View source for IA-87-235, Provides Summary of 760203-06 Insps at Commercial Waste Burial Facilities in Sheffield,Il,Beatty,Nv,Richland,Wa, Maxey Flats,Ky,Barnwell,Sc & West Valley,Ny.Nrc Finds No Evidence of Significant Radwaste Migration.Related Encls

{{Adams
| number = ML20239A061
| issue date = 03/30/1976
| title = Provides Summary of 760203-06 Insps at Commercial Waste Burial Facilities in Sheffield,Il,Beatty,Nv,Richland,Wa, Maxey Flats,Ky,Barnwell,Sc & West Valley,Ny.Nrc Finds No Evidence of Significant Radwaste Migration.Related Encls
| author name = Davis J
| author affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE)
| addressee name = Gossick L
| addressee affiliation = NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
| docket = 02700010, 02700039, 02700047, 02700048
| license number = 
| contact person = 
| case reference number = FOIA-87-235
| document report number = NUDOCS 8709170057
| package number = ML20238F347
| document type = INTERNAL OR EXTERNAL MEMORANDUM, MEMORANDUMS-CORRESPONDENCE
| page count = 23
}}

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UNITED STATES j              q
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                                                       /                                       NUCLE A R REGULATORY COMMISSION
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March 30, 1976                                                           ,
J Lee V.'Gossick, Executive Director for Operati6..s INSPECTION OF WASTE BURIAL FACILITIES Special inspections were conducted at comadreial waste burial facilities similar to those carried out about one year ago and reported to L. Manning Muntzing en January 16, 1975 (Enclosure 1).                                                                             These special inspections of the six commercial waste burial sites under vdricus levels of NRC and/or Agreement State jurisdiction were all conducted between February 3 and 6, 1976 and the licensees are listed below:
Site                                                                              Jurfadiction Nuclear Engineering Company Sheffield, Illinois                                                                                                          NRC
                 . Nuclear Engineering Company Beatty, Nevada                                                                                                               NRC (SNM)
State of Nevada Nuclear Engineering Company Richland, Washington                                                                                                         NRC (SNM)
St' ate of Washington Nuclear Engineering Company Maxey Flats, Kentucky                                                                                                        State of Kentucky Chemical-Nuclear Systems Inc.
Earnwell, South Carolina                                                                                                     NRC (SNM)
State of South Carolina Nucienr Fuel Services West Valley, New York                                                                                                        State of New York
* This memorandum is a summary of the results of those inspections, including the analyses of the samples obtained during site visits.                                                                                             In general, we conclude, as we did after last year's round of inspections, that there is no,cvidence of any,significant transport of radioactive materials from digration through underground movement. In addition, based on off-site sampling by licensees and States, there is no significant impact to the off-site environment attributable to the operation of the waste burial facilities although rome small quantities of radioactive material have been detected away from the burial locations at some sites.
I B709170057 870910                                                                                                                                                                d2 PDR                          FOIA                                                                   .          '
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Lee V. Gossick                                        The Regi.onal' Directors were requested to hav'e inspectors conduct a survey 'of burial grounds similar to the survey conducted during November 1974 and 'desetibed in more detail in the January 16, 1975 memorandum to Mr. Muntzing. One difference in this round of inspections as compared to the previous effort was the IE visit to the Kentucky burial site.
Samples from esteb11shed test weils or nearby streams collected during these inspections were analyzed by the Health Services Laboratory, Idaho Falls. The data as tabulated in Enclosure 2 shows levels that agree reasonably well with licensee and State analysis results.
A summary of the inspection findings for the commercial waste burial facilicies is described below. It should be noted that the conclusions are based largely on review of records with li'censee's and/or State regulatory agencies.
Nuclear Engineering Company, Sheffield, Illinois Review of the licensee's envircamental sampling program does not indicate any migration of any radioactive materials; however, the sampling results do not preclude migration. The state advises they cannot support a positive conclusion that migration is taking place.         .
Nuclear Engineering Company, Beatty, Nevada Based on the current and past inspections, we conclude there is no indication of radioactive vaste migration from the site.              l l
Nuclear Engineering Company, Richland, Washington                        l Based on the current and past inspections, we conclude there is no indication of radioactive waste migration from this site.
Chem-Nuclcar, Barnwelig cauth Carolina Basedo 'n lic'ensee and state data there is no evidence of migration     !
of alpha and beta emitting radioactive material. There is no evidence of tritium migration off-site but on-site levels are            ;
slightly clevated.
l 9
1 L______________________-_____------_---     ..-

e 3 Lee V. Gossick                                                                                                                                                               1 Nuclear Engineering Company, Maxey Flats, Kentucky The' State's environmental program for the period of May 1974 -
December 1975 shows a general decline in radioactivity in the off-site environment. The -ircase is attributed to identification and                                                            j decontamination of surf at contamination about the burial ground                                                             ]
plus the removal of significant amounts of water from the burial                                                             i trenches. However, the State is concerned that preliminary results of recent samples indicate increasing levels including gamma emitting isotopes not previously identified. This situation will be watched closely.
_ Nuclear Fuel Services, West Valley, New York A study by NSF and the State concluded that radionuclides migration from burial trenches into the undisturbed silty till is slight.
Rain water is the most likely cause of rising trench water levels.
Surface contamination may have occurred from spills during burial and from deposition of stack effluents from the fuel reprocessing plant.
Our instructions to the regional offices also requested that they give us a brief feel for the number of burials made- under the authority of 10 CFR Part 20. This was to obtain some estimate of the amount of                                                                '
radioactive waste which is being buried at places other than the commercial waste burial sites. Although difficult to determine accurately without a thorough search of inspecti.on repo'rts the responses indicate that there is probably much less than 10 curies of radioactive material l
buried in the United States in this manner by fewer than 50 licensees.
Since completion of this group of inspections, the removal of contaminated                                                         l items from the Beatty, Nevada site has come to light. A summary of that                                                            I situation and the efforts of the State of Nevada and the KRC is provided for your information in Enclosure 3.
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V     j John G. Davis,' Acting Director Office of Inspection and Enforcement

==Enclosures:==

As stated                                                                                                                           i I
cc: K. R. Chapman R. Cunningham W. Kerr
       ' R. Mattson C. Smith Regional Offices               ,

Enclosure 1
 ,                             ,                ,. [ %,                                                                  UNITED STATCS 8
* ATOMIC ENERGY COMMISSION
                                                                / - ~ab ,
WASHINGTON. D.C. 20545                                             !
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I L. Manning Muntzing                                                                                     l Director of Regulation WASTE BURIAL FACILITIES This is in response to your request of November 20, 1974 that RO inspect all AEC licensed waste burial sites on a priority basis.             This request for immediate inspections was prompted by notification that a Kentucky report on the Maxey Flats burial' facility was about to be made public.        An early draft of the Kentucky report concluded among other thinge that there had been some migration of Pu to the unrestricted environment.        (The final Kentucky report released in mid-December stated that Pu and other radionuclides were measured in individual samples but the waste burial site did not create a public health hazard.)           These special AEC inspections of five commercial waste burial sites, either partially or fully licensed by AEC, were completed on November 29, 1974 and are listed below:
NuclearFuelServices,NestValley,NewYork Nuclear Engineering Co., Inc., Beatty, Nevada Nuclear Engineering Co., Inc., Richland, Washington Nuclesr.. Engineering Co. Inc., Sheffield,_ Illinois...__
Chem-Nuclear Systems, Inc., Barnwell, South Carolina This memo is a summary of the results of those inspections. In general, there was no evidence of any significant transport of radioactive materials through migration. In addition, -based on of fsi?e sampling by licensecs and States, no impact to the offsite environment could be attributed to the operation of these waste burial facilities.
The RO Regional Directors were requested to have their inspectors determine, in detail, that which had been done to monitor for migration of radioactive material and review the results cf these determinations.
Inspectors were asked to obtain the maximum information possible concern-ing the complete operation of the burial sites. In addition, to provide a basis to judge the correctness of !.he licensee and State measurements, we requested the collection of samples from onsite sampling points for AEC analysis.
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JAN 1 0 1F5 L. Manning Muntaing                          ,
Attachment 1 shows that as of the end of 1973, the total quantities of radioactive wastes buried at these facilities varied from about 200,000 cubic feet (Barnwell site) to almost 2,000,000 cubic feet of                  ,
wastes (West Valley site). Average radioactive material concentrations at waste burial sites are generally in the range of tenths of a curie per cubic foot.
From the information gathered, it appears that licensees and States have initiated reasonabic environmental monitoring programs which l                 consider the major pathways to the public. A variety of samples as I                 shown on Attachment 1, are collected and analyzed periodically. The licensee records of these analyses showed no evidence of any offsite environmental impact.      In addition, State environmental monitoring programs which were established to check the facility operation conditions support these results.
All facilities with the exception of NFS have onsite monitoring wells to attempt to detect the movement of radioactive material away from the trenches. (NFS had used two nearby streams as such an indicator, but several test wells have recently been dug as part of a special study.)
No significant activity due to waste burial was measured beyond burial          ,
j trenches at any of the sites. A small amount of activity was found in                 l some wells located fairly close to the trenches, but in those cases, the concentrations were ceveral orders of magnitude' lower than the concen-trations in the trenches.
Sampics from test wells or nearby streams collected during these                    .
inspections by RO inspectors were analyzed by the Health Services Labora-tory, Idaho Falls.      The data, as tabulated in Attachment 2, showed levels         I that agree well with licensee and State analysis results.
The location of the test wells for measuring migration are critical and I
there is no satisfactory means of determining that a suitable placement has been accomplished. Test wells placed close to the trenches can be
                 " bypassed by trench leakage, whereas wells too far away may not detect migration until it is significant. In addition, the depth of the test well is crucial since the possible migration elevation is not normally known. However, even if activity is detected in the. test wells, this may, in many cases, be due to surface runoff into.the well rather than lateral migration.      Therefore, in order to make a more conclusive determination of migration of radioactive materials from the burial trenches, detailed studies on soil conditions, geological structure, underground water movement and meteorology, etc. , would be required.
Such studies are vell beyond the scope of routine monitoring programs.

