ML20151A779

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Response to Util 801010 Interrogatories & Requests for Admissions & Production of Documents.Cites & Documents Instances of Noncompliances Noted in IE Insp Repts.Insp Correspondence,Affidavits & Certificate of Svc Encl
ML20151A779
Person / Time
Site: 02700039
Issue date: 11/03/1980
From: Dragonette K, Hawkins E, Shaffner J, Turi G
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
U.S. ECOLOGY, INC. (FORMERLY NUCLEAR ENGINEERING
References
NUDOCS 8011060248
Download: ML20151A779 (38)
v • d • e


Text

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11/3/80

,/

  • UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i

t BEFORE THE ATOMIC SAFETY AND LICENSING BOARD _.

In the Matter of ) Q  !;lj

) -

no NUCLEAR ENGINEERING COMPANY, INC. '#'

) Docket No. 27-39 '

[59 ,

(Sheffield, Illinois Low-Level 3 Radioactive Waste Disposal Site) ) io ^'s  ;

Y y IS  ;

NRC STAFF'S RESPONSE TO REQUESTS FOR ADMISSIONS, s.JJ '

INTERR0GATORIES AND REQUESTS FOR THE  :

PRODUCTION OF DOCUMENTS OF THE NUCLEAR ENGINEERING C0.

l In accordance with the Licensing Board's "Prehearing Conference Order and Order  !

Setting Time for Discovery," dated September 9,1980, the NRC Staff herein files ,

its response to Requests for Admissions, Interrogatories and Requests for the Production of Documents numbered 11(a), (b) and (c); 12(b) and (c); and "Other  ;

Requests" numbered 1, 2, 3 and 4 propounded to the Staff by the Nuclear  ;

Engineering Company on October 10,1980.S Request For Admission 11(a):

As of March 8,1979, NEC0 had complied with all require-ments of its then existing license and applicable NRC regulations and no condition existed to bar the cessation of all operations at Sheffield and the surrender of its  !

leasehold in the disposal site to the State of Illinois. ,

l I

-/By a document entitled " Objections of NRC Staff to Requests for Admissions, l Interrogatories and Requests for the Production of Documents of the Nuclear i Engineerjng Company," dated October 23, 1980, the Staff objected to admissions, i interrogatories and re uests for production of documents numbered: 1(a),(b),  ;

(c);2(a), b , (c); 3 a), (b), (c); 4(a), (b), (c); 5(a), (b), (c); 6(a), (b), .

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(c);7(a), b , (c); 8 a), (b), (c); 9(a), (b), (c); 10(a), (b), (c); 11(c), fl in part; 12 a ; 13(a), (b), (c); 14(a), (b), (c); 15(a), (b), (c); 16(a), (b),- -

(c);and17(a),(b),(c).

THIS DOCUMENT CONTAINS P00R QUALITY PAGES 8011060 SH '

1 Y, .Res ponse :

Denied. See responses to 11(b) and 11(c) below.

Interrogatory 11(b):

Please describe in detail each respect, if any, in which NEC0 has failed to satisfy conditions under its license or NRC regulations that the NRC deems as prerequisite to NEC0's withdrawal from the site and transfer of the leasehold to the State of Illinois. As to each such condition, please specify the license requirement or regulation in effect on March 8, 1979, upon which the NRC relies to assert this position.

Response

An inspection of the Sheffield LLW Facility on March 9 and 16,1980, noted 6 areas in which NECO was in non-compliance.

It is evident by the nature of several of these violations that site conditions )

were deficient on March 8,1979. (See attachment 1).

Document Request il(c):

Please provide a copy of all documents which discuss any aspect in which NEC0 has allegedly failed to comply with its materials license or NRC regulations. Further, please provide a copy of all documents which discuss or relate to the subject matter of the following:

(i) " Preliminary Report on the Hydrogeology of a Low-Level Radioactive-Waste Disposal Site near Sheffield, ,

Illinois," Open-File Report 79-1545, prepared by i United States Department of the Interior Geological -

l Survey (January 1980); l

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1 (ii) " Interagency Task Force on the Proposed Decom-missioning of the Sheffield Nuclear Waste Disposal Site," prepared by United States Nuclear Regulatory Commission, Illinois Department of Public Health and Illinois Institute of Natural Resources ,

(September 1979);

(iii) " Interim Branch Position - Low-Level Burial Ground '

Site Closure and Stabilization," prepared by Low-Level Waste Branch, Nuclear Regulatory Commission (March 1979) (and revisions thereto).

Further, please provide a copy of all documents which discuss possession of material licensed under the Atomic Energy Act of 1954, as amended, 42 U.S.C. 62011, as a basis for regulating or otherwise exercising authority over the person or entity having such possession.

Response

Cited below are I&E reports contained in DF 27-49 which document instances of non-compliance during NEC0's active operation of the site:

Inspection Date Report No. Violations 11/29, 30; 12/2, '77 27-39/77-03 Waste buried too shallow in T-14a June 29, 30, '77 27-39/77-01 2 monitoring violations November 3, 4, '76 2 minor violations corrected during inspection November 26, '74 27-39/74-01 2 Class II violations 1 Class I violation Also refer to " Interagency Task Force Report on the Proposed Decommissioning i of the Sheffield Nuclear Waste Disposal Site," September 1979. This document i 1

has been provided to NEC0 and is in the NRC Waste Management docket files. c

I

_4 With regard to ll(cliil: '

No documents exist that the Staff is aware of other than the letter submitted to the Atomic Safety and Licensing Board dated April 24, 1980, which was provided to NECO and is in the PDR.

With regard to 11(c)(ii):

The Staff identified the following documents:

1. Memo to Bivins, Thompson, Turi, Wastler from Dragonette dated 9/24/79 (attachment 2).
2. Memo to R. D. Smith from R. E. Jackson dated 1/9/80 (in PDR).
3. Letter to W. J. Dircks from Troy B. Conner, Jr. , dated 1/22/80 (in PDR).
4. Letter to T. B. Conner, Jr. , from R. D. Smith dated 2/4/80 (in PDR).
5. Memo to ASLB from J. B. Martin dated 1/3/80 (in PDR) transmitting copy.
6. Memo to R. Jackson from R. D. Smith dated 10/6/79 (attachment 3).

With regard to 11(c)(iii):_

The primary reference for the document identified was the " Branch Position Uranium Mill Tailings Management," dated May 13, 1977 (attachment 4).

Documents concerning Revision 1, May 17, 1979, include:

1. Letter to Nevada, Soutn Carolina, and Washington from G. Wayne Kerr dated ,

June 14,1979 (attachment 5). -

2. Letter to Kitty S. Dragonette from Dean Hansell dated July 3,1979 i (attachment 6).

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3. Correspondence and license documents in Docket No. 27-48 for NEC0's .

Washington site (in PDR).

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4. Correspondence and license documents in Docket No. 27-47 for Chem-Nuclear's Barnwell site (in PDR).  !
5. Correspondence in Docket No. 27-39 for NECO's Sheffield site (in PDR).  !

I Dockct No. 27-39 is for this proceeding. '

6. " Low-Level Waste Licensing Branch Review of NEC0's Application for Renewal  :

I of the Beatty, Nevada License" dated July 3,1980 in Docket No. WM-13  ;

(in PDR).

