ML20155F727
| ML20155F727 | |
| Person / Time | |
|---|---|
| Issue date: | 09/08/1988 |
| From: | Bahadur S NRC |
| To: | Knapp M NRC |
| Shared Package | |
| ML20155F725 | List: |
| References | |
| FOIA-88-418 NUDOCS 8810130374 | |
| Download: ML20155F727 (119) | |
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NOTE TO: Mal Knapp FROM: Sher Bahadur l
SUBJECT:
NRC/00E/ EPA Heuting on CERCLA Requirements for Radioactive Waste Sites DATE:
Thursday, September 3, 1987 TIME:
10:00 a.m. - 1:30 p.m.
PLACE:
EPA offices at Waterside Mall THOSE PRESENT: See attached list
SUMMARY
- The meeting was a result of DOE' request to clarify interagencv issues related to the implementation of CERCLA (Superfund) requirements for cleaning up radioactive waste sites.
In chair was Frank Biros, Deputy Director for CERCLA Enforcement Division. Office of Waste Programs Enforcement. 05WER/ EPA. Biros indicated that the meeting was meant only i
for an information exchange and,n_ct for negotiating positions or modifying o
policies.
Please refer the attached Agenda for the items discussed. Also, refer to the enclosed Item of Interest on the meeting prepared by Kitty Dragonette, which adequately sumarizes the discussions.
It should be noted that:
1,.
No comprehensive guidance is available on CERCl.A compliance which incorporates both EPA and NRC cor.cerns.
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2.
EPA Regions will continue to play a major role in making decisions on site specific remedal activities.
Sher Bahadur Attachments As stated CC:
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20*d M 01 AGENDA:
EPA / DOE /NRC MEETING APPLICABLE OR RELEVANT AND APPROPRIATE REQUIR8MENTS 4
FOR LOW LEVEL RADI0 ACTIVE WASTE SITE 8 September 3, 1987 10:00-12:00 1)
Introductions and CERCLA overview (Frank airos/
Mike Rilpatrick) 2)
NCP policy / guidance on ARARs in the RI/F8 process (Steve Smith) 3)
Maxey Flats description and current problems (Chuck Wakamo) 4)
Potential ARARs, future potential ARARs under development and guidance available a)
EPA Radiation program (Stri Lichtman) b)
DOE description of their orders (DOE) c)
HRC presentation of their procedurea (NRC) 5)
Follow up discussion (EPA)
- 6) Interagency task forces organization, issues, and tasks (EPA) t 1
,n,
I t e.n of interest-week of 9/8/87 Low-level Wastes EPA / DOE /NRC Meeting on Applicable or Relevant and Appropriate Requirements for Low Level Radioactive Waste Gites-Representatives cf a variety of organizational groups at EPA, NRC, and DOE held an information exchange meettng at EPA's offices at Watersion Mall on September 3, 1987.
The meeting was chaired by EPA Superfund enforcement staff and was held at DOE'S request.
The Kentucky owned ano licensed low-level waste at Maxey Flats and a number of other sites containing radioactive matr-tals are being remediated under Superfund.
FPA explained the process EPA follows under Superfund i
and the role of other Federal and State regulations and guidance.
EPA's decisions are site specific but EPA must consider all applicable and relevant and appropriate requirements in making decisions on the site specific remedies.
NRC staff outlined the agency's role and requirements and guidance and was asked to confirm the discussion as a contribution to a list of EPA, DOE, and NRC materials to consider as potential requirements.
EPA Superfund staff will recommend that EPA guidance documents being developed include a comprehensive discussion o* radiological requirements.
No additional meetings are planned.
I contacts Kitty Dragonette 7-4763
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LtNittiLU H/.it l
August 20, 1952 Mr.11. Doyle lillis Office of Special Projects Natural Resources and Environ:nental Protection Cabinet i
Fourth Floor Capital Plaza Tower Frankfort. KY 40631
Dear Mr. Mills:
This is in reference to the inspection conducted by staff meribers of this department on August 5 & 6, 1982 of activities conducted und-Kentucky Radio-active katerial License Hucher NBF-2-03 relating to the low level nuclear waste disposal dte located near Maxey Flats. Kentucky.
The inspection was an examination of activitics conducted under the license as they relate to radiation safety, compliance with the department's rules and regulations, and conditions of the license.
Specifically, the inspection consisted of an examination of procedures, records, measurements, and observations made by the inspectors.
Of the items reitewed during the inspection, it appeared certain of the ac-tivities were in non-coc3pliance with the department's rules and regulations and conoitions of the licensing docurrent. The items of non compliance are outlined below:
i I
1.
904 XAR 100:020 Section 10, requires each licensee to make or cause to be ir.ade such surveys as may be necessary for the licensee to establish compli-ance witn these regulations, and 902 KAR 100:020 Section 20(2), requires each licensee to maintain records showing the results of surveys required by Section 10 of this regulation.
In addition. Condition 17 8 of NBF-2-03 g
by referencing the Radiation Protection Program for the Maxey Flats low level Disposal Site dated Hay.1%0. Work Procedure 8. page 7. Section 3.5 indi-cates limits and action levels in terms of disintergrations per minute anc indicates that areas and objects found to be contaminated will be decontami-nated to levels specified in Section 3.5 or removed from service and marked "Contaminated Material."
y a.
It was found from a review of records and interviews with personnel that no documentation was maintained showing conversions fror counts per min-ute (cps) to disintergrations per minute (dpa).
b.
Survey records showed that for certain areas found to be contaminated no documentation of contamination levets existed and no documentation of follow-up actions or dee.ontamination procedures existed. This was noted on ten survey records between June 1981. through October,1981.
In addition it was noted, subsequent to October,1982, the survey results in counts per minute were recorded, but in cases which decor tamination was indicated, there was no record of a follow-up survey.
f b
. e. :-
Mr. H. Doyle Hills August 20, 1982 Page 2 2.
Condition 17 8 of NBF-2-03 by referencing the Radiation Protection Program for the Maxey Flats low Level Disposal Site dated May,1980, Work Procedure 9, page 3 Section 2.0, indicates laundry items will be screened for contamination levels prior to their being laundered, a.
No records of laundry surveys were maintained subsecuent to July 1,1901.
This includes laundry being sent off site for cleaning.
Also, as a result of the inspection the following cocraents and recom(ndations are made:
1.
Records reviewed indicated that minutes of inonthly safety meetings were re-corded starting December,1950.
It is brought to the attentien of the li-censee that minutes of monthly meetings were evidently not being recorded and inaintained prior to Decerbor,1950.
2.
Page 21, Section 2.3.2 of the manual indicates radiation workers shall have thirty (30) days from the date of hire to successfully complete radiation worker qualification requirements. These requirerents include passage of an ex mination.
It was found during a review of exacinations that a date: of testing was, missing from some exaninations. The date should be placed on all examinations in order that the licensee can show that the radiation worker took the examination within thirty (30) days af ter the date of eeplopent.
3.
A review of records indicated swipe results were recorded only if such ex-ceeded background.
Background levels were not recorded.
It is recorr.caded that the licensee revise their record keeping procedures to indic1te bach ground levels.
4 As soon as the gama spectrometer system is calibrated, it is recorriended that gama scans be perfomed on the leachate going into the evapor3+.or systea and tnat gan,a scant, be perforred on the daily effluent saroles obtained fror the evaporator.
It is necessary that managenent action be taken to ensure compliance with departrent rules, regulations, and license conditions. Please notify this depart-ment in writing within thirty (30) days from receipt of this letter of the corrective steps taken or to be instituted in achieving correction and preventing further violations and the date when such correction and cocipliance will be achieved.
Sincerely, Donald R. Hughes, Supervisor Radiation Control Secticn Radiation and Product Safety Branch sgv cc:
Reba Page
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$4(2 litic (natractoc Tesit Key _lssue CluracterfstIcs E -Iwatfon Cosseent 48 tee t Ca t factfle til; rat ion Leechste Surfeco covering has bees t,1;'meegle the mee of the source Proj7CL 13 releve*C to our E lear ac t es la s f r a sant al.we s t Charactert-emplaced on Trench 27 whirle trench to me longer providing the long-tern needs. We request Isl e s at lan. and tabaraterlee retten and served as eeurce for test celle.
Intended function, tlee surface any available leformation rate of 3 48 -
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- lowcaent nacilJes at cover will provide the poenibl11t: relevant to afgratten ratee of tee'los at the entent emb-Amerwed er calculated to Homer Flate sad e
s***.ee skattow surface inflitrattaa. This will date. We request res=ler t*=J 5=rimi growide we a "before" and "after" certes of qwerterly and Sites picture of migretten.
=pdate reporte.
O.catcal teachate Seeface ce=erlag has been Yl.e present surf ace cover will Project le revelant to owr
%eracter-Characteri-emplaced on Trencle 2f wblcle provide en opportunity to observe long-tern meeJa. Ide regweet Isation aat!en, served as source for test cet te.
for n c13de species as they as ht regular certes of quarterly s
Selfdifica-C alth attempting to appear la later yeere in a trench and update repnete.
tlen, and resewe all pompable water free wlitch doce not ineve to contend Tranwport western sectlen of trenchen, with surface ?nfiltration. The opportunity to leek for species in nearby sprinse will provide me with aff-stte data we need.
Pedte-Treacle Cover A swbotantial area of the este Altbewgle a subetentiel pertion of Freject le revelant to ear awclide schehttite-will be covered with a evitt-the ette will be covered with lena-term neede. By 7tapplan s8en layer trencle cover enlithis tag pleetic, the rematalag eetle will identifying stees needing tl.e propeettee of a noteture be ave 11able for depeetted remedial action prior to er barrier. This work w111 be part nucildes and mitimate transport.
during trench cover rehabili af a DOE grant.
TI.e data betin en and eff-ette, tatten, we may prevent is valuable in tle eveteatten of unnecemeary radien.cIlde con radienocitdes contributed to the tentnation to ottier parte of general environment. The the este or general area.
drainage cleannel taformation le espects11y waeful and needed.
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y Centractor T sk Key Isswe Characteristics E"Ivatien Cosament Trener.rt of tse Alemme Deep-Treacte Cover lhe east mejerity cf flee cito Dve to propeeed long-tgre condt-project deem met seem l
Westo 3,11 -
saat te=al Beeted Bef.sht1tre-will be eventually covered t!en, the project would not seen particularly relevant at n citdes Throwr.
t.nberstory Flente aten vits, a a=rface rever er e It t-especially e.sef=1 et thte time.
e els e noch a= Mamey Sotto A-7040 1ayer cover eyetem es wever. how mecle the mechente=
Flete, but co.ste be eeeful l
e et present contributes to surface informat ten for ett.er et tes conteetnetten le omknown and may provide e 3 1 epee et evela 8
procedores.
71.e reesibility of planting deep-reeted crete out-eide the restricted area =ey provide a (tret Ilme of mentterini for embourface movement.
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Uneaturated Unteetetty pe t tweeye Trench Cever A embetontiel portion of time The informattom to be Seined project le relevant to. r Tane t'yJaelegy of of Rel.ebili t e-ette will be covered witte show'd be quite weef=1 in ehert-tere and long-term ct Ptasey Flate Colliernia -
lefiltre-tien a eurface ocebrene including determining tie effectiv m ee neede, we need informatta.:
Berbeley tien the eres ereund 195. Thte of the laterim surface cover.
relevant to pathways S-1042 will provide e "before" and This work should else oestet in ebeerved er inferreJ.
L'e "efter" picture of infiltretten 1 der.tifying the trench-request regular cortes of es the original eres wee withewt esadterurbed oo11 Interface se quarterly and wedete evrface cover.
est taf11t rat ten pathway.
reporte.
- yelmeters Trencle Caver Althewsh Llee eres in wietets thte
&c present'enty Itatted infu me-Con we obtain a copy of gehebilite-esperiment will be cenJucted tien will be gained for imp!a ca-the pub!!cetten referenced tien will be outside the trencle tetten et Mesey Flete. The in Seit Science dated July, restricted eres, e embetontist ides and reentre would probably 19811 At prescat the porttom of tl.e ette will be be applicable et etleer er future C_-
rettfe le cenetJering covered with e surface me=brane ettee.
Ste.a will present ehert-reeted crepe for the er a smeste lleyer treacle cover, tystnetere esclude reeled water multtleyer covers witte ereund their time! The problem possible inclusion of of tritive migretten and ble-be r r ie r e.
transport may be weeful in 18.e teng-ters.
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Characteristics Evaluatlee Cesesent Cheelzctly Settella Cheelect tasch te Surface covering hee been The hoewledge to be prewtJed by Frsj2ct r: levant to cut Tate Wastes facific Testetty 0 erectert-e=placed on Tsenet.es 27 sad this teek could be poteattelly famedtste and toeg-term mad Their Iser tineest estien sad 195. A evbetentist portion entremely weef=1 in the everall meeJe for steb13tantion Trntaent Laboratories Hovement of the ette will be covered decesuntestenleg of any shallow and decometastentes. We 5-1064 with a surfece membrene er a leed bettet factitty.
we=Id rece==end that at.e melttleyer trench cover.
eempting be espanded te include ette surface drainete channels, wet weetber oprings and a few eclected off-stte seacting etresee for concentrat tee camperieen enJ relevance to EPA guldence. Rece w ed
- be ceneideretten of onelyste of e Itatted member of evaporeter-eterk ea=rles.
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a INITIAL RESEARCH OBSERVATIONS AT MAXEY FLATS WHICH ARE RELEVANT TO SITE CLOSURE Deliberations of a Research Panel Convened November 30 and December 1, 1982 Reston, Virginia Panel Chairman:
Jared J. Davis, NRC, Office of Nuclear Regulatory Research Panel Members:
Enrico F. Conti,. HRC, Office of Nuclear Regulatory Research Ramesh Dayal, Brookhaven National Laboratory John Fischer, U. S. Geological Survey John F. Kendig, NRC, Office of State Programs
' Doyle Mills, Commonwealth of Kentucky
' Edward O'Donnell, NRC, Office of Nuclear Regulatory Research Roger Pennifill, HRC, Office of Nuclear Material Safety and Safeguards Richard W. Perkins, Pacific Northwest Laboratory W. L. Polzer, Los Alamos National Laboratory David E. Robertson, Pacific Northwest Laboratory John 8. Robertson, U.S. Geological Survey Robert Schneider, U.S. Geological Survey Robert K. Schulz, University of California, Berkeley
+
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03/22/83 HAXEY FLATS RESEARCH OBSERV
INITIAL REVIEW 0F RESEARCH OBSERVATIONS AT MAXEY FLATS WHICH ARE RELEVANT TO SITE CLOSURE f
1 INTRODUCTION During the past few years, the U.S. Nuclear Regulatory Commission (NRC) has conducted research at the Haxey Flats LLW Disposal Facility to determino the processes which are occurring relative to degradation of radioactive materials within the burial trenches, the chemical and physical characteristics of the trench leachates and the key geochemical controls governing the leachate char-acteristics, the chemical forms of the leached radionuclides, the, mobility of these radionuclides, their subsurface and surface transport processes, the biological uptake, the development of environmental monitoring strategies, and other factors which influence the long-term fate of the radionuclides.
In addition, the U.S. Geological Survey (USGS) has conducted extensive hydrogeo-logical studies which have provided insight into the possible sechanisms of water movement. The Commonwealth of Kentucky has carried out extensive mont-toring programs of environmental radioactivity levels both in their private laboratories and under contract with their past and present site operation contractors.
i The primary objective of the present and future management of the Maxey Flats Disposal Facility should be to insure the protection of the general population living near the site from releases of radioactive materisis.
This will require a reasonable isolation of the radioactive wastes contained on site, such that any radioactive materials released to the environs do not result in an annual I
dose to man that exceeds recommended regulatory limits throughout the institu-tional and passive control phases of the site.
In addition, the ALARA concept of maintaining radionuclide releases to the environs as low as reasonably achievable should continue to be an integral part of the management plan.
Studies currently sponsored by the NRC which are investigating Maxey Flats l
include the following-P 03/22/83 1
MAXEY FLATS RESEARCH OBSERV
o Geochemical evaluation of isotope migration at LLW sites (Brookhaven National Laboratory) o Burial ground site survey (Commonwealth of Kentucky)
Waste radionuclide migration in s, oils at the Maxey Flats shallow land o
burial site (Los Alamos National Laboratory) i o
Chemical species of migrating radionuclides at shallow land burial sites (Pacific Northwest Laboratory) o Study of unsaturated zone hydrology at Haxey Flats (University of California - Berkeley) r On November 30 aad December 1, 1982, a panel of researchers and administrators (see cover page) was convened at the USGS National Headquarters in Reston, Virginia, to outline and sumarize the available information on Maxey Flats l
which is pertinent to closure of the disposal facility. 'This report is the result of those deliberations and is an initial resource document which can be used by the Comonwealth of Kentucky to assist them in developing a closure plan for the site.
This document is not intended to provi4 a plan of actions that should be taken to riose the site, instead, it examines available data, summarizes important observations, and draws cor.clusions relating to those I
1 observations.
It is intended to provide an initial review of research observa-tions which are relevant to site closure. A more extensive review of those observations and tha past and current research rel'tive to site closure is (dudN under way and will be published later, i
i 2
STATEMENT OF THE PROBLEM Observations to date show that water infiltsation and accumulation in the waste trenches has been the primary problem at Maxey Flats.
Since the waste trenches are located in media of low-hydraulic conductivity, water, that infiltrates through the trench cap accumulates in the trenc5es and was overflowed in the past. This is referreo to as the "bathtub effect." The accumulated water 03/22/83 2
MAXEY FLATS RESEARCH OBSERV
accelerates the degradation and dissolution of the waste material, helps mobilize the radionuclides, and acts as a driving force for subsurface trans-port of the radionuclides.
If the trenches fill and overflow, th"n racionu-clides can be transported directly to the surface.
The large inventory (presently about 300,000 curies) of tritium in Trench 31, which exists as mobile tritiated water, is of major concern during the first 100 years of closure when institutional control may be needed because it could be trans-ported offsite in the groundwater flow.
Thus, continued accumulation of water in the vaste trenches, particularly during the short ters (about 100 years),
is undesirable.
