ML20203B994

Forwards Comments on Remedial Investigation Rept & Feasibility Study for Cotter U Mill Site in Canon City,Co. Selection of Cleanup Alternative Considered Premature.Rept Fails to Provide 40CFR192 or State of Co Criteria

ML20203B994
Person / Time
Issue date:	03/25/1986
From:	Rich Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Hazle A COLORADO, STATE OF
References
REF-WM-22 NUDOCS 8604180319
Download: ML20203B994 (3)

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UlbiH1bUlAUN Dockst Filo WM-022 PDR/DCS DBangart,' RIV WM-022/TT0/86/03/24/0 T01sen ,

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MAR 2 51986 URFO:TTO Docket File WM-022 Albert J. Hazle, Director Radiation Control Division Colorado Department of Health 4210 E. lith Avenue, Room 355

-Denver, Colorado 80220

Dear Mr. Hazle:

We have reviewed the Remedial Investigation Report and Feasibility Study for the Cotter Uranium Mill site at Canon City, Colorado (Fremont County). Our specific comments are provided in the enclosure to this letter. -

To summarize those comments, (1) predict' ions of future conditions by use of the ground-water model are questionable since the parameters of the model are based on insufficient field data and sampling; and (2) the source control and remedial action measures presented in the study appear

, to cover the range of alternatives that could be implemented, but selection of alternatives based on the modeling effort could very well lead to an inappropriate choice that is neither adequately designed or cost effective in terms of expenditure. Reference is also made to polychlorinated biphenol (PCB) contaminated materials, but there is no evaluation or discussion pertaining to their remedial action in the report. Since PC8s are hazardous materials, their study and evaluation should include these and any other hazardous or toxic materials as part of any investigation for the purpose of remedial action. Accordingly, it may be premature to select a cleanup alternative until the proper field data has been accumulated an! explicit standards for cleanup adopted.

Finally, the report fails to provide criteria, such as 40 CFR Part 192, the alternative concentration limits of 40 CFR Part 192 or equivalent State of Colorado standards that will be used to determine if selected alternatives are adequate for the purposes of resecial action (s) at the mill site and vicinity.

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1 WM-022/TT0/86/03/24/0 MAR 2 51986 Regretfully, we will be unable to attend the public meeting on March 26, 1986, due to previous commitments. If you have any' questions regarding  ;

our review or items discussed in this letter, please contact '

Edward Hawkins at (303) 236-2805 or Tom.01sen at (303) 236-2813.

Sincerely,

. Isl R. Dale Smith, Director Uranium Recovery Field Office Region IV

Enclosure:

As stated I

cc: Duane Woodward, Attorney General State of Colorado William Brown, Counsel NRC, Region IV ,

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3 ColetENTS ON THE REMEDIAL INVESTIGATION REPORT AND FEASIBILITY STUDY FOR COTTER URANIUM MILL SITE AT CANON CITY, COLORADO (FREMONT COUNTY)

1. The report does not discuss the cleanup criteria that will be used.

Proper identification and selection of a remedial action alternative (s) will depend on the standards to be applied to the cleanup. It is possible that some of the alternatives could not  ;

reasonably accomplish the cleanup for some standards. .The report should be based on criteria such as 40 CFR Part 192 standards, alternative concentration limits in 40 CFR Part 192 or equivalent State of Colorado standards.

2. There is insufficient data on the mill site and vicinity in the ,

following areas: soils, geology, aquifer characteristics, '

geotechnical properties, and geochemistry; to name but a few. Such  ;

data is necessary to make informative decisions on restoration methods and their associated costs.. Also, more sufficient field

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data will pemit better model calibration and increase confidence-in '

the model. '

3. Model assumptions are numerous and, in many cases, do not appear to i satisfy the need for input parameters. There are altogether too many assumed and judgmental variables utilized in the model for adequate prediction with regard to the complex environment existing at the mill site and vicinity. Assumptions utilized in the model need to be thoroughly discussed as to their importance and how they impact the interpretation or prediction phases of the study. ,

4. The modeling effort and remedial actions do not address other hazardous or toxic materials. For instance, reference is made to PC8 contaminated material, but there is no evaluation or discussion pertaining to their remedial action. There is also a reference to TCE, but no evaluation. These other constituents should be '

addressed and considered in the remedial actions.

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