ML18235A068

NRC Letter with NRC-DOE Joint Plan for SRS Sdf

ML18235A068
Person / Time
Site:	PROJ0734
Issue date:	10/23/2018
From:	John Tappert Division of Decommissioning, Uranium Recovery and Waste Programs
To:	Connell E US Dept of Energy, Office of Environmental Management
H FELSHER NMSS DUWP
References
Download: ML18235A068 (16)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 23, 2018 Ms. Elizabeth Connell, Director Regulatory, Intergovernmental, and Stakeholder Engagement Office of Environmental Mgmt.

U.S. Department of Energy 1000 Independence Ave., SW Washington, DC 20585

SUBJECT:

JOINT PLAN FOR THE SAVANNAH RIVER SITE SALTSTONE DISPOSAL FACILITY

Dear Ms. Connell:

The purpose of this letter is to transmit the enclosed Joint Plan, developed by the U.S. Nuclear Regulatory Commission (NRC) and the U.S. Department of Energy (DOE), which identifies the information needed to support an NRC finding of reasonable assurance that the DOE demonstrated meeting the Title 10, Code of Federal Regulations Part 61 Subpart C Performance Objectives at the DOE Savannah River Site Saltstone Disposal Facility. Such an NRC finding would resolve the concerns in the NRC letter to the DOE dated April 30, 2012 (Agencywide Documents Access and Management System Accession No. ML120650576).

If you have any questions or need additional information, then please contact Harry Felsher of my staff at Harry.Felsher@nrc.gov or at (301) 415-6559.

Sincerely,

/RA/

John R. Tappert, Director Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards Docket No. PROJ0734

Enclosure:

Joint Plan for the Savanah River Site Saltstone Disposal Facility cc: J. Folk, DOE S. Wilson, SCDHEC WIR Service List WIR ListServ

SUBJECT:

JOINT PLAN FOR THE SAVANNAH RIVER SITE SALTSTONE DISPOSAL FACILITY DATE: October 23, 2018 DISTRIBUTION: KPinston GAlexander HArlt LDesotell MRoberts/Region I ADAMS ACCESSION NO. ML18235A068 *via email OFFICE NMSS/DUWP NMSS/DUWP NMSS/DUWP NMSS/DUWP ASchwartzman NAME HFelsher ARidge* SAchten* for CMcKenney*

DATE 08/23/18 08/23/18 08/23/18 08/28/18 OFFICE NMSS/DUWP NMSS/DUWP NMSS/DUWP NAME RChang AKock JTappert DATE 08/27/18 09/11/18 10/23/18 OFFICIAL RECORD COPY

JOINT PLAN FOR THE SAVANNAH RIVER SITE SALTSTONE DIPOSAL FACILITY The purpose of this Joint Plan to identify what information is needed from the U.S. Department of Energy (DOE) to support an U.S. Nuclear Regulatory Commission (NRC) finding of reasonable assurance that the DOE demonstrated meeting the Title 10, Code of Federal Regulations Part 61 (10 CFR) Subpart C Performance Objectives (POs) at the DOE Savannah River Site (SRS) Saltstone Disposal Facility (SDF).

The NRC determined that resolving the current High-Priority monitoring factors (MFs) from the 2013 NRC SDF Monitoring Plan (NRCs Agencywide Documents Access and Management System (ADAMS) Accession No. ML13100A113), as supplemented by the NRC letters listed below to the DOE, would support an NRC staff finding of reasonable assurance that the DOE had demonstrated meeting the 10 CFR Part 61 POs. The NRC requested schedule input from the DOE on when information related to those High-Priority monitoring factors would be provided to the NRC. The DOE provided the current anticipated schedule of providing that information to the NRC. However, if any of the following occurs, then the NRC expects that either the risk-significance and prioritization of the SDF monitoring factors may be affected or new SDF monitoring factors may be created, which would need to be addressed by the DOE in order for the NRC to reach a finding of reasonable assurance and issue an NRC Type-V Letter of Resolution: (1) significant future changes in either the DOE model or the DOE model assumptions; or (2) future research or future field observations that significantly increase uncertainty or demonstrate significantly worse than expected performance at the SDF.

