ML20238F842
| ML20238F842 | |
| Person / Time | |
|---|---|
| Issue date: | 07/28/1975 |
| From: | Karen Chapman NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20238F347 | List:
|
| References | |
| FOIA-87-235, TASK-IR, TASK-SE SECY-75-392, NUDOCS 8709160379 | |
| Download: ML20238F842 (24) | |
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.' ,4 July 28, 1975 NIT D STNfEs SECY NUCLEAR REGULATORY COMMISSION INFORMATION REPORT For: The Commissioners Thru: Executive Director for Operation p
Subject:
COMPLETION OF NRC REVIEW OF MAXEY FLATS, KENTUCKY COMMERCIAL WASTE BURIAL GROUND .
Discussion: Governor Julian M. Carroll, State of Kentucky, requested the NRC, by TWX of April 30,1975 to Chairman Anders, to assess the current situation at the Maxey Flats, Kentucky commercial waste burial ground, and to provide himy with j our findings. We met with representatives of the l Governor's staff on May 7,1975 to discuss the nature of I our review. The NRC review group which was established l visited the site bn June 3, 1975, and met with State and j licensee repres'ent'atives on June 4'and 5, 1975. Chairman. '
Anders' letter of June 20, 1975 to Governor Carroll, confirmed the action we were taking in respon'se to thei Governor's request (Reference SECY 75-?32).
i 1 Enclosure A is a copy of our July 14, 1975 letter to l 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 impicmentation of the recommendations contained in the State's six-month study report. The NRC report also includes several recom-mendations for consideration by the State which deal i principally with methods to improve water management at I the site so as to minimize migration of radioactive material.' l
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I I 8709160379 070910 1/*
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p j MINTON87-235 PDR .
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The Commissioners .
Discussion: We have also informed the State, by letter dated (continued) July 14, 1975, to C. Leslie Dawson, Secretary, Kentucky Department for Human Resources (Enclosure B),
that the NRC is not able to provide financial assistance to conduct further studies at the site. We indicated, however, the NRC would provide continuing technical assistance to Kentucky.
Governor Carroll issued a press release on July 17, 1975 regarding the NRC report (Enclosure C) . In the release, Governor Carroll indicates the NRC was responsive to his request, notes the conclusions of the NRC report, and directs the Department of Human Resources to review the report's recommendations for implementation at the site.
Kenneth Ch Office of Nuclear Material 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 l
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Contact:
G. Wayne Kerr Telephone: 492-7767
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il UNITED STATES 1 j
NUCLEAR HEGULATOnY C O M M IS S!O t; W AS HIN oTO N. o. C. 2 05 G 5 JUL 141975
< l Honorable Julian M. Carroll Governor of Kentucky
- Frankfort, Kentucky 40601 ,
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Dear Governor Carroll:
This refers to your TWX of April 30, 1975, to Chairman Anders, requesting the Nuclear Regulatory Commission (NRC) to assess the current situation ,
nr the Maxey Flats, Kentucky, commercial waste burial ground, and to l provide you with our findings. You may recall that members of my staff met uith your representatives on May 7, 1975, to discuss the nature of the review which we wou].d make. Chairman Anders' letter to you of June 20, 1975, confirmed the action we were taking in response to your r: quest.
A: 7.0 review group was appointed consisting of staff members knowledgeable in Agreement State relationships, hydrology, and radiological assessment to conduct this review. This group revicued availabic information regarding the site, the State's December 1974 project report, the report i
of the State's Environmental Study Design Committee, and recent environ-l mental monitoring data. The review group visited the site on June 3,1975, and met with State and licensee officials on June 4 and 5, 1975.
T;nclosed is the report of the NRC review group, which includes certain
- cce=mendations for the State's consideration. The report concludes Lat there is no significant public health problem associated with the release of radioactive material from this burial site. It is also our ,
l c'o nclusion that the State has been taking appropriate action concerning )
implementation of the recommendations as contained in the six-month study report. The recommendations deal principally with methods for improving '
water management at the site so as to minimize migration of radioactive .
material. !
