ML20033B276
| ML20033B276 | |
| Person / Time | |
|---|---|
| Site: | 02700010 |
| Issue date: | 10/16/1981 |
| From: | Dragonette K NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rich Smith NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20033B277 | List: |
| References | |
| REF-WM-8 NUDOCS 8112010167 | |
| Download: ML20033B276 (6) | |
Text
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_j. -[o MEMORANDUM FOR:
Low-Level Waste Licens g q.
FROM:
Kitty S. Dragonette b935 Low-Level-Waste Licensing Branch
SUBJECT:
REVIEW OF NEVADA REGULATORY PROGRAM AND VISIT TO BEATTY, NEVADA SITE Enclosed are copies of comments provided to State Programs on my review of the, Nevada Program during the week of August 17, 1981. General comments discussed with management ar.d supplementary comments discussed with staff were provided.
A copy of my trip report is also enclosed.
I would like to highlight the following points:
1.
State officials would not permit review of the license prepared for renewal.
The renewal had not been issued and was still undergoing legal challenge.
2.
State efficials seem to be still trying to legally close the site.
3.
U.S. Ecology has submitted no new information in support of renewal not covered by our July 3, 1980 and August 8, 1980 reviews.
4.
The site appears well run.
DIST:
TICKET NO:
/N OFC : J, NAME :
DATE :81/10/16 t
8112010167 811016 PDR WASTE WM-13 PDR
KITTY DRAGONETTE/10/16/81/0 5.
The third party inspection program has significantly curtailed receipt of wastes.
Only 16 shippers have been permitted.
No waste from Nevada licensees is snipped. The University of Nevada is storing liquid scintillation wastes until a 10 CFR 20.306 exemption can be adopted by the State.
M Kitty S. Dragonette Low-Level Waste Licensing Branch
'osures:
1.
General Comments 2.
Supplementary Comments 3.
Trip Report P.S.
Copies of State Program letters to Mr. John Vaden and Mr A. R. Marte11e on the program review dated October 19, 1981 are also enclosed.
DIST:
TICKET NO:
OFC :
NAME :
DATE :E1/10/16
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DRAFT 9/30/81 DRAG 0NETT.E:AJF
GENERAL COMMENT
S AND RECOMMENDATIONS CONCERNING THE BEATTY, NEVADA LOW LEVEL WASTE DISPOSAL SITE 1.
Based on the NRC staff site visit to the Beatty, Nevada Low Level Radioactive Waste Disposal Site on August 17, 1981, review of the license renewal application materials as reflected in a July 3,1980 report by the Lcw-Level Waste Licensing Branch and review of supplemental application materials in August 1980, and review of records and files in the Division of Health, NRC staff find no tech-nical reason to preclude continued site operation and license renewal.
2.
Early resolution of the license renewal consistent with legal constraints would affinn that the site does not represent a threat to the public health and safety and provide a means of updating the license requirements.
3.
Additional technical information on the site and site performance would provide greater assurance in decisions regarding the site. Based on references in application materials, U.S. Ecology has performed technical studies on ground-water flow, excavation safety, and migration of chemicals at the chemical site but has not provided the reports or other documents containing details about the work.
Operational experience (e.g., rainfall pattern, maintenance required.
geotechnical evaluation of excavated trenches) has not been documented in
~ materials submitted to the Department or factored into site operational planning or closure planning.
NRC does not recommend any new studies at the site until documentation concerning past work can be reviewed.
4.
Improvements in both the site operator's and state's environmental monitor-ing activities would provide greater assurances concerning continuing protection of the public health and safety and environment.
U.S. Ecology needs to establish I
DRAFT 9.30/81 DRAG 0NETTE:AJF and document the rationale for the site environmental monitoring program. The H-3 detection limit problem with the contractor laboratory should be resolved.
The state should also establish and ' document its rationale for its independent monitoring program. A program to evaluate and report the Environmental Protec-tion Agency's findings on state samples should be developed. As a minimum, a separate log with a description of the program, the rationale, a map of sampling points, and graphs showing results over time should be maintained to facilitate communication of the data.
5.
U. S. Ecology should be required to prepare a site closure plan that addresses both technical and financial requirements.
Requirements for closure planning are one of the most important features that should be included in the renewed license.
6.
The Department of Health's resources could be augmented by closer coordina-l tion with the Division of Environmental Protection which as responsibility for the chemical site.
Expertise and consultants could possibly be shared.
l 7.
NRC Waste Management is prepared to provide technical assistance. Assistance could include geotechnical and hydrological review of site studies, review of proposed licenses, or review of environmental monitoring rationale and design, l
and coordination with other state activities.
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St'PPLEMENTARY COMMENTS AND RECOMMENDATIONS CONCERNING THE BEATTY, NEVADA LOW LEVEL WASTE DISPOSAL SITE Note: General comments are provided in the attached copy of the enclosure to the companion letter to Mr. A. R. Martelle A number of topics were discussed where NRC and the state staff share concerns.
Topics included:
1.
Operator Staffing - U.S. Ecology radiation safety staff hold multiple positions and temporary duties.
Vacancies should be filled as soon as possibl e.
2.
State Staffing - Activities related to the disposal site pose both an
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administrative and technical burden on state staff. - The demands on the Supervisor, Radiological Health, by the pennitting system and dealing with the shippers and third party inspection program are great.
3.
0bnsultants - NRC agrees that it is a good idea for the state to use.
a geotechnical consultant to independently review site studies.
Continuity and familiarity with the site are important. The state may wish to have such a consultant inspect all new trenches before use.
4.
The potential for erosion of the spoils at the site and the generation of dust from such spoils.
The site operator indicates no problem thus
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far but review of the situation by persons knowledgeable in soils or l
civiliengineering would be reassuring.
5.
Stability of the deeper trench walls. The newest trenches are 50 feet deep. The site operator lcaves 10' ledge near the top of the trench to l
catch loose materials from the upper 2 - 3 feet.
Review as in #4 above would be reassuring.
1 L
', y ' ;
. 6.
Updated disposal operations.
Specific procedures and measures address-ing segregation of chemical and nuclear disposal,' deeper burial of more highly radioactive shipments and an adequate buffer zone around the site are needed.
Miscellaneous observations ' bout site related matters include:
a 1.
The state inspection program is a good faith effort to comply with earlier NRC recommendations.
2.
State staff have provided a good overview of the user permitting system.
3.
Current files appear in reasonable order. Administrative help with older files and maintaining future files would hel p.
4.
The draft renewal license was not reviewed so NRC provided no comments on the language or specifics.
5.
The state on-site inspector keeps staff informed about what is going on. Responses to incidents rate good marks.
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