ML20216B968
| ML20216B968 | |
| Person / Time | |
|---|---|
| Issue date: | 11/25/1994 |
| From: | Doda B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Cain C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20216B779 | List: |
| References | |
| FOIA-97-105 NUDOCS 9709080197 | |
| Download: ML20216B968 (12) | |
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e From: -Bob'J. Dogla
-To: CLC M dJ f(AJD)f M IW Dnto: -Fri ay, NovembrF 25, 1994 7:37 am
Subject:
Envirocare -Reply Chuck, this subject is being explored with-OGC right now. UT's request covers
-a category that is not one of the five categories presently available under NRC's policy statement for~ obtaining-agreement status. Thus, any movement in this area would require a specific exception to the policy statement.
If OGC; finds some legal mechanism to proceed and there are further meetings or actions on the subject, I will certainly keep you informed.
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1 1 AGENDA TOPICS FOR STATE OF UTAH TELECONFERENCE - NOVEMBER 28, 1994
- Atlas (PM - Allan Mullins) {. [g ,
- 1. Status of EIS
- 2. Status of Safety Evaluation Review, recent nuestions, and meeting
- 3. Other items such as county concerns and their acquisition of legal assistance
- White Mesa (PM - Charlotte Abrams) 8/ ,6
- 1. Status of Hearing
- 2. Information on DOE decision and local position on disposal
- 3. New NRC PM
- Shootaring Canyon (PM - Jim Park)
- 1. Stolen - No NRC action
- 2. Update on Plateau's inquiry to " start-up" milling operations
- Lisbon (PM - Ken Hooks) @ @f w
- 1. New I4RC PM
- Envirocare (PM - Robert Carlson)
- 1. State request for agreement state status
- 2. Any recent state inspections
- 3. Annual fees dispute letter
- 4. Update of rail car incident (!lov 16. 1994)
- 5. New NRC PM
- Other Utah topics
DEPARTMENT OF ENVIRONMENTAL QUAll1Y DIVISION OF RADIA110N CONTROL Woheel 0. tma 164 Nwei 1950 West osan= F.o.Saa144430 thanne R. Meleen. PLD, . sah take Cey. Utah 84114-4450 sasswa pew = (801) 33H130 0ffles Wahwa J. sinales rtol) $3346 Fan c e=== (801)s3H414 f.D.D.
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November 7,1994 5
Mr. Richard L Bangart Director e
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Office of State Programs Nuclear Regulatory Comrmssion 5
Washington, D.C. 20555-0001 m
Dear Mr. Bangart:
Thanx you for the opportunity to meet with you ana Paul Lohaus pner to tne Management Review Board meeting on October 7,1994. As I discussed with you m the meeung, the Division of Radiation Concol (DRC) is very interesteo in finding a mechuusm to allow us to assume pnmacy fer the uranium mill [1le.(2)] disposal acuvities at Enytrocare ci Utan. As indicated to you m the mecung, this would be assumenen of the uruuum null program en a puttal basis. It is my understanding that NRC may et construnec in grantmg a parual Agreement State status by statutory or regulatory means. I am noping tnat througn a cooperanye anc innovauve effen we can 5nd a way to wort: througn the exisung bureaucranc process to allow Utah this unique opportunity. Our *easons for wishing to assume the ile.t2',
regulatory program at Envirocare are as follows:
(1) Envirocue is already licensed by DRC for source, by.precuct. special nucieu matenal.
and naturally occurnng radioacuve matenal (NORM) wastes. Ar.;tner level of regulanon oy SRC for lle.(2) complicates an already complex regulatory scneme by the state of Utan.
