ML20003E485
| ML20003E485 | |
| Person / Time | |
|---|---|
| Site: | 02700039 |
| Issue date: | 03/27/1981 |
| From: | Hawkins E NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Conner T CONNER, MOORE & CORBER |
| References | |
| WMLL:3201.1, NUDOCS 8104030581 | |
| Download: ML20003E485 (2) | |
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DOCKET NO. 27-39 MAR 2 71931
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Dear Mr. Conner:
This is in reference to your February 10,1981 le er to Edward F. Hawkins.
'With the letter you transmitted U.S. Ecology's proposals for recompacting and recovering the trenches above the base of the existing cap at the Sheffield facility.
The proposed capping scheme, as presented, would not be acceptable to the staff.
Condition 8 addresses the need for trenches to be stabilized to minimize settlement of the trenches.
It also recognizes that there may be some amount of future settlement, and discusset the need for er rangements to be made with the State of Illinois for future corrective work.
The response by U.S. Ecology is deficient in that it does not present the technical bases for the proposal as to how it would minimize trench settlement.
In addition, there is insufficient detail presented to allow the staff to independently evaluate the proposal.
You also suggested that at the September 25, 1980 meeting the staff agreed to revise proposed site closure conditions.
In fact, the staff agreed to review site closure conditions to determine whether any revisions were warranted.
The staff duly noted the areas of conflict with respect to the conditions. Suggested change.= to the wording of several conditions were also noted.
(See NRC staff minutes of September 25, 1980 meeting with HECO.) At no time did. staff agree to revise the basic intent of any of the closure conditions, the implementation l
of which are necessary for the long term isolation of the waste buried at l
Sheffield. However, we are willing to discuss the need for and possible l
implementation of the conditions with U.S. Ecology and the State of illinois at i
any time.
At the September meeting, U.S. Ecology said it would send copies of engineering
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drawings and specifications of the chemical waste site isolation dike.
The staff would appreciate receiving this information as soon as possible to complete its assessment of the interrelationships of the chemical and nuclear wastes.
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I'AR 27 1931 Troy B. Conner, Jr. If you have any questions do not hesitate to contact staff counsel. Thank you for continued cooperation.
Sincerely, b
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Edward F. Hawkins, Acting Chief Low-Level k'aste Licensing Branch
Enclosure:
NRC Staff Minutes of Sept. 25, 1980 Meeting cc: Henry J. ticGurren, ELD 9
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NUCLEAR REGULATORY COMMISSION WASHWGTON, D. C.20$55
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\\ f C % /j NOV 2 21990 DOCKET N0.p-35 MEMORANDUM FOR:
R. Dale Smith, Chief Low-Level Waste Licensing Branch FROM:
Edward F. tswkins Low-Level Waste Licensing Branch
SUBJECT:
MINUTES OF SEPTEMBER 25, 1980 MEETING WITH NECO REPRESENTATIVES ON SHEFFIELD CLOSURE CONDITITIONS On September 25, 1980 an informal meeting was. held in the law offices of Connor, Moore & Corber in Washington, D. C. to discuss the details of the staff's Site Closure Conditions for Sheffield Low-Level Disposal Facility.
Attendees:
K. Dragonette, NRC T. Baer, NECO E. Hawkins, NRC T. Connor, Attorney for NECO R. Lessy, NRC C. Eason, NECO D. Siefken, NRC R. 3.ader, Attorney for NECO J. Shaffner, NRC G. Turi, NRC i
Su=ary of Agreements:
No formal acreements or comitments were rade.
NECO ano i RC are lookir.g into some of the ques.icns that were raised during tne meeting and may provide informally additi:nal details or clarifying irformation.
Detailed Minutes of Meeting Each of the following conditions as filed with the ASLB on July 17, 1930 was discussed to clarify the irtent and possible cethods of compliance.
(1) That all waste is buried in accordance with requirements of the Cennission and the license.
Issues discusud included the role of NRC's I&E efforts, the unbrella nature of the conditions and the avialability and magnitude of relevant NEC0 records.
That all structures, equipment and materials not to be transferred (2) to the custodial agency have been dismantled, decontaminated, if necessary, and disposed of.
Issues discussed included the need for coordination with the State on which b'uildings, equipment and materials should be transferred for use during long-term care.
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(3) That institutional arrangements have been made for long-tem custodial care by the State of Illinois; that there will be an orderly transition to Illinois; and 'that organizational and funding mechanisrn are in place.
Issues discussed include the need for assurance that institutional arrangements are currently in order, the need for assurance that final planning has taken place, and the historical connitments by the State.
(4) That gamma radiation from buried wastes does not increase background radiation on the site.
