Permitting & Regulatory Support Projects

Radioactive Waste Disposal Facility

INTERA has provided geologic, hydrogeologic, and other technical support for several permit and license applications for a hazardous waste disposal and low-level radioactive waste storage and processing facility in Andrews County, Texas. This includes the license application to expand operations to include receipt, treatment, and disposal of low-level radioactive waste from both the Texas Compact and other federal agencies. Our efforts have focused on evaluating the regional and local geologic and hydrogeologic conditions in the vicinity of the site and have included a detailed literature review, borehole drilling and well/piezometer installation, borehole geophysics, evaluation of surface geophysical surveys (seismic and resistivity), surface mapping, excavation structural mapping and analysis, and development of comprehensive geologic and hydrogeologic conceptual models of the area.  Our responsibilities have also included interacting with regulatory agencies (i.e., the Texas Commission on Environmental Quality and the Texas Department of State Health Services), participating in client and agency meetings, conducting site and regional geologic and hydrogeologic field workshops with agency personnel, making technical presentations to regulatory agencies, providing testimony at regulatory hearings, and addressing various regulatory agency comments and requirements in the license applications.

Closure of a Rare Earths Facility

INTERA is currently assisting the Illinois Department of Nuclear Safety (IDNS) in the review of a license application for the closure and unrestricted release of a rare earths facility located in West Chicago, Illinois.  This effort involves a multi-disciplinary technical review of the application to determine whether the reclamation design and processes proposed by the applicant comply with the regulatory requirements in Title 32 of the Illinois Administrative Code 330, 332, 340, and 400.   The decommissioning plan calls for the excavation of impacted site soils and the backfilling of the excavations with residually contaminated soils.  Excavations will extend into the saturated zone in many portions of the site.  Sheet pile, slurry walls, and a dewatering well array will control groundwater levels during excavations beneath the water table.  If determined necessary, active groundwater remediation beneath the site will commence after excavation activities are completed.

INTERA’s involvement on the project is focused on groundwater issues on and in the vicinity of the site.  We developed the regulatory framework for the development of the Groundwater Protection Program at the facility consistent with 32 IAC 332.230 and 10 CFR 40, Appendix A.  Elevated constituents at the site include, but are not limited to, uranium, combined radium (226+228), nitrate, arsenic, and several metals.  INTERA has developed groundwater protection standards for the site, reviewed all groundwater monitoring information provided by the licensee, and provided consultation to IDNS in the development of a groundwater compliance program at the site consistent with NRC regulations codified in 10 CFR 40, Appendix A.  We are currently overseeing an off-site groundwater monitoring program to determine the extent of impacted groundwater downgradient of the facility. INTERA has also assisted in preparing environmental analyses (EAs) for each decommissioning phase. These EAs include:  (1) an assessment of the radiological and nonradiological impacts to the public health from the activities proposed by the applicant; and (2) an assessment of impacts on any waterway and groundwater resulting from previous activities and activities proposed by the applicant.  The assessment also includes the consideration of remedial alternatives and evaluation of the long-term impacts of the decontamination and reclamation activities proposed by the applicant.

Uranium Mill Closure Strategies

Over the last eight years, INTERA personnel have prepared numerous compliance documents and defense of strategies at the U.S. Nuclear Regulatory Commission (NRC) headquarters in Washington , DC and the New Mexico Environment Department Offices in Santa Fe, New Mexico.  Examples of completed studies and documents include: (1) developing a comprehensive conceptual model of the groundwater hydrogeology and geochemistry to serve as a basis for an alternate concentration limit (ACL) application;  (2) conducting a background water quality study that demonstrated that a number of sources, specifically mine pumping and discharge, seepage from the nearby U.S. Department of Energy facility and runoff/erosion from abandoned mine spoils and ore piles, had contributed constituents to the alluvial groundwater, and as a result, background groundwater in the alluvial materials is of low quality and of limited use; (3) developing a MODFLOW model of groundwater flow in the alluvial system underlying the uranium mill to assist in defining regulatory goals and boundaries and to support an as low as reasonably achievable (ALARA) demonstration; (4) preparing a predictive geochemical model of constituent concentrations in groundwater in support of an ACL application that demonstrated that the presence of excess reductive and neutralization capacity in alluvial materials acted to limit the migration of constituents from any of the multiple sources in the area causing a reduction in constituent concentrations in groundwater over time and over distance from the source; (5) developing risk scenarios to allow quantitative risk calculations at proposed point of exposure (POE) locations; and (6) preparing and obtaining approval of an ACL application for submittal to the NRC to amend the groundwater protection standards.

Groundwater Quality Standards

INTERA personnel provided expert testimony to the New Mexico Water Quality Commission on the efficacy of groundwater treatment technologies for uranium. Testimony involved discussions of three areas relating to proposed rule changes to 20.6.2 Administrative Code WQCC 02-18 including 1) the natural occurrence of uranium throughout the State of New Mexico, 2) the consequences of the application of proposed standards at various sites throughout New Mexico, and 3) an evaluation of the cost and feasibility of various treatment technologies. Specific testimony included expert evaluation of distillation, reverse osmosis, and ion exchange technologies applied to large-scale groundwater applications. The distillation discussion was based on long-term involvement with the distillation process (falling film and vapor recompression) being used at the Tuba City DOE Uranium Mill Tailings Remedial Action (UMTRA) site to treat groundwater.