The panel identified at least 14 specific issues which should be considered in developing a closure plan for the Maxey Flats disposal facility (see Section 3),
all of which generally stem from the following tite co..ditions:
o 3ubsidence of waste trench covers o
Water accumulation in the trenches 2
o Waste trench leachate contains high tritium concentrations and complexed forms of other radionuclides o
Complicated hydrogeology, including fracture ficw, which makes prediction of subsurface radionuclide transport and radiological 1
surveillance difficult All of the available data relating to these conditions which seemed pertinent to site closure were examined to provide a sunnary of important observations.
lhese observations were then interpreted in the form of conclusions which addressed the various problems relating to site closure, and which would be essential to consider in developing a decommissioning plan for the site.
i n
03/22/83 3
KAXEY FLATS RESEARCH OBSERV
t 4
3 SITE CHARACTERISTICS
- Naxey Flats is an isolated plateau in northeastern Kentucky approximately 19 km from the City of Morehead.
The radioactive waste burial site is located en the plateau about 90 to 122 meters above the surrounding valleys.
Radioactive vaste burial at Maxey Flats began in 1963.
Comp 1,eted trenches at the site vary from 6 to 12 meters deep (20 to 35 feet) and occupy an area of about 0.08 square kilometers (25 acres).
As of January 1978 0.13 million cubic meters (4.75 million cubic feet) of nuclear waste consisting of approximately 2.4 million curies of byproduct material, 431 kg of special nuclear caterial, 241,769 kg of source material andiapproximately 3 kg of plutonium, had been buried there.
S7 Rocks exposed in the Maxey Flats area consist of nearly horizontal bedded siltstones, mudstones, sandstones, and shales of Minissippian, Late Devonian to Silurian Ages including, in descending order, the Nancy and Farmers Members of the Borden Formation, Sunbury, Bedford, and Ohio Shales, and upper part of the Crab Orchard Formation.
The total thickness of these rocks is about 98 meters. All radioactive wastes are buried in the Nancy Member.
The Nancy Member is predominantly a silty shale with a few lenses of siltstone 2-12 cs i
thick and a 25-100 cm thick sandstone bed that forms the bottom of many trenches.
Because of its induration, only a few trenches pass through this sandstone.
(L M t
Mean annual precipitation at Maxey Flats is about 115 ca.
(This value is the average of the annual precipitation at Farmers, Kentucky for 1948-1977.) Infil-trating rainfall is temporarily stored in regolith on the hilltop, deeper unweathered bedrock beneath the hilltop, and in colluvium and soll on hillsides.
Discharge occurs by lateral flow from the regolith and bedrock to the sides of hills or to alluvium in valley bottoms. Well yields are low in all rock forma-i tions at Maxey Flats, and most groundwater movement is through secondary openings, particularly through fractures (Zehner,1979).
The groundwater system at Maxey Flats is probably unconfined, and recharge occurs by (1) infiltration of rain-f all into the regolith, and (2) vertical unsaturated flow from the regolith at the top of tu n111 to saturated zones in the Farmers Member and Ohio Shale.
Some recharge could occur as lateral flow to rock from hillsides, but the "For a more detailed description of the site characteristics anct history, see Clancy et al., 1981, and Zehner, 1979.
03/22/83 4
MAXEY FLATS RESEARCH OBSERV
^^
i significance of this method of recharge is not known at this time.
Thus the very low permeability of the regolith and unweathered rock beneath Maxey Flats results in water accumulation in the waste-filled trent.hes.
4 SPECIFIC ISSUES TO BE CONSIDERED IN DEVELOPING A CLOSURE PLAN FOR THE MAXEY FLATS LtW DISPOSAL FACILITY There are numerous issues th,it need to be considered in developing a closure plan for the Maxey Flats Disposal Facility.
Yhese include some problems that result from the high rainfall, the perc01ation of water through the trench caps, the impermeability of the media in which trenches were excavated which results in the accumulation of water, and the possible overflow of trench leachate through the trench caps.
Key issues and problems which have been identifled are summarized below.
(1) Water infiltration and accumulation in trinches.
(2) Relatively high radionuclids concentrattor.s, especially tritium, in trench leachate.
(3) Subsidence of trench cosers.
(4) Uncertainties as to the waste feras which ar) readily leachable.
l (5) Trench water chemfitry which enhances radlonuclide roeility.
l (6) Subsurface migration of radionuclides and other leachate constituents.
l
(
(7) Corplex hydrogeology that compilcates the prediction of migration patterns.
l (8) Surface contamination associated with site operations.
(9) Offsite transport of radionuclides by surface runoff.
l (10) Ercslon processes that threaten the integrity of the site.
l 03/22/83 5
IWEY FLATS RESEARCH OBSERV
~
(11) Dispersion of tritium and possibly other radionuclide~ in the evaporator plume.
(12) Biological pathways and uptake of radionuclides.
(13) Lack of effective monitoring methods.,
(14) Nonradlulogical tuxic materials in waste trenches.
In the following section, each of these problem areas is briefly discussed and the relevance of the problems to site closure is considered.
1.
Water Infiltration and Accumulation in Trenches Water infiltration ano accumulation in the waste-filled trenches has been a problem at Maxey Flats.
The problem has been aggravated by subsidence, which results in the periodic failure of trench caps even though they have been repaired many times. A basic problem at the sita is that the,permcobility of the geologic media in which the trenches are located is relatively low, partic-ularly when contrasted with the trench caps.
Infiltration through the trench caps hat greatly exceeded the rate of subsurface transport of water from the trenches. To avoid excessive accumulation, the water in trenches is periodic-ally pumped and disposed of by evaporation.
A long-tern solution to the accumulation of water in the trenches must include a means of avoiding water infiltration.
Recent remedial action by Kentucky involving land surface buildup, surface drainage construction surface regrading, and installation of a temporary plastic cover (PVC) over approximately 3/4 of the burial trenches in 1981-82 hat, greatly reduced water infiltration into the waste burial trenches. Thic reduction of inflitration has been demonstrated by reduced increase in trench water levels and decreased soil moisture content in the top 0.9 to 1.5 meters l
of 5o1.1 in areas where the plastic cover did not contain holes. However, the water level in some of the PVC covered trenches has continued to increase although at a much slower rate (Mills, Octolur 27, 1982, verbal communication),
i l
03/22/83 6
MAXEY FLATS RESEARCH OBSERV
~.-
a 4
presumably due to infiltration of water through uncovered areas such as road-ways, and via leakage through the plastic cover particularly near drain areas.
The decreased infiltration of water into some of the waste trenches has caused i
increased tritium concentrations in the trench leachates due to limited dilu-tion of the tritium leaking from waste containers.
Such leachates now contain tritium concentrations above the levels perjoitted for processing through the j
evaporator, used at Maxey Flats to dispose of trench water, unless they are
)
diluted with less contaminated water.
This has inhibited the ability to dewater l
these trenches.
The outflow of groundwater through the bottom of the trenches to the reckr immediately bcneath them has been estimated by the USGS (Zehner, verbal t
communication October 26,1983) to be only about 0.03 cm per year.
Therefore, an impermeable cover would have to restrict water infiltration in the region j
of the trenches to no more than 0.03 cm per year to prevent the eventual accu-i mulation of water in the trenches.
Since the average annual precipitation at the site is 115 cm/yr, an impermeable cover would have to be about 99.98%
[
ef fective to prevent water accumulation in the trenches.
2.
Subsidence of Trench Covers 1
Trench covers need to be designed to provide structural integrity which will prevent surface water penetration.
Subsidence of trench covers may be a problem that will require continual monitoring and appropriate remedial action I
for the next several decades. Any permanent decommissioning of the Maxey Flats f
site will have to contend with this as a potential, yet real long-term problem.
l Subsidence could structurally damage either an engineered impermeable cover j
(e.g., asphalt surface or concrete tiles), or a contoured vegetated cover.
This l
could allow water to infiltrate into the waste trenches and could possibly l
result in the transport of radioactive and nonradioactive contaminants offsite, j
Therefore, it appears inevitable that some maintenance will be required for the short ters (up to 100 years) to limit infiltration into waste trenches unless the material in the trenches can be stabilized.
4 l
03/22/83 7
MAXEY FLATS RESEARCH OBSERV E-
3.
Radionuclide Concentration in Trench Leachate.
Some of the radionuclides contained in the waste forms buried in the trenches are highly leachable, which has resulted in considerable amounts of several radionuclides (Sr"90, CS-137 Pu) accumulating in the trench leachate.
Another important source is tritium which escapes i,nto the trench water as buried
)
tritium containers fail.
The concentrations of tritium in leachtte range up to 105 pCi/1, Concentrations of up to the pC1/1 range occur for several other radionuclides (e.g., Sr-90).
Consideration should be given to methods which could minimize the leachability of radionuclides from these wastes.
Such tech-niques as in situ waste solidification may be useful; however, it is clear that j
I i,f infiltration of water could be completely stopped, and ij the trenches could be completely dewatered, then ferther leaching of the waste would probauly be eliminated.
I 4.
Un:ertaintiesAsToWastaFormsWhichAreReadilyteachabh This topic is closely related to item 3.
The fact that the waste was not i
solidified prior to disposal has resulted in some radionuclides being disposed of in readily leachable forms.
For example, many of the decontamination reagents which contain complexing substances were disposeu of in containers which havr. subsequently fdled. Thus, soluble and mobile forms of plutonium and sor<. other radionucli les rre presunt in trench leachate and can possibly migrate by subterranean routes in groundwater.
5.
Trench Water Chemistry Which Enhances Radionuc1tde Solubility i
'this topic is directly related to items 3 and 4.
The waste leachate is highly anosie, which results in plutonium beirg mainly in the Pu'8 and Pu'* valence state. These chemical forms of plutonium are readily complexed by EDTA and ptrhaps other complexing agents which are present in decontamination solutions.
These corplexing agents, together with container and waste degration products including carboxylic acids, enhance the solubility of plutonium, Co 60, Cs-137,
)
Sr-90, and perhaps other radionuclides.
03/22/83 8
KAXEY FLt.TS RESEARCH OBSERV
6.
Subsurface Migration of Radi,onuclides and Other Leachate Constituents Subsurface migration of radionuclides appears to be mainly'through fractures in the rock.
Because this is a relatively slow process, compared to surface flow, the cpportunity for long distance migration seems rather limited.
How-ever, movement of radionuclides by subsurfgce transport is difficult to trace and the extent of subsurface migration has not yet been fully established.
Recent observations based on tritius in the leaves of trees growing around the site perimeter, and ccacentrations in monitoring Wells 11E and 13E tuggest that l
some subsurface transport of tritium to offsite locations (particularly near 1rench 31) has already occurred (PNL,1982 unpublished data). This correlates with the lateral flow rate of the onsite groundwater which has been observed by the USGS, near Trench 46 to be as much as 14 to 17 moters per year (Zehner, October 26, 1982, verbal communication).
However, the relative contributions of tritium in the discharge plume from the evaporator, which hes been used to dispose of trench water,.ind surface pathways have not yet been fully assessed.
Within the saturated conditions of the trenches the waste trench leachates are strongly anoxic. The radionuclides that are dissolved in trench water and grounawater have been observed to be present in organic complexed chemical forms.
However, as the leachates move away from the trenches, they become more oxic, resulting in a dectease in pH and an increase in Eh and a series of chemical chc5ges in soil chetistry such as in the partial oxidation of Fe*8 to Fe+a, These changes affect the chemical speciation of the radionuclides, thus affect-ing their migration rates and retention in the surrounding soil. While the full impact of these changes cannot be precisely defined at the present, it appears that plutonium retention by the soil is substantially enhanced by the transforsation to otic conditions.
Anotter factor which affects.the subsurface migration of radionuci des is th presence of cheisting agents such es EDTA and other polar organic compounds b
which can recur in the waste leachates.
These substances appear to have com-3 plexed with plutonium, Co-60, and possibly other radionuclides, thus enhancing their ability to migrate in the onsite groundwater.
No subsurface migration t%wu'swhy 03/22/83 9
MAXEY FLATS RESEARCH OBSERV
of these radionuclides to the offsite environs has yet been observed with cer-tainty. According to Zehner (written cossiunication February 15,1983),1974-75 Kentucky Department of Human Resource data showed concentrations of Pu, Sr-90, and H-3 above world failed levels, but he noted surface and subsurface routes i
have not been verified. Currently, except for tritium, radionuclide concentra-tions are at world background levels and some onsite movement away froe the waste trenches has been observed.
Manganese-54 and Co-60 have migrated over 60 meters at one location (near Trench 44), and Co-60, Sr-90, and plutonium isotopes have noved 7 to 12 meters at other locations (near Trench 27 and near W311s 081 and 081A).
7.
Complex Hydrogeology that Complicates the Prediction of Micration Pattorns Because of the very complex hydrogeology at the Maxey Flats site, it is l
l extremely difficult to predict migration patterns.
Available information suggests that in order to determine the rate and extent of subsurface migra-tion, it wtII be necessary to do additional monitoring at the site.
l The uncertainty in estinating groundwater flow rates is quite high and it is complicated by limited knowledge of the hydrologic properties of the strata i
f beneath the site and the patterns, extent, and dimensions of fractures in that strata. Observations at the experimental treg ear Trench 27, the Wells UB1 and VB1-A, and near Trench 46 indicateQture' fly of groundwater at i
l rates up to 17 meters / year.
(This estimate comes froe the detection of Mn-54 and Co-60 migrstion near Treach 46; Zehner, verbal communication October 26, 1982.) A limited series of laboratory tests of cores from the Nancy Member had j
much lower hydraulic conductivities ranging free 0.003 to 1.0 cm/ year (Encon l
Associates,1975).
Base flow to the streams adjoining the Maxey Flats (Rock
]
Lick Creek, Drip Springs Hollow, and the unnamed streas to the east) is apparently also quite low.
Zehner (verbal comunication, October 26, 1982) has i
i estimated the discharge of water from the Maxey Flats disposal trenches to the rocks immediately beneath them to be 0.03 cm/ year and he estimates that by the time this water reachr.' the 1.treams adjoining the site it will have a mean l
dilution with water froe the colluvium on the hillsides bordering the dhposal
)
facility of 2000X.
I f
03/22/83 10 KuEY FLATS RESEARCH OBSERV l
)
{
8.
Surface Contamination Associated with Site Operations.
Observed offsite contamination of soil and sediment with traces of Co-60 and Pu-238 is apparently the result of surface runoff from the site which trans-ported alldly contaminated soil.
The onsite soil contamination probably resulted from contamination of surface soil,by spillage during the initial burial operations, erosion of contaminated soil from burial areas where waste has been exposed due to insufficient soil cover, from accidental releases of trench leachate during pumping for processing in the evaporator, or from other surface releases or from fallout from the evaporator plume.
9.
Offsite Transport of Radionuclides by Surface Runoff The high rainfall at Maxey Flats has caused rapid surface runoff, resulting in surface transoort of contaminants deposited by site oparations.
Radionuclidos which have been observed offsite (such as Pu and Co-60), with the possible exception of tritium, appear to have most probably resulted froe surface flow which results from heavy rainfall on the disturbed soil surface.
Unfortunately, the offsite surface contamination complicates the problem of defining subsur-face flow. Groundwater discharge may also possibly be contributing to offsite contamination.
It will be necessary to develop a measurement protocol which allows one to distinguish between surface runof f carrying radioactive materials and subsurface transport of radionuclides, 10.
Erosion Processes that Threaten the Integrity of the Site The Maxey Flats disposal facility is located on a relatively flat upland and bounded by slopes. Because of this, erosion is a potential hazard to site integrity and it should be addressed by any long-term site closure plan.
It should be noted that any onsite remedial action designed to reduce infiltration will increase surface runoff.and the potential for erosion, t
1 03/22/83 11 MAXEY FLATS RESEARCH OBSERV
11.
Dispersion of Tritium and Possibly Other Radionuclides in the Evaporator Plume Virtually all of the tritium in the trench leachate pumped from the trenches is vented to the atmosphere throuch the evaporator.
This has resulted in a rather low but measurable contamination of the immediate environs of the site. Other radionuclides are also present in the evaporator plume, but our observrtions have shown that deposition of them in the surrounding environment are insignif-icant compared to radioactivity from fallout.
Thus, while the evaporator plume complicates the background concentrations through the addition of \\ritius to the environs, it does not contribute significantly to other radioactive contami-nation and would not appear to present a long-term problem following discon-tinuation of its use and site closure.
12.
Biological Pathways and Uptake Radionuclide transport via biological pathways setas to be minimal at the present time except for tritium.
Howeve'.*, levels of other radionuclides in the blota may rise if containment fails and certain radionuclides, e.g., Cs-137 and St 90, migrate to areas where they can be intercepted by plant roots and animals.
Readily measured concentrations of tritium have been observed in fescue grass grown direc'.'y above the waste trenches, and also in the leaves and sap of trees prowing near waste trenches containing high tritium livels. While ne serious radiological problems associated with plant uptake appear to exist, the bio-logical uptake pathways may prove to be useful in monitoring subterranean trans-port of radionuclider, particularly tritium.
13.
Lack of Effective Monitorino Methods Because of the complex hydrogeology, it is difficult to develop an effective monitoring syster for detecting subsurface radionuclide migration.
The problem is one of sampling for radionuclide movement in a fracture flow regime where the fracture geometry is imperfectly known.
Most fractures are oriented nearly vettical so conventional vertical wells must be supplemented by other methods.
The panel discussed, without making any recommendations, the following methods 03/22/83 12 MAXEY FLATS RESEARCH OBSERV
which might be used to monitor radionuclide movement:
inclined wells designed to intercept fractures (N.B. inclined wells were recognized as a very expen-sive method in which the data gathered might not justify the cost), monitoring trenches along the perimeter of the site, porous cups, measurements of base flow into the streams adjoining the site during low flow periods, and wells in the colluvium on the slopes bordering the s,ite.
Vegetation, particularly trees, could be used to detect the leading edge of any tritium plume moving offsite.
h'-
14.
Nonrsdiological Toxic Material in Waste Trenches It Ls been observed in preliminary measurements that several toxic substances se.g., barbiturates, chlorinated hydrocarbons) are present in the waste trenches in addition to radionuclides.