0 L. Manning Muntzing,                                          M 16 5 75 L and RO reeently met with a representative of the U. S. Geological Survey (USGS) and were informed that legislation requires USGS to survey existing waste burial sites in order to determine criteria for locating future waste disposal sites. USGS expects to initiate detailed studies in early 1975 on at least two of the burial sites covered in this report (Sheffield, Illinois and West Valley, N. Y.). It is antici-pated that such studies will continue for several years and will provide the type of information NRC needs regarding containment at the current sites as well as provide the Commission and the Agreement States with criteria for siting future waste burial facilities.
I In addition to material buried at the comme'rcial waste sites listed           I above, there are significant quantities of radioactive material entombed at decoraissioned reactor facilities, i.e., Bonus (50,000 C1), Hallam (300,000 C1) and Piqua (60,000 Ci). Also, a few licensees have been authorized to bury radioactive materials in private burial grounds in I
excess of the quantities specified in Section 20.304. A listing of these latter licensees has not been separately maintained by L. To identify those licensees would require an extensive and time consuming search of the files. However, during routine inspections, such special license authorizations are reviewed by the RO inspector but to our             ;
recollection there are no special requirements for monitoring for              l p6ssible migration of radioactive materials. Additionally, it should be noted that the regulations grant all licensees authority to bury            i ncminal quantities of radioactive material.
LG4 f /(wn?
Donald F. Knuth, Director Directorate of Regulatory Operations 9
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ATTACHMENT 2 INDEPENDENT MEASUREMENTS - WASTE BURIAL SITES Gross d Tritium               144Ce   137Cs      60Co Burial Sites           Sam                           <dpm/mi     uC1/mi                    uC1/mi Chem-Nuclear           CN-1                           <0.06    2.81 4E-6          '<5E-8    2.11 5E-8  1. 6+. 4 E-Barnwell, S.C.        .CN-2                           <0.04    1.71 4B-6            <5E-8   <8E-9      <9E-9 CN-3                           <0.04    1.7i.4E-6            <5E-8   <6E-9      <5E-9 CN-4                           <0.01    1.71 4E-6            <6E-8   <2E-8      <9E-9 CN-5                           <0.04    <7E-7                <6E-8   <6E-9      <5E-9       l l
4FS                    Buttermilk Creek              <0.01     <lE-6                <5E-8   <6E-9      2. 4i. 4E-Jest Valley, N.Y.      Erdman Brook (NY #67)         <0.01     <1E-6                <6E-8   <6E-9      <5E-9 Erdman Brook (NY #53)         <0.01     211E-6               <5E-8   <8E-9      <5E-9       .
l Hot-Cold Ditch (NY #73)       <0.02     <1E-6                <6E-8   1.%i.1E-7  <9E-9 Ditch North (NY #74)        . <0.02     2.91 1E-5*           <5E-8   1.31 5E-8 <5E-9 r7                     S.E. Creek                    <0.02     <1E-6                <7E-8   <2E-8      <9E-9 3heffield, Ill.        Water Strip Mine               <0.06    <1E-6    -
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Test Well B                   <0.02     <1E-6                <6E-8   <6E-9      <5E-9       l Test Well D                   <0.01     <1E-6                <7E-8   <2E-8      <9E-9       I Test Well E                   <0.04     <1E-6                <6E-8   <2E-8      <9E-9 Test Well P                   <0.06     <1E-6                <2E-8   < 5 2-8    <9E-9 TECO                   NE-9                          <0.07     <1E-6                <6E-8   <2E-8      <9E-9 leatty, Nev.           NE-10                          <0.05    <1E-6                <6E-8   <6E-9      <5E-9 NE-11                          <0.09    <1E-6                < 4E-8  <8E-9      <5E-9 ECO                    NE-1                           <0.05    < E-6                <9E-8   <2E-8      <2E-8 dchland, Wash.         NE-2                           <0.05    <1E-6                <9E-8   <2E-8      <1E-8 liquid sample from ditch receiving surface drainage and water from swamp.                     Previous invest:
: ion of elevated tritium levels at this location disclosed most likely source appeared ti be seepage from reprocessing plant lagoons and not from burial trenches.
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g Enclosure 3 REMOVAL OF CONTAMINATED MATERIAL FROM THE BEATTY. NEVADA SITE The Nevada State Department of Human Resources initiated an investigation in Beatty, Nevada on March 6, following a report by the Nuclear Engineering Compan'y, Inc. (NECO), the Beatty burial ground operator. NECO reported to the State that a cement mixer used at the burial site to solidify low-level liquid radioactive vaste had been used in the town.of Beatty to pour concrete slabs at a local saloon and a few private properties. During the course of.
the State's investigation concerning the use of the cement mixer, the State uncovered evidence that other violations of the company's license had occurred over a, period of several years 1nvolving rerioval of contaminated tools, equip-ment and supplies from the Beatty site by NECO employees.           The State suspended NECO's license to operate the burial ground on March 8.
The State subsequently asked for assistance from the Environmental Protection Agency in Las Vegas which dispatched a radiation survey team to Beatty. The State also reported itt evidence to the Nucicar Regulatory Commission (NRC) ,
which also sent inspectors to Beatty. (The NRC license issued to NECO covers special nuclear material.) When the scope of the problem became apparent, the NRC requested additional assistance from the Environmental Research and Development Administration (ERDA) Nevada Operations Office, which provided additional survey teams and a range of sophisticated and very sensitive radiation detection equipment, including a helicopter, mobile laboratory and a van designed to locate radioactive material. The NRC suspended NECO's license on March 11.
The Federal / State investigation conducted at Beatty was essentially completed March 14. Some follow-up work is continuing at Beatty but the majc'r effort to identify and remove cor.taminated equipment and material is completed.
During the course of the investigation, the radiation survey teams turned up a large number of itema which had been removed from the Nuclear Engineerlag Company facility by employees and former employees. A large number of these items were voluntarily turned in by the people of Beatty as a result of an appeal made at a town meeting. Based on our present knowledge, both State and Federal radiation specialists are convinced that no health hazard exists in Beatty and that all contaminated material that has been identified as coming from the NECO site has been returned to the facility. Generally, the items that were contaminated were of a very low-level, typically 2 mr/hr at contact.
Over a period of five days, the survey teams surveyed about 150 residences in Beatty, which is essentially the entire town and surrounding ranches.
Only two of those homes contained items inside with traces of radioactive contamination. One home had a chemical balance scale with traces of plu-to nium. In another residence, a spot on the carpet about the size of a dime was found which was contaminated with radium. Both the scale and the carpet were removed from the homes and no residual radiation was detected.
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Enclosure 3                                                                                                          .
Contaminated tools, equipment and plywood were found in several yards, sheds and other storage areas. This material included hundreds of items such as hand tools,' electric motors, lumber, radio equipment and similar types of material. This material was returned to the burial facility.
The investigation also identified metal tanks, called Bennett Buckets, which had been used to ship contaminated' material to Nuclear Engineering Company, being used throughout the town. The survey teams found no con-tamination on any of the 23 tanks found. These tanks were being opened at the facility, the contents dumped and scavenged, and the tanks used throughout the area for septic tanks, water supply and general storage.
An effort is being made to identify additional tanks in surrounding areas.
As a precautionary follow-up, whole-body radiation measurements were made on several individuals who were in closest contact with the contaminated items and no significant activity was detected. The NRC is continuing to investigate allegations and rumor ~s that some items from the Nuclear Engineering Co. facility may have been taken from the immediate Beatty area.
             ,    Representatives of IE, NMSS and ELD plan to meet with officials of the State of Nevada on March 31 to discuss further enforcement action.
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              .icensing !!istory:,
Kentucky becar_e the first Agree.ent State when they cip.ed an agree =ent I
in March 1962. With the primary intention of encouraging nucleac industry in Kentucky, the Kentucky Atomic Energy Authority (now the Kentucky Science and Technology Cc=sission) pursued the concept of a radioactive disposal site in Kentucky. In October 1962, the State issued a license to the Nuclear Engineering Company to operate a disposal site at Maxey l
Flats, Kentucky. The land was purchased by Nucle'ar Engineering Company and the title to the land was transferred to the State. The land was then leased back to Nuclear Engineering Company for operation of the site.
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           , For perpetual care of the site, the lease agreement contains a clause stating that Nuclear Engineering Company will pay the State a negotiated price per cubic foot of waste not 'to e.xceed 4 percent of the average                            i burial charge per cubic foot charged by the licensee. The State has                                l i
approximately $160,000 in the perpetual care fund.
l Since 1970, increasing quantities of radioactive material have been disposed of at the Maxey Flats site. During the past ten years, the licensee has buried about 3 million cubic feet of radioactive wastes, containing about 1-1/2 million curies of byprodset material, 300 kilograms of special nuclear material, and 50 tons of source materia 1. In addition to cocsercially generated waste s from reactors, isotope users, and fuel                           j cycle facilities, significant quantites of plutenium 238 and tritium from Cocimission contractor operations are buried bere.
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                                     ~
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s Trench Water Preblem:
In 1970 the State became concerned with on-site water eccagement problems.
This concern increased during 1971 as the licensee continued to have prob-lems with accumulation of water in completed trenches.                                  The State instituted enforcement action but the licensee was unable to control the water prob-lems on site.                               In September 1972, the State issued an order against Nuclear Engineering Company for non-compliance and v111ful violation of conditions of the license relating to water in completed trenches, burial of unauthor-ized material, and disposal of liquid wastes.                                   Following issuance of the 4
order, the licensee 'was permitted to operate the waste burial site for the disposal of solid wastes only. The licensee was required to file an                                              ,
irrevocable letter of credit for $500,000.
* This letter of credit vns in I
        ' lieu of a performance bond to assure compliance with the terms of the order.                                  The letter of credit will come up for renewal in January 1975.
Action by the licensee to control water problems has included the pumping of water from trenches into above ground storage tanks and the installa-tion of an evaporator to concentrate the liquid wastes for disposal as solids. The evaporator is being operated under an interim authorization by the State to test its effectiveness. The evaporator is not effective in removing tritium from the water. At the present time, the licensue has approximately 650,000 ga11ont of trench water stored in the surface tanks and has processed about 1 millica gallons of water through the evaporator.
Trench pumping operations are continuing but about 25% of the trenches still have water in them.
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                                                                               ,         1 Site Descrip_ tion:
Maxey Flats is located in Fleming County in the Northeastern portion of the state of Kentucky. As seen on the topographic nap (slide 1) Maxey            ;
I Flats is a flat-top hill with s:eep sides. Throughout most of the area the flat " top land" is in grass or crops and the steep hillsides are forested. This is true of the !bxey Flats burial site, the burial              !
i taking place on cleared flat land at the end cf the fan-shaped mesa.
The " bottom land" at the foot of the mesa, so=e 250 to 300 feet below, also is in grass or crops. The area is generally sparsely inhabited, but there are small far=s in the vicinity.
l The three areas from which environmental samples were taken for the State          !
i report were (1) the restricted area of the site itself (slide 2) within the fenced area under the licensee's control; (2) the periceter area immediately surrounding the burial site, under the State's control (slide 2);
and (3) unrestricted areas surrounding the state ovoed land. The relatins-ehip of these three sampling areas are shown in slide 3.
The geology of the area is characterized by nearly horizontal beds of differing geologic units. Tb,e relationship of the geologic units to
!     copography, each other, and the disposal site is shawn schematically in slide 4. Also shown are the underground flow patterns for water move-ment.
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5025643450 R ELAY TDMT ERANXFOR T XY 04-30 0505A EST PMS 3ILL A NDES, CHAIR FAN NUCLEAR REGULA TORY COMMISSION                                                                                          ,
i WUX WASHINGTON DC 2-035222E119 04-29 0416P EST                                                                                                                        '
SI NC E I A SS UM ED TH E OFFI C E OF G OVIR HOR OF X EN TUC K Y ON D EC EP.3 ER 28 19 74, I HAVE S EC OME INCR EASI NGLY CONCERNED . A30UT THE SAFETY OF THE NUUL EAR VASTE SI TE A T XA XEY FL A TS H ER E I N X EN T UC XY. TH E SA FETY OF THIS SITE HAS ALSO 3 EEN Q UESTIONED IN THREE R EC ENT STORIES IN THE                                                                                .
LOUISVILLE COURI G J OURNAL. THE XENTUCKY S UR EA U FOR HEALTH SG VICES,                                                                             j CH AR GES ' I TH MONI TOR I NG TH E SI TE, MAS B EEN ' ACC US ED OF I NS UFFi ACTION IN REQUIRING CERTAIN REPORTED EFFICIENCIES AT THS2 SIT @jIENT                                                        TO BE C CR R EC T ED.
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c I HAVE BED MADE AUARE OF INDICATION OF THE MIGRATION OFbuRIb FA TERI AL A T THE M0.11 TORI NG STA TI ON. HOWEVER, I HAVE 3EEN ASSUR ED THA T TH E5 E IN Dica u v.is n ren a :.n 4 I HA VE ORDE ED TUR THE EVALUATION.NO DANGER AI THE PRESENT TIME                                                                                .
i IT WOULD B E VERY HELPFUL TO US IF THE STAFF OF THE NUCLEAR                                                                                              !
REGULATORY AGENCY COULD BE MADE AVAILABLE TO ASSESS THE CURRENT                                                                                           I SITUA TION A ND GIVE ME IHE B ENEFIT OF YOUR A DVIC E. THEREFOR E I 0FFICI ALLY RE3 UEST THAT YOU PROVIDE THIS HELP AT YOUR EARLIEST CONVENIENCE YOUR C00PERA TION WILL 3 E GREATLY APPR ECI ATED.
J ULIAN M CARR OLL GOVERNOR COMMONWEALTH OF X ENTUCXY 0621 ES T                                                                                                                                                 {
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_ _ _ _ _ _ _ _ _ _ _ _     . _ _ _ _ _ _         _ . _ _ _ _ _ _ _ _ _                                                                            :]

