ML20033B279
| ML20033B279 | |
| Person / Time | |
|---|---|
| Site: | 02700010 |
| Issue date: | 10/19/1981 |
| From: | Kerr G NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Martelle A NEVADA, STATE OF |
| Shared Package | |
| ML20033B277 | List: |
| References | |
| REF-WM-8 NUDOCS 8112010171 | |
| Download: ML20033B279 (4) | |
Text
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a Ref:
SA/JRMcG UNITED ST ATES
/f" " %,,7c, NUCLEAR REGULATORY COrafalsslOtJ WASHINGTON, D. C. 20555
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OCT 1 s 1981 Mr. A. R. Martelle, Director Department of Human Resources 505 E. King Street, Room 600 Carson City,tievada 89710
Dear Mr. Martelle:
This is to confirm the discussion Mr. McGrath and Mrs. Dragonette held with you and Mr. Vaden on August 20, 1981 during our review of the Nevada radiation control program.- The review covered the principal 4
administrative and technical aspects of the Department's program including organization, management, personnel, regulation, licensing, and compliance.
Our review also included a visit to the low-level waste burial site in i
Beatty and a review of available file information on the operation of the site.
As a result of our review of the State's program and the routine exchange of information between the Nuclear Regulatory Comission and the State, the staff believes that the State's program for regulation of agreement materials is adequate to protect the public health and safety and compatible with the Commission's program.
We do have concern with the staffing situation in Nevada, particularly the recent staff turnover.
The two professional positions which have been budgeted for should be filled as soon as possible.
In view of the staff turnover, we believe the State should consider reviewing the current salary structure. To assist the State in this review, we have enclosed a listing of median Agreement State staff salaries indicating where Nevada stands in relation to the other Agreement States. Those salaries with an asterisk (*) are those of the other western Agreement States.
A major portion of our review concerned the low-level waste burial site at Beatty. Based on our review, we found no significant deficiencies with regard to this licensee activity. Some general comments on improving regulation of the waste burial ground are pmvided as an enclosure to
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this letter.
8112010171 311016 PDR WASTE WM-13 PDR
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4 lir. A. R. Martelle,
I am also enclosing a copy of a letter to Mr. Vaden regarding other aspects of the State's program.' As is our usual practice, I am~ enclosing-an extra copy of these letters for placement in tne State public document room or other means by which they may be made available for public review.
I appreciate the courtesy and cooperation extended to Mr. McGrath and Mrs. Dragonette during their meeting with you and your staff.
Sincerely, W
G. Wayne Kerr, Director Office of_ State Programs
Enclosures:
As stated cc:
J. Carr, w/ encl.
J. Vaden, w/ encl.
NRC Public Document Room, w/ encl.
State Public Document Room, w/ encl.
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MEDI AN AGREEMENT STATE STAFF SRt. ARIES 29602
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28699*
2.
28108 3.
24746 i
4.
23991 5.
23577 6.
23394*
7.
22205*
8.
21668 9.
21492 10.
21353 11.
21245*
12.
211 51*
13.
21108*
14.
20993 15.
20968 16.
20710*
17.
20350 18.
Nevada 20252 19.
1 9,627 20.
i 19,496 21.
19,276 22.
19,176 23.
18,824 24.
18,275 25.
17,996 26.
3 17,695 27.
15,610 28.
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GENERAL C0fMENTS ON REGULATION OF THE WASTE BURIAL G0UND 1.
It would be prudent at this time to require U.S. Ecology to' prepare a site closure plan that addresses both t'echnical and financial arrangements for decommissioning. Requirements for closure are one of the most important features that should be inc1cSd in the license at the time of renewal.
2.
Based on references in application materials U.S. Ecology has performed technical studies on groundwater flow, excavation safety, <
and migration of chemicals atzthe chemical disposal site, but has not provided the reports or other documents containing details about the work to the State. Neither the results of these studies or operational experience (e.g., _ rainfall pattern, maintenance required, geotechnical evaluation of excavated trenches) at the site has been documented in materials submitted to the Department or factored into site operational planning or closure planning.
It would be desirable to document these activities prior to conducting new studies at the site.
3.
U. S. Ecology should document the rationale for the site environmental monitoring program. The State should also document the rationale for its indepqndent monitoring program. A program to evaluate and report the Environmental Protection Agency's findings on State samples should be developed.
