ML20033H074
| ML20033H074 | |
| Person / Time | |
|---|---|
| Issue date: | 03/26/1990 |
| From: | Tokar M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Boyle R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-PROJ-M-32 NUDOCS 9004180112 | |
| Download: ML20033H074 (7) | |
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MAR 2 6 %90 A:\\JK-BOYLE.MEM MEMORANDUM'FOR:
Regis R.
Boyle, Acting Chief Regulatory Branch' Division.of Low-Level Waste Management-and Decommissioning, NMSS THRU:
John J.
Surmeier,. Chief Technical Branch Division of Low-Level Waste Management and Decommissioning,-NMSS.
FROM:
Michael Tokar, Section Leader i
Technical Branch Division of Low-Level Waste Management
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and Decommissioning, NMSS
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SUBJECT:
LLTB REVIEW COMMENTS ~ON WESTEVALLEY i
DEMONSTRATION PROJECT (WVDP) DOCUMENTS i
I In accordance with~the verbal request of Larry Pittiglio, LLWM' Contact for-the West Valley project, we have attached the review comments of Engineering Section, LLTB on the three. WVDP' documents provided to NRC for review by DOE.
We have identified the three DOE documents'that LLTB has reviewed at the beginning of our comments-for each specific DOE submittal.
The enclosed comments were prepared by Joseph Kane (2-3449), who~
l may be. contacted if you have any questions on the enclosure, i
Michad1 'cinal Signed ByYokar, Section Leader 0 'i i
Technical. Branch Division of Low-Level Waste Management and Decommissioning, NMSS.
Distribution: (Central-File-#-
LLTB r/f
' NMSS r/f JSurmeier JKane MTokar JStarmer.
LPittiglio JParrott RBoyle PLohaus-JGreeves RBangart PDR Yes:
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PDR No:
Reason:
Proprietary or CF Only
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ACNW Yes:
No:
f SUBJECT ABSTRACT:
SEE SUBJECT OF MEMORANDUM i
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DATE: 3 / 71-/ 9 0
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'NRC:STAFFEREVIEW-COMMENTS 1ANDIQUESTIONS S
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WESTL VALLEY DEMONSTRATION. PROJECT - (WVDP) e Prepared by:. Joseph'D'.'Kane, LLWM/LLTB Comments on:- Implementation Plan for the Environmental i
Impact Statement on Phase II of.the West Valley Demonstration ProjectLand closure 1of the Western New York
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Nuclear Service. Center,.
Rev. 0 - Draft B,1 July, 1989.
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General..The emphasis of the Implementation Plan (IP) is stated (p.-1) to be directed at theiidentification of.the y
issues.to bel considered.in the: preparation of the EIS for the completion of the WVDP and the closure of the' Western New York Nuclear Service' Center-(WNYNSC).
On the face-of' this stated objective:it would appear that the_NRC's staff review and comments would be limited'to the information
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typically developed.for an'EIS. ~ NUREG-1300, the Environmental Standard Review: Plan, would be-a good NRC source for. identifying the issues to~be considered in preparing an EIS.
However, the IP also' appears to be-L
' intended to cover more.than~ environmental' issues.
The IP Jappears to also involve safety review considerations that would typically be addressed in a. Safety' Analysis Report.
j For example, it is stated on Page 3.that the purpose of the' EIS is "...., and to bring the entire WNYNSC to a safe, stable condition."
There are many other areas of-the IP where it appears that safety issues are intended to be covered.
i DOE should be asked to clarif'y whether the IP and EIS are intended to cover safetyLissues, as'well as environmental issues.. This clarification is~important because it will significantly affect the scope and type of'information that would be expected to be' developed, analyzed and evaluated for the WVDP.
The IP, when discussing the proposed schedule for the EIS preparation (p.50), indicates ~that both~the follow-on-environmental and safety' reviews'are to be completed by December, 1994.
This. concurrent date raises a question as to how DOE plans to address safety review issues, if they are not to be included in the EIS effort described in the IP.
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Section 3.2.2, p.15.
Does' management of localized " hot-spots".and area contamination in the State-licensed disposal erea ' (SDA). and NRC-licensed' disposal' area (NDA) imply,
ultimately meeting Performance _ objective-61.44, Stability ot-s the Disposal Site after Closure?f i
3.
