ML19308A546
| ML19308A546 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/07/1979 |
| From: | Rich Smith NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 7910310294 | |
| Download: ML19308A546 (90) | |
Text
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o UNITED STATES OF AMERICA i
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PRESIDENT'S COMMISSION ON THE ACCIDENT AT 0
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DEPOSITION OF:
ROBERT DALE SMITH 0
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August 13, 1979' V
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FROM:
Richard S. Mallory, OGC Enclosed b a copy of the transcript of your deposition before the President's Commission on the Accident at Three Mile Island.
Please read through the transcript carefully and correct any errors (other,than unimportant punctuation errors) in black pen on this copy.
Correct any errors you can identify in the questions, as well as in your answers. This copy will not be retyped, but will be reproduced as you have marked it, so your corrections should be dark and legible.
If you cross out words in the transcript, draw only a single line through them, so that they can still be easily read when the transcript is copied; do-not obliterate them.
After you have corrected the transcript, please sign and date' the certificate at the end, and type your name under your signature.
You may wish to make a copy of the transcript for yourself before returning b
O )g[p the original to me. When you return the transcript, please indicate if you h
object to making your transcript available to the Commission or to the Commission's investigation of Three Mile Island.
Because of Commissioner interest, we would appreciate receiving your corrected copy by c.o.b.
Tuesday, August 14, if possible.
/
The President's Commission on Three Mile Island will also be sending you a copy of your transcript with a request to make an " errata sheet" and sign a signature page.
Please make up an " errata sheet" based on the copy of the transcript that you have retained and return the errata sheet and signature page to the President's Commission as requested in their letter.
If you have any questions or problems, do not hesitate to call me or the attorney who represented you at the deposition.
Enclosure:
Transcript COMMIT G b II > 1 3,!la,'l'l 3, 2 A 'A 1
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1 UNI"'ED STATES OF AMERICA 2
PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE ISLAND 3
4 5
6 7
DEPOSITION OF:
ROBERT DALE SMITH 8
9 10 Room 6211 7735 Old Georgetown Road 11 Bethesda, Maryland 12 August 7, 1979 10:15 o clock, a.m.
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13 14 APPEARANCES:
15 On Behalf of the Commission:
16 G ARY M.
SIDELL, ESQ.
17 2100 M Street, N.
W.
Washington, D. C.
18 On Behalf of the Deponent:
19 MARK E.
CHOPKO, ESQ.
20 Office ef the General Counsel Nuclear Regulatory Commission 21 7735 Old Georgetown Road Ber.hasda, Maryland 22
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23 24 s
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EXHIBITS 2
NUMBER DESCRIPTION IDENTIFIED 3
1 Resume of Robert Dale Smith 5
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(to be supplied) 4 2
Memorandum dated August 1, 1979 from 25 5
S. Latlief to R. Dale Smith, subject:
Discrepancies and violations found on 6
low-level radioactive waste shipments at the Chem-Nuclear burial facility 7
in South Carolina 8
3 Letter dated July 10, 1979 to Chairman 41 Hendrie, NRC, from governors of the 9
states of Washington, Nevada and South Carolina 10 4
Memorandu'm dated July 17, 1979 from 45 11 R.D. Smith to John B. Martin, subj: Trip Report: Disposal Site Visit and Meetings 19 with State of Washington Offic,ials
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13 5
Transcript of August 2, 1979 meeting with 51 Chairman Hendrie, Commissioner Ahearne 14 and others (to be supplied) 15 6
July 13, 1979 letter (three individually 54 addressed to governors of Washington, 16 Nevada, and South Carolina) from Chairman Hendrie--acknowledgement letter 17 7
Proposed letter from NRC to governors of 53 18 Washington, Nevada, and South Carolina re NRC action plan (to be supplied when 19 final letter is sent out) 20 S
November 24, 1975 Technical Position 57 ETSB-11-3 (to be supplied) 21 9
June 18, 1979 memorandum for Harold Denton 57
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22 from W. Dircks re TMI with covering trip report to TMI 23
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24 25 Exhibits attached.
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1 PRqgliglNg1 2
WHEREUPON, 3
ROBERT DALE SMITH f
4 was duly sworn by Stan M. Helfman, Esquire, and was examined 5
and testified as follows:
6 MR. HELFMAN:
Would you please state your full name 7
for the record?
8 MR. SMITH:
My name is Robert Dale Smith.
9 MR. HELFMAN:
Have you ever had your deposition 10 taken before?
11 MR. SMITH:
No.
12 MR. HELFMAN:
Let me explain,to you some of the
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characteristics of a deposition.
The testimony that you are 13 14 giving today is sworn and although we are sitting in the 15 relative informality of a conference room at the NRC building, 16 your testimony will have the same force and effect as if it 17 had been given in a Court of Law.
Therefore, it's important 18 that you be as accurate as you possibly can, and if you have 19 questions about any question I ask, please feel free to ask 20 before you attempt an answer.
21 At the conclusion of the Deposition your testimony 22
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will be reduced to transcript form by the court reporter and 23 in the course of time you will be provided with a copy and an 94
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opporttinity to make any changes that you feel are necessary.
25 You should be advised, however, that should you make substantial Acme Reporting Company aes, u......
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I changes, we would have the opportunity to comment on them and e
2 they could adversely reflect on your credibility.
3 For the benefit of the court reporter, it is neces-b 4
sary that you give audible responses since it is difficult 5
for the court reporter to take down nods of the head or ges-6 tures, and also for the benefit of the court reporter it is 7
necessary that you allow me to complete my question before you 8
commence an answer, and I'll try to remember to allow you to 9
finish an answer before I begin my next question, because it to is difficult for the court reporter to distinguish two people 11 talking at the same time.
12 It is our practice at the conclusion of the Deposi-13
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tion to recess it rather than terminate it; in the event that 14 we have additional information that we wish to seek from you, 15 we'll simply reconvene the Deposition.
It hasn't happened yet 16 and we'll try to avoid it, but we maintain that option.
17 Do you have any questions about any of the foregoing?
18 MR. SMITH:
No, no questions.
19 EXAMINATION OF MR. SMITH 20 BY MR. HELFMAN:
21 Q
Were you asked to bring a resume with you?
22 A
Yes.
23 Q
Did you do so?
24 A
No.
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25 Q
Do you have a resume that you could provide us with Acme Reporting Company n,,..-...
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in the next day or so?
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A I will furnish you a resume yet today.
3 Q
All right.
Is this something you will send to us
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4 in the mail or is it something you can hand to us?
5 A
If you will be here, say, within half an hour after 6
we adjourn, I could give it to you then.
I'll find a type-1 1
7 writer and prepare it.
8 Q
All right.
I think what we ought to do at this 9
point is to stipulate that an accurate resume will be provided 10 to us by Mr. Smith'and that it will be deemed Exhibit 1 to the 11 Deposition when it is received.
Is that agreeable, Mr. Chopko?
12 MR. CHOPK0:
I think that's acceptable.
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13 (WHEREUPON, the document referred 14 to shall be marked for identifi-15 cation as Exhibit 1 to the 16 Deposition when received.)
17 Q
Would you please state for the record what your 18 title is with NRC and briefly describe your functions?
19 A
I am Chief of the Low-Level Waste Licensing Branch 20 in the Division of Waste Management, Office of Nuclear Material 21 Safety and Safeguards.
As chief, I supervise the operations r
of the branch of approximately fourteen (14) people.
Our 1
23 branch is concerned with two primary concerns, first of which j
24 is to carry out the normal licensing functions for the exist-25 ing low-level waste disposal operations; the second of which Acme Reporting Company
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is to prepare regulations, gdides, standards and criteria for 1
2 the licensing of these burial sites.
Existing regulations that 3
we have are practically non-existent.
Previous licensing actions have been done on more of an ad, hoc basis and our
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4 5
charter is to develop a comprehensive set of regulations and 6
requirements for the disposal of low-level waste.
7 At the same time, we have three operating burial 8
sites and three closed sites in this country that we share 9
some responsibilities with the state in terms of joint licens-10 ing.
At i+ast one, we hold the only license on it, and in 11 several cases we're providing technical assistance to the 12 states in terms of environmental and safety reviews to back up 13 their licensing operations.
14 Q
So if I understand you correctly, your branch is 15 involved both in the licensing of the treatment facility at 16 the reactor and the licensing of the site where the wastes are 1;
ultimately disposed.
Is that correct?
18 A
That's not correct.
Our responsibility is for the 19 safe disposal of waste.
One of the characteristics, one of 2
the features of the regulations that we're developing is that 21 we are going to put reliance on waste form where this has 22 never been done before.
We're going to set specifications on
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3 the type of waste that would be acceptable for disposal under l
24 various means.
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25 Now we have to interface with the producer of the 1
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I waste, and --
2 Q
That would be the utility?
3 A
That, in the case of a reactor, would be the utility.
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In the case of fuel cycle facilities or other institutions, it 5
could be a hospital, it could be medical research, that sort 6
of thing.
I guess the interface that we see between us and 7
the people who license the waste generator is that we'll be 8
concerned with the waste product; therefore, we want to be 9
able to review and assess the adequacy of whatever system is 10 there to produce a waste product that's acceptable for disposal 11 The operation of that facility, the health and 12 safety implications, the interface with the rest of the plant, 13 is not something that we want to get into.
14 Q
Who is responsible for licensing the waste treatment 15 facility at the plant in the case of a utility?
Is that NRR?
16 A
NRR.
There are two groups that appear, within NRR, 17 appear to be concerned with effluent and waste treatment sys-18 tems.
One is the Effluent Treatment Systems Branch (ETSB) 19 which is concerned with, as I understand, with the review of 20 new applications, construction permits for new reactors.
There 21 is a corresponding group in another part of NRR that is con-
'5 cerned with the operating reactors and the maintenance or
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23 backfitting of existing reactors.
24 Q
Do you recall the name of that group or that branch?
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25 A
No, I don't.
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Q Do you recall the name of anyone who is involved in 2
that branch that you've had dealings with?
3 A
Lake Barrett, who is section leader in that branch,
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4 has been one of our principal contacts.
5 Q
Have you had any dealings with Richard Vollmer?
S A
I have not had dealings with Mr. Vollmer.
7 Q
Do you know if he's in the same branch?
8 A
I don't believe so, because as I understand the 9
current organization in NRR, Vollmer is John Collins' boss.
10 John Collins is head of the Effluent Treatment Systems Branch 11 as his regular job; he's also the man on site at Three Mile 12 Island.
So I think that this is on the construction permit 13 side of the house rather than the operating license side.
14 Q
What forms can reactor wastes take for treatment?
15 What are the various alternatives?
16 A
Do you mean alternatives to the way it comes out of 17 the reactor or including the way it comes out of the reactor 18 as one of the a;ternatives?
19 Q
Well, basically what I want to know is how is the 20 waste which comes out of the reactor prepared for shipment?
21 What are the alternative methods for preparing it and what 22 forms does it take?
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23 A
The principal wastes out of the reactor will take 24 probably three forms as it's generated.
One will be the
! x 25 normal assortment of rags and bags and protective clothing Acme Reporting Company
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and contaminated equipment--solid waste, which is normally
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2 packaged perhaps with some compaction to make sure your con-3 tainers are as full as possible.
At this point, very little
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4 treatment is given or has been considered being given to these l
5 dry solid wastes.
6 The second category of concern are the resins that 7
come from the treatment of contaminated coolant and liquids 8
at a reactor.
The resins are an ion exchange medium that 9
extracts the contaminants, concentrates them on the resin beads 10 and the resin beads then, as a minimum, are de-watered; that is 11 they are either allowed to drain or are drainages accelerated 12 by air drying or some other method.
And frequently these 13 resins are shipped for burial i.. that form.
14 There are a number of solidification systems that 15 are available for solidifying these kinds of resins, and a 16 number of reactors have made it a practice.
It is the posi-17 tion of the Effluent Treatment Systems Branch that all new 18 reactors should have capability for solidifying resins as well 19 as sludges, which is the third category.
20 Q
Sludges are the third category?
21 A
Sludges are the third category -- sludges resulting 22 from evaporation, volume reduction activities on contaminated 23 liquids.
Now the solidification systems that appear to be 24 available for both resins and sludges are of several types.
s 25 One of the more common types is a process called Acme Reporting Company
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urea-formaldehyde.
Mixing these materials with concrete is 2
another proven method. of solidification.
There is a process 3
where they are mixed with an asphalt-like bitumine material.
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4 There is another process that has been used on an experimental 5
basis that has not had wide application yet but appears to 6
show promise, and this is a process developed by the Dow 7
Chemical Company which utili es a polymer reaction.
8 Q
You indicated that with new plants there must be 9
facilities at the plant to solidify resins and sludges.
10 A
This is the position that NRR is taking with their 11 new applicants, yes.
12 Q
Do you know if this requirement comes about as a 13 result of the SRP?
14 A
This requirement comes about as a result of the SRP-+
15 Standard Review Plan--which references a branch technical 16 position that NRR generated, I believe, some time two years 17 ago or thereabouts--two or three years ago.
And it has been 18 their intent and, as far as I know, their practice to get new 19 reactors to have solidification capabilities.
20 Q
Do you know i? this SRP requirement was backfitted 21 to TMI-II?
22 A
Let me ask.
When you say backfitted to TMI-II, you 23 mean the original rad waste treatment system in TMI-II or the 24 EPICOR-II system that's being installed to treat the wastes 25 there?
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Q Let's talk about it prior to the transient of i
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March of this year.
Do you know if prior to that transient
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3 this SRP requirement was backfitted to TMI-II?
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A I believe not.
5 Q
And since the transient at TMI-II of this year, has 6
this requirement been backfitted?
7 A
The equipment that is being installed to process 8
the auxiliary building waste water, the system that is known 9
as EPICOR-II, at the present time I believe does not include 10 any provisions for solidification.
11 Q
Would this also include the waste, the liquid waste, 12 that's in the containment building?
You mentioned the 13
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auxiliary building waste.
14 A
I believe not.
I believe the plan is that the 15 EPICOR-II system will process only the auxiliary building 16 waste, some 250,000 gallons or so.
The water that is in con-17 tainment, prit y coolant, and the water--I don't know what 18 the current estimate is, but it's recently estimated as 19 7-800,000 gallons--that water I'm told will likely not be pro-20 cessed with EPICOR-II because of the higher concentrations 21
+he ' expect of isotopes 22 And at this point I don't believe, I'm not aware of-j 23 other decisions that have been made as to the type of system 24 that is going.to be installed to take care of that.
s 25 Q
Has-there been some discussion of alternatives?
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A Not with us--us being NMSS.
My conversations with 2
the people at TMI and the people here lead me to believe that 3
they are considering a number of alternative metheds for t
4 handling this waste, and that as of a couple weeks ago, at 5
least the last time I talked to anybody, a decision had not 6
been made as to the type of system that would go in.
7 Q
Irrespective of the type of system that's used on 8
the containment building wastes, would it produce eith.er a 9
resin or sludge or a solidified waste?
Do you know what the 10 alternatives are in that regard?
11 A
Would you ask that question again, please?
12 Q
With respect to the liquid waste that's in the con-13 tainment building, are you aware of whether, whatever method
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14 is used to treat it, whether it would produce a resin waste, 15 a sludge waste, or a solidified waste?
16 A
If they utili e ion exchange there will be resins.
IT If they don't, there are evaporator systems that, I think 18 they've been considering, that would produce something akin to 19 a sludge, at least a concentrated material, and whether any 20 treatment system automatically produces a solid, I don't know.
21 Now, if it produces resins or if it produces sludges, those t.
22 could be solidified.
