ML20215K089
| ML20215K089 | |
| Person / Time | |
|---|---|
| Issue date: | 04/09/1976 |
| From: | Karen Chapman NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Pastore J CONGRESS, JOINT COMMITTEE ON ATOMIC ENERGY |
| Shared Package | |
| ML20215G205 | List: |
| References | |
| FOIA-87-235 NUDOCS 8706250211 | |
| Download: ML20215K089 (34) | |
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9 APR 9 197E-Honorable John D. Pastore Chairman, Joint Committee on Atomic Energy Congress of the United States
Dear Chairman Pastore:
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There has been much recent public and Federal agency attenti6h'iiven to !
the disposal of radioactive waste at the commercial burial grounds aud, l
('~ in particular, the Maxey Flats, Kentucky site. At the recent Authoriza- !
tion Hearings, at which Chairman Anders testified, you asked several l questions on the vaste burial grounds. The purposo of this letter is l to provido you with general information concerning the commercial burial grounds, background information about the development and current status of the Maxey Flats site, and our program of reviewing the other burial grounds.
The Nuclear Regulatory C;mmir. 9n (NRC) has closely followed the problen at Nbxey Flats. In June 1975, at the request of Kentucky Governor Julian Carroll, the NRC conducted an independent assessment of the Maxey Flats j site. NRC concluded, on the basis of the assessment, that there was no {
significant public health hazard from the small amounts of radioactivity {
being releaced by the site. A summary and chronology regarding Maxey l Flats are attached as Enclosures 1 and 2. The NRC has also followed the !
situation at the New York site and NRC staff conducted a site visit last !
4 month. A summary of this situation is attached as Enclosure 3. Except ;
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for the site at Maxey Flats, Kentucky and the site in New York, there is ;
no evidence based upon samples taken by the licensecs, the atates, and NRC that any off-sito migration of radioactive material from the sites is. i occurring. The NRC also has a program to routinely review the commercial :
, burial grounds. All sites were visited during 1975 and 1976. In addition, NRC recently initiated a special inspection at each commercial burial ground, 1 including Maxey Flats, to take independent environmental samples for analysis.
A discussion of this program is attached as Enclosures 4 and 5. Euclosure 6 !
providea background information on the co~mmercial burial grounds including I procedures for operation. In addition, the NRC has actively investigated !
the recently reported- evidence that Nuclear Engineering Company employees j have been removing contaminated material cud equipment from the Beatty, i Nevada sito. The investigation, conducted by the NRC, other Federal agencies j and Statc of Nevada, confirmed that there has been removal of contaminated. ,l material and equipment fro- 'hnt site. A summary of this problem is attached j 1
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Honorabic John D. Pastore .
as Enclosure 7. As a precaut1onary measure, the NRC, in cooperation with i i
the ' States of Illinois, Washington and South Carolina, has also investi-gated the operation of the burial sites in these states. The investigati and thorough radiation surveys did not reveal that items and equipment we_.
being removed from these sites. New York State and Kentucky are conducting investigations at their burial grounds to determine if similar practices have occurred at these sites. I l
There are six commercial low-level waste burial grounds; .these are located j in West Valley, New York (operated by Nuclear Fuel Services, Inc.); j Barnwell, South Carolina (operated by Chem Nuclear Systems, Inc.); and in j g- Maxey. Flats, Kentucky; Sheffield, Illinois; Beatty, Nevada; and Richland, '
,. Washington (operated by the Nuclear Engineering Company, Inc.). All the !
burial grounds are located on state-owned land except for the Richland i site. This is located on federally-owned land which has been leased to ]
the state. The purpose of requiring the siting of waste burial grounds l on government-controlled land is to aosure long-term control of the. site. i It is intended that af ter radioactive wastes are buried at the site, the {
1and not be used for any other purpose. I The ecumercial waste burial grounds are licensed by the NRC or, in the case where they are located in an Agreement State,. by the State Regulatory ,
authority. The burial ground located at Sheffield, Illinois is regulated l by the NRC. (1111noia is not an Agreement State.) The'other burial grounda (all located in Agreement States) are regulated by the states.
The basis for approving a sit.o is that the geological,- hydrological, and climatological characteristics of the site are adequate to assure contain-([j ment of the waste materiala in a manner that'will not endanger public henith and safety. In each case where an AEC license was issued, the geological and hydrological suitability of the site'was assessed by the U.S. Geological Sdrvey (USGS). Three of the burial sites were originally licensed by tha Atomic Energy Commission (AEC) - Nevada, Illinois, and . Washington. In the case of the Agreement States, the site suitability was assecsed by the USGS or an equivalent stato agency. In the NRC or Agreement State evaluation, no credit is given to the type of packaging used for the waste in assuring containment. The packaging muut, however, moet the NRC and' Department of Transportation (DOT) standards for safe trancportation of the waste materials. Where the radios.ctivity of the waste materials is very low (bolow lovcis specified in the regulations), industrial type packaging, such as cardboard boxes or steel drums, may be used.
On September 12, 1974,-the AEC issued a proposed ruls which would prohibit
The September 12 rule and an accompanying draft environmental statement i
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- e Honorable John D. Pastote ,
cont;emplated AEC acceptance of transurante waste from licensees. NRC's staff is presently reviewing the proposed rule.
The following pot.icies are currently in effect at the'various sites regarding the acceptance and' burial of wasta containing transuranium nuclides: l;
- 1. Beatty, Nevada, although presently closed; Maxey Flats, Kentucky; Sheffield,. I111nois; and Barnwell, South Carolina will not accept transuranic. contaminated waste when the concentration exceeds,10
(~. nanocuries per gram;-
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- 2. The West Valley..New York site, although presently closed, previously. 'q instituted a policy.of not accepting more.than trace quantitics of
, plutonium. NES defined this limit as "no more than one gram of plutonium per nominal 1000 cubic foot' shipment, with a concentration of no more than 0.1 gram Pu/ cubic foot. NFS would accept other trans-
-uranic contaminated waste;;and ..
- 3. The Richland, Washington' site presently accepts transuranic contaminated.
wastes. '
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Beginning as early as 1972,' the AEC staff provided technica1' assistance to tha State of Kentucky to improva management of the site.- 'In Tune 1974, the General Accounting Office -(GAO) initiated a review of. waste burial ~
grounds. ' The NRC continued to provide recommendations :and technical assist-
{ ance to Kentucky during the course of. the CA0_ study. .' Since many of these :
activities were in progress when GAO initiated its study, both the AEC and the.NRC' staff were able to provide GAO.with-information about the status of' the sita'and appropriate corrective actions. On January 12,.1976, GA0 issued its report to' Congress. The report deals with both commercial ~ burial'activi-ties and.the'burtal practices at Energy Research and; Development (ERDA)?
. operated facilities. ' The GAO made several recommendations- to tho: NRC con-corning the need for comprehensive studies of: waste dispossi'sitos,. development of site selection criteria, improvements in monitoring programa-and' development:
of long-term care requirements.- In general, the _NRC' agrees with these recem-mandations.. The NRC staff has taken or'will take positive action to implement' each of the recoraendations addressed to.NRC in'the report.