7. Memo to Sheffield Service list from K. S. Dragonette dated 6/5/79 trans-  !

mitting copies (in PDR).

A search for documents which discuss possession of material discussed under f the Atomic Energy Act of 1954, as amended, 42 U.S.C. 62011, as a basis for  !

regulating or otherwise exercising authority "over the person or entity  !

having such possession" has not been conducted by the Staff. f Interrogatory 12(b):

Please specify all such radioactive materials subject  !

to NEC0's license, if any, which have not been removed. j b

Response: ,,'

The response to Interrogatory 12(b) is dependent upon the response to Request for Admission 12(a) which was objected to by the Staff. Accordingly, the Staff [

will not respond to Interrogatory 12(b) unless it receives an adverse ruling i on its objection. [

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Document Request 12(c):

Please provide a copy of all documents which discuss ,

the presence of radioactive materials subject to I NEC0's license at the Sheffield site (i.e. , other than buried wsttes).

Response

The following documents which are available in the PDR discuss the presence of radioactive materials subject to NEC0's 11 ense at the Sheffield site.

1. Reports of Inspections conducted by NRC.

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2. March 22,1979 letter from Michael Bell to John B. Martin,

Subject:

Trip Report on Visit to Sheffield Illinois Disposal Site.

3. Interagency Task Force Report on the Proposed Decommissioning of the Sheffield Nuclear Waste Disposal Site transmitted to the Atomic Safety and Licensing Board on January 3,1980, in PDR. Docket No. 27-39.

Other Request 1:

Pleaee provide a copy of all documents received by the NRC from any other party in this proceeding, or any 1 consultant thereto, which pertains to this proceeding i and which has not been previously served upon NECO or i its counsel.  ;

Response: '

Such documents exist in the PDR and the NRC Division of Waste Management docket '

files. ,I!

f

Other Request 2:

Please provide a copy of any other document not herein before specifically requested which pertains to conditions at NEC0's low-level radioactive waste disposal site at Sheffield as of March 8, 1979 or thereafter, or otherwise related to the NRC's position on site closure and with-drawal by NECO.

Response

While the Staff believes that the requests made for documents by NEC0 is inclusive, the Staff has not made an exhaustive search of its files.

Other Request 3:

As to each person within the NRC who genera +"

assisted in the generation of any document pursuant to the request herein, please ident1.,

such individual by name, work address, title or position, and educational and professional background.

Response

Jim Shaffner Low-Level Waste Licensing Branch, WM, NRC (June 1980 to present)

B.S. Civil Engineering, Drexel University M.S. Civil Engineering, University of Maryland U.S. Department of Agriculture as Hydraulic Engineer, Design Engineer and Water Resources Planner (1969-1980)

Gale P. Turi, Hydraulic Engineer and Meteorologist, Low-Level Waste Licensing Branch, WM, NRC B.S. Meteorology, Lowel Technological Institute M.S. Environmental Water Resources Engineering, University of Maryland Sandra Wastler, Structural Geologist, Waste Management Standards Branch, SD, NRC (since 1974)

B.S. Geology Wright State University M.S. Geology Wright State University l

l Owen Thompson, Geotechnical Engineer Hydrologicsl and Geotechnical Engineering Branch, NRR, NRC B.S. Civil Engineering, Royal Melbourne Institute of Technology M.S. Civil Engineering, University of Illinois Ph.D. , Civil Engineer, University of Illinois Research Engineer, Corps of Engineers (1969-1970)

Consulting Geotechnical Engineer (1971-1977)

Lyman W. Heller, Leader of Geotechnical Engineering Section, Hydrological and Geotechnical Engineering Branch, NRR, NRC B.S. Agricultural Engineering B.S. Civil Engineering M.S. Civil Engineering Ph.D. Civil Engineering Department of Navy (1959-1965)

Army Corps of Engineers (1965-1974)

William S. Bivins, Chief Hydrological and Geotechnical Engineering B.S.C. New Mexico State University M.S. Water Resources Management, University of Wisconsin Hydraulic Engineer, Army Corps of Engineers (1966-1972)

John B. Martin, Director Division of Waste Management NMSS, NRC, Washington, DC 20555 B.S. Electrical Engineering, University of Illinois Certificate of Nuclear Engineering, Bettis Reactor Engineering School Department of Navy, Naval Reactors Division (1962-1976)

R. Dale Smith, Chief Low-Level Waste Licensing Branch, NRC B. A. Chemistry and Biology, University of Colorado Radiation Engineer, Dow Chemical Co.

Health Physicist, Coors Porcelain Co.

Kitty S. Dragonette, Health Physicist Low-Level Waste Licensing Branch, WM B.S. Math and Chemistry, Alabama Collete M.S. Vanderbilt University -

Ross A. Scarano, Chief Uranium Recovery Licensing Branch, WM, NRC ..

B.S. , Math, University of Pittsburgh .

Graduate work at University of Michigan (no degree) ,

Supervisor of Criticality Control for Health Physics  !

Project at Westinghouse Astrological Nuclear Laborato,ies (1962-1972)

Manager of Criticality Control and Radiation

' Safety Director United Nuclear (1972-1974) l l . - .- -

Edward Hawkins, Section Leader of Site Suitability i and Design Section, Low-Level Waste Licensing Branch, WM NRC .

B.S. Civil Engineering, Oklahoma State i M.S. California State University at Sacramento Corps of Engineers (1961-1972), Hydraulic Engineer i AEC/NRC(1972-1979), Senior Hydraulic Engineer ,

Michael J. Bell, Chief  !

High Level Waste Technical Development Branch, WM, NRC i Bachelor of Chemical Engineering Degree, Villanova University i Ph.D. , Chemical Engineering, Princeton  ;

Oak Ridge National Laboratory (1968-1972)

AEC/NRC, Senior Nuclear Engineer, Effluent Treatment Systems Branch  :

(1972-1977)

Roy P. Lessy, Attorney Office of the Executive Legal Director, NRC  ;

t Robert L. Fonner, Attorney Office of the Executive Legal Director, NRC r Edwin J. Reis, Attorney Office of the Executive Legal Director, NRC j t

I i

Other Request 4:

Please provide the information requested in (3), above,  :

as to each witness which the NRC intends to call at i hearing, and describe the areas in which the witness .

will testify. Please provide a copy of any documents [

upon which the witness will rely if not alreaoy j provided. l Response: f The Staff has not yet determined the specific witnesses, areas of testimony,

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or materials to be relied upon by such witnesses for the instant proceeding.  !

It is likely, however, that such witnesses will be among those listed above in  ;

response to "Other Request 3." '

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Attachment 1 j/ "" UNITEo STATES fw . NUCLEAR REGULATORY COMM!SSION

, f i , REGloN 111 f., $. g; p j j

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. , %, j GLEN E LLYN, lLLINols 60137 e...a WAR. 30.1979 Nuclear Engineering Company, License No. 13-10042-01 Incorporated ATTN
Mr. James N. Neel President 9200 Shelbyville Road P. O. Box 7246 Lousiv111e, KY 40207 Gentlemen:

This refers to the inspection cond eted by Messrs. A. B. Davis, T. H. Essig, and W. B. Grant on March,9, 1979; Messrs. A. B. Davis, W. B. Grant, and R. A. Paul on hkrch 16, 1979; }k. R. A. Paul on March 21-23, 1979; and Messrs. C. J. Paperiello and R. A. Paul on March 29, 1979, of activities at Sheffield, Illinois, authorized by NRC License No. 13-10042-01 and to the discussion of our find-ings with Messrs. Baer and/or Moore at the conclusion of each part of the inspection.

