ML20236M406
| ML20236M406 | |
| Person / Time | |
|---|---|
| Issue date: | 09/06/1983 |
| From: | Nussbaumer D NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Hughes D KENTUCKY, COMMONWEALTH OF |
| Shared Package | |
| ML20236E585 | List:
|
| References | |
| FOIA-87-235 NUDOCS 8708110053 | |
| Download: ML20236M406 (1) | |
Text
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Ref: SA/JFK SEP 6 1983 i
Mr. Donald R. Hughes Supervisor Radiation Control Section Department for Human Resources 275 East Main Street Frankfort, Kentucky 40621
Dear Mr. Hughes:
' As per your phone conversation of August 31, 1983 with Mr. Kendig of rqy staff attached are NRC coments on task 1 and 2 of the Maxey Flats i
Disposal Site Decommissioning Plan.
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Sincerely, Oricinal Signed by l
H5 anal'd kEiiuksEumer Assistant Director for l
State Agreements Program Office'of State Programs
Enclosures:
As stated
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Ms. Rose Marie Carr, Economist Commonwealth of Kentucky Ne.tural Resources and Environraental Protection Cabinet Depcrtrc,ent of Environmental Protection Fort Boone Plaza 15 Reilly Road i
Frankfort, Kentucky 40601 k
Dear Ms. Carr:
Asperyourrecuestandourresponseofhugust3,1983attachedareNRC l
1 of the Maxey Flats Disposal Site Decouaissioning cor.nents on Tat i Plan.
f Sincerely, i
1 Donald A. Nussbaumer Assistant Director for i
State Agreencrts Program Office of State Prograr.;s Er.cl esure:
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.NRC COMMENTS ON MAXEY FLATS DECOMMISSIONING PLAN l
1.
Page 3, lst 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-d more correct in stating the NRC position. The following wording-may be considered.- Pursuant to the Energy ReorganizationAct of 1974 (Public Law 93-438) the NRC was established as.the. primary
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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 a. applicability of the requirements in 10 CFR 61' to. Commission licenses for waste disposal. facilities in effect on' January 26, 1983 will be determined ori 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 existing locations.
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.
S.
Page 14, last line, "... separation of the wastes from atmospheric effects"...":
This statement needs to be clarified.
6.
Page 19, Performance Standard No. 4, "long-term... minimize...
minor custodial care...":
These are very general terms 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...":
l How can this be demonstrated or even quantified?
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2 8.
Page 20, last paragraph, "The analysis shows that over 60% of the individual trenches for which data are available..."
l 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.
9.
Page 20, 3rd paragraph, "... wastes will be stabilized..." and Page 24, last paragraph:
... stability *of the disposed 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 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 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?
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 comunicate 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:
j What does the author have in mind? " This statement is unclear.
Explain / elaborate.
18.
Page 31, 2nd paragraph:
Does author mean trench volumes or volume of the disposed waste?
19.
Page 31, last two paragraphs:
How was analysis performed? What are the assumptions? Tables and figures are confusing /not well defined.
i 20.
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 's correct 1
3.
Document lacks design objectives (e.g., keep groundwater out j
of trenches, trench markings, record keeping, etc.).
l 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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.Ms. Rose _ l'iarie. Carr, Economist j_
Commonwealth of' Kentucky
. Natural. Resources and Environmental Protection Cabinet L Department of Environmental Protection Fort Boone Plaza 18 Reilly Road Frankfort, Kentucky 40601
Dear Ms. Carr:
' As per your recuest and our response of August 3,1983 attached are i;RC coments 'on Task 2 of the Maxey Flats Disposal Site Decocriissionir:g-Plan.
Sincerely, Donald A. Nussbaumer Assistant Director for State Agreements Program Office of State Prograns 1
Er. closure:
As stated i
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AUG 2 91983 F
SPECIFIC COMMENTS ON MAXEY FLATS PLAN l'.
Page 2, 2nd paragraph:
Commissioner Teimf identified five tasks
. (July'19,1983 letter).
This paragraph identifies 7 tasks.
j 2.
Page 3, top line:
What criteria were established to determine the appropriateness and applicability. of the alternatives? These criteria should be listed or referenced early in the document.