These toxic substances should be identified and the degree of their movement relative to tritium should be detemined.
Parti-cular attention should be given to the degree of degradation of toxic materials as they move away from disposal trenches and, if desirable, to means of enhanc-ing in situ degradation of those compounds in trenches.
5 OBSERVATIONS AND CONCLUSIONS RELATING TO SITE CLOSURE Much of the research that has been conducted at Maxey Flats by the NRC, USGS, EPA, and others has been of a somewhat generic nature, and has not necessarily been directed toward the specific objective of site closure.
However, essen-tially all of this research has addressed problems at Maxey Flats which are of concern in the development of a site closure plan.
This section of the report summarizes those research observations which appear to be most relevant to site closure. The following observations have served as a basis for developing con-clusions which are of concern to site closure.
These observations and conclu-sions are grouped into seven different categories addressing the various problem areas outlined in Section 3..
03/?2/83 13 NAXEY FLATS RESEARCH OBSERV
(
j"'
l 5.1 Hydrogeology Observations Conclusions a.
The discharge of water from the A very small portion of the average disposal trenches to the rocks 115 cm of precipitation percolates below them is about 0.03 cm/ year.
deeply into bedrock below the By the time this water reaches the trenches. This indicates a very low streams adjoining the site, it will volume of groundwater (and quantity have a mean dilution with water of dissolved radionuclides) in the from tr.e colluvium on the hillsidas bedrock beneath the site.
bordering the site of 2000X.
b.
Subsurface materials have very An effective groundwater monitoring low primary permeability.
- However, system would need to be designed to they are frequently fractured, and adequately sample fracture flow, the fractures transmit water.
Accurate modeling of groundwater Virtually all groundwater flow flow within the site boundaries occurs in the fractures.
Based on would be very difficult, radionuclide information at one location, the rate of flow through fractures is estimated to be approximately 14 to 17 meters /yr.
The groundwater system is highly nonuniform (Zehner, 1979).
5.2 Unsaturated Zone Hydrologic Transport Observations Conclusions l
a.
From relative soil moisture The accumulation of water into the readings, tritium movement, trenches (bathtub effect) is caused rapid response of water. levels in by the permeability of the trench trenches to rainfall events, and caps which permitted water infiltra-organic tracer movement, it was tion into the trenches accompanied l
03/22/83 14 MAXEY FLATS RESEARCH OBSERV
~
,T Observations Conclusions found that the principal mode of by relatively impermeable undisturbed water entry into the trenches was material between and benea the by percolation through the trench trenches.
In order to inhibit cover and that little occurred by surface water infiltration into the lateral movement within the soil trenches, an effective trench cover profile.
It was also found that must be designed and constructed, the vertical permeability of the Trench cap design must address undisturbed soil profile 8 meters controlling permeability anni from Trench 19-5 was very low subsidence.
(Schulz, 1982 UCB Ref. 3).
5.3 Waste Form and teachate Characteristics Observations gonclusions a.
Most trench wastes exhibit a Trench waste compositions reflect a strongly developed anoxic regime, combination of two processes:
(1) characterized by high alkalinity interaction between the waste and and NH, and low $0.8, N05 nd accumulated water, and (2) the effects dissolved oxygen.
High concentra-of bacterial decomposition of organic tions of waste-derived components, matter.
The extent to which trench such as radionuclides, Fe *, dis-wastes are modified relative to the 8
solved organic carbon, etc., were groundwater reflects the length of also observed (BNL Ref. 1; LANL; time that water is it, contact with the PNL).
waste, groundwater chemistry, and the intensity of bacterial action.
m b.
Water in the exsterimenta renches Indicates possible transport by located abouth-8 meter from subsurface flow from nearby trenches hibits an anoxic water and suggests that radionuclides
- p '
chemistry (Iow $0.8, high alkalinity, may have migrated beyond the experi-and Fe *) and the presence of radio-mental trench location.
8 nuclides, the concentrations of which are intermediate between the trench leachates (26 and 27) and well water (UB1-A) (BNL Reference 1).
03/22/83 15 MAXEY FLATS RESEARCH OBSERV
1 Observations Conclusions c.
Groundwater becomes more oxic These changes indicate that the with increasing lateral distances in situ trench water chemistry is up to about 3 meters tros the highly sensitive to conditions that waste-filled trenches.
Exposure are encountered as the water moves of strongly anoxic trench waters
, away from the immediate trench to oxygen initiates a series of vicinity.
These changes affect the irreversible changes such as chemical speciation of the radio-i partial oxidation of Fe + to Fe +,
nuclides, generally reducing their 2
s and also decrease in pH and solubility and thus affecting their increase in Eh (BNL Ref. 2, 3; migration rates and retention in LANL; PHL).
the surrounding soil.
d.
Numerous organic compounds have The presence of these compounds can been identified in CH 01: and enhance the migration of some radio-2 CHC13 extracts of trench waters.
nuclides that may leach from buried Some of these compounds are known
- wastes, to act as chelating agents for radionuclides (BNL Ref. 1; PNL).
e.
Plutonium has been observed to occur The mobility of plutonium and Co-60 mainly as an anionic complex and in is probably enhanced by forming 1
the +3 or +4 valence states in both soluble EDTA complexes.
trench leachate and water from onsite i
monitoring locations. Generally good j
correlation was observed between plutonium, Co-60, and EDTA in leachtte sampled from experimental wells about j
4 7 m from Trench 27 (PNL).
4 f.
Plutonium in trench leachate Plutonium is prot ably migrating i
exists in true solution and not as as a soluble EDTA complex and
. colloids (Cleveland, and Rees, 1981).
not as a colloid.
1 I
ll
\\
03/22/83 16 MAXEY FLATS RESEARCH OBSERV
\\
Observations Conclusions g.
Small, but measurable amounts of Pu Pu has migrated in onsite ground-were found in porous sag ling cups water at distances up to 7.6 eters installed up to 7.6 meters from from Trench 19-5.
Trench 19-5 (LANL).
~
h.
Sr-90 and CS-137 generally showed good The Sr-90 and Cs-137 that is migrat-correlation with carboxylic acids in ing is probably associated with leachate sampled from experimental carboxylic acid complexes or salts wells located about 4-7 m from in onsite subsurface waters.
Trench 27 (PNL).
i.
Toxic chemicals, includint) barbitu-Because of the hazards and mobility rates and chlorinated hydrocarbons, of certain nonradiological toxic have been observed in trench leach-chemicals found at or near EPA ates (PNL; BNL), and other toxic limits, they need to be considered chemicals (pesticides) are known to in a site closure plan, have been placed in the burial t enches at Maxey Flats (Mills).
j.
Leachate collected at different Mixing of leachates within indi-dewatering sumps and depths within vidual trenches is of ten minimal, a trench commonly has different This variability in leachate compo-radisnuclide concentrations as a sition compounds the problem of result of the variability of waste describing the source ters which disposed of in different parts of is ivortant if selected remedial the trenches.
This variability is actions are needed for specific compounded by internal dans in the trenches or parts of trenches, trenches resulting from cperations.
e 03/22/83 17 MAXEY FLATS RESEARCH OBSERV
Observations Conclusions k.
Recent site operations have revea19d There presently is not adequate the presence of several areas knowledge of the thickness of cover where waste is within inches of the over all trench areas at Maxey Flats, ground surface.
In at least two There is no assurance that wastes instances, the waste had been are indeed buried with the required covered with lead sheets to reduce 1 meter soil cover. Thus, any onsite surface radiation exposure rates surface recontouring (i.e., rebuild-(Mills),
ing) should be carefully planned and monitored.
Erosion of the surface must also be minimized.
1.
Under present license restrictions, Since several trenches now contain the evaporator system is limited leachate with tritium concentrations to processing leachate with tritium for in excess of these limits, the concentrations not exceeding 7 pCi/at, leachate requires dilution prior to gg, this translates to the current processing or redesign of the avapo-I
(
C F / tritium emi dion rate 7 permitted for rator to meet existing emission j
\\
the evaporator (Mills).
requirements, s.
Tritium was the most abundant radio-Chemically bound as HTO, tritium nuclide in the trench leachates has the greatest migration potential studied by BNL (BNL Reference 1.)
of any radionuclide, n.
Trench 30 contains tritium con-Substantial quantities (100,000's of centrations ranging from 34 to liters) of leachate from Trench 30 45 pCi/at (1982 data, Mills).
will need to be diluted with water containing low concentrations of tritium if the practice of dissipating tritium through the evaporator is co....oed.
03/22/83 18 MAXEY FLATS RESEARCH OBSERV
5.4 Subsurface Transport of Radionuclides Conclusions Observations a.
Activities of Sr-90, Co-60, and Pu Indicates onsite subsurface migration isotopes above background have been of radionuclides from trenches approx-
)
observed in wells U81 and U81-A, imately 10 meters away.
Transport is 1
together with organic compounds that through the fractured lower sandstone j
are also present in nearby trenches marker bed which is at the base of (BNL; Ref. 1 USGS).
most trenches at the site (Zehner written communication, February 14, l
1983),
t v'4 y b.
Excavation of experimental trenches Lateral transport of radionuclides by j
t parallel to Trench 27 resulted in subsurface flow may occur over short i
[k, a rapid (hours to days) inflow of distances in a relatively rapid time
]
water containing_ trench 1
- hate, frame, if open fractures exist.
A
< ----- ~gTy by fracture flowe The
'^1 distan between trenches ranged from 4-7 rg (PNL Ref. 1).
l c.
The data from the experimental This may be the result of organic
)
trenches and Trench 27 indicate that complexation of the radionuclides, adsorption does not markedly inhibit of chemical saturation of the the attenuation of radionuclide exchange sites by components of the l
gtration over short distances trench leachate, or of too little (4-7m)'(PNL Ref. 1).
contact time with the exchange sites.
i i
j d.
Pumping of leachate from the trenches The flow of leachate between trenches j'
does not rapidly affect the level of is small in volume when compared to j
leachateinancdjacenttrench the total leachate volume in the (Mills).
trench.
)
]
l i
4 i
03/2?/83 19 MAXEY FLATS RESEARCH OBSERV j
t Observations Conclusions e.
Leachate has been observed to Subsurface transport of trench leachate j
flow along the sandstone fracture has been physically observed to occur system underlying the site up to via fracture flow. Where unhealed distances of 100 meters (U.S.
fractures and hydraulic gradients exist Ecology fide, Zehner written at Maxey Flats there will be readily comunication, February 15,1983),
observable fracture flow in strata which exhibit low hydraulic conduc-tivity (see observation 4.2(a) and Section 3 item 6).
f.
Water collected from a seep along Onsite subsurface transport of the wall of Trench 46 during con-radionuclides in trench leachate struction contained H-3, Sr-90, has been observed where the flow Pu-238, Mn-54 and Co-60. These is through fractured rock.
radionuclides were transported by ground water from one of the other burial trenches at Maxey Flats.
Trench 46 was located 60 meter from the nearest waste-filled trench (U.S. Ecology fide, Zehner written comunication, February 15,1983).
g.
Tritiumconcentrationsinsg1 Comparison with tritium concentra-T solution at various depths (from tions in the cap over Trench 19-S 0.3 m to 7.6 m) 8 meters away indicates that the evaporator was
)
from Trench 195 are low, and they the source of the water and the Ic' decrease markedly with depth concentration at the 7.6 m depth i
(Schulz 1982, Ref. 2),
shows that the undisturbed profile l
15 quite impermeable to percolat-ing water. Water movement then in j
both the horizontal and vertical direction is very slow in the.
absence of fissures, I
03/22/83 20 MAXEY FLATS RESEARCH OBSERV
Observations Conclusions h.
Tritive concentrations in the The marked increase in tritium with trench cap of Trench 19-S depth (note observation g) in the increased markedly with increas-trench cap indicates that the waste ing depth in the trench cap is the principal source of the (Schulz 1982, Ref. 2).
tritium and not the evaporator.
4 Tritium from trench leachate would be available for root uptake by plants growing over the trenches, 1.
At Trench 19-S, the ratios of Not all of the complexed plutonium
'p[
plutonium to tritium decreases as remains mobile in the soil, a function of distance away from
[yb Trench 19 S (up to at least 6 m)
(LANL Ref. 2).
j.
In the Trench 19-5 study area The data suggest that the sandstone tritium concentrations are higher layer provides a partial barrier to above the sandstone layer than downward movement of water.
below (LANL Ref. 2, 3).
k.
Tritium concentrations are higher The data suggest that this inter-above the interface between the face provides for lateral flow of undisturbed profile and the land-infiltrated surface water, fill than below (LANL Ref. 2, 3).
1.
Laboratory studies of Maxey Flats Complexing by EDTA appears to be a l
shale and oxic waters which are potentially important mechanism spiked with various Organc chelat-that increases mobility of some ing agents showed a decrease in radionuclides such as Co-60, Pu-238, sorption coefficients relative to Am-241, and Sr-90.
EDTA is likely unspiked waters.
EDTA produced the to be present in most trenches.
most drastic change (BNL Ref. 1).
1 03/22/83 21 MXEY FLATS RESEARCH OBSERV
a J
i 5.5 Radioecolooical Factors
[
i I
Ob:ervattons Conclus1ons a.
Fescue grass extracts considerable Sampling of grass for tritium may water from the top 2 meters of trench be a useful method for determining T
caps but except for tritium the
, the location of poorly recorded l
grass,up very little radioactivity.
burial sites.
Transpiration by l
The tritium concentration in grass plants can provide an effective t
c i
from the caps was about 1,000 times means for gradually dissipating 1
l greater than in grass sampled 2-3
- tritius, meters from the trenches (UC8 Ref. 3).
I b.
Localized was of elevated tritium 1.
Data suggest subsurface flow of in tree leaven have been observed tritium to offsite, although f
along the west side, down-slope from the relative contributians from i
f Trench 31 (high tritium trench).
A air and surface pathways have 10X decrease in tritium was observed not been fully evaluated.
between 1981 and 1982 in leaves (PNL.
l verbal communication. W. H. Rickard, 2.
Trees (leaves and sap) may serve 1982), which coincides with the as useful post-closure biological installation of the plastic cover.
monitoring devices for trench leachate movement, particularly l
- tritium, f
f c.
Radionuclide concentrations in off-Measurements made to date indicate j
site surface soil and vegetation that the site appears not to have
]
(other than tritium) are essentially been significantly breached by sub-at weapons testing fallout levels in surface transport, except possibly areas free of surface runoff (PNL for tritium.
Additional monitoring l
Ref. 5, 6).
sites would be needed to adequately i
assess subsurface transport.
i i
s i
03/22/83 22 MAXEY FLATS RESEARCH OBSERV
!L
Observations Conclusions d.
Surface sediments in drainage areas One source of onsite surface con-adjacent to the site contain traces tamination may have been spillage of Co 60 in concentrations slightly of radionuclides during pumping of greater than in fallout, but low trench leachates in 1972.
The compared to other fallout radio-Co-60 was translocated by surface nuclides (PNL Ref. 7).
runof f into adjacent woods, e.
Plutonium-238 attached to sediments The apparent source of this has been observed in excess of back-plutonium has been erosion of t
ground concentrations in offsite contaminated surface soil, drainage areas (east and south drain-age areas) (PNL; EPA; XDHR fide Mills i
written communication March 14,1983).
l f.
Many operaHonal activities have been Current environmental assessment implementeo at the site in order to is complicated by past and on-effect stabilization, but the radio-going s%e operational activities.
nuclide concentrations observed off-site have remained reasonably con-sistent(Mills).
5.6 Engineering Factors Observations Conclusions a.
Subsidence has been noted to occur on Any site closure plan must address essentially all of the trench cap the inevitable probles of continuing j
covers. This subsidence has been subsidence of trench caps.
Subsi-I more readily observed since the dance problems could damage an engi-installation of the temporary surface neered and/or vegetated cover which plastic cover.
Subsidence has taken could collect precipitation and l
the fore of small area depressions, enhance water inflitration with large area catastrephic subsidence, its resultant accumulation, differential settlement within the i
trench boundaries, and subsidanc'd l
between the trench contents and the ur. disturbed soil side wall.
The l
subsidence is still continuing (Mills).
)
03/22/83 23 MAXEY FLATS RESEARCH OBSERV
Observatio.n_s, Conclusions b.
Water levels vary within trenches as lhe deliberate construction of is observed by sump liquid level internal trench dams, or those measurements even after pumping of inadvertently created by waste, liquid from one sump or a series of arke trench dewatering difficult sumps from the same trench (mills).
to accomplish, c.
Water levels in trenches which were The temporary plastic surface cover covered with the surface plastic is an effective short-term method have shown reduced increases in for significantly reducing infil-water levels when compared to tration and rasultant water accu-similar uncovered trenches (Mills).
mulation in the short term.
d.
Where perforations were present An impermeable cover must essentially in the plastic cover, soil be perfect or the defective cover moisture increased (UCB Ref. 3),
will function as a "one-way valve,"
letting water into the soil but preventing evaporation, i
e.
Soil moisture in the upper 0.9 to An impermeable cover will permit the 1.5 eeters has generally decreased site to be dewatered, and therefore since installing the plastic cover, eventually eliminate subsurface water where the cover is intact (UCB Ref. 3), and radionuclide transport.
i i
f.
Approximately 2-5 cm of the 115 cm Although only a small percent of i
total snnual rair. fall penetrated into the annual rainfall penetrated into the trenches before installation of the trenches before installation of l
the plastic cover (UCB Ref. 3).
the plastic cover, it still resulted j
in excessive water accumulation in the trenches because of the low
]
hydraulic conductivity of the media in which the trenches were excavated, i
j l
i 03/22/83 24 MXEY FLATS RESEARCH OBSERV
6 POSTCLOSURE MONITORING The research studies have identified needs and suggested potential methods for postelosure monitoring needed to assure that the radioactive wastes at Maxey Flats are behaving as predicted.
Radiological surveys of the site have defined the current distribution of radionuclides a,t the ground surface, in waters of shallow test wells on the site, in the biota surrounding the site, and in sediment from streams near the site boundaries.
The studies indicate that principal radionuclides which need to be considered in developing a monitoring program include H-3, Co-60, Sr-90, Cs-137, Pu-238, Pu-239/240, and An-241.
l Implementation of a monitoring program should be done in stages.
