ML14357A343
| ML14357A343 | |
| Person / Time | |
|---|---|
| Site: | SHINE Medical Technologies |
| Issue date: | 12/03/2014 |
| From: | Bynum R SHINE Medical Technologies |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML14356A527 | List: |
| References | |
| SMT-2014-040 | |
| Download: ML14357A343 (7) | |
Text
Page 1 of 198 SHINE MEDICAL TECHNOLOGIES, INC.
SHINE MEDICAL TECHNOLOGIES, INC. APPLICATION FOR CONSTRUCTION PERMIT RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION PUBLIC VERSION The NRC staff determined that additional information was required (Reference 1) to enable the continued review of the SHINE Medical Technologies, Inc. (SHINE) application for a construction permit to construct a medical isotope facility (References 2 and 3). SHINE responded to a portion of the NRC staffs requests via Reference (4). The following information is provided by SHINE in response to the NRC staffs remaining requests.
CHAPTER 2 - SITE CHARACTERISTICS Section 2.4 - Hydrology (Applies to RAIs 2.4-1 through 4)
NUREG-1537, Part 1, Section 2.4, Hydrology, states, in part, that the applicant should provide sufficient information about the water table, groundwater, and features at the facility site to support analyses and evaluations in the PSAR Chapters 11 Radiation Protection Program and Waste Management, and 13, Accident Analysis, of consequences of uncontrolled release of radioactive material from pool leakage or failure, neutron activation of soils in the vicinity of the facility, or deposition and migration of airborne radioactive material released to the unrestricted area.
RAI 2.4-2 SHINE PSAR, Table 2.4-13, Summary of Parameters Used for Advective Travel Time Estimations (Section 2.4.11.2), presents the results of the travel time analysis. The effective porosity for the expected case is 30 percent. The reference cited in the table for the porosity (Gaffield et al., 2002), however, indicates that a porosity of 20 percent is most representative of the site conditions. A porosity of 20 percent would result in a travel time of 6 years as opposed to 9 years presented in the table.
Provide additional information on the technical rationale for the 30-percent porosity or recalculate the expected travel times.
SHINE Response Reference (5) (referenced in footnote e of Table 2.4-13 of the Preliminary Safety Analysis Report (PSAR)) provides a range of porosity values from 10 percent to 30 percent. The 10 percent porosity value would provide the shortest groundwater travel time, while the 30 percent porosity value would provide the longest groundwater travel time. SHINE used the 10 percent porosity value provided in Reference (5) to calculate the conservative advective travel times provided in Table 2.4-13.
Page 2 of 198 Although Reference (5) provides a typical value for porosity in Rock County, Wisconsin of 20 percent, SHINE does not believe a 20 percent effective porosity value would be consistent with the site-specific soil conditions described in Subsection 2.5.2.3 of the PSAR. Reference (6) provides arithmetic mean effective porosity values of 30 percent, 32 percent, and 33 percent for coarse, medium, and fine sand, respectively. These arithmetic mean porosity values are more typical of the subsurface conditions encountered at the SHINE site. Therefore, SHINE used a porosity value of 30 percent to calculate the expected advective travel times provided in Table 2.4-13.
RAI 2.4-3 SHINE PSAR, Table 2.4-13 (Section 2.4.11.2), presents the results of the travel time analysis.
An arithmetic average of the hydraulic conductivities was used in the expected case calculations. Typically, hydraulic conductivities are represented in a log-normal distribution, and geometric means are used to represent typical values.
Provide either additional information on the technical rationale for the averaging of the hydraulic conductivities or recalculate the expected travel times using a geometric mean for the hydraulic conductivity. Additionally, provide the Advanced Aquifer Test Analysis Software (AQTESOLVE) graphical output for the hydraulic conductivity calculations from the slug tests.