Xentucky Department for Hum-   Resources SIX MONTH STUD.Y OF RADIATION CONCENTRATIONS AND TRANSPORT MECHANISMS AT THE MAXEY FLATS AREA 0F FLEMING COUNTY, KENTUCKY
 -                                           CONCLUSIONS
 +.
Based on the studies and data described in this report, the following conclusions concerning the Maxey Flats area and the radioactive waste disposal facility have been arrived at:
(1) The radioactive waste disposal site at Maxey Flats, Kentucky is contributing radioactivity to the environment. The activity detected in the environment does not create a p;blic health hazard. However, the level of activity detected demonstrates the need to intensify current monitoring activities to provide additional information to determine to what possible extent
                    , migration of radioactive material is occurring at the site and for assessing the long range sigrifficance of the findings.
(2) The movement of radioactivity from the facility could be through k                    four major routes:
(a) Surface water run-off.
(b) Atmospheric fallout'from the evaporator plume.
(c) Migration through geologic formation fissure systems.
(d) Lateral migration through the ' soil zone.
                                        ~
(3) Existing geologica1 mechanisms are not effective in, maintaining tritium waste within the disposal trenches.     (The rate of tritium migration was not determined by the study.)
(4) Man-made radionuclides measured in certain individual samples collected in the unrestricted environment identified Tritium, Cobalt 60, Strontium 89 and 90, Cesium 134 and i37, and Plutonium 238 and 239.       -
O                                                                           Enclosure 2

18                                                                          .
(5) Plutonium concentrations measured in certain individual samples collected in the unrestricted environment and Test Wells exceed ambient levels.
(6) According to the Department's data, radioactivity concentrations measured at one suaple point in the unrestricted environment exceeded the maximum permissible concentrations.      (This determi-nation was made using the most restrictive definition of maximum permissible concentrations, which is based on sample analysis for which no specific isotope determinations are made.)
R' RECOMMENDATIONS Based on the conclusions of this report, the following recommendations are made which the Department believes will result in 'the proper assessment FS'                                                                                                                                                                                                   ,
of the long-range pu~olic health significance of the radioactivity detected from the radioactive waste disposal site. Additionally, the implementation I
of these recommendations should improve site operations 'and circumstances which may be causing the release of radioactivity from the site.
General Recommendations (1) A further environmental study should ue commenced as soon as i
possible to assess the long-range potential health an'd safety                                               1
                                                                                                                                                                                                            \
significance of the conclusions stated in this report. The                                                   !
                                       .                                                       results of such a study will not only be us,eful in determining the environmental conditions at the Maxey Flats facility but will aid in developing criteria for shallow land radioactive j
waste disposal facilities in general. Such a study should be D
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supported by federal agencies having responsibility for radiation safety and protection of the environment. The data collected from such a study would be useful for comparison with other similar studies which may be con-I ducted at other radioactive waste disposal facilities.
These studies should include:
(a) A geological, hydrological, and climatological profile of the radioactive waste disposal facility.
(b)
Methods to' control potential environmental and public health hazards which may be created by the release of radioactivity from the radioactive waste disposal site.
(2)
Special studies should be implemented to determine the following:
D (a) The appropriateness of a more restrictive criteria                    l than maximum permissible concentrations as related to i
the possible migration of radioactivity from shalle,< 1and radio-active waste disposal facilities.                                    i (b)
Types of containers which.would be suitable for the            -
burial of tritium in shallow land radioactive waste disposal facilities.
Specific Recommendations (1)
The disposal of discrete packages containing large quantities of tritium should be restricted to specialized sealed gicss con-tainers until research and development activities determine 6
that other type containers are suitable.
N

jg3 (2) Standards and terminology designed to control short-tenn transportation hazards should not be routinely accepted as permanent disposal criteria.                                    '
(3)
Receipt and disposal records maintained by the waste disposal 3
facility should be specific as to isotope, amount, and form from information supplied by radioactive waste generators.1   '
State and federal regulatdry agencies should strictly enforce                                  i all applicable transfer record requirements of licensable radio-active materials.
IMPLEMENTATION OF RECOMMENDATIONS The following specific responses as related to the recommendations of.
this report are planned:
(1 }
The Department will, formally apprise the company (licensee) f'C                      operating the radioactive waste disposal facility as to the                               '
environmental conclusions drawn from this report. The licenses will be requested to s0bmit a plan to assure that the waste disposal facility will not establish environmental problems of significance to the public health and safety. .The licensee has 1
a' iready established an environmental task force which is evaluating the environmental conditions at the facility. 'The company has also developed procedures and contingency plans to restrict any                                     '
migration of radioactivity from the site. The request to the licensee, therefore, will be directed toward plans for implementa-tion or expansion of their developed contingency plans as related to the results of this study.
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n                               (2) The Department will coordinate the expansion of the existing environmental study design corrinittee for the purposes of develop-ing a more comprehensive environmental study to assess the long ~
range significance of the results of this study. This committee is currently composed of a represtintative from the U. S.
Environ:vatal Protection Agency, U. S. Geological Survey, Kentucky DeparSent for Human Resources, Kentucky Geological Survey and Muclear Engineering Company.
(3) The Department in cooperation with other appropriate agencies will coordinate the implementation of the environmental study developed by the environmental study design committee.
(4) The Department will intensify its radiological monitoring of the environment surrounding the radictctive waste disposal facility.
q'                               (5) The Department will continue to evaluate the need for possible                  1 amendments of the radioactive material license authorizing the burial activities for the improvement of site operating procedures.
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burial containment, and environmental monitoring by the licensee. l (6) The Department will request that appropriate standard setting groups review and determine the appropriateness of applying a core restrictive criteria than maximum permissible concentra-tions as' they relate to the potential migration of radioactivity
                                        , from shallow land radioactive waste disposal facilities.
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9, f/ 5 Mr. Damon W. Harrison Chairman Kentucky Science and Technology Consnission                         >                                                                                            l.
Office of the Covernor                                               ,
1 Frankfort, Kentucky 40601 Daar Mr. Harrison:
I am pleased to respond to your letter of April 18, 1973 to Mr. Lee V. Gossick concerning perpetual care and maintenapes of tb2                                                            j Ientucky waste burial site at Maxey Flats.                                 ,
j As your letter suggests, there are two pti$cipal considerations involved -                                              '
in establishing a perpetual care program for a vaste burial site. One concerns the technical criteria for maintaining the buried waste under proper control from a health and safety standpoint. The other concerns the creation of the necessary financial resources to cover the costs in-                                                             !
volved in maintaining perpetual care of the burial site.
* i          l With respect to the technical critetria, w, believe +the following general                                                i elements should be included in a perpetual et% program as a minimum:                                                     I
: 1. "3striction of the sita against unor.W,1xed access including s rveillance program;                                                                                                       j
: 2. an environmental monitoring program designed to provide early detection of any migration of radioactivity;
: 3. mainte. nance of the covering on trenches where tho waste is bu* led; and                                      '
: 4. a contingency plan in the evenh corrective action is nece54ary due to the migration of radioactivity.                   ,.
of course, detailed criteria vould need to be developed for each element which are specifically related to the site characteristics and the type of radioactivity buried. It would appear that the Kentucky agencies exerciaing control over the site, in conadtation with the site operator j
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Mr. Damon W. Harrison                                                                        -
l and 9ther consultants as appropriate, are in the'best position to develop the det ailed technical criteria since they are the anost familiar with the                         l specific site characteristics and operational history. We would be                                 ;
pleased to offer our technical assistance in the review and evaluation of                           I any proposed perpetual care program developed.                           .
i With respect to establishing the necessary financial resources for carrying
            .ost the perpetual care plan, we believe this is a metter for the State to work out, basad on the detailed perpetual care criteria established for the site. We have no particular expertise in the area of determining the amount of funds necessary to carry out a perpetual care program.                                           ,
A Task Force of *he Conference of Radiation Control Program Directors pre-pared a report entitled " Bonding and Perpetual Care of Nuclear Licensed Fac'.11 ties." The Task Force consisted of representatives from several States. EPA, and the NRC. The objective of the Task Force report was to                             j
            "..,. assemble into a' single document the guidanca necessary for State officials to develop bonding and perpetual care programs..." Mr. Charles M.
Hardin, Manager, Radiation Control Program, Kentucky Department For Human Easources, has a copy of that report. Under separate cover, we are sending                           l you a report prepared by the South Carolina Agricultural Experimental Station entitled " Economic Analysis of Funding Arrangements for Maintenaues ,                      j Surve111s:2ce, and Contingtucy Costs associated with Burial of Low-level Radicarttre Waste in South Carolina." The South Carolina report describes                           i one method for analyzing md estimating the costs required for the care and
           . maintenance of a waste burial facility.
Tour letter also suggests that Kentucky is committed to perpetual care and                          1 maintenance of the Maxey Flate site under the original agreement with the Nuclear Regulatory Cocaission (WRC). Federal and State regulations require the siting of vaste burisl trounds on land owned by either the Federal or                           i State government. Kentucky has assumed responsibility for perpetual care of the site independent of the authority Kentucky assumed under agreement with the NRC. The agree.nent provides for discontinuance by the Cosmission and assumption by the State of authority for regulating the use of byproduct,                     .
source and small quantities of special nuclear material. Since the site is located on State owned land, the perpetual care program would be a State responsibility regardless of whether the site operation was licensed by the NRC or State, under terms of an agreement with the NRC.
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Mr., Dancu W. Harrison                                                                                                                            {
Flasse let me know of the details, purpose and scope of the May meeting.
Sincerely, i
D*          .....
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Howard J. Larson, Director a-          -
Division.of Materials and                                                                                     4 Fuel Cycle Facility Licensing B
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OFFICE OF TH E GOVERNOR F R A N K FO RT, K E N T U C K Y 40601 JUL8 AN he . C A m m O L 4 aoa..a.
April 18,197 5 Mr. Lee V. Gos sick Acting Executive Director for Operations ,
U. S. Nuclear Regulatory Commission Washington, D. C. 20555

