ML23156A471

PR-MISC - 58FR62384 - Decommissioning of Shieldalloy Metallurgical Corporation'S Facility in Cambridge, Oh; Notice of Intent to Prepare an EIS and Conduct a Scoping

ML23156A471
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Issue date:	11/26/1993
From:	NRC/SECY
To:
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PR-MISC, 58FR62384
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ADAMS Template: SECY-067 DOCUMENT DATE: 11/26/1993 TITLE: PR-MISC - 58FR62384 - DECOMMISSIONING OF SHIELDALLOY METALLURGICALCORPORATION'S FACILITY IN CAMBRIDGE, OH; NOTICE OFINTENT TO PREPARE AN EIS AND CONDUCT A SCOPING CASE

REFERENCE:

PR-MISC 58FR62384 KEYWORD: RULEMAKING COMMENTS Document Sensitivity: Non-sensitive - SUNSI Review Complete

STATUS OP RULEMAICING PROPOSED RULE: PR-MISC OPEN ITEM (Y/N) N RULE NAME: DECOMMISSIONING OF SHIELDALLOY METALLURGICAL CORPORATION'S FACILITY IN CAMBRIDGE, OH; NOTICE OF INTENT TO PREPARE AN EIS AND CONDUCT A SCOPING PROPOSED RULE FED REG CITE: 58FR62384 PROPOSED RULE PUBLICATION DATE: 11/26/93 NUMBER OF COMMENTS: 10 ORIGINAL DATE FOR COMMENTS: 01/15/94 EXTENSION DATE: I I FINAL RULE FED. REG. CITE: FINAL RULE PUBLICATION DATE: I I NOTES ON FILE LOCATED ON Pl.

ATUS RULE TO FIND THE STAFF CONTACT OR VIEW THE RULEMAICING HISTORY PRESS PAGE DOWN KEY HISTORY OF THE RULE PART AFFECTED: PR-MISC RULE TITLE: DECOMMISSIONING OF SHIELDALLOY METALLURGICAL CORPORATION'S FACILITY IN CAMBRIDGE, OH; NOTICE OF INTENT TO PREPARE AN EIS AND CONDUCT A SCOPING OPOSED RULE PROPOSED RULE DATE PROPOSED RULE SECY PAPER: SRM DATE: I I SIGNED BY SECRETARY: I I FINAL RULE FINAL RULE DATE FINAL RULE SECY PAPER: SRM DATE: I I SIGNED BY SECRETARY: I I STAFF CONTACTS ON THE RULE CONTACTl: MICHAEL WEBER MAIL STOP: 5-E-4 PHONE: 504-1298 CONTACT2: CHAD GLENN MAIL STOP: 5-E-4 PHONE: 504-2546

DOCKET NO. PR-MISC (58FR62384)

In the Matter of DECOMMISSIONING OF SHIELDALLOY METALLURGICAL CORPORATION'S FACILITY IN CAMBRIDGE, OH; NOTICE OF INTENT TO PREPARE AN EIS AND CONDUCT A SCOPING DATE DATE OF TITLE OR DOCKETED DOCUMENT DESCRIPTION OF DOCUMENT

- 12/27/93 11/19/93 FEDERAL REGISTER NOTICE RE SHIELDALLOY FACILITY LOCATED IN CAMBRIDGE, OHIO. PUBLISHED ON 11/26/93 12/27/93 12/20/93 COMMENT OF CAMBRIDGE GUERNSEY CO. (CIC) (AL HILLS) ( 1) 01/14/94 01/06/94 COMMENT OF JAN OLDS ( 2) 01/19/94 01/10/94 COMMENT OF JACKSON TOWNSHIP BOARD OF TRUSTEES (ROBERT RASOR/S. KING/HARRY HOGAN) ( 3) 01/19/94 01/14/94 COMMENT OF OHIO ENVIRONMENTAL COUNCIL (BRIDGETTE MARIEA) ( 4) 01/19/94 01/15/94 COMMENT OF JAY PHILLIPS ( 5) 01/19/94 01/14/94 COMMENT OF JOAN PHILLIPS ( 7) 01/19/94 01/14/94 COMMENT OF OHIO EPA (DAVID HUNT) ( 8) 01/21/94 01/14/94 COMMENT OF SHIELDALLOY METALLURGICAL CORP (DAVID R. SMITH) ( 6) 01/24/94 01/12/94 COMMENT OF US DEPARTMENT OF THE INTERIOR (KENT KROONEMEYER) ( 9) 02/04/94 12/13/94 TRANSCRIPT OF PUBLIC SCOPING MEETING ON THE ENVIRONMENTAL IMPACT STATEMENT FOR SHIELDALLOY'S FACILITY IN CAMBRIDGE, OHIO 04/14/94 04/07/94 COMMENT OF ZEOLITIC TECHNOLOGIES INCORPORATED (GARY L. PRITT, V. P.) ( 10)

ZEOLITIC pR f'l .s G TECHNOLOGIES, DOCKET NUMBER PROPOSED RULE I INCORPORATED

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DOCKETED USMBC "94 APR 14 P2 :5 3 OFFICE F Sf CPJTi\~'f April 7, 1994 00Ci',ETiHG ,.. St..R **

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Secretary, U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Attn: Docketing and Services Branch Re: Remediation techniques for Shieldalloy Metallurgical Corp. -- Cambridge, OH

Dear Sirs:

Zeolitic Technologies is writing the commission to propose consideration of an alternative technique to remediate the Shieldalloy site in Cambridge, OH. Our corpora-tion owns the license for a geopolymer process which can effectively stabilize and remediate low-level nuclear contamination.

Our manufacturing facility is located less than 75 miles away from the Cambridge, OH ,

site and the inventor of the geopolymer technology, Mr. Doug Comrie, is the technical director for our company. I have enclosed an article written by Mr. Comrie which describes the basis for our technology.

• Zeolitic Technologies would be happy to answer any additional questions if your commission deems our technology has potential as a remediation/stabilization technique tor the Shieldalloy -- Cambridge, OH , site.

Sincerely yours, Ga L. Pritt Vice President, Marketing enc: Natural Science article, "New Hope for Toxic Waste" 3081 Gilchrist Road

• Suite 105

• Akron , Ohio 44305 * (216) 794-8422

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• NATURAL SCIENCE IJTHI EDGE NE\\ HOPE FOR 1 TOXIC WASTE The recent discovery of an ancient cement promises to be the solution to toxic and radioactive waste contqmination problems of today.

DOUG LAS C. COMRJE When nuclear plants began to dot the landscape of reactors remain extremely expenaive and potentially our planet, industry planners assumed that by the dangerous to disasaemble.

time the react.ors' service lives were spent. in 25 to The entombment of a spent or damared reactor 35 years, the technology would exist to render them poses severe problems, many of which are exempli-environmentally safe by disassembling or entombing fied by the damaged Chemobjl reactor. Alter the them. Today, altbourh a number of these service The Yankee Rowe nuctear reactor near Pittsfield, Mase .. 11 the lives are drawini to a close, there is still debate about oldest commercial reactor strn in aervice, having been built in

• the selection of a suitable entombment technology. A 196 1. Using geopolymeric concrete may be the answer to the permanent solution has yet to be accepted, and entombment 0t diaasaembly of nuclear power plants.

AUGUST 1988 171

NATURAL SCIENCE Al 1HI IDOi ....

disaster at Chernobyl. the reactor was *entombed in Chernobyl concrete casing may crack and break concrete-a mixture of portland cement with sand apart in the coming years. Repeated seasonal cycles and rravel. One of the dangers with this type of of freezing and thawing accelerate the decomposition entombment involves the development of hydrother- of concrete. Of course, waterproofing compounds or mal conditions-eonditions that encourage the exis- waterproof barriers can be applied to prevent the tence of warm, aqueous solutions. Hydrothermal penetration of water, but these will be subject to solutions are created when rain. snow. or iI"Oundwa- attack by chemical, eolaz- (ultraviolet), and seasonal ter penetrate the concrete mass and are warmed by (freezing and thawing) conditions that will occur in beat stored within the reactor. Over long periods of the coming centuries. Unless constant surveillance time. the reactor may actually act like a "beat and repairs an maintained for thouaanda of yean, enaine," encouraaini convection and circulation of the leachini of irradiated concrete and the nuclear auch aolutiona. materiala in the reactor may lead to sustained Portland cement concrete does not readily tolerate environmental contamination. The problems of-Cher-hydrothermal conditions for an appreciable time; the nobyl an especially critical in view of the number of reactors uistini around tbe world that must soon be decomm.isaioned. In the United Stat.ea alone, over 60 f GEO POLYMERIC STRUCTURE larp reactors an due for decommiuioninr durinr

II ( - I le-> the next decade.

I Si .Al ...;.. 0 - S i ) The rate at which other environmental problems

• ,,t\: are moun~ ia also aiannin,. Toxic dumps are

~f I:, 0 I 0 I 0 I beinr filled at a rapid pace. with few new sit.ea beinr .

developed. Vut acres of once-virrin land are beini

• 1 poisoned by abandoned mininr wastes laden with m I I I heavy metals and acidic aolutiona. Rivera and rround water are widely threatened, and in many caaea, AbcMt: The atructure of a geopotymer cryetal conelata of contaminants already exceed water quality stand-lillcon and aluminum ataN Inked together by atrong chemical bondl. floeitJvllly charged metal iona, provided by ards by several fold. The volume of hiiblY toxic fly the addition of metal-bearing waatN, are linked to the aah, a dustlike pollutant extracted from industrial geopolymer atructure at the negatively charged eltea in the chimneys, ia rapidly inc~. It ia imperative that llluatratlon. UnUke cement. geopolvmer'I do not rely on lime industrial wast.ea of hundreds of kinda be effectively and hence are not diuolved by acidic aolutlona. Below:

Thie photomicrograph of a thin aectlon of geopolymerized and aggreaaively dealt with if we an to preaerve undltone lhow8 the homogel1e01.11 nature of the cement public health and our ecosystem.

matrix eurrounding the undatone partlclee. Thia uniformity In order t.o prevent interaction of these hazardous

I" contrtbutN to the geopclyrnena' comprNaive atrength and contaminants with the biosphere, they must be solid-reaiatanoe to chemical attack and lhrinkage.

med or contained within an impermeable material I that will last for thousands of yeara. Such a product baa been developed-the result of a technolon that could eolve the problems of reactor entombment and

.I some of the stubborn environmental pollutante that plague modem civilization.

'I

• I GIOPOLYMIIIC CIMINT Ii

,:f This new technology ia actually one that belonged 11 to the ancients, one that was loni lost and has now J3 been recovered. The key to ihia discovery ia the

ia chemistry of geopol,,menzation; a new word for this ecience of the ancient world. The word implies a i _______________

geological origin, and the product.a of i9()polymeriza-tion can be effectively thourht of as synthetic rock .

172 THE WORLD & I

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The geoJX)lymerization process entails a number of low-temperature chemical reactions that bond mineral grains with a synthetic cement. The result-ing solid is characterized by properties similar to a group of clay minerals known as zeolites. Natural zeolites are formed during the interaction of mois-ture with clay minerals rich in silicon and aluminum.

The resulting minerals (zeolites) are characteristi-cally highly adsorbent and have well-known abilities

to immobilize toxic wastes.

In the basic geoJX)lymerization reaction, a slurry of rock particles and a mineral binder are mixed at

. room temperature; once hardened, the mixture has

' the integrity of natural rock. Phenomenal compree-atve and tensile strengths, beat stability, freeze-thaw resistance, hydrothermal tolerance, acid resistance, long-term durability, and the appearance and beauty of natural stone can be achieved with this synthetic material.

Essentially, geopolymerization enables the manu-facture of tailor-made rock. This is an iinJX>rtant new tool for permanent waste solidification and disposal.

When, for example, high concentrations of toxic heavy metals are mixed with the geoJX)lymeric slur- Last February two lllaba of Umestone weighing a total of 700 ry, the geopolymeric reaction develops a metal-rich pounds fell from the shoulder of the Sphinx at Giza. Egypt. A

• synthetic rock comparable to the ore from whence team has been attempting to restore the ancNtnt monument, they came-except that, unlike natural ores, the using modern stone that contrasts sharply with the original material. Geopo/ymer9 offer a more compatible matenal to i!Opolymerized equivalent ia impenetrable to circu- rebuild this and other ancient atn.,ctures.

latinQ' ,roundwater and hence environmentally safe.

The key to the quality of the synthesized solid is the geopolymeric binder, which rivals the natural DISCOVIIY AND DIVILOPMINT siliceous binders responsible for adhesion in sedimen-tary rocks like sandstone and limestone. These rocks GeoJX>lymeric binders were developed in France by consist of fniments of older rocks held together by chemist Joseph Davidovits, the founder and director a binder, or cement, made of silicon or calcium of the Geopolymer Institute, a private research carbonate; in effect, they are examples of nature's group in Saint Quentin, France, and director of the concrete. By combining an aggregate of natural rock Institute for Applied Archeologjcal Sciences (IAPAS) with a geopolymeric binder, what took nature eons of Barry University near Miami.

to accomplish is achieved in seconds, minutes, or An expert on ancient cement technology, Davido-hours, as the application requires. vits has characterized popolymeric bindinr aa beinr For modern researchers, geopolymers are versa- comparable to ancient cements that have survived tile, apace-age materials, possibly the most impor- climatic erosion for thousands of years. A number of tant since the development of plastics, with numer- ancient cements demonstrate far more structural ous potential variations and applications. Last June integrity than modem portland cement. The Roman an international symposium, Geopolymer '88, was cement of antiquity ia well known for its durability.

held at the University of Technology in Compiegne, Recent excavations and under/water exploration of :

France, to bring toiether representatives from the ancient seaport city of Caeaarea. built by Herod acience and industry to explore the contemporary the Great of Judea. have publicized the superb and futuristic applications for geopolymeric materi- quality of Roman cement. Concrete breakwater ala. blocka have remained intact underwater after two f.i';,:

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AUGUST 1988 *173

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NATURAL SCIENCE AJntllDOI tered in waste management appli-cations. The prevention of envi-ronmental contamination can be

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approached through two methods:

( 1) creation of barrier structures

,j and (2) waste stabilization. Phys-ical barriers effectively seal off waate from the surrounding envi-ronment so that there can be no interaction between cor:itarnin&l'lts and local surface and ground wa*

ter. Waste that ia stabilized by

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aolidification or chemical neutrali-zation procesae.s is highly resist-ant to leaching should interaction with ground water occur.

Since geopolymeric cements are characterized by high strengths and resistance to highly acidic or A technician travels through the deeOlate Kam--Kolia mining area near rmmina, ~ly caustic solutions, they re-Ontario, monitoring samples of groundwater. Current plans cal for the iaolation of main the prime candidates for the mining wastes by constructing t>amn made of geopolymer. either the entombment of toxic waste dumps and nuclear a-enerat-thouaand years. The still-standinir Roman concrete ing sites or for the solidification and lona--term baths in Israel have withstood two thousand years stabilization of both radioactive and toxic wastes.

of hydrothermal conditions created by flowing hot aprinp. Older cement ia found in the Great Pyramids CofnAININO MINNo WASTU

. of Egypt, and it ia in good condition after 4,500 years.

The oldest known cement, 9,000 years old, is found Today, plans are being made for the containment in the ruins of Jericho, in the Jordan valley. of metal-laden acidic waste at the Kam-Kotia mine, By comparison, the geopolymer-baaed cementi- located north of Tirnrnina, Canada. The Kam-Kotia tioua system outperforms concrete made with port- mine was a lai,ie base-metal depoeit originally mined land cement. Modern repairs to the ancient Roman for copper, lead, and line. Abandoned in 1972. it baa baths in Israel have been rapidly detrrading due to since come to be considered the larirest a-enerator of environmental weathering. In Egypt, where ancient acidic mine waters in the Province of Ontario.

repair& cauaed no damage, repairs made with mod- During the orilina) mininr procesa the ore was

. ern cement have damapd the Great Sphinx. The finely crushed and treated with cyanide and acidic modern concrete used to repair other treasured baths in order to remove the metala. The remaining

• monument.a of Egypt, such as the Step Pyramid of watery sludge, or "tailinp," still rich in iron. copper, Pharaoh Zoeer (2760 a.c.) have cracked within 30 zinc, anenic, and a number of other metals. was then years. These concrete blocks had to be replaced with pumped out to large containment ponds around the limestone blocks from local quarries. Geopolymeric mine.

cementa and concretes are ideal for producing a Using containment ponds to store tailinp is a

• laatm, restoration of the Sphinx and other monu- common mininr practice. In theory, containment menta. ponds serve to sto~ the tailinp while the liquid Like their ancient counterparts, modern geopoly- portion either evaporates, ia treated, or ia diluted by mers experience practically no shrinkage or volume natural waters before the draina,e ia released down*

change. Geopolymeric cementa have been designed to stream. Ideally, the particulate matter in the tailinp endure the rugged environments of the higher lati- remains in the containment pond for perpetuity.

tudes and the adverse chemical conditions encoun- Dama of rock. sand, and clay constructed around the 174 THE WORLD & I

taillnp are designed to Isolate the surrounding for Kam-Kotia; current plans call for the complete environment from contamination. isolation of the Kam-Kotia tailings from both ground In practice, the tailinp ponds are commonly infil- and surf.ace water through the use of physical bar-trated by rain ud groundwater. In the past, the riers conBtructed of geopolymer. The most important dams of many tailinp ponds have been constructed component of this PI'Oil'am will be the placement of out of permeable waste rock or local aggregate, and a geopolymeric cap, over 80 acres in size, that will all tailinp ponds are susceptible to ~ by rainwa- cover the moet chemically offensive waste at Kam-ter. Repeated freezin1r and thawing also plays havoc Kotia. Abutting properly designed containment with containment strategies. >.. the water moves dams, the cap will prevent penetration of rain and through the tailings maas, it takes on a hiihlY acidic surface water through to the contaminated tailinp.

character, leacbini out metals from the surrounding In reality, the cap will be a number of individual tailings. The resulting effluent, draining out of geopolymeric tiles, linked together by flexible, water-the tailinp along earlier groundwater channels proofed joints that will allow it to bend or shift in or through permeable zones in the dams, ia often response to movement in the tailinp over time; in "leachate toxic"; in other words, a aerioua health effect, the geopolymer cap will follow the contour of

, .... , hazard. the tailings mass like a pliable skin.

• -* Before operations at the Kam-Kotia mine ceaaed. By entombing the tailings in this impermeable over 31 million cubic meters of tailings were dumped casing, interaction between contAroinanta and the in the areas surroundinr the mine. Pipes mounted on surrounding environment will be brought to a stand-treaties pumped out waste that eventually covered still. Effective reclamation of the area will be com*

over 300 acrea of northern Ontario wilderness up to pleted by covering the cap with a two-foot-thick layer 20 feet thick in some places. Almost 10 million cubic of fill and topsoil, which will then be landscaped with meters of tailinp were initially placed without any native vegetation.

attempt to avoid contaminating the environment. In Before the rediscovery of geopolymera by Davido-later years, *when tailings were pumped into desig- vita, such a solution could not have been either nated impoundments, breaches and leakaae eventu- technically or economically feasible. Concrete- and ally caused further contamination. plastic-based products can, of course, be aubetituted To stand on the Kam-Kotia mine at sunset ia an for geopolymers, but they inevitably break down eerie experience. The tailinp are now bard and under the advene effects of the tailinp environ*

compacted, and the fading glow of the sun over the ment.

dry fiats gives the impresaion of a rust-colored desert. The dead and blackened Thia di8')0Nl crew near Minneapoli8 cleans up paint-related solvents that trunks of a forest that once stood in the had percolated into the ground atte, !hey were improperty atored. Trapping auch wutae within geopolymeric matariala C0Uid be

• permanent IOlution to tailinp pond area cut Ion, shadows in hazardous wute dilpoeal.

the duak, and in the distance immense rock dumps are silhouetted against the eky. All ia 1ilent-notbinr grows, noth-inl Uvea on the vast expanse of the tailinp. Even the streams and marshes of the once thriving Ontario wildernesa IWTOunding the tailinp have been con-taminated. The Kam-Kotia mine and the 1urroun~ area have effectively be-come a biolOi'ical desert.

Because of their resistance to acidic conditions, geopolymen are thought to be the aolution for the problems of Kam-Kotia and other mines like it. D. Comrie Consulting Ltd. has already carried out the initial phaae of a rehabilitation study r45..,..~

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AUGUST 1Q88 175

NATURAL SCIENCE AJntl EDGI Studies by the U.S. Army Corps of Engineers waste is exposed to a leaching solution.

indicate that geopolymeric cements also have super- In Ontario, stringent guidelines have been devel-ior resistance to chemical attack and remain intact oped t:o determine whether or not a waste is leachate after over 3,000 cycles of freezing and thawing. Their t.ox:ic. Solidified waste is first crushed to a fine grain tests also confirmed the cement's ability t.o develop size before immersion and tumbling in a circulating high structural strengths. Testing performed by acidic bath for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Following this rigorous Davidovits on geopolymer-fiber mixtures indicates procedure, the acidic solution is examined for concen-that strengths of up t:o 55,000 pounds per square inch trations of contaminants that may have been leached can be achieved. Other testing done by D. Comrie out during the process. During the course of testing, Consulting on . geopolymer and sand mixtures de- leachate levels of radium and practically all heavy

.monstrates that approximately 75 percent of t:otal metals examined have been found to be reduced after strength can be achieved after a cure time of only geopolymerization, usually by a factor of several two days. Equivalent and higher strengths can be times less than that required by regulatory stand*

attained through the use of aggregate and smaller ards.

portions of geopolymers. Successful results have been obtained in the sta*

In short, geopolymeric cement provides many ad* bilization of tailings generated by both base and

• vanta,ea in constructing any barrier to be used in precious metal mining operations, from low-level waste containment. Its most important features radioactive mine tailings, from metal plating wast.es, include high structural strengths, short curing and from paint sludie& developed during manufac*

times, and resistance to chemical attack. conditions tu.ring processes.

• of high acidity, and repeated freezing and thawing. Geopolymerization of the mine tailings resulted in the development of a highly cohesive solid. In con*

5tAIIUUrtON Of WASTI trast. geopolymerized paint sludges remained ip a .

plastic form but were nevertheless rendered leachate

• Waste can be stabilized by either rendering par- resistant.

ticulate matter chemically innocuous or by creating Similarly, tests of uranium tailings reduced radi*

a monolithic solid. The criterion for successful stabil- um concentration, to levels far below acceptable ization ia, of course, the toxicity of the leachate; emission criteria set by the Atomic Enera Control ideally, the leachate never reachea levels considered Board of Canada. Geopolymerized tailings with ex* .

harmful, rea-ardless of the length of time that the pected concentrations of at least 400 picocuries per

..... The leaching of toxine from mine 0) tailings by even mildly acidic ao-

. . - ~ ~ - ~ ~...-.- 7 ~ lutiona can be prevented by en-

~ casing the waste in geopolymer.

Thia chart shows the concentra*

tiona of various metals in the

.,Q) leachate of untreated waste, E contrasted with ttiat of geopo-lymerized samples. (Concentra-8Q) tions are based on milligrams of

...J toxin per kilogram of waste aub*

,ected to leaching.)

.,0 en en 0

...J 171 THE WORLD & I

liter (pCVl-the curie ia a standard measure of radioactivity) of radium give results as low as 18.7 pCi/1. .

• I tl: ~

'1, MAnllAL Of THI fUTUII

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With the unique chemical and structural proper-ties that characterize eeopolymers, new applications arise almost on a daily basis. Geopolymera have already been introduced by an American concrete manufacturer, producing a hybrid buildini stone of extreme durability and structural strength. Result.a from present testing suggest that geopolymera are Thia ingot ooneiet1 of geopclymerized beuxite mining wa1te.

deatined t.o have an enormous impact on the t.oxic Geopolymerized IOlide are euily molded and hive high eur-waate industry. As barrien, geopolymera can be used face amoothnNa.

t.o creat.e on-site bases, walls, or cape for t.oxic-waate or mine-waste dumps: Their resistance t.o chemical rocket and space shuttle applicationa. Corroded un-deterioration makes them ideal in many waste appli- der,round pipee can be replaced by ,eopolymer-cationa. baaed pipes with hirh flexural stren,tba. Providinl Old. wut.e dumps can be. *rehabilitated through hardnesa, flexibility, and lonrevity.

encapsulation, and new waste solidified and made Inaccessible areas allO benefit, because a small aa.fe aa it ia produced. Toxins that were once trans- proportion of a ,eopolymer can be added t.o locally ported at great coat t.o designated dump sites can available materiala t;o create hirh-quality cementa, now be solidified and safely disposed in municipal without the neceaaity for transportation of raw ,oocls landfills. In fact, work at the University of Toront.o over a rugged countryside.

is currently addressing the possibility of converting The pouibilities 10 on, and more will arise as waste renerated by bauxite minine int.o high~uality research continues on thia lone*loet cement. What bricks and ceramics that can be employed in the better way t.o immortalize ancient civilizationa than construction industry. AB an added feature, the t.o recreate their materiala to solve the problema of zeolitic properties allow eeopolymerized cement.a to today?

at.ore water taken in from the atmoephere, releasin1 it durinr times of intense heat and dryness. Davido- ADDfflONAI. IWNNG vita observes that rrain eiloe constructed of a ma~

rial able t.o maintain a constant humidity would C,omrie, D.C., Patenon. J.B. aad Ritce,, D.J.' Gtopolpwr likely have impreaaive capabilities t;o preserve food ..<tpplicaliou i" IAI Jli"i"' lflllMll,r. Proc:eedmp of t.be 20t.la and eeed over long periods of time. Cantdien "'1Denl ProceNon Auul ()pent.on Coaferace. C..

udiaa Iut.ituw of l&1nr aad Metal.hu-n', Ottawa. Ontario, Jaa.

The nuclear industry also stands to rain immea- 1988.

surable benefit .from the qualities of ,eopolymera. DaYiclcmta, J. "Allciellt and Modern Coacmee: What la t.be

.The current d.iaposa1 technologies under examina- Real oor,rencer Coftcr,111~ (Dec. 198'0: ~28.

tion. iucb aa salt mine and deep abaft st.orage, depend Danicmta, J. aad Worril. M. n, lyofflidl: A" lliti,iu

, upon the isolation of radioactive waste from circulat- SolNd, Hippocnu Book.I IDc:., Nn Yon. In prodw:tioL Morria, M. "Arc:baeoloa ud Tecluiolor,," Cotlcr,11 ,,.,,,,.._

inr ,roundwater: reopolymerization could provide tiollOl (Dec. 198'1): 28-36.

the ideal solution of encapeulatinr the waste before stora,e. And how much safer ent.ombment would be with a one-time application of 1eopolymera, instead of repeated applications of lesser products.

Of course. other applicationa preaent themaelvea Dou,llu C. ea.,;, ii 1A1 pruidnt of D. d.,;, Couulliftf W, Cl IINMtl IIIO.,.,,..,,.I caflll t11illl ffl1i11Hri71f COIIIJ'C111¥ Nlf4 i" and can only be briefly addressed at this *tare of Jli.muollfG, O!Ulario, C.Mdo. Hi, wori OIi ffOJKHpwtl YI 11,,,.

development. Geopolymer stability at intense tem- corrifd WI ill COlljallCholl tfi,A 1',r,tdt . .wal "'filNlf' Joa,pA peraturel makee it a promisiq aaent for ~ in Do~.

AUGUST 1988 177

1

' 1 2

3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOCK TEO USHRC

• 94 F f"! - 4 P 4 44 4 PUBLIC SCOPING MEETING 5 ON THE ENVIRONMENTAL IMPACT STATEMENT (EIS )

6 FOR SHIELDALLOY METALLURGICAL 7 CORPORATION FACILITY -- CAMBRIDGE, OH 8

9 10 Meadowbrook High School 11 Auditorium 12 58615 Marietta Road 13 Byesville, Ohio 14 December 13, 1993 15 16 17 18 19 The above-entitled meeting was held, pursuant to 20 notice, at 7:15 p.m., Michael Weber presiding.

21 22 23 24 25 ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W ., Suite 300 Washington, D.C. 20006 (202) 293-3950

1 PARTICIPANTS:

2 ,

2 3 PRESENT ON BEHALF OF THE NRC:

4 5 Michael Weber 6 Chad Glenn 7 Mike Mccann, Region III , Fuel Facilities &

8 Decommissioning Section 9 Barbara Stinson, Meeting Facil i tator 10 11 PRESENT FROM THE PUBLIC:

12 13 Scott Eaves 14 Tom Laughman 15 Carolyn Arnold 16 Art Valentine 17 Mayor Shaub 18 Deborah Lorz 19 Greg Nageotte 20 David Ellison 21 Sherwood Bauman 22 Chris Trepal 23 Bob Greenbaum 24 John Perera 25 ANN RILEY & ASSOCIATES, LTD.

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3 l PARTICIPANTS, CONTINUED:

2 3 John Sedor 4 Joe Latchik 5 Bill Davis 6 Jack Dunning 7 Brenda Hibbs 8 Greg DeDinato 9 Tony Celebrezze 10 William T. Oliver, II 11 Nancy Howard 12 Michael Finn 13 Matthew Bennett 14 Barbara Miller 15 Melvin Eubaniks 16 James Jewel 17 Michael MacMurray 18 19 20 21 22 23 24 25 t

I.

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4 1 P R O C E E D I N G S 2 [7:15 p.m.]

3 'MR. WEBER: Good evening. My name is Michael 4 Weber. I am here from the Nuclear Regulatory Commission, 5 from Rockville, Maryland, a suburb of Washington, D.C. I am 6 pleased to be with you tonight. I am looking forward to a 7 productive interchange. We are here to hear what your 8 concerns are. We are also prepared to share with you some 9 background information regarding the Shieldalloy 10 Metallurgical Corporation facility in nearby Cambridge 11 half-way between here and Cambridge, Ohio.

12 I certainly want to express my appreciation for 13 your turnout*. Like I said, we are here to hear your 14 comments and the issues that are of concern to you. That is 15 our principal objective in being here tonight. We are at 16 the very early stage of a process which, if everything goes 17 according to plan, will be played out over the next two 18 years or so in the development of what is referred to as an 19 environmental impact statement, which the NRC will prepare.

20 And the purpose of tonight's meeting -- and I will get into 21 this in more detail later on, but I just want to set the 22 stage at this point -- is to hear and share with you about 23 the project that we are focusing on.

24 I also want to express my appreciation to the 25 Meadowbrook School. This is certainly about the best kind ANN RILEY & ASSOCIATES, LTD.

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5 1 of facility that I have been in in public meeting, and I 2 think it is a tribute to the citizens of the local 3 community.

4 Several months ago, Shieldalloy Metallurgical 5 Corporation proposed to the NRC staff that the radioactive 6 waste currently at their facility in Cambridge would be 7 stabilized onsite as part of the decommissioning operation.

8 My presentation a little bit later on and the presentation 9 of Chad Glenn, will hopefully illuminate for you what that 10 means and also how we plan to address that and evaluate it 11 as part of our process.

12 I want to call your attention to several documents 13 that are on the back table. If you did not get them, please 14 don't get up. You will have plenty of opportunity later on.

15 But, I certainly want you to be aware of them. One document 16 is a summary of the slides that Chad Glenn and myself will 17 be using tonight. There is also another document that is

- 18 19 20 caused the Action Plan for Timing and Clean-up of Site Decommissioning Management Plan Sites. That gives you kind of a policy, regulatory background on how the NRC -- the 21 Nuclear Regulatory Commission -- approaches these kinds of 22 decommissioning actions.

23 There is a general summary and background 24 information on radioactive material and radiation and 25 general. That is for your information. Then there is the ANN RILEY & ASSOCIATES, LTD.