Now, I don't know whether they have a 1
23 system under consideration that would produce a solid as the l
24 primary product.
s 25 Q
You've indicated that :he forms that the waste Acme Reporting Company m.........
I normally takes, dry solid waste such as clothing and contami-2 nated equipment and materials, resins, and sludges, and the.n 3
solidified wastes, have all of these forms of wastes been 4
shipped in that form?
In other words, have you shipped cloth-5 ing as dry solid waste?
Have you shipped resins and sludges?
6 Have you shipped solidified wastes?
Do you have experience in I
all of these areas?
s A
Those -- Yes.
We--the utilities, the industry, the 8
transportation people--have all shipped these products.
They to have all been transported and disposed of in those forms.
11 Q
Who is it that proposes the form for shipment or 12 treatment of wastes?
Is that the NRC or is that the utility 13 or the state?
14 A
When a utility prepares a shipment for transportation 15 43;) 77u ;.,they are guided by whatever regulatory require-16 ments exist.
Regulatory requirements could exist at the II burial site and, indeed', do either as a result of license 18 conditions or state policies, whatever.
There are a certain 18 number of requirements that are laid on by the receiver that 20 the shipper has to recognize.
There are certain requirements
., i of DOT that have to be met in terms of packaging, in terms of 22 radiation level, contents, this sort of thing.
And the
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23 utility operator or the waste generator has to take all of 94 these into consideration and decides, then, what form he wants 25 to ship his particular waste in.
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Now, superimposed on that may be some requirements 2
of his license, his con license, as a result of NRR review 3
that would require certain things to be done before he dis-poses or ships the waste.
4 5
So it has really been the shipper's responsibility 6
to decide what form of waste he's going to ship in order to 7
meet all of the requirements that are laid on him.
a Q
When you say shipper, are you referring to,.in the 9
case of a commercial reactor, the utility, or is the shipper to a separate entity?
11 A
When I say shipper, I'm thinking of the utility, the 12 waste generator.
13
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Q So the plan is originated by the utility with 14 reference to requirements that they may be aware of?
15 A
Right.
16 Q
Is that plan then presented to the NRC for review?
17 A
In some cases, it may be, those cases being in the 18 case of reactors, those reactors that are adhering to the 19 branch technical position and have submitted as part of the 20 standard application. 'In general, the waste generator does 21 not submit anything to NRC for review in advance of the ship-22 ment.
The footnote is that if the amount of material being
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23 shipped exceeds certain quantities, his packaging may be 24 subject to an NRC review.
And involved in the review of pack-25 aging is some consideration is given to the waste form, but Acme Reporting Company
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only as it affects the packaging.
2 Q
In the normal operation of that commercial reactor, 3
my understanding is that once or twice a year there will be a 4
shipment of nuclear waste.
Is that fairly accurate?
5 A
I think that's a reasonable estimate.
Some of the 6
numbers I've seen vary all over the' place; it depends on the 7
age of the reactor, the level of maintenance, and things like 8
that.
It's a fair estimate.
9 Q
In the case of a normal or routine shipment such as 10 that, would the quantity be such as to come under NRC scrutiny 1 11 A
Likely not.
Most of this waste, most of the waste 12 from a reactor qualifies as low specifi,c activity material.
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13 That's a definition out of the. DOT regulations.
14 Q
What does that mean?
15 A
It means that the concentration of radioisotopes is 16 less than specified limits that are in the regulations.
The 17 low specific activity provision in DOT requirements was 18 originally inteaded to take care of such things as uranium ore 19 monosite sands, low cadiation, low activity, naturally, occurr-20 ing materials.
Built into it, however, are some concentration 21 limits for everything else, and those concentration limits 22 generally allow resins and sludges to be shipped as low
.u 23 specific activity material.
If they are, the NRC has no juris-24 diction and no surveillance and no responsibility over the s
25 transport at all.
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1 If the concentration is low but the quatity is large:
2 they may pass into a category called Type A shipments.
Type A 3
shipments--this is another DOT classification--Type A shipments ty and strength, some 4
require packages that are of good qut 4
5 of which NRC has reviewed and approved, but not all of which.
6 It's only when you get to so-called Type B quantity that NRC 7
does a review, and this is through our regulations and through 8
a Memorandum of Understanding with the Departr.ent of i
9 Transportation.
10 Q
You indicated that the Type A package is a good 11 package.
What is a Type B package by comparison?
12 A
Type B package has been designed and tested to 13 withstand not only the normal conditions of transport, but sca6.aAk 14 also conditions.
The accident conditions that are specified 15 in the regulations include such things 'as a 30-foot drop test, 16 30-minute fire, immersion in water for a specified period of 17 time, puncture tests, things like this.
IS A Type A package is only looked at in terms of its 19 ability to withstand normal conditions of transport.
20 Q
So, in other words, if the radiation level is 21 sufficiently low and the quantity in the shipment is suffi-22 ciently low, the utility could use the Type A package, which 23 is simply the normal transportation package, without any NRC 24 review and transport their waste to a burial site in that s
25 manner.
Is that correct?
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A That's correct.
ape 2 2
Q Are you aware of any accidents, road accidents, 3
leakages, which have occurred in the transportation of radio-4 active wastes in Type A packages?
5 A
There have been several road accidents recently 6
involving shipments of waste, the most recent being I think 7
within the last few months.
Consequences were minimal because 8
this happened to be solidified waste and solidified in. concrete 9
These things, even though they are Type A packages, frequently 10 have to be shipped in an overpack that is a large, heavily 11 shielded container to keep the external radiation levels 12 acceptable.
In the mcst recent case that I'm aware of a truck
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tipped over and one of :hese big casks slid off and nothing 13 14 spilled as a result.
15 Q
3ecause ths.t was a solidified waste?
16 A
Yes.
At least the fact that it was solidified pre-17 cluded leakage from the carrier.
18 Q
Are you aware of any accidents with Type A packages 19 containing semi-liquid waste such as sludge?
20 A
Do you mean highway accidents or just accidents --
21 Q
Highway accidents, any incidents, leaking containers
'7 accidents, whatever.
23 A~
There have been a fairly substantial number of 24 incidents, if you will, observed at the burial sites when 25 wastes come in and are unpackaged and liquid contamination is Acme Reporting Company
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observed, free-standing water, contaminated casks, contami-2 nated trucks, spillage on the ground as a result of liquids 3
frequently leaking out of the container, the Type A container, 4
into the shielding of the cask.
There have been a substantial 5
number of those, both with unsolidified as well as certain 6
solidified waste.
The wastes that are solidified with 7
urea-formaldehyde have caused a number of incidents like this.
8 Q
The incidences th'at you refer to with the urea-9 formaldehyde method, does that produce completely solidified 10 waste which would then leak?
11 A
Urea-formaldehyde, according to the people who make 12 the stuff, is capable of producing solid waste with no free-(
13 standing liquid.
My understanding is that the process is 14 rather sensitive to chemistry and other variables and that it 15 doesn't always produce solid product with no free-standing 16 liquid; in fact, quite frequently is incomplete in its 17 solidification.
18 The problem is that when you have incomplete solidi-19 fication, the liquid that is left over is highly a:idic and 20 corrosive and attacks the containers.
The most recent, I 21 guess famous example of this is an incident that happened 22 several weeks ago in Beatty, Nevada where solidified wastes 4
i 23 from Palisades reactor were received at Nevada and found that 24 a couple of the containers were leaking, apparently as a result i
25 of corrosion from inside from the urea-formaldehyde solution.
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Q kihenanevent such as this occurs, is it normally 2
reported to the NRC?
3 A
Not as a matter of prompt notification.
The reason being all three of the burial grounds that are in operation 4
5 operate under state licenses.
NRC has licenses that cover the 6
disposal of special nuclear material at Barnwell, South 7
Carolina and at Hanford, Washington.
The primary disposal 8
of waste is regulated by the states and are generally inspected 9
by the states.
So when a state inspection uncovers some sort 10 of discrepancy or deficiency, the action is (1) to notify 11 NRC through what would appear to be rather routine kinds of 12 channels, but the action is generally taken by the state.
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13 the action taken by the state frequently results in returning 14 improperly packaged shipments back to the shipper and refus.ing 15 to accept them.
Or in the case of Nevada, the governor has 16 declared an embargo on certain shippers who have been found 17 to have sent packages that were improperly prepared.
18 Q
Where are the wastes normally put in the containers?
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19 Would that be at the utility, at the reactor site?
20 A
The wastes are normally prepared and packaged at j
21 the reactor site in the case of reactors.
In the case of 22 institutional waste, the non-fuel cycle wastes, the first 23 packaging is almost always done by the generator--the scientist l
a in the laboratory fills his trash can and seals up the bag l
l 25 and sends it down the hall.
For institutional type of wastes, i
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1 there are some intermediaries, some waste collectors, that I
2 will provide a service of providing containers, picking up the 3
packaged waste, consolidating it, perhaps putting it in larger l
4 containers, and ultimately delivering it to the burial ground 5
as a consolidated shipment.
6 Q
With respect to fuel cycle wastes, in the event a 7
shipment arrives at a burial site and it is discovered that 8
the containers have been corroded and are leaking and as a 9
result the state refuses to accept that shipment, does that to result in reshipment of that waste in leaky containers back 11 to the utility for repackaging?
12 A
In the specific case of Nevada when the governor b
13 found these leaky packages and refused to allow them to be 14 buried, he ordered them to be returned back to the shipper.
I 15 don't know under what circumstances they were returned.
It 16 would not be prudent, it would not appear to me to be prudent li at least, to just turn the truck around and send it back.
18 Repackaging would seem to be the proper thing to do.
19 They don't always get sent back.
I think South 20 Carolina has, in the past at least, has accepted these kind 21 of shipments, has done something to solidify the offending 22 liquid, and then back-charged the shipper for the service that 23 they performed and went ahead and disposed of it.
24 Q
Would there be any way for us to discover what, in 25 fact, occurred with the wastes that were rejected at the Acme Reporting Company I
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Beatty site in Nevada?
Would a report have been filed with 2
the NRC?
Is there something you could provide to us?
3 A
I don't have anything I could provide you.
The 4
people that I would go to or that you could go to would be 5
our Office of Inspection and Enforcement.
Even though this 6
was a state matter, the NRC, through interaction between the Governor and Chairman Hendrie, got involved in this situation 8
out there and we've had inspectors down there and become 9
pretty well involved in that problem.
10 Q
Do you have the approximate date on this Beatty 11 refusal?
12 A
My recollection of dates is poor.
I can find it;
(
13 I don't know.
It was in late June.
14 Q
Of this year?
15 A
Yes.
is Q
With respect to the shipment of lower level radio-17 active wastes and sraller quantities or the normal quantities, 18 is it up to the utility to choose whether the material will 19 be shipped in resin form, sludge form, or solidified form?
20 A
Subject to any requirements that may have been or 21 may not have been put on them as part of their licensing, 22 otherwise the answer is yes.
23 Q
With respect to the wastes of TMI-II, do you know 24 where it's contemplated those wastes will be buried?
25 A
My understanding is that they will go to Hanford, Acme Reporting Company
1 Washington.
2 Q
Would that be the auxiliary wastes as well as the 3
containment wastes, or what?
4 A
The auxiliary wastes are intended to go to Hanford.
5 I don't have any idea and I'm not sure that anybody yet knows 6
beyond the auxiliary wastes where they will go, what form they 7
will be in or whatever.
8 Q
With respect to the auxiliary wastes from TMI-II, do 9
you know if the Hanford burial site in Washington has any 10 requirements with respect to the form in which the wastes must il be shipped and buried?
12 A
They have requirements that the wastes be dry and
(
13 solid packaged wastes.
14 Q
You mentioned earlier that one of the forms in which is the wastes could be prepared for shipment could be sludge.
16 Would sludge qualify as a dry solid waste for purposes of the 17 Hanford site?
18 A
I would think not.
19 Q
How about resins?
O<
M A
The resins themselves are a solid, are considered to 21 be a solid.
I think the interpretation would hinge on the 22 presence or absence of water.
Ehe;..sguac.:nts, I don't 23 believe their requirements specify that it has to be a mono-c.orpace.a b 24 lithic solid, that is, a big solid chunk,
-Pe*
the relatively A
25 granular form of the resins,is I dcn't b e li c'/
2 consider 2tien Acme Reporting Company m
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23 i
1
-in them. 1 sense.
2 Q
Would you re'fer to these resins beads as dry or would 3
you refer to them as semi-liquid?
What would be the correct 4
characterization?
5 A
They're really hard things to describe.
The
]
I 6
untreated resins, as they are received from the manufacturer, 7
are dry in the sense that if you squeeze them you would not 8
squeeze water out of them.
After having been subjected to 9
Water, then I think it's probably a matter of how well the 10 water has been removed as to whether you would consider them 11 to be dry or not.
12 Most of the dewatering processes and most of the
(
13 so-called dewatered resins appear to contain liquid as a 14 result of capillary action, or whatever, that traps it in the 15 interstices of the resin, and would therefore be kind of 16 mushy, I would say.
In fact, I read in the Sundav ' Star where 17 they were described as having the appearance of caviar.
I 18 hadn't thought of it in those terms, but that's probably not a 19 bad description.
20 Q
Would it be accurate to refer to them as resin 21 slush or resin sludge or radioactive liqueur?
I'm quoting to 22 you from the Deposition of William J. Dircks which was taken 23 on July 27 of this year.
24 A
How could I contradict my boss?
25 Q
Feel free.
Acme Reporting Company 202' 428 4*??
24 1
A Sludge and slush, those are kind of abstract terms 2
that are a little hard to precisely define, but they conjure up the kind of image at least that correspond to my understand-3 4
ing of what this stuff looks like.
Liqueur--I think of 5
liqueur as clear liquid, and maybe the stuff you squeeze out 8
of it is a liqueur, but the stuff that remains behind is more
~
akin to being a sludge.
8 Q
Has there been any experience with this liquid which 9
is contained in the resin beads as a result of capillar action 10 or otherwise in which such liquid has come out of the contain-11 ment vessel due to road accidents or so forth?
12 A
We recently did a survey of a number of incidents
~
(
13 that were reported by the State of South Carolina.
The State 14 of South Carolina, over approximately a two-month period, in 15 inspecting shipments arriving at the burial sites, found that there were some 43 sh'ipments that were received with some sort 16 17 of shipping problem.
Of these forth-three (43), thirty (30) 18 originated at nuclear power plants and of the 30, approximately 19 one-third of the packages, one-third of the shipments, were 20 found to have free-standing liquid either in the container or 21 having contaminated.
Now, these eleven (11) our data show or 22 the South Carolina data show that five (5) of these were from 22 so-called dewatered spent resins.
The five leaky shipments 24 were out of a total of twelve problem shipments.
The other 25 problems had to do with improper sealing and high radiation Acme Reporting Company
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25 I
levels, placarding, and thinks like that.
But of twelve 2
dewatered resins received, five showed free-standing liquid.
3 On the other hand. of eleven solidified waste shipments that 4
showed to be some kind of problem, only two of them experienced 5
problems with free-standing liquid.
6 Q
Would it be your interpretation that the two solidi-7 fied waste shipments that evidenced free-standing liquid 8
referred to the urea-formaldehyde form of solidification which 9
does not completely solidify?
10 A
That would be a guess on my part.
Certainly the 11 solidified wastes that were received where we know what the 12 form was--that is, resin in cement--no,ne of those showed any
(
13 leakage.
The solidified waste that showed free water in the 14 cask was not identified to us as to the method of solidifica-15 tion.
16 Q
You!re referring to Table B, am I not correct, which 17 is attached to a memorandum dated August 1, 1979?
