NRC Generic Letter 1980-09

NRC Generic Letter 1980-009: Low Level Radioactive Waste Disposal

ML031350287
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Nine Mile Point, Palisades, Indian Point, Kewaunee, Saint Lucie, Point Beach, Oyster Creek, Cooper, Pilgrim, Arkansas Nuclear, Three Mile Island, Prairie Island, Brunswick, Surry, North Anna, Turkey Point, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Duane Arnold, Farley, Robinson, San Onofre, Cook, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Fort Calhoun, FitzPatrick, Fort Saint Vrain, Trojan
Issue date:	01/29/1980
From:	Eisenhut D G Office of Nuclear Reactor Regulation
To:
References
GL-80-009, NUDOCS 8002140005
Download: ML031350287 (25)

GL- go --os UNITED STATES NUCLEAR REGULATORY

COMMISSION

1WASHINGTON.

D. C. 20555 January29v

19f Jaocanur 9 90 ALL POWER REACTOR LICENSEES Subject: Low Level Radioactive Waste Disposal Recent developments at commerical low level waste burial sites have substantially impacted waste disposal operations.

The license to operate the facility at Barnwell has been recently revised by the State of South Carolina to further limit the volume of waste buried and to upgrade the Integrity of the waste form received at the site. Similar requirements to upgrade the integrity of waste forms packaged for the Richland, Washington burial site also have been required by the State of Washington.

NRC licensees are required by Commission regulations to assure that wastes prepared for shipment are in a form that the Agreement State licensee is permitted to receive under applicable Agreement State regulations as well as meeting all pertinent NRC and DOT transportation regulations.

The past closure of low-level radioactive waste burial sites in Washington and Nevada and the strict enforcement of license conditions at Barnwell have resulted from the States' dissatisfaction with the events that have occurred involving solid radwastes shipped from waste generators including power reactors.Consequently, improvements will have to be made to comply with the State licenses.NRC OIE Bulletin No. 79-19, Packaging of Low Level Radioactive Waste for Transport and Burial, has already been sent to you regarding this matter.You should review your system and operating procedures to assure the strict adherence to the revised burial site license conditions and their interpreta- tion by the State authorities.

The enclosed license and accompanying letter from the State of Carolina to the site licensee, Chem-Nuclear Systems, Inc., describes the restrictions to be adhered to for the wastes received at that site. The requirements by the State of Washington on waste form upgrade is similar. The following areas are of particular concern to the States and should be acted upon accordingly.

1) Free Liquids in Wastes Leaving Reactor Site The objective for solid radioactive wastes leaving the reactor site for burial is that they should contain no detectable free liquids as dtfined by Appendix 2 of ANSI/ANS 55.1-1979.

In no case however, should the amount of free liquid upon arrival at the burial site exceed the burial site license conditions.

Free liquid determination should consider the effects of transportation, e.g., vibration, freezing and thawing. This requirement is applicable to both dewatered resins and spent filter media as well as solidified wastes departing the reactor site>

-2 -The following conditions (items 2 -4) must be met for the waste to be acceptable by burial sites in the States of Washington and South Carolina.2) Free Liquids in Wastes on Arrival at the Burial Site Until December 31, 1980, provide assurance that all wastes do not contain more than 1% liquid by volume upon arrival at the burial site. Any liquids present in waste packages shall be non-corrosive with respect to the container.

Non-corrosive means conformance with 10 CFR 71.31, 49 CFR 173 and other DOT regulations such that there should be no significant chemical, galvanic or other reaction with the packaging components.

Tests should be conducted either on simulated or actual waste which demonstrate that wastes to be shipped conform to the above criteria.

In addition, operating procedures shall be developed that implement the methods to be used to assure that all wastes arriving at the burial site compley with burial site free.liquid licensing conditions.

3) Future Free Liquids Reqgirements Effective January 1, 1981, no wastes Dackages shall contain more than trace quantities of non-corrosive free liquids upon arrival at the burial sites.Trace quantities is defined as no more than 0.5% of, or one gallon in, the container volume, whichever is less. For those waste currently solidified by UF systems, you should prepare to meet this requirement as soon as feasible before January 1, 1981. Present methods of waste solidification by UF systems do not provide assurance that the waste packages on arrival at the burial site contain no more than trace quantities of non-corrosive free liquids.4) Requirements on Spent Resins and Filter Media Effective July 1981, spent resins and filter media with radioactivity levels above 1 pCi/cc of isotopes must be stabilized by solidification.

However, in lieu of solidification, other methods such as packaging dewatered resins in a high integrity container (e.g., reinforced concrete)may be proposed to the NRC and the States licensing the burial sites.Although the South Carolina letter accompanying the license amendment does not discriminate between long and short half-live isotopes, it is our understanding through discussions with the State officials, that only isotopes with half-lives greater than 5 years need to be included in the radioactivity level (i.e., greater or less than 1 pCi/cc) consideration.

Consequently, solidification or high integrity containers would then only be required if radioactivity levels exceeded 1pCi/cc for radioisotopes with half-lives greater than 5 years.In addition, the revised South Carolina License for Chem-Nuclear Systems, reduces the volume of waste allowed to be buried at Barnwell.

This, and possible future burial site problems may result in a shortage of low level waste disposal capacity.

Consequently, licensees should take positive steps to minimize the volume of waste produced.

To this end, each licensee should implement a program to minimize the generation of radioactive solid wastes (edg., waste segregation)

and implement methods to reduce the volumes of waste which cannot be eliminated (e.g., use of trash compactors).

