ML20126L984
| ML20126L984 | |
| Person / Time | |
|---|---|
| Issue date: | 07/17/1985 |
| From: | Kelly W, Richard Lee NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Jackson K, Justus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-8 NUDOCS 8508010186 | |
| Download: ML20126L984 (6) | |
Text
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DISTRIBUTION (W51 s/f NMSS r/f W1GT r/f N
REBrowning MBW
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,y, J0 Bunting MRKnapp WRKelly & r/f RLee & r/f PDR MEMORANDUM T0: Kenneth C. Jackson, Section Leader a
Geochemistry Section, WMGT Philip Justus, Section Leader Geology-Geophysics Section, WMGT FROM:
Walton R. Kelly, WMGT Geochemistry Section Richard Lee, WMGT Geology-Geophysics Section
SUBJECT:
TRIP REPORTS FOR VISIT BY WMGT STAFF TO BEATTY, NEVADA, LLW DISPOSAL SITE, JUNE 19 21, 1985.
At the invitation of WMLU, Walt Kelly and Richard Lee of WMGT visted the LLW disposal site in Beatty, NV. Attached please find individual trip reports (attachments 1 and 2).
Walton Kelly Geochemistry Section, WMGT Richard Lee Geology-Geophysics Section, WMGT
Enclosures:
As Stated a
WM Record file WM Preisct ___
Docket No.
PDP W LN3 __.__._
8500010186 850717
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ATTACm!ENT 1 201/WRK/85/06/24 TRIP REPORT FOR MEETING AT LLW DISPOSAL SITE AT BEATTY, NV, JUNE 19-22, 1985, BY WALTON R. KELLY, WMGT, GE0 CHEMISTRY SECTION.
j The purpose of the trip was to discuss with State of Nevada officials the NRC's coments on the closure plan developed for the Beatty LLW disposal site and to tour the facility. On June 20, 1985, NRC staff members (Jim Shaffner, John Stanner (WMLU), John Surmeier (WMPC), Jack Hornor (Region V), Richard Lee, and i
myself (WMGT)) met in the town of Beatty, NV, with members of the State of Nevada Bureau of Regulatory Health Services (John Vadon, Stan Marshall, Burt j
Grey). Discussion of the NRC's comments on the closure plan centered on two j
major concerns:
(1) that there was a need for site characterization and how it relates to site performance; and (2) that the monitoring plan, system, and j
history were inadequate.
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The state officials were very receptive to our comments. Most of the j
discussion concerned clarifications and examples. One thing that was apparent from the meeting is that the more detailed our comments (e.g., examples that we think are appropriate), the more pertinent and helpful our comments.
j Another shortcoming of the NRC's methods became apparent the following day, t
June 21, when we toured the site. Had members of the NRC been familiar with the site beforehand, our comments would have been more detailed and some concerns would probably have been diminished.
For example, a major coment we I
made concerned inadequate assessment of flood and erosion potential. However, the site sits up on a knoll, perhaps 20 to 30 feet above the floodplain.
The fact that the site is elevated was not discussed in the closure plan and is not readily apparent on topographic maps; our visit to the site, however, made J
this fact obvious. Another comment on the closure plan we made was that there was no demonstration of minimization of infiltration into the trenches. The visit to the site showed that the compacted site soil was very hard, and presumably relatively impermeable, when left undisturbed and precipitated upon.
John Starmer commented that tuffaceous material (such as is present at the site) is mined in Italy and used in a siliceous cement. The point is not that our comments should not have been made, but that they would have been more thorough and helpful if we had had first-hand knowledge of the site prior to 4
j commenting.
j The site itself is very impressive and seems ideally suited for LLW disposal.
The trench presently operational, trench 22, is approximately 800 feet by 250 feet by 50 feet deep. Only a small fraction of trench 22 has been used to 1
date, with mainly class A waste and some class B waste. We were able to 3
observe waste that had been delivered on June 20 covered. The sediments l
exposed by the trench were very stable; the vertical walls showed little sign I
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of instability and erosion, especially in the lower 35 feet of the trench. The sediments were fairly coarse-grained alluvial sediments with a thick (12 feet),
cobbly channel fill deposit in the lower half.
The cementing material in the sediments was deduced to be siliceous. John Vadon stated that the precipitation rate is low enough and the evaporation rate high enough that there should be no local recharge to the aquifer (250 to 300 feet below the surface). The well in which levels of tritium above background has been found l
(well 302) is located at the southern edge of the site. The source of the i
elevated concentrations of tritium is still unknown. The two most convincing l
explanations I heard were that there were poor monitoring practices leading to well contamination or that there was leaching from older trenches where bulk material was disposed of, presumably below the 7one of evaporation. The USGS j
is performing a study of migration in the vadose zone adjacent to the site.
We also were given a tour of the toxic waste site by the US Ecology site a
operator. The toxic waste site receives significantly more waste than the LLW site (at least ten times the volume).
