Technical Note
ORP/LV-76-3
REVIEW OF STATE LICENSES FOR
DISPOSAL OF LOW-LEVEL RADIOACTIVE
WASTE BY SHALLOW LAND BURIAL
JUNE 1976
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF RADIATION PROGRAMS
LAS VEGAS FACILITY
LAS VEGAS, NEVADA 89114
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Technical Note
ORP/LV-76-3
REVIEW OF STATE LICENSES FOR
DISPOSAL OF LOW-LEVEL RADIOACTIVE
WASTE BY SHALLOW LAND BURIAL
Bruce J. Mann
Donald J. Nelson
June 1976
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF RADIATION PROGRAMS
LAS VEGAS FACILITY
LAS VEGAS, NEVADA 89114
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This report has been reviewed by the Office of Radiation Programs-
Las Vegas Facility, U.S. Environmental Protection Agency, and
approved for publication. Mention of trade names or commercial
products does not constitute endorsement or recommendation for
their use.
11
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PREFACE
The Office of Radiation Programs of the U.S. Environmental
Protection Agency carries out a national program designed to
evaluate population exposure to ionizing and non-ionizing radi-
ation and to promote development of controls necessary to protect
the public health and safety and assure environmental quality.
Within the Office of Radiation Programs, the Las Vegas
Facility conducts in-depth field studies of various radiation
sources and provides other technical support for a variety of
(ORP) program activities. This report was conducted in support
of the ORP radioactive waste management program.
Comments on this review would be appreciated. These should
be sent to the Director, Office of Radiation Programs-Las Vegas
Facility-
Donald W. Hendricks
Director, Office of
Radiation Programs, LVF
111
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TABLE OF CONTENTS
Page
PREFACE iii
LIST OF TABLES V
ACKNOWLEDGMENT vi
SUMMARY AND CONCLUSIONS 1
INTRODUCTION
Purpose 2
Summary of Recent Developments 2
Historical Background 3
Identification of Technical and Policy Issues 4
LICENSE ADMINISTRATION 6
Purpose of License 6
Authority and Scope 6
Application Policy for License 10
Financial Responsibility, Reports, and Records 10
Enforcement 11
LICENSE FORM AND CONTENT 14
Supporting Information 14
License Form 15
License Conditions and Performance Requirements 15
REFERENCES 19
APPENDIX A-l
IV
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LIST OF TABLES
Table Page
1. Regulation of Radioactive Waste Disposal
Sites 7
2. Scope and Authority for Specific Burial
Site Licenses 8
3. Current Form for State Low-Level Radioactive
Waste Burial Site Licenses 16
v
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AC KNOWLED GHENT
This report was produced primarily from information provided
by radiation control program officials in Illinois, Kentucky,
Nevada, New York, Oregon, South Carolina, and Washington. Their
assistance is appreciated. The accuracy of the information pre-
sented is solely the responsibility of the authors, however.
VI
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SUMMARY AND CONCLUSIONS
This paper reviews state licenses for burial of radioactive
waste by commercial firms. The terms and conditions contained in
licenses issued by the States of Illinois, Kentucky, Nevada, New
York, South Carolina, and Washington are summarized. For illus-
tration, a license developed for a proposed commercial site in
the State of Oregon is included as an appendix.
The procedures and mechanics of license development and
administration are reviewed. This information is derived from
questionnaires sent to state radiation control officials, sup-
plemented by recent literature and personal communications with
knowledgeable officials in state and Federal agencies.
A review of problems encountered with the burial sites and
the administration of licenses reveals a number of unresolved
difficulties. Some of these concerns have been previously ad-
dressed by the Conference of Radiation Control Program Directors
Task Force on Radioactive Waste Management (Cashman, 1973, 1974),
and by the Federal General Accounting Office (GAO, 1976). Addi-
tional problems, not noted elsewhere, in the area of license
enforcement, are reviewed herein.
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INTRODUCTION
PURPOSE
In 1972, a questionnaire was sent to radiation control pro-
grams of the six states in which commercial radioactive waste
burial sites are operated. This survey was performed by the En-
vironmental Protection Agency in conjunction with the Conference
of Radiation Control Program Directors Task Force on Radioactive
Waste Management (Cashman, 1973).
Information was collected on a number of subjects relating
to burial site licensing and license administration. It was sub-
sequently used by the Task Force as the basis for recommendations
to the Conference. A systematic compilation of the information
collected has not been published, however.
This report, which is concerned with burial site licensing,
attempts to summarize information obtained from the questionnaire
responses and other sources of recent information. It is intended
to assist those concerned with the development of licensing cri-
teria, review of license applications, and the administration of
existing licenses. As an example, a license (which was not issued)
developed by the State of Oregon in 1974 for a radioactive waste
and hazardous chemical burial site is included as an appendix to
this report.
SUMMARY OF RECENT DEVELOPMENTS
A number of problems, which relate in part, to licensing and
regulation of commercial radioactive waste burial sites have been
experienced in recent years. A recent report of an investigation
by the Federal General Accounting Office summarized problems
encountered at Federal and commercial burial sites and identified
a number of deficiencies in Federal regulatory programs for
commercial burial sites (GAO, 1976).
The Nuclear Fuel Services (NFS) site in West Valley, New
York, was closed by NFS in March 1975, upon the discovery that
water containing tritium and strontium-90 had seeped from a
burial trench (Nucleonics Week, 1975). A request was made by NFS
to New York State regulatory authorities for clarification of
operational requirements in order to control the problem.
In early 1975, the Kentucky Department for Human Resources
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(KDHR) reported that off-site migration of radioactivity from the
Nuclear Engineering Company (NECO) Maxey Flats burial facility
had been observed (Hardin, 1975). The KDHR subsequently requested
guidance from the EPA concerning the development and application
of "as low as practicable" criteria for radioactivity released to
the environs from the burial site. A detailed review of the data
and developments associated with the occurrence of off-site
migration at the Maxey Flats site has been recently published
(Meyer, 1976).
The Nuclear Engineering Company (NECO), Beatty, Nevada
burial site license was suspended by the State of Nevada in March
1976. The license was suspended and operations terminated when
it was determined that materials intended for burial had been
removed rom the site by employees for a number of years (Trounday,
1976) .*
HISTORICAL BACKGROUND
Production of significant quantities of radioactive waste in
the United States began during World War II with the Federal pro-
gram to develop nuclear weapons. Since that time, control of
radioactive waste material has been achieved by temporary storage,
placement in the ground by a variety of means, and by disposal at
sea. With the exception of ocean disposal, these activities were
initially conducted at laboratory or test sites owned by, and op-
erated under the jurisdiction of the Federal Government.
The U.S. Atomic Energy Commission (AEC) gradually phased out
commercial ocean dumping in the 1960's (Belter, 1970). In 1960,
the AEC published criteria for selection, licensing, and operation
of commercial waste burial facilities (AEC, 1960). These guidelines
included a number of considerations, which are summarized here:
1. The location of burial sites on state- or Federal
Government-owned land, under long-term Government
control to assure protection of public health and
safety.
2. Site selection based on detailed studies of geologic,
hydrologic, and topographic factors which would result
in a site with maximum inherent retention capability for
radioactivity. Containment would be assured primarily
by site characteristics with little reliance on waste
containers.