Currently four Divisions within DUQ have pernuts and/or licenses at Envirocare. DRC does an effective job in coorcinatmg those acuvities among the Depanment. However, the process becomes complicated when NRC enters into the picmre. Coorcination must occur with both Headquaners and NRC Region IV. It is more difficult to adequately coordinate with parues located in Arlington, Texas and Rockvtile Marylano. It has been our expenence that coordma: ion occurs most often as a counesy after we have mace a great deal of noise regarding the need to let us know tnat NRC inspectors are commg mto our state. It is cur perception for the most part there is no real desire er need fer tnis coordinanon by certam NRC staff.
(2) Duplicative regulatory requirements ue in eff=t at Eny:rocue of Utah cue to the NRC 11e.(2) license. The Division of Water Quality (DWQ) has a groundwater protection program in effect for the low level and NORM waste areas of Envirocare and has extenced this
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proaction program tg non.radiologics at the 11e.(2) area. D$wculd like to avoid this duplicative regulatorywort wherever possible. Assumpnon of the lle.(2) program at Envirocare could resolve this groundwater regulatory duplication (which extenes to other Area: 48 well).
(3) A low level waste program is in existence that already oversights the facility, it is anticipated that existing staff would be sufficient to assume the regulatory responsibility.
DRC can provide a better inspection capability than NRC because of DRC staff being on. site at leut three to four times per week. Even thougn there has been commumcanon eerween DRC and NRC Region IV on assumption of some inspecuan responsibilities. this has not been clearly defined. DRC feels that a total assumpoon of resoonsibility including the actlity to take enforcement action is the only sensible approacn to oversighting this facility.
(4) A funding mechanism could be put into place to provide resources for DRC to oversee the Envirocare lle.(2) program. Without primacy, DRC does not have the ability to collect disposal fees from the 1le.(2) activines for oversignt costs. With primacy. DRC could cotlect fees or charge an annual fee for the program costs.
(5) Typically, DRC could provide better and faster service to Envirocare in tne lle.t2) area in terms of licenung. Additionally, licenstng acuvities such as amendment reouests would fall under DRC's public comment rule which would better inform the citizens of Utah of the lle.(2) acuvities at Envirocare in the matter they are accustomeo to with otner waste factlices in Utah. -
(6) NRC is not a signatory to the Memorancum ci Understanaing (MOC) developec between DEQ Divisions that regulate Envirocare, This MOU recogmzes DRC has pnnetoie anc comprenensive responsibility for all activities at Enytrocare anc therciare :s tne pnmary regulatory agency within Utah DEQ. As an exampie, with tne transfer of the DWQ groundwater position to DRC. :his has oeen further solidified as DRC now nas assumec El groundwater responsibilities witn the excepuon of the RCRA Mixed Waste 'tres.
In conclusion, I feel that Utah citizens are better servec havmg DRC as the ican agency ter regulation of uramum mtil acuvities at Envirocare. I would appreciate heartna your iden if and how DRC can assume entnacy for this facility. We wotud be interested in exotonng inv avenues suca as a pilot program for pamal State Agreement status. Thanx you for your consideration of this maner.
Sincerely -
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- h M b,s i am J. Sincidir/ Directer Division of Radigtion Control c:
Dianne Nielson. Executive Director. UDEQ
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O S~ ate of Uta, DEPARTMENT OF ENVIRONMENTAL QUALITY v DIVISION OF RADIATION CONTROL j Michael o. teavitt 168 North 1950 West l G'"" P.o. Box 144850 Dianne R. Nielson, I%D. Salt uke City Utah 841144850 8"" h** (801) 536-4250 voice l William J. Sinclair (801) 5334097 Fax D"" (801) 536-4414 T.D.D, l
January 10,1995 CERTIFIED MAIL RETURN RECEIPT REOUIRED Charles Judd, Vice-President of Operations l Envirocare of Utah, Inc. I 46 West Broadway, Suite,240 l Salt Lake City, Utah 84101 -
i RE: Handling of Bulk Waste in Areas Other Than the Bulk Storage Pad and The Rollover Area # UT2300249 Dear Mr. Judd On January 6,1995, during Division of Radiation Control (DRC) oversite activities at the Clive site, our inspector identified an area of concem to the DRC. Broken Arrow personnel were using-a backhoe and reaching into the rail cars on the track to breakup frozen waste in the bottom of the rail cars. This work was being done on the track between the rollover area and the bulk storage pad. The Envirocare license allows for the unloading of bulk waste in the rollover area and on the bulk storage pad. The DRC has worked diligently with Envirocare to develop procedures that insure that waste is handled at specified locations where the effect of any waste spill is negated to the greatest extent. We believe that any management or working with waste, outside the embankment, should be performed under the same requirements.