In addition, NRC wasto management research activitics'which. ara currently.
underway include NRC participation in a USGS studyfand a contracted' Brookhaven1 National Laboratory study. The USGS is conducting;a~ study to
, develop geologic' and hydrologic cr1* aria- for evaluating waste bur 1a1 attes -
and-to' develop? predictive wasto traAsport modelslfor buried radionuclides.
NRC is assisting'USGS in.this program by providing analytical services for.
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i Honorable John D. Pastore- ,
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samples obtained by USGS. USGS has already. initiated geological and s hydrological sampling programs at ~ the New York and South Carolina sites l and plans to initiate further studies at the Kentucky site in the near !
future. Preliminary negotiations are being made by USGS to make similar l investigations at the Illinois site.. Under the NRC contract, work is j underway at Brookhaven to carefully catalogue the types and characteristics !
of wastes likely to be found at the various burial grounds. f l
As th'e information outlined above and presented in the enclosures shows, y commercial land burial is a complex matter. We feel that appropriate !
g- actions are being taken at the sites concerning current problems and that 1, additional study is indicated for long-term considerations. We intend to give continued attention to the issues which have not been resolved. ,
We would be pleased to respond to any further questions you may have l concerning commercial waste burial gradnds. I Sincerely, l
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/ Kenneth R. Chapman, Director
'I Office of Nuclear Material Safety and Safeguards Enclosures.
(} 1. Summary of Maxey Flats, Ky.
Burial Ground
- 2. Chron. of Major Events at M'axey Flats, Ky. Durial Ground
- 3. Summary of Incident at the West Valley, N.Y. Durial Ground ,
- 4. NRC Rev, of A/S Programs incl.
Rev. of the State Licensed Commercial Radioactive Waste Bugial Grounds ,
- 5. NRC Program of Insp. and Rev. of Commercial Waste Burini Crounds
- 6. Background info. on Commercial Radioactive Waste
- 7. Removal of Contaminated Material from Beatty, Nov. Site by NECO Employees
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SUMMARY
Kentucky Burial Site The Maxey Flats, Kentucky commercial low-level waste burial ground is licensed and regulated by the Commonwealth of Kentucky, an Agree-ment State. (License issued in October, 1962.) It is operated by the Nuclear Engineering Co., Inc. (NECO). During the early 1970's, Kentucky became concerned about on-site water management and the accumulation of water in completed trenches. Kentucky required the licensee to institute a water management program which included' pumping water from trenches to above-ground stor' age tanks and installing an evaporator to concentrate the pumped liquids for disposal as solids.
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4 In October,1974, Kentucky inforced the NRC of the preliminary results of their special six-month environmental stutdy at Maxey Flats. (The site has since been studied by the NRC, at the request of Kentucky Governor Julian Carroll, and the EPA and USGS, under contract with Kentucky.)
Kentucky has continued their extensive environmental monitoring progrin and several EPA and USGS research studies are underway at the site.
i Kentucky concluded, on the basis of their special 6-month study published in December, 1974, that the' burial ground was contributing radioactivity to the local environment, but at levels which did not create a public health hazard. They identified tritium, Co-60, Sr-89 and 90, Cs-134 and 137, and Pu-238 and 239 in certain individual samples in the un-restricted environment. The levels ranged from slightly above back-ground to orders of magnitude above background for certain individual samples. (The NRC, based on available Kentucky and licensee data con-
,. cerning acquatic releases calculated a maximum potential whole body
(, dose to persons in the area of 125 millirem per year including natural !
radioactivity. This dose does not represent actual human exposure. t It was based on the maximum levels of radioactivity observed and the most restrictive radionuclide mixture.) Kentucky recommended further studies at the site to assess the long-range health and safety signifi-cance of their findings.
Kentucky expanded their Radioactive Waste Disposal Environmental Study Design Committee to include members from other Kentucky and Federal agencies and held a meeting in February, 1975 The NRC participated.
The Committee recommended a 6-point program for further studies at Maxey Flats. Kentucky initiated implementation of. some of these studies and requested Federal funding assistance. Concurrently, Governor Carroll requested the NRC to conduct an independent review of the site. An NRC review group was appointed which reviewed info'rmation available about the site, conducted a site visit and met with Kentucky Enclosure 1
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and NECO officials. The NRC concluded on the basis of their study that l there is no significant public health problem associated with the re-lease of radioactive material from the burial ground and that Kentucky ,
has been taking appropriate action to implement the recommendations made f in their December, 1974 report. The NRC also made several recommenda- t tions principally dealing with methods to improve the water managemenc !
program to minimize the potential for migration of radioactivity. Gover- )
nor Carroll was informed of the results of the NRC review in July, 1975 He subsequently, issued a press release indicating the NRC was responsive to his request and directed the Kentucky Department for Human Resources to carry out the NRC's recommendations. The NRC also informed Kentucky
[, that the NRC would provide continuing technical assistance but was not able to provide financial assistanc to help carry out the studies. The EPA has been taking and analyzing environmental. samples for Kentucky. t A January 14, 1976 EPA press release concerned an EPA report which ;
presents Kentucky environmental data, describes various potential mi-gration pathways and draws conclusions from EPA's analysis of the data. ,
NRC has reviewd the paper and provided comments to EPA. '
The licensee (NECO) has conducted their own environmental monitoring l program. NECO has previously taken exception with the significance of the findings of Kentucky and more recently with conclusions in the
, EPA report. NECO believes their data, covering a longer period of time, shows no trends toward increasing levels of environmental radioactivity and shows no real potential for human exposure to persons living in the l area.
{' The Maxey Flats burial ground has generally been operated as the other commercial low-level waste burial grounds are operated. Packaged waste is dumped into trenches about '25 feet deep which is then covered with j soil. When a trench is completed, it is capped with four feet of soil I and a vegetation cover is established. The geological features of the burial site, not the packaging, is depended upon'to assure containment of the waste at the site.
NRC staff believe the burial ground is contributing radioactivity to the local' environment, but there is no significant public health problem associated with the release of material. NRC staff believe the State is taking appropriate action to improve conditions at the site by requiring the licensee to carry out and continually improve a water management program. Our most recent review of the Kentucky Agreement program,. con-ducted December 1-5, 1975, concluded the State is taking appropriate-action.regarding the NPC review group recommendations and is continuing their efforts to improve the on-site water management program.
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Chronology of Maior Events at Maxev Flats, Kentucky Commercial Radioactive Waste Burial Ground Time Frame 1962-1969 Introduction ,
1 Kentucky became the first Agreement State when they signed an Agreement with the AEC in thrch, 1962. With the primary intention.of encouraging a nuclear industry in Kentucky, the Kentucky Atomic Energy Authority (now I the Kentucky Science and Technology Commission') pursued the concept of a radioactive waste disposal site in Kentucky. In October, 1962, the i
/' State issued a license to the Nuclear Engineering Company, Inc. to 1- operate a disposal site at Maxey Flats, Kentucky and the burial ground
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began operation in March, 1963 The Nuclear Engineering Co., Inc.
(NECO) had previously purchased the site (about 330 acres) and the title of the land was transferred to the State. The State in turn leased the land to NECO. For perpetual care, the lease agreement con-tained clause stating that NECO would pay the State four percent of the charge per cubic , foot of waste buried. The State has about $160,000 in l the perpetual care fund at present and is negotiating with the licensee for increased burial charg'es.
