ML20138G872

Trip Rept of 850619-21 Visit to Beatty,Nv & Site Tour of Low Level Waste Disposal Facility Re Draft Closure Plan. Three-phased Approach for Closure Plan Suggested by NRC

ML20138G872
Person / Time
Issue date:	08/01/1985
From:	Shaffner J, Starmer R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Higginbotham L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
REF-WM-8 NUDOCS 8510280064
Download: ML20138G872 (5)

Text

_ _ _ ._ __ . _ - - ._ - - _ _ _ _ _ _ - - - _ _ - _ _ _ _ _ . _ ._.

ylM Rard Mc VM Pi@ ~~

Ut w t h . e - __

pad __- '

LPG / ._-- -

- " '9/JA' 5/7/2 dim:aM t __ . - -- - -

l p$ _ _ _ . _ . . _

- ~

AUG 1 1985 5 5 m fo Y O '2 DISTRIBUTION: I WW"-' -

NMSS rf 6 of WM-8) RBrowning XBell MKnapp JGreeves JSumeier MEMORANDUM FOR: Leo B. Higginbotham, Chief WMLU RLee WKelly JHornor .

FROM: R. John Starmer, WMLU PDYt 4

James A. Shaffner, WMLU (UBJECT: TRIP REPORT FOR TRAVEL TO BEATTY, NEVADA JUNE 19-21 i

Enclosed is a trip report documenting a visit by James A. Shaffner, And .

l R. John Starrer to Beotty Nevada on June 19, 1985.

I 4

/5/ -

R. John Starmer, WMLU

/5/

James A. Shaffner, WMLU Er. closure: As stated i

j d

i I B51028 850001 PDR WAS E WM-8 PDR OFC :WML bkJ :WMLlf 6:  :  :

1 ..... : ...Q..iL.....:....J......:............:............:............:............:...........

: i jNAME:JShaffner :JStariner  :  :  :  :  :

.....g............:........ ..:............:............:............:............:...........

.DATE :85/7/7tg :85/7/  :  :  :  :  : ,

o

. AUG 1 M65 TRIP REPORT TRAVEL TO BEATTY, NEVADA JUNE 19-21, 1985

Purpose:

1) Meet with State of Nevada Officials to discuss draft closure plan for Beatty LLWDF

2) Site tour of Beatty LLWDF and Beatty LLWDF and Beatty Hazardous Waste Disposal Facility NRC

Participants:

John Starmer, Section Leader, WMLU Jim Shaffner, WMLU John Surmeier, Section Leader, WMPC Richard Lee, WMGT Walt Kelly, WMGT Jack Hornor, State Agreements Offices, NRC Region V Persons Contacted: John Vaden Supervisor, Radiological Health Section Nevada Deptartment of Human Resources Stan Marshall, Radiological Health Section Burt Gray, Radiological Health Section Tom Piyes Site Manager, US Ecology Summary On June 20, 1985, NRC participants met with representatives of the Nevada Department of Human Resources in Beatty, Nevada to discuss and clarify NRC staff comments on the draf t closure plan for the Beatty LLWDF. John Vaden chaired the meeting and gave a history of the Beatty site.

The original intent was to open a waste storage facility on 50 acres of land obtained from BLM. The site was licensed by AEC for disposal of waste in 1962.

According to Vaden the older trenches are very shallow and the waste emplacement practices were somewhat lax. Because of the remote location of the site in an arid area, no formal site characterization was performed. Covers on the older trenches are only three feet thick.

Nevada became an agreement state in 1972 and took over licensing responsibility from the AEC. In recent years burial practices have been revised to include stacking of waste in deep trenches and a minimum of 8 feet of cover over waste.

Vaden went on to note other interesting facts about the site. He noted that it was located on a knoll which sits above the Aramagosa ficod plain. Later, the l

k'* e 1 -

l -

i i

! I NRC staff present acknowledged that observation of the site seemed to confim that it was on a topographic high. However, we noted that there was no

! quantitative evidence to support this conclusion in the closure plan. We  !

j suggested that a valley cross section across the site should be included as l 1 part of the plan. Vaden noted that the nearest domestic downgredient water use  ;

j was 13.5 miles away. He also mentioned that USGS was doing a study of i migrstion (of what was not clear) in the vadose zone in a study area adjacent i to the southwest corner of the site. It was not known by Vaden or site  :

1 USGS . l l personnel in residencewhatwhilethe weexact nature of the experiments is.PeteReston,VA)will were there. Stevens of the USGS (pe; i

be contacted for information.