- 3. _ Page 7, throughout:
Name of rock unit should be Nancy M_ ember.
4.
Page 10, last line:
Meaning of "(4)" in that'line?
5.
Page 10-11, Site History discussion:. Waste disposal operations were much less orderly.than that implied in this section.
The trenches were haphazardly dug. - The boundaries and outlines of several trenches are not known.
Some trench floors looked like "rollercoasters" and " zig-zagged."
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. Trenches were placed close together so that the intervening wall would sluff off, exposing waste in the next trench.
6.
Page 11 arid Page 25, 3rd paragraphs:
These paragraphs do not agree as to the depth,of the trench cover (more than three feet compared with less than 45 cm of soil).
7.
Page 12, Bathtub Effect discussion:
This effect is not present in l
all trenches.
- 8. 'Page 13, center paragraph:
Should it be stated as'follows: "This situation occurred where a sandstone lens'was exposed in the side of the
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trench. Water which had accumulated moved into the trench..."?
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9.
Page 13, center paragraph: The assumption underlying this section is 1
J that since significant migration has not been detected, it is not occurring.
This need not be the case in view of the difficulty in monitoring the site.
10.
Page 14, 1st paragraph:
We agree that given the present system "it is difficult to implement a (water) monitoring program which will give adequate assurance that if any significant migration should occur, it is observed."
We believe that there are other alternatives.
For example,
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AUG 2 91983 201.6/SN/83/08/26/ ENCL /1 (a) Plants seek water. With impermeable strata which are fractured, trees could serve as a very inexpensive monitoring system.
(b) The USGS has several wells located along the hillside slopes which may prove to be reliable indicator sites for contaminant migration.
(c) An array of porous cups may prove to be an inexpensive but reliable monitoring system.
Of course, H the Positive Trench Drainage alternative was adopted, a reliable water monitoring program would be feasible.
11.
Page 15, Table 2-2:
This table could be moved into the appendix.
12.
Page 23, 1st paragraph:
With regard to sealing the site with PCV sheeting, it should be noted that with the plastic in place, the trench did not drain.
Once pumped and drained, the trench stayed " dry."
One l
would conclude that the ground water flow is extremely slow.
13.
Page 24, Hydrological Evaluations discussion:
This discussion needs to have references cited.
Al'so, reference any work on " attempts to fit the site to hydrological models..."
14.
Page 25, top three lines:
References needed here on " Studies by NRC, EPA and other investigators have concluded that there is no significant public health problenF..."
15.
Page 25-6, Environmental Monitoring:
References needed here, too.
16.
Page 26, Missing Paragraph:
It seems that there should be a
. paragraph added at bottom of p. 26 entitled " Engineering Evaluation and Designs," in order to conform with list on page 14.
l 17.
Page 40, Deep Compaction discussion:
Although the benefits of l
dynamic compaction are discussed quite thoroughly, the possible disadvantages are not mentioned.
These include: (a) the destruction of protective packages - this would be of particular concern with liquid wastes or the highly mobile. large inventory of tritium - especially if the Positive Trench Drainage system was adopted, (b) the rendering of nearly all radioactive materials available for transport, and (c) a possible short-term rise in the water table leading to additional leaching.
18.
Page 40, Piles discussion:
Again, the authors do not mention possible cisaovantages sucn as the likely destruction of protective waste packaging and the possible fracturing of bedrock beneath the trenches.
Fracturing may provide new drainage pathways for leachate and therefore
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. be incompatible with a positive trench drainage system.
i.e., drainage flows into the fracture rather than into the trench drain.
What about direct radiation hazard to workers if piles are removed?
- 19. Page 42, top paragraph:
The reduction of drainage from the trench (by grouting) is also a positive characteristic of any other method of I
waste stabilization.
20.
Page 41-42 Grouting discussion:
It seems that the authors emphasize j
the negative aspects of this mode of stabilization as opposed to, say, the emphasis on the positive aspects of Deep Compaction (page 40) or of Positive Trench Drainage (page 49-50) 21.
Page 42, Explosives discussion:
Coments made with respect to Piles l
l (comment 18) apply to this paragraph as well.