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6 1 notice that we refer to as the Scoping Notice, which was 2 published several weeks ago in a document called the Federal 3 Register. That provides, in gory detail, the scoping 4 process, what we are about here tonight, and what we would 5 propose as an agency of the Federal Government to carry out 6 over the next two years.

7 The other document I will call your attention to 8 is a small publication that looks like this. It is called 9 the Public Document User's Guide. This document summarizes 10 for you how you, as a local representative or citizen, or 11 just an interested individual can access information that is 12 in NRC's files that may be pertinent to this particular 13 licensee.

14 At this point, I would like to turn the meeting 15 over to Barbara Stinson .. Barbara is joining us tonight from 16 the Keystone Center. She will describe to you a little bit 17 about what the Center is and what it does, and facilitate 18 19 20 the rest of the meeting.

Stinson.

So, without further ado, I give to you Barbara

• 21 MS. STINSON: Thank you. As Mike said, my name is 22 Barbara Stinson.- You will get an opportunity to meet the 23 other gentlemen at the table here this evening shortly.

24 Let me start by just introducing you to the format 25 for this evening and a few details about how we hope to ANN RILEY & ASSOCIATES, LTD.

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7 1 conduct this session. It is a little bit out of the 2 ordinary, in that it is a public hearing, per se, but it is 3 also an information exchange opportunity. So, we try to 4 structure the discussion so there will be more opportunity 5 for question and answer and understanding of particular 6 perspectives regarding the decommissioning of the facility 7 in question.

8 Let me say, first of all, you may have received as 9 you came in the front door, a description of the public 10 meeting process for this meeting. I just want to call your 11 attention to the first three bullets. They are in fact the 12 purpose behind this meeting and what we hope to accomplish.

13 And really what my role is here is to help and assure that 14 we accomplish the following things: Increasing an 15 understanding of the technical information that is before us 16 and the actual alternatives that have been proposed and will 17 be under consideration.

18 This is your opportunity to effect those 19 alternatives and the alternatives that will be analyzed by 20 NRC and any cooperating agencies. And we will talk more 21 about what that means, "cooperating agencies" -- and also 22 just to encourage communication on the issues amongst 23 .members of the community.* So, that is the "Community, 11 with 24 a capital "C," including members of the local community, 25 regional representatives that are here from environmental ANN RILEY & ASSOCIATES, LTD.

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8 1 organizations, state representatives that are here on behalf 2 -- as elected officials, and state and Federal Government 3 representatives who are also here. So, as I said, we are 4 trying to encourage that communication and cooperation as a 5 big part of this meeting. And it is just the beginning of a 6 process that will hopefully build on that throughout the 7 next year or how ever long the scoping and actual EIS --

8 Environmental Impact. Statement process goes.

9 The last bullet item is specifically to receive 10 comment on proposed -- the scope of the proposed EIS and 11 also on the onsite disposal alternatives. There are five 12 alternatives mentioned. But, as Mike mentioned already, the 13 licensee has proposed onsite disposal, and that is what 14 brings about this entire process.

15 So, we are looking forward to just general 16 discussion that will illuminate your ideas on that disposal 17 alternative, but also specific comments during the public 18 comment period.

19 Please note that this is the first of several 20 opportunities for input. Don't feel pressured that you have 21 to speak tonight. Don't feel pressured that it is your only 22 opportunity for input into the agencies that are here to 23 listen to you. You can do it in writing. As Michael 24 described, there is a lengthy public participation process 25 that goes along with the development of an Environmental ANN RILEY & ASSOCIATES, LTD.

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9 1 Impact Statement and so tonight you can sit back and get 2 just get information if you want and formulate your opinions 3 and register those in many other forms later on down the 4 road.

5 The other point to make is this is hopefully an 6 exploration meeting. We are here to explore the issues, 7 explore the alternatives, discuss the ins and outs and 8 impacts of all of those. It is not a decision-making 9 meeting. No one will walk away from this meeting and say X 10 or Y will happen. So, you can breathe a little bit of a 11 sigh of relief on that. But, it doesn't remove the 12 importance of this meeting and the importance of this input 13 opportunity.

14 Mike introduced that I am with the Keystone 15 Center. So, I will tell you a little bit more about my role 16 here at this meeting and what the Keystone Center is. We 17 are a non-profit, neutral mediation organization. That 18 means that we are neutral, in the sense that we are process 19 advocates. We try to established fair and balanced 20 discussion opportunities on specific environmental natural 21 resource management issues. So, I am basically here to 22 assist all of you all in conducting a productive meeting, 23 and having an opportunity to speak, and ensuring that people 24 listen to each other. So, you may notice me being a traffic 25 cop over here, insisting on people not interrupting one ANN RILEY & ASSOCIATES, LTD.

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10 1 another. That should be one of our ground rules, on not 2 targeting any comments to any personal -- either an 3 individual or a personal characterization of anyone. So, 4 keep your comments slated towards the issues at-hand and not 5 towards individuals. And, as I say, it is going to be 6 important to give the people that are at the microphone and 7 people that are speaking from the audience your full 8 attention. Don't interrupt them. I will be assuring that 9 we have one person speaking at one time.

10 So, if there are no questions about that general 11 process and those ground rules, I am going to describe a 12 little bit the agenda and the structure for this meeting.

13 Any questions or comments at this point?

14 [No response. ]

15 MS. STINSON: Okay. Pull out your agenda. It is 16 the one-pager that describes the course of the evening. We 17 will be moving right into presentations of information 18 shortly. During this period, two members of the Nuclear 19 Reg1,1latory Commission, two employees from headquarters in 20 the Washington, D.C. area will make presentations of 21 information that hopefully will lay out some factual 22 information and offer you an opportun~ty to ask questions 23 about that information. So, we will first have a site 24 description and status presentation and a short question and 25 answer period after that for questions of clarification ANN RILEY & ASSOCIATES, LTD.

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11 1 only. This is not the opportunity for you to express your 2 views on anything presented, but rather, just ask questions 3 to make sure you understand it.

4 The same with the second and third bullets. We 5 will get a description of the alternatives. NEPA is the 6 National Environmental Policy Act, which the development 7 of an Environmental Impact Statement, an EIS, is*brought 8 about under the jurisdiction of this Act, and you will have 9 an opportunity to understand more of the scoping process, 10 the timeline involved, the various benchmarks that take 11 place during the scoping process.

12 Hopefully, by 7:45 or shortly thereafter, we will 13 be moving into the public comment period. We have 14 structured this discussion to offer an opportunity for all 15 of us to hear from specific interest groups all at the same.

16 time or by category. So that, first, we will listen to the 17 Shieldalloy Metallurgical Corporation representatives make a 18 brief presentation about the issues of concern to them and 19 some general facts, and then have a short question and 20 answer period if there is time. Then any representatives 21 that are here, local officials or as elected officials or 22 local government will have an opportunity for 15 minutes to 23 offer their perspectives, and we will move on accordingly 24 throughout the schedule.

25 Now, let me say that this is a general break-out ANN RILEY & ASSOCIATES, LTD.

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12 l of the timeframes. We may be somewhat flexible about the 2 timeframes. We are going to insist that people not take 3 more than 15 to 20 minutes for their entire interest group 4 presentations. So, pay attention to -- if we have four 5 people, then obviously, you are going to have to take less 6 than five minutes a person for your presentation. Again, we 7 want to get a flavor of the concerns and interests that are 8 represented by that group. So, that is the purpose of each 9

10 11 of those discussions.

Then, at 9:30, hopefully we will have time for an open discussion, where you can ask each other questions, you 12 can ask the NRC, you can ask the licensee questions, you can 13 explore issues that have come up as a particular concern to 14 you.

15 We will take closing comments at 9:55. Unless 16 this group wants to go on longer, and we get agreement on 17 that, we will adjourn at 10:00 o'clock.

18 This entire meeting is going to be transcribed.

19 If you signed up in the back, on the right-hand side, on the 20 general sign-up sheet, you will receive a copy of that 21 transcript. You may be sorry. It is probably going to be 22 very thick. There are also plenty of other documents back 23 there. And, if you want to, note next to your name any 24 special documents that you would like to receive that are 25 not listed back there -- you can do that.

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13 1 Do be sure that you sign in so that we know you 2 are here. Let me see if there are any questions regarding 3 the agenda and the format for the evening.

4 [No response. J 5 -MS. STINSON: Okay. Good.

6 Let's move into the opening presentations.

7 MR. WEBER: By way of introduction, if I didn't 8 introduce myself earlier, I am Mike Weber. I am a Section 9 Leader -- out at the office of Nuclear Materials Safety and 10 Safeguards in Washington, D.C. With me tonight is the 11 Project Manager -- the NRC Project Manager for the 12 Shieldalloy facility, and that is Chad Glenn, sitting in the 13 middle of the table. Chad will make the next 9resentation.

14 We are also fortunate to have with us tonight several 15 representatives of our Region III Office, located just in 16 Metropo~itan Chicago. With us at the table.is Michael 17 Mccann, who is the Section Leader of the Fuel Facilities and 18 Decommissioning Section at our Region III Office.

19 So, without further ado, Chad.

20 MR. GLENN: Okay. Good evening ladies and 21 gentlemen. What I would like to do in this segment is offer 22 just a brief overview of the site, a description of the site 23 and follow that. But, first I would like to start with a 24 little bit on NRC involvement.

25 Shi~ldalloy Metallurgical Corporation possesses -

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14 1 - has an active NRC license from the Nuclear Regulatory 2 Commission, which authorizes them to possess uranium and 3 thorium. NRC refers to this material sometimes as source 4 material. The Vanadium Corporation of America initiated 5 operations at the site in 1953. Foote Mineral Company --

6 Vanadium Corporation of America merged with Foote Mineral

7. around 1970 and Shieldalloy purchaned the facility in 1987.

8 The facility imported and processed niobium ore to 9 produce a ferro-columbium alloy from the '50s, all the way 10 up to the early '70s. I want to point out that niobium is 11 not a radioactive material. It is a metal used to harden 12 steels. However, "the' niobium ore does contain trace amounts 13 of uranium and thorium, which is what we refer to as source 14 material.

15 The Shieldalloy Corporation continues to process 16 ferro-vanadium to the present day, but the processing of 17 source material was ended prior to the Shieldalloy purchase 18 of the facility in 1987.

19 Decommissioning at the site was initiated in 1988 20 and continues to the present. Shieldalloy has -- their 21 cleanup -- their decontamination activities have been 22 effective in cleaning up the radiological contamination over 23 most of the site.

24 NRC has conducted, with its contractor, Oak Ridge 25 Associated Universities, three radiologicai surveys and has ANN RILEY & ASSOCIATES, LTD.

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15 1 confirmed that the contamination on the site presently is 2 limited to two slag piles.

3 I want to move now to just a picture of the site.

4 As most of you are probably aware, the site occupies 5 approximately 130 acres situated between Cambridge and 6 Byesville, Ohio. It is bounded on the north and east by the 7 Conrail property, on the s.outh by Route 2 O9, on the west by '

a Chapman Run.

9 The focus of this discussion, as you are aware, is 10 on the ultimate disposition of two slag piles. I want to 11 point out the east slag pile and the west slag pile. The 12 east slag pile occupies about two and a half acres and 13 contains about a million cubic feet of low-level waste. The 14 west slag pile occupies seven and a ~alf acres and contains 15 approximately six million cubic feet of low-level waste.

16 I think it is also important to point out that the 17 groundwater beneath the site generally moves from the east

- 18 19 20 to the west. The surface water generally moves from the southeast to the northwest.

Chapman Run is a small stream on the western 21 portion of the property. It runs north and flows into Wills 22 Creek, approximately a thousand feet north of the property.

23 As far *as* the Shieldalloy process, niobium ore, 24 which contains the natural uranium and thorium, is taken to 25 the facility. This ore contains approxi.tmately two percent ANN RILEY & ASSOCIATES, LTD.

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16 1 thorium and .04 percent uranium. In the process, the 2 niobium is extracted and used as a metal alloy in the steel 3 industry. The slag from the process is stored onsite.

4 Now, this is what the form of the slag is today.

5 This is a fair advanced slag. It is not source material.

6 It is not regulated by NRC. It is similar to the form of 7 slag -- the ferro-columbium slag. As you can see, it is 8 very dense and this is what it looks like.

9 I would like to now turn to the radionuclides we 10 are going to look at. The radionuclides that are in this 11 slag are basically the radionuclides in the uranium decay 12 chain and the uranium-238 decays and this is the decay 13 chain for uranium. We are going to be talking about I

14 uranium-238, but we are actually looking at all of the decay 15 products of uranium 238. Likewise, thorium is the -- is 16 also regulated by the NRC and, like uranium, this is the 17 decay chain for thorium. We looked at all of the 18 radionuclides in the decay chain.

19 The next slide. I would like to talk a little bit 20 about the concentrations in the east and west slag pile. As 21 we indicated, the primary radionuclides are thorium-232, 22 uranium-238 and radium-226. The quantity of radioactivity 23 or activity is measured in curies. Generally, the larger 24 the activity level, the greater the potential health hazard, 25 if the material is not controlled properly.

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17 1 In the environment, the activity of these 2 radionuclides are typically described in terms of 3 picocuries. A picocurie is one-trillionth of a curie. We 4 have a brochure in the back, I believe, Mike --

s MR. WEBER: Yes.

6 MR. GLENN: -- that describes some of these terms.

7 If we look at the east slag pile first, we can see 8 that the concentrations in the east slag pile are thorium-9 232, is four picocuries per gram; uranium-238 is 21 10 picocuries per gram; and radium-226 is 66 picocuries per 11 gram.

12 In the west slag pile, the pile is really divided 13 into two layers: A lower layer, which we refer to as the 14 original slag, and an upper layer which contains slag and 15 soil. This upper layer was slag that was placed on the 16 original slag in the process of cleaning up the site. The 17 original slag on the base has concentrations of thorium, 18 uranium and radium below five picocuries per gram. Average 19 concentrations in the slag and soil on the upper layer are 20 between 40 and so picocuries per gram.

21 One other point that I would like to point out is 22 that on the west slag pile there is no fence surrounding the 23 slag pile, however, there is a three-foot cover that is 24 depicted on your diagram. On the east slag pile there is no 25 cover. There is a fence that extends around the slag pile.

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18 1 Now, just for perspective, the next slide we are 2 going to get into is the average concentration of 3 radioactive material in the slag. Here the concentrations 4 of radioactive material in the east and west slag pile are 5 compared to NRC guideline concentration for unrestricted use 6 and natural background concentrations. By natural 7 background concentrations, I am referring to the 8 concentrations of uranium and thorium that would be expected 9 prior to any source material being processed at the site.

10 As you can see on the far left, background 11 concentrations of thorium-232, uranium-238, and radium-226, 12 are in the range of one to two picocuries per gram. NRC's 13 guideline for unrestricted release contains basically two 14 options: The option one level for thorium-232, uranium and 15 radium is five picocuries per gram; the option two limit is 16 restricted to thorium-232, and there the limit is 25 17 picocuries per gram. There are no option two limits for 18 uranium or radium, so the option one limits apply.

19 On the right, you can see the concentrations in 20 the west slag pile and the east slag pile, compared to those 21 guideline concentrations.

22 The next slide provides the exposure rates at the 23 Shield.alloy site. By exposure rate, this is basically the 24 gamma radiation in the air. The unit we use to measure the 25 gamma radiation in air is the micro -- is the micro ranking ANN RILEY & ASSOCIATES, LTD.

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19 1 or micro-Ras we refer to it.

2 In the environment, the exposure rates are usually 3 measured in terms of micro-R per hour. The background 4 exposure rates in this area, 10 micro-R per hour. NRC 5 guideline for unrestricted release of a site is background 6 plus 10 micro-R per hour, or NRC's guideline is actually 20 7 micro-R per hour.

8 The west pile, which has a cover, is essentially 9 at background. It is 23 -- average exposure rates are 23 10 micro-R per hour. The uncovered east slag pile has an 11 exposure rate of 115 micro-R per hour.

12 This chart I think clearly shows the effect the 13 cover has on absorbing gamma radiation. You can see the 14 difference between the west and the east slag pile, which 15 essentially is similar concentrations. Actually, the west 16 pile has higher concentrations on the upper layer, and the 17 cover has a significant affect on the exposure rate.

18 That concludes my presentation.

19 MS. STINSON: Let me just say that you have heard 20 a lot of information here and a lot of terminology used. I 21 am going to leave it to you to flag get my attention when 22 there are either phrases or acronyms that you don't 23 understa~d, and we will make sure we get those spelled.

24 Let's take about two or three minutes of questions 25 of clarification, if anybody has ones that they would like ANN RILEY & ASSOCIATES, LTD.

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20 1 to ask?

2 Yes, sir?

3 FROM THE FLOOR: You said that the 23 micro-R per 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> -- was the background radiation.

5 MS. STINSON: Excuse me. You are going to have to 6 repeat the question. Please repeat the question, and then 7 answer it.

8 MR. GLENN: I think the question was, as I heard 9 it -- I stated that 23 micro-R per hour was background. And 10 that is not -- I should clarify that. You are correct. 23 11 micro-R is not background; 10 micro-R is background. The 12 exposure rates over the west slag pile actually range 13 between six and 23 micro-R per hour. I have used the upper 14 range of that, which i$ 23. So, that is above background.

15 MS. 'STINSON: Yes?

16 FROM THE FLOOR: You point out the significance of 17 how much the count dropped when you cover it. My question 18 is is that for exposure airborne -- my question is, if you 19 cover that pile and it is raining and we have a heavy rain 20 and the area floods, and the water goes up underneath that 21 cover, and then it drains off into the wetlands that those 22 piles extend into, what happens to those numbers, as far as 23 far as the downstream migration?

24 MR. GLENN: If I understand it, your question is 25 what happens if you have precipitation -- you get a lot of ANN RILEY & ASSOCIATES, LTD.

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21 1 rain, and a lot of groundwater gets into the pile? Perhaps 2 the water table gets higher or you get water getting into 3 the pile from underneath the pile, or from above the pile?

4 What is the effect of leeching the radioactive material out 5 of the pil~ and downstream, offsite? I don't have an answer 6 for that. I think that is a question that we intend to look 7 at these types of scenarios in the Environmental Impact 8 Statement and we would expect to evaluate those in the 9 course of doing this EIS. I think that is all I would like 10 to say. We can look at this rock and say it looks 11 relatively dense, and leech-resistent, but, in fact, we have 12 not conducted tests that demonstrate that, so I cannot -- we 13 would have to look at that and evaluate that in the EIS 14 process.

15 FROM THE FLOOR: What have been the tests that you 16 have done?

17 MR. GLENN: This leechability test -- what tests 18 have been done to the slag? And this slag -- the licensee 19 has done leechability tests for slags of this nature at 20 their Newfield, New Jersey facility. Based on that 21 information, the slags in the Newfield, New Jersey facility 22 are very leech-resistent, from the tests that they have 2~ conducted. So, if th~se are sim~lar slags, we might expect 24 similar results; but, the fact is that these tests have I not 25 been conducted on these slags.

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22 1 MS. STINSON: Any other questions of 2 clarification?

3 [Show of hands.]

4 MS. STINSON: We will take one, maybe two more.

5 FROM THE FLOOR: My colleague here mentioned the 6 wetlands on the site. Maybe you could show the map again.

7 Have these wetlands been delineated? Has there been any 8 function or value assessment done to these wetlands?

9 MS. STINSON: The question is have there been an 10 examination or delineation of the wetlands on the site.

11 MR. GLENN: I don't think adequately, to answer 12 your question. We know that the slag piles are adjacent to 13 wetlands. They are also in the 100-year flood plain. Both 14 of those concerns need to be evaluated in the Environmental 15 Impact Statement.

16 MS. STINSON: Any other questions from anyone 17 else?

18 [Show of hands.]

19 MS. STINSON: Right here?

20 FROM THE FLOOR: That one slide that shows the 21 gamma rate -- how far down is that?

22 MR. GLENN: Well, it depends on the --

23 MS. STINSON: Please repeat the question.

24 MR. GLENN: She wanted to know how far gamma rays 25 will travel. A gamma ray being essentially like light, as ANN RILEY & ASSOCIATES, LTD.

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23 1 it is the same type of energy, a photon-type energy, will 2 travel quite far. It can go miles, or it can go inches, 3 depending on what is in between it and the type of 4 radioactive material. Do you know what the average gamma 5 ray field is? Okay. But, it can go far.

6 FROM THE FLOOR: Will it go through the 7 uncovered 8 MR. WEBER: I think what we can do I think that 9 was what we were going to talk about at the end of the 10 meeting -- more technical information. We will give you 11 what you need as a clear background of what Chad has 12 mentioned earlier, the magnitude of the radiation levels 13 being measured. In other wqrds, it is directly proportional 14 to the radioactive material that is there in the quadrant.

15 So, I think we can scope that a little bit better.

16 MS. STINSON: The purpose of the public comment 17 period is to raise issues of concern, just like that, and to 18 explore them a little further. So, we will have plenty of 19 time to do that.

20 Let's move on to the second part .of the 21 presentation.

22 MR. WEBER: We will address the question. I am 23 getting-the sign from the facilitator, so I better move on.

24 By way of overview, what I plan to do, as a 25 follow-up to the previous presentation is to overview for ANN RILEY & ASSOCIATES, LTD.

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24 1 you the NEPA process which was briefly touched on earlier, 2 describe what an Environmental Impact Statement and what is 3 the purpose of the scoping process here tonight, and the 4 period that ensues. I will also talk about the proposed 5 action being onsite disposal of the radioactive waste that 6 already exists at the Cambridge Facility. I will talk about 7 alternatives to that proposed actions, or at least those 8 alternatives that the NRC would propose to consider as part 9 of its evaluation. I will talk about what impacts we would 10 evaluate associated with those alternatives and then end 11 with an overview of when will the EIS be available and what 12 is the schedule for developing and what additional 13 opportunities are there for public input to the process.

14 And Environmental Impact Statement is basically an 15 evaluation* of the environmental impacts associated with the 16 proposed action. Now, that is a mouthful. What we do is we 17 identify alternative actions, as well as the proposed 18 action, and then we try to estimate or project what, if any, 19 environmental impacts would be associated with that. In 20 other words, would we expect that there would be some risk 21 of accidents because trucks would be driving down the road,

• 22 as part of one alternative? Would there be airborne 23 emissions of either a toxic material or a radiological 24 material? What is the impact on the workers that might be 25 engaged in moving material around as part of the ANN RILEY & ASSOCIATES, LTD.

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25 1 alternatives? These are all of the sorts of things that we 2 evaluate. I will describe a little bit later on what 3 specific impacts we would propose to consider.

4 It also assists us. It is important to the NRC 5 because we-use it as the basis for our decision-making 6 process. NEPA was enacted by Congress to ensure that the 7 agencies did not take major Federal actions without first 8 evaluating, in a deliberative process, what are the impacts 9 and what alternatives exist that might reduce those impacts 10 on the human environment. That would include impacts on the 11 environment in general. In addition to all of these good 12 things, it is also required by the law and by NRC's 13 requirements in 10 CFR Part 51. CFR stands for the Code of 14 Federal Regulations.

15 Now, the scoping process that we are here tonight 16 as part of the public meeting is just the first part of the 17 development of the EIS. So, we haven't made any decisions 18 at this point, other than the decision to in fact prepare an 19 Environmental Impact Statement and to hold this public 20 meeting as part of the scoping process.

21 Basically, you can summarize what we are about 22 here tonight as is the NRC on the right track? Are we 23 considering the right kind of alternatives that are feasible 24 or viable for this facility? Are we plaruiing to evaluate 25 the right kind of issues or environmental impacts? What we ANN RILEY & ASSOCIATES, LTD.

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26 1 would like to hear from you, if you believe that we have not 2 identified them appropriately, that is what we are here to 3 hear. If you believe that there are alternatives that we 4 have not identified, if you believe that there are impacts 5, that we have not identified, we would like those comments 6 here tonight or in writing from you before January 15th.

7 . Also, there is the general issue of are there 8 other issues besides just the impacts and the alternatives 9 that should also be considered as part of the development of 10 the Environmental Impact Statement?

11 Briefly, let me overview the alternatives that we 12 have identified in the notice that is available at the back 13 of the table. The licensee's proposed action is to dispose 14 of the radioactive waste that currently exists on the site 15 at the site. And something -- I will be going into more 16 detail in this briefly -- but just let me overview the 17 general alternatives that have been identified. What NRC 18 has tried to do is come up with a suite of alternatives that 4lt 19 reasonably bounds the type of alternatives that may exist, 20 all the way from leaving all of the radioactive waste

21. onsite, to taking it all offsite. So, you can see that that 22 pretty much spans the spectrum.

23 The other alternative involve the offsite removal 24 of the contamination. In this scenario, the material would 25 be removed from the Cambridge facility and disposed of ANN RILEY & ASSOCIATES, LTD.

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27 1 elsewhere.

2 There is also an alternative of doing some 3 processing onsite, which may be useful in reducing the 4 volume or reducing the hazards of the waste t~at cu£rently 5 exist onsite, perhaps with offsite disposal of some of the 6 higher concentration material. There is also an onsite 7 processing by bringing in relatively clean soil and diluting B the contamination to reduce the average concentration, thus 9 protection any people who may, in the long run, penetrate

• 10 11 12 into that waste and become exposed.to it.

And the final alternative is the no-action alternative. Now, by raising it, we are not saying that we 13 are proposing to take no action at this facility. Let there 14 be no mistake about that. The no action alternative 15 provides us a baseline against which to compare the other 16 four previous alternatives.

17 Briefly, onsite disposal would primarily consist 18 of the type of disposal activity that Shieldalloy has*

19 already engaged in stabilizing the west* pile, or some sort 20 of earthen cover of some design or another would be placed 21 over the waste, perhaps used to be used of the material that 22 is already on top of the west pile in the form of a cover.

23 Perhaps some other alternative would have.to be used as part 24 of an onsite disposal. But, the principal components here 25 would be using some combination of engineered material, as ANN RILEY & ASSOCIATES, LTD.

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28 1 well as natural materials to provide for long-term 2 stabilization of the radioactive waste at the site. That 3 would be stabilization, in terms of preventing or mitigating 4 airborne releases, water-borne releases inco Wills Creek, 5 and into the run nearby, or groundwater discharge, or 6 gaseous release from the pile. All these sorts of things 7 will be taken into the development of the disposal 8 alternative.

9 The second alternative would be offsite disposal.

10 In this alternative, what is contemplated is that the 11 material would be exhumed from the site, placed in either 12 trucks or train cars and would be sent offsite. Now, the 13 offsite disposal location would have to be licensed by the 14 NRC, or by an Agreement State,, depending on where it would 15 go. That could include areas in the near vicinity of 16 Cambridge. It could be someplace within the State of Ohio.

17 It could be someplace outside of the State of Ohio. All of 18 those are reasonable alternatives. -

19 I show in the diagram an arrow indicating that the 20 stuff is going to New Mexico. That is only for figurative 21 purposes. I am not sure the citizens of the State of New 22 Mexico would appreciate the waste coming to them. But, in 23 any case, I am just showing that to indicate that offsite 24 disposal would entail, in fact, removal of the material 25 of the waste on the site and taking it elsewhere.

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29 1 A variation of that theme would be combining 2 offsite disposal with some sort of processing onsite. I 3 mentioned earlier, this may entail taking the waste and 4 separating it physically or chemically, or using its S radioactive properties to try to segregate the material that 6 posed a greater risk from the material that poses a lesser 7 risk -- the concept being leaving some of the lesser-risk 8 material behind and taking the material or waste that poses 9 a greater risk to the environment and to humans offsite for 10 disposal in a licensed facility.

11 For the sake of completeness, we also included a 12 dilution scenario or a dilution alternative. This would 13 entail, rather than removing the material from the site, 14 bringing the material to the site, mixing it with the slag 15 in some process to redu9e the average concentration of the 16 radioactive materials within the disposal.

17 And then the last alternative that we have 18 identified so far is the no-action alternative. Again, we 19 are not proposing this. We are just saying that this is one 20 of the alternatives that we will be considering, just to be 21 sure that we have a complete spectrum of what is currently 22 available and has been identified. The no-action 23 alternative provides us with a baseline.

24 It is important to point out, with the no-action 25 alternative, however, that even though NRC may take no ANN RILEY & ASSOCIATES, LTD.

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30 1 action, there certainly are other regulatory bodies, for 2 example, the state agencies and the Federal agencies, like 3 the Environmental Protection Agency, that may, on its own, 4 initiate action that could stabilize this material in some 5 way or lead to the selection of some remedial action of some 6 disposal alternative.

7 In fact, the NRC has proposed to these various 8 local, state and Federal agencies that they consider whether 9 they are willing to cooperate with the NRC in the 10 development of the Environmental Impact Statement. The 11 objective of that cooperation is to provide for early 12 consultation and cooperation between the agencies so that 13 there is sharing of information and so that all of the 14 agencies that may have jurisdiction or special experience or 15 expertise about this kind of action be brought in. That 16 information can be then used in developing a coordinated 17 remedial action plan.

18 I mentioned earlier about potential impacts. This -

19 is just a brief picture to show what kinds of impacts we 20 would propose to consider. They are described in greater 21 detail on the notice that is available at the back of the 22 room. Principally, we would be looking at potential 23 exposures to residents that may move on to the site at some 24 point in the future. How might they be exposed? Would they 25 dig a foundation in the material? Would they grow crops on ANN RILEY & ASSOCIATES, LTD.

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31 1 top of the contaminated material? Would they be exposed to 2 radioactive gasses like radon that may be emitted through 3 the cover in the facility? What would the construction of 4 the disposal cell itself -- how would that impact upon the 5 environment? Would there be sedimentation and run-off into 6 adjacent surface-water? Would there be groundwater 7 contamination, either during remedial action, or the 8 stabilization of material, or after at some point?

9 Certainly, for the offsite disposal alternatives,

• 10 11 12 this would entail consideration of transportation impacts.

By driving so many trucks down the road, what is the probability that somebody may be injured or in fact killed, 13 because you are moving so many trucks, or because you are 14 transporting the material through rail cars. This gives you 15 a range of alternatives. As I mentioned, the full range of 16 alternatives is described in greater detail in the scoping 17 notice.

18 To wrap up on the schedule, what we would propose 19 to do is, in February, based on t~e public comments that we 20 have received here tonight, as well as any written comments 21 that may come in, and the consultation that goes on between 22 the state, local and Federal agencies, with our cooperation, 23 we would prepare a scoping summary. And that document would 24 digest the comments that have been received on this scoping 25 process, and identify specific alternatives or specific ANN RILEY & ASSOCIATES, LTD.

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32 1 issues which will need to be considered by the NRC as part 2 of the development of that Environmental Impact Statement.

3 We would also propose then to proceed in the 4 publication of a draft Environmental Impact Statement and 5 then complete a final Environmental Impact Statement, you 6 can see, by June of 1995. This schedule is contingent upon 7 the successful resolution of some of the financial issues 8 that currently face Shieldalloy Metallurgical Corporation, 9 as well as other additional information that may come out as 10 part of the scoping ~recess. For example, new information 11 may come to light which would identify new issues which will 12 take far longer to evaluate. On the other.hand, information 13 may also surface which could be used to accelerate the 14 schedule somewhat.

15 By this point, you are saying, okay, when do I 16 have an opportunity to have input into the process? I have 17 tried to describe up here what alternatives exist for public 18 19 20 input throughout. We have tonight's scoping meeting where you can submit both oral or written comments, if you choose to, to identify issues of concern that you may have. There 21 is also the opportunity, as I mentioned earlier, to submit 22 written comments for the record by January 15th of 1994.

