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 STATESNUCLEAR REGULATORY COMMISSION1WASHINGTON. D. C. 20555January29v 19f Jaocanur 9 90ALL POWER REACTOR LICENSEESSubject: Low Level Radioactive Waste DisposalRecent developments at commerical low level waste burial sites havesubstantially impacted waste disposal operations. The license to operate thefacility at Barnwell has been recently revised by the State of South Carolinato further limit the volume of waste buried and to upgrade the Integrity ofthe waste form received at the site. Similar requirements to upgrade theintegrity of waste forms packaged for the Richland, Washington burial site alsohave been required by the State of Washington. NRC licensees are requiredby Commission regulations to assure that wastes prepared for shipment arein a form that the Agreement State licensee is permitted to receive underapplicable Agreement State regulations as well as meeting all pertinent NRCand DOT transportation regulations.The past closure of low-level radioactive waste burial sites in Washington andNevada and the strict enforcement of license conditions at Barnwell haveresulted from the States' dissatisfaction with the events that have occurredinvolving solid radwastes shipped from waste generators including power reactors.Consequently, improvements will have to be made to comply with the Statelicenses.NRC OIE Bulletin No. 79-19, Packaging of Low Level Radioactive Waste forTransport and Burial, has already been sent to you regarding this matter.You should review your system and operating procedures to assure the strictadherence 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 thesite licensee, Chem-Nuclear Systems, Inc., describes the restrictions to beadhered to for the wastes received at that site. The requirements by theState of Washington on waste form upgrade is similar. The following areasare of particular concern to the States and should be acted upon accordingly.1) Free Liquids in Wastes Leaving Reactor SiteThe objective for solid radioactive wastes leaving the reactor site forburial is that they should contain no detectable free liquids as dtfinedby Appendix 2 of ANSI/ANS 55.1-1979. In no case however, should theamount of free liquid upon arrival at the burial site exceed the burialsite license conditions. Free liquid determination should consider theeffects of transportation, e.g., vibration, freezing and thawing. Thisrequirement is applicable to both dewatered resins and spent filter mediaas well as solidified wastes departing the reactor site>

-2 -The following conditions (items 2 -4) must be met for the waste to beacceptable by burial sites in the States of Washington and South Carolina.2) Free Liquids in Wastes on Arrival at the Burial SiteUntil December 31, 1980, provide assurance that all wastes do not containmore than 1% liquid by volume upon arrival at the burial site. Anyliquids present in waste packages shall be non-corrosive with respect tothe container. Non-corrosive means conformance with 10 CFR 71.31, 49CFR 173 and other DOT regulations such that there should be no significantchemical, galvanic or other reaction with the packaging components.Tests should be conducted either on simulated or actual waste which demonstratethat wastes to be shipped conform to the above criteria. In addition, operatingprocedures shall be developed that implement the methods to be used to assurethat all wastes arriving at the burial site compley with burial site free.liquidlicensing conditions.3) Future Free Liquids ReqgirementsEffective January 1, 1981, no wastes Dackages shall contain more than tracequantities 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, thecontainer volume, whichever is less. For those waste currently solidifiedby UF systems, you should prepare to meet this requirement as soon asfeasible before January 1, 1981. Present methods of waste solidificationby UF systems do not provide assurance that the waste packages on arrivalat the burial site contain no more than trace quantities of non-corrosivefree liquids.4) Requirements on Spent Resins and Filter MediaEffective July 1981, spent resins and filter media with radioactivitylevels above 1 pCi/cc of isotopes must be stabilized by solidification.However, in lieu of solidification, other methods such as packagingdewatered 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 amendmentdoes not discriminate between long and short half-live isotopes, it isour understanding through discussions with the State officials, that onlyisotopes with half-lives greater than 5 years need to be included in theradioactivity level (i.e., greater or less than 1 pCi/cc) consideration.Consequently, solidification or high integrity containers would then onlybe required if radioactivity levels exceeded 1pCi/cc for radioisotopeswith 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, andpossible future burial site problems may result in a shortage of low levelwaste disposal capacity. Consequently, licensees should take positive stepsto minimize the volume of waste produced. To this end, each licensee shouldimplement a program to minimize the generation of radioactive solid wastes(edg., waste segregation) and implement methods to reduce the volumes of wastewhich cannot be eliminated (e.g., use of trash compactors).

