ML20239A021

Research Summary of Rept Entitled, Control of Water Infiltration Through Shallow Land Burial Trench Covers Annual Rept Oct 1984 - Sept 1985

ML20239A021
Person / Time
Issue date:	07/23/1987
From:	Odonnell E NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To:
Shared Package
ML20238F347	List: IA-87-235, Provides Summary of 760203-06 Insps at Commercial Waste Burial Facilities in Sheffield,Il,Beatty,Nv,Richland,Wa, Maxey Flats,Ky,Barnwell,Sc & West Valley,Ny.Nrc Finds No Evidence of Significant Radwaste Migration.Related Encls ML20238F345 ML20238F384 ML20238F401 ML20238F411 ML20238F418 ML20238F526 ML20238F646 ML20238F695 ML20238F731 ML20238F741 ML20238F765 ML20238F842 ML20239A005 ML20239A021 ML20239A061
References
CON-FIN-B-8958, FOIA-87-235 NUDOCS 8709170024
Download: ML20239A021 (3)

Text

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RESEARCH

SUMMARY

Control of Water Infiltration Through Shallow Land Burial Trench REPORT TITLE: t l Covers Annual Report October 1984 - September 1985 PROJECT TITLE / FIN: The Control of Water Infiltration at Humid Area Shallow Land Burial Facilities, B8958 NRC PROJECT MANAGER: Edward O'Donnell CONTRACTOR: Laboratory of Biomedical and Environmental Sciences, UCLA PRINCIPAL INVESTIGATORS: Robert K. Schulz, University of California Berkeley and Robert Ridky, University of Maryland REGULATORY CONTEXT:

A primary problem associated with short and long term management of near surface low-level radioactive waste disposal sites located in humid regions has been intrusion of water into the waste disposal trenches. Water within the disposal trenches not only leaches radionuclides from the wastes, but also upon exiting from the trenches, that water can transport radionuclides into the environment. In some cases, where trenches are excavated in relatively impermeable formations, the trenches may fill with water and run over if such' steps as pump out and evaporation of trench leachates are not taken to prevent that occurrence. Thus, to minimize the potential for water borne radionuclides movement from trenches, water infiltration into waste burial trenches should be l

minimized.

l To minimize water control problems 10 CFR Part 61 requires that waste disposal i

sites are to be located where they are " generally well drained" (10 CFR 61.50 1

(a)(5)) and the trench covers must be " designed to minimize to the extent practicable water infiltration, to direct percolating or surface water away from the disposed waste, and to resist degradation by su'rface geologic processes and biotic activity' (10 CFR Part 61.51(a)(4)). The focus of this project is on an assessment of trench cover designs which may be used to control percolation.

Current trench capping practice (Herzog,1982 NUREG/CR-2478) in humid areas is to use a 1-3 meter cover that is composed of compacted backfill or compacted l backfill with a locally derived clay. The covers are graded into a low crown

to promote runoff and they are vegetated .

4th grass. The grass is to reduce erosion and to remove infiltrating moisture by evapotranspiration. Experience l with.the existing covers at the humid area LLW sites has not been good. This l

' is due in part to subsidence which leads to fissuring of the cap and, in part, to increased cap permeability with time due to root growth (and subsequent root decay) which creates water channels. For sites that are well drained the disposal system can accommodate water entry through the caps. Any infiltrating.,

B709170024 B70910 ETO 235 PDR 1 [^!<jQl'/T(('y u _

water will exit the disposal trench. However, trenches in low permeability media Leve experienced " bath tubbing," and they require better protection from I water intrusion than the existing cap designs are providing. ,

l Several alternative trench cap design approaches have been proposed for future humid area sites (e.g., capillary barrier system, layered soil system, impermeable barriers, and a bioengineered system). They are intended as improvements over current capping technology. From a regulatory perspective they are des.igns which may be promising but whose performance is still unassessed.

RESEARCH OBJECTIVES:

The ob'jective of this research is to assess potentially promising methods for controlling deep water percolation through low-level waste disposal trench Covers.

RESEARCH FINDINGS AND RESULTS-I The attached report describes the results of preliminary field testing at Maxey Flats. This preliminary work was undertaken to provide a reference for designs of full s.cale trench caps at the Beltsville, Maryland site.

The principal investigator employed 12 existing small scale (5' diameter X 10' deep) lysimeters in which there was an established vegetative crop and 2 years baseline data on t% effectiveness of that crop in controlling deep water percolation. The wil in the lysimeters was a weathered clay rich shale from Maxey Flats that was compacted to the same density as a typical new trench cover. Thebaselinedataindicatethatabout20%ofthewaterinput(rainfall) was disposed of as surface run-off, 50% was removed by evapotranspiration, and 30% ended up as deep percolation water. During the winter-spring, when evapotranspiration was low, the deep percolation that occurred resulted in a rise of the water level in the bottom of the lysimeters. To reduce percolation run-off was artificially enhanced by covering 70% of the surface in 6 lysimeters. Six other lysimeters were left with their existing vegetation as a control; however, a number of different crop-management schemes were employed to determine whether there might be a scheme that is optimal for controlling deep water percolation. Results are summarized in figures 6-12 of the attached report. With the control lysimeters there was deep percolation as evidenced by rising of the water in them, especially during the winter.and spring months.