Section 3.3.3, p.24.
To-help better. understand the subalternatives, within'the' broader _ alternatives of in-place.
stabilization, and exhumation ~and-redisposal1for the 1
existing SDA and NDA disposal areas,.the staff requests-that referenced reports Grant.and Blickwedehl, 1988; DOE,21986; a n d E n v i r o s p h e r e,: 1986 be-providod'for information.
4.
Section 3.5.1-2',
p.31.
LIn expansion of'the site characterization data base and information that is planned by DOE, is it intended that the developed.information will be comparable to the information that-is' identified in NUREG 1200, Rev.
1, under Sectioni2, Site. Characteristics?-
5.
Section 3.5.1.3, p.32.
. Will'the=information to be developed;
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by DOE on engineering details and the anticipated
. performance of'the disposal units,. waste' cover. cap, and other portions.of the closure system be comparable to the:
applicable information needsLidentified in NUREG-1200,.
-Section 3, Design and Construction;.Section 5,' Site Closure Plan and Institutional Controls;-and pertinent: portions of t
Section 6, Safety Assessment?
6.
Section 3.5.1.4,'p.32.
The IP-states that "The EIS will i
propose a site performance objective for. releases, and facility objectives for accessible contamination."
It would be helpful if this statement were expanded to cover whether it'is intended that 10 CFR Part 61rPerformance Objective 4
(61.41, 61.42, 61.43 and 61.44)1are to be met, or if some i
other performance objectives are intended.
Comments on:
Draft Site Characterization Plan (SCP) Phase II, West Valley Demonstration Project, July 10, 1989.
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7.
Section 2.0, p.6.
The SCP.on this page in'the last paragraph'provides a discussion on the chronological extent-of the environmental analyses which the characterization activities will support.
An arbitrarily selected time interval of 1000 years is indicated.
The:SCP also indicates 1
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-2, that 1000 years is the' point beyond'which.the consequences:
' of failure would no longer.be time dependent, because all but the-veryclong half-lived: isotopes will have decayed to levels which will not creato an= environmental impact.- It I
appears.the generally accepted understanding of site 1
characterization is'beingimerged'and confused'with the time:
L interval thattis-needed'to analyze performance assessment.
b Site' characterization is typically. intended to cover the establishment'ofosite information.(e.g. geography, demography, meteorology,, climatology, geology, seismology, l
hydrology andlgeotechnical)' specific to a given site'which L
can be characterized,.modeled,= analyzed and monitored.
Site =
' characteristics can be modified:byLengineering design and-L construction activities and1 impacted by the occurrence of l
- design basis events (e.g..floodsland earthquakes); however, the basic!information required for site characterization is
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. not typically considered to'be. limited to a specific time H
interval.
On the other hand, questions often arise relative r
- to the appropriate time interval 1 that performance assessment:
studies would need-to be, carried'out.
There is no single-
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answer that can be give to this" question.
T The design basis :for. low-level waste -(LLW) disposal facilities is 500 years (47 FR 57446).
The NRC staff.
l assumes that performance ofia.LLW facility would be analyzed L
for at least.that time.
When establishing. analysis time, I
and time increments, the analyst.would need to consider the following:
(1) half-life'of the'radionuclide, (2). behavior of the' released nuclide in the biosphere,- (3) waste packaging and waste form (4)-demonstrable containment provided by engineered features of the facility-designnand (5) the increasing-uncertainty of' predictions with-increasing time.
Data points and time increments should be j
such that reasonable-extrapolations can be made for time periods greater than 500 years.and up-to-periods that regulatory limits would be shown not be to be exceeded.
This would include analysis of long-lived isotopes.
Preliminary performance assessment results obtained in the NRC-staff's review of DOE's Below-Ground Vault Prototype License Application. Safety Analysis Report (PLASAR) indicated that under certain assumed source term and. site L
conditions, long-lived radionuclides can present-a problem.
l in' meeting 10 CFR'Part 61 performance objectives.
This finding of a problem in an actual license application would require some action to be taken to ensure compliance with c
the LLW regulations.
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8.
Section 3.0, p.7..