23 And the mailing address is provided in the notice on the 24 back of the table.

25 After the scoping summary is distributed to people ANN RILEY & ASSOCIATES, LTD.

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33 1 who request a copy, you may also feel free to write in and 2 say, no, you don't have the issue quite right, I meant this 3 issue. That is another alternative that you have.

4 At the time that the NRC publishes the draft 5 Environmental Impact Statement, there will be a formal 6 public comment process -- at least a 90-day comment period, 7 where the document will be available, and you will be' 8 entitled to go through, get a copy if you want one, and 9 identify the comments on that.

10 I might also point out that there is an 11 opportunity for continuing consultation. You have met Chad 12 Glenn from his previous presentation. He is here as a 13 project manager. It is important to identify him as the 14 point person with the NRC. So, if you have concerns or 15 comments that may come up at any time, please feel free to 16 comment and to tell Chad what those are.

17 That's my overview of the schedule.

- 18 19 20 MS. STINSON: Once again, we will take questions of clarification, if you have any at this point.

can -- you can certainly return to them.

If not, we 21 [Show of hands . ]

22 MS. STINSON: Yes.

23 FROM THE FLOOR: What is being done in terms of 24 the workers at the site?

25 MR. WEBER: Okay. That is a good question. The ANN RILEY & ASSOCIATES, LTD.

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34 1 question was what is being done to protect the workers at 2 the site until all this matter is resolved?

3 As Chad mentioned in his overview, the west pile 4 is currently covered. And so, with some minor exceptions, 5 the level of exposure that we see at that west pile is 6 roughly what it is as you would find around the level. The 7 levels are not elevated significantly. So, it doesn't pose 8 a risk to the workers who continue to work on site.

9 The east pile, as Chad also mentioned, is fenced.

10 There is an elevated exposure rate along the fence line.

11 But, generally, the work takes place far from the east pile 12 location. Just being out there today, we had our survey 13 meters. You don't see any elevated exposure rates beyond 14 what, about a hundred yards or so or less from the east 15 pile. And merely driving by would not pose a significant 16 risk.

17 The material that is presently being handled at 18 the site is the ferro-vanadium material, and that is not 19 licensed by the NRC. But, we surveyed this piece of slag 20 and the levels are not significantly elevated in that 21 either.

22 MS. STINSON: Any questions for clarification of 23 understanding the scoping process?

24 [Show of hands.]

25 MS. STINSON: Yes, sir.

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35 1 FROM THE FLOOR: Has the NRC and the company put a 2 dollar limit on the preparation of the Environmental Impact 3 Statement and have other Federal agencies done likewise?

4 MR. WEBER: We have contracted with the Oak Ridge 5 National Laboratory.

6 [Show of hands.]

7 MS. STINSON: Question?

8 FROM THE FLOOR: [Inaudible.]

9 MS. STINSON: Repeat the question.

10 MR. WEBER: The question was has the NRC put a 11 dollar limit on the preparation of the Environmental Impact 12 Statement? And have the other Federal agencies done 13 likewise?

14 FROM THE FLOOR: And state agencies.

15 MR. WEBER: And the state agencies and the 16 company.

17 FROM THE FLOOR: That's right.

18 MR. WEBER: With respect to the NRC, we have 19 contracted with the Oak Ridge National Laboratories. I 20 think the contractual amount is $300,000 for the preparation 21 of this environmental impact statement. We are also 22 planning to do another one for Shieldalloy's other facility 23 in Newfield, New Jersey. The value of that contract is the 24 same.

25 As to whether the other Federal and State agencies ANN RILEY & ASSOCIATES, LTD.

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36 1 have committed to specific dollar amounts, I am not aware 2 that they have. I think, at this point, many of them are 3 just right now sorting out what their role is and do they 4 want to cooperate with the NRC in developing this 5 Environmental Impact Statement.

6 There are representatives of those agencies here 7 tonight. Perhaps later on, if they can, they can answer the 8 question.

9 MS. STINSON: And, in terms of the company, 10 perhaps they will address the question in the course of 11 their comments coming up.

12 Any other questions at this stage?

13 [Show of hands.]

14 MS. STINSON: Yes, ma'am?

15 FROM THE FLOOR: Is it mixed waste, hazardous and 16 radioactive waste?

17 MS. STINSON: The question is is it mixed and 18 radioactive -- is it mixed waste, radioactive and hazardous 19 waste?

20 MR. WEBER: I think we are sorting that out. The 21 reason I say that is because the material when it was 22 generated, to our knowledge, would have not been mixed 23 waste. - But, it may have been mixed with other materials 24 onsite, which may make it mixed waste today. In fact, we 25 have been discussing that with EPA. I think, rather than ANN RILEY & ASSOCIATES, LTD.

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37 1 make a decision here tonight, I think we have got to 2 continue those discussions.

3 MS. STINSON: So, it sounds like it is a question 4 before them.

5 Any other questions at this point?

6 [Show of hands.]

7 MS. STINSON: Yes?

8 FROM THE FLOOR: How can you say that, looking at 9 the records from the Nuclear Regulatory Commission, in 10 reference to a particular accident at the Shieldalloy site I 11 believe back in 1990, when they were cleaning up part of one 12 of the piles and a canister of hazardous waste exploded?

13 That is in your records.

14 MR. WEBER: The question was how can I say that 15 when --

16 FROM THE FLOOR: That it is not mixed hazardous 17 waste?

18 MR. WEBER: I am not aware that we determined that -

19 it is mixed hazardous waste. I am not -- I am going to have 20 to check into what you are saying.

21 MR. GLENN: I will just try this one. I think, in 22 terms of the slag itself, at the present time, we don't view 23 that as a mixed waste. However, there was this ferro-24 vanadium dust that does contain heavy metals and is used as 25 the capping material on the west slag pile. That -- it may ANN RILEY & ASSOCIATES, µTD.

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38 1 turn out that that cover and the heavy metals in that cover 2 contain hazardous components. That is all I can say at this 3 point in time.

4 MS. STINSON: 'Any other questions of 5 clarification?

6 [Show of hands.]

7 ~s. STINSON: One last one. Go ahead.

8 FROM THE FLOOR: [Inaudible.]

9 MS. STINSON: Can you describe the explosion 10 situation that he is referring to? Sherwood? Okay. We 11 will have to pose that question to the company.

12 FROM THE FLOOR: [Inaudible.]

13 MS. STINSON: Okay. We will.reserve that question 14 and make sure we get back to it.

15 'Anything efse?

16 MR. WEBER: Can you repeat the question?

17 MS. STINSON: The question was related to the

- 18 19 20 explosion on the site and what was it precisely.

Okay. As I described earlier, during the next period, for probably at least an hour, we are going to hear 21 from various perspectives that have signed up to present 22 comments from their perspective. The interest groups that

• 23 have signed up are the** licensee themselves, elected 24 officials and local government, environmental citizen 25 organizations, folks that are site employees, or members of ANN RILEY & ASSOCIATES, LTD.

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39 1 the labor union and various local business representatives.

2 We will just ask each individual as you come up to please 3 limit your comments to about three minutes. That ought to 4 keep us relatively on schedule. Hopefully, at the end of 5 each interest group session, we will have time for questions 6 back to that group.

7 Let's begin with the SMC, the Shieldalloy 8 Metallurgical Corporation's comments.

9 MR. WEBER: Please state your name.

10 MS. STINSON: During this period, whenever you 11 approach the mike, you are going to have to state your name 12 clearly so that it is on the record. Thank you.

13 MR. EAVES: Good evening. I am Scott Eaves. I am 14 Vice President of Environmental Services for Shieldalloy 15 Corporation. I wanted to tell you that in 1987 Shieldalloy 16 bought the Cambridge facility. The previous owners had 17 processed columbium-ore at the site from the early 1950's 18 until 1971. This processing generated a slightly 19 radioactive slag which was left onsite when Shieldalloy 20 bought the facility. The slag has been sitting on the site 21 for over 20 years. In 1993, the NRC said the sight poses no 22 immediate threat to the public.

23 Shieldalloy has never processed columbium at the 24 site, but has spent over $4 million remediating the site so 25 far. The Environmental Impact Statement that is going to be ANN RILEY & ASSOCIATES, LTD.

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40 1 prepared -- and this is the first step in that process, is 2 estimated to cost an additional $2 million.

3 In all the time since the slag was first put down' 4 on the land in the early '50s, there has been no evidence s that there has been any radiological contamination spreading 6 from the piles. Risk is one of the terms that you have 7 heard used tonight. You will hear it a lot through this 8 whole process. For practical evaluation of a remediation 9 technique, there are two components of risk that need to be 10 evaluated. One if the risk of .performing*the remediation 11 and the other is the risk remaining after the remediation is 12 complete. These two components have to be added together to 13 come up with a total risk for a given project.

14 When the risk of constructing and installing a cap 15 for the two piles is calculated and compared to the risks 16 associated with moving the material offsite, the risks from 17 moving the material offsite are much much higher. This is

- 18 19 20 due to the hazards associated with the excavation and with moving the material over highways using trucks The amount of material that is onsite for it to be moved offsite would 21 take 26,000 tractor trailers. The risk of death and injury 22 go way up because of this transportation portiQn.

23 The proposed remediation methods -- stabilization*

24 and capping is the alternative that poses the least amount 25 of risk to members of the public. Not insignificantly, it ANN RILEY & ASSOCIATES, LTD.

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41 1 is also the next to lowest in cost. This is important to 2 Shieldalloy because the company is currently trying to 3 develop a reorganization plan under Chapter 11 of the 4 bankruptcy code.

5 Some of the major points I would like to leave you 6 with is that there has been no known migration of radiation 7 since the material was placed on the ground; that the lowest 8 risk to the general public is capping in place; and that 9 proceeding with a capping in place solution will allow 10 Shieldalloy_to continue to protect jobs and to be a viable 11 member of the community.

12 That is all I have.

13 MS. STINSON: I believe you are the only 14 representative of the company making comments? Okay. We 15 will take questions.

16 [Show of hands.]

17 MS. STINSON: Yes?

18 FROM THE FLOOR: Yes. I believe you stated that 19 there have been no known studies showing any migration 20 offsite and that there is no threat to humans. What I would 21 like to ask you is -- the major programs and perform the 22 site assessment of the Shieldalloy facility in September of 23 1990. They concluded, and I quote: "That Shieldalloy 24 threatens human health and the environment in the following 25 manners: One, because of its proximity to commercial and ANN RILEY & ASSOCIATES, LTD.

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42 1 residential areas, Shieldalloy Metals Corporation poses a 2 threat of radiation and metal exposure to the surrounding 3 population. Unrestricted access to the area surrounding the 4 facility increases the likelihood of exposure to 5 radionuclides and heavy metals.

6 "Two, Wills Creek and Chapman Run border a large 7 portion of the SMC site. These streams directly supply 8 drinking water for the City of Cambridge. Elevated levels 9 of certain metals and radionuclides were evident at the 10 confluence of the two streams. Likewise, samples collected 11 from the wetlands west of SMC exhibited elevated levels of 12 certain metals and vanadium compounds and radionuclides."

13 Now, my question is how can you sit here before us 14 tonight and. tell us that there is no study that shows 15 offsite migration, when.this study was done for site? And, 16 two, how can you sit there and tell us that there is no risk 17 to human beings?

18 MS. STINSON: The question was referring ta a 19 study that was completed, in the questioners mind, I believe 20 for the SMC site. He cited several citations from that.

21 Let me just say, at this point, if you are going to have 22 long questions, I think we are going to have to get them in 23 on the record through the microphone. So, you may have to 24 step up and ask your questions. Go ahead.

25 MR. EAVES: I will answer the second part of your ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

43 1 question first. The allegations that Westin put in this 2 report that says that there are elevated readings of metals 3 and radiation don't have anything to do with and make no 4 reference to any impact on human health.

5 ~he second part of it that is one data point.

6 There have been a number of other tests that refute that.

7 So, there has been no conclusive information on your 8 question.

9 MS. STINSON: Other questions? This is a good 10 time for me to state that we all know that there are a 11 variety of perspectives on all of these issues. We are 12 going to disagree on our perspectives on those issues. We 13 know that. So, I think we should strive tonight to better 14 understand what the different points of view are and what 15 those disagreements are, and you have got to remain tolerant 16 that there are going to be different points of view coming 17 out of this microphone and from the audience. So, bear with 18 us on that. -

19 Any other questions for SMC at this time?

20 [Show of hands.]

21 MS. STINSON: Yes?

22 FROM THE FLOOR: Does the metallurgical operation 23 -- what happens to the dust on the road, if it runs off --

24 water run-off from the road in the area -- do you process 25 that at the site?

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44 1 MR. EAVES: The question was what happens to the 2 dust from the manufacturing operations? The questioner 3 wanted to know if it had been treated. The company does not 4 process any of the columbium ores that result in the 5 radioactive slags at all. We have never processed them 6 there.

7 MS. STINSON: Other questions?

8 [Show of hands.]

9 MS. STINSON: This won't be your last chance.

10 Yes?

11 FROM THE FLOOR: Does Shieldalloy now have --

12 MR. EAVES: I think that question would be better asked of 13 the NRC.

14 MS. STINSON: Can you repeat the question?

15 MR. EAVES: I don't think I completely understand.

16 She wanted to know -- the questioner wanted to know if 17 Shieldalloy had the license that was previously held by 18 another company to process ores onsite.

19 MR. WEBER: Shieldalloy no longer has a license to 20 process source material. Their license authorizes them for 21 possession only and decommissioning.

22 MS. STINSON: Any other questions?

23 [Show of hands~]

24 MS. STINSON: In the back.

25 FROM THE FLOOR: Does Shieldalloy have sole ANN RILEY & ASSOCIATES, LTD.

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45 1 responsible for the --

2 MR. EAVES: I think that the question was does 3 Shieldalloy have sole responsibility for the radioactive 4 slags and other toxic materials onsite or would liability 5 fall to the previous owners, if the site became a Superfund 6 site? I would have to say I don't know the answer to that 7 question. It is probably involved in the documents of nale.

8 MS. STINSON: That also sounds like a question for 9 the U.S. EPA. I know there are representatives here. Maybe 10 they will take an opportunity to answer that question at 11 some point.

12 Other questions?

13 , [No response.]

14 MS. STINSON: Okay. Thank you.

15 We have a number of elected officials and local 16 government representatives who are here tonight to make a 17 few comments. Why don't I just run straight through the 18 list so you will know when you are up? Tom Laughman, 19 Carolyn Arnold, Ernest Rogers, and Art Valentine. If there 20 are others who did not sign up, who may wish to come up to 21 the mike and make a few comments, you will be allowed to do 22 so. Take about three minutes. We will start with tom.

23 MR. LAUGHMAN: Thank you. My name is Tom 24 Laughman. I am President of the Gurnsey County Board of 25 Commissioners. I want to welcome the Federal and state ANN RILEY & ASSOCIATES, LTD.

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46 1 agencies that have traveled to our fine county this evening.

2 We are proud here in Gurnsey County to have many responsible 3 corporate citizens. Shieldalloy has been one of our I

4 corporate citizens since 1987. At the time Shieldalloy 5 purchased* the Gurnsey County Plant, they inherited a 6 slightly radioactive area which was generated by the 7 previous owner. We have been told that in 1993 the NRC, 8 through an updated report on a site decommissioning 9 management plan, stated that the site poses no immediate 10 threat to the public.

11 While we understand that the NRC has a duty of 12 regulating such activity at the Shieldalloy site, we ask 13 that you understand the economic impact offsite disposal 14 would have on Shieldalloy, especially given their present 15 financial status. Removal of material from this site would 16 impact no only Shieldalloy, due to the cost, but also 17 Gurnsey County, as a whole, considering the traffic 18 congestion, in an already burdened industrial. artery.

19 We are proud to have Shieldalloy as one of our 20 long-standing corporate citizens. They contribute in the 21 neighborhood of $3 million in payroll to our local economy.

22 This figure translates to approximately $7 million in total

• 23 cumulative expendable income for our area. In addition, 24 Shieldalloy pays real estate taxes which amount to $27,000 a 25 year, as well as their share of personal property taxes.

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47 1 While these figures may seem minimal at the Federal level, 2 they are very essential to Gurnsey County's economic base.

3 To lose over a hundred employees, as a result of cost-4 prohibitive, offsite disposal of these areas would result in 5 a negative 1rnpact on Gurnsey County.

6 I ask that you continue to work with Shieldalloy 7 to decommission these areas onsite, which, in the end, will 8 benefit both Shieldalloy, as well as Gurnsey County as a 9 whole. Thank you.

10 [Applause.]

11 MS. STINSON: Any questions for --

12 [Show of hands.]

13 MS. STINSON: Yes?

14 MR. BAUMAN: Yes. You mentioned Shieldalloy 1 s 15 contribution to the, community. I was wondering if you would 16 care to comment on their contribution in the way of fines 17 for continued dumping of chromium and chlorine into our 18 sewage treatment plant?

19 MR. LAUGHMAN: I have not seen any indication in 20 writing.

21 MS. STINSON: I am sorry. Could you repeat the 22 question, or do you want me to do it?

23 MR. BAUMAN: I have a letter here from the City of 24 Cambridge about fines for continued dumping of -chlorine ar.d 25 chromium into our sewage treatment plant. If you are ANN RILEY & ASSOCIATES, LTD.

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48 1 talking about the contributions, I was wondering if you 2 would care to talk on that?

3 MR. LAUGl:iMAN: So, your question is what 4 contributions* have they done in the way of dumping into the 5 sewage tre~tment plant?

6 MR. BAUMAN: Right. Above and beyond the 7 radioactive waste?

8 MR. LAUGHMAN: I think that they have --

9 MR. BAUMAN: Do you think they are being good 10 cooperate neighbors? Let's look at the entire story.

11 MR. LAUGHMAN: I am saying that this county cannot 12 afford to lose over a hundred jobs, Mr. Bauman. That is the 13 bottomline. I have not seen anything indicating any kind of 14 industrial waste dumped into a sewage treatment plant.

15 MR. BAUMAN: Maybe you could do something to bring 16

,_ 17 18 19 MR. LAUGHMAN:

MS. STINSON:

me, both of you.

I am not here to debate that.

I don't want to get into -- excuse I don't want to get into a debate between 20 two people here. Again, it is going to be a difficult 21 discussion. What we want to do is to try to explore the 22 issues. I think your question, Sherwood, relates to the 23 fines themselves. I think there is a City of Cambridge 24 representative here who can possibly answer that more 25 specifically. So, we will try to get to that.

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49 1 Any other questions?

2 [Show of hands.]

3 MS. STINSON: Yes.

4 FROM THE FLOOR: [Inaudible.]

5 MS. STINSON: Yes. The question is can we stay to 6 the point. The point is that I think there will be 7 different interpretations of what is on point and what is 8 not. So, bear with us on that*as well.

9 Any other specific questions of Tom?

ro [Show of hands.]

11 MS. STINSON: Yes, sir. If you can speak up?

12 FROM THE FLOOR: [ Inaudible . ]

13 MS.: STINSON: Sure. Sherwood, what is your last 14 name? Bauman?

15 MR. BAUMAN: Bauman.

16 MS. STINSON: This is Sherwood Bauman, and he 17 represents Mills Creek Environmental Organization.

18 Other questions?

19 [No response.]

20 MS. STINSON: Okay. Thanks. We are having a 21 problem here in that we can't register each of the questions 22 on the microphones because we only have two. So, our 23 stenographer is struggling. If you do have your comments 24 typed out, that would be helpful. We will enter them into 25 the record that way.

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so 1 Carolyn? Carolyn Arnold?

2 MS. ARNOLD: I really have nothing to say. I just 3 want to say --

4 MS. STINSON: Carolyn, I am sorry. Can you step 5 up to the mike? You can use this one.

6 MS. ARNOLD: Thank you. I just want to say that I 7 am here at the reques~ of Senator John Glenn to hear from 8 you tonight, Here I am. If you want to talk to me at any 9 time, please, make yourself known. Thank you.

10 MS. STINSON: Ernest Rogers?

11 MR. ROGERS: I will pass at this time.

12 MS. STINSON: I am sorry. You will pass at' this 13 time? Okay. How about Art Valent'ine? Do you mind coming 14 down? I am sorry. What we really need is a portable 15 microphone, and it just wasn't available.

16 MR. VALENTINE: I am Art Valentine from Byesville.

17 I would like to second Mr. Laughman's comments, and I want

- 18 19 20 them to stay here.

[Applause . ]

MS. STINSON: We now are going to hear from some 21 of the environmental organizations. As I am peaking through 22 this, I think it might be a good idea to adjust the schedule 23 slightly and allow for T~ did you want to make comments now, 24 Mayor?

25 MAYOR SHAUB: Yes.

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51 1 MS. STINSON: Okay. Why don't you go ahead and do 2 that. This is Mayor Shaub obviously.

3 MAYOR SHAUB: Thank you. I apologize that we were 4 late. We had a council meeting in Cambridge, and we just 5 arrived a few moments ago.

6 I would reiterate and reinforce the comments made 7 *by Commissioner Laughman, in that we feel that Shieldalloy 8 has been a good corporate citizen within our community. I 9 would very briefly address the question or comment raised 10 with regard to chlorine dumping into the city sewer system.

11 The city does have a pre-treatment program, and there are 12 certain permit levels whereby only a certain amount of 13 chlorine or anything can be dumped into our sewer system.

14 The idea that chlorine going into the sewer system is not a 15 problem in itself, what happened was an excessive amount 16 went into the sewer system in a short period of time which, 17 if it had been diluted, it would have been totally within 18 the permit limitations which we in the city have established 19 with EPA approval.

20 We did confront Shieldalloy, advised them that 21 they were out of permit violation. And the first 22 occurrence, we did impose a fine upon them, I believe it was 23 of $2,500 for the first occurrence. Some time later, 24 whether it was accidental or what, but maybe a year later, 25 another dumping occurred, which we again notified ANN RILEY & ASSOCIATES, LTD.

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52 1 Shieldalloy and this time we fined them I believe it was 2 $12,000, which they paid to the city.

3 I have been advised, since that time they have, at 4 their own expense, expended approximately $28,000 to come up 5 with some ~ype of a system so that this unfortunate 6 accidental dumping will not occur again. I, as the Mayor of 7 the City of Cambridge, appreciate the cooperation on the 8 part of Shieldalloy. Shieldalloy is not the only company or 9 plant within our community which has had EPA violations. We 10 are more than willing to work with those and have great 11 hopes of their continued cooperation. So, we, too, would 12 like to see Shieldalloy stay within our community. We would 13 also think that the onsite contamination remain there for 14 whatever degree it is, rather than remove it.

15 I would address one other question or comment. I 16 have been Mayor for 14 years. Two or three years ago we 17 were approached, not by Mr. Bauman, but by someone else

- 18 19 20 saying that this slag pile was contaminating our city water, which is the source of Wills Creek, as the city source of water. At least twice we had independent testing done above 21 and below the stream site of the slag site itself, upstream 22 and downstream, and the water tested on both sides of where 23 it could leech into our water system. The test came out the 24 same on both sides of the slag pile, which would indicate to 25 us that there has been no adverse impact upon the city's ANN RILEY & ASSOCIATES, LTD.

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53 1 source of water at this point in time.

2 Those are my comments, ma'am. I am sorry that I 3 didn't have them prepared.

4 MS. STINSON: That is fine. Will y0u take 5 questions?

6 MAYOR SHAUB: Oh, sure. I love to take questions.

7 MS. STINSON: Oh, good.

8 [Show of hands.]

9 MS. STINSON: Let's see. Yes, ma'am, back here.

10 FROM THE FLOOR: Did you say chlorine? I didn't 11 understand what that was -- chlorine?

12 MS. STINSON: Would you repeat the question, 13 please?

14 MAYOR SHAUB: The question, I believe, was I 15 stated chlorine and she thought they were being fined for 16 chromium. The part involved with the city only involved 17 chlorine.

18 [Show of hands.]

19 MS. STINSON: Apparently chlorine, not chromium.

20 Yes, Sherwood?

21 MR. BAUMAN: May I read it into the record?

22 MS. STINSON: Yes. Come over here.

23 MR. BAUMAN: You just stated it was chlorine and 24 not chromium. I would like to read that part. "Since SMC 25 has rather consistently violated its permit for free ANN RILEY & ASSOCIATES, LTD.

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54 l chlorine and other pollutants, notably chromium, without 2 what I consider much regard for the permit compliance nor 3 requirement to notify the city when any such violation has 4 occurred, SMC is fined $5,500 payabl~ to the City of 5 Cambridge within 10 business days from the date of this 6 letter, plus an additional $15,000 for the repair of the 7 damage caused to the lift station."

8 The first part of the question is would you like 9 to explain why you are willing to forgive chromium dumping, 10 when you believe that it is chromium that can destroy the 11 bacteria in our three-stage water treatment facility? Two, 12 I would like to know why, when your own utilities director 13 says blatant disregard of rules and violations, you are 14 standing up for Shieldalloy?

15 MAYOR SHAUB: I didn't have a copy of the letter 16 in front of me. I know.the concern that we expressed our 17 concern when the chlorine was dumped into our system, it was

- 18 19 20 for the safety, health and welfare of our employees.

other words, the chlorine gas can be very dangerous, is a lift station in the close proximity to Shieldalloy.

In There 21 When our workers went to check out the lift stations, which 22 we do on a daily basis, this was the first thing that was 23 brought to my attention.

24 I don't know what the chromium violation was 25 permit-wise, on down the line. It was the chlorine which ANN RILEY & ASSOCIATES, LTD.

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55 1 did damage to our lift station. That was what we zeroed in 2 on. If we had not fined Shieldalloy, EPA would have fined 3 us. It is a trickle-down theory. I was not trying to cover 4 up the idea of chromium. I talked with the utilities 5 director today and he said it was the chlorine which was the 6 big violation. So, I will stand on that. I will defend 7 Shieldalloy again, Mr. Bauman.

8 MS. STINSON: Any other questions for the Mayor?

9 [No response.]

10 MS. STINSON: Okay. Thank you, sir.

11 MAYOR SHAUB: Thank you, ma'am.

12 [Applause.]

13 MS. STINSON: Now, we move to the environmental 14 citizen organizations who registered that they would like to 15 speak tonight. Deborah.Lorz is going to start us out with 16 the Green Party of Ohio.

17 I am sorry. Let me just read the list, if I can.

18 We have several tonight. Greg, you are going to have to 19 help me with your last name.

20 MR. NAGID: Nagid.

21 MS. STINSON: Nagid. It looks a lot worse than it 22 sounds. Greg Nagid is here from the National Audubon 23 Society; David Ellison, Northeast Ohio Greens; Sherwood 24 Bauman from Save Wills Creek Water Resources Committee; 25 Chris Trepal, is here from -- I have forgotten what EDC ANN RILEY & ASSOCIATES, LTD.

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56 1 stands for -- Environmental --

2 MR. TREPAL: Earth Day Coalition.

3 MS. STINSON: Oh,*Earth Day Coalition, that's 4 right. Sorry. Bob Greenbaum is here from the Sierra Club, 5 from the Ohio Chapter. So, that will be the order that you 6 will speak, if you don't mind.

7 MS. LORZ: Hi. My name is Deborah Lorz, I am with 8 the Greens, Green Party of Ohio. I am one of our 9 representatives to the National Council of the Green Party, 10 USA. I have been active in the debate in Ohio concerning 11 the low-level radioactive waste dump that has been proposed 12 here for the Midwest Compact. The areas that I will comment 13 on today are the legal requirements for decommissioning, the 14 health effects of exposure to low levels of ionizing 15 radiation, the proposed alternatives, and processes for 16 involving the public in the costing process and decision-17 making.

- 18 19 20 My foremost concern is in the arena of regulations. Currently, 10 CFR 40.42 requires that a site be able to be released for unrestricted use before a license 21 is terminated, period. Now, I am aware that NRC is 22 currently involved in drafting an Environmental Impact 23 Statement concerning codifying, decommissioning, and 24 decontamination regulations that may be less restrictive 25 than the current. regulations. The fact is that these ANN RILEY & ASSOCIATES, LTD.

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57 l regulations do not yet exist. This leads me to question the 2 authority of the NRC to consider Shieldalloy's proposed 3 action at all.

4 Section 40.36 of Title X of the Code of Federal 5 Regulations requires licensees to submit a decommissioning 6 funding plan and assure funds for decommissioning. The 7 amount required to be set aside is a pittance compared with 8 decommissioning costs. This mechanism does, however, infer 9 that decommissioning should be an early consideration for 10 anyone applying for a license from NRC. These funds should 11 have been set aside long before Shieldalloy applied for 12 bankruptcy.

13 It is hard to find sympathy for short-sighted, 14 profit-minded thinking; but I do feel very strongly for the 15 workers who will be affected by this kind of thinking.

16 Industries in this country have often shown a* lack of 17 concern for the health and safety of their workers; but, as 18 soon as an environmental concern comes up, start a job 19 versus environment kind of debate, which tends to obscure 20 the concerns that we hold in common for health and safety.

21 Section 40.14 of Title X of the Code of Federal 22 Regulations, allows the NRC to grant exemptions, provided 23 that it is authorized by law, it will not endanger life or 24 property, or the common defense, and it is in the public 25 interest. Those requirements seem to me to make the ANN RILEY & ASSOCIATES, LTD.

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58 1 granting of such an exemption to the Shieldalloy Corporation 2 to be illegal. Beyond the lack of legal authority, it may 3 well endanger life and property, and is in the interest of a 4 private corporation, not the public.

5 The Federal Government has bailed out the nuclear 6 industry from day one. The Price Anderson Act made the 7 taxpayers liable for nuclear accident. Subsidies of uranium 8 mining and processing have further shifted the costs 9 associated with nuclear technologies onto the citizens.

10 Shieldalloy is asking the residents of Gurnsey County to 11 pay, not only with their tax dollars, but also with their 12 health, the value of their property, and the health of their 13 children. The Atomic Energy Commission originally had the 14 dual role of promotion and regulation of nuclear industries.

15 There are many who question the integrity of the NRC has a 16 regulatory agency as well, due to the revolving door, from 17 positions of regulation of the industry, to employment 18 within the industry.

19 Well-respected researchers who differ from the 20 industry's preferred findings are routinely ostracized and 21 painted as crack-pots. Dr. John Gofman, Dr. Author Tamplin, 22 Dr. Alice Stewart, and Dr. George Kneale, are all examples.

23 Their studies found there to be no safe level of exposure to 24 ionizing radiation. The work of Dr. Gofman was requested by 25 the Atomic Energy Commission's Chairman, to study the ANN RILEY & ASSOCIATES, LTD.

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59 1 effects of peaceful uses of atomic energy. When Gofman 2 found that the risks to public health were significant, his 3 findings were ridiculed and suppressed.

4 There is no end in site to the debate on the 5 effects of low levels of radiation. Even the Bible of the 6 industry, the BEIR V, states that some forms of low-level 7 radiation can be more effective in causing health problems 8 than high doses. Until there is an open and fai~ debate 9 floor, there is no way to find the. truth. Until such time 10 as it can be definitively stated that there is no risk, we 11 must behave as though there is. It is only fair to be 12 conservative in our action in this arena, where our 13 decisions affect life for thousands of years.

14 My understanding of this site is that it is in the 15 watershed that supplies the City of Cambridge with drinking

.16 water. This would indicate to me a need to proceed with 17 great caution.

18 I would like to move on to a discussion of the 19 alternatives proposed by the NRC for consideration in the 20 draft Environmental Impact Statement. Again, I question 21 whether the NRC has the authority to grant an exemption to 22 the Shieldalloy Corporation to do anything other than 23 offsite disposal, which is alternative two in the notice I 24 received. I have grave concerns for any community that has 25 to deal with radioactive waste. I question the current ANN RILEY & ASSOCIATES, LTD.

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60 1 technologies that are used to isolate radioactive waste.

