ML20236E327
| ML20236E327 | |
| Person / Time | |
|---|---|
| Issue date: | 07/28/1975 |
| From: | Karen Chapman NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20236E074 | List:
|
| References | |
| FOIA-87-235 SECY-75-392, NUDOCS 8707310311 | |
| Download: ML20236E327 (23) | |
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l JUL 2 81975 I6C K 7 5^_ 394 i
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Fort The Commissioners
. Thru: Executive Director for Operations (staned) La* Y C'"k i Subj ect: COMPLETION OF NRC REVIEW OF MAXEY FLATS, KENTUCKY j COM4ERCIAL WASTE BURIAL GROUND-
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- Discussion: Governor Julian M. Carroll, State of Kentucky, requested the NRC, by TWX of April 30, 1975 to Chaiman Anders, to assess the current situation at the Maxey Flats, Kentucky comercial waste burial ground, and to provkh him with our findings. . We met with representatives of the Governor's staff on May 7,1975 to discuss the nature of our review. The NRC review group which was established visited the site on June 3,1975, and met with Stato and licensee representatives on June 4 and 5,1975. Chairman Anders' letter of June 20, 1975 to Governor Carroll, confimed the action we were taking in response to the Governor's request (Reference SECY 75-232).
Enclosure A is a copy of our July 14, 1975 letter to Governor Carroll transmitting the report of the NRC review group. The report concludes there is no significant public health problem associated with release of radioactive -
material from this burial site and that the State has been
, taking appropriate action concerning implementation of the recommendations contained in the State's six-month study report. The NRC report also includes severel recom-sendations fee consideration by the State which deal principally with methods to improve water management at~
the site so as to minimize migration of radioactive material.
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I 8707310311 870728 PDR FOIA MINTON87-235 PDR ,
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- l, The Commissioners - 2- I
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t Discussion: We have also informed the State, by 1ctter dated (continued) July 14,1975, to C. Leslie Dawson, Secretary. '
Kentucky Department for Human Resources (Enclosure B), l that the NRC is not able to provide financial assistance i to conduct further studies at the site. We indicated, however, the NRC would provide continuing technical f 1 assistance to Kentucky.
1 Goverr.or Carroll Assued a press release on July. 17, 1975
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regarding the NRC report (Enclosure C). In the release, Governor Carroll indicates the NRC was responsive to his .,
request, notes the e.aiciusions of the NRC report, and l directs the Department of Human Resources to review the -i report's recommendations for implementation at the site, l i
Originel Signed by Kenneth R. Chapman Kenneth R. Chapman, Director Office of Nuclear Material f Safety and Safeguards
Enclosures:
A. Ltr to Gov. Carroll fm K.R. Chapman dtd 7/14/75 with report B. Ltr to C. Leslie Dawson fm K.R. Chapman dtd 7/14/75 C. Gov. Carroll press release dtd 7/17/75 j
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Contact:
G. Wayne Kerr
. Telephone 492-7767 7/22/75 / / /
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Mr. C. Leslie Dawson 1 The Secretary for lluman Resources i Commonwealth of Kentucky i Frankfort, Kentucky 40601
Dear Mr. Dawson:
In our June 55, 1975, response to your !!ay 13,197?,, letter, we informed {
you of our activities regarding review of the Maxey Flats low 1cyc1 l radioactive waste disposal site which included consideration of your request for financ'ial assistance to conduct further studies at the site, j While uc are able to provide continuing technical assistance to'the State, we are not abic to provide financial assistance. We believe that the information expected to be obtained from the Environmental Study Design Committee's proposed studies will be sufficiently site specific so as not to be of direct applicability to other IIRC activitics'.
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Enclosed is the report of the NRC revicu group which.uc have sent to j Governor Carroll. The report concludca that there is no significant j public health probica associated with the relcace of radioactive materini i from this burial site. It is also our conclusion that the State hcu been taking appropriate action concerning implementation of the recommendation.4 as contained.in the six-nonth study report. The report includes several recommendations for ccnoideration by the State which deal principally uith methods for improving wat,cr management at the site .so as to minimize 4
. migration of radioactive material.
Regarding the statements in your letter that the'AEC concurred in your irsuance of the license for the Ma::cy Flats burial ground in 1963, information in our files shows that uhile the AEC staff commented upon !
certain geo-hydrological aspects of the site that should be invecticoted,. > I the AEC never actually reviewed or concurred in all the information upon I which the original licensing action unc based. This was considofed' i
approtrinte since Kentucky uas an Agreement State with authority to l regulate, among of.her things, commercial burial of certain radioactive l waste in the State.