As data become available the program should be flexible enough to accommodate the changes that i
data indicate are necessary.
The panel made no specific recommendations as to methods f u monitoring radionuclide migration.
The panel noted that tritium can be a useful indicator of radionuclide migration in groundwater since it precedes other nuclides in the moisture front moving away from buried waste.
However, the presence of tritium in itself does not mean that other radionuclides will follow as they may be in an immobile form or their migration may be attenuated due to geochemical processes.
Some other methods which might be employed for sonitoring include vertical wells, inclined wells designed to intercept fractures and/or to measure downward flow into deeper rochs, porous cups, wells in the colluvium on the slopes bordering the site, monitoring trenches along the peri-meterofthesite,measurementsofbaseflowintothestreamsadjoiningthesite during low flow periods, and analysis of vegetation. The trees growing around the perimeter of the site may be good indicators of tritium migration from the site but may be inadequate to detect the acvement of complexed plutonium.
i It appears that, in the very complex hydrogeological system at Maxey Flats, a 1
site closure monitoring plan might well include consideration of each of the above methods to help ensure.that any subsurface flow, which would lead to j
movecent of contaminated water offsite, is observed in sufficient time to take l
appropriate. remedial action.
3ecause of the complex hydrogeology of the site, including the predominance of fracture flow, reliance should not be put on only
}
one surveillance eethod.
l 03/22/83 25 MAXEY FLATS RESEARCH OBSERV
i 7
SITE CLOSURE SCENARIOS Af ter considering all the observations and conclusions based on the available data pertinent to site closure, it was felt that site closure scenarios should be considered for two major time frames.
The first timo frame would be approx-I imately the first 100 years of closure durt,ng which institutional control could be provided.
In this period water infiltration and accumulation in the waste trenches should be avoided to prevent the offsite transport of tritium and other short-lived radionuclides via groundwater flow.
Af ter about 100 years, the f
tritium would have decayed to much lower levels and may no longer be a concern to human exposure (it would be about 0.2% of original burial a vitg.
In the first time frame various engineering activities and environmental control actions may be undertaken to innobilize the wastes and stabilize the site.
This could include actions to ameliorate any site stabiliza-tion prcblems that may develop. The institutional control during this period may control access to the site and use of the area.
A monitoring program will need to be maintained to assure that the site is performing as predicted and in compliance with closure requirements.
The major concerns for the second time frame, the past 100 year period, would i
encompass long-term site stability and the potential for offsite migration of
~
long-lived radionuclides (Sr-90, Cs-137. Pu-238) via the groundwater or by l
l overflowing trenches.
Plutonium is of major congnJnce approximately 63 kg i
(105 curies) of plutonium are buried at the site. 3 This plutonium has been p
I observed to have migrated for several meters from was,te trenches.
However
{
evidence developed thus far suggests that the plutonium is ab', orbed as it moves from the anoxic trench environment to the oxic soil environment a few meters j
from the trench. Our current state of knowledge contains,a number of important uncertainties (e.g., unknown environmental lifetime of the organically com-I plexed radionuclides; changes in soil retardation factors in going froa
)
anoxic to oxic conditions; comp 11cated hydrcgeology) so that it is difficult
)
. at this point to predict the amounts of Sr-90, Cs-137, and.Sr238 that would
)
or could ultimately migrate offsite.
It may be that totally insignificant J
4
)
03/22/83 26 MAXEY FLATS RESEARCH OBSERV l
amounts of these long-lived radionuclides would leave the site even if unre-stricted water infiltration occurred.
Af ter the 100 year period, tritius would have decayed to relatively insignificant levels (0.2% of original burial activity), and it should be possible to allow the site 'a be rW 'ored to the indigenous ecosystem or to some limited agricultural use. The panel dis-cussed the feasibility or advisability of 1,imited use without providing a recommendation.
The panel discussed three general scenarios for the short-ters (100 year) decom-missioning phase of the site which are sunmarized below. $1nce it would be inappropriate for this panel to define and recommend specific deconmissioning plans, the following should be considered as broad environmental and engineer-ing concepts in which costs and other socioaconomic and environmental impacts were not considered, and they should not be construed in any way as preferred or even reasonable alternatives. The people involved in developing site closure plans for the Maxey Flats Disposal Facility or any other low-level i
waste disposal facility are encouraged to examine the numerous alternative plans which are available, j
7.1 Leveled Site With Grassland Cover i
Brief consideration was given to the possibility of restorin; the site to the original leveled sloping condition with fescue grass cover as was maintained before the plastic sheeting was installed.
This type of cover if properly maintained could be expected to be quite effective in inhibiting water free infiltrating and accumulating in the trenches.
However, this method could not adequately restrict the percolition of rainf t11 through the soil to prevent accumulation of water in the waste trenches on an annual basis, s) ace the flow j
through the slopes and bottoe of the site is only about 0.3 ca per year.
There-j fore, it is obvious that a closure method which will provide more efficient j
water manager.ent must be considered.
l i
j l
l l
i 03/22/83 27 MAXEY FLATS RESEARCH OBSERV
7.2 Trenches Mounded and Veaetated (see Figure 1)
A proposed more effective system for controlling water infiltration would involve contouring the surface of the site into a series of mounded rows of appropriate slope to increase runoff but avoid erosion.
The grade of the slopes that could be used would be dependen,t on the characteristics of the cover selected.
The saterial covering the slope would be chosen to reduce infiltration.
Examples of materials considered by the panel fer covering the slopes of the mounds included vegetation, rip rap, or impermeable material such as asphalt, plastic sheeting, or concrete tiles.
Additional soil water control could be achieved by growing small trees or laige shrubs on the tops of the mounds.
Trees or shrubs should be selected whith develop deep root systems and evergreen species should be considered becaust they transpire throughout j
the year. By this method the precipitation which fa'ts upon sounded trenches, properly covered with vegetation, would be removed by tr 9spiration and ruNff.
The main advantage of this system is that it can inhibit water from getting q
into the trenches and provides an effective mechanism for removal of water that enters the soil. A negative water balance may be established especially in the 4
summer months, by the combination of the imperseable cover-drainage system and the vegetation. This method could result in the eventual dewatering of the l
waste trenches, and eliminate the problem of subsurface migration of radio-nuclides in groundwater to offsite locations.
It was felt that one person working fu'l time could maintain such a system.
Another advantage of this l
j method is that it would be relatively easy to eventually let the site return to a natural forest ecosystem after the initial 100 year period, b which time the j
tritium will have decayed.
Several factors that would need to be investigated
)
in planning this approach include:
l t
(1) Assessment of uptake of long-lived radionuclides (e.g., Sr-90, Cs-137, i
complexed Pu) by the vegetation; (2) Assessment of capabilities of deep-rooted plants to penetrate trenches j
and transpire infiltrating water; j
l j
03/22/83 28 KuEY FLATS RESEARCH OBSERV l
l l
j l
Figure 1.
Trenches Mounded and Vegetated.
I i
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l VEGETATION to remove moisture COVERED SLOPES to reduce by TRANSPIRAT10N INFI' TRATION i
I u
W 'b,_
fA N.
rY !, &.
% DRAINS to remove /
LOW MOUNDS to promote
)
RUNCFF RUNOFF i
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)
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1 j
1 1
(3) Assessment of effectiveness of vegetation in this system to transpire soil moisture throughout the year; and (4) Assessment of the ability of the plants to survive when exposed to the toxic chemicals and anoxic conditions in and close to the trenches.
The panel felt that if this cover system was given serious consideration as a short-ters (100 year) site closure scenario, it would be wise to convene a 4
peer review committee to examine such a system in detail.
Also, it m y be l
desirable to devise a small-scale demonstration project on the site to test the.Ifectiveness of this cover system before a full-scale application.
7.3 Hard Impermeable Enaineered Cover Over Site Another suggested means of covering the site to prevent water inflitration during the first 100 years of institutional control would be to cover the site with a hard impermeable engineered cover.
Such a cover would have to limit infiltration to less than 0.3 cm/ year to avoid water accumulation in the trenches. One suggested eethod would be to cover the site with an impermeable material such as concrete or asphalt.
This material would be laid out over slopes i
designed to handle runoff and it would have to include an effective surface drainage system.
The advantages of the impermeable cover are that it would be observable, repairable, resistant to biological intrusion and biodegradation, and subsidence could be repaired relatively easily.
Another advantage of such a system would be that it would discourage unintentional human intrusion for a j
long period of time. A serious disadvantage is that any leakage through the l
cover would constitute a major problem.
Therefore, if an impemeable cover was used, water levels in trenches would have to be carefully monitored.
For the long ters, that is, after institutional control has ended, a closure plan for an impermeable engineered cover would have to deal with failure of the engineered cover and reversion of the site to an indigenous ecosystes.
There may be considerable uncertainty as to the "smoothness" of this transition.
For example, the seasures taken to increase runoff will increase erosion. Without human intervention, this may lead to waste exhumation.
It would be difficult to transfer the controlled engineered system to a suitable long tern situation.
If I
03/22/83 29 PMEY FLATS RESEARCH OBSERV
pioneer vegeta-tion was permitted to gradually take over the site it could not be expected to be able to accommodate enough of the water falling on the site to prevent reflooding of burial trenches.
For reasons such as these, very care-ful consideration would have to be given to the effect of an engineered cover on the environment, its predicted performance in the absence of institutional controls, and to actions which should be taken to assure that the first phase of closure can be effectively transferred to the final closure phase.
i 4
An impermeable hard cover could be installed over the entire site or only over particularly problem waste trenches.
For example, about two-thirds of the Maxey Flat tritium inventory resides in a single trench, and it eay be feasible to construct an impermeable hard cover over only several of the trenches containing the high tritium concentrations.
If lateral subsurface flow from uncovered areas is not significant, then a partial cover over the problem areas could possibly be a short-ters (100-year) mitigative procedure for preventing signif-icant offsite transport of tritium, t
Complimentary to the above schemes (7.1, 7.2, 7.3), engineering methods should be considered to immobilize radioactive wastes within the trenches.
This could include various methods of fepregnating the waste with matrix naterials to reduce radionuclide migration, incorporating trench water in solidifying mate-rials, or compaction to reduce gradual settling of covered trenches.
These sethods could be incorporated with any of the above three general scenarios.
\\
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1 03/22/83 30 MAXEY FLATS RESEARCH OBSERV 4
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REFERENCES BML References Cryscinski, K. S., and A. J. Weiss, 1981, Brookhaver. National Laboratory, i
"Evaluation of Isotope Migration-Land Burial Water Chemistry at Commercially Operated Low-Level Radioactiva Waste Disposal Sites, Status Report October i
1979-September 1980," NUREG/CR-1862, BNL-N4 REG-51315 (BNL Ref.1).
Pietrzak, R. F., K. S. Czyscinski, and A. J. Weiss,1982, Brookhaven National Laboratory, "Evaluation of Isotope Migration-Land Burial Water Chemistry at Comercially Operated Low-Level Radioactive Waste Disposal Sites, Status Report, October 1980-September 1981," NUREG/CR-2616, BNL-NUREG-51514 (BNL Ref. 2).
Pietrzak, R. F., R. Dayal, M. T. Kinsley, J. Clinton, K. S. Cryscinski, and A. J. Weiss, "Trench Water Chemistry at Comercially Operated Low-Level Radio-active Waste Disposal Sites," in Proceedings of the 1982 Annual Meeting of the Materials Research Society, Boston, MA (in press) (BNL Ref 3).
Comonwealth of Aentucky References Mills, D.,
and R. Page, 1982, "A Brief Overview of Remedial Actions Necessary at Maxey Flats," in Proceedings of Fourth Annual Participants Information Meet-ing, DOE-LLW Management Program, Oak Ridge National Laboratory ORNL/NFW-82-12.
t l
LANL References Poirer, W. L., E. H. Essington and E. B. Fowler,1981, "Migration of Waste Radionuclides Through Soils at Maxey Flats, KY", In:
Research Program at Maxey
{
Flats and Consideration of Other Shallow Land Burial Sites. NUREG/CR-1832, PNL-3510. U.S. Nuclear Regulatory Comission, Washington, D.C., March 1981, (LANL Ref.1).
Polzer, W. L., E. B. Fowler and E. H. Essington,1982, "Potential for Migration of Waste Radionuclides at the Maxey Flats, KY Shallow Land Burial Site," In:
Radionuclide Distributions and Migration Mechanisms at Shallow Land Burial Sites, NUREG/CR-1383, U.S. Nuclear Regulatory Commission, Washington, D.C.,
July 1982 (LANL Ref. 2).
Polzer, W. L., E. N. Essington and E. B. Fowler,1982, "Transport of Waste Radionuclides Through Soil," Draft of Annual Report, FY 1982, Los Alamos National Laboratory Los Alamos, New Mexico (LANL Ref 3).
PNL References Kirby, L. J.,
1981, "Chemical Species of Migrating Radionuclides at Maxey Flats and Other Shallow Land Burial Sites," In:
Research Program at Maxey Flats and Consideration of Other Shallow Land Burial Sites NUREG/CR-1832. PNL-3510 U.S. Nuclear Regulatory Commission. Washington. 0.C., March 1981 (PNL Ref.1).
03/22/83 31 MAXEY FLATS RESEARCH OBSERV
Kirby, L. J., C. W. Thomas, A. P., Toste and C. L. Wilkerson, 1982, "Chemical Species of Radionuclides at Maxey Flat," In:
Radionuclide Distributions and Migration Mechanisms at Shallow Land Burial Sites, NUREG/CR 2383, PNL-4067, U.S. Nuclear Regulatory Commission, Washington, D.C., July 1982 (PNL Ref. 2).
Kiraby,L.J.IdesatCommercialShallowLandBurialSites.W. H. Rickard and A. P. Teste, 19 ing Radionuc1 Quarterly Progress i
Report April-June 1982, PNL-4432-1, Pacific Northwest Laboratory, Richland, WA., August 1982, (PNL Ref. 3).
l Kirby, L. J. and A. P. Toste, 1982 Chemical Species of Migrating Radionuclides at Comercial Sha11cw Land Burial Sites.
Quarterly Report, July-September 1982 PNL-4432-2, Pacific Northwest Laboratory, Richland, WA., October 1982, (PNL Ref. 4).
l Rickard, W. H., L. J. Kirby and M. C. McShane,1981, "Radioecology Studies at Maxey Flats, Kentucky:
Radionuclides in Vegetal Samples" In:
Research Program j
at Maxey Flats and Consideration of Other Shallow Land Burial Sites, NUREG/
CR 1832, PNL-3510. U.S. Nuclear Regulatory Comission, Washington. 0.C.,
March 1981, (PNL Ref. 6).
Rickard, W. H., L. J. Kirby and M. C. McShane,1982, 'Radioecology of the Maxey Flats Site," In:
Radionuclide Distributions and Migration Mechanisms at Shallow Land Burial Sites, NUREG/CR-2383, PNL-4067, U.S. Nuclear Regulatory Comission, Washington, D.C., July 1982, (PNL Ref 6).
I Kirby, L.
J., 1982, "Areal Distribution of Radionuclides at Maxey Flats," In:
Radionucilde Distributions and Migration Mechanisms at Shallow Land Burial Sites, NUREG/CR 2383, PNL-4067, U.S. Nuclear Regulatory Comission, Washington, j
0.C., July 1982, (PNL Ref. 7).
UCB References Schulz, x. K.,1981, "Study of Unsaturated Zone Hydrology," In:
Research Program at Maxey Flats and Consideration of Other Shallow Land Burial Sites, NUREG/CR-1832. PNL-3510 U.S. Nuclear Regulatory Comission, Washington, D.C.,
March 1981 (UCB Ref. 1).
I Schulz, R. K.,1982, "Study of Unsaturated Zone Hydrology at Maxey Flats," In:
Radionuclide Distributions and Migration Mechanisms at Shallow Land Burial
$ttes, NUREG/CR 2383, PNL-4067, U.S. Nuclear Regulatory Comission, Washington, 1
D.C., July 1982, (UCB Ref. 2).
Schulz, R. K.,1982, "Study of Unsaturated Zone Hydrology at Maxey Flats," in Proceedings of Fourth Annual Participants Inforsation Meeting, DOE LLW Manage-serit Program, Oak Ridge National Laboratory, ORNL/NFV 82-12, pages 423 436, (UCB Ref 3).
i 1
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1 03/22/83 32 MAXEY FLATS RESEARCH OBSERY
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USGS References Cleveland, Jess M., and Terry F. Rees, 1981, "Characterization of Plutonien in l
Maxey Flats Radioactive Trench Leachates " Science Vol. 212 June 26, 1981, pages 1506-09.
Zehner, Harold H.,1979, "Preliminary Hydrogeologic Investigation of the Maxey i
Flats Radioactive Waste Burial Site, Fleming County, Kentucky," U.S. Geological Survey, Open File Report, 79-1329, 66 pp..
Zehner, Harold H., October 26, 1982 Verbal Communication, Oral Presentation on l
USGS Research at Maxey Flats made at the Maxey Flats Disposal Facility.
Zehner, Harold H., February 14, 1983, Written Communication, Written Comments on the January 14, 1982 draft of this report, a
Other References Clancy, J. J., D. F. Gray, and 0. I. Oztunali,1981, "Data Base for Radioactive Waste Management--Review of Low-Level Radioactive Waste Disposal History,"
NUREG/CR 1759, Vol. 1, pp. 3 1 to 3-20.
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RADICASTIVE MATERIAL INSPECTION RkP8RT Maxey Flats Disposal Facility Page 2 of 9 i
i 1.0 LICENSING HISTORY Since the previous inspection Amendments 12 15 vere issued.
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Amendment 12 was for renewal Amendment 13 ado } Work Procedure 17 regarding respiratory program.
Amendment 14 added Work Procedure 19 regarding direct reading dosimeter testing and QA I
program.
Amendment 15 was for renewal.
2.0 SITE DESCRIPTION 4
The site is located on the flat-topped ridge known as Maxey flats situated between Morehead and Flemingsburg, Kentucky.