18 A
That's correct.
19 Q
Let's have this marked as the second exhibit to l
20 the Deposition.
21 (Whereupon, the document referred 22 to was marked as Exhibit 2 to s.s 23 the Deposition.)
24 Q
To further identify this exhibit for the record, it l
25 is a memorandum dated August 1, 1979 for R. Dale Smith, Chief Acme Reporting Company
,sev.a.a...
26 1
of Low-Level Waste Licensing Branch--that's.you, I assume?
2 A
Yes, Sir.
3 Q
And it's from Sally Latlief, Low-Level Waste 4
Licensing Branch, and the subject: Discrepancies and violations i
5 found on low-level radioactive waste shipments at the 6
Chem-Nuclear Burial Facility in South Carolina.
7 Referring back to Table B again, we've discussed 8
the dewatered resin; we've discussed the solidified waste.
1 9
There's another category called evaporator bottoms.
There 10 were a total of two shipments, according to this table, one of 11 which evidenced free-standing liquid.
Could you describe what 12 evaporator bottoms are and indicate whether they are like r
(
13 solidified waste or dewatered resins?
14 A
Evaporator bottoms result from volume reduction of j
15 contaminated liquids by the process of evaporation.
And as 16-the quantity of water that is evaporated increases, the concen-17 tration of the impurities increases in the remaining liquid 18 and reaches a point where it has to be drained off and dis-19 carded, I guess for the continued efficient operation of the 20 evaporator.
And these are sludges, if you will.
They are 21 different from the resins in their physical characteristics.
22 They are more truly sludges than the resins in that they con-23 tain high concentrations of dissolved chemicals, some of which 24 as well as particulate matters and stuff that have stayed 25 behind as the pure water has been boiled off.
(
l Acme Reporting Company
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27 1
Q Would you characteri:e the evaporator bottoms as
.2 being more like dewatered resin or more like solidified waste?
3 A
They are more like dewatered resins than like 4
solidified waste.
5 Q
The fourth category --
6 A
Excuse me.
Unless they have been solidified them-7 selves.
But as generated, they are more akin to the dewatered 8
resins than they are solid waste.
9 Q
The fourth category is solid dry waste.
Can you 10 describe what that is and indicate whether that is more like 11 dewatered resin or solidified waste?
12 A
Solid dry waste, at least as,we've interpreted the 13 term and care, consists of contaminated materials and equip-
{
14 ment generally from the facilities--protective clothing, con-15 taminated laboratory wear, tools, this sort of industrial 16 trash that occurs as a result of operations which happens to 17 be contaminated, and as such it's a solid dry material under 18 normal circumstances.
19 Q
I notice that on this table it is indicated that 20 out of five, a total of five solid dry waste shipments, three 21 evidence free-standing liquid.
Is there any way to explain t
22 that?
23 A
I'm sure there is but I don't know what the explana-24 tion is.
I can make some -- I can speculate and guess, but I 25 don't for a fact know what the situation was.
Acme Reporting Company
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1 Q
All right.
We should note for the record that the 2
Title of Table B is " Tabulation of Prob 1' ems by Type of 3
Shipment."
4 Let me read to you some testimony concerning the 5
form which the dewatered resin takes and ask you if you agree 6
with it.
7 The pertinent question reads:
"You referred to using 8
a vacuum to dewateri:e the waste.
Would that produce a powder 9
or a clay-like material or a liquid waste?"
10
" Answer:
It would produce a sort of sand-like 11 material, resin which are dry and would pour out on the table 12 but not flow like a liquid.
And the radioactive material is f
13 not easily detached from that, just by pouring it out or 14 opening up the container they are in.
They are fairly well 15 captured by that."
16
' Question:
So by dewateri:ed, you mean it would be 1
l 17 dry?"
18
" Answer:
It would be dry, yes."
Do you agree with that description of dewatered 19 20 resins?
Is that accurate?
21 A
The characterization of a sand-like material that is 22 free-flowing goes beyond my limited knowledge of the resi.ts.
23 The resins samples that we have seen that have not yet been 24 processed, which I would assume to be as dry as they would 3
normally be found, have a tendency not to free flow like you Acme Reporting Company
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29 I
would expect to pour sand out of a bottle.
They have a cer-2 tain attraction for each other that makes them fluid but not 3
necessarily like a bunch of little beads bouncing out on the 4
table.
The extent to which dewatering can be done to produce 5
a dry material, I guess, I would certainly think that it's in 6
the realm of technology to remove whatever water you put in 7
there and get them as dry as they were when you first started'.
8 The question in my mind and I guess the thing that concerns us 9
in our business is how well that is done and what common 10 practice has been, because it's been our observation that most 11 of the so-called dewatered resins have not been through a 12 process that has extracted all free water out of it.
(
13 Q
With respect to common practice as opposed to what 14 is technologically possible, would you then disagree that by b ~
i:ing you produce a dry resin?
15 water A
16 A
Those wastes that have been identified and called 17 dewatered resins in the past as a matter of practice were 18 not dry.
19 Q
For the record I should not'e that I've been quoting 20 from the Deposition of Richard Vollmer taken on Thursday, 21 July 26, 1979, page 46.
22 With respect to the wastes from the auxiliary build-23,
ing at TMI-II, is the amount of waste that's contemplated or 24 the radioactivity of the waste that's contemplated sufficient 25 to bring the NRC into play in the packaging, treatment, and Acme Reporting Company
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.a..a...
30 shipment of these materials?
A Yes.
These are e$pected to be Type B quantity ship-3 ments and therefore will involve NRC approved packaging.
4 Q
In this event, would the utility likewise present a 5
proposal to the NRC for approval or does the NRC specify how 6
it is to be done?
7 A
Somebody would present to the NRC a package for 8
approval.
The reason I say somebody is that there are people 9
who are in the business of transporting wastes who would be 10 the ones who would design, build and own the shipping container 11 the Type B package, and they would provide that hauling as a 12 service to the utility.
It's not impossible, although per. haps
(
13 unlikely, that a utility would build its own packages and sub-14 mit them for approval.
15 The point is that NRC reviews and approves packaging 16 and certifies it as meeting the requirements of the regulations 17 and that certified package' then is available for use by is licensees.
It depends then on who is going to be the origi-19 nator of the shipment.
20 Q
If we assume that the utility is going to be the 21 originator of the shipment and we have a Type B situation, is 22 it up to the utility to select either dewatered resin form for 23 shipment, solidified form for shipment?
Does the utility 24 select the method and present it to the NRC for approval?
25 A
The evaluation and certification of the paccwage Acme Reporting Company er u.a...
O 31 I
usually contemplates a variety of contents.
For example, 2
they'll do a heat transfer evaluation to decide whether or 3
not there should be restrictions on liquids in the container.
4 Generally, these packages have so much shielding and so much 5
metal involved in the structural part that 30 minutes in a 6
fire hardly warms up the inside so that liquids become a problem.
8 But the package is approved on the basis of evalua-9 tions of a variety of contents and if there are restrictions to on a particular package, they'll be spec.ified on the certifi-11 cation.
And then the shipper has to match up what he has with 12 what the package is capable of being u. sed for.
And there may
([
13 be Type B packages that would put restraints on the presence 14 or absence of liquid.
15 Q
Could the NRC require that the wastes be converted 16 to a completely solid or completely solidified form as opposed I;
to a semi-liquid form?
18 A
As I mentioned at the beginning of the Deposition, 19 one of the primary tasks that our branch is concerned with is 20 developing a set of regulations.
And right now as we develop et these regulations we are beginning to take positions regarding 22 waste form, siting requirements, a whole bunch of things that
.s 23 all go together to make up a suitable disposal system.
And to answer your question directly, yes, the NRC 24 23 can, it's my belief that the NRC can specify waste form for Acme Reporting Company 2*2' 928 4999
w-32 I
disposal.
At the present time, those requirements as NRC 2
requirements exist only in the form of ETSB branch positions 3
which sort of says it's a good idea and we would like you new 4
reactors to do it.
It exists in the form of branch technical 5
position drafts that we are working at the present time to 6
make it as a precursor to issuance of regulations to develop 7
a position with respect to solidification of sludges and resins 8
It exists in whatever requirements the states have 9
imposed at the burial ground.
10 Q
With respect to the TMI-II wastes, would the NRC 11 have the authority to require that the wastes be completely 12 solidified for shipment?
(
13 A
I don't think there's any question about the NRC 14 having the authority to put that kind of requirement.
15 Q
Are the regs that you've mentioned yhich are in the e
16 developmental stage directed at least in part at the TMI-II 17 situation?
18 A
The regulations that we're developing are aimed at 19 providing adequate disposal of all radioactive wastes, all 20 so-called low-level radioactive wastes.
And to the exter.t that 21 TMI-II or any other reactor or any fuel cycle facility wastes 22 have to be subjected to those requirements, they will be 23 ultimately.
If your question was are we putting'anything in 24 the regulat, ions that are specific and unique for Three Mile 05 Island, the answer is no.
We're not developing a set c.f Acme Reporting Company J
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l I
special regulations and special requirements just to deal with
~
2 TMI.
3 Q
Is it contemplated that the regs that are under 4
development will be in effect at the time the wastes from 5
TMI-II would have to be prepared for shipment and shipped?
6 A
The commitments that we have made are to have a set
~
of draft regulations out available for public comment before 8
the end of FY-80, which is about a year from now.
Our 9
schedule calls for those to be put into final regulations by to
'82, going through the normal rulemaking process.
So, I don't 11 know what the projected schedule is for all of the decontami-12 nation work at TMI-II.
It certainly seems obvious to me that
(
13 the processing of the auxiliary building wastes will commence 14 and will be underway before the end of FY'80 when these 15 regulations will be out for comment.
16 As far as shipment and disposal, I don't know at 1~
this point what kind of residence time they'll be subjected to 18 at TMI because we were told that they anticipate a bottleneck 19 in terms of available shipping containers and they have pro-20 vided for on-site storage as sort of a surge capacity to L_ck 21 up wastes that are awaiting shipment.
22 So when they finally get shipped and buried and 23 how that phases with our regulations is something I can't 24 really predict.
25 Now as far as the primary containment, that I have Acme Reporting Company
.sa,,.,......
~
34 no idea really what their schedule calls for at this point.
I 2
Q With respect to the wastes from TMI-II, are you aware 3
of an tentative positions that have been reached within tne 4
NRC concerning how the wastes are to be prepared for shipment?
5 A
I'm aware of at least two positions.
6 Q
Could you describe them and indicate who has these 7
positions?
8 A
The Division of Waste Management, the Office of 9
Nuclear Material Safety and Safeguards has taken the position 10 that these wastes, these resins and sludges generated from the 11 EPICOR-II system, should be solidified.
Our reasoning and 12 basis for taking this position are several.
One, our basic b
13 concern for a waste form in the burial grounds that will be 14 less susceptible to leaking, will provide a more stable form 15 to prevent subsidence of trenches, minimi:e handling problems 16 in terms of contamination and leakage.
Solid form, we feel, 17 would enhance transportation safety.
18 Then there's a certain basic logic that we find in 19 the NRR position that all new systems, all new reactors at 20 least, shotdd have waste solidification capabilities.
We view 21 this new waste treatment system at TMI-II as a new system being installed and feel that it ought to be subjected to NRR 22 23 position requiring solidification.
The countervailing point of view is expressed by 24
$5 the NRR people, the NRR people in particular I guess being Acme Reporting Company 222 429 2899
35 4
John Collins and Richard Vollmer, who have taken the position 1
2 that they don't feel that solidification is necessary.
One of 3
the strong arguments that they give is that there are no 4
regulatory requirements that would mandate it.
In spite of 5
the fact that they have taken a policy earlier that says that 6
it should be done, in this particular case they have declared 7
they don't think it should be done.
8' Also, one of Collins' strong points, and I guess I 9
can't quarrel with this point, he said that they want to treat to TMI the way you treat any other reactor, that in their view 11 the waste products coming out of this reactor, out of this 12 partictlar clean-up campaign, are not significantly different
(
13 from sone rad wastes that have already been encountered from 14 other reactors, and that nothing should be done to single out 15 TMI to do something that you would not also want done and 16 require it be done at all the other reactors.
Which is a 17 position basically I 'uess we don't disagree with because our 18 idea is that as we promulgete these regulations, they likely 19 will be applicable to all reactors.
'M Our singling out TMI-II--if singling out is the 21 proper term--hinges around a couple of considerations, one being the ones I gave you a minute ago about our general con-22 23 cern for improving the waste form and enhancing transportation 24 safety, the fact that it is a new system, and then superimposed 25 over all of that is kind of a nonscientific, nontechnical Acme Reporting Company n r.:.....
36 1
awareness that any incident, whether you technically view TMI 2
waste as being any different than anybody else's, the public 3
perception is somethir., satirely different.
The public 4
reaction and ti.e politica consequences in what we feel is an 5
almost indefensi!
i position that NRC would be in if there 6
were to be any kind of shipping incident or any kind of inci-7 dent at the burial site that could have been prevented or at 8
least minimized by solidifying the waste, that if a truck were 9
to tip over and lose any contents, as low as that probability 10 might be, or if the packages were unloaded at Hanford and 11 found to have water and this was brought to the governor's 12 attention and to the press's attention.
And the obviov; 4
13 question that would be asked of NRC is wasn't there scmething 14 you could have done to have prevented this?
The obvious 15 answer is yes.
16 Q
With respect to the alternative that is apparently 17 favored by NRR, is that the first alternative described in 18 Table B, and that is dewater resins?
19 A
Yes.
20 Q
And that's the form which has had some history of 21 prob'lems of shipment and problems in burial due to free-1 22 standing liquids?
23 A
That's right.
24 Q
How many truckloads is it contemplated would be 25 required to remove the auxiliary building wastes to Hanford?
Acme Reporting Company
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37 1
A I've seen several numbers cited and we've done some 2
calculations.
It's a little bit hard to predict for a couple 3
of technical reasons.
These resins will be operated until one 4
of two things happens:
either the radiation level builds up 5
to some preset limit, or they lose their activity by having 6
become contaminated with nonradioactive chemicals.
So I 7
think optimistically we are probably looking at numbers like 8
50 as a minimum number of shipments.
That number may grow to 9
more than 50; maybe between 50 and 100.
Numbers that I've 10 heard quoted are a total of 200 shipments to Hanford over the 11 next year or two.
But I would expect that that number includes 12 some of the dry solid trash type of waste as well.
[
13 Q
So somewhere between 50 and 200 would be a ballpark 14 figure?
15 A
That probably bounds it, yes.
16 Q
Do you have any idea of which ntates these 50 to 200 17 truck loads of dewater resin wastes would be traversing on its 18 way to Hanford?
19 A
There are two routes under consideration.
I'm try-20 ing to recall a conversation I had with one of the state 21 officials in Washington.
They had a meeting out there some 22 week or so ago, one of purposes of which was to meet with 23 officials, state and community officials, who might be on the 24 route.
These were both northern routes, one of which involved 25 some eleven states and I believe the other one inv.olved a Acme Reporting Company u,,,....
38 I
larger number, the number being like 15 or 17 states.
These 2
were interstate highways in the norther tier of states and I 3
think I recall Interstate 90 as being one of the principal 4
routes.
5 Q
Is the process of solidif,ing these wastes completely 6
to making them completely dry by putting them in a concrete 7
matrix, a more expensive alternative?
8 A
More expensive than?
9 Q
Than shipping them in the form of semi-liquid resin 10 beads or rasin wastes?
11 A
It's one more processing step so it is more expensive 12 At least at the manufacturing end of it it is more expensive, l
13 yes.
s 14 Q
Who would bear the cost of that?
