ML20199C251

Responds to Concerning Status of mixed-waste at Cintichem Site.Attached Table Presents Overview of Radioactively Contaminated Waste That Remains to Be Disposed of from Decommissioning Project

ML20199C251
Person / Time
Site:	05000054
Issue date:	01/02/1998
From:	Mcgovern J CINTICHEM, INC.
To:	Aldrich R NEW YORK, STATE OF
References
NUDOCS 9801290204
Download: ML20199C251 (4)

Text

_ _ - - _ _ - - _ _ _ _ - - -

CINTICHEM, INC.

P.O BOX G16 TUXEO 1 NEW YORK 10987 (914] 351-2131 Januaty 2,199 8 NYS Department of Environmental Conservation Div. of Solid & Hazardous Ma*erials, Region 3 21 So. Putt Corners Rd.

New Paltz, NY 12561-1696 Att: Mr. Rodney L Aldrich, P.E.

Dear Mr. Aldrich:

Ref. NYDEC letter ( R. Aldrich) dated Dec. 19,1997 This letter is in response to your letter, referenced above, concerning the status of mixed waste at the Cintichem site. As you indicated in your letter, there are 9 drums of radioactively contaminated waste that have been in the fmal stages of the characterization process. The attached Table presents an overview of the radioactively contaminated ,

waste that remains to be disposed of from the decommissioning project at Cintichem, and that requires processing or management that is extraordinary from the normal decommissioning bulk waste stream. The first item on the table, Dmm #38, is composed solely of radioactive items and it will be disposed of at a suitable, licensed disposal facility.

A summary of the current natus of the remaining items in the table follows:

Drums #32, #29, #30 & #27 contain lead that is either volumetrically contaminated ()

or activated with radionuclides that cannot be separated from the lead. The contents of these four drums are the remnants &om the extensive decontamination and volume-reduction program that had been conducted throughout this project by Cintichem and two outside service contractors. Many tons oflead were processed /jb O through this program and, except for the materials in these four dmms, were either recycled or disposed of through a macroencapsulation & disposal process at En irocare Of Utah. The characterization of this material is based on cur knowledge ofits origin and its obvious physical appearance.

Dmm #3 contains about 20 Lb. of cadmium metal that was segregated from the lead waste stream. The Barringer Lab report enclosed is the basis for its characterization. Recent discussions with Envirocare Of Utah leads us to believe that :his material can be treated by macroencapsulation and would be disposed of in a similar manner as the contaminated lead previously shipped to them. We hope

~

9801290204 980102 l llI l! I' I PDR y

ADOCK 05000054 PDR 1, I,I! ,1! I, I,, f. ,fi ,f,

_ _ _ _ _ _ _ @ C M bid b I

to be completing the Waste Profiling process to obtain approval for the disposal of

., t.his materialin the near future.

• Drums #7, #9, #10 & #12 contain items of radioactively contaminated waste that are also contaminated with volatile organic substances. The materials in these drums consist of items that were either used for or are the result of laboratory

.. cleanup operations which included the shipment of bulk liquids of the same hazard class that were disposed of by incineration recently. We have just, this month, received the Barringer laboratory reports on the contents of these drums that will allow the final characterization of these items to be completed. A copv of these reports are enclosed as requested. It appears that the contents of drum #12 de not exceed the TCLP threshold concentration for chloroform, the only hazardous constituent detected in the analyses ofits contents, and therefore this drum will be included in the last shipment of bulk radioactive waste that will go to l'avirocare Of Utah as soon as we have their concurrence. Envirocare Of Utah has also agre , to look at the characteristics of drums #7, #9 & #10 to evaluate the possibility of their treatment and/or disposal at the Clive facility. We have sent them copies all of our information on these items for their evaluation.

In summary, drums #32, #2o, #30, #27, #7, ,#9, & #10 are the only ones remaining for which we have not yet found a suitable method for treatment or disposal. We have contacted many companies and government agencies the either provide waste treatment services or are knowledgeable about such things. 5, cifically, they included SEG, ALARON, Chem-Nuclear, Envirocare, DSSI, HAIC Assoc., Perma Fix, NSSI, HTS, NRC, DOE, NYSERDA, INEL, LANL, SANDIA and specialists within our parent company. Although these sources of information about evolving waste treatment technologies were helpful in disposing of all of our mixed wastes to date, we have been unsuccessful in finding solutions that are currently available for these last few items. We have been advised that DSSI is currently seeking authorization to use an evaporation / oxidation treatment process that could be used to remove the volatile organics from solid waste materials such as are in drums #7, #9 & #10. They anticipate having approval for using this process late in 1998. Envirocare has informed us that they anticipate receiving a license amendment that will raise the concentration limits of radionuclides in waste going into the Clive site. It is possible that the higher limits will allow the disposal of drums #32, #29, #30 & #27 after being treated by macroencapsulation. We don't have sufficient information about this forthcoming license amendment to be able to evaluate the feasibility of this.

We want to complete the decommissioning of the Cintichem site and return it to a prcductive use as soon as possible. Toward this end, we will have to arrange for suitable storage of the seven dmms that must await suitable disposal technology. We have had several discussions with the NRC, NYDOL & NYDEC in which we stated that our primary objective is to arrange storage away from the Cintichem site in Tuxedo, preferably at the site of our parent company, Hoffmann La-Roche(HLR), in Nutley NJ. We are not aware of a precedent for such an arrangement and therefore we have little or no guidance to work from. HLR has applied to the NRC for an amendment to its Byproduct license for the Nutley site to obtain authorization for this interim storage arrangement. HLR has

also initiated discussions with NJ authorities to obtain the concurrence of the appropriate State authority. HLR has contacted the NE Waste Compact to obtain their concurrence with this arrangen,ent. We have contacted the NYSERDA and made them aware of our efforts in the event they were contacted by their counterparts in the NE Compact. We have also briefly investigated the availability of other off-site storage. One such possibility exists at Perma Fix in Florida but we are advised that it could only be arranged for a lhited time and that it would require an agreement between the States of Flor:da and NY about the ultimate return of the waste to NY ifit could not be disposed of within the limited storage term of 3 years. Another possibility for off-site storage was identified within NY but this would require the approval of the NYDOL and DEC. We have not pursued these other options vigorously and we don't intend to unless we are frustrated in the achievement of our primary storage option.

