ML19276E461
| ML19276E461 | |
| Person / Time | |
|---|---|
| Site: | 02700039 |
| Issue date: | 02/15/1979 |
| From: | Bell M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Neel J U.S. ECOLOGY, INC. (FORMERLY NUCLEAR ENGINEERING |
| References | |
| NUDOCS 7903140193 | |
| Download: ML19276E461 (5) | |
Text
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FEB 151979 Docket No. 27-39 Mr. James N. Neel President and Chief Executive Officer Nuclear Engineering Company, Inc.
9200 Shelbyville Road.
Suite 526 P. 0, Box 7246 Louisville, Kentucky 40207
Dear Mr. Neel:
The plans described in your letter of December 27, 1978, to William J.
Dircks and your motion to the Atomic Safety and Licensing Board (ASLB) of the same date indicate that you seek to defer consideration of your application for relicensing of the Sheffield low-level waste disposal site. The public health and safety requires that specific procedures and plans be established and carried out for that site until such time that the site is decommissioned. We indicated in our motion to the ASLB of January 16,1979, that licensed activities at the Sheffield site might be renewed for the collection and incidental processing of waste and the maintenance of the 20-acre site, subject to conditions to protect the public health and safety. However, the NRC staff must consider the effects that might be caused by materials buried at the Sheffield site and the activities you intend to continue at the site.
In order that we may formulate proposed license conditions for collection, transshipment, and incidental processing, submit the following information within 30 days:
1.
A complete description of operations you anticipate in association with transshipment and incidental processing.
Provide an evaluation of their potential impacts. The evaluation should consider, but not be limited to, the following factors:
a.
The quantities of radioactive materials and volumes of waste that will be stored, b.
The number of trailers likely to be on site at a given time.
c.
Other storage provisions planned.
d.
The type, number, and capacity of your collection vehicles and expected frequency of shipments and traffic density.
7 9 0 314 01Cl 6
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s James II. Neel FEB 7 51979 The quantitles of radioactive materials and volumes of waste e.
that will be processed.
f.
Confirmation, after review, that the analysis submitted August 9,1978 concerning effluents from the solidification operations is consistent with your current plans.
If not, provide a revised analysis.
2.
Copies of specific procedures for the operations described.
3.
Identity of personnel that will be available for the operations described.
Specify the individuals who will be available for radiation safety and environmental sampling and analyses, and provide their qualifications, if not submitted previously.
Indicate management audits and supervision to be provided.
4.
A description of specific radiological monitoring equipment that will be available.
Include survey equipment and assay capability to remain on site.
5.
An assessment of alternatives to using the site for collection and incidental processing.
To provide us the best information base to formulate proposed license conditions for care of the 20-acre site, provide the following in 30 days:
6.
Specific procedures for monitoring, site maintenance and surveillance applicable until burial is resumed or the site decommissioned.
Include:
a.
Enviroi.antal media and wells to be monitored.
b.
Environmental monitoring sampling points and frequency of sampling.
c.
Analyses to be performad on environmental samples.
d.
Split sampling and other quality assurance measures to verify analytical findings, e.
Flumber, location and frequency of groundwater level measurements to be taken.
f.
Procedures and frequency of monitoring site surface stability, including examination of the integrity of the soil and vegeta-tive cover.
Specify surface degradation criteria to establish the need for maintenance.
James fl. fieel FEB 151979 7.
Identity of personnel that will be available to care for the 20-acre site.
Indicate the numbers of operation, maintenance, and surveillance staff to be available (full time, part time or on call).
Indicate management audits and supervision to be provided.
8.
A description of specific equipment that will be available for site care.
Include routine maintenance equipment available for the radioactive site.
Since you no longer plan to bury wastes on the 20-acre site, the site must be prepared for long-term care (decommissioned).
flecessary work must be completed so that if you decide not to pursue site expansion, license termination can be accomplished quickly and easily. However, additional information is required to resolve whether the 20 acres can safely contain buried wastes for the long term and to specify any necessary remedial actions.
Provide the following information, also within 30 days:
9.
A schedule, not to exceed six months, for the development of a detailed decommissioning plan. Any plans already developed should be submitted for review. Your response should include a clear discussion of how monitoring and maintenance programs will be continued throughout the implementation of your plan so that pro-tection of the public health and safety is assured.
In planning the development of your decommissioning plan, you should include preparation of supporting rationale and analyses and address factors such as:
a.
Slope stabilities b.
Trench markers c.
Trench cap construction and conditions d.
Erosion control measures e.
Final topography planned f.
Long-term surface water management g.
Planned vegetation cover and recommendations for long-term control to assure cover and exclusion of undersirable vegetation h.
Recommendations for long-term monitoring
s James N. Neel
-4_
FEB ;5 ig79 i.
Estimates of long-term maintenance required J.
Cost estimates for site preparation and long-term care k.
Establishing an adequate buffer zone, including deeding additional land to the State if required 1.
Potential impacts of the chemical site and other future uses of adjacent land m.
Final fence n.
Records maintenance including trench locations, trench contents, monitoring information o.
Documentation of current conditions and step-by-step descrip-tion of all necessary remedial actions including Trenches 11 and 18, the ice holding pond, and sand formations p.
Removal or decontamination of the solidification facility and other contaminated equipment and facilities q.
Alternatives to recommended actions Since you will need to consider the following information in preparing your decommissioning plan schedule and in the plan itself and since we also need tne information now to make more informed recommendations to the ASLB, please submit the following within 30 days:
- 10. A plan showing the detailed topographic survey of the existing surface features of the 20-acre site and adjacent areas to at least 200 feet beyond the site boundary.
Include on the plan (s):
a.
Existing topography b.
Actual trench locations including bottom elevations c.
Existing trench marker details and locations d.
Existing vegetation types and conditions e.
Actual trench cap details including thickness and material descriptions f.
Existing erosion control features
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James N. Neel E 8 7 5 1979
- 11. An assessment of the performance and current condition of compacted fill used for Trenches 14 and 14A.
- 12. Additional information on the chemical site. The Illinois Environmental Protection Agency (IEPA) responded to our December 15, 1978 letter. However, information was missing or unavailable.
In particular, provide:
Logs of borings for wells other than numbers 1-6.
Additional a.
wells are shown on maps previously provided for the radio-logical site.
b.
Reports on the construction of the earthen barrier to date.
The IEPA permit dated August 5,1978 did not specify depths and represents planned, not actual, construction.
Include a description of the natural materials (e.g., permeabilities) forming the barrier's foundation.
c.
Groundwater levels from monitoring wells.
d.
The results of any chemical analyses performed on monitoring well samples.
e.
An assessment of the likelihood and consequences of possible migration of chemicals into the radioactive site from barrier failure. We will assume that any chemicals interacting with radionuclides will increase the migration rates unless you can demonstrate that the chemicals will not affect the radionuclide distribution coefficients.
The development and implementation of a decommissioning plan will require close coordination with the Illinois Department of Public Health (IDPH). The final conditions of the site must be acceptable to the IDPH.
Sincerely, f/i'v lw.f,/yf e
Michael J. Bell, Chief Low-Level Waste Branch Division of Waste Management cc: Gary Wright, IDPH Sheffield Service List