The information in this publicly available NRC/DOE Joint Plan mostly exists in publicly available NRC and DOE documents. It is important for all stakeholders to understand that: (1) the DOE may decide at any time to change their schedule for providing information to the NRC; (2) the Joint Plan is expected to change over time; and (3) the Joint Plan relies on future NRC and DOE research results.

Currently, the 2013 NRC SDF Monitoring Plan (Rev. 1, September 2013) (ADAMS Accession No. ML13100A113), as supplemented by NRC letters to the DOE listed below, is the primary source for the NRC information used to develop the Joint Plan:

• In the letter dated June 5, 2017, (ADAMS Accession No. ML17097A351), the NRC closed MF 3.01, MF 3.02, and MF 3.04 under both the POs §40.41 and §40.42.

• In the letter dated March 1, 2018, (ADAMS Accession No. ML18033A071), the NRC clarified the number of monitoring factors in the SRS SDF and Tank Farms Monitoring Plans, such that the total number of monitoring factors when the SDF Monitoring Plan, Rev. 1 was created was 40.

• In the letter dated June 29, 2018, (ADAMS Accession No. ML18107A161), the NRC opened the new MF 10.14 (Scenario Development and Defensibility) under both the POs

§40.41 and §40.42.

Enclosure

• In the letter dated October 16, 2018, (ADAMS Accession No. ML18219B035), the NRC:

(1) opened the new MF 8.03 (Identification and Monitoring of Groundwater Plumes in the Z-Area) under the three POs §61.41, §61.42, and §61.43; (2) lowered the priority of MF 5.02 (Chemical Reduction of Technetium by Saltstone) from high to medium under both POs §61.41 and §61.42; (3) closed MF 5.05 (Potential for Short-Term Rinse-Release from Saltstone) under both POs §61.41 and §61.42; and (4) closed MF 6.02 (Technetium Sorption in Disposal Structure Concrete) under both POs §61.41 and

§61.42.

Currently, the DOE SRS Liquid Waste Performance Assessment Maintenance Program Fiscal Year 2017 Implementation Plan (SRR-CWDA-2016-00119, Rev. 0, January 2017) (ADAMS Accession No. ML17047A418), which is updated annually by the DOE, is the primary source for the DOE information used to develop the Joint Plan.

WASTE INCIDENTAL TO REPROCESSING BACKGROUND:

As required by Section 3116(b) of the Ronald W. Reagan National Defense Authorization Act for Fiscal Year 2005 (NDAA), the NRC, in coordination with the NDAA-Covered State, monitors the DOE disposal actions at the DOE NDAA Waste Incidental to Reprocessing (WIR) locations to determine DOE compliance with the five POs in Subpart C of 10 CFR Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste."

For each of the specific DOE NDAA-WIR locations, the NRC issued a monitoring plan that includes such activities as: technical reviews, data reviews, and onsite observation visits (OOVs). When the NRC performs those activities, the NRC issues publicly available Technical Review Reports (TRRs), Data Review Reports, and OOV Reports.

The current programmatic DOE documents for all the DOE WIR locations (both NDAA and not NDAA) are DOE Order 435.1, Radioactive Waste Management, associated DOE Manual 435.1-1, Radioactive Waste Management Manual, and other associated DOE guidance.

In those DOE documents, the DOE requires the ongoing maintenance of all performance assessments (PAs), which is done by an annual site-specific implementation plan that includes:

(1) annual maintenance program activities; (2) PA development/revisions (i.e., both in-progress and future), and (3) testing and research activities.

Note that it is a routine NRC/DOE WIR process that the DOE provides research plans to the NRC for review during NDAA monitoring. Many times during previous NDAA monitoring activities, the DOE provided the NRC with the DOE research plans or path forward plans. In response, the NRC provided recommendations on those DOE research plans or path forward plans back to the DOE. Both the NRC and the DOE consider that NRC/DOE coordination on research plans or path forward plans to be successful. Accordingly, the NRC and the DOE plan to continue NRC/DOE coordination on future research plans or path forward plans.