* The suspension was lifted by the State of Nevada in May 1976,
following an investigation which determined that a public hazard
did not exist. The suspension was lifted subject to the strength-
ening of inadequate security measures at the site which had in-
volved "breaches of the license" (Nevada, 1976).
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3. Emphasis would be placed on operating and monitoring
practices, including radiation surveillance of surround-
ing areas to insure that the opercition is conducted in a
safe manner.
4. These sites would be used for the disposal of low and
intermediate level wastes only.
In 1962, the first license was granted to the Nuclear Engi-
neering Company for the operation of a commercial radioactive
waste burial facility at Beatty, Nevada. The number of sites
increased to the present six with the opening of the Chem-Nuclear
Systems, Inc. site at Barnwell, South Carolina in 1971. Proposals
have been made for additional sites in several other states in
recent years, but no other sites have been approved or licensed.
IDENTIFICATION OF TECHNICAL AND POLICY ISSUES
Concern has been expressed by a number of state and Federal
officials about the proliferation of commercial burial sites in
the absence of a national plan. This matter headed the list of
issues which had been identified by the Task Force on Radioactive
Waste Management in its report to the 1974 Conference of Radiation
Control Program Directors (Cashman, 1974). The AEC had also
issued recommendations for requirements for new burial site
license applications in response to the concerns over burial site
proliferation and related issues (AEC, 1974).
The 1974 Task Force report (Cashman, 1974) recommended the
following requirements for new site license applicants:
1. The need for a new site should be demonstrated by the
applicant and supported by an analysis of the economic
impact on existing sites.
2. Applicants for burial site licenses should complete a
full environmental report including a detailed cost-
benefit analysis.
3. Information should be provided on the proposed funding
of perpetual care and maintenance programs for each site,
to be administered by the appropriate state agency-
4. Plans for site decommissioning, including cost estimates,
should be provided by the applicant prior to the licensing
of a new site.
A number of other issues have been identified which effect
license terms and conditions concerning the definition of materials
which are acceptable for burial in commercial sites. The AEC
proposed in 1974 to prohibit land burial of wastes containing
transuranium elements in concentrations greater than 10 nanocuries
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(nCi) per gram (AEC, 1974). In January 1975, the newly-formed
Nuclear Regulatory Commission (NRC) inherited those regulatory
programs and functions formerly vested in the AEC. The proposed
AEC rulemaking action on transuranic wastes is currently under
review by the NRC (Chapman, 1975). The Task Force developed in-
terim guidance for states to apply to existing site licenses in
its 1974 report to the Conference (Cashman, 1974).
The Task Force recommended that each package of waste intended
for nonretrievable burial in commerial sites contain less than 10
nCi/gm of plutonium. This restriction should be specifically
stated as a license condition. It was anticipated by the Task
Force that the implementation of such a policy for plutonium
would establish a procedure that could be subsequently applied to
other transuranics (Cashman, 1974). Several states have subsequent-
ly issued license amendments to existing sites prohibiting burial
of plutonium. Final guidance concerning the administration of this
requirement by the states remains to be given pending publication
by the NRC of the final rule-making action.
Additional Task Force recommendations concerning the nature
of materials acceptable for burial at commercial sites are sum-
marized from the 1974 report (Cashman, 1974):
1. Non-radioactive toxic chemicals and wastes should be
excluded from disposal at sites designated for radio-
active waste burial.
2. Pyrophoric materials, gases compressed to greater than
1.5 atmospheres, and bulk-unsolidified radioactive waste
liquids should be excluded from burial.
3. Existing commercial sites meeting requirements for dis-
posal of wastes from nuclear power plants, hospitals,
and laboratories should not be used to dispose of high-
volume, low-specific activity wastes such as uranium mill
tailings.
As indicated by the discussion above, a number of issues have
been identified concerning the siting, licensing, management, and
regulation of the burial sites. The criteria published by the AEC
in 1960 have been expanded to include a number of specific issues
which have surfaced during the past 14 years of experience with
the commercial sites. It is noted that several of the states have
recently, or are presently, rewriting their site licenses, moti-
vated in part by the desire to incorporate some of the specific
items that were not included in the original licenses. It is also
worth noting that the burial site operations and their regulation
are under a great deal more public and technical scrutiny than
when they were originally licensed. The general trend is to in-
clude more conservative criteria in the licenses than existed at
the time of the original licensing.
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LICENSE ADMINISTRATION
PURPOSE OF LICENSE
Poorly managed and controlled radioactive waste disposal
sites pose a potential hazard to public health and safety and
have the potential of denying portions of the environment to
safe, long-term human occupancy. Burial site licensing and
regulation generally fall under the purview of state codes and
regulations (within the framework of NRC agreement state programs
where applicable) for the control of radioactive materials.
In most cases, several state agencies may be involved with the
administration of site licenses and leases. In those states in
which the burial site is located on state-owned land, the site
is leased by the operator from the state with the lease being
under the administration of a designated agency. A particular
agency is identified as the state executive agency and grants
licenses or permits for the possession, use, and disposal of
radioactive material in conformity with state statutes and appli-
cable Federal laws. The license is the authority for the company
to operate a waste burial site in the state receiving remuneration
for accepting and disposing of radioactive waste materials.
AUTHORITY AND SCOPE
Table 1 shows the governmental authority structure for the
development of licenses or other regulatory management of waste
disposal sites. Table 2 summarizes the scope and authority for
the specific burial site licenses. Federal regulations require
the licensing of persons who carry out land burial of solid
wastes contaminated with radioactive materials.* The license may
be issued by the NRC or an "agreement state" (i.e., one which
licenses certain activities under agreement with the NRC pursuant
to 42 U.S.C. 2021). The agreement authorizes the state to regu-
late by-product, source, and limited quantities of special nuclear
material. The state may require additional operating permits for
the control of air and water pollution of a non-radioactive
nature. In states without agreements with the NRC to license
radioactive material, authority to license burial of radioactive
wastes is retained by the NRC; however, certain controls regarding
use and operation of a waste disposal site are required by indi-
vidual state regulations.
* Radioactive materials herein refers to those materials designated
in 10 CFR 20 as "by-product", "special nuclear", and "source"
materials, and defined therein.
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TABLE 1. REGULATION OF RADIOACTIVE WASTE DISPOSAL SITES
Basic Statutes and Regulations
Energy Research and Development Act 1974
National Environmental Policy Act 1969
Atomic Energy Act 1954 (and amendments)
Public Health, Sanitary, and Safety Codes (States)
Radiation Control Acts (States)*
Federal Agencies
Department of Transportation (DOT)
Nuclear Regulatory Commission (NRC)
Environmental Protection Agency (EPA)
State Agencies
Environmental Protection
Public Health or Human Resources
Atomic Development
Commerce
Department of Conservation and Natural Resources
Regulatory Actions
Issue license to receive, possess, use, and dispose of
radioactive material (NRC and states)
Publish rules for safe use and radiation protection (NRC)
Publish rules for transportation of radioactive wastes in
interstate commerce (DOT)**
Transfer authority to state to license radioactive material
under agreement (NRC)
Establish generally applicable environmental standards (EPA)
* Generally referred to as "enabling legislation" which provides
for promulgation of specific radiation control regulations by
the states.