SHINE Response The arithmetic mean of the Advanced Aquifer Test Analysis Software (AQTESOLV) hydraulic conductivity values from on-site slug tests is 0.0045 ft/sec. The geometric mean of the AQTESOLV hydraulic conductivity values from on-site slug tests is 0.0041 ft/sec. Since the calculated arithmetic mean of the hydraulic conductivity values was found to be more conservative than the calculated geometric mean of the hydraulic conductivity values, SHINE used the arithmetic mean of the hydraulic conductivity values to calculate the expected advective travel times provided in Table 2.4-13.
The AQTESOLV graphical outputs for the hydraulic conductivity calculations from on-site slug tests were previously provided to the NRC as Appendix F of the Preliminary Hydrological Analyses for the Janesville, Wisconsin site, provided as Attachment 23 to the SHINE Response to Environmental Requests for Additional Information (Reference 7).
RAI 2.4-4 SHINE PSAR, Section 2.4.11.2, Pathways, indicates that travel times through the unsaturated zone had not been considered due to the limited information available. An estimation of potential lag times through the unsaturated zone, following a release, is important with respect to evaluating accident scenarios and designing monitoring frequencies and remedial options.
Provide additional information on the bounding estimates for travel time through the unsaturated zone.
SHINE Response SHINE determined bounding estimates for travel time through the unsaturated zone, or vadose zone, based on the estimated travel distance (thickness) of the vadose zone and the estimated velocity of groundwater travel through the vadose zone.
Page 3 of 198 For vertical flow, the travel distance is calculated as the thickness of the vadose zone. The thickness of the vadose zone can be estimated as the difference between the surface and water elevations in boreholes drilled at the SHINE site, provided in Table 2.4-1 of the PSAR. SHINE estimates of vadose zone thickness are provided in Table 2.4-4-1.
A reasonable representative vadose zone thickness for travel time calculations can be taken as the minimum measured vadose zone thickness of 50 ft. As described in Subsection 2.4.1.4 of the PSAR, water table fluctuation at the SHINE site can be estimated to be two feet. A lower bound vadose zone thickness was estimated as the minimum measured vadose zone thickness (50 ft.) minus three times the estimated water table fluctuation (two feet), or 44 ft.
An upper bound vadose zone thickness was estimated as the maximum measured thickness (65 ft.) plus three times the estimated water table fluctuation (two feet), or 71 ft.
As described in Subsection 2.4.11.2 of the PSAR, the velocity of groundwater can be calculated using Darcys Law. The effective hydraulic conductivity for vadose zone transport was derived by applying a characteristic curve to the measured hydraulic conductivity values provided in Table 2.4-13 of the PSAR to adjust for the effect of water saturation. Unsaturated water content values are based on the information provided in Reference (8). SHINE assumed an effective gradient of 100 percent for vadose zone transport.
Bounding estimates for travel time through the vadose zone are provided in Table 2.4-4-2.
Table 2.4-4-1: Thickness of Vadose Zone Borehole Number Surface Elevation (ft)(b)
Water Elevation (ft)(b)
Thickness of Vadose Zone (ft)
G11-01 818.9 753.9 65.00 G11-02 822.09 763.6 58.49 G11-03 824.69 765.7 58.99 G11-04 821.65 763.2 58.45 G11-05 824.33 (a)
(a)
G11-06 825.65 (a)
(a)
G11-07 826.13 761.2 64.93 G11-08 824.52 765.5 59.02 G11-09 824.77 (a)
(a)
G11-10 825.96 761 64.96 SM-GW 1A 825.56 763.6 61.96 SM-GW 2A 819.01 762 57.01 SM-GW 3A 827.09 764.6 62.49 SM-GW 4A 811.5 761.5 50 Maximum Thickness of Vadose Zone 65.00 Minimum Thickness of Vadose Zone 50.00 Average Thickness of Vadose Zone 60.12 a) Measurements are obscured by drilling fluids.