2 But, it does seem preferable to have some engineered 3 barriers and containment processes rather than having none.

4 Alternative one suggests leaving the waste onsite 5 and providing some minimal barriers to intrusion -- the 6 addition of a grass cap, as proposed, to minimize 7 groundwater contamination. Now, at the Barnwell, South 8 Carolina low-level radioactive waste dump, the older 9 trenches of waste were covered with dirt and grass. These 10 trenches have leaked into the water table, as evidenced by a 11 plume of tritium, which is migrating offsite. This 12 technology has been proven to be ineffective.

13 currently, Chem Nuclear Systems, Incorporated, 14 proposes above-grade concrete modules, with an engineered 15 cap of high-density polyethylene, clay and grass. I am not 16 enamored of this techno1ogy either; but it is certainly more 17 responsible than this current proposal. I would hope that 18 NRC would not consider using a method that has already been 19 proven inadequate.

20 My other concern is about the proposal to monitor 21 the site for problems and possible remediation. I wonder 22 who would do the monitoring and who would mitigate any 23 problems or threats to the public health that might arise?

24 If this company had filed for bankruptcy already, I have 25 serious doubt as to whether they will be able to do anything ANN RILEY & ASSOCIATES, LTD.

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61 1 about later problems.

2 My concerns about alternative three hinge on 3 issues of safety. It seems that such a process would result 4 in unnecessary exposures to workers. I also wonder what 5 processes are used and what the cost of that may be.

6 Alternative four is one of the more creative 7 methods I have seen for sweeping a problem under the rug 8 the idea of diluting radioactive waste and leaving it there 9 unrestricted turns fuy stomach. There is no proof that any 10 level of exposure is safe, even 10 picocuries per gram.

11 Regardless of the concentration, the amount of radioactive 12 uranium and thorium left onsite would be the same. The same 13 amount of rain water would pass through it. The same amount 14 would end up in the water, in the air, in the food and in 15 the people.

16 Alternative five seems ridiculous to even mention.

17 I know it has to be included in the Environmental Impact 18 Statement, but I hope -you have no intention of taking it any -

19 further.

20 I know that you include socioeconomic impacts in 21 the costing process. I think that there are areas of impact 22 that are difficult to quantify, but also need to be included 23 in the equation. Impacts on human health and the 24 environment are hard to measure, but they are there and need 25 to be considered. Attention needs to be given to developing ANN RILEY & ASSOCIATES, LTD.

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62 1 and implementing processes for quantifying these impacts.

2 My final area of concern is in the realm of 3 democracy and process. I think the idea of a site-specific 4 advisory board composed of concerned citizens, environmental 5 representatives, labor representatives and technical 6 advisors would be appropriate. I would. like to see forums 7 for public participation in decisions and monitoring.

8 Thank you for your time.

9 MS. STINSON: We are going to move on just with 10 the next commenter --

11 [Applause . ]

12 MS. STINSON: -- just because of the extended 13 comments, which is fine. Greg?

14 MR. NAGID: Hi. My name is Greg Nagid. I am 15 Wetlands Coordinator for the National Audubon Society, the 16 Great Lakes Regional Office. I was just invited last week 17 to come by Sherwood Bauman to support the environmental side

- 18 19 20 of this issue.

I just have a few comments that -- I will reiterate what Deborah here says. We are concerned with the 21 slag being left onsite if there is inadequate monitoring.

22 This makes common sense. You don't leave a mess and have

-23 nobody watching after it, especially when the radioactive 24 material can last for billions of years.

25 Now, a concern I have specifically, Audubon, ANN RILEY & ASSOCIATES, LTD.

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63 1 rather, is about the wetlands onsite. It has been conveyed 2 to me that the two slag piles are located either adjacent to 3 or within the wetlands. This isn't -- I don't know this 4 myself. I haven't seen the site; but, for some reason, a 5 proper delineation process and value assessment process has 6 been neglected. Typically, when a wetland is impacted by 7 dredge or fill material, there is a permit process initiated 8 from the Army Corps of Engineers. This is called Section 9 - 404 of permit process. This has not been done to my 10 knowledge. Typically, the Ohio EPA will also perform a 401 11 water quality standard permit process as well, where these 12 assessments are evaluated and proper mitigation action can 13 be required of the permittee or, in this case, Shieldalloy.

14 It is my concern that, with this EIS, these proper 15 assessments be made, and that the wetlands be given their 16 full consideration in terms of all of their functional 17 values. That may be flood control, wildlife habitat, water 18 quality, water recharge for the groundwater, et cetera.

19 I think that is all I need to say right now.

20 MS. STINSON: Thank you.

21 Let's move on. David Ellison.

22 MR. ELLISON: Hello. My name is David Ellison. I .

23 am the convener of the National Committee of the Green 24 Party, USA, and the Treasurer of the Northeast Ohio Greens 25 and the Green Party of Ohio. For your information, the ANN RILEY & ASSOCIATES, LTD.

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64 l Green Party is based on values. There is ecology, social 2 justice, non-violence, grass-roots democracy and community-3 based economics.

4 our official position on the workers who are 5 involved in nuclear technology is that a Superfund be 6 established to cover tuition and compensation during the 7 period of retraining and the divestiture of the nuclear 8 industry.

9 The termination of Shieldalloy's NRC license 10 unfortunately does not alleviate the community's burden of 11 uranium, thorium and other radioactive pollution of the 12 environment. An Environmental Impact Statement is an order 13 to assess the corporation's liability and complete 14 decommissioning efforts; but, in a broader sense, an EIS is 15 appropriate to begin to weigh the environmental impact felt 16 by the people of Ohio as a result of an industrial system 17 and regulatory agency which historically has been less 18 concerned with long-term sustainability than with short-19 term profits.

20 Already legal actions have cast a pall of 21 censor,ship and repression on parts of the Cambridge 22 Community. Already threats of violence towards those who 23 sp~ak out contaminate th~_ environment in a_ way more 24 immediately visible than the insidious effects of 25 radioactive contamination, which will begin to show ANN RILEY & ASSOCIATES, LTD.

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65 1 themselves in future generations.

2 We commend the NRC in their determination that 3 their action regarding the Shieldalloy site constitutes a 4 major Federal action and warrants the preparation of an EIS.

s In response to their solicitation for public input on the 6 scope of the EIS, the Northeast Ohio Greens offer the 7 following questions which should be addressed in the 8 eventual Environmental Impact Statement.

9 The area around the Coshoctin Flint Outcropping 10 and east of the Hopewell Civilization's Earthworks has a 11 high probability of containing early archaic, and that would 12 be from 500 B.C. through pre-Columbian, which is from a 13 thousand to 1,500 A.O., archeological sites, which would be 14 likely to include burial ground, ceremonial and sacred 15 places, and other remnants of prehistoric culture. In order 16 to preserve this archaeological record, we believe any 17 archaeological findings should be left in tact and 18 undisturbed. What will any action taken by Shieldalloy have 19 on the archaeological record left by the prehistoric people 20 who lived in this area?

21 I-70 follows what at one time was the National 22 Road, and was the first road into the Ohio Territory. The 23 area around Cambridge has a high probability of containing 24 historical sites and archeological records of the early 25 settlement of Ohio by Europeans. It is likely that it ANN RILEY & ASSOCIATES, LTD.

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66 1 contains remnants of early glass industry and clay works.

2 What impact will any action taken have on this historical 3 and cultural record?

4 The costs involved in moving materials, 5 administration and constructing barriers are fairly simple 6 to calculate, based on contractor's bids and company 7 employment projections. Other less tangible costs exist 8 which must be estimated. A value system might be used which 9 considers only the most immediate economic costs, thus 10 predetermining the outcome of this process. The 11 archaeological, cultural, historical, ecological, economic, 12 social, transportation risks and other costs need to be 13 assigned values. How will the NRC and its contractor 14 determine these values?

15 Long-term care of the waste generated by 16 Shieldalloy and its predecessors will have an impact on 17 whatever community is burdened with it. What social,

- 18 19 20 cultural and economic impacts will long-term care and radioactive waste products, which require monitoring, sequestering, and possible future remediation have on that 21 community?

22 Uranium and thorium have half-lives of four to 14 23 billion years and hazardous lives of 10 to 20 times that.

24 If public access to the site is to be restricted, will the 25 institutional control period be commensurate with the ANN RILEY & ASSOCIATES, LTD.

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67 1 duration of the hazard?

2 In radiation monitoring activities, it is 3 important to plan for long latency periods. In the receding 4 waters of the Mississippi Ri~.rer this past summer, it was 5 found that.significantly more pesticide and fertilizer 6 residue existed in the unsaturated zone of the soil than had 7 reached the groundwater, suggesting a long latency period 8 between soil contaminat~on and groundwater pollution. What 9 will the actions do to alleviate or create a problem of 10 materials migrating through the soil to the groundwater.

11 And experience with thorium contamination, where 12 the material is mixed diluted with clean fill and spre*ad 13 around, there are indications of elevated incidence of 14 pancreatic, colon and lung cancers, as well as abnormally 15 high incidence of Hoqgkin's Disease. In any of the options, 16 how will the health effects of this.waste on the community 17 be determined?

18 19 20 In the processes of decommissioning, license termination and long-term oversight, how are the people who are directly affected going to be involved? What processes 21 will be used to involve the general public in decisions 22 which will affect them? What formal process will be used to 23 reach consensus on the action to be taken?

24 Onsite disposal, with restricted access is not 25 allowed under current regulations. Dilution has been proven ANN RILEY & ASSOCIATES, LTD.

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68 1 to decrease property values and cause doubt regarding a 2 place's healthfulness. Clean-up and release of the 3 decommissioned site for unrestricted use is the only 4 apparent option within the authority of the NRC. What 5 effect would altering the rules to allow higher levels of 6 contamination and restricted access in the Shieldalloy case 7 have on decommissioning and pollution prevention efforts 8 around the country?

9 Thank you.

10 [Applause. ]

11 MS. STINSON: Sherwood Bauman.

12 MR. BAUMAN: My name is Sherwood Bauman. I am 13 with the Save the Wills Creek Water Resources Committee.

14 On May 3rd, 1993, Shieldalloy submitted a 15 decommissioning document to the Nuclear Regulatory Agency, 16 wherein they contend that the best method of clean-up is in 17 situ disposal. In common terms, it amounts to covering up 18 the radioactive waste and pretending that because it is 19 covered up, the problem has been taken care of.

20 A cursory glance at the Federal Code of 21 Regulations for the Nuclear Regulatory Agency would point 22 out that for a license to be retired the company would have 23 to accomplish the following tasks: One, terminate use of 24 source material; two, remove radioactive contamination to 25 the extent practicable. You will notice that nothing is ANN RILEY & ASSOCIATES, LTD.

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69 1 said about leaving it there in the middle of a wetland that 2 drains into the tributary that supplies the City of 3 Cambridge's water supply. Three, properly dispose of source 4 material. Disposing of source material does not mean 5 covering it up for the next 14 billion years, which is only 6 its half-life. Four, submit a report that demonstrates the 7 premises are suitable for release for unrestricted use in 8 some other manner. These regulations can be found in 9 Section 40.42 in book number 10 of the Federal Code of 10 Regulations. Section 40.42 shows that the Shieldalloy 11 Company's preferred choice of decommissioning falls far 12 short of the NRC clean-up guidelines for the site.

13 I am sure that the company will tell you that, 14 with proper policing of the site and other safeguards, it is 15 a site that will propose no risk to human health or the 16 environment. In effect, they are saying trust us. Sadly, 17 we as affected citizens, cannot trust Shieldalloy.

18 In a guest column that appeared in the 19 Jeffersonian, Shieldalloy claims they are being made a 20 scapegoat in this whole affair. However, before the Nuclear 21 Regulatory Agency or you, the members of the public, believe 22 this, let's look closely at a few cold, hard facts. One, in 23 the Company's decommissioning report of May 10th of this 24 year, they make some assertions that are based on purely 25 fictional facts and figures. A, for instance, option number ANN RILEY & ASSOCIATES, LTD.

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70 1 four of the report, which is complete clean-up and removal 2 to an approved storage facility of the radioactive materials 3 has an estimated cost to implement of $467 million. With 4 that large of a price tag, I would admit that the company's 5 $200 million plus dollars in assets would fall far short of 6 covering that cost. However, that cost is false. I submit 7 as proof a letter dated November 15th, 1993 from 1:nvirocare, 8 wherein they state, and I quote: "The document quotes $467 9 million as the cost of offsite disposal at Envirocare.

10 Since we have not received an inquiry from Shieldalloy, we 11 do not have adequate information to determine the exact 12 disposal fees. However, it is my understanding that the 13 material at the Shieldalloy site may approach five million 14 cubic feet, and, for such a large volume, our disposal fees 15 currently are clearly less than $10 per foot. 11 16 The letter goes on to fault other assertions of 17 Shieldalloy*s decommissioning report. I, at this point and 18 time, do not have enough information to endorse or recommend 19 against Envirocare as a site of choice to dispose of the 20 radioactive waste from the shield allow site.

21 However, their letter to the Nuclear Regulatory 22 Agency brings into doubt the very validity of Shieldalloy's 23 decommissioning plan. This letter, coupled with faults 24 noted by the various governmental agencies involved, should 25 be enough to through out the entire report and force ANN RILEY & ASSOCIATES, LTD.

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71 1 Shieldalloy to allow the decommissioning report to be 2 prepared by an uninterested outside source.

3 These faults cited by the Ohio EPA, the NRC and 4 others, include but are not limited to the following 5 examples: One, Shieldalloy's soil concentrations would 6 exceed the option one concentrations limits for natural 7 uranium and, therefore, the site could net be released for 8 unrestricted use; two, adoption of a specific dose objective 9 would have to be justified by site-specific alloy analysis.

10 Shieldalloy has not done this; three, after the license is 11 terminated, there is no restriction on the use of the land 12 and, therefore, no guarantee that the cover will be 13 maintained over its intended life or that it will continue 14 to be effective in shielding humans from direct gamma 15 radiation; four, soil ingestion is not included among the 16 pathways listed; five, the report did not provide a 17 rationale for using a drinking water intake of 410 liters 18 per year, and places the restrad default value of 510 liters e 19 per year, or the NRC's default value of 730 liters per year.

20 These are five of the dozens of deficiencies pointed out by 21 the Federal and state agencies who reviewed the Shieldalloy 22 decommissioning report.

23 Two. Despite the company's view that they are 24 scapegoats, I would like to point to a letter from the City 25 of Cambridge, wherein, I quote, it states: "Since SMC has ANN RILEY & ASSOCIATES, LTD.

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72 1 rather consistently violated its permit for free chlorine 2 and other pollutants, notably chromium, without what I 3 consider much regard for permit compliance, nor requirements 4 to notify the city when any such violation has occurred, SMC 5 is fined $5,500 payable to the City of Cambridge."

6 Three. I submit, as a final example of why 7 Shieldalloy cannot be trusted, a letter dated November of 8 this year from the Ohio EPA, wherein Shieldalloy is cited 9 for a total of 12 separate brand new violations of the Ohio 10 revised code. As you can see, Shieldalloy does not deserve 11 our trust in the cleanup of this site.

12 I would like to discuss the pros and cons of all 13 six of the alternatives in the Shieldalloy decommissioning 14 plan. Option one is simply to do nothing. Being as the NRC 15 has known about this site for 20 years and done exactly 16 that, nothing, I am surprised they haven't already approved 17 option one. However, the reasons this option will not work 18 are very simple. Offsite migration of radionuclide 19 contamination thereby contaminating the water source and 20 exposing the human population, as well as the entire flora 21 and fauna to tremendous health risk, including birth defects 22 and cancer.

23 Option two is the one that Shieldalloy Company 24 actually favors. The reason they favor this option is two-25 fold. The first, in my opinion, revolves around corporate ANN RILEY & ASSOCIATES, LTD.

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73 1 greed. The cost is less than $2 million. The second reason 2 they favor this option is very simple. It is a glorified 3 version of option one, which is to do nothing, simply 4 putting a cap over a problem in the old out-of-site, out-s of-mind scenario, has not and will not ever work. We deal 6 with the problem and it is a very real menace to our health 7 now, or we deal with it in the future. Perhaps, if the NRC 8 had done its job back in 1974, Cypress Foote Mineral, would 9 have already done the decommissioning work at a much lower 10 cost than today's efforts will cost either the company or us 11 the taxpayers.

12 This option does not meet any of the following NRC 13 rules and regulations: One, NRC's branch technical 14 position, disposal or onsite storage of thorium and uranium 15 waste from past operations, which is why the company is 16 seeking exemption from NRC regulations, as allowed under 17 Section 10 Code of Federal Regulations 40.14. Nowhere in 18 the NRC regulations is there anything giving this agency the -

19 right to grant such an exemption that would leave the 20 citizens of Gurnsey County at great risk to their health and 21 safety for billions of years to come.

22 In fact, I would propose that, if the NRC is even 23 seriously considering this proposal, that they, the NRC, and 24 the Federal Government sign a contract with each and every 25 citizen of Gurnsey County, wherein they agree to accept all ANN RILEY & ASSOCIATES, LTD.

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74 1 of the moral, legal, and financial obligations, should the 2 proposed decommissioning plan fail to provide the safety we 3 deserve as United States' citizens. Their refusal to do so 4 is absolute proof that option two will fail.

1 5 Two. Section 40.42 discussed earlier this evening 6 options one and two can never meet any of the 7 requirements i*1 this section in the Federal Code of 8 Regulations.

9 Three. Section 40.36 of the Federal Code of 10 Regulations dealing with financial assurance and 1.1 record.keeping for decommissioning. Even should the 12 exemption be granted, the company cannot guarantee the 13 monies to provide the perpetual care that would be needed to 14 maintain the cover for some 14 billion years; in fact, not 15 even our own Federal Government could make that kind of a 16 guarantee, let alone a company attempting to escape its 17 moral and financial obligations through the Federal

- 18 19 20 Bankruptcy Courts.

disposal.

Option three is relocation of slag and onsite Again, this is the world-famous shell game 21 scenario of which shell is the crap under. Anywhere on the 22 site the slag materials sit on a flood plain and also the 23 _ company does -not have the ability to guarantee our safety, 24 nor the health of our future generations. Any disposal 25 method that leaves the materials onsite or in the hands of ANN RILEY & ASSOCIATES, LTD.

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75 1 Shieldalloy has to be unacceptable.

2 Option four is the workable solution. For 3 starters, it allows the site, as required by NRC 4 regulations, to be returned to unrestricted use. It removes 5 the materials from the wetlands, as well as the 100-year 6 flood plain. We already know that the Company's figure of 7 $467 Million for this option are bogus.

8 As to where the money is going to come from, I 9 would make the following suggestions: One, our entire 10 Governmental leadership has failed us, by failing to 11 exercise good judgment and enforce regulations. In plain 12 language, you are guilty of gross negligence. You should 13 pay whatever portion of the bill cannot be covered by other 14 parties who have a legal and financial responsibility to 15 clean-up the mess they ~reated.

16 Two, although in Federal Bankruptcy Court, 17 Shieldalloy has close to or over $100 million in assets, 18 above and beyond their liabilities, they volunteered to 19 accept responsibility to decommission the site, if 20 necessary, liquidate their assets and use the revenue to 21 remediate the site.

22 Three. Let's not forget Foote Mineral, who was 23 bought out by Cypress, and is now called Cypress Foote 24 Mineral Company. The latest financial sheets that I pulled 25 on the company show assets of over $5 billion. They have a ANN RILEY & ASSOCIATES, LTD.

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76 1

moral, if not legal obligation to the citizens of this 2 county to see that the site is properly cleaned up and 3 returned to full, unrestricted use.

4 Options five and six are not even worthy of review 5 because, by the company's own admittance, the technology to 6 implement them is still in the developmental stages.

7 I have now touched base on the six available 8 options. On behalf of the Save the Wills Creek Water 9 Resources Committee, I would like to state for the record 10 that we feel it is a fair and workable solution that takes 11 into effect the safety and health concerns of all of the 12 citizens of the county, but also deals with the workers of 13 Shieldalloy who, through Governmental delays, corporate 14 misconduct and greed, stand to pay the highest price.

15 With that, we*would like to suggest the following 16 10-point clean-up plan. One. There are approximately 100 17 people employed at the Shieldalloy plant in Cambridge. More

- 18 19 20 than likely, they will be displaced as a result of the cleanup of the plant site. We propose that, within the decommissioning to plan be approved, $10 million be set 21 aside into ,some type of an investment account. The interest 22 and dividends from this account would generate at least 23 $600,000 a year. These new revenues should be equally 24 distributed once a year to the employees of Shieldalloy 25 company until their death. Once the last employee has ANN RILEY & ASSOCIATES, LTD.

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77 1 passed away, the entire escrow account should be turned over 2 to Gurnsey County's Government to be used to improve and 3 build the inf~astructure that would attract new, viable, 4 much needed industry to our area. In this action, you at 5 least provide a stipend to the displaced employees that 6 would amount to some $6,000 a year. You, in the future, 7 would also repay the County for all that it has done over 8 the years for the companies that occupy the site and brought 9 so much trouble and worry to our county.

10 Two. All parties to the suit agree to open up two 11 document repositories here in Gurnsey County, Ohio. The 12 first will be sited at the Gurnsey County Library and the 13 second is to be placed with the Save the Wills Creek Water 14 Resources Committee.

15 Three. Option four becomes the only acceptable 16 means of remediation of the site, and a11 parties agree to 17 abide by Senate Bill 130, now in statute form, which would 18 make it illegal to leave the radioactive slag onsite.

19 Four. As part of the decommissioning, NRC perform 20 a rad fly-over of the entire county to assure the citizens 21 that none of the hot slag was sold in the past as road or 22 construction fill.

23 Five. The Save the Wills Creek Water Resources 24 Committee be recognized as the official watchdog group for 25 the cleanup of this site.

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78 1 Six. In conjunction with the slag piles, the Ohio 2 SPA take all steps necessary to also decommission the other 3 environmental problems at the site, including hazardous 4 waste, as well as the chromium contamination in and around 5 the bag house.

6 Seven. The NRC enforce all portions of the 7 Federal Code of Regulations pertaining to this site, and 8 deny the exemption sought by Shielda.lloy.

9 Eight. The Ohio EPA also enforce all Ohio rules 10 and regulations in reference to this site, including civil 11 penalties, and/or criminal charges against Shieldalloy's 12 management for their ongoing violation and disregard of 13 Ohio's laws.

14 Nine. If the Gurnsey County water supply is 15 threatened during cleanup, the NRC include, as part of the 16 cleanup cost, the money it would take to lay a 12-inch pipe 17 out the Salt Fork to access the second water supply.

18 10. To assure that moneys are available to clean 19 up this site, the Shieldalloy site must be accepted into the 20 Superfund cleanup program.

21  ! would also at this point like to point out that, 22 for various reasons, a lot of the information on this site 23 is not yet available to the general_public. The U.S. EPA's 24 water test results, the Ohio EPA's verified complaint 25 findings, and the NRC's own findings of tests conducted in ANN RILEY & ASSOCIATES, LTD.

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79 1 October at the site are but a few of the documents not 2 released for general consumption. I feel it only fair that, 3 realizing this impact, the NRC agrees to an additional town 4 meeting after this information has been provided to the 5 general public of Gurnsey County, Ohio.

6 Thank you.

7 MS. STINSON: Chris Trepal.

8 [Applause.]

9 MS. TREPAL: My name is Chris Trepal. I am the 10 Co-Director of the Earth Day Coalition in Cleveland, Ohio.

11 My organization has been working on an SDMP site in 12 Cleveland for the past four years. To those of you who 13 haven't already guessed, it is not a pretty'process.

14 I did have a process question to the NRC. A lot 15 of folks have asked questions that have not received 16 answers. When you generate the document from tonight's 17 meeting, will those questions be answered in the text?

18 Because I planned to ask about a dozen questions. That was 19 one of my first ones.

20 MS. STINSON: Good. I am glad you asked that 21 question. I think the answer is we will have to give 22 that question to the correct individual.

23 MR. WEBER: I think our intent would be to --

24 since we are preparing this document at the beginning part 25 of the process, we can only answer those questions for which ANN RILEY & ASSOCIATES, LTD.

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80 1 we have the answers. If it is the kind of question that 2 deserves an answer that has to come out of some thoughtful 3 evaluation, we won't have those answers until we go through 4 that and get the draft EIS.

5 MS. TREPAL: Okay. We will look for some answers 6 then when it comes out.

7 A previous speaker had referred to this fact --

8 and I guess -- I mean, I don't expect you to answer now; 9 but, my understanding is that, on the NRC's part, there are 10 no specific regulatory guidelines at the moment, and that 11 the Federal agencies do not have compatible regulations.

12 So, I have to kind of echo one of the previous speaker's 13 comments. I am a little concerned that at the beginning of 14 this process, you know, we have an incomplete set of 15 regulations on behalf *of the regulators.

16 I also wanted to bring up our newly-enacted BRC 17 bill, Senate Bill 130. At the other site that I am ,working

- 18 19 20 on in Cleveland, it is the opinion of the state agencies that onsite disposal would conflict with the certain statutes of Senate Bill 130. I was wondering if the various 21 state agencies and the NRC how they have taken that into 22 account. At the site that I am working on, the latest 23 information we have that all solid waste landfill rules 24 would apply to an onsite disposal, including post-closure 25 regulations, and I wondered how that information would apply ANN RILEY & ASSOCIATES, LTD.

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81 1 here?

2 I would like to know what the total quantity of 3 the materials processed was during the 20 years at the site 4 and the total volume and curie content of the licensable 5 materials.

6 I was very disturbed to here words thrown around 7 like seasonal flooding, flood plains and wetlands. I think 8 it is absolute lunacy to even consider onsite disposal when 9 this is the quality of the land that we are talking about.

10 I am wondering what the NRC and other state agencies are 11 going to require in terms of hydrological and geological 12 assessments.

13 We very much oppose any proposal for dilution. We 14 think that it is just absolutely not the way to go. Our 15 company in Cleveland and the NRC have sort of agreed 16 well, the company has agreed not to do dilution at our SDMP 17 site. I would like to ask the company to consider such a 18 pledge to the citizens of this county.

19 In terms of the run-off control, my understanding 20 is that there is some run-off control done at ~he piles now.

21 What is done with this contaminated run-off? Where does it 22 go? How is it treated? Is it processed? Who is it 23 processed by? What happens to it?

24 I am really concerned -- and I need to throw this 25 back on the NRC. How did the NRC allow Vanadium and Foote ANN RILEY & ASSOCIATES, LTD.

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82 1 Mineral, their license to lapse? I'think that is a very 2 disturbing sentence. It needs some looking into.

3 We oppose the unrestricted publi~ use of lands, if 4 there is going to be onsite disposal. Uranium-238 has a 4.5 5 billion half life. I don't know what anybody could do to 6 protect the public health and safety for four and a half 7 billion years.

8 We are also opposed to Shieldalloy being released 9 of their license. We feel that we need to hang onto 10 responsible parties. Regulations change, the weather 11 changes, the proposed cap can change. A lot of things can 12 happen. Our only security is that we have a responsible

13. party, and that means the license.

14 I wondered if the site characterization has been 15 deemed adequate and has been accepted? I don't really have 16 all of the documents. I haven't reviewed it. I had a lot 17 of questions about that.

18 My understanding was that there were past 19 decommissionings. I would like to know where the past 20 decommission materials were sent, volumes and activity, 21 where they were put.

22 I also wonder if any of the materials from the 23 site were sent offsite. I would like to have those records 24 made available in terms of volume and where they were sent 25 and if they were used for fill or construction materials.

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83 1 I have a question. If an option is chosen, like 2 onsite disposal, what would happen if let's say in another 3 30 years regulations changed and were strengthened, would 4 that mean the company or the responsible party or the 5 citizens of Gurnsey County would have to go back to the site 6 and make other changes?

7 I had a question. If both site8 were totally and 8 completely fenced off and there was signage, I didn't quite 9 -- I know it seemed like one of the piles was completely 10 fenced. I wasn't sure about the other one.

11 I have a lot of concerns about the bankruptcy 12 impact. I think where there isn't money -- we have a very 13 very hard time talking about a cleanup. I saw a little note 14 on one of the slides, in terms of even this very process, if 15 bankruptcy were declared, that the EIS process might be 16 discontinued. I would 'like to know from the NRC what 17 happens if that in fact comes to be.

18 I would-like to know -- I am pretty sure that what -

19 we saw were average concentrations of waste. I would like 20 to know what the very highest concentrations .of the waste 21 are. Maybe that exists in some documents I don't have.

22 I would like to know what the proposed thickness 23 of the cap is? At our site in Cleveland, the proposed 24 thickness was 16 feet. I have a hard time imagining a big 25 lump of waste with yet another 16 feet of fill, but maybe it ANN RILEY & ASSOCIATES, LTD.

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84 1 can happen. So, I would like to know what is being proposed 2 here.

3 I am really concerned -- and I am not quite sure 4 if I heard this right that assumptions based on either 5 site characterization or some studies from New Jersey might 6 be used for the site here in Ohio -- if that isn't true. I 7 think it is really inappropriate.

8 I am also very concerned that what I thought I 9 heard was that hazardous waste was used to cap one of the 10 piles. I think that is pretty indefensible, if that in fact 11 did happen.

12 I would like to know if there is any record of 13 trespassing over the waste piles in the past 30 years if 14 there are any records of animal traffic, children, hikers, 15 hunters, whatever in the area. I am not real familiar, so 16 maybe it is not an appropriate question, but I would like to 17 ask it.

18 Finally, I just had kind of a philosophical 19 question about above-ground disposal and cap integrity. I 20 have h~ard of a lot of below-ground disposal where, you 21 know, a cavity is excavated and the contaminated materials 22 put in and then capped. I am just really concerned that we 23 have an above-ground disposal proposal -with a t~tally 24 three-quarters of the waste pile would be enclosed in a cap.

25 Finally, I had a question about one of the ANN RILEY & ASSOCIATES, LTD.

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85 1 comments that was made on the slides. In terms of an 2 exposure rates, r thought I heard one of the NRC folks say 3 that the west capped piles exposure rate was cut the 4 gamma exposure rate was cut because of the capping. I 5 thought that was very unusual, and I didn't know that you 6 could -- I thought gamma required actual shielding, concrete 7 and lead, and I wasn't aware that dirt could be used for 8 shielding. So, those are my questions. Thank you.

9 [Applause.]

10 MS. STINSON: We have two more commenters in this 11 category. Let me just give you a check on where I think we 12 should head. We will ask these two commenters to keep their 13 comments to three minutes or as close to it as you can. And 14 then we will go on to the other two categories that have 15 listed -- requested time.

16 Then I think it would be a good idea to spend some 17 time answering some of the questions that have been posed.

18 So, if you hear a question posed that you know you have --

19 or you would like to offer an answer to, there will be time 20 to do that in the discussion, question and answer period at 21 the end. Also, note that we are hearing sort of two kinds 22 of questions -- one kind of question offers an answer -- or 23 poses a question that can be answered now as a factual-type 24 question. I think another type of question we are hearing 25 forms or somehow shapes the EIS analysis. I see NRC madly ANN RILEY & ASSOCIATES, LTD.

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86 1 writing over here. Hopefully they are getting some of these 2 questions down that can be reflected in the EIS scoping 3 document -- the scoping summary that will come out.

4 The next speaker is Bob Greenbaum.

5 MR. GREENBAUM: Okay. Thank you. In the interest 6 of time, I am going to submit my comments to you in writing 7 by the 14th. I would like to comment very briefly on a few 8 things that I think have not quite been touched on 9 adequately here.

