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Surveillance of Buried Radioactive Waste



Radsafers:

Have any of you had to deal with NRC over buried radioactive waste issues?
Montana State University was licensed in the past to bury LLRW in an
abandoned gold mine (ha, you thought I was going to tell you where!). That
last disposal took place in the mid-eighties, and the mine was back-filled
and sealed in 1989 by the State Lands Commission.  It is now surrounded by a
ten foot fence and labeled as containing RAM.  There is a ventilation tube
protruding from the concrete slab sealing the mine.  The mine sealing was
performed per the specifications of the State's Abandoned Mines Program.

All this was done on the "up-and-up", with full NRC approval.  NRC actually
drafted a lengthy report regarding the issue, concluding positively to seal
the mine.  Presently, however, as part of MSU's Decommissioning Funding
Plan, NRC wants to know (among other things) how we propose to address "long
term surveillance."

Is there a precedent in the established "Rules and Regulations" that
addresses this particular scenario?

The mine itself is situated in "natural rock".  It is dry throughout the
year (i.e., no percolating water), and is five hundred feet above the
existing water table.  The shaft itself is one hundred feet below the ground
surface at its extreme end (it's a horizontal shaft bored into the side of a
large hill).

NRC first approached me on this last year during a pre license renewal
visit.  The license reviewer intimated "strong concern" over the future
disposition of the mine.  You can probably imagine my feelings in response
to this.  Pandora's Gold Mine!

I did not put anything into the license application promulgating site
surveillance.  Nothing in the our new license (Type A) mentions the mine, or
any custodial requirements.

I am not in the mood to make a commitment that has neither legal precedent
(from my vantage point) or environmental merit.

Why would NRC present this issue without tying in (or illustrating) what
their fundamental concerns are?

Any thoughts, comments, EXPERIENCES, etc., would be appreciated.

Regards,

-Erick Lindstrom

 Erick Lindstrom
 Radiation Safety Officer
 309 Montana Hall
 Montana State University
 Bozeman, MT  59717-0244
 Phone: (406) 994-2108
 Fax:	(406) 994-4792
 avrel@gemini.oscs.montana.edu