ML20059E496

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Concurs W/Doe 900711 Rept, Ambrosia Lake Umtra Site Waste Disposal Recommendations, W/Conditions That Certain Waste Containers Be Considered Further.Review Encl
ML20059E496
Person / Time
Issue date: 08/30/1990
From: Yandell L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Matthews M
ENERGY, DEPT. OF
References
REF-WM-67 NUDOCS 9009100217
Download: ML20059E496 (4)


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URFO:JPG Docket No. WM-67 040WM067160E I

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ATTN: Mttk L. Matthews 5

Albuquerque Operations Office P.O. Box 5400 Albuquerque, New Mexico 87115

Dear Mr. Matthews:

Our office is in receipt of your report entitled, " Ambrosia Lake UMTRA Site Waste Disposal Recommendations," submitted by cover letter dated July 11, 1990 As we understand your proposal, DOE intends to dispose of hazardous wastes at-an EPA-approved facility, recycle other wastes, and dispose of the remaining wastes as byproduct material in the tailings cc.il.

NRC staff have reviewed your proposal and find the olan for the hazardous. and recyclable material to be generally acceptable.

However, 8 of the 156 drums of radioactive wastes do not clearly meet th.e criteria foi byproduct material and require further characterization to detemine if the material is byproduct or mixed waste.

In addition, one 5 gallon pail-of fire extinguisher powder is not clearly contaminated and would not be properly disposed of in the tailings i

pile. Our conclusions regarding disposition of the Ambrosia Lake wastes are detailed in the attached summary.

Therefore, we concur in your submittal, with the conditions that certain waste containers be considered further.

This matter was discussed by JGrimm/l'[

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I Joel Grime of my st.aff with I'r. John Ishiam of MK-Ferguson on August 28, and.

I Mr. Mike Abrams on August 29, 1990.

If you have any questions or comments regarding our review, please contact Mr. Grime at (303) 236-2805 or FTS 776-2805.

Sincerely, i

I.sl L. A. Yandell Acting Chief t

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NRC Summary of Review i

t Hazardous Waste Disposal Plan Ambrosia Lake, New Mexico, UMTRAP Site l

1.

The following drums are not radiologically contaminated but contain l

hazardous properties or constituents 4

drums of flammable paint solids l

1 drum of pH 14 solution I

1 drum of waste grease Subtotal

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drums T

These wastes must be sent te an EPA permitted treatment, storage and disposal facility..

2.

a.

The following drums are radiologically contaminated and appear to be byproduct material as defined under Section 11(e)(2) of the Atomic Energy Act:

71 drums of radioactive sludge 26 drums of slightly contaminated cottonseed insulation 12 drums of radioactive organic liquid 1

drum of radioactive soil with < 2 ppm PCB 38 drums of radioactive trash one selenium rectifier-Subtotal 148 drums and one selenium rectifier These wastes can be placed into the tailings cell under UMTRCA.

b.

The following drums are radiologically contaminated and contain hazardous properties that could disrupt or compromise the integrity i

of the tailings cell:

5 drums of radioactive liquid pH 11 2

drums of radioactive sludge with lead and ignitability 1

drum of radioactive sludge with ignitability Subtotal 8

drums These drums should be characterized further for their possible impacts to ground water hydrology and cell compatibility.

The content of these drums must also be defined as byproduct material or mixed wastes.

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3.

The following drums are not radiologically contaminated:

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5 drums of lead-acid automobile batteries 1

drum of Matheson gas cylinders 1

5 ga11on pail of Ansul Purple K fire extinguisher powder Subtotal 6

drums plus one 5 gallon pail These materials should be recycled at the appropriate vendor.

Total 168 drums, one 5 gallon pail, one selenium rectifier l

There were no wastes characterized that would be classified as acutely toxic, although some of the wastes were hazardous due to extremes in pH or ignitability. A majority of the drums contain wastes that are not considered hazardous but are slightly contaminated by radioactive materials during their use in mill operations.

The materials contained in the drums under type 2b, drums 116,118-121,141,142, and 173, should be further characterized to determine compatibility with and disposal in the tailings cell byproduct materials.

Alternate disposal methods or disposal at EPA approved locations for these possible mixed wastes should also be considered.

One drum of radioactive soll is contaminated with less than 2 ppm PCB, below concentrations regulated by the Toxic Substance Control Act, and can be

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disposed of in the tailings cell as byproduct material.

The one 5 gallon pail of Ansul purple K fire extinguisher powder is probably not radiologically contaminated and should be recycled or disposed of in an approved landfill.

The selenium rectifier, as a former part of the mill structure, is considered byproduct material and should be disposed of with the demolition debris in the tailings cell.

l Conclusion The staff concludes that the disposal or recycling of wastes as reported by MK-Ferguson Company's Waste Disposal Recommendations study is in accordance with applicable federal regulations under RCRA and UMTRCA except for drums 116, 118-121, 141, 142, 173, and 128.

Drum 128 (5 gallon pail) of Ansul Purple K should be recycled and drums 116, 118-121, 141, 142, and 173 have hazardous constituents that could preclude their disposal in the tailings cell.

Further analysis should be conducted on these drums to ascertain if they are byproduct material.

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