ML20235V558
| ML20235V558 | |
| Person / Time | |
|---|---|
| Issue date: | 08/15/1983 |
| From: | Higginbotham L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Nussbaumer D NRC OFFICE OF STATE PROGRAMS (OSP) |
| Shared Package | |
| ML20235U845 | List:
|
| References | |
| FOIA-87-235 NUDOCS 8707230221 | |
| Download: ML20235V558 (4) | |
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- ,,.>u HM55 r/f 201.6/SN/83/08/12 1-WMLL r/f SNeuder PHLohaus DEMartin REBrowning J0 Bunting /WMPI MEMORANDUM FOR: Don Nussbaumer, Assistant Director Office of State Programs FROM:
Leo B. Higginbotham, Chief Low-Level Waste Licensing Branch
SUBJECT:
DECOMMISSIONING PLAN FOR MAXEY FLATS 1
i We have reviewed the draft of the Decommissioning Plan for the Maxey Flats Disposal Site, Task 1:
Performance Standards.
Our comments are enclosed.
Please contact me at 427-4433 should questions arise.
Qid SipUaW.
i Leo B. Higginbotham, Chief Low-Level Waste Licensing Branch j
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Enclosure:
l As stated l
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NAME : S.N_e_u_d_e_r_:a.j f.L.H.i g botham DATE :83/08/12
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NRC COMMENTS ON MAXEY FLATS DECOMMISSIONING PLAN 1
l (1) Page 13 item (3), " Difficulty of monitoring groundwater and
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Page 23, "... groundwater monitoring should be distressed (?)":
We believe that there should be groundwater monitoring at some new locations (as those being investigated by USGS) if not at the existing locations.
(2) Page 14, 3rd paragraph, "This indicates that the site basically affords a good confinement system...":
The fact that the health and safety of the public around the MFDS has never been endangered as a result of site operations (to date) does not prove that the site affords good confinement especially in the long run.
(3) Page 14, last line, "... separation of the wastes from atmospheric effects"...":
This statement needs to be clarified.
(4) Page 19, Performance Standard No. 4, "long-term... minimize... minor custodial care...":
These are very general terms which would need further definition and elaboration.
4 (5) Page 19, 2nd paragraph,
... stability of the disposed site...is one of the few aspects of Maxey Flats that can be tested and its long-term performance confidently predicted...":
How can this be demonstrated or even quantified?
(6) Page 20, last paragraph, "The analysis shows that over 60% of the individual trenches for which data are available..."
l How was analysis performed?
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201.6/SN/83/08/12/1 ;
(7) Page 20, 3rd paragraph, "... wastes will be stabilized..." and l
Page 24, last paragraph:
...stabiility of the disposed waste..."
The buried waste was not stabilized nor can it readily be stabilized at this time.
(8) Page 21, first two paragraphs, "In addition..."and "In view of...":
These discussions need elaboration and clarification. Some of the questions ne have are (a) " plateau" in what? (b) " relative toxicity" means what? dose equivalent? (c) why only as measured by " inhalation-lung dose factors?"
(d) the 100-year institutional controls conclusion does not follow from first I
paragraph (e) why will an intruder barrier not bring trenches into compliance with Class C concentration? etc. How were these analyses done? What is the purpose of the discussion?
Which curve is the author referring to?
(9) Page 21, 3rd paragraph,
...the site provides a good confinement system.":
This assertion has not been clearly demonstrated at all, especially-in the long-term.
(10) Page 22,1st paragraph:
What is meant by a " site-specific intrusion scenario?"
(11) Page 22. Intruder performance Standard,
... prevent a dose of 500 mrem / year.":
Why include the number 500 mrem if not enforceable nor can compliance be demonstrated after 100 years. What was the rationale for the Commonwealth of Kentucky limit of 500 mrem / year and is it applicable to the decommissioning of Maxey Flats?
(12) Page 23, 3rd paragraph, "It appears that groundwater monitoring systems are neither practical nor useful...":
Groundwater monitoring serves as an early detection system and 1
indicator of site performance.
It should be done.
(Seeitem1.)
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1 201.6/SN/83/08/12/1 (13) Page 23, 3rd paragraph:
l Why are surface water and atmospheric monitoring " essential" while groundwater monitoring is not " essential"? Does the groundwater communicate with surface waters?
I (14) Pages 25 and 21:
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A 100-year active institutional control period may not be J
sufficiently long for Maxey Flats. The rationale for the 100-year limit on institutional controls (in Part 61) was accepted based on provisions of Part 61 that combine institutional controls with I
waste form, site characteristics and site design and operations to provide assurances that potential exposures will be within acceptable limits. These provisions do not apply to Maxey Flats.
(15) Page 26, item 4:
What does the author have in mind? This statement is unclear.
Explain / elaborate.
I (16) Page ?l, 2nd paragraph:
l Does author mean trench volumes or volume of the disposed waste?
(17) Page 31, last two paragraphs:
I How was analysis performed? What are the assumptions? Tables and figures are confusing /not well defined.
(18) Pages 33-5, Trench data:
What are the units? Trench activity data to six significant figures? Where did these numbers come from?
General Comments:
1.
Final draft should be edited.
2.
Emphasis on site stability is correct.
3.
Document lacks design objectives (e.g., keep groundwater out of trenches, trench markings, record keeping, etc.).
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