-3 -The revised requirements on waste forms may necessitate the use of mobile or temporary solidification systems. Regulations require that any changes to your solidification systems differing from your FSAR submitted for the issuance of your Operating License be reviewed by you in accordance with 10 CFR Part 50.59.According to this regulation, an internal safety evaluation has to be prepared prior to making the facility modification.

With respect to future changes in solidification systems, copies of the safety evaluations along with any additional supporting documentation concerning the safety adequacy of any mobile or temporary solidification system shall be submitted to the NRC. In addition, the appropriate revision to the Process Control Program (PCP) required under the model Radiological Effluent Technical Specifications shall be submitted for review if it has not been previously submitted or if it is being modified.Your PCP should be based on data or tests which demonstrate not only that complete solidification of liquid waste takes place, but that no free standing liquid exists in any waste container leaving your site. The PCP should also be based on data or tests that demonstrate that your waste will have no free standing liquid in excess of the burial ground license requirements at time of burial and that any trace quantities of liquid are non-corrosive.

The submittals (the safety evaluation and the revised PCP) should be made prior to the operation of your modified systems.Sincerely, Darrell G. Eisenhut, Acting Di ector Division of Operating Reactors Office of Nuclear Reactor Regulation Enclosure:

Letter and License from State of South Carolina cc w/enclosure:

Short Service List

...1 v t chment for Lett~e to Licensees I.-Soih Cardn a Depaerd He ha nd;.Conkol 111--WOARD.VAPRn M. lm. erg.J.Lhn Mawi Jr., M.D.. Vkr. y;ifirs 1. OskyNeyNw Secrty LsomrdW. DoIas. M.D.Georg M Grah.n. D.D.S.dchael W. hUr Barara P. Nuessle CMhUSSIONER

Malom U. Dantzr. M.O., M.P.H.Cl0u8tla Stre22 October 30, 1979 Mr. Bruce W. Johnson, President Chem-Nuclear Systems, Inc.P. 0. Box 1866 Eellevue, Washington

98009 Dear Mr. Johnson: Your South Carolina Radioactive Material License No. 097 has been amended in its entirety by Amendment No. 26. The enclosed license supersedes the original license and all previous amendments.

Amendment of your license was necessary to further define the requirement that there shall be no detectable free standing liquids contained in radioactive waste received and buried at the Barnwell Facility.

Other changes reflect clarification of eidsting license conditions,and additional requirements as previously discussed with the Barnwell Site management.

With respect to license conditions

25. and 32., the terminology"no detectable free standing liquids" will be defined as less than 1% liquid by volume until December 31, 1980. Effective January 1, 1981, waste packages shall contain only trace quantities (not more than 0.5% or 1 gallon per container;

whichever is less) of free standing liquids. Any liquids present in waste packages which are allowable until Decenber 31, 1980, shall be non-corrosive with respect to the container.

Effective January 1, 1981, the allowable trace quantities of liquid shall also be non-corrosive.

It is the goal of the Department to enhance the stability of the waste form consigred for burial. To that end, resins with a total specific activity of 1 yci/cc or greater, disposed of after June 30, 1981i must be stabilized by solidification.

However, in lieu of solid-ification, or other methods such as packaging dewatered resins with only trace quantities of non-corrosive liquids in high integrity containers ame being considered at this time.1878 Century of Servce 1978 Br. Buce W. Jcohnsn -2- October 30, 1979 It Is anticipated that your ccanpan will Imdiately Infarm your custamrs of the changes in the amended license and the fartbcodng

'reqiments.

Should you have any questions, please do not hesitate to contact me.Vem truly yours, Bureau of Radiological Health HGS:bo Eolosure c¢: Mr. Herbert R. Oakley Vice-President of Nuclear Sites Mr. Louis L Reynolds Director, Regulatory Affairs I~t. Lee B. Hebbard Banwell Site Manager 1rk. arvid G. Ebenhak Manager Health & Safety

6V License No. 097 Amndment No. 26 anmrids License No. 097 in its entirety.SOUIH CARLINA DEPARThW OP HEAL7H AND ENVIR AL CONWL BUREAU CF RADIOO1ICAL

HEALM COLUMIA, SOCUH CAROLINA RADIOAC`IVE

MATIAL LICENSE Pursuant to the Atomic Energy and Radiation Control Act, Sections 1-400.U1 through 1-400.16 of the 1962 Code of Laws of South Carolina and Supplement thereto; and the South Carolina Department of Health and Environmental Control Rules and Regulations Pertaining to Radiation Control, Part III and in reliance on statements and representations heretofore made by the licensee, a license is hereby issued authorizing the licensee to receive, acquire, possess, and transfer radioactive material listed below; and to use' such radioactive material for the purpose(s)

and at the place(s) designated below. This licensee is subject to aUl applicable rules and regulations of the South Carolina Department of Health and Environmental Control now or hereafter in effect and to any conditions specified below.*1. Licensee:

Chem-Nuclear Systems, Inc.2. Address: P. 0. Box 726 Barnwell, South Carolina 29812 3. License No. 097 (Amendment No. 26 amends Radioactive Material License No. 097 in its entirety.)