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, , . Enclosure B
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Mr. C. Leslic Dawson -2'- -
If you have any questions regarding the attached report and its recommendations, please let nie know. -
Sincerely,
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'enneth me N./ bb R. Chapman, Di;r,.,
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Office of NuclearI!6terial Safety
, and Safeguards
Enclosure:
Report of NRC Review Gro*up l
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Enclosure B en e o e me. w.e-. .. .-
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Fiom the Office of ,.overnor Julian Carroll
. Press Advisory July 17, 1975
- Governor Julian Carroll issued the following statement 5 .
today upon receipt of a report from the Nuclear Regulatory Commission Review Group.
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"In a report just received from the Federal Nuclear l I
Regulatory Commission, that agency has now fully responded to my I I
request for a prompt evaluation of the situation at the Maxey Flats i l
nuclear waste disposal site. ,
"The seven member multi-disciplinary review team from NRC has reached two important conclusions:
- 1. There is no danger associated with the release of radioactive material from this burial site. j l
- 2. Action has been taken to implement previous 1 1
recommendations which NRC has made. )
"This report thus supports the corrective action previously implemented by the Radiation Control Branch of the Bureau of Health Services. Although NRC concludes that there are no public health hazards at this site, I have instructed the Radiation Control Branch to continue to improve the site and closely monitor the situation in order to preclude and prevent the occurance of any problem whatsoever. ,
"NRC recommends several specific actions. These recommend-ations have been referred to the Department of Human Resources for implementation. I have directed the department to advise me as soon as possible concerning their plans for implementat' ion of NRC's re-c o mmen da tion s ."
Enclosure C
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8 ., UNITED STATEG l'
, . tJUCLEAH HEGULATORY CO r.1fA IS S!O N I
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i JUL 141975 l i N: i I
Honorable Julian M.. Carroll
Dear Governor Carroll:
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1 This refers to your TWX of April 30, 1975, to Chairman Anders, requesting the Nuclear Regulatory Cocmission (NRC) to assess the current situation at the Maxey Firsts, Kentucky, commercial waste burial ground, and to provide you with our findings. You may recall that tedbors of ny staff met with your representatives on May 7, 1975, to discuss the nature of the review which we would make. Chairman Anders' ictter to you of June 20, 1975, confirmed the action we were taking in response to your request. j An ERC revick gro*up was appointed consisting of staff tasbers knowledgenbic hi Agrerement State relationships, hydrology, and rcdiologieni asseeament i to conduct this review. This group revicued availabic information l
, regarding the site, the State's December 1974 project report, the report I of the State's Environmental Study Design Committee, and recent cuviron- l mental monitoring data. The revicu group visited the site on Jenc 3, 1975, and met with State end licensee officials on June 4 and 5, 1975.
Enclosed is the report of the NRC review group, which includes ccetain recommendations for the State's consideration. The report concludes that there is no significant public health problem associated uith the release of radioactive materini from this burial site. It is also our c'onclusion that the State has been taking appropriate action concerning implementation of the recommendations as contained in tbc six-month study report. The recommendations deal principally with methods for irgroviu3 water management at the site so as to minimise migration of radioactive material.
We have also received a letter dated May 13, 1975, from C. Leslic Dawson, Secretary, Department for Hum.an Resoureco, requacting both
! technical and financial assistance in the conduct of t'ic studies out-lined by the Sente's Environmental Study Design Committee. While na are able to provido technical assistance, we are not in a pnsition to provide financial assistance in this matter. Ue are sending a copy of
. our report to Mr. Dawson and will, at the same time, inform him of our I
decision regarding financial assistance.
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i Enclosure A
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, I Honorable Julian M. C.arroll I
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i If you have any questions regarding the encloced report and its l recommendations, please ict be know. {
If you think it would be helpful, j we after you have a chance to review it. or your staff to discuss the report would be pleased to mcot with you
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Sincerely, i 1
/ A Kennet~,h R .
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Q u:isnna-Director ispra Office of Nucica!an Material l
Safety and Safeguards
Enclosure:
Report of NRC Review Group e
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?A f 0 REPORT OF THE NUCLEAR REG,ULATORY C0&lISSION REVIEW GROUP REGARDING MAXEY FLATS, KENTUCKY COFEfERCIAL RADIOACTIVE WASTE BURIAL GROU D JULY 7, 1975 O
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1 Table of Contents' y .- ,
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. Page I. Introduction........................................ 1 II.- Radiological. Assessment............................. 2 III. Hydrological Assessment............................. 3 )
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IV. Re c o cune n d a t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . S Appendix A List of NRC Review Group Members........... A-1
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Appendix B Action Being Taken by the Commonwealth of Kentucky Regarding Implementation of
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Recorranendations as Set Forth in the Six- -)
Month Study Report......................... B-1 )
i Appendix C Action Being Taken by the Nuclear Engineering Company, Inc................... C-1 l
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represent actual human exposures. They are based on the j maximum levels of radioactivity observed in the environment !