Site access is via a road known as Maxey Flats Road (State Road 1895) 1 located approximately six miles northwest on State Routs 32 from i
the Route 32 and Interstate 64 junction.
l The Site is a 280 acre parcel of land owned by the Commonwealth l
of Kentucky.
It is bounded on three sides by steep slopes covered with native vegecation.
The Site boundary has been described in the /leming County Court C1stk Deed Book on page 274 l
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of Deed Book # 120 (1963) and page 65 of Deed Book #148 (1978).
I Radioactive material haa been buried in currently 51 trenches, I
excluding hot wells, within the designated restricted area of j
approximately 25 acres.
The perimeter of the restricted area is l
surrounded by a continuous six foot high chain link fence topped i
with three strands of barbed wire.
t 3.0 ORGAN!ZATVON l
The license is issued to Natural Resources and Environmental i
Protection Cabinet wh.Jh is managed by the Division of Waste Management. Permit Review Branch.
The Division Director is J.
l Alex Barber and Branch Manager is Caroline Patrick Haight.
The i
Radiation Protection Officer for the licensee is Doyle Mills.
I The nn-site activities is contracted to Westinghouse Electric, Inc. for the performance of day-to-day management and operational i
functions.
The on-Site Radiation Protection Officer is John 1
Razor.
The on-site workers repcrt to the on-Site Radiation i
Protection Officer.
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j 4.0 PERSONNEL f
The personnel on-site are designated into classifications according to qualifications of training.
The current classifications are radiation worker, non-radiation worker.
visitor and contr0ctor personnel.
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Page 3 Cf 9 4.1 Radiation Worker Personnel who work in restricted areas are trained and qualified as radiation workers.
The qualification is that the individual has attained their 18th birthday and training consists of successfully completing (70%) the Radiation Worker Training Cuurse presented in WPr6.
Since last inspection, two additional personnel were designated as radiation workers.
A review of training records revealed no documentation was available for one of these individuals i
indicating successful completion.
This is an 111g_o1 non-compli agg.
Currently, six individuals are designated t
l as radiation workers.
Radiation workers are given periodic training in the form of monthly safety meetings covering various topics of the i
radiation protection program.
Minutes are maintained of the meetings and each attendee must initial indicating their presence.
A review of the minutes indicated appropriate topics and attendance by personnel.
4.2 Non-Radiation Workers Site personnel who do not work in the restricted area are j
classified as non-radiation workers.
Non-radiation workers receive instruction r.o to understand the radiation environment outside the restric';ed area, posting of radiation areas, and restrictions of crossing barriers.
If a non-radiation worker require occasional access to the l
restricted areas, they are treated as visitors.
i 4.3 Visitors and Contractor Personnel Persons who require occasional access to restricted areas but have not successfully completed the radiation worker training are escorted by a radiation worker.
If a person 1
has a specific function and has no access to high radiation or contaminstad areas. limited training is provided j
commensurate with the work.
I No problems were noted in this area with the exception i
identified in 4.1.
5.0 ACTIVITIES The activities performed at the site are components of three broad prcgrams.
They are health physics progran, water l
management program and water accumulation minimitation program, i
Each program and the findings are discussed below.
5.1 Health Physics Progran i
1 The health physics program contains requirements for contr:111ng and monitoring personnel exposure to external
)
and internal radiation.
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Pago 4 of 9 5.1.1 External Radiation Exposure Personnel on-site are issued a whole body TLD processed by Eberline on a monthly basis.
The results are then transferred to Form KR-401.
A review of the results indicated the greatest exposure in a month was 125 mRen shallow dose.
All individuals entering the restricted area are issued a TLD or a pocket dosimeter.
A visitor register is maintained indicating date, badge number, name, company, time in and time out.
The badge number column includes the TLD number or pocket dosimeter serial number including initial and final reading.
Primarily, recorded readings of the pocket dosimeters were zero with the highest as three.
No problems were noted.
The pocket dosimeters utilized undergo a testing and quality assurance program.
Each pocket dosimeter is tested for leakage on a quarterly frequency with a 5% of full scale in a 24-hour period as a tolerance level.
Each pocket dosimeter is also tested annually for response with a response greater than i 20% from the theoretical response as a tolerance level.
Since last inspection, three pocket dosimeters were removed from service for failure to meet the tests.
Porty-five pocket dosimeters are in use.
No problems in this area were noted.
5.1.2 Internal Radiation Exposure Personnel whose duties include handling or processing trench leachate or under support participate in a weekly urine bioassay for tritium.
Others participate on a monthly basis.
Since last inspection, results of the tritium bioassay indicated the highest sample was 62 pCi/ml versus the expected concentration yielding a body burden is 23,000 pCi/ml.
Semi-annually bioassays for St-90 and Cs-137, analyzed by Teledyne, are also conducted.
The highest readings were slightly above minimum detectable limits.
Ito problems noted in this area.
Page 5 of 9 5.1.3 Radiation Surveys Personnel contamination surveys are made by each individual of their own person prior to leaving the restricted area.
The date, time, name and count rate is recorded.
The background is determined once daily by senior personnel.
Any count rate of 100 cpm above background requires decontamination.
Daily contamination surveys are conducted of the change building.
Swipe locat. ion always includes the lunch table then one or two other locations.
Each location is measured using a pancake probe G-M and alpha proportional meter.
Weekly, the swipes taken for the week are analyzed in a gas laboratory gas proportional counter.
Weekly contamination surveys are conducted of the evaporator building, assistant RSO office, and yard equipment.
Method of counting is the same as daily surveys.
In addition, a general radiation survey is conducted to detect the highest reading obtainable and general area levels of radiation (mR/hr).
Monthly contamination surveys are conducted in the main office and maintenance.
Records of this i
activity is similar to daily surveys.
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Radiation detection instrumentation used for personnel and contamination surveys are calibrated on a six month interval by Eberline.
The efficiency vf each instrument is determined by the licensee.
Each survey record includes the instrument used by serial number therefore a random cross-check was performed to assure instruments used were calibrated.
The only exception is the record for personnel contamination surveys.
There is not currently a j
method to determine which instrument was used for i
the survey thus verifying a calibrated instrument was used.
This was mentioned to the licensee but is not considered an item of non-compliance.
No problems were noted in this area.
P0g3 6 of 9 S.1.4 Environmental Monitorina An air monitoring system is employed at fourteen locations.
These locations are within the restricted area, perimeter of the restricted area and unrestricted area.
Each location includes a vacuum pump, rotameter, particulate filter, TLD and a bubbler.
Samples are collected weekly for tritium, gross alpha, gross beta and gamma analysis.
The TLDc are processed quarterly.
The limits are those specified in 902 KAR 100:025 for air.
Analysis indicated the greatest concentrations were less than 2% of the MPC.
The rotameters used in the air monitoring system are calibrated on-site.
A standard rotameter which has been certified by the manufacturer to be accurate within 1 2% of full scale is used.
A correction factor is then determined for each rotameter.
This activity is conducted on a quarterly frequency.
A record is maintained of this activity and labeling of each rotameter is performed.
The environmental monitoring also includes:
surface runoff water weekly, if available; stream sampling by automatic and grab samples; stream sediment semi-annually; groundwater by wells; and crop sampling.
Generally euch sample has an analysis performed for gross alpha, gross beta, i
tritium, and gamma emitters.
Sediment samples are analyzed for Sr-90, Pu-238, Pu-239/240 and gamma emitters.
Other samples may have specific analysis performed.
The licensee also monitors rainfall.
No problems were noted in this area.
5.1.5 Effluent Monitorino The evaporator was shut down April 28, 1986 and s
operations have not resumed.
Therefore, effluent j
monitoring has not been conducted.
S.1.6 Protective Equipment The licensee maintains a respiratory program.
Since last inspection, no actual use has been required.
The personnel have had a complete physical with only two individuals repeating the physical within the last year.
Annual physical must be perf ormed prior to use of respiratory equipment.
No problems noted in this area.
t Page 7 of 9 5.1.7 Laboratory Analysis Analysis of sampler are performed on-site or sent to commercial labs.
The on-site lab participates in U.
S. Environmental Protection Agency cross check program for tritium in water, tritium in urine, gamma in water, gross alpha and beta in water, and gross alpha and beta and cesium-137 in air.
A review of the results was not conducted.
5.1.8 Site Security As stated in site description, the restricted area perimeter is surrounded by a continuous six foot high chain link fence topped with three strands of barbed wire.
Since the last inspection, an additional wire-coated fence was installed within the restricted area.
This fence permits further control of vehicles and persons which have entered the trench and work building areas.
Access is controlled by key control by persons designated by the RPO.
No problems were noted in this area.
5.2 Water Management Program The water management program contains requirements for trench dewatering and contaminated water treatment and/or disposal.
5.2.1 Trench Dewaterino The licensee performs water level measurements of each sump located in the trenches on a monthly basis.
A summary is conducted f or sump levels that have increased by four-tenths of a foot.
The licensee is required to classify each trench based on liquid level and use this classification for priority of trench pumping.
However, trench dewatering is not currently being conducted.
This is an item of non-compliance; however, after discussions with Mr. Hughes, Manager Radiation Control and Mr. Moore, Director Division of Radiation and Product Safety, their recommendation and directive is to exempt the licensee from this requirement with stipulation.
This exemption shall be by amendment.
4 Page 8 of 9 Existing leachate and any pumped liquids, primarily from building sumps, is stored in tanks within two buildings.
The area within the buildings are bermed in case of f ailure of a tank.
During the walk-over, it was noticed that water was standing in the floor of both buildings.
Investigations have been conducted by the licensee to determine the source with no final determination.
This item will be monitored for any action necessary.
5.2.2 Contaminated Water Treatment and/or Disposal Since last inspection, contaminated water has not been processed for treatment or disposal.
5.3 Water Accumulation Minimization Program The water accumulation minimization program consists of trench cover maintenance, drainage improvement and control, contaminated waste solidification, and solid waste disposal.
b.3.1.
Trench Cover Mrintenance The trench caps are covered with 6 ml plastic.
Monthly a walk-over is performed to detect splits or holes.
Remarks are made on the trench leachate level summary.
The splits or holes are repaired and the plastic is replaced approximataly every 2 years.
No problems were noted in this area.
5.3.2.
Drainace Improvement and Control As a result of the last inspection, the erosion problem on the next hillside associated with the detention pond was cited at a non-compliance item.
The licensee has addressed the problem by identifying alternatives for correction with concurrence of this office of the most appropriate option.
Finalization of the approval process has not been completed; therefore, this will remain as pending.
5.3.3.
Contaminated Waste Solidification Since last inspection, no activity in this area has been conducted.
5.3.4.
Solid Waste Disposal Since last inspection, no solid wa<te has been disposed.
All waste is currently being held in storage.
(.
Page 9 of 9 6.0 AUDI'l PROGRAM The RPO conducts quarterly audits of the licensed activities.
Each area of review is reported with any problems noted to the Site RPO.
The quarterly audits are submitted to this office.
No problems noted in this area.
7.0 INCIDENTS No incidents have occurred.
8.0 EXIT INTERVIEW An exit interview was held with licensee representatives on November 5, 1987 concerning the findings.
The attendees were Doyle Mills, John Razor and Mark Mays.
The discussion included the lack of training records, method to indicate instrument used for personnal contamination surveys, trench pumping, pending erosion control and the standing wtter in the tank farm buildings.
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Summary Reoort During 1987, 2076 water samples were collected in the environment surrounding the Maxey Flats Disposal Site (MFDS) to a distance of 4.5 air miles.
The Radiation Control Branch Laboratory performed 7298 analyses on these samples with an additional 4278 quality control analyses performed to insure the accuracy and precision of these tests.
Mean tritlated water (HTO) concentrations for off-site sample locations (excluding test wells and soll lysimeters) ranged from 633.7 pC1/ml at Location D33LN4 on the west hillside at MFDS to 0.1 pCl/ml in Fox Creek at the Ringo Mills covered l'rldge.
Location D33LN4 has been dry since the first week in May.
,. large number of sampling locations in washes and creeks surrounding the MFDS were dry from late spring through mid-November; therefore, no data is available for these locations during a substantial period of 1987.
Location 113 in the east drainage channel at the MFDS exhibited a mean HTO concentration of 189.3 pC1/ml for 1987.
Location 113 is at an elevation of 800 feet above mean sea level or approximately 250 feet below MFDS.
This was the highest mean HTO concentration at any location which was not dry for an extended period during 1987.
Location 1131s on state controlled property and a significant distance from the first resident which would be adjacent to Location 106.
Location 106 is at the intersection of No-Name Creek and Rock Lick Road. In 1987, the mean tritium concentration at Location 106 was 13 3 pC1/ml.
These values are in comparison to a limit of 3,000 pC1/mi imposed by state radiation regulations for controlled release of tritium to the environment.
All alpha and beta activities were within normal environmental levels.
No nonnaturally occurring gamma emitters were detected above normal fallout levels.
Dose from tritium in water for the first resident in the east drainage area at Location 106 would be approximately 1.0 mrem /yr.
- Water, if used for drinking purposes, from Location 143, south drainage at Rock L!ck Road, would yleid a dose from tritium of approximately 2.4 mrem /yr for the first resident.
In the west drainage area a dose of 1.0 mrem /yr for the first resident would result from tritium in water at Location 145 in Drlp Springs Creek, if water at this location was used as a drinking source.
At a distance of 2 air miles from the MFDS in Fox Creek af ter its confluence with Rock Llck Creek the dose from tritium in water, if this location was used as a drinking water sources, decreases to < 0.07 mrem /yr.
At 4.5 air miles from the site the mean annual tritium concentration is less
than the Minimum Detect 0ble Activity of OA pC1/ml for our analytical system used to measure tritium in water, Finally, the mean annual tritium concentration in water from the public water system at Hillsboro is also less than our Minimum Detectable Activity.
For comparison, the worldwide level of tritiu m is approximately 0.2 to 0.3 pC1/ml due to weapons testing and naturally occurring sources.
Doses are calculated according to U.
S.
Nuclear Regulatory Commission Regulatory Guide 1.109. A usage value of 730 liters / year (approximately 2.1 quarts or eight 8-ounce glasses per day) for drinking water for all locations was used as recommended in Regulatory Guide 1.109 for the maximum exposed individual.
The usage value (730 liters / year) is used in lieu of site specific knowledge since these locations are not used as a drinking water source.
Since no individual actually obtains water from any streams in this area for drinking water, these values are only useful as an indicator of the maximum exposed individual in the drainage areas surrounding MFDS.
Based on the environmental data (evaluation of dose from tritium) generated by this agency during 1987, the MFDS does not pose an environmental or public health threat to the citizens of Fleming or surrounding counties.
Mean activities for 1987, at all locations are provided and the data summaries upon which these mean activities are based is enclosed.
Maps of sampling locations have been provided in previous reports, therefore. no maps are included in this year end report.
Included in the year end report is data for off-site locations, washes, monitoring wells (water
- levels, tritium concentrations and conductivity measurements), the public water supply at Hillsboro, and soll lystmeters (soll water samplers; porous cups).
Statistical analyses were performed for locations provided sufficient data was available. Descriptive and comparative statistical analyses were conducted for most locations. Scattergrams were prepared and simple regression analyses were attempted, if the data could not be fit by simple regression analysis, no further attempts were made at more complex analyses.
This type of analysis provides a useful indicator of trends and seasonal variations in tritiu m in the environment.
Such analysis over a number of years can provide valuable insight into the stability and integrity of MFDS.
Included in this year end report are three documents dealing with various aspects of the Radiation Control Branch's environmental monitoring program at MFDS.
These documents are as follows: (1)
Maxey Flats off-Site Environment Data: 1977 to 1986; (2) Daily Tritium Activity in Surface Water in Rock Lick Creek at Highway
158-Location 102; and (3) Compilation of Deta for the UE-Series Wells l
and Well North-28 at the Maxey Flats Disposal Site: 1984-1986.