10 To begin with, I am Bob Greenbaum. I am down here 11 representing the Sierra Club, Ohio Chapter. The Sierra Club 12 is a half million member, nation-wide group of 13 conservationists with about 17,000 members here in Ohio. We 14 have had contact and work with a number of radiological 15 problems around the co~try. We have worked with Senator 16 Glenn on the Fernault problem and in a number of the 17 Department of Energy sites.

18 I would just like to comment to the community at-19 large, and particularly to the workers and management of the 20 Shieldalloy plant. You are undertaking a journey right now 21 that, although it looks on paper like this will be completed 22 in a one-year period, the experience of the site that Chris 23 Trepal was talking about in Cleveland is that s.o far it has 24 been four years and they have not reached the first 25 milestone at this point yet on characterizing the site and ANN RILEY & ASSOCIATES, LTD.

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87 1 agreeing on the scope of the delineation. So, in all 2 likelihood, you are facing a rather extended learning and 3 study period here. I ask you to take into account during 4 this period that this is a problem of survival in the short-s term -- people have got to eat, you have got to have jobs.

6 It is also a problem of survival, in the long-term. Any 7 site that is contaminated beyond use, there will be no new 8 industries located on these sites. We have to keep that in 9 mind. Your children and grandchildren won't live here if 10 you have a site that is contaminated beyond possible use.

11 So, there is a balancing that goes on between the 12 long-term of the community, the short-term survival, and you 13 are going to have adequate time over the next several years 14 to evaluate this as a community. Don't make any real early 15 judgments here. Perhaps some of those who are coming to you 16 from the outside that you perceive as your enemies are your 17 best friends. Perhaps we have some information for you that 18 you are not aware of.

19 We would be happy to help you network with some of 20 the workers and their unions at some of the other facilities 21 that have faced radioactive waste problems, where the 22 consistent message has been, first, the workers were 23 informed, there was no problem and everything was safe.

24 Secondly, that there were no health effects and so forth.

25 First, there was stonewalling, second there was denial, ANN RILEY & ASSOCIATES, LTD.

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88 1 third, there were lies, finally there were lawsuits, lastly, 2 the truth came out.

3 There has been a long record in the nuclear and 4 chemical industries of these things. I ask you to consider 5 the historical record of other sites. I ask the workers of 6 this plant to network with some of the workers at the 7 Fernault facility, oil, chemical and atomic workers -- to 8 network with some of the folks at the Piketon facility. I 9 could put you in touch with some of their union leadership -

10 - to network with the steelworker local, I believe it is in 11 Ashtebulah, at a radioactive site RMI, where the past 12 president of the union is currently dying. So, these are 13 the kind of things I want you to consider slowly over time.

14 The Sierra Club is here to support the 15 environmental perspective in this, to work with the 16 community in all of your concerns, as outdoors people, as 17 drinkers of water, breathers of air, and as workers in the 18 plant. We are going to be here for quite some time. We are 19 going to be here to support the free exchange of ideas. We 20 will do that legally, if we have to. We will do that with 21 amicus briefs, it looks like there are slap suits being 22 instituted, as we have elsewhere in the country. But, most 23 of all, we will be here speaking for the environment and 24 seeing what we can do there.

25 We view this and want the NRC to realize this -

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89 1 - as kind of a test case of two things. Ohio has been asked 2 to become both an Agreement State and to host a radioactive 3 waste dump for the Midwest Radioactive Waste Compact. We 4 also understand from some research that Senator Glenn's 5 office has done that there are 800 other sites like 6 Shieldalloy in the state here. Most of them have not been 7 characterized. We can get you the information on that.

8 We ask you where are these sites? We want to know 9 what the public record has been on those sites, in terms of 10 the health protection of the communities, not only here in 11 the Cambridge area, but at these other 800 sites.

12 Again, you are asking us to do two things, NRC.

13 You are asking us to become an Agreement State. What are we 14 agreeing to? Are we agreeing to the standard of cleanup and 15 enforcement that we have seen here so far -- that we have 16 seen in some of the other facilities around the state, such 17 as Bird Avenue in Cleveland? What are you asking us to 18 agree to? Okay. The second thing that we are concerned 19 about here is that we are being asked to host a low-level 20 radioactive waste dump. So, the standards that you will 21 e*nforce here are something that we are going to publicize 22 around the state, because the record of your enforcement and 23 the kind of work that you do will reflect how the citizens 24 of ohio can expect to be treated several generations 25 downstream for the waste that you are proposing through the ANN RILEY & ASSOCIATES, LTD.

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90 1 Midwest Compact being imported in through Ohio.

2 And this doesn't involve only you. We ask that 3 you and your Environmental Impact Studies collaborate 4 closely with the Ohio EPA, the Federal EPA and so forth. I 5 have walked this'site. I have been on the site. This site, 6 in my opinion, would not qualify as a garbage dump under the 7 rules in place in Ohio, much less a hazardous waste dump, 8 much less a nuclear waste dump. In walking the perimeter of 9 the site, you walk on wetlands. There is run-off directly 10 into a stream.

11 Now, my understanding is -- and please correct me 12 if I am wrong on this -- my understanding is that Thorium is 13 water-soluble; is that correct? Okay. You can look at some 14 of these things. I think it should be a thorough 15 characterization, not only in terms of nuclear things, but 16 in terms of the hazardous materials on this site.

17 Again, we will submit our comments to you in 18, writing; but I think we should all prepare for a lengthy 19 process, with much sharing of information. I do not have 20 all of the information. I am looking forward to learning 21 from the NRC, from the EPA, from the plant management, from 22 the citizens and from the workers here. We ask you to be 23 open to some other information also in this very long 24 process.

25 Thank you.

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91 1 [Applause . ]

2 MS. STINSON: And, lastly, John Perera.

3 MR. PERERA: My name is John Perera. I am the 4 Water Co-Chair of the Northeast Ohio Sierra Club in 5 Cleveland,-and I sit on the RAP, the remedial action plan to 6 clean up one of our rivers, one of the 43 sites that runs 7 into Lake Erie. I have spent a couple of years in many 8 committee meetings with hundreds of people, thousands of 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />, thousands of pages, looking at one river and how do 10 we clean it up, of the 43 that run into the great lakes. We 11 are dealing with sediment on the Kiahogi River that has been 12 polluted for over 150 years. We thought it would never be 13 cleaned up. We now find fish living in it. You can almost 14 swim in it. No, it doesn't burn anymore. It is a very 15 complicated process and it takes a long time.

16 One of my concerns when I sat on the RAP group was 17 air pollution as well as water pollution. What goes up does 18 come down. I realize when we looked at -- which is only 19 recently established toxic release inventory of chemicals 20 found or found to be hazardous by EPA and other groups, we 21 are only looking at 20 categories of chemicals. We are only 22 looking at 300 chemicals, of thousands that are known to be 23 hazardous, which have never been evaluated by EPA. So, we 24 don't even have handles on these -- of the seven million 25 known chemicals, some of which you have both the elemental, ANN RILEY & ASSOCIATES, LTD.

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92 1 the natural and the process refined in this site.

2 I was concerned, as I listened to this and saw the 3 diagrams and the cross-sections of this that it is now 4 marked as a radioactive site. You also have mixed 5 materials, some of which are soluble. Who knows what is 6 under that site? Who knows what leeches out the bottom of 7 it? Because you are certainly not going to dig it up and 8 look at it easily. Has it ever been cored and sampled? How 9 far down does it go? Some things leech out of this by being 10 wet from below and drained out again as flooding happens in 11 this area. We also know that very small quantities, below 12 detectible limits until recently -- and our testing is 13 getting much better in detecting parts per million, parts 14 per billion, parts per trillion -- very small amounts of 15 substances getting into the groundwater, the drinking water, 16 your bodies, the air, what you eat, what your cows eat, the 17 crops you raise, get into your system and they affect you - affect you not only by cancers, leukemias, birth defects, 19 reproductive abilities; but genetic defects that affect your 20 immune system forever.*

21 We are finding that NRC, which is the son of AEC, 22 didn't know and didn't tell and actually covered up, 23 concealed and lied to us for a couple of generations. There 24 is a book that your library ought to have known as Deadly 25 Deceit. They have systematically done this when things got ANN RILEY & ASSOCIATES, LTD.

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93 1 really bad. They didn't want you to look at the fallout 2 from Three Mile Island. They didn't want to tell you about 3 Savannah River. They didn't want to tell you about 4 Millstone when it affected the Lyme Disease. Many of these 5 are changes that have happened in our environment --

6 mutations that took a long time to come into effect, and are 7 now found almost everywhere.

8 You need to look into the fact that nobody has 9 rules and regulations for some of these, and nobody has 10 tested and found the results, and you are all guinea pigs.

11 I do not know whether you can see the headline here, but 12 even the reports are trashed, covered up, and people who 13 blow the whistle are fired, ostracized, attacked on the 14 street or killed on the highway, like Karen Silkwood. This 15' is not unknown in the chemical industry. You and I and 16 workers in this community and people who live here and have 17 children are facing a million-dollar industry onsite here, 18 and billions of dollars of vested interest that don't want 19 you to know. .

20 You will have to keep asking questions for 21 yourself, for your present job, and for your future, if you 22 have one, if children are ever going to be born in this 23 area. Thank you.

24 [Applause . ]

25 MS. STINSON: Okay. Keep your questions in the ANN RILEY & ASSOCIATES, LTD.

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94 1 back of your mind. We will return to those. We have*a 2 number of representatives either from local unions or from 3 labor who would like to speak tonight. The order that I 4 have them in is John Sedor, first, from the United 5 Steelworkers of America; Joe Latchik, who is a retiree 6 actually; and Ronald -- I can't read your last name, who is 7 an employee.

8 If anybody else wants to speak, you can identify 9 yourself. Let's start with John.

10 MR. SEDOR: My name is John Sedor, President of 11 the Local 5050, United Steelworkers, of the Shieldalloy 12 Plant. I am here. I have been listening to all of the 13 comments from the different groups. I am here first to say 14 that Shieldalloy is not hiding anything. If they were 15 hiding anything, they wouldn't have even brought this to 16 anybody's attention.

17 I have got a few questions that I haven't even got

- 18 19 20 answers for. The first one was, if they didn't want to decommission this site, would there have been any stink raised at all about it? Because, for so many years, no one 21 said anything about these sites. No one knew they were 22 there. All of a sudden Shieldalloy decided to decommission 23 them, and let it known to the public. That is one reason 24 why we are here today -- is they are not hiding what they 25 are doing. Th~y are open with people. They have been open ANN RILEY & ASSOCIATES, LTD.

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95 1 with people for quite a few years since Shieldalloy has 2 taken over. They have had meetings in the past with the 3 community to solve some of these problems. They have asked 4 the community for their input. I think, working together 5 with them, they have come up and solved some problems. I 6 have been there for 20 years. I wish one man was here that 7 just celebrated 40 years. He is not glowing in the dark as 8 some of you might think. He has walked those sites, and he 9 has filled some of the slag in those sites.

10 Fr~m what I have got in the information, you have 11 got more radiation coming from*your own homes than what is 12 on these sites. The NRC has been down there many times in 13 ~?e past years. They have run tests. I am aware off some 14 of their tests that they have run. They are continuing to 15 test the grounds for leech into the water systems. From the 16 reports that I have gotten from the NRC or from Shieldalloy, 17 or from my own digging around, there is still no 18 contamination of any great amount that is going anywhere.

19 Yes, they have been cited before, as every factory 20 in this county has been cited before. So, I think that 21 people ought to wake up, because Shieldalloy is not hiding 22 anything.

23 One guy said about trust -- one guy mentioned 24 about taxpaying. Well, in the papers you can see one guy 25 don't pay his taxes. One guy, right now, through the ANN RILEY & ASSOCIATES, LTD.

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96 1 courts, of stealing documents, but yet he wants people to 2 trust him. I think it is time that people wake up and see 3 who is in the right.

4 Now, with the NRC. I have been there, like I 5 said, for 20 years. One of the main questions I have since 6 I have been there 20 years -- what effects has anything got 7 to me? As I said before, we have got ?eople who have been 8 there 40 years, and they are in probably better health than

• 9 some of the people who have never worked there. So, I would 10 like to have a report on the radiation levels and how it has 11 affected me.

12 Again, if this was never decommissioned, would 13 there be a meeting here tonight? As I read one report, I 14 see that there seems to be a difference in agreement between 15 the NRC and EPA on how to handle things. I would like to 16 know if your two companies or organizations are going in 17 opposite directions, or somewhere down the line, are we 18 going to come up with a happy meeting that everyone can live 19 with?

20 No one mentioned that a few years ago when this 21 all started that there was another group involved that has 22 done some of the onsite covering of the slag, known as the 23 west pile. That was through a national organization. I 24 believe that was Inser that came in there and dug up what 25 they did and moved material and covered it. It has been ANN RILEY & ASSOCIATES, LTD.

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97 1 covered I will say for three or four years. I may be wrong.

2 From the last report that I have got on that, is that the 3 levels are within reason. We are waiting for a cap on that.

4 Why has there never been the okay to cap it?

5 So, that is about all I have to say. As I said 6 before, if Shieldalloy was going to lie to anybody, they 7 wouldn't even have had this mneting today. Thank you.

8 [Applause . ]

9 MS. STINSON: Now, Joe.

10 MR. LATCHIK: I am Joe Latchik. I live in 11 Cambridge, Ohio. I worked at the plant that is now known as 12 Shieldalloy for 31 years.

• I started in 1955 and I retired 13 in 1

86. I have heard the talks on this slag, pro and con.

14 I realize that modern technology, you can get more results 15 than you can with a human being. I have walked over these 16 sites that they referred to for 31 years. I wore my clothes 17 that I worked in, I wore the protection that the plant 18 mandated me to wear, and I don't -- to my knowledge, I have 19 never been affected by anything in that plant.

20 You men can talk about your environment. I agree, 21 we should be aware of our environment. But, while I worked 22 at that plant, I have seen deer feed on the lawns that were 23 mowed around in the immediate area, and I have seen more 24 rabbits on that plant ground than I have seen on my farm 25 when I worked on nightshift. I have seen ducks raise their ANN RILEY & ASSOCIATES, LTD.

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98 1 young on the streams that you referred to that go past these 2 slag piles. The only thing that bothered them was the 3 snapping turtles that feeded on them.

4 I pumped the manholes that the electric current s flowed to the plant. And what I found in the manholes after 6 the water was pumped out were crayfish and earthworms.

7 You are cor*cerned. I realize you have got to be 8 concerned., but you also have got to fair-minded enough to 9 realize what you are referring to and what you are getting 10 into when you are talking about moving this slag or covering 11 it over onsite.

12 I worked there, and you can see, if it has had a 13 slight affect on me, so help me, I do not know it. You 14 listened to the Union President talk there, and he talked 15 words of wisdom. He has been there for 20 years. I think 16 you have got to listen to people like that. You have got to 17 listen to these people that work there and get their point

- 18 19 20 of view.

day. Good.

You can go down there and walk over that site one You can pass judgment on something that has been going on since 1952. But, I don't think you can get 21 right down there to the core of it. I think you should 22 think this over. This is something that affects the 23 community and, not only the community, but the children in 24 this community. It is going to cause more kids to grow up 25 in poverty -- what you are talking about. Is it going to ANN RILEY & ASSOCIATES, LTD.

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99 1 save lives or cause poverty? I think we ought to consider 2 that.

3 I looked at this fact sheet, and I agree that 4 Shieldalloy's intent is to protect the environment and the 5 people in the vicinity of the plant, and to implement the 6 safest, most effective cleanup possible. Shieldalloy will 7 continue cooperating with the Nuclear Regulatory Commission 8 and arrange for a permanent disposition of slag on the site.

9 I see no fault in that. I agree with the Commissioner and 10 the Mayor and all that this has been an asset to the 11 community. And, if it necessary, yes, but if it is not, 12 think it over and think it over hard. If it not necessary, 13 let's do what we have to and continue to have a plant 14 operating in the Cambridge area.

15 Thank you very much.

16 [Applause.]

17 MS. STINSON: Ronald. Where are you? Is he still' 18 here? Ronald -- it looks like Travis maybe?

19 [No response. ]

20 MS . STINSON: Okay.

21 We will move on to the next perspective then.

22 Finally, tonight -- at least for now, finally, we will hear 23 from a number of local business representatives. Bill Davis 24 is here from the Cambridge area -- the Chamber of Commerce -

25 - Jack Dunning, the Community Industrial Association, and ANN RILEY & ASSOCIATES, ~TD.

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100 1 Brenda Hibbs, from the Byesville Board of Trade. Bill.

2 MR. DAVIS: Thank you. It is rather difficult 3 following everyone that has used all of the key phrases and 4 terms already. My name is Bill Davis. I am the President 5 of the Cambridge area Chamber of Commerce. Our main reason 6 for being here tonight, of course, is our interest in 7 Shieldalloy and certainly, as was stated before, Shieldalloy 8 hasn't been sneaky about this. They initiated the meeting 9 and they certainly have wanted to be up-front on everything 10 they have done. I believe all the things that have been 11 done on the property by Vanadium, by Foote Mineral and by 12 Shieldalloy have been done according to the regulations and 13 the terms that were established by our Government, the EPA, 14 those bodies.

15 Shieldalloy, in one of the commen~s they made, was 16 to protect the environment and the people in the vicinity of 17 the plant. I believe they do have that concern. I have not 18 seen anything contrary to that. We certainly would be 19 supportive of that statement -- to implement the safest and 20 most effective cleanup possible. We certainly would believe 21 in that -- the safest and most effective.

22 Of course, we are concerned about losing a plant.

23 Global competition is having an effect on Shieldalloy. They 24 are now competing globally, as well as just here in the 25 United States. It certainly puts a drain on their funds.

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101 1 We certainly want to see them healthy and able to take care 2 of their plan for cleaning up the facility. Of course, 3 Gurnsey County, being in the top 10 in the state in 4 unemployment, certainly cannot afford to have a good quality 5 company leave the area. So, the Chamber, I think, would 6 just like to go on record as being supportive of Shieldalloy 7 and certainly their intentions, to this point, have been 8 honorable, and we certainly support that.

9 Thank you very much.

10 [Applause. ]

11 MS: STINSON: Jack.

12 MR. DUNNING: Thank you. I am Jack Dunning and I 13 am a businessman in Cambridge. I spend a lot of time -- I 14 am deeply involved in economic development in this county.

15 I am always glad to see the radicals on both sides of an 16 issue because they do all of the ground work that lets the 17 silent majority make sensible decisions.

18 We certainly spent an awful lot of time to develop 19 a hundred good jobs in this county. We certainly don't need 20 to see Shieldalloy leave. Thank you.

21 [Applause . ]

22 MS. STINSON: Brenda.

23 MS. HIBBS: My name is Brenda Hibbs. I am the 24 President of the Byesville Board of Trade. One of the major 25 priorities of the Byesville Board of Trade is to work ANN RILEY & ASSOCIATES, LTD.

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1 diligently for the retention of business in our area.

2 Certainly, the last thing the Board wants to see is a 3 business closing its doors or for a manufacturer to move.

4 Our area has experienced enough unemployment and loss of 5 jobs.

6 Naturally, I was very concerned when the rumors 7 began to circulate about Shieldalloy. That is why I am here 8 tonight and why I attended the onsite tour earlier this 9 afternoon. I wanted to see for myself .if indeed Shieldalloy 10 was in danger of closing; if so, why, and if there was 11 something that could be done to keep the plant*open.

12 After today's tour I was greatly relieved to see 13 how the management team at SMC is aggressively addressing 14 the problem. They are currently cooperating with the EPA 15 and the NRC to initiate a plan that is both effective and 16 cost-efficient -- cost-effective.

17 You might ask, are we allowing money to override

- 18 19 20 our good judgment or moral duty concerning the potential health hazard presented by the waste product?

believe so.

I don't The information given today explains an 21 alternative plan to contain the waste product that would be 22 safe for the employees of the plant, the residents that live 23 nearby and *even for the environment. Moreover, this plan 24 would save jobs, not just for the SMC employees, but, in 25 many cases, for their spouses as well. After all, who knows ANN RILEY & ASSOCIATES, LTD.

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103 1 how far the negative impact would reach of yet another plant 2 closing in our area. We can't afford to let that happen, 3 especially when capping the slag piles seem to be the most 4 feasible and easiest plan to execute, with minimal economic 5 impact on Shieldalloy and its employees.

6 Speaking on behalf of the Byesville Board of 7 Trade, I offer our full support and to Shieldalloy. I 8 encourage the EPA and NRC to allow Shieldalloy to cap the 9 slag piles as a solution to this problem. Thank you.

10 [Applause.] -

11 MS. STINSON: There are two other representatives 12 of local businesses who would like to speak. Who are they?

13 Come on up.

14 MR. DeDINATO: Hi. I am Greg DeDinato, the State 15 Representative for the Gurnsey/Tescarales County area. I 16 guess I am basically here today to say probably for someone 17 who has experienced -- this is probably my fifth site in 18 three years of being in office that I am going through --

19 problems with environmental problems on the sites. I guess 20 what I would like to express and also be involved in some 21 environmental issues in Columbus is to the NRC Commission is 22 basically to move very -- I guess slowly, but very 23 professionally on this. I think we have to use common 24 sense. I think so often we are driven by emotions and some 25 of our actions sometimes are extremely severe, extremely ANN RILEY & ASSOCIATES, LTD.

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104 l expensive and really do not resolve a problem.

2 I guess I caution -- I think we need to work with 3 the company. I think we need to be open and honest to all 4 here -- citizens, employees, and everybody. I think there 5 needs to be honesty through the whole process. I think we 6 have got to deal with the problem practically. This problem 7 didn't come overnight. It is not going to go away 8 overnight. And driving the business out of business, to 9 stick the tab to the taxpayer is not sensible. If most of 10 you have any knowledge of the Superfund, you will find that ll it has done a very poor job. 80 percent of it goes to legal 12 fees -- it doesn't go to cleaning up -- and consultant fees.

13 I have a site that is currently -- just got 14 finished after about 25 years in Jeanette, Ohio that was 15 under the Superfund. So, if anybody thinks by shutting the 16 business down or not working with them is going to clean it 17 up tomorrow, they are wrong. We will probably go another 20

- 18 19 20 or 30 years.

I just am here to express -- to please take a good look at the whole situation, act with good conscience on the 21 problem and a practical sense, because I have also learned 22 there are a lot of things -- we have spent millions and 23 -billions of dollars in this country thinking we have cleaned 24 up a problem, when really we did not resolve the problem.

,25 When you get into these types of situations, whether we move ANN RILEY & ASSOCIATES, LTD.

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105 1 it around, whether we pass the buck, or what we are doing, 2 we still do not have the technology, in marty ways, to deal 3 and address the problems we have created today that we have 4 to clean up. They are not available.

5 -I guess what I am saying is to spend millions and 6 millions of dollars to haul it away, may not be the 7 practical sense here. So, I am, again, encouraging the 8 state representatives -- some of you are familiar with the 9 area -- like I said to use good common sense to address the 10 problem. I think common sense would be to try to work with 11 all parties involved to come up with a solution.

12 Thank you.

13 [Applause.]

14 MR. CELEBREZZE: My name is Tony Celebrezze. I am 15 Senator Robert Birch's ~egislative Aide. Senator Birch 16 picked up Gurnsey County with the 1990 reapportionment and 17 redistricting. Unfortunately, he had a prior commitment 18 tonight and asked me to come o~t and listen. Tomorrow, we 19 will be giving him a full report on the different aspects 20 and the different opinions that have been voiced here. He 21 is deeply concerned about this issue. He was involved with 22 the low-level radioactive waste dump that the Governor said 23 is going to be slated to come into Ohio. He sat on the Blue 24 Ribbon Commission. He is very concerned with the 25 environment, yet we still need to look at the economic ANN RILEY & ASSOCIATES, LTD.

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106 1 aspect -- the economic impact that closing down Shieldalloy 2 can have on Gurnsey County.

3 As the Chamber of Commerce gentleman did say, the 4 uew unemployment figures for Gurnsey County were not very 5 optimistic this past month and a half ago. So, we need to 6 look at the two different aspects, the environment and the 7 economic impact. There has got to be a medium ground. We 8 need to search it out and we need to work together. We will 9 come up with a solution.

10 Thank you.

11 [Applause.]

12 MS. STINSON: So, hopefully, this format has given 13 us an opportunity to concentrate a bit on the various 14 perspectives, but still give everybody an opportunity to I

15 make a few comments. I. think one of the things you could 16 say about everything you have heard this evening is there 17 are obviously some severe differences in viewpoint and the 18 problems I would say in many sectors in development of 19 trusting relationships and a real understanding of other 20 people's perspective. I think, above all, we can respect 21 that people here tonight have expressed a lot of passionate 22 care for the perspectives that they offered. That is 23 something that means that there is a lot of energy behind 24 the debate that is taking place now and the scoping process, 25 the actual fa~tual information gathering process that the ANN RILEY & ASSOCIATES, LTD.

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107 1 NRC will be pursuing from this point on.

2 It is clear that more information needs to come 3 out as a result of the development of the EIS. So, I think 4 you all are in a good place. We heard a lot from different 5 folks around the room about cooperation and beginning to try 6 -- or continuing to try to work together in trying to better 7 understand what is going on on the site. So, I would put to 8 you that, in some ways, you are really an opportunity point 9 here for moving that whole process forward, if you choose to 10 do that. I appreciate, as a facilitator, all of the 11 tolerance that you all have had for each other's points of 12 view.

13 I hope that you have accumulated some questions 14 that either you have now or answers to questions that were 15 posed -- factual questions that were posed before that you 16 would like to address. We are going to open it up now and 17 ask folks to either well, if you have a question or 18 19 20 comment, initially, you are going to have to use the microphone and then whoever if it is appropriate for someone to respond to that and you would like to do that 21 get recognized and go up to the microphone also.

22 So, we will open it up now for questions or 23 comments -- on comments made previously.

24 [Show of hands.]

25 MS. STINSON: Yes. Come on up. Let me say also, ANN RILEY & ASSOCIATES, LTD.

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108 1 time-wise, I will check back with at about 10:00 o'clock.

I 2 We may take a few extra minutes, if we are rolling with the 3 question and answer period, if people want to do that.

4 MR. GREENBAUM: Thank you. I have a question. I 5 have been hearing a repeated theme here tonight from several 6 sectors that say Shieldalloy is going to go out of business .

.7 N?w, I am just curious. I haven't seen the financial sheets 8 here or anything else, but I would like to ask the company 9 and the union -- and the Government officials have* all 10 testified that Shieldalloy is going to go out of business.

11 Has the company told you that, if they have to do an 12 expensive cleanup here that they are going to fold? Is that 13 -- because I want to share with you something about that.

14 Okay. Again, I don 1 't know the specifics of the.bankruptcy 15 situation your c;:ompany .is in, which clearly puts you gUys in 16 a nerve-racking position here. But, I do want to say to you 17 that there has been a history in American business, in other

• 18 19 2*0 sectors, of going into bankruptcy as a way of avoiding environmental responsibilities.

I urge you, for example, to read something called 21 the Asbestos Papers, from many many years ago. In 22 particular, the union guys here may wish to contact the 23 Machinist Union, because about 12 years ago they put 24 together a series on that, where there were health studies 25 done on asbestos that were suppressed for 40 years that the ANN RILEY & ASSOCIATES, LTD.

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109 1 company knew about -- knew about, and it finally came out.

2 When they were called on to pay their share, they went 3 bankrupt. Now, I don't know if that is the situation here.

4 I also want to share with you another point of 5 view on that, and then I would like to hear from the Company 6 and the union about this thing. It sounds to me like a 7 threat of blackmail. We are going, if you guys make us 8 clean this thing up. That is what I have been hearing. I 9

• hope I am wrong on that.

10 You hear these kinds of things. There is a 11 wonderful book out by a guy named Richard Grossman, who used 12 to head up a group called the Environmentalists for Full 13 Employment, out of Washington, that worked with a number of 14 cities and unions on this kind of thing. You have a 15 situation that is called job blackmail, which is that it is 16 likely that people will say*to you, yes, either reduce your 17 wages, work in intolerable conditions, ignore the health and 18 safety threats of equipment or the stuff you are breathing.

19 Has anyone here had health studies? Do you know if you have 20 uranium in your lungs, like my friend Vina Colley from 21 Portsmouth does? Have those things happened here?

22 I guess my major question that I would really like 23 to know is has there been a threat that, if there is a real 24 cleanup here, and it is very expensive, this plant is going 25 to close? Has that happened? Thank you.

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110 1 MS. STINSON: I would invite either 2 representatives from the company or a labor representative 3 to specifically answer that question, if you would be 4 willing. I am sorry, sir. Actually, I was pointing to this 5 gentleman up front. Did you have an answer?

6 MR. OLIVER: My question is is the gentleman a 7 resident?

8 MR. GREENBAUM: I am an out-of-towner. I am from 9 Cleveland.

10 MR. OLIVER: It seems like everybody is from out-11 of-town. The local folk here, I am 12 MS. STINSON: I am sorry, if you want to make a 13 speech, you are going to have to use the mike.

14 MR. OLIVER: I may not need the microphone. It 15 might not be necessary. I have got kind of a loud voice. I 16 am the appointed Recording Secretary of the Joint Safety and 17 Healtn Committee at the plant. I want to talk to the, local

• 18 19 20 people here. Listen to the local people.

referred to tonight as thugs, murderers and --

MS. STINSON: I am sorry, sir.

We have been You are going to 21 have to stay with the mike. And also, please keep the 22 comments related to the questions.

23 MR. OLIVER: I am just trying to talk to the local 24 people here -- that -- the local people are backing us all 25 up -- Mayor Valentine, Mayor Shaub, the business community.

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111 1 The only people that seem to be against us are the out-of-2 towners. That is my point, folks.

3 [Applause. ]

4 MS. STINSON: Thank you.

5 Let's take other questions that you may have of 6 representatives he~e tonight or comments that you would like 7 to make an answer to -- previously stated questions.

8 [Show of hands.]

9 MS. STINSON: Yes. Please.

10 MS. HOWARD: Hi. I am local. I am Nancy Howard.

11 I.have some information that I would like to submit to the 12 Nuclear Regulatory EIS study, if that is possible.

13 MS. STINSON: Okay. Sure. You can submit it.

14 MS. HOWARD: It is entitled the Phase I 15 Environmental Assessment. It covers everything from 16 watershed, our drinking water, to what is in the soil. I 17 believe there is a whole other there is a whole run I 18 19 20 am sure someone else could probably describe it a lot better than I can. But, I really feel that this is critical.

• NRC needs to have this documentation.

The 21 MS. STI~SON: Thank you.

22 I believe we have an SMC representative willing to -

23 answer the previous question. Sorry I missed you, sir.

24 MR. FINN: My name is Michael Finn, and I am the 25 Corporate Secretary of Metallurg, Inc., which is the holding ANN RILEY & ASSOCIATES, LTD.

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112 1 company of Shieldalloy. In answer to the question whether 2 an expensive cleanup would put everyone out of a job, I 3 would just like to say a few words about the bankruptcy 4 system and the filing under Chapter 11 of the Bankruptcy 5 Code. We-filed under Chapter 11 and the Court gives us --

6 gives anyone who files under Chapter 1i 120 days in which to 7 come up with a business plan. And the business plan is an a analysis of what you would do to get on a proiitable footing 9 again so that you could pay your creditors, perhaps not a 10 hundred cents pn the dollar, but perhaps 80 cents on the 11 dollar or 60 cents on the dollar, whatever.

12 We are now in that period where we have to come up 13 with a business plan. In order to come up with a business 14 plan, you have to quantify, put a figure on your 15 liabilities. It suddenly becomes an emergency; whereas, in 16 the past, negotiations with the EPA and with the.NRC could 17 have dragged out or be postponed until those organizations 18 came to decisions or until certain tests have been carried 19 out, et cetera, et cetera, the expenditure could be put off 20 and all of.the work could be put off. That is no longer the 21 case. We have a short period of time in which we have to 22 say our liability to the NRC is X-million.