The inspection was an examination of activities conducted under your license as they relate to radiation safety and to compliance with the Commission's rules and regulations and with the conditions of your license. The inspection consisted of a selective examination of pro-cedures and representative records, observations, independent measure-ments, and interviews with personnel.

During this inspection, certain of your activities appeared to be in noncompliance with NRC requirements, as described in the enclosed Appendix A.

This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Section 2.201 requires you to submit to this office within twenty days of your receipt of this notice a written statement or expla-nation in reply, including for each item of noncompliance: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance vill be achieved. Your response vill be taken into consideration in determining whether fur ther enforcement action in the form of civil penalties and/or orders may be required. ~

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.- Nuclear Engineering '

L Company, incorporated .

l In accordance with Section 2.790 of the NIC's

  • Rules of Practice,"

Part l l

2, Title 10, Code of Federal Regulations, a copy of this 1etter, the enclosures, and your response to this letter will be l placed in the NRC's Public Document Rocan, except as follows. If l

I the enclosures contain information that you or your contractors i believe to be proprietary, you must apply in writing to this office, 1

within tsenty days of your rocaipt of this letter, ce withhold such informaties free pehlic disclosars. The application amat ime.lude a full statenest of the reasema far which the information is considered proprietary, and should be prepared eo that proprietary informatico identified in the application is contained in an enclosure to the application.

  • Ve vill gladly discuss any questions you have concerning this ins pe c tion. '

Sincerely, James C. Keppler Director Enclostre: Appendix A, Notice of Violation ec w/ enc 1:

Central Files Reproduction Unit MRC 20b FDR

, NSIC Mr. Dean Fausell, Office of Assistant Attorney General _

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h Appendix A ,

NOTICE OF VIOLATION Nuclear Engineering Co=pany, License No. 13-10042-01 Incorporated Based on the inspection conducted on March 9, 16, 21-23, and 29, 1979, it appears that certain of your activities were in noncomplianca with NRC requirements, as noted below. Items 1 throu'gh 6 are infractions.

1. The Code of Federal Regulations, Title 10, Part 30, Paragraph 30.52(a); Part 40, Paragraph 40.62(a); and Psrt 70, Paragraph 70.55(a) require each licenses.to cake available to the Com=1ssion for inspection, upon reasonable notice, records kept pursuant to l the regulations in Part 30, Part 40, and records kept pertaining to the receipt, possession, use,'acquisitien, import, export, or '

transfer of special nuclear material. ,

t Contrary to the above, on March 21, 22, 23, and 29, 1979, the licensee would not make available to the Coe=ission.for inspection  ;

records related to byproduct, source, and special nuclear saterials.

Specifically the licensee would not make available records related to trench su=p and surface runoff monitoring, trench cap material .

density, security patrols, date on water pu= ped from trenches, personnel exposure records, personnel bioassay records, and airborne .

sampling records. #

2. The Code of Federal Regulations, Title 10, Part 30, Paragraph i 30.52(a); Part 40, Paragraph 40.62(a); and Part 70, Paragraph 70.55(a) require each licensee to afford to the commission at all reasonable times opportunity to inspect typroduct, source and  ;

specirl nuclear material, respectively and the premises and i facil: ies wherein these caterials' are used, produced er stored. t Contrary to the above, on March 29, 1979, the licensee refused to provide admittance to the Sheffield Burial Site so as to permit l  ;

the Co==ission the opportunity to inspect the Site.  ;

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Appendix A ,

3. License Condition 8 states in part "...the licensee shall conduct operations in accordance with application dated November 4,1976, as a= ended November 18, 1976 and December 10, 1976." The applica-tion dated November 4, 1976 contained the Site Operations Manual for Low Level Rad-Waste Disposal at Sheffield, Illinois.

Section 4.1.1 of the Site Operations Manual requires principal perimeter security to be maintained by a continuous six foot chain link fence topped with three strands of barbed wire. It further requires the integrity of this fence to be maintained at all times.

Contrary to the above, on March 9 and 16, 1979, the integrity of the fence had not been maintained'in that there were large separa-tions between the top of chain link material and its upper support and strands of barbed wire were missing in areas vest of the parking lot and on the east side of the burial site.

4. License Condition 8 states in part "...the licensee shall conduct operations in accordance with application dated November 4, 1976, as amended November 18, 1976 and December 10, 1976." The applica-tion dated November 4, 1976 contained the Site Operations Manual for Low Level Rad-Waste Disposal at Sheffield, Illinois.

Section 4.3 of the Site Operations Manual require. r. :urity personnel to patrol the Burial Site property and storage areas during periods when Burial Site Operations are suspended. Among the guard's duties is a requirement to make periodic patrols of restricted areas.

Contrary to the above, during the period from March 8 to 16, 1979, no security patrols of the Burial Site had been performed.

5. License Condition 8 states in part "...the licensee shall conduct operations in accordance with application dated November 4, 1976, as amended November 18, 1976 and December 10, 1976." The applica-tion dated November 4, 1976 contained the Site operations Manual for Lov Level Rad-Waste Disposal at Sheffield, Illinois.

Radiological Control Procedure SI-002, Section 6.1.1 of the Site Operations Manual requires sump monitoring stations for trenches 14 and 14A to be checked on a weekly basis for any water accumulation.

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, Appendix A .

l Contrary to the above, for the period February 27 through March 16, I 1979, trenches 14 and 14A rumps were not checked for water accumulation. l l

6. License Condition 8 states in Part "...the licensee shall conduct I operations in accordance with application dated November 4,1976, as a= ended Nove ber 18, 1976 and December 10, 1976." The application dated November 4,1976 contained the Site Operations Manual for Low l Level Rad-Waste Disposal at Sheffield, Illinois.

Radiological Control Procedure ST-002, Section 6.1.2 of the Site Operations Manual requires surface runoff sa=pling station "S" to l be monitored on a weekly frequen y.

Contrary to the above, for the period February 27 through March 16, 1979, surface runoff sampling station "S" was not monitored.

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Of?TCS.0F INSPECTION AND .Eh70TsCURHT

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, , EC10N III R.:por.: No. 27-39/79-02 Ibchec Mo. 27-39 License No. 13-30042-01 Licensect Nuclear En3f.r.cering Coc:pany Inc.

9200 Shalbyv111e Road Sutta 525 -

P. O. Box 7746 Lottisville , KY 40'.07

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Tec111t.y Mr.me : Nucicar T.ngi'neering Shefficid, IL Burial Facility Inspection At: Sheffield, IL Inspection Conducted: March 9 and 16, 1979 Inspectors: A; 3. Dav #

bNJ T. H. Ecudg (hrch J only) Si y

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  • r h.fL-W. B. Cra k 2I O 4;0 m M-{'

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LR. A. Isul (darch 16 only) ?7 7/ 7 --

App rove d Ey : A. B. Devin, 3!*A/[79 Fuol Facili.ty and Ma t.erfalu _

Safety Branch -

Insocction Sme.nry .