MONITORING AT THE SAVANNAH RIVER SITE SALTSTONE DISPOSAL FACILITY:

In 2009, the DOE submitted a new SDF PA (October 2009, Rev. 0, ADAMS Accession No. ML101590008) to the NRC for review. In 2012, the NRC issued the second SDF Technical Evaluation Report (TER) (April 30, 2012, Rev. 1, ADAMS Accession No. ML121170309). The 2012 NRC SDF TER contained the NRC review, including detailed descriptions of the NRC staff evaluation and a summary table in Appendix A that linked a concise statement of each NRC technical concern with the sections of that TER that provided more detailed descriptions of

those NRC technical concerns. Also on April 30, 2012, the NRC issued the Type-IV Letter of Concern (ADAMS Accession No. ML120650576). The NRC will issue a Type-IV Letter of Concern to the DOE and the NDAA-Covered State when the NRC staff concludes that there are concerns with the DOE demonstration of meeting the POs and the DOE cannot adequately address those NRC concerns. The Appendix A summary table of NRC technical concerns in the 2012 NRC SDF TER was revised to identify the monitoring factors in the 2013 NRC SDF Monitoring Plan.

In the 2013 NRC SDF Monitoring Plan, the NRC staff included tables that provided the NRC staff prioritization of the monitoring factors based on the 2012 NRC SDF TER. The current versions of the NRC staff prioritization of the SDF monitoring factors are included below. The current NRC review of the DOE disposal actions at the SDF is based on the DOE documents that supplemented the 2009 SDF PA. After the NRC issues a new SDF TER, the NRC expects to issue a revised SDF monitoring plan, which may have updates to monitoring areas, monitoring factors, and the NRC staff prioritization of those monitoring factors.

CURRENT TABLE FOR CLOSING HIGH PRIORITY DOE SRS SDF MONITORING FACTORS The Table below provides the status of progress of the DOE activities, as described in the 2013 NRC SDF Monitoring Plan and as supplemented by the NRC letters to the DOE listed above in the Joint Plan, for the NRC to close the High Priority monitoring factors for the DOE SRS SDF.

The following bullets provides the sources of information for the Table below:

• The 2013 NRC SDF Monitoring Plan dated September 2013 (ADAMS Accession No. ML13100A113) includes tables that link each 10 CFR Part 61 PO to one or more monitoring areas and links each monitoring area to one or more monitoring factor.

• The 2012 NRC SDF TER dated April 30, 2012, (ADAMS Accession No. ML121170309) contained the NRC technical concerns, which were summarized in a concise form in the summary table in Appendix A. The NRC technical concerns led to the 2012 NRC Type-IV Letter of Concern, dated April 30, 2012, (ADAMS Accession No. ML120650576). The High Priority monitoring factors are in the column entitled, High Priority MF # and Title in the Table. Note that the current NRC staff prioritization tables for all the SDF monitoring factors are also included below.

• In each monitoring factor in the 2013 NRC SDF Monitoring Plan and as supplemented by the NRC letters to the DOE listed above in the Joint Plan, there is a description for how the NRC expects to close that monitoring factor.

• For each fiscal year, the DOE updates the SRS PA Maintenance Program Implementation Plan, which includes the DOE plans to address the SDF monitoring factors. The most recently issued version of that DOE document is SRR-CWDA-2016-00119, Rev. 0, dated January 2017 (ADAMS Accession No. ML17047A418).

• For consistency in the Table below, the NRC used standard formatting and changed the DOE terminology to the NRC terminology.