A separate log with a description of the program, the rationale, a map of sampling' points, and graphs showing results over time should be developed and maintained to-facilitate evaluation and communication of the data.
4.
The Department of llealth's resources could be augmented by closer coordination with the Division of Environmental Protection which has responsibility for the chemical disposal site. Expertise and consultants could possibly be shared.
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NUCLE AR REGULATORY COMMISSION g $24;;qf(,g C
WASmNG TON. D. C. 20555 a
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- OCT 191981 REF: SA/JRMcG Mr. John Vaden, Supervisor Radiological Health Consumer Health Protection Services Room 103 Kinkead Building Capitol Complex Carson City, fievada 89710
Dear Mr. Vaden:
This is to confirm the comments made to you by John McGrath and Kitty Dragonette during their recent review of the Nevada radiation control program.
As we indicated in our letter to Mr. Martelle, we believe that the State should fill the two budgeted slots as soon as possible.
We were somewhat concerned about the increase in the number of overdue inspections, but believe that the additional staff will ameliorate this situation.
We were pleased with the status of the State's licensing program.
The State is to be commended for maintaining the quality of licensing actions in view of the high workload associated with the Beatty site.
We also want to commend the State for the quality of its incident responses in the past year. With regard to other areas of the compliance program, we would like to make four recommendations regarding minor improvements that can be made in inspection reports.
" Inspection Reports" is a Category II Indi ca tor.
(1) Reports should indicate the status of previous items of noncompliance. We feel that the maintenance of compliance histories is an important part of the program.
(2)
Inspection reports should be better structured, categorizing inspection topics (organization, training, personnel monitoring, surveys, waste disposal, etc.) to facilitate review and retrieval of information from reports.
(3) Reports should provide better documentation of independent measurements made during inspections.
(4) Reports should also provide better documentation of licensee compliance with the Nevada equivalent of 10 CFR Part 19.
A number of minor deficiencies were noted with regard to the report of the inspection of the University of Nevada.
(1) A single report should be prepared covering all activities of the licensee's broad license.
(2) The inspection should address the licensee's centralized receipt and inventory procedures, radiation survey program, and waste disposal program.
(3)
Inspection reports and compliance letters should agree regarding items of noncompliance.
QW7OCV
Mr. John Vaden Some supplementary comments on the burial site piogram reflecting discussion points with you are enclosed.
We would appreciate your review of the above comments and any response you might have.
I appreciate the cooperation extended to Mr. McGrath and Mrs. Dragonette during their meeting with you.
Sincerely, J h.
l4Ut!"
Donald A. Nussbaumer Assistant Director for State Agreements Program Office of State Programs
Enclosure:
As stated cc:
A. Martelle J. Carr i
4 Wm
COMMENTS AND RECOMMENDATIONS CONCERNING THE BEATTY, NEVADA _ LOW-LEVEL WASTE DISPOSAL SITE-A number of topics were discussed during the program review where NRC and the State staff share concerns.
The topics included:
1.
U.S. Ecology Staffing - Radiation' safety staff hold multiple positions and temporary duties.
Vacancies should be filled as soon as possible.
2.
Consultants - 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.
3.
It would be desirable to have a person knowledgeable in c1eil engineering evaluate the potential for erosion of the spoils at the site and the generation of dust from such spoils.
4.
Stability of_the deeper trench walls.
The newer trenches are 50 feet deep.
The site operator leaves 10' ledge near the top of the trench to catch loose materials from the upper 2 - 3 feet. A review of the adequacy of the practice by a person knowledgeable in civil engineering would be desirable.
5.
The tritium detection limit problem with the contractor laboratory should be resolved.
6.
Updated disposal operations.
Specific measures addressing segregation of chemical and nuclear disposal, deeper burial of more highly radioactive shipments and an adequate buffer zone around the site are needed.
7.
Miscellaneous observations about site-related matters include:
a.
The State inspection program is a good faith effort to comply with earlier NRC recommendations.
b.
State staff have provided a good overview of the user permitting system.
c.
Current files appear in reasonable order. Administrative help with older files and maintaining future files would help.
d.
The draft renewal license document was not reviewed so NRC provided no comments on the language or specifics.
e.
The State on-site inspector keeps. staff informed about what is going on.
Responses to incidents is satisfactory.
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