ML20236M358
| ML20236M358 | |
| Person / Time | |
|---|---|
| Issue date: | 08/16/1983 |
| From: | Nussbaumer D NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Carr R KENTUCKY, COMMONWEALTH OF |
| Shared Package | |
| ML20236E585 | List:
|
| References | |
| FOIA-87-235 NUDOCS 8708110033 | |
| Download: ML20236M358 (4) | |
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Ref: SA/JFK gGM6 ION Ms. Rose Marie Carr, Economist Conrnonwealth of Kentucky Natural Resources and Environmental Protection Cabinet Department of Environmental Protection Fort Boone Plaza 18 Reilly Road Frankfort, Kentucky 40601 l
Dear Hs. Carr:
I As per your request and our response of August 3,1983 attached are NRC cocinents on Task I of the Maxey Flats Disposal Site Decocinissioning Plan.
Sincerely, Donald A. Hussbaumer Assistant Director for State Agreements Program Office of State Programs
Enclosure:
As stated i
l Distri tution:
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k NRC COMMENTS ON MAXEY FLATS DECOMMISSIONING PLAN 1.
Page 3,1st paragraph, Suggest replacement of the word " equivalent" with compatible or more stringent.
2.
Page 6, item 2.1, Suggest a rewrite of this paragraph so as to be more correct in stating the NRC position. The following wording may be considered. Pursuant to the Energy Reorganization Act of 1974'(Public Law 93-438) the NRC was established as the primary licensing and regulatory body for nuclear materials, including licensing of waste disposal facilities. Under a Section 274b agreement, the NRC may relinquish its authority and a State may assert its authority if the State has a program compatible with NRC and adequate to protect public health and safety. The Commonwealth of Kentucky is one of the Agreement States which has assumed this responsibility. Regarding. existing low level waste sites it should be noted that Part 61 states that applicability of the requirements in 10 CFR 61 to Commission licenses for waste disposal. facilities' in effect on January 26, 1983 will be determined on a case-by-case basis and implemented through terms and conditions of the license or by orders issued by the Commission.
3.
Page 13 item (3), " Difficulty of monitoring groundwater and 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 1
existing locations.
1 4
Page 14, 3rd paragraph, "This indicates that the site basically affords a good confinement system...":
The statement that there are indications that the site basically affords a good confinement system is questionable and should be supported.
5.
Page 14, last line, "... separation of the wastes from atmospheric effects"...":
This statem'ent'needs to be clarified.
6.
Page 19, Performance Standard No. 4, "long-term... minimize...
minor custodial care...":
These are very general te7s which would need further definition and elaboration.
7.
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...":
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i How can this be demonstrated or even quantified?
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b 8.
Page 20, last paragraph, "The analysis shows that over 60% of the individual trenches for which data are available..."
To make the information understandable show the calculations and assumptions where the referenced data was used to arrive at "60%".
Perhaps this could be presented in the appendix.
1 9.
Page 20, 3rd paragraph, "... wastes will be stabilized..." and
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Page 24, last paragraph:
... stability of the disposed
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waste..."
The buried waste was not stabilized nor can it readily be stabilized at this time.
- 10. Page 21, first two paragraphs, "In addition..."and "In view of...":
These discussions need elaboration and clarification. Some of the questions we have are (a) " plateau" in what? (b) " relative a
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 paragraph (e) why i
will an intruder barrier not bring trenches into compliance with j
Class C concentration? etc. How were these analyses done? What is the purpose of the discussion? Which curve is the author referring to?
- 11. 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.
)
- 12. Page 22, 1st paragraph:
What is meant by a site-specific intrusion scenario?"
- 13. 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?
- 14. Page 23, 3rd paragraph, "It appears that groundwater monitoring systems are neither practical nor useful...":
Groundwater monitoring serves as an early detection system and indicator of site performance.
It should be done. (See item 3.)
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- 15. Page 23, 3rd paragraph:
Why are surface water and atmospheric monitoring " essential" while groundwater monitoring is not " essential"? Does the groundwater communicate with surface waters?
' 16. Pages 25 and 21:
A 100-year active institutional control period may not be 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 waste form, site characteristics and site design and operations to provide assurances that potential exposures will be within acceptable limits.
- 17. Page 26, item 4:
What does the author have in mind? This statement is unclear.
Explain / elaborate.
- 18. Page 31, 2nd paragraph:
l Does author mean trench volumes or volume of the disposed waste?
- 19. Page 31, las~t two paragraphs:
How was analysis performed? What are the assumptions? Tables and figures are_ confusing /not well defined.
- 20. Pages 33-5, Trench data:
What are the units? Trench activity data to six significant l
figures? Where did these numbers come from?
L 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.).
J 4
In many places we find the document difficult to understand or not clear as to what the report is trying to say. As written we believe the document would be difficult for the public and legislation to understand.
5.
Careful consideration should be given if the State wishes to use 10 CFR Part 61 standards and whether the objectives of Part 61 are feasible with resources available to the State.
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