The variation of crop-management schemes had little effect on deep water percolation. Because of the relative impermeability of the Maxey Flats clay, that excess water would have to be removed by pumping. In contrast, lysimeters with enhanced runoff showed no water level rise and presumably would not need to be pumped. Thus the data obtained to date, albeit in the rather small scale lysimeter experiment, indicate that an enhanced runoff system might serve as a tool for control of water. infiltration through shallow land burial trench covers. Basically the system calls for engineered, or pcitive, guaranteed runoff, along with substantial evapotranspiration.

In summary several points should be noted: (1) In the lysimeters without enhanced runoff containing compacted clay to simulate a conventional tre'nch cap there was ap vegetation. proximately 30% deep percolation (2) In the ly,simeters below with enhanced the root runoff lesszone.of water isthe available 2

for the vegetation. Plants are " stressed" and they enter an overdraft situa-tion where they actively seek what little water is available. In this case, ceep percolation below the root zone approaches zero. (3) The results of this small scale lysimeter experiment indicates that the concept of using enhanced runoff with " stressed" vegetation is a promising way to control deep water percolation into burial trenches. A large scale field experiment embodying that concept is underway at Beltsville, Maryland. A drawing of a test cell emnl e g--+ bat enncont 4y Qnyn _in Ji m a 1a nf +he =++=ehad reonet 3 j@

noted that the results of these tests would be applicable equally to a

[iconventionalSLBtrench,oranyaboveorbelowgradestructure(suchasan earth mounded bunker) which relies on a cover or cap to control / divert surface water infiltration.  ;

REGULATORY IMPLICATION:

The small scale lysimeter experiment indicates that about 30% of the precipitation falling on plots of compacted clay covered with fescue grass or alfalfa will percolate below the root zone of the vegetation. Varying vegetation and cropping methods had very little effect on this deep percolation. Extrapolating those results to disposal facilities in humid areas, one can expect water movement through earthen or clay covers. This is borne out by experience at the commercial LLW sites in the Eastern United States. Improved methods are needed to control surface water percolation at LLW disposal sites where such percolation could adversely affect the performance of the facility.

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Edward O'Donnell Earth Sciences Branch Division of Radiation Programs and Earth Sciences Office of Nuclear Regulatory Commission i

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FEB'10 M7 #' .

Maxey Flats File No 201.6 .

NOTE TO:~ Mal Knapp John Starmer Maxine Dunkleman Kathy Schneider, OSPy FROM: KittyDragonettefh!,f

SUBJECT:

Price Anderson Claims for EPA Superfund Activities at Maxey Flats Enclosed is a copy of a claim filed to establish that radioactive releases at the Maxey Flats, Kentucky low level waste site should be covered by Price Anderson.. The encised claim is by Battelle.

General Dynamics has filed a similar claim. OGC has the lead to respond to both claim letters. According to Bob Fonner, this strategy is based on the fact that activities and liabilities associated with byproduct, source, and special nuclear materials covered by Price Anderson are exempt under Superfund. Such claims could lead to litigation of the issue before EPA could collect. Fonner noted that the nonradicalgical hasards of the wastes and releases would not be covered by Price Anderson in any case so that the claims address only part of the liability.

Fonner also indicated that NMSS involvement on what constitutes an " incident" might be needed at some future time but for now, the claims are strictly legal matters.

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CERTIFIED MAIL 4 e5 \ @@

Director of Nuclear Material Safety and Safeguards

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U.S. Nuclear Regulatory Commission g DOCKETED .

1717 H Street, N.W. USNRC Q Washington, D.C. 20555 - t .)

9; FEB 5 1037 yypl

Dear Sir or Madam:

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NOTICE OF DEMAND BY THE ENRIVONMENTAL //

PROTECTION AGENCY UNDER 42 U.S.C. 59 9601 ET SEQ. A .

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NUCLEAR DISPOSAL SITE, MOREHEAD, FLEMING COUNTY, KENTUCKY Battelle Memorial Institute (BATTELLE) and Battelle Columbus Division, "

an operating division' thereof, have received notice under the captioned statute that they are potentially responsible parties (PRP's) for costs related to response or remedial action taken and planned by the Environ-mental Protection Agency (EPA). A copy of the notice from EPA is appended as Attachment A.