Would that be the 15 utility if that alternative were chosen?
i is A
In all likelihood, yes.
1; Q
Would I be accurate in concluding that the complete l
18 solidification which is preferred by your branch would be the 19 safer but more costly alternative, whereas the alternative 20 favored by NRR would be the less safe and less costly 21 alternative?
22 A
That's a fair statement.
s 23 Q
You've indicated earlier that there has been some 24 documented history of accidents with the shipment of these 25 dewatered resins and problems of liquid in the containers and Acme Reporting Company 202' 429 4989
39 1
so forth, as documented in this Exhibit 2 that we have.
Let 2
me show you a letter which is dated July 10, 1979, addressed 3
to Chairman Hendrie, which bears three signatures, and ask you 4
if this letter was directed at the sort of problem which we've 5
been discussing, and that is liquid seepage from containers 6
due to accidents or otherwise at the containment site?
7 A
This letter which is from the. governors of the 8
three states that operate and regulate commercial low-level 9
burial grounds was precipitated or at least was encouraged by 10 Governor List's action in the State of Nevada where two inci-11 dents over a period of a month or so caused him to close down 12 the burial site at Beatty until the situation was taken care
(
13 of.
Both of the situations involved improper packaging of 14 low-level wastes.
The first resulted in a fire on a truck 15 that had brought waste in there, the fire resulting from is improperly packaged hospital wastes that included liquid Sc mbuaba 1-ciru12ti:n vials which contained toluene and were simply 18 thrown in with the rest of the trash.
19 Q
That was a situation of spontaneous combustion?
20 A
It was spontaneous combustion.
This caused 21 Governor List to request NRC do something to prevent similar 22 incidents from happening in the future, not only with liquid 23 simulation vials but all improperly packaged waste.
24 Shortly thereafter, shortly being a matter of 25 several weeks, a shipment arrived at Beatty from the Palisades Acme Reporting Company 2"2* 92s.49,9
40 I
plant that contained evaporator bottoms that had been solidi-2 fied with urea-formaldehyde, or at least had been processed 3
with urea-formaldehyde.
At least two of these containers were 4
found to be leaking and apparently as a result of corrosion 5
from the inside of the container to the outside.
6 At this point, Governor List closed the burial 7
ground, and my understanding is at the National Governors 8
Conference met with Governor Ray and Governor Riley and the 9
three of them then drafted this letter addressed to Chairman 10 Hendrie and laid out what you might easily interpret to be an 11 ultimatum to NRC to get with the Department of Transportation 12 and prepare some sort of plan, an action plan, and submit it
'[
13 to the governors by the first of September, assuring them that 14 improperly packaged waste shipments would not be delivered to 15 their facilities anymore, or at least that we would be taking 16 actions to minimize that.
Tape 4 1"
Q Would it be fair to characteri e the latter of the 18 two events which you've described as leak from containers of i
19 liquid, radioactive liquid?'
20 A
Yes.
21 Q
From semi-liquid waste?
22 A
Semi-liquid in that there was. free liquid present 23 with whatever solids were there.
24 Q
Let's have this letter which is signed on the second 25 page by Dixy Lee Ray, the governor of Washington, Acme Reporting Company m u.4...
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41 1
Richard W. Riley, the governor of South Carolina, and Robert 2
List, the governor of Nevada, marked as the third exhibit to 3
the Depostiion.
4 (WHEREUPON, the document referrec.
5 to'was marked as Exhibit 3 to 6
the Deposition.)
Q Are you aware of whether there has been a response 8
from the NRC to this letter, specifically from Chairman Hendrie ?
9 A
There was a response to that letter, I believe --
to let's see, that letter was dated July 10.
I believe there was 11 a response within about a week or so after being received here 12 which was sort of an acknowledgement--we're working on the b
13 Problem and we'll get back in touch.
14 The action plan that they requested or demanded be 15 submitted by August 1, I don't know whether that letter went is out.
I saw the thing being prepared in draft and a Commission n
paper being prepared to transmit it to Chairman Hendrie.
That is was done last week prior to the first of August to that it was 19 down there or was at least on its way down there prior to 20 August 1 for signature and dispatch.
My personal knowledge of i
1 21 whether that second letter went out, I don't know.
r Q
Do you recall whether in either the first letter 23 which was sent out or the second letter which may or may not 24 have been sent out as of this date there was a commitment on 25 the part of the NRC to require complete solification of the Acme Reporting Company u t n,a,,,
6 42 1
TMI-II wastes prior to shipment, or whether no position on that has been officia'lly taken?
2 3
A There was no official position taken with regard I
4 to solidification of TMI-II wastes.
There is in the action 5
plan a statement that we intend to have a branch te hnical 6
position developed by the first of September dealing with
~
7 solidification of sludges and resins, but there were no state-8 ments that were specific to TMI-II wastes.
9 Their concern, TMI-II may have been in the back of 10 their minds or in the forefront o f their minds, but TMI-II was 11 never singled out, has not been singled out in any of the 12 actions of the governors in terms of health and safety or
(
13 shipping problems.
Governor Riley refused to accept TMI-II 14 waste in South Carolina.
The principal reason that he gave 15 for that was one of economics and volume limitations on the 16 Barnwell site, that, bluntly put, they didn't want to fill up 17 their burial ground with a large volume of waste from TMI-II 18 and they have put annual volume limitations to assure adequate 19 financing.
And he just said we're not going to accept any 1
m TMI-II wastes because it's out of the normal kind of volumes 21 that we are able to handle.
22 But nobody has -- None of the governors has addressed 23 TMI-II. wastes specifically in any correspondence with us.
24 Governor Ray had a public meeting in Olympia, as I say, a 25 little over a week ago at which discussions were held relative Acme Reporting Company us,42......
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to bringing TMI II wastes out to Hanford for disposal.
2 Q
Let's go off the record for a moment.
3 (Off the record briefly)
/
Q I have here a document dated July 17, 1979, a 4
5 memorandum directed to John 3. Martin, Director of the Division 6
of Naste Management, from R. Dale Smith, Chief of the Low-Level 7
Waste Licensing Branch, and it's entitled " Trip Report:
1 8
Disposal Site Visit and Meetings with State of Washington 9
Officials."
10 Could you please describe what this memorandum is i
11 and what it describes?
j 12 A
Yes.
This is a memo that was prepared in our branch
(
13 and signed by me documenting a trip that one of my staff i
14 members, Gary Roles, and I had made to the State of Washington 15 back on June 11 and June 12.
The purpose of the trip was to 16 visit the low-level waste disposal site operated by Nuclear 17 Engineering Company out at Hanford, principally in connection 18 with license renewal of the NRC license and also to meet with 19 the state health officials regarding their renewal of the 20 source and by-product material license.
21 Ne also met with other officials of the State of 22 Washington while we were there to discuss several other 23 matters.
24 Q
Was waste from the Three Mile Island Unit II power 25 plant discussed with Washington officials on this visit?
Acme Reporting Company u......
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A Yes, it was.
There were a couple of incidents where 2
we discuss TMI wastes with the state people.
3 Q
Was there any discussion of shipment and burial of 4
contamine.ed resin wastes as opposed to shipment and burial of 5
solid form wastes containing no free-standing liquid?
6 A
We had mentioned to the state people and, as I 7
recall, yes, this was at the site visit so there were also the 8
site operating people were in attendance.
We mentioned that 9
we were developing a branch technical position on solidifica-10 tion of resins and sludges.
And we also mentioned that if the 11 TMI wastes were to comply with this position that we were 12 developing, then they would have to sol.idify in menolithic
(
13 form with no free-standing water.
14 Q
Would that require some modification of the treat-15 ment facilities at the TMI plant?
16 A
Yes, it would.
17 Q
So this discussion concerning semi-liquid or con-18 taminated resin wastes, vis-a-vis, completely solid wastes 19 with no free-standing water, was discussed in the context of 2
the TMI-II situation?
21 A
Yes, it was.
It was discussed in general terms but because of the timing and because of the fact that this 22 23 was the site that was likely to receive the waste, they, of 24 course, had a very high interest in TMI itself.
25 Q
Do you know if the response to your memorandum was Acme Reporting Company u r u......
45 1
prepared by NRR?
2 A
There was a memorandum addressed to Robert Browning, 3
who is our Deputy Director, from John Collins who offered 4
several comments on this trip report as well as some recount-5 ing of a visit Chairman Hendrie had paid him at TMI.
6 Q
3efore we get into that, let's have this memorandum which was prepared by you for John B. Martin marked as 8
Exhibit 4 to the Deposition.
9 (WHEREUPON, the document referred to to was marked as Exhibit 4 to the 11 Deposition.)
12 Q
Do you have a copy of that communication from b
13 Mr. Collins to Mr. Browning?
14 A
I do not.
No, Sir, I don't.
15 Q
Let me note for the record that that letter or is memorandum has already been marked as Exhibit 2 to the t-Deposition of William J. Dircks.
That memorandum is dated is July 25, 1979 and refers to a meeting between Mr. Collins and 19 NRC Chairman Hendrie on July 6, 1979, and refers also to a 20 visit to the site of TMI-II by Chairman Hendrie where there 21 was a meeting with representatives of GPU and Meted.
Do you 22 recall whether that's an accurate description o: that
~
q memorandum?
describes -- That's an accurate description of A
That 25 about half of what was in the memorandum.
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Q Would it be accurate to state that the second half
?
~
2 of the memorandum is directed toward the trip report prepared 3
by you and addressed to John Martin?
e 4
A Yes.
There were, I believe, at least three comments 5
directed toward this trip report, 6
Q Do recall whether anyone from your branch attended 7
the meeting between Mr. Collins and NRC Chairman Mr. Hendrie?
8 A
No, Sir, nobody from our branch did attend.
9 Q
Was your branch invited to attend?
10 A
No, it was not.
11 Q
Do you recall whether anyone from your branch 12 participated in the on-site visit by Chairman Hendrie to
(
13 TMI-II?
14 A
No, Sir, nobody did.
15 Q
Was anyone from your branch invited to attend?
16 A
They were not.
1; Q
To the best of your recollection, would it be is accurate that that memorandum states, "The currdnt position 19 of NRR is that the resins will not be solidified."?
2 A
I be'lieve that is a correct statement.
21 Q
Would that be an accurate description of the present
,(
r position of NRR today?
23 A
Yes.
24 Q
On page 1 of the letter at the end of the first 25 paragraph it states, " Chairman Hendrie indicated that in his Acme Reporting Company
. m,,......
47 1
opinion it was not necessary at this time to solidify the l
2 resins from EPICOR-II prior to shipment."
3 Is that your understanding of Chairman Hendrie's 4
position with respect to the TMI-II auxiliary wastes?
1 5
A I don't know that I understand -- I don't know that 1
1 6
I know what Chairman Hendrie's position is.
I read it as it was described by Mr. Collins.
I have heard in a meeting with 8
the Chairman on Thursday of last week, heard him express a 9
point of view that I would have a little hard time inter-10 preting.
If I were John Collins, I might interpret it as 11 being supportive of his position.
Being oa'the other side of 12 the issue, I didn't interpret it as being til that supportive.
f 13 It was sort of a. middle-of-the-road, you know, it doesn't 14 really look like it's all that bad kind of a position, but it is was not a strong statement that says that we think that we is should not solidify.
It was sort of a doesn't look all that i
1-bad to me kind of statement.
is Q
Are you saying that Chairman Hendrie's statement 19 was that nonsolidification doesn't look all that bad to him?
m)
A Right, that shipping the resins in an unsolidified 21 form -- how to put it?
He didn't seem to show'any great con-22 concern for shipping unsolidified resins.
23 Q
Who was at this meeting with Chairman Hendrie besides 24 yourself and Mr. Collins?
25 A
Okay, the principals were Commissioner Ahearne,and Acme Reporting Company 2:2' 429 49W8
48 1
Chairman Hendrie.
The people who did the most talking and 2
were the principal presenters were John Collins; Jack Martin, 3
the Director of Waste Management Division; Bill Dircks, the 4
Director of the Office of Nuclear Material Safety and Safe-5 guards.
Those were the principals.
This was an open meeting 6
and I was there, Bob Browning was there, there were other 7
staff people from NRR, there were the usual assortment of 8
Commissioners assistants and other people.
9 Q
Were any of the other Commissioners present besides 10 Chairman Hendrie and Commissioner Ahearne?
11 A
No, they were the only two.
A transcript was made 12 of the meeting at Commissioner Gilinsky's request.
It was not b
13 a quorum of the Commission that required a formal open tran-14 script type of meeting, but a transcript was made for 15 Commissioner Gilinsky's benefit.
16 Q
And the date of the meeting, as best as you can 17 recall?
18 A
Last Thursday.
19 Q
Would that have been August 2?
20 A
Yes.
21 Q'
Can we stipulate that last Thursday was August 2?
22 A
On advice of counsel, I'm told to say yes.
23 Q
Would it be possible for us to obtain through you a 24 copy of that transcript?
Could you arrange for a copy of that 25 to be provided to us?
Acme Reporting Company l
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A I see no reason why not.
2 Q
Could that be done within the next couple of days, 3
do you think?
4 A
I'll try.
5 Q
Okay.
Would it be accurate to state that the pri-6 mary function of the NRC is to insure the safe operation of 7
nuclear reactors and the safe transportation of radioactive S
wastes?
9 A
The primary mission of the NRC is to protect public 10 health and safety, and insofar as that involves transportation 11 of waste, operation of nuclear reactors and any one of a myriad 12 of other things that we have responsibility for, the answer is 13 yes.
With a qualification:
I think you said that NRC 14 operates reactors safely.
NRC assures that the licensee 15 operates the reactor safely.
16 Q
So safety would be the primary concern of the NRC 17 then?
18 A
Public health and safety.
19 Q
You indicated a moment ago that solidification, com-3) plete solidification of the wastes would be the more safe 21 alternative and the more expensive alternative.
Can you see
,(
22 any safety advantage to the shipment of 50 to 200 truck loads 23 of semi-liquid wastes through 15 to 17 states to Washington 24 from TMI?
25 A
I see no safety advantage whatsoever.
Acme Reporting Company ses.,s......
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Q With respect to the eleven states through which the 2
waste will be shipped, assuming that Plan A is followed, or 3
the 15 to 17 states through which the waste will be shipped if
?
Plan 3 is followed, is there any formal notification of these 4
s states before the shipments go through with an opportunity for 5
6 them to comp 1,ain or express their views?
7 A
Because this is what it is, Three Mile Island waste 8
shipment, I think that great efforts are being expended to 9
assure that everyone along the route is notified in advance.
10 Under normal shipments of anybody else's reactor waste, this 11 sort of notification is not done.
It is not required and is 12 not routinely done.
Because of the high public interest, they f
13 are making sure, I'm quite sure, that everybody knows when 14 and where the shipments will occur.
15 Q
So this notification procedure is a special proce-16 ditre for TMI-II?
17 A
Yes.
18 Q
Do you know if there will be any security provided 19 for the se trucks along the way?
20 A
I guess my answer has to be no, I don't know.
Noti-21 fication of states may well precipitate a police escort or something, but my personal knowledge is I don't know.
23 Q
Have you heard anything about a recent release of 24 4,000 gallons of "slightly radioactive" (and that's in quotes) 25 water from TMI-II?
Apparently a news article appeared'to this Acme Reporting Company
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51 I
effect last week.
2 A
I read the news article.
3 Q
Other than that, you have no notification or informa-4 tion regarding this?
5 A
No.
6 Q
Would such a release come within the jurisdiction of 7
your office?
8 A
Probably not.