22.
Page 44, 2nd paragraph:
It need not be necessarily true that a raised structure over the site be impractical because of substantial i
maintenance.
Consider, for example, pressure treated lumber and corrugated steel roofing which could provide a low-cost, virtually maintenance-free system for at least 50 years.
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23.
Page 44, 3rd paragraph:
" Intensive" perpetual care and maintenance may not be necessary to correct site deficiencies as they appear. This l
would depend on the final site configuration / stabilization.
See our General Coment No. 5 regarding a stabilization alternative not addressed by the authors.
If a similar syst~em was adopted, maintenance may then be minimal.
24.
Page 45, 3rd paragraph:
One reviewer quest'ioned the assertion regaroing the " difficulty" in assessing the effectiveness of particular trench covers in preventing the bathtub effect.
25.
Page 45, last paragraph:
Complicated trench cap designs may prove unreliable.
Moreover, a trench cap itself is not effective without trench stability.
That is, trench structural stability is mcst important in avoiding the bathtub effect.
26.
Page 46, Plastic Sheeting:
Sheeting is a disadvantage in that it requires constant maintenance.
Also, reference / explain " Burial of membranes with soil generally enhances their performance."
l 201.6/SN/83/08/26/ ENCL /1 AUG 2 3 363 27.
Page 46,1st paragraphi While it may be true that "a multi-layer s
trench cover can be effective in achieving all of these objectives" (for controlling infiltration) it would not accommodate the collapse of large voids.
Some means of structural stability must be provided.
The University of Arizona is investigating this question. -See Volume 2, paper by Nowatasky and McCray (page 186).
28.
Page 47, 2nd Paragraph:
Regarding the use of bentonite or smectite group of clay minerals, work at Los Alamos (see Hakonson) pointed out problems in using the bentonite.
Kentucky has local sources of some very plastic clayey shales which should do a good job.
The Estill shale member of the Crab Orchard Formation is one source.
29.
Page 47, 3rd paragraph:
Elaborate on " multiple layers alternat'.ve with gravel.."
30.
Page 48, Coarse Gravel Layer:
This heading should not be underTined.
31.
Page 49-50, Positive Trench Drainage discussion:
It is obvious to the reviewers that this is one of the options favorer 'y the authors since there are many positive st&tements but no drawbacks listed.
Possible problems with this option which must be addressed include: (a)
Providing a pathway for non-sorbing radionuclides transport to the environment, especially tritium, in view of the high inventory in the trenches, (b) Trenches may drain into the fractures'beneath tne trenches rather than be captured by this kfhd of drainage system, and (c) The low permeability (1-10 ft/yr) may not result in significant drainage capability.
32.
Page 50, 1st paragrach:
What happens to any radioactive materials and non-soroed effluents? Also, drainage effluent should be collected and analyzed prior to release.
33.
Page 51, last four lines:
Regarding the appropriateness of constructing a grouno water flow barrier to prevent the movement of any off-site groundwater into the waste disposal area, there are several lines of evidence that there was little ground water flow at Maxey Flats.
Interviews with older workers pointed out that trenches were bone dry when first excavated.
Recent installation of lysimeters at the northwest corner of the site bears this out.
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Page 54, top two lines:
What animals burrow at Maxey Flats?
Is this of substantial magnitude to be of concern?
Note that coarse gravel and cobbles for a bio-intrusion barrier will be hard to find locally and that the most comon local cobb1r "'mestone) would not be desirable.
35.
Page 56, missing items (2):
Should one also include in the list functionality, ease of implementation, cost-effectiveness', etc.?
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36.
Page 58, Table 6-1:
Missing from this table of alternatives is the Positive Trench Drainage technique.
Also, what about other kinds of raised covers (under " Infiltration Barriers") such as corrugated l
aluminum? How were these screening characteristics judged? Why, for example, is feasibility of a concrete cap judged to be " poor"? With what "Scandards" are the alternatives judged to be.in " compliance"?
(Third columninTable).
37.
Page 60, Alternative 2-B:
Has a tile covering over the site been considered as an alternative? This method was discussed at the August 3, 1983 DOE Headquarters Workshop.