Site Descriotion The Maxey Flats site is located in Fleming County in the Northeastern portion of the State of Kentucky. As seen on a topographic map, Maxey, Flats is a flat-top hill with steep sides. Throughout most of'the area the flat " top land" is in grass or crops and the steep hillsides are
( forested. This is true of the Maxey Flats burial site, the burial taking place on cleared flat land at the 'end of the fan-shaped mesa.
The " bottom land" at the foot of the mesa, some 250 to 300 feet below, also is in grass or crops. The area is generally sparsely inhabited, but there are small farms in the vicinity.
Maxey Flats is underlain with nearly horizontal beds of differing geo- ,
logic units: i a .. 2 to 4 fe'et of s' oil I
. b. Black to gray fissile shale (4.0 feet)
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- c. Sandstone (40 feet) 'j
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- d. Green-gray shale (10 feet) ;
- e. Black to gray fissile shale (18 feet)
- f. Green-gray shale (20 feet)
- g. Black to gray fissile shale (190 feet) k Enclosure 2 e
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- Most of the rocks in the area have visible jointing. The disposal
', trenches are located in the upper. half of layer b. Trenches are dug with a~ scraper and are 300-600 feet long, 20-80 feet wide and 30-40 feet deep.-
' Evaluation The Maxey Flats site was chosen from several sites under consideration in Kentucky. The State iDepartment of Health was principally responsible ;
for the evaluation. . The geological hydrological, and meteorological
. aspects of the site were studied and reviewed by the Kentucky State
- j. Geological Survey, U.S. Geological Survey, Oak Ridge National Laboratory,' j
, s U.S. Public Health Service, an-independent geologist hired by NECO, and -
a Geological Testing fien. Background radioactivity measurements were 1 also taken. The"AEC also. reviewed
' the application' submitted by NECO and provided comments'to the State. AEC's comments were. principally-
, technicals in. nature dealing with' the applicant's proposed monitoring j
, and hand. ling techniques. The.AEC also commented'that firm-conclusions.
could not tre drawn, on 'the basis of information contained in the Lappli-cation, concerning the geologic suitability of, the proposed burial. site to assure:there would not be transport of radioactive materials through -
. ground water to' surrounding streams. The State concluded, on the-basis of their evaluation, . that the site'was suitable for' the ' disposal sof radioactive waste and Authorized 'its' use, f
1970-1976
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Through 1969 no major'M oblems'were 1dentifiedicelating to operation of
([" the burial ground. In 1970, Kentucky staff expressed concern about opera-tion of the site and the'need'for a more extensive review of the burial- 4 ground operation. This. concern was based on the increasing quantities ;
of radioactive material being' buried at the site, and on-site water management problems.
.About 3 million cubic feet of waste containing 1-1/2-million curies of 1 byproduct material 300 kilograms of special nuclear. material land 50 tons :
of' source material have been buried at the site. In addition to com-merciallfgeneratedwastesfrom. reactors, isotope.usersandfuelcycle facilities, significant' quantities 1of plutonium and tritium from.AEC contract operations were buried.at the site. Staff concern increased during'1971 as the licensee continued to have problems with the accur -
lation of water in completed trenches. - The State instituted enforce-ment action, tut the licensee continued to. experience difficulty in; con- i trolling on-site water.. In 1972 environmental monitoring ' data began sto-indicate that the' site might be contributing. radioactivity to the-local environment. The. licensee continued to experience difficulty in con- I
, trolling on-site ' water and NECO violated 1 terms of' th'eir license.- !
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-3 In September' 1972, the State issued an order against NECO for non-compliance and willful violation of conditions of the license relating to water in completed trenches, burial of unauthorized material, and
. disposal of liquid wastes directly to solid waste disposal trenches.
Following issuance of th~e order, the licensee was permitted to operate the waste burial site for,the disposal of solid wastes only. -The licensee was required to. file an irrevocable letter of credit for .
$500,000. This letter of credit was in lieu of a performance bond to assure complianc,e with the terms of the order.
~ Action taken by NECO to control water problems included the pumping
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of water from trenches into above-ground storage tanks and the instal-1ation of an evaporator to concentrate the liquids for disposal as solids.
Envirgnmental Monitorine The State 'and NECO have conducted environmental monitoring programs at
. Maxey Flats since 1962. The routine State program consisted of monthly trips to collect samples from natural' streams, wells, springs, including drainage and seepage from all sides of the site. These sample points -
ranged.up to approximately two miles in distance from the site. In November 1973, the state instituted a special six-month environmental nonitoring study to identify the source and scope of the increased levels of environmental radioactivity previously identified in the lite environs.
Early AEC Review of Kentuckv#s Agreement Material Program and the
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Maxev' Flats Burial Ground '
The AEC reviewed licensing and/or inspection files concerning NECO' as part of the review of Kentucky's agreement materials program in 1971, 1972, 1974 and 1975. Site visits were conducted in 1964, 1973, 1974 and 1975 The earlier reviews had. included a discussion of the initial action status of the burial ground and environmental monitoring pro-grams. During 1972, the AEC conducted a review of the actions Kentucky was taking in connection with the September 1972 order against NECO and 'a site visit was conducted in April 1973 The review and site visit showed that Kentucky was requiring NECO to take necessary cor-rective action and that environmental monitoring data showed no radio-activity.in the environment in excess of acceptable standards.
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~4-Kentucky Informs AEC of Results of Six-Month Study Kentucky informed the AEC in October.,1974, of the preliminary results -
-~of their special six-month environmental study at the burial area.
In November, 1974, AEC conducted a site visit, met with State officials )
and' received a copy of a draft report documenting the purpose, scope q
, and results of the study. The report contained information.which j indicated that radioactivity may be migrating from the burial ground i
-and was.being detected in sampling. wells immediately adjacent to the burial site and in water collected from. unrestricted areas near the >
burial site. The activity levels reported for unrestrictedL areas ]
.- around the site exceeded, in some cases, ambient levels as well as Part j 20 concentrations for releases to unrestricted' areas. I d
In providing technical assistance to Kentucky, the AECLprepared' written J comments on the draft report. The AEC noted that the report'did not a'ppear to contain sufficient information to support all of the con- ,
clusions, pr ticularly whether the site was creating a public health j and safety problem. The AEC suggested that further comprehensive environmental studies should be conducted to. provide a technical basis for determining whether and to'what extent migration of radioactive material was occurring and for assessing the health and safety aspects l of conditions at the site. During November and December, the AEC also 1 participated in meetings with the State and the licensee concerning the report and the conclusions which could be drawn from the study.
NECO had taken exception with the conclusions in the State's report and had requested AEC assistance in resolving " differences of' opinion"
({j between the State and NECO.: NECO believes their data, covering a
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longer period of time, shows no trends toward increasing levels of environmental radioactivity and shows no real potential for human )
exposure to persons living in the area. l The final report of the six-month study was released in December.1974 by the Kentucky Department for Human Rescurces.- The report concluded that the burial ground was contributing radioactivity to the environ-ment; that the activity detected did not create a public health hazard; and that further studies were necessary to determine to what extent migration.was occurring and to assess the long-range public health and safety significance of the findings. The report stated that tritium, Co-60, Sr-89 and 90, Cs-134.and .137, and Pu-238 and '239 were identified in certain individual samples in the unrestricted en-vironmem', The levels ranged from slightly above back6round to orders of magnf.tude above background for certain individual samples.