Uc have.also received a letter dated May 13, 1975, from C. Leslie Dawson, Secretary, Department for Human Resources, requesting both l technical and financial assistance in the conduct of the studies out- ,
lined by the State's Environmental Study Design Committee. While we are able to provide technical assistance, we are not in a position to provide financial assistance in this matter. Ue are sending a copy of car report to Mr. Dawson and will, at the same time, inform him of our decision regarding financial assistance. -
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Enclosure A !
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Honorcble Julian M. Carroll l l
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1 If you have any questions regarding the encloced report and its ,
recommendations, please let me know. If y'ou think it would be hcipful, !
we would be pleased to meet with you or your staff to discuss the report I after you have a chance to review it.
Sincerely,
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u2O b$ ,,ms->
Kennetn ,h R. Ctapma jn 31 rector Office of Nuclea1' Material Safe'ty and Safeguards
Enclosure:
Report of NRC Review Group I
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9 Enclosure A e
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l REPORT OF THE NUCLEAR REGULATORY COMMISSION REVIEW GROUP O
REGARDING MAXEY FLATS, KENTUCKY C0hWERCIAL RADI0 ACTIVE WASTE BURIAL GROUND !
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JULY 7, 1975 l
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Enclosure A
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Tabic of Contents i
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I. Introduction........................................ 1 II. Radiological Assessment............................. 2 ,
. 1 III. Hydrological Assessment............................. 3 IV. Recommendations..................................... 5 l
1 Appendix A List of NRC Review Group Members........... A-1 l l
l Appendix B Action Being Taken by the Commonwealth of l
. Kentucky Regarding Implementation of l Recommendations as Set Forth in the Six- !
l Month Study Report......................... B-1 Appendix C Action Being Taken by the Nuclear Engineering Company, Inc................... C-1 l i
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l O O C
l Report of Nuclear Regulatory Commission Review Group Regarding Maxey Flats, Kentucky Commercial Radioactive Waste Eurial Ground
- .:n;rnauction n;c :cmmercial radioactive waste burial ground at Mancy Flats,
'.tntuchy began operation in 1963 under a license issued by the Cu:c.:.cnwealth of Kentucky (Kentucky is an Agreement State) to Nuclear Engineering Co., operator of the site. The burial ground and adjacent area is owned by the Commonwealth of Kentucky. The S: ate ar.d the licensee have conducted environmental monitoring prograus cr. and around the site since prior to start up of operations. I.: a
- cL=1t of increasing quantitics of radioactive material being cf.spaaed of at the site, State concern over water management at the
.2, nn6 some indications of radioactivity being contributed to ,
t_c Mcxey Flats site,arca as a result of site operations, the Stara ;
n;1ated a special environmental monitoring study in Novenber 1973. ,
irs study covered a sixenonth period, ending in May 1974, and a i
- -jact report of the study was published in December 1974. The o conclusion of the report was that site operations were
- .cributing radioactPiity to the environment', that the activity
. . c.a t create a public health hacard, and there was a need to
.:eneify monitoring activities to determine the long term signi-f.ccnee of the findings.
- r a result of the State's sin-month study report, there has been public interest regarding the health and safety aspects of the
- :. t a . Kentucky Governor Julian M. Carroll requested the NRC, by JD: af April 30, 1975, to independently assess the situation and novide him with its findings and recommendations. Governor Carroll at informed that NRC would review recent information developed bout conditions at the site, conduct a site visit and advise him cf our findings. The Director, Office of Nuclear Material Safety end Safeguards appointed an NRC review group which consisted of
- -a. acts of the Agreements and Exports Branch knowledgeable in ,
A c: ment State relationships, and persons with expertise in hydrclogy and radiological assessment from the Division of Technical Revios, Office of Nuclear Reactor Regulation. Appendix A lists members of tha NEC review group.