** Intrastate transport of radioactive materials does not fall
within the purview of DOT. Several states have issued regu-
lations concerning intrastate transportation which includes
the provisions of the DOT regulations.
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TABLE 2.
SCOPE AND AUTHORITY FOR SPECIFIC BURIAL SITE LICENSES
STATE
SCOPE OF LICENSE
AUTHORITY
(OR PRIMARY ENABLING LEGISLATION)
Illinois
(Sheffield
Nuclear Center)
Kentucky*
(Maxey Flats)
CO
"purchase, lease, accept or acquire
suitable site for the concentration
and storage of radioactive wastes"
(In this state, the NRC licenses
the disposal operation)
"receive, possess, package, store
and dispose of radioactive material
at ... subject to all applicable
rules and regulations"
Radioactive Waste Act, 1963,
Chap. 111.5, Sec. 230 of Il-
linois revised statutes (Di-
rector of Public Health)
Kentucky Board of Health Re-
gulations KRS 152.105 et seq,
to orders of Kentucky Dept.
of Health, Rad. Health Prog.
Nevada*
(Beatty Facility)
"receive, process, package, store
and dispose of by-product, source
and special nuclear material"**
State of Nevada Revised Stat-
ute 459 "Nuclear Affairs"
New York*-
(West Valley
Site)
"receives solid radioactive wastes
packaged as designated, bury waste
by licensed procedures, maintain
insurance from liability, special
services from technical personnel
available for damaged or non-
compliant packages"
New York State Sanitary Code
(Exemption form Sec. 16.8,
part 16) Responsible for New
York Public Health Laws,
Waste Agreement with Atomic
and Space Development Agency,
also Dept. of Environ. Cons.
Chap. IV, part 380
* NRC Agreement State
** Currently amended to include the 10 nCi/gm limitation on plutonium.
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TABLE 2. SCOPE AND AUTHORITY FOR SPECIFIC BURIAL SITE LICENSES, CONTINUED
STATE
SCOPE OF LICENSE
AUTHORITY
(OR PRIMARY ENABLING LEGISLATION)
South Carolina*
(Barnwell Site)
"receive, possess, store, and
dispose of radioactive material
at locations designated"
Atomic Energy and Rad. Control
Act of 1962 Code of Laws of
S.C. S.C. State Board of
Health Rules and Regulations,
Title A, part I
Washington*
(Richland Site)
"to receive, possess, repackage,
store, and dispose by burial in
the soil . . . waste materials"
Nuclear Energy and Rad. Control
Act RCW 70.98 and Rules and
Regulations, Washington State
Department of Social & Health
Services
NRC Agreement State
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In summary, the three companies now operating the six waste
disposal sites hold licenses or permits to bury radioactive mate-
rial issued directly from the NRC or by an agreement state for
the Federal Government.
APPLICATION POLICY FOR LICENSE
As a part of the procedure for licensing low-level radioactive
waste disposal sites by a state, the applicant for a license is
required to follow certain policies and provide information to
the responsible state agency. Although the requirements may vary
by state, the following provisions must generally be satisfied
prior to the granting of a license:
1. Disposal of waste should be on state- or U.S.-owned land.
2. Technical information on site and operating procedures
should be supplied by an applicant for a license.
3. Financial arrangements, such as trust funds, should be
made to cover costs of maintaining the site, including
surveillance in perpetuity.
4. The site operator should include a provision for liabil-
ity insurance coverage.
5. An environmental impact assessment of the proposed
burial site and its operation will be required for new
sites (Stanford, 1975).
6. A public hearing should be held and a review be conducted
by other agencies having responsibility for any aspect
of the operation.
FINANCIAL RESPONSIBILITY, REPORTS, AND RECORDS
Financial responsibility provisions of the licenses, in the
case of the states in this evaluation, are as follows:*
1. License fees payable to the states range up to $3,000
annually- In one case, fees were paid to both state and
Federal licensing agencies. Federal NRC charges are an
initial fee of $500 with a proposed annual fee of $300.
2. Performance bonds of up to $500,000 are generally requested
to be posted by site operators, if available.
* Most of the states are currently in the process of reviewing
license fees, bonding requirements, and perpetual care fund
assessments with increases in nearly all cases to be expected.
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3. Liability insurance is specified in license documents in
the minimum amount of one (1) million dollars.
4. Licensee burial charges to customers range up to about
$2.50 per cubic foot of waste buried, of which a specified
amount is allocated to perpetual care funds (currently
ranging up to $0.25 per cubic foot of waste buried. In
addition to burial charges, other charges may be imposed
on customers by the site operators to cover special
handling and packaging, for example.
Periodic reports are required of the licensees on such matters
as waste receipts and environmental monitoring. Special reports
may be required for incidents such as accidents, radiation expo-
sures, contaminating events, uncontrolled releases of radioactive
material to the site environs or other specified events as required
by license conditions. Financial record keeping and reporting is
generally the same as required by Federal and state regulations
for any similar business enterprise.
For each shipment of waste received at a burial site, a re-
ceipt form is completed. These are generally referred to as radio-
active shipment records (RSR's). The site operators, in some cases,
are required to send a copy of each RSR to the appropriate licens-
ing agency, while in other cases, are merely required to maintain
a copy on site for inspection upon request.
The RSR contains information identifying the origin of the
waste, estimates of quantities of source material, by-product
material, or special nuclear material and quantities of specific
isotopes where appropriate. The site operator is generally re-
quired to keep a log of receipts and a record of burials in the
trenches. The logs and operational records of the licensees are
also made available to licensing agency officials for inspection
upon request.
ENFORCEMENT
License administration and enforcement are generally conducted
by the states through several means. Requests for amendments and
exemptions concerning specific license conditions are routinely
received and reviewed. In routine or non-controversial cases,
decisions on such requests are usually made by officials of the
licensing agency, and formal notification is made to the site op-
erator. In controversial or contested actions, a hearing can be
convened to review pertinent information and obtain testimony
from interested parties. State officials also review reports
submitted by burial site operators on environmental monitoring,
radioactive waste inventories, and other topics.
In conformance with NRC agreement state arrangements, periodic
on-site inspections are conducted by state officials. In most of
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the states, this occurs at least semiannually, and the trend is
toward more frequent inspections. For those sites holding NRC
licenses, additional inspections are conducted by the NRC.
If deficiencies in the site operation, or violation of
license conditions are discovered, several kinds of enforcement
action are available to the state agency- In most cases, a
letter of non-compliance is written to the licensee to which the
licensee is requested to respond within a specified period indicating
how the condition(s) of non-compliance will be corrected. The
state can subsequently conduct a follow-up inspection, if necessary,
to determine compliance.
Should the above described actions yield unsatisfactory re-
sults, or in the case of serious or flagrant and continued viola-
tions, the state can issue a formal "show cause" order. This
gives the licensee a specified period to show cause why the
license should not be suspended or revoked. In at least one
case, this mechanism has been used by a state to gain compliance
with license conditions (McElwain, 1972). In the case of an
emergency situation, i.e., where the potential exists for public
hazard, a burial site license can be suspended by state authorities
on immediate notice, as done recently by the State of Nevada
(Trounday, 1976) .
In addition to suspension or revocation of licenses, other
sanctions are available such as fines and penalties under state
civil codes. As far as is known, however, these have not been
applied to burial site licensees to date.