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Following recommendations in the six-month report, the. State expanded an existing Environmental' Study Design Committee for the Jtaxey Flats i Radioactive Waste Disposal Facility and held a meeting of the Committee I in February 1975 -The Committee consisted-of representatives:from several~ State agencies: NECO, USGS, EPA, ERDA, and NRC. The purpose of..
the Committe'e.was to recommend to the State, further environmental . ,
studies to' determine the.long-range significance;of the. radioactivity 1
. detected in the site environs. .The following six items were identified during the February meeting'as the type of studies which should be con- m ducted at the site:
1 Priority I' Hydrogeologic Study (Deep Geology)
Priority'II Surface Study (Water runoff, meteorologica1' data, ar soil study in the-top o'ne foot) .
Priority III Weathered Zone Study (About'the top ten feet of soil)
Priority IV Definition of Source Term Priority V Agricultural Pathways (Livestock, milk,.
garden crops) j
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f Priority VI Environmental Biological Pathways (Vegetation',
stream biota, and non-domesticated ' sources of ~
food) .
( The cost for these studies was estimated by the Committee to be in excess of one million dollars. The. State subsequently requested NRCland'other-j l
Federal agencies to provide. financial assistance to' carry.out thgse 9 studies in Mays 1975 '
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Recuest for Indeoendent NRC Review of' Maxey Flats Burial Ground ~
On April 30, 1975,. Kentucky Governor Julian.M.l Carroll, requested the.NRC to independently assess conditions at-the site.and-to: provide'him with ,
findings and recommendiations. - An NRC review group -was- appointed. which consisted of NRC staff knowledgeableLin Agreement' State. relationships, hydrolo6y,;and radiological assessment. The review group examined infor-mation regarding the site, the State. license hydrogeologica1'information
.about'the site,'the State's six-month report,'the' report'of the State's I Environmental Study Design Committee, State environmental; monitoring -
data, NECO environmental monitoring data and actions'being taken.by?the<
State and NECO. . The review group also conducted an unannounced site < visit:
as part of the review and met, with State and' NECO officials. The'NRC- 1 e j i
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i concluded, on the basis of their study, that there was no significant j public health problem associated with the release of radioactive material l from the burial ground and that Kentucky has been taking appropriate l action to implement the recommendations made in their December 1974 six- ;
month study report. The NRC, based on available Kentucky and licensee !
data concerning aquatic releases, calculated a maximum potential whole body dose to persons present in the area of 125 millirem per year in- l cluding natural radioactivity. This dose does not represent actual human i exposure. It was based on the maximum levels of radioactivity detected !
and'the most restrictive radionuclide mixture. The NRC also made several !
recommendations principally dealing with methods to improve the water !
management program to minimize the potential for migration of radio- !
activity. Governor Carroll was informed of the results of the NRC review k g(_y in July 1975. The Governor subsequently issued a press release indicating j that the NRC was responsive to his request and directed the Kentucky Depart- j ment for Human Resources to carry out NRC's recommendations.
l The NRC also informed Kentucky at that time that the NRC would provide con-tinuing technical assistance but was not able to provide financial assist- !
ance to help carry out the further studies recommended by the Environmental j Study Design Committee. t Recent NRC Reviews of Kentucky Agreement Materials Program and Assessment of Maxey Flats Burial Ground d
NRC staff believe the burial ground is contributing radioactivity to the local environment, but there is no significant public health problem associated with the release of material. NRC staff believe the State is taking appropriate action to improve conditions at the site by requiring
, (,_j the licensee to carry out and continually improve a water management program. Following review of their program in 1974, we recommended that
~ the State reassess NECO's water management program and initiate a program to establish ,the validity of NECO's environmental monitoring data.
Our most recent review of the Kentucky Agreement program, conducted December 1-5, 1975, concluded the State is taking appropriate action re-garding the recommendations made by the NRC review group and is continuing their efforts to improve the on-site water management, program.
Maxey Flats Site Studies The State, NECO, EPA, and USGS have been conducting further studies at the site since the State published their six-month report in December 1974.
We understand the results of studies conducted by the State, EPA, and USGS will be published in the near future.
Enclosure 2
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Recent EPA Reeort .
A recent EPA press release dated January 14, 1976, concerned an EPA report which presents Kentucky environmental data developed during the l six-month study, describes various potential migration pathways and draws l conclusions from EPA's analysis of the data. The EPA report has been re- .
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viewed by the NRC and comments were provided.to EPA. Our principal com- !
ments were that the report failed to 'give adequate emphasis to the public I health and safety significance of the data and conclusions presented and l the paper was pr'eliminary in nature'since. it presents several specific j and general conclusions concerning pathways for the migration of plutonium ]
('i based on data which the author concedes equally support other possibilities. !
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NRC staff believes that before attempting to predict the future effective- 1 ness of the Maxey Flats burial ground in containing radioactive material, the degree to which site operations and each pathway presented in the
. report is contributing radioactivity to the environment should be deter-mined. j i
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Enclosure 2 j
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Summary of Incident At The West Valley. New York Burial Ground j I
l Ihe West Valley, New York commercial low-level waste burial ground is licensed and regulated by New York, an Agreement State.1/ (License issued in 1963.) It is operated by Nuclear Fuel Service, Inc. (NFS).
.In March 1975, the NRC learned.of a water seepage problem at the NFS commercial burial ground. The New York State Department of Environmental Conservation (DEC) had noted increased levels of tritium in water samples taken from on-site monitoring stations. The source was traced to water seeping out of the interface between the original till and cap of two
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trenches. (Estimated flow 6f 1 gallon per day.) NFS diverted seepage to a holding lagoon. No significant increase.in radioactivity in the unrestricted environment was detected, l
A meeting of Federal, State and NFS representatives was held at the site l on Fhrch 11, 1975 Based on discussions between NFS and State representa- I
' tives, NFS dispatched a letter informing their customers that they were suspending operation until the requirements for operation of the site were known and agreed to by the State.
NFS requested and obtained approval from the State DEC to pump liquids from the trenches to a holding lagoon. The liquids are subsequently processed through the reprocessing plants' low-level waste treatment system and released. NFS_and State representatives have, held several meetings since March 1975, to_ reach agreement on the conditions for re-opening and operating the site. Several studies, being conducted by the g"J State, EPA, and USGS are also-underway at the site. As of March 1976, L no agreement has been reached and the site. remains closed. -4 l
I 1/ A second burial ground at West Valley, N. Y. is not a commercial
' burial ground. It is used by NFS to bury fuel hulls and contaminated equipment from their reprocessing plant. (Authorized in NRC license.)
l Enclosure 3 D'N -
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l NRC Review of the Agreement State Programs. Including j Review of the State Licensed Commercial Radioactive. j Waste Burial Grounds. l In May 1965, che Atomic Energy Commission adopted the policy of making l l
an annual redetermination of the Agreement States' regulatory program J with respect to continuing compatibility with the Commission's program !
and adequacy to protect the public health and safety. The most recent !
determination was made September 15, 1975 covering calendar year 1974.
