ML20040F959
| ML20040F959 | |
| Person / Time | |
|---|---|
| Issue date: | 01/04/1982 |
| From: | Scarano R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Campbell R ENERGY, DEPT. OF |
| Shared Package | |
| ML20040F960 | List: |
| References | |
| REF-WM-39 NUDOCS 8202100524 | |
| Download: ML20040F959 (4) | |
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Mr. Richard H. Campbell, Project flanager D('
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U.S. Depa rtment of Energy
[f Albuquerque Operations Office
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P.O. Box 5400 Albuquerque, NM 87115 y
Dear Mr. Campbell:
In response to your October 26, 1981 letter, we are providing the attached NRC staff comments on the September 1981 DOE Final Draft Technical Criteria for Uf1 TRAP disposal site selection.
Attachment I presents our comments.
In addition, other comments were previously provided on the December 1980 Draf t version of these criteria by my flarch 20, 1981 letter to Robert W. Ramsey, Jr., DOE-HQ.
In the matter of site selection, we consider the minimization of
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potential for disturbance by natural forces to be of paramount importance, In this regard, we note that only minimal importance on
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long tem stability potential is reflected by the weighting factors I
assigned to wind and water erosion potentials.
This low weighting of these critical factors is unacceptably inconsistent with similar weighting being provided for factors of low importance and for factors which will not vary significantly between viable candidate disposal sites.
1 Assuming our current comments can be accomodated or otherwise resolved, we look forward to receiving the final DOE Uf1 TRAP Site Selection Criteria S:to:
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Any questions you may have should be addressed to me or William M. Shaffer, III (FTS 427-4538) of my staff.
Sincerely, S
Ross A. Scarano, Chief Uranium Recovery Licensing Branch Division of Waste Management cc: Robert W. Ramsey, Jr., DOE-HQ Dr. William E. flott, DOE-HQ Robert J. Stern, DOE-HQ Case Closed:
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ATTACHMENT I NRC STAFF COMMENTS ON SEPTEMBER 1981 DOE FINAL DRAFT TECHNICAL CRITERIA FOR UMTRAP DISPOSAL SITE SELECTION
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1.
- p. 1 (Sec. 0) and p. 9 (Sec. 1.6.2):
It is inferred in Section 1.6.2 that a site will be selected only from those surviving the site evaluation process described in Section 1.6.1.
We agree that hopefully this would be the case and, with appropriate guidance to a site evaluation team, may prove true.
However, Section 1.6.1 allows for individual site evaluation team member's flexibility to add new criteria and for a site evaluation team on its own to, exclude geographical areas from further consideration based on social and political constraints.
While this may prove necessary to an evaluation team's effective functioning, if they are expected to reach a conclusion, this may also result in ultimately excluding candidate disposal areas from consideration which are desirable to consider from a technical viewpoint.
In our judgement, the DOE should not, in these Criteria, foreclose the option that a disposal site may ultimately be selected which is different from those recommended initially by such other groups.
We view final disposal site selection to be a DOE responsibility.
This would of course involve mutual agreement with and concurrence by the State as a logical part of that step as has been incorporated, for example, in Article II.C. of the recently executed UMTRAP Colorado Cooperative Agreement.
Neither Section 0.,
nor Section 1.6.2 appears to clearly convey the evaluation / selection system concept as discussed above.
However, we feel that both Sections should clearly do so.
2.
p.7-10 (Sec. 1.6,1.6.1, and 1.6.2):
We note from Sec. 1.5. that these Final Draft Criteria have now been broadened to include factors such as Land Ownership and Land Use.
We also believe such factors warrant careful consideration in the deliberations of any groups making disposal site recommendations to the DOE.
However, we view such criteria, as well as the Engineering Econcmics Criteria of Sec. 1.4, to be non-technical in nature. We therefore believe that the whole Criteria document, and the discussion in the Sections noted, should be presented as " Criteria" for selecting disposal sites rather than " Technical Criteria".
In our view, only the Environmental, Geologic, and Hydrologic Criteria are purely technical
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a in nature and we note that, together, they account for only 60% of the i
total of the suggested weights to be assigned all of the criteria in Table 1 of the document (p.11).
It would appear prudent to avoid any public misconception that UMTRAP disposal sites are initially recommended and evaluated on strictly technical grounds.
At the same time, however, we support the inclusion of such guidance to site evaluation teams as provided by Table 1 in accordance with a previous NRC comment from our March 20, 1981 referenced letter.
3.
- p. 9 (Sec. 1.6.2):
We believe the " Method of Ranking" to be sufficiently prone to error such that it should not be offered as an example.
Two of its serious disadvantages are already noted in the document on p.9.
A third is that its results are extremely susceptible to distorted interpretation simply by the number of sites considered. For example, we understand that up to 32 sites may have been considered initially in the case of possible relocation of the Grand Junction / Rifle tailings.
In terms of ease of engineering an acceptable tailings impound-ment, a site ranked #32 may not be significantly more difficult to engineer than one ranked #1.
Yet, by the Method of Ranking, one site would be commonly perceived to be 32 times more difficult to engineer.
In comparison, we support, as is currently the case, inclusion of the
" Method of Weighted Scores" as an example.
It is, by far, more tech-nically correct, comprehensive, and sensitive to the actual relative importance of evaluation factors.
4.
p.11 (Table 1):
In our judgement, two of the most important criteria related to a disposal site are the wind and water erosion criteria (1.2.b and 1.2.c).
We strongly believe that each of these should be weighted at least double their current values in Table 1 (i.e. at least 8 rather than 4), in recognition of the overriding importance of long term disposal site stability.
To compensate for greater weighting l
being given to long term disposal site stability, we suggest that reduced weighting be afforded to those factors of lesser importance or factors for characteristics which can be expected to be very nearly the same for all viable disposal sites (e.g., precipitation).
5.
- p. 12 (Sec. 2.1.1):
Article 192.03(a) of the proposed 40 CFR 192 EPA Disposal Standards, as published at 46 FR 2562, January 9, -1981, allows for the radon flux from a disposal site to be as high as 2pC1/m -sec. plus that expected from the " disposal" (i.e, covering) 2 materials themselves.
We suggest the definition of this standard be reworded on p. 12 to note this.
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