• Upon receipt of the notice, Battelle conducted a preliminary survey l of the materials which were or may have been sent to the captioned disposal site. That survey indicates that many of the materials were generated, received or otherwise employed by Battelle in performance of Government contracts. Many of these were prime contracts with the Atomic Energy Commission (AEC) and its successor agencies, the Department of Defense (D0D), or the National Aeronautic and Space Administration (NASA). Others were subc.ontracts with AEC, D00, or NASA contractors. l In performing these contracts, Battelle made extensive use of depleted uranium, source materials, and enriched (or special nuclear) materials.

Most of these materials were Government-owned and furnished.

Accordingly, by contract and regulation, the Government at all times retained title to ,the radioactive contaminants and wastes generated in these operations.\1)

Certain of Battelle's contracts, and the contracts under which Battel N subcontracted, contained or were subject to various indemnificatice agreements, including indemnification against public liability author 1:ec by the Price Anderson Act. See 42 U.S.C. 65 2014, 2210(d) (1982)

Battelle also may be iridemni fied as a processor of Government-ownec and furnished nuclear material produced by AEC or Nuclear Regulatory Commission (NRC)- licensees who had entered into indemnification agreements in connection with the operation of production and utilization (1)The standard Government furnished property clauses cppearing in AEC prime contracts explicitly provided that title to property furnished by the Government remaDd at..all times with the Government.

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' 4 Director of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission 2 January P8,1987 facilities. See 42 U.S.C. 99 2133, 2134, 2210(c) (1982). As a result, Battelle. is a "pe rson indemnified" within the meaning of the Price Anderson Act. See 42 U.S.C. 9 2014(t) (1982).

The attached notice of demand which may create legal liability arising out of or resulting from a " nuclear incident" may result in "public liability" within the meaning of the Act. See 42 U.S.C. 9 2014(w).

A " nuclear incident" is defined as "any' occurrence. . . causing. . . . loss of or damage to property, or loss of use of property, arising out of or resulting from radioactive, toxic, explosive, or other hazardous properties of source, special nuclear, or by-product material..."

42 U.S.C. i 2014(q).

As a PRP for costs related to response or remedial action taken and planned by EPA, Battelle may be required to take affirmative ard costly action. In addition, the issue of responsibility for the costs ulti-mately may be committed to the Federal Courts for determination. Because.

EPA's claims are premised solely upon the occurrence of a nuclear incident, any judgment against Battelle or expenditures required of this organization would result in public liability within the meaning of the Act. See 42 U.S.C. 9 2014(w) (1982).

In light of the foregoing, this letter, in accordance with 10 C.F.R. 9 140.6, constitutes written notice of a claim for property damage arising out of or in connection with the possession or use of radioactive materials. Should you have any questi.ons concerning this matter or should you wish to discuss the issues raiced in this letter, please contact the undersigned at (614) 424-6580.

Sincerely yours,

h. W Xathy A. Olson Assistant General Counsel. <

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Attachment 1

I ATTACHMENT A I*

oo r Oq iD IJ UNITED STATES ENVIRONMENTAL '~tnTECTION AGENCY

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CERTI?!?D WAIL FET'*.PS RECEIPT PEOUESTED liATTELLE MEM. INSuntrE NOV 2 61986 505 KING AVENUE COLUM3US. CH 43201 REF: Maxey Plats Nuclear Disposal Site Morehead, Flecing County, Kentucky

Dear Sir / Madame:

The United States Environ = ental Protection Agency (hereinaf ter E.P. A.) has spent and is considering expenditures of public funds to investi$ ace and rake corrective action for the control of releases and of threatened This releases action is being of taken hazardous substances at the above mentioned site.

pursuant to Section 104 and other provisions of the comprehensive Envircr ental Response, Cc=pensation and Liability Act of 1980 (hereinaf ter referred to as CERCLA), codified at 42 U.S.C. Section 9601 f3 ggg. and recently a= ended by the Superfund Amend =ents and Reauthori:acion Act of 1986 For (SARA), P.L. 99 499 (si ned 5 by President Reagan on October 17, 1986).

your infor=ation, tha key ter:n " hazardous substance" is defined at 42 U.S.C.

Section 9601 (l'a.

Potentially responsible parties (PRPs) under CERCIA include current and for=er owners and operators of the disposal site, persons and entities who generated or produced the disposed of hazardous substances and who made agreemenes for disposal of such ha:ardcus substances at the site, and persons and antities who vere involved in the transport, treat =ent, or disposal of hazardous substances at the site. Under Section 107(a) of CIRCLA, 42 U.S.C. Section 9607(a), under SARA, and other laws, PRPs nay be liable for costs incurred by Such coscs =ay the government in taking corrective actions at the site.

include, but may not be limited to, expenditures for investigation, planning, cleanup of the site and enforce =ent ac:ivities. By eeans of this let:er, EFA is giving you notice cf your potencial CIRCIA liability and to encourage you as a PRP to undertake voluntary cleanup activities at the above-na=ed site; specifically the re=ediel investigation and feasibility studyitself. (RI/TS) and ultimately the remedial design and remedial action (RD/PA)