Tnc review group examined information regarding the site, the Srnte license, hydro-geological information about the site, the State's 30:c=ber 1974 project report, and the report of the State's Environ-
- .cn:a1 Study Design Committee which was established in February ,
1975. On June 3, 1975, the review group made an unannounced visit
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to the burial ground in the accompaniment of Mr. Charles Hardin, Manager, Rodiation Contro.1 Branch, Deportmore for Human Resources, Commonwealth of Kentucky. The review group not uith Mr. Hardin and his staff on June 4,1975, to review environ."mtal monitor $ng data 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 reviews 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 taking appropriate action in implementation 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 NECO representatives to receive their views on environmental monitoring results, operation of the evaporator at the site, current operating practices and the status of the water management program. Appendix C reviews the actions being taken by the company.
Mr. Kerr discussed the review group'c activities with Mc. Jachie Feigart, Chairperson, Kentucky Environmental Quality Commission on June 9, 1975. Ms. Swigart had expressed the commission's concern about the burial site in a letter dated April 21, 1975, to Governor Carroll.
II. Radiological Assessment As a result of the site visit and evaluation of the data available l 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-active materials are being released in the hydrosphere in unrestricted areas. In our evaluation it was assumed, conservatively, that the water would be consumed 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 dose was calculated to be 15 mrem per year. For beta and ^ alpha activity, including natural radioactivity,.the potential doses would not exceed 110 mrem per year to the whole body and 1500 mrem per year to the skeleton (using Srso as the limiting beta emitter and '
Pu239 as the limiting alpha emitter). These doses do not e e D
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represent actual human exposures. They are based on the maximura levcis of radioactivity observed in the environment I and the most restrictive radionuclides mixture. Actual human I doses would be below these levels.
B. Atmospheric Releases The potentini 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 doce at the nearest residence which would not exceed 5 mrem per year. In addition, traces of other l nuclides are known to be present of which the largest expo.aure !
is that due to Sr90 For this nuclide the calculated poten- ]
tial bone dose would not exceed 1.5 mrem per year. !
C. Conclusions
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We conclude that, at the present time,'there appears to be no i significant public health probicm associated with the relcane
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of radioactive material from this burial site. The Radiation '
l Control Branch of the Department for Human Resources of the Commonwealth of Kentucky has adequately evaluated the potentini effects to the public health and safety through its environ- 4 mental monitoring program and is continuing this program in order to detect,any problems 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 analyser. of radiological samples. 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 potent $al human exposure can be better estimated. Also, the analyses can serve as bases for the measurement of radioactive material migration.
Notwithstanding the above, the data on tritium concentrations in the water sampled from Test Wells 11 E (located onsite but in the unrestricted area) and 13 E (oncite and in the restr.icted area) are sufficiently high to merit consideration of further action. This is addressed in Recommendation No. A.6.
III. Hydr _ological Assec .:ent A. Site Description and Operations The site is on a relatively flat hilltop in north central Kentucky. Most precipitation (annual average of about 47 inches) that falls cn the site runs off and into small streams.
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- Precipitation that does not run off is either evaporated, consumed by vegetation or percolates into the ground. The fraction that percolates flows at a low rate into underground zones for eventual drainage to seeps, wells and stream channels.
The subsurface material is composed of successive layers of different shales and sandstone. The surficial layer is clay, a weathered shale. Groundwater is considered to move through cracks and fissures in the shale. ,
Although the radioactivity detected in the offsite environ-ment presents no significant health problem to the population residing in the area, removal of water from th'e trenches is l necessary to minimize the potential for the' migration ,of radioactivity. The licent ae has performed a considerable amount of work to reduce the infiltration of surface water
- into completed trenches in the older section of the burial '
facility. This work includes grading and improving surface drainage, recapping of trenches with clay, and establishing a vegetative ground cover over the capped trenches. Improved methods are currently being used in the completion of newer trenches to minimize the infiltration of surface water into the trenches. We believe these methods are necessary to , *l minimize 'the infiltration of water into completed trenches. l It is not possible to assess the complete effectiveness of l these efforts at the present time.
l The State requires the licensee to remove water from open trenches and to remove liquids collecting in closed trenches.
The licensee has established a program to pump water from the l l trenches until the trenches reach a dry status as defined in i the license. The licensee has installed an evaporator system '
to treat and process liquids removed from the trenches. The l liquids are first pumped to a temporary liquid' storage area '
l adjacent to the old burial area and subsequently processed
. through the evaporator. We believe these actions are appropriate in order to minimize the movement of contaminated water from the trenches to the underlying geologic formations. .