==Dear Mr. Gossick:==

The Commonwealth of Kentucky ' as you already know I am sure - owns a nuclear waste disposal site at Maxey Flats in Fleming County which is operated under lease with Nuclea r Enginee ring Company, Inc.                         ,
Kentucky is committed to perpetual care and mainten-                               ,
ance of this site under the original agreement with the Atomic                             ''
Energy Commissidn. A burial fee based on cubic feet of waste buried was included in the original lease with Nuclear Engineer-ing. The revenue from this fee has been used to create a trust fund to provide for perpetual care and maintenance of the site.                              j However, in the judgment of the Kentucky Science and Technology                               '
Commission, the fee is too small to build an adequate trust fund.
The fee at present is four percent of the charge per cubic foot of waste buried and the lease stipulates that the charge shall never exceed four percent. However, Nuclear Engineering is now disposed to waive this provision and socms willing to negotiate a charge that will be adequate.
l In earlier discussions, there were wide differences between the                               l Science and Technology Commission and the company as to the size of fee required. I doubt that these differences can be resolwl                          !
in a manner that is fair and equitable to both parties without qualified                     l advice from an impartial party. The Nuclear Regulatory Commission,                            )
in my opinion, is the best qualified and logical body for this purpos'e.                     1 i
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                                                                                                - -_______-_-_O

                                                                                                     )
1 Mr. Lee V. Gossick l                        Page 2                                                                    ,
April 18, 1975                 -
1 I
I, the refore, request the assistance of the Nuclear Regulatory Commission in:                                               .
1                                   1. Establishing adequate criteria for the perpetual I
l care and maintenance of the site.
: 2. Determining the costs required for adequate care and maintenance at curren,t prices.
It would be extremely helpful to have an expression of your position in this regard as soon as possible.
We are planning a meeting of the Kentucky Science and Technology Commission sometime between May 12-23 and would like to have ajepresentative of your office at that meeting if at all pos sible. The specific date will be provided within a week or ten days.
* An early response to this request will be extremely helpful,                                                                     t 1
I Sincerely,                                         i p,yg,ryg / //,-      M ** *
                                               /    amon W. Harrison Chairman Kentucky Science and Technology Commission I
                                                                              .-                     l DH/lh                                                                        ;
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O C 05068 23 5025643450 PMS BILL A NDES,R ELAY TDMT FR ANXFOR                                                    04-30 0506A  T KY EST WUK                                               - CHAIRFA N NUCLF>R REGVLA TORY COMMISSION WSHINGTON DC 2-035222El19 04-29 0418P EST                                                                                                                                                g4 SINCE I ASSUMED THE OFFICE OF GOVENOR                                                                                                                     25                  6 I
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NUCL EAR WAS TE SI TE A T FAX EY FL THE                                                                              . A TS      SAFETI  H ER       OF E I N K EN THI S SI TE H AS A LS O 3 EEN Q UES TI ONED I N T LOUISVILLE CH AR GES k'I TH                                          COURI MONI TORING        ER JOURNAL.      TH E SI TE, THE                 MAS 3KENTUCKY            EEN NT , ACC US ACTI ON I N R EQUIRING CERTAI N REPORTED C CR R EC TED.
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: i.          F IFAHAVE      TERI AL A T THE MONI TORI NG S, I TA SEEN       MADE                  AUARE                 OF  HAVE INDICATION TIBON. EEN ASS      HOUEVERURD D              OF THE I HAVE ORDER ED FUR TH E EVALUATION.THA                                                                                                               , B UT i
IT VOULD B E VERY HELPFUL TO US IF THE STAFF O REGULA SIT'.M TI ON                                         TORY AND GIVE  AGENCY         ME THE        COULD  S ENEFIT         BE OF          MADE      YOUR             AVAILABL 9
A DVICE THEREFORE                I               3\
CONVENIENCE JULIAN M CAREOLL GOVERNOR COMMONWEALTH OF KEN YOUR COOPERA TION W                             .
I EST 0621 ES T 2                                                                                                                                                                                          !
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LE E DA G TWN Rec'd Ott. Dir.,
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In providing technical assistance to Kentucky, we prepared written comments on the draft report. We noted that the report did not appear to contain i                                                                                                                                       i sufficient information to support all of the conclusions, particularly whether the site was creating a public health and safety problem. We suggested that I
further comprehensive environmental studies should be conducted to provide a technical basis for determining whether and to what extent migration of radioactiv- )
I material was occurring and for assessing the health and safety aspects of con-ditions at the site. During November and December we also participated in meetings with the State and the licensee concerning the report and the con-clusions which could be drawn from the study.
The final report as prepared and released by the Kentucky Department for Human Resources concludes that the burial ground is contributing radioactivity to the environment; that the activity detected does not create a public                                            l health hazard; and that further studies are necessary to determine to what extent migration is occurring and to assess the long range public health and i
safety significance of the findings. We believe these' conclusions are reasonable.
Following recommendations in the final report, the State expanded an existing Environmental Study Design Committee For The Maxey Flats Radioactive Waste Dispesal Facility and held a meeting of the Committee on February 18,19,                                      I and 20, 1975. The Committee consists of representatives from several State agencies, Nuclear Engineering Co. , USGS, EPA, ERDA, and NRC (Waync Kerr) . The purpt of the Committee was to recommend to the State, the environmental studies needed                                            1 i
to determine the long range significance of the detected radioactivity in the l                                                                                                                                         j
.                                                                                                                                              4 l
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i environment surrounding the burial ground.
The following six items were identified during the February meeting as the type of studies which should be conducted at the site:
Priority I Hydro-geologic Study (Deep Geology)
Priority II Surface Study (Water runoff, meterological data, and soil study in the top one foot)
Priority III Weathered Zone Study (About the top ten feet of soil) a.
Priority IV Definition of Source Term                                         -
Priority V Agricultural Pathways (Livestock, milk, garden crops) l Priority TI Environmental Biological Pathways (Vegetation, stream t
biota and non-domesticated sources of food).
'                                   .The cost for these studies was estimated by the Committee to be in excess of j
one million dollars and the State may ask NRC and other Federal agencies for                  '
financial assistance to carry cut these studies.
i 1
                       )              The TWX from Covernor Carroll asks for our technical assistance in                                            !
                      /
                     /                assessing the situation at the site. There have been several news                                         b articles in Kentucky about possible radiation hazards at' the atte.                                           i We believe the Governor vents an independent assessment of the                                                !
situation
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4                                             +
1 Summary of Current Kentucky Burial Site Situation I
4 Kentucky informed us in October 1974 of the results of a special six-month environmental study at the burial area which showed that vaste radioactivity may be migrating from the site.                                                In November, we met with State officials and received a copy of a draft report documenting the purpose, scope and results of the study. The report contained information which indicated that radio-active vaste materials were migrating from the burial ground and were being detected in sampling wells immediately adjacent to the burial site and in water collected from unrestricted areas near the burial site. The report concluded that the burial site was contributing radioactivity to the environ- r'N
                                                                                                                                                                       %e                             9,)
ment and that the migrated radioactivity -created potential for a public                                                      Y/
A health and safety hazard.
The a"ctivity IcVels reported for unrestricted areas around the site exceeded, in some cases, ambient icvels as well as Part 20 concentrations for releases to unrestricted areas. The measurements were mostly in terms of gross alpha                                         ,
and gross beta activity and it was difficult to ascertain if there was a public health hazard. There was limited data to correlate the gross activity measurements with specific isotopes. Some specific isotopes that were' identified were tritium, cobalt-60, strontium-89 and -90, cesium-134 and -137
                       .                                             and plutonium-238 and -239.

t l
In providing technical assistance to Kentucky, we prepared written comments on the draft report. We noted that the report did not appear to contain sufficient information to support all of the conclusions, particularly whether the site was creating a public health and safety problem. We suggested that rurther comprehensive environmental studies should be conducted to provide a technical baeis for determining whether and to what extent migration of radioactive l
I material was occurring and for assessing the health and safety aspects of con-ditions at the site. During November and December we also participated in                                                               I meetings with the State and the licensee concerning the report and the con-clusions which could be drawn from the study.
The final report as prepared and released by the Kentucky Department for Human Resources concludes that the burial groand is contributing radioactivity                                                            f I i
to the environment; that the activity detected does not create a public health hazard; and that further studies are necessary to determine to what extent migration is occurring and to assess the long range public health and safety significance of the findings. We _ D.th these conclusions 4cc hd l
Following reconnendations in the final report, the State expanded an existing Environmental Study Design Committee For The Maxey Flats Radioactive Waste Disposal Facility and held a meeting of the Committee on February 18,19, and 20,1975.
The Committee consists of representatives from several State agencies, Nuclear Engineering Co. , USGS, EPA, ERDA,Aand                                                            TheNRC(alope purpose of ferr) the Committee was to recommend to the State, the environmental studies needed to determine the long range significance of the detected radioactivity in the                                                                  t i
I

l
,       4   .      . ,
9 environment surrounding the burial ground. The following six items were identified during the February meeting as the type of studies which should be conducted at the site:
Priority I Hydro-geologic Study (Deep Geology)
Priority II Surface Study (Water runoff, meterological data, and soil study in the top one foot)
Priority III Weathered Zone Study (About the top ten feet of soil)
Priority IV Definition of Source Term Priority V Agricultural Pathways (Livestock, milk, garden crops)
Priority VI Environmental Biological Pathways (Vegetation, stream biota and non-domesticated sources of food).
l The cost for these studies was estimated by the Committee to be in excess of one million dollars and the State may ask NRC and other Federal agenc'ies for                           -
financial assistance to car'ry out these studies.
I The TWX from Governor Carroll asks for our technical assistance in assessing the situation at the site.'~There have been several news 1
articles in Kentucky, about possible radiation hazards at the site.                                       i We believe the Governor wants an independent assessment of the situatio                                                                                                  '
l D
Y