b) Elevations are in NAVD-88
Page 4 of 198 Table 2.4-4-2: Vadose Zone Travel Time Vadose Zone Thickness (ft)
Assumption Soil Hydraulic Conductivity(a)
(ft/s)
Unsaturated Water Content(b)
Relative Permeability Effective Transport Porosity(c)
Gradient Advective Travel Time (years) 44 Upper Bound (Less Conservative) 0.002 20%
1%
40%
100%
2.8E-2 44 Expected (Mean) 0.0045 40%
10%
30%
100%
9.3E-4 44 Lower Bound (More Conservative) 0.0083 70%
40%
10%
100%
4.2E-5 50 Upper Bound (Less Conservative) 0.002 20%
1%
40%
100%
3.2E-2 50 Expected (Mean) 0.0045 40%
10%
30%
100%
1.1E-3 50 Lower Bound (More Conservative) 0.0083 70%
40%
10%
100%
4.8E-5 71 Upper Bound (Less Conservative) 0.002 20%
1%
40%
100%
4.5E-2 71 Expected (Mean) 0.0045 40%
10%
30%
100%
1.5E-3 71 Lower Bound (More Conservative) 0.0083 70%
40%
10%
100%
6.8E-5 a) Expected and Lower Bound values are based on the values provided in Table 2.4-13 of the PSAR. The Upper Bound value was approximated as 50 percent of the mean value.
b) Estimated from the information provided in Reference (8).
c) Expected and Lower Bound values are based on the values provided in Table 2.4-13 of the PSAR. The Upper Bound value was estimated based on maximum values anticipated for sandy soils.
Page 5 of 198 RAI 2.4-5 NUREG-1537, Part 1, Chapter 2, Site Characteristics, states, in part, the applicant should discuss and describe the hydrological characteristics of the site and vicinity in conjunction with present and projected population distributions, industrial facilities and land use, and site activities and controls.
SHINE PSAR, Section 2.4.1.2, General Setting - Groundwater, mentions that there are irrigation wells operated on properties in the vicinity that have the potential to influence groundwater levels. These irrigation wells could also act as pathways for bringing any groundwater contamination released by the facility to the surface. The pumping of irrigation wells can also have a significant effect on groundwater flow directions.
Provide additional information (e.g., irrigation well location(s), pumping rates, screened intervals) for the potential consequences of an uncontrolled release. Potentiometric surfaces under pumping versus non-pumping conditions should also be presented.
SHINE Response provides a list of well construction reports filed with the Wisconsin Department of Natural Resources (WDNR) since 1988 within five miles of the SHINE site. While historic well construction reports can be obtained from the Wisconsin Geological and Natural History Survey (WGNHS), the well data since 1988 contained in the WDNR database provides a better basis for evaluation of current flow rates and flow directions for SHINE site characterization, as the well data is more recent and more accurate. In addition, the WGNHS data reflects different hydrologic conditions that existed over a 50 year time period and are not reliable for use in characterizing the SHINE site.
Publicly available information from the WDNR includes well locations, pumping rates, and screened intervals. The well coordinates were estimated using the street address reported from the WDNR database. From this data set, potentiometric surfaces within four square miles of the SHINE site were generated for analysis. Figures 2.4-5-1 and 2.4-5-2 provide four mile by four mile scale potentiometric surfaces based on these wells using non-pumped (static) and pumped conditions, respectively. These surfaces were created by using the Kriging process on the wells provided in Attachment 1.
The groundwater flow direction on the SHINE site is toward the Rock River for both pumped and non-pumped conditions. Consequently, it is not anticipated that withdrawals from wells within a five mile radius will change the flow direction of groundwater on the SHINE site.
During a review of the well listing provided in Attachment 1, SHINE determined well UJ792, which is located about 2,000 ft from the SHINE site, has the lowest pumping head of the wells closest to the SHINE site. Using Darcys Law, SHINE calculated the advective travel times for well UJ792 to be 0.1 years (expected permeability and porosity assumptions) and 0.01 years (conservative permeability and porosity assumptions). SHINE will update Table 2.4-13 of the PSAR in the FSAR to include well UJ792 as an additional example receptor.
An IMR has been initiated to track the update to Table 2.4-13 in the FSAR.