The temporary liquid waste storage area consists of steel 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 gallons of -
l liquid waste is stored 'in this area. An opparent deliberate act by a person or persons unknown last winter resulted in the contents of one of these tenks being dumped within the berm '
i area. Consequently, all rainfall which is collected within l
the area must now be treated as radioactive liquid waste. All f
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rainfall collected within the area lu now br.ian trand erred t.o a newly lined pond. Leakage from the pond and dilutinn by !
additional rainfall is minimized by confining the contaminated liquid between two impermeable membrancs. There are tuo additional onsite ponds: one is used as a non-potabic water supply and the other is a surface drainage pond. The licencec's efforts to minimize the quantities of water stored on site should be continued. It appears that the problem of migratien )
of radioactivity at the site can best be controllad by further )
j improving surface and groundwater management techniques at the i site. 1 l
Conclusions
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After visiting the site and reviewing data collected by the Commonwealth of Kentucky, the Nuclear Engineering Company and various federal agencies, we conclude that to date the wastes s are being entombed at the site and in an environment contaiujug significant amounts of groundwater. The continuous use of the groundwater evaporator hcs, in our opinion, substantially reduced the offsite migration of contaminated water. Actione, should be taken to improve the water management prograu, minimize the need for the evaporator, and further reduce offsite migration of low level radioactive water. Recommended ceasures to accomplish these objectivos are cet forth in Section IV of this report.
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~V. Recommendations The fcllowing recommendations addr ss several methods which should )
be considered by the State to improva water management and site operations. Improved water management should minimize the potential !
for nigration of radioactivity from the burial trenches. Each should l be evaluated on a cost effective basis. The specific recer.cendations j in A below relate to immediate improvements and should be considered by the State for implementation in the near term. The general recommendations in B below address additional measures which.could be considered if the water management aspects of site operations do f not improve. These should also be considered in lieu of or in j conjunction with the proposed studies of'the Environmental Study {
Design Committee, i.e., if conditions at the site do not improve and the mcnitoring programs indicate increasing levels of environmental radioactivity, further positive actions to improve the water management program should be taken as opposed to only studying the site. 3 l
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A. Specific Recommendations for Consideration by the Stato i 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 l 2. The density of the top surface layers of soil should be determined. If it is not compacted to near optimum <
1evels (as determined by the standard American Association l l of State Highway Officials compaction methods), engineering I methods should be used to obtain maximum compaction. If an optimum surficial density cannot be obtained, the ;
s'urface could be covered with a well compacted layer of I some essentially impervious material, such as clay or soil cement.
- 3. The method of measuring water extracted from the trenches, I 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 i specified to minimize water accumulations, contact with I waste, and potential contamination of groundwater.
- 4. The effect of the onsite non-engineered ponds on the groundwater table should be evaluated. These ponds should be eliminated or lined unless it can be demonstrated that they do not significantly enhance dissolution of radioactive materials in the' trenches and increase the rate of movement of contaminated groundwater.
'5. The program for nessuring source terms (radioactivity being released in the evaporator effluent and that present
, in trench water) and the environmental mon,itoring program being conducted by the licensee should be continued. The State should assess the licensee's program to be sure it includes nuclide analysis of evaporator effluent releases, trench water and appropriate environmental med1a (air, water, soil, crops and other direct pathways to man). An air sampler should be placed at the nearest residence north of the site. The monitoring program should be such l
that it is possible to evaluate the environmental impact from all significant pathways such as breathing, drinking water, eating fish, etc. It should provide information needed to determine whether public exposures are within established limits and to ensure that long term buildup of
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specific radionuclides in the environment will not become significant. Thc State may exercisc it's regulatory function to ensure quality assurance and compliance by splitting samples, 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 j is the most likely source. An assessment should be made l of the f easibility of isolating this waste in place or l removing and disposing of it in an appropriate manner. I Such an assessment should be performed on a cost-benefit basis ine.luding consideration of any additional radiation j safety problems that may be created by such measures.
l l With respect to the radioactivity data from test well 13 E, it appears that the most likely source is waste buried in Trt,ch No. 33 L. This trench should be brought to a dry state to determine if tritium levels in well 13 E l can be reduced. -
I B. General Recoc=endations for Consideration by the State
- 1. Measures could be taken to increase the ability to remove water from future trenches (once they are closed).