4 Draft 5/1/75
                                ,                                                                                                             PHLohaus/hkr       l
                            , ,                                                                                                                                  l j
j              We are here this morning to inform the commission of the situation at the Kentucky comrcial low level waste burial area operated by the Nuclear Engineering Company, Inc.
                         ,               Kentucky informed us in October 1974 of the results of a special six-month environmental study at the burial area which showed that waste radioactivity may be migrating from the site. In November, we met with State officials and
                                                                                                                                                                 ]
received a copy of a draft report documenting the purpose, scope and results of the study. The report contained information which indicated that radio-active vaste materials were migrating from the burial ground and were being
                      .                  detected in sampling welle immediately adjacent to the burial site
* and in 1
water ecliected from unrestricted areas near the burial site. The repore li
,                                        concluded that the burial site was contributing radioactivity to the environ-ment and that the migrated radioactivity. created .the p6'te'                        n tial for a public i
A j                    health and safety hazard.
l                    The activity levels reported for unrestricted areas around the site exceeded, i                    in some cases, ambient levels as well as Part 20 concentrations for releases i
j                    to unrestricted areas. The measurements were mostly w terms of gross alpha and gross beta activity and it was difficult to ascertain if there was a I
public health hazard. There was liinited data to correlate the gross activity f                     measurements with specific isotopes. Some specific isotopes that were l                     identified were tritium, cobalt-60', strontium-89 and -90, cesium-134 and -137 l
and plutonium-238 and -239.
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I
                                      '                                                                                             Cs v       Q/                        ,/- .,
N ATTACINENT 2 x                           /

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               .     .s                                                                  !'
k In providing technical assistance to Kentucky, we prepared written comments on the draft report.
l       .
We noted that the report did not appear to contain 8
{                        sufficient information to support all of the conclusions, particularly whether i
the site wac creating a public health and safety problem. We suggested that further comprehensive environmental studies should be conducted to provide a technical basis for determining whether and to what extent migration of radioactive I
material was occurring and for assessing the health and safety aspects of con-ditions at the site. During November and December we also participated in l                                  meetings with the State and the licensee concerning the report and the cone clusions which could be drawn from the study.
The final report as prepared and released by the Kentucky Department for
..                                 Human Resources concludes that the burial ground is contributing radioactivity to the environment; that the activity detectel! does not create a public health hazard; and that further studies are necessary to determine to what extent migration is occurring and to assess the long range public health and safety significance of the findings. We believe these'' conclusions are reasonable.
Following recommendations in'the final repo'rt, the State expanded an existing Environmental Study Design Comittee For The Maxey Flats Radioactive i                        Waste Disposal Facility and held a meeting of the Comittee on February 18,19, and 20, 1975. The Committee consists of representatives from several State agencies,'Nucicar Engineering Co., USGS, EPA, ERDA, and NRC (Wayne Kerr).                                              The purpt i
of the Connittee was to recommend to the State, the env1ronmental studies needed to determine the long range significance of the detect'                 e d radioactivity in the l

                                                                                         ..:_     . . .                       =
:p         I
                                                                            -3 I
I I
l environment surrounding the burial ground. The following six items were
            !                         identified during the February meeting as the type of studies which should i
be conducted at the site Priority I Hydro-geologic Study (Deep Geology)
Priority II Surface Study (Water runoff, meterological data, and soil study in the top one foot)                           .
Priority III Weathered Zone Study (About the top ten feet of soil)                   !
Priority IV Definition of Source Term
[                              Priority V e                                             Agricultural Pathways (Livestock, milk, garden crops)                   t l
Priority VI Environmental Biological Pathways (Vegetation, stream i                                               biota and non-domesticated sources of food).
f The cost for these studies was estimated by the Committee to be in excess of s              -
one million dollars and the State may ask NRC and other Federal agenh(es for                l financial assistance to carry out these studies.                                             l 1            The TWI from Governor Carroll asks for our technical assistance in
                      /             assessing the situation at the site. There have been several news                         U
                   /
articles in Kentucky about possible radiation hazards at the site.
I I
We believe the Governor wants an independent assessment of the situation                                                                                   !
        !                                                                                                                       i 6
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* l UNITED STATES NUCLEAR REGULATORY COMMISSION
                                                .       W ASH AN G ton, o. C. 20555
           .1 1.
A.PR 21 %75                             i I
Note to Don Nussbaumer 4
Mr. C. Eason, Washington representative for NECO called me'on
          /)                     April 21, 1975. He stated that Bobby Wilson, former employee of the Kentucky radiological health program had testified at a hearing held by the Chairman, Kentucky Environmental Quality l         3,                     Commission. I understand his testimony was similar to infor-l                               mation he had formerly sent to the Governor in writing.                                          -
1
          ;,                    Wilson alleged that the Kentucky Radiological Health Program ij                     (Chuck Hardin's group) had not properly enforced regulatory h                      requirements at the NECO Maxey Flats commercial waste burial
          '.                    facility. He recommended an independent investigation of the State's radiation control program and the conditions at the burial site.
h Eason stated that the State inspected the site over the last Weekend and found no problems. He stated that an article appeared in the Louisville paper on (4/17), an editorial in the same paper on 4/20 and a feature story would be run on 4/27.
l<                      He stated that NECO was not invited to the hearing and that                           s     a 3
e-
                               -Hardin was invited but did not attend.[ /A ~,q.'sj Q (.c st4+J'w+_,_Id].
g                       Eason stated that NECO may suggest that NRC conduct an independent
             '                  investigation of the,whole matter. 'It is my impression that NECO is afraid that EPA may be asked to do the independent investigation and they want to head that off.
Hardin informed me that they prepared a position paper for the Governor reiterating they do not feel the site should be shut down
       '                       for health and safety reasons and based on one person's general allegations. He stated that Wilson inferred the forthcoming GAO l                               report on vaste disposal may adversely reflect on several of the l
commercial sites.
I        -
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l ATTACHMENT 3                               i l
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                           , ,                                          s
                                                                                                                                                                                                           }!
2-In providing technical assistance to Kentucky, we prepared written coments i                                                            on the draft report. We noted that the report did not appear to contain l
8 I                                                              sufficient information to support all of the conclusions, particularly whether the site was creating a public health and safety problem. We suggested that                                             \
further comprehensive environmental studies should be conducted to provido c.                                            i l
j technical basis for determining whethcr and to what extent migration of radioactive I
material was occurring and for assessing the health and safety aspects of con-l l
                                                                                  . ditions at the site. During November and December we also participated in                                                I meetings with the State and the licensee concerning the report and the con-
                                                                                                                                                                                                             \
clusions which could be drawn from the study.                                                                            I L
The final report as prepared and released by the Kentucky Department for                                               -
(                                                                                 Human Resources concludes that the burin 1 ground is contributing radioactivity to the environment; that the activity detected! does not create a public health hazard; and that further studies are necessary to determine to what extent migration is occurring and to assess the long range public health and i
1                                                                                safety significance of the findings. We believe these' conclusions are reesonable.
Following recommendations in'the final repo'rt, the State expanded an
{
existing Environmental Study Design Comittee For The Maxey Flats Radioact1 e
* i; Waste Disposal Facility and held a meeting of the Comittee on February 18,19, and 20, 1975. The Committee consists of representatives from several State agencies,' Nuclear Engineering Co. , USGS, EPA, ERDA, and NRC (Wayne Kerr).                     The purpt of the Comittee was to recommend to the State, the environmental studies needed to determine the long range significance of the detect'ed radioactivity in the 1
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ye e-* . gup p +eme ** * * * * * *      *
                                                                                                                                                                                                  ''N 4

                            ^                                                                        .
Licensing History:
I Kentucky became the first Agreement State when they signed an agreement
: i.                                                                                        I                              !
in March 1962. With the primary intention of encouraging nuclear industry                              J
                  ,l in Kentucky, the Kentucky Atomic Energy Authority (now the Kentucky Science and Technology Cor: mission) pursued the concept of a radioactive I
a disposal site in Kentucky. In October 1962, the State issued a license o                   to the Nuclear Engineering Company to operate a disposal site at Maxey j                  Flats, Kentucky. The land was purchased by Nuclear Engineering Company and the title to the land was transferred to the State. The land was then leased back to Nuclear Engineering Company for operation of the site.
l-
                 )
n For perpetual care 'of the site, the lease agreement contains a clause l
i
                 ?
stating that Nuclear Engineering Company will pay the State a negotiated r             .
price per cubic Foot of waste not to exceed'4 percent of the average n
            ,j          [~         burial charge per cubic foot charged by the licensee. The State has 1
approximately $160,000 in the perpetual care fund.
            't t
t                   Since 1970, increasing quantities of radion:tive material have been i
i disposed of at the Maxey Flats site. During the past ten years, the L
licensee has buried about 3 million cubic feet of radioactive wastes, t
containing about 1-1/2 million curies of byprodnet material, 3G3 kilograms
[                     of special nuclear material, and 50 tons of source ne' erial. In addition l                     to commercially generated wastes from reactors, isotope users, and fuel
           .i                                                                                                                              l i                     cycle facilities, significant quantites of plutonium 238 and tritium i'
             ,                     from Commission contractor operations are buried here. .
I r
j         'i-ATIACEMENT 5 e
5            .              _
_ _ _ _ _ _ . . _                                                                     i

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Trench L.'ater Problem:                               I 1
In 1970 the State became concerned with on-site water management probicas.
                                                               ,)                                                                    This concern increased during 1971 as the licensee continued to have prob-       -
4 a                                                                   less with accumulation of water in completed trenches. The State instituted j                                                                   enforcement action but the licensee was unable to control the water prob-
                                                                 ?
s less on site. In September 1972, the State issued an order against Nuclear Engineering Company for non-compliance and willful violation of conditions l                                                              \
l                                                                l                                                                   of the license relating to water in completed trenches, burial of unauthor-l                                        .
                                                                                                                                  ~ ired material, and disposal of liquid vastes. Following issuance of the
                                                                                                                                                                                                                        )
                                                                                                                                                                                                                   *    (
order, the licensee was permitted to operate the vaste burial site for the disposal of solid vastes only. The licensee was required to file an
                                                                                                            -                                                                          I 1rrevocable letter of credit for $500,000. This letter of credit was in
, s.
l                                                                                                                               \                                                    l i
                                                                                                                                   ,xlieu of a performance bond to assure compliance with the. terms of the l
order. The letter of credit will come up for renewal in January 10'!.
Act. ion by the licensee to control water problems has included the pumping of water from trenches into above-ground storage tanks and the installa-l tion of an evaporator to concentrate the liquid vastes for disposal as solids. The evaporator is IIeing operated under an interim authorization by the State to test its effectiveness. The evaporator is not eff6ctive in removing tritium from the water. At the present time, the licensee has approximately 650,000 gallons of trench water stored in the surface tanks           l and has processed about 1 million gallons of water through the evaporator.          <
                                                                                                                                  . Trench' pumping operations a're continuing but about 25% of the trenches still have water in them.                                           -
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         !             Site