-3 -The revised requirements on waste forms may necessitate the use of mobile ortemporary solidification systems. Regulations require that any changes toyour solidification systems differing from your FSAR submitted for the issuanceof 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 preparedprior to making the facility modification. With respect to future changes insolidification systems, copies of the safety evaluations along with any additionalsupporting documentation concerning the safety adequacy of any mobile ortemporary solidification system shall be submitted to the NRC. In addition,the appropriate revision to the Process Control Program (PCP) required underthe model Radiological Effluent Technical Specifications shall be submittedfor 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 thatcomplete solidification of liquid waste takes place, but that no free standingliquid exists in any waste container leaving your site. The PCP should alsobe based on data or tests that demonstrate that your waste will have no freestanding liquid in excess of the burial ground license requirements at time ofburial 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 operationof your modified systems.Sincerely,Darrell G. Eisenhut, Acting Di ectorDivision of Operating ReactorsOffice of Nuclear Reactor RegulationEnclosure: Letter and License fromState of South Carolinacc w/enclosure: Short Service List

...1 vt chment forLett~e to LicenseesI.-Soih Cardn aDepaerdHe ha nd;.Conkol111--WOARD.VAPRn M. lm. erg.J.Lhn Mawi Jr., M.D.. Vkr. y;ifirs1. OskyNeyNw SecrtyLsomrdW. DoIas. M.D.Georg M Grah.n. D.D.S.dchael W. hUrBarara P. NuessleCMhUSSIONERMalom U. Dantzr. M.O., M.P.H.Cl0u8tla Stre22October 30,1979Mr. Bruce W. Johnson, PresidentChem-Nuclear Systems, Inc.P. 0. Box 1866Eellevue, Washington 98009Dear Mr. Johnson:Your South Carolina Radioactive Material License No. 097 has beenamended in its entirety by Amendment No. 26. The enclosed licensesupersedes the original license and all previous amendments.Amendment of your license was necessary to further define therequirement that there shall be no detectable free standing liquidscontained in radioactive waste received and buried at the BarnwellFacility. Other changes reflect clarification of eidsting licenseconditions,and additional requirements as previously discussed withthe Barnwell Site management.With respect to license conditions 25. and 32., the terminology"no detectable free standing liquids" will be defined as less than1% liquid by volume until December 31, 1980. Effective January 1,1981, waste packages shall contain only trace quantities (not morethan 0.5% or 1 gallon per container; whichever is less) of freestanding liquids. Any liquids present in waste packages which areallowable until Decenber 31, 1980, shall be non-corrosive withrespect to the container. Effective January 1, 1981, the allowabletrace quantities of liquid shall also be non-corrosive.It is the goal of the Department to enhance the stability of thewaste form consigred for burial. To that end, resins with a totalspecific 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 onlytrace quantities of non-corrosive liquids in high integrity containersame being considered at this time.1878 Century of Servce 1978 Br. Buce W. Jcohnsn -2- October 30, 1979It Is anticipated that your ccanpan will Imdiately Infarm yourcustamrs of the changes in the amended license and the fartbcodng'reqiments. Should you have any questions, please do not hesitateto contact me.Vem truly yours,Bureau of Radiological HealthHGS:boEolosurec¢: Mr. Herbert R. OakleyVice-President of Nuclear SitesMr. Louis L ReynoldsDirector, Regulatory AffairsI~t. Lee B. HebbardBanwell Site Manager1rk. arvid G. EbenhakManager Health & Safety

6VLicense No. 097Amndment No. 26 anmridsLicense No. 097 in itsentirety.SOUIH CARLINA DEPARThWOP HEAL7H AND ENVIR AL CONWLBUREAU CF RADIOO1ICAL HEALMCOLUMIA, SOCUH CAROLINARADIOAC`IVE MATIAL LICENSEPursuant to the Atomic Energy and Radiation Control Act, Sections1-400.U1 through 1-400.16 of the 1962 Code of Laws of South Carolinaand Supplement thereto; and the South Carolina Department of Healthand Environmental Control Rules and Regulations Pertaining to RadiationControl, Part III and in reliance on statements and representationsheretofore made by the licensee, a license is hereby issued authorizingthe licensee to receive, acquire, possess, and transfer radioactivematerial listed below; and to use' such radioactive material for thepurpose(s) and at the place(s) designated below. This licensee issubject to aUl applicable rules and regulations of the South CarolinaDepartment of Health and Environmental Control now or hereafter ineffect and to any conditions specified below.*1. Licensee: Chem-Nuclear Systems, Inc.2. Address: P. 0. Box 726Barnwell, South Carolina 298123. License No. 097(Amendment No. 26 amends RadioactiveMaterial License No. 097 in its entirety.)4. Expiration Date:December 31,, 19810