Originally the trenches were to have a gravel drain on the bottom. This practice was later discontinued because the backfill material was apparently clogging the gravel.
Clogging could be prevented if an adequate layer of sand was provided on top of the gravel.
- 2. Lined channels could be provided between and around the 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 hydro-geological study proposed by the Environmental Study Design Committee is initiated, an attempt should be made to determine the extent of the pervious zone indicated i by EMCON Borings 2E, 7E, 8E, 10E, and 12E. The zonc should ,
i be located and its leakage investigated. The zone should be '
grouted with a suitable slurry material, such as clay, if it can be determined that the zone contributes sigr.ificantly l to offsite groundwater flow. A similar technique could be used to seal any other leaky zones encountered as a !
result'of subsurface explorations.
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- s 4.- The need for the proposed mantic study would be obviated by successful reductions in percolation. Subsurface explorations could also be used to establish whether groundwater is reaching the site in the near surface strata by flowing from the north and northeast. If it was determined that a significant amount of water is reaching the site in this manner, an interceptor dicen could be constructed across the north end of the site.
- 5. Consideration could be given to ef fectively encapsulating i
huried waste in an impervious side and bottom trench liner.
l Such a liner could be constructed of bentonite, hydraulic l"
asphalt or other durable 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.
C. Summary A number of proposals for investigating the Maxey Flats site have been made. While ctudies for learning more about site conditions have merit, we believe careful consideration of poritive actions to reduce offsite migration of contaminated water should be considered.
if conditions at the site do not improve 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 o! the environmental monitoring program.
The State has requested that NRC contributu 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 information expceted to be obtained from the recommended studies wil3 be sufficiently site specific so as not to be of direct applicability to other NRC activities. Therefore, the review group does not recommend that NRC provide financial assistance to the studies.
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APPENDIX A . .
KRC REVIEU GROUP MEMBERS l
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G. Wayne Kerr, Chief (Chairman)
Agreements & Exports Branch Division of Materials & Fuel Cycle Facility Licensing 4 Office of Nuclear Material Safety and Cafeguards l William Gammill, Chief .
Site Analysis Branch Division of Technical Review Office of Nucicar Reactor Regulation Jrcob Kastner, Chief Radiological Assessment Branch Division of Technical Review j Office of Nuclear Reactor Regulation j L. G. Hulman * .
t Site Analysis Branch G. P. Turi Site Analycis Branch ,
J. S. Blcnd j Rcaiological Assessment Branch P. h. Lohaus Agreements and Exports Branch i
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I APPENDIX B i
Action Being Taken _by the Ceponwnalth of Kentuc)y_Rytarding, Irgpiemen,-
tation of Recommendations os Set Forth in the Six Month Study Report..
, A. On January 7,1975, the State inforned the ;Nncicar Engineering Co.
(NECO), the site opcrztor, 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, i They requested NECO to notify them of the stepc NECO is taking and ;
I future actions to be taken to assure that the site does not contribute
) further significant radioactivity to the' environment. The NECO l response consisted of a report of their environmental study committee. l The primary conclusions of the report are: )
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- 1. No long term increasing trends in environmental radioactivity '
are observable from NECO's environmental monitoring data.
- 2. The present 2xtensive environmental monitoring program should be continued for two years after all trenches reach a dry status.