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' Insnection on &rch 9 and 16.1979 (Repc,rr. No. 27-39/79-02)

Arey:: Inspected:  ;

of the site. Lecluding: Special, announced inspection to decert:.ine statyt, radiation surveyn, physical tour of the site

  • radioactive material ototus, site o c c u rit:.' ,

The inspection involved 26 inspcetor-houro on site by four NRCenvironmental ina '

inspectors.

ne s ult s,: Of th /

four arcas inspected, four apparent items of noncomplicaco with NRC regulations were identified, three of ubic*u.were,:

inf ractiono and one uns a deficiency. (Licenac Condition B, cite . '

ce'cu rit y, integrity of fence - Paragraph 7a) (Iicense Condition B ,--

envitontr.ents1 sampling, sump samples and surface water runoff - ~.

Paragraph 8) (License condition 8, security personnel not employed - ..

Paragraph Parat;raph 9)8) . (Licenna Condition B, organi::ational pocition deleted.- ~ '

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1. rernone Contceted

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T. Beer, Vice Prnoident. Nuclear EngineerinE Company (NP.CO) y R. more, Sito Manager, llECO, Shef fiald .

J. Blackburn, Illinois Department of Public Health (Murch 9, 1979 portien of inupaction only)  :

A. A:aburst , Radiction Safety Officer, NECO, Sheffield Site

2. Cennrul

'Ib2 incpection was conducted in two parts. The first p:rt vns conducted on March 9 and the second part was conducted on Harch 16, 1979. The purpose of the inspuction was r.0 (1) deten,ine the prene.nt status of the Sheffield lou IcVel radioactivewaste$disposa) site relative to the require:nents ,

of Licanso No. 12-10042-01, (2) conduct radiation surveys of  !

f acilitica und b'nildincu which were stated by the licet.sce to havu Won decoutar.inated, and (3) determine if .111 non-boried

  • rr.diesettve weste had been re;:eved from the f acility. This special inspection was conducted 'at this ti.ma because Nuc1 car EnSineering Company (NT,CO) in a letter to INC dated March 8 '

1979, he.d utsted t.hcir unilaterni intention to terminate the liccuse.

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3. Licenoce Action on Prr:vious_ Inspectico Fin' ings d I Not inopected. .
4. Radiction Survnys Independent radiation imrveys vere conducted by the inspectors.

Direct radiation not.sure=ents vere taken usir.g NRC survey insertmente Eberline E5005 Sr 322 und Victorcan Thyac III calibrated on January 23, 1979 and February 10, 1979, respectively. In -

additien, ccear sampleo were take.n in vr.rienc locations of these

  • buildions to assess the dearoc of removabits cont ar.ination. The e car snaplen vere analyzed at the NFC-P.egion ITT Laboratory.'

One, (M;L).

sar:ple was alco unn2yzed at the Argonne National Laboratory Lt acceptance criteria for those rncacurements uere tha demin'irms criterin provide in Drnf t Guidelines for Decontoninntion of .

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Fr.-111tica and Equip:: ant Prior to Relense for Unrestricted Use . ' ,

or Totmint.tica of License for Byproduct. Source or Special Nu.cicir liatcrial dated D:ccmber 3 975. / -

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W cirect rt.: .atiet.. .;4asttrementa varc nr.de' a..t the ..aste Solidification '

2t 11 ding, Truck hy, nna 2*miptansuc.e Shop /Chutige Roor. . (Tita Office Buf.1 ding, which As located outside of the restrict.ed area, ,

l us.t not surveyed). direct radiation levelu were siso censured at j

eclected lomsticas in th3 equipment yard and at trenches where sink ,

hoics were obnor .nd (Paragraph 5) . Radiation icvels at all'arcas except thn sink holes' vere approximately 0.02 1.tR/hr. The radiction surveys of the sink hoics vara parfor:ned at distcncas ranging frore gros:nd surface (i.e. , at the " couth" of the hole) to opproximately four feet below the ground surinec, the location depending on the -

acccasibility of the uink hole. Radiation levels ranged from 0.02 sa/br to 0.3 mR/hr, the latter being rocasured at the "cosr.h" of the cink hole naar Trench 23. '

Th: ur ear sanple resul ts were:

Itesul t Alpha- Beta Loestion (dom /le6 ca2)_ ,(dpn730 em2) j 1 Maiut. bay - shop are.a (1 0  !

south end, near dorg . l 2 5' tore rdo nourec O 7 3 Drum in storage arer.

(3 0 4 North vall 2 25

- . 5 Floor sont uall 2 0 5 Ecut wall 3 16

. 7 s.I. floor 5

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. 3 S . it. corner f1w r .

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9 Vest vall* 5 m 125 o

10 West' floor center [ (1 13 e5 13 N.W. corner floor y (1-s O

12 Inafda washing tacheno p '3 0

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, 13 Under clotheo dryer 2 0

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14 Floor N.2. corncr 3

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15 Sh::1f or.se 'umil 6 6 0'1 16 Shelf west wall  ;; 5 17 .

17 Sump cover incide sail (1 11 .

center of room *

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18 Floor E 1 5 between conter of 2 4 1-S vell door and' drain 19 Floor 1:n between center of N 2 vall and drain (1 20 Floor - centur of N un31  ; 3 g

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Location, Ota

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"Thece results ov.ceed the. detaini:aua criteria for dodine-125; t.htrefore, .7dditice.al decontrutination vill be ro.1uired, ho items of noncompliance or dev3.ctions vere idantified.

S. Tour of thi Tuanty Acre Burial Site 1 1 . '

i Tao inopertors toured the buria1 site on Wrch 9 and 16,1979.

1.1 the burial coveral locationu. tranch area uick. areaholen (settienents) were found at '

ernllasc being aboutThe 3 ft.hole varied in cite, uit h the

,t,5 ft. zad the largest 1 e1.nc about 1.0 ft. nguare. The '

4 ft. depth of the holco ranged frc:n about 2 to 11.11.es were found in that following'loestions:

(n) Trench 23, cast end (1 hole)

(b)

Bdveen of trenchca 14 and 14!. (3 holca npaced along the length tbs trecehes) .

~

(c) Trcoch 6, north ed;c (1 heln)

'Ina si;:e Shef field,0:mratico.s Illinci.t Har .m1 for Leu-Level Rad-Waste Disposal at

(! s te Operutionn 2:auuc3 ),

states that.

m !ntenance condit!on: willsuch wiko he perferimd rr to repair the trenches whau wizther r practicablu.

hava. not yet occurrsd  : Ap dns. Practicabic conditions Mnott ly Trench Innecticn recordr. chov the inst inspectiou of .

trinch condition vec pnt fomed by the licennett l'.09, De an.1 c ert.b er the 3 act trench maintenanen was performed onon Febrecry 27, 19, 1978. .

f.:o .iterra of noncomplinoce or c'.eviationo were id entified. -

5 Ra M o.netive Meterici Statun -

Vi w a obnetvations and kt et radiation nurveyn diar.ussed in scetf on 4 of thic report indicated t1uit n11 radioactive storial ,

to be buri2d or processed had been renoved from the fccility.

