ML19207B548
| ML19207B548 | |
| Person / Time | |
|---|---|
| Issue date: | 04/02/1976 |
| From: | Anders W NRC COMMISSION (OCM) |
| To: | Staats E GENERAL ACCOUNTING OFFICE |
| Shared Package | |
| ML19207B549 | List: |
| References | |
| RULE-PRM-20-7 NUDOCS 7908300237 | |
| Download: ML19207B548 (10) | |
Text
~
UNITED STATES y
l*g NUCLEAR REGULATORY COMMISSION
- 2. {p e $ $
- f I WASHINGTON. D. C. 20555
- {'Td[7[,8 9E
-i APR 2 1976 OFFICE OF THE CH/.lRM AN Honorable Elmer B. Staats Comptroller General of the United States General Accounting Office
Dear Mr. Staats:
This is to acknowledge receipt of your letter of January 12, 1976 transmitting to Congress copies of your report entitled,
" Improvements Needed in the Land Disposal of Radioactive Wastes--A Problem of Centuries".
Enclosed is a copy of a statement provided to Congress which sets forth the actions NRC has taken and plans to take to implement the recommendations of the GAO report and explains that additional funding and staff may be needed to carry out
{theGAOrecommendations.
Sincerely,
' William A. Anders Chairman
Enclosures:
Letters to the Chairman, Senate Committee on Government Operations, and Chairman, House Committee on Government.
Operations w/ enclosed NRC t
Actions on GAO Recommendations' on Waste Burial and attached !
Summary of MTjor Events at Maxey Plats Burial Grounds, 1970-1976 cc:
Dr. Robert Seamans
' Taministrator cn 7^%
Energy Research and b3d JdJ Development Administration t
^
7908300 N h
NRC ACTIONS ON GAO RECOMMENDATIONS ON WASTR BURIAL
(
Actions to be taken by NRC to implement the recommendations in GAO report " Improvements Needed in the Land Disposal of Radioactive Wastes--A Problem of Centuries".
1.
Recommendation that NRC and ERDA jointly should:
Enlist the cooperation of other Federal and State agencies with regulatory or program responsibilities and expertise and sponsor a comprehensive study of existing commercial and ERDA disposal sites to better evaluate their ability to retain radioactive waste; and Use the results of the comprehensive study to develop site selection criteria for determining the long-term suitability of existing disposal sites and for selecting future sites.
2.
Recommendation that ERDA and NRC jointly develop radiation detection standards for' disposal sites and issue such standards for universal application.
(, 3.
Recommendation that ERDA and NRC direct their staffs,
~
as part of the comprehensive study previous?.y recommended, to-evaluate the effectiveness of monitoring programs at existing disposal sites and to redesign them as necessary and that redesign work should be done in conjunction with Agreement States for disposal sites regulated by such States.
NRC Action:
When the Nuclear Regulatory Commission was created in January 1975, the Waste Management Branch in the Office of Nuclear Material Safety'and Safeguards was established.
The primary responsibility of the e
branch was to do a full reassess.nent of. the existing waste management program, to recommend what actions needed to be taken to improve the existing programs, and to work toward greater inter-agency cooperatf.on.
In responding to recommendations 1, 2 and 3, th(7 branch arranged for a meeting with representatives of ERDA, U.S.G.S., EPA and NRC on February 13, 1976.
At this meeting, action was initiated to delineate L
o c 'L 724 LJ mem e
M Mhr
4
(.
various agency responsibilities, current agency activities relating to waste disposal, and actions which need to be taken.
The NRC is providing-initial leadership for the group and will respond to those areas of responsibility and need determined to be NRC's.
The NRC will request State participation through the National Conference of Radiation Control Program Directors.
In addition, the NRC is cooperating in a U.S.G.S. study and a contracted Brookhaven National Laboratory study.
The U.S.G.S. is conducting a study to develop geologic and hydrologic criteria for evaluating ~
wante burial sites and to develop predictive waste
- transport models.
NRC is assisting U.S.G.S. in this program by providing analytical services for samples obtained by U.S.G.S.
Under an NRC contract, work is underway at Brookhaven to carefully catalogue the types and characteristics.of wastes likely to be found at the various burial grounds.
This work will, in large measure, serve as the technical bases for developing improved criteria for the management and disposal of radioactive wastes.
4.
Recommendation that NRC direct the staff to monitor the actions being taken by Kentucky and insure that the trench water problem at the Maxey Flats disposal site is corrected.