The absolutism of the words was discussed.
l (5) That the rate of release of r'adionuclides through ground and surface water pathways are at or belcw the levels set ferth in 10 CFR Part 20, Appendix B at the site boundary, at or below EPA dri~nking water limits at the nearest water supply, and a small fraction of the levels set for:n in 10 CFR Part 20, Appendix B through air pathways; and that studies have been conducted and techniques have been eroloyed to ensure maintenance of these rates for the period of custoidal care by the 5 ate of I
Issues discussed include the' exact value of "a small fraction of the levels" the difficulty of ensuring versus prcviding reasonable assurance, the need to evaluate the range of pctential values for r. acel parameters which could be expected to vary, and the need tc include up-to-date data in migrition models.
(6) That trench bottom elevations are abcve water table levels, taking into account the complete history of seastnal water table flu:tuations, and that conditions will be created to prevent cont'act between ground water and the buried waste.
Issues discussed include the elevation of the ground-water table above the bottom of Trench.18, the special waste contair.ers in the bottom of Trench 18, the need to assure that the final site closure design (e.g., contours, drainage channels) did not produce a rise in the ground-water table, and the meaning of "will be created" as to future NECO responsibilities, and the absoluteness of
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" prevent".
l (7) That all conditions that caused positive environmental samples in the past, including any evidence of unusual or unexpected rates or levels of radionuclide migration in or with ground water, are analyzed and corrected.
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NOV 121330 Issues discussed include a quantitative definition of " unusual or unexpected",
the need to compare observed and 'redicted migration estimates, the possibility that corrective measures may not ce needed in'all cases, and the action limits specified in the Sheffield license.
(8) That the trenches are stabilized such that. settlement of the trenches is reduced to minimal rates. That arrangements are made with the State of Illinois to ensure proper stabilization when anticipated future settlement occurs.
Issues discussed include the elusiveness cf the work " minimal" and the difficulty tnat NECO would have in ensuring that tne State of Illinois would stabilize the site.
HECO will consider some of the methods : hat could be used to minimize
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settlement and ensure stabilization and may provide information informally.
(9) That conditions for erosion, water infi~etration into trenches, loss of site or trench integrity due to su:h factors as ground water, surface water,'nd wind, are eliminated. This would require (1) the establishment a
of a proper surface drainage system t: -ecove rain water and snowmelt; (2) gradino of site to prevent si:pe #ailure and minimize infiltration; and (3) stabilization of surface by s.o-t-rooted vegetation, ground cover or riprap to prevent ~ercsi:n; ( ) or other sinilar and acceptable methods.
The awkward wording of this condition was discassed.
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(10)
That tne integrity of the racioteti.ve.;aste discosal site is not degraded by the chemical wastes and, if necessary, positive controls are instituted to assure this.
Issues discussed include the earthen barr'er wall between the chemical site and l
the low-level radioactive waste site and the absolutehes's of the words.
l "ECO will review existing documents and may provide available documents that summarize the design bases and details of the earthen barrier wall.
As-built drawings may be provided when they have been comoletely compiled.
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(11) That trench markers identifying :he size and exact location of each trench, and the materials buried thsrein, are in place, stable, and e
clearly and permanently marked.
Issues discussed include the use of the word exact", the legibility of the trench marker plates, and the fact that although trench locations are known l
within plus or minus 10 feet, the " exact" location of some of the trenches l
is not known.
That complete records of site maintenance and stabilization activities, (12) trench elevations and location, trench inventories and monitoring data for use during custo' dial care are compiled and transferred to the agency assuming custodial ca,'e.
No discussion.
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(13)
That a buffer zone surrounding the site to provide sufficient space to stabilize slopes, incorporate surface water management featu'res, and provide working space for unexpected mitigating measures in the future, is established and transferred to the custodial agency. The buffer zone shall be sufficient to ensure that use of adjoining areas, including disposal of chemical waste will not compromise trench or site integrity.
Issues discussed include the ownership of the buffer zone, the location of the road to the chemical site in the buffer zone, the fact that the basis for the adequacy of the buffer zone has not been established, and the nonspecificity of " unexpected mitigating measures".
(14)
That provisio'n is made for a secure; passive site security system.
Issues discussed included the need for a 'ence in good repair that would discourage intruders and the need for other security measures.
(15)
That a surveillance program, to assure the objective of the decommissionir.g plan have been met, is establis5ed. This shall include a ground water, surface water and air quality m:nitcring system.
Issues discussed include whether or not f;ECC will be required to conduct the surveillance prog *ar, what would be recui-ed in addition to what NECO has already done with regard to a surveillanct program, and the r.eed for coordination wi-h the State on tni: planned surveillan:e orsgram.
I;RC will review the site conditions and dstermine if clarificatien of the wording of any is warranted. Any clarification w:uid be discussed with I;ECO and others.
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Edward F. Hawkins Low-Level Paste Licensing Branch I
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