4. Expiration Date: December 31,, 1981 0

-2-Conditions

-General 5. Radioactive material, except special nuclear material, may be received, transferred, stored, and disposed of by burial at a site located approximately five miles northwest of Barnwell, South Carolina, at a site located in the Seven Pines School DWatrict, Red Oak Tbwnship, Barnrell Countys South Carolina, within the boundary of the land area described in Lease Agreement dated April 6, 1976. unless otherwise authorized In this license, only radioactive material consigned for burial shall be received at the site described above.6. The licensee shall comply with the provisions of Title A, State of South Carolina Rles and Regulations for Radiation Control, Part I -General Provisions, Part III -Standards for Protection ga.inst Radiation, and Part VI -Notices, Instructions, and Reports to Workers; Inspections.

7. Operations shall be conducted in accordance with Chem-Nuclear Systems, Inc., Radiation Protection and Procedures Manual dated April 4, 1977, and subsequent revisions and additions approved by the Department.

8. Operations shall be conducted under the supervision of H. R.Cakley? Robert Posik, John Ott, L. B. Hebbard, Jr., David 0.Ebenhack (RPO), Leonard Toner, or other individuals designated by the licensee's Radiation Protection Officer upon completion of the licensee's training program.9. The transportation of radioactive material within the state shall be in accordance with Title A -State of South Carolina Rules and Regulations for Radiation Control, F{A 2.22, "Transportation of Radioactive Materials." 10. Radioactive materials authorized by this license are to be received at the site in shipping containers which have been approved by the U. S. Department of Transportation, U. S. Nuclear Regulatory Comtmission, and subject to final approval by the Department.

11. The licensee is not authorized to open any packages at its facility, except for the following: (a) For purposes of repairing or repackaging containers damaged in transit.(b) For purposes of inspecting to insure conpliance with the effective Barnwell Site Disposal Criteria.(a) For purposes of returning outer shipping containers.(d) For purposes of retrieving shipment documentation arnd confirming package contents.

Conditicn

-General 12. A monthly site receipt and burial activities report shall be submitted no later than the 10th day of the following month to the Chief, Bureau Of Radiological Healths South Carolina Departmnt of Health and Environerntal Controls 2600 Bull Street, Columbtia, South Carolina 29201.13. Should any samples taken from trench monitoring wells, cluster wells, or air samples reveal increases in the concentrations of radioactive material which were determined prior to commence-ment of the burial operations, the licensee shall perform further surveys to determine whether or not the increase is due to the land burial operations.

The licensee shall notify the Chief, Bureau of Radiological Health, South Carolina Department of Health and &7vironmental Control, Within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of any such increases.

14. the licensee shall submit results of all scheduled envirorumntal sampling to the Department quarterly.

15. The licensee shall mnintain all records pertinent to the receipt and burial of radioactive material at the location specified in Condition

5. of this license until authorization is given by the Department for transfer or disposal of said records.16. Licensee is authorized to possess a 100 millicurie Cesium 137 sealed source (Eberline Model No.64-76A), for the purpose of calibrating portable survey instruments, as outlined in Chem-Nuclear Systems, Inc., Radiation Protection Procedures No. 7: Calibration of Portable Survey Instruments, submitted March 13, 1978.17. A. Each sealed source containing radioactive material, other than Hydrogen 3, with a half-life greater than thirty days and in any form other than gas shall be tested for leakage and/or contamination at intervals not to exceed six months.In the absence of a certificate from a transferor indicating that a test has been nmde within six months prior to the transfer, the sealed source shall not be put into use until tested.B. The test shall be capable of detecting the presence of 0.005 microcuries of radioactive material on the test sample. the test sample shall be taken from the sealed source or from the surfaces of the device in which the sealed source is permanently mounted or stored on which one might expect contamination to accumulate.

Records of leak test results shall be kept in units of microcuries and maIntalned for inspection by the Department.

-4.Clditiocns

-General C. If the test reMveals the presende of 0.005 microcuries or nMre Of remvable contmniaticn, the licensee shall Immediately witbd'w the seale" sorce from use and shall cause it to be decontaminated an repaired or to be dispoed of in accoance with Department regulatis.

A report shal be fed within 5 days of the teat with the Ciief, BureaU of adiaOogiCal Health, S. C. Department of Health and &nv==ntal Control, 2600 Bull StreO3 Columbia, 3o$th Caolina 29201, descibing the equipmnt inolved, the teat results, and the correqtive action taken.18. Tets3 for leak and/Cr contamination shall be perorvd by the licemse or by other persons speciacally authorized by the U. S.Nuclear tgglatory COmnislon or an Ageement State to perfm such service.19. *The licensee may receive am process waste shipmnta only during nd wark1S hours as specified in the effective Barnwell Site Disposal Criteria.Conditions- Waste 20. The licensee shall not recelive possess or have in his possession at the location specified in ti .at an one tize unburied radioactive material in exrcess of: (a) 50,000 curies of radioactive material excluding source and special nuclear materials;(b) 60,o00 pounds of soure material.21. The licensee shall insure that all waste received at the site described in Condition No. 5 i packaged and prepared in accordance with the conditions of this license ad the effective Barnwell Site tisposal Criteria.

AnW chnes made to the Site Criteria shall have prior approval by the Department.

22. te"s speciaicalY

authorized, all radioactive waste shan be received and buried In appropriate cntainers.

23. A seven-day written notification shall be submitted to the Departnent by the licensee of radioactive material shipments to be received In excess of 2500 curtes per shipmnnt with the excepticn of tritium shipmlents.

24. ble=s otherwise a orzed, the licensee hall not receive waste containing ay transwi eleints. HoweVer, waste containing less than 10 nanoures total tranaizn nuclides per gpam of waste is acceptable provided tansuranic nuclides are evenly distributed within a hosgeneous waste form. This license condition does not authorize receipt or burial of cagonents or equimnt contaminated with transranlc rmclides.