NRC Action:
The NRC has and will continue to review actions taken by Kentucky to improve the Maxey Flats burial ground water management program.
A recent review, conducted December 1-5, 1975, concluded the ctate is taking appropriate action regarding recommendations made by NRC to improve the water nanagement program and I
is continuing their efforts to improve site operations.
In February 1976, the NRC conducted a survey of the commercial burial grounds, including Maxey Flats, which included i dependent sampling by n
NRC.
The results of analyses of samples taken at Maxey Flats indicate that releases of radicactivity to the site environs are decreasing.
(see attached Summary of Major Events at Maxey Flats Burial Grounds 1970-1976)
L
,c us
(
- 5.
Recommendation that NRC direct the staff to take the necessary actions to determine whether disposal site licenses should be renewed.
NRC Action:
The NRC directly regulates low-level commercial waste disposal only at the Nuclear Engineering Company site located near Sheffield, Illinois.
(The same company's sites in three other states --
Kentucky, Nevada, and Washington -- are subject to state regulation under the Agreement State Program.)
On July 9, 1975, the staff notified Nuclear Engineering Company that their application for license renewal needed to,be updated and that an environmental ~ report would be necessary.
Upon receipt of the revised application, a detailed schedule will be established for determining whether or not to renew the license.
It should also be noted that at two of the sites
(
where ccmmercial waste burial is subject to Agreement State regulation -- Beatty, Nevada and Hanford, Washington -- an NRC license is also required because the quantity of special nuclear material exceeds the amount an Agreement State may license.
A review to determine the adequacy of their renewal application is underway and should be completed during 1976.
Through the Agreement State Program we will work with the Agreement States to determine whether their waste disposal licenses will be renewed.
15.
Recommendation that NEC direct the staff to arrange for the systematic exchange of monitoring results among the Federal and State agencics regulating or independently monitoring commercial disposal sites.
NRC Action:
The staff is arranging with appropriate Federal and State agencies, for the establishment of a formal program to exchange data regarding burial ground monitoring programs.
The results of the February 1976 survey conducted by the NRC at all burial sites has been made available to interested
(_
agencies.
852 526
7.
Recommendaticn that NRC direct the staff to establish independent monitoring programs for NRC-licensed disposal sites where there are no such programs or where existing monitoring programs are inadequate.
NPC Action:
As part of the NRC license renewal reviev, the monitoring program at the NRC regulated Sheffield, Illinois, site will be carefully reviewed for adequacy.
Any deficiencies in the monitoring program proposed by the Nuclear Engineering Company will be corrected prior to renewal of their license.
Confirmatory meacurements to verify the results of the licensee's environmental monitoring program have been made by NRC in the past.
The NRC plans to collect samples on a routine basis for analysis at the NRC's reference laboratory.
{
8.
Recommendation that ERDA and NRC direct their staffs to study ways to improve record-keeping practices at commercial and Government-owned disposal sites.
NRC Action:
The NRC staff will take appropriate steps during review of the application for renewal of the license for the Sheffield site to assure that records of waste buried will be accurate and quantitative, insofar as practicable.
In addition to ERDA-NRC efforts, Lhe Task Force on Waste Management of the Conference of Radiation Control Program Directors (an organization of all
~,
the states) has considered the problem of record-keeping at commercial burial grounds.
It was agreed that some shipments of waste were not quantitatively identified.
The Task Force is continuing to study this problem.
We plan to work with the Task Force and provide continuing support.
C 852 327
(.
9.
Recommendation that NRC direct the staff to establish, in cocperation with Agreement States, long-term-care requirements for commercial disposal sites and require that adequate funding be established to support such requirements.
NRC Action:
The Conference of Radiation Control Program Directors' Task Force on Bonding is developing requirements relating to bonding and perpetual care funding for commercial radioactive waste burial grounds and guidance is set out in their January 20, 1975 report.
However, the Task Force believes changes in the guidance provided may be needed in the future as more detailed requirements for perpetual care and maintenance are developed.
The NRC participates in the Task Force and will continue to work with the Statac to develop better guidance concerning perpetual care and maintenance.
(
10.
Recommendation that NRC and ERDA develop a policy on Federal involvement in correcting migration problems at commercial disposal sites.
NRC Action:
The NRC presently has a policy to assure correction of problems affecting health and safety at NRC and Agreement State licensed facilities.
We would require an NRC licensee to take appropriate corrective action and we expect the Agreement States to require their licensees to take similar corrective action.
