ML20196K369
| ML20196K369 | |
| Person / Time | |
|---|---|
| Issue date: | 06/23/1988 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Bangart R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-3 NUDOCS 8807060583 | |
| Download: ML20196K369 (6) | |
Text
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88104 NF 6/23 JUN 2 31988
<l MEMORANDUM FOR: Richard Bangart, Acti'1g Director
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Division of Low-Level Waste Management h
and Decomissioning
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FROM:
Paul Lohaus, Chief Operations Branch Division of. Low-Level Waste Management and Decommissioning
SUBJECT:
SUMMARY
NOTES OF HRC-DOE TITLE I MEETING Date/ Time:
May 24, 1988 - 9:00 A.M.
Location:
HRC, White Flint North, Rockville, MD The purpose of the meeting was to discuss, at a management level, policy and other issues related to the Title I program. The agenda for the meeting is attached as enclosure 1. is a list of participants.
M Jack Baublitz, DOE initiated discussion by reviewing the status of the Title I program and the effort needed for DOE to obtain NRC agreements and concurrences.
It was pointed out that much of the difficulties that DOE is now seeing in obtaining NRC concurrences relates to groundwater protection which h
result from the new EPA groundwater standard. Mike Fliegel, NRC pointed out that in the recently completed NRC review of the proposed Green River remedial action, of the 13. open items identified,12 were groundwater concerns and the other related to a novel cover design.
l John Arthur discussed the need DOE felt to move ahead on the program while there is Congressional cumitment to continue funding it. We then moved on to I
a discussion of conditional concurrences.
The q)uestion of what is needed in the area of surveillance and maintenance (S&M plans at the Remedial Action Plan (RAP) stage of the review was discussed. DOE raised the question of completely deferring NRC review of S&M plans at the RAP stage.
It was pointed out that at the April 20, 1988 groundwater meeting and the April 21, 1988 Green River meeting, NRC staff l
stated that while details of S&M prograns could be deferred, RAPS should contain at least a conceptual discussion of the plans.
Discussion on other aspects of conditional concurrences continued, especially ontheL'questionofproceedinginstages.
In the situation where NRC cannot l
concur on a proposed remedial action because of open items, DOE would like to be able to close out specific open itens that would allow them proceed, with HRC concurrence, with specified aspects of the remedial action.
For example, closing some open items may enable NRC to concur in DOE's preparation of the sitefincluding excavation.
Later, closing other open items may enable NRC to
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' concur in placement of tailings, with concurrence in the cover and erosion protection cc, ting later. The consensus of the grou) was that this was feasible. Mike Fliegel pointed out that 90E would lave to address all open issues at each concurrence, DOE would have to close those issues relevant to the work they want to proceed with and make the case that the other open issues can be postponed.
Ed Hawkins, NRC and John Arthur discussed the problems at the Lakeview site in relation to staged concurrences and DOE proceeding at their own risk without NRC concurrence.
The issue of the Spook, Wyoming site was discussed next. HRC expressed concerns about DOE's proposed remedial action and the ccmplications resulting from the other radioactive material at the site that will be handled under the Abandoned Mines Land (AML) program. Jack Baublitz also had concerns with the regulatory problems this presented but concluded it did not warrant spending p~
k additional money to move the tailings to another site just to avoid these problens.
Ed Hawkins added that the two nearby Title 11 sites, Bear Creek and Exxon, would not take the tailings, so that a solution similar to Riverton was probably not feasible.
The issue of non-byproduct material (NARM) in tailings impoundments was discussed. NRC asked about the status of our letter to Mr. Baublitz asking whether DOE would accept ownership of tailings inipoundments containing(DOE such materials.
Jack Baublitz said that DOE is considering the question.
subseque,1tly responded by letter dated June 10).
Jack Baublitz discussed the status of legislation proposed to extend the Title i-I program to FY1994. 00E is preparing contingency plans in the event that the l;
program does not get extended by Congress.
John Arthur stated that he was leased with the way the weekly telephone conference calls on schedule pr crities were being implemented. He mentioned a potential schedulin0 problem is that some States may be running out of funds to cover the 10 percent of the costs that they are responsible for. This would result in delays for the effected sites. Another potential scheduling problem is that DOE's contract for technical assistance in design of remedial actions runs out in two years. 00E is' trying to extend the contract.
John Arthur discussed priorities site by site.
As a way to help expedite the process, NRC l
agreed to provide, early in our reviews, informal feedback to DOE on major l
issues identified.
John Arthur briefly discussed the history of the Title ! QA program. He acknowledged the problems at Canonsburg and Lakeview and that they had caused DOE to take another look at the QA program. The revised documentation i discussed at the February 11, 1988 meeting on QA will be coming in for cur review soon.
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Paul Lohaus alerted DOE to a decision we have reached with respect to QA at Canonsburg. As a result of the problems found with rock rip rap at the site, NRC planned to raise the general issue of QA at the site. Paul Lohaus suggested one way of addressing the issue would be for DOE to have a third party. independently look at the QA program at that site.
Jack Baublitz discussed the briefing that DOE subsequently made to the Comission on June 3,1988. The briefing was on three program areas (Title 1, West Valley, and Low level waste) where DOE interacts with NRC.
Because of HRC's role in these three DOE programs, DOE sought the opportunity to brief the Comission to help them become more aware of the programs.
The meeting ended at noon. The individuals involved concluded that it had been very useful. The desire to have this type of meeting more often was expressed.
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Paul Lohaus, Chief Operations Branch, LLWM Division of Low-Level Waste Management and Decommissioning
Enclosure:
As stated DISTRIBUTION:
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DATE:h /p7/88
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I 0FFICIAL RECORD COPY
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NRC-DOE TITLE I MEETING
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May 24, 1988 9:00-12:00 Rorn 10-B-11 1
Participants:
_ HBC DOE R. Bangart J. Baublita J. Greeves J. Arthur P. Lohaus J. Sunneler M. Bell E. Hawkins M. Fliegel AGENDA 4
"Conditional Concurrence" vs. "Prepared to Concur"
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Lakeview, OR
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Green River, (TP Schedules & NRC resources EPA Groundwater Standards Spook, Wy. site Non-byproduct material (NAIM) in tailings ponds DOE's QA program DOE Conunission briefing l
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