This has the disadvantage however of requiring continuing maintenance.
38.
Page 60, Alternative 2-B:
What does the coarse cover layer refer to?
Is it for wicking or, erosion retardation?
If'it is not the wick system it should be listed as an option.
39.
Page 61, Alternate 3-A:
" " Retard the migration of radionuclides" should be "...of some radionuclides" since s.ome radionuclides, such as H-3, will not be slowed.
40.
Page 62:
Is this page missing or blank?
41.
Appendix, Page 146:
Additional references on vitrification include:
(a) Oma, K.H., et. al.
In-situ vitrification:
Applicational analysis for Stabilization of Transuranic Waste; PNL 4442, PNL, Richland.
Washington, Sept. 1982.
This document discusses application of the technique at Maxey Flats.
(b) Brouns, R.A. and C.L. Timberman.
In-situ Thermoelectric Stabilization of Radioactive Waste.
Proceedings of the
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GENERAL COMMENT
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1.. Volumes 1 and 2 of task 2 are comprehensive _ documents which were j
generally well received.
Several reviewers. commented on an apparent i
subjective presentation of some of the individual decommissioning alternatives.
For example, the " Positive Trench Drainage "(p. 49) and
" Deep Compaction" (p.40) options were elaborately described in a very positive fashion with.little, if any, negative characteristics mentioned.
See, also, our Specific Coments section on the disadvantages of the Positive Trench Drainage'and Deep Compaction options.
Unbalanced
' descriptions could lead to poorly supported decisions on selecting decommissioning alternatives.
- 2. : With respect to the Positive Trench Drainage option, the authors are.
1 presenting (almost recommending) an untried and unproven' system which does not meet most of the authors' selection criteria for viable options (e.g., page 56:. Applicability, Maturity, Complexity, Safety, QA).
Moreover, this system seems to present a potentially long-term (indefinite?) maintenance requirement with a high frequency of repair, allows. direct pathways to the env4ronment, provides little if_any
. assurance of capturing and.transmi-tting all radioactive contaminants and may violate the general criterion that releases from the site be minimized.
3.
More thought needs to be given to developing monitoring alternatives - especially if the Trench Drainage option is not exercised.
4.
With respect to Chapter 6, Selection of Alternatives (p.57-61), A much more meaningful list of alternatives would be a combination of measures and alternatives.
(See, for example, our Specific Co'ments section, item 25 on trench cap-trench stability combined options.)
Individual alternatives in themselves are almost meaningless.
See also, for example, pages 337, 3rd paragraph and p.,272,' both in Volume 2.
5.
One combination of alternatives apparently not considered in Chapter Remove about a 20-foot soil layer of farmland found 6 is the following(:
north of the site-State property).
Cover the disposal facility with 20-30 feet of the soil layer.
Contour to promote runoff.
Use plant management techniques to optimize evapotransportation and reduce water infiltration to zero levels. (trees with 6 ft. rooting - see Volume 2, Pg.
j 21, Table-2.).
Maintenance would be very low, and inexpensive, i
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AUG 2 91983 20126/SN/83/08/26/ ENCL /2 2
subsidence would no longer be a critical problem in that it could be acconnodated/ managed, and the waste would then be at sufficient depths to mitigate against. intrusion without having to excavate the waste.
6.
Appendix needs some editing.
Some of the references are incomplete,
_ (e.g., p. 330, p. 352), some of the figures are not in correct order, etc.
The addition of an author index in volume 2 would be extremely helpful to the. reader.
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j SEP 20 :1983 Ref: SA/JFK i
MEMORANDUM FOR: Leo Higginbotham, Chief Low Level Waste Licensing Branch, NMSS
'FROM:
Donald A. Nussbaumer Assistant Director for-State Agreements Program Office'of State Program's
SUBJECT:
KENTUCKY REQUEST FOR ASSISTANCE
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As per our letter of intent to Mr. T. M. Taimi dated August 3,1983, attached is the third task of the Maxey Flats Report. Please note that they have extended their due date from September. 23, 1983 to September 29, 1983.
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Donald A. Nussbaumer Assistant Director for State Agreements Program Office of State Programs
Enclosure:
As stated Distribution:
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