-2-Conditions -General5. Radioactive material, except special nuclear material, may bereceived, transferred, stored, and disposed of by burial at asite located approximately five miles northwest of Barnwell,South Carolina, at a site located in the Seven Pines SchoolDWatrict, Red Oak Tbwnship, Barnrell Countys South Carolina,within the boundary of the land area described in LeaseAgreement dated April 6, 1976. unless otherwise authorizedIn this license, only radioactive material consigned for burialshall be received at the site described above.6. The licensee shall comply with the provisions of Title A, Stateof South Carolina Rles and Regulations for Radiation Control,Part I -General Provisions, Part III -Standards for Protectionga.inst Radiation, and Part VI -Notices, Instructions, andReports to Workers; Inspections.7. Operations shall be conducted in accordance with Chem-NuclearSystems, Inc., Radiation Protection and Procedures Manual datedApril 4, 1977, and subsequent revisions and additions approvedby 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 designatedby the licensee's Radiation Protection Officer upon completionof the licensee's training program.9. The transportation of radioactive material within the state shallbe in accordance with Title A -State of South Carolina Rules andRegulations for Radiation Control, F{A 2.22, "Transportation ofRadioactive Materials."10. Radioactive materials authorized by this license are to be receivedat the site in shipping containers which have been approved by theU. S. Department of Transportation, U. S. Nuclear RegulatoryComtmission, 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 damagedin transit.(b) For purposes of inspecting to insure conpliance with theeffective Barnwell Site Disposal Criteria.(a) For purposes of returning outer shipping containers.(d) For purposes of retrieving shipment documentation arndconfirming package contents.

Conditicn -General12. A monthly site receipt and burial activities report shall besubmitted no later than the 10th day of the following monthto the Chief, Bureau Of Radiological Healths South CarolinaDepartmnt of Health and Environerntal Controls 2600 BullStreet, Columbtia, South Carolina 29201.13. Should any samples taken from trench monitoring wells, clusterwells, or air samples reveal increases in the concentrationsof radioactive material which were determined prior to commence-ment of the burial operations, the licensee shall perform furthersurveys to determine whether or not the increase is due to theland burial operations. The licensee shall notify the Chief,Bureau of Radiological Health, South Carolina Department ofHealth 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 suchincreases.14. the licensee shall submit results of all scheduled envirorumntalsampling to the Department quarterly.15. The licensee shall mnintain all records pertinent to the receiptand burial of radioactive material at the location specified inCondition 5. of this license until authorization is given by theDepartment for transfer or disposal of said records.16. Licensee is authorized to possess a 100 millicurie Cesium 137sealed source (Eberline Model No.64-76A), for the purpose ofcalibrating 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, otherthan Hydrogen 3, with a half-life greater than thirty daysand in any form other than gas shall be tested for leakageand/or contamination at intervals not to exceed six months.In the absence of a certificate from a transferor indicatingthat a test has been nmde within six months prior to thetransfer, the sealed source shall not be put into use untiltested.B. The test shall be capable of detecting the presence of 0.005microcuries of radioactive material on the test sample. thetest sample shall be taken from the sealed source or fromthe surfaces of the device in which the sealed source ispermanently mounted or stored on which one might expectcontamination to accumulate. Records of leak test resultsshall be kept in units of microcuries and maIntalned forinspection by the Department.

-4.Clditiocns -GeneralC. If the test reMveals the presende of 0.005 microcuries or nMreOf remvable contmniaticn, the licensee shall Immediatelywitbd'w the seale" sorce from use and shall cause it to bedecontaminated an repaired or to be dispoed of in accoancewith Department regulatis. A report shal be fed within5 days of the teat with the Ciief, BureaU of adiaOogiCal Health,S. C. Department of Health and &nv==ntal Control, 2600 BullStreO3 Columbia, 3o$th Caolina 29201, descibing the equipmntinolved, the teat results, and the correqtive action taken.18. Tets3 for leak and/Cr contamination shall be perorvd by thelicemse or by other persons speciacally authorized by the U. S.Nuclear tgglatory COmnislon or an Ageement State to perfmsuch service.19. *The licensee may receive am process waste shipmnta only duringnd wark1S hours as specified in the effective Barnwell SiteDisposal Criteria.Conditions- Waste20. The licensee shall not recelive possess or have in his possessionat the location specified in ti .at an one tize unburiedradioactive material in exrcess of:(a) 50,000 curies of radioactive material excluding source andspecial nuclear materials;(b) 60,o00 pounds of soure material.21. The licensee shall insure that all waste received at the sitedescribed in Condition No. 5 i packaged and prepared in accordancewith the conditions of this license ad the effective Barnwell Sitetisposal Criteria. AnW chnes made to the Site Criteria shallhave prior approval by the Department.22. te"s speciaicalY authorized, all radioactive waste shan bereceived and buried In appropriate cntainers.23. A seven-day written notification shall be submitted to the Departnentby the licensee of radioactive material shipments to be receivedIn excess of 2500 curtes per shipmnnt with the excepticn of tritiumshipmlents.24. ble=s otherwise a orzed, the licensee hall not receive wastecontaining ay transwi eleints. HoweVer, waste containingless than 10 nanoures total tranaizn nuclides per gpam of wasteis acceptable provided tansuranic nuclides are evenly distributedwithin a hosgeneous waste form. This license condition does notauthorize receipt or burial of cagonents or equimnt contaminatedwith transranlc rmclides.