Several nLora room.

exc=pt inntrimont check soureco ure In addition. the plastic lined pend inside thastill located iu the -

Buri 151tc. which had been used to stoic ic.c. with tritium , -

concentrations sbove the 2 nC1/1 reporting icvel, still exints .' .

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  • Csu 1979 Liqu.id Shipmtat Log (b)

.s . The tuo 1stemt Rndioactive Ships'ent Recordr. (RSR'u)

'Ihc Liquid !Jhipment Los shoved all liquids roccived had been solidified and shippod from"the site. The 'lest race.,1pt and

, .ohapment had occurred on March 7, 1979.

Tha ESMn 'did not contain a running inventory so they could not be no26 to cor:coborate thsc all so13.d austerial hcd been shipped f:ro: the site.  !

Do items of noncomplience or deviatinns were f dentified.

7. 31re Sectr-ity 1
n. jgru :-ity Tence _I_ntagfg i The inopoctors oboerved damste to the zi:: foot chain link fence Wich surrewnde tho burial nite. An area c,f the i i

fence vest of the parking ; tot cod ercas on the eaat aide of the' burial cito aledg a road but.it t o th e 11. S.  ;

Ceolor,ical Curvey Tunnel r.hovad damagad. Tne. tence chain link r.atorini wou ueparated frew its upper support recultion in 3c;a of 2 to 3 fact do height. Tho upper r.upport was dise.usaged in tuo locationn.

cissing from the fence tcp at one Strands of barbed udre vare location.

Sactica 4.1.1 of tha Sito Operationc Mt.nual statSc th:.t principoJ. perineter necurity of the buri11 nite is maintr.ined by a continucun cix foot chain link fence topped vit.h t.hrou strando of bnrbod wJre. It further st.atas that the integrity of thi.c paritacter f ance raunt be =aintnined at all times. i Tha condition of the fence vac not in conformance with this '

Manuc.1 requireocne and fc, therefore, in noncocpliance with -

Licensa No. 13-10042-01, Condition n.

b. Othar Sneurity Measures By ecutnet with the County She rif f, obcewation, discussion with a 11cancca reprasentat.1ve , and review of ree.cr.tc, ths inspectors deter =ined the fo11otting re.lative to securityt . .

(1)

The County during Sharf.ff makes uou-busfr.ess huuru. perdt.dic cheeks of the foeility During the March 16 incpectic.u. ,'

an Illinois Statt Policeman stopped at the cito.

(2) "Ihe licen sec has not ecployed occurity personnel froa private siencien and is not conducting p2riodic putrole, -

of the Durcial Site redLricted nrea as required by Section 4.3 of the Site Operntfnnn Manual. Therefore. che 11,cc' ctier. 2' 2

in in noncompliance vit.h Licenne No. 13-1004/'-01, for.dit.io.3 !!.

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C' ne '"C0 industriol occurit(... Jrogr:.. . in in effect.

i h Finc; the buriel zite in viinin MT.Cu propctt/, this i

cito benefitt; fro =i the industrin1 security p,;cgr:a. l (4) NE.0 personnel hr.ve continuud checking to anr;ure bttrid zite gatoo are closed and locked. Thn atite.d ter.ncn for this check to that there is soca HECO ovaed property inside the burial'aite fence.

(5) Licensee persontel intend to no::ify rpproprhte l authorities of c.ny security or enercency proMurc  !

'rala tiva to the burial s;ite shno.1d any occur.

vould act Th-y as responsihic citir. nc in this rc,;ced.

(5) Tlin 1teennen in continuing to twintain r.hc Af ter 4

Shift chech and Veckend Log. which lucludes a security s tuce tsart:h ts, 19 /S , sin ent.riac hsve b entered presence et into thir. los indic: ting liconaec perse,enn noci hourn. the site duriun veckend er non day shi.ft c.

Site Secu'ftr Audits Sectics,4.0 stateu tant of the Radiolo'gical Control en.1 Safrty Hr.nnat the Ch1ef Fadiologice.1 Control cod s:Cety Officer of villt be eat a s.di directly responsible for the inpleecntation of.Pidiological Cuntrol and Safoty willprogrnm and an in depth audit o qt:srte rly. be conducte.1 is revi e red. As part of this audit, the burial cire security thia audit vus Accordiun 1.o a licanoce repensentative, conduct ed on Marc.h 0, ~19 79.

Th'e report for thin nudit ha:s .

not yet been written. I t.

vill be reviewed during a future inspection.

In nddition, tho 11censo. conduct.e en

.atnAnictr:.ttva aurH t en c quxrt.crJy hanis by persons appointed by n ecmber of corporato r:nneger::ent which includoo o review of site security.  :

inspe ct 5 on. Records of thesa uudits ve.re reviewed during this Yne last audit was performd February 9, 1879.

T n> ite=s of noncompliance were identified.

D.

En M rontental ibnitoriny[ Program __

The environ which is required .antalby v:enitoring Conditier.progem No. for trenches 14 and 34A ,

Atendment No. 11, ut.s c>:aznined. 8 of Line.tsso Mo. 13-10042-01, The prograui. which is conducted ,

eccording regttires ptto Procedure S1.002 of the Site Operatiord Manual rr.anont ,

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In additt on, operational portabic grab air r.amples and equecu  !

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t r a nch d .... Ihr.- ..la vere revieved f or f.'- pe ri- of Jnuunry 1973 l

".hrough' ?cb runiy ;'? , 19 79. ,This vsview and dinenacio.n with

) # coucoe reprenantativou verified that cemple collectics und unutyens have been performed as required through that date tud .

thac :xtinn 1cvele have not Lt.en execeded. However, the ucchly nanplins of trench 14 and 14A numpo nud the surface run off scppleo hava not baan enllected f or the vacks of March ! nud 12.

This constitutes noncor.pliance with Licence Conditinn No. 8.

1 The licanbue enmples ground and surf ace water, soil, ned vegatetion ou a quarterly basis, nnsi te and offsj te. 3he sempic:  ;

cre'enclyced for t. rose alpha, grosn bnta and tritium. The j 1cupectors reviewed these vample resuJ.tv for calendar year 1978 i and no probica areas or ano=slouc sesults were noted. i s

Dr.t Itea of noncompli>qce wun identified. .

9. Uceties 2.2.1 of the Site operations finnnal requiren r.he I crnamiestioaal pooition of Cencrcl Msnager Eastern Operationu.

