ML092040038
| ML092040038 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project, P00M-032 |
| Issue date: | 07/24/2009 |
| From: | Glenn C NRC/FSME/DWMEP/DURLD/MDB |
| To: | Tadesse R NRC/FSME/DWMEP/DURLD/MDB |
| References | |
| Download: ML092040038 (5) | |
Text
July 24, 2009 MEMORANDUM TO: Rebecca Tadesse, Chief Materials Decommissioning Branch Decommissioning and Uranium Recovery and Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Program FROM: Chad Glenn, Project Manager /RA/
Materials Decommissioning Branch Decommissioning and Uranium Recovery and Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Program
SUBJECT:
JUNE 15, 2009 MEETING REPORT On June 15, 2009, the U.S. Nuclear Regulatory Commission (NRC) met with U.S. Department of Energy (DOE) via videoconference. The purpose of this meeting was to discuss NRCs request for additional information based on its review of the DOE Phase 1 Decommissioning Plan for the West Valley Demonstration Project. The meeting report is enclosed. This information is also available on the NRC public meeting website: http://www.nrc.gov/about-nrc/regulatory/decommissioning/public-involve.html.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice for Domestic Licensing Proceedings and Issuance of Orders, a copy of this letter will be available electronically for public inspection in the NRC Public document Room or from the Publicly Available Records component of NRCs Agencywide Documents Access and Management System (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Docket No.: P-32
Enclosure:
Meeting Report CONTACT: Chad Glenn, FSME/DWMEP 301-415-6722
July 24, 2009 MEMORANDUM TO: Rebecca Tadesse, Chief Materials Decommissioning Branch Decommissioning and Uranium Recovery and Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Program FROM: Chad Glenn, Project Manager /RA/
Materials Decommissioning Branch Decommissioning and Uranium Recovery and Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Program
SUBJECT:
JUNE 15, 2009 MEETING REPORT On June 15, 2009, the U.S. Nuclear Regulatory Commission (NRC) met with U.S. Department of Energy (DOE) via videoconference. The purpose of this meeting was to discuss NRCs request for additional information based on its review of the DOE Phase 1 Decommissioning Plan for the West Valley Demonstration Project. The meeting report is enclosed. This information is also available on the NRC public meeting website: http://www.nrc.gov/about-nrc/regulatory/decommissioning/public-involve.html.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice for Domestic Licensing Proceedings and Issuance of Orders, a copy of this letter will be available electronically for public inspection in the NRC Public document Room or from the Publicly Available Records component of NRCs Agencywide Documents Access and Management System (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Docket No.: P-32
Enclosure:
Meeting Report CONTACT: Chad Glenn, FSME/DWMEP 301-415-6722 ML092040038 OFC DWMEP DWMEP DWMEP NAME CGlenn SMichonski CGlenn DATE 7 /23 /09 7/23/09 7/24/09 OFFICIAL RECORD COPY
June 15, 2009 DOE-NRC Meeting Report DOE Proposed Response to NRC Request for Additional Information On West Valley Demonstration Project Phase 1 Decommissioning Plan Introduction On June 15, 2009, the U.S. Department of Energy (DOE) and the U.S. Nuclear Regulatory Commission (NRC) met to discuss DOEs proposed approach for responding to NRCs request for additional information (RAI) on the West Valley Demonstration Project (WVDP) Phase 1 Decommissioning Plan (DP). In this meeting, DOE provided information on how it plans to address 33 of NRCs 44 RAI comments on the WVDP Project Phase 1 DP. DOE solicited NRC feedback on the proposed approach to responding to these comments. DOE did not require clarification on the remaining RAI comments.
In addition to DOE and NRC staff, meeting attendees included representatives of the New York State Energy Research and Development Authority (NYSERDA), New York State Department of Environmental Conservation (NYSDEC), U.S. Environmental Protection Agency (EPA),
Citizens Environmental Coalition, and Nuclear Information and Resource Service (NIRS). The meeting notice and agenda, presentation material, and list of attendees are located in ADAMS at ML091410435, ML091620425, and ML092040127 respectively.
Discussion The technical discussion principally addressed the following topics: radiological status of facility, dose modeling, radiation surveys, and hydraulic barriers.
