Re: Old burial sites and decommissioning

[Erick Lindstrom <avrel@gemini.oscs.montana.edu>]

Jim:

I too received IN 96-47 (on Wednesday), and yesterday we were given a call
by Region IV.  However, due to the fact that I was escorting my
father-in-law around Lewis and Clark Caverns, I was not available to join
our VP for Research to discuss this delightful topic.  Not being fluent in
"Regulatoreese", the VP was baffled at the outset of his conversation with
the NRC.  Needless to say, I was summoned to his office this morning!

If you recall, Jim, (and y'all too radsafers) I posted a message some time
ago discussing our situation here at MSU-Bozeman.  We have an old burial
site (abandoned gold mine - sunk in rock) that was back-filled and concrete
capped at NRC's request (closure occurred in 1989).  Unfortunately since my
arrival here at MSU, the NRC has persistently hounded me regarding the
decommissioning status of the burial site.  I submitted "round-one" of MSU's
Campus-wide Decommissioning Funding Plan (DFP) in November of last year.
NRC responded that our positioning regarding the burial site was
"noteworthy", and included the following observations:

    "In response to the NRC's request to submit additional information on
the burial site, the licensee submitted a discussion of the site, a
description of the materials buried at the site, and copies of various
records and correspondences regarding the site.  The submission acknowledges
that there are radioactive materials at the site.  It states that
"radioactive materials deposited at the site were placed there with full NRC
approval", and that all radiological operations at the site were conducted
"in full accordance with all applicable laws."  The submission also states
that there is essentially no way to further stabilize the site.
Consequently. the cost estimate does not include any costs related to the
burial site and the statement of intent does not assure any amount for the
burial site.  Moreover, in describing the facilities covered by the
statement of intent, the statement of intent seems to exclude the burial
site by stating that "the facilities presently covered by this license
include only those established on the central campus of Montana State
University located in Bozeman, Montana."

Though our position was deemed "noteworthy", it certainly didn't provoke any
substantive mandates regarding permanent disposition (probably because NRC
is ". . .currently developing a methodology that can be used to determine
the acceptability of prior burials. . ."(IN 96-47)).  Given such weak
guidance, I did not even mention the burial site in "round-two" of the DFP
submitted in March '96 (and have received no further response from NRC
regarding the DFP).

The "Timeliness Rule" states:

	Therefore, licensees who have unused outside areas (i.e., burial areas) that
	contain elevated levels of licensed radioactive materials, and have declared
	that licensed operations have ceased in those areas, are subject to the
	Timeliness Rule.  In addition. for an outside area (i.e., burial area) that
	has been unused for NRC licensed operations for a period of 24 months prior to
	August 15, 1996, the licensee should

	1.	No later than October 15, 1996, notify NRC of the above and either; (1)
begin decommissioning;                 or (2) submit, within 12 months of
notification, a decommissioning plan, if required by the
regulations; or

	2.	Submit a request to extend the above time periods by no later than
		September 15, 1996, in accordance with the provisions of the rule.

If I submit a request for extension (Sept. 15), I'm disallowing our DFP
position.  Moreover, I'm opening the proverbial door just that much wider.
That's definitely a "no-go."  What I've decided to do is to fax Region IV a
memo that acknowledges the "Timeliness Rule", but essentially establishes
that we've already addressed those issues via the DFP.  We're going to wait
for more specific guidance - period!

For those of you who don't have to deal with these burial issues, smile
appreciatively at your display terminal. For those of you who do, run to the
nearest window and shout "I'VE HAD IT, AND I'M NOT GOING TO TAKE IT ANY MORE!!!"

I apologize for the length of this post. . .

Regards and adieu!

-Erick Lindstrom

PS  Keep those cards, faxes, and e-mail messages coming in regarding your
experiences with dosimetry vendors - there's some very interesting opinions
emerging out there!


At 11:27 AM 9/13/96 -0500, you wrote:
>
>Here's one for Friday the 13th:
>
>How many of you out there have an old radioactive waste burial site which 
 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