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' and the most restrictive radionuclides mixture. Actual human {
doses woul'd be below these levels.
B. Atmospheric Releases The potential radiation dose from the evaporator effluent was estimated at the location of the nearest residence, about 0.5 mile north of the site. The major component of the radioactive releases, as expected, was tritium. This was calculated to provide a potential dose at the nearest residence which would not exceed 5 mrem per yeay. In addition, traces of other nuclides are known to be present of which the largest exposure is that due to Sr90 For this nuclide the calculated poten-tial bone dose would not exceed 1.5 mrem per year.
C. Conclusions i We conclude that, at the present time,' there appears to be no significant public health prob 1cm associated with the relcace of radioactive material from this burial site. The Radiation Control Branch of the Department for Human Resources of the
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Commonwealth of Kentucky has adequately evaluated the potentini effects to the public health and safety through its environ-mental monitoring program and is continuing this program in order to detect any probicas that might arise in the future.
Recommendations to be considered by the State concerning their environmental monitoring program are contained in Section IV of this report. Of special significance is the need for additional isotopic analyses of radiological sampics. These are necessary to distinguish between the natural radioactive environment and that material which is being released from the site. By doing the above, the actual potential human exposure can be better estimated. Also, the analyses can serve as bases for the measurement of radioactive material migration.
l Notwithstanding the above, the data on tritium concentrations l in the water sampled from Test Wells 11 E (located onsite but in the unrestricted arca) and 13 E (onsite and in the restricted ;
area) are sufficiently high to merit consideration of further action. This is addressed in Recommendation Mo. A.6.
III. Hydrological Assessment A. Site Description and Operations The site is on a relatively flat hilltop in north central
, Kentuchy. Most precipitatica (annual nyerage of about 47 inchec) that f alls on the site ronr off and into small strea::.s.
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to the burial ground in the accompaniment of Mr. Charles Hardin, l Manager, Rodiation Control Branch, Department for Human Resources, l Commonwealth of Kentucky. The reviw group met uith Mr. Hardin and l his staff on June 4, 1975, to revicu environmental monitoring data l generated by the State for the period since the six-month study, '
i.e., through April 8, 1975, and to. discuss the current actions being taken by the State. Appendix B revicus the actions of the State concerning implementation of the recommendations contained in the six-month study report. It is our conclusion that the State is I
taking appropriate action in impicmentation of these recommendations.
Mr. G. Wayne Kerr, Chairman of the review group, briefed members of Governor Carroll's staff on June 4 regarding the group's activities.
On June 5, 1975, the group met with MECO representatives to recc1ve their views on environmental monitoring results, operation of the 3 evaporator at the site, current operating practices and the status ]
of the water management program. Appendix C reviens the actions j being taken by the company. i l .
! Mr. Kerr diccussed the revieu group'c activities with Ms. Jachie !
Svigart, Chairperson, Kentucky Environmental Quality Commicsion on (
! June 9, 1975. Ms. Swigart had expressed the commission's concern I about the burial site in a letter dated April 21, 1975, to Go'ernor ]
Carroll.
II. Radiological Accessment As a result of the site visit and evaluation of the data available with regard to aquatic and atmospheric releases of radioactive material during FY 1975, quantitative estimates of environmental impact.as well as recommendations with respect to operation of the facility (which are discussed in Section IV), were -developed.
A. Aquatic Releases The environmental data reviewed indicate that tritium, beta-active and alpha-activo materials are being released in the hydrosphere in unrestricted areas. In our evaluation it was assumed, conservatively, that the uater wo61d be concumed by ,
man all year long at the conventional rate of 2.2 liters per day. Using the maximum concentrations identifed at certain sampling stations in the unrestricted areas, the maximum potential tritium whole body doce vas calculated to bc 15 mrem per year. For beta and alpha activity, including natural radioactivity,.the potential doses would not exceed ,
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110 mrom per year to the uhole body and 1500 urem per year to the skeleton (uning SrD0 as the limiting beta emitter and Pu?.3 9 as the limiting cipha emitter). These doscs do not a
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. l Report of Nuclear Regulatory Commission Review Group Regarding Maxey Flats, Kentucky Commercial Radioactive Waste Burial Ground i I. Introduction The commercial radioactive vaste burial ground at Mar.cy Flats, i Kentucky began operation in 1963 under a license issued by the l Commonwealth of Kentucky (Keatucky is an Agreement Statc) to Nuclear .