Based upon radioac:ive shipping records (RSR's) ga hored by EPA, the Agen:y as has reason to believe :na: ycu =ay be a responsible party under CIRCIA, amended. At this :ime appr:xi=ately eight hundred thirty-two (832) PP.?s km e

e t.

p linked to the Ma.xay FInts Disposal Site. Attachment A is a list of g FPPs with their current t.ddresses. E6cause cf the large nicber of f pgpe and the deadline discessed belcw fcr the PRFs to undertake the RI/FS, GA rec::rraends that tre FRPs at their earliest convenience crganize i

themselves into a steering cemittee. It is fm.her suggested by EFA that a steering co.mittee spckesperson be c.%sen as som as practical and that the steer 1rq cc:mittee er FRFs retain an environmental eNineering i c:nsulting fi=n to setzfy the draf t wrkplan fer the PJ/Fs which is included I

as Attachment B to this notice / demand letter. We constituted steerirq cecmittee, PRFs, cr environmental consultants are directed to call the

• DA perscenel indicated belcw fer further inic:=atien about the Faxey riats Disposal Site.

By my cf background, in 1963 tr.e C:rrenwealth cf Kentucky connanced operaticn cf a 1:w-level radioactive disposal sita at Maxey Plats.

Earlier in 1962, Kentucky entered into a licensing agreement with the U.S.

Atcmic Energy missicn to assume regulatcry powes for the managecont of t*m icw-level radioactive materials. 74 licensing agreement transferred -

titia cf the Maxey Flats Disposal Site to t's Councnwealth cf Kentucxy and the leasirq of site operatices to the Nuclear Engineering Cc 9.any.

An estimated 4.75 millicri c. ic feet cf waste were de;esited at Maxey Plats frcs tre beginnirq cf cper:tiens in 1963 to the cicae of diel activities i

in 1977. About 2.4 millicn curies of at=nic by-product natarial, cver l 240,000 kilegrert.s cf accuic scurce material, and 430 kilegrac:s of special l nuclear material wre placed in trenenes, pits, and het wells in tra active l

die;csal area en-sita mich censists of 25 acres. Scecific Icw level i

radicective wsta dispesed cf at Faxey flats includeId items such as c=nt.:nirated paper, trash, clothirq, lateratcry glamsware, plastic tubing, filters, icn-excharge resins, and evaporation slu:iges, crqanic materials placed in Paxey Plats included animal tissue, paper, cardboard, w:od, plastics, and crganic cranicsis (found in leachate san:ples wre benzene, rephthalere, d-n-extyi phtr. slats, and 1,4 dicxane alcng with cthers).

We lee 50e of the Paxey Plats 01.ep:: sal Site, 9. clear Engineering Cc ::any, (rcw U.S. Ecc1cgy) r. ads cent.racts er agreenents with FFPs for dis;csal of their harardcas substances fr=s 1963-1977 at tre site. 74ee arrangements, centracts, er agreteents are reflected by tre radioactive shippirq records (FSR's) cellected and separated by DA. 24 present volunetric/percentx;e

• breakd m of each PRF's centr'.::utien cf haurtous substances to t.be Maxey l Flats Divel sits is attac .ed to tnis retice/de and letter as Attaen ent W.e volu:netric brea)ck~.n is teing prcvided enly fer general infc= etien C.

purposes. Purther refirments in the velunetric breakdcms ty DA aru anticipated.

DA has detecnined that "a release" cf 'hazar&us substances as defined by Sectica 101(22) of sca, as scended by SAFA, 42 U.S.C. 59601(22) has cccurred at the Paxey Plats cie;csal Site. Water collected in tre dispcsal trenches and such water, af ter teccming cent::-inated, has leached cut er was

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Ftreed eva;cratton was also utilized to dispcse of the contm inated w ter. As a result of these measures ( ,

contaminated wte:# has migrated offsite and weer va; pumping, evaporation) trititra has been released into the at espnere. x:r contaminated witn Elevated levels of radionu:lides sucn as Strontitra-90 and C calt-60 have been detened Studies have stow 1 higher-than-ncrmal tritiun levels in leaves oc trees adjacent to the site.

Tractures in sandstene beds outside the trenen area of contaminated leachate and radionuclides may pose an to local sur' face waters, groundweer, wils, and landowners.