Variono cacedoua of thic 1knua3 (o . g . , 4 . 3 .1 .'.n d 4. 3 )

dencriba f unctions of or notifications to the General Mannger {

Es nt o rn Oparntions. Thir. position dons act presently exist da i the organizstion. The rer.p.ess1bilities are being ccrried out  !

by other individuals, primarily by tbn Excentive Vice Pr.tr.idesc.

t Yhn in11ure to have a Gaucral Mannger Eastern Operctionn is  !

contr:ry to P1gure 2.1-1 and is, therefore, in noncomplionen  !

with .ticence No. 13-10042-01 Coudition 8. '

Ona itsa of,nencomplie.nen was identified. I

10. _E::it In t e rvi ew The f nspectore pet with licensee representativen (deuoted in Peracraph 1) at the conclusinq nf both parto of this ircpectinn I (March 9 and 16.1979). The folic +ing items were discussed:  ;

r

a. The itera of noncomplionec reintive tn rhn sumdition of [

the se.curity fenen. (Paragraph 7.n) I

b. Other security raeosures and cud J ts. (Par.,grapha 7.1 and 7. c) [
c. The item of noncompliance relative co the failurn to perfore weelly campling of trenches 14 nrad 14A sue.pc and curface

.uu eff water. (Paragrnph 8) j

6. Tho status of smear sample results and the possibility f j

thct iodine-125 1 cyclo at tuo locations e>.cceded the  ;

dcninicus criterie. i

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. .CE : In a telephone converwu tion on Murch 19,197*),  !

the Site Manoger was informed of the reculto i reported in Section 4 of thia report and agreed I to further decontaminate thn tress with high (

iodine-123 curface conta instion Ivvele. - !

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. trauch usintenance usa not yet practicable due to e,rnena  ;

cenditie:20 but moon would be. The licencoe sected that trunch m.aintenance la no loor,cr a liECD rut.ponoibi?.ity, ,

  • 2. Thes 11censee audio taped the exit intchview and other  :

dincur.cio:J: during the inspection. He nareed to provide  ;

tbn incpectors with a transcript of the 4.nf omation tapud..

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NOTICE OF VIOLATICN .

t Waclant. Rugineering Company Licenue No. 13-10042-01 Lased on the inopection conducted on March 9 and 16,1979, it r rpears that tettsin noted below.

of your activition were in noncompliance with HP.C tequ2rementr, as .

Irons 1, 2, and 3 are Inf ractiono; item ,4 is a Deficiency. '

ticecce Condition B states in part ". . . the licensee shall conduct i oparstionn in accordancu with application dated Noveuber 4, 1976, ac "

cuanded Hove =ber 18, 1976 and Dece=ber 10, 1976."

The opplicatien dated Nove=ber 4,1976 contained the Site op= rations banual for Low Level Rad-Waute Disposal at Shef fic1d, Illinoic. .

1.

Seiti.on 4 1.1 of the Site Operationo Manual requires principal '

periteter occurity to be maintained by a continucus six foot chain link fence toppad with three otrands of barbed wire. It furt*nct i requires the integrity of this fence to be maintained at r.11 tinct.  :

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  • Centrary to the above, on Merch 9 ar.d 16, 1979, the detagrity cf the fence had not been naintained in that I bctueen the top of chain link materini andthnreits were'large separations upper support nr.d l strando of lurbed wire were missing in areas vest of the perking lo t a nd on t.hn ca s t side of the burini site. ,

l 2.

Section 4.3 of the Site. Operations Manual requires security personnel employed by privnte agencies to patrol the Rurial Site property and  ;

i itorage nrcra during pericdc whco Burial Site Operations are cuspended i Anang the geord's duties is a requirement to make periodic patro15--

of restricted creac. -

Coatecry to the zbove, ducirg the period ft om Harch 8 to 16,1970, I no tecurity personnel from priv:ta agenciec had been employed and .

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no patrels of the Burial Site htd been performed.  ;

I.

K2diologier.1 Control Procedure SI-002, Section 6.1 of the'sste Operations Manual requires sump nonitoring stations for trenches 14 and 14A to be checked on a weekly b=sia for any vetor accuuulation.

It tico require.s surface runoff sampling vtction

'S" to be conitored on' a veckly frequency.

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~5" tre.nchos 14 and 14A siunpa and surfaen runoff on have not been checke.1 for water aces:mulation respectively. '

anoni and tored,

, 4. ,

Nnager, F. astern Operationc be appointed e oral ve b

Of ficer, Preaidcut or tha Ex2cutive Vice Procident.

contrary to the above, during the period of Deccobe.r 1

1979, no Cencral Manager, E.+.utern Operations wac oppo.197/' to intod.

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. . Attachment 2 SEP 2 41979 NOTE TO: W. bivins, NRR

0. Thompson, NRR G. Turi, NRR S. Wastler, NRR FR0ii: Kitty S. Dragone tte, Section Leader f Licensing Sectita, Low-Level Waste Licensing Branch Division of Waste Management

SUBJECT:

TASK FORCE REPORT For your information and review, attached is a copy of Interagency Task Force Report on the Proposed Decommissioning of the Sheffield Muclear Waste Disposal Site,* September 1979.

Larry Brenner would like to meet and discuss agency review and development of a position on this report. We should also think of supplements we could add as an agency, e.g. health and safety significant of current migration, cost / benefit

__' analyses, more detailed consideration of p~ros and cons on alternatives, interim

~~"

license for stabilization.

The site description sections on groundwater, surface water, and geology plus the USGS report on the site due in a week or so by latest estimate - can be input for the EA.

I will be in touch the week of October 1, after I finish a training course September 24 - 28.

Original Signed By Paul H. Lehhus Kitty S. Dragonette -

Section Leader, Licensing Section Low-Level Waste Licensing Branch Division of Waste Management cc: Larry Brenner, ELD g y..

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MEMORANDUM FOR: . Rob'ert Jackson, Chief '

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' Geosciences Branch'~~ : : ~

_ Office of Nuclear Reactor Regulation

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FROM:- '"

R. Dale Smith, Cliief. :' .E .-

. . Low-Level Waste Licensing Branch

  • Division of Waste Management - .'~I J .- -
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Office.of Nuclear Material Safety and Safegu.ards

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SUBJECT:

REQUEST FOR TECHNICAL REVIEW OF INTERAGENCY TASK FORCE

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L REPORT ON THE PROPOSED DECOMMISSIONING 0F SHEFFIELD NUCLEAR WASTE DISPOSAL SITE  ?

. We'would like your review of the subject report, particularly in the 'areasr- '

of foundation engineering and geology. Copies of the report were provided

..~ to 0. Thompson and S. Wastler on September 24, 1979.

. l

. We plan to use parts of.the interagency report directly in preparing the. -

preliminary draft environmental assessment on Sheffield. Our current plans are to directly incorporate the sections dealing with geology and foundation '

engineering. .

.-We would appreciate receiving your comments by November 30,1979 in or&r t.o maintain the project schedule.- If there is any difficulty with meeting -

this schedule, please contact me by November 5,1979. ,

~~

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.' . R' Dale Smith. Chief ~

. Low-Level Waste Licensing Branch '

Division of Waste Management

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rf Office of Nuclear Material Safety . ' -

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and Safeguards. ...