The effluents, at least the gaseous 9
and liquid effluents from plants are normally the province of 10 the people who license the facilities.
11 Q
With respect to the transcript you indicated you 12 would be providing for us, could we have a stipulation from
(
13 Counsel that that would be Exhibit 5 to the Deposition once 14 it is provided?
15 A
Do you have any problem with that?
16 MR. CIIOPK0:
I have no problem.
17 A
We'll stipulate.
18 (WHEREUPON, the docu. ment referred 19 to will be marked at Exhibit 5 20 to the Deposition when received.?
21 MR. IIELFMAN:
With that stipulation, unless Mr.
22 Chopko has any questions for the witness?
i.s 23 MR. CHOPK0:
I have no questions at this time.
A I
24 some point Mr. Smith will, I guess, write you and enclose a l
25 copy of his resume and a copy of the transcript.
l i
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MR. HELFMAN:
There were two other items that were 2
mentioned during the course of the Deposition; perhaps we can 3
handle them in the same way.
One was a letter which you felt 4
had been sent already from Chairman Hendrie in response to 5
the letter which we have marked as Exhibit 3 to this Deposi-6 tion, signed by the three governors; and a second letter that 7
you referred to which you did not know whether it had actually 8
been sent yet.
Could we have a similar stipulation that those 9
two materials will be provided by Mr. Smith and when received 10 would be deemed Exhibits 6 and 7 to the Deposition?
11 MR. CH0PK0:
As to the first, the acknowledgement 12 letter, I don't think that there would,be any proboem with b
13 that.
I think that there may be more sensitivity to the final 14 letter if it's still in draft and circulating for Commissioner 15 concurrence.
When the final letter is sent from the Chairman, 16 I don't think there's any problem with providing it, but not 17 until then.
18 MR. HELFMAN:
With respect to the draft letter, 19 could we handle it in this fashion:
that it would be provided 20 to us but not marked as an exhibit to the Deposition and that 21 when a final draft is obtained which has been sent, that copy 22 would then be deemed Exhibit 6 to the Deposition?
,(
23 MR. CH0PK0:
I think Exhibit 6 we're designating as 24 the acknowledgement letter, and that I believe has been sent.
25 The action plan letter is the final, is going to be the NRC Acme Reporting Company 2025 829 4999
33 I
response and that is going to be Exhibit 7 when it is sent.
(EXHIBIT 7 identified) 2 MR. SIDELL:
There's probably somebody within a door 3
or two of here that could tell us whether or not that letter 4
has been sent.
5 MR. HELFMAN:
Why don't w'e go off the record then for 6
a moment and find out if it has been sent and available to us.
~
MR. CH0PK0:
That's great.
8 (A brief recess was taken for the above purpose.)
po 5 9
CONTINUED EXAMINATION OF ROBERT DALE SMITH:
10 BY MR. HELFMAN:
11 Q
Have you been able to obtain any information about 12 the letter which has been sent by Chairman Hendrie to the
[
13 three governors and the proposed letter which has not let been 14 sent?
15 A
Information such as the letter of July 18 was the i
16 response to Governor Ray, Governor Riley, and Governor List.
17 Q
I see you obtained a copy of that letter during the 18 break in the Deposition.
19 A
Yes, Sir.
l 20 Q
May I see that, please?
(Receives document) 21 We have what appears to be a three-page letter signed by 22 Chairman Hendrie dated July 18, 1979, one copy to The 23 Honorable Dixy Lee Ray, the Governor of Washington; a second 24 copy of that letter addressed to The Honorable Robert List, 25 the Governor of Nevada; and a third copy addressed to Acme Reporting Company u r.a......
s4 1
The Honorable Richard W. Riley, Governor of South Carolina.
2 I would like to have these three copies marked jointly as 3
the next exhibit to the Deposition which I believe is
/*
4 Exhibit 6.
5 (WHEREUPON, the three copies of 6
the document referred to were 7
marked as Exhibit 6 to the 8
Deposition.)
9 Q
With respect to the letters that have been marked to as Exhibit 6, have you had an opportunity to review these 11 letters?
12 A
Yes, Sir.
f 13 Q
Would it be accurate to state that the subject of 14 completely solidified waste versus semi-liquid wsste is not 15 addressed in this letter?
16 A
Yes, Sir, that is correct.
17 Q
You've handed me another document dated June 18,
~
18 1979, directed from William J. Dircks, Director of the Office 19 of Nuclear Material Safety and Safeguards, for Harold R.
20 Denton, the Director of the Office of Nuclear Reactor Regula-21 tions, which covers a memorandum for John Martin, Director
(
22 of the Division of Waste Management, and Richard E. Cunningham,
23 Director of the Divison of Fuel Cycle anc Material Safety, 24 from Robert Browning, Deputy Director. Division of Waste 25 Management, and Charles E. MacDonald, Chief, Transportation Acme Reporting Company
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55 1
Branch, Division of Fuel Cycle and Material Safety, with the 2
subject title: " Trip Report to Three Mile Island."
3 Would you please describe for the record what this 4
document is?
5 A
The trip report recounds a visit we made--we being 6
representatives of Waste Management and Fuel Cycle Divisions--
7 we made to Three Mile Island on June 5.
The purpose of the 8
meeting, the trip, actually, was to meet with the NRC people 9
on-site to discuss with them their plans for processing and 10 treating the contaminated liquids at TMI.
11 The reason for going to TMI, there were several 12 reasons for going up to Three Mile Islana, one of which was 13 the desire to talk to the people directly on site.
We found 14 at least at that time the people who were here in Bethesda 15 were not sufficiently knowledgeable on what was going or at 16 Three Mile Island to really tell us what we wanted to know, so 17 we arranged to visit with John Collins and Rick Weller, who 18 works with John up there.
19 The other reason we wantad to go up was to see m
firsthand the types of equipment and the preparations that 21 were being made for processing the waste.
That was the purpose
,(
22 of the trip report.
23 The purpose of the covering memo was to transmit to 24 Harold Denton a copy of this report and to identify the staff 25 member within NMSS that had been identified as the lead for Acme Reporting Company
56 I
NRR contact in terms of dealing with TMI wastes, and requesting 2
NRR to identify a principal contact to deal with us.
3 Q
Has there been a response from NRR to this memoran-4 dun?
5 A
Not to my knowledge, there has not been a response.
6 Q
Normally, is it a function of ISE to conduct on-site 7
investigations and obtain the information necessary for other 8
branches?
9 A
I'm sure there have been circumstances and occasions l
10 when ISE people gathered information for other offices as 11 part of their site visits.
On the other hand, it's not at all 12 uncommon for the program offices, the Jicensing offices, to b
13 go out and get the information for themselves.
14 Q
Is that due in part to a lack of technical expertise 15 with ISE?
16 A
Not necessarily.
I guess the occasions when I would 17 imagine IGE getting the most use are those occasions where 18 they are going to be there anyway and it's not worth sending 19 somebody from Headquarters out if an I$E guy can do it.
There 20 may be circumstances where the kind of information that we 21 want to get is beyond the expertise of the inspector, but it's 22 not a rigid arrangement either way.
-(
23 Q
This memorandum which you've handed me which bears 24 the date June 18, 1979 indicates on the first page that 25 Metropolitan Edison is planning to dewateri:e the wastes and l
Acme Reporting Company
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have them shipped in that form.
Is that your understanding?
2 A
That was our understanding at the time we wrote the 3
memo, yes.
(
4 Q
A memorandum also exists that the approach on 5
reducing the wastes in the form of a solid matrix, such as 6
mixing the resins with concrete, would comply with the techni-7 cal position of the Effluent Treatment Systems Branch, 8
ETSB-ll-3, dated November 24, 1975.
Is that accurate?
9 A
Yes.
10 Q
Would it be possible to obtain from you a copy of 11 the technical position dated November 24, 1975?
12 A
Yes, I could send you a copy.
13 Q
Can we have a stipulation from Counsel that when 14 that is received it will be marked as Exhibit 8 to the 15 Deposition?
16 MR. CH0PK0:
So stipulated.
17 (WHEREUPON, the document referrec 18 to will be marked as Exhibit 8 19 to the Deposition when received.)
20 MR. HELFMAN:
Let's also have this memorandum which 21 we've identified as the June 18, 1979 memorandum for Harold 22 Denton from William J. Dircks covering the previously identi-23 fied memorandum or trip report to Three Mile Island marked 24 as Exhibit 9 to the Deposition.
(WHEREUPON the document referred 23 to was marked as Exhibit 9 to the Deposition.)
Acme Reporting Company
58 I
BY MR. HELFMAN:
2 Q
Would it be an accurate conclusion that the reason 3
the alternative remains for TMI-II as to whether the wastes 4
will be shipped in completely solid form or in the semi-liquid 5
form is the result of the time when TMI-II received its 6
operating license and the time when the ETSB-ll-3 was promul-7 gated?
In other words --
8 A
If I understood your question, the reason that 9
TMI-II did not have or does not have a built-in solidification 10 system was due to the timing of their application as compared 11 to this technical position, yes, I'm sure that's the situation.
12 Q
Do you know of any reason why this requirement was
(
13 not backfitted to TMI-II?
14 A
I don't know any reason.
15 Q
Who would be responsible for making a decision to 16 backfit such a requirement?
17 A
The backfitting reviews have been done by the branch 16 in which Lake Barrett is a section leader.
It's within that 19 part of the organization within NRR that concerns itself with 20 operating reactors.
I'm sorry I can't lead you through the 21 organization chart to the specific title, but within NRR the 22 group that deals with operating reactors is attempting to 23 evaluate existing reactors in terms of backfitting for 22 solidification.
25 Q
Is that primarily under the SRP?
Acme Reporting Company
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A I don't know how NRR does its business so I don't 2
know that I can answer that.
Certainly the requirement for 3
implementing ETSB-11-3 as part of the review process for new
(
4 reactors for construction permits I believe does derive from 5
the Standard Review Plan.
Now reviewing it for backfitting 6
may spring from that same source; I don't know.
7 Q
Has your branch ever recommended the backfitting of 8
this requirement to operating reactors, such as TMI-II?
9 A
We have not reached the point in the development'of 10 regulations or branch technical positions that we have taken 11 a formal stand regarding backfitting.
We at this point have 12 made information declarations, informal being something less 13 than a technical position or regulation, regarding our feeling 14 that the wastes should be solidified.
Implicit in that is 15 the need to work out a plan for implementation and backfitting i
16 of existing facilities.
17 Q
But that is implicit; there has been no expressed 18 recommendation or suggestion to backfit this requirement to 19 operating reactors.
Is that correct?
1 2
A That's correct.
21 MR. HELFMAN:
Then there's one final thing we ought 22 to take care of and that is the question of Exhibit 7 which
,(
23 will be the final position from the Commissioners in response 24 to the letter from the three governors, and we understand 25 that the NRC is unwilling to provide us with a copy of the Acme Reporting Company n a, < u a...
60 I
draf t which is presently in the hands of the Commissioners for 2
review, but is willing to provide us with a final copy of 3
that once it is approved by the Commissioners.
Is that 4
accurate?
5 MR. CH0PK0:
That's close.
We will send you the 6
final letter when it is sent.
I suspect it will be sent in 7
the next couple of days.
The Commissioners recognize that it 8
is important.
I 9
MR. HELFMAN:
Shall we have a stipulation that that 10 letter when received will be deemed Exhibit 7 to the 11 Deposition?
12 MR. CHOPK0:
We've already agreed to that on'the
(
13 record.
(See page 53) 14 MR. HELFMAN:
All right.
Do you have any further is questions, Mr. Chopko?
^
16 MR. CH0PK0:
No other questions.
17 MR. HELFMAN:
On that note we will recess the 18 Deposition.
As I indicated earlier, if we have further 19 questions of you, we will simply reconvene it.
Thank you 2
very much for your time.
21 (WHEREUPON, at 12:40 p.m. the Deposition was
'5 y
recessed.)
I have read the foregoing pages, 1 through 60, and they are a true inc RS/vis 23 Subscribed and sworn to
. accurate record of my testimonv aefore me this day
~
therein recorded.
24 af 1979.
~
25 Robert Dale Smith Notary Public My Commission Expires:
Acme xeparung Company
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CERTIFICATE I certify that I have read this transcript and corrected any errors in the transcription that I have been able to identify, except for unimportant punctuation errors.
$ 3 ?f Date:
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5 DOCIET NUMSER:
6 CASE T!!LE: DEPOSITION OF ROBERT DALE SMITH EEARING DATE:
August 7, 1979
~
8 CCATION:
Bethesda, Maryland 9
10 I hereby certify that the proceedings and evidence 11 herein are contained fully and accurately in the notes 12 taken by me at the hearing in the above case before the 13 PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILT
(
ISLAND 14 and that this is a true and correct transcript of the 15 sa:e.
16 IT 13 Date:
August 8, 1979 19 00 21 Official Recorter Acr.e Repcrting Cc=pany, Inc.
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N!c 1 1979 F
MEMORANDUM FOR:
R. Dale Smith, Chief Low-Level Waste Licensing Branch Kitty S. Dragonette h TriRU:
Low-Level Waste Licensing Branch FROM:
Sally Latlief Low-Level Waste Licensing Branch
SUBJECT:
DISCREPANCIES AND VIOLATIONS FOUND ON LOW-LEVEL RADI0 ACTIVE WASTE SHIPMENTS AT THE CHEM-NUCLEAR BURIAL FACILITY IN SOUTH CAROLINA The State of South Carolina has been conducting an inspection program at the Chem-Nuclear Low-Level Waste Burial ground located near Barnwell, South Carolina to determine the condition of packages arriving at the site. Major violations in the packaging for transportation of Low-Levet Waste to the I
burial site are described in 43 radioactive waste discrepancy reports resulting from this state inspection program. The 43 problem shipments were received at the Chem-Nuclear burial facility between April 10 and June 5 of this year (1979).
The improper shipments were received from power plants, institutions, industries and the military.
Table A is a summary of the problems encountered with the 43 shipments. This sumary is broken down into the four different source groups and further arranged by the types of waste in each of the defective shipments.
Of the faulty shipments, the majority, 70 percent, were received from power plants.
Institutional waste packages comprised 14 percent of the improper shipments.
Nine percent of the discrepancies were attributed to industrial sources and the remaining seven percent were. received from military sources.
Table B shows a separation of the waste by type and the problems with each j
defective shipment.
There were nine different violations including; improper packaging, free standing licuid in the dr"% mislabeled drums, improper single-walled drud, unpreservea carcasses, nigh-levels of radiation that were not indicated by the placards, trailers missing placards, improper loading of the trailer and contaminated trailers. There were a total of 63 discrepancies l
with the 43 shipments because several of the shipments had two or more violations.
l
.s There were 30 defective shipments from the powerplants. The four types of waste involved in the problematic shipments were dewatered resins, solidified waste, evaporator bottoms and solid dry waste.
Of the twelve resin shipments, seven l
R.D. SMITH DEPOSITION 8/7/79 EXHIBIT 2, page 1 of 7
9*
I2 "
1 U77 R. Dale Smith (
involved poor packaging techniques including loose or missing bolts, no sealing gasket, bent cask lids etc. Five of the resin shipments contained up to 30 gallons of free liquid in the cask. Two shipments had leaking casks which contaminated the trailer.
Five remaining discrepancies in resin shipments consisted of administrative failures such as missing placards.
Eleven of the power plants shipments were solidified waste.
Seve.' of these shipments involved poor packaging. Two of the solidified wante shipr. ants contained free liquid. Two other problems were a contaminated trailer and an improperly loaded trailer.
There were two shipments of evaporator bottom concentrates.