-5-Cmditiorn -Waste25. Unless otherwise specified in this license, thereceive arn liquid radioactive waste regrdlessor physical frm.n Solidified radioactive wastedetectable free standing liquids.licensee shall not -of the chemicalshall have no26. The licensee shall not receive waste in any month in excess of thevolume limits specified in the schedule below. The licensee shallinsure thit waste generated in South Carolina which is acceptablefor burial under all other terms and conditions of this license andthe effective Barruell Site DLsposal Criteria is received, and thatthis waste is within the volume limit specified for that month.Volume Limitation Schedulebnth and YearVolume Limit in Cubic FeetNovember, 1979December, 1979January, 1980February, 1980March, 1980April, 1980May, 1980June, 1980July, 1980August, 1980September, 1980October, 1980November, 1980December, 1980January, 1981February, 1981March, 1981April, 1981May, 1981June, 1981July, 1981Augt, 1981Septenber, 1981October, 1981November, 1981December, 1981January, 1982 and each month thereafteror until this condition is otherwise amended.189,000..189,000178,000178;000178,000167,000167,000167s000156,000156,000156,000144,500144,500144,500133,500133,500133,500122,50O122,500122,500111,000111,000111,000100,000100,000lOQ000100,00027. The licensee shall not receive toluene, xylene, dioxane, scintillationliquids, or other orgnic liquids with simila chemical properties;or containers ohich have at any tixz contained ary of the liquidsmentioned above. However, after complete incineration, the ashand/or residue from these wastes are acceptable.

Canditions -Waste28. Ihe licensee shall not receive or bury radioactive waste contaLningmore than one (1) percent absorbed oil by volum.29. Waste containing both toxic chemicals and radioactive materials shallrequire an independent evaluaticn of both hazards. If the chemicalhazard exceeds the radiological hazard, the waste containing bothradioactive material and chemically toxic waste shall not be buriedat the site as described In Condition No. 5 except as specificallyapprvd by the Department. Records of hazard evaluation of suchwastes performed by the licensee shall be kept for inspection bythe Department.30. The licensee shall not store any packag containing radioactivematerial or source material for a period greater than six monthsfra the date of receipt of the package prior to burial.31. The licensee nmay receive liquids solidified with one of thefollowing solidification media provided the requirements ofother conditions as specified in this license are mat:(a) Dow media(b) Cement(c) Urea Fomaldehyde(d) Asphalt(e) Delaware Custom MdiaCf) Solidification media and processes reviewed and approved bythe U.S.N.R.C., Office of Nuclear Reactor Pesulaticns, subjectto final approval by the S. C. Department of Health and Envirwnmental Control, Bureau of Radiological Health.32. Ion exchange resins and filter media may be received in a dewateredform for transportation and subsequent burial and shall contain nodetectable free standing liquids.33. he e.licensee shall maintain records of isotopic analysis (quantitativeand qualitative) for each package containing ion exchange resinsreceived at the site.34. Ihe licensee shall not receive evaporator bottcms, concentrates, orother wastes containing free standing liquids unless they meet therequirements as specified In Condition 31. of this license, priorto receipt at the site.

-7-Caditions -Waste35. Effective Novenber 1, 1979, the licensee shall insure that eachRadioactive Shipment Record fom used to describe a low-levelradioactive waste shipfznt received at the Barbwell Site hasthe following certification properly executed by a representativeof the shipper/generator of the waste:"Certification is hereby made to the South Carolina Department ofHealth and Environmental Control that this shipment of low-levelradioactive waste has been inspected in accordance with the require-ments of South Carolina Radioactive Material License No. 097, asamended, U. S. Nuclear Regulatory Comuission License No. 46-13536-01,as amended, and the effective Banve"l Site Disposal Criteria within48 hours prior to shipment; and further certification is made thatthe inspection revealed no items of non.-capliance with all applicablelaws, rules and regelations.Date: By:Title and Organization:__TelephoneNb. ( ) -36. The licensee shall insure that any package used as the final burialcontainer shall be of such material and construction that therewill be no significant chemical, galvanic, or other reaction amongthe packagng components, or between the packaging components andthe package contents.37. The licensee may bury Krypton 85 and Xenon 133 gaseous sourcesprovided they meet the following criteria:(a) Burial containers Amst be approved by the Departimnt ofTnaxsportation.(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 amrir man spacing of ten (10) feet.Conditions -Site38. A registered surveyor cast verify and document the location of eachtrench: (a) prior to the beoifing Of trench construction; (b) atthe cop letion of trench construction, prior to the initiation ofthe burial operations; and (c) at the completion of the grading andseeding operation.39. Construction of radioactive waste burial trenches, slit trenches,"Toner Tubes", trench monitoring wells and site cluster wellsshall 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 fromthe Department before construction begins.