23 I can tell you that, if we had to meet an 24 expenditure like 350 million or 250 million or $150 million 25 to cart all of the.material offsite, there would be no ANN RILEY & ASSOCIATES, LTD.

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113 1 further existence of Shieldalloy or Metallurg, its holding 2 company. So, that I think answers that question.

3 If I could just mention -- just say one additional 4 point. That is you may not -- or certain speakers may not 5 like the idea of leaving material onsite, and they say it 6 must be much better to move it off somewhere else. I would 7 like you to bear in mind two things. First of all, if you 8 move it off somewhere else, you are perhaps polluting that 9 somewhere else. And the second thing I wanted to say was 10 that, if you are going to move it off somewhere else, 11 whoever is going to pay for it is not going to be 12 Shieldalloy or not going to be Metallurg, because those two 13 organizations will not exist. It will be paid for by the 14 taxpayer. Whereas, under an acceptable business plan, the 15 problem might be dealt with after one year or after two 16 years, if those companies didn't exist and the problem was 17 18 19 just left with the NRC, because I think the Shieldalloy site must be comparatively low-priority, I think it might be 10 years, it might be 15 years, it might be 25 years before any

-}

20 work was done on the site whatever by the Government 21 agencies. Thank you.

22 [Applause . ]

23 MS. STINSON: Carolyn, do you have a follow-up to 24 that?

25 MS. ARNOLD: I just wanted to say to that that the ANN RILEY & ASSOCIATES, LTD.

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114 1 proposal to move it offsite would be sending it to a 2 facility that is licensed to dispose of low-level 3 radioactive waste, which would do it in a really different 4 manner than just leaving it piled with a grass cap.

5 I had a question about the posting of signs. I 6 went to the site this afternoon and I didn't see any signs 7 posted by the west pile. I also noticed that in the diagram 8 of the west pile and the cap it_ shows this cap that goes 9 across the whole thing. But, what I saw was that the top 10 was capped, and you could see the slag still at the bottom.

11 It looked like erosion was affecting that. I wondered what 12 proposals there were for managing that differently?

13 MS. STINSON: Okay.. SMC, can you answer those 14 two?

15 MR. EAVES: The west pile has the signs on it. I 16 don't know what area you were in, but we also were out there 17 today _and the signs are, as required, posted around the 18 pile.

19 As far as the NRC diagram and what it showed or 20 alleged to show, I am not sure I am really the person that 21 would be in a position to answer that at this time.

22 MS. STINSON: Can you just describe what is at the 23 site?

24 MR. EAVES: The west pile is not entirely covered.

25 There is a portion of it that still needs to be covered.

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115 1 One of the things that will come out of this EIS is the 2 ability to go ahead with that continued capping.

3 MS. STINSON: That is the diagram you are 4 referring to. Did you have answers to questions?

5 MR. GLENN: This diagram is simply conceptual.

6 There is a cap. We tried to in the diagram show that there 7 is a cap on the one pile, and there is no cap on the second 8 pile. You are correct that the on the clay cap, there is a 9 riprap on the base of the pile. That riprap was placed 10 there for stabilization. -

11 The capping is not complete. Decommissioning has 12 not been completed at the site. The whole question about 13 the type of cap is an open issue. The fact that there is a 14 cap on the west pile and -- it is probably not -- it doesn't 15 look exactly like that diagram. That diagram was intended 16 to be reflective.

17 MS. STINSON: Did you have a follow-up question?

18 MR. BAUMAN: First, I would like to say that the 19 Vice President's statements oefinitely sounded like a threat 20 to me. In other words, you -- in situ disposal or we are 21 popping out of here.

22 Two, in reference-to your diagram, my follow-up 23 question to that would be why it is that the NRC is dragging 24 its feet in avoiding doing the proper and just thing of 25 ordering a fence around the site when in fact you had toid _

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116 1 me personally a fence had not been ordered yet because the 2 pile was secure. We have just had testimony that the pile 3 is not secure, nor is the cap secure, thereby, that site 4 should be fenced until such time as it is decommissioned.

5 MR. GLENN: You know that that is an allegation 6 that has been made with the Agency, and the Agency is 7 processing that allegation.

8 Mike Mccann, who is with the NRC Region III can 9 answer the question .

• 10 11 12 MR. McCANN:

is not complete.

You are right. The inspection report I would hope that it will be completed within the next two weeks.

13 One thing that I have mentioned to you earlier is 14 that we are waiting for the final sample analysis from Oak 15 Ridge, Tennessee. Typically, we analyze these samples in 16 our lab. We just reloc"ated our office from Glen Ellyn, 17 Illinois to -- so our lab has been down basically for* the 18 last four weeks. In addition, the sample types that are 19 being analyzed and average sample count takes a thousand 20 minutes to count, and then you have several days critical 21 preparation. So, there has been a delay in the analysis of 22 the sample.

23 In our inspection in October, we did look at site-24 secured access control posting. I can't get into 25 particulars of what violations or concerns will be sited in ANN RILEY & ASSOCIATES, LTD.

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117 1 the inspection repo~t, because we are precluded by 2 regulation until the report is signed and final.

3 We were at the site today and we did see five 4 "~aution Radiation" signs that have been added to the west 5 pile since* last time --

6 I do have -- Our site inspection --we did -- I 7 will give you an idea of the samples that were taken. We 8 took soil sediment samples from around tbe complete 9 peripheries of both piles. We took water -- standing water 10 and low-level -- which would be considered run-off water 11 from the pile. During the period we were there, the river 12 beds were drier than they had been recently, so there was 13 standing water.

14 We also went back to the plant and looked at TLD 15 data, that is thermal luminescent dosimeters radiation 16 monitors. It is a little monitor that they place three feet 17 above the ground. What they have been doing is taking it 18 out at a quarterly period._ We have that data now and we are -

19 going to look at the summaries of that and compare it 20 against the Code of Federal Regulations, Part 21, for 21 unrestricted release, which right now is 500 millirem per 22 year. As of January 1994, it will become 100 millirem.

23 If you would like that complete -- we will let you 24 know when we are done, and you can officially request a copy 25 then. It should be done in two weeks.

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118 l The gentleman asked the question earlier about the 2 exposure rate -- was there a railroad track or something 3 going by.

4 MS. STINSON: Would you please speak closer to the 5 mike?

6 MR. McCANN: Sure. A gentleman has mentioned 7 earlier about his concern about the radiation to a railroad 8 track going by. I want to give you a general idea of what 9 we would be looking at. There are three real simple

• 10 11 12 principles in radiation protection.

course.

I teach a civil defense One of the first principles that radiation health physicists and radiation prevention people learn is distance 13 and shielding. I think the Chad had mentioned 23 micro-R -

14 - let's must make this even numbers -- 20 micro-R per hour.

15 These are the hand-held meters that were used.

16 Mike Weber has -- I would be willing to have one of my 17 inspectors, Ray Valinski, is here -- we would be willing to 18 show you some of the -- how the meters work and what the 19 radiation levels are.

20 But, to give you an idea of the value, let's start 21 with 20 micro-R per hour. That would be if you had -- say 22 you took a measurement at this microphone and say you went -

23 - just take a distance of three feet, and you went three 24 feet away and you measured 20 micro-R per hour, it follows 25 what is called an inverse flow. If you went another three -

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119 1 - if you doubled that distance and you went another three 2 feet, it would be one-fourth of the value. So, in other 3 words, you would get five micro-R per hour. If you doubled 4 that distance, and said 12 feet, it would be one-fourth of 5 that value~ and it would be 2.5 micro-R per hour. Now, 6 to put that in perspective, what the NRC used the new 7 Part 21 that is going to be effective in January of 100 8 millirem per year -- if a person was continuously present on 9 a pile -- at the Shieldalloy pile 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> a day, 52 days a 10 week, they would come up with approximately 100 millirem, 11 and have a radiation level of about 10 micro-R per hour. If 12 you were there 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> a week for 52 weeks, you would have 13 a reading of about four micro-R per hour. So, that gives 14 you some idea -- if I am not confusing it -- that gives you 15 some idea that the radiation drops off inversely 16 proportional to the distance.

17 MS. STINSON: That is okay. Do you have anything 18 else? -

19 MR. McCANN: As far as shielding, we mentioned 20 earlier that there are many types of radiation that come 21 from radioactive material. Some are particulate, in other 22 words, actual solid matter that is emitted from the 23 radioactive material. Some of it is photon energy or gamma 24 rays or x-rays, which is part of light. Gamma rays do --

25 are affected by shielding. Each radioactive material has ANN RILEY & ASSOCIATES, LTD.

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120 1 different energy of photons or gamma rays coming off of it.

2 The primary shielding, besides concrete or lead or in 3 teletherapy units, which is used to treat cancer, is, in 4 fact -- around many shielding places.

5 MS. STINSON: Did you have a follow-up question?

6 Does anyone have a follow-on question?

7 [No response.]

8 MS. STINSON: Okay. Go ahead.

9 MR. BENNETT: Matthew Bennett. I am a member of

• 10 11 12 the Ohio Valley Greens. I have to call you on one of the more offensive acronyms from Government agencies, this A.LARA, as low as reasonably achievable. I noticed it popped 13 up in page six. The criteria are applied on a site-specific 14 basis, .with emphasis on residual contamination levels that 15 are as low as reasonable achievable. I was wondering if you 16 could tell me what the criteria are that determine what is 17 reasonable in this case and what is not?

18 MS. STINSON: Mike?

19 MR. WEBER: Just for clarification, you are 20 referring to page six of the --

21 MR. BENNETT: The Notice -- the Scope -- the 22 notice that I received in the mail from being on your 23 mailing list.

24 MR. WEBER: Right. That comes out of the -- 1n 25 this specific allocation, it comes out of the NRC's action ANN RILEY & ASSOCIATES, LTD.

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121 1 plan for ensuring timely decommissioning of the SDMP sites.

2 The SDMP is for site decommissioning and management plan.

3 The kind of process we would go through is to 4 evaluate whether there are reasonable steps that could be 5 taken -- arid I will explain reasonable -- that could further 6 reduce the level of contamination at a site, using NRC 7 existing guideline values, which are set out in our action 8 plan at the back of the room.

9 The types of trade-offs that we would look at is 10 what is the cost, what is the benefit. Is there a social 11 benefit to the additional action? Would it allow the use of 12 the .property for some application that would otherwise not 13 be allowable? It is a structured process. It often employs 14 things that are also considered just good practice. For 15 example, if you have a wall that is contaminated and, by 16 washing down the wall you can remove the contamination, thus 17 reducing that contamination and potential future exposures, 18 good practice would say, yes, go ahead and do it, as long as -

19 you are not going to cause another problem like creating a 20 waste that couldn't be disposed of.

21 It is a case-specific evaluation. I know that 22 doesn't really help clarify it in great detail; but, ALARA 23 is used and has been used traditionally in the radiation 24 protection field.

25 MR. BENNETT: So, in this case, it might boil down ANN RILEY & ASSOCIATES, LTD.

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122 1 to what is reasonable, either the taxpayer is paying with 2 their health or with their tax money, in terms of the 3 difference between the different alternatives and saying 4 well, it would be nice if we could ensure public health and 5 keep the company open; but we don't know if we can do both, 6 so maybe we will do one or the other, which ever seems 7 reasonable. But, we have two competing factors here.

8 I have one other question. That is, if the 9 offsite alternative was chosen, is there a chance that this 10 would go -- that this material would go to the low-level 11 radioactive waste facility that is proposed for Ohio?

12 MS. STINSON: Can you answer that, Mike?

13 MR. WEBER: Sure. I think, in part, the answer to 14 your question is a function of timing. Also, I don't 15 believe, based on our earlier discussions with Ohio EPA, 16 that they would currently be planning to take this kind of 17 bulk waste at the kind of disposal facility that they would 18 eventually create in the state.

19 I think-the alternatives that we will look at, as 20 to the comments to the contrary, or other suggestions, would 21 be disposal offsite and at a currently available licensed 22 disposal facility. We may also look at disposal at a 23 facility specifically created to take this-waste for 24 disposal.

25 MR. BENNETT: Are there any facilities such as ANN RILEY & ASSOCIATES, LTD.

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123 1 those that are licensed, besides Barnwell right now, that 2 could take waste like this?

3 MR. WEBER: Yes. I believe one company was 4 mentioned earlier out in Utah that is presently licensed and 5 could take at least the bulk of the material at the site.

6 MR. BENNETT: Okay. Thank you.

7 MS. STINSON: Other questions from the audience?

8 [Show of hands. ]

9 MS. STINSON: If you don't mind, I will take 10 someone who hasn't spoken yet.

11 MS. MILLER: My name is Barbara Miller. I am from 12 Cleveland. I am an outsider. I used to live in Byesville, 13 Ohio in 1987. I ate at restaurants in Byesville, and I am 14 concerned that was I exposed when I was here drinking 15 water? I know it was just a small amount, but, I am not 16 down here to try to help close a plant. I am not here 17 representing that. I am concerned about the people that 18 live here, the people that work here, because I have friends -

19 in Ava, I have friends in Byesville, I have friends in 20 Woodsville. What is to say there aren't things going on 21 there like that that is going on here? I think this should 22 be an issue that is taken care of here so that those 23 communities don't have to go through this. I think it is 24 unfortunate that all of you people that live here are having 25 to under go this hardship. That is all I have to say about ANN RILEY & ASSOCIATES, LTD.

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124 1 that.

2 I do have a question for the NRC. Why can't you 3 put a fence up right now, instead of saying we have to wait 4 for results in two weeks? What if those results tell you 5 that you s~ould have had a fence up in the meantime? Why 6 not do that now and protect these people? I know the one 7 gentleman said he walked around the slag and everything.

8 Have you been to the doctor to have your lungs checked? Do 9 you know? Okay. Good. I.am glad. Does that mean everyone

• 10 11 12 that has been across that site has been tested.

have.

FROM THE FLOOR:

I hope you Once a year we have to. Everyone 13 has to.

14 MS. MILLER: I am concerned about that. I care 15 about people.

16 FROM THE FLOOR: We are too. That is why we have 17 that --

18 MS. STINSON: If you want to make comments, it is 19 fine to answer; but you should come up to the mike.

20 MS. MILLER: Okay. I don't want people being 21 angry at the groups that are coming from the outside, 22 because we aren't down here to put you out of work. We re 23 down here because we ~are al;>out people. Tha~ is wby we are 24 in environmental groups. That is the point I want to make.

25 MS. STINSON: Thank you.

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125 1 MR. McCANN: To answer your question, our 2 regulations do specify that radioactive materials have to be 3 accessible to them and have to be controlled. The degree of 4 that control depends upon what we consider the type of 5 material involved, the radiation hazard involved and what 6 type of other controls are in place to control. We look at 7 the riprap that is around the plant. We have inspectors 8 take measurements. The average value of the highest 9 location was about 35 micro-R per hour --

10 Most of the material we assert was material -- I 11 would question hold off -- The signs have been posted 12 We won't encourage them to put a sign up. That has not been 13 decided yet. That is what we will -- I guess I have to say 14 we will follow due process. The regulations are clear. I 15 think the rules of law and process are the same, whether you 16 are being arrested for a traffic ticket or anything else.

17 Like I say, if that case came up, I could order that; but I 18 don't think you would want us to act as public officials, 19 without following due process law.

20 MS. MILLER: Thank you.

21 MS. STINSON: Thank you. We are running over 22 here. I see a couple more questions. We will go for at 23 least another 10 minutes. Bear with us. If you would like 24 to speak to anyone up here, especially after we conclude, I 25 think folks are going to be willing to stick around. So, we ANN RILEY & ASSOCIATES, LTD.

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126 1 will check back with you in about 10 minutes.

2 Did you have an answer to the question about 3 employee testing?

4 MR. EUBANIKS: My name is Melvin Eubaniks. I have 5 been an employee of Shieldalloy for almost 28 years. As far 6 as the lady is concerned about drinking the water and having 7 contamination, Byesville does not get their water from the 8 creek, they get their water from the well water, which is 9 far away from Shieldalloy. So, you do not have any 10 contamination, except maybe too much chorine that they put 11 in the water.

12 Also, as far as the testing that she was concerned 13 about, for the past two or three years, the company, at 14 their expense, has a portable lab come in and voluntarily, 15 you can have x-rays, blood tests, cardiograms, taken. And 16 the blood test will test for heavy metals, which they have 17 not had anybody who is over the limit in any category..

- 18 19 20 I have one comment. I see a piece in the paper, one of our weekly free papers that we get, that this meeting was called by the Wills Creek Committee, and this meeting 21 was set up and called by them, the water committee -- this 22 Wills Creek is that what it is -- this Wills Creek Water 23 Committee? I was just wondering who actually called this 24 meeting -- whether this meeting was set up by this Committee 25 or by someone else?

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127 1 MS. STINSON: I can't speak to you about what was 2 in the paper. This is a Nuclear Regulatory Commission 3 scoping hearing. So, it was called by the NRC.

4 MR. EUBANlKS: It was not in fact _set up -- the 5 paper said. by the Wills Creek?

6 MS. STINSON: I can't speak to that. No. I do 7 not know what the papers say; but, maybe Sherwood would be 8 willing to talk to that later on with you.

9 MR. EUBANIKS: Okay. Also, I would like to know 10 who is this Committee -- this Water Committee? How many 11 members do they have and who is on their Committee Board?

12 MS. STINSON: Can you address those questions, 13 Sherwood? Describe the publication or article it is 14 published in.

15 MR. BAUMAN: I believe the document he is 16 referring to is the Gurnsey Noble Courier, whereby we 17 released a press release to them. I believe, if he would 18 read a little carefully, what it says is, as a direct result -

19 of our efforts and others, this meeting was being called.

20 We did not take sole responsibility nor credit for the 21 calling of this meeting.

22 Okay. Two. The Save the Wills Creek Water 23 Resources Committee is a group of concerned citizens 24 throughout Gurnsey County that are here to protect our 25 drinking water supply. When you look at the fact that, for ANN RILEY & ASSOCIATES, LTD.

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128 1 instance, in 1967 --

2 MR. EUBANIKS: All I want to know is how --

3 MR. BAUMAN: Excuse me, I am answering your 4 question. He asked me who it was and how many members we 5 had. Now,* if you will allow me to answer the question?

6 MS. STINSON: Let's let him answer the question.

7 He can address whatever question he wants also.

8 MR. BAUMAN: When you look at the fact that in 9 1967 the Ohio Department of Health recommended against an 10 issuance of a permit for a dump over in Byesville that is 11 now a Superfund cleanup site called the False Landfill, 12 whereby Byesville does get its water indirectly from_ Chapman 13 Run, because it drops down into an underground coacquifer 14 that was polluted during the False Landfill fiasco, because 15 even though the Ohio Department of Health recommended 16 against it, our wise County Commissioners went ahead and 17 granted that license, and we are now spending $20 million

- 18 19 20 cleaning it up. So, we are a group of .concerned citizens throughout Gurnsey County trying to protect our*water supply because we have got over 40 miles of interstate to develop 21 wonderful industry in this county, and the powers that be at 22 places like the CIA are doing the best to keep that growth 23 from coming.

24 As far as the number of members --

25 MS. STINSON: Okay. It is important -- I am ANN RILEY & ASSOCIATES, LTD.

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129 1 sorry, sir. I am sorry, Sherwood.

2 MR. BAUMAN: -- we have 19.

3 MS. STINSON: It is important not to make 4 references to specific organizations remember no 5 accusatory statements. Can you just mention the number of 6 members that you have?

7 MR. BAUMAN: Yes. We have currently 19 members.

8 MS. STINSON: Thank you.

9 FROM THE FLOOR: Boo.

10 FROM THE FLOOR: Boo. Boo.

11 MS. STINSON: All right. Enough of that.

12 [Show of hands.]

13 Sir?

14 MR. JEWEL: My name is James Jewel. I don't live 15 here. I don't work at your plant. I don't drink your 16 water. I don't even know what it tastes like. It sounds 17 like, from what the gentleman said from his walking around 18 the creek and stuff, it doesn't sound like there is any 19 really obvious damage to any of the living creatures there.

20 There have been a lot of things said, but no specific 21 numbers mentioned. The must be tests done on the amounts 22 and concentrations of any heavy metals or whatever. There 23 should be that information available by now, but nobody has 24 mentioned any of it -- no specific numbers. So, I can't say 25 anything specific, so I won't. I will just stick to a ANN RILEY & ASSOCIATES, LTD.

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130 1 general statement.

2 So, why should I be here and why should I care 3 about Cambridge and the water and stuff? Well, one of the 4 reasons is this is a national committee here, and the 5 decisions that are made here and the way it is done affects 6 everybody on a national level. So, I was curious to see how 7 that goes. That is not really enough to take me away from 8 the things I need to do.

9 Then I had heard that -- somebody that works with 10 a friend of mine had a death threat. That makes me a little 11 more curious. It comes to mind this whole issue of jobs 12 versus the environment. That is what I would like* to say -

13 - something kind of general about that -- about people who 14 are stuck in a situation where their job involves byproducts 15 that are dangerous possibly, or have a potential to be 16 dangerous.

17 If you are in a water shed that feeds your water

- 18 19 20 supply, then you should be concerned about it, and you should look into it for yourselves. Don't listen to what all of these experts say, find out for yourself. If you are 21 doing the work, if your hand is in it, then find out for 22 yourself. If it is okay, then find out how to do the job 23 right, so that the drainage is taken care of and things --

24 there are all kinds of options out there. People are do1r.g 25 studies on artificial wetlands.

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131 1 When I was in Massachusetts a couple of years ago, 2 they were due to do the results of an artificial wetland and 3 how it absorbed heavy metals or not. If an artificial 4 wetland would absorb heavy metals, and then, if it would 5 stay in the* plants, and then what would you do with the 6 plants that had these heavy metals in them? And this 7 they did this -- so the results of that is out there. I 8 don't know what they are, but maybe I could find them and 9 send them.

10 The point is, if you are in a situation like this 11 and, if it turns out -- you know, if it turns out -- you 12 know, here is another what if -- but, that is what this 13 discussion is about. We are not making decisions. This is 14 what if. If it turns out that what you find out for 15 yourselves is not to the standards that you consider to be a 16 good job -- that would protect your water supply, what are 17 you going to do? If it turns out that it is not up to your 18 personal standards, are you going to become so fearful and 19 doubt yourself so much that you are going to overlook it 20 because you are afraid that you can't find some other way of 21 making money or making ends meet and continue, or are you 22 going to say this job is not up to my standards, what I 23 believe in, so to hell with it, you know, I can take care of 24 myself and I don't need to work for this company if this 25 company is going to ask me to do a job that is not up to my ANN RILEY & ASSOCIATES, LTD.

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132 1 standards?

2 So, generally speaking, as far as jobs versus the 3 environment, it is not going to go away because there is 4 more of a -- I mean, our population has not stabilized. We 5 are still- growing, and the world is still the same size.

6 So, the jobs versus the environment is not going to go away.

7 It is something that needs to be looked at. You need to ask 8 yourself is my job -- and you have to know. I mean, you 9 can't let other people tell you, because, you know, they 10 have got their own biases. You have got to find out for 11 yourself, for your own satisfaction. Is my job safe? Do I 12 want to continue doing it? Can it be done safely?

13 So, those are the things we need to look at and 14 n?t get really fearful about, you know, I am so dependent on 15 this company and I am so afraid that I won't be able to make 16 it on my own or something that you are going to overlook 17 these things. That is my concern. On a national level, I

• 18 19 20 think that is the concern -- because jobs versus the environment has been a big debate on a national level as well.

21 Thank you.

22 MS. STINSON: Thank you. Other comments or 23 questions _..:. particular questions or clarification? Use the 24 opportunity that you have here with all of the resources we 25 have collected together in this room.

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133 1 [Show of hands . ]

2 MS. STINSON: Sir? We will take two more 3 questions, and then we will check in and see if it is time 4 to close.

5 MR. ELLISON: I have kind of a point of 6 information about exposure to low levels of radiation and 7 their affects on human beings and other living things. What 8 they found is that exposure to low levels of radiation 9 doesn't necessarily manifest itself in the first or second 10 generation, so that the people who are walking across this 11 pile of slag and being exposed to it, may not be adversely 12 affected at all. But, the cells which are dividing, 13 particularly reproductive cells can be affected, and it can 14 show up in their children and their grandchildren. So, we 15 may not see any effects right away from this stuff.

16 Some of the studies on this I think Deborah 17 Lorz referred to the doctors involved in studying it have 18 been marginalized and ridiculeq by the Nuclear Regulatory 19 Commission and the establishment. My father worked in the 20 Atomic Energy Commission. I grew up in New Mexico, around 21 the Nuclear Laboratories there. His job was secret. He 22 couldn't tell me anything about what he did for a living.

23 This is the history of the nuclear industry of secrecy 24 and deception. It is in that environment that this whole 25 thing is happening. I really feel for the threat of losing ANN RILEY & ASSOCIATES, LTD.

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134 1 a job, because nuclear -- anti-nuclear activists have bee'n 2 threatened with losing their jobs.

3 If a GE employee was to speak out against the 4 bombs programs they have going on in their plant, if they 5 were to have an accident of something in the GE plants, they 6 would lose their jobs. So, I feel for the threat of job 7 loss, but it sciunds like Metallurg has filed Chapter 11 and 8 is in the midst of going bankrupt.

• 9 10 11 Thank you.

[Show of hands.]

MS. STINSON: Yes, sir. State your name.

MR. MACMURRAY: I am Michael MacMurray, and I live 13 in Cleveland. I am from Mississippi. But, I was wondering 14 I would like to address this to the gentleman -- I 15 believe he is the Vice President of the Company, with what 16 sounded like a British accent, it didn't sound like he was 17 from around these parts -- I would like to ask the name of 18 the holding company and where it is located that actually 19 controls the local plant that is about to shut down? Could 20 you tell me what the name of the holding company was again?

21 MR. FINN: Shieldalloy Metallurgical Corporation, 22 which is 17 -- 25 East 39th Street, New York.

23 MS. STINSON: Metallurg, Inc? 25 East 24 MR. FINN: 39th Street.

25 MS. STINSON: 39th Street, New York, New York.

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135 1 MR. FINN: 10016, 2 MR. MACMURRAY: Thank you.

3 MS. STINSON: That is the holding company for 4 Shieldalloy.

5 Any other final comments or questions?

6 [No response.]

7 MS. STINSON: Okay. I want to thank you all for 8 your participation this evening.

9 [Show of hands.]

10 MS. STINSON: Did I miss somebody? State your 11 name.

12 MR. LATCHIK: My name is John Latchik. I am the 13 son of a father who happened to walk across the contaminated 14 slag piles and may have inadvertently worked in some of the 15 products that they have produced. If it is a level of such 16 grades of radiation that causes some biological malfunction 17 that we are looking in the food chains and our reproduction 18 cycles, I feel like it hasn't affected me. I, too, work at 19 that plant. If it is, I don't have a doctor's degree of 20 something of that nature. I feel it is because have left 21 myself unexpanded in these areas. I feel the deficiencies 22 that some people may view as a byproduct of the Vanadium 23 Corporation -- I hope you don't see us unfavorably. I hope 24 you continue to let Shieldalloy work with the community and 25 the NRC to develop some techniques for plans that will help ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

136 1 this decommissioning process be completed. Don't be too 2 harsh in your judgment on the environmental impacts. We 3 need time. I~ is my livelihood. I am a generation. I have 4 another generation behind me. I have a son that is 15 years 5 old. I feel that he has progressed well. These are 6 stressful times, and our national economy does demand that 7 we take time to reach the proposed agreements to work these 8 things out. Give it time and let it work. Thank you.

9 [Applause.]

10 MS. STINSON: Thank you. We have just enough time 11 for a couple of closing comments. 1 I was going to say how 12 much I appreciate people's comments and working in this 13 format. We would like to know what your feeling is about 14 this format. The NRC conducts scoping hearings of this type 15 all the time. Check in with us afterwards and let us know.

16 As well, I hope you all view this as the beginning of a 17 communication process between NRC, the other agencies, and

• 18 19 20 yourselves. We will take the opportunity to ask questions, if you have them, tonight -- certainly to submit your public comments, your written comments, and to be in contact with 21 the staff in the future.

22 Mike?

23 MR. WEBER: Let me just add- my thanks to all of 24 you who stayed throughout the meeting and shared your views 25 with us. I want to assure you that those comments will be ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202} 293-3950

137 1 taken. They have been transcribed. We will use them in 2 developing the Environmental Impact Statement. You will 3 pro~ably see reference to them in the Scoping Summary that 4 will come out.

5 We have had a dynamic year of job concerns and 6 environmental concerns and some tension I am sure in the 7 community. I hope that*we can all leave here tonight with 8 the expectation that over the next several years this issue

.9 will be resolved.

10 I want to thank you again for coming out. Thanks.

11 [Whereupon, at 10:37 p.m., the above-entitled 12 meeting was concluded.]

13 14 15 16 17 18 19 20 21 22 23 24 25 ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

REPORTER'S CERTIFICATE Thi* la to certify that th* attached pr0ceedings betor* th* United Stat** Nuclear Regulat0ry c:omm.1**1011 in the utter ofs HAMB OP PR0CE!DINGI Scoping Meeting on Environmental Impact Statement for Shieldallo1 DOClCff NtrMSER.1 PLACI OP PROCEECINGI Byesville, OH were held** herein appears, and that this is tha original tranacript th*r*o~ tor th* tile ot the Unit*d Stat** Nuclear Re9Ul&tory commission taken by me and thereaft*r reduced to typewriting by~*

or under the direction of th* court reporting company, and that the transcript is a true and accurat* record ot the toregoinq proceedings.

ol!Ic:laiapoz:ter l Ann Riley, uacclates, Ltd.

United States (j)

FISH AND WILDLIFE SERVICE Ecological Services 6950-H Americana Parkway *94 JAN 24 I\ 9 :52 Reynoldsburg, Ohio 43068 IN REPLY REFER TO:

V January 12, 1994 1[ l\l T Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTN: Docketing and Services Branch

Dear Mr. Secretary:

We would like to respond to your November 26, 1993 Federal Register Notice regarding "Decommissioning of Shieldalloy Metallurgical Corporation's Facility in Cambridge, OH; Notice of Intent to Prepare an Environmental Impact Statement and to Conduct a Scoping Process." We have the following comments:

1. We believe that any action on the part of NRC to address the request by Shieldalloy for only onsite disposal of radioactive waste is premature and defeats the purpose of the proposed EIS. We also believe that any such ruling prior to the appropriate site investigations and feasibility studies may be illegal. The "Guidelines for Federal Agencies Under the National Environmental Policy Act" (issued by the Council on Environmental Quality on April 23, 1971) declares in section 2 that "As early as possible and in all cases prior to agency decision concerning major action *** " the action agency (in this case NRC) consult with other agencies, assess environmental impacts in detail, and assess alternative actions. We reiterate, all this is to be done before any decisions are made. Any decision on where to dispose of site waste should not be made until after all consultations and assessments have been completed. This decision might be made before decommissioning if the EIS has been completed and if decommissioning comes after the EIS. We understand that the issue of bankruptcy is new to NRC and therefore Shieldalloy will become a test case that could set a bad precedent for similar sites if the rules for the EIS and other assessments are not scrupulously followed.

2. In "The Scoping Process (2)(a)" we believe that the proposed action is incorrectly stated to be that of onsite stabilization. The major Federal action is actually the disposal of site wastes. We believe that limiting the scope of the EIS only to onsite disposal is a major Federal action in itself and that NRC could be inviting a court challenge to any early decision it makes on this issue. The scope of the EIS should include a thorough discussion and full consideration of the issue of offsite waste disposal.

