ML20238F411
| ML20238F411 | |
| Person / Time | |
|---|---|
| Issue date: | 05/09/1975 |
| From: | Larson H NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Harrison D KENTUCKY, COMMONWEALTH OF |
| Shared Package | |
| ML20238F347 | List:
|
| References | |
| FOIA-87-235 NUDOCS 8709160135 | |
| Download: ML20238F411 (3) | |
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Mr. Damon U. Harrison Chairman Kentucky Science and Technology Connission j
Office of the Governor l Frankfort, Kentucky 40601 !
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Dear Mr. Harrison:
l I am pleased to respond to your letter of April 18, 1975 to .
Mr. Lee V. Cossick concerning perpetual care and maintenance of the Kentucky waste burial site at Maxey Flats.
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As your letter suRCests, there are two principal considerations involved l i
in establishing a perpetual care program for a vaste burial site. One concerns the technical criteria for maintaining the buried waste under l proper control from a health and safety standpoint. The other concerns l
the creation of the necessary financial resources to cover the costs in- >
volved in maintaining perpetual care of the burial site.
With respect to the technical criteria, we believe the following general elenents should be included in a perpetual care program as a minimum:
- 1. Restriction of the site against unauthorized access including a surveillance program;
- 2. an environmental monitoring }.rogram designed to provide early l detection of kny migration of r bioactivity;
- 3. maintenance of the covering on trenO es where the vaste is buried; and
- 4. a contingency plan in the event corrective action is necessary due to the migration of radioactivity.
Of course, detailed criteria would need to be developed for each element which are'specifically related to the site characteristics and the type of radioactivity buried. It would appear that the Kentucky agencies exercising control over the site, in consultation with the site operator 4
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MI N. TON 87-235
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_ e Mr. Damon W. Harrison and other consultants as appropriate, are in the best position to develop the detailed technical critaria since they are the most familiar with the specific site characteristics and operational history. We would be pleased to offer our technical assistance in the review and evaluation of i any proposed perpetual care program developed. .
With respect to establishing the necessary financial resources for carrying out the perpetual care plan, we believe this is a natter for the State to work out, based on the detailed perpetual care criteria established for the site. We have no particular expertise in the area of determining the amount of funds necessary to carry out a perpetual care program.
A Task Force of The Conference of Radiation Control Program Directors pre-pared a report entitled " Bonding and Perpetual Care of Nuclear Licensed 7acilities." The Task Force consisted of representatives from several States, EFA, and the NRC. The objective of the Task Force report was to
"... assemble into a single document the guidance necessary for State officials to develop bonding and perpetual care programa..." Mr. Charles M.
Hardin, Manager, Radiation Control Program, Kentucky Department For Human Resources, has a copy of that report. Under separate cover, we are sending you a report prepared by the South Carolina Agricultural Experimental Station entitled " Economic Analysis of Funding Arrangements for Maintenance,.
' Surveillance, and Contingency Costs associated with Burial of Lcw-level l Radioactive Waste in South Carolina." The South Carolina report describes I one method for analyzing and estimating the costs required for the care and maintenance of a vaste burial facility.
Tour letter also suggests that Kentucky is committed to perpetual care and maintenance of the Maxey Flats site under the original agreement with the Nuclear Regulatory Cocmission (NRC). Federal and State regulations require the siting of vaste burial grounds on land owned by either the Federal or State government. Kentucky has assumed responsibility for perpetual carc of the site independent of the authority Kentucky assumed under agreement with the NRC. The agreceent provides for discontinuance by the Commission and assweption by the State of authority for regulating the use of byproduct, source and small quantities of special nucicar material. Since the site is located on State owned land, the perpetual care program would be a State responsibility regardless of whether the site operation was licensed by the NRC or State, under terms of an agreement with the IGC.
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- I Mr. Damon W. Harrison .
Please let me know of the details, purpose and scope of the May meeting.
Sincerely, C. * .....
C ., e Howard J. Larson, Director Division of Materials and Fuel Cycle Facility Licensing Distribution:
HJLarson LVGossick DANussbaumer P h haus GErtter (DR 8578)
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! FAY 1 3 1975 Frank Schroeder, Acting Director Division of Technical Review .
TECHNICAL ASSISTANCE TO THE STATE OF FJ2iTUCKY Covernor Carroll of Kentucky has roquested our assistance in reviewing information regarding conditions at the low level commercial waste burini facility located near Maxey Flata, Kentucky. There has been substantial
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publicity in the press about the site and charges by a former State employee over the health and safety aspects of the site and that the State has not done an adequate job in regulating the licensee's operation. The publicity bog.an when the State issued a report on a six month special
! environmental study at the site in December 1974. That report concluded that the burial ground was contributing radioactivity to the environment, that the activity detected does not create a public health hazard, and that further studies are needed to access the exact nature of conditions at the site. We believe that these conclusions are reasonable. However, Governor Carroll asked the NRC to conduct an independent review of the situation.
In order to implement this review and to provido a bionder base of technical o expertise for the review than exists on our staff, I would like to have one person from the Division of Technical Review with knowledge and experience in ground water hydrology and another with knowledge and experience in radiological assessment participate. C. Wayne Kerr, Chief, Agreements and ,
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Exports Branch, will chair this review group. He has discursed this orally with Mr. Harcid Denton and Mr. Jacob Kastner.
We anticipate this review vill include a review of several existing docu-monts in our files, review of recent data collected by the Stato, and a visit to the site.
Our target for completing the review and making recom-mendations to the Covernor is inte June.
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1 inwould appreciate this reviev group. your inforcing me of the two persons who can participate in the near future. We expect to arrange a meeting of the review group y,: - , ,r Distribution: I: 3 HJLarson DANussbaumer Howard J. Larson, Director PHLohaus Division of Materials and HDenton Fuel Cycle Facility Licensing NMSS R/F MP: AE R/F Central Files " l
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