One shipment had 30 gallons of free liquid in a drum and a contaminated trailer. The other shipment had outdated placards on the trailer. The five remaining power plant shipments were dry solid waste. Three of the dry waste shipments contained free liquid in the drums.
One shipment of dry waste was improperly packaged. One shipment contained a higher level of radioactivity than was indicated by the placards and also contaminated the trailer.
The six shipments of institutional waste were all scintillation vials and animal carcasses. Two shipments contained liquid in single-wall drums with no absorbent and unpreserved animal carcasses. Two shipnents were improperly
, (
packaged and contained free liquid in drums and two contained mislabeled drums.
The four industrial shipments all contained depleted uranium. Three of the rhipments contaminated the trailers and two shipments were improperly loaded on the trailers. One remaining shipment had mislabeled drums.
Of three military shipments, two contained electro 1 tube assemblies and one contained needles, syringes and serum bottles. Both of the electron tube shipments were improperly packaged and one contained a higher level of radioactivity than was indicated by the placards. The syringe shipment was improperly packaged and vials of liquid were in a single-wall drum with no absorbent.
The. general trends in the state inspection were also found by the site operator in reviewing a recent month's experience. The recent data, from June 20 thru July 20, reports that 448 shipments were received at the South Carolina site.
84 of the shipments contained discrepancies and another 19 were rejected primarily because the waste form could not be accepted for burial (e.g., liquid scintillation fluid in absorbent). Of the 84 problem ship'ments, 56 percent were improperly
,.(
~
j R.D. SMITH DEPOSITION S/7/79 l
EXHIBIT 2, page 2 of 7
0 R. Dale Smith 1 UD l
packaged or contaminated.the trailer. This compares to 51 percent in similar catagories derived from the 43 state descrepancy reports.
21 percent of the faulty shipments contained casks with free standing liquids which compared to 22 percent of the same discrepancy in the state reports.
Approximately 10 '
percent of the trailer: were improperly loaded and 15 percent included improper paper work or mislabeled drums according to both informatica sources, t$
Sally Latlief Low-Level Waste Licensing Stanch Division of Waste Management
Enclosures:
1.
Table A 2.
Table B
(
e R.D. SMITH DEPOSITION 8/7/79 EXHIBIT 2, page 3 of 7
l TABLE A:
SUMMARY
OF THE PROBLEMS EfiCOUNTERED WZTH THE 43 SHlPMENTS Power Plants Shipper Type of Waste Problem Arkansas P&L spent resin filters cask missing. bolt, no sealing gasket, free liquid, loose securing cnains Boston Edison spent. resin loose bolt, no sealing gasket, free water Boston Edison solidified liquid boxes on top of drums, improper trailer compacted trash loading Boston Edison spent resin poor packaging, contaminated liners l
Carolina P&L resin free water in the cask Carolina P&L resin no placards for 20 mr/hr radiation Carolina P&L evaporator conc.
30 gal. water in drum, contaminated trailer Carolina P&L solid waste and contaminated trailer, incorrect radiation components readings Carolina P&L solidified waste free water in cask
(
Carolina P&L resins Broken tie for cask rain cover Carolina P&L evap. Dottoms outdated placards Com Ed concentrate in cement loose turnbuckle tie downs i
Com Ed resin in cement missing bolt on cask lid Com Ed resin in cement cask lid stud bent, loose lid Com Ed resin in cement stripped threads on bolt (impossible to tighten)
- Ce Ca resin in cement loose and improperly maintained turnbuckle tie downs used as only means to secure cask Com Ed dry solid waste loose bolt on cask door, door ajar no sealing gasket Com Ed spent filters outside cask contaminated, free water and vermiculite in cask Conn Yankee solidified waste loose securing nuts, bent studs, cask improperly sealed R.D. SMITH DEPOSITION 8/7/79 EXHIBIT 2, page 4.of 7
e R.D. SMITH DEPOSITION 8/7/79 H
,pg 5 of 7
.TdBLEAcon't Shipper Type of Waste Problem D. C. Cook spent resin
- 30 gal, free water in cask Duke Power liner in flux cask free water in Bx-48-220 and cask tie downs Florida P&L spent resin loose and improperly assembled Ratchet 5 Georgia Power trash and resin 19 mr/hr at 6 feet violates DOT reculations Iowa Electric resin improper cask fcotings Jersey Central radwaste in concrete free water in cask i
Jersey Central solidified filters loose tie down chains and load binders,
chains worn and improperly fastened Jersey Central contaminated material free water in cask and equipment Jersey Central solidified filter contaminated cask sludge Millstone Power resin missing bolts on cask lid VEPCO dry solid waste free liquid in drum Institutional Shipper Type of Waste Problem Atomic disposal scintillation, improper fastening of lids animal Interex scintillation, liquid in single wall drums w/no animal absorbent, unpreserved carcasses Interex scintillation, liquid in single wall drum w/no
.\\-
animal absorbent, unpreserved carcasses Monsanto institutional contaminated trailer Research
~
Radiac institutional improper packaging, poor paperwork Research Radiac scintillation, inadequate bracing, leaking and mislabeled Research animal drums
' TABLE A con't
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1 Industrial Shipper Type of Waste Problem General Electric Depleted Uranium Mislabeled drums, no placards, inadequate sideboards and bracing N&L Industries Depleted uranium contaminated trailer Nuclear metals Depleted uranium improper loading, contaminated trailer United Nuclear U235 solid contaminated trailer Military Shipper Type of Waste Problem
(
Redstone Arsenal Electron tube Not labeled IAW 49CFR172.403 Tinker AFB Tube assembly Improper label for 30 mr/hr U.S. Anny Needles, syringes Improper drums, loose top on drum serum bottles single well drum w/no absorbent
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l l
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R.D. SMITH DEPOSITION 8/7/79 EXHIBIT 2, page 6 of 7
TABLE B:
TABULATION OF PROBLEMS BY TYPE OF SHlPMENT E.E
?
obi m
- C =
E
-5"n s
3 a
Ebd3 5
i 20
%;3%
E m
u
$a t &5
- 2
- Mi%
E?
ETb ib o 5 u k *J e3 OS 20 : SE US 25; 3; 5=2
@ % Sl ".x f,2 s22 82 lug 0f E S 8.' Z o Ef $!
Shipment a~ m =
w-zu mm ov
='cc z c.
v~
Power Plant Dewater (spent) 12 7
/ 5 2
2 1-2 resin Solidified waste 11 7
2 1
1 Evaporator 2
0 1
1 bottoms Solid dry 5
1 3
1 1
wasto
,t
' TOTAL 30 15 11 3
3 2
5 Ir- *.i tutio nal
(
Scintillation and animal 6
2 3
2 2
2 1
1 TOTAL 6
2 3
2 2
2 1
1 Industrial Deoleted U 4
1 2
3
= TOTAL 4
1 2
3 Military Electron tubes 2
2 1
- Needles,
1 1
1
' syrinces
! OTAL 3
3 1
1 T
i
- T0 rnt SH8FMENTS 43
' T0"I.
. JBLEMS 63 20 14 3
3 2
4 3
5 9
7,of each type of problem 32 22 5
5 3
6 5
18' 14 R.D. SMITH DEPOSITION 8/7/79 EXHIBIT 2, page 7 cf 7
e
'a fe July 10, 1979 e
The Honorable Joseph Bendri Chairman Nuclear Regulatory Commission Washington, D. C.
Dear Mr. Hendri:
This letter will serve to point out the serious and repeated disregard for existing rules governing the shipmenet of co=mercia11y-generated low level nuclear wastes, and the total lack of corrective measures by the Nuclear Regulatory Commission.
Accordingly, the undersigned governors, representing the only states with depositories of low level nuclear waste, hereby require that the Nuclear Regulatory Commission and the Department of Transportation develop a detailed plan to upgrade inspection and enforcement of the rules for proper packaging and ship =ent of waste materials in order to
(',
ensure the safety of the citizens of the nation.
It is further required that such plan be delivered to the respective states by August 1, 1979.
The plan must include the following components:
1.
The dispatch of a trained team of inspectors to perform regular site inspections of both the source generators and the collectors of nuclear waste.
These inspections must include the opening of. containers.
2.
The consistent and uncompromising enforcement of sanctions imposed whenever violations are discovered.
3.
The submission of monthly reports to the three respective states detailing the activitics of the team, including the number, the location and the findings of the team.
i 4
The issuance of a joint announcement by the NRC and the DOT to all source generators of nuclear waste nationwide containing details of the new plan.
Such issuance will guarantee maximum i= pact.
5.
The plan must be imple=ented by September 1, 1979.
,..(
We further urge the timely implementation of a national nuclear waste management program that will include a formula for regional dis-tribution of low level nuclear waste at various waste management sites.
s R.D. SMITH DEPOSITION S/7/79 '
EXHIBIT 3, page 1 of 2
- Mr. Joseph Handri July 10, 1979 Pa:;e Tt.o l'
Ce consider the problem of low level nuclear waste to be of critical importance to our respective states and have determined that this action is needed to protect the health and safety of our citizens.
Sincer
.y, f,f
/
ixy Lee Ray Governor of Wash ngton s
e d.
92.
Richard b. Riley
)
Governor of South Carolina
- ~
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,g-e
-\\,-
^N Robert List Governor of Nevada ec:
Members of the National Governors Association All Members of Congress 1
.(
R.D. SMITH DEPOSITION S/7/79 EXHIBIT 3, page 2~of 2
[-[hy [k UNITED STATES g
g NUCLEAR REGULATORY COMMISSION j
.E WASHINGTON, D. C. 2L %55 g/
JUl-17 1979
~
p. j ^
r / {/,
ws MEMORANDUM 10:
John B. Martin, Director Division of Waste Management jA FROM:
R. Dale Smith, Chief V /./
Low-Level Waste Licensing Branch 6(
SUBJECT:
TRIP REPORT:
DISPOSAL SITE VISIT AND MEETINGS WITH STATE OF WASHINGTON OFFICIALS Dates and Places of Trip / Meetings:
June 11, 1979:
Visit to low-level waste (LLW) disposal site operated by the Nuclear Engineering Company (NECO) and located in the center of the Hanford Reservation.
June 11, 1979:
Visit to' 200-E and 200-W areas of the Hanford Reservation.
June 12, 1979':
Meeting with State officials in Olympia, Washington.
June 12,1979:
Meeting with State Radiation Control Unit (RCU), State Department of Social and Health Services, in Olympia, Washington.
Purcoses of Trio /Meetinas:
1.
Visit the NECO-operated disposal site on the Hanford Reservation.
2.
View DOE waste management activities in 200-E and 200-W areas of the Hanford Reservation.
3.
Discuss with State officials transuranic (TRU) waste disposal, waste from the Three Mile Island (TMI) nuclear plant, the site closure and stabiliation plan for the NECO site, and other issues related to renewal of the State and NRC disposal licenses.
Attendees:
R. D. Smith, NRC Robert Will, RCU Supervisor G. W. Roles, NRC Lee Gronemeyer, RCU Nancy Kirner, RCU Also attending:
June 11 visit to NECO site:
Vern Apple, NECO site manager Robert Phalen, NECO site radiation control officer June 11 visit to DOE facilities:
s Ron Gerton, Chief, Operational Waste Management Branch Richland Operations Office, DOE.
R.D. SMITH DEPOSITION S/7/79 EXHIBIT 4, page 1 of 5
JUI.17 g3 John B. Martin 2
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09 June 12 meeting with State officials:
Jack Wood, Director, Washington State Energy Office (WSED)
Rav Dinsmore, WSEO i.arry Bradley, Office of the Governor Fred Adair, staff, State House of Representatives, Energy and Utilities Committee Terry Frazee, RCU June 12 meeting with RCU:
Terry Frazee, RCU Summary:
NECO Site Visit:
During the June 11 visit to the NECO-operated LLW disposal facility, tne three stage treatment system currently being constructed for decontaminating the TMI nuclear plant was outlined to State and NECO personnel.
It was pointed out that the treatment system would generate contaminated resin wastes which, when packaged f.or shipment, would have surface radi tion levels in the range.of from 30 to 2500 r/hr.
Mr. Apple did not indicat that the high' radiation levels would require significant changes in NECO' current procedures for handling and disposing of wastes having high surf 4ce radiation levels.
~
Wastes with high surface radiation levels are currently placd in burTal g
trenches by use of a crane.
The~ wastes are then covered with backfill.
Mr.
Apple also stated that NECO has an attachment to the site crane which NECO can use to further increase the distance between the crane operator and the waste.
Mr. Apple and the State personnel were also informed of the Low Level Waste Licensing Branch Technical Position being prepared on solidification of low
\\
level wastes.
This position will state that all reactor resin wastes should i
be combined into a solid matrix (e.g., cement).
All wastes shipped to a disposal site for burial shall be in a solid form containing no free-standing liquid.
It was noted that in order to comply with this position the waste l
treatment system being constructed at the TMI plant will require modification to include provisions for resin solidification.
This discussion was followed by a short look at the site and site activities.
State and NRC personnel were escorted by Mr. Apple.
Besides the site office and lunchroom (both located within a small trailer), structures on the site include a warehouse equipped with a loading dock, a workshop containing an employee change room, a water tank, and a gasoline pump.
A number of small hand-held fire extinguishers were conspicuously located around the site.
In one area of the site, a number of tanks are buried which were once used for
'(
solar evaporation of low-level contaminated waste liquids.
The evaporation facility is apparently presently only used for liquid storage.
The site also contains a small number of caissons which have been used for disposal of high-curie content waste.
In another area, the head from the Shippingport nuclear reactor is buried, s
l R.D. SMITH DEPOSITION S/7/79 EXHIBIT 4, page 2 of S l
M 17lE John B. Martin 3
Three of the five onsite burial trenches are filled and capped.
These three trenches are mounded, covered with a layer of gravel, and surrounded by a three-strand barbed wire fence.
The gravel layer on the trenches, however, was relatively thin with occasional bare patches.
Of the remaining two trenches, one is filled but not yet capped and the other is still operational.
l Both trenches are surrounded by a well posted, eight-foot-tall chain link fence topped by barbed wire.
An air monitor is located near the entrance to the active trench area and Mr. Apple stated that this monitor is in operation 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.
The burial site is located in an extremely sandy, sparcely vegetated, arid area with temperatures regularly exceeding 100 degrees.
Walls of trenches dug in the sandy soil tend to sluff inward and windblown sand drifts into the excavated trenches.
For these reasons, Mr. Apple stated that the usual prac-tice is to only excavate enough space in the operational trench for working purposes.
As the trench is filled at one end, the other end is excavated to provide disposal space.
Spoil excavated from the operational trench is temporarily piled on either side of the operational trench to be later used for back*:11., The wind was b' lowing at about 20 miles an hour (apparently a not infrequent occurrence) and the area in the immediate vicinity of the trench was extremely dusty.
Although the site personnel wore hard hats and wereequippedwithgoggles,noneofthesitepersonnelwerewearingprotective{
clothing such as coveralls or boot covers.
f Low-level waste in drums are frequently delivered to the site by common carrier.
Mr. Apple stated that a common practice is to unload the drums from the carrier at the loading dock located next to the site warehouse and, using a forklift, reload the drums onto a NECO-owned flatbed truck.
The flatbed truck is then driven the short distance to the area of the operational trench where the drums are hoisted into the trench using a sling operated by a crane.
Frequently, the NECO personnel were witnessed to stand on top of the waste drums in order to attaca Lae s ting locking collar t.o Lae wa:n.e urum ana Lo guice the crums being hoisted.
When it was noted that the site personnel unloading the waste did not seem to be using a survey meter, Mr. Apple stated that the waste drums had already been surveyed and that the radiological control technician--who was then operating the crane--had a survey meter with him.