-5-Cmditiorn

-Waste 25. Unless otherwise specified in this license, the receive arn liquid radioactive waste regrdless or physical frm.n Solidified radioactive waste detectable free standing liquids.licensee shall not -of the chemical shall have no 26. The licensee shall not receive waste in any month in excess of the volume limits specified in the schedule below. The licensee shall insure thit waste generated in South Carolina which is acceptable for burial under all other terms and conditions of this license and the effective Barruell Site DLsposal Criteria is received, and that this waste is within the volume limit specified for that month.Volume Limitation Schedule bnth and Year Volume Limit in Cubic Feet November, 1979 December, 1979 January, 1980 February, 1980 March, 1980 April, 1980 May, 1980 June, 1980 July, 1980 August, 1980 September, 1980 October, 1980 November, 1980 December, 1980 January, 1981 February, 1981 March, 1981 April, 1981 May, 1981 June, 1981 July, 1981 Augt, 1981 Septenber, 1981 October, 1981 November, 1981 December, 1981 January, 1982 and each month thereafter or until this condition is otherwise amended.189,000..189,000 178,000 178;000 178,000 167,000 167,000 167s000 156,000 156,000 156,000 144,500 144,500 144,500 133,500 133,500 133,500 122,50O 122,500 122,500 111,000 111,000 111,000 100,000 100,000 lOQ000 100,000 27. The licensee shall not receive toluene, xylene, dioxane, scintillation liquids, or other orgnic liquids with simila chemical properties;

or containers ohich have at any tixz contained ary of the liquids mentioned above. However, after complete incineration, the ash and/or residue from these wastes are acceptable.

Canditions

-Waste 28. Ihe licensee shall not receive or bury radioactive waste contaLning more than one (1) percent absorbed oil by volum.29. Waste containing both toxic chemicals and radioactive materials shall require an independent evaluaticn of both hazards. If the chemical hazard exceeds the radiological hazard, the waste containing both radioactive material and chemically toxic waste shall not be buried at the site as described In Condition No. 5 except as specifically apprvd by the Department.

Records of hazard evaluation of such wastes performed by the licensee shall be kept for inspection by the Department.

30. The licensee shall not store any packag containing radioactive material or source material for a period greater than six months fra the date of receipt of the package prior to burial.31. The licensee nmay receive liquids solidified with one of the following solidification media provided the requirements of other conditions as specified in this license are mat: (a) Dow media (b) Cement (c) Urea Fomaldehyde (d) Asphalt (e) Delaware Custom Mdia Cf) Solidification media and processes reviewed and approved by the U.S.N.R.C., Office of Nuclear Reactor Pesulaticns, subject to final approval by the S. C. Department of Health and Envirwn mental Control, Bureau of Radiological Health.32. Ion exchange resins and filter media may be received in a dewatered form for transportation and subsequent burial and shall contain no detectable free standing liquids.33. he e.licensee shall maintain records of isotopic analysis (quantitative and qualitative)

for each package containing ion exchange resins received at the site.34. Ihe licensee shall not receive evaporator bottcms, concentrates, or other wastes containing free standing liquids unless they meet the requirements as specified In Condition

31. of this license, prior to receipt at the site.

-7-Caditions

-Waste 35. Effective Novenber 1, 1979, the licensee shall insure that each Radioactive Shipment Record fom used to describe a low-level radioactive waste shipfznt received at the Barbwell Site has the following certification properly executed by a representative of the shipper/generator of the waste: "Certification is hereby made to the South Carolina Department of Health and Environmental Control that this shipment of low-level radioactive waste has been inspected in accordance with the require-ments of South Carolina Radioactive Material License No. 097, as amended, U. S. Nuclear Regulatory Comuission License No. 46-13536-01, as amended, and the effective Banve"l Site Disposal Criteria within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to shipment;

and further certification is made that the inspection revealed no items of non.-capliance with all applicable laws, rules and regelations.

Date: By: Title and Organization:__

TelephoneNb. ( ) -36. The licensee shall insure that any package used as the final burial container shall be of such material and construction that there will be no significant chemical, galvanic, or other reaction among the packagng components, or between the packaging components and the package contents.37. The licensee may bury Krypton 85 and Xenon 133 gaseous sources provided they meet the following criteria: (a) Burial containers Amst be approved by the Departimnt of Tnaxsportation.(b) Internal pressure of containers may not exceed 1.5 atmospheres.(c) Tbtal activity of containers may not exceed 100 curies each.(d) Containers must be buried in an upright position with a mrir man spacing of ten (10) feet.Conditions

-Site 38. A registered surveyor cast verify and document the location of each trench: (a) prior to the beoifing Of trench construction; (b) at the cop letion of trench construction, prior to the initiation of the burial operations;

and (c) at the completion of the grading and seeding operation.

39. Construction of radioactive waste burial trenches, slit trenches,"Toner Tubes", trench monitoring wells and site cluster wells shall be constructed as specified in chem-Nuclear Systems, Inc., Trench Construction Detail Drawings No. 500.101, dated December 12, 1978. Any changes to these specifications must have approval from the Department before construction begins.

4-8 CTiditions

-Site 40. Mcnitoring wells in clusters will be placed outside the trenches but In the trench area. Specific locations shall be determined through consultation.