Page 6 of 198 Figure 2.4-5-1: Groundwater Elevation Contours (Static State)
Page 7 of 198 Figure 2.4-5-2: Groundwater Elevation Contours (Pumping State)
Page 1 of 198 SHINE MEDICAL TECHNOLOGIES, INC.
SHINE MEDICAL TECHNOLOGIES, INC. APPLICATION FOR CONSTRUCTION PERMIT RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION PUBLIC VERSION The NRC staff determined that additional information was required (Reference 1) to enable the continued review of the SHINE Medical Technologies, Inc. (SHINE) application for a construction permit to construct a medical isotope facility (References 2 and 3). SHINE responded to a portion of the NRC staffs requests via Reference (4). The following information is provided by SHINE in response to the NRC staffs remaining requests.
CHAPTER 2 - SITE CHARACTERISTICS Section 2.4 - Hydrology (Applies to RAIs 2.4-1 through 4)
NUREG-1537, Part 1, Section 2.4, Hydrology, states, in part, that the applicant should provide sufficient information about the water table, groundwater, and features at the facility site to support analyses and evaluations in the PSAR Chapters 11 Radiation Protection Program and Waste Management, and 13, Accident Analysis, of consequences of uncontrolled release of radioactive material from pool leakage or failure, neutron activation of soils in the vicinity of the facility, or deposition and migration of airborne radioactive material released to the unrestricted area.
RAI 2.4-2 SHINE PSAR, Table 2.4-13, Summary of Parameters Used for Advective Travel Time Estimations (Section 2.4.11.2), presents the results of the travel time analysis. The effective porosity for the expected case is 30 percent. The reference cited in the table for the porosity (Gaffield et al., 2002), however, indicates that a porosity of 20 percent is most representative of the site conditions. A porosity of 20 percent would result in a travel time of 6 years as opposed to 9 years presented in the table.
Provide additional information on the technical rationale for the 30-percent porosity or recalculate the expected travel times.
SHINE Response Reference (5) (referenced in footnote e of Table 2.4-13 of the Preliminary Safety Analysis Report (PSAR)) provides a range of porosity values from 10 percent to 30 percent. The 10 percent porosity value would provide the shortest groundwater travel time, while the 30 percent porosity value would provide the longest groundwater travel time. SHINE used the 10 percent porosity value provided in Reference (5) to calculate the conservative advective travel times provided in Table 2.4-13.
Page 2 of 198 Although Reference (5) provides a typical value for porosity in Rock County, Wisconsin of 20 percent, SHINE does not believe a 20 percent effective porosity value would be consistent with the site-specific soil conditions described in Subsection 2.5.2.3 of the PSAR. Reference (6) provides arithmetic mean effective porosity values of 30 percent, 32 percent, and 33 percent for coarse, medium, and fine sand, respectively. These arithmetic mean porosity values are more typical of the subsurface conditions encountered at the SHINE site. Therefore, SHINE used a porosity value of 30 percent to calculate the expected advective travel times provided in Table 2.4-13.
RAI 2.4-3 SHINE PSAR, Table 2.4-13 (Section 2.4.11.2), presents the results of the travel time analysis.
An arithmetic average of the hydraulic conductivities was used in the expected case calculations. Typically, hydraulic conductivities are represented in a log-normal distribution, and geometric means are used to represent typical values.
Provide either additional information on the technical rationale for the averaging of the hydraulic conductivities or recalculate the expected travel times using a geometric mean for the hydraulic conductivity. Additionally, provide the Advanced Aquifer Test Analysis Software (AQTESOLVE) graphical output for the hydraulic conductivity calculations from the slug tests.
SHINE Response The arithmetic mean of the Advanced Aquifer Test Analysis Software (AQTESOLV) hydraulic conductivity values from on-site slug tests is 0.0045 ft/sec. The geometric mean of the AQTESOLV hydraulic conductivity values from on-site slug tests is 0.0041 ft/sec. Since the calculated arithmetic mean of the hydraulic conductivity values was found to be more conservative than the calculated geometric mean of the hydraulic conductivity values, SHINE used the arithmetic mean of the hydraulic conductivity values to calculate the expected advective travel times provided in Table 2.4-13.