I tmst that this provides the information you require concerning these last few items of mixed-waste and that it gives you an appreciation of our past achievements and continuing efTorts in the safe management and disposal of all of the wastes from the Cintichem decommissioning project. It is only recently that we have encountered difTiculty in this endeavor because of the unavailability of suitable treatment technology. I would welcome any assistance from your stafTif the" know of any other possibilities for 4 the treatment of this material that we have not discovered. Any assistance with the arrangement ofinterim storage would also be appreciated.

In addition to the mixed waste described above we have some hazardous materials that we are in the process of characterizing for shipment and disposal. These last items are described in the enclosed table. Hazardous waste disposal of nonradioactive materials has been routinely conducted throughout the decommissioning project and these will make up the final shipment as soon as they have been completely characterized. We have used the disposal senices of Advanced Environmental Technical Services (AETS) almost exclusively for this program. The small volume of contaminsted soil was removed from a

)

settling pit that had been connected to a machine-shop floor drain system which was removed during the decommissioning project. This material has been sampled twice for characterization and a copy of the summary report on it is enclosed but AETS has requested that this material be sampled again for characterization by the incineratior.

senice before they will remove it for disposal. This last sampling was done in the third week of December. The other items in the table will be manifested by AETS on the day of shipment which has been the routine procedure for surplus or spent laboratory reagents such as these. As soon as the analytical results are obtained from the last soil samples all of these items will be removed for treatment and disposal by AETS.

Ve truly ours J

W w e J h cGovern cc: B. Youngberg T. Dragoun D. Orlando weAM s JJM145

{L

AN .. .

78;f . .. .. . . . .

P.ited usta iz-trytEI'OiASTE.WD}12/%/97 ID C3HUi1 CNTS BI DCSE A'.I DCSE !H DCT A: TIT 1H CNC'll WU2T WEN EISP:51H3 CEN5 _

' C33lT 81ft tci/:ritT:HI Ci pCi/g (Its) pts)

(r,t) (r/t) 5i7 SLSS f38 StlCP Cl Fat,Eesias,5cras,Rt Metal 23 0.C4! 5;: ed- 6.3 0.442 4749.114 235 360 Chen-R:1 Sped-sheet steet Ingets - His pl:cs 34 50/50 6.69 227.46 720Fi2.3 ;53 stre? 4115:17 29tfe55,12tslU 5t 132 5% da: 230 6 95 515i61,lto63,1.5tD,1.5h;ic99,1132,licder 3 Stl-jrktd cyls 0.30 CsD7 12.37 3 97171 115 9 .19 645 700 stee? elp f29 5% das 3 f30 55G dru:lCyl as in l29,2 cm /stl cv s, 13 C.76 Cs137 12.04 9.1504 34453.1 5!5 64 8 store? CslU 1 La.ge cy11rder(50 rjh IG) 127 33Gd:ur CM,:etal, lead filigs 120 4.67 50/50 6.69 31.2423 132337.8 523 550 stca. 4115:13 29'.re55,12tCs1 H 517:9?,

5tNi6),ltCo60,1.510,1.5h;1Ez,ltether 13 10G das Caistis retal 3.001 '0621A02 M 0.010742 11 0 20 32 Envi:Cre-stro? 'StCo62,79tf.109,115tl25,Eu152iA;1:1 Stl CF E3468-1 0006Cd StlCP 0.141 70621A07 M 0.171155 2218 170 250 store? 74tsip,26tAs241(52, /g R3Eyla2 tate (.25MA

$7 1/2Galbottles E4331-l* D03cthylse Clori .15/k;,,F351'iIi.5?

/k;l,n03tetene[1.!xl;)

1f ;} ;)

0022Olorof0:3[.95M/l (42 Poly CP Ccrmied dris with r2W (dirt) 0.005 70621A098 M 0.02dl2 515 95 145 store? 11C06319131U IUZEK .05cc/l]

19 E3468-6 .

00223Iereforz(.lg/1),{003E'J:ylretate(.05:g/l) f PolyCP Carroded dris with GW <0.002 E4MI-2 M 0.020975 353 1 32 152 stm? 17tCsip,UE235 totali l10 MiM.4 Mill @f**'2*""^"

0.098 70621A12 E 0.124019 40 '90 640 stere? 96 tsl U,312n1 % ,<llSr90,NiO,Cc60,u134 l12 PolyCF Solid Concete E3468-8 002221ercica((.02g/l) ,

Haratins hterials Inventory 1211_17 10 DESCRIm0N V011E hD27 CWJJ15 1 Settl.'9 pit soil 70 cuit 7125 lbs T002(trichloroettee, trichlorethylene),FCB +-

2 Dit-octpphthalate $ gal 19 lbs U107 3 Luote 5 gal 19 lts 100) 4 ha3H 1/2lb 0002 ,

5 S h a lisd fa:e 5% g 6 E;i 500al :00g DX2 7 Chroserge ligal 90Its D002 ,

8 e

-f

_ _ _ _ _ - - . _ _ _ _ _ - _ _ _