, We then discussed the possible causes for tritium contamination found in well ,

i 302. These included contamination due to poor monitoring practices, off site

! contamination and possible downward migration from older trenches where bulk .

i material was disposed of. Stamer suggested looking at rainfall records to see if a large rainfall event coincided with the observation of high tritium concentrations. Vaden stated that water never infiltrates deeper than 7 feet as evidenced by a slit trench dug by site personnel "soon" after a " heavy" J

rain.

1 We then got into specific issues related to the closure plan. Veden stated Nevada's intent to accept responsibility for maintaining the site after it was .

. closed and the USE license was terminated. NRC staff suggested that in any i event, the licensee should address all aspects of closure and post closure

! whether or not he was responsible for them. By doing this the licensee would '

i be providing the State of Nevada some insight into what its responsibilities

] would include after closure.

NRC staff suggested a three phased approach for " cleaning up" the closure plan. -

First (1) that a site cheracterization report based on available data should be prepared. According to Vaden there are more data available related to site characterization from USGS and the State of Nevada than is evident from the l closure plan. The report will require the integration of data available from

, the State of Nevada, USGS and the licensee. The site characterization report j should include the development of a physical model of the site which describes '

i expected site behavior. Thelicenseeshould(2)thendoasiteperformance

! assessment to determine significant release pathways. Finally, (3) based on L the foregoing, the licensee should develop closure plans and post closure

! monitoring plans that take into account expected site perforinance. Within this

{ framework we discussed specific areas in which the closure plan appeared ,

! deficient: lack of data and a synthesis of the data (site characterization  !

report), no physical model, inadequate monitoring plan, lack of contingency i planning, lack of accounting for cap stability during extreme surface runoff, i

l i _

o I lack of consideration of cross contamination between the chemical and radioactive waste sites, the inadequate time suggested by the licensee for post closure observation and the need to consider mitigating action in the monitoring plan. We expressed concern about moving the chemical waste j~ demarcation line closer to the radioactive waste disposal area because it reduced the buffer zone between the sites.

Vaden asked the NRC to summarize these concerns, wrote them down, repeated them to us and agreed to forward them to US Ecology. He expected to meet with US Ecology on July 2. To date, however there is no time table for upgrading the closure plan. NRC staff volunteered to provide technical assistance to Vaden in upgrading the plan.

On the morning of June 21, 1985, the NRC staff toured the Beatty LLWDF by the Nevada officials. The tour included a bumpy trip around the entire site on the back of a pick up truck. Some of the observations were as follows:

1) Some of the trench monuments look as though they have been recently

replaced. In most cases brass plaques are original but the concrete slabs 1 to which they are attached look new.

i j 2) There are some gradual depressions in the covers of some of the older trenches. Vaden noted that the state plans to mound some 7 feet of soil on the older trenches as part of closure.

3) There are very few monitoring facilities currently in operation on the site. There are two groundwater monitoring wells operating on-site. One

is upgradient of the disposal units and the other is innediately inside J the fence on the downgradient side. In addition, there is a downgradient well outside of the fence. The downgradient well off-site was originally

! installed with PVC casing, the casing collapsed and the well is to be redrilled and lined with a steel casing.

1 1

4) There is one very large trench currently open and in operation. It has been open for over 2 years and still has about 90% capacity. The trench is about 50 feet deep with vertical side walls in soil with good natural

! cementation. The cement is apparently of the puzzolene type, high in clay minerals derived from its volcanic origin. Because of good soil stability, waste shipments can be and are driven directly into the trench

and off loaded. Waste is being segregated in the trench, neatly stacked

] and covered.

Following the tour of the LLWDF. Tom Hayes, USE site manager took the NRC participants on a brief walking tour of the solid waste disposal facility l

l i

--_ _ ~ - _ _ _ _ _ - _ _ - - _ - - _ _ _ _ _ _

u

}e e

l operated by US Ecology. Hayes noted that the site receives dry solid waste only. This includes sorbed liquids which pass a " paint strainer" test prescribed by EPA.

The facility is permitted to receive and dispose of transformers contaminated with PCB's. The transformers are emptied of liquid PCB's and the empty transformers are disposed of in trenches. The PCB's are collected in a storage vat and transported elsewhere for incineration.

Tom also noted that they are operating under an interim status permit currently but expect to be brought under full RCRA compliance shortly. Hayes hopes that future trenches will not be required to have liners. It appeared that he believed this to be a good possibility.

i i

i l

l c - - - -- _ _ - __ . - - . . -- -- . ,_