The AQTESOLV graphical outputs for the hydraulic conductivity calculations from on-site slug tests were previously provided to the NRC as Appendix F of the Preliminary Hydrological Analyses for the Janesville, Wisconsin site, provided as Attachment 23 to the SHINE Response to Environmental Requests for Additional Information (Reference 7).
RAI 2.4-4 SHINE PSAR, Section 2.4.11.2, Pathways, indicates that travel times through the unsaturated zone had not been considered due to the limited information available. An estimation of potential lag times through the unsaturated zone, following a release, is important with respect to evaluating accident scenarios and designing monitoring frequencies and remedial options.
Provide additional information on the bounding estimates for travel time through the unsaturated zone.
SHINE Response SHINE determined bounding estimates for travel time through the unsaturated zone, or vadose zone, based on the estimated travel distance (thickness) of the vadose zone and the estimated velocity of groundwater travel through the vadose zone.
Page 3 of 198 For vertical flow, the travel distance is calculated as the thickness of the vadose zone. The thickness of the vadose zone can be estimated as the difference between the surface and water elevations in boreholes drilled at the SHINE site, provided in Table 2.4-1 of the PSAR. SHINE estimates of vadose zone thickness are provided in Table 2.4-4-1.
A reasonable representative vadose zone thickness for travel time calculations can be taken as the minimum measured vadose zone thickness of 50 ft. As described in Subsection 2.4.1.4 of the PSAR, water table fluctuation at the SHINE site can be estimated to be two feet. A lower bound vadose zone thickness was estimated as the minimum measured vadose zone thickness (50 ft.) minus three times the estimated water table fluctuation (two feet), or 44 ft.
An upper bound vadose zone thickness was estimated as the maximum measured thickness (65 ft.) plus three times the estimated water table fluctuation (two feet), or 71 ft.
As described in Subsection 2.4.11.2 of the PSAR, the velocity of groundwater can be calculated using Darcys Law. The effective hydraulic conductivity for vadose zone transport was derived by applying a characteristic curve to the measured hydraulic conductivity values provided in Table 2.4-13 of the PSAR to adjust for the effect of water saturation. Unsaturated water content values are based on the information provided in Reference (8). SHINE assumed an effective gradient of 100 percent for vadose zone transport.
Bounding estimates for travel time through the vadose zone are provided in Table 2.4-4-2.
Table 2.4-4-1: Thickness of Vadose Zone Borehole Number Surface Elevation (ft)(b)
Water Elevation (ft)(b)
Thickness of Vadose Zone (ft)
G11-01 818.9 753.9 65.00 G11-02 822.09 763.6 58.49 G11-03 824.69 765.7 58.99 G11-04 821.65 763.2 58.45 G11-05 824.33 (a)
(a)
G11-06 825.65 (a)
(a)
G11-07 826.13 761.2 64.93 G11-08 824.52 765.5 59.02 G11-09 824.77 (a)
(a)
G11-10 825.96 761 64.96 SM-GW 1A 825.56 763.6 61.96 SM-GW 2A 819.01 762 57.01 SM-GW 3A 827.09 764.6 62.49 SM-GW 4A 811.5 761.5 50 Maximum Thickness of Vadose Zone 65.00 Minimum Thickness of Vadose Zone 50.00 Average Thickness of Vadose Zone 60.12 a) Measurements are obscured by drilling fluids.