Engineering Co., operator of the site. The burial ground and adjacent area is owned by the Commonwealth of Kentucky. The State l and the licensee have conducted environmental monitoring programs i on and around the site since prior to start up of operations. As a result of increasing quantities,of radioactive material being disposed of at the site, State concern over water managccent at the site,.and some indications of radioactivity being contributed to the Maxey Flats site area as a result of site operations, the Stato initiated a special environmental monitoring study in November 1973.
The study covered a six-month period, ending in May 1974, and a i project report of the s.tudy was published in December 1974 The !
general conclusion of the report was that cite operations were contributing radioactivity to the environment, that the activity
, did not create a public health hazard, and there was a need to intensify monitoring activities to determine the long term signi-ficance of the findings.
As a result of the State's six-month study report, there has been public interest regarding the health and safety aspects of the
, site. Kentucky Governor Julian M. Carroll requested the NRC, by TWX of April 30, 1975, to independently assess the situation and provide him with its findings and recommendations. Covernor Carroll was informed that NRC would review recent information developed about conditions at the site, conduct a site visit and advise him of our findings. The Director, Office of Nuclear Mat'erial Safety and Safeguards appointed an NRC review group which consisted of members of the Agreements and Exports Branch t: knowledgeable in Agreement State relationships, and persons w.tth exportise in hydrology and radiological assessment from the Division of Technical Review, -
Office of Nuclear Reactor Regulation. Appendix A lists memberr of I the NRC review group.
The review group examined information regarding the site, the State license, hydro-geological information about the site, the State's December 1974 project report, and the report of the State's Environ-mental Study Desiga Committee which was established in Febr'uary 1975. On June 3, 1975, the revicu group mcde an unannounced v$ sit 1
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Precipitation that does not run off is either evaporated, consumed by vegetation or percolates into the ground. The l fraction that percolates flows at a low rate into underground I zones for eventual drainage to seeps, wells and stream channels.
The subsurface material is composed of successive layers of different shales and sandstone. 'Ihc surficial layer is clay, !
a weathered shale. Groundwater is considered to move through cracks and fiscures in the shale, j i
. Although the radioactivity detected in the offsite enviren-ment presents no significant health problem to the population
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l residing in the area, removal of water from the trenches is j necessary to minimize the , potential for the riigration .of l radioactivity. The licensee has performed a considerable j amount of work to reduce the infiltration of surface water )
into completed trenches in the older secticn of the burial l' facility. This work includes grading and improving surfaco drainage, recapping of trenches with clay, and establishing a vegetative ground cover over the capped trenches. Improved l methods are currently being used in the completion o'f newer !
trenches to minimize the infiltration of surface water into the trenches. We believe these methods are necessary to minimize the infiltration of water into completed trenches.
It is not possible to assess the complete effectiveness of these efforts at the precent time.
The State requires the licensec to remove water from open trenches and to remove liquids collecting in closed trenchen.
The licencee has established a program to pump water fron the trenches until the trenches reach n dry status as define ( in i the license. The licensee has innta11cd an evaporator system I to treat and process liquids removed from the trenches. The liquids are first pumped to a temporary liquid' storage area adjacent to the old burial area and subsequently processed ,
through the evaporator. We believe these acticas are appropriate {
in order to minimize the movement of contaminated water from j the trenches to the underlying geologic fornications. .
, The temporary ifquid waste storage area consists of steel l tanks having a total capacity of about 600,000 gallons. The storage area is surrounded by a berm or dike approximately four feet high. At the present time about 500,000 gallonc of liquid waste is ntored 'in this area. An apparent deliber.:te act by a person or p'crsons unknown last wintor resulted in the contents of one of these tanks being dumped within the berm area. Consequently, all rainf all which is colketed within the area must now be treated as radioactive liquid wante. All
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- l rainfall collected uithin the area is now being transferred to .
a newly lined pond. Loakag'e from the pond and dilution by .
- I additional rainfall is minimized by confining'the contaminated {
liquid between two impermeable ucmbranes- . There are tuo i additional onsite ponds: one io used as a non-pctahic' water '
i supply and the other is a surface drainage pond. The licensec's efforts to minimize the quantitics of water stored on cito j should be: continued. It appears that the_ probicm of migration i of radioactivity at the site can best' be controlled by further improving surface and groundwater management techniques at the site.