Me initial well of a cluster will be core drilled to the water table and a representative sample of the core shall be submitted to the Departmunt, The depth and number of additional wells in the cluster are to be determdned by the sand-clay caTposition observed in the initial core. All wells shall be grouted, sealed, and capped.41. The licensee shall not Initiate burial operations in newly excavated trenches until the Department has inspected and approved the trenches.An initial inspection will be made by the Depaeztnt upCn ccvpletion of excavation of the trench, sumps, french drain inside the trench, drainage ditches adjacent to the trench and installation of msciftorfg well standpipes.

An intermdiate inspection wil be made by the Department after the french drain and sumps have been filled with rock. A final inspection will be made by the Department upon completion of construction requirements per Trench Construction Detail r'awdngs No. 500.101 dated December 12, 1978.42. Each well and 'Toner Tube" must be sufficiently capped or covered to prevent the introduction of any extraneous material.43. Open trenches and partially filled trenches shall be protected to prevent runoff water frau entering trenches.

Radioactive waste shall not be placed into trench areas Where water has accumulated.

BurIal of radioactive waste into trenches with unusual amounts of water shall immediately cease until corrective action has been taken and origin of water determined.

44. The licensee shall maintain a minimum of two feet of caopacted clay between the last layer of waste and the surface of the ground.BacflJ.ing shall commence immediately as waste reaches the top elevation of the trench. Uncovered wastes shall not extend more than 100 feet beyond the backfilled portion of the trench. Upon completion of burial operations in a burial trench, the licensee shall add an additional three feet minitmi of earth on top of the two foot cover. Carpleted trenches shall at no time be used for stockyiling earth not withstanding provisions for a final grading plan.45. The cover over the completed burial trenches at the site specified in Condition

5. of this license shall be ntained to minimnm erosion.46. The disposal area and cover of the trenches shall be arranged and graded in such a manner that all surface runoff water shall be carpletely reed frm the vicinity of the trenches.47. Tempozary trench bculary ma&ers and trench identification mFmer shall be erected upon completion of backfill operations until pernmuwnt granite markers are installed.

0

A* -S --9- -Conditions

-Site 48. All wells constricted at the site specified in Condition

5. of this license shall be protected from damage.4 9.Interim or final grades shall be established and seeding of trench covers shall comence at no mm than one year following final trench burial operations.

50. A series of granite markers, one at the end of each completed trench and on each corner, shall be erected upon completion of the seeding of trench covers. the following infobration shall be inscribed on the end monument, and this information shall be reported to the Chief, Bureau of Fadiological Health, South Carolina Department of Health and Environmental Control, 2600 Bull Street, Coludbia, South Carolina 29201.a. Thtal activity of radioactive material in curies excluding source and special nuclear materials, total amount of source material in pounds, and total amount of special nuclear material in grans in the trench.b. Date of completion of the burial operations;

and c. Volume of waste in the trench.51. The licensee may not exhume previously buried waste.52. As material buried may not be transferred by abandonment or other-wise, unless specifically authorized by the Department, the expir-ation date on this license applies only to the above ground activities and to authority to bury radioactive material wastes at the site specified in Condition No. 5. The license continues in effect and the responsibility and authority for possession of buried radioactive material wastes continues until the Department finds that the plan established for preparation of the Earnwell site for transfer to another person has been satisfactorily implemented in a manner to reasonably assure protection of the public health and safety and the Department takes action to terminate your responsibility and authority under this license. All requirements for environmental monitoring, site inspection, and maintenance, and site security continue whether wastes are being buried or not.53. Site closure and stabilization of the licensee's facility shall be accomplished in accordance with the U. S. Nuclear RLegulatory Comnission's Low-Level Waste Branch Position entitled, "Low-Level Waste Burial Ground Site Closure and Stabilization," Revision 1 dated May 17, 1979. A copy of the performance dbjectives is attached.

-10-Conditions

-Site 54. Prior to May 319 1980, a preliminary plan for preparation of the site for transfer to another person who would only passively hold the site shall be submitted for review. The plan shall be consistent with Condition

53. of this license and shall include demonstration that funds are being set aside or other measures being taken are adequate to finance the site closure plan. The plan shall also include preliminary estimates of costs, environmental impacts, data needs, personnel needs, material and equipment needs, planned documentation and quality assurance, and detailed plan for trench locations and elevations, expected capacities, planned surface contours, and buffer zones.55. Prior to May 31, 1980, a reassessment of current operating practices shall be submitted.

The reassessment shall consider the objectives of the site plan specified in the preceding paragraph and any changes in operation at the site which would enhance implementation of the plan.56. The licensee shall submit an updated plan and operational assessment every five years for review.57. One year prior to the anticipated transfer of the site and buried radioactive materials to another person (including an agency of the U.S. Government)

the licensee shall submit a final version of the site preparation plan including a schedule for irplen~ntation of all remraining plan elements prior to transfer, =nd a description of the mechanics of orderly transfer in coordination with the transferee.

58. Except as specifically provided otherwise by this license, the licensee shall possess and use radioactive material described in Condition

20. of this license in accordance with statements, representations, procedures, and site criteria, heretofore made by the licensee in application for and subsequent to the issuance of S. C. Radioactive Material License No. 097, and amsndln~t thereto.For The South Carolina Department of Health and Evironrmental Control Date of Issuance October 30. 1979 BY: 3G. -ealy, Chlefy B of Radiological Health

-Enclosure

2 REPORT OF MEETING ON RADIOACTIVE

LOW-LEVEL

WASTE WITH SOUTH CAROLINA OFFICIALS, OCTOBER 17-19, 1979 NRC representatives from NRR, NMSS, SD, SP, IE, DOE and EG&G-Idaho (DOE lead con-tractor for low level waste) met with officials from the State of South Carolina (see Attachment No. 1) and visited the low-level waste burial site at Barnwell, South Carolina.