The visiting party noted several large stee.1 bins marked "LSA Material" in storage near the trench.
Mr. Apple stated that these bins are from the Argonne National Laboratory.
Some of the bins, as well as several large wooden crates (containing fuel racks from the Trojan nuclear plant), were stacked at various locations within the burial trench.
It was NECO's practice to stack the bins and boxes to form a " dam" across the trench width.
The space in front of the
" dam" is then filled with waste drums.
Mr. Apple stated that the bins arranged in the waste trench can also be used to provide shielding from radiation
,A emitted from bich gamma content waste placed in the trench.
Several cardboard boxes containing wastes from universities and hospitals were also contained in the trench.
The visitinp party did not fill out radiological exposure forms nor were they s
issued dosimeters.
The State personnel brought their own film badges but the NRC personnel wore no radiological monitoring instruments for the entire time they were on the site.
R.D. SMITH DEPOSITION S/~/79 EXHIBIT 4, page 3 of 5
l l
~
John B. Martin 4
M-17 E73 l
l DOE Site Visit.
Later in the day on June 11, the NRC and State personnel were met by Mr. Ron Gerton of the DOE Richland Operations Office and taken for a short tour of the 200-E and 200-W areas.
Of interest were the old process l
buildings, the new double-walled waste storage tanks under construction, the TRU solid waste storage pads, and the solid waste disposal trenches.
It was noticed that there seemed to be much less sand blowing from the DOE trench areas then was blowing from the NECO trench area.
Mr. Gerton stated that in the vicinity of the DOE trench area, the sandy soil is treated with an inert chemical substance to reduce blowing dust.
In another difference between NECO and DOE burial practice, Mr. Gerton stated that 00E generally placed from 8 to 10 feet of cover over the waste as compared with NECO's practice of three to five feet of cover.
Meetina with State Officials.
During the meeting on June 12 with State officials, there was general agreement that burial of TRU waste at the Richland facility should be discontinued.
State personnel expressed their intention to shortly announce a restriction on disposal of TRU waste in concentrations greater than 10 nanocuries per gram of waste material.
This restriction would be imposed on the basis of th'e State's position as site landlord.
NRC staff agreed to supply some background information on Federal government activities (e.g., proposed 1974 AEC TRU rule, IRG Report on TRU waste disposal).
After the announcement of the restriction on TRU burial, the State and NRC disposal licenses would be amended to comply with the restriction.
l
(
The general opinion was expressed that DOE would not otherwise make a definite commitment to accept commercial TRU waste for disposal.
It was pointed out that much, if not most, of the TRU waste now being shipped to the Richland site results either directly from ongoing DOE-financed study programs or from decontaminating research facilities that previously performed work for DOE.
Another person noted that ECO's business at the Richland site had recently increased (mainly due to restrictions on burial of waste at the Barnwell, S.C.
site) and that the loss of the TRU business would not be an insurmountable hardship on NECO.
State officials also emphasized the importance of keeping the State informed regarding shipment of wastes from the TMI Power Plant.
State personnel repeatedly requested advance notice of shipments of any wastes from the faci-lity.
In connection with this request, the State personnel noted the indepen-dent truck drivers' strike that has disrupted truck traffic in several States.
Advance notice of State agencies could help to prevent any potential problems with shipping the TMI waste that could arise from the truck drivers' strike.
NRC staff stated that they would reiterate to NRC personnel in the Office of State Programs and at the TMI site the need to keep the States informed.
The forthcoming Branch Technical Position on waste solidification was also k
briefly discussed.
This discussion changed focus to the matter of disposal of materials containing very low concentrations of radioactive material.
State personnel discussed the disposal of Wah Chang sands on the Richland site and stated that they felt that burial sites were a national resource.
State personnel stated that they felt the site shouldn't be needlessly useci for s
materials with very low concentrations of radioactivity.
A lower limit for material requiring disposal in burial sites is needed.
R.D. SMITH DEPOSITION 8/7/79 EXHIBIT 4, page 4 of 5
(
John B. M2rtin 5
A'l 1 7 E 3 The representative from the Governor's office also discussed the upcoming Governors' Conference to be held on July 21.
As issues such as transportation of TMI waste would be discussed at the meeting, he suggested that NRC personnel be in attendence to monitor the meeting.
Meetino with RCU.
Following the June 12 meeting discussed above, a short meeting was held with personnel from the Radiation Control Unit (Department of Social and Health Services) to discuss the renewal applications.
State person-nel were asked about their environmental review process.
The State personnel replied that the State equivalent of NEPA legislation--the State Environmental Policy Act (SEPA)--specifically exempted renewals of existing licentes from the requirement of preparing an environmental statement.
NRC personnel stated that as long as disposal of plutonium was removed from the SNM application, they expected that renewal of the NRC license could be accomplished by preparing a negative declaration as provided for in 10 CFR Part 51.
However, NRC personnel stated that they had a number of questions and comments on NECO's application and site procedures and that NECO needed to completely and favorably respond to these questions and comments before a license renewal could be issued.
In this matter, NRC' personnel stated that site procedure; needed to be improved to minimize exposures to radiation workers at the burial site.
The need for coordination during NRC and State reviews of the respective renewal applications was discussed.
It was agreed that,NRC and the State would issue joint comments on the applications.
NRC personnel would redraft a
(
list of questions and' comments on the application and forward the questions and comments to the State for review.
The State anc' iRC would then jointly issue the questions and comments to NECO.
The draft site closure and stabilization plan that the State was negotiating with NECO was also discussed.
Although a few minor points were noted on the plan, NRC personnel felt that for the most part, the plan met the conditions of the Branch Technical Position on closure and stabilization.
State personnel stated that the plan would be shortly redrafted based on NRC comments and forwarded to NECO.
It is believed that the closure plan can be finalized in a j
short time period.
Other issues relating to the site applications--such as environmental surveil-1 lance and monitoring and site burial practices--were also discussed.
State personnel provided d C with a document which discusses the confirmatory measure-ments and surveillance activities performed by the State Health Department.
W A.
R. Dale Smith, Chief 7A Low-Level Waste Licensing Branch 6
R.D. SMITH DEPOSITION S/7/79 EXHIBIT 4, page 5 of 5
W AsMN CTO N. D.C. 20!!:
RSmith
~ t *G.R J!
. re:
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July 18, 1979
.jDO6343 i
kautrcks
.c =ica en Txt
- va Leins cm.amt :.n VStello
...enton nu
...sya n
.uinogue HShapar
_.s ne..ncnorable D xy Lee Ray SECY-79-2064 Gcverner cf Washington
.Cunninnham n
State Cap 1:o1 Olp. pia, Washingt:n 95504 vear Governor Ray:
Thank ycu for your letter of July 10, 1979, with Governers Riley a:1d Lis: cor.cerning the transportation and disposal of low-level nuclear-waste.
We are pleased to see that States with similar concerns have ccme ecether to address :.nem in a unirled and effective manner.
.,e
.n
~
believe that your joint letter represents a needed action.
Your ;mosition is clear to the.:ederal regulatory agencies involved and should also, be c'. ear c icw-levei waste genera: Ors and shippers.
It facilita es he N:.C'.s ability to deal with these concerns collectively and ~ serves as a venici.e :nrou;n wnicr. the Nr,.C can work with the.,tates in an errec:ive a..d cecperative way.
We'want to work with the States on a uniftad basis c bring about some cf the regula: cry improvements which are outif:ned beicw.
(~
Our a'0;mented pr'ograrto bring about improvements in the packaging, transp:rt and disposal of icw-level nuclear wastes includes the forrr
- ctn:s listed in your le ter in addition to others.
The steps cailled
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and D
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. i per ccm suen inspections on a pe-.ccic casis.
.ne createst e :nasis on cackace ma.geup will be c...arected a
waste generaters.
We suggest that these inspect:rs be augment.e.d by
- ..e A;reemen-5:1 e inspec:crs where appr:priate.
'n's will work wi:h the Agree ent Sta es to arrange for these inspections and will keep you
'. _fcr e'.cf cur progress and of steps tha you migh take to help us in
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R.D. SMITH DEPOSITION S/7/79 3
EXHIBIT 6, page 1 of 9 g.
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The censistent end uncemeromisinc enforce,ent of sanct-icns imcosed whenever viciatiens are ciscoverec.
Enfercement a:tien will be taken, in conjunction with 00T and '.he Agreement 51:ss, where violations of packaging and transportatien regulations are
,,e censider tn..is a necessa.rv ingredien: to cur inspecticn and Teunc.
n enicreement program.
ine sub=1ssion ci renthlv re:crts to tn.e t.nree resoect.zve states de:aliine :ne ac:1v1:1es oT :ne :eam, inesucine :ne nummer anc locations cf inroections anc tne fincines of tne team.
All reports of inspection and enforcement will be made pub'2ic as they
'ce: cme available.
They will be forsarded to the affected and interested
~
States by our Office of State Programs.
ne... and the
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to ir.e issuance 07 a 3cint announcement bv..
n.u.
s a.1 s:urce cenerators oT. nuclear waste na:ionwice containiric ce ails c' :ne new cian.
Sucn issuance will cuarantee maximum 1msac:.
A. announ:ement is being prepared fer issuance by Septembe:.1,1979.
It will be cocrdinated with DOT.
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1-in; about i.prevements.
Key c this effort is a rule cha:r.c= which the staff is :reparir.; fcr Commissien consideration which would E.lcw NRC to
- i s:-iy enf: ce DOT regulations a liRC licenses si es and -thus significantly
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-r S :n a rule change wculd be supplemented with new programs -for -inspecting trans cr activities and new enfcrcemen: criteria for vioim. tion.s of li?C-
.. ; sni::ine reccia:1cns.
,Je are a.lso exciorine wavs to pr=vid.e trainanc.
=..: packaging 1. crma:1cn Tor waste generator:.
inese reg:.::ato.ry actions a e : sin: su::lemented.:v inves:1ca:1ons teacine a im:rovec :esien c.
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- c. an: o ner low spec 171c activity material packages, wr.. h; constitute
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- ..s bulk cf packages shipped to low-level burial grounds.
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R.D. SMITH DEPOSITION 8/7/79 EXHIBIT 6, page 2 of 9 m
- ', ine F.:norable Dixy Lce Ray '
discesal cf low-level waste and we expect that such an active pregram ceuld serve to facilitate the development of regional site:.s.
The absence of s.uch criteria has been noted as a major impediment to t6e development of li:ensed sites.
Draf: regulations will.be available fc-public cc- :er.: 1 ate next year.
We intend to explore ways by whic. NRC can play an active : cle in the er.:curacement of the principal waste generators to assume responsibility fer providinc means 'to dispose of their nuclear wastes.
For example, we are investicating alternative me-heds for the disposal.cf liquid scintillation viais and will work with the medical research establishme.n
.to offer them licensable op: ens or safe disposal of this. kind cf weaste.
Again, we believe the States of South Carolina, Nevada, and Washington ha"e taken an important step in dealing with problems of waste transport and disposal en a unified basis.
It will allow us to w:rk to5 ether in an effe::ive and cooperative manner.
Sincerely, f 1
L N
o-..,,h M. Hendrie Chai rman c:: Jhs Honorable Richard W. Riley g
Governer of South Carolina TheHencrableRoberiList Governor of Nevada
.s
(
R.D. SMITH DEPOSITION 8/7/79 EXHIBIT 6, page 3 of 9
%[:~.R f July 18,1979
.emer: m chA! A W.AN s..e nen:rab.e e.obert List i
i G:vernor of Nevada e..,.. e,.,.1.o 1
.~
Carsen City, Nevada 89710
Dear Governor List:
Thank you for your letter of July 10, 1979, with Gcvernors Ray and R'iley
- n:erning the transportation and disposal of icw-level nuclear waste.
We are cleased to see that States with sicilar c:ncerns have cc:rre together
- Ecdress them in a unified and effective manner.
We believe that your
- 1n: letter represents a needed action.
Your p:31:1cn is clear to ::he
- ederal regulatory agencies involved and should also be clear to low--
isvel waste generators and shippers.
It Tac 1:1tates tne.. C.s ab111t.y im
- ceal with these concerns collectively and serves as a vehicle thre) ugh whi:n the NRC can work with she States in an effe:tive and' cooperativ:e way. %'s wan to work with the States on a unified basis.c bring abe.u:
s:me of the regulatory improvements which are cutiined beicw.
trans: ort and c..
. ram to brinc. about impr:vements in the s. ackac.inc.,
~ ur au.:mented proc sposal or. low. level nuclear wastes in:1udes tn.
e our
(
- ints 11sted in your letter in add 1
- 1on to o-hers.
.he steps calleo.
i x
f:r in your letter are ad, dressed as fo11cws:
1.
T.e disca:ch cf a trained tea = cf insrect:rs
- serfor-. re:ular
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inese insoections mus: inciuce :ne c:enir.: of cor. a.ners.
i
. a ned a,. C and Du..
inspectors wil.l per e m such inspecticr.s on a
- sriedic basis.
The greatest emphasis en packace makeup will be dire:ted a
waste generators.
We suc.c.est that these inspe:: ors be augmented b..v l
- ne;reemen: Sta e inspectors where appr:priate.
We will work with the
.-;ree.ent States o arrange Tor tn.ese inspections and wil.. Keep yo.u irf :-.es of our progress and of steps that you might Eke o help us in
- .:i=:in; such arrangements.
Selected centainers will be opened
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iter #:r :;enin;, jr.s:sc:icn, and repackaging.
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l R.D. SMITH DEPOSITION 8/7/19
~
l EXHIBIT 6, page 4 of 9
n n=ra::e ebert Lis:..
. no..
n l
ine c:nsisten: and uncemsromisine enforcement o. san =,. ens 7moosed c
whenever viola:icns a're ciscovereo.
Enforcement a: tion will be taken, in c:njunction with 00T and the Agreement S.ates, where violations of packaging and transper:ation regulaticr.s are f:und.
We consider this a necessary ingredient to our inspection and enforcement program.
3.
The submission of renthly recorts to the three respective states detaiiing :ne activities of :ne team, includino :ne numoer and l ocations cf insoections anc tne fincines of :ne team.
All reports of inspection and enforcement will be made public as they beccme available.
They will be forwarded to the affected and interested S a:es by our Office of State Programs.
4.
T'.e issuance of a joint announcement by the NRC and the DOT to a.: s:urcs cenerators o nuclear waste nationwice con:aln7nc catalls T :ne neve :ian.
Sucn issuance will cuarantee maximum immac.
An announ:ement is' being crepared for issuance by September 1,1979.
It wili be c:crdinated with DOT.
5.
The slan must be imclemented by Se:tember 1,1979.
With the exception of Item 4, which will be comple.ted -by 54ptember 1, r
ail attiv1:les are under way.
1 In addi icn to these actions, the Cont.ission is taking f::rther steps to b-ing about improvements.
Key to this effort is a rule change which the staff is :reparing for Cc :.ission consideration which wculd allow NRC ::
- '-e:-ly inf:rce DGT re:uiations at NRC licensee sites and thus significantly
.:;ra:e i..spe::icn and enfor:ement actions in waste packaging e.md trar. spor ati:n.
Su:h a rule c.ance would be supplemented with new procrs=s for i'nspecting
- ans; r: ac-ivi-ies and new enf:rcement criteria for viciations cf NRC-
- T shipping regulations.
We are also exploring ways t: provide training a.-d packagin-information for waste generators.
These regulat:ry actions 1
a.e beir.; su;;1ecanted by investigations leading to improved design of Type A and c.ner low specific activity material packages, which constitute tne buik cf packages shipped to low-level burial grouncs.