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106 11.9 112 1.5 113 109.3 l
144 63.9 119 0.2 120 0.6 121 0.5 122 0.3 124 6.8 130 0,1 132 0.9 133 30 145 13.1 136 0.2 Itnlmum = 0.1 et Locellori 130 Maximum 189.3 at tocellon 113 I
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6ross Seta and A164 ActMiy Ior 1987 At off-site Locations Swrounding Maxey Flats Disposal Site location Beta Act. (pct /1)
Alpha Act. (DCl/l) 101 5.2 1.3 102 7.0 1.2 103 5.9 1.1 143 6.5 1.7 106 S.0 1.1 i
107 52 04 l
1 106 4.6 0.6 112 6.0 1.0
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113 17.7 2.0 144 11.0 1.5 119 3.7 0.6 120 8.2 3.9 121 5.6 0.6 122 4.1 06 124 3.0 0.3 130 5.4 1.0 132 0.0 0.8 133 6.6 1.9 145 7.4 1.1 136 5.4 1.1 I
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Trittated Water (HTO), Beta and Alpha ActMty For 1987 From Public Water Sectly at Hitsboro, Kentucky I.ocation pCIHT0/mi Beta Act. (DCi/l)
Alpha Act. (pCi/1)
West Fleming Water Olstrict
-0.03 2.9 0.3 l
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HTO Comparslon for 1967 in the East Drsin at Maxey Flats Disposal Site Collection Date LocaUon 113 (PCI HT0/ml)
East Drsin Outlet (pCI HT0/ml)
SM7 372 105 20-Jan-67 112 15 2-fe647 76 41 25-feb-67 79 941ar-67 280 97 2541er-67 385 20 6-Ace-67 til 27 20-Aor-67 320 15 5-day-67 326 to IS-May47 486 9
2-Jun-67 262 9
15-Jun-87 345 11 i
29-Jun-67 341 2
l 13-Jul-87 85 5
27-Jul-67 45 4
4 10- Aug-67 63 4
24-Aug-67 125 5
6-Sep-67 239 6
l 22-Sep-67 142 4
l 5-Oct-67 116 8
I 19-Oct-87 209 8
2-Ncy-67 147 14 16-Nov-67 150 16 30-Nov-67 43 9
14-Oec 67 26 12 26-Oec 67 IS 9
Meana 109 Macia 21 Std. Dev.=
132 Std. Dev.s 26 Masimum=
466 Masimum=
105 Minimum =
15 Minimum =
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1 Tritisted Water DiTO), Beta and Alpha ActMty For 1987 in Wash 7 at the Naxey Flats Weste Disposal Site i
Location pCIHT0/ml Beta Act. (pCl/l)
Alpha Act (pCi/l) j J107 15 6.1 0.9 l
OCl 1202 72 1.0 H107 16 4 5.9 12 6107 26 2 7.3 1.7 F107 36 4 4.7 12 E107 39 4 4.7 1.1 0107 372 4A Ob C107 39.0 4.1 0A W7st50' 36 4 45 15 W7stRd 42 2 4.0 0.9 B107 38.0 3.9 0.7 t
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Tritiated Water (HTC), Beta and Alpha ActMty for 1987 in Wash from S;vth Drsin of 33L st Namey Flats Weste Disposal Site Location pCiHT0/mi Beta Act. (pCl/l)
Alpha Act (pCl/1) 114 30.3 11.8 22 Wild 27.4 10.1 22 i
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e TrillatedWater(HTC) Beta and Alpha ActMty For 1967 In lipper logging Road et Maxey Flats Weste Disposal Site Location pCIHT0/mi Beta Act. (pCl/l)
Alpha Act (pC1/1)
Drain North Pond 46.1 9.0 1.0 Logging Road (LGRA) 54.5 7A 1.1 Lo9ging Road (LGRD) 19 5 12 4 4A 4
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1987 in Wash Crested by North Drain of 33t at Maxey Flats Westa Olsposal Site i
i location pCi HT0/ml Beta Act. (pCl/l)
Alpha Act (pCI/l) l 035tN3 586.5 5.5 0.4 D33LN4 621.7 14.9 2.5 Wbytu 31 2 5.8 24 d
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In W-Wells et Mawy Flots Disposal Site f
r (ocation Mean WCi HT0/mi W-1 0.96
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E-2 0.62 W-3 0.17 W-7 0.023 W-6 0.047 W-9 0.017 f
W-11 0.16 i
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\\1-2 622096 tf-5 310769 LF4 18692 LF-6 620 15-10 685 LF-11 4
LF-12 8
LF-13 3
LF-14 4
LF-15 6
LF-16 2
i LF-17 5
LF-18 1
LF-19 1
LF-20 2
17-21 0
LE-22 5
LF-23 13 t1-24 4
LF-25 3
LF-26 186 LF-27 2
15 -28 4
(K-29 2
LF-31 2
LF-32 6
(E-33 2
LF-34 5
LE-35 3
th -36 185 LF-37 1014 LK 36 6
11 39 1
17 40 51 (M-41 2
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LF-43 6
1 ts 44 1
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W 47 9
tf-46 34 LK-49 103 1
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Tritiated Water (H10)Mean ActMty For 1967 in U6-Wells at Maxey Flats Disposal $tte location Mean pCI HT0/ml 06-1 344816 l
U6-2 100044 J
06-3 110 U6-4 128 06-5 59 U64 1751 U6-7 5631 i
U64 12 i
U6-9 35 1
06-10 2512 i
06-11 9299 r
U6-12 110567 i
06-13 2778 i
06-14 10 i
U6-16 5
06-17 176 l
06-18 63 06-19 153 2
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TntiatedWater(HTO)Hean ActMty For1987 In UK-Wells at Maxey Flats Disposal Site location Mean DCI HT0/mi UK-1 397224 UK-2 1425849 UK-3 64 W4 2
UK-5 31 UK-6 6
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Wallace G. Wilkins secasun 0 ""
CoMMoNwtAttw or Kturucxy NATURAL RESOURCES ANO ENVIRONMENTAL PROTECTION CA81 NET DEPARTMENT FOR ENVIRONMENTAL PROTECTION FRANKFORT OFFICE PARK 18 RElLLY RoAo FRANKFORT. KENTUCKY do601 J:nuary 27, 1988 Donald R. Hughes, Sr., Manager Radiation Control Branch Cabinet for Human Resources 275 East Main Street Frankfort, Kentucky 40621
Dear Mr. Hughes:
Enclosed please find a copy of the fourth quarttr 1987 audit of the Maxey Flats Nuclear Taste Disposal Facility as required by the Cabinet for Human Resources Radioactive Materials 1.lcense 206 002-03. This quarterly audit was performed on January 6,7 and 11,1988.
i There appears to be no deficiency in practice or process observed during the audit, if you should have any questions or comments on the enclosed audit, plea.
call Doyle Mills or me at 564-6716.
Sincerely, D
-hN j
, Caroline Patrick Haight, anager Uncontrolled Sites Branch CPH:DMimip Enclosure i
cc D. Mills J. Razor i
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Cari H Bradley I
I Wallace G. Wilkinson owtae sacasu n COMMONWEALTH of KENTUCO NATURAL RESOURCES AND ENVIRONMENTAL. PROTECTION CABINET DEPARTMENT FOR ENVIRONMENTAL PROTECTION FRANKFORT OFFICE PARK 18 REILLY RoAo FRANKFORT. K[NTUCKY do6ot t
MEMORANDUM TO:
Caroline Patrick Haight, Manager Uncontrolled Sites Branch V
FROM:
Doyle Mills, Chief i
Maxey Flats Section l,
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DATE:
January 27, 1988 i
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SUBJECT:
Maxey Flats Quarterly Audit - Fourth Quarter 1937 i
As specified in Section 6 of the license operation Radiation Protection Program Manual for the Maxey Flats Nuclear Taste Disposal Site, the fourth quarter 1937 audit was performed. Audit areas specified in Section 2.2.1.1 of the manual were covered during the audit which was conducted on January 6,7 and 11, 1938. This record of the audit will be organized according to the subjects specified in that Section.
Occupational Radiation Exposure Monitoring and Control J
Whole body exposures and bloassay records were reviewed for Brown; Frank; i
Heath; Kornman Pol!1tt; Razor; Stamper; and Buinickas. Whole body dosimetry T1.D badge data for all employees identified above Indicated that all external exposures were zero (0) for the September th',dy exposure is 1250 mRem ough November 1987 time period.
The quarterly license limit for external whele F.
4 I
No seasonal laborers were utilized during this quarter.
One university researcher was on site during the quarter and his whole body dvsimetry T1.D badge indicated all external exposures were zero (0) for the September through November 1937 time period.
j The Superfund contractor and oversidht staff personal lon chamber data indicated values similar to our contractors,i.e. mini'na: total monthly values.
The weekly on-site tritium in urine bloassay data indicated that those persons working on site received less than 0.3 parcent of the maximum permissible body burden (MPBB) of tritium during this quarter. The hl; hest tritium bloassay sample
)
reported dJring this quarter occurred on October 16, 1937 and was 74 pCl/ml
]
versus an action limit of 23,000 pCi/ml.
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The commercial third party bloassay samples were collected and shipped for analysis at the end of the quarter. The results are anticipated to be received during the first quarter of 1988.
Site Radiation Surveys The monthly and weekly radiation surveys were being conducted as required by the license. The evaporator building maximum exposure level was reported as 6 mR/hr and the general area exposure level was reported as 0.2 mR/hr for the quarter. Limited contamination was noted in the area of sumps, evaporator floor, the work table area, and the bottom landing of the stairs. The Assistant Radiation Safety Officer's office had a maximum exposure level of 2.3 mR/hr and the general exposure level was reported as 0.2 mR/hr during the quarter. The large tank farm building had a quarterly maximum exposure level of 3 mR/hr with a general area exposure level of 0.3 mR/hr inside the building. The small tank farm building had a quarterly maximum exposure level of 1 mRhr with a general area exposure level of 0.2 mR/hr inside the building. The Pole Building had a maximum exposure level of 0.2 mR/hr reported for the quarter.
All areas were decontaminated (if necessary) in accordance with Work Procedure WP-9.
Building 3 South Bay has been cleaned for use by Superfund contractors. Due to the contaminated liquid existing in the floor of the large and small tank farm building, entry onto the building floor is prohibited.
As a result of this fact, the Cabinet for Human Resources has allowed the general area exposure measurements to be performed from the berm areas.
The snack area in the change building had daily surveys performed and recorded. The gross alpha and gross beta readings were generally at or sligh'.ly above minimum detectable levels. The weekly laundry survey and check-off v.ere also performed and recorded as required by the license. As a result of a clord out comment during a Cabinet for Human Resources inspection, the laundry survey documentation has been increased to mora t!early specify the survey equipment and probe.
The employee personnel dosimeter (PIC) readings were reviened and were generally less than 10 mR for any given month in the quarter. The PIC values were consistent with the TLD whole body dosimetry data.
Environmental Monitoring The U.S. Environmental Protection Agency (USEPA) cross check data was reviewed. The site laboratory participated in analysis of tritium in waters tritium in urine; gamma in water; gross alpha and gross beta in waters and gross alpha, gross beta and ceslum 137 in air. Also the site laboratory participated in the performance evaluation intercomparison study. A review of the previous three analyses indicated generally good agreement in almost all cases. The gross alpha 1
results still tend to be lower than they should be for the Intercomparison perf ormance tests.
]
The alt monitoring systerri at Cox's barn (PL-13) had a fourth quarter 1937 tritium in air a<erage of 4.4 E Il uC1/ml. This value represents about 0.2 percent of the license limiting tritium in air concentration of 2,000 E-Il uCl/ml.
1
g The office alr monitoring system (PL-13) had a fourth quarter tritium in air average of 8.2 E-Il uCl/ml.
This value represents about 0.05 percent of the tritium unrestricted maximum permissible concentration (MPC) of 20,000 E-!!
uCl/ml.
The "North" (PL-1), "Northwest" (PL-8) and "Northeast" (PL-2) air monitoring systems had fourth quarter 1987 tritium in air averages of 5.6 E-Il uCl/mi,15.4 E-!! uCl/mi and 8.1 E-!! uCl/mi respectively. These values represent about 0.03 percent, 0.08 percent and 0.04 percent respectively of the tritium unrestricted MPC for the fourth quarter 1987 averages. Air monitoring station PL-7 (west fence) had the highest fourth quarter 1987 average of 62.8 E-Il uCl/mi or 0.3% of the unrestricted MPC.
All fourth quarter environmental air sampling stations were numerically higher than the third quarter results.
The "Rad Lab"(PL-9) alt monitoring system in the Assistant Radiation Safety Officer's office in the employ /ml. ThIs value represents about 0.03 percent of ee change building had a fourth quarter 1987 tritium in air average of 126 E-Il uCl i
tritium restricted MPC of 500,000 E-!! uCl/ml. The building 4 (PL-12) outside air monitoring system had a fourth quarter 1987 trit!um in air average of 37.9 E-Il uCl/ml. This value represents less than 0.01 percent of the tritium restricted MPC.
A problem with antifreeze separating from the water in the air sampling system when the solvent was added for counting of tritium is causing a backlog of samples.
Several manufacturers of antifreeze bwe been tried with limited success. Thus the last half of the quarterly data has not been reduced at this time.
The weekly composite of PL 1 *hrough PL 15 for gamma analysis have been completed. As a general rule, no gamme emitters other than naturally occuring isotopes were identified for the fourth quarter of 1937. On occasion, cesium 137 was noted at or slightly above the minimum detectable level for the sample. The third quarter 1937 composite of each Individual PL station had been completed.
These :esults were similar to the weekly analysis discussed above.
The third quarter 1987 environmental TLD report had been received. A review of the results indicated they were similar to previous reports and the 1
environmentallocations had values consistent with area background.
The front farm cistern water had an average tritium in' water concentration i
of about 1.7 E-6 uCl/mi or about 0.06 percent of the tritium in water unrestricted MPC lim.t of 3,000 E 6 uCl/ml for the fourth quarter 1987 sampling period.
The east detention pond sampling system had an average tritium in water concentration of about 11.3 E-6 uCl/ml or about 0.4 percent of the tritium in water unrestricted MPC limit for the fourth quarter 1937 sampling period. The south welr sampling system had an average tritium in water concentration of about 64.9 I
E-6 uC1/ml or about 2.2 percent of the tritium in water unrestricted MPC limit for the fourth quarter 1987 sarpling period. The west detention pond sartpling system had an average tritium in water concentration of about 13.6 E-6 uCl/ml or about 0.5 percent of the tritium in water unrestricted MPC limit for the fourth quarter 1937 sampling period. A copy of compositing Stations A, B C, D and E i
data ls enclosed as Attachment I for completeness of the surf ace water monitoring program.
i
[
In addition to the actual quarterly values noted above, the following observations were made relevant to the surface runoff stations.
The surface water sampling stations indicate increased tritium activity during the fourth quarter when compared to the summer months.
In some Instances, this increase is about double to triple the earlier lower values. Of 4
particular concern is the rire in tritium in the south drain, from a summer range of 5 to 10 pCl/ml, measurements now range from 50 to 190 pCl/ml.
Effluent Monitoring The evaporator was shut down April 28, 1986 at the request of the Cabinet for Human Resources Radiation Control Branch so they could perform sampling activltles on the west hillside without having their results masked or intermingled with the evaporator output. The evaporator remained shut down throughout the iourth quarter 1987.
Radiation Detectior. Instrumentation Use and Calibration Instrument calibration records were reviewed.
All Instruments in service were in calibration. A RM-14 was out of calibration and had been shipped to l
Eberline Instruments for callbration. One E 330 and a PIC-6A will be out of calibration in January 1988 and in need of recaubration prior to continued usage.
The quarterly 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> leakage test was performed on the pocket lon enamber (PIC) direct reading doslmeters as required by the license.
Six dosimeters indicated a leakage of 0.1 percent in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The remaining 14 dosimeters indicated zero leakage in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The Ucense limit is 5% of full scale in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Laboratory Analysis As on-site and commercial results of sarnple analyses have been received, they have been trasmitted to the Cabinet for Human Resources (CHR). At the request of CHR, only when data is deemed unusual or different, do they wish to t
receive copies of the data.
j The tritium counting instrumentation has had subs 9ntial repairs and parts replaced during this quarter. This has resulted in a backiug of samples awaiting analysis. The problems appear to be resolved at present and the samples have been priortized to minimize the impact of this delay in analysis.
Employee Radiation Protection Training The October thru December 1987 monthly safety meetings were held. All meeting minutes hrd been written and initialed by attending personnel.
The October meeting h4d emphasis on employee exposure and bloassays. The November meeting concerned the decontamination laundry procedures, liquid holding tank operation and alpha activity in the evaporator building. The December meeting emphasized entry into confinsd spaces and the requirements which must be enforced to permit such an activity.
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I RAO!OACT!vE MATERIAL LICENSE i
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LICENSEE AND 2.
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LICENSE tvMGER: 206-002-03 AMENDMENT 17 PAGE 2
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Avir<0R!2ED USE 4
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CARE AND MA;NTENANCE OF THE CLOSED MAAEY FLATS RAQ]0 ACTIVE l
WAETE EUR]AL FACILITY.
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l' MONWEALTH OF XENTUCKY RADI CT!vE MATERIAL LICENSE l
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LICENSE NUMBER: 206-002-03 AMENDMENT 17 3
............. --.. ------......--------------------- ----...PAGE a
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17.
THE LICENSEE !$ "EREBY AELIEVEC FRCM THE REQUIREMENTS I
SPECIFIED.IN RADI ATION PROTECTIGN PROGRAM FOR THE MAxEY FLATS l
LOW-LEVEL DISPOSAL SITE DATED MAY 1960 p,0RK PROCEDURE 1, i
SECTION 2.1.2. TRENCH PUMPING.
THE F0LL0wlNG CRITERIA SHALL SE I
APRcICABLE:
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THE LICENSEE 3 HALL SU6MIT TO THE QASINET. ON A GUARTEALr EAils. WATER LEVEL MUNITURING DAT4 FOR A;.L SvMPi, AS t
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B.
RA01ATION PROTECTION PROGRAM FOR THE MAAEY FLATS LOW-LEVEL DISPOSAL SITE DATED MAY 1980. AND REVISIONS THERETO.
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WP-2 REV 1, MARCH 28 1985.
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LETTERS C'ATED:
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MAY 16, 196S, 51%EO By CAR 0w!NE FATRICK. HAIGHT.
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SEPTEM6EF. 6 1965. SIGNED BY CAROLINE PATRICK HAIGHT.
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SEFTE.M5E4 25. i335. SIGNED BY CAR 0wlNE AATAICA H,sIGnT.
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TYPE
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DISCIPLINE 2_d.J County (1-routine, 6-investigation)
LICENSE NUMBER 206-002-03 INSPECTION DATE_///J M 5It'7 ACTION A
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RADICAwTIVE MATERIAL INSPECTION REPORT Maxey Flats Disposal Facility Page 2 of 9 1.0 LICENSING HISTORY Since the previous inspection. Amendments 12-15 were issued.
Amendment 12 was for renewal. Amendment 13 added Work Procedure 17 regarding respiratory program.
Amendment 14 added Work Procedura 19 regarding direct reading dosimeter testing and QA proggars.
Amendment 15 was for renewal.
2.0 S ITE DL'.SCRIPTION The Site is located on the flat-topped ridgu known as Maxey Flats situated between Morehead and Flemingsburg. Kentucky.
Site access is via a road known as Maxey Flats Road (State Road 1895) located approximately six miles northwest on State Route 32 from the Route 32 and Interstate 64 junction.
The Site is a 280 acre parcel of land owned by the Commonwealth of Kentucky.
It is bounded on three sides by steep slopes covered with native vegetation.
The Site boundary has been described in the Fleming County Court Clerk Dead Book on page 274 of Deed Book # 120 (1963) and page 65 of Deed Book #148 (1978).
Radioactive material has been buried in currently 51 trenches, excluding hot wells, within the designated restricted area of approximately 25 acres.
The perimeter of the restricted area is surrounded by a continuous six foot high chain link fence topped with three strands of barbed wire.
3.0 ORGANIZATION The license is issued to Natural Resources and Environmental Protection Cabinet which is managed by the Division of Waste
)
i Management. Permit Review Branch.
The Division Director is J.
{
Alex Barber and Branch Manager is Caroline Patrick Haight.
The Radiation Protection Officer for the licensee is Doyle Mills.
The on-site activities is contracted to Westinghouse E)'ctric.
