ML20215K024
| ML20215K024 | |
| Person / Time | |
|---|---|
| Issue date: | 01/15/1976 |
| From: | Dragonette K NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Lohaus P NRC |
| Shared Package | |
| ML20215G205 | List:
|
| References | |
| FOIA-87-235 NUDOCS 8706250192 | |
| Download: ML20215K024 (4) | |
Text
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4 UNITED STATES NUCLEAR REGULATORY COMMISSION
'E W ASHING TON, D.
C, 20555' 4
i January 15,. 1976-MEMORANDUM FOR:
Paul Lohaus' Agreements. and Exports Branch FROM:
. Kitty S. Dragonette 1
Waste Management Branch
SUBJECT:
> EPA PAPER " PRELIMINARY DATA ON THE OCCURRENCE OF TRANSURANIUM NUCLIDES IN THE ENVIRONMENT AT THE RADI0 ACTIVE WASTE BURIAL SITE, MAXEY FLATS, KENTUCKY" RECEIVED WITH LETTER DATED DECEMBER 22,1975
-l FROM DAVID S. SMITH.
l This is to confirm our discussions.of Tuesday, January 13, concerning Lewis Meve 's paper.
I We agree with your coments as outlined in 'your draf t response' to.Mr.
Smith. Additional comments are attached.
We: hope that EPA will'give serious consideration to.our recommendation.that an overview approach be adopted for the full' report.
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Enclosure:
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COMMENTS ON THE EPA PAPER " PRELIMINARY DATA ON THE OCCURRENCE OF TRANSURANIUM NUCLIDES IN THE ENVIRONMENT AT THE RADIOACTIVE WASTE BURIAL SITE, MAXEY FLATS, KENTUCKY" RECEIVED WITH LETTER DATED DECEMBER 22, 1975 FROM DAVID S. SMITH.
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,CENERAL COMMENTS i
Our general impression of the purpose, content, and tone of the report is i
soit twhat negative.
We suggest that a more appropriate purpose at the present time would be a status report.
For e xample, the KDHR six-month study, the July 7,1975 NRC report, activities of the Kentucky Radioactive Waste Disposal Environment Study Design Committee, current NECO and Kentucky activities and responses to recommendations in these documents, and the scope and status of research efforts underway for the site could be s ummarized.
A number of studies are in progress, some of which are indicated in the paper on Page 11.
The amount of new data included in the report is. minimal (e.g. the addition of two qualitative samples in the footnote on Page 22).
The Kentucky report has already received considerable public and regulatory attention. A number of statements are made that could be taken out of context.
bbny specific and general conclusions were reached based on data which the author conceeds equally support or do not rule out possibilities. A more objective summary would provide a useful l
reference document for those agencies and parties having responsibilities while still serving to focus attention on a situation that merits continued monitoring and study.
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l SPECIFIC COMMENTS 1.
Abstract Paragraph 1 and Page 10: References to large undetermined quantities of other Pu isotopes are made.
Data from invoices is j
referenced and data from safeguards tranfer reports should be available.
j The scope of the inventory study referenced on Page 11 should be indicated.
I 2.
Abstract, Paragraph 3 and Page 30: The inference that 80 kg of Pu 239 is available in a mobile form is made.
We feel that the data available to I
date have n'ot shown the entire source to be mobile and have not clearly l
established the roles of operational contamination, leaching, and migration.
i This inference is an exanple of statements that may be taken out of con te xt.
3.
Page 9, last Paragraph: Question the doubling rate every 1.3 years in light of 10 nanocuries/ gram limite on NECO license.
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Page 10, Section 4.2, Paragraph 1: Ad hoc site requirements and restrictions can provide flexibility as warrented and are not-necessarily bad.- Coordination of:six sites for implemention of general requirements is no: difficult.
5.
Page. 23, last two observations: The conclusion that well data are relatively "very high"'is not clear._ We note that the data reported' on Pages 7 and 16 of the Kentucky. report ~ indicate that 'the well' samples
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averaged 360 times the_ Pu 238 controls and 7 times. the Pu 239 controls -
j While the soll sanples averaged 200 times the Pu.238 controls and 25 j
times the Pu'239.
The conclusion should bel explained more fully.
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~ 6.
Page 31, last Paragraph: We feel'that the 1 dea of no migration or zero radiation release is not' realistic.
It is doub tful. that a site could.be found that would not permit some migration from the burial trenches.
.Disposa1' sites should be-selected and operated in such a'way as to provide reasonable assurance that radioactivity will not be released to unrestricted areas. Criteria _ for evaluating ' migration or release ' of radioactivity from commercial burial grounds should be defined :to. assist in determining the acceptability of existing and future ' disposal sites and. disposal practices.
These specific comments are illustrative 'and are.not f ntended to. be comprehensive
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Traces of plutonium and fuel, which is disposed of k low level radicactive wastes under much tighter controls.
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havt been detected hundreds Scientists initially had t
of feat from where they were thought of the shallow burial buried in Kentucky, promp-technique used in Kentucky I
ling a review of U.S. disposal and the other sites offered a f
methods, the Environmental permaner,t solution for low.
f Protection Agency reports.
level waste disposal. But an t
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William D. Rowe, head of EPA spokesman said such U.3 '-
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the EPA radiation morutoring-burial now can be considered Y*.
program, said Wednesday only "a holdup technique" that tha urgd radiation until better methods or con-merstinn poses no public trols can be found.
health bazard.
The wastes-such things as i
Dut, he said, it means new contaminated clothing and f~1 methods must be.found for resins used to remove getting rid of low level in-radiation from nuclear s
dustrial atomic wastes.
reactor parts-were buried
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enntinues uncheckcil, ne said, trenches in a shallow landfill If the current mirration between 1963 and 1972 in
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g b the dispor,al site at Maxey at the Kentucky site, Some
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Flafs, Ky., may have to be wastes were put in metal enlarged.
containers, Rowe said, while
, Simila'r burial sites for low-others were not'
, level, industrial a temic wasics are lceated at West Tito lleported lil Valicy, N.Y, Barnwell, S.C.:
BELGRADE, Jan.
13d Sheffreid. Ill.: Beatty, Nev.
' L'PD-President Tiln of and Richia:vi, Wash.
Yugoslavia is receiving meWal tuatment Wa coV None <4 the wastm poses the j
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