ML20235V431
| ML20235V431 | |
| Person / Time | |
|---|---|
| Issue date: | 03/23/1983 |
| From: | Nussbaumer D NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Page R KENTUCKY, COMMONWEALTH OF |
| Shared Package | |
| ML20235U845 | List:
|
| References | |
| FOIA-87-235 NUDOCS 8707230168 | |
| Download: ML20235V431 (7) | |
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Ref: SA/JFK MAR 2 3 1983 l .r. ., . . .3.,. . . . . . . . :. . . s/ .g..
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Ps. Reba Page Deputy Commissioner l
- stural Resources and j Environmental Protection Cabinet Ospartment for Environmental Protecticn Fcrt Boone Plaza 18 Reilly Road {
Frankfort, Kentucky 40601 l 1
j Oear !'s. Page:
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in response to your letter of Februvy 4,1903 we hava re"inwed the I preliminary draft copy of "A Progran to Provik the Basis and Plan for 3 the Decommissioning of the iiaxey Flats Sballow Land Gurial Facility." !
Coments from the various NRC offices have been consoli&.ted a0d are 1 l provided as an enclosure. As a general coment, the pNposed pla: ccens to consist of a series cf engineering #ixes which can be inplenented i innediately to achieve stabili:ation. Although the 1:=cdiat 2 i
I deccamissioning of the site is e desirable gotl, longesr tern plw ".al' be more cost effective, even theugh a hicher degran of surveillance and maintenance may be raquired in the short tem.
Early ir. T4sk 4 of the pico, we recc. mend that entirated costs be reviewed to see if the necessery fuulirg will be avail-bl: Wcre procceding with detaileu construction plans. If noms J rhe designs is economically feasible, gwan thc funcs that will be avcilt.010, . met h er iteration of Task 3 would need to be perfctmd, lecking it lo car torn decenni3sicnino plans.
An I:RC report on research cbsnrvatica at Maxey Fl:* is ferthceninc which will provide additional ir.#cmation and insight rtlemt ta fita chsure, i
1 0707230168 FOIA 870717 DR PDR MINTONs7-235 J'
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Ms. Reba Page 1 If you would like tc discuss any of these matters further we would be I I
pleased to reet vi+h you and your staff.
Sincerely, {
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Donald A. Nussbr. uter Assistant Directcr for State Agreeneers Progr.m Office of State Prograns f
Enclosure:
As stated D'str* bu tion :
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f Enclosure Comments on A Program to Provide the Basis and Plan for the Decommissioning of the Maxey Flats Shallow Land Burial Facility
- 1. Page 1-3
- a. In the list of engineered features contained in the deconnissioning plan " surface water management" should also be included. Later in the report on page 3.8 this is listed as l
being important. Since surface erosion could drastically affect any cover in the long term, this should be considered as a major engineered feature. {
- b. Fig. 1.2. A major deficiency is the lack of consideration f,or environmental parameters,
- c. On this.page and throughout the report, the phrase " updip ground-water flow barrier" is used. We believe this should be "upgradient" instesd of " updip."
- 2. Page 1-5
- a. In the list of present needs, the phrase " provide permanent upgradient ground-water flow barrier" should be added,
- b. Figure 1-3. The decommissioning plan should not exclude the option of using barriers'which might have to be periodically renewed. They may provide an acceptable cost-effective means of keeping water out of disposal trenches.
- c. An acceptable cost-effective design may be found which would allow for subsidet.ce. The decommissioning plan should keep this option open. Some members of the techr.ical community would maintain that a certain amount of subsidence may be acceptable as long as it is detectable and capable of being remedied. The cost / benefit of designing to preclude any subsidence should be carefully weighed.
- 3. Page 1-6 a, The list of engineered features should again include " surface water managenent."
- b. In developing a decommissioning plan thc technology base from the Uranium Mill Tailings Remedial Action Progran (UMTRAP) should be assessed for its relevance tewards stabili:ing slor/s, iimiting water infiltration, and/or confining fluids.
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- 4. Page 1-8
- a. Fig. 1-5. The matrix does not include other alternative For design concepts which may be applicable to Maxey Flats.
example, our Research office is funding a project at the !
University of Arizona on using soil beams for trench cap stability. To the infiltration control techniques listed I should be added an evaluation of the Illinois Geological j Survey's study of the " wick effect" and Pacific Northwest Laboratories suggestion to use concrete tiles as well as {j Birney Fish's suggestion to use a metal shed over the site, '
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We believe that the potertial role that vegetation and other environmental parameters could play in limiting water infiltration and in dewatering the site has been ove-looked.
- 5. Page 1-7
- a. References should be given to the various inves,tigations so
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that a reviewer can judge if any important omisMons wcre made.
- 6. Page 1-9 j
- a. The diagram is confusing and several viable alternatives are j
omitted. See Pg. 1-8 *
- b. The design drcwing for the Native Soil / Bentonite option should be modified to show .a " bentonite-treated soil" fnstead of'
" bentonite." Pure bentonite is subject to excessive cracking upon drying. It is usually applied in a mixture with soil to minimize the probability of cracking and to keep costs low. q Acceptably low permeabilities can be obtained when the {
bentonite is mixed with local soils or lays. See also comment 9.b. for pages 3.20. {J
- 7. Page 1-10
- a. The basis fer h cost estimates shown here and en page 4-2 I' were not given. Therefore, we have not been able to evalutte these numbers.