EPA has already expended public funds producing the draft workplan for the tm edial investigation and feasibility study. Approximated er estimated  !

i costs ofS130,000.

exceed this activity and other costs recoverable pursuant to CERCIA now i It is anticipated by EPA that it will cost S1,300,000 (reflected in the remedial design and remedial acticn) m or m re. ,

We RI/FS will largely dete nine tt.e secpe and ecst of tra actual cleanup.

ccmnittee and to notify EPA,Accordingly, you and the other PRPs are reque willingness to conduct er undertake tne RI/FS.in writing, at the address given bel '

cf SARA,'P.I.99-499 eich has acended Section 104(a)(1) of NSee specifically Sec Your made within ninety (90) days of your receipt of this letter. no to notify er reach an agreement witnin the ninety (90) day ti e frameShould ycu fail

, EPA will do the RI/FS itself.assune that ycu will not ecnduct the RI/FS and t*e goverment Ycur written responses to enis notice /derand letter should indicate the and should include a staterent of your desire 'eere .

to conduct th engaged in voluntary action, er involved in a lawsuit , pu regar srculd centinue these actions that letter.

in ycur activity and report tne status cf tncse diseassicos er otter party involved in trcse diseassicns.Please previde a ecpy ef.ycur letter to any Ycur written response steald be sent to:

Mr. Harold Taylcr Enforcement Prc;ect Manager Invest gat en and Cc pliance Section Ehergency and Femedial Pesponse Branch U.S. Enviremental Prctection Agency 345 Courtlard street, ti.E.

Atlanta, Ga. 30365 (404) 347-2234 I

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. s; Due te de seriousness of the prcblers at this site and the atterdant 1egal rxtificaticns, OA strengly urges ycu to resecrd within de tire l

fr=_. u indicated abcw. Le41 g:esti ns' shculd be 'lirec.ed to Mr. Jares F.

Bycett, Assistant Fagional Counsel, at (4C4) 347-2641.

i 'n.e factual and legal discussions centained in this letter are ir. tended l sciely for netificaticn ard edification purpcses. They are not intended l

to, do net. ard ray nct be relied upon as a firal Acency pcsition en any ratter set ferth herein.

To facilitate inferraticn recuests, GA vill establish a repcsitcry cf rec =rds at our Atlanta office. Cr.ce a steering carittee has been selected, the carittee can review the dcct:nents fer eg:ying and distribution p'.t.rpeses. Tc schedule ~a jcint ents fer reviewing the dce ents, please centact.Mr. Taylcr at the above address.

'n.ank icu for ycur attentien and resycnse to this letter.

Sincerely, m ,

Fatrick M. Tchin Di.rectcr Waste Paracement Divisicn -

cc: Mr. A hx Earter, Cirectcr Divisien of Waste Paragenent t

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q 4Au i Distribution List  !

Robert E. Browning NMSS h 1 Michael Bell NMSS Joseph Bunting NMSS Mal Knapp NMSS John Starmer NMSS l John Surmeier NMSS Robert McDougall NMSS Robert Fonner OGS e

m 9 9

1 MAR 101907 TRIP REPORT l

WHO: Advisory Task Force to The Governor of Kentucky -

WHERE: Capitol Annex Building, Frankfort, Kentucky WHEN: Meeting of March 3,1987 State Representative Pete Vorthington addressed the Advisory Task Force on the issue of continuing State funding.for the pumping and evaporation operations at Maxey Flats. He stated his concern that management of Maxey Flats by the Natural Resources and Environmental Protection (NREP) Cabinet is less than satisfactory - citing "seven years of poor project management, almost $10 million expenditures, and the ongoing, potentially serious problem." In October of 1986, Representative Worthington had urged Governor Martha Layne Collins to. appoint an Advisory Task Force to " audit the past actions at the site and to make recommendations for the future." He reviewed the history of the site and mentioned the dissension between his office and the NREP with regard to stabilization activities over the past few years.

Representative Worthington urged that pumping and evaporation activities not be continued at this time on the basis that "there is no convincing data today l which proves that pumping reduces water levels in the trenches." He suggested that sump water le.vels be carefully monitored for several months while the pumping is not operative. Pumping and evaporating would cost the State 5610,000 in '1987.

The Advisory Task Force did nct find the water level data (distributed by Representative Worthington) to be adequate to substantiate his contention that levels are not affected by pumping. The Task Force will hear technical evidence from the NREP Cabinet and from the Human Resources Cabinet on this issue.

]ee+4%-  ;

Stan Neuder, WMPC l Member, Advisory Task Force 1

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UNITED STATES NUCLEAR REGULATORY COMMISSION

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0CT 131983 MEMORANDUM FOR: Don A. Nussbaumer, Assistant Director Office of State Programs FROM: Leo B. Higginbotham, Chief Low-Level and Uranium Projects Branch Division of Waste Management l

SUBJECT:

DECOMMISSIONING PLAN FOR MAXEY FLATS We have reviewed the draft of the Decommissioning Plan for the Maxey Flats Disposal Site, Task 3: . Evaluation of Alternatives. Our comments are enclosed. Dr. Stan Neuder is the Branch Technical contact for this project. Please contact him at 427-4 should any questions arise.