We have and will continue to provide technical assistance to the Agreement States wiuhin our budgetary and technical resources.
We will work with ERDA and other Federal agencies to establish a position on Federal involvement (both financial and technical) relating to correcting any migration problems at the commercial waste burial grounds.
852 328
O
SUMMARY
OF MAJOR EVENTS AT MAXEY FLATS BURIAL GROUNDS 1970-T976
~
~
Initial Conuerns
~
p Through 1969 no major problems were identified relating to' operation of the burial ground.
In 1970, Kentucky staff expressed concern about opera-tion of the site and the need for a more extensive revieu of the burial-ground operation. This concern was based on the increasing quantities of radioactive material being buried at. the, site, and on-site water.. '
management problems.
'About 3 million cubic feet of waste containing.1-1/2 million curies of byproduct ma.terial, 300 kilograms of special nuclear material and 50 tons of source material have been buried at the ' site.. In addition to commer cially generated ~ wastes frcm reactors, isotope users and. fuel cycle fanilities, significant quantities of plutonium and tritium from AEC contract operations were buried at the site.. Staff. concern increased during 1971 as the licensee continued to have. problems with the accumu-lation of water in completed trenches. The State ' instituted enforde-
{
ment action but the licensee continued to experience difficulty in con-trolling.on-site water.
In 1972 environmental monitoring data began to indicate that the site might be contributing radioactivity to the local environment. The 1.icensee continued to experience difficulty in con-trolling on-site water and NEC0 violated terms of.their ligense'.
6 In Sepitember 1972, the State issued an order against NEC0 for non-compliance and willful violation of conditions of the' license relating.
to water in completed trenches, hurial of coauthorized material. and disposal of liquid wastes directly to solid waste dispocal trenches.
Following issuance of the order, the licensee was permitted to operate the waste burial site for.the disposal of solid wastes only.
The' licensee was required to file an irrevocable letter of credit for
$500,000.
This letter of credit was in lieu of a perf.ormance b'oiid to '
assure compliance with the terms of the order. '
Action taken by NECO tg centrol water problems included the' pumping of water from trenches into above-gr.ound storage. tanks and the instal-lation of an evaporator to concentrate the liquids for disposal as solids.
Environmental Monitoring
.The State innd UECO have conducted environmental monitoring programs at Maxey Flats since 1962. The routine State program consisted of monthly b.
832 529
I ib d (
trips to collect samples from natural streams, wells, springs, incl ing drainage and seepage from all sides of the site. These sample points ranged up to approximately two miles in distance from the site.
In Movember 1973, the State instituted a special six-month environmental monitoring study to identify the source and scope of the increased levels of environmental radioactivity previously identified in the site environs.
Early AEC Review of Kentucky's Agreement Material Procram and the Maxey Flats Burial Ground The AEC reviewed licensing and/or inspection files concerning NECO as part of the review of Kentucky's agreement materials program in 1971, 1972,1974 and 1975. Site visits were conducted in 1964,1973,1974 and 1975. The earlier reviews had included a discussion of the initial
' action, status of the burial ground and environmental monitoring pro-During 1972, the AEC conducted a reyiew of the actions Kentucky grams.
was taking in connection with the September 1972 order against UECO and a site visit was conducted in April 1973. The review and site visit showed that Kentucky was requiring HEC 0 to take necessary cor-rective action and that environmental monitoring data showed no radio-activity in the environment in excess of acceptable standards.
(
Kentucky Informs AEC of Results of Six-Month Study Kentucky informed the AEC in October,1974, of the preliminary results of their special six-month environmental study at the burial area.
In November,1974, AEC conducted a site visit, met with State officials and received a copy of a draft report documenting the purpose, scop and results of the study. The report contained information which indicated that radioactivity may be migrating from the burial ground and was being detected in sampling tells immediately adjacent to the burial site and in water collected Pom unrestricted areas near the burial site. The activity levels reprted for unrestricted areas around the site exceeded, in some cases, ambient sevels as well as Part 20 concentrations for releases to unrestricted areas.
In providing technical assistance to Kentucky, the AEC prepared written coaments on the draft report. The AEC noted that the report did not appear to contain sufficient information to support all of the con-clusions, particularly whether the site was creating a public health and safety problem.
The AEC suggested that further comprehensive environmental studies should be conducted to provide a technical basis for determining whether and to what extent migration of radioactive material was occurring and for assessing the health and safety aspects
.L 65' 330
l'
\\
of conditions at the site.