4-8CTiditions -Site40. Mcnitoring wells in clusters will be placed outside the trenchesbut In the trench area. Specific locations shall be determinedthrough consultation. Me initial well of a cluster will becore drilled to the water table and a representative sample ofthe core shall be submitted to the Departmunt, The depth andnumber of additional wells in the cluster are to be determdnedby the sand-clay caTposition observed in the initial core. Allwells shall be grouted, sealed, and capped.41. The licensee shall not Initiate burial operations in newly excavatedtrenches until the Department has inspected and approved the trenches.An initial inspection will be made by the Depaeztnt upCn ccvpletionof excavation of the trench, sumps, french drain inside the trench,drainage ditches adjacent to the trench and installation of msciftorfgwell standpipes. An intermdiate inspection wil be made by theDepartment after the french drain and sumps have been filled withrock. A final inspection will be made by the Department uponcompletion of construction requirements per Trench ConstructionDetail r'awdngs No. 500.101 dated December 12, 1978.42. Each well and 'Toner Tube" must be sufficiently capped or coveredto prevent the introduction of any extraneous material.43. Open trenches and partially filled trenches shall be protected toprevent runoff water frau entering trenches. Radioactive wasteshall not be placed into trench areas Where water has accumulated.BurIal of radioactive waste into trenches with unusual amounts ofwater shall immediately cease until corrective action has beentaken and origin of water determined.44. The licensee shall maintain a minimum of two feet of caopacted claybetween the last layer of waste and the surface of the ground.BacflJ.ing shall commence immediately as waste reaches the topelevation of the trench. Uncovered wastes shall not extend morethan 100 feet beyond the backfilled portion of the trench. Uponcompletion of burial operations in a burial trench, the licenseeshall add an additional three feet minitmi of earth on top of thetwo foot cover. Carpleted trenches shall at no time be used forstockyiling earth not withstanding provisions for a final gradingplan.45. The cover over the completed burial trenches at the site specifiedin Condition 5. of this license shall be ntained to minimnmerosion.46. The disposal area and cover of the trenches shall be arranged andgraded in such a manner that all surface runoff water shall becarpletely reed frm the vicinity of the trenches.47. Tempozary trench bculary ma&ers and trench identification mFmershall be erected upon completion of backfill operations untilpernmuwnt granite markers are installed. 0

A* -S --9- -Conditions -Site48. All wells constricted at the site specified in Condition 5. of thislicense shall be protected from damage.49.Interim or final grades shall be established and seeding of trenchcovers shall comence at no mm than one year following finaltrench burial operations.50. A series of granite markers, one at the end of each completedtrench and on each corner, shall be erected upon completion ofthe seeding of trench covers. the following infobration shallbe inscribed on the end monument, and this information shall bereported to the Chief, Bureau of Fadiological Health, South CarolinaDepartment of Health and Environmental Control, 2600 Bull Street,Coludbia, South Carolina 29201.a. Thtal activity of radioactive material in curies excludingsource and special nuclear materials, total amount of sourcematerial in pounds, and total amount of special nuclearmaterial in grans in the trench.b. Date of completion of the burial operations; andc. 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 activitiesand to authority to bury radioactive material wastes at the sitespecified in Condition No. 5. The license continues in effect andthe responsibility and authority for possession of buried radioactivematerial wastes continues until the Department finds that the planestablished for preparation of the Earnwell site for transfer toanother person has been satisfactorily implemented in a manner toreasonably assure protection of the public health and safety andthe Department takes action to terminate your responsibility andauthority under this license. All requirements for environmentalmonitoring, site inspection, and maintenance, and site securitycontinue whether wastes are being buried or not.53. Site closure and stabilization of the licensee's facility shallbe accomplished in accordance with the U. S. Nuclear RLegulatoryComnission's Low-Level Waste Branch Position entitled, "Low-LevelWaste Burial Ground Site Closure and Stabilization," Revision 1dated May 17, 1979. A copy of the performance dbjectives isattached.

-10-Conditions -Site54. Prior to May 319 1980, a preliminary plan for preparation of thesite for transfer to another person who would only passively holdthe site shall be submitted for review. The plan shall be consistentwith Condition 53. of this license and shall include demonstrationthat funds are being set aside or other measures being taken areadequate to finance the site closure plan. The plan shall alsoinclude preliminary estimates of costs, environmental impacts,data needs, personnel needs, material and equipment needs, planneddocumentation and quality assurance, and detailed plan for trenchlocations and elevations, expected capacities, planned surfacecontours, and buffer zones.55. Prior to May 31, 1980, a reassessment of current operating practicesshall be submitted. The reassessment shall consider the objectivesof the site plan specified in the preceding paragraph and any changesin operation at the site which would enhance implementation of theplan.56. The licensee shall submit an updated plan and operational assessmentevery five years for review.57. One year prior to the anticipated transfer of the site and buriedradioactive materials to another person (including an agency of theU.S. Government) the licensee shall submit a final version of thesite preparation plan including a schedule for irplen~ntation ofall remraining plan elements prior to transfer, =nd a descriptionof the mechanics of orderly transfer in coordination with thetransferee.58. Except as specifically provided otherwise by this license, thelicensee shall possess and use radioactive material described inCondition 20. of this license in accordance with statements,representations, procedures, and site criteria, heretofore madeby the licensee in application for and subsequent to the issuanceof S. C. Radioactive Material License No. 097, and amsndln~t thereto.For The South Carolina Departmentof Health and Evironrmental ControlDate of Issuance October 30. 1979 BY:3G. -ealy, ChlefyB of Radiological Health