- .r ".e: sr aisc centiens the timely implementa:icn cf a national wae =
i-..,.. enr~ has su.,.,.,..,.....=..n.., r.._... _, _ e..s
.. h e-
._,...____....g_....
...:...=.......
.- ert;en:y :.sv-:e<< Gr up tha: the Department of Energy should deveicp a j
.a-i:raci:s :r: gram aimed at esta:iisning re;ienai capacity for cis:: sal
....,.......:... 4.v=. was.=.
We. ha va.. =.. a.' v =.
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- 5e=1:; a :ct:renensive se: Of regula icns, guides and standards f:r the i
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R.D. SMITH DEPOSITION S/7/79 EXHIBIT 6, page 5 of 9
...c..-nursoie v.ccert List.
disp: sal of low-level waste and we expect that such an active program c:uld serve to fa:ilitate the development cf regional sites.
The absence of l'icensed sites.cf such criteria ha.s been noted as a :r.ajor impediment to the d Draft regulations will be available for public
- ment 1 ate nex: year.
We intend to explcre ways by which NRC can play an active role in the a
for providing means to dispose of their nuclear wastes. encourage vials and will work with the medical research establishmen ror exa.mple, we them licensable options for safe disposal of this kind of waste.
Again, we belie */e the States of S:uth Carolina, Neva and disposal on a unified basis.
an effective and c: operative manner.It will allow us to werk together in Sin:erely, n 4 *-t:a1 sis =ea 57 i
acse w);,se:ar.e r-doseph H. Hendrie Chair: an The Honorable Dixy Lee Ray
- c:
(
GTv'ernor cf Washirigten The Hencrable Richard W. Piley Governor Of 50 th Carolina i
i s
R.D. SMITH DEPOSITION S/7/79 EXHIBIT 6, page 6 of 9
(+,P_#, j p
wAssmcion. o.:.:esss
. ' y-
,x j July 18,1979
- om:s on Tur Cu!RMAW The Honorable Richard W. Riley Governor of South Carolina State House Colu=bia, South Carolina 29211
Dear Governor Riley:
Thank you for your letter of July 10, 1979, with Governors: Ray and List con:erning the transportation and disposal of low-level nu clear waste.
We are pleased to see that States with similar concerns ha-ve come together to address them in a unified and effective manner. We bel-ieve that your
.icint letter represents a needed action.
Your position is clear to the Federal regulatory agencies involved and should also be cleear to low-level waste generators and shippers.
It facilitates the WRC's ability to deal with these concerns colle :ively and serves as a veehicle through wnich the NRC can work with the States in an effective and cooperative way.
We want to work with the States on a unified basis ::o bring about s:ce of the regulatory improvements which are outlined bellow.
Our augmented program to bring about improvements in the p>ackaging, trintport and d.isposal of low-level nuclear wastes.includets the four
(
- cinti listed in youF" letter in addition to others. The s teps called for in your letter are addressed as follows
i.
The discatch of a trained team of instectors to perfor m recular site insoections of oc:n tne source cenerators anc the coi iectors of
- iear waste.
Tnese insoec lons cust in:iuce :ne oceninc of containers.
Trained NRC and DDT inspectors will perfo-m such inspectic ns on a
- eriodi basis.
The greatest emphasis on package makeup w-ill be directed a
waste generators.
We suggest tna; these irispectors be augmented by the Agreement State inspectors where appropriate.
We will, work with the A;reement States to arrange for these inspections and will keep you informed of our progress and of steps that you might take to help us in completing such arrangements.
Selected containers will bet opened
- uring the course of inspection.
I should point out that seme waste
- lie: :rs are not equipped to have packages Opened at their facilities
.zi:ncu endangering personnel or risking contamination of fa:ilities and
..s'.- licenses :rchibit such activities.
In these cases, we will need
- i:en:ify cualified facilities o which the sele::ed :or; tainers may be ar er. f:r c:ening, inspection, and repackaging.
R.D. SMITH DEPOSITION S/7/79 EXHIBIT 6, page 7 of 9
The h:r.:rable ?.ichard 'd. Riley Ouly '18,1979 2.
He censistent and uncomoromisine enforcement of sanct. ions imoosed henever viciations are ciscoverec.
Enfor:emen: action will be taken, in conjunction with DOT and the Agreement States, wnere viciations of packaging and transportation regulations are founc.
We c:nsider this a necessary ingredient :.o our inspection and enfor:ecent program.
3.
Be submission of rmnthly recor.ts to the three respect.-ive states detatiing :ne ac:1v1:1es of :ne team. inciucing tne numser anc Iccations cf insoections anc :ne findings of tne team.
All reports cf inspec' tion and enforcement will be made public as they becore available.
They will be forwarded to the affected and interested Sta:ss my our Cffice of State Programs.
4 79e issuance of a 'oin: announcement by the NRC and the DOT to all s:urce cenerators cf nuciear waste nationwice conta1n-1; cetails cf tre nea c'.an.
Suen 1ssuance will cuarantee maximum imoact.
An ar..cuncement is being srepared for issuance by September 1,1979.
It will se c:cr:inated wi-Ji DOT.
5.
T.e :lan must be imslemented by Sectember 1.1979.
With the exception of Item 4, which will be completed by September 1,
(
all activities 'are under way.
In acti:icr..o these actions, the Commission is taking further steps to bring accu imprevemen s.
Key :: tnis effort is a rule change which the staff is cre;arir.; fer Cc=.ission consideration which wculd allow NRC to ci-ec:1 er.f:rce JCT re;'.lations at NRC licensee sites and :nus significantly
.:;-a:e i.s:e::ica ar.d er.fer:eser.: actions in waste packaging and transportation.
Sacn a rule enange wculd be suppiemented with new programs for inspecting trans:or ac-ivities and new enforcement criteria for viciations of NRC-i CCT s.i; ping regulatier.s.
We are also exploring ways te provide training and packaging infer aticr. for waste generators.
These regulatory actions are bein; su;ple: ented by investigations leading to improved design of Type A and c:.her icw specific activity material packages, which constitute the bulk of packages shipped to low-level burial grounds.
l
' :u
's-er als: centiens :ne ti. ely implementation cf a n ationai waste
.ar.a;a er. pr:g ram.
The *,'p.C has supported tne reccmmencations of the l
l-era;e--. Fevie, 3r:.; -ha: :ne De:ar ment cf Energy sac uid develop a a-i:- ':e : :gra aimed a esta:iisning regional capaci y fer disposal
- f Ic
.e/el -adi a::ite sas e.
We have an active progran under.,ay to
- ecei:: a ::r:rerer. site se: :f regulaticns, guides and s.ar.darcs for :ne R.D. SMITH DEPOSITION 8/7/79 EXHIBIT 6, page 8 of 9
f Tno Hencra:le Ri:h:rd 'a'. Riley July 18,1979 disp: sal cf low-level waste and we expect that su:h an active program
- uld se ve to facilitate the development of regional sites.
The absence
- f s :n :riteria has been noted as a major imeediment to the develcpment.
- f license: sites.
Draft regula-ions will be available for public c:= men:.a:e next year.
We intend :.o explore ways by which tiRC can play an active rcle in the encouragenent of the principal waste generators to assume responsibility f:r providing means to dispose of their nuclear wastes.
For example, we are investigating alternative methods for the disposal of liquid scintillation vials and w'ill work with the medical research establishment to offer them lice: sable cations for safe disposal of this kind of waste.
Again, we believe the Sta es of South Carolina, tievada, and Washington nave take. an important step in dealing with problems of waste transport art disoc:a'. en a unified basis.
It will allow us o work together in a
effe::ive and : cop;cative manner.
Sincerely, [
3
~
.'--- h M. Hendrie Chairman 5e honorabhe Dixy" Lee Ray I
~
G0ver.0 of Washingt:n ins h:n:rable ?.:bert List G:ver.:
- f !svaca R.D. SMITH DEPOSITION 8/7/79 EXHIBIT 6, page 9 of 9
- ~
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M E
JUN 1819 E5
'E
.g MEMORANDUM FOR: Harold R. Denton, Director Office of Nuclear Reactor Regulation E
FROM:
William J. Dircks, Director i
Office of Nuclear Material Safety and Safeguards j
E
SUBJECT:
THREE MILE ISLAND (TMI)
M
~
E
'M Enclosed is the report of a trip to TMI by NMSS representatives.to review 3
planning for processing of TMI-2 facility wastes.
Specific emphasis was i
placed on waste disposal and transportation.
5,
~
,u; 1
~
The main issue coming out of this' trip is 'whether the waste ~ resulting from Ti decontaminating the contaminated water should be shipped for disposal in j
the fem of dewatered spent demineralizer resins and filter medium as is E
presently planned by Metropolitan Edison, or in the fem of a solid matrix M
(formed by mixing the spent resins and filter medium with a suitable binding M
agent, such as concrete).
The latter approach would be consistent with the 5
-Effluent Treatment Systems Branch, Technical position, ETSB 11-3 dated EM Noves er 24, 1975._ As you are aware NMSS fully supports the latter approach M
from both transportation and disposal considerations.
9 In view of the decision during the Chairman's staff meeting on June 12, 1979 5
that the latter approach of converting the waste to a solid matrix should be y
pursued, please have the person who will take the lead for NRR contact
?M R. Dale Smith, Chief, Low-Level Waste Licensing Branch, for any support
]j?-2 required from NMSS.
==
=
4 gy JPM.
M tSL.'P GE
=.
st
- William J. Dircks, Director h5
'.s Office of Nuclear Material Safety y
and Safeguards s.
a=-
Enclosure:
Trip Report
.?'T';.~.i...l,;).]gi.;.,!-
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SMITH DEP6SITION S'/1/7S:. ~
~
EXHI3IT 9, p a ge 1 6 f 4 ' C
'dWi 17. C*:
!ma 3
i ME"0RNiDUM FOR:
John B. Martin,. Director Division of Waste Management' i
Richard E. Cunningham, Director Division of Fuel Cycle and Material Safety L
l.
FROM:
Robert E. Browning, Deputy Director l'
Division of Waste Management i
r e
Charles E. MacDonald, Chief Transportation Branch i
Division of Fuel Cycle and Material Safety SUEJECT:
TRIP REPORT TO TliREE MILE ISLAtiD (TMI) i
$==
j.
Cate of Trip:
June 5, 1979 I
Place of Trip:
Three Mile Island,-Middletown, Pennsylvania
..:rpose:
To review waste disposal and transportation aspects
(
at Three Mile Island
~
~
Attendces:
?! MSS-!M -- R. Dale Smith, Robert E. Brov.ning. Timothy Johnson flMSS-FC -- Charles MacDonald, Charles Marotta
-arsons Contacted:
fiRR - John Collins and Rick Heller t
Su:=ary:
Representatives from !! MSS visited TMI on June 5,1979 to discuss with HRR representatives, Metrepolitan Edison's plar.s for processing the WI-2 facility wastes.
Specific emph~ asis was pla'ced on waste disposal and transportation.
Tne fiRR representatives noted that.their on-site operation at TMI involved procedure reviews with their attention directed i
to health, safety and protection of the environment.
These reviews are the same as what would normally be dona by ETSB in Bethesda..
Seven (7) liners of filter medium and resin from orodominantly I
Unit 1 processing and 40u steel 55 gallon dru: s of compacted low-level waste.was prepared for shipment.
This waste was
~
stated to be typical of any other utility waste and would be shioced accordinoly.
...E*-
A1:.. shipments..lapving"the..s&te..are.4nspocte+.by I.f.E.~..F0r
. ~. " - " -
...................TK..4. 2....w..a..s..t..e..s..,.. 5..t.4.te.. P r.o..c.g.ra.s i l
h 5 n tified. w!'o in turn notifies ig".o. p"m"e'n't"s'"th'rou"g"n"*t'n"e"1"r" 3"t"a"te"s
,DE 88 88 E M-
., cte representa ;1ve"s or "p"en'cl
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R.D. SMITH DEPOQITION 8/7/79 N;
E'5NIBIT 9,' page 2 of a
- s.
~
Jb l
l i
With respect to TMI-2 waste, planning is proceeding in three separate steps:
a) decontamination of approximately 200,000 gallons of contaminated water frgthe auxiliary building (the limiting radionuc which has less than 40 pCi/ml Cs b) decentamination of apprcximately 300,000 gallons of water in the primary containment which is contaminated to a higher but not well c.,aracterized level; and c) care removal.
Only the first step !s well defined at this time. Metrocolitan Edisen is seeking contractors for 'rocessing equipment for handling L
the waste in the containment. Bechtil Corp. has been selected j.
to study core removal. -
With regard to the planned first step to clean-up the 200,000 gallons of water from'the auxiliary building, a system (Epicor-II) has been designed and installed in a facility originally designed for chemical cleaning of the steam generators.
This system is now being checked out but will not be made operational until completion of an environmental assessment and delivery of a shield bell for handling of the processing units when they are depleted.
The shield bell will be delivered in approximately five weeks.
The system for processing the contaminated water involves three 2". "
processing units in series. The processing units are:
- 1) an initial prefilter using silver impregnated charcoal; j
- 2) a demineralizer; and 3) a polisher. The prefilter is a 7
4' diametcr by 4' high carbon steel cylinder. The deminerali:er i's al so 4 ' by 4 '. The polisher is G' diameter by 6' high.
These units will be operated until activity on contact reaches 2,500 r/h,
- t..
400 r'/h and frem 20 to 30 r/h, respectively, or until the medium l
loses its capability. These units when depleted and when dewatered r
will be removed and replaced with identical new units.
The units I*
will be stored temporarily on site in an interim carthern embankment and subsequently in an engineered storage facility. All units are planned to be shipped to Richland for burial.
Present plans call i
for the 4' by 4' units to be shipped in accident resistant packaging (Type B) and the 6' by 6' units to be shipped as 1.SA material'in Type A packaging.
Type B package designs are not available for i
shipment of the Type B wastes.
The NRR representatives requested l
prompt IEISS action on any requests for URC certification for Type B packaging for TMI wastes.
It was noted that Metropolitan Edison's plans for processing the j
]
waste are consistent with present practice followed in older plants I
but are not consistent with the Effluent Treatment Systems Branch i
(NRR) Technical Position ETSB.ll-3 which has resulted in new U!R plants installing capability to place all wastes in a solid immobile form prior to shipment off-site.
NRR has requested the utility to i
- t t - ~ w "."
l
- f :M :;&:f:bility and y
w..
-. :.. :...;;... = = =c.:
The fea i i
few ig
............q.sjn, g.s,,,occosed,,to,, je w,a,ter,,,n,,,res ns,Ti3 imobi' 3 fdm"ar reg
==*
a rred ~~----
n m ts er put:1ng the astes in a so
...........by ETSG-11-S crrdis.ussed --HRR-i odicated..that 4f-sol ?dif.icati.ca..............
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.- 8; t
is to be required, a decision should be made within one month to avoid delays in processing the 200,000 gallons of contaminated water from the auxiliary building.
The itRR representatives agreed to keep.T155 informed of progress and future plans as well'as the specific results of Metropolitan Edjsen's assessment of putting the wastes into a solid in:nobile form as required by ETSB 11-3 and tha results of a meeting to be held between the burial site operator (TIECO) and Metropolitan Edison.
~
/d Robert E. Browning. Deputy Director Division of Waste. Management
- =.
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Charles E. MacDonald, Chief Transportation Branch -
Division,of Fuel Cycle and Material Safety
, j,,
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d R.D. SMITH DEPOSITION 8/7/79 EXHIBIT 9, page 4 of 4