CURRENT TABLE FOR CLOSING HIGH PRIORITY DOE SRS SDF MONITORING FACTORS POs High Priority NRC Closing MF DOE Activity in DOE Comments in NRC Comments Schedule that MF # and Title Appendix A of Appendix B of DOE Provided SRR-CWDA-2016-00119 SRR-CWDA-2016-00119 to NRC Monitoring Area (MA) 1 - Inventory - No Current High Priority Monitoring Factors MA 2 - Infiltration and Erosion Control - No Current High Priority Monitoring Factors MA 3 - Waste Form Hydraulic Performance

§61.41 3.03 - The NRC expects Section 2.3.3.1 - Measure The saltstone sampling On 03/23/2017, the NRC February 2020 and Applicability of to close MF 3.03 Physical Properties of and analysis plan issued the TRR entitled,

§61.42 Laboratory Data under both POs Laboratory Prepared established a strategy for Saltstone Waste Form to Field- §61.41 and §61.42 Saltstone Simulant studies to reduce Hydraulic Performance Emplaced after the NRC Samples, Actual Tank 50 Performance (ADAMS Accession Saltstone determines that Salt Solution Samples, Assessment uncertainty No. ML17018A137) representing the Saltstone In-Line Process in the area of saltstone related to MF 3.01, hydraulic properties Sample, and [SDS] 2A hydraulic conductivity and MF 3.02, MF 3.03, of field-emplaced Emplaced Core Sample for correlating grout MF 3.04, and MF 10.05, saltstone with the properties between recommended to close hydraulic properties Laboratory prepared and laboratory-prepared MF 3.01, MF 3.02, and of laboratory- processed room samples will samples and core-drilled MF 3.04; recommended produced samples have physical properties samples from actual to narrow the focus of is adequate. That testing performed to emplaced grout. A MF 3.03, and included assessment should determine the hydraulic variety of laboratory information needed from account for the conductivity, Kd, bulk cured testing has been the DOE to close range of expected density, porosity, and micro completed, including one MF 3.03 and MF 10.05.

disposal conditions structure/phase analysis. in which samples were of field-emplaced Future testing will compare cured under conditions On 06/05/17, the NRC saltstone as well as these properties to those similar to those expected sent a letter to the DOE effects of scale. measured from field- for field-emplaced (ADAMS Accession emplaced core sampling. saltstone. The results No. ML17097A351) that Alternately, were incorporated into the closed MF 3.01 under MF 3.03 may be FY 2014 SDF Special both POs §61.41 and closed if the NRC Analysis Document. §61.42; MF 3.02 under determines that the both POs §61.41 and DOE bases the Multiple cores were §61.42; and MF 3.04 hydraulic properties extracted via a wet core under both POs §61.41 of saltstone on the drilling process in and §61.42.

properties of an FY 2015 approximately appropriate range 20 months after the of samples of field- saltstone of interest was emplaced processed in the saltstone, rather Saltstone Processing than on Facility and subsequently measurements of emplaced in SDS 2A.

The physical property

laboratory- data for field-emplaced Even though the DOE produced samples. and laboratory-prepared Comments indicate that samples is summarized No further specific in the SDS 2A Core work will be done by Sampling Report (SRR- the DOE, the DOE is CWDA-2016-00051) with currently performing values for SDF model dynamic leaching inputs provided in the experiments on SDS 2A report where applicable. cores that are expected No further specific work to address the issues regarding field-emplaced remaining in the saltstone is planned for narrowed scope of this monitoring factor. MF 3.03.

POs High Priority NRC Closing MF DOE Activity in DOE Comments in NRC Comments Schedule that MF # and Title Appendix A of Appendix B of DOE Provided SRR-CWDA-2016-00119 SRR-CWDA-2016-00119 to NRC MA 4 - Waste Form Physical Degradation

§61.41 4.01 - Waste The NRC expects Section 2.3.2.2 - Studies The degradation models In the NRC Request for February 2020 and Form Matrix to close MF 4.01 Related to Cementitious for concrete and Additional Information

§61.42 Degradation under both POs Materials Degradation Due saltstone grout were (RAI) Comments on the