The redeterminations are based on review meetings during which the in- j dividual State programs are evaluated following the NRC " Guide for ;
g, Evaluation of Agreement State Radiation Control Programs," and on an !
- s. exchange of information program with the States.
Review meetings involve a detailed discussion and review of the States' management and organization, program administration, personnel resources, radiation control regulations, licensing and compliance activities (in-cluding waste burial grounds) and licensing and compliance practices and procedures. It is our current policy to hold an orientation meeting i
~
with new Agreement States within three months of the effective date of the Agreement, and to subsequently meet at approximately twelve-month intervals with States. More frequent meetings may be scheduled with States having program weaknesses or unique problems. i J
The objective of the review of Agreement State regulated burial grounds is to determine that the State is requiring the operation to be con-ducted in a manner which does not present a hazard to the public health j and safety and which is compatible with the MRC's requirements for the 1
(,.; operation of waste burial grounds. The license and inspection flies are reviewed about every two years, or more frequently, if unusual problems are being experienced in operation of the. site. A site visit is conducted about every three years in the accompaniment of a State representative.
During each review meeting, we review the environmental surveillance program being conducted at the site, any special site studies, changes in perpetual care funding, and discuss any major changes in the license, operational problems, and contingency actions taken to control operational problems. During the site visits, we review general site operations, the burial procedures being used, and on and off-site environmental surveillance activities. Records maintained by the licensee may also be reviewed. Recommendations for improvement in site operations are made on an individual basis. Following are the dates of site visits recently made by the State Agreements Branch staff to the commercial burial grounds licensed by the Agreement States:
Enclosure 4
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l 1
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_2_
- 1. Barnwell, South Carolina - December 9, 1974; February 24, 1976.
- 2. Richland, Washington - February 21, 1973; February 19, 1976.
- 3. Maxey Flats, Kentucky - November 8, 1974; June 3, 1975.
- 4. .Beatty, Nevada - January 20, 1976.
- 5. West Valley, New York - March 18, 1976. j l
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Enclosure 4
NRC Program o.f Insoection and Review of the Commercial Waste Burial Grounds l
The NRC Office of Inspection and Enforcement (IE) schedules inspections of the commercial waste burial grounds on approximately an annual fre- l quency. The frequency can vary somewhat depending on the inspection his- i tory of the particular licensee. The major objective of these unannounced l inspections is to determine if waste disposal operations are being con-ducted' safely and in accordance with the license issued by the NRC and g
the NRC regulations governing these activities.
During the inspections of a waste disposal facility, an inspector will
( pay particular attention to the following areas:
1 The overall organization structure pertaining to the licensed program.
- Training, retraining and instructions to workers.
Radiological protection procedures for operations and emergencies.
Available instruments, equipment, and facilities for
, radiation protection.
- Receipt and transfer or radioactive materials.
- Personnel radiation protection.
Notifications and reports to NRC.
Environmental monitoring.
Confirmatory measurements to verify the results of the licensee's environ-mental monitoring program and his on-site program have been made by in-spectors periodically in the past. The procedures are now being modified so that inspectors will collect samples on a routine basis for analysis at the NRC's reference laboratory. In addition, IE is now considering the inclusion of waste disposal facilities in the collaborative monitoring contracts NRC has with several States.
In November 1974, following notification by Kentucky of migration of radio-active materials at Maxey Flats, the NRC conducted special inspections at the New York, Nevada, Washington, Illinois, and South Carolina sites. _NRC inspectors collected independent environmental samples during these in-spections. NRC concluded, on the basis of these inspections, that there was no evidence of any significant transport of radioactive materials through migration and based on off-site sampling by the licensees and 4
Enclosure 5
4 2-States, no impact to the off-site environment could be attributed to the operation of these burial grounds. The results of NRC independent samples agreed with licensee and State analytical results. NRC also found'that the licensees and States had initiated appropriate environ-mental monitoring programs which considered the major pathways of ex-posure to the public.
1 l
In February 1976, the NRC went to each commercial burial ground to collect further independent environmental samples. The analysis of the data does ,
not indicate offesite migration from the Illinois, Nevada, Washington, i South Carolina and New York sites. The results of the analysis of samples taken by Kentucky and NRC indicate that off-site radioactivity is t_ decreasing.
I I l l
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9 Enclosure 5
j ,
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Background Information on the Commercial i Radioactive Wasce Burial Grounds 1/ I Radioactive waste generated during fuel cycle operations is divided l into two categories: high-level, and other than high-level. High-level I waste is defined as the aqueous wastes resulting from the operation of the 'first cycle solvent extraction system, or equivalent and the con-centrated wastes from subsequent extraction cycles, or equivalent, in a facility for reprocessing irradiated reactor fuels. All other solid waste,'regardless of its source, falls into the other than high-level category and may be sent to a commercial land burial facility for dis-posal. ' Included in this category is waste generated from educational,
, medical, industrial, and research facilities using radionuclides.
Pursuant to Nuclear Regulatory Commission (NRC) regulation (10 CFR 20) i commercial land burial sites must be located on land which is owned by either a State or Federal Government. The purpose of this requirement is to assure long-term control of the site in the event of default or abandonment of the site by the commercial operator. It is intended that, after radioactive wastes are buried at the site, the land not be used for any other purpose. The States have the obligation for perpetual care !
and maintenance of land burial sites to assure their dedication to waste i burial and to assure that they are not use,d for other purposes. j Authorization to operate a commercial land burial facility is based on J an analysis of the site topographic, geographic, meteorological, and I hydrological characteristics, and usage of ground and surface waters in the general area, which demonstrate that it is unlikely that buried radioactive waste will migrate from the site. No credit is taken for containment provided by the packages once they are buried. The purpose
{ of the packages is to provide ease of handling and minimization of per-l i
sonnel exposure and to prevent loss of the radioactive material to the i surroundings prior to burial. The packages are normally buried as re-ceived with no reprocessing or repackaging of package contents. However, in some cases, the primary package containing the waste is shipped in a reusable overpack or secondary container which may be required by Depart-ment of Transportation (DOT) regulations for shipment of the particular materials involved. In those instances, the primary package is removed from the reusable overpack before burial of the primary package.
The prime operations at a commercial land burial facility are the receipt, temporary storage, and burial in trenches of packaged radioactive wastes.
If
Reference:
"Snvironmental Survey of the Uranium Fuel Cycle" U.S. AEC, April 1974.
Enclosure 6
Among the criteria developed for accepting radioactive wastes for burial were the requirements that liquid wastes would be solidified before burial and that all shipping and packaging would meet the require-ments of the DOT and NRC for transportation of radioactive material. The
. burial of liquid wastes was excluded on the premise that such waste, however packaged, would be a compromise which could adversely affect the environmental controls for rad'.onuclide migration.
Monitoring programs are conducted at the sites to detect any ear.ly indications of mig' ration of radioactivity from the burial tren=. as.
7 The programs include sampling on-site monitoring wells; and air, water, and vegetation samples ara routinely collected around the sites.