Inc. for the performance of day-to-day management and operational functions.
The On-Site Radiation Protection Officer is John Razor.
The on-site workers report to the On-Site Radiation Protection Officer.
4.0 PERSONNEL The personnel on-site are designated into classifications j
according to qualifications of training.
The current classifications are radiation worker, non-radiation worker, visitor and contractor personnel.
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Pcgo 3 of 9 4.1 Radiation Worker Personnel who work in restricted areas are trained and qualified as radiation workers.
The qualification is that the individual has attained their leth birthday and training consists of successfully completing (70%) the Radiation Worker Training Course presented in WP-6.
Since last inspection, two additional personnel were designated as radiation workers.
A review of training records revealed no documentation was available for one of these individuals indicating successful completion.
This is an item of non-compliance.
Currently, six individuals are designated as radiation workers.
Radiation workers are given periodic training in the form of monthly safety meetings covering various topics of the radiation protection program.
Minutes are maintained of the meetings and each attendee must initial indicating their presence.
A review of the minutes indicated appropriate topics and attendance by personnel, t
4.2 Non-Radiation Workers Site personnel who do not work in the restricted area are classified as non-radiation workers.
Non-radiation workers receive instruction so to understand the radiation environment outside the restricted area, posting of radiation areas, and restrictions of crossing barriers.
If a non-radiation worker require occasional access to the restricted areas, they are treated as visitors.
4.3 Visitors and Contractor Personnel Persons who require occasional access to restricted areas but have not successfully completed the radiation worker training are escorted by a radiation worker.
If a person has a specific function and has no access to high radiation or contaminated areas, limited training is provided commensurate with the work.
No problems were noted in this area with the exception identified in 4.1.
5.0 ACTIV! TIES The activities performed at the site are components of three broad programs.
They are health physics program, water i
management program and water accumulation minimization program.
Each program and the findings are discussed below.
j 5.1 Health Physics Program The health physics program contains requirements for controlling and monitoring personnel exposure to external and internal radiation.
Pcge 4 of 9
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5.1.1 External Radiation ExDosure Personnel on-site are issued a whole body TLD processed by Eberline on a monthly basis.
The results are then transferred to Form KR-401.
A review of the results indicated the greatest exposure in a month was 125 mRen shallow dose.
I All individuals entering the restricted area are issued a TLD or a pocket dosimeter.
A visitor register is maintained indicating date, badge number, name, company, time in and time out.
The badge number column includes the TLD number or pocket dosimeter serial number including initial and final reading.
Primarily, recorded readings of the pocket dosimeters were zero with the highest as three.
No problems were noted.
The pocket dosimeters utilized undergo a testing and quality assurance program.
Each pocket dosimeter is tested for leakage on a quarterly l
frequency with a 5% of full scale in a 24-hour period as a tolerance level.
Each pocket dosimeter is also tested annually for response with a response greater than i 20% from the theoretical response as a tolerance level.
Since last inspection, three pocket dosintters were removed from service for failure to meet the tests.
Forty-five pocket dosimeters are in use.
No problems in this area were noted.
5.1.2 Internal Radiation Exposure Personnel whose duties include handling or processing trench leachate or under support participate in a weekly urine bioassay for tritium.
Others participate on a monthly basis.
Since last inspection, results of the tritium bioassay indicated the highest sample was 62 l
PCi/ml versus the expected concentration yielding a body burden is 23.000 PCi/ml.
Semi-annually l
bioassays for St-90 and Cs-137, analyzed by i
Teledyne, are also conducted.
The highest readings were slightly above minimum detectable limits.
No problems noted in this area.
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l Pogo 5 of 9 5.1.3 E.adiation Surveys Personnel contamination surveys are made by each individual of their own person prior to leaving the restricted area.
The date, time, name and count rate is recorded.
The background is determined once daily by senior personnel.
Any count rate of 100 cpa above background requires decontamination.
Daily contamination surveys are conducted of the change building.
Swipe location always includes the lunch table then one or two other locations.
Each location is measured using a pancake probe G-M and alpha proportional meter.
Weekly, the swipes taken for the week are analyzed in a gas laboratory gas proportional counter.
Weekly contamination surveys are conducted of the evaporator building, assistant RSO office, and yard equipment.
Method of counting is the same as daily surveys.
In addition, a general radiation l
survey is conducted to detect the highest reading obtainable and general area levels -)f radiation j
(mR/he).
1 Monthly contamination surveys are conducted in the main office and maintenance.
Recordo of this activity is similar to daily surveys.
Radiation detection instrumentation used for personnel and contamination surveys are calibrated j
on a six month interval by Eberline.
The j
efficiency of each instrument is determined by the i
licensee.
Each survey record includes the j
instrument used by serial number therefore a tandon cross-check was performed to assure instruments used were calibrated.
The only exception is the record for personnel contamination surveys.
There is not currently a 1
method to determine which instrument was used for the survey thus verifying a calibrated instrument was used.
This was mentioned to the licensee but i
is not considered an item of non-compliance.
No problems were noted in this area.
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e Pago 6 of 9 5.1.4 Kay(ronmental Monitorino An air monitoring system is employed at fourteen locations.
These locations are within the restricted area, perimeter of the restricted area and unrestricted area.
Each location includes a vacuum pump, rotameter, particulate filter, TLD and a bubbler.
Samples are collected weekly for tritium, gross alpha, gross beta and gamma analysis.
The TLDs are processed quarterly.
The limits are those specified in 902 KAR 100:025 for air.
Analysis indicated the greatest concentrations were less than 2% of the MPC.
The rotameters used in the air monitoring system are calibrated on-site.
A standard rotameter which has been certified by the manufacturer to be accurate within i 2% of full scale is used.
A correction factor is then determined for each 1
rotameter.
This activity is conducted on a quarterly frequency.
A record is maintained of i
this activity and labeling of each rotameter is performed.
The environmental monitoring also includes:
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surface runoff water weekly, if available: stream sampling by automatic and grab samples: stream sediment semi-annually: groundwater by wells; and crop sampling.
Generally each sample has an analysis performed for gross alpha, gross beta, tritium, and gamma emitters.
Sediment samples are analyzed for St-90 Pu-238, Pu-239/240 and gamma emitters.
Other samples may have specific analysis performed.
The licensee also monitors rainfall.
No problems were noted in this area.
5.1.5 Effluent Monitorina The evaporator was shut down April 28, 1986 and operations have not resumed.
Therefore, effluent monitoring has not been conducted.
5.1.6 Protective Eculoment The licensee maintains a respiratory program.
Since last inspection, no actual use has been required.
The personnel have had a complete physical with only two individuals repeattnq the physical within the last year.
Annual physical must be performed prior to use of respiratory i
equipment.
No problems noted in this area.
Page 7 ef 9 5.1.7 Laboratory Analysis Analysis of samnles are performed on-site or sent l
to ccamercial labs.
The on-site lab participates in U.
S.
Environmental Protection Agency cross i
check program for tritium in water, tritium in urine, gamma in water, gross alpha and beta in water, and gross alpha and beta and cesium-137 in air.
A review of the results was not conducted.
5.1.8 Site Securitz As stated in site description, the restricted area l
periaater is surcounded by a continuous six foot high chain link fence topped with three strands of barbed wire.
Since the last inspection, an additional wire-coated fence was installed within the restricted area.
This fence permits further control of vehicles and persons which have entered, the trench and work building areas.
Access is controlled by key control by persons designated by the RPO.
No problems were noted in this area.
5.2 Water Management Program The water management program contains requirements for trench devatering and contaminated water treatment and/or disposal.
l 5.2.1 Trench Devatorino The licensee performs water level measurements of i
each sump located in the trenches on a monthly basis.
A summary is conducted for sump levels that have increased by four-tenths of a foot.
The licensee is required to classify each trench based on liquid level and use this classification for priority of trench pumping.
However, trench 4
dewatering is not currently being conducted.
This is an item of non-compliance; however, after discussions with Mr. Hughes, Manager Radiation Control and Mr. Moore. Director Division of i
Radiation and Product safety, their recommendation and directive is to exempt the licensee from this requirement with stipulation.
This exemption sha'.1 be by amendment.
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Pago e of 9 Existing leachate and any pumped liquids, primarily from building sumps, is stored in tanko within two buildings.
The area within the buildings are bermed in case of failure of a tank.
During the walk-over, it was noticed that water was standing in the floor of both buildings.
Investigations have been conducted by the licennee to determine the source with no final determination.
This item will be monitored for any action necessary.
5.2.2 Contaminated Water Treatment and/or Discosal Since last inspection, contaminated water has not been processed for treatment or disposal.
5.3 Water Accumulation Minimization Program The water accumulation minimization program consists of trench cover maintenance, drainage improvement and control.
contaminated waste solidification, and solid waste disposal.
5.3.1.
Trench Cover Maintenance The trench caps are covered with 6 al plastic.
Monthly a walk-over is performed to detect splits or holes.
Remarks are made on the trench leachate level summary.
The splits or holes are repaired and the plastic is replaced approximately every 2 i
years.
No problems were noted in this area.
5.3.2.
Drainace Improvement and Control As a result of the last inspection, the erosion problem on the next hillside associated with the detention pond was cited as a non-compliance i
iten.
The licensee has addressed the problem by identifying alternatives for correction with concurrence of this office of the most appropriate option.
Finalization of the approval process has j
not been completed; therefore, this will remain as j
- Pending, t
5.3.3.
Contaminated Waste Solidification Since last inspection, no activity in this area has been conducted.
5.3.4.
Solid Waste Disposal Since last inspection, no solid waste has been disposed.
All waste is currently being held in storage.
(
Page 9 of 9 6.0 AUDIT PROGRAM The RPO conducts quarterly audits of the licensed activities.
Each area of review is reported with any problems noted to the Site RPO.
The quarterly audits are submitted to this office.
No problems noted in this area.
7.0 INCIDENTS No incidents have occurred.
8.0 EXIT INTERVIEW An exit interview was held with licensee representatives on November 5 1987 concerning the findings.
The attendees were Doyle Mills, John Razor and Mark Mays.
The discussion included the lack of training tacords, method to indicate instrument used fcr personnel contamination surveys, trench pumping, pending erosion control and the standing water in the tank farm buildings.
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Summarv Renort During 1987, 2076 water samples were collected in the environment surrounding the Maxey Flats Disposal Site (MFDS) to a distance of 4.5 air miles.
The Radiation Control Branch Laboratory performed 7298 analyses on these samples with an additional 4278 quality control analyses performed to insure the accuracy and precision of these test?.
Mean tritlated water (HTO) concentrations for off-site sample locations (excluding test wells and soll lysimeters) ranged from 633.7 pC1/ml at Location D33LN4 on the west hillside at MFDS to 0.1 pC1/ml in Fox Creek at the Ringo Mills covered bridge.
Location D33LN4 has been dry since the first week in May.
A large number of sampling locations in washes and creeks surrounding the MFDS were dry from late spring through mid-November; therefore, no data is available for these locations during a substantial period of 1987.
Location 113 in the east dralnage channel at the MFDS exhibited a mean HTO concentration of 189.3 pC1/ml for 1987.
Location 1131s at an elevation of 800 feet above mean sea level or approximately 250 feet below MFDS.
This was the highest mean HTO concentration at any location which was not dry for an extended period during 1987.
Location 113 is on state controlled property and a significant distance j
from the first resident which would be adjacent to Location 106.
Location 1061s at the intersection of No-Name Creek and Rock Lich i
Road. In 1987, the mean tritium concentration at Location 106 was 13.3 pC1/ml.
These values are in comparison to a limit of 3,000 pC1/ml imposed by state radiation regulations for controlled release of tritium to the environment.
I All alpha and beta activities were within normal environmental levels.
No nonnaturally occurring gamma emitters were detected above normal fallout levelt Dose from tritium in water for the first resident in the east drainage area at Location 106 would be approximately 1.0 mrem /yr.
- Water, i
if used for drinking purposes, from Location 143, south drainage at Rock Lick Road, wnuld yleld a dose from tritium of approximately 1
2 4 mrem /yr for the first resident.
In the west drainage area a j
dose of 10 mrem /yr for the first resident would result from tritium i
in water at Location 145 in Drlp Springs Creek, !! water at this location was used as a drinking source.
At a distance of 2 air miles from the MFDS in Fox Creek af ter its confluence with Rock Lick Creek i
the dose from tritium in water, if this location was used as a drinking water sources, decreases to < 0.07 mrem /yr.
At 4.5 air miles from the site the mean annual tritium concentration is less t
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than the Minimum Detectable Activity of 0.4 pC1/ml for our analyttcal system wed to measure trittum in water.
Fmally, the mean annual trittum concentration in water from the public water system at Hillsboro is also less than our Minimum Detectable Activity.
For comparison, the worldwide level of trittu m 15 approximately 0.2 to 0.3 pC1/ml due to weapons testing and x
naturally occurring sources.
Doses are calculated according to U.
S.
Nuclear Regulatory Commission Regulatory Guide 1.109. A usage value of 730 liters /
(approximately 2.1 quarts or eight 8-ounce glasses per day) year for drinking water for all locations was used as recommended in Regulatory Guide 1.109 for the maximum exposed individual.
The usage value (730 liters / year) is used in lieu of site specific knowledge since these locations are not used as a drinking water source.
Since no individual actually obtains water from any streams in this area for drinking water, these values are only useful as an indicator of the maximum exposed individual in the drainage areas surrounding MFDS.
Based on the environmental data (evaluation of dose from trittum) generated by this agency during 1987, the MFDS does not pose an t
environmental or public health threat to the citizens of Fleming or surrounding counties.
Mean activities for 1987, at all locations are provided and the data summaries upon which these mean activities are based is enclosed.
Maps of sampling locations have been provided in previous reports, therefore, no maps are included in this year end report.
Included in the year end report is data for off-site locations,
- washes, monitoring wells (water
- levels, tritium concentrations and conductivity measurements), the public water supply at Hillsboro, and soll lystmeters (soll water samplers, porous cups).
Statistical analyses were performed for locations provided sufficient data was available. Descriptive and comparative statistical analyses were conducted for most locations. Scattergrams were prepared and simple regression analyses were attempted. If the data could not bc
)
fit by simple regression analysis, no further attempts were made at more complex analyses.
This type of analysis provides a useful Indicator of trends and seasonal variations in tritium in the t
environment.
Such analysis over a number of years can provide valuab!c insight into the stability and integrity of MFDS.
Included in this year end report are three documents desling with various aspects of the Radiation Control Branch'- environmental monitoring program at MFDS.
These documents at ts follows: (1) i Maxey Flats Off-Site Environment Data: 1977 to 1986; (2) Daily Tritium Activity in Surface Water in Rock L!ck Creek at Highway 1
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I 158-Location 103; and (3) Compilation of Data for the UE-Series Wells and Well North-28 at the Maxey Flats Disposal Site, 1984-1986.
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Tritiated Weter (HTC)Noen ActMty for 1967 I
At Ort 5ite Lecettens %rroWmg Mosey Flets Diesesel Site i
l Locatice Neon pCI HT0/mi for1967 i
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101 1.1 l
102 3.3 l
103 5.2 143 31.5 l
106 13.3 I
107 4A N107 5.1 l
l 106 11.9
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112 13
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113 109.3 j
144 63.9 i
119 02 r
1 120 0.6 121 0.5 l
122 0.3 l
l 124 6.8 l
130 0.1 132 0.9 3
l 133 30 j
145 13.1 i
1 136 02 1
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Nmiasm = 0.1 el Ls etion 130 l
I Maniw199.3 et Locetten 113 l
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4 tross Sett, and Alphe ActMiy for 1967 At 0#.51te Lacellens 5urrowwh6 Mesey Flats Dietesel Site l
Lecstten Bete Act. (pCl/l)
Alphe Act. (DCl/l) f i
101 5.2 1.3 102 7.0 1.2 1
103 5.9 1.1 l
143 6.5 1.7 1
106 50 1.1 i
107 5.2 04 106 4.6 04 I
4 112 6.0 1.0 i
113 17.7 2.0 c
4 144 11.0 1.5 119 3.7 06 i
120 82 3.9 121 56 06 i
122 4.1 06 I
i 124 30 0.3 1
130 54 1.0 1
1 132 6.2 0.8 133 66 1,9
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Tritleted Water (HTC), Beta and Alphe ActMty For 1967 l
f rom Mlic Water letly at 14tisbert, Kentucky l
r Lecollen pCIMT0/ml Sete Act (pCtM)
Alphe Act (pCi/l)
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j West Fleming j
1 Water District
-0.03 2.9 0.3 J
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HT0 Comparston for 1967 in the fest Desin et Money Flats Dispose! Site l
Collection Dets locsUon 113 (PCI HT0/ml) fest Drein Outlet (pCl HT0/ml)
L 5-Jun-67 372 105 l
N7 112 15 L
24sb47 76 di l
254eH7 96 79 9-fir-67 260 97 25-ftr-67 385 20 6-Aer-67 11I 27 20-Aar-87 320 15 l
5 % -67 326 to 16-Piey-87 466 9
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2W7 262 9
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15-M -67 345 1I l
3 29-M-67 341 2
15-#-67 85 5
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27-N-87 45 4
10- Aug-87 63 4
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24-Aag47 125 5
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6-See-67 239 6
b 22 Sep-67 142 4
rott47 116 8
t 19-Oct-67 209 8
2-her-67 147 14 j
16-Nov-67 150 16 I
30-Mer 67 43 9
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l 14-Osc-67 26 12 J
26 Oec-67 15 9
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Mean*
189 Nean*
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5Le C4 132 Std Dev =
28 Maaimwn*
466 Menimum*
105 j
M w m.rna 15 ftnimum*
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l In Wesh 7 et the Newy Flots Weste Otteenal Site i
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LacetHm pCiHf0/mi kla Att. (pCl/l)
Alphe Act (pCL/l)
J107 1.5 6.1 0.9 OC) 1206 72 1.0
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6107 26.2 7.3 1.7 i
F107 36 4 4.7 12 l
1 (107 394 4.7 1.1 j
D107 374 4.4 04 C107 39.0 4.1 0A l
Wet 50' 36 6 45 15 i
V7stRd 42 2 40 0.9
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6107 36.0 39 0.7 l
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1 fritietsd Water (HTO) Beta ord Ales AcLMty fcr 1987 in Wash from k,*t.L a:.' af 33L st Maiey Flats Wests Othwal Sits location PC6HT0/mi t<ta Act. (pCl/l)
Ates Act (PCl/l) 114 30 3 11 8 22 W114 27.4 10.1 22
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1967 in Upper Legging Reed et Nemey Flats Weste Diteetel Site l
j Lecollen 6 Mf0/mi tota Act. (sCl/l)
Alphe Act (pCl/I) f
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Drein North PW 4.1 90 1.0 f
l Legeng need (LORA) 54 5 7.4 1.1 town, no e (tano) 19 5 12 4 44 l
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t 1967 in Wash Created by North Orain of 33L st Money Flets Weste DNeesel Site
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Location pCI HT0/mi Be'.a Act. (sCl/l)
Alphe Act(act/l)
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033LN4 621.7 14.9 23 WytR 312 54 24
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j Trilleled Woler (HTC)Mean ActMty for 1987 i
in LE Wells et Money Flata Olssonal Site j
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Location Mean pCl MT0/ml l
tt l 0.96 l
W2 0.62 l
l LE-3 0.17 l
l W7 0.023 LE,3 0.047 W-4 04 7 i
W-11 0.16 1
N26 0.39 j
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'l intiated Water 04TC)Mean ActMty For 1967 in W wells et Namey Flett Disposal 5ite Lotetton Noen pCl HT0/mi r
tf 1 261374 L7 2 622096 LF 5 3107 0 t# 4 IM92 LF-4 620 l
W 10 MS l
t1-11 4
I W 12 8
.i ts 13 3
I W-14 4
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tJ-15 6
if 16 2
I t7 17 5
l 17 18 1
l LF 19 1
tf-20 2
IX-21 0
i LF 22 5
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LF-23 13 t7 24 4
LF-25 3
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if-26 186 LF-27 2
\\1 -29 4
LF-29 2
l LF -31 2
(F 3?
