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Category:Letter
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2024-09-23
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Department of Energy West Valley Demonstration Project 10282 Rock Springs Road West Valley, NY 14171-9799 September 5, 2008 Mr. Keith I. McConnell, Deputy Director Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs United States Nuclear Regulatory Commission Washington, D.C. 20555-0001
SUBJECT:
Response to the Additional U.S. Nuclear Regulatory Commission Staff Review of the Cover Design for the Nuclear Regulatory Commission Licensed Disposal Area
REFERENCES:
- 1) Letter (99363), K. 1. McConnell to B. C. Bower, "Additional U.S. Nuclear Regulatory Commission Staff Review of the Cover Design for the Nuclear Regulatory Commission Licensed Disposal Area at West Valley, New York," dated May 30, 2008
- 2) Letter CRR:98235- 439, B. C. Bower to K. 1. McConnell, "U.S.
Department of Energy (DOE) Supplemental Response to U.S. Nuclear Regulatory Commission (NRC) Comments on 30% Design for the Nuclear Regulatory Commission Licensed Disposal Area (NDA) Cap and Slurry Wall," dated November 6, 2007
Dear Mr. McConnell:
The U.S. Department of Energy West Valley Demonstration Project (DOE-WVDP) appreciates the reviews and comments received from the NRC staff on the NDA Cap and Slurry Wall Project, Your staff indicated that they consider that there are "no imminent risks or hazards posed by the current design," and have provided suggestions that would enhance performance of the facility (Reference 1). To that end, the following is in response to these suggestions.
As you are aware, NRC guidance NUREG 1623 was created to address permanent installations while the NDA Cap and Slurry Wall project is a relatively "short term," 30-year installation being implemented under the Resource Conservation and Recovery Act (RCRA) Corrective Action program as an Interim Measure, not a final remedy. As such, it is felt that some requirements of NUREG 1623 are overly restrictive for our project.
Regarding rock quality, DOE-WVDP agrees that specifying the rock specific density alone could allow for poor rock quality. Therefore, we will add a maximum adsorption requirement to the riprap to maintain the absorption below 0.80%. Additionally, we have been working with the U.S. Army Corps of Engineers (USACE) who have been utilizing local quarries for riprap on many of their long-term shore and stream bank protection projects in and around Western New York. Enclosed is information provided by USACE personnel regarding available rock from local quarries. It is our intent to utilize local quarries for the rock specified in this project.
Mr. Keith 1. McConnell September 5, 2008 Regarding rock placement, it is DOE-WVDP's belief that the New York State Department of Transportation (NYSDOT) Section 620 requirements were not employed in the current (existing) rock placement. We believe that there is little value in testing the existing rock in the ravine leading from the NDA to Erdman Brook. This rock will be covered with the newly placed rock which will meet the above rock quality specifications. Due to the slope, limited access, and safety issues, the stone gradation, thickness, and placement will be performed to the current NYSDOT Section 620 specifications per a future revision to existing construction documents.
Regarding rock gradations and testing, construction specifications will be revised to incorporate specified rock gradation and gradation testing. Gradation will be specified per the local conditions based on the 30-year design life of the installation for the RCRA Interim Measure and modeled hydrologic response to /2of the Probable Maximum Precipitation (PMP) (Reference 2).
Regarding NRC's suggestions for flood protection, the rock size that will be specified for the lower portion of the slope leading to Erdman Brook. The rock will be compatible with erosion protection requirements and assure prevention of undermining of the riprap covered slope.
Based on review of the topography leading to Erdman Brook, there is limited space for a flat run-out before the water monitoring station. Rock size will be specified to minimize the potential for erosion (e.g., gullying and head-cut concerns) over the 30-year design life of this RCRA Interim Measure. Toe protection will be provided by the placement of a sufficient quantity of launchable stone to stabilize erosion.
Upon completion of the NDA cap and slurry wall project, as-built design drawings and specifications will be issued and available for the evaluation and assessment for the future long-term performance and designs.
Should you have any questions, please contact Ms. Moira Maloney of my staff at (716) 942-4255.
Sinrely,
/( C. Bower, Director West Valley Demonstration Project
Enclosure:
USACE Table, DOE WVDP Riprap Needs for NDA Floodway & Outfall to Erdman Brook cc: P. Gardina, EPA, w/enc.
G. Baker, NYSDOH, w/enc.
P. Concannon, NYSDEC, w/enc.
P. J. Bembia, NYSERDA, AC-NYS, w/enc.
D. Garber, WVES, WV-ADM, w/o enc.
J. R. Gerber, WVES, AC-ESHQ, w/o enc.
K. K. Gupta, WVES-AC-WDP, w/enc.
D. C. Meess, WVES, AC-WDP, w/enc.
MPK:99737 - 439
DOE WVOP Riprap Needs for NDA Floodway & Outfall to Erdmann Brook Quarry Samples Lithology Specific Gravlty Absorption % Sodium Sulfate % [a] UA Abrasion (100 revs) % [bJ Schmidt Hammer (-I Weathering Idl Range from NUREG Table D-1:
Upper Range for Fair to Good Medium to Massive Bedding - Non-arillaceous 2.60- 2.75 0,10- 0.67 1.0- 6.7 1.0- 6.7 54-70 -
Frontier Ouarry Ledgerock Shaty Dolomite to Shaly Argillaceous Dolomite 2.79- 2.81 0.24- 0.44 - - 0.35 (80 cycles)
(now LaFarge Lockport) Dolomite to Dolomitic Limestone 2.61 - 2.66 0.53- 0.77 - - 0.083 - 0.53 (80 cycles)
Dolomite 2.62-2.80 0.26- 1.93 - 22.3 - 0.33 (80 cycles)
Niagara Stone Lockport Dolomite 2.64-2.72 1.07 - 1.51 - - - 0.024 80 cycles)
Genstar Stone Products Lockport Dolomite 2.67 0.846 ý 1.16 - - - 0.099 - 0.322 (80 cycles)
Buffalo Crushed Stone Onondaga Limestone (with Chert) 2.69 -2.71 0.10-0.70 - 19.1 - -
Buffalo Slag Company Onondaga Limestone (with Chenl) 2.64- 2.70 0.034 - 0.21 - 18 - 0.0116 -0.50 (80 cycles)
NOTES:
a - Lockport Dolomite can emit sulfury odor when cru*hed and associated groundwater can extlibity surfury odor from sulfate reducing baderia; the presence of sodium sulfate is assured at unknown levels.
b - Only one test result was available for each quarry with most reporting insignificant to minor slaking; all samples were found acceptable for streambank armor stone applications.
c - These local rock formations ar highly resistaent to impact at Schnidt Hammer scales, especially since several members are thick bedded and crystaline rock d - Test is similar to UA Abras*on; all samples were found acceptable for streambank armor stone applications and likely this interim remedy.