ML18153A808

Provides Comments on EPA Pr Re Criteria for Certification & Determination of Waste Isolation Pilot Plant Compliance W/ Environ Standards for Mgt & Disposal of SF,high-level & Transuranic Radwastes.Guidance Re Categorization Needed

ML18153A808
Person / Time
Site:	Surry, North Anna
Issue date:	04/28/1995
From:	Bowling M VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	ENVIRONMENTAL PROTECTION AGENCY
References
GL-95-04, GL-95-4, NUDOCS 9505090018
Download: ML18153A808 (2)

Text

5000 Dominion B011le1*ard Glen Alle11, Virginia 23060

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Apri 1 28, 1995 Attn: Docket No. A-92-56, Air Docket Room M-1500 (LE-131)

VIRGINIA POWER Serial No. GL 95-004 NL&P/EJW U.S. Environmental Protection Agency 401 M Street SW.

Washington, D.C. 20460 Gentlemen:

COMMENTS ON PROPOSED RULE CRITERIA FOR THE CERTIFICATION AND DETERMINATION OF THE WASTE ISOLATION PILOT PLANT'S COMPLIANCE WITH ENVIRONMENTAL STANDARDS FOR THE MANAGEMENT AND DISPOSAL OF SPENT NUCLEAR FUEL. HIGH-LEVEL AND TRANSURANIC RADIOACTIVE WASTES In the January 30, 1995 Federal Register (page 5766), the U. S. Environmental Protection Agency (EPA) solicited comments concerning a proposed rule change to 40 CFR Part 194. The proposed rule establishes criteria for certifying and determining whether the Department of Energy's Waste Isolation Pilot Plant (WIPP) complies with disposal standards set forth in 40 CFR Part 191 (Environmental Standards for the Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes). Based upon our review, the following comments and concerns with the EPA's proposed rule are hereby submitted:

• The proposed 40 CFR Part 194.23{a)(2) requires any application for certification of compliance to include a complete listing .of conceptual models considered but not used to support such application, a description of such models, and an explanation of the reasons why such models were not used to support such application. The discussion in 60 FR 5771 states that this requirement is proposed in order to assist the EPA's determination of whether the conceptual models used to support a compliance certification application offer the best representation of the disposal system or whether other theories may be more or equally appropriate.

The application for certification of compliance has already inclu-aed a complete -

listing and description of the models used to support such application. All relative information (models, computer codes, observed and measured data, etc.) demonstrating compliance are stipulated in the proposed 40 CFR Part 194.23{a)(3). Therefore, the proposed 40 CFR Part 194.23(a)(2) creates an

.__._ extra burden and unnecessary documentation for the applicant to follow.

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• The proposed 40 CFR Part 194.24(c)(1) requires any application for certification to identify and describe the methods used to determine waste characteristics and the uncertainty associated with such methods. In the discussion about characterization of wastes for the WIPP, the EPA identifies a variety of methods which may be used including sampling and analysis, radioassay, and examination of waste generation documentation and associated records (60 FR 5772). The proposed rule would then subject the characterization and the process used to obtain it to EPA's scrutiny.

Guidance should be provided, either in the regulation or in a separate publication, describing those categorization methods which are acceptable and which are not acceptable to EPA and the bases for acceptance or rejection of such methods. Additionally, if calculation methods are used for waste characterization analysis, guidance should be provided for any assumptions, model parameters, and data ranges which are acceptable to the EPA.

We appreciate the opportunity to comment on the Federal Register Notice. If you have any questions, please contact us.

Very truly yours, M. L. Bowling, Manager Nuclear Licensing and Programs cc: ,* U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Docket Nos. 50-280, 50-281, 50-338, and 50-339 License Nos. DPR-32, DPR-37, NPF-4, and NPF-7 Mr. M. W. Branch NRC Senior Resident Inspector Surry Power Station Mr. R. D. McWhorter NRC Senior Resident Inspector North Anna Power Station Mr. John F. Schmitt, Director Radiological Protection, Emergency Preparedness, and Waste Regulation Nuclear Energy Institute 1776 I Street, Suite 400 Washington, D. C. 20006-3708