ML20212C590
| ML20212C590 | |
| Person / Time | |
|---|---|
| Issue date: | 06/30/1986 |
| From: | Nussbaumer D NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Woodruff R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20212C555 | List: |
| References | |
| NUDOCS 8608120098 | |
| Download: ML20212C590 (5) | |
Text
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- %'*t UNITED STATES I
NUCLEAR REGULATORY COMM6sslON Ref: SA/J0L f
,j WASHINGTON, D.C. 20555 e
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[<lub JUN 3 0 1986 MEMORANDUM FOR Woodruff
. Regional. State _ Agreements _ Officer l
Region-II-l 1
FROM:
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. Donald A. Nussbaumer Assistant Director for
-State ~ Agreements Program._
Office of State Programs
SUBJECT:
FURTHER-NRC STAFF COMMENTS-ON PROPOSAlcTO -BURY CS-137_.. _ _
-CONTAMINATED S0Il-
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In response to Mr. Godwin's May 9,1986 request we and NMSS staff reviewed the supplemental infomation furnished by U.S. Pipe and Foundry Company on the subject proposa1r We also. factored in..the-additional information on_the_ site _ disclosed by Messrs..Godwin.and_McNe.es-at the-m
.m Conference meeting 11n Charleston, Wy_ last month and the results of your discussion with.Mr._Godwin1 June 27, 1986.- -~
m.
._u Our coments and those of NMSS staff are enclosed (enclosures 1 and 2)._..
The bottom line seems-to be a need to resolve the question of whether hazardous materials are present in both.the radioactive contaminated
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soil and in the soil of the site proposed for burial of--the-soil.- (See our general coment no.-1,-enclosure 1). -We believe that this question-must be resolved before; Alabama 4an-appropriately-address the
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applicant's propo. sal.1---Q_a-C,2_ z.1-1J-+= %.;.
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We would suggest thatThe applicarit eiiamine"~the optionlof dispos.al by___
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burial at a local or nearby. site..(see.Our_ general comment no. 2, enclosure 1). A site freetof-hazardo's materials contamination and u
having more favorable geohydrological characteristics would have obvious technical advantages compared to the presently. proposed burial site.
When a satisfactory site 'for jaiid burial has been identified (e.g., by
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resoluti.on of ~the question ~~on the presence of hazardous materials at the presently proposed site or by identification of an alternative site) NRC WM staff will be pleased to_perfom_the..necessary-analyses-to-detemine if the burial would meet NRC criteria for burial.
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_ _~ dona Nus mers
_.. 1.T _.. J Assistant. Director for - _
.m
-_+--
State Agreements Program r__ _ _
_ _ __0ffice:of: State: Programs- - __ _-_
Enclosures:
As stated 8608120098 860710 PDR STPRG ESCAL PDR
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Comments on U.S. Pipe and Foundry Company
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Responses to NRC 2/19/86 coments.
I.
General Coments 1~-~~ ] ~i
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1.
Our February 19, 1986 comments inclided the following:
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"The discussion of the history bf thb sitd'an'd'1Vout~in~d ~1n-particular past usage of the site as a landfill, raises a--
question about the potential for future needs'for' remedial ~
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7 actions of this site on account of these pastlandfil1 activities."
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At the annual meeting of the Conference of-Radiation-Control"N-1 Program Directors, Inc., in Charleston, West Virginia in-May,-1986,--
Alabama representatives disclosed that site samples collected for
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radioactivityanalysiswerefoundtoalsocontain-lead ~andjadmium.1
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This finding raises two issues. First, NRC staffs notwithstanding other technical concerns (discussed below), has reservations over recomending authorization o_f burial of licensed material at a site that may contain hazardous materials.' Other regulatory agencies, such as EPA, may have a regulatory-interest in the site ~gn account' ~ -
of the presence of these materials and NRC staff would recomend no further action on -the proposal for on-site burial' of the Cs-137
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l until these other regulatory agency interests-are explored and= ~
resolved satisfactorily. Secondly, the presence of Pb, Cd or other hazardous materials may affect the availability of-the option to dispose of the radioactive material at the comercial-low-level--
waste disposal sites. We recomend Alabama and the applicant fully coordinate with the site operators and State licensing agencies-to-assure a full understanding exists of the options that-are i
available if comercial disposal is utilized for the Cs-137 contaminated soil.