The meeting was held as the result of an earlier discussion between Ken Perkins, SD, and Lamar Priester, Director, South Carolina Division of Energy Resources, at which a commitment was made to hold an infornmation exchange meeting amoung the concerned State and federal agencies.

Another purpose for meeting was to discuss specifically the revision being made by the South Carolina Department of Health and Environmental Control (DHEC) to the license that is issued to Chem-Nuclear Systems, Inc. to operate the Barnwell facility.

A copy of the itinerary for the trip is enclosed as Attachment

2.On the afternoon of October 17, R. L. Bangart (DSE/NRR), L. H. Barrett (DORINRR), G. Bidinger (IE), K. Schneider (SP), and R. Dale Smith (WM/NMSS)

met with Heyward Shealy (DHEC) and members of his staff to discuss the Order issued to Commonwealth Edison prohibiting low-level waste transport into South Carolna, and to discuss the contents of a draft letter to the president of Chem-Nuclear Systems, Inc. which ex-plains the implementation policy of South Carolina regarding free standing liquid and resin solidification.

At this meeting G. Bidinger invited DHEC inspectors to accompany IE inspectors on inspections of waste management programs of NRC licensees which DHEC had identified as problem shippers (such as Commonwealth Edison). NRC representatives suggested that some modifications to the DHEC draft letter (Attach-ment 3) to B. Johnson of Chem Nuclear regarding free standing liquid and resin soli-dification might be appropriate.

H. Shealy agreed to discuss our recomended changes.After discussions amoung NRC representativeson the evening of.Qtfofbe'r-17, suggested changes (as shown in Attachment

4) were given to H. Shealy on October 18. After dis-cussions held on the afternoon of October 19, the changes shown in Attachment

5 were agreed to by DHEC and NRC as being appropriate.

During this meeting, both NRR and IE representatives agreed that low-level waste from reactor sites should contain no (zero) free standing liquids at the time of shipment.

However, because of factors which occur during transportation (such as freeze-thaw cycling and vibrational effects), it is recognized by both DHEC and NRC that small quantities of liquid may be present at the time of burial.October 18 began with all NRC and DOE representatives shown on Attachment

1 meeting with David Reid, Executive Assistant to Governor Riley, Lamar Priester, Director, South Carolina Division of Energy Resources, Larry LeFebvre, Deputy Director of Policy Analysis and Planning, Division of Energy Resources, and Heyward Shealy, Chief,

-2 -Bureau of Radiological Health, DHEC. For over an hour the South Carolina officials, lead by Mr. Reid, explained the policies of Governor Riley with respect to the burial ground operations at Barnwell and low-level waste management in general. It was stated the volume of waste authorized for burial will be reduced over the next two years to 1/2 of that volume now authorized.

Mr. Reid made it clear that enforce--ment actions including the issuance of Orders to prohibit shipment of waste into South Carolina, will be taken against those who ship or transport waste that is not in compliance with applicable state or federal regulations.

Statutory autho-rity to issue civil penalties against violators is also being sought. Mr. Reid strongly urged the NRC to take actions which will lead to the creation of more burial ground facilities in the U.S. in order to lift the burden that South Carolina is facing. He suggested such actions as early publication of 10 CFR Part 61,"Disposal of Low-Level Radioactive Waste and Low Activity Bulk Solid Waste," NRC review of burial ground license applications in advance of the adoptinn of 10 CFR Part 61, and not issuing operating licenses to nuclear power plants unless adequate low-level waste disposal capacity can be oredicted fnr the life of the plant. In addition, Mr. Reid emphasized that in a November 6, 1979 meeting to be held with Chairman Hendrie the Governors of South Carolina, Nevada and Washington will be seek-ing additional "guarantees" that inspection efforts will be increased to provide further assurances that only waste that is in compliance with applicable regulations will be shipped. Other NRC actions that demonstrate that positive stops are being taken to solve the problems of low-level waste are being sought also.The remainder of October-18 was spent by NRC and DOE representatives, accompanied by H. Shealy, visiting the burial ground at Barnwell, South Carolina.

After a briefing by H. R. Oakley, Vice President of Nuclear Sites, Chem-Nuclear Systems, Inc., the group toured the site. We observed the administrative areas, trucks lined up waiting to enter the site, the control building for site access, the storage area for new liners (manufactured locally), the "slit" trench for burial of irradiated components, the completion of a liner offloading into the burial trench, offloading of drums (shoved from the back of a truck at the edge of the trench), stacking of LSA wooden boxes within the trench with a forklift, earth-moving operations, monitoring wells and standpipes in the trenches, markers desig-nating completed trenches, radiation surveying operations, and South Carolina and NRC inspection activities.

The site employs over 100 people and is authorized presently for disposal of 2.1 million ftJ of waste per year. The trenches are backfilled so that a 10 foot layer of clay is placed on top of the waste. Informa-tion brochures on Chem-Nuclear Services, Inc. were distributed and may be obtained from R. L. Bangart for review.The morning of October 19 was spent meeting with L. Priester, L. LeFebvre (both of Division of Energy Resources)

and Joyce Marchand (with the Staff of the Joint Committee on Energy) to discuss the topics identified on the itinerary.

These discussions were mostly concerned with the definition of responsibilities between NRC and DOE, short and long range programs of DOE, and South Carolina's concerns about and relationships to the federal programs.