- 3. No~ physical remedial actions are planned until the monitoring '
I program mentioned in No. 2 is completed. . (NECO " plans to occide i on what physical remedial actione should be taken based on an cualysis of data gathered through the monitoring program.) ;
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. NECO does not fully agreo with the conclusions drawn from the '1
, State's study, particularly since they believe their data, covering i a longer period of time than the six-month study, shows no trends l toward increasing levels of environmental radioactivity. However, l the Company has agreed during discussions that the State data indicates the site is contributing small quantities of radioactivity to the offsite environment as any nucle.ar facility would. They l believe the prob 1cm lies in how the data is interpreted, and they believe neither the State's data nor their data shod any rea) potential for human exposure to persons living in the area. ,
i B.' The State expanded their Radioactive Wasto Disposal Environmental Study Design Committee to include representatives from the:
U. S. Geological Survey i Kentucky Geological Survey ' ;
Nuclear Regulatory Commission Environmental Protection Agency Energy Research and Development Administration t
. , 3 3-2 Kentucky Science and Technology Commission Kentucky Department for Natural Resources and Enf comental ?
Protection ,
Kentucky Department for Hawm Resources The Committee met on February 18-20, 1975, and developed a six p61nt.
program to be considered Ter ferther studies at the site as listed below by priority:
- 1. Deep Hydro-Geological Study
- 2. Surface Run-Off Water
- 3. Mantle Study (Weathered Zoae) .
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- 4. Definition of Source Term . i
- 5. Agricultural Pathway l
- 6. Environmental Biological Pathway !
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The State is proceeding in the implementation of these studies and has requested finandial tssir.tanca from several federal agencien including the'NRC. Presently, the EPA is conducting the Agricultural Iathway study at no co.it to the State. NECO, with some State participation, is conducting the Surface Run-Off Water study. The j
Department of Human Ret..ources staff has reconmen.ed that the Environ-i mental Biologica: Pathway study bc initiated. The State plans to take no action regarding the other ntudies until they receive a response to their request for financial assistance from the federal agencies.
l C. The State has continued to expand its comprehensive environmental l monitoring program at the site. Prior to the six-sonth study the State was sampling 12 stations for water at a monthly lftequency.
The program has been expanded ?.o include 30 sampling utations. which are sanpled on a bi-weekly basis.' In addicion, the State and NECO have established a split samplirg program and certain sampicssue I clso analyr.ed by the EPA. The fes; tits of the split and tri-s impling programa are in substantial' agreement.
D. The State is proceeding with amendment of FECO's,licenshlto re<(uire ,
improved site operating procedures, burial containment, and ensiron-mental r.onitoring by NECO. The license is prese ttly .being renewed and amended in its entirety. The primary chr. opes preposed ,to be made in the license are:
- 1. Improved trench construction and completion including the p'lacement of three sumps in each trench recessed into the -
trench wall to prevent shear. n
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. 2. Improved method f or keeping water of f the active J aci of j l waste in.the trench. ;
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- 3. The containment of tritium contaminated waste in ceramic material when the specific activity exceeds 10 microcurica per milliliter and buried such that the container will not be breeched. .
- 4. Restriction on the stack effluent from the evaporator to reduce the contribut1on of radioactivity to the environment.
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- 5. Con:inuation of water management program. The State has l renegotiated the agreement bcLkcen the State and NECO I which provides that NECO will supply a security in the ,
amount of $430,000.00 to assure that NECO carries out the l wat'er management program as specified in NECO's "PJan of l Corrective Action and Schedule of Compliance" previou.,3y i l
filed with the State and incorporated into NECO's Idem.se.
The mency will go to the Stato if NECO fails to carry out the program. The agreement was signed on March 39, 1975, has no expiration date, and will not expire until all
( trenzbec reach a dry status as defined by the licence.
E. The State has requested and has obtained the opinions of two federe?
agencies relating to the appropriateness of applying a more restrictive criteria than the Maximum Permissible Concentrations (MPC's) as
- specified in t.he Kentucky Radiation Regulations to the potentici i
migratioa of radioactivity from shallow land radioactive waste disposal facilities. Both EPA and NRC indicated that the philorophy I of total contafument should be applied to the burici of radioactive
! waste and the design objective of a site should be such that cli l waste is retain?d within the site boundaries throughout its haznrdaus lifettsc. The NRC stated thlat the ITC's and "as low as practicable" concept are not appropriate for application to the migration of radioactive waste from a burial site except that the MFC values are appropriate.in ascessing the public health significance of the
, radioactivity detected.