During riovember and December, the AEC also participated in meetings with the State and the licensee concerning the report and the conclusions which could be drawn from the study.
HEC 0 had taken exception with the conclusions in the State's report and had requested AEC assistance in resolving " differences of opinion" between the State and UECO.
NECO believes their data, covering a longer period of time, shows no trends toward incre.asing levels of environmental radioactivity and shows no real potentM1 for human exposure to persons living in the area.
The final report of the six-month study was released in December.1974 by the Kentudky Department for Human Resources. The report concluded that the burial ground was contributing radioactivity to the environ-ment; that the activity detected did not create a public~ health hazard; and that further studies were necessary to. determine to what
' extent migration was occurring and to assess the long-range.public.
health and safety sig'iificance of the findings. The report stated
~
that tritium, Co-60, Sr-89 and 90, Cs-134 and 137, and Pu-238 and 239 were -identified in certain individual samples in the unrestricted en-vironment. The levels ranged from slightly above background to orders of magnitude above background for certain individual samples..
Following recommendations in the six-month report,'the State ~ expanded an' existing Environmental Study Design Committee for the Maxey Flats
(
Radioactive Waste Disposal Facility and held a meeting of the Committee in February 1975. The Committee consisted of representatives from several State agencies: NEC0, USGS, EPA, ERDA, and NRC. The' purpose of the Committee was'to recommend to the State, further environmental studies to determine the long-range significance of the radioactivity detected in the site environs.
~
The studies recommended by the Committee were estimated to cost in excess of one million dollars. The State subsequently requested NRC and other Federal agencies to provide financial assistance to carry out these studies in May 1975.
Request for Independent NRC Review of Maxey Flats Burial Ground On April 30, 1975, Kentucky Governor Julian M. Carroll', requested the HRC to independently assess conditions at the site and to provide him Oith findings and recommendations.
An NRC review group was appointed which consisted of NRC staff knowledgeable in Agreement State relationships, hydrology,.and radiological assessment. The review group examined infor-mation regarding the site, the State ~ license,hydrogeological information about the site, the State's six-month report, the report of the State's
4_
Environmental Study Design Committee, State environmental monitoring data,1:ECO environmental monitoring data and actions being taken by the State and iiECO. The review group also conducted an unannounced site visit as part of the review and met with State' and !!ECO officials.
The I!RC concluded, on the basis of their study, that there was no significant public health problem associated with the release of radioactive material from the burial ground and that Kentucky has been taking appropriate action to implement th.e recommendations ~ made in their December 1974 six-month study report. The ilRC, based on available Kentucky and licensee data concerning aquatic releases, calculated a maximun potential whole body dost '.o persons present in the area of 125 millirem per year in -
cluding natural radioactivity. This dose does not represent actual human exposure.
It was based on the maximum levels of radioactivity detected and the most restrictive radionuclide mixture. The flRC also made several recommendations principally dealing with methods to improve the water fnanagement program to minimize the potential for migration of radio-activity.
Governor Carroll was informed of the results of the !!RC review in July 1975. The Governor subsequently issued a press release indicating that the llRC was responsive to his request and directed the Kentucky De-partment for human Resources to carry out flRC's recomendations.
The flRC also informed Kentucky at that time that the llRC would provide con-tinuing technical assistance but was no'. able to provide financial assist-f ance to help carry out the further studies recommended by the Environmental
(
Study Design Committee.
Recent i1RC Reviews of Kentucky Agreement 14aterials P'rogram and Assessment of flaxey Flats Burial Ground NRC staff believes the burial ground is contributing radioactivity to the local environment, but there is no significant public health problem associated with the release of material.
FIRC staff believes the State is taking appropriate action to improve conditions at the site by requiring the licensea to carry out and continually improve a water management program.
Following review o-f their program in 1"4, we reccmmended that the State reassess flEC0's water management program and initiate a program to establish the validity of ilECO's environmental monitoring data.
Our most recent review of the Kentucky Agreement program, conducted December 1-5, 1975, concleded the State is tching appropriate action re-garding the recomendations made by the MRC review group and is continuing their efforts to improve the on-site water management program.
llaxey Flats Site Studies The State, f!ECO, EPA, and USGS have been conducting further studies at the site since the State published their six-month report in December f
1974.
tie understand the results of studies conducted by the Sta te, EPA, L
and USGS will be published in the near future.
052 532