3. Some issues that we believe should be included within the scope of the EIS for the Shieldalloy site include:

a. Offsite disposal of waste

b. Injuries to wetlands on site caused by Shieldalloy .activities to include maps, acreages, and descriptions

c. The role of the U.S. Army Corps of Engineers under Section 404 of the Clean Water Act and any role they may have in project design

d. In the interest of completeness, the issue of Federally listed endangered species should be mentioned (although our records indicate that no Federally listed endangered species occur in Guernsey County)

e. Impacts of Shieldalloy activities to Federally protected migratory birds and their habitats

f. The need for chemical analysis of representative onsite terrestrial and aquatic organisms tissues (including bone) to determine if site pollutants are being accumulated, and a similar assessment of aquatic biota in offsite surface waters receiving site runoff (site pollutants to MAY 1 O 19941 Acknowledged by card ..................................

1$. NUCL[t r: :1E:GULtT8RY COMMISSION DOC/c 1 *:,,c & SF:;:'V!Ct SECTION 01: 1:iGi.: o,: r: t: SC:\.;:~E-,,~,RY OF -r;r: ,_.o,,~i\.lS::iiON

include both radionuclides and conventional pollutants)

g. The need for genetic and biomarker investigations to determine chronic impacts to site biota

h. The project design life (it should reflect the half-lives of the radionuclides being sequestered, i.e. the attempt should probably be made to design the project for a time scale in the hundreds or thousands of years)

i. The role of U.S. EPA in the clean-up process and their possible role in financing a remedial action alternative if the responsible party is unable to fully finance the selected alternative

j. The source of funding for the selected remedial action and the impact that the source of this funding will have on the choice of remedial action alternative.

4. In the "Description of Proposed Action" section, we believe that the proposed action is incorrectly stated and that the proposed action should be framed as the disposal of site waste in general and not be limited to onsite disposal of waste. To eliminate from serious consideration other alternatives before the EIS and appropriate studies of alternatives have been completed may be illegal.

We find it ironic that the threat of bankruptcy by a polluter can drive the clean-up process to ignore alternatives on the basis of cost even before the necessary feasibility studies have been completed. NRC's site assessment and choice of alternative should be independent of coercion or even the appearance of coercion by t he r esponsib le party.

5. The role of the U.S. Fish and Wildlife Service in the EIS and other activities pertaining to the Shieldalloy site will be that of a consulted agency under the authority of the Fish and Wildlife Coordination Act (48 Stat.

401, as amended; 16 u.s.c. 661 et seq.) and the Endangered Species Act of 1973, as amended. The Service could also become involved in Natural Resources Damage Assessment (NRDA) actions and negotiations under CERCLA as a representative of the Department of the Interior, a Federal natural resources trustee. The Service would like to be kept informed of developments at Shieldalloy extending to the review and comment on site workplans, investigations, reports and assessments.

If you have questions or we may be of further assistance in these matters please contact Mr. Bill Kurey of this office at 614-469-6923.

State of Ohio Environmental Protection Agency Southeast District Office 2195 Front Street Logan, Ohio 43138-9031 (614) 385-8501 *94 J N ~ orFt~  :[V~ inovich FAX (614) 385-6490 * ~overnor January 14, 1994 RE: SHIELDALLOY METALLURGICAL GUERNSEY COUNTY Secretary, DERR CORRESPONDENCE U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTN: Docketing and Services Branch

Dear Sir or Madam,

On November 26, 1993, the Nuclear Regulatory Commission (NRC) issued in the Federal Register a notice of its intent to perform an Environmental Impact Statement (EIS) on the Shieldalloy Metallurgical Corporation site in Cambridge, Ohio. The purpose of the EIS is to d eterm ine whether on-site s ta bili zation and disposal of radioactive waste is acceptable for decommissioning and to evaluate other decommissioning alternatives. This correspondence constitutes the Ohio EPA's comments to the EIS proposal.

In a phone discussion between the NRC and Ohio EPA on January 11, 1994, NRC expressed that the planned EIS will only address the environmental problems that are directly related to the two waste piles containing low level radioactive waste that currently exist at the site. The NRC has indicated that the risks associated with hazardous substances mixed with radioactive materials in the piles will be addressed in the EIS. NRC has stated that other contaminants, outside of the waste piles, will apparently not be addressed under the scope of the EIS or the decommissioning process.

Since the EIS process is evaluating alternatives for the waste piles, and since the waste piles contain other materials besides low level radioactive slag, Ohio EPA recommends that t he National Contingency Plan (NCP) (40 CFR 300) process tor evaluating risks to human health and the environment at a site, and the NCP process for evaluating and selecting remed ial actions or cleanups, should be utilized in this EIS. Op January 11, 1994, Ohio EPA discussed the EIS with U.S.EPA and it appears USEPA is in general agreement with the NCP approach for the ElS. Since there are many, complex environmental problems existing at this site, which appear to span several jurisdictional boundaries, it is important for NRC, USEPA and the State of Ohio to work together to address all of the problems at the site at this time.

Ohio EPA would like the NRC to consider expanding the proposed EIS to address all environmental problems at the SMC site. This could save time and money for all involved parties by ensuring that

@ Printed on recycled paper MAY 1 o 1994 Acknowledged by card ......... _ ......." ....".......

• • I*

NUCLEAR REGUL!<"'f");\y COMMISSION DOCltE.TING & s;: I.\,,'! ~c SECTION OFFICE OF TH: Sc. ;*?.ETAAY OF THE co:.F,!l3SION Docum~nt S!1tistics

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NRC Secretary January 14, 1994 Page 2 when decommissioning has been concluded, re-evaluation of this site by Ohio EPA and/or U.S.EPA under CERCLA will not be necessary.

Ohio EPA has commented on the proposed EIS with the anticipation that all of the environmental problems, chemical and radiological, will be addressed. The following are Ohio EPA's comments on the EIS proposal and the decommissioning alternatives being evaluated.

1. The EIS should be consistent with the National Contingency Plan (40 CRF part 300) (NCP) in order to ensure that all environmental problems that exist at the site (radiological and chemical) will be evaluated and addressed and that the current and future cummulative risks associated with the entire site can be adequately evaluated.

2. The alternatives should be developed and evaluated using the nine criteria specified in the NCP. The criteria are: overall protection of human health and the environment; compliance with applicable and relevant and appropriate federal and state laws and regulations; long-term effectiveness and permanence; reduction of toxicity, mobility or volume through treatment; short-term effectiveness; implementability; cost; state acceptance; and community acceptance.

3. As indicated above, the EIS and the chosen decommissioning alternative, should address both chemical and radiological contaminants in the waste piles and for the entire site.

4. The NRC, USEPA and the State of Ohio need to determine all applicable Federal, State and Local laws and regulations that may impact the alternatives that are being reviewed under the EIS. Each alternative should be evaluated in terms of compliance with the identified laws and regulations prior to the selection of the most appropriate alternative.

5. The EIS should include the performance of an Ecological Assessment, to evaluate the impact on the biota, at and near the site, due to the placement of the waste piles in a wetland and on a 100-year floodplain. The Ecological Assessment will also play a role in determining what impact the implementation of a selected alternative will have on the environment at

NRC Secretary January 14, 1994 Page 3 the site. The Ecological Assessment should follow current USEPA guidelines for performing such an assessment, and be performed by trained professionals that have experience in performing ecological assessments.

6. The EIS should determine the current extent of the wetlands at and near the site and the extent of the wetlands prior to the creation of the waste piles.

7. The EIS should identify the data gaps that exist and obtain the information needed to perform the alternative evaluation process. The determination of the total extent of surface water contamination due to the presence of the waste piles and the impact of the waste piles on ground water has not been adequately d e termined. USEPA has performe d two studies of surfa ce and ground waters at the site, which indicate that additional sampling and evaluation are necessary.

8. Besides the criteria listed in comment 2, the EIS specifically should evaluate each alternative in terms of the waste piles being present in wetlands and in a 100-year floodplain; that the depth of ground water below the waste piles and the impact of the waste piles on ground water have not been adequately determined; and the potential long-term impact on Cambridge's municipal water supply that serves 12,000 people.

9. Please find attached a list of guidance documents that the State of Ohio utilizes in the performance of environmental investigations, evaluations of alternatives and the design and implementation of a selected alternative. We encourage the NRC to follow theses guidelines in developing an alternative to address the radiological and non-radiological issues present at this site.

Many of the issues raised in this letter have been raised in a June 30, 1993 Ohio EPA comment letter on the SMC Technical Basis Document for Decommissioning. The NRC has sent our comments, along with their own, to SMC. In order to fully evaluate alternatives for decommissioning, the EIS should adequately address the state of Ohio's June 30, 1993 comments. Unless these comments are sufficiently addressed, it appears that it will be very difficult for the NRC to select, and the State to accept, an alternative for decommissioning that would be consistant with CERCLA.

NRC Secretary January 14, 1994 Page 4 To address these issues, Ohio EPA recommends that the NRC develop an EIS workplan for the performance of the EIS, similar to a CERCLA Remedial Investigation/Feasibility study workplan. The workplan should include a review of all information and data generated to date . and determination of any data gaps that may exist. The workplan should then specify how to address these data gaps and outline the sampling requirements. The development of a workplan would provide the NRC the o"pportunity to solicit U.S. EPA's and Ohio EPA's expertise in investigating non-radiological contaminants and in the evaluation and selection of an alternative that addresses, not only the radiological threats, but also the non-radiological threats to human health and the environment associated with the waste piles.

If you should have any questions concerning these comments please fe e l free to c a ll at 61 4- 385-8501 Sincerely,

~ ,t-c:~, , P~~ /1----:t Davi d unt Site Coordinator Division of Emergency and Remedial Response Enclosure cc: Jenifer Kwasniewski, OEPA-DERR, CO Catherine Stroup, OEPA-Legal, co Jennifer Wendel, USEPA-Region V Jim Payne & Bob Karl, Ohio Attorney General's Office Dwain Baer & Bob Owen, OOH-Radiological Health Chad Glenh, NRC

OHIO EPA AND U.S. EPA GUIDANCE DOCUMENTS How Clean is Clean, Final, Ohio EPA, Division of Emergency and Remedial Response, Policy No. DERR-OO-RR-009, July 26, 1991 I

2. Background Guidance, Final, Ohio EPA, Division of Emergency and Remedial Response, July 26, 1991

• 3. Guidance for Conducting Remedial Investigation and Feasibility Studies under CERCLA, Interim Final, OSWER 9355.3-01, EPA/540/G-89/004, Oc~ober 1988 Cs?

4. Conducting Remedial Investigations/Feasibility Studies for CERCLA Municipal

• Landfill Sites, OSWER Directive 9355.3-11, EPA/540/P-91/001, Feburary 1991 Risk Assessment Guidance for Superfu~~: Volume I - Human Health Evaluation Manu~ (Part A), Interim Final, EPA/540/1-89/002, December 1989 n~.*

..... Risk Assessment Guidance for Superfund: Volume I - Human Health Evaluation Manual (Part B), "Development of Risk-based Preliminary Remediation Goals,"

OSWER Directive 9285.7-0lB, December 1991, Interim

7. Risk Assessment Guidance for Superfund: Volume I - Human Health Evaluation

. Manual (Part C)~ ~*Risk Evaluation of Remedial Alternatives," OSWER Directive 9285.7-0lC, December 1991, Interim * *

8. Risk Assessment Guidance for Superfund: Volume I - Human Health Evaluation Manual, Supplemental Guidance: "Standard Default Exposure Factors," OSWER Directive 9285.6-03, March 1991,,interim final

~i Risk Assessment Guidance for Superfund

Volume Il -Environmental Evaluation Manual, . OSWER Directive 9285.7-01, EPA/540/1-89/00lA, March 1989, interim final *

10. Superfund Exposure Assessment Manual, OSWER Directive 9285.5-1, EPA/540/1-88/001, April 1988 1 I. Exposure Factors Handbook, EPA/600/8-89/043, March 1990

12. RCRA Ground Water Monitoring Technical Enforcement Guidance Document (TEGD), OSWER Directive 9950.1, September 1986 Revised February 12, 1993

Ohio EPA/U .S. EPA Guidance Documents Page 2 of 4

13. Guidance for Remedial Actions for Contaminated Ground Water at Superfund Sites, OSWER Directive 9283.1-2, EPA/540/G-88/003, December 1988, interim final

14. Leachate Plume Managemen~, EPA/540/2-85/004, November 1985

15. Data Quality Objectives for Remedial Response Activities,. Volume I - Example Scenario, OSWER Directive 9355.0-?B, EPA/540/G-87/004, March 1987

- ** 16.

• Superfund Remedial Design and Remedial Action Guidance, OSWER 9355.0-4A, June 1986

• " ~ Ecological Assessments of*H~dous Wastes Sites: A Field and Laboratory Reference, EPA/600/3-89/013, March 1989

18. Guidelines and Specifications for Preparing Quality Assurance Project Plans, Ohio EPA, Division of . Emergency and Remedial Respo_nse, Policy No.

DERR-00-RR-008, March 1990 * .

• 19. CERCLA Compliance with Other Laws Manual - Part I, OSWER Directive 9234.1-01, EPA/540/G-89/006, August 1988, interim final

20. CERCLA Compliance with Other Laws Manual - Part II, OSWER 9234.1-01,EPA/540/G-89/006, August 1988, interim final

21. U.S. *EPA Integrated Risk Information System (IRIS) Data Base

22. Guidance for D~ta Usability in Risk Assessment, OSWER Directive 9285.7-05, EPA/540/G-90/008, October 1990, interim final

23. U.S. EPA Health Effects Assessment Summary Tables, Office of Emergency &

Remedial Response, published annually .

• 24. A Compendium of Technologies Used in the Treatment of Hazardous Wastes, EPA/625/8-87/014, September 1987 25 . Guide for Conducting Treatability Studies Under CERCLA, EPA/540/2-89/058, December 1989, interim final

26. Guide for Conducting Treatability Studies Under CERCLA: Aerobic Revised February 12, 1993

Ohio EPA/U.S. EPA Guidance Documents Page 3 of 4 Biodegradation Remedy Screening, EPA/540/2-91/013A, July 1991, interim guidance

27. Guide for Conductipg Treatability Studies Under CERCLA: Soil Vapor Extraction, EPA/540/2-91/0~9A, September 1991, interim guidance

28. Handbo"ok on In Situ Treatment of Hazardous Waste-Contaminated Soils, EPA/540/2-90/002, January 1990,

- 29.

30.

Handbook for Stabilization/Solidification of Hazardous Wastes, EPA/540/i-86/001, June 1986 .

Stabilization/Solidification of _CERCLA and RCRA Wastes - Physical Tests, Chemical Testing Procedures, Technology Screening and Field Activities, EPA/62~/6-89/022, May 1989 .

g Technical Guidance Document: Final Covers on Hazardous Waste Landfills and Surface Impoundments, EPA/530-SW-89-047, July 1989

• • ~- Technical Guidance Document: Construction Quality Assurance for Hazardous Waste Land Disposal Facilities, EPA/530-SW-86-031, October 1986

~3 . Seminar Publication - Requirements for Hazardous Waste Landfill pesign,

- ** 34.

Construction, and Closure, EPA/625/4-89/022, August 1989 Technical Guidance

• Document: Inspection Techniques for the Fabrication of Geomembrane Field Seams, EPA/~30/SW-91/051, May 1991

35. Technical Guidance for Corrective Measures - Subsurface Gas, EPA/530-SW 023, March 1985

• • 36. Handbook - Guidance on Setting Permit Conditions and Reporting Trial Bum Results - Volume II of the Hazardous Waste Incineration Guidance Series, EPA/625/6-89/019, January 1989

• • 37. Handbook - Hazardous Waste Incineration Measurement Guidance Manual -

Volume III of the Hazardous Waste Incineration Guidance Series, EPA/625/6-89/021, June 1989 Revised February 12, 1993

Ohio EPA/U.S. EPA Guidance Documents Page 4 of 4

• • 38. Handbook - Permit Writer's Guide to Test Bum Data - Hazardous Waste Incineration, EPA/625/6-86/012, September 1986

• • 39. Handbook - Quality Assurance/Quality Control (QA/QC) Procedures for .

Hazardous Waste Incineratio~, EPA/625/6-89/023, January 1990

40. Guidance on Remedial Actions for Superfund Sites with PCB Contamination, OSWER Directive 9355.4-01, EPA/540/q:90/007, August ,1990 Assessment of Technologies for the Remediation of Radioactively Contaminated Superfund Sites, EP A,/540/2-90/001, January l 99q

• 42. Handbook - Dust Control at Hazardous Waste Sites, EPA/540/2-85/003, November 1985 43: Closure *of Hazardous Waste Surface*Impoundments, SW-873, Sept~mber 1980

44. Guide for Decontaminating Buildings, Structures, and Equipment at Superfund Sites, EPA/600/2-85/028, March 1985

45. U.S. EPA Alternative Treatment Technology Information Center (ATTIC) Data Base and Reference Library, ATTIC System Operator Phone Number (301) 670-6294

• Notes:

1) Documents and guidances denoted by an asterisk (*) are those which are important to the.

Remedial Investigation/ Feasibility Study process but generally will have limited relevance to the Remedial Design/Remedial Action phase of a project.

2) Documents and guidances denoted by a double asterisk (**) are those which may be important to the Remedial Design/ Remedial Action phase of a project but generally will have limited relevance fo th~ Remedial Investigation/Feasibility Study process.

3) This list of guidance documents is updated periodically. You should check with Ohio EPA to verify that this list is the most current available .

Revised Fcbru11ry 12, 1993

Due;~::: T UMBER .

PROPOSED RULE PR MI (r?FRt1.s1r

• 94 JAN 19 PS :C3 January Secretary, U.S. Nuclear Regulatory Commission Washington, DC 20555.

ATTN. Docketing and Services Branch

Dear Secretary,

Full responsibility for the clean-up and decommissioning of the Shieldalloy Metallurgical Corporation's facility in Cambridge, Ohio should be done by Shieldal loy and predecessor companies proportionate to the amount each company generated.

These companies should also pay for independent experts and scientists chosen by the citizens and citizens' groups to provide important information to the citizens and help make necessary decisions regarding safety, health and environmental issues.

The clean-up will include exhuming and removing all contaminated waste including both low level and high level nuclear waste from the site and taken out of the state of Ohio to a facility licensed for proper disposal.

Ci t.izen groups and involved citizens such as Sherwood Bauman should over-see the clean-up. They should make the final decisions regarding acceptable community standards for the clean-up and if and when those standards have been met. Before the involved companies are 1 et off the hook, they must demonstrate to the satisfaction of the community that the radiation and contamination have been cleaned up and the property can safely be given back to the cornrnuni ty for unrestricted use. (Any credible citizen or citizert;' group participating in oversight could have no history or connection to Shieldal 1 oy, any predecessor company, any shareholder of these companies nor any connection to the nuclear industry.)

Sincerely Yours, MAY 1 o 1994 Ackno~ Iedged by card ..._IIMlYl~ll't-'l!iw.

' (IS-NUCLEAR REGuLATORY COMMISSION OOCf<ETING & SERVICE SECTION OFFICE OF THE SECRETARY OF THE COMMISSION Document Statistics Postmark Date / /r1--/CjL/

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.r ** TELEPHONE (609) 692-4200 DAVID R. SMITH . ,l, ,, TWX (510) 687-8918 DIRECTOR OF E;NVIRONMENTAL SERVICES FAX (609) 692-4017 ENVIRONMENTAL DEPARTMENT FAX (609) 697 -9025 January 14, 1994 Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Docketing and Service Branch RE: Decommissioning of Shieldalloy Metallurgical Corporation Facility in Cambridge, Ohio: Notice of Intent to Prepare an Environmental Impact Statement and to Conduct a Scoping Process

Dear Secretary:

Shieldalloy Metallurgical Corporation (SMC) is submitting written comments regarding NRC's Public Notice and our recommendations for modification to the subject scope. It is requested that NRC and its contractor utilize these enclosed comments and recommendations for the development of the Environmental Impact Statement (EIS).

SMC's specific comments or recommended changes to NRC's Public Notice are attached.

SMC is in receipt of the Official Transcript of Proceedings to Public Scoping Meeting on the Environmental Impact Statement (EIS) for Shieldalloy Metallurgical Corporation Facility -- Cambridge, OH on December 13, 1993 at the Meadowbrook High School, Byesville, Ohio. We plan to prepare and submit to NRC under separate correspondence our comments and responses to the testimony presented. It became quite evident from listening to various speakers and then reading the transcript that the local community supports in-situ decommissioning as evaluated and selected by SMC's Technical Basis Document for Decommissioning at the Cambridge, Ohio Facilities (IT/NS-93-108, May 1993). SMC is confident that NRC's EIS will also support and recommend this same method for decommissioning of the Cambridge facility.

~ !f.~t.....

Acknowledged by card .. ~:...:... ... H

Letter to Secretary of the USNRC January 14, 1994 Page 2 If you have any questions regarding these comments, please do not hesitate to contact myself or Mr. C. Scott Eves at 609-692-4200.

• David R. Smith DRS:lms Enclosure CC: Cambridge and Byesville Business Leaders and Elected Officials OEPA, ODOH, NRC Region III, USEPA Region V United Steel Workers Local 5050, John Sedor, President Speakers from the various Environmental Groups

Comments to NRC's Public Notice for the Decommissioning of Shieldalloy Metallurgical Corporation's Facility in Cambridge, Ohio:

Notice of Intent to Prepare an Environmental Impact Statement and to Conduct a Scoping Process [7590-01]

References

( 1) Decontamination and Decommissioning Plan for the Shieldalloy, Cambridge, Ohio Plant (ERT, 1987)

(2) Radiological Survey of the Shieldalloy Corporation Site, Cambridge, Ohio (USNRC, July 1988) - ORAU 88/D-23 (3) Shieldalloy Metallurgical Corporation, Cambridge, Ohio Radiological Characterization Plan (ENSR, 1989)

(4) Shieldalloy Metallurgical Corporation, Cambridge, Ohio Decontamination Report, License SMB-1507, License Amendment (ENSR, January, 1990)

(5) Shieldalloy Metallurgical Corporation, Cambridge, Ohio West Pile Decommissioning Plan (ENSR, February 1990)

(6) Confirmation Survey of the Shieldalloy Metallurgical Corporation Cambridge, Ohio (USNRC, May 1991) - ORAU, Docket No. 40-8948 (7) Shieldalloy Metallurgical Corporation Technical Basis Document for Decommissioning at the Cambridge, Ohio Facilities (IT/NS-93-108, May 1993)

Page 1, Summary, line 3: Change sentence beginning with "Shieldalloy" to read as follows:

Shieldalloy's predecessor companies (Vanadium Corporation of America and Foote Mineral) at the Cambridge location had been licensed...

Page 1, Summary, line 7: Delete "the facility concentrated".

Page 1, Summary, line 8: Insert after the word "materials" was segregated into high

. temperature slag".

1

Page 1, Summary, line 8: Insert the following sentences after the sentence above:

In 1973, Foote Mineral requested that NRC terminate their license for possession and storage of source material. The property was acquired by Shieldalloy Metallurgical Corporation in 1987 and the source materials license; SMB-1507, was obtained by Shieldalloy in May of 1987 (see SMC letter of February 20, 1990, attached).

Page 1, Summary, line 8: Change "no longer" to "has never".

Page 1, Summary, line 11: Insert new sentence after "site":

SMC has completed the decontamination of buildings, equipment, and soils, and consolidated the source material from this decontamination effort onto the West Pile. This effort was documented by SMC's Decontamination Report (Reference (4) ). NRC verified that the site decontamination effort performed by SMC had been very effective as reported in reference (6),

"Confirmatory Survey of the Shieldalloy Metallurgical Corporation Site, Cambridge, Ohio", prepared by Cotton, Oak Ridge Associated Universities, dated May 1991 (Docket No. 40-8948).

Page 4, Need for Proposed Action, 1st paragraph, line 12: SMC questions how NRC derived the quantity of material stored in the piles. The volumes and tonnage of the piles are inconsistent with the reports and information submitted to NRC by SMC since 1987 until the present time, References 1 through 7.

Page 4, 2nd full paragraph, after 1st sentence: Insert "Use of source material ceased in 1971 and Foote Mineral Company requested the termination of their NRC license in 1973".

Page 4, 2nd full paragraph, 2nd line: Change sentence to read as follows: Shieldalloy has been engaged in decontamination and decommissioning efforts since the acquisition of this site in 1987 in preparation for requesting the NRC to terminate the license ...

2

Page 6, 2nd paragraph: General comment and statement - At the time SMC acquired the facility NRC had four decommissioning options available to its licensees for decommissioning and termination of their license. Since that time the NRC requirements changed an now only options 1 and 2, which do not allow for land use restrictions, are available. Options 3 and 4, which were available previously, did allow for land use restrictions as part of the closure plan.

Page 6, 3rd paragraph, line S: Insert in sentence after "OHEPA": SMC has undertaken the groundwater and surface water monitoring program in collaboration with NRC, USEPA, Ohio BPA, and Ohio Department of Health to obtain ~ata and information to address the viability of decommissioning of these materials in-situ and to assure other environmental issues and concerns are not being adversely impacted.

Page 9: After first full paragraph, insert new paragraph:

Shieldalloy Metallurgical Corporation requests that NRC and its contractor in their efforts to develop the subject environmental impact statement for decommissioning of the source materials in-situ, utilize and consider data and I

alternatives presented in previous documents submitted by the company.

Page 10, 4.2(a), line 3: Eliminate "in a single pile that" and insert "and".

Page 11, 4.2(b), line S: SMC questions if there is a viable facility which possesses the necessary license and physical requirements for disposal of the radioactive material within 50 kilometers of the site. SMC is unaware that Ohio or any states within its Mid-West Compact have sited a facility for low-level waste disposal. The only site which SMC is currently aw"re of that could accept this quantity of material and may possess an appropriate NRC license or state equivalent license is Envirocare in Utah.

Page 11, 4.2(c): Same comment as above.

Page 12: Insert paragraph after 4.2(e), labelled 4.2(f): Alternative 6, Develop Commercial Use and Market for Radioactive Slag. The slag could be sold to NRC licensed facilities or NRC could exempt the licensing requirement for a specific use or export the material.

3

Page 14, paragraph (d), lines 6, 7, and 8: SMC questions the appropriateness of NRC's decision to develop an EIS for the decommissioning of the waste piles at Shieldalloy's facility in Newfield, New Jersey at this time since Newfield is currently an active site, processing source material in the production of ferroalloys.

Page 15, paragraph (t), lines 8-10: SMC requests clarification of the purpose and intent of its statement regarding termination or postponement of the development of the EIS due to the status of the financial restructuring under Chapter 11.

4

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January 15, 1994 Secretary, U.S. Nuclear Regulatory Commission Washington, DC 20555.

ATTN. Docketing and Services Branch

Dear Secretary,

The NRC together with the citizens of Cambridge, Ohio should hold Shieldalloy Metalurgical Corporation and all predecessor companies responsible for the entire clean-up operation according to their r e spective degree of liability. These companies should also pay for independent experts and scientists chosen by the citizens to help in making necessary decisions regarding safety, heal th and environmental issues.

Since Ohio is already a very polluted state, all contaminated and radioactive waste should be removed from the state to a licensed facility for disposal.

Interested citizens' groups and people such as Sherwood Bauman should oversee the clean-up. They should be given all the assistance they need in deciding if and when community standards are reached so that the land can be returned to the community for "unrestricted use". Any citizen involved in the process should have no affiliation with Shieldalloy, predecessor companies, or shareholder of these companies.

Sincerely ~

J~ lips 45 Canterwood Ct.

Gahanna, Ohio 43230

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S. NUCLEAR iii ... ~,- .J;*iY COMMISSION DOCi(ETlt~G & Sf.RVICE SECTION OFFICE OF THE SECRETARY OF THE COMMISSION Document Statistics Postmark Date q I I, r l 1..J Copies Recoived_*_*_*__/_ _ _ __

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OHIO ENVIRONMENTAL COUNCIL 400 Dublin Avenue

• Columbus, Ohio 43215-2333 Tel. ( 614) 224-4900

• Fax ( 614) 224-4914 1.. :.c: . ; *1

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• January 14, 1994 PROPOSED RULE PR ~~

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Chad Glenn, Project Manager Decommissioning and Regulatory Issues Branch Division of Low-Level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards

SUBJECT:

Written Comments on Preparation of EIS regarding in Shieldalloy Metallurgical Corporation's Facility near Cambridge, Ohio FROM: Submitted by the Ohio Environmental Council Bridgette Mariea, Director of Environmental Research TO WHOM IT MAY CONCERN:

Although I could not attend the NRC scoping hearing in Cambridge, Ohio at 7:00 pm on December 13, I want to submit written comments regarding the Shieldalloy Metallurgical Corporation's Facility near Cambridge, Ohio.

I am writing on behalf of the Ohio Environmental Council which is a non-profit coalition of over 170 environmental, conservation, and public health groups and approximately 1000 individual members from throughout Ohio. The OEC works with communities to improve environmental protection and public health statewide.

I find it irresponsible that the NRC would consider a decommissioning plan for the Shieldalloy site which would permit it to leave the waste on-site. NRC's own guidelines require a site to be cleaned up so all radiological contamination is removed and any residual contamination is at "acceptable levels." This policy should be followed and the site should be completely cleaned up so it can be used again for other activities.

Shieldalloy created a big mess -- about 10 million cubic feet of radioactively contaminated soil and slag -- and now they want to employ the cheapest method of cleanup. Just because they have filed bankruptcy, they should not be allowed to bend NRC's weak rules and get away with leaving the waste on-site as they propose.

What is the point of regulations if smart companies can bend them to suit their financial needs? The concentrations of thorium and uranium exceed NRC's current criteria for allowing a site to be released for unrestricted use. This fact alone should cause NRC to

• deny Shieldalloy's request. This community does not deserve to be continuously threatened by the site.

The site is proposed to be a disposal site for this waste simply because this is where Shieldalloy operated. The site was never characterized to meet regulations for treating or disposing of llrw.

In fact, its in the middle of wetlands which drain into a tributary to the community's drinking water supply. Other treatment and disposal A

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sites exist which were sited to be treatment and disposal sites because they met criteria to be treatment and disposal sites. (Of course, as official treatment and disposal sites, t hey also have in place a monitoring system and they expect regulatory oversight.)

Another issue of concern is if NRC allows Shieldalloy to leave the waste on-site, would the engineered protective measures be enough to protect the community and the environment from exposure to radioactivity for the length of time it would remain radioactive?

Thorium 232 has a half life of 1 4 billion years and uranium 238 has a half-life of 4.5 billion years. Yes, billion! It takes about 10 half-lives for waste to decay to "sa fe " levels of radioactivity.

Obviously, this site wouldn't need just long-term protective measures in place, it would need perpetual barriers! Thus , there is no future date that we can imagine whereby the site would be available for unrestricted use even though that is what decommissioning is supposed to mean.

On page 10 of the NRC summary, Shieldalloy 's plan is to "cover and grade " the site in a manner that would minimize spread of contamination. This is totally insufficient. What about liners?

What about monitoring wells? What about air monitors?

One problem is that current NRC gu i delines do not allow for land use restrictions. This is because the whole purpose of decommissioning a site is to get radioactive level s down so the site is safe for unrestricted use. But if Shieldalloy gets their decommissioning plan approved and can l eave waste on-site, the site will require restrictions so no one could get on-site and get exposed.

These restrictions are really land use restrictions, which current NRC guidelines do not allow! Why would Shieldalloy deserve such special treatment?!