== Description:==

I l             Haxey Flats is located in Fleming County in the Northeastern portion of the state of Kentucky. As seen on the topographic                      p (slide 1) Maxey I
Flats is a flat-top hill with steep sides. Throughout most of the area I
the flat " top land" is in grass or crops and the steep hf11 aides are forested. This is true of the Maxey Flats burial site, the burial i
taking place on cicated flat land at the end of the fan-shaped mesa.
jl The " bottom land" at the foot of the mesa, some 250 to 300 feet below,                                 )
l              also is in grass or crops. The area it generally
* sparsely inhabited, i
but there are small farms in the vicinity.
The three areas from which environmental samples were taken for.the State report were (1) the restricted area of the site itself (slide 2) within i
a-
{       the fenced area under the licensee's control; (2) the perimeter area
{             , immediately surrounding the burial site, under the State's control (sli's 2);
and (3) unrestricted areas surrounding the state owned land. The relation-ship of these three sampling areas are shown in slide 3.
The geology' of the area is charneterized by nearly horizontal beds of differing geologie units. The relationship of the geologie units to topography, each other, and the disposal site is shown schematically in i
slide 4. Also shown are the underground flow patterns for water move-ment.
l                                                 ..                                                              .
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l PROJECT REPORT SIX HONTH STUDY OF RADIATION CONCENTRATIONS AND TRANSPORT MECHANISMS AT THE MAXEY FLATS AREA 0F FLEMING COUNTY, KENTUCKY I
l l
I T
                 -)
Kentucky Department for Human Resources Bureau for Health Services 1
Office of Consumer Health Protection                         I Radiation and Product Safety Branch                  ,.
l i
December, 1974                       -          j O                                                                                                  ATTACHMENT 6            l E "i g ,, ' L [ :, s g         ;'   ,
                                                                                                                                           )
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The Nuclear Engineering Company, Inc. (NECO) of Louisville, Kentucky operates a radioactive waste disposal site at the Maxey Flats area in Fleming County, Kentucky.              The operation of this site is under authorization              '
of a radioactive .aaterial license issued by the Radiation and Product Safety Branch of the Department for Human Resources.               Regulation of the operation is also under the Kentucky Department for Natural Resources and Environmental ,
I
           -                 Protection, Division of Air, Division of Water, and Division of Solid Waste.
The Department for Human Resources is the, primary regulatory agency under the terms of a Kentucky-U. S. Atomic Energy
* Commission (AEC) regulatory agreement. This radioactive disposal facility was started in 1963.                  The Radiation and Product Safety Branch, Environmental Radiation Laboratory                               i j
has maintained a comprehensive pre and post-operational radiation monitoring                          l program at the facility since March,1963.                Also, NEC0 has conducted a radiation monitoring program.
During the first ten years of operation, no detectable quantities of I
radioactivity, above natural background,on a repeated basis, had been                                ]
observed.2 In 1971 a proposal for future studies at the waste disposal facility was recommended by members of the Radiological Health staff.                The basis for this recommendation wes due to:
(1) increasing quantities of radioactive materials, particularly large quantities of special nuclear material, being disposed of at the site; (2) staff concern about the containment of buried waste relating to water management aspects.
i e                                                                                                                             i h

x 2
f In 1972 certain environmental monitoring data began to indicate a
    )
possible initiation of radioactivity contribution to the immediate Maxey Flats site area. On November 15, 1973, a six month special environmental radiation monitoring study of the radioactive waste disposal facility was initiated. The study was designed, within the constraints of available resources, to qualitatively and quantitatively "dentify the source and scope of increased levels of environmental radiation previously discovered in the area.
The routine Maxey Flats environmental radiation program had consisted of monthly sample collection trips. Approximately ten water samples were collected from selected natural streams, wells, and springs.      The sampling stations were selected to include drainage or seepage from all sides of the elevated site.
These sample points ranged up to approximately two miles in    '
distance from the disposal site.
}                                                    Four sample stations were considered controls, and six were considered non-controls.
During the special six month study, the monitoring network was extended to cover an area with a greater than six mile radius from the site.      Efforts
                                                                                                             \
were made to establish control points to match each non-control sampling point in elevation, approximate distance from the site, and geological and hydro-                   !
logical considerations (shallow wells, springs, etc.). Three hundred and thirty-two water samples were collected outside the res'tricted area during 4
this special study, not including E-Series Test Wells.      Thirty-six water               ,
samples from E-Series Test Wells and eleven surface water samples inside the               i !
restricted area were collected. Forty-five soil samples were also collected from many points within the restricted area and in the immediate unrestricted                   !
area.
All samples were analyzed by the Branch Laboratory for tritium, gross
[
l I

l alpha, and gross beta.        Equipment and personnel restrictions prevented the
    ,)                performance of.more specific analyses.         Six additional water samples were selected for analysis by a federal water qualit'y laboratory for standard water chemistry, pesticides, and heavy metals. Also, a contract with an environmental radiation laboratory of another state was initiated for the analysis of thirty water samples for specific ga rna emitters a,nd Strontium-89 and 90. A comercial radiochemistry laboratory analyzed thirty six soil i
samples, including six control samples taken in Franklin County, for Plutonium-     )
l 238 and 239. Twenty-four soil samples, including five control samples, taken from Franklin County and Fleming County, were sent to a federal environmental l                     radiation laboratory for Plutonium-238 and 239 analysis.                            1 SAMPLE ANALYSIS METHODOLOGY l                             Gross alpha and beta samples were prepared for analysis according to l                     Standard Methods.3 Prepared samples were counted for 50 minutes each in a Beckman Wide Beta II Alpha-Beta Counter. The minimum detectable activity (MDA)was:          Gross Alpha, 0.3 x 10-9 microcuries per milliliter; Gross Beta, 0.7 x 10'' microcuries per milliliter.                         ~
l Water and soil samples to be analyzed for tritiuto were distilled to reduce color and chemical interferences.        Duplicate sets of counting samples 1
were prepared by adding eight milliliters of distillate to 16 milliliters of         '
liquid scintillation mix (toluene, PPO, bis-MSB and detergent Triton X-100).
Sample preparation, except for distilling, was done under red lights to reduce photo-luminescence problems. Samples were thoroughly mixed and stored in           i darkness for four hours to further reduce chemo- and photo-luminescence contributed counts. Counting samples, standards, and background samples O                                                                                          -
1                                                                                                         .
E___________.__________________________________                                                           !

                                                                                                                         .           .                             4-                                        ,
                                                                                                 , i s
were counted in a Beckman LS 250 counter for 100 minutes each. The minimum
                                                                                                                                                                                                     ~
                                                        )                                                                  dete'ctable activity (MDA) for tritium for this technique was 0.18 x 10 microcuries per milliliter.
PROJECT RESULTS Project areas were divided into five categories derived from specific sampling locations by origin. These included the following:
(1) E-Series Test Wells (2) Restricted Area Surface Water                                              .
                                ,, ,                                                                                       ,    (3) Unrestricted Area Water (Hon-Control)
(4) Unrestricted Area Water (Control)      *
(5) Soils (1) E-Series Test Wells Thirteen E-Series Test Wells were designed by and drilled under the supervision of Emcon Associates, a geological survey firm retained by NECO. The purposes of the wells were to provide geological and hydrological information and improve subsurface monitoring capabilities.
The wells were identified by numbers 1-E through 14-E.      A planned well, 7-E, was a test drill experiment but had collapsed and was non-functional.
Ocpths of these wells ranged from 51.2 feet to 311.8 ' feet.
Test Wells were sampled by conventional manual methods. Thirty-one water samples were collected from 11 Test Wells. Only wells 4-E and 5-E were not sampled. A sampler was lodged in Test Well 4-E near its bottom, and Test Well 5-E was too difficult to sample by hand duetoitsdepth(311.8 feet). Some wells were dry or had insufficient water to produce a sample.
(a) E-Series Tritium Analysis                                                  -
                              .i V
                                                                                                                                                                                         ..                      g   p .6 =

f All Test Well water samples were analyzed for tritium
      )                                                      concentrations. Tritium concentrations measured in Test Well water samples were compared with ambient tritium concentrations.     " Ambient" was defined as the mean tritium concentration measured in natural water sources in Fleming County, Unrestricted Area Water (Control) sample stations 1, 7,18,19, 20, 21, 22, 26, 27, 29, and 30 throughout the period of the study.       Tritium concentrations equal to or greater than twice the mean apient concentration
                                                                       -6 (9.3 x 10      microcuries per milliliter) were considered significant for purposes of the study. Such tritium concentrations ranged from 9.3 x 10-6 microcuries per milli-liter in Test Well 8-E to 2820.5 x 10' microcuries per milliliter in Test Well 11-E (approximately 300 times
     }                                                                                                                              l
                                                                                                                                    \
the mean ambient tritium concentration).         Test Well 11-E        i is near trench numt$er 31 where 645,400 curies of tritium were buried in a single shipment in 1971.                              I I
(b) E-Series Gross Alpha Analysis i
l All Test Well gross alpha analysis showed readily             .. j 1
detectable alpha concentrations in the suspended portion of the sample. Gross alpha concentrations equal to or greater than three times the mean gross alpha concentrations           l (1105.6x10-9 microcuries per milliliter) measured in a Test Well control group, consisting of wells 1-E, 2-E,                  l S-E, 9-E and 14-E were considered significant for purposes 1

