ML20238F401

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Responds to Note on Knuth 750116 Memo Re Status of Kentucky Waste Burial Site.Final Rept Released by State on 741216 Concluded That Site Contributing Radioactivity to Environ Did Not Create Public Health Hazard
ML20238F401
Person / Time
Issue date: 01/30/1975
From: Larson H
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Gossick L
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20238F347 List:
References
FOIA-87-235 NUDOCS 8709160125
Download: ML20238F401 (2)


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NU,CJ.E A R REGULATORY COMMISSION el W ASHINGTON, o. C 20555

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C6ssic ",' Acting Executive Director

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This is in regard to.your note on the January 16, 1975 memo i from Knuth to Muntzing regarding the status of the Kentucky waste burial site. As noted in Mr. Knuth's memo, the State released its final report on December 16, 1974. The final l report concluded that the site was contributing radioactivity l to the environment but it did not create a'public health hazard.  !

The report included recommendations for further environmental studies at the facility and the State is taking action to carry out the recommendations.

The Agreements and Exports Branch performed a review of the total Kentucky radiation control program for agreement materials on December 17-19, 1974. We reviewed a substantial portion of the State files on this. licensed facility during that meeting.

As a result of this review we informed State officials that we believed prompt action was needed to initiate the expanded monitoring program referred to above and to begin a reassessment of the licensee's program for water management at the site. The '

State has orally informed us they are in general agreement with our recommendations.

It should be noted that the West Valley, New York commercial waste burial facility is solely under the regulatory authority {

of the State of New York, and NRC has never issued a license for  ;

any portion of that operation. In the case of the Chem-Nuclear

'ystems, Inc. facility at Barnwell, South Carolina they did possess 1 an NKC license authorizing burial of special nuclear material at i the time of the IE inspections in November 1974. However, that NRC license was terminated on December 4, 1974, and that facility is now solely under the regulatory authority of the State of i South Carolina.

Ihavebeeninformedbystaffmembersinvolvedinlicensinkof institutions such as universities that there have been few, if any, authorizations for burial of waste in excess of the limits provided for in Section 20.304 of Part 20 in the last few years. i

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Lee V. Gossick . JAN 3 01975 Where such authorizations were granted to institutions to bury their own vastes, they involved limited quantities of radioactive material resulting from experimental programs (e.g., trace quantities in large research animals). Under these circumstances, monitoring for possible migration was not considered necessary. Generally, the use of private burial grounds was phased out w'da the availability of commercial burial grounds.

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Howard.J.'Larson}, Director Division of Mate' rials and I Fuel Cycle Facility Licensing j l Office of Nuclear Material Eafety 1 and Safeguards ec: D. Knuth, IE e

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S4 pE/ j L. Manning Muntzing Director of Regulation

'f WASTE BURIAL FACILITIES j

l This is in response to your request of November 20, 1974 that RO f inspect all AEC licensed waste burial sites on a priority basis. This  !

request for im=ediate inspections was prompted by notification that a Kentucky report on the Maxey Flats burial facility was about to be made public. An early draft of the Kentucky report concluded among other things that there had been some migration of Pu to the unrestricted environment. (The final Kentucky report released in mid-December stated that Pu and other radionuclides were measured in individual samples but the waste burial site did not create a public health hazard.) These special AEC inspections of five commercial waste burial sites, either i partially or fully licensed by AEC, were completed on November 29, 1974 and are listed below:

Nuclear Fuel Services, West Valley, New York Nuclear Engineering Co., Inc., Beatty, Nevada Nuclear Engineering Co. , *Inc. , Richland, Washington Nuclear Engineer.ing. Co. , Inc. , Sheffield, Illinois i

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Chem-Nuclear Systems, Inc. , '3arnwell, South Carolina

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This memo is a su==ary of the results of those inspections. In general, there was no evidence of any significant transport of radioactive i materials through migration. In addition, based on offsite sa=pling by licensees and States, no impact to the offsite environment could be attributed to the operation of these waste burial facilities.

l The R0 Regional Directors were requested to have their inspectors l determine, in detail, that which had been done to monitor for migration of radioactive material and review the results of these determinations.

Inspectors were asked to obtain the maxi =um information possible concern-ing the co=plete operation of the burial sites. In addition, to provide a basis to judge the correctness of the licensee and State measurements, l

we requested the collection of samples from onsite cacpling points for AEC analysis.

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JAN 1 0 $75 L. Manning Muntzing o Attachment 1 shows that as of the end of 1973, the total quantities of radioactive wastes buried at these facilities varied from about 200,000 cubic feet (Barnwell site) to almost 2,000,000 cubic feet of wasteo (West Valley site). Average radioactive material concentrations at waste burial sites are generally in the range of tenths of a curie per cubic foot.

From the information gathered, it appears that licensees and States have initiated reasonable environmental monitoring programs which consider the major pathways to the public. A variety of samples.as shown on Attachment 1, are collected and analyzed periodically. The licensee records of these analyses showed no evidence of any offsite environmental impact. In addition, State environmental mor.itoring programs which were established to check the facility operation conditions support these results.

All facilities with the exception of NFS have onsite monitoring wells to attempt to detect the movement of radioactive material away from the trenches. (NFS had used two nearby streams as such an indicator, but several test wells have recently been dug as part of a special study.)

