ML20034E162
| ML20034E162 | |
| Person / Time | |
|---|---|
| Site: | Wood River Junction |
| Issue date: | 02/02/1993 |
| From: | Griffith R UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| To: | UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| References | |
| NUDOCS 9302250209 | |
| Download: ML20034E162 (6) | |
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Department of Administration OFFICE OF STRATEGIC PLANNING.
.j One Capitol Hill Providencei RI 02908-5871 i
MEMORANDUM TO:
Interested Parties 3
FROM:
Robert K. Gi-if fith, Ph.c
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-i RE:
Proposed License Termination of United Nuclear Corporation Facility
~l Attached is a summary of a meeting held 11 February 1993.. The delicensing of the UNC facility has proved to be as complicated as' it is important.
We have attempted to accurately. report the positions presented by all involved par, ties.
Please note.that a complete file is available for review at our office.
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Meeting Regarding License Termination of United Nuclear Facility 11 February 1993
Background
An informal pres 6entation on the decommissioning of the United Nuclear Corporation (UNC) facility in Charlestown, RI was conducted on 4 OCT 1991 by the Nuclear Regulatory Commission (NRC).
In f
attendance were representatives of the United Nuclear Corporation, the state, local officials, and the Narragansett Indian Tribe.
On 7 OCT 1991 the State Single Point of Contact (SPOC) began review of the proposed license termination.
On 24 FEB 1992 the SPOC sent i
a State Process Recommendation to the Nuclear Regulatory Commission 1
opposing the termination unless certain conditions were met.
NRC s
was not agreeable to the conditions.
On 2
APR
- 1992, representatives of UNC met with the Governor's -Office and i
Department of Environmental Management to express their concerns.
This prompted a further meeting on 6 MAY 1992 with all interested
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parties in attendance.
Over the next two months, correspondence was exchanged between NRC and SPOC indicating that neither had substantially altered their previous positions. NRC then requested a
meeting with the Director and Associate Director of the Department of Administration which was held on 11 SEPT 1992.
After
- a flow of additional correspondence which failed to provide a i
resolution, a meeting was held on 11 FEB 1993 at the request of the NRC for the purpose of attempting to come to a mutually acceptable agreement with the State over this issue.
Attendees included, in addition to NRC, representatives of UNC, representatives of the
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I Narragansett Indian Tribe, representatives of the RI Department of
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Environmental Management (RIDEM), and acting as the SPOC, the RI Division of Planning. 'Also invited but not-in attendance were the.
RI Department of Health and the RI Department of Economic' l
Development. The following is a summary of the positions expressed E
at the meeting.
i NRC: Contamination at the site consists _ of Sr90 and nitrates.
NRC legal counsel advises that NRC does not have jurisdiction over l
l non-radiological contaminates, in this case, nitrates.
The' f
law does not provide authority for NRC,to - enforce a non-radiological cleanup action or to enforce state. environmental.
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standards.
The Sr90 is at an acceptable level according to proposed EPA drinking water standards.and therefore not a problem.
Regarding the Sr90, NRC has provided the' State with l
a draft of its risk assessment and will provide supplementary
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material as it becomes available. While NRC fully understands Jl Rhode Island's concerns regarding the nitrate contamination-and wishes to accommodate the State, UNC has complied with NRCl regulations and guidance', and therefore should be granted the license termination.
-NRC is open to a-solution which would 1
require UNC to establish, through a contractual mechanism, a j
monitoring program of tw2nty to thirty wells measured over a 1
five year period.
The design would have'to be acceptable to RIDEM.
At the~ conclusion of the monitoring period, -UNC would report on the state of the nitrate plume to RIDEM.
Once this 2
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program is underway, NRC would terminate the license.
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UNC: UNC is ( Dnanitted to leaving the site in an environmentally safe condition.
However, they cannot commit to a solution until they }tnow what is acceptable to all other parties
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involved.
They wish to resolve this quickly.
If a five year monitoring period is required, they want the five years to begin now, not after months of negotiation.
They are willing to meet with RIDEM for more detailed discussions on what would i
be required of them.
They will provide a copy of.their non-radiological risk assessment to RIDEM when it is available (March).
UNC has a couple of other items of concern. Namely, the vast majority of their property is not contaninated and t
should not be constrained, and, they do not want to be held accountable for contaminants which may have migrated from the abutting property (Carol Products).
RIDEM:
The preferred solution is to have one agency i.e.
NRC oversee remediation of the site through its final resolution.
If such a " global" settlement is not possible, then parallel enforcement will be pursued.
RIDEM has jurisdiction over groundwater, soil, and air.
The UNC site is located over a GAA groundwater aquifer.
While the existing centamination violates state standards, RIDEM has not issued a violation notice pending the outcome of the decommissioning procedure.
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In addition, RIDEM is about to issue a set of site remediation f
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t rules and regulations which would cover the UNC site.
They will be provided to NRC and UNC.
RIDEM is not convinced that no further radiological hazard exists.
Sr90 may still be a problem and gross alpha and beta levels have been detected at certain test wells at certain times.
There is a need for a more thorough risk assessment (with advice. from the RI Department of Health) followed up Dy a feasibility study to-identify and select remedial actions.
Passive remedies-(natural flushing) could be evaluated at this time.
It is
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premature to set a definitive time frame such as five years.
The exact length and frequency of monitoring should depend on hazards identified and remedial actions taken.
A properly designed monitoring system would also disclose contaminates I
migrating from adjoining property.
UNC would not be responsible for such contamination.
As to the vast-majority i
of the UNC property which does not contain contarination, RIDEM has no objection to their expeditious reuse provided l
i that UNC demonstrates the absence of any hazards.
RIDEM suggests that UNC adopt the - procedures being used by the military in base closures.
RIDEM will gladly cooperate..
i RIDEM suggests that UNC technical staff meet with RIDEM l
technical staff to discuss and clarify' monitoring standards.
RIDEM would like UNC to use such information to prepare j
l alternatives for action. RIDEM could then negotiate, ' approve, l
or reject specific actions.
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4-i Narragansett Indian Tribe:
The Tribe wished to emphasize its status as a sovereign entity and that the State ' does not represent it in negotiations with NRC. The Tribe wishes to be ir.cluded in all future negotiations.
Planning:
The State's goal is a clean site achieved through a fair and equitable solution.
The Division of Planning is still acting as the SPOC for the State regarding the proposed license termination.
Nothing at this meeting alters previous positions stated to NRC.
The preferred choice.is for NRC to continue the license until the site is remediated.
Absent this option, RIDEM will have to intervene pursuant to its legal mandates.
The NRC should continue to address this matter through Daniel Varin, Associate Director of the RI Division of Planning who will work in conjunction with the Governor's Office.
Technical matters can be dealt with through RIDEM, but this office should receive copies of any corrernondence.
The meeting ended with the understanding that-UNC would soon schedule a meeting with RIDEM to discuss technical issues pursuant to developing a course of action dealing with the contaminated l
site.
This would be a pre-enforcement level meeting, not an opportunity to negotiate a final enforcement agreement.
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