If Envirocare wishes to continue waste handling activities in areas that are not specifically
! addressed in the license, Envirocare management should meet with the DRC to discuss locations where specific waste related activities can take place and clarify the definition of what is meant by unloading, handling and management of waste, etc.,
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January 10,1995 Page 2 Should you have any questions pertain:.y . $ this metter please contact Ray Nelson at 536-4250.
UT. AH RADIA N CO- L BOARD
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(,l Wi tam J. Sinc ' , Executive Secretary _
cc: Myron Bateman, R.S., M.P.A., Health Officer / Department Director Tooele County Health Department Bob Doda, NRC Region IV
S ate o: D:ah DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF RADIATION CONTROL Mechsel O. tesvis 168 North 1950 West 0""' P.o. Bos 144150 Dianne R. Nwison, Ph D. salt the Crry, Utah 841144850 E8"" D**' (801) 53u150 Voice williarn J. sinclair (801)5334097 Fu D **'
(801) 536 4414 T.D.D.
January 23,1995 Charles Judd Envirocare of Utah, Inc 46 West Broadway, Suite 240 Salt Lake City, Utah 84101
Dear Mr Judd:
During a meeting, between the Division of Radiation Control and Envirocare staff, on January 19,1995, one item of discussion was the status of the Kerr-McGee rail car shipments that arrived several weeks ,
earlier at Envirocare with free standing liquid (water). During the discussion it became evident that'tifc7 Mr. Vemi Andrews was not aware of this incident. To be cenain that this was the case, Dane Finerfmck specifically asked Mr. Andrews if he was aware of the incident. Mr. Andrews indicated he was not infonned of the situation. As the Corporate Radlation Safety Officer, Mr. Andrews is the key individual for additssing all radiation safety issues including those involving transpor% tion of wastes to the facility.
There is an expectation by this agency that the Corporate Radiation Safety Officer should be notified of the incident and actively involved in discovery of the causes and fimal resolution.
In consideration of the circumstances, we are concemed about the lack of intemal communication conccming radiation safety matters. Altnough the wastes involved were 1Ic.(2) byrmduct material and outside of the Divisions regulatory responsibility, we view this as a generic pmblem that should be resolved by Envirocare. Therefore, within 15 working days we request that you provide the Division with a written report identifying the factor: which may have led to the problem and corrective steps to be taken to prevent recurrence.
FOR THE RADIAT N CONTROL BOARD
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O William J. Sinclair. E ccutive Secretary . #S C' . p#.p>y cc: Robert Doda, NRC Region IV Veme Andrews, Envimcare of Utah, Inc.
Myron Bateman, R.S., M.P.A., Health Officer / Department Director Tooele County Health Department
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DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF RADIATION CONTROL Mxhael O. teann 168 Nonh 1950 West 0"'*" P.O. Box 144150 D6 anne R. Nielson. Iit.D. Sah take Cny, Utah 841144850 h"* Da5* (801) 5364250 voice Wabam J. sinclair (801) 533-4097 Fat D'***
(801) 536-4414 T.D.D.
January 24,1995 Mr. Charles Judd, Vice President Envirocare of Utah, Inc.