B. Conclusions
- Af ter visiting the site and reviewing data co11ceted by' the Commonwealth of Kentucky, the Nuclear Engineering Company and various federal agencies, we conclude that to date the vastes are being entombed at the site and in an environment containing significant amounts of groundwater. The continuous use of the' groundwater evaporator has, in our opinion, substantially reduced the offsite migration of contaminated water. Actions should be taken to improve the water nanagement program,-
minimize the need for the evaporator, and further reduce '
offsite migration of low 1cyc1 radioactive watcr. Recommended measures to accomplish these objectivas are'cet forth in l l Section IV of.this report.
l IV. Recommendations The following recommendations oddress severci methods which should be considered by the State to improve unter managenent and site
. operations. Improved water management should minimize the potential for migration of radioactivity from the burial trenches. Eache.hould be evaluated cnt a cost effective basic. The specific recommendations in A below relate to immediate improvements and should be. considered by the State for impicmentation in the near term. The general
) recommendations in B below addreno additional measurce which could '
i be considered if the water management aspects.of site operations do not improve. These should also be considered in lieu of or in conjunction uit'h the proposed studies of the Environmental ' Study Design Committee, i.e. , if conditiona at the site do not improve .
and the monitoring programs indicate increasing Icvols of environmental radioactivity, further positive actions to improve the water management program should be taken as opposed to only studying the site.'
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A. Specific Recommendations for Consideration by the State 1
- 1. The height of vegetative ground cover should be kept to a '
minimum. Long grass will hold the rainfall and give it a longer period of time to infiltrate, thus increasing the amount of groundwater. l
- 2. The density of the top surface layers of soil should be !
determined. If it is not compacted to near optimum i levels (as determined by the standard American Association of State Highway Officials compaction methods), engineering
- methods should be used to obtain maximum compaction. If an optimum surficial density cannot be obtained, the surface could be coveted with a well-compacted layer of some essentially impervious material, such as clay or soil cement.
- 3. The method of measuring water extracted from the trenches, as defined in the license, should be evaluated. Water extraction measurements could be improved by requiring the measurements to be volumetric rather than by pumping rate. Consideration should also be given to pumping trenches more frequently at a lower rate than presently specified to minimize water accumulations, contact with vaste, and potential contamination of groundwater.
- 4. The effect of the onsite non-engineered ponds on the groundwater tabic should be evaluated. These ponda should be eliminated or lined unless it can be demonstrated i that they do not significantly enhance dissolution of I radioactive materiale in the' trenches and increase the I rate of movement of contaminated groundwater.
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- 5. The program for measuring cource terms (radioactivity being released in the evaporator effluent and that present in trench water) and the environmental monitoring progrr.n being conducted by the licensec should be continued. The State'chould assess the licensee's program to be sure it i includes nuclide analysic of evaporator effluent releases, trench water and appropriate environmental media (air, water, coil, crops and other direct pathways to can). An air sampler should be placed at the nearest residence i north of the site. The monitoring program should be such that it is possibic to evaluate the environmental irepcet from all significant pathuaya cuch as breathing, driabing water, eating fish, etc. It should provide inforcazion needed to detemine whether public c::posures are within established limits and to ensure that lon; term buildur: of
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I specific radionuclides in the environment will not become l significant. The Sta'te may exercise its regulatory ,
function to ensure quality assurance and compliance'by I splitting sampics, spot checks, etc., or by carrying out )
an equivalent environmental monitoring program.
- 6. With respect to the results of tritium analyses of water samples taken from test well 11.E we believe the waste in Trench No. 31 containing about 650,000 curies of tritium is the most likely source. An assessment should be made of the feasibility of isolating this waste in place or removing and disposing of it in an appropriate manner. j Such an assessment shon1d be performed on a cost-benefit j basis incluaing consideration of any additional radiation safety problems that may be created by such measures. ;
With respect to the radioactivity data from test well 13 E, it appears that the most likely source is wacte buried in Trench No. 33 L. This trench should be brought to a dry state to determine if tritium levels in well 13 E can be reduced.
B. General Recommendations for Consideration by the State l
- 1. Measu,res could be taken to increase tbc ability to rer.:ove water from future trenches (once they are closed).
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Originally the trenches were to have a gravel drain on ;
the bottom. This practice was later discontinued because 1
.' the backfill material was apparently clogging the grovel. l Clogging could be prevented if an adequate layer of sand I was provided on top of the gravel.
- 2. Lined channels could be provided between and arcund the 1 capped trenches to speed the removal of runoff and thereby ;
decrease the time available for rainfall to infiltrate into the soil.
- 3. If the deep hydre-geological study proposed by the Environment 1 Study Design Committee is initiated, an attempt should be made to determine the extent of the parvious zone indicated by EMCON Borings 2E, 7E, 8E, 10E, and 12E. The zcna.chould be located and its leakage investigated. The zone should be grouted with a suitable slurry reatorial such as cla , , if it can be determined that the zone contributes sigE.ificantly to offsite grounducter flow. A similar technique could be used to soci c.ny other leaky zones enecuntered as a result of subsurface explorations.