It is indicated in the Section on Issues:
that the SCP was developed to provide. input to_ support a_
performance assessment after closure and to address a series of technical issues.-
This statement appears to" omit ScP-efforts that would'be needed to address design,
-construction, and closure considerations related to the proposed alternatives of in situ stabilization or. exhumation and redisposal.
Typically, in most engineered' projects, the work performed under SCP efforts is: closely tied to'and' '
coordinated with design and' construction = concepts.. This-would~also appear to be the case for the West Valley project, and the scope of the SCP' program would benefit by a revision to clearly indicate this, objective.
9.
Section.5.0, p'.9.
Table 2--(p.10 to'14) presents a list of site' characterization reports that have been developed i
through the years.for-the West' Valley Project.. It is'.
t recommended that LLWM in' cooperation with R.
Davis Hurt',.
obtain a copy for LLWM of each listed report-for future reference.
10.
Section 5.0, p.9.
The four. major' programs'(Regional, Site, Facility,.and Facility Generic) that are identified by DOE in the SCP reflect a very; extensive and' ambitious program-for the West Valley project.
The four major 1 programs are subdivided in the Appendix into a large number of_ individual studies and work activities ~that are to be completed by DOE.
1 The level of description of the studies and work activities in the Appendix-is essentially equivalent to;brief statements on overall program' objectives and purpose with i
preliminary estimates of required DOE resources.
Projected schedules by DOE for completing the activities has been provided for only a small portion of_the identified studies.
The descriptions of the planned work are notJequivalent to initial design concepts which would appear to be the.next major step by DOE in-proceeding'with the listed activities.
From the description of the activit'ies in the Appendix of the SCP it would appear that normal regulatory' interest of.
the Engineering Section, LLTB, would be in the following program. activities for the WVDP.
Activity 2.4 Activities 3.1.3, 3.1.6, 3.2.1, 3.2.2, 3.2.4, 3.2.5, 3.2.6 and 3.2.7 Activities 4.1, 4.2, 4.2.1, 4.2.2, 4.3, 4.4, 4.4.1, 4.4.2 l
and 4.4.3 g
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L If NRC is-to continue assisting DOELin review andi j
j consultation on:the WVDP, it is suggested that other LLWM sections also be asked to identify the activities where_they, i
-would anticipate review involvement.
The fol' lowing _ items are suggestions if NRC's participation'is to_ continue'in reviewing:the many planned activities identified-in the
' Appendix of the SCP.
'1)
DOE should be asked to keep NRC informed (e.g. through' meetings and the providing.of pertinent reports) as.the L
conceptual plans and designs are developed for the:
various listed' activities.
2)
DOE's and NRC's staffs'should schedule meetings _on a
. regular-basis to discuss and addressEimportant desi'gni and review issues related to;the: planned studies and-F activities (e.g. the scope and~ details of the planned-programs; identification, application.and-l interpretation of specific regulatory: requirements:and._
regulatory guidance documents; discussions on-problems-and unique environmental and safety' considerations;'and t
the clear identification of. major or. outstanding review l
concerns / issues.
3)
DOE should be asked to provide an estimated. schedule.
for-completing the activities' identified'in the Appendix of the SCP to permit the NRCL o estimate and t
schedule staff resources that-would be' required for future DOE requested review efforts.
11.
Activity 4.2.2, p. 4-2. ( Appendix)'.
DOE should be provided'a copy _of the report prepared by;NRC's' consultant,.Dr. Stewart Silling, regarding the structural stability _of.the!HDPE:
L High-Integrity Containers (HIC).
The June 10, 1988 report-L by Dr. Silling titled, " Review of,the Structural Designst of D
Polyethylene High Integrity Containers," should prove l
helpful to DOE in identifying problems with HDPE materials-in DOE's. efforts to evaluate the effects of low-level radiation on HDPE.
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Comment on:
Performance Assessment at the West Valley Demonstration Project, A Review of Methodology and Potentially Useful Pathway Analysis Codes, July 10,_1989.
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e 12.
Thel description of Pathway Assessment'and Methodology.that.
-is presented in the above DOE document is very general'and lacks specificity.
It is suggested that DOE be provided copies of the recent reports by NRC's-consultant, Sandia-National Laboratories on Low-Level Waste Performance Assessment Methodology (NUREG/CR-5453)-for DOE's information and consideration.
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