F. The Kentucky Science and Technology Commission has appointed a task i
group to study, evaluate, and determine the changes which may be s
needed in the perpetual cara and long range maintenance program fcr the site and the associated financial responsibilities for carrying out.the program.
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t C-1 APPENDIX C !
Act ion _ Ueing,'lii.: . b s ib' 1% ear Enginfieri ty Com m iy, Inc. OE.C$
Several c tions are listc d brd o.' ubich NECO hno taken to improvo cc..vH.nono a t the c.i ';c. Sev:.y.M c.f :;huc were initiated prior to the six month st udy por formed by t1:n State.
A. NECO appoint"d r, three d. caber internal taa;k p,roup to study the ,
State's and the Ccr.,uusy's ruvironmental data. The Trsk Group preprived a repet which was r,ubMt.ted to the State in renponse to the Steu:e's 1/7/D 3 et ter. (See iten A in Appendix U.)
B. UEr0 has co 1.hirt"d .. ourface run- of f ni o<iy. The report of thtir study is bei.ng prm.ared fer t ran:. mitt al to the State. They f c>umi r.ewral surface cren onsite 9hir.h were contaminated and cleane,)
work on t.hese areas unn tarted in March 1975. The State pari.ie-irated in a part oC t.his stedy end bcUcVes the drop in icvc3 n :r certain sampling utat* tons 1F. att.ributable .to the cleanup operations beine undertaken by HI,CO.
1 C. KECO has incrcr wl their own environment.n3 ronitoring progran te coincide with that being cenducted by the State. They are partic-ipating in a split ennpling propren with tbc Etate and have obtet.isi hetter onsite laboratory inscrutaentation capnhility for cnmple analysec.
D. NECO propoacd to 1.he State that future burials of tritium, which enceed a specific activity of 10 micrecurdec per ndllilit.cr, br.
contained in eersuale material. The Stat e plnan to incorporat e 11.J ,
condition into t.he-licence uith the additional condition that ibe-container be buried cuch that the container wi)) not be breeche.r.
E. NECC believes all phases of the operation have improved and cited l the following examples:
j 1. New management and site operations porsonnel have been hire .
The operation of the site has received increaned r.innn;ccent attention. Quarterly meetings and unannounced inspections of the site and operations are c'enducted by taanagement with site operations personnel.
- 2. Improvement in the curface uater manancinent program through l better control of surface unter run-off, grading, reccaling I (capping) of exinting trenches and the estcb31ahuant 01 a vegetation c.over on these trenchen.
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- 3. The conduct of an extensive water manutenent program to cereo e water from the trenches. An evcporator systen han been innta10:d to reduce the r4. bioactivity and concent rate the liquids pwpt d from the trenches.
- 4. Increased attention to site operations and the' materials receivea from custorr.ers for burial. A new form for use by customers in reporting the material being shipped for burial has been developed.
- 5. The conduct of hydro-geological evriluotions of the site and based on thece evaluntlons development of p master site development plan and a revised radiation nnfety plan for site operationn. Thet.c involve new methods fo; preparing and utilizing trenchen, the installaLJon of three sumps per L:eneb recenne.1 into the trench wall, $mproved c.epping procedures, and methode, for keeping water off tho open fsce of waate in the trench.
- 6. Twenty-four of the 42 completed trenches have been' brought to a dry status as defined by the license. .
- 7. Efforts are being made to reduce: 1) the quantity of water st,ored at the tank faru which subsequent.ly ic procewerj threur,b the evaporator; and 2) the nize of the tank farm.
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tb;. C. Leslie Dausca l I
Tip? Secre:.:'iry f or !Iu... n Renources {
Coo ivannith of INntuchy ,
I'r a f. T o r t , lie.;tucky 40601 3.ar Mr. Denmon :
li, our Jtme 25, 3975, sc.pon;e to youi ifay 13l 1975, let ter, un in f ou.
y u.. of our activiLJe.s regardJng rev.icu of the Hv.ny Flarn low ]cvel rn lieact ive wante din 1>o:< d site uh tch included consideration of :/our 1, a .c. . L for finaacial assistanec Lo conduct further studien at the she, o
Unile uc are ab1n to provide concim.Jun technical acsiatance to the Stote are not ahic to provide firancial assistance. He heliev: ri.- t the 2nformation expected to be obtained from the Environment.1 Study 1 -
n Com ittee's proponed studies vill be suf ficientJy si tt r.p ec i f l e an not t.o be of direct appij cability to other l'RC activitiec.