Several problems have been encountered in the area of enforce-
ment. Most licenses do not contain provisions for identifying
exactly what constitutes non-compliance with license conditions
on the part of the licensee. As expected, this is a matter of
judgment on the part of licensing agency officials, particularly
on items which appear to be less than "flagrant" violations.
To date, the states have largely relied on voluntary corrective
action by the licensees in regard to correcting noted deficiencies
and items of non-compliance. In several cases where this has not
been forthcoming, there has been little success in obtaining com-
pliance short of issuance of a "show cause" order for license
revocation. Application of effective intermediate sanctions
such as fines by the states has not been achieved, partly due to
the difficulty in imposing civil penalties in the face of legal
resistance on the part of licensees.
The recent GAO report (GAO, 1976) contains a discussion of
regulatory problems encountered at several of the commercial
burial sites, with recommendations to the NRC for improving
regulatory efforts.
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It should be noted that effective administration of commercial
radioactive waste burial site licenses has required the expenditure
of significant financial and manpower resources by the state agen-
cies concerned. In several of those states with relatively modest
radiation control programs, the burial sites have required a dis-
proportionate share of the program resources.
A number of problems, such as too infrequent inspections,
insufficient environmental monitoring by the states, and lengthy
response periods to license amendment and renewal applications,
could be relieved if a way could be found to provide adequate
resources for operation of several of the state radiation control
programs.
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LICENSE FORM AND CONTENT
SUPPORTING INFORMATION
Any applicant for a burial site license is required to
submit supporting information. This information includes reports
of site characteristics, operation and safety manuals, and other
material in response to specific requests by the licensing agency.
Such information assists the agency in determining the suitability
of the proposed site and the fitness of the applicant to carry
out the operation of the activity in a safe and responsible
manner. It is also generally used as the basis for setting
technical conditions and operational requirements, and in such
case, would be incorporated in the license by reference.
Supporting documentation describing the site and its environs
should include:
1. General descriptive material including location, land
use, and population distributions for the site environs.
2. Topographical, geographical, meteorological, geological,
and hydrological characteristics with analysis and
evaluation related to the disposal site operation.
3. Proposed radiological and hydrological monitoring proce-
dures, including well log data, water quality surveys,
and the air sampling program.
Operations and safety manuals should include descriptions
of:
1. Qualification and training of personnel in key areas of
radiation monitoring and health physics practices rele-
vant to burial site operation.
2. Radiation protection procedures and instrumentation.
3. Burial site operating facilities and equipment.
4. Receipt, handling, and burial of wastes, including
trench management.
5. Emergency procedures.
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The NRC will require applicants for new burial site licenses
to file an environmental report. The required environmental
report should contain a cost-benefit analysis for the proposed
operation. An analysis which predicts the transport of radio-
nuclides from buried waste materials through the geologic media
to off-site environs shall be developed by the applicant and
included in the environmental report (Stanford, 1975).*
LICENSE FORM
The licenses themselves, as issued originally without amend-
ments, generally are fairly short documents. Most include a
great deal of material by reference, as indicated. Referenced
often are the regulations of the Department of Transportation
(DOT)(49CFR173-179) relating to packaging of radioactive materials,
marking and labeling of the package, placarding of transportation
vehicles, and transportation accident reporting.
Also referenced are state rules, regulations, or standards
for atomic energy, health, environmental protection, and radiation
control.
Table 3 summarizes the form of the current licenses. In
most cases, the licenses have been changed and expanded through
the addition of amendments subsequent to the issuance of the
original license.**
LICENSE CONDITIONS AND PERFORMANCE REQUIREMENTS
Although there are variations between the six disposal
sites, the following requirements or license conditions were
present either in the license itself or in statements of responsible
state officials describing operations at the burial sites, in
response to the Task Force questionnaire.
1. Radioactivity limits are usually the amount expressed as
a possession limit for the operator or as permitted for
storage above ground prior to burial. Typical values
are: a) 50,000 curies of by-product materials, b) 4,000
to 60,000 pounds of source materials, and c) 350 grams
* At the time the licenses were issued for the existing sites,
criteria and guidance for environmental assessments as current-
ly applied to environmental reports were not available.
** The six commercial site licenses have been amended numerous
times by letter so that the actual size of the file, including
amendments, may be 10 to 20 times that of the original license.
Also included, by reference in the licenses, is a considerable
amount of additional material on regulatory, administrative,
and technical aspects.
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TABLE 3. CURRENT FORM FOR STATE LOW-LEVEL RADIOACTIVE WASTE BURIAL SITE LICENSES
STATE
ISSUE
YEAR*
LENGTH OF
LICENSE**
TERMS AND CONDITIONS
REMARKS
Nevada
1965
8
Illinois
1966
11
South
Carolina
Kentucky
1971
1967
Basic authority to possess
and bury waste under 21
conditions
Radioactive Waste Act (3
pages) authority to acquire
site and Dept. of Health
Criteria (8 pages) 30 con-
ditions
Authorizes receipt and
burial under 26 conditions
Authorizes burial of waste
under 24 conditions
Numerous amendments, exemp-
tions , and procedural changes
since 1965 AEC License 4-
37661. Ref. to Fed. Reg.
AEC 10CFR20,30,40, and 70,
DOT Regs, and Nevada Codes
State statute for site acqui-
sition with published criteria
for selection of site and su-
pervision of operation of
waste disposal site, state
leased site 1966
Ref. to State and Federal
rules and regs. for radiation
protection and transportation
Ref. to State and Federal
transportation, safety, and
radioactive protection stand.
Washington 1965
New York
1963
Basic radioactive materials
use license stating materi-
als, form, and amounts for
burial under 16 conditions
Authorizes operation of
radioactive waste disposal
site under 26 general terms
and conditions
Ref. to separate State letter
procedures for trenching.
Also State and Federal rad.
and transportation regs.
General r.ef. to State and
Federal regs., initial license
as exemption to State Sanitary
Code (1963)
**
Year of issue of license in effect at time of 1972 questionnaire, several have since
been renewed or have renewals pending.
Single spaced, pages typed.
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of uranium-235, 200 grams of uranium-233, 200 grams of
plutonium*, or the weighted sum limit.** If possession
is requested for more than the above specified amounts
of special nuclear material, a nuclear safety analysis
must be performed, which demonstrates that accidental
criticality cannot occur. Storage time above ground is
generally limited prior to burial. (Additional amounts
of tritium, krypton-85, and special nuclear material may
be allowed by a specific license amendment.)
2. A daily log of waste received is normally maintained by
the site operator showing quantity, type, and origin
with container dose rates and transport class specified.
3. In some cases, periodic summary reports are required for
submission to the state agency, including volume, activ-
ities, grams of special nuclear material, pounds of
source material, curies of by-product material, and
form of waste handled during the reporting period.
4. Burial trench specifications are usually indicated with
provisions for control of water in exposed trenches. A
separate, permanent concrete or metal marker indicating
basic information on buried material is required in most
cases, to be placed at each end of filled trenches.
5. Pyrophoric or explosive material is prohibited in at
least one site.
6. Site safety and fire protection is specified by reference
to appropriate state regulations.
7. Radiation protection standards are included by reference
to state and Federal regulations. Normally, NRC Regula-
tions 10CFR20, 40, and 70, or equivalent state radiation
control regulations are referenced.