-Enclosure 2REPORT OF MEETING ON RADIOACTIVE LOW-LEVEL WASTEWITH SOUTH CAROLINA OFFICIALS, OCTOBER 17-19, 1979NRC 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 betweenKen Perkins, SD, and Lamar Priester, Director, South Carolina Division of EnergyResources, at which a commitment was made to hold an infornmation exchange meetingamoung the concerned State and federal agencies. Another purpose for meeting wasto discuss specifically the revision being made by the South Carolina Department ofHealth and Environmental Control (DHEC) to the license that is issued to Chem-NuclearSystems, Inc. to operate the Barnwell facility. A copy of the itinerary for the tripis 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 HeywardShealy (DHEC) and members of his staff to discuss the Order issued to CommonwealthEdison prohibiting low-level waste transport into South Carolna, and to discuss thecontents of a draft letter to the president of Chem-Nuclear Systems, Inc. which ex-plains the implementation policy of South Carolina regarding free standing liquidand resin solidification. At this meeting G. Bidinger invited DHEC inspectors toaccompany IE inspectors on inspections of waste management programs of NRC licenseeswhich DHEC had identified as problem shippers (such as Commonwealth Edison). NRCrepresentatives 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, suggestedchanges (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 wereagreed to by DHEC and NRC as being appropriate. During this meeting, both NRR and IErepresentatives agreed that low-level waste from reactor sites should contain no(zero) free standing liquids at the time of shipment. However, because of factorswhich occur during transportation (such as freeze-thaw cycling and vibrationaleffects), it is recognized by both DHEC and NRC that small quantities of liquid maybe present at the time of burial.October 18 began with all NRC and DOE representatives shown on Attachment 1 meetingwith David Reid, Executive Assistant to Governor Riley, Lamar Priester, Director,South Carolina Division of Energy Resources, Larry LeFebvre, Deputy Director ofPolicy 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 burialground operations at Barnwell and low-level waste management in general. It wasstated the volume of waste authorized for burial will be reduced over the next twoyears 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 intoSouth Carolina, will be taken against those who ship or transport waste that isnot in compliance with applicable state or federal regulations. Statutory autho-rity to issue civil penalties against violators is also being sought. Mr. Reidstrongly urged the NRC to take actions which will lead to the creation of moreburial ground facilities in the U.S. in order to lift the burden that South Carolinais 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," NRCreview of burial ground license applications in advance of the adoptinn of 10 CFRPart 61, and not issuing operating licenses to nuclear power plants unless adequatelow-level waste disposal capacity can be oredicted fnr the life of the plant. Inaddition, Mr. Reid emphasized that in a November 6, 1979 meeting to be held withChairman Hendrie the Governors of South Carolina, Nevada and Washington will be seek-ing additional "guarantees" that inspection efforts will be increased to providefurther assurances that only waste that is in compliance with applicable regulationswill be shipped. Other NRC actions that demonstrate that positive stops are beingtaken to solve the problems of low-level waste are being sought also.The remainder of October-18 was spent by NRC and DOE representatives, accompaniedby H. Shealy, visiting the burial ground at Barnwell, South Carolina. After abriefing by H. R. Oakley, Vice President of Nuclear Sites, Chem-Nuclear Systems,Inc., the group toured the site. We observed the administrative areas, truckslined up waiting to enter the site, the control building for site access, thestorage area for new liners (manufactured locally), the "slit" trench for burialof irradiated components, the completion of a liner offloading into the burialtrench, offloading of drums (shoved from the back of a truck at the edge of thetrench), 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 andNRC inspection activities. The site employs over 100 people and is authorizedpresently for disposal of 2.1 million ftJ of waste per year. The trenches arebackfilled 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 obtainedfrom R. L. Bangart for review.The morning of October 19 was spent meeting with L. Priester, L. LeFebvre (bothof Division of Energy Resources) and Joyce Marchand (with the Staff of the JointCommittee on Energy) to discuss the topics identified on the itinerary. Thesediscussions were mostly concerned with the definition of responsibilities betweenNRC and DOE, short and long range programs of DOE, and South Carolina's concernsabout and relationships to the federal programs. During this meeting, SouthCarolina officials emphasized their belief that reactor licensee applicationsshould be reviewed for the determination that adequate low-level waste disposalcapacity exists.