The problem encountered with Maxey Flats demonstrates that the monitor-ing programs do provide early detection of any released radioactivity.
When radioactivity is detected off-site, and it is determined that the radioactivity originated from the burial operation, its significance must be analyred and appropriate corrective actions developed. There are several courses of action which could be taken depending upon the significance of the problem, the extent of radioactivity migration, and the hazard to the public health and safety from the radioactivity being released. These include: (1) a halt in the burial ground opera-tion, (2) removal of radioactive material from the burial area where the migration is occurring, (3) grouting or sealing that portion of the site from which material is migrating, and (4) increase the geographical size of the site to exclude the public from affected areas.
An average burial trench at a commercial burt.a1 site is about 300 feet long, 30 feet wide, and 25 feet deep, and ha o.!
- 5. Reference Number: 103-R-31
- ^/.?
- 6. Other Kentucky Radioactive Material Licenses: 16-SBN-10 6 16 ,BPI-47 ;
- 7. The authorized place for disposal of radioactive material shall be at bluey Flats, !
Fleming County, Kentucky, within the boundary of the land area described in the Kentucky Atomic' Energy Authority-Nuclear Engineering Company, Incorporated !
21 1963. a ; .c-Agreement dated January ..-
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-1/ For the purpose of this license (16-NSF-1), the term radioactive material l shall be defined to include not only byproduct, source and-special nuclear material, but all other naturally occurring or artificially produced radioactive material.
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2/ Objects, such as end boxes and control rods, made radioactive incidental to their primary use, and which are considered to be in non-leachable form are exempted from packaging for land burial.
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, , . . . Supplementary Sheet ,Liceme Number AMENDMENT NO. 27
- 8. The licensco shall not receive, possess, or have on his premises at the location specified in Condition 7, at any one. time, unburied radioactive material in excess of: ,
(a) 15,000 curies of radioactive material other than source material !
with atomic number 1 through 91, except Radiunt 226, which shall be -
l limited to 500 millicuries. For quantities of radioactive materials i
with atomic numbers greater than 92, the average concentration of these materials shall not exceed 10 nanocuries per gram of waste i in any container; _ .,q (,,,
l (b) 10,000 pounds of sou,rce material;
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350 grams of Uranium-235; 200 grams of Uranium-233, 200 grams of Pu; j (c) or any combination of them in accordance with the following formula:
for each kind of special nuclear material, determine the ratio be- .
tween the quantity of that special nuclear material and the_ quantity specified above for the same kind of special nuclear material. The sum of such ratios for all kinds of special nuclear materials in com-bination shall not exceed unity; ' .'me n > ....
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(d) Notwithstanding the provisions of subparagraph 8 (c), the' average concentratipn of plutonium shall not exceed ten (10) nanocuries
- per gram of waste in any container; and . i
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(c) The licensee shall not receive or possess'at any one time a quantity of radioactive material in excess of that specified in subparagraphs
.8 (a), (b),. (c), and (d) above unless the Department has first evalu-ated the proposed packaging, handling, storing, and burial procedures, and determined that the proposed operations can be accomplished without undue risks to thehealth and safety of occupationally exposed individuals and the public, and has issued a specific amendment approving the proposal.
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Ucense Number 16-N W-1 Supplementary Sheet l REND.\ENT NO. 27 9 # .
Txkages containing special nuclear material in excess of 100 grams of U-235 tr 60 grams' of U-233 shall be placed in trenches such that a minimtm of eight
, inches of carth or twelve feet of space containing no cther special nuc1 car piterial will completely surround each package. Packages containing special e,9cicar material in excess of 20 grams but less than 100 grams of U-235 or less j lhan 60 grams of U-233 shall be placed in trenches such that a minimum of cight 2
- ches of . earth or two feet of space containing no other special nuclear material teill completely surround each package. , .
- 10. t. l fadioactivematerialshallbereceived, possessed,anddisposedofby,orinthe physical presence of, persons designated by the licensec's Radiological Safety Conmittee. , ~j
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- 33. b f(ithin 20 days following each calendar month, the licensee shal'1 submit to the i ehnager, Radiation Control Branch, Kentucky Department for Human Resources, l Frankfort, Kentucky, 40601, a report showing the total volume in cubic feet and 1 nctivity of radioactive material, other than source and special nuclear materials, l
.in curies; the total amount of source material in pounds; and the total amount of cipecial nuclear material in grams buried during the referenced month for each 0.rench in which burial took place. The report shall also show the cumulative l potal of the voltme of all waste buried and the activity of radioactive material; j pounds of source; and special nuclear material buried through the month being i g cported for each trench in which burial took place during the referenced month.
Any trench which is open, but for which no burial took place shall also be shown l ti nd reported in the monthly cumulative totals. Each report shall show the date that any trench was opened or closed during the month being reported.
- -"m- ^
- 12. t
(,'ithin one year of the clo.,ing of a' trench, the licensee shall install permanent strench markers, one at each end of e,ach trench, bearing permanent codes sufficient to reference at least the following infomation: ,
Ya) The trench number, date , opened, and date closed.
'(b) The location of the center of the surface plane of the trench with reference to a designated permanent bench mark. The permanent bench mark shall specify the date of construction and the geological elevation at the top of the bench mark;
"(c) The definition of the trench surface plane boundary with, reference to the j determined center point;
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Supplementary Sheet License Nuir.ber . 16-NSF-1 N.END.\ENT NO. 27 j
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(d) The remaining dimensions of the trench shall be graphically portrayed, with reference to the surface plane . boundaries; l (c) ' Total activity of radioactive material in curies, excluding source and special ;
nuclear materials, the total ama'unt of source material in pounds, and t.he t j
total amount of special nuclear material in grams in the trench; l (f) The total volume,'in cubic feet, of waste buried in the trench;
);
(g) The information required by this condition, in addition to being referenced i on the permanent trench marker, shall be filed by written report to the Manager, Radiation Control Branch, Kentucky Department for Human Resources, Frankfort, Kentucky, 40601, within thirty (30) days after the closing of l a trench. 9 j. ,j l, s m.i ! , l 19 3 p.;, y=
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- 13. Prior to completion and final covering of trenches, backfilling shall be performed l as required to maintain a radiation level at the edge of the trench to less than ;
100 mR por hour. The open face of the trench shall be covered at the close of each {
work day in accordance with letters dated October'3, 1974, and December 18, 1974, sigt by Arvil Crase. However, in the event the plastic cover, referred to in the referencd letters in this condition cannot be utilized because of mechanical or weather conditid the licensee shall backfill with earth within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
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.t4. Within.three stonths after the' trench spoils are resoved, an appropriate shallow )'
root vegetation shall be init.iated and maintained, on the mounded carth to prevent crosion. % . g nEm. _, 3.s- o.. Q :s S * -
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- 15. All liquids removed from sumps of completed trenches and/or liquids which have made contact with waste in open trenches shall be treated as liquid radioactive j waste and processed as such. For liquids in trenches which have not come in j contact.with waste in open trenches, such liquid shall be analyzed for gross :
alpha, beta, and tritium activity. Such liquid shall be treated as radioactive i liquid waste if the analysis shows that the activity exceeds the following: l 1
(a) Gross alpha or gross beta activity of 3 X 10-8 microcuries per milliliter j (30 pCi/1); i I
(b) Tritium activity of 3 X 10-5 microcuries per milliliter (30,000 pCi/1). j l
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- Supplementary Sheet License Number 16-NSF-1 ANEhrD.\ENT NO. 27
- 16. Every reasonabic effort should be made so as to prevent rainwater from making contact with waste in trenches. No disposal operations shall be carried out whilo water exists in open trenches which can make contact with the waste. . .