b) Elevations are in NAVD-88
Page 4 of 198 Table 2.4-4-2: Vadose Zone Travel Time Vadose Zone Thickness (ft)
Assumption Soil Hydraulic Conductivity(a)
(ft/s)
Unsaturated Water Content(b)
Relative Permeability Effective Transport Porosity(c)
Gradient Advective Travel Time (years) 44 Upper Bound (Less Conservative) 0.002 20%
1%
40%
100%
2.8E-2 44 Expected (Mean) 0.0045 40%
10%
30%
100%
9.3E-4 44 Lower Bound (More Conservative) 0.0083 70%
40%
10%
100%
4.2E-5 50 Upper Bound (Less Conservative) 0.002 20%
1%
40%
100%
3.2E-2 50 Expected (Mean) 0.0045 40%
10%
30%
100%
1.1E-3 50 Lower Bound (More Conservative) 0.0083 70%
40%
10%
100%
4.8E-5 71 Upper Bound (Less Conservative) 0.002 20%
1%
40%
100%
4.5E-2 71 Expected (Mean) 0.0045 40%
10%
30%
100%
1.5E-3 71 Lower Bound (More Conservative) 0.0083 70%
40%
10%
100%
6.8E-5 a) Expected and Lower Bound values are based on the values provided in Table 2.4-13 of the PSAR. The Upper Bound value was approximated as 50 percent of the mean value.
b) Estimated from the information provided in Reference (8).
c) Expected and Lower Bound values are based on the values provided in Table 2.4-13 of the PSAR. The Upper Bound value was estimated based on maximum values anticipated for sandy soils.
Page 5 of 198 RAI 2.4-5 NUREG-1537, Part 1, Chapter 2, Site Characteristics, states, in part, the applicant should discuss and describe the hydrological characteristics of the site and vicinity in conjunction with present and projected population distributions, industrial facilities and land use, and site activities and controls.
SHINE PSAR, Section 2.4.1.2, General Setting - Groundwater, mentions that there are irrigation wells operated on properties in the vicinity that have the potential to influence groundwater levels. These irrigation wells could also act as pathways for bringing any groundwater contamination released by the facility to the surface. The pumping of irrigation wells can also have a significant effect on groundwater flow directions.
Provide additional information (e.g., irrigation well location(s), pumping rates, screened intervals) for the potential consequences of an uncontrolled release. Potentiometric surfaces under pumping versus non-pumping conditions should also be presented.
SHINE Response provides a list of well construction reports filed with the Wisconsin Department of Natural Resources (WDNR) since 1988 within five miles of the SHINE site. While historic well construction reports can be obtained from the Wisconsin Geological and Natural History Survey (WGNHS), the well data since 1988 contained in the WDNR database provides a better basis for evaluation of current flow rates and flow directions for SHINE site characterization, as the well data is more recent and more accurate. In addition, the WGNHS data reflects different hydrologic conditions that existed over a 50 year time period and are not reliable for use in characterizing the SHINE site.
Publicly available information from the WDNR includes well locations, pumping rates, and screened intervals. The well coordinates were estimated using the street address reported from the WDNR database. From this data set, potentiometric surfaces within four square miles of the SHINE site were generated for analysis. Figures 2.4-5-1 and 2.4-5-2 provide four mile by four mile scale potentiometric surfaces based on these wells using non-pumped (static) and pumped conditions, respectively. These surfaces were created by using the Kriging process on the wells provided in Attachment 1.
The groundwater flow direction on the SHINE site is toward the Rock River for both pumped and non-pumped conditions. Consequently, it is not anticipated that withdrawals from wells within a five mile radius will change the flow direction of groundwater on the SHINE site.
During a review of the well listing provided in Attachment 1, SHINE determined well UJ792, which is located about 2,000 ft from the SHINE site, has the lowest pumping head of the wells closest to the SHINE site. Using Darcys Law, SHINE calculated the advective travel times for well UJ792 to be 0.1 years (expected permeability and porosity assumptions) and 0.01 years (conservative permeability and porosity assumptions). SHINE will update Table 2.4-13 of the PSAR in the FSAR to include well UJ792 as an additional example receptor.
An IMR has been initiated to track the update to Table 2.4-13 in the FSAR.
Page 6 of 198 Figure 2.4-5-1: Groundwater Elevation Contours (Static State)
Page 7 of 198 Figure 2.4-5-2: Groundwater Elevation Contours (Pumping State)