8. The activities of the operator in the transportation of
radioactive materials are required to be in conformance
with U.S. Department of Transportation regulations (10
CFR71.5b references DOT regulations for shipment of
radioactive materials) for interstate shipment.
* The imposition of the limitation of wastes bearing transuranium
elements to less than 10 nCi of such nuclides per gram of waste
would effectively remove plutonium from criticality safety
considerations.
** The weighted sum limit cannot exceed unity and is determined
by summing the ratio of each isotope present to the allowable
limit in cases where more than one species of special nuclear
material is present.
17
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9. Determination of radioactivity levels in surface and
ground-water is generally required and, in some cases,
soil and vegetation sampling, on a quarterly or monthly
basis, is specified.
10. Other license terms of an administrative nature include:
a. Designation of operators and radiation safety or
health physics staff.
b. Location of disposal operations.
c. Burial charges.
d. Leasing of land.
e. License fees.
f. Insurance.
11. Actions permitted by special written authority of the
state have included:
a. Solidification of certain liquid wastes.
b. Dewatering and storage of contaminated ion-exchange
resins.
c. Burial of high specific activity radioactive wastes
when packaging is concrete and metal, or as approved
by the licensing.
d. Burial of wastes that are both chemically toxic and
radioactive.
18
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REFERENCES
Atomic Energy Commission, Memorandum to Agtie.e.me,nt Status, January
16, 1974
Atomic Energy Commission press release, AEC Formulate.* Policy {oi
Land Vi.&po&a.t ofi Radtoacttve. Watte.*: Govifinme.yit-Contn.ol.Liid
S-Lte.t to be. Ettab£tthe.d at Needed, January 28, 1960
Atomic Energy Commission, Tsiantu/iantc. (Matte. Vttpotat, Federal
Register, Vol. 39, No. 178, p. 32921, September 12, 1974
Belter, W. G. , Re.ce.nt De.ve.topme.ntt -in the. UnJ.te.d State.* Low-Le.ve.£
Radioactive. Watte. Manage.me.nt Vn.oQHa.m--k Px.e.vte.w ^on the. 1970'A
in "Management of Low- and Intermediate-Level Radioactive
Wastes", IAEA Vienna, 1970
Cashman, Thomas J., Re.poftt o& the. Tatk Fofice. on Radioactive. Watte.
Manage.me.nt, in "Proceedings of the 5th Annual National Con-
ference on Radiation Control, May 6-10, 1973, Portland,
Oregon", DREW (FDA) 74-8008, pp. 132-137, October 1973
Cashman, Thomas J., Re.poit o& the. Tatk Voice, on Radtoactive. Watte.
Manage.me.nt, in "Proceedings of the 6th Annual National Con-
ference on Radiation Control, April 28-May 2, 1974, San
Antonio, Texas", DHEW (FDA) 75-8010, pp. 56-62, October 1974
Chapman, K. R., Director, Office of Nuclear Material Safety and
Safeguards, Nuclear Regulatory Commission, T'e.t>t-Lmony Be.{,on.e.
Jo-int Commj.tte.e. on Atomic. Ene.^gy, Nove.mbe.1 9, 7975, Atomic
Energy Clearing House, Vol. 21, No. 47, pp. 13-21, November
24, 1975
General Accounting Office, Comptroller General of the United States,
Report to Congress, lmpSiOve.me.ntA Weeded -in the. Land V
-------
Meyer, G. L., VtuiLi.mA,nci?iij Vata on tko, OccuA/Lence ojj
NucttdzA -in the, Env-i/ionmant at the. R a. dto active.
S^te., Maxey F-tatA, Kentucky; in "Transuranium Nuclides in
the Environment", IAEA Proceedings Series, Vienna, 1976,
p. 231-270.
Nevada Department of Human Resources, News Release, May 25, 1976.
Nucleonics Week, WFS ka& CloA&d Down i.t& Low-Lzval Ua^te,
Fac.
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APPENDIX
LICENSE CONDITIONS
DEVELOPED BY OREGON DEPARTMENT OF
ENVIRONMENTAL QUALITY FOR A PROPOSED
COMMERCIAL HAZARDOUS WASTE DISPOSAL SITE
This section contains the license developed by the Oregon
Department of Environmental Quality for a proposed site for dis-
posal of radioactive and chemically hazardous wastes. It was
included in the record of the public hearing conducted by the
Oregon Environmental Quality Commission on September 6, 1974,
in Dalles, Oregon. The draft license is intended to provide an
example of the terms and conditions which comprise a license
for a commercial radioactive waste burial site.
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A. GENERAL CONDITIONS
Al. Authorized representatives of the Department of Environmental
Quality (hereinafter referred to as the Department) shall
have access to the site, at all reasonable times, for the
purpose of inspecting the site and its facilities and the
records which are required by this license.
A2. The Department, its officers, agents and employees shall not
have any liability on account of the issuance of this license
or on account of the construction, operation or maintenance
of facilities permitted by this license.
A3. The issuance of this license does not convey any property
right or exclusive privilege, except pursuant to the lease
for the State-owned portion of the site, nor does it autho-
rize any injury to private property or any invasion of
personal rights, nor any violation of Federal, State, or
local laws or regulations.
A4. The Department may revise any of the conditions of this li-
cense or may amend the license on its own motion in accordance
with applicable rules of the Department.
A5. Transportation of wastes to the site by or for the licensee
shall comply with rules of the Public Utility Commissioner
of Oregon, the State Health Division, and any other local,
State, or Federal agency having jurisdiction.
A6. A complete copy of this license and approved plans and pro-
cedures shall be maintained at the site at all times.
A7. The licensee shall not conduct, or allow to be conducted,
any activities that are not directly associated with the
construction, operation, or maintenance of the disposal
facilities at the site as authorized by this license, with-
out written approval from the Department for such other
activities.
A8. The licensee shall not sell or otherwise dispose of any por-
tion of the site without prior written approval from the
Department. This condition shall survive the expiration,
revocation, suspension, or termination of the license for any
reason other than those specified in condition C7, for a peri-
od of two years during which time the Department shall have
exclusive right and option to purchase all of the site and
improvements thereon not theretofore deeded to the State at
book value of the site and improvements on the books of the
licensee, net of depreciation and depletion.
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B. SPECIAL CONDITIONS
Management of the site, including all activities related to pro-
cessing, treatment, handling, storage, and disposal of wastes at
the site, construction and maintenance of facilities at the site,
and monitoring and maintenance of records concerning operation of
the site shall conform with the following conditions, limitations,
and provisions:
Bl. No construction activities related to waste disposal facili-
ties at the site may be undertaken by the licensee until the
Department has approved in writing final plans for facilities
proposed by the licensee.
B2. Following written approval by the Department of final detailed
engineering plans, the licensee shall proceed expeditiously
with, and complete, construction of the approved facilities.
B3. No disposal activity may be undertaken by the licensee until
the Department has inspected the site and certified in writing
that the facilities provided for disposal activities are sat-
isfactory and comply with approved final detailed engineering
plans.