I believe that the trip was very worthwhile for the technical staff, and that those involved in LLW should be able to visit all the sites, operating and closed, as the opportunity arises. Being able to see the site and directly ask questions based on observations is very valuable to our understanding site i
performance and problems.
i Walton R. Kelly Geochemistry Section, WMGT i
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ATTACHMENT 2 l
TRIP REPORT BEATTY, NV LOW-LEVEL WASTE FACILITY JUNE 19 to 22, 1985 Richard Lee Geology-Geophysics Section, WMGT 4
On June 20, 1985 representatives of NRC and the state of Nevada met in the Beatty, Nevada Community Center to discuss and clarify NRC comments on the U.S. Ecology Draft Closure Plan submitted to the state of Nevada on April 29, 1985. The meeting was chaired by John Vaden of the state of Nevada, and Jim Shaffner of WMLU was the NRC trip coordinator. The list of attendees is included in Enclosure #1.
While nearly all of NRC's detailed comments were discussed at the meeting, the following recurring comment from NRC appeared to apply to nearly all detailed comments. That is, to resolve NRC's comments the operator (U.S. Ecology) should: 1) provide data to more fully characterize the natural site characteristics that contribute to waste isolation, 2) demonstrate how those site characteristics contribute to site performance and potential release pathways, and 3) provide a plan that will monitor site performance. NRC made it clear that while these activities were desirable to demonstrate reasonable assurance that the site will perform as expected, it is the responsibility of the state of Nevada to request such action.
After the meeting, NRC made a vehicle tour of the site area including the Amargosa River north of the site and the hills to the east of the site.
It was observed that the river appears to be more of an arroyo than a river.
It was also observed that the site is located on a topographic high with as much as 10 to 15 feet of relief above the surrounding area. Because of the vast expanse of the Amargosa Desert and the subtle nature of the topographic high, it is difficult at first to recognize or photographically document the high. The high does not appear to be structurally related, and thus it is concluded to be an erosional / depositional high.
On June 21, 1985 NRC was taken on a tour of the site which included a walk into open trench #22. That trench has been open for about 3 years, and surprisingly, there was no evidence of sidewall material collapse. The material is gravelly and is interpreted to be of alluvial origin. The 50-feet deep sidewall contains 5 alternating layers, each roughly 10-feet thick, of flat-laminated fine gravel separated by coarse, cross-bedded gravel. The fine units have an average pebble size of approximately 1" but is dominated by sand-sized grair.s. The coarse gravel contains cobbles up to 6"-8" in diameter, a larger percentage of pebbles than the finer units, and one coarse unit near the trench bottom has a marked erosional lower contact with roughly 6' of scour in isolated areas.
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Other site observations were made of the nature dF the desert soil. A fine powdery matrix of the material is evident et#.he ssurfece where vehicular and foot traffic are comon. The matrix is soft 'and, difficult to walk on uphill, I
similar to walking up a sana dune. Where the soil ls undisturbed, the surface is hard and consists of a layer of roughly 1" diameter pebbles.
It is presumed tut fine material is eroded by $_ and water, leaving the pebbles at d
the surfa:e in undisturbed areas. With vigcVous' digging 3y hai4, T could only penetrate this hard surface to about 1" depta. 'It is inccrpretei that the fine powdery material found on the surface of dishrbed areas acts es a
" cement", possibly a silica cement, tcWnd cater.iai % uncisturbed areas.
This interpretation is used to explain both the hard crusty surface of undisturbed areas and the high integrity ard lack of erosive collapse of the trench sidewflls.
In tenns o# the bearing of these observ'ations on' site performance, it is i
tentativeij concluded that the..dndetermiried " cement" is a key element' in limiting water infiltration, surface water crosion, and trench subside,ce.
It should be noted, however, tSat"these conclusions are based only on cursory site and material examination,.a.id part of NRCM unofficial recomendations to the state of Nevada is to request an Sna' lysis of the " cement" and' Tis contribution to site stability.
Following our tour of the LLW facility, the U.S. Ecolpqy site manager took us on a brief walking tour of the adjacent hazardous waste facility.
My general perception is that the entire facility is effectively operated a,d managed. Officials from both U.S. Ecology and the state of Nevada were gracious hosts and provided us with frank responses to our questions..
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i From the. perspective' of the LLW progra, I.think the trip was extremely successful. The observations I rade at the site, as well as the approsch of the state of Nevadh staff to site' operations, were very useful in terms of making further technical recomendations. Had I taken this trip prior to commenting on the.$1te Closure Plan, mf coments yould have more effecf.ively addressed the:ty m of specific, observations I rade at the site. h eafore, 4
I return with the conviction that for the staff to make effective technical coments that provide realistic assistance to gtates or compacts, site visits.
are an absolute necessity. This mears that geologic site characteristics should be seen by a geologist, hydrogeologic by a hydrogeologist, and se on.> The observations I made, which are important to site stability, wouic simply not a
be made by a hydrogeologist because one. makes observations commensorMe with-one's technical background and trip ob.1 actives.
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i, ENCLOSURE #1
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MEETING ATTENDEES 1
State of Nevada
Participants:
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John Vaden Stan Marshall Larry (?)
j Burt Grey i
. NRC
Participants:
j Jim Shaffner John Starmer i
John Surmeier I
Richard Lee Walt Kelly i
Jack Horner i
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