17/ Any liquid collecting in closed ' trenches shall be removed until a dr'y
. status is established. A dry status is defined as a condition in which ,
a pump, pumping at a rate of 100 gallons per hour or less, will " gas-out" after 50 gallons or less of liquid is ptcped from the trench. The licensee shall detemine the dry status condition weekly until it has been established that the recharge rate for that trench will not exceed 100 gallons per week.
Thereafter, the trench shall be pumped monthly. ,
.v
- 18. Should any water sample obtained from any observation.well or from established sampic locations offsite reveal a gross beta and/or gross alpha concentration ,
greater than 3 x 10-8 microcuries per milliliter (30 pCi/1) of radioactive !
material, the licensee shall perfom further surveys and isotopic analysis of the water sample to detemine the.cause of the increase. Following the deter-mination of the cause of the increase, the licensee shall notify the Manager, ;
Radiation Control Branch, Kentucky Depart ent for"Brnan Resources, Frankfort, Kentucky, 40601, within forty-eight (48) hours of such findings.
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'9. The licensee ,is .2uthorized to possess and dispose of 'gaseous Tritium and -
Krypton-85 waste provided.that: .9%
(a)
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Each. primary container does not exceed 1,000 curies.
- 7 f .
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~ (b) Each primary container containing 100 curie.s but less than 1,000 l curies shall be encased in concrete with supporting auxiliary '
secondary centainer with a minimum of six (6) inches of concretc '
in every direction from any outside surface of the primary container.
The secondary container shall be positioned in the trench in a manner which will place the primary container in an upright position for final burial.
(c) Each primary container containing less than 100 curies may be ;
buried in an approved D.O.T. shipping container as received. '
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. * #ENDENT NO. 27
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(d) No container shall be buiied under this condition in which the pressure exceeds one atmosphere. ,
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- 20. Thelicenseeisauthorizedtopro'cessliquidwaste$en~eratedonsite in accordance with descriptions, designs, and procedures contained in '
Q the following documents'and/or letters; ..
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(a) Health' Physics Program associated with the operation of,the -
evaporator system as enclosed with letter signed by.B.V.',
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Roberts, . dated: December 27,.1972.
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(b) " Engineering Design of a Treatment System for Aqueous Radioactive j Waste," prepared by James H. Leonard, dated January 21,'1973, as l submitted.under cover letter signed by B.V. Roberts,. dated January 26, 1973. 'j .t 1
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Evaluation of the evaporator health' physics program of'Floyd W.
(c)
Wilcox in his letter dated February 3,1973, as submitted under cover letter signed byLB.V., Roberts, dated February 8,- 1973.
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(d) " Plan for Handling"and Disposition of. Tritium-Bearing Ground Water at .
Maxey Flits Disposal Site," prepared by-James H.~ Leonard, dated
, April 16,1973,: as submitted under cover letter; signed by B.V. l Roberts, dated April 19,;.1973. . ;.f.Sp .
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(e) ." Effluent Sampling Program an'd' Operational Limits for Radioactive Liquid Treatment System," prepared by James H. Leonard, dated July 7, 1973, as submitted under cover letter signed by B.V. Roberts, dated July 13, 1973.
(f) Procedures
~
used to defermine afGuent and effluent concentrations as submitted under cover letter signed by B.V. Roberts, dated July 16, 1973.
. (g) Details on analyses pertinent to waste treatment system operations as submitted under cover letter signed.by B.V. Roborts, dated July 20, 1973.
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Supplementary Shect' . ,
License Number ' 16-NSF-1
. AbEND.E.Yf \
NO. 27 (h)
"Perfonnance Evaluation and Specifications for Radioactive Liquid Treatment System," prepared by James H. Leonard, dated April 9, 1974, as submitted under cover letter signed by s Arvil Crase, dated May 7, 1974.
(1) " Interim Report on Evaluation of Solidification Techniques for Low i Lcyc1 Nuclear h'aste Materials," dated August,1974, as submitted under cover letter signed by James N. Neel, dated August 22, 1974 <
l (j) Sampling and Analysis Program for the Water Treatnent Facility as submitted under cover letter signed by Arvil Crase, dated ,
December 18, 1974. p. l
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- 21. The licensee is authorized to remove and store radioactive liquids generated j on site in accordance with descriptions, designs, and procedures contained in ~
the following documents and/cr letters. -
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l (a) Procedures dated November 13, 1972, signed by James L. Harvey and amended February 28, 1973, signed by B. V. Roberts. - ~
l (b) Letter sioned by B 'V. Roberts, dated July 20, 1973, providing j l
details on analy,+ses ;;je pertinent.to . .: , wnste treatment system operation.
(c) Letter signed by B[V[ Roberts, dated August '6,'1'973, regarding '
construction of the tank fann berm.
(d)' Letter signed by Arvil Crase,' dated October 30, 1974, regarding construction of an interim water storage facility.
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(P~. 3 75) 16-NSF-1 Sup@ementory Sheet License Number AMENINENT NO. 27,
- 22. The authorization for the processing o~f liquid waste generated on site -
as provided under Condition 21 shall be only in accordance with the following evaporator stack release limits: , . . . .
3 '*
.2 x 10 uCi/sec.
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SGrois'u Alpha.- 5 x.10-4 uCi/sec. ,,
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[/'GrossBeta - 2 x 10-2 uCi/sec. 3 y;.
If the gross beta or gross alpha limits specified above are exceeded for any sample, specific isotopic analysis shall be perfomed and the following for-mula utilized to determine if the maximum release rate for the, identified isotope (s) has been exceeded: ,
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R(uCi/sec.)' = MPC(uCi/ml) x (1 x 10 10 ml/sec.)* ;' ~ 4 ju 1
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h kWhbre R = Maxianum Release Rate n. Y. ) '/ /d/
.C.'i? .s D.;.
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IPC for air, 168 hour0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> week ' .NO M '
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l Should the abo d limit's be exceeded the licensee shall' take appropriate l
immediate action to reduce the stack effluent such that'these limits are not exceeded. The licensse shall maintain records relative to , l l
these stack effluent measurements and should these limits be exceeded
. the licensee shall notify the Department and shall include the action (s) l that were taken to reduce the release within these limits.
- 23. The procedures authorized under Condition 21 shall be covered.and secured in accordance with the Agreement of March 19, 1975, signed by and between C. Leslie Dawson, Secretary of the Department for Human Resources, and James N. Neel, Vice Chairman of the Board and Chief Executive Officer of the Nuclear Engineering Company, Incorporated.