§61.41 and §61.42 to Radiation Damage revised for the FY 2014 DOE FY 2013 SDF after the NRC SDF Special Analysis Special Analysis determines that A literature search will be Document to incorporate Document (ADAMS support for conducted to gain a better greater conservatisms Accession modeled changes understanding of the potential and to modify inputs to No. ML14148A153) and in the saltstone degradation of cementitious implicitly model fractures the RAI Questions on the hydraulic materials exposed to in the matrix. FY 2014 SDF Special conductivity and radiation. Analysis Document diffusivity during (ADAMS Accession the performance Section 2.2.1 - Prepare No. ML15161A541), the period is sufficient. Out-Year Saltstone NRC raised concerns Disposal Facility related to the DOE waste Performance Assessment form degradation Revisions assumptions, including justification for the This section describes future assumed controlling revisions to the Performance degradation mechanism Assessment that will and the adequacy of the incorporate improvements to linear degradation rate to conceptual modeling. compensate for additional degradation mechanisms.

The NRC staff is currently reviewing the DOE revised modeling of waste form physical degradation from the DOE FY 2014 SDF Special Analysis Document and that NRC staff review will be documented in a forthcoming TRR.

In addition, when the DOE submits the next SDF performance assessment in February 2020, the NRC will evaluate whether the model support for the amount of credit taken for long-term performance of the waste form is sufficient.

POs High Priority NRC Closing MF DOE Activity in DOE Comments in NRC Comments Schedule that MF # and Title Appendix A of Appendix B of DOE Provided SRR-CWDA-2016-00119 SRR-CWDA-2016-00119 to NRC

§61.41 4.02 - Waste The NRC expects Section 2.3.2 - Degradation The degradation models In the NRC Request for February 2020 and Form to close MF 4.02 Studies for concrete and Information (RAI)

§61.42 Macroscopic under both POs saltstone grout were Comments on the DOE Fracturing §61.41 and §61.42 Previous testing and research revised based on FY FY 2013 SDF Special after the NRC activities were carried out to 2013 test data for the FY Analysis Document determines that provide a better 2014 SDF Special (ADAMS Accession model support for understanding of Analysis Document to No. ML14148A153) and the assumed degradation mechanisms and incorporate greater the RAI Questions on the formation of fracturing. See the DOE conservatisms and to FY 2014 SDF Special macroscopic document SRNL-STI-2013- modify inputs to implicitly Analysis Document fractures during the 00522. model fractures in the (ADAMS Accession performance period matrix. No. ML15161A541), the is sufficient. NRC raised concerns related to the DOE waste form degradation assumptions, including justification for the assumed controlling degradation mechanism

and the adequacy of the linear degradation rate to compensate for additional degradation mechanisms.

The NRC staff is currently reviewing the DOE revised modeling of waste form physical degradation from the DOE FY 2014 SDF Special Analysis Document and that NRC staff review will be documented in a forthcoming TRR.

In addition, when the DOE submits the next SDF performance assessment in February 2020, the NRC will evaluate whether the model support for the amount of credit taken for long-term performance of the waste form is sufficient.

POs High Priority NRC Closing MF DOE Activity in DOE Comments in NRC Comments Schedule that MF # and Title Appendix A of Appendix B of DOE Provided SRR-CWDA-2016-00119 SRR-CWDA-2016-00119 to NRC MA 5 - Waste Form Chemical Performance

§61.41 5.01 - The NRC expects Section 2.3.2.1 - Long- In June 2015, the NRC On 06/05/2015, the NRC February 2020 and Radionuclide to close MF 5.01 Term Radiological issued a TRR entitled, issued the TRR entitled,

§61.42 Release from under both POs Lysimeter Program Oxidation of Reducing Oxidation of Reducing Field-Emplaced §61.41 and §61.42 Cementitious Waste Cementitious Waste Saltstone after the NRC This task is expected to Forms (ADAMS Forms (ADAMS determines that provide Kd values in soil and Accession Accession measurements of cementitious materials as No. ML15098A031) No. ML15098A031) radionuclide well as additional information related to MF 5.01, related to MF 5.01, release rates from about long-term geochemical MF 5.02, MF 5.03, and MF 5.02, MF 5.03, and field-emplaced and transport phenomena MF 5.05. MF 5.05 and included saltstone used in that will be used to support the information needed

the performance the waste release and Studies to better quantify from the DOE to close assessment are transport models. radionuclide release from those four monitoring reliable. field-emplaced saltstone factors.