I
           ,, l                                            6-of this study.          Such gross alpha concentrations were measured I
in four Test Wells, ranging from 1283.6 x 10-9 microcuries                    .
per milliliter in Test Well 6-E (approximately 1.2 tirnes
                                                                                            ~
the control group mean concentration) to 4305.6 x 10 ' micro-curies per milliliter in Test Well 6-E (approximately 3.9 i
times the control group mean concentration).                                            )
(c) ,E-Series Gross Beta Analysis Gross beta concentrations equal to or greater than three times the mean gross beta. concentrations (1420.2 x 'O microcurles per milliliter)were considered significant for purposes of this study.              Such gross beta concentrations were measured in three Test Wells, ranging from 1478.5 x 10-9 j                       microcuries per milliliter (approximately equal to the control group mean concentration) to 4851.0 x 10'9 microcuries                          1 i
per milliliter (approximately 3.4 times the control group mean concentration).
l (d) E-Series Specific Analysis l
Eight samples, collected from Test Wells 3-E,11-E,12-E and 13-E, were analyzed for specific gamma emitting isotopes and Strontium-89 and 90 by another state environmental radiation                        '
laboratory.       Specific analyses indicated the presence of man-made radionuclides, Cobalt-60, Cesium-137 and Strontium-89 i
and 90 in Test Well ll-E. Strontium-89 and 90 were also measured in Test Wells 12-E and 13-E. Test Wells 11-E, 12-E and 13-E were located on the west side of the disposal site
: s. )                                               .
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                                                                                                                                                                      )
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l and, of the E-Series Test Wells, are closest to the disposal               !
l
           )                                                                                             a rea.                                                                     I Five samples representing the suspended solids portion of water samples from Test Wells 3-E, 6-E and 11-E were                 ,
analyzed for Plutonium-238 and 239 by a. federal environmental             l radiation laboratory. Test Well 3-E had a concentration i
of 8.6 dpm per gram, Plutonium-238 and 0.12 dpm per gram, Plutonium-239. Test Well 6-E had a mean concentration of 6.75 dpm per gram, Plutonium-238 and 0.21 dpm per gram, Plutonium-239. The overall mean* concentrations of Plutonium measured in the E-Series Test Wells were 15.42 dpm per gram, Plutonium-238 (approximately 360 times the mean concentration Plutonium found in the control soil samples) and 0.32 dpm
     ,                                                                                                   per gram, Plutonium-239 (approximately 7 times the mean                    '
concentration of Plutonium found in the contrcl soil samples).
The mean Plutonium concentration measured in 11 control soil samples collected from the Fleming and Franklin County areas were 0.014 dpm per gram, Plutonium-238 and 0.014 dpm per gram Plutonium-239. Plutonium concentrations equal to or greater than 3 times the control group soil sample mean concentrations (0.042 dpm per gram) were consid'ered ignificant for purposes of this study. Control group soil sample Plutonium concen-                !
l trations agreed with national levels.4 According to federal environmental laboratory staff, Plutonium-238 and 239 should rarely be found deeper than several inches below the surface of undisturbed soils since the only widespread environmental          -
i
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l
                                                                                                                                                                                    )

j,'                                                                                                                                          .
source of Plutonium contamination was from atmospheric
       )                                                '
fallout.
Natural gama logs were conducted in all functional                   i E-Series Test Wells by the U. S. Geological Survey within the study period, On August 26, 1974, a specially equipped logging vehicle from the U. S. Geological Survey office, Denver, Colorado conducted a gamma log of Test Well 12-E. This equipment had gama ray spectroscopy capabilities. These logs of Test Well 12-E confirmed the presence of narrow bands of man-mdde
{
radioisotopes, Cesium-134, Cesium-137, and Cobalt-60. These isotopes were found to be in several predominant discrete l
zones below the soil surface.
(2) Restricted Area Surface Water
      .)                                                  '
Restricted area surface water sampling locations cbnsisted of drainage channels located within the facility control fence.
Samples were collected during periods of rainfall when water flow was present. Samples were also collected from a pond within the restricted area.
(a) Tritium Analysis Tritium concentrations equal to cr greater than twice the
                                                                 ~                                    i mean ambient concentration (9.3 x 10     microcuries per milli-            l liter) were considered significant for purposes of the study.
Such tritium levels ranged from 9.7 x 10-6 microcuries per l
milliliter to 40.3 x 10-6 microcuries per milliliter. A total of 11 samples were analyzed for tritium.
_    a

s (b) GrossAlphiAnalysis                                                                -
Gross alpha concentrations equal to or greater than 3 times the mean gross alpha concentration measured in Unrestricted Area Water (Control) samples (9'.'1 x 10-9      ,
mi-ocuries per milliliter) were considered significant for purposes of the study. Standard gross alpna analyses were performed on 11 surface water samples collected within the facility control fence. Such gross alpha concentrations i
ranged froo 14.0 x 10-9 microcuries per milliliter to 37.3
* x 10-9 microcuries per millilite'r.
(c) Gross Beta Analysis Gross beta concentrations equal to or greater than 2 1
times the mean gross beta concentration measured in Unrestricted Area Water (Control) samples (30.3 x 10-9 microcuries per
         )
milliliter) were considered significant for purposes of the study. Standard gross beta analyses were performed on 11 surface water samples collected within the facility control fence. Concentrations ranged from 34.8 x 10-9 microcuries per milliliter to 654.4 x 10       microcuries per milliliter.
(d) Specific Analysis                                                               ''
Four steface water samples were sent to a commercial laboratory for gamma, Strontium-89 and 90, and tritium analysis. Two of these water samples taken from the pond overflow drain emptying on the west side of the site and paralleling the north side of Trench No. 33L were of greatest interest. Sample No.1649 was obtained, from the eastern-most
      \                                                                                                   .
L__________ _ _ _ _ . . . . _ _ _ . . _ _ . _ - - - _ _ - - - - - _ - - - - - -

    ..              s           ,,
portion of this drain and indicated no detected gamma 1          %'
i                                   activity but did measure 57 x 10~9 micrccuries per milliliter I
                                       ) of Strontium-90. Sample 1650 was obtaired immediately after collection of Sample 1649 but in the western portion l                                    i of the drain within the restricted area. Sample No. 1650
                                                               ~
measured:    102 x 10 ' microcuries pr milliliter, Cobalt-60;
                                                  ~9 36 x 10     microcuries per milliliter, Cesium-137; 20 x 10~9
                                                                                                 ~
microcuries per milliliter, Ma,nganese-54; 60.0 x 10 ' micro-curies per milliliter, Strontium-90; and 18 x 10~9 micro-curies per milliliter, Strontium-89.       It should be noted that another environmental laboratory performed analyses on the same samples and gave different results, lower than
  ,                                      those reported above. However,*from a nore conservative                                                               l l
                                       . viewpoint, the above-referenced measure: rents were used in
(. )
this report.                                                                                                 .
(3) Unrestri,cted Area Water (Non-Controlled)
One hundred forty-three water samples in the unrestricted area-                                                                  !
i were collected. Non-controlled sampling stations refer to those                                                                      I locations which could receive radioactivity from the site due to any migration which might occur.
(a) Tritium Analysis                                 -
l Tiltium conceerations equal to o: greater than twice the mean ambient concentration (9.3 x 10-6 microcuries per ,,,
l milliliter) were considered significant for purposes of the study. Such tritium concentrations in these water i
l v                                                                                                                                                             .
i
                                                                                                                                                                   )

              ~
s                                          .
             .,s samples ranged from 9.6 x 10-6 microcuries per milliliter
     -)
                                                           '                                                                    ~
to 1,710.0 x 10-6 microcuries per milliliter.
(b) Gross Alpha Analysis Gross alpha concentrations equal to or greater than 3 times tne mean gross alpha concentration measured in
                                                                                                                      ~
Unrestricted Area Water (Control) samples (9.1 x 10 microcuries per milliliter) were considered significant for purposes of the study. Such gross alpha concentrations ranged from 11.2 x 10''9 microcuries per milliliter to 81.0 x 10-9 microcuries per milliliter.
l                                                          (c) Gross Beta Analysis Gross beta concentrations equal to or greater than 2 times the mean gross beta concentration measured in
(,                                                          Unrestricted Area Water (Control) samples (30.3 x 10~9
!                                                               microcuries per milliliter) were considered significant for purposes of the study. Such gross beta concentrations ranged from 30.4 x 10-9 microcaries per milliliter to 2569.7 x 10~9 microcuries per milliliter.
(d) Specific Analysis                              *                    -
1 Twenty-one of the one hundred forty-three samples were analyzed for specific gama emitters and Strontium.
Strontium-89 and 90 were detected at station #2 which is approximately two miles from the site center. Of these 21 samples, 7 were from Station #13. These' 7 samples for Station #13 averaged 80.4 x 10-9 microcuries per milliliter, i

s            .
0
                  '                                                                        Strontium-90. No detectable gama activity was found                                                    -
(.)                         for these 7 samples. A separate sample from the main easterly site drain leading to Station #13 showed 1,100 x 10'9 microcuries per milliliter, Strontium-90, with no detectable gamma emitters.
Another sample was obtained at the north fork of the western drain leading to Station #8. For this sample specific analyses were performed and had conceritrations of 1.69 x 10-9 microcuries per milliliter, Strontium-89 l                                 and 11.8 x 10-9 microcuries per milliliter, Strontium-90.
(4) Unres,tricted Area Water (Control)
Sampling stations designated as Unrestricted Area Water (Control) are those stations at a location in which it would be highly unlikely that any migration from the site could contribute radio-()
activity. These control points consisted of 11 surface water and shallow well sampling stations selected to , measure radioactivity in similar conditions to those stations adjacent to the NECO operational site.                  -
(a) Tritium Analysis One hundred eighty-seven Unrestricted Area Water (Control) samples were analyzed for tritium concen-trations. Tritium concentrations equal to or greater than twice the mean ambient concentration (9.3 x 10-6 microcuries per millilit&) were considered significant for purposes of the study. Such tritium concentrations                                                   I 1

           ..                                o                                                                    .
I
                                      ,.,*'         .                            13--
ranged from 10.3 x 10-6 microcuries per mi'.1111ter
                         )                              to 208.0 x 10-6 microcuries per milliliter. Mean
                                           ,            tritium concentrations in these control sample st'ations conformed with background tritium levels measured at other laboratories and as published in the literature.'
(b) Gross Alpha Analysis One hundred eighty-seven samples were analyzed for gross alpha concentrations. Gross alpha concentrations         .
considered significant for pur'poses of this study are as defined in Section (2) (b). Such gross alpha con-centrations ranged from 10.6 x 10-9 microcuries per milliliter to 32.9 x 10-9 microcuries per milliliter.
(c) Gross Beta Analysis                         .
S One hundred eighty-seven samples were analyzed for G                                                                                                                .
gcoss beta concentrations. Gross beta concentrations             -
considered significant for purposes of this study are as defined in Section (2) (c). Such gross beta con-centrations ranged from 32.5 x 10-9 microcuries per milliliter to 102.8 x 10-9 microcuries per milliliter.      '
(d) Specific Analysis Samples from 3 control stations were sent to a state environmental laboratory for selected gamma, strontium, and tritium analysis. No gamma emitting nuclides                     I or strontium were observed in these samples. Tritium resultswerereportedin4(a)above.
eD j
_ _ _ _ _ _ _ _ - _ _ = _ - _ - _ _ -

r             ,.
                .e   '
(5) Soils Analysis I
Fifty-five soil samples were collected,      Samples were primarily collected with an Oakfield hand coring tool which takes a 2.5 centimeter by 25 centimeter core. This tool is capable of taking a sample up to approximately ninety centimeters in depth. Other samples were taken using a "Little Beaver" gasoline-powered auger tool. Collection depths ranged from near surface to approxi-mately ninety centimeters in depth using the Oakfield sampler and                      .
up to approximately one hundred and fifty centimeters using the                                l powered auger.
Non-control samples were taken frnm pit mounds, drainage ditches, work areas, fresh pit excavations, and forest loam.      Background samples were collected in a similar manner from soils primarily in-the Frankfort, Kentucky area. Soil sample analyses included tritium, t,    I gross alpha, gross beta, and plutonium.
(a) Tritium Analysis Forty soil samples were analyzed for tritium concen-trations in soil water. This technique was useful as a screening method for contamination. Soil water tritium                          . .
concentrations were not related to MPC's or other standards.
Tritium soil concentrations equal to or gr' eater than two                .
times the mean tritium concentration measured in background control soil samples (30.4 x 10-6 microcuries per milliliter, soil water) were considered significant for purposes of this study. Such tritium concentrations ranged from 35.2 s
e l