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- 4. The need for the proposed mantle study would be obviated by successful red ~uctions in percolation. Subsurface explorations could 'also be used to establish whether groundwater is reaching the r.ite in the near surface .
strata by flowing from the north and northeast. Ifsit was determined that a significant amount of water is.
reaching the site in this manner, an interceptor ditch could be constructed across the north end of the site.
- 5. Consideration cou3d be given to effectively encapsu]nting
'ouried waste in an impervioun side and bottom trench liner.
Such a liner could be constructed of bentonito, hydraulic asphalt or other durabic impervious material. Because of the manner in which waste is disposed of, such a liner would have to be constructed in sections along a trench. i C. Summary .
A number of proposals for investigating the Maxey Flats site have been made. While studies for learning more about site conditions have merit, we belicye careful consideration of positive actions to reduce of fsite migration of co'ntaminated water should be considered.
If conditions at the site do not in: prove and the monitoring programs indicate increasing levels of environmental radio-activity sufficient to be of 'public health concern, contingency '
actions should be instituted. State and licensee efforts to develop a contingency plan should be continued in the event corrective action is deemed necessary based upon the results of the environmental monitoring program.
The State has requested that NRC contribute to the_ costs of the studies recommended by the Environmental Study Design Committee. The review group considered this matter from a technical standpoint and believes that the inforr.ation expected to be obtained from the recommended studies will be sufficiently site specific so as not to be of direct applienbility to other NRC activities. Therefore, the reviou group does not recommend that NRC provide financial assistance to the studies.
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APPENDIXA l
NRC REVIEW GP.0UP MEMBERS G. Wayne Kerr, Chief (Chairman) "
Agreements & Exports Branch i Division of Materials & Fuel Cycle l Facility Licensing Office of Nuclear Material Safety end Safeguards William Gammill, Chief Site Analysis Branch ,
j Division of Technical Review I Office of Nuclear Reactor Regulation j Jacob Kastner, Chief Radiological Assesstr.ent Branch '
Division of Technical Review Office of Nuclear Reactor Regulation L. G. Hulman Site Analysis Branch l
G. P. Turi Site Analysis Branch J. S. Bland Radiological Assessment Branch P. H. Lohaus -
Agreements and Exports Branch I
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APPENDIX B yr ,
1 Action Being Taken by the Cecnonuenith of Kentucky _R_egardin d eplemen-tation of Reconcendations os Set Forth in the Six Month Study Report.
j A. On January 7, 1975, the State informed the Nuclear Engineering Co.
(NECO), the site operator, of the results of the State's six-month study. Their letter stated that conclusions drawn from the study indicate the site is contributing radioactivity to the environment.
They requested NECO to notify them of the s'teps NECO is taking and future actions to be taken to assure that the site does not contribute further significant radioactivity to the environment. The NECO response consisted of. a report'of their environmental study committee.
The primary conclusions of the report are:
- 1. No long term increncing trends in environmental radioactivity are observable from NEC0's environmental monitoring data. .
I I 2. The present extensive environmental mo'nitoring program should be continued for two years after all trenches reach a dry l status.
- 3. No physical remedial actions are planned until the monitoring program nentioned in No. 2 is completed. '(NECO plans to oecide on what physical remedial actions should be taken based on an analysis of data gathered through the monitoring program.)
NECO does not fully agree with the conclusions drawn from the State's study, particularly since they believe their data, covering
, a longer period of tion than the six-conth study, shous no trends i
toward incr.cacing levels of environmental radioactivity. However, l the Company has agreed during discusufons that the State data i indicates the site is contributing small quantities of radioactivity to the offsite environment as any nucicar facility would. They believe the problem lies in how the data is interpreted, and they believe neither the State's data nor their data show any real i
potential for human exposure to persons living in the area.