2.
To date, it appears that only two options have been given consideration; (1) on-site burial or (2) disposal at a commercial low level radioactive waste disposal site. Disposal at another ~
local or nearby site may be an alternative deserving consideration, particularly if a site havir., more favorable geohydrological characteristics can be found. NRC staff recommends this
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alternative be explored particularly if the presence of hazardous materials in the soil adversely affects other options for disposal.
3.
NRC staff continues to recomend that the State' provide-for public "-~
m participation in the decision making ~ process if the Department ~
believes that local disposal is not to be precluded on technical grounds.
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II. Technical Coments
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Page (of original proposal)
Sec./ Para.
Coment 21 3
The original comment has not bsen fully-responded to. No test data has been -
provided showing-that-the ---
Cs-137 will be. bound to- -
- either..the underlying soil at the site or the baghouse dust. - At the annual" ------
meeting-of-the Conference _ --
of Radiation Control Program Dire ~ctors, IncZin.
. Charleston, WV.in May,1986 Mr. McNees, in his paper on this incident, reported that migration of Cs-137 has been= detected-thus-raising-questions--about the validity of.the assertions about the behavior _of._the.
cesium in the. soil.
33 2nd paragraph and Controlled,a.ccess-for 30._.
following under years is a critical factor
" Method of in utilizing 50 uR/hr as Disposal" the criterion for.--~-
excavating contaminated -
soil but as proposed will i
be dependent upon the continued-existence of,U.S.- --
Pipe and Foundry.- We believe that the 50 uR/hr criterion for excavation and later tilling to reduce levels to-20 uR/hr (including background) at one meter as the final level is technically acceptable provided the site covenent restriction is expanded to cover this.
area of the site as_wellEas-
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the burial-site.
34 Middle paragraph As noted earlier, the applicant'.s. statements.on _ '- -
the rates of leachability of the cesium are unsupported by test data that is specific to the
site. A review by a qualified geologist of the potential-erosion. problems of the site would also be appropriate.
34 Section on The applicant's._ responses _
training to NRC comments suggest laundering of contaminated or potentially contaminated
~ clothing way take place.
. Procedures for surveying -
such clothing before and. ___.
after laundering.and for= -
surveystofalaundry=-.. _
_v_:
equipment and_ effluents should be.-reviewed ast ::r=r:
. _ _appropria_teg With respect:to-surveys for contamination of--
nearthmoving and other. _. _
equipment leaving the. site, we note no criteria are provide.for removable.._
contamination. Also, is _
the 5 uR/hr criterion a surface reading?
Allowing waste wash water
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from decontamination of equipment to " soak into the ground in the contaminated zone" could mean altering the physical and chemical behavior of the cesium in the soil. Controls on the amounts of waste water 1
used, its application, and on collection should be considered.
It is asserted that the pipe containers will have a life of more than 100 years but no data supporting this is provided.
What QA measures will be taken to assure the welding of plates to the ends of the pipe result in full seals (e.g., no burn throughs)?
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Polyethylene (thickness unspecified)willbe wrapped around each container as an anti-corrosion measure.
Has the possibility of corrosion from within been considered?
We recomend that the post disposal monitoring be specified in detail; e.g.,
locations of monitoring wells, stream sampling
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points,-surface radiation surveys should be specified; What kinds of laboratory analyses are to
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- -. - - ____,.___._ _.n _._(dissolved and suspended
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. solids)~;Tand:who~are the-r
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- reports._to go to.and in.
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---c what timeframe?.
See our general coments, 40, 41 43, 44 items 3.4, 3.6, especially nos. I and 2.
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