ML20215K195
| ML20215K195 | |
| Person / Time | |
|---|---|
| Issue date: | 12/09/1977 |
| From: | Bell M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Swanberg F NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20215G205 | List: |
| References | |
| FOIA-87-235 NUDOCS 8706250251 | |
| Download: ML20215K195 (5) | |
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55BIRR DISTRIBUTION Central File NMSS r/f DEC . l'l WM r/f LLW r/f JDTHomas 1 MJBell i RDSmith MEMORANDUM FOR: Frank Swanberg, Jr., Chief MAu Health and Environmental Research Branch, RES WBivins DSchreiber FROM: Michael J. Bell, Chief HLefevre Low-Level Waste Branch PLohaus Division of Fuel Cycle and Material Safety, NMSSgile: Kentucky
SUBJECT:
COMMENTS ON THE NOVEMBER 23, 1977 MAXEY FLATS RESEARCH PROPOSAL In response to a November 29, 1977 memo from P. Reed, we have reviewed the proposal from the Kentucky Department of Human Resources (KDHR) for research on the Maxey Flats waste disposal site. 'KDHR originally submitted a proposal for research at Maxey Flats in June 1977. Our
. general connent on the November 23 proposal is that the revised proposal still lacks many of the specific details which were absent in the June 1977 proposal .- Thus, in our view, each of the tasks outlined in Section 3.0 of the proposal will require more detailed information from XnHR such that we can properly evaluate the studies. The infor-mation requested and comments on each task are given below.-
\ Task _1 - Water and Mass Balance Studies We feel that this would be a very beneficial study, but still have the following outstanding questions which KDHR should address prior to any contrast arrarg a ts.
- 1. The task description often uses the phrase " key radionuclides."
The key radionuclides should be specifically identified.
- 2. What provisions have been made to establish the background i levels for Rock Lick Creek 7 If sampling of Rock Lick Creek before the confluence with Drip Springs Hollow is to.accom-plish this, is that sampling point hydrologically isolated from the site? '
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- 3. What criteria will be used to select sediment sampling loca'-
i tions in Rock Lick Creek and-in the site surface runoff channels?
- 4. Describe the methods to be used to obtain and ' analyze sediment \
i samples.
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Frank Swanberg, Jr. Task 2 - Alternatives to the Water Hanagement Program Subtask 2.1 describes a series of tests to determine soil density, porosity, etc. The purpose of these tests is not specified; however, we assume that the intent is to evaluate methods (trench cap engineer-ing) to reduce trench wter infiltration and might better be included as a part of Task 7. Further, we question the overall validity of such tests if not conducted in situ. In any case, we feel that the results of this effort would probably be too specific to Maxey Flats to be generically applicable to our program. We suggest that KDHR ;
be asked to explain the purpose of the site tests described in '
Subtask 2.1 and how the results could be used for sites other than' Haxey Flats.
Sabtask 2.2 contains most of the elements described in Section 6, Appendix A of User Need Letter No NMSS 78-2. However, we feel that the following elements are lacking and should be added.
- 1. The present and future costs associated with the current program and the resulting dose to the public. -
- 2. The dose impact of not treating the trench leachate.
- 3. The guidelines that will be used to determine whether a method is viable from the economic and dose assessment points of view.
N Task 3 - Atmospheric Studies We feel that the results of this study could be beneficial to our program, but still have outstanding questions which KDHR should address prior to any contract arrangonents.
- 1. The air sampling study appears to reply exclusively on the NECO airborne monitors. What assurance is there that these monitors are of a type and are located such that they will obtain an c accurate sample of offsite airborne radionuclides? .
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- 2. The proposal does not explain what provisions will be taken to assure that the samples of evaperator effluent are representa-tive. This may be crucial since the process batches going into the evaporator may vary greatly as to radionuclides and activities.
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- 3. Provisions should be made for some chemical analyses of the evaporator effluent and evaporator bottoms.
Our need for this work is covered in Section 1.2 and 1.3 of Appendix B of flMSS User Need Latter No. NMSS 78-2.
Task'4 - Extended Care and Maintenance Programs The infonnation provided is far too general ~ for us to evaluate this
. study. We request that KDHR provide a more detailed description which, at the minimum, addresses the following:
- 1. Length of time for which the cost of administrative controls will be evaluated.
- 2. How does the proposed study differ from that previously conducted by Dames and Moore for the Kentucky Department of ,
Finance? ,
- 3. Will the use of the evaporator or other trench water treatment methods be considered in the costs?.
- 4. Will the study consider the use of contingency funds for the purchase of contaminated lands?
- 5. Will activities be conducted by State employees or MECO employees under contract? ,
j ..'N Task 5 - Trench Studies !
, We feel that the results of this study would be applicable to our development program but request that the following be clarified prior to funding.
! 1. What criteria will be used to select trenches for trench
- gas generation measurements?
- 2. Ilow will the trench gas generatican tests be conducted? l
- 3. What procedures will be used to assure that representative !
i trench lanchate samples are taken?- q
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., 4. Describe the techniques to be used-in analyzing the trench leachate - particularly suspended particles? -
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Our need for this work is discussed in Section 1.1, Appendix B 'of User Need Letter NMSS 78-2.
Task 6 - Subsurface Studies Subtask 6.2 deals with flow in unsaturated media which we do not i require for our program and would not recommend funding. Subtask 6.1 l and 6.3, however, are applicable to our program development and we would recommend funding after the following information is provided.
- 1. What methods will be used to assure the springs (Subtask 5.1) j are not contaminated by_ surface water 7 1
- 2. Provisions should be made for chemical analyses on some of )
the springs.
- 3. With respect to the ten proposed test wells (Subtask 6Ji), l what provisions have been made to assure that this study will not duplicate the USGS effort at Maxey Flats?
Our need for this work is discussed in Section 1.6 of Appendix B to ,
letSS User Need Letter No. l#tSS 78-2.
Task 7 - Surface Studies
[ In view of the high cost of installation and maintenance, we do not.
recommend funding research on asphalt and soil coment saalers. However, the cost of the plastic sealer may be acceptable for sites where it is installed as the trench is being covered.
1 The lOHR proposal did not specify any information as to the type of plastic, its cost or its expected durability. We request that KDHR be asked to provide this information and if these factors are favora-
! ble, we would recommend fcnding the plastic sealer experiments and the cost for the applicabla number of monitoring sumps.
i Our need for this work is discussed in Section 4 of Appendix B to ,
r 19tS$ User Need Letter No. !9tS3 78-2.
l Task 8 - Hydrological Investigation l We request that KDHR address the following such that we'can properly assess this study:
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- 1. Since the work described under Task 7 will place at least a portion of the site in an unnatural hydrological state, how can the models developed under Task 8 be used to predict water movement in the future when the site reaches a new equilibrium?
- 2. How will this task complement the ongoing USGS programs in this area?
If you have any questions concerning these coments, please contact me.
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t Michael J. Bell. Chief Low-Level Waste Branch Division of Fuel Cycle ,
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