I, B. The State expdnded their. Radioactive Waste Disposal Environmental l Study Design Committee to include repr'esentatives from the:
l U. S. Geological Survey i Kentucky Geological Survey *
! Nuclear Regulatory Commission
} Environr.. ental Protection Agency -
1 Energy Research and Development Administration i
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Kentucky Science and, Technology Conmission Kentucky Department for Natural Resources and Environmental
, Protection Kentucky Department for Humad Resources
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The Committee met on Febre,ary 18-20, 1975, and developed a six point program to be considered fer further studies at the site as listed tc.',ow by priority:
- 1. Deep Hydro-Geological Study '
- 2. Surface Run-Off Wateib
, 3. Mantle Study (Weathered Zone)
' s- l 4. Definition of Source Term )
- 5. Agricultural Pathwa'y
- 6. Environmental Biological Pathway ;
. The State is proceeding in the impicmentation of these studies and has requested financial assistance from several federal agencies ,
including the ERC. Presently, the EPA is conducting the Agriculturij Pathway study at no cost to the State. NECO, with sor.e. State participation, is conducting the Surface Run-Off Water study. The Departraent of Human Resources staf f has recommended t1 at the Envil w-mental Biological Pathway study be initiated. The State plans to ,
take no acqica regarding the other, studies until they roccive a i response ts their request for finais.ini acsistence frott the federal agencies. i I
1 C. The State has continued to expand its comprc'hensive environmental !
monitoring program at the site. Prior to the six-month study the l
State was campling 12 stations for water at a monthly frequency. l The prograu has:been expanded ts include 30 canpling stations which are sampled onla b'i-veckly basis. In addition, the State and :CCO have established'a split sampling program and <0rtain sampics are i
also analyzed by the EPA. The results of the ' split and tri-sampling programs are in substantial agreement. s D. The State is proceeding with amendment of NECO's license to require' ,
,..g ; improved site operating procedures, burial containment, and environ-Ts, mental monitoring by NECO. The license is. presently being rcriwed ,
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s y 4 and amended in its entirety. The primary ebanges propoced to be made in the license are:
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- 1. Improved trench construction and cotpletion including the l
placement of three sumps in each trench recessed into the trench wall to prevent shear.
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- 2. Improved method,for keeping rater off the active face of waste in the tr6nch.'
- 3. The. containment of tritium contaminated uaste in ceranic 1 material when the specific activity exceeds 10 micro:u ics 4 per milliliter and buried such that the container will not j be breeched.
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- 4. Restriction on the stack effluent from the evaporator to l reduce the contribution of radioactivity to the environment.
- 5. Continuation of water management program. The State has rene'g otiated the agreement betecen the State and 14EC0 which provides that'NECO vill sapply a security in the amount of $430,000.00 to assure that NECO carries out the water management program as speciffrd in NECO's "P)ca of Corrective Action and Schedule of Compliaoce" previously filed with the State and incorporated into NECO's license.
The money will go to the Stato if NECO fails to carry out the program. The agreement vac signed on March 19, 1975, has no expiration date, and vill not expire until all trenches reach a dry statur, ac defined by the licence.
4 E. The State has requested and has obtained the opinions of two fcc' era 2 '
agencies relating to _ the appropriateness of applying a more rcu.rict;'cc ,
criteria than the Maximum Permissible Concentrations (MPC's) as (
specified in the Kentucky Radiation Regulations to the potenttal j migration of radioactivity from nhallou land radioactive unste disposal facilities. Both EPA and NRC indicated that the philer:'phy of total containment should be. applied to the burial of radiocetitc ,
l waste and the design objective of a site should be such that all waste is retained dithin the site boundaries throughout its hc n.rdous lifetime. The NRC stated that the MPC's and "as lou as practicable" 4 l
concept are not appropriate for application to the migration of l
. radioactive vaste from a burial site except that the :9C values are appropriate in asr.essing the public health significance of the ;
radioactivity detected, i F. The Kentucky , Science and Technology Commission has appointed a tash group to study, evaluate, and determine the changes which may be needed in the perpetual care and long range maintenance progro for the site and the associated financial recronsibilitice for carrying l out the program. .
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l APPENDIX C l 1
,h' i Action Being Taken by the Nuclear Engineering Company, Inc. (l'ECO) {
Several rctions are ' listed beloa uhich NECO has taken to improve conditions' '
at the site. Several of these were initiated prior to the six month study performc0 by the State.
A. NECO appointed a three neober internal. task group to study the State's and the Company's environmental data. The Task Group 4 prepared a report which was submitted to the State in response to the State's 1/7/75 letter. (See Item A in Appendix B.)
4 B. UECO has conducted a surface run-off study. The report of their
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study is being prepared for tranr,mittal to the State. They found i several surface areas onsito which were contaminated and cicanup I work on these areas uns started in March 1975. The State partic-i, pated in a part of this study and belicves the drop in Icvcis at certain sampling stations is attributabic to the cicanup operations ;
being undertaken by NECO. I C. NECO has increaned their own environmental monitoring program to i
j
, coincide with that being conducted by the State. They are partic- i ipating in a split sanpling progran uith the State and have obtained {
better onsite laboratory instrumentation capability for sample i analyses. l D .' NECO proposed to the State tha't future burials of tritium, uhich exceed a specific activity of 10 microcuries per milliliter, be '
contained in ceramic caterial. The State plans to incorporate thin condition into the license uith the additional condition that the container be buried cuch that the container will not be breeched.