Enclo:..ed in the report of the NRC revice group 1.bich va have nort le G : nor carroll. The report concludco that there Js no significu.t pui.f ic heal th problem araotiated with t he release of radj onctive no r m.a ni i r, . th N hurial cite. It :in alco our conc 3 nc,lon that the State hno h... n aM an nr. ropriate act ion c oncerning implernentat ion of the recon..enda t o.ii..t a: s e.tained in t he .; i.r-aou t.'a study report. Tin report includen unv"rci re o n,b io,u for coa.;iduration by the State which deal principa.11,3 ;Jih
. thods li r improving wat cr manar,cracnt at t.bc cilo no as to minimize talgra r ion 'of rad J oactive rtah. cici.
Magarding the ntatementn in your IcLter that the AUC con'eurred in your insm. ace of the licence for the Ma;.cy FlaL3 buria] ground :in 1963, i nf o r: nation in cur fil.c: i ho.m that while Lbc AEC al.af f o"; a t e0 ti,n certain ceo--hydrologleal aspects of the site thvL nhould be inve.ti -1 ;,
the AEC never actually sevicued or concurred in all the inforaarjoa upon uhich the original licertnjuc action una bnced. Thin was connidernd appropriate since Kentucky was an Agreement State uith nothority to regulate, an.ong other thiro., cot..racrcial burial of cert ain radioaci tv-waste in the State.
Enclosure B 1 _ - _ - _ _ _
W M
Mr. C. Ler.lic D:wson -
2'- i If you havo.any quer,Lione, regarding the attached report and .it s reconneidations, please let toe know.
Sincerely,
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1.f Ch[apenan
- ,: . / . ;,
.['cnneth
- l. , lhi t ect.or Office of Nuc1 car lidterJ.al Safety and Safeguards Enclosurn:
Report of IRC Review Group 4'
Enclosure B I I
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j From the Office of Governor Julian Carroll l Press Advisory July 17, 1975 ,
l Governor Julian Carroll issued the following statement o
I today upon receipt of a report from the Nuclear Regulatory Commission Review Group.
i "In a re~ port just received from the Federal Nuclear Regulatory Commission, that agency has now fully responded to my request for a prompt evaluation of the situation at the Maxey Flats l nuclecr waste disposal site.
"The seven member multi-disciplinary review team from URC has reached two important conclusions:
- 1. There is no danger associated with the release of radioactive material from this burial site.
- 2. Action has been taken to implement previous
. recommendations which NRC has made.
"This report thus supports the corrective action previously inglemented by the Radiation Control Branch of the Bureau of Health Services. Although NRC concludes that there are no public health hszards at this site, I have instructed the Radiation Control Branch 1
to ccarinue to improve the s,ite and closely monitor the situation in order to preclude and prevent the occurance of any problem whatsoever.
"NRC recommends several specific actions. These recommend-acions have been referred to the Department of Human Resources for implement a tion . I have directed the department to advise me as soon as possible concerning their plans for implementation of NRC's re-commenda tions ."
Enclostre C i
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I DISTRIBUTION DISTRIBUTION I Secretary 5 l
Chairman Anders 4 Commissioner Rowden 2 Commissioner Mason 3 Commissioner Gilinsky 2 Commissioner Kennedy 3 l Exec Dir for Operations 2 l Agency Inspector 6 Auditor 2 I
Congressional Affairs 1 Public Affairs 2 General Counsel 2 Exec Legal Director 2 Administration 3' Policy Evaluation 2 Asst Exec Dir for Operations 1 International 6 State Programs 1 Nuclear Reactor Regulation 2 Technical Review - 1 Nuc Mat Safety 6 Safeguards 2 Mats & Fuel Cycle Facility Licensing 5 Inspection 6 Enforcement 1 Nuclear Regulatory Research 1 l
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