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L. Heller'

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' UNITED STATES NUCLEAR REGULATORY COMMISSION L, Tf :3 '977 BRANCH POSITION - URANIUM MILL TAILINES MANAGEMENT Uranium Recovery Licensing Branch

Background

A major expansion in the uranium industry is taking piace. Many times more uranium will be extracted in the upcoming decades than has been extracted so far. This requires that the NRC examine very closely the past problem areas encountered in the uranium industry and make sure they are not ecmpounded on an even larger' scale.

l 4

The first major portion of the industry within the Ticensing juris-diction of the NRC is uranium milling. The major probTem encountered in past milling operations is the management of tailings generated by the milling process. Although the concentration of radioactivity in i

the tailings is relatively low, control measures are necessary because l of the large quantities involved and because of the long half-life of l the parent radionuclides that are c esent.

The managecent of mill tailings has received increasing attention and interest in recent years from involved federal and state agencies and frem environmental conservation groups. This interest has resulted from studies carried out during the last decade which have indicated that uranium mill tailings, if not properly managed and controlled, could present a potential public health hazard. The most vfvid example, of course, is the situation that occurred in Grand Junction. The remedial actions detennined necessary to correct the misuse of tailings in the construction of heres, schools, and other public structures are continu-ing at substantial cost to the Federal Government and the State of Colorado.

In addition, final technical resolution and financial responsibility
for the disposition of tailings at the 22 " inactive" sites being evaluated

< by ERDA will further increase public, state, and locai as well as con-  !

gressional concern with prevention of similar problems in the future.

It is incumbent on NRC and the uranium industry to assure that current and future licensed milling operations do not result in similar i

si tuations.

1 i Towards this end, the NRC staff has developed performance objectives

for an acceptable tailings management progran based arr the most up-to-date technology available today.

Position

The staff is of the opinion that an acceptab7e tailings manage =ent '

program will vary depending on site or region specific parameters, such as geology, hydrology, and meteorology. Viable methods of tailings l

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management for a specific m'111 location may include classic impoundment  !

behind a dam, deep mine burial, open pit mine burial, specially excavated pit burial, or even elimination of radioactive waste by process variations.

l Considering the many varfables involved, the staff will use the following performance objectives to detennine the adequacy of proposed site specific tailings management programs.  ;

_ Siting and 'Desien

1. Locate the tailings isolation area remote fmr people such that population exposures would be reduced tn the maximum extent reasonably achievable. i
2. Locate the tailings isolation area such that disruption and I dispersion by natural forces is eliminated or reduced to the '

maximum extent reasonably achievable. t

3. Design the isolation area such that seepage of toxic materials t

into the groundwater system would be eliminated or reduced 3 to the maximum extent reasonably achievable. '

During Ooerations I

4. .

Ciminate the blowing of tailings to unrestrfeted areas durir.g normal operating conditions.  ;

t post Reclamation

5. Reduce direct gansna radiation from the impoundment area to

, essentially background.  !

6. Reduce the radon emanation rate from the impoundment area to about twice the emanation rate in the surrounding environsj
7. Diminate the need for an ongoing monitoring and maintenance i program following successful reclaration. '
8. Provide surety arrangements to assure that sufficient funds  ;

are available to complete the full reclastion plarr.  ;

Imolementation ,

All objectives will be considered and satisfied during the review c-  ;

of proposed tailings management programs fer new mi1 Ting operations.

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3-current licensees' tailings nanagement programs will'be reviewed to detennine the best way to apply objectives 4 through 8 to the extent practicable.

During the course of license renewal reviews, the locations of existing tailings areas will be reviewed considering objectives 1 through 3 to determine if sufficient cause exists to require an alter-nate disposal location for tailings generated by future milling operations and the relocation of existing tailings at the time of mill decomissioning.

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Attachment 5 l

/ *4 UNITE o STATES

,', .. [ .. . .,. J'g NUCLE AR REGULATORY COMMISSION i f' ? :a j j}.

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.. WASHINGTON, o. C. 20!$$

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  • ON 2.; 37g Ref: SA/JFK

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Nevada .

South Carolina Washington

. .. The NRC's Division of Waste Management is amending all NRC low-level

. waste burial ground licenses to add site closure and stabilization f requirements. They plan to meet with Washington regarding addition of Tl 2J site closure and stabilization requirements to the State and NRC-licenses issued to the Nuclear Engineering Company (NECO) for the site at Richland. The SNM license for the Barnwell, South Carolina site is being amended at NRC initiative based .on no objection by the operator, Chem-Nuclear Systems. Copies of the Chem-Nuclear license amendment, and referenced Low-Level Waste Branch Position are enclosed. The

, license amendment is in final concurrence.and we expect it to be issued shortly. *

In the enclosed Branch Position, recent events have shown the critical need for explicit planning for si'te closures; and we recommend that you implement similar requirements to your low-level waste burial licenses. If we can be of assistLnce in implementing the Branch Position, please let us know.

.. <W *(b3f G. Wayne err, Assistant Director for State Agreements Program Office of State Programs

Enclosures:

~

1. Amendment 15 to License ?6-13536-01
2. Branch Position, Rev. 1, 5/17/79 cc: All Agreement State & Illinois, w/ enc 1.

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, Sc ;,[,v',e WILLIAM J. scott ATTORNEY GENERAL j STATE OF ILLINo!S TELEPHONE ISO NORTH LA S ALLE STREET 783*8800 .

CHICAGO 60601 1

1 .

July 3, 1979 Kitty S. Dragonette - .

Low Level Waste Licensing Board Division of Waste Management Washington, D.C. 20555 Re: Revision 1, Branch Position

" Low Level Waste Burial Ground Site Closure and Stabilization

Dear Kitty:

The following are comments regarding Revision 1 of the Branch Position Low-Level Waste Burial Ground Site Closure and Stabilization.

These comments in no way should be interpreted as a waiver of Illinois' position that it is the applicant at Sheffield which maintains ultimate responsibility for the site rather than the state. These comments are submitted because Revision 1 is a generic document applying to all low level sites.

In making funding arrangements an applicant should insure both the ivailability and the adequacy of funds. (

Reference:

Performance Objective 3).

The third sentence in Performan'ce objective 6 referring to parking lots should be eliminated. The use of Low-Level Waste Site for such a purpose may effect the permeability of the trench cover. An applicant should be required to demonstrate that such use would have no ,

deleterious, effects ra%er than to assume by way of example that such an activity as a parking lot is appropriate.

Performance Objection 12's example of a fence as an acceptable ..'

possible security system should be eliminated. In many situations a fence may not be an adequate passive security system.

Performance Objective 14. Not only must corrective. measures be implemented by the licensee to deal with radionuclide migration but these measures must be successful. (See, letter of Ed Reis of NRC Staff, April 10, 1979 to the Sheffield licensing board) . j

. l

4

. Conditions 10, 11 and 16 from the letter of Ed Reis of. i April 10, 1979 to the Sheffield licensing board should be generic  !

requirements incorporated into the branch position. Each of these  ;

requirements will contribute to the public health and safety. l

. i Very truly yours, l M/ S \

DEgiHANSELDJ {

Assistant Attorney General ,

Environmental Control Division  !

188 West Randolph Street Suite 2315 '

i Chicago, Illinois 60601 i

[312] 793-2491 '

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UNITED STATES OF AMERICA

' NUCLEAR REGULATORY COMMISSION  ;

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD  ;

In the Matter of ) -

NUCLEAR ENGINEERING COMPANY, INC. Docket No. 27-39

)

(Sheffield, Illinois Low-Level )

Radioactive Waste Disposal Site) )

AFFIDAVIT OF EDWARD HAWKINS Now comes Edward Hawkins and being duly sworn, deposes and says as follows:

l

1. I am employed by the U.S. Nuclear Regulatory Conmis .on as a Section i Leader, Site Suitability and Design Section, Low-Level Waste Licensing  !

