ML20235V276
| ML20235V276 | |
| Person / Time | |
|---|---|
| Issue date: | 08/29/1983 |
| From: | Nussbaumer D NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Carr R KENTUCKY, COMMONWEALTH OF |
| Shared Package | |
| ML20235U845 | List:
|
| References | |
| FOIA-87-235 NUDOCS 8707230114 | |
| Download: ML20235V276 (8) | |
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Distri!ctiom Ms. Rose Marie Carr, Economist 4. N _ _ . _ _ . _ _ _ _
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Protection Cabinet Department of Environmental Protection J Fort Boone Plaza l 18 Reilly Road l Frankfort, Kentucky 40601 '
Dear Ms. Carr:
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1 As per your request and our response of August 3,1983 attached are NRC '
concents on Task 2 of the Maxey Flats Disposal Site Decommissioning Plan. 1 Sincerely, Donald A. Nussbaumer i Assistant Director for l State Agreements Program Office of State Programs
Enclosure:
As stated a
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PLohtus LNartin MEMORANDUM FOR: Donald A. Nussbaumer Assistant Director for State Agreements Program Office of State Programs FROM: Edward F. Hawkins, Acting Chief Low-Level Waste Licensing Brar.th Division of Waste Management SUSJECT: REVIEll 0F PLAN f0R FINAL CLOSURE OF MAXEY FLATS SITE As you requested, we have reviewed the preliminary dra't copy of "A
( Program to Provide the Basis and Plan for the Decommissioning of the Maxey . Flats Shallow Land Burial Facility." The approach presented in this document seems to be generally well thought out.
The plan presented in this document should lead to an environmeatc.11y acceptable decommissioning plan. However, this document does not appear to address the p6ssibility that plans which are feasible from an engineering and long-term safety point of view may result in significant short-term releases and may be relatively expensivn;. Although the inmediate decommissioning of the site is undoubtedly des',rable, longer termed plar.s may be more cost effective even though a higher degree of maintenance would be required in the short term. Early in Task 4 of the plan, we recommend that estimated costs be reviewed tc see if funding at the desireo level will be available before they proceed with detailed construction l plans. If none of the designs are economically feasible, given the funds that will be available, they could perform anothe* iteration of Task 3 by lookina at longer termed decommissioning plans. 1 l
Longer termed decommissioning plans could include continued operation of ;
the evaporator or provisions for periodic replacement of a temporary infiltration barrier, such as the current plastic covering, in conjunction with backfilline cf areas of subsidence. When consolidation of the 3 materials in the trenches has rea::hed a point where subsidence of trench l caps is no longer a problem, a permanent infiltration barrier could then :
be constructed. Other long term plans have als6 been suggested.
Although maintenance costs in the short term would be higher, the total cost of the project could be lower.
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4 FEB 2 31993 201.6/ RAP /83/2/23 We are available to provide assistance as this project continues. You should be aware that we are in direct contact with Kentucky relative to specific technical aspects of the project. We will keep you informed of our activities. Specific connents on the draft report are attached.
If you have any futher questions, please contact me.
Original Signed Py Edward F. Hawkins, Acting Chief Low-Level Waste Licensing Branch Division of Waste Management
Enclosure:
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COMMENTS ON "A PROGRAM TO PROVIDE THE BASIS AND PLAN FOR THE DECOMMISSIONING OF THE MAXEY FLATS SHALLOW LAND BURIAL FACILITY"
- 4. Page 1 In the list of engineered features contained in the decommissioning plan " surface water clanagemer,t" should also be included. Later in the report on page 3.8 this is listed as being important. Since surface erosion could drastically affect any cever in the long term, this should be considered as a major engin;ered feature.
- 2. Page 1 On this page and thrcughout the report, the phrase
" updip ground-water flow barrier" is used. Inic should be "upgradient" instead of " updip."
- 3. Page 1 In the list of present needs, the phrase " provide permanent upgradient ground-water flow barrier" should be added.
- 4. Page 1 The list of engireered features should again include
" surface water management."
- 5. Page 1 The design drawing for the Native Soil / Bentonite option should be rodified to show a " bentonite-treated soil" instead of
" bentonite." Pure bentonite is subject to excessive cracking upon drying. It is usually applied iis a mixture with soil to minimize the probability of cracking and to keep costs low. Acceptably low permeabilities can be obtained when the bentonite is mixed with local soils or clays.
- 6. Page 1 The basis for the cost estimates shown here and on page 4-2 tare not given. Therefore, we have not been able to evaluate these numbers.
- 7. Page 1 Part of Task 3 should include evaluating the potential of radioactive releases during_ the remedial action or as a result of the remedial action.
- 8. Page 3 The section entitled " Bentonite" should be modified to show that the bentonite would be mixed wi+h native soils. It is possible that this will significantly reduce the cost estimates of using a bentonite cover.
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- 9. Page 3 On the list of characteristics we would again recommend including an effective surface water management system to minimize erosion.
- 10. Page 4 In the third paragraph of this page, it is stated that "in-situ greuting and synamic compaction both appear feasible."
Although both methods are physically possible it is questionable whether dynamic compaction of low-level waste can be achieved without l excessive short term releases or increases in the likelihood of {
future releases. Further, there is a question as to whether dynamic compaction can effectively stabilize the entire depth of i the trenches.
- 11. Page 4 The method for evaluating existing designs shows four general tcpics t'or consideration, one of which is " safety and licensing." We feel that a best to worst ranking on this tcpic 4 s
should only be done after determining that all designs to be I evaluated meet safety requirements. Additionally, safety ne6ds to be considered during the remedici action as well as after decommissioning.
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