ML20135B011

Informs That Decommissioning Activities Not Already Authorized by Existing License or by Commission Regulations Should Not Take Place W/O Prior NRC Approval,Per State of Il,Dept of Nuclear Safety Encl 850710 Request to USGS

ML20135B011
Person / Time
Site:	02700039
Issue date:	08/16/1985
From:	Fonner R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Moran E ILLINOIS, STATE OF
References
NUDOCS 8509100356
Download: ML20135B011 (5)

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• Title of file Ecmend B. Moran, Jr.

Assistant Attorney General Environ;r. ental Control Division 10D Wu t Randolph Street, 13th Floor Chicago, IL 60601

SUBJECT:

US ECOLOGY INC. SHEFFIELD, ILLIN0IS LOW-LEVEL WASTE BURIAL SITE By letter dated July 10,1985 (copy enclosed) Dr. Terry Lash, Director, IDNS recuested of Mr. Larry Tcler, District Chief, U.S. Geological Survey (USGS) that all USGS structures on the Sheffield low-level radioactive waste disposal facility (LLWDF) be removed or decommissioned by October 31, 1985.

This recuest was made of USGS without the knowledge or consent of the U.S.

Nuclear Regulatory Comission (NRC).

I remind you, and hope that you will remind Dr.' Lash, that the NRC continues to be the primary regulatory authority for the Sneffield LLWDF. Further, as you well know, there is currently a legal proceeding before the Atomic Safety and Licensing Board involving decommissioning to which the State of Illinois, the NRC and the site licensee, US Ecology Inc., are parties. For these reasons the NRC has a regulatory interest in any decommissioning activities associated with Sheffield. We are disturbed that IDNS has chosen to make this request of USGS without consultation with the NRC.

Decommissioning activities that are not already authorized by the existing 11.ms: Or ':j Cacdz;b, a:s ',etion3 stivoid not take piace without prior NRL approval.

In particular, some of the facilities which would be decommissioned as a result of Dr. Lash's request, particularly USGS monitoring wells, are, in the opinion of the NRC staff, an integral part of the post-closure activities associated with site decommissioning. The NRC's mandate for pr:to:tkr # pdlic health and safety, and the environment therefore dictates that we exercise our regulatory authority and not approve the removal of any facilities that we deem necessary for the protection of public health and safety.

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i Members of the NRC staff met with the USGS Office of Hazardous Waste Hydrology in Feston, VA on July 30, 1985. The staff indicated to USGS which of their monitoring locations are considered by NRC to be an integral part of the site closure plan. This information is attached.

I look forward to your full cooperation in this matter. If you have any questions about the contents of this letter please do not hesitate to contact me.

4 Sincerely, Robert L. Fonner, Deputy Director Regulations Division Office of the Executive Legal Director Counsel to NRC Staff

Enclosures:

1. Ltr to L. Toler from T. Lash dtd 7/10/85

2. USGS Monitoring Well Locations cc. Dr. Terry R. Lash

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STATE OF ILLINOIS DEPART.TIENT OF NUCLEAR SAFETY tc35 OUTER PARK DRIVE SPRINGFIELD 62704 (217) 546-8100 TE=Av R Lt ss DAN L. WILUAMs D aE *U oE*UTY olRECTOR July 10, 1985 Mr. Larry Toler, District Chief United States Geological Survey 102 East Main Street, 4th Floor Urbana, IL 61801

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Dear Larry:

The Department is actively pursuing decommissioning of the Sheffield low-level radioactive waste disposal site. While the steps necessary to accomplish this decommissioning are still being negotiated by the Department, US Ecology and the U.S. Nuclear Regulatory Comission (NRC), it is likely that application of a final cap will be required. This will necessitate removal of all structures on the site, in order to eliminate all controllable releases of e M ionuclides. One structure which concerns the Department is the tunnel built by the United States Geological Suryey (USGS) which has been proven to be a conduit for releases of radionuclides,.

In a letter dated April 17,1978 (copy attached), J.S. Cragwell, Jr.,

Chief Hydrologist for USGS made a commitment to use "the best available technology to remove and plug" any USGS structures on the Sheffield site.

This would include observation wells, the tunnel, and any and all support structures. Since the studies that use these structures will be completed in September,1985, I am requesting that these structures be removed and plugged to prevent the possibility of unnecessary leakage of radionuclides. I am  :

further requesting that these activities be completed by the end of October, '

1985.

In this regard, please submit within 60 days to this Department a plan for removing and plugging the USGS structures on the Sheffield site. This plan should provide detailed information on the technologies you plan to use to accomplish this task.

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, Mr. Larry Toler

". July 10, 1985 If you have any questions on this matter, please contact Mr. David Flynn of the Department's Office of Environmental Safety. Thank you for your continued cooperation.

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Terry t. Lash 1

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USGS Monitoring Well Locations Considered to be an Integral Part of Post Closure Monitoring and Surveillance of the Sheffield LLWDF USGS Well Number Location 511 or 548 West of Site 519 Vic. Tr. 18 520 Vic. Tr. 18 513 North of Site 514 North of Site 515 North of Site 518 North of Site 554,555,556,557,516(oneonly) North of Site 535 or 55.' North of T-23 539 or 538 North of T-14 549 or 529 South of T-14 531 South of SW Corner 530 South of Trench 11 510 South of SW Corner 523 South of. Trench 11 524 South of Trench 11 527 South of Trench 11 l 537 East of Site 504 East of Site 505 East of Site 564 NE of Site 5-6 Wells in Preferential Migration Pathway NE of Site 3-4 Wells, including 602, between SE corner of site and strip mine pond Note: These USGS wells in conjunction with other wells on and in the vicin!ty of site would be part of a post closure monitoring plan. Sampling locations may be reduced at the end of a post-closure observation period.

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