E. NECO believes all phases of the operation have improved and cited the following exampics:
- 1. New management and site operations personnel have been hired.
The operation of the site has received increased nanag: cent -
attention. Ourrterly meetings and unannounced inspect $,one of the site.and operations are conducted by t:anagement with site operations perconnel.
- 2. Improvement in the surface cator management program through better control cf surface cater run-off, grading, rescaling (capping) of existing trenches and the establishment of a ve;:ctation cover on these trenches.
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C-2 l 3 ._ The conduct of an extensive water management program to rep.ove water from the trenclies. An evaporator system has been inc:alled to reduce the radioactivity and concentrate the liquids putrped j from the t.renches.
- 4. Increased attention to site operations and the materials received from customers for burial. A new form for use by customers in reporting the material being shipped for burial K has been developed. !
l S. The conduct of hydro-geological evaluations of the site and l based on these evaluations development of a master site j development plan and a revised radiation safety plan for site operations. These involve new methods for preparing and 3 utilizing trenches, the installation of three sumps per trench l recessed into the trench wall, improved capping procedures, l and methods for keeping water off the open face of waste in the trench. I I
- 6. Twenty-four of the 42 completed trenches have ben brought to l a dry status as defined by the license.
7.. Efforto are being made to reduce: 1) the quantity of water j stored at the tank farra which subsequently is processed through I the evaporator; and 2) the nice of the tndk farm.
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. Aussbaumer -AEB R/F
'e 6WKerr Kentucky File _
) PHLohaus Non-Routine Even U i1'e) ~5 e NOT FOR PUBLIC DISCLOSURE Dec. 22, 1975 N WICE OF NON-ROUTINE EVENT INVOLVING AGREEMENT STATE AGREEMENT MATERIALS--75-05 This NMICE constitutes an early report of events occurring in an Agreement State of possible safety or public interest significance.
The information presented is as initially received without ver;fication or evaluation and is basically all that is known by Agreements and R= arts Branch staff as of 10:00 a.m. on date of this notification. IT SHOULD BE SPECIFICALLY Noir.D THAT INACOJRATE 1NIS NunCE MAY CONTAIN INFORMATION THAT LATER MA OR INCONSISTENT.
AGREEMENT STATE: Kentucky_
, FACILITY:
Maxey Plats waste burial. ground operated by NECO I
/
SUBJECT:
EPA Press Release Regarding Migration of Radioactivity On December 19, 1975 John Hollis, Deputy to William Rowe, EPA discussed with AEB 1975. staff a draft press release which is expected to be made on December / 23 The press release will state EPA's position on a paper presented by ,
Lewis Meyer, an EPA staff member at the IAEA/ERDA International Symposium o 3 Transuranium Nuclides in the Environment held 11/17-21/75 in San Francisco.
Meyer's paper was on the subject of the ~ radioactivity migration problem at j
the Maxey Plats, Kentucky commercial waste burial ground. The press release expresses EPA's concern about the use of' land burial for long half life ;
ment of regulations for land burial. radioactive materials and urges that h lieve there is a public' health hazard at Maxey Plats at present.It also state Kentucky Congressman Perkins' office (Mr. Swift) discussed the matter with press staff AEB release andisstrongly made. urged the NRC to be in Morehead, Kentucky when the on Maxey Flats, that'Maxey Flats is a State regulated operatton, Kentucky had handled all press relations. previously.
feel it necessary to be in Kentucky when the release is made.Therefore;vwe do not the licensee (NECO) offichts are aware of the proposed press release.' Kentucky and CONTACT: G. W. Kerr, N w3, 492-7767 P. H. Lohaus, 492-7767 Distribution: 4 Chairman Anders Commissioner Gilinsky Consissioner Mason Commissioner. Kennedy C. C. Kammeros , CA Commissioner Rowden g, J+ Chilk, SECY L. V. Gossick, EDO D. F. Knuth, IE B. C. Rusche, NRR J. A. Harris, PA H. K. Shapar, ELD J. D. Lafleur, Jr.,-ISP K. R. Chapman, NMSS j
omer > ...f . A, 7,,,,,,,, ,,,,,,, !
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- PHL h'ddf.hr __GWKjrr Dgigsbaumer m t urr . ..12/22/2s , ,, .12Ltps Form AEC-318 (Rev. 9-53) AECM 0240
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U. s. GOVERNMENT PRDITDic OFFICE 8970 O. 405-344 -
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