46 West Broadway, Suite 240 Salt Lake City, Utah 84101 Re: 1994 Trust Submissions dated, October 4,1994, and December 9.1994, Radioactive Material License No UT 2300249
Dear Mr. Judd:
The Division of Radiation Control has completed its review of Envirocare's 1994 Trust submission including the updated submissions of December 9,1994. The DRC has concluded that $4,158,790 amount proposed by Envirocare is adequate to fund closure and long term monitoring requirements. Should you have any questions pertaining to this matter please contact Ray Nelson at 536-4250.
FOR THE UTAH RAD (ATION CONTROL BOARD ,
William J. Sinct ir xecutive Secretary c: Otis Willoughby, Division of Solid Hazardous / Waste Roben Doda, NRC Region IV Myron Bateman, R.S., M.P.A., Health Officer / Department Director Tooele County Health Department 0
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Suaoe or, .l. aa DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF RADIATION CONTROL Micteel O. travia 168 North 1950 West
- P.o.Ikn 144t$0 Dianne R. Nielson, Ph.D. i salt t>4e City. thah 84114-4850 E"" D"8* (101) $3M250 voice Waliam J. sinclair (801) 5334097 Fan D"'" (801) 536-4414 T D.D.
February 24,1995 CERTIFIED MAIL RETURN RECEFF REOUIRED Charles Judd, Executive Vice-President Envirocare of Utah, Inc.
46 West Broadway, Suite 240 Salt Lake City, Utah 84101 RE: "As Built" Drawing Submission Radioactive Material License No. UT 2300249
Dear Mr. Judd:
During the meeting on February 9,1995, a concem related to the "As Built Drawing Submission", required by Radioactive Material License Condition 36, was discussed. The latest submission by Envirocare was found to be lacking essential detail. It appears that clarification of what the Division of Radiation Control (DRC) expects to be included in the "As Built" submission needs to be provided. This letter is intended to provide that clarification.
Radioactive Material License # UT 2300249, License Condition 36 states, "The licensee shall provide "as built drawings" of the facility, at intervals not to exceed six (6) months. Drawings shall be submitted by February I and August 1 of each year. The drawings shall show conditions on the site as they existed no earlier than thirty (30) days prior to the submittal of the drawings to the Division of Radiation Control. 'lle drawings shall be certified by a Utah Licensed Land Surveyor or Professional Engineer. Drawings submitted as, "as built drawings" will be marked as such, and will be marked in the same place on each drawing. Record drawings showing approved future designs, final or finished conditions at the site may be included in the "as built drawings", but shall be marked as " record drawings"." It is intended that the "as built" drawing submissions be as complete as possible and represent a snap shot in time that documents current conditions at the Clive Facility. The last set of drawings submitted to satisfy License Condition 36 provide details of the disposal cell only. Furthermore, drawings that had been submitted in the past were deleted. The deleted drawings addressed conditions of the site for all areas outside of the disposal cell area, au 1 blM@d C0 reCy(100 [Alfe*
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February 24,1995 Page 2 The DRC recognized that redrafting drawings twice a year was a lot of work and proposed a change in the license condition. The following summarizes the proposal:
o two "as built drawing" submissions per year will "ill be required.
the February I submission will be a complete set of "as built drawings" that reflect all changes that have taken place on the entire site for previous year up to 30 days prior to the submission,-
o the August 1 submission will update drawings that show conditions in the disposal cell and will address any mal 0I changes in areas of the site that have not bcen addressed in drawings or plans submitted as part of other licensing review activities, o
"as built" submissions will provide an index of all drawings needed to document I conditions for the entire facility, the index will identify the drawings by title, identification number and revision date for each drawing.