& A Leo B. Higgin ham, Chief I Low-Level and Uranium Projects Branch i

Division of Waste Management

Enclosure:

As stated ,

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Specific Comnents On The Maxey Flats l Decommissioning Plan, (Task 3).

1. Page 8, Intruder Performance Standard:

, " Ensure protection of any individual" to what degree?

<.. Page 17, 2.2.1.8 Monitoring system:

There are many other reasons for monitoring which were not  !

mentioned. For example, to verify confinement, to detect changes, i to indicate trends, to identify potentially problematic situations, * '

to project doses, etc.

l 3. Page 17,20, Environmental Surveillance Programs: I

a. These tables appear to be listings of generic surveillance programs rather than site-specific programs to Maxey Flats. Were i these programs in place at Maxey Flats? Note that these programs  !

were not recommended by the NRC for the Kentucky site and '

indeed may not be totally applicable. These monitoring programs first appeared in NUREG/CR-0570, Addendum, July 1981 for i reference disposal sites. '

b. Much of this discussion is not applicable to decommission -

(e.g., establish baseline information, list of pre-operational ironitoring activity, etc. ).

c. Conspicuously absent are (i) a non-radiological surveillance program and (ii) a surveillance program during the dcccrrnissioninc activities.

4. Page 20. Table 2-5, Post-0'perational surveillance:

6. Eefire the post-operational perico in terrns of the active ar.c passive institutional control periods. .

b. Here again, the post-operational surveillance program appears to be generic rather than site specific to Maxey Flats. Components of an in-place monitoring program would ordinarily be continued into the active institutional control period.

5. Page 21, Deep dynamic compaction:

The word "only" in the last sentence of the page, which reads

... densification of.Maxey Flats trenches require only the development of methods to control potential releases of radioactivity and personnel exposure," is grossly misleading.

l Densification procedures with pile removal may lead to major

! radiological and non-radiological hazards off site as well as on l site. The control of potential releases will not be readily I achieved. Indeed, pile removal may present insurmountab'-

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il radiation control problems'(See Item 42).

6. Page 25, Structural cap ,

Clarify the extent of structural concrete caps. Are they to be above the trenches only? Explain " bridge over the trenches." Is the cap to be below grade, on the soil surface or raised above the surface? Give examples and briefly explain what kind of cover will protect the cap in the long-term.

7. Page 26, Clay cap:

The bentonite clay layer will only remain relatively impermeable as long as it is kept wet. This limitation condition should be l included in the discussion to clarify why the bentonite layer must l be protected. It should also be noted that root systems can c.1use l localized drying of the bentonite with attendent shrinking and infilling of the cracks by non-bentonite soil. This may effectively destroy the relative impermeability of the cap. '

8. Page 39-40, Trench inventories:

What are the units associated with the given quantid es? What are the

! datos of these inventories? The curie contents listed in Tables 2-6 and 2-9 do not seem to be in agreement. (e.g., ?t appears thaO Trench 001 has 306 Ci according to Table 2-9 but enly a few mci  !

according to Table 2-8). <

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9. Page 42, Table 2-10, Radiological source term: j  !

1 (a) units missing on all quantities. ' 'I I (b) defirle." source, term," and how used in t:te study. ,j (c) Where were the measurements made? (e.g. , adjacent to trench, 4 site boundary, etc. ).

10. Page 45, Table 3-1, Potential accidents: '

(a) what is the basis or source of information regarding " frequency" of various accident occurrences?

(b) define " performance scenario." <

11. Page 46, next to last paragraph, Careful control over quality:

Give details or examples ~of quality control of the positive trench drains.

12. Page 47, 3.1.3, Observation period:

(a) What specifically is to be observed and why? .

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(b) What is the duration of the observation period?

(c) khr,t criteris 's to be used for determining the duration of .the obser tation per'.~/

(d) How will cesign performance be evaluated? What are the criteria?

13. Page 47, 3.1.4, Active institutio_nal control period:

What is the rationale for a 100-year active institutional control period?

14. dage 48, 3.3, last few lines, models to evaluate adequacy:

Existing computer or other analytical models are frequently not appropriate for evaluating design adequacy for many reasons (e.g., gross uncertainties of input parameter values, oversimplification in the mathematical descriptions of l

phenomenological behavior, etc. ). Modeling for comparative purposes would be more appropriate and meaningful.

15. Page 51, 4.1, Primary performance requirements:

Add a fourth component, namely " compliance with other standards" to the words " waste isolation, safety and long-term performance."

16. Page 55, 4.1.13_, ALARA.:. .

Add the word "public" after " general" in that sentence. I

17. Page 56, 4.1.2.3, Operational safety-occupational:

" Occupational" should include radiological as well as non-radiological regulations. How does thi.s differ with section 4.1.2.1, Goerational Safety-Radiological?