Section 2.3.3.1 - Measure are complete. Multiple Physical Properties of cores were extracted via The DOE is currently Laboratory Prepared a wet core drilling process performing dynamic Saltstone Simulant in FY 2015 approximately leaching experiments on Samples, Actual Tank 50 20 months after the SDS 2A cores that are Salt Solution Samples, saltstone of interest was expected to address Saltstone In-Line Process processed in the MF 5.01; however, the Sample, and [SDS] 2A Saltstone Processing DOE may need to revise Emplaced Core Sample Facility and subsequently model assumptions if emplaced in SDS 2A. preliminary results for Tc Laboratory prepared and The physical property release and I release are processed room samples will data for field-emplaced supported by the results have physical properties and laboratory-prepared of ongoing experiments.

testing performed to samples is summarized In addition, the priority of determine the hydraulic in the DOE SDS 2A Core MF 5.04 may be changed conductivity, Kd, bulk cured Sampling Report (SRR- from Medium to High, density, porosity, and micro CWDA-2016-00051) with depending on whether structure/phase analysis. values for SDF model the DOE model Future testing will compare inputs provided in the assumptions are these properties to those report where applicable. supported by the results measured from emplaced No further specific work of ongoing experiments core sampling. regarding field- emplaced with the SDS 2A cores.

saltstone is planned for this monitoring factor. On 01/05/2017, the NRC issued the TRR entitled, Iodine Sorption Coefficients for use in Performance Assessments for the Saltstone Disposal Facility (ADAMS Accession No. ML16342C5751) related to MF 5.04, MF 6.01, MF 7.01, MF 10.04, MF 10.06, and MF 10.09 and included the information needed from DOE to close those six monitoring factors. In addition, because of the risk-significance of the

assumed saltstone Kd values for iodine, the TRR recommended to expand MF 5.04 to include the sorption of iodine on saltstone and to expand MF 6.01 to include sorption of iodine on disposal structure concrete. Also, because the Kd values assumed by the DOE appear to be slightly higher than is justified and the low sorption of iodine in saltstone may cause the chemical performance of the disposal structure concrete to control the release of iodine from the engineered system, the TRR recommended expanding MF 6.01 to include sorption of iodine on disposal structure concrete. In addition, because the basis for the DOE assumed leachate impact factors and resulting leachate impacted subsurface Kd values is unclear, the TRR recommended expanding MF 7.01 to include the subsurface Kd values for iodine as well as the leachate impact factors and the leachate impacted subsurface Kd values for iodine.

MA 6 - Disposal Structure Performance - No Current High Priority Monitoring Factors MA 7 - Subsurface Transport - No Current High Priority Monitoring Factors

POs High Priority NRC Closing MF DOE Activity in DOE Comments in NRC Comments Schedule that MF # and Title Appendix A of Appendix B of DOE Provided SRR-CWDA-2016-00119 SRR-CWDA-2016-00119 to NRC MA 8 - Environmental Monitoring

§61.41 8.03 - The NRC expects Not Applicable because Not Applicable because On 5/17/2018, the NRC February 2020 and Identification and to close MF 8.03 MF 8.03 was created after MF 8.03 was created issued the TRR entitled,

§61.42 Monitoring of under both POs SRR-CWDA-2016-00119 after SRR-CWDA-2016- Groundwater Monitoring Groundwater §61.41 and §61.42 was issued 00119 was issued At and Near the Planned Plumes in the when the NRC Saltstone Disposal Z Area determines that the Facility (ADAMS groundwater Accession monitoring system No. ML18117A494).

in the Z-Area can: That TRR recommended (1) identify that the NRC create saltstone MF 8.03, Identification contaminants in the and Monitoring of groundwater in the Groundwater Plumes in SDF at no more the Z-Area as a High than 150 ft [46 m] Priority monitoring factor from a disposal and included the structure; and information needed from (2) track the the DOE to close movements of the MF 8.03 under both PO groundwater plume §61.41 and PO §61.42.

