ML20042F785
| ML20042F785 | |
| Person / Time | |
|---|---|
| Issue date: | 05/04/1990 |
| From: | Bangart R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-PROJ-M-32 NUDOCS 9005090385 | |
| Download: ML20042F785 (21) | |
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UNITED STATES l
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RichardE.Cunningtam} Director HEMORANDUM FOR:
Division of Industria and Medical Safety, NMSS FROM:
Richard L. Bangart, Director Division of Low-Level Waste fianagement and Decomissioning, NMSS
SUBJECT:
REVIEW 0F THE SITE CLOSURE DOCUMENTS FOR THE WEST VALLEY DEMONSTRATION PROJECT Enclosed you will find our comments on the West Valley Demonstration Project (WVDP) package. The coments are based on a review of the following documents:
Site Characterization Plan, Phase II, West Valley Demonstration Project, July 10. 1989.
Performance Assessment at the West Valley Demonstration Project, A Review of Methodology and Potentially Useful Pathway Analysis Codes, i
July 10,1989.
Implementation Plan for the Environmental Impact Statement (EIS),
Phase II of the West Valley Demonstration Project and Closure of the l
Western New York Nuclear Service Center, Rev.0 - Draf t B, July 1989.
l Both your September 8,1989, memorandum (Cunningham/Bangart) and the follow-up meeting on January 30, 1990, stated that the Department of Energy (DOE)
I requested that we formally review the Site Characterization Plan and the Performance Assessment Plan.
The primcry focus of our review was to determine if the programs for site characterization and performance assessment that are being developed by DOE omitted arty major areas in the