The DRC has determined that the current submission of "as built drawings" is deficient. Please provide drawings for the entire site, within 30 days, showing conditions as they exist at this timec The DRC will evaluate Envirocare compliance with License Condition 36 upon receipt and inspection of drawings provided at that time. Should you have any questions pertaining to this matter please contact Ray Nelson at $33-4250, FOR THE UTAH RADIATION CONTROL BOARD k- . -
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'illiam J Sinclai xecutive Secretary cc: Myron Bateman, R.S., M.P.A., Health Officer / Department Director Tooele County Health Department -
Robert Doda, NRC Region IV
ENVIROCARE or umusc. -
THE SAFE ALTERNATIVE March 13,1995 _ ._.__ _ _
Mr. Joseph J. Ilolonich, Chief liigh-Level Waste and Uranium Recovery Projects Branch United States Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Annual Report License No. SMC-1559
Dear Mr. Holonich:
Envirocare of Utah, Inc. ("Envirocare") hereby notifies the Nuclear Regulatory Commission (the "NRC") that the annual report required pursuant to License Condition 12.6 was not completed and submitted to the NRC by March 1,1995. The reason for the delay is due to the fact that Envirocare has not received analytical results from its outside laboratory for environmental sampling results. Envirocare expects to have these results prior to April 1,1995, and anticipates being able to submit the annual report to the NRC on or about April 3,1995. Envirocare will request an an endment to the license, to formally change the date of the annual report to April 1 of each year due to the delay associated with analytical reporting and to be consistent with Envirocare's state reporting requirements. This request will be made by separate letter.
Envirocare requests that the NRC extend the time for Envirocare to file its annua'. report to April 3,1995. If you have any questions regarding this matter, please contact George Hellstrom at (80l) 532-0920.
Sincerely, [ Y
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' George W. lie Istrom Envirocare of Utah, Inc.
Enclosure cc: Robert Carlson t'RC Region IV Utah Division of Radiation Control 46 It' CST BRO:tDilblY
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,; S: ate oT;ah DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF RADIATION CONTROL Micieel O. lesvin 168 Nctih 1950 West O*'"' P.O. Boa 144850 1 Dianne R. Nielson. ISD. salt take City, Utah 54114-4850 8:==w D"*"
(801) 5364250 voice Williarn J. sinclair (801) 533 4097 Fat D'** (801) 536 4414 T.D D.
May 9,1995 Mr. Charles Judd Executive Vice President Envirocare of Utah, Inc.
46 West Broadway, Suite 240 Salt Lake City, Utah 84101
SUBJECT:
"As Built" Submission / Rewrite of License Condition 36, Radioactive Material License Number UT 2300249
Dear Mr. Judd:
In an effort to alleviate some problems that were identified during the last "As Built" drawing submission, the Division of Radiation Control (DRC) has decided to rewrite Envirocare's Radioactive Material License Condition 36. Several meetings were held with members of your staff to determine what could be done to resolve the identified problems. The DRC believes the following license condition change will resolve these problems and clarify what DRC expects from Envirocare. Please review the changes as shown below.
EXISTING LICENSE CONDITION 36 The licensee shall provide "as-built drawings" of the facility, at intervals not to exceed six (6) months. Drawings shall be submitted by February 1 and August 1 of each year.
The drawings shall show conditions on the site as they existed no earlier than thirty (30) days prior to the submittal of the drawings ta the Division of Radiation Control. The drawings shall be certified by a Utah Licensed Land Surveyor or Professional Engineer.
Drawings submitted as, "as-built drawings" will be marked as such, and will be marked in the same place on each drawing. Record drawings showing approved future designs, final or finished conditions at the site may be included in the "as-built drawings", but shall be marked as " record drawings."
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4-n Envirocare of Utah,Inc,-
May 9,1995 Page 2 -
PROPOSED LICENSE CONDITION 36 -
A. The licensee shall provide a comprehensive set of drawings for the entim Clive site. The drawings shall: (1) locate all structures, utilities, fences, ponds, drainage features, railroad tracks, roads, storage facilities, loading and off loading facilities, disposal embankments, l all environmental monitoring locations including instruments / devices, and any-other al purtenants related to the operadon, maintenance and closure of the disposal facility;
(', j provide structural details including site elevation. A directory shall be included that
' identifies drawings by discrete number, title, date and revision, ne drawings shall be updated no later than February 1 of each-year. The drawings shall indicate as built condidons as they existed no earlier thaw 30 days prior to the submittal. Drawings of finished construction shall be marked as "As Built." Drawings showing approved future designs, shall be marked as " Record Drawings." All drawings shall be certified by a Utah Licensed Surveyor or Professional Engineer.