- b. Part of Task 3 should include evaluating the potential of radioactive releases during the remedial action or as a result of the remedial action. l
- c. The tasks as proposed are a reasonable approach tcward developing a decommissioning plan. However implementation of the plan should include a complete evaluation of reasonatle alternatives, i
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- 8. Page 3-8
- a. It may be quite cost-effective and scientifically sound to employ methods which would involve remedial action on any subsidence and periodically replacing impermeable barriers.
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- 9. Page 3-18 To the list of capping ~ methods should be added such things as
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concrete tiles, vegetation, a metal shed, wick effect, plastic reen.branes , etc. Also, if this is to be a discussion (line 19) rather th6n a description, the pros and cons of the various techniques should be mentioned.
- 10. Page 3-20
- a. The section antitled " Bentonite" should be inodified to show that the bentonite would be mixed with native soil. It is possible that this will significantly reduce the cost estimates of using a bentonite cover.
- b. Bentonite. The State Geologist, Dr. Donald C. Haney should be consulted on the use of clays. Bentenite has a serious disadvantage -- it shrinks on drying. Bentonitir. soils usually exhibit what is called " pop cdrn" weathering which is an expression of this pruperty. Eastern Kentucky University had at least one M.S. dissertation or, clays in tne Maxey Flats- :
area. Estill 5 hale, which does not have bentonite, may prove to be a superior alternative.
- 11. Page 3-21
- a. Trench Stabilization. Throughout che program plan all stabilization attention is directed towardt settlement of trench caps. Attention shculd be given to minimizing water entry into trenches and water exit from them,
- b. Dynamic consolidation. The risk to operator safety sounds cuite hign. The high moisture content in the trenches (even if they ara 95% "dewatered") may result in increased of site
) releases.
- 12. Page 3-23
- a. Line 8. It seems as though the plan has rejected a few reasonable alternatives (see comments Pg.1-8). Seme of the discarded alternatives should be citea.
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- 13. Page 3-23
- a. On the list of characteristics we would again recommend including an effective surface water management system to minimize erosion.
- b. Last paragraph. We are in agreement that there are many.
existing alternative methods to decommission a shallow-land burial facility. However to instill public confidence it may be'necessary to cond::ct.a small scale demonstration project.
It should be recognized that it takes time, perhaps 5 years or-so, through several " unusually" wet or dry years, to get an adequate data base.
- 14. Pege 4-1
- a. This program plan should describe the potential .
l decommissioning scenarios evaluated. This would demonstrate if a reasonable suite of alternatives has been considered.
- b. 15 the th4rd paragraph of this page, it is. stated that "in-situ grouting and dynamic compaction both appear feasible." Although both methods are physically possible!it is questionable whether dynamic compactiow of low-level waste can be achieved without excessive short term releases or increases in the likelihood of future releases. Further, there is a question as to whether dynamic comptction can effectively stabilize the entire depth of the trenches. In addition, insitu grouting appears to be very expensive und therefore may not be cost effective.
l c. Paragraph 4. The concept of assuming more or less ' complete .
l stability of the trcnch cap is greatly over emphasized in Go j program plan. The alternative of accepting the site as it is, j and allowing for a modest amount of cap failure which could be !
handled by low cost maint6 nance, should be evaluated as to cost-effectiveness. :
- d. Paragraph 4. The decommissioning plan neglects the use of '
vegetation in reducing infiltration. This is an alternat1ve j which should be discussed,
- e. Paragraph 4. See comments on pg. 3-20 regarding bentonite. i i
- 15. Page 4-2
- a. Table 4-1. As noted earlier, there appecrs to be a mind-set ;
in the alternatives being considered. Therc are many other alternative design concepts which may provide cost-effective nethods of decommissioning Maxey Flats (see connents on pg.
1-5).
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- 16. Page 4-3
- a. Paragraph 2. The other low cost options alluded to should be part of the alternatives considered. Some of the ones put forth, although requiring some maintenance, might be done with very little continuing costs. For example, if a vegetative ,
cover were chosen, the u'-front p cost would be considerably less than the $35,000,000 shown on Table 4-1. A vegetative {
cover might require only the part time services of a local i j
farmer and periodic inspection by State Officials, )
17 Page 4-11 f
- a. The method 'or evaluating existing designs shows tour general topics for consideration, one of which is " safety end licensing." We feel that a best to worst ranking on this topic should only be done after determining that all designs to be evaluated meet safety requirements. Additionally, safety needs to be considered during the remedial action as well as after decommissioning. I
- b. Bottom of page, bullet 2. I do not think that just because so.nething is " automatic" you will ar rive at a design which is best suited to meet the needs. As noted above, if the basic premises in developing a decommissioning pian preclude some I reasonable, cost-effective alternatives, it will be I unfortunate.
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