Significant Discussion Points:
- DOE provided information regarding its decision to perform probabilistic dose modeling (in addition to deterministic analysis), which represents a significant change in its approach to calculating Derived Concentration Guideline Levels (DCGLs). DOE will use the results of its probabilistic modeling to either: (i) support deterministic DCGL calculations or (ii) use the peak of the mean dose from the probabilistic analysis to determine DCGLs. DOE intends to brief NRC staff in a follow-up meeting with additional information regarding the parameters it intends to vary and the associated distributions to be used in the analysis. NRC staff recommended that DOE use an iterative approach to identifying risk-significant parameter values and refining those parameters and distributions in the probabilistic analysis. Certain parameters are scenario-dependent and should be treated as deterministic parameters. In general, DOE should not use a single probabilistic analysis to evaluate scenario uncertainty. Rather, DOE should present the results for various scenarios independently. Additionally, regional and site-specific information should be used to reduce the uncertainty in key parameter values (e.g., Kds), when available.
Enclosure
2
- DOE indicated its plans to perform additional modeling to address several NRC RAI comments related to evaluation of erosion scenarios and additional groundwater pathways, as well as evaluate the potential impact of hydraulic barriers on the assumed dilution factors in RESRAD. NRC staff recommended that DOE consider additional radionuclides (in addition to Cs-137 and Sr-90) that may be more mobile or longer-lived.
In addition to evaluating erosion impacts for onsite, recreational receptors, DOE should also evaluate the potential impacts from offsite exposures. DOE can use qualitative arguments and screening level analyses (e.g., to limit the list of radionuclides to be evaluated), when appropriate.
- NRC staff provided specific recommendations regarding selection of parameters to be varied in the probabilistic analysis, assumed correlation between parameters, and development of parameter values based on site-or problem-specific information. For example, NRC and DOE discussed recent references for bioaccumulation factors and assumed correlations with distribution coefficients, selection of source geometry for the subsurface DCGLs, selection of irrigation and pumping rates, and development of radionuclide-specific external gamma shielding factors for key radionuclides dominated by the external gamma pathway.
- DOE stated that its Characterization Sampling and Analysis Plan (CSAP) and Final Status Survey Plan would not be available until later in the year (December 2009 timeframe). Thus, NRC may not be able to review these plans prior to issuance of its Technical Evaluation Report (TER) documenting the results of its review. DOE should provide sufficient information in its response to RAIs to allow NRC to evaluate the overall methodology in its TER and should provide a mechanism for NRC review and comment following issuance of the TER, when the plans are finalized or if they are revised in the future. DOEs RAI response should provide the Remedial Action Support Surveys (based upon guidance in NUREG-1757, Vol. 2, Rev. 1, Section 4.3, and MARSSIM Section 5.4), and the Final Status Survey Design as requested in 9C4 of the RAIs (based upon the checklist in NUREG-1757, Vol. 1, Appendix D,Section XIV.d and MARSSIM Section 5.5 guidance). NRC can evaluate the high-level approach in its TER, perhaps with its conclusions contingent on its review of the plans when they are finalized.
- DOE indicated that the designs of the Waste Management Area (WMA) 1 and WMA 2 hydraulic barrier walls and French drain presented in the DP were conceptual. The final design will consider the capabilities of the existing Waste Tank Farm dewatering system and the proposed tank and vault drying system. The final designs will be provided for NRC review once all of the required subsurface geotechnical data become available.
Action Items DOE and NRC agreed to schedule a follow-up meeting for additional discussion on composite sampling, and probabilistic modeling.
3 Observer Comments/Questions and Responses NIRS
- Is it cost effective to leave piping in place? All of the piping will be removed in WMA 1 and 2 excavations down to the Lavery Till.
- Will the DP be revised if the preferred alternative changes? Yes, the DP as currently written only supports Phase 1 of the Phased Decisionmaking Alternative.
- Will the public have the opportunity to comment on the sampling and analysis plans?
These documents will not be available for review until after the Record of Decision is issued, at which time, they will be available for review by the NYSERDA, NYSDEC, etc.
- Who pays for the NRC review? NRC stated that neither DOE nor NYSERDA pays for such reviews under the West Valley Demonstration Project Act.
- In response to question regarding opportunities for pubic participation, NRC stated that it plans to schedule a public outreach meeting in the vicinity of the West Valley site in the near future.
- Questioned DOE statement that the CSAP would be informally reviewed since it is a Resource Conservation and Recovery Act (RCRA) requirement and thus, it would not be an informal review. DOE responded that the CSAP will focus on radioactivity and will not address sampling for RCRA constituents for site characterization purposes.
- Asked about effects of the construction of the hydrologic barriers on monitoring plans for the site.
- Raised concern about public/stakeholder opportunity to comment on sampling analysis and final status survey plans.
- Earlier review and comment on characterization plans is better.
- Final status surveys should be adequate for NYSERDA in the future (NYSERDA should not have to go back and clean-up or show clean-up was sufficient).
- Questioned soil management strategy and if there would be a cost savings if uncontaminated soil was not shipped offsite.