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LF 33 2
j LF-34 s
I L7-35 3
LF-36 185 i
LF-37 1014 3
LF 36 6
f LF-39 1
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L7-40 51 I
W41 2
LF-42 i
i LF-43 6
3 LF-44 1
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!j intiated Weter (HTC)Mean ActMty For 1M7 im W Welle et Masey Flots mesecol Site 4
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tecouen Mean pCl MTWm1 j
V6 1 344616
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W3 110
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06-4 128 i
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U64 1751 1
U6-7 E31 i
J U64 12 1
06 9 35 l
06 10 2512 j
U611 9299 i
06 12 110567 I
06 13 2776 l
U614 10 06-16 5
U617 178 06 16 63 1
06 19 153 l
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Tritiated Water DiTO)tiean ActMty For1987 In UK-Wells at Maxey Flats Disposal Site location Nean pCl HT0/ml LK-1 397224 LK-2 1425849 LK-3 64 LK-4 2
LK-5 31 LK-6 6
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Trilleted Water (HTC) Nean ActMty For 1987 in E-Wells et Maxey Flats Disposal Sits i
Location Mean pCI HT0/ml IE 8
l 3E 2
4 5
6E 80 i
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9E 193 10E 11 11E 32694 r
12E 169 1XA m eu i
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pp Carl H0.Bradley i
I Wallace G. Wilkinson Seca m "
G w emaon COMMONWEALTH oF KENTUCKY NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION CA8irJET DEPARTMENT FOR ENVIRONMENTAL PROTECTION FRANKFOMT OFFICE PAnx 18 REILLY RoAo FRANMFOMT, KENTUCKY 406o1 January 27, 1988 Donald R. Hughes, Sr., Manager Radiation Control Branch Cabinet for Human Resources 275 East Main Street "rankfort, Kentucky 40621 uear Mr. Hughes:
Enclosed please find a copy of the fourth quarter 1987 audit of the Maxey Flats Nuclear Waste Disposal Facility as required by the Cabinet for Human Resources Radioactive Materials 1.lcense 206-002-03.
This quarterly audit was performed on January 6,7 and 11,1988.
There appears to be no deficiency in practice or process observed during the audit. if you should have any questions or comments on the enclosed audit, please call Doyle Mills or me at 564-6716.
Sincerely, Caroline Patrick Haj %h--
Odd ght, Manager Uncontrolled Sites Branch CPH:DM:mlp Enclosure cc:
D. Mills J. Razor i
l Am Ec.a' ococ%mity f reer M S.H
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5 Carl H. Bradley j
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Wallace G. Wilkinson see,runy L)
GCNtanoa COMMONWEALTH op KENTUCO NATURAL RESOURCES ANO ENVIRONMENTAL PROTECTION CABINET DEPARTMENT FOR ENVIRONMENTAL PROTECTION FRANKFORT OFFICE PARK 18 RtitLY RoAo FRANKFORT. KENTUCKY do6ot MEMORANDUM TO:
Caroline Patrick Haight, Manager Unc5ntralled Sites Branch I
FROM:
Doyle Mills, Chief ni Maxey F!sts Section v
i DATE:
January 27, 1988
SUBJECT:
Maxey Flats Quarter;y Audit - Fourth Quarter 1987 As specified in Section 6 of the license operation Radiation Protection Program Manual for the Maxey Flats Nuclear Taste Disposal Site, the fourth quarter 1937 audit was performed. Audit areas specified in Section 2.2.1.1 of the manual were covered during the audit which was conducted on Jariuary 6,7 and 11, 1988. This record of the audit will be organized according to the subjects specified in that Section.
Occupational Radiation Exposure Monitoring and Control Whole body exposures and bioassay records were reviev,ed for Brown; Frank; Heath; Kornman; Pollitt; Razor; Stamper; and Buinickas. Whole body dosimetry TLD badge data for all employees identified above indicated that all external exposures were zero (0) for the September through November 1987 time perioJ.
The quarterly license limit for external whole body exposure is 1230 mRems.
No seasonal laborers were utilized during this quarter.
One university researcher was on-site during the quarter and his whole body dostmetry TLD badge indicated all external exposures were zero (0) for the September through November 1987 time period.
The Superfund contractor and oversidht staff personal lon chamber data indicated values similar to our contractors, i.e. minimal total monthly values.
The weekly on-site tritium in urine bioassay data indicated that those persons working on-site received less than 0.3 percent of the maximum permissible body burden (MPBB) of tritium during this quarter. The hi; hest tritium bioassay sample reported during this quarter occurred on October 16, 1937 and was 74 pCi/rr!
versus an action limit of 23,000 pCi/ml.
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The commercial third party bioassay samples were collected and shipped for analysis at the end of the quarter.
The results are anticipated to be received during the first quarter of 1988.
Site Radiation Surveys The monthly and weekly radiation surveys were being conducted as required by the license. The evaporator building maximum exposure level was reported as 6 mR/hr and the general area exposure level was reported as 0.2 mR/hr for the quarter. Limited contamination was noted in the area of sumps, evaporator floor, the work table area, and the bottom landing of the stairs. The Assistant Radiation Safety Officer's office had a maxirnum exposure level of 2.5 mR/hr and the general exposure level was reported as 0.2 mR/hr during the quarter. The large tank farm building had a quarterly maxLnum exposure level of 5 mR/hr with a general area exposure level of 0.3 mR/hr inside the building. The small tank farm building had a quarterly maximum exposure level of 1 mRhr with a general area exposure level of 0.2 mR/hr inside the building. The Pole Building had a maximum exposure level of 0.2 mR/hr reported for the quarter.
All areas were decontaminated Of necessary) in accordance with Work Procedure WP-9.
Building 5 South Bay has been cleaned for use by Superfund contractors. Due to the contaminated liquid existing in the floor of the large and small tank farm building, entry onto the building floor is prohibited.
As a result of this fact, the Cabinet for Human Resources has allowed tne general area exposure measurements to be performed from the berm areas.
The snack area in the change building had daily surveys performed and recorded. The gross alpha ar.d gross beta readings were generally at or slightly above minimum detectable levels. The weekly laundry survey and check-off were also performed and recorded as required by the license. As a result of a close out comment during a Cabinet for Human Resources inspection, the laundry survey documentation has been increased to more clearly specify the survey equipment and probe.
The employee personnel dosimeter (PIC) readings were reviewed and were generally less than 10 mR for any given month in the quarter. The Plc values were consistent with the TLD whole body dosimetry data.
Environmental Monitoring The U.S. Environmental Protection Agency (USEPA) cross check data was reviewed. The site laboratory participated in analysis of tritium in water; tritium in urine; gamma in waters gross alpha and gross beta in water; and gross alpha, gross beta and cesium 137 in air. Also the site laboratory participated in the performance evaluation intercomparison study. A review of the previous three analyses indicated generally good agreement in almost all cases. The gross alpha results still tend to be lower than they should be for the intercomparison performance tests.
The air monitoring system at Cox's barn (PL-13) had a fourth quarter 1987 tritium in air a<erage of 4.4 E-li uCi/ml. This value represents about 0.2 percent of the license limiting tritium in air concentration of 2,000 E-ll uCl/ml.
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1 The office air monitoring system (PL-13) had a fourth quarter tritium in air average of 8.2 E-Il uCl/ml. This value represents about 0.03 percent of the tritium unrestricted maximum permissible concentration (MPC) of 20,000 E-Il uCl/ml.
The "North" (PL-1), "Northwest" (PL-8) and "Northeast" (PL-2) air monitoring systems had fourth quarter 1987 tritium in air averages of 3.6 E-Il uCl/ml,13.4 E-11 uC1/mi and 8.1 E-ll uCl/mi respectively. These values represent about 0.03 percent, 0.08 percent and 0.04 percent respectively of the tritium unrestricted MPC for the fourth quarter 1987 averages. Air monitoring station PL-i 7 (west fence) had the highest fourth quarter 1987 average of 62.8 E-Il uC1/ml or 0.3% of the unrestricted MPC. All fourth quarter environmental air samp!!ng stations were numerically higher than the third quarter results.
The "Rad Lab"(PL-9) air monitoring system in the Assistant Radiation Safety Officer's office in the employ /ml. Ths value represents about 0.03 percent of the ee change building had a fourth quarter 1987 tritium in air average of 126 E-Il uCl tritium restricted MPC of 300,000 E-11 uCl/ml. The building 4 (PL-12) outside air monitoring system had a fourth quarter 1987 tritium in air average of 37.9 E-Il uCi/ml. This value represents less than 0.01 percent of the tritium restricted M PC.
A problem with antifreeze separating from the water in the air sampling system when the solvent was added for counting of tritium is causing a backlog of samples.
Several manufacturers of antifreeze have been tried with limited success. Thus the last half of the quarterly data has not been reduced at this time.
The weekly composite of PL 1 through PL 13 for gamma analysis have been completed. As a general rule, no gamma emitters other than naturally occuring isotopes were identified for the fourth quarter of 1987. On occasion, cesium 137 was noted at or slightly above the minimum detectable level for the sample. The third quarter 1987 composite of each individual PL station had been completed.
These results were similar to the weekly analysis discussed above.
The third quarter 1987 environmental TLD report had been received. A review of the results indicated they were similar to previous reports and the environmental locations had values consistent with area background.
1 The front farm cistern water had an average tritium in' water concentration
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of about 1.7 E-6 uCl/mi or about 0.06 percent of the tritium in water unrestricted i
MPC lirnit of 3,000 E-6 uCl/ml for the fourth quarter 1987 sampling period.
The east detention pond sampling system had an average tritium in water concentration of about 11.3 E-6 uCl/mi or about 0.4 percent of the tritium in water unrestricted MPC limit fer the fourth quarter 1987 sampling period. The south weir samp!!ng system had an average tritium in water concentration of about 64.9 E-6 uCi/mi or about 2.2 percent of the tritium in water unrestricted MPC limit for the fourth quarter 1987 sarpling period. The west detention pond sarpling system had an average tritium in water concentration of abeut 13.6 E-6 uCl/ml or about 0.5 percent of the tritium in water unrestricted MPC limit for the fourth quarter 1987 sampling period. A copy of compositing Stations A, B, C, D and E data is enclosed as Attachment I for completeness of the surface water monitoring program.
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the actual quarteily values noted above, the following in addition to observations were made relevant to the surface runoff stations.
The surface water sampling stations indicate increased tritium activity during the fourth parter when compared to the summer months.
In some instances, this increase is about double to triple the earlier lower values. Of particular concern is the rise in tritium in the south drain, from a summer range of i
5 to 10 pCl/ml, measurements now range from 50 to 190 pCl/ml.
Effluent Monitoring The evaporator was shut down April 28, 1986 at the request of the Cabinet for Human Resources Radiation Control Branch so they could perform sampling activities on the west hillside without having their results masked or intermingled with the evaporator output. The evaporator remained shut down throughout the iourth quarter 1987.
Radiation Detection Instrumentation Use and Calibration Instrument calibration records were reviewed.
All instruments in service were in calibration.
A RM-14 was out of calibration and had been shipped to Eberline Instruments for calibration.
On2 E 530 and a PIC-6A will be out of calibration in January 1988 and in need of recalibration prior to coatinued usage.
The quarterly 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> leakage test was performed on the pocket lon chamber (PIC) direct reading dosimeters as required by the license.
Six dosimeters indicated a leakage of 0.1 percent in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The remaining 14 dosimetirs indicated zero leakage in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The license limit is 5% of full scale in 24 hou1.
Laboratory Analysis As on-site and commercial results of sample analyses have been received, they have been trasmitted to the Cabinet for Human Resources (CHR). At the request of CHR, only when data is deemed unusual or different, do they wish to receive copies of the data.
The tritium counting instrumentation has had substantial repairs and parts replaced during this quarter. This has resulted in a backlog of samples awaiting analysis. The problems appear to be resolved at present and the samples have been priortized to minimize the impact of this delay in analysis.
Employee Radia.on Protection Training The October thru December 1987 monthly safety meetings were held. All meeting minutes had been written and initiated by attending personnel.
The October meeting had emphasis on employee exposure and bloassays. The November meeting concerned the decontamination laundry procedures, liquid holding tank operation and alpha activity in the evaporator building. The December meeting 4
emphasized entry into confined spaces and the requirements which must be enforced to permit such an activity.
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Site Security A walkover of the site was completed and there doe: not appear to be any problem ereas. Water was noted standing In the floor of the old tank farm and smaii tank farm building floors. The pve on the middle and westem trench areas no longer has the resillency of a viable pmduct. Due to the cold temperatures, no entry onto the plastic is permitted sithout the express approval of the site manager.
As indicated previously, the site evaporatar is not operating at this time and all staff are on day shif t. This means there is no evening or n4ht surveillance of the site. During weekends the farm leasee is generally at the front of the site so there is the additional appearance of people in the vicinity of the site.
Additionally, the S@erfund contractor is coming to work early and leaving late and have worked some weekends adding to the appearance of people at the site.
Other The visitors log was reviewed. A total of 151 entries were made in October, 74 entries were made in November and 66 entries were made in December. The visitor dosimetry records for the fourth quarter 1987 generally showed a zero (0) exposure reading with an occasional 1 or 2 mR recorded. A total of 865 visitor entries were made into the site during 1987. This does not include superfund contractor and oversight staff.
Pumping records indicated that 1,444 gallons were removed in October, 520 gallons were removed in November and 1,680 gallons were removed in December 1987. This was generally building sump liquids. Approximately 26,500 gallons of trench teachate and building sump / wash liquids were removed during 1987 and stored in the large and small tank farm structures.
The monthly soundings requirement for those non-functioning sumps covered with plastic has been amended to provide for alleviation of this requirement.
The monthly site walkover is being performed in accordance with the license requirements. Several pve holes and splits were noted and repaired as weather permitted. Most of the repairs were on the middle and forties trench area of pve trench cover.
The rotometer calibrations were performed during the fourth quarter as required by the license.
All 21 rotometers passed the criteria without any ditficulty.
Summary A close out discussion was held with John Razor, Site Radiation Safety O!!icer, to discuss the areas reviewed during the audit. There appears to be no deficiency in practice or process observed during the audit.
cc D. R. Hughes, Sr.
J. E. Razor Enclosures
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RADI0 ACTIVE MATERIAL LICENSE I
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L!CENSEE AND 2.
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RADIOh.CTIVE MATERIAL LICEN5E i-LICENSE NUMBER: 206-002-05 AMENDMENT 17 PAGE 2
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CARE AND MAINTENANCE OF THE CLOSED MAXEY FLATS RADI0 ACTIVE WASTE BURIAL FACILITY.
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MONWEALTH OF XENTUCKY RADI CTIVE MATERIAL LICENSE l
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8 LICENSE NUMBER: 206-002-03 AMENOMENT 17 P
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l inE LICEN5EE 15 rEREBV AELIEVEC FRCM THE REGuiAEMENTS SPECIFIED.IN RADIATION FROTECTION PROGRAM FOR THE MAxEY FLAT 5 l
loa-LEVEL DISPOSAL SITE DATED MAY 1960, NORK PROCEDURE 1,
SECTION 2.1.2. TRENCH PUMPING.
THE F0LLowiNG CRITERIA SHALL BE APALICA6LE:
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INET FOR HUMAN RESOURCE OMMONWEALTH OF KENTUCKY RADIOACTIVE MATERIAL LICENSE LICENSE NUMBER: 206-002-93 AMENDMENT 17 PAGE 4
B.
RADIATION PROTECTION PROGRAM FOR THE MAxEY FLATS LOW-LEVEL OISPOSAL SITE DATED MAY 1980, AND REVISIONS THERETO.
1.
WP-2 REV 1 MARCH 28, 198S.
2.
WP-12 DELETED.
3.
WP-13 DELETED.
4 WP-14 REV 0, AUGUST 16 1984 5.
WP-15 REV i, JANUAAy' 14,
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LETTER $ DATED:
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MAY 16. 1965, 51G',ED Br CAROu!NE FATRICK HAIGHT.
2.
SEPTE.v6ER 6 1965. LIGNEO BY CAROLINE PATRICK HAIGHT.
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3EF7EM6E4 25. is65, SIGNED Sy c,:.go, NE Ai4ICN MAIG,*T.
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