-3 -The afternoon was spent meeting with DHEC officials to reach agreement on thewording of the letter to B. Johnson, as discussed in the second paragraph ofthis 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 untilDecember 31, 1980. Effective January 1, 1981, waste packages shall containonly 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 oflong-lived (greater than tl/2 = 5 years) isotopes greater than 1 uCi/ccdisposed of after July 1981 shall be stabilized by solidification or anequivalent method, such as packaging dewatered resins in a high integritycontainer, e.g. reinforced concrete.The high integrity container alternative was proposed by DOR and South Carolinamay, in the future, request NRC to review for acceptability containers that maybe proposed for use. DOR has lead action for developing acceptance criteriafor use in the review of improved burial containers.The day ended with a tour of OHEC's laboratory and mobile radiological analysisfacilities. 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 list2. Itinerary for Trip3. Draft letter to President ofChem-Nuclear, Inc.4. Initial Comments on draft letterto Chem-Nuclear5. Final Comments on draft letter toChem-Nuclear ATTACHMENT 1PARTICIPANTS IN THE OCTOBER 17-19, 1979 MEETINGIN COLUMBIA, SOUTH CAROLINATO DISCUSS LOW-LEVEL RADIOACTIVE WASTECathy Schneider, Office of State ProgramsRobert Brown, Office of Nuclear Material Safety & SafeguardsDale Smith, Low Level Waste Management OperationsDick Bangart, Office of Nuclear Reactor RegulationLake Barrett, Office of Nuclear Reactor RegulationKen Perkins, Office of Standards DevelopmentGeorge Bidinger, Office of Inspection & EnforcementJim Oieckhoner, DOE Low Level Waste OfficeGeorge Levine, Db-LLW contractor, Idaho National LaboratoryDavid Reid, Executive Assistant to Governor RileyLamar Priester, Director, S. Carolina Div. of Energy ResourcesLarry LeFebvre, Deputy Dir. of Policy Analysis & Planning,Division of Energy ResourcesJoyce Marchand, Staff of S. Carolina Joint Committee on EnergyHeyward 6. Shealy, Chief, Bureau of Radiological Health,South Carolina Department of Health &Environmental Control (DHEC)Emory Williams, Bureau of Radiological Health, DHECVirgil Autry, Bureau of Radiological Health, DHECBill House, Bureau of Radiological Health, DHECMike Tkacik, Bureau of Radiological Health, DHECHerbert R. Oakley, Director of Nuclear Sites, Chem-Nuclear Systems, Inc.

---TENTATIVEATTACHMENT 2ITINERARYNUCLEAR REGULATORY COMMISSION VISITCOLUMBIA, SOUTH CAROLINA--OCTOBER 17, 18, 19, 1979TRIP

PURPOSE

Meet with South Carolina technical and policy officials to reviewpending NRC low-level radioactive waste regulation and implementa-tion timetable, and discuss associated issues.NRC OFFICIALS MAKING THE TRIP:Cathy SchneidiRobert Brown--Dale Smith-Dick Bangart--Lake Barrett--er-----Office of-Office of-Low Level-Office of-Office of4 -State ProgramsNuclear Material Safety & SafeguardsWaste Management OperationsNuclear Reactor RegulationNuclear Reactor Regulation--__Ken Perkins--George BidingerJim Dieckhoner-George Levin---------Office of Standards Development-----Office of Inspections & Enforcement--- -DOE Low Level Waste Office------DOE LLW Contractor, Idaho National LaboratoryWEDNESDAY, OCTOBER 17NRC Staff arrivals and afternoon meetings with Heyward Shealy, S.C. DEEC.THURSDAY, OCTOBER 189:00-10:OOam10:00-11:30am11:30-12:30pm12:30- 3:00pm3:00- 4:00pm4:00- OpenGovernor's Conference Room, State HouseMeeting with David Reid, Executive AssistantTravel to Chem-Nuclear LLW Disposal FacilityLunch (Somewhere in route to C-N, Barnwell?)Tour Chem-NuclearReturn to ColumbiaMeeting with Div. of Energy Resources & Joint LegislativeCommittee on Energy Staff (place to be determined).FRIDAY, OCTOBER 199:OOam-5:OOpmRoom 507, Gressette Office Building -Informal discussionof following low-level radioactive waste topic areas:1 -Waste Forms, particularly dealing with free-standingliquids2 -High volume, low specific activity waste3 -Regionalization of waste sites and programs4.- DOE-vs.-NRC roles in LLW planning5 -Need for stepped up inspection activities on the partof NRC and Agreement States6 -Inspection focus: at waste originator-vs.-waste disposalfacility7 -Follow-up status report to recent NRC/DOT visit to S.C.