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18. Page 56, 4.1.3.1, Active institutional control period:  !

b (a) dere too, as before (item 13), give rationale for "a minimum'o'f 100 l years." l (b) What criteria.will be used to terminate the active control period

19. Page 57, 4.2, Secondary performance requirements:

Site characteristics determination is not a performance requirement.

20. .Page 59, Table 4-1, Site Characteristics to be determined for decom'ai ssioning:

Add to the list: wind speed and standard deviations, atmospheric '

pressure, relative humidity, meteorological and radiological background levels.

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21. Page 66, Manage surface water:

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l The management of surface water is also closely related to, and j influences, ground-water infiltration. I

22. Page 70-72, 5.1.1, - wach consolidation model: j The model used (Sowers-1973) assumes that settlement due to I decomposition of e ste is negligible and that primary consolidation has been completeu. It has not been demonstrated that dynamic ,

consolidation will collapse a significant number of 55-gallon drums' l or other structural containers. Primary settlement may therefore continue to occur for long periods of time making this modeling formula inapplicable at Maxey Flats. In addition, this formula.is an empirical relationship developed on the basis of observations made at sanitary landfills. The applicability of this formula to Maxey Flats has not been demonstrated.

23. Page 74, third paragraph, Structural covers:

Here again "structual covers would be able to span areas where formulation conditions in the trenches are poor" needs clarification. Comments made in item 6, as to the extent of structural caps, apply here as well.

24. Page 77, F.igure 5-1, Trench design covers for Modelin_gi Define symbols SC, CH, and GP which appear in the figure. )

Explain " filters."

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25. Page 81-83, 5.1.4, Trench drain model:

Has this system of trench drains and laterals (channel's) ever been l tested anywhere? What about long-term maintenance problems? Will these be sources of radioactivity to the environment? What is the ,

l environmental impact of this system? What of the accumulation of 1 radioactivity in the drain materials over time? Th'is system raises j many important questions which are u ,ddressed in the document.  :

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26. Page 82, Soil inputs: l Parameter values for trench covers (e.g., hydraulic conductivities) l are different from those used in the infiltration modeling. This does i not allow for reasonable compariti"e analysis.  ;

l 27. Page 83, third paragraph, Closed from solutions to the movement of l ground water:

j The ground-water modeling seems to be superficial in nature. tiot enough details are provided to allow for an adequate assessment  ;

of the methodology. The term " closed form" in the text leads one to l

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believe that a simplistic, one-dimensional flow model was used. The statement "These solutions assume that a phreatic surface forms within the laterals" needs elucidation. What are the real-world consequences of that assumption? Explain rhat is meant by '

" behavior of the lateral drainage system." i3ehavior with respect to what?

28. Page 94, 5.1.6.2, Modeling methods:

(a) "... simplified analyses of contaminant transport in the ground water were made. . ." What are the simplifying assumptions? What are the analyses? Describe the modeling.

(b) "... Ground water ineasurement through the site rocks was assumed to occur at a rate of 15 meters per year." This statement doesn't make sense. What is moving? Water? leachate? contaminants? If so, which contaminants?

29. Page 94, last two paragraphs, Dose calculations:

What scenarios were assumed for the dose calculations? Was NUREG 1.109 used for all calculations? (NUREG 1.109 is primarily applicable to nuclear power plants). What were the radionuclides and source terms used for the, calculations? What was assumed about exposure times and ingestion rates?

30. .Page 95, Table 5-2, Site configuration for dose evaluation:

Define " travel time." For what distance and what radionuclides? Are l the values listed for trench infiltration ( 1/10 and 1/100 inch) I assumed to apply to the decommissioning period? They do not appear to be conservative estimates. Compare also page 96 of the text, which assumes an infiltration of one inch per year.

31. Page 96, Discussion of dose calculations: I (a) Large volumes of surface water were apparently used, hence large dilution factors result. A realistic scenario woul'd be the nearby drinking water well used by an individual for daily intake. Little or no dilution may occur. This scenario was not addressed. ,

(b) Which radionuclides and what concentrations were used for l the drinking water scenario and for the consumption of milk?  ;

What are the assumed pathways? Here again, an in-depth review is not possible because of insufficient information.

32 .' Page 99-100, Sources for costs:

1 Page 99 makes reference to the use of R. S. Means Construction Costs ,

l Data 1983 whereas Page 100 specifies the use of costs being provided by i Law Engineering Company (without reference). This is ambiguous and '

does not permit analysis of cost data. .

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33. Page 101, Table 5-6, Cost Bases:

Cost comparisons between the Corps of Engineers, 1983 information (NUREG/CR-3144) and Law Engineering show wide descrepencies. (e.g.,

cost of clay cap, cost of flexible liners, etc.).

34. Page 104, Modeling discussion:

The HELP model is questionable for use in determining exact values of infiltration (.01 inches per year). This probably exceeds the limits of this model. Very little input data used in the analysis has been provided making an in-depth review imposs.ible. l

( 35. Page 104, last line-1 Describe " filters."