I                                                                       -_          .
             ,'e
* x 10-6 microcuries per milliliter to 124,271,6 x 10-6 microcuries per milliliter, soil water, (b-) Gross Alpha Analysis Gross alpha soil concentrations equal to or greater than three times the mean gross alpha concentration measured in background control samples (68.7 x 10-9 microcuries per gram) were considered significant for purposes of this study. Two such gross alpha soil                 .
concentrations were measured, ra,nging from 75.3 x 10~9 microcuries per gram to 89.8 x 10-9 microcuries per gram 1
dry sample weight.
j (c) Gross Beta Analysis Gross beta soil concentrations equal to or greater than three times the mean gross beta concentration
    ']
measured in background control samples (152.4 x 10-9 microcuries per gram) were considered significant for purposes of this study. Three such gross beta soil concentrations were measured, ranging from 191.7 x 10~9 microcuries per gram to 359.6 x 10-9 microcuries per gram dry sample weight.
(d) Specific Analysis l
A total of 55 soil samples were sent to either a comercial or a federal radiochemistry laboratory for plutonium analysis. Eleven of the fifty-five samples were control background samples taken from the Franklin s
V                                                                                  -
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N                                                                                         - -

o
                                ,.s                                                                                                                   .
j and Fleming County areas. Forty-four non-control 1
samples were taken to de'termine the extent of possible plutonium contamination in soils at Maxey Flats, ,The Plutonium-238 and 239 concentrations considered signi-ficant for purposes of t,his study are as defined in Section(1)(d), Such plutonium concentrations ranged
* from 0,05 disintegrations per minute per gram to 41,96 disintegrations per minute per gram for Plutonium-238 and from 0.05 disintegrations per minute per' gram to 5.80 disintegrations per minute per gram for Plutonium-239. These analyses indicate an approximately 200 times higher concentration of PU-238 and 25 times higher concentration of Pu-239 in the soils at the immediate Maxey Flats site area over i
that of the control samples collected in the Franklin
(-
County and Fleming County area. Other environmental                  .
I plutonium background concentration studies report a mean                 {
of 0.004 dpm per gram Pu-238 in this approximate geographi-cal region.4 l                                                                                                 (6) Other Analyses (pesticides, Heavy fietals)                                        ,
                                                                                                                                                                                  .     \
Six special water samples collected from E-Series Test Wells, streams, and ponds were analyzed by a federal laboratory for pesti-              I 1                                                                                                                                                                                       \
l                                                                                                      cides and heavy metals. Standard water chemistry analysis was                 !
I also performed on each of these samples. Analytical results showed no significant concentrations of compounds of interest.
l Q                                                                                                                        -
l 1

        *.,        O                                                                                                   -
y,                                             ~17-CONCLUSIONS 1)
Based on the studies and data described in this report, the following conclusions concerning the Maxey Flats area and the radioactive waste disposal facility have been arrived at:
(1) The radioactive waste disposal site at Maxey Flats, Kentucky is contributing radioactivity to the environment.                          The activity detected in the environment does not create a public health hazard. However, the level of activity detected demonstrates the need to intensify current monitgring activities to provide additional information to determine to what possible extent                                                  <
migration of radioactive material is occurring at the site and for assessing the long range significance of the findings.
(2) The movement of radioactivity from the facility could be through four major routes:
            )                                                                                                                                 L (a) Surface water run-off.
(b) Atmospheric fallout fron the evapo: ator plume.
(c) Migration through geologic formatin fissure systems.
(d) Lateral migration through the soil zone.                                                                  <
(3) Existing geological mechanisms are not e ffective in maintaining
* tritium waste within the disposal trenches.                       (The rate of tritium                        I migration was not determined by the study.)                                               -
(4) Man-made radionuclides measured in certain individual samples collected in the unrestricted environment identified Tritium, Cobalt 60, Strontium 89 and 90, Cesium 134 and 137, and Plutonium 238 and 239.
O i

o
              ,[ ,                                                     ,
(5) Plutonium concentrations measured in certain individual s.
samples collected in the unrestricted environment and Test Wells exceed ambient levels.
(6) According to the Department's data, radioactivity concentrations measured at one sample point in the unrestricted environment exceeded the maximum permissible concentrations.     (Thisdetermi-nation was made using the most restrictive definition of maximum permissible concentrations, which is based on sample i                                analysis for which no specific isotope determinations are made.)
RECOMMENDATIONS Based on the conclusions of this report, the following recommendations are made which the Department believes will result in the proper assessment           j
       ;            of the long-range public health significance of the radioactivity detected l
l from the radioactive waste disposal site. Additionally, the implementat. ion of these recommendations should improve site operations and circumstances l
i which may be causing the release of radioactivity from the site.                      l General Recommendations (1) A further environmental study should be commenced as soon as               j possible to assess the long-range potential health and safety significance of the conclusions stated in this report. The results of such a study will not only be useful in determining the environmental conditions at the Maxey Flats facility but will aid in developi; a criteria for shallow land radioactive waste disposal facilities in general. Such a study should be
    .     )

l --
I#
                              ,                                                                                   1 4                                                                                         .
3
                                                                 \l supported by federal agencies having responsibility for radiation safety and protection of the environment. The                          !
data collected from such a study would be useful for 1
comparison with other similar studies which may be con-                          l ducted at other radioactive waste disposal facilities.                            i These studies should include:
(a) A geological, hydrological, and climatological profile             -
of the radioactive waste disposa,1 facility.
(b) Hethods to control potential environmental and public                         l health hazards which may be created by the release of radioactivity from the radioactive waste disposal site.                     ,
I (2) Special studies should be implemented to determine the l
following:                                                                         !
(a) The appropriateness of a more restrictive criteria                             l than maximum permissible concentrations as related to the possible migration of radioactivity from shallow land radio-             j activ!. :*.te di ;.<<> sal facilities.
(b) Types of containers which would be suitable for the            -
l burial of tritium in shallow land radioactive waste disposal facilities.
Specific Recornendations (1) The disposal of discrete packages containing large quantities of tritium should be restricted to specialized sealed glass con-tainers until research and development activities detennine 6
that other type containers are suitable.
l l
1

                                                          .                                              i l
             *= o
                                                                       ,w
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(2) Standards and terminology designed to control short-term I
transportation hazards should not be routinely accepted as permanent disposal criteria.
(3) Receipt and disposal records maintained by the waste disposal facility should be specific as to isotope, amount, and form               I from information supplied by radioactive waste generators.
State and federal regulatory agencies should strictly enforce all applicable transfer record requirements of licensable radio-  ..
l active materials.
* IMPLEMENTATION OF RECOMMENDATIONS i
ine following specific responses as related to the recommendations of            '
l                 this report are planned:
\                                                  e                                                     !
l (1) The Department will formally apprise the company (licensee)
        ;                     operating the radioactive waste disposal facility as to the
    ~
environmental conclusions drawn from this report. The licensee l
will be requested to submit a plan to assure that the waste                I disposal facility will not establish environmental problems of significance to the public health and safety. The licensee has already established an environmental task force which is evaluating l
the environmental conditions at th.e facility. The company'has also developed procedures and contingency plans to restrict any migration of radioactivity from the site,     The request to the licensee, therefore, will be directed toward plans for implementa-tion or expansion of their developed contingency plans as related to the results of this study.
I l
* l        '
b

     .     . . . o l
l
            .e * #                                             -21 (2) The Department will coordinate the expansion of the existing i!
environmental study design comittee for the purposes of develop-ing a more comprehensive environmental study to assess the long range significance of the results of this study. 'This committee t
is currently comp 6 sed of a representative from the U. S.                    {
Environmental Protection Agency, U. S. Geological Survey, Kentucky           j Department for Human Resources, Kentucky Geological Survey and Nuclear Engineering Company.
                        '(3)          Department in cooperation with other appropriate agencies will l
coordinate the implementation of the environmental study developed by the environmental study design committee.
(4) The Department will intensify its radiological monitoring of the environment surrounding 'the radioactive waste disposal facility.
(5) The Department will continue to evaluate the need for possible amendments of the radioactive material license authorizing the i
burial activities for the improvement of site operating procedures, burial containment, and environmental monitoring by the licensee.            i (6) The Department will request that appropriate standard setting                   j groups review and detemine the appropriateness of applying          ,
a more restrictive criteria than maximum permissible concentra-tions as they relate to the potential migration of radioactivity from shallow land radioactive waste disposal facilities.
1 l
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                                                                                                             ]

   ' ~. "; 3 .
                \                   .
      -)
REFERENCES (1)   U. S. ENVIRONMENTAL PROTECTION AGENCY. A History and Preliminary Inventory Report on the Kentucky Radioactive Waste Disposal Site, Clark, David T., Radiation Data & Reports '/ol. 14, No. 10, October 1973.
(2) KENTUCKY RADIOLOGICAL HEALTH ENVIRONMENTAL RADIATION LABORATORY, unpublished data.
1 (3) AMERICAN PUBLIC HEALTH ASSOCIATION. Standard Methods for the I                          Examination of Water and Waste Water,13th Edition, Part 300,
: p. 583, 1971.
(4)   U. S. ENVIRONMENTAL PROTECTION AGENCY.Radiation      Data & Reports, Vol.15, Number 3, p.145, March 1974.           .
(5)   U. S. ENVIRONMENTAL PROTECTION AGENCY. Radiation ~ Data &' Reports.
                  .,       Vol.14 Number 10, p. 604, October 1973.
(6)   U. S. ATOMIC ENERGY COMMISSION. Plan for the Management of
!.    's 1   \,.)                   AEC-Generated Radioactive Wastes, WASH-1202 (73), p. 40.
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