(e.g., know the horizontal and On October 16, 2018, vertical extent of the NRC sent a letter to the plume; be able the DOE (ADAMS to follow the Accession approximate path No. ML18219B035 that of the peak of the created MF 8.03 under plume). POs §61.41, §61.42, and

§61.43.

§61.43 8.03 - The NRC expects Not Applicable because Not Applicable because On 5/17/2018, the NRC February 2020 Identification and to close MF 8.03 MF 8.03 was created after MF 8.03 was created issued the TRR entitled, Monitoring of under PO §61.43 SRR-CWDA-2016-00119 after SRR-CWDA-2016- Groundwater Monitoring Groundwater when whichever of was issued 00119 was issued At and Near the Planned Plumes in the the following comes Saltstone Disposal Z Area first: (1) when the Facility (ADAMS institutional control Accession period ends; or No. ML18117A494).

(2) when the NRC That TRR recommended staff determines that the NRC create that the

groundwater MF 8.03, under both POs monitoring system §61.41 and PO §61.42.

in the Z-Area can: After the July 2018 NRC (a) identify Onsite Observation Visit, saltstone the NRC decided to also contaminants in the add MF 8.03 under PO groundwater in the §61.43 SDF at no more than 150 ft [46 m] On October 16, 2018, from a disposal the NRC sent a letter to structure; and (b) the DOE (ADAMS track the Accession movements of the No. ML18219B035) that groundwater plume created MF 8.03 under (e.g., know the POs §61.41, §61.42, and horizontal and §61.43.

vertical extent of the plume; be able to follow the approximate path of the peak of the plume).

MA 9 - Site Stability - No Current High Priority Monitoring Factors POs High Priority NRC Closing MF DOE Activity in DOE Comments in NRC Comments Schedule that MF # and Title Appendix A of Appendix B of DOE Provided SRR-CWDA-2016-00119 SRR-CWDA-2016-00119 to NRC MA 10 - Performance Assessment Model Revisions

§61.41 10.01 - The NRC expects Section 2.2.1 - Prepare The FY 2014 SDF Special The NRC staff is The schedule is and Implementation to close MF 10.01 Out-Year Saltstone Analysis Document currently reviewing the tied to the

§61.42 of Conceptual under both POs Disposal Facility provides a revised model DOE implementation of schedule for the Model §61.41 and §61.42 Performance Assessment with a number of the DOE document revision to the after the DOE Revisions important updates. With entitled Conceptual DOE SDF updates the SDF it, the DOE also provides Model Development for performance performance This section describes future more intermediate results the Saltstone Disposal assessment and assessment and revisions to the SDF and evidence of quality Facility Performance supplements the NRC performance assessment assurance practices. Assessment (SRR- (i.e., special determines that that will incorporate CWDA-2018-00006, analysis intermediate model improvements to conceptual Rev. 0) and will review documents).

results are modeling. the implementation of consistent with the conceptual models in the conceptual models, expected future DOE quality assurance SDF performance methods used are assessment.

appropriate, and

parameter values and uncertainty ranges are appropriate.

POs High Priority NRC Closing MF DOE Activity in DOE Comments in NRC Comments Schedule that MF # and Title Appendix A of Appendix B of DOE Provided SRR-CWDA-2016-00119 SRR-CWDA-2016-00119 to NRC

§61.41 10.02 - The NRC expects Section 2.2.1 - Prepare The FY 2014 SDF Special The NRC staff is The schedule is and Defensibility of to close MF 10.02 Out-Year Saltstone Analysis Document currently reviewing the tied to the

§61.42 Conceptual under both POs Disposal Facility provides a revised model DOE implementation of schedule for Model §61.41 and §61.42 Performance Assessment with a number of the DOE document revision to the after the DOE Revisions important updates. With entitled Conceptual DOE SDF updates the SDF it, the DOE also provides Model Development for performance performance This section describes future more intermediate results the Saltstone Disposal assessment and assessment and revisions to the SDF and evidence of quality Facility Performance any the NRC performance assessment assurance practices. Assessment (SRR- supplements determines that the that will incorporate CWDA-2018-00006, (i.e., special conceptual models improvements to conceptual Rev. 0) and will review analysis are appropriate. modeling. the conceptual models documents).

used in the expected future DOE SDF performance assessment.