- 24. The disposal of radioactive wasto is not authorized under this license when the hazard of any chemically toxic waste associated with the radioactive waste exceeds the radiological hazard. Any chemically toxic waste listed in the Irving Sax manual, " Dangerous Properties of Industrial Materials," Third Edition, Van Nostrand Reinhold Company, ,
1968,,shall be considered more hazardous than its associated radioactive material until the Department has been supplied with sufficient information
, to determine t % he radiotoxicity exceeds the chemical toxicity.
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AhENDWNr NO. 27 l
- 25. Tritium contaminated waste with a specific activity greater than 10 microcuries per milliliter will be contained in a ceramic material
- l prior to burial. .,. . ,, c ., O, '
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- 26. Notwithstanding the introductory paragraph of this l'icense, scintillation vials containing beta emitters in liquid form, when the concentration does not exceed 10 microcuries per milliliter, are authorized for burial -
when packaged in accordance with sub-section 5-F of the Rad.iological Safety Plan revised December, 1974, provided that such packages are placed in trenches such that the package integrity is not breached. I
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- 27. The licensee shall comply with the appropr$ ate regulations of the Kentucky Department for Natural Resources and Envi.ronmental Protection and the ,
. requirements.of all permits issued by that Department to the licensee. l
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- 28. Unless contraindicated by specific conditions stated in this license, j the licensee shall receive, possess, and dispose '6f radioactive materials !
in accordance with the following documents and/or letters; ,
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(a) Application' dated December" 30, 1974, signed by Arvil.Crase. .l j.Q ~. .; :.. ".
(b) " Radiological' Safety Plan'," Revised December,'1974', as -
1 submitted under cover letter signed by Arvil Crase, dated- l December 31, 1974. z; .i og g;- ' ~ . ,~,y
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(c) " Radiological Physics safety; Manual . Kentucky Facility," '
revised burch, 1975. l (d) "Geotechnical Investigation and Waste Management Studies, Nuclear Waste Disposal Site, Fleming County, Kentucky," February 6,1975, Emcon Associates, exc'epting the specific trench design which is
. superseded by the trench desir,n as specified in the " Radiological 1 Safety Plan." Prior to the construction of trenches in geological contour clevation lower than 970 feet, approval for such construction 1 shall be obtained from the Department. !
(e) Letter dated July 18, 1975, signed by Arvil Crase.
- 29. In lieu of any reference documents in support of this license, the licensee is not. authorized to solidify liquids generated on site.
_A . - An O -
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Secretari, Di' par tamnt for Human Resources Commissioner, Bureau for Hoolth Services
&tober 1, 1976 gTQG g 9.g ..g Date of hsuance Manager. Radiation Control Granch Office of Consumer Health Protection r
Ir N -
Q-Nuclear EnsincerinA Con 1pany Inc.
920o SHELOYVILLE ROAD. SUIT E G2G
- P. o. Oox 7246 LoUlsVILL E. K E NT UcKY 4o2o7 PHONE f 5o2) 42G-7tGo Oc'tober 12, 1976 s
Mr. Brian Kiernan Committee Staff Coordinator l Legislative Research Commission l State Capitol '
- l Frankfort, Kentucky 40601 1 l
Dear Mr. Kiernan:
I am in receipt of your letter dated September 20, 1976, j
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requesting information relating to NECO burial charges at our Maxey Flats f acility. As you are well aware, NECO is engaged in a very competitive business situation in that approximately l ninety (90) per cent of NECO's contracts withNaturally, its customcrs are obtained on a sealed competitive bid basis. as always, NECO wishes to cooperate with your Committee, however, some of the material you requested may be considered proprietary data and its inclusion in the public record could render NECO non-competitive "
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in its sealed bid process.
Within the parameters as discussed above, NECO shall, provide .
your Committee with the following information.
Among other re quests you-have -posed the question as to what .
.is meant by burial charge. In order to properly understand this.
charge it is necessary to relate the various aspects of our busines, operations. Although the end result of our activities is burial of the waste material received it is important to note there are other activities that are separate and distin ct in and of them-selves and thus are not directly related to burial per se. Our activities break down into three major groupings Transportation, Handling and Durial. .
Transportation as a category is self evident and hence does not warrant a detailed discussion. However, the Handling category represents a more complex area in that it'may result in. additional charges being assessed NECO's customers. These increashd costs are dictated by the type of containerization of the wastes, the weight of the waste and the degree of hazard generated by the waste to site pers,onnel.
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. Mr. Brian Kiernan October 12, 1976 Page 2 l
NECO maintains a supply of shielding devices and containers which we in turn rent or sell to our customers upon receiving their requests for same. Most shielding devices due to their nature are capable, if contaminated, of being decontaminated and thus are reusable. Their sole purpose is to ensure transportation ,
and handling safety. .
Additional charges are applicable as described later herein ;
for waste shipments that exceed NECO's weight limitations. The necessity for this charge is that different and more. costly pro-cedures must be utilized for proper unloading of the material (i.e. utilization of heavy duty cranes, end loaders.and other expensive machinery).
Finally it is necessary to understand the hazardous nature of the material being unloaded. It is a maxim of the industry that every effort be expended to protect operating site personnel l
from suffering additional occupational exposures. The more haz-ardous the individual load the more necessary it becomes to rotate available personnel and to utilize mechanical procedures to accomplish proper handling techniques. These methods entail the necessary imposition of additional fees based on the number of R/hr and the amount of curies in excess of one hundred.
The last distinct procedure is the actual burial of the waste.
As you are aware NECO has operated its.Morehead low-level
radioactive waste disposal facility since 1963. At that time NECO, with concurrence of the Commonwealth, assessed its customers a burial charge of eighty cents ($0.80) per cubic foot of waste.
Due to inflationary and normal business expenses dictated by'the economy this burial fee was subsequently increased. In the fall of 1975 the burial fee was assessed at $1.75 per cubic foot. This aforesaid charge represents NECO's current cubic foot charge for burial and includes provisions for perpetual care and maintenance accruals. The subsequent enactment of KRS 138.810 et seq. has required NECO to advise its customers of the ten cents ($0.10) per pound charge which is assessed in addition to our burial charge.
All charges, both burial and others as stated, are billed directly to the customer who has shipped the waste to the disposal' facility. NECO does not bill the trucking or transportation service for the burial fee nor any of the additional fees neces-sitated for handling and health and safety reasons.
Purcuant to your request we have attached a copy of our current price list detailing charges applicable to our Eastern sites. You should note that all the fees represented on-this
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.' Mr. Brian Kiernan i October 12, 1976 Page 3 schedule do not solely reflect burial charges but rather are also related to transport container rental and other related shielding devices. These devices are not buried and are ,
supplied to the customer upon request merely to ensure safe l transportation of the waste materials in compliance with all !
applicable laws and regulations. It should also be noted that I the attached fee schedule reflects the additional charges necessaryj to ensure safe and proper handling procedures for the more hazard- !
ous materials. ;
i Plutonium and other transuranics are not being buried at the facility and this fact is also reflected on the attached fee {
j schedule. !
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I trust that NECO's answers as set forth above will provide j your Committee with sufficient information for your needs. Should you require additional relevent information prior to your next. !
meeting, please do not hesitate to contact me.
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Yours truly, !
i NUCLEAR ENGINEERING COMPANY, INC. l
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R. Lee Armbruster !
Corporate Counsel )
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' Attachment - , . .. 2. - .
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