During this meeting, South Carolina officials emphasized their belief that reactor licensee applications should be reviewed for the determination that adequate low-level waste disposal capacity exists.

-3 -The afternoon was spent meeting with DHEC officials to reach agreement on the wording of the letter to B. Johnson, as discussed in the second paragraph of this report. A summary of the agreed upon DHEC positions is as follows: 1. No detectable free standing liquids" will be defined as less than 1%liquid (non-corrosive with respect to the container)

by volume until December 31, 1980. Effective January 1, 1981, waste packages shall contain only trace quantities (not more than 0.5% of 1 gallon per container, which-ever is less) of free standing non-corrosive liquids.2. To enhance the stability of waste forms, resins with an activity level of long-lived (greater than tl/2 = 5 years) isotopes greater than 1 uCi/cc disposed of after July 1981 shall be stabilized by solidification or an equivalent method, such as packaging dewatered resins in a high integrity container, e.g. reinforced concrete.The high integrity container alternative was proposed by DOR and South Carolina may, in the future, request NRC to review for acceptability containers that may be proposed for use. DOR has lead action for developing acceptance criteria for use in the review of improved burial containers.

The day ended with a tour of OHEC's laboratory and mobile radiological analysis facilities.

From both the NRC's and South Carolina's standpoints, an informa-tive and constructive interchange had been accomplished during the 3-day period.Enclosures:

1. Attendee list 2. Itinerary for Trip 3. Draft letter to President of Chem-Nuclear, Inc.4. Initial Comments on draft letter to Chem-Nuclear

5. Final Comments on draft letter to Chem-Nuclear ATTACHMENT

1 PARTICIPANTS

IN THE OCTOBER 17-19, 1979 MEETING IN COLUMBIA, SOUTH CAROLINA TO DISCUSS LOW-LEVEL

RADIOACTIVE

WASTE Cathy Schneider, Office of State Programs Robert Brown, Office of Nuclear Material Safety & Safeguards Dale Smith, Low Level Waste Management Operations Dick Bangart, Office of Nuclear Reactor Regulation Lake Barrett, Office of Nuclear Reactor Regulation Ken Perkins, Office of Standards Development George Bidinger, Office of Inspection

& Enforcement Jim Oieckhoner, DOE Low Level Waste Office George Levine, Db-LLW contractor, Idaho National Laboratory David Reid, Executive Assistant to Governor Riley Lamar Priester, Director, S. Carolina Div. of Energy Resources Larry LeFebvre, Deputy Dir. of Policy Analysis & Planning, Division of Energy Resources Joyce Marchand, Staff of S. Carolina Joint Committee on Energy Heyward 6. Shealy, Chief, Bureau of Radiological Health, South Carolina Department of Health &Environmental Control (DHEC)Emory Williams, Bureau of Radiological Health, DHEC Virgil Autry, Bureau of Radiological Health, DHEC Bill House, Bureau of Radiological Health, DHEC Mike Tkacik, Bureau of Radiological Health, DHEC Herbert R. Oakley, Director of Nuclear Sites, Chem-Nuclear Systems, Inc.

---TENTATIVE ATTACHMENT

2 ITINERARY NUCLEAR REGULATORY

COMMISSION

VISIT COLUMBIA, SOUTH CAROLINA--OCTOBER

17, 18, 19, 1979 TRIP

PURPOSE

Meet with South Carolina technical and policy officials to review pending NRC low-level radioactive waste regulation and implementa- tion timetable, and discuss associated issues.NRC OFFICIALS

MAKING THE TRIP: Cathy Schneidi Robert Brown--Dale Smith-Dick Bangart--Lake Barrett--er-----Office of-Office of-Low Level-Office of-Office of 4 -State Programs Nuclear Material Safety & Safeguards Waste Management Operations Nuclear Reactor Regulation Nuclear Reactor Regulation

--__ Ken Perkins--George Bidinger Jim Dieckhoner- George Levin---------Office of Standards Development

---

Office of Inspections

& Enforcement

--- -DOE Low Level Waste Office------DOE LLW Contractor, Idaho National Laboratory WEDNESDAY, OCTOBER 17 NRC Staff arrivals and afternoon meetings with Heyward Shealy, S.C. DEEC.THURSDAY, OCTOBER 18 9:00-10:OOam

10:00-11:30am

11:30-12:30pm

12:30- 3:00pm 3:00- 4:00pm 4:00- Open Governor's Conference Room, State House Meeting with David Reid, Executive Assistant Travel to Chem-Nuclear LLW Disposal Facility Lunch (Somewhere in route to C-N, Barnwell?)

Tour Chem-Nuclear Return to Columbia Meeting with Div. of Energy Resources

& Joint Legislative Committee on Energy Staff (place to be determined).

FRIDAY, OCTOBER 19 9:OOam-5:OOpm Room 507, Gressette Office Building -Informal discussion of following low-level radioactive waste topic areas: 1 -Waste Forms, particularly dealing with free-standing liquids 2 -High volume, low specific activity waste 3 -Regionalization of waste sites and programs 4.- DOE-vs.-NRC

roles in LLW planning 5 -Need for stepped up inspection activities on the part of NRC and Agreement States 6 -Inspection focus: at waste originator-vs.-waste disposal facility 7 -Follow-up status report to recent NRC/DOT visit to S.C.