No significant activity due to waste burial was measured beyond burial trenches at any of the sites. A small amount of activity was found in some wells located fairly close to the trenches, but in those cases, the concentrations were several orders of magnitude lower than the concen-trations in the trenches.

Samples from test wells or nearby streams collected during these inspections by RO inspectors were analyzed by the Health Services Labora-tory, Idaho Falls. The data, as tabulated in Attachment 2, showed levels that agree well with licensee and State analysis results. l The location of the test wells for measuring migration are critical and there is no satisfactory means of determining that a suitable placement .

has beer accomplished. Test wells placed close to the trenches can be bypassed by trench leakage, whereas wells too far away may not detect migration until it is significant. In. addition, the dep'th of the test well is crucial since the possible migration elevation is not normally known. However, even if activity is detected in the test wells, this may, in many cases,'be due to surface runoff into the well rather than lateral migration. Therefore, in order to make a more conclusive determination of migration of radioactive materials from the burial trenches, detailed studies on soil conditions, geological structure, underground water movement and meteorology, etc., would be required.

Such studies are well beyond the scope of routine monitoring programs.

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L. Manning Muntzing MN 1 6 3 73 o

L and RO recently met with a representative of the U. S. Geological Survey (USGS) and were informed that legislation requires USGS to survey existing waste burial sites in order to determine criteria for locating future vaste disposal sites. USGS expects to initiate detailed studies in early 1975 on at least two of the burial sites covered in l this report (Sheffield, Illinois and West Valley, N. Y.). It is antici-l pated that such studies will continue for several years and will provide the type of information NRC needs regarding containment at the current-sites as well as provide the Com=1ssion and the Agreement States with ,

criteria for siting future vaste burial facilities.

l In addition to material buried at the commercial vaste sites listed above, there are significant quantities of radioactive material entombed at deco ==1ssioned reactor facilities, i.e. , Bonus (50,000 C1), Hallam (300.,000 Ci) and Piqua (60,000 C1). Also, a few licensees have been g i authorized to bury radioactive materials in private burial grounds in *

) i excess of the quantities specif1ed in Section 20.304. _A listing _of et* !

tEese latter licensees has not been separately maintained by L. To 4t9 l ident:Lty tnose licensees would require an extensive and time consuming '

search ot the rues.- -nowever, curing routine inspections, such spEcial 1Ynse aucnornations are reviewed by the R0 inspector but to our 5 recollection there are no special requirements for monitoring for 'g. A U" I possible migration of radioactive materials. '

Additionally, it should be noted that the regulations grant all licensees authority to bury nominal quantities of radioactive material. [I1 hG ~)*

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L4-4tr/Caf Donald F. Knuth, Director Directorate of Regulatory Operations j Attachment 1 & 2

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ATTACHMENT 2 INDEPENDENT MEASUPJ2iENTS - WASTE BURIAL SITES Cross a Trit'ium 144Ce 137Cs 60Co Burial Sites Sample dpm/ml uC1/ml e uCi/ml -

l Chem-Nucicar CN-1 <0.06 2.81 4E-6 <5E-8 2.11 5E-8 1. 61 4 E-Earnwell, S.C. CN-2 <0.04 1.71 4E-6 <5E-8 18E-9 <9E-9 g

l CN-3 <0.04 1.71 4E-6 <5E-8 <6E-9 <5E-9 CN-4 <0.01 1.71 4E-6 <6E-8 <2E-8 < 9'i-9 CN-5 <0.04 <7E-7 <6E-8 <6E-9 <.S E-9 IES Buttermilk Creek <0.01 <1E-6 <5E-8 <6E-9 2. 41 4E-West Valley, N.Y. Erd =an Erook (In #67) <0.01 <1E-6 <6E-8 <6E-9 <5E-9 Erdman Brook (12 #53) <0.01 211E-6 <5E-8 <8E-9 <5E-9 Hot-Cold Ditch (NY #73) <0.02 <1E-6 <6E-S 1.51 1E-7 <9E-9 Ditch North (NY #74) <0 02 2.Q.1E-5* <5E-8 1.31 5E-8 <5E-9 NECO -

S.E. Creek <0.02 <1E-6 <7E-8 <2E-8 <9E-9 Shefficid, Ill. Wcter Strip Mine ,

<0.06 11E-6 <9E-8 <2E-8 <2E-8 Test Well A <0.02 <1E-6 <5E-8

<8E-9 <9E-9 Test Well B <0.02 .1E-6

< <6E-8 <6E-9 <5E-9 Test Well D $0.01 11E-6 <7E-8 <2E-B <9E-9 Test Well E <0. 04 - <1E-6~ <6E-8 <2E-8 <9E-9 Test Well P <0.06 <1E-6 <2E-8 <5E-8 <9E-9 NECO NE-9 <0.07 <1E-6 <6E-8 <2E-8 <9E-9 Beatty, Nev. NE-10 <0.05 <1E-6 <6E-8 <6E-9 <5E-9 NE-11 <0.09 <1E-6 < 4E-8 <8E-9 <5E-9 NECO NE-1 <0.05 <1E-6 <9E-B <2E-8 <2E-8 Richland, Wash. NE-21 <0.05 <1E-6 <9E-8 <2E-8 <1E-8

  • 1.iquid sample from ditch receiving surfcce drainage and water from swamp. Previous invest:

gation of elevated tritium icvels at this location disclosed most likely source appeared te 3e scepage from reprocessing plant lagoons and not from burial trenches.

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