36. Page 105-106, Figure 6-1 and 6.2:

It may be difficult to obtain field permeabilities of 7 x 10-10 for the lower layer as indicated, unless nearby pure benetonites are used. In addition, it may not be possible to compact the local soils to 10-7 cm/sec hydraulic conductivity. ]

l 37. _Pjage 109, 6.1.4, Trench drain model:

(a) Explain how the drains will be constructed to connect the l interior trenches to the surrounding collector trench. l (b) It is our understanding that several of the disposal trenches I at the site were excavatec into the sandstone layers. This will l

necessitate the excavation of the drains through the sandstone l which could be quite expen'sive. Wnat is the impact of excavating through the sandstone? The estimates for drain infiltration appear quite low unless an engineered cover is used over the drains. Has the cover been assumed? .

! ('c) Provide rationale for seemingly wide drains (10-60 feet). l

' (d) Explain " drains are more effective in removing large slugs of  !

m er in the trench as apposed to handling continuing water

,l ume's . " l s e) How will these deep drains and trenches be maintained? l i

1 l 38. Page 110, Table 6-1:

(a) Drain infiltration values seem too low unless an engineered I l

cover is in place.

(b) Travel time - for what radionuclides?

(c) What distances are assumed for travel time calculations?

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39. Page 111, second paragraph, These results demonstrate:

The second paragraph does not follow from the discussion in the previous paragraph.  !

40. Page 111, third paragraph, A properly constructed drain system:

1 A " properly constructed drain system" has not been defined.

41. Page 114-115, Migration pathway analysis; Table 6-2, Dose calculations: I (a) No details are provided for the dose calculations with regard

.to radionuclides, exposure periods, exposure scenarios, pathways considered, critical pathways, assumptions used (e.g.,

infiltration, leach rates) etc.

(b) " Dose calculated for all other cases are less than performance standards limits." What are the other cases?

(c) ".. these results are preliminary." Why? How will dose calculations be refined?

(d) Cases A through F in Table 6-2 have not been defined. What are they? Are they the same as "desi or " design options" A through F (gn concepts" A through F (pp 133) pp. 136)?

(e) Again, not enough information has been provided for any analyses.

Table 6-2 is one of the most important pieces of information in the entire study yet lacks the details necessary for analysis.

42. Page 116, second paragraph, Dynamic compaction:

... dynamic compaction using driven pile. Piles are driven to 7 meter depth at a spacing of 5 x diameter. The pile are removed as the work progresses." This is another untested, unproven method which may readily produce biological, chemical, and radiation hazards off site as well as on site. What levels of contamination would be expected on the piles themselves upon removal from the ground? What levels of gaseous activities will be released to the atmosphere? The document does not address hazards nor provide environmental impact -assessments.

43. Page 116, 6.2.2, Positive trench drains:

(a) Here again, how will the drains be interfaced with existing trenches? See Items No. 37 and 44.

(b) What, if anything, would prevent leakage into and out of drains? What would prevent a " bath-tub" effect in the drains, laterals and surrounding collector trench?

(c) The document does not address long-term maintenance problems of the trench drain system.

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! 8 l_ 44. Page 117, 6.2.3, Cutoff trench:

l (a) How will the cutoff (collector) trench, at 21 meters down, l interface with the drains at 13 meters down?

(b) Explain " stockpiles" (Pgs. 116 and 117).

45. Page 118, Table 6-3, Construction costs:

The cost of a ground-water flow barrier was not estimated.

46. Page 132, Design concept A:

DesfgnconceptAwithalowerbarrierofhydraulicconductivity 10~ cm/sec will not achieve the desired infiltration of .01 inches per year according to the graph on page 106.  !

l 47. Page 133, Table 7-3, Recommended Monitoring:

(a) What is the rationale for monitoring off-site milk? .Where 'are the nearest farms? ~

(b) This table is not in' agreement with Table 2-5 (page 20) for the post-operation period. How do they interface? For example, monitoring of milk, fish and farm crops were not recommended in Table 2-5, but are recommended in Table 7-3.

48. Page 134, Design concept D:

(a) Why is the plastic cover placed at the surface?

(b) Why not use plastic in conjunction with designs A or B?

49. Page 134, Design concept F:

How was the 40 year servic'e life for the asphalt membrane liner determined? A PNL document (PNL-4752, DOE /VMT-0064) specifies a much longer service life.

50. Page 152, top two lines, viability of option C:

Why is there a (premature) inclination to reject option C? Option C is very viable in that the waste is not disturbed.

51. Page 156, last paragraph, Rockwell-Hanford demonstration:

The demon.tration of impact compaction at the Hanford site will not be completed before early to mid'1984. Also trench waste ~

conditions at Hanford are quite different from those at Maxey Flats.

Results must be generalized with caution.

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