South CarolinasHeal h mdConkolDRAFT>h4ACHMENT 3 BOARDWillam M. WUson. OverrrnWilliam C. Moore. Jr., D M.D.. Vke-ChairrrenI. DeOirnceyNewan, SecretaryLeonardW. Douglas. M.D.GeorCeG. GrahNm. D.D.S.J. Lorn Mason. Jr.. M.D.C Maurice PattersCOMISSIONERAlbertG FPnJil, M.D., M.P.H2600 Bun StreetCdlUrris. &-C. At=Mr. Bruce W. Johnson, PresidentChem-Nuclear Systems, Inc.aP.O. Box 1866Bellevue, Washington 98009Dear Mr. Johnson:Your South Carolina Radioactive Material License No. 097 has been amendedin its entirety by Amendment No. 26. The enclosed license supersedes theoriginal license and all previous amendments.Amendment of your license was necessary to further define the requirementthat there shall be no detectable free standing liquids contained inradioactive waste received and buried at the Bamwell Facility. Otherchanges reflect clarification of existing license conditions and additionalrequirements 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% liquidby %atlmoe. However, our goal will be to allow only trace quantities (0.51cr ,a-lon per container: whichever is less) of non-corrosive liquids dueto6- :--. 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 facilitywi.: December 31, 1980. Effective January 1, .981, all ion exchange resinsad for burial shall be solidified with an appropriate solidificationrn approved by the Department and shall contain only trace quantites of;:e- standing liquids. A future amendment will be forthcoming to reflectth_ requirement.1878 Century of Service 1978

• r.'-' ATTACHMENT 3 (cont'd)Mt. Bruce E. JohnsonPage 2It 11 afin8cipated that your company will immediately inform your customersof 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, ChiefBureau of Radiological HealthHGS:migEnclosurecc: Mr. Herbert R. OakleyVice-President of Nuclear SitesMr. Louis E. ReynoldsDirector, Regulatory AffairsMr. Lee B. HebbardBarnwell Site Mmagerr. David G. Ebenhack.Ninager, Health & Safety ATTACHMENT 4Suggested changes to draft letter to Bruce JohnsonParagraph 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 lessthan 1% liquid by volume until December 31, IqbO. EffectiveJanuary 1, 1981, waste packages shall contean only.tracequantities (-not more than 0.5% or 1 gallon perCon'ainer;.whichepver is less) of free standing liquicd iiAn Liquidspresent in waste.packages which are allowablem int1 December31, 1980 shall be non-corrosive with respectib the container.EVffective January 1, 1981 the allowable tracJ .uantities of Iiquidshall be non-corrosive.?aragraph 4: Delete and replace with:It is the goal of South Carolina to enhance the stability of thewaste 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 anequivalent method such as packaging dewmteed rnsins in a hI4hintec-ity container e.z. reinforced concrete.

. hK.ACHMENT 5Z'ipsjs:;1." chalnmr to dr-aft leit.ter tLn &ce Johiv onPara'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= lessthan 1% liquid by vollun until Dtcqdmcr 31, 1980. EffectiveJanuarfv 1, 1981, waste rackares shall- corrtAin only tracequantities (not more than 0.5% or,1 rnillon per container;whichever is less) of free standing liquids. Any liquidspresent in waste packages which ame allowable until Decemrber31, 1980 shall be non-corrosive with respect to the container.Eftective January 1, 1981 the allowable trace quantities of liquidshall be non-corrosive.Paragraph 4: Delete and replace with:It is the imoal of South Cirolina to etnaire the starbillty of thewaste forms eons1ied for burial. W) t.Iat end, +du'TE level resinF Wlkaq.I%tISI( >.Wij Cl/cc of isotopes wih half llves Strater than Likyears tdiSsosed of after July l9l irwst e stobi; 2ied by solidtai&ca ermnequivalent. rpthod such as paekaging deater4 ffestins In a highin1esl1tA' vontaitner e.g. reinforcd concteV.qs/r -iy,4c tqC. -¢ -' 5 d -AW

.I50-259Mr. Hugh G. Parris 50-260Tennessee Valley Authority --50-296cc:H. S. Sanger, Jr., EsquireGeneral CounselTennessee Valley Authority400 Commerce AvenueE llB 33 CKnoxville, Tennessee 37902Mr. Ron RogersTennessee Valley Authority400 Chestnut Street, Tower IChattanooga, Tennessee 37401Mr. E. G. BeasleyTennessee Valley Authority400 Commerce AvenueW IOC 131CKnoxville, Tennessee 37902Robert F. SullivanU. S. Nuclear Regulatory ConmmsionP. 0. Box 1863Decatur, Alabama 35602Athens Public LibrarySouth and ForrestAthens, Alabama 35611