Branch. ,

2. I am duly authorized to answer "Other Requests" numbered 4, and I  !

hereby certify that the answer given is true and correct to the best of my knowledge. l A Lbl%YY i.. a

  • Edward Hawkins '

l Subscribed and sworn to before me

, this 3i d day of Ch ,1980.

(IEmeh dke '

hotarjPublic My Conmission expires:4Ai vu a I J0

, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l

In the' Matter of -

NUCLEAR ENGINEERING COMPANY, INC. ) Docket No. 27-39 (Sheffield, Illinois Low-Level Radioactive Waste Disposal Site) )

AFFIDAVIT OF JIM SHAFFNER t

Now comes Jim Shaffner and being duly sworn, deposes and says as follows: ,

1. I am employed by the U.S. Nuclear Regulatory Comission as a Project -

Manager, Project Management and Operations Section, Low-Level Waste Licensing Branch. i

2. I am duly authorized to answer interrogatories, admissions and requests for documents numbered 11(a), (b) and (c) and "Other Requests" numbered I and i

2, and I hereby certify that the answers given are true and correct to i the best of my knowledge.

i

^

JpShaffner -

Subscribed and sworn to before me this l pi day of ce w s, 1980.

Qssh Notarj Public b Ake' --

i My Commission expires: LL u n t a. .

5* l l

l

J UNITED STATES OF AMERICA <

NUCLEAR REGULATORY COMMISSION i i

1

., BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,

In the Matter of -

l NUCLEAR ENGINEERING COMPANY, INC. Docket No. 27-39

)

(Sheffield, Illinois Low-Level )  ;

Radioactive Waste Disposal Site) ) i-t i

VFIDAVIT OF GALE P. TURI  !

Now comes Gale P. Turi and being duly sworn, deposes and says as follows: l

1. I am employed by the U.S. Nuclear Regulatory Comission as a Hydrologist. l i

Site Suitability .d Design Section, Low-Level Waste Licensing Branch. l t

2. I am duly authorized to answer interrogatories, admissions and requests for documents numbered 12(b) and (c) and "Other Requests" numbered 3, and f I hereby certify that the answers given are true and correct to the best of my knowledge. '

i

- I

) 1 l

, ~

<xc .lJEcu i Gale P. Turi l i

i Subscribed and sworn to before me j this 37 day of uh_,1980.  ;

\l pin -usz .hkw h Notdry Public ' '

My Commission expires: -

1. m a. ,

e l

6' (

L

?

i

[

l t

h

. l UNITED STATES OF AMERICA  !

NUCLEAR REGULATORY COMMISSION  !

i i

., BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l l

In the Matter.of NUCLEAR ENGINEERING COMPANY, INC. ) Docket No. 27-39  !

(Sheffield, Illinois Low-Level i Radioactive Waste Disposal Site)

I AFFIDAVIT OF KITTY S. DRAG 0NETTE ,

Now comes Kitty S. Dragonette and being duly sworn, deposes and says as follows:

i

1. I am employed by the U.S. Nuclear Regulatory Conmission as a Section Leader, Project Management and Operations Section, Low-Level Waste {

Licensing Branch. [

2. I am duly authorized to answer interrogatories, admissions and requests f i

for documents numbered ll(c) and "Other Requests" numbered 3, and I hereby i i

certify that the answers given are true and correct to the best of my j knowledge.

f l

/ t & $d)w w!L l KitfjS.Dragonhtte l

Subscribed and sworn to before me I this Y day of OEh ,1980. l t

i

+

_Q O 'dau dk w '

-l Notarf Public -

l

$ Commission expires: h 4 i, m t :2 l 4 o i i

l i

aa m a .m .A L _ _ . L

.. ( s  :

. UNITED STATES OF AMERICA-  !

NUCLEAR REGULATORY COMMISSION

  • BEFORE THE ATOMIC ___ SAFETY AND LICENSING BOARD In the Matter of } i

) - ;

NUCLEAR ENGINEERING COMPANY, INC. Docket No. 27-39 (S:1effield, Illinois Low-Level

)

.ladioactive Waste Disposal Site) )

CERTIFICATE OF SERVICE i I hereby certify that copies of ".YRC STAFF'S RESPONSE TO REQUESTS F0P, ADMISSIONS, [

INTERR0GATORIES AND REQUESTS FOR THE PRODUCTION OF DOCUMENTS OF THE NUCLEAR ENGINEERING C0." w/ attachments, and Affidavits of Edward Hawkins, Jim Shaffner,  ;

Gale P.' Turi and Kitty S. Dragonette, in the above-captioned proceeding have i been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk by deposit in the Nuclear Regulatory Commission  ;

internal mail system, this 3rd day of November,1980:

Andrew C. Goodhope, Esq. Cornelius J. Hollerich, Esq. '

3320 Estelle Terrace State's Attorney Wheaton, Maryland 20906 Bureau County Court House Princeton, Illinois 61356 -

Dr. Linda W. Little 5%0 Hermitage Drive Susan N. Sekuler, Esq.

Ral eigh, .'IC 27612 Mary Jo tiurray, Esq.

State of Illinois r Environmental Control Division Dr. Forrest J. Remick 188 West Randolph Street 7 305 E. Hamilton Avenue Suite 2315  ;

State College, Pennsylvania 16801 Chicago, Illinois 60601 j .

Scott Madson, Esq. John M. Cannon, Esq.

Assistant State's Attorney '!

Mid-America Legal Foundation I 601 South Main Street

20 North Wacker Drive l Chicago, Illinois 60606 l D. J. McRae, Esq.

217 West Second Street Kewaunee, Illinois 61443 no I

I

..- -, .. . - - . - . - , - . . . _ - . - . . . - . - , . . . . - - , - , . ~ . .

k. (.

a A

2- i Atomic Safety and Licensing Docketing and Service Section*  !

Board Panel

  • Office of- the Secretary  !'

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555  :

Atomic Safety and Licensing Troy B. Conner, Jr. , Esq.  ;

' Appeal Panel *  !! ark J. Wetterhahn, Esq. i U.S. Nuclear Regulatory Conunission Conner, Moore & Corber 7 Washington, D. C. 20555 1747 Pennsylvania Avenue, N.W. j Suite 1050  ;

Robert Russell, Esq. h'ashington, D. C.- 20006 l Johnson, Martin & Russell l 10 Park Avenue West- Mr. Charles F. Eason l Princeton, Illinois 61356- Nuclear Engineering Company j Director for Governaant /.tfairs Admiral Vincent T. de Poix 110017th Street, H.W. l Chainnan of the Board Suite 1000  ;

for Nuclear Engineering Co. Washington, D.C. 20036 l P.O. Box 7246 i 1.ouisville, KY 40207 i

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i-i hmy// t /lb]w- 4 j  !

Henry p. )1cGurren Counsel for NRC Staff  !

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