comments made in previous correspondence.
- a. Comment #2 in the NRC Staff Review of Position Paper: Suspension of Groundwater Extraction and Evaporation Pond Operations (ML19074A025).
- b. Comment #1 in the NRC Staff Review of Draft Reevaluation of Ammonia, Manganese, Selenium, and Strontium as Contaminants of Concern (ML22242A316).
Both of these previous comments pertain to possible contamination below the pond liner. Since there have been liner defects in the past that have since been repaired, it is possible that a defect may have occurred and gone unnoticed due to being under the water line. A defect like this could have leaked contaminants into the soil below the liner. The NRC staff would like to know how DOE will determine if contamination exists below the liner. If DOE finds contamination below the liner,
M. Kautsky 2 i) how would DOE determine the extent of the contamination, and ii) what steps would the DOE take after characterization activities had been completed?
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
If you have any questions concerning the NRC comments, please feel free to contact me at 301-415-3285 or by email at brittany.bolz@nrc.gov .
Sincerely, Signed by Bolz, Brittany on 10/14/22 Brittany Bolz, Project Manager Uranium Recovery and Materials Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards Docket No.: WM-00058 cc: Shiprock ListServ List
Ltr ML22286A178 NMSS/DUWP NMSS/DUWP NMSS/DUWP OFFICE NMSS/DUWP/URMDB
/URMDB /RTAB /URMDB RVon NAME BBolz BB HArlt HA BBolz BB DMandeville for DM DATE Oct 13, 2022 Oct 13, 2022 Oct 14, 2022 Oct 14, 2022