It has been stated that cleanup at the Shieldalloy facility may displace 100 workers. To deal with this possibility, we suggest the company set aside $10 million. Use the interest , which will be about

$600,000 per year, to distribute to the displaced employees. This would equal about $6,000 per year per displaced employee. After all the employees die, the $10 million should be turned over to Guernsey County."

No mat ter which decommissioning plan gets approved, the citizens group - Save the Wills Creek Water Resources Committee - should be designated as a watchdog and funded to do monitoring of the clean-up.

The Cambridge community shou ld know there is a big debate about a proposed low-level radioactive waste disposal facility being sited in Ohio on behalf of the Midwest Compact. This debate centers around siting criteria for the dump and whether there is any suitable location in Ohio to dump waste that is life-threatening for thousands of years. The waste at the Cambridge site is as dangerous as low-level radioactive waste and should be t re ated as such. Unfortunately, i t appears the NRC may let Cambridge become a defacto llrtt1 dump in Ohio without any of the necessary precautions that are being taken for the Midwest dump being met for the Cambridge dump (such as site characterization to see if the site meets any siting criteria). This is totally unfair to Cambridge, Ohio.

JACKSON TOWNSHIP BOARD OF TRUSTEES GUERNSEY COUNTY, OHIO STANLEY KING ROBERT E. RASOR HARRY HOGAN 9153 Indian Lake Road 231 Watson Avenue 221 Seneca Avenue Byesville, OH 43723 Byesville, OH 43723 *94 JAN 19 p . _ Byesville, OH 43723 685-2006 685-3481 4 .53 685-3648 TOWNSHIP HALL MEETINGS HELD:

250 S. 5th Street !st & 3rd Wednesday Byesville, OH 43723 685-2568 Jarnmy 10, 1994 S:aetary u.s. Nu::!l£m' ~ ctnmi.S3i01 Attn: D:x:Ketir:g arrl ::ervi.CES Bran:h W:lEhirgtm, D.C. '2fJ555 RE: Ia:rnmi.S3imir:g of Ehi.eldallay ~urgiatl Cbqxrati01 1s Fc:ci.lity in Cm:ri~, Chio D:Br Sir:

'lhis letter is su1:mittErl to expra;s tre Sl1fIX)It of tre Jad<s:n 'IG1n:hlp B:Erd of Trust:a:S, Q:emsey cn.mty, Chio far en-site stabilizati01 of arrl disp:Eal of tre 101-level. radica:+/-ive slag trat exists at thls facility.

It is rur urrerst.an::li. fran tre infamati01 provid:rl at tre Ia:ari:er 13, 1993 R.iblic 8:r,pir:g M:etir:g in B_yesvj.ll.e, Chio trat tre c:x::ntclrd.naterl s1ag ras J:::en 01 site far rrore thm. batty :years. ~ :furtlEr urrerst:arrl trat tre level of radica:+/-ivity is rnly slightly e1evatErl arrl is less of a threBt to latlth than srddnJ td::E.cm. Mliticmlly, tre slag rray 1:E lea::h :resistant which vOil..d aJ;P':x1t" to 9.ltstantially

furtlEr .ra:b:E a rni.nirrelly existir:g ~ .

It was int:erestir:g to rote durirg t.l'E :neatir:g 01 U:u!tlet 13 trat virtually n:re of t.l'E cgnert::s to s,,c' s prqx::sa1 are fran thls area or rave aey- tyJ;e of vest.Erl interest ~ in Q:emsey Q:ulty,

<lrl.o. Ctnversel.y, th:l:e of ll'3 -wlD are :resid:nts of Cm:ri~ arrl B,yesville arrl -wlD "\<Olld 1:E m::st in lmm's way if a ~ did exist cb mt l:elieve t.l'E s1ag a:nstitutes a .te:ll ~ -

s,,c is CllITB1tly ~cpir:g a rusiress plan to arerg: fran ~ 111:enkruptcy. I t ~ trat if S-C i s ~ to <Bnmd.S3i01 t.l'E s1ag piles in aey- rreth:rl l::e}'arl tl'e 1EBst aEt en-site rreth:rl t.l'E Glrbri~ facility will cla:e arrl 8ltE ae hmrErl jets will 1:E lest. 'lhis will truly 1:E d:!vast:atir:g to t.l'E area - rrore oo tran aey- !CM levels of c:x::ntclrd.nati01 trat rave J:::en lEre over batty :years with m krnvn hmnfu1 mp:lCt.

~ l1rg:! t.l'E m::: to allc:M en-site disp:Eal at t.l'E Cm:ri~ Ehi.eldallay facility.

Rd::ert Rasr, P.resid:nt MAY 1 o 1994---..,___

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Se cret ary, US Nuclear Regulatory Commission Washington, D. C. 20555 ATTN: DOCKETI NG ';94 ,!JU!.nUL...R,

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Dear Commission Members:

r ~t; * \'.fa,h Thank you for this opportunity to respmi. ii{).(y@fui Jtt

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• SHIELDALLOY' s disposal of radioactive waste .uO ~j am "v~ry: 'd~ep ly con-cerned about this issue of disposal, because it affects not only me and Ohio now, out.also the land/ water resources for all Ohio children and grandchildren. I earnestly urge you to consider your rulings about this cleanup from this perspective, considering first the welfare and health of Ohio residents now and future. Please do NOT be influenced by the bottom line" of Shieldalloy's prospective or actual creditors.

The biggest lie in this country today is WE the Corporations are the people. Shieldalloy and its predecessor profited over 30 years from Ohio land and water, externalizing the cost of their hazardous waste disposal by freely" dumping into Ohio land and water without regard for consequences. Now let Shieldalloy pay for its careless disregard for environment and people by paying for its mess: pay for off site disposal to a licensed out-of-state facility of the 900 lbs of thorium with half-life of 10 billion years, and 38,000 lbs of uranium with half-life of 4 billion years that is in their slag piles.

Their free dump is located on a we t la nds site, near a source of Cambridge city water supply, and in a 100-year flood plain. All of this means leaching, Love Canal style.

Ohio has no facility for this quantity of "hot" garbage. It would be unconscionable for Ohio citizens to pay for removing th ~s radioactive waste to a facility with capacity to handle and store it. Perhaps some future scientist will figure a way to make it useful without killing people. In the meantime, it must be s~ored safely:

ABOVE GROUND with RETRIEVAL CAPABILITY IN A PROTECTED, SECURE ENVIRONMENT CONSTANTLY MONITORED AWAY FROM POPULATION CENTERS Please rule for the health, welfare and pocketbooks of the People of Ohio, not for the shareholders of Shieldalloy.

Sincerely,

~~

Ms. Jan Olds 404 Summit Gardens Blvd.

Kent, OH 44240 Acknowledged by card ... ~:...  !. £...!~~t.....,

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• 93 Off 27 P2 :JS 901 Wheeling Avenue Cambridge, OH 43725 Co mmunity Improvement Corporation I (J t f It t

,., (614) 432-1881 December 20, 1993 Secretary U.S. Nuclear Regulatory Camli.ssion Attn: Docketing and Services Branch Washington, D.C. 20555 RE: Decamli.ssioning of Shieldalloy Metallurgical Corporation's Facility in Cambridge, Ohio

Dear Sir:

This letter is sul:mitted to express the support of the Cambridge-Guernsey County Ccmnunity Inprovement Corporation for on-site stabilization of and disposal of the low-level radioactive slag that exists at this facility.

It is our understanding fran the information provided at the December 13, 1993 Public Scoping Meeting in Byesville, Ohio that the contaminated slag has been on site for 100re than twenty years. We further understand that the level of radioactivity is only slightly elevated and is less of a threat to health than s100king tobacco. Additionally, the slag may be leach resistant which would appear to substantially further reduce a minimally existing danger.

It was interesting to note during the meeting on December 13 that virtually none of the opponents to SMC's proposal are fran this area or have any type of vested interest whatsoever in Guernsey County, Ohio. Conversely, those of us who are residents of Cambridge and Byesville and who would be 100st in harm's way if a danger did exist do not believe the slag constitutes a real danger.

SMC is currently developing a business plan to emerge fran Chapter 11 bankruptcy. It appears that if SMC is required to decamli.ssion the slag piles in any method beyond the least cost on-site method the Cambridge facility will close and sane one hundred jobs will be lost. This will truly be devastating to the area -- 100re so than any low levels of contamination that have been here over twenty years with no known harmful inpact.

We urge the NRC to allow on-site disposal at the Cambridge Shieldalloy facility.

Al Director MJH/sar MAY 1 O 1994 Acknowledged by card ...- ....."".._,_.........

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• I 02384 Federal Register / Vol. 58, No. 226 / Friday, November 26, 1993 / Notices lstf'Fi

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y Alternative Use of Resources facility concentrated the radioactive defined in the NR~ ~tions~i'n .

This action does not involve the use materials in high temperature slag. CFR 40.4, for examole, means to remo of any resources not previously Shieldalloy no longer actively processes nuclear facilitieb a.fefy from si tyice andV. \:,S' considered for HBPP. source material at the Cambridge site to reduce residual radioactivity tb*!a and is, therefore, decommissioning the level that permits release of the property _

Agencies and Persons Consulted site in preparation for requesting the for unrestricted use and termination o \ en The ?\'RC staff reviewed the NRC to terminate the license controlling the license. l * '

exemption request. No other agencies or the possession of source material at the Once licensed activities have ceased personnel were contacted. site. This notice indicates NRC's intent licensees are ~lrired. in existing NRC to prepare an Environmental Impact regulations, to decommission thejil , ,

Finding of No Significant Impact Statement in conjunction with this facilities so that their licenses can be Based upon this environmental proposed action and to conduct a terminated. This requires that assessment, the staff concludes that the scoping process that will include a radioactivity in buildings, equipme t proposed action will not have a public scoping meeting. soil, groundwater, and surface water significant effect on the quality of the DATI:S: Written comments on matters resulting from the licensed operation be human environment. Therefore, the covered by this notice received by reduced to acceptably low levels that NRC will not prepare an environmental January 15, 1994, will be considered in allow the property to be released for impact statement for the propoied developing the scope of the EIS. unrestricted use. Licensees must then xemption.

• Comments recei\l'ed after this date will demonstrate by a site radiological For further details with respect to this be considered if it ia practical to do so, survey that residual contamination in

• action, the licensee's letter dated July but the NRC is able to assure all facilities and environmental media 28, 1993, and the NRC staff's Safaty consideration only for comments have been properly reduced or Evaluation, included in the exemption. received on or before this date. eliminated and that. except for any are available for public inspection at the A public scoping meeting will be held residual radiological contamination NRC's Public Document Room. the at the Meadowbrook High School in found to be acceptable to remain at the Gelman Building. 2120 L Street NW .. Byesville, Ohio, on December 13, 1993 site, radioactive material has been Washington DC 20037, and at Humboldt from 7-10 p.m. transferred to authorized recipients.

County Library. 421 I Street, Eureka. CA ADDRESSES: Written comments on the Confirmatory surveys are conducted by 95501. matters covered by this notice and/or NRC, where appropriate, to verify that sites meet NRC radiological criteria for Dated at Rockville. Maryland, this 19th day the scoping meeting should be sent to:

of November, 1993. Secretary, U.S. Nuclear Regulatory decommissioning.

For the Nuclear Regulatory Qnmnission. Commission, Washington. DC 20555. Need for Proposed Action John lL Austin, ATIN: Docketing and Services Branch. Shieldalloy Metallurgical Corporation Chief. Decommissioning and Regulatory Hand deliver comments to 11555 (Shieldalloy) is licensed by the NRC Issues Branch. Dmsio:n ofLow-Lttvel Waste Rockville Pae, Rockville. Maryland (License Number SMB-1507) to possess Management and Decommialo~-Office of 20852, between 7:45 a.m. and 4:15 p.m., and store the radioactive materials Nuclear Material Safety a:nd SaftJBuards. on Federal workdays. uranium and thorium (source material)

(FR Doc. 93-29015 Filed 11-24-93: 11:45 aml The scoping meeting will be held in at a site located south of Cambridge, the auditorium of the Meadowbrook Guernsey County, Ohio. Under NRC

- 81LUNG COD£ 'l'St0-01-4" High School. 58615 Marietta Road, license, previous owners of the site Byesville, Ohio 43723, on December 13, processed niobium ore containing Decommissioning of ShleldaJloy 1993. licensable quantitfes of the radioacti .*e MetaJturgtcal Corporation'* FacilJty In FOR FURTHER INFORMATION CONTACT: materials uranium. thorium, and their Cambridge, OH; Notice of Intent To Michael Weber, Office of Nuclear

• associated decay products (i.e.,

Prepare an Environmental Impact Material Safety and Safeguards, collectively considered source material).

Statement and To Conduct SCoping Washington, DC 20555, Telephone: As a result of the processing of the ore Process 301-504-1298, or Chad Glenn, Office of to produce metal alloys, the radioa.!7..ive AGENCY: Nuclear Regulatory Nuclear Material Safety and Safeguards, materials were incorporated into waste Commission. Washington, DC 20555. Telephone: slag and are currently stored in two 301-504-2546. separate piles (west and east) at the site.

ACTION: Notice of intent to prepare an Environmental Impact Statement (EIS), SUPPLEMENTARY INFORMATION: Shieldalloy previously remediated to conduct a scoping process for the EIS, Background portions of the site by removing and to conduct a scoping meeting. contamination and consolidating the The Nuclear Regulatory Commission radioactive materials into the two piles:

SUMMARY

The NRC intends to prepare (NRC) has the statutory responsibility the west pile ~;th a mass of about an Em'ironmental Impact Statement for for protection of public health and 400,000 metric tons (440,000 tons) and decommissioning Shieldalloy safety and the environment related to a volume of 160.G00 cubic meters (about Metall'Ufl!ical Corporation's the use of source, byproduct, and 5,700,000 cubic feet), and the east pile (Shieldalloy) facility located in special nuclear material under the with a mass of about 81,600 metric tons Cambridge, Ohio. Shieldalloy and Atomic Energy Act. The NRC believes (90,000 tons) and a volume of 32,600 predecessor companies at the that one portion of this responsibility is cubic meters (about 1,200,000 cubic Cambridge location have been licensed to assure safe and timely feet). The-principal radionuclides in the by Llie NRC to process ores and mineral decommissioning of nuclear facilities waste are thorium-232 (and decay concentrates containing the radioactive which it licenses. Titis responsibility products) and t:ranium-238 (and decay materials uranium, thorium. and their can be partially fulfilled by providing products).

associated decay products (i.e.* guidance to licensees on how to plan for Processing at the site no longer collectively considered source material). and prepare their sites for involves source material. Consequently, As a result of processing the ores, the decommissionins. Decommissioning. as Shieldalloy has been engaged in

Federal Register / Vol. 58, No. 226 / Friday, November 26, 1993 / Notic~s 62385 decommissioning the site for the last decommissioning do not allow for land the Agency's decision makers in several years in preparation for use restrictions. reviewing the licensee's requesting the NRC to terminate the In addition to the issues discussed decommissioning plan for the license and release the site for above that fall under NRC's jurisdiction, Cambridge site.

unrestricted use in accordance with there are other environmental issues t NRC's requirements. Because the . associated with decommissioning the The Scoping Process Cambridge site has inactive waste piles Cambridge site that are regulated by The Commission's regulations in 10 containing a large volume of other State and Federal agencies, CFR part 51 contain requirements for radioactively contaminated soil and slag including the U.S. Environmental conducting a scoping process prior to (up to a total of 10 million cubic feet), Protection Agency (USEPA) and the preparation of an EIS. In accordance NRC included the Cambridge site in the Ohio Environmental Protection Agency with 10 CFR 51.26, whenever the NRC Site Decommissioning Management (OHEPA). The scoping process and EIS determines that an EIS will be prepared Plan (SDMP) 1 and has been devoting will not only aid NRC in reaching by NRC in connection with a proposed special attention to the site to ensure decisions about the decommissioning of action, NRC will publish a notice of timely and-effective decommissioning. the Cambridge site, but should also be intent in the Federal Register stating In September 1993, Shieldalloy and useful to these other agencies in that an EIS will be prepared and its parent company, Metallurg Inc., filed discharging their respective duties. conduct an appropriate scoping process.

for protection from creditors under In addition, this scoping process rnay Chapter 11 of the Bankruptcy Code. Description of Proposed Action include the.holding of a public scoping Decommissioning the Cambridge The proposed action is onsite meeting.

facility, and another licensed site in stabilization and disposal of radioactive NRC also describes, in 10 CFR 51.27.

Newfield, New Jersey, represent two of waste containing elevated the content of the notice of intent and Shieldalloy's largest and unquantified concentrations of thorium and uranium requires that the notice describe the liabilities, which must be resolved as and their radioactive decay products at proposed action and also, to the extent part of the company's restructuring the Shieldalloy facility in Cambridge, that sufficient information is available, activities under Chapter 11. To Ohio. Because radioactive possible alternatives. In addition, the complete restructuring in a timely contamination at the site has been notice of intent is to describe the manner, Shieldalloy has requested NRC consolidated into two waste piles, the proposed scoping process, including the to determine whether onsite proposed action principally focuses on role of participants, whether written stabilization and disposal ofradioactive the disposal of the radioactive materials comments will be accepted, and waste is acceptable for completing the within those waste piles. whether a public scoping meeting will decommissioning of the Cambridge Preparation of an Environmental be held.

facility. In accordance with §§ 51.26 and Impact Statement The NRC has determined that 51,27, the proposed action and possible approval of onsite stabilization and Under the National Environmental alternative approaches are discussed disposal of the radioactive waste Policy Act (NEPA), all Federal agencies below. The role of participants in the constitutes a major federal action and, must consider the effect of their actions scoping process for this EIS includes the therefore, warrants preparation of an EIS on the environment. Section 102(1) of following:

in accordance with the National NEPA requires that the policies, (1) Participants may attend and Environmental Policy Act (NEPA) and regulations, and public laws of the provide oral discussion on the proposed the NRC's implementing requirements United States be interpreted and action and possible alternatives et the in 10 CFR part 51. Concentrations of administered in accordance with the public scoping meeting at Meadowbrook uranium, thorium, and their radioactive policies set forth in NEPA. It is the High School auditorium, Byesville, decay products in the waste piles intent of NEPA to have Federal agencies Ohio, on December 13, 1993, from 7 to exceed NRC's current criteria for incorporate consideration of lOp.m.

allowing release of sites for unrestricted environmental issues into their (2) The Commission will also accept use. These criteria are listed in NRC's decision-making processes. :t-.'RC written comments on the proposed Action Plan to Ensure Timely Cleanup regulations implementing NEPA are action and alternatives from the public.

of SDMP Sites (57 FR 13389; April 16, contained in 10 CFR Part 51. To fulfill Written comments should be submitted 1992). As described in the Action Plan, NRC's responsibilities under NEPA, the by January 15, 1994, and should be sent the criteria are applied on a site-specific NRC intends to prepare an EIS that will to: Secretary, U.S. Nuclear Regulatory basis with emphasis on residual analyze the environmental impacts of Commission, Washington, DC 20555.

contamination levels that are as low as the proposed action, as well as ATfN: Doclceting and Services Branch.

is reasonablv achievable (ALARA). environmental impacts of alternatives to Hand deliver comments to 11555 Consequently, ifNRC approved on- the proposed action and the costs Roch-ille Pike, Roclcville, Maryland site stabilization of the radioactive associated with both the proposed between 7:45 am and 4:15 pm on material. land use restrictions or other action and the alternatives. All Federal workdays.

institutional controls may be necessary reasonable alternatives to the proposed According to 10 CFR 51.29, the to ensure long-term protection of the action, including the "no action" scoping process is to be used to address public and the environment. NRC alternative, will be analyzed. The scope the topics which follow. Participants expects that Shieldalloy would have to of the EIS includes consideration of may make written comments, or verbal apply for and obtain an exemption from both radiological and non-radiological comments at the scoping meeting, on NRC's present requirements because impacts associated with the alternative the following (current preliminary NRC NRC's current requirements for actions. staff approaches with regard to each This notice announces the NRC's topic are included for information):

• The Site Decommissioning Management Plan, intent to prepare an EIS. The principal (a) Define the proposed action to be U.S. Nuclear Regulatory Commission, NUREG- the subject of the EIS. The proposed 1444, 1993, is available from the U.S. Government intent of the EIS is to provide a Printing Office, Mail Stop SSOP, Wubington, DC document describing environmental action is the onsite stabilization and W-402-9328. consequences that will be available to disposal of radioactive waste in the form

62386 Federal Register / Vol. 58, No; 226 / Friday, November 26, 1993 / Notices of slag and contaminated soil at the monitor the long-term effectiveness (e) Alternative 5, No Action-Shieldalloy facility in Cambridge, Ohio. of the disposal and take mitigative radioactive contamination would be (b) Determine the scope of the EIS and measures as necessary to protect the abandoned in its present the significant issues to be analyzed in public and environmanL configuration without any depth. The NRC is proposing to analyze (b) Alternative Z, OjfsittJ Disposal- additional processing or the costs and impacts associated with radioactive contamination would be stabilization. This alternative does the proposed action and alternative exhumed .&om the site and not consider any protective decommissioning approaches. The disposed offsite at a licensed low* measures, such as land use following proposed outline for the EIS level waste disposal facility. The restrictions or other institutional reflects the current NRC staff view on disposal facility may either be controls, that might mitigate or the scope and major topics to be dealt located in the vicinity of prevent intrusion into the waste or with in the EIS: Camhridae, Ohio (e.g.. within 50 long-term release and transport of Proposed Outline: Environmental km) or in another State. This contamination in the environment.

Impact Statement alternative could also consider 4.3 Method of Analysis of Abstract disposal of the contamination along Regulatory Alternatives ..

Executive Summary with other wastes of similar (a} Define a range of alternative physical. chemical, and radiological decommissioning approaches; Table of Contents characteristics, such as mill tailings. (b} Evaluate the alternative

1. Introduction or in a dedicated disposal facility decommissioning approaches with 1.1 Background that would provide enhanced respect to: (1) the incremental 1.2 Purpose and Need for Proposed barriers against human intrusion impact to workers, members of the Action into the waste for thousands of public, and the environment, both 1.3 Description of Proposed Action years, such as a deep mine. radiological and nonradiological, 1.4 Approach in Preparation of the Radioactive contamination onsite resulting from each alternative, and Draft EIS would be reduced down to levels (2) the costs associated with each 1.5 Structure of the Draft EIS that NRC presently considers regulatory alternative. Evaluations

2. Alternatives including the Proposed acceptable for release for of impacts and costs are contained Action unrestricted. use (e.g., 10 picoCuries in Sections 5 and 6 below; 2.1 Factors Considered in Evaluating per gram (pCi/g) total uranium (c) Perform a comparative evaluation Alternatives (with decay products) and 10 pCi/ of the decommissioning approaches 2.2 Alternatives g thorium-232 and thorium-228 and based on the impacts and costs of 2.3 Regulatory Compliance other criteria such as exposure rate each alternative from 4.3(b).

• 3. Affected Environment and radon concentrations): 5. Environmental Consequences, 3.1 Introduction (c) Alternative 3, Onsite Separation Monitoring, and Mitigation 3.2 Description of the Cunbridge Processing with Offsite DisposaJ- 5. 1 Construction and Remediation facility radioactive contamination would be 3.3 Land Use Consequences processed using physical or 5.2 Monitoring Programs 3.4 Geology/Seismicity chemical methods to separate more 3.5 Meteorology and Hydrology 5.3 Mitigation Measures highly concentrated contamination 3.6 Ecology - 5.4 Unavoidable Adverse from lower concentrations that 3.7 Socioeconomic Characteristics Environmental Impacts could be stabilized onsite. Higher 3.8 Radiation 5.5 Relationship between Short* .

concentration wastes would be sent 3.9 Cultural Resources Term Uses of the Environmentand offsite to a licensed disposal 3.10 . Other Environmental Features facility. Radioactive contamination Long-Term Productivity

4. DecommissioJling Alternatives 5.6 Irreversible and Irretrievable onsite would be reduced down to Analyzed and Method of Approach levels that NRC presently considers Commitments of Resources for the Analysis acceptable for release for 6. Costs and Benefits Associated with 4.1 General Information on unrestricted use (e.g.* 10 pCi/g total Decommissioning Alternatives Approach and Method of Analysis uranium (with decay products) and 6.1 General of Decommissioning Alternatives 10 pCi/g thorium~2 and thorium* 6.2 Quantifiable Socioeconomic 4.2 Alternatives Considered~ach 228 and other criteria such as Impacts of the alternatives represent exposure rate and radon 6.3 The Benefit-Cost Summary alternate decommissioning concentrations): 6.4 Staff Assessment approaches. (d) Alternative 4, Onsite Dilution 7. List of Preparers (a} Alternative 1, Onsite Stabilization Processing and Dis~sting 8. List of Agencies, Organizations, and and Disposal [Licensee's Proposed radioactive contamination would be Persons Receiving Copies of the Action)-radioactive contamination blended with clean fill to reduce Draft EIS would be consolidated and average concentrations of uranium 9. References stabilized in a single pile that and thorium to levels that NRC Appendix A-Reserved for Comments would be covered and graded in a presently considers acceptable for on DEIS manner to provide long-term release for unrestricted use (e.g.* 10 Appendix &-Results of Scoping protection against wind and water pCi/g total uranium (with decay Process erosion and to minimi:r.e products) and 10 pCi/g thorium-232 (c) Identify and eliminate from groundwater contamination. This and thorium-228 and other criteria detailed study issues which are not alternative would also likely . such as exposure rate and radon significant or which are peripheral or include land use restrictions and/or concentrations). Diluted which have been covered by prior other institutional controls to contamination would then be environmental review. The NRC has not prevent or reduce potential graded onsite and released for yet eliminated any nonsignificant intrusion into the waste and to unrestricted use; and issues. However. NRC is considering

Federal Register / Vol. 58, No. 226 / Friday, November 26, 1993 / Notices 62387

.uinmation of the following issues from plan as required in 10 CFR 40.42(c)(2). Decommialonlng of Shleldalloy scope of this EIS because they have Depending on the resolution of the Metallurgical Corporation'* Facility in n previously analyzed in a previous licensee's financial restructuring under Newfield, NJ; Notk:e of Intent To Qmeric ~vironmental Impact Chapter 11 of the bankruptcy code, the Prepare an Environmental Impact ement (GEIS) (NUREG-0586) and NRC may terminate or postpone Statement and To Conduct a Scoping uded in an earlier rulemaking (53 development of the EIS. Procesa

jl.%4018, June 28, 1988): (i) Planning

• ary to conduct decommissioning (g) Describe the means by which the AGENCY: Nuclear Regulatory operations in a safe manner; (ii) EIS will be prepared. NRC will prepare Commission.

...t111'1!m,ce that sufficient funds are the draft EIS according to the ACTION

Notice of intent to prepare an lfflli).able to pay for dACOroroiflioning; requirements in 10 CFR part 51. Environmental Impact Statement (EIS),

the time period in which Specifically, in accordance with 10 CFR to conduct a acoping process for the EIS.

• mm.issioning should be completed; 51.71, the draft EIS will consider and to conduct a scoping meeting.

111d (iv) whether facilities should not be comments submitted to NRC as part of

SUMMARY

The NRC intends to prepare ieft abandoned. but instead remad.iated the scoping process and will include a an EIS for decommissioning Shieldalloy to.appropriate levels. In addition. preliminary analysis which considers Metallurgical c.orporation's teqUirements were recently proposed in and balances the environmental and (Shieldalloy) facility located in a.separate rulemaking regarding other effects of the proposed action and Newfield. New Jersey. Shieldalloy and

.' UJ'.._..... ,ess of dflCOrornissioning for 10 the alternatives available for reducing or predecessor companies at the Newfield CPR Parts 30, 40, and 70 licensees (58 avoiding adverse environmental.and location have been licensed by the NRC In 4099: January 13. 1993). other effects, as well as the to process ores and mineral concentrates

, (d) Identify any Environmental environmental, economic, technical, containing the radioactive materials Assessments or EISs which are being or and other benefits of the proposed uranium, thorium, and their associated will be prepared that are related but are action. decay products (i.e., collectively not part of the sct,pe of this EIS. A draft considered source material). As a result

_Environmental .Assessment on the The EIS will be prepared by the NRC staff and an NRC contractor. NRC is of processing the ores to produce metal

• timeliness of decommissioning has been alloys, Shieldalloy concentrated the prepared as part of a separate arranging a project with Oak Ridge radioactive materials in high rulemaking on decommissioning National Laboratory to provide technical temperature slag and in baghouse dust.

timeliness (58 FR 4099: January 13, assistance in the preparation of the EIS. Shieldalloy continues to process the 1993) and will be finalized. NRC is In addition, NRC anticipates requesting source matsrial. Although Shieldalloy

• presently developing a Generic .EIS to specific information from the licensee to has no intent to close down the

~support a rulemaking to establish support preparation of the EIS. Any Newfield facility in the foreseeable

• generic radiofogical criteria for information received from the licensee future, plans for stabilizing or disposing decommissioning. In addition. NRC is related to the EIS will be available for of the slag and dust need to be presently developing an EIS for public review, unless the information is established u part of a process for

.. decommissioning the waste piles at protected from public disclosure in renewing the NRC license at the site.

Shieldalloy's facility in Newfield. New accordance with NRC requirements in Tb.is notice indicates the NRC's intent to

]eney. 10 CFR 2.790. prepare an EIS in conjunction with this

_* (e) Identify other environmental review or consultation requirements In the scoping process, participants proposed action and to conduct a related to the propossd action. NRC will are invited to speak or submit written scoping process that will include a consult with other Federal, State, and comments, as noted above, on any or all public scoping meeting.

local agencies that have jurisdiction of the areas described above. In DATES: Written comments on matters over the Cambridge site accordance with 10 CFR 51.29, at the covered by this notice received by decommissioning. For example, NRC conclusion of the scoping process, NRC January 15, 1994, will be considered in has already been coordinating its will prepare a concise summary of the developing the scope of the EIS.

reviews of decommissioning actions at determinations and conclusions Comments received after this date will the Cambridge site with the USEPA, reached, including the significant issues be considered if it is practical to do so, OEPA, and the Ohio Department of but the NRC is able to assure identified, and will send a copy to each Health. NRC anticipates continued consideration only for comments participant in the scoping process. received on or before this date.

consultation with these and other agencies, as appropriate, during the Dated at Rockville, Maryland, this 19th day A public scoping meeting will be held development of the EIS. of November 1993. at Delsea Regional High School in (0 Indicate the relationship between For the U.S. Nuclear Regulatory Franklinville, New Jersey, on December the timing of the preparation of Commission. 16, 1993, from 7-10 p.m.

environmental analysis and the John H. Autin, ADDRESSES: Written comments OD the Commission's tentative planning and Chief. Decommissioning and Regulatory matters covered by this notice and/or decision making schedule. NRC intends Issues Branch, Division of Ltnv-u,vel Waste the scoping meeting should be sent to:

to prepare and issue for public comment Management and Decommissioning, Office of Secretary, U.S. Nuclear Regulatory a draft EIS in October 1994. The Nuclear Material Safety and Safeguard,. Commission, Washington. DC 20555.

comment period would be for 90 days. {FR Doc. 93-29013 Filed 11-24-93; 8:45 am) ATI'N: Docketing and Services Branch.

The final EIS is scheduled for BIWNG CODI! 7510-411...P Hand deliver comments to 11555 publication in June 1995. Subsequent to Rockville Pike, Rockville, Maryland completion of the final EIS, the NRC 20852, between 7:45 a.m. and 4:15 p.ro.,

would review and act on a license on Federal workdays.

amendment from the licensee requesting The 8COping meeting will be held at authori7.ation for decommissioning the Delsea Regional High School.

site, including the decommissioning Blackwoodtown Road (County Highway