South Carolinas Heal h md Conkol DRAFT>h4ACHMENT

3 BOARD Willam M. WUson. Overrrn William C. Moore. Jr., D M.D.. Vke-Chairrren I. DeOirnceyNewan, Secretary LeonardW.

Douglas. M.D.GeorCeG. GrahNm. D.D.S.J. Lorn Mason. Jr.. M.D.C Maurice Patters COMISSIONER

AlbertG FPnJil, M.D., M.P.H 2600 Bun Street CdlUrris.

&-C. At=Mr. Bruce W. Johnson, President Chem-Nuclear Systems, Inc.a P.O. Box 1866 Bellevue, Washington

98009 Dear Mr. Johnson: Your South Carolina Radioactive Material License No. 097 has been amended in its entirety by Amendment No. 26. The enclosed license supersedes the original license and all previous amendments.

Amendment of your license was necessary to further define the requirement that there shall be no detectable free standing liquids contained in radioactive waste received and buried at the Bamwell Facility.

Other changes reflect clarification of existing license conditions and additional requirements as previously discussed with the Barnwell Site management.

With respect to license conditions

25 and 31, the terminology "no detect-abla zree standing liquids" will presently be defined as less than 1% liquid by %atlmoe. However, our goal will be to allow only trace quantities

(0.51 cr ,a-lon per container:

whichever is less) of non-corrosive liquids due to6- :--. ensate.L resins, i.e., resins fra which all detectable free standing liquids:-av.: been removed, will be acceptable for receipt and disposal at the facility wi.: December 31, 1980. Effective January 1, .981, all ion exchange resins ad for burial shall be solidified with an appropriate solidification rn approved by the Department and shall contain only trace quantites of;:e- standing liquids. A future amendment will be forthcoming to reflect th_ requirement.

1878 Century of Service 1978

• r.'-' ATTACHMENT

3 (cont'd)Mt. Bruce E. Johnson Page 2 It 11 afin8cipated that your company will immediately inform your customers of the changes in the amended license and the forthcoming requirements.

Should you have any questions, please do not hesitate to contact me.Very truly yours, Heyward G. Shealy, Chief Bureau of Radiological Health HGS:mig Enclosure cc: Mr. Herbert R. Oakley Vice-President of Nuclear Sites Mr. Louis E. Reynolds Director, Regulatory Affairs Mr. Lee B. Hebbard Barnwell Site Mmager r. David G. Ebenhack.Ninager, Health & Safety ATTACHMENT

4 Suggested changes to draft letter to Bruce Johnson Paragraph

3: Delete and replace with: With respect to license conditions

25 andi 31. t'he terminology"n detectable free standing liquids' will be d rtted as less than 1% liquid by volume until December 31, IqbO. Effective January 1, 1981, waste packages shall contean only.trace quantities

(-not more than 0.5% or 1 gallon perCon'ainer;.whichepver is less) of free standing liquicd iiAn Liquids present in waste.packages which are allowablem int1 December 31, 1980 shall be non-corrosive with respectib the container.

EVffective January 1, 1981 the allowable tracJ .uantities of Iiquid shall be non-corrosive.

?aragraph

4: Delete and replace with: It is the goal of South Carolina to enhance the stability of the waste forms consigned for burial. To that end resins ( >lQu Ci/cc of isotopes with half lives greater than Midyears)dAlsposed of after July 1981 nmst be stabilized by solidification or an equivalent method such as packaging dewmteed rnsins in a hI4h intec-ity container e.z. reinforced concrete.

. hK.ACHMENT

5 Z'ipsjs:;1." chalnmr to dr-aft leit.ter tLn &ce Johiv on Para'aph 3: tWlete atd repLas-with.

With respect to license conditioira

25 aryl 35, thc terminology"no dOA.Mlct able frevef standtljn liquid:a" wl l b decrlncd n= less than 1% liquid by vollun until Dtcqdmcr 31, 1980. Effective Januarfv 1, 1981, waste rackares shall- corrtAin only trace quantities (not more than 0.5% or,1 rnillon per container;

whichever is less) of free standing liquids. Any liquids present in waste packages which ame allowable until Decemrber 31, 1980 shall be non-corrosive with respect to the container.

Eftective January 1, 1981 the allowable trace quantities of liquid shall be non-corrosive.

Paragraph

4: Delete and replace with: It is the imoal of South Cirolina to etnaire the starbillty of the waste forms eons1ied for burial. W) t.Iat end, +du'TE level resinF Wlkaq.I%t ISI ( >.Wij Cl/cc of isotopes wih half llves Strater than Likyears t diSsosed of after July l9l irwst e stobi; 2ied by solidtai&ca ermn equivalent.

rpthod such as paekaging deater4 ffestins In a high in1esl1tA'

vontaitner e.g. reinforcd concteV.qs/r -iy,4c tq C. -¢ -' 5 d -AW

.I 50-259 Mr. Hugh G. Parris 50-260 Tennessee Valley Authority --50-296 cc: H. S. Sanger, Jr., Esquire General Counsel Tennessee Valley Authority 400 Commerce Avenue E llB 33 C Knoxville, Tennessee

37902 Mr. Ron Rogers Tennessee Valley Authority 400 Chestnut Street, Tower I Chattanooga, Tennessee

37401 Mr. E. G. Beasley Tennessee Valley Authority 400 Commerce Avenue W IOC 131C Knoxville, Tennessee

37902 Robert F. Sullivan U. S. Nuclear Regulatory Conmmsion P. 0. Box 1863 Decatur, Alabama 35602 Athens Public Library South and Forrest Athens, Alabama 35611