B4. Following certification of the site and facilities (condition
B3), the licensee shall commence operation of the site and
facilities as soon as possible thereafter. Operation shall
not be discontinued without the approval of the Department,
except for temporary work suspension caused by conditions
beyond the control of the licensee such as, but not limited
to, labor disputes, weather conditions, equipment failure,
shortages of materials, or unavailability of qualified per-
sonnel. In the case of a temporary discontinuance of disposal
activities which exceeds 5 working days, the licensee will
notify the Department in writing, giving the reason for the
shutdown, and the estimated time of the temporary closure.
B5. Conditions Bl, B2, B3, and B4, and other conditions of this
license shall apply to initial facilities and operations,
and to any subsequent facilities and operations proposed by
the licensee.
B6. Transportation, handling, disposal, treatment, monitoring,
and other activities at the site shall comply with procedures
and plans approved by the Department and other conditions of
this license.
B7. In the event of fires, accidents, or emergencies that occur
at the site, or during transportation of wastes to the site,
the licensee shall employ emergency procedures approved by
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the Department. The occurrence of any fires, accidents,
emergencies, or other unusual conditions at the site, or in
connection with transportation of wastes to the site, shall
be reported to the Department as soon as possible, such that
the Department can monitor or direct clean-up or other activ-
ities necessary to rectify conditions resulting from the
incident. If deemed necessary, the Department may require
special precautions to be taken during, or as the result of
fires, accidents, or emergencies.
B8. Before use of the site for disposal is terminated, the licens-
ee shall restore the site to its original conditions, to the
extent reasonably practicable. No less than one year prior
to intended closure of the site, the licensee shall submit
detailed plans for the Department's approval indicating steps
to be taken to properly close and restore the site.
B9. Upon completion of each burial trench, a granite or concrete
marker shall be erected at the end of the trench. To such
trench markers shall be attached a bronze or stainless steel
plate which shall contain the following information: a trench
identification number; dimensions of the trench and its loca-
tion relative to the marker; volume of waste buried; and dates
of beginning and completion of burial operations. For radio-
active waste trenches, markers shall also include the total
quantity of radioactive material, the quantity of source
material only, and the quantity of special nuclear materials
only buried in the trench.
BIO. The licensee may at any time propose in writing for the
Department's consideration, changes in previously approved
facilities or procedures, or the addition of new facilities
or procedures.
Bll. The licensee is authorized to accept and dispose at the site
only those chemical wastes for which specific treatment and
disposal procedures or research programs have been approved
by the Department. Treatment and disposal of chemical wastes
at the site shall be conducted only in facilities approved
by the Department.
B12. Within 14 days after receipt of a written request for service
from a waste generator or source specifying the volumes and
chemical and physical composition of wastes requiring dispos-
al, if treatment and disposal procedures have not been pre-
viously approved by the Department, the licensee shall forward
a copy of such request to the Department together with either:
a. Proposed treatment and disposal procedures; or
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b. A proposed research program for development of
disposal procedures and the time required for
completion; or
c. A determination that the wastes should not be
accepted at the site and the reasons therefor.
Any treatment or disposal procedures or research programs
which are approved by the Department pursuant to such re-
quests shall be undertaken by the licensee as soon as
practicable.
B13. Notwithstanding the provisions of condition B12, item c, if
the Department determines that any specific waste originating
in Oregon should be disposed at the site, based on unavail-
ability or unfeasibility of alternative disposal methods or
other factors, the licensee shall provide disposal for such
waste under treatment or disposal procedures directed by the
Department utilizing existing site facilities and equipment.
In the event the treatment or disposal procedures directed
by the Department require additional facilities or equipment,
the obligation of licensee shall depend upon financial com-
mitments by the waste generators satisfactory to licensee.
B14. No less than 18 months and no more than 21 months after the
effective date of this license, the licensee shall submit a
report to the Department which outlines the feasibility of
adding incineration facilities at the site. This report shall
include an analysis of: the types and volumes of organic
wastes that would be amenable to incineration; volumes of
such wastes that have been disposed at the site by other means;
conceptual design for appropriate incineration facilities
including capital and operating costs; method of feed, hourly
feed rate, hours of operation, quantity and character of air
contaminants to be emitted, and proposed monitoring equip-
ment, if any; and other information pertinent to incineration.
B15. The licensee is authorized to accept and dispose of radio-
active wastes at the site, including naturally occurring or
accelerator produced isotopes, by-product material, source
material and special nuclear material, but excluding radio-
active wastes under sole Federal jurisdiction. Acceptance
and disposal of radioactive wastes at the site shall be sub-
ject to all applicable conditions of this license and in
compliance with procedures approved by the Department and
only in facilities approved by the Department.
B16. The volume of radioactive wastes originating from sources
outside Oregon which are accepted for disposal at the site
shall not exceed 150,000 cubic feet per year averaged over
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the five-year period beginning on the effective date of this
license.
B17. The licensee shall not receive and possess unburied, at any
time at the site, radioactive waste in excess of:
a. 5,000 curies of radioactive material in any form.
b. 60,000 pounds of source material in any form.
c. Special nuclear material in quantities of 350 grams
of Uranium 235 or 200 grams of Uranium 233 or any
combination of special nuclear material such that
the sum of the ratios of the quantities possessed
to the quantities specified herein shall not ex-
ceed unity. Unity shall be determined by the fol-
lowing formula:
grams possessed U-235 + grams possessed U-233 = 1
350 200
B18. The licensee shall not conduct any of the following activities
at the site:
a. Burial of liquid radioactive wastes.
b. Burial of gaseous radioactive wastes which are above
1.5 atmospheres absolute pressure.
c. Incineration or burning of radioactive wastes.
B19. The licensee shall not open any packages of radioactive wastes
at the site except to repair or repackage containers damaged
in transit or to remove wastes for solidification. For pur-
poses of returning or reusing outer shipping packs and casks,
the licensee may remove intact inner containers for disposal.
B20. All radioactive wastes received at the site which are to be
buried shall be placed in a burial trench as soon as possible,
normally on the day of receipt at the facility, except in the
case of radioactive wastes which are to be solidified. In no
case shall wastes be stored above ground for longer than 5
days unless the Department is notified and approves of storage
for a longer period. Liquid or slurry radioactive wastes
which are to be solidified shall not be stored at the site
for a period greater than 6 months from the date of receipt
prior to burial.
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B21. Packages containing special nuclear material shall be sepa-
rated by a minimum of 8 inches of earth in the burial trenches,
B22. Radioactive wastes containing transuranic elements (atomic
number greater than 92) shall not be accepted at the site.
B23. The licensee shall comply with Oregon Regulations for the
Control of Radiation, Parts B.100 and C, of the Oregon State
Health Division. All reporting and notifications required
of the licensee by such regulations shall be to both the
Radiation Control Section of the State Health Division and
the Department.
B24. Trenches used for disposal of radioactive wastes shall not
be used for disposal of wastes not containing radioactive
materials.
B25. Level indicating devices shall be provided on liquid or slur-
ry radioactive waste storage tanks. In the event leakage is
found or suspected from and such tank, it shall be removed
from service and the Department shall be notified immediately.
B26. Decontamination of employees and of equipment to remove radio-
active material shall comply with procedures approved by the
Department. Wastes resulting therefrom shall be disposed in
compliance with procedures approved by the Department.
B27. Radioactive wastes received, stored, or disposed at the site
shall not contain in excess of 5 grams of Uranium 233 and
Uranium 235 per cubic foot of waste.