MA 11 - Radiation Protection Program - No Current High Priority Monitoring Factors

Current Status of Monitoring Factors in Monitoring Areas 1 through 6 MA 1 MA 2 MA 3 MA 4 MA 5 MA 6 Inventory Infiltration Waste Form Waste Form Waste Form Disposal and Erosion Hydraulic Physical Chemical Structure Control Performance Degradation Degradation Performance

- 1.01 - - 2.01 - - 3.01 - - 4.01 - - 5.01 - - 6.01 -

Inventory in Hydraulic Hydraulic Waste Form Radionuclide Certain Risk-Disposal Performance of Conductivity of Matrix Release from Significant Kd Structures § Closure Cap Field-Emplaced Degradation +/- Field-Emplaced Values in Saltstone +/- Saltstone +/- Disposal Structure Concrete

- 1.02 - - 2.02 - - 3.02 - - 4.02 - - 5.02 - - 6.02 -

Methods Used Erosion Control Variability of Waste Form Chemical Tc Sorption in to Assess of the SDF Field-Emplaced Macroscopic Reduction of Tc Disposal Inventory Engineered Saltstone +/- Fracturing +/- by Saltstone +/- Structure Surface Cover Concrete +/-

and Adjacent Area.

- 3.03 - - 5.03 - - 6.03 -

Applicability of Reducing Performance of Laboratory Data Capacity of Disposal to Saltstone Structure Roofs Field-Emplaced and HDPE/GCL Saltstone +/- Layers

- 3.04 - - 5.04 - - 6.04 -

Effect of Curing Certain Risk- Disposal Temperature on Significant Kd Structure Saltstone Values for Concrete Hydraulic Saltstone Fracturing Properties +/-

- 5.05 - - 6.05 -

Potential for Integrity of Short-Term Non-Rinse-Release cementitious from Saltstone Materials

§ Periodic Monitoring Factors (i.e., MFs related to data that NRC staff expects to review on a periodic basis)

Low Priority Medium Priority

+/- High Priority Closed

Current Status of Monitoring Factors in Monitoring Areas 7 through 11 MA 7 MA 8 MA 9 MA 10 MA 11 Subsurface Environmental Site Stability Performance Radiation Transport Monitoring Assessment Model Protection Revisions Program

- 7.01 - - 8.01 - - 9.01 - - 10.01 - - 11.01 -

Certain Risk- Leak Detection § Settlement Due Implementation of Conceptual Dose to Significant Kd to Increased Models +/- Individuals Values in Site Overburden During Sand and Clay Operations §

- 8.02 - - 9.02 - - 10.02 - - 11.02 -

Groundwater Settlement Due Defensibility of Conceptual Air Monitoring § Monitoring § to Dissolution of Models +/-

Calcareous - 10.03 -

Sediment Diffusivity in Degraded Saltstone

- 8.03 - - 10.04 -

Identification and Kd Values for Saltstone Monitoring of Groundwater - 10.05 -

Plumes in the Z Moisture Characteristic Area +/- Curves

- 10.06 -

Kd Values for Disposal Structure Concrete

- 10.07 -

Calculation of Build-Up in Biosphere Soil

- 10.08 -

Consumption Factors and Uncertainty Distributions for Transfer Factors

- 10.09 -

Kd Values for SRS Soil

- 10.10 -

Far-Field Model Calibration

- 10.11 -

Far-Field Model Source Loading Approach

- 10.12 -

Far-Field Model Dispersion

- 10.13 -

Impact of Calcareous Zones on Contaminant Flow and Transport

- 10.14 -

Scenario Development and Defensibility

§ Periodic Monitoring Factors (i.e., MFs related to data that NRC staff expects to review on a periodic basis)

Low Priority Medium Priority

+/- High Priority