B. ' Within 30 days of the completion of any project that requires approval of the DRC, a set of "As-Built" drawings shall be submitted for review and inclusion into the comprehensive drawing set.
The change of License Condition 36 will be included in the upcoming License Amendment request proposed by Envirocare relative to lowering waste concentration limits for several nuclides already included in the license.
Should you have any questions pertaining to this matter please contact, Woody Campbell at 536-4250 by May 15,1995.
- Sincerely, Willi J. Sinclair, irector Divisi n of Radiation Control cc: Steve Peterson, Envirocam of Utah, Inc.
Vernon Andrews, Envirocare of Utah Inc.
Myron Bateman, R.S., M.P.A., Health Officer / Department Director Tooele County Health Department Robert Doda, NRC Region IV .
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W 9-ENVIROCARE vv unu:.w A Tile SAFE.\LTERNATlW f~ ggg hlay 17.1995 - - . . _
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hir. Joseph J. Ilotonich, Chief liigh Level Waste and Uranium Recovery Projects Branch United States Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Notification of Exceeded Background Concentration Arsenic, GW-57 Compliance Well I.icense No. Sh1C-1559
Dear h1r. Ilolonich:
linvirocare of Utah, Inc. ('linvirocare") hereby notifies the Nuclear Regulatory Commission (the "NitC1 pursuant to I.iceme Condition 12.2 that the background concentration tor arsenic for GW-57 was eseceded for the January 1995 sampling event. linvirocare has confirmed that the background concentration was exceeded by resampling the well pursuant to 1.icense Condition i1.1. The sampling esents are summarized as follows:
Background Standard 0.026 mg/l January 1995 0.031 mg/l Resample 0.029 mg/l linvirocare is required to notify the NRC by telephone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after confirming that the standard was esceeded, linvirocare received final results from its contract laboratory of on hlay
- 17. 1945. confirming the value of 0.029 mg/l for arsenic for GW-57 The NRC was notified Ntay 17.1995, by telephone.
The well was initially sampled on January 26. 1995, the results were transmitted to Emirocare hlarch 17. 1995, and the well was resampled on N1 arch 20.1995. The initial results from the resample event were available mid April 1995. Envirocare requested that the sample be reanalyzed, since the result was very tiear the background standard. The reanalysis was received by Envirocare on hlay 17. 1995. The well was sampled in April as part of the regular quarterly sampling program. These results will be reviewed before Em irocare proposes a course et action to be taken with this well.
Pursuant to License Condition 11.1, Envirocare is required to establish and submit for NRC approval within 30 days from receipt of the analysis results a compliance monitoring plan and site specific concentration standards for the detected constituent, arsenic. Envirocare will submit the conmliance monitoring plan within such time period.
Envirocare believes that these results are still consistent with background concentrations in the area. This well is located over 1.000 feet from the disposal area and between two wells uith I
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- 9NVIROCARR Joseph J, llolonich May 17,1995 Page 2 significantly higher background concentrations for arsenic (0,059 mg/l for GW-27 and 0.078 mg/l for GW 28). Additionally, the arsenic concentration in the waste received has generally been less than 5 ppm TCl.P. Therefore, the probability of the increased arsenic level being attributable to waste operations is very remote.
It-you have any questions regarding this matter, please contact George llelistrom at (801) 532-0920.
Sincerely.
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George W. llelistrom linvirocare of Utah, Inc.
linclosure cc: llobert Carlson NitC llegion IV l'tah Division of lladiation Control
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