B28. The licensee shall designate a site manager. The licensee
shall advise the Department of the name and qualifications
of the site manager. The site manager shall be in charge of
all activities at the site within his qualifications. The
licensee shall also advise the Department of the individual
to be contacted on any problem not within the site manager's
qualifications. The licensee shall immediately notify the
Department if any change is made in these designated indi-
viduals .
B29. The licensee shall not open burn any wastes or materials at
the site.
C. BONDING, FEE, LEASE AND INSURANCE CONDITIONS
Cl. Within 30 days following the effective date of this license,
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the license shall post a cash bond with the Department in
the amount of $113,400. The following shall be eligible
securities deemed equivalent to cash: bills, certificates,
notes, bonds, or other obligations of the United States or
its agencies. The cash value at the time of posting shall
not be less than the required bond amount.
Interest earnings on the cash bond shall be paid annually
by the Department to the licensee, except for that amount
necessary to offset inflationary increases in monitoring,
security, or other costs to be funded by the cash bond.
C2 . The licensee shall pay a license fee to the Department in
the amount of $4,890 within 30 days after the effective date
of this license. Thereafter, the licensee shall pay the
Department an annual license fee of $7,330 within 30 days
after July 1 each year.
C3. The licensee shall pay to the Department of Environmental
Quality a volumetric fee of eight cents ($0.08) per cubic
foot of wastes received at the site. Such fees shall be paid
by the last day of each month for wastes received at the site
during the preceding month.
C4. Within 30 days after the effective date of the license, the
licensee shall deed the following properties at the site to
the State: radioactive waste burial area; chemical waste
burial area; biodegradation basin A; chemical evaporation
ponds; chemical waste process building area; and radioactive
waste process area. Within 60 days after completion of on-
site roads, the licensee shall deed such roads to the State.
Within 30 days after deeding of these properties to the State,
a lease between the licensee and the Department for these
properties shall be executed. The lease shall be maintained
for the duration of this license.
C5. The licensee shall maintain liability insurance for operation
of the site, with respect to all types of wastes, in the
amount of not less than $1,000,000 to cover transportation of
all types of wastes to the site. The licensee shall provide
the Department with certified copies of such insurance policies
within 30 days after the effective date of this license and
of all policy changes within 30 days after each such change.
All such insurance policies shall provide that such insurance
shall not be cancelled or released except upon 30 days prior
written notice to the Department.
C6. The licensee shall submit audited financial statements to
the Department, on or before December 1 of each year, for the
A-8
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annual period ending July 31 each year. Such statements
shall cover both the licensee's entire operations and oper-
ation of this site. The Department shall withhold financial
statements covering only this site from public disclosure.
C7. The licensee shall convey title for the entire site to the
State, except for those portions previously owned by the
State, in the event of any one of the following circumstances,
a. Expiration of the license due to failure of the
licensee to seek renewal.
b. Termination or expiration of the license due to
utilization of the site to its full capacity, as
determined by the Department.
This condition shall survive the expiration or termination
of the license.
D. RECORDS AND REPORTING CONDITIONS
Dl. The licensee shall maintain records and submit monthly reports
to the Department indicating quantities and types of wastes
received, stored, and disposed at the site and fees collected
therefor. Such reports shall be on forms approved by the
Department.
D2. The licensee shall maintain records, on forms approved by
the Department, indicating the type, quantity, and location
of wastes which have been buried in burial trenches at the
site. Such records shall be submitted to the Department
biannually.
D3. The licensee shall maintain survey records for each burial
trench, referenced to the nearest U.S.G.S. bench mark to
define the exact location and boundaries of each trench.
Within 60 days after completion of trenches, the licensee
shall forward the required marker information and a copy of
survey records to the Department.
D4. All findings and results from the licensee's environmental
monitoring program shall be recorded on appropriate forms
and shall be reported to the Department quarterly.
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E. ENVIRONMENTAL MONITORING CONDITIONS
El. The licensee shall conduct a chemical environmental monitor-
ing program as follows:
a. On-site dry test wells (wells numbered B-l, B-2,
B-3, B-4, B-5, and B-6) will be checked annually
when the water table in the area is at its highest
level. Water samples will be obtained from each
well in which water is observed.
b. Monitoring wells at the end of each chemical burial
trench will be checked quarterly for the presence
of water. If water is observed, a water sample
will be taken and the Department will be notified
immediately. If no water is observed, a sample of
sediment (soil) from the monitoring well will be
obtained biannually- Once per year, a sample of
soil from trench monitoring wells will be sent to
the Department.
c. All water and soil samples required by items a and
and b above will be analyzed for zinc, copper, ar-
senic, cadmium, chromium, lead, mercury, cyanides,
chemical oxygen demand, total organic carbon,
chlorides, specific conductance, chlorinated hydro-
carbons, and phenols using procedures approved by
the Department.
d. A sample of the resident vertebrate population and
of vegetation will be obtained annually. These
samples will be analyzed for zinc, copper, arsenic,
cadmium, chromium, lead, mercury, cyanides, chlori-
nated hydrocarbons, and phenols.
E2. The licensee shall conduct a radiation environmental monitor-
ing program as follows:
a. The on-site dry test wells will be checked annually
when the water table in the area is at its highest
level. If water is observed in the test well(s),
samples will be obtained. Analyses for gross alpha
and beta will be conducted.
b. The on-site water supply well will be sampled quar-
terly. Analyses for gross alpha, gross beta, and
for tritium will be conducted quarterly. Samples
will be analyzed for radium and strontium annually.
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c. The monitoring wells at the end of each radioactive
waste burial trench will be checked monthly for the
presence of water. If water is observed, the De-
partment will be notified immediately, a sample will
be obtained, and an analysis for gross beta and
gross alpha will be conducted. If no water is ob-
served, samples of the sediment (soil) will be ob-
tained from the trench monitoring wells on a quar-
terly basis. Analyses on these samples will include
gross beta, gross alpha, and a gamma scan. Once per
year, a sample of soil from trench monitoring wells
will be sent to the Department.
d. Two off-site water samples will be obtained bian-
nually at Alkali Flat W-l and the Hillside Water
Seep. Analyses for gross alpha, gross beta, and
for tritium will be conducted.
e. Six on-site and two off-site samples of soil will
be obtained quarterly. These samples will be taken
at the same general location each quarter and will
be analyzed for gross beta and a gamma scan annually.
f. Three on-site and one off-site samples of vegetation
will be obtained biannually. These samples will be
analyzed for gross beta and a gamma scan.
g. A sample of a resident steer from adjoining property
will be obtained every 18 to 24 months at the time
of slaughter. A gamma scan of the groin muscle and
thyroid will be made. A sample of resident field
mice will be obtained on an annual basis. A gamma
scan of the groin muscle and thyroid will be made.
h. An air sampler will be operated on-site for at least
two hours each day- The filter will be changed ev-
ery two weeks and analyzed for gross beta activity.
i. The perimeter fence line of the licensee's property
will be surveyed quarterly using a portable end
window Geiger counter. In addition, two TLD's or
film badges will be placed at two points on the
perimeter fence. These devices will be changed
and analyzed quarterly.
j. The level in liquid or slurry radioactive waste
tanks will be checked weekly. Each such tank will
be pressure tested no less frequently than once
every six months using procedures approved by the
Department.
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F. APPROVED PLANS AND PROCEDURES
As referred to in conditions Fl, F2, and F3, the licensee's manage-
ment plans shall mean the licensee's June 14, 1974 Program for
Management of Hazardous Materials and revisions and additions there-
to submitted to the Department by letter of September 24, 1974.
Fl. The following general plans and procedures are approved:
a. Location of facilities at the site as described
on Licensee's Plot Plan (Drawing No. 1), dated
June 25, 1974.
b. Security plans as described on pages 4 and 5 of
the licensee's management plans, except that a
three strand barb wire fence shall be maintained
around the perimeter of the site.
c. Firefighting procedures as described on pages 2,
6, and 7 of the licensee's management plans, except
that the requirements of condition B7 shall also
apply.
d. Fire and water systems as described on page 2 and
Figure G-5 of the licensee's management plans, ex-
cept that 200 feet of fire hose and a nozzle be
provided at each fire hydrant.
e. Roads as described on the Licensee's Plot Plan
(Drawing No. 1) , dated June 25, 1974 and on page
2 and Figure G-l of the licensee's management plans.
f. Operations center as described on page 2 and Figure
G-4 of the licensee's management plans.
g. Machine and storage building as described on page
1 and Figure G-2 of the licensee's management plans.
F2. The following plans and procedures for transportation, han-
dling, disposal, and treatment of chemical wastes are approved:
a. Chemical staging area (drum storage pad) and tank
farm as described on pages 2 and 3 and Figure C-l
of the licensee's management plans.
b. Chemical process building as described on page 1
and Figures G-3 and C-4 of the licensee's manage-
ment plans, except that only facilities for office,
laboratory, sanitary facilities, and emergency
shower are approved.
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c. Evaporation ponds, three only, as described on
page 17, item 1, and Figure C-5 of the licensee's
management plans.
d. Chemical burial trench, three only, as described
on page 14, item 1, and Figure C-2 of the licensee's
management plans, with the following additions and
exceptions:
(1) Trench floor and gravel ditch to be sloped
at 1 foot per 100 feet toward sample pipe
(monitoring well).
(2) Sample pipe to be installed at trench edge
rather than at trench center. Sample pipe
shall be in place before disposal of wastes
in trench is begun. Adequate provision
shall be made to allow sampling of soil
and water below sample pipe.
(3) An earthen berm of two feet minimum height
shall be maintained along the uphill edge
of an active trench (stockpiling of ex-
cavated soil along the uphill edge will
satisfy this requirement). A drainage
ditch of two feet minimum depth shall be
maintained adjacent to each end of the
trench.
(4) Burial of wastes shall commence in the
end of the trench opposite the monitoring
well. Equipment operating in the trench
shall not travel on or across the gravel
ditch.
(5) Final mounding of completed trenches is
to extend two feet beyond the trench edge.
Suitable vegetation is to be established
and maintained on completed and mounded
trenches.
e. Biodegradation bed, Basin A, Phase 1 only, as de-
scribed on page 15 and Figures B-l and B-2 of the
licensee's management plans.
f. Procedures for the pickup and transportation of
chemical wastes as described on pages 55 and 56 of
the licensee's management plans.
F3. The following plans and procedures for transportation, handling
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disposal, and treatment of radioactive wastes are approved:
a. Radioactive waste burial trenches, three only, as
described on Figure R-3 of the licensee's manage-
ment plans, with the following additions and
exceptions:
(1) Trench floor and gravel ditch to be
sloped at 1 foot per 100 feet toward
sample pipe (monitoring well).
(2) Sample pipe to be installed at trench
edge rather than at trench center. Sample
pipe shall be in place before disposal
of wastes in trench is begun. Adequate
provision shall be made to allow sampling
of soil and water below sample pipe.
(3) An earthen berm of two feet minimum height
shall be maintained along the uphill edge
of an active trench (stockpiling of ex-
cavated soil along the uphill edge will
satisfy this requirement). A drainage
ditch of two feet minimum depth shall be
maintained adjacent to each end of the
trench.
(4) Burial of wastes shall commence in the
end of the trench opposite the monitoring
well. Equipment operating in the trench
shall not travel on or across the gravel
ditch.
(5) Final mounding of completed trenches is
to extend two feet beyond the trench edge.
Suitable vegetation is to be established
and maintained on completed and mounded
trenches.
b. Radioactive slit trench, one only, as described on
Figure R-4 of the licensee's engineering plans, ex-
cept that final mounding shall extend a minimum of
two feet beyond and two feet above the trench edge.
c. Radioactive liquid and resin transfer and solidi-
fication facilities as described on page 3 and
Figures R-l and R-2 of the licensee's management
plans, subject to the additional requirements of
condition B25.
A-14
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Procedures for the Pickup and Transportation of
Packaged Radioactive Wastes as described on pages
64-66 of the licensee's management plans.
Procedures for the transfer of Radioactive Spent
Resins from Transport Cask to Storage Tank or
Disposal Container as described on pages 69-71 of
the licensee's management plans.
Procedures for the Removal of Irradiated Material
from Shield Cask and Burial as described on pages
72-74 of the licensee's management plans.
General Procedures for Trench Burial of Radioactive
Waste as described on page 75 of the licensee's
management plans, except that item 6, page 75, is
not approved.
Procedures for the Solidification of Liquid Radio-
active Wastes as described on pages 76 and 77 of
the licensee's management plans.
Radiation Protection Program as described on pages
78-79 of the licensee's management plans.
Radiation Training Program as described on pages
80-82 of the licensee's management plans.
Radiation Detection and Measurement Instruments as
described on page 83 of the licensee's management
plans.
Emergencies procedures as described on pages 84
and 85 of the licensee's management plans.
A-15
&GP O 692. 028-1 976
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
ORP/LV-76-3
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Review of State Licenses for Disposal of Low-Level
Radioactive Waste by Shallow Land Burial
5. REPORT DATE
June 1976
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
B. J. Mann and D. J. Nelson
8. PERFORMING ORGANIZATION REPORT NO.
ORP/LV-76-3
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
Office of Radiation Programs—Las Vegas Facility,
U.S. Environmental Protection Agency,
P. 0. Box 15027, Las Vegas, Nevada 89114
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
State licenses for disposal of low-level radioactive wastes at commercial
burial sites are reviewed. Information concerning license, terms and conditions,
and license administration has been obtained from questionnaires sent to those
six states with commercial radioactive waste burial sites. The questionnaire
information has been supplemented by recent reports of the Task Force on Radio-
active Waste Management of the Conference of Radiation Control Program Directors
and personal communications with knowledgeable officials in state and Federal
agencies.
A number of problems associated with licensing and license administration
by the states have been identified by the Task Force, by the Federal Government
Accounting Office (GAO), and by various state and Federal officials. These are
summarized and recommendations are included.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDEDTERMS
COS AT I Field/Group
Radioactive Wastes
Waste Disposal
Radiation Control Regulations
Shallow Land Fill Burial Sites
Commercial Radioactive Waste
Disposal Sites
Licensing and
Regulation, Shallow
Land Burial
0504
1807
8. DISTRIBUTION STATEMENT
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
35
20. SECURITY CLASS (This page)
TTnfl assi f ied
22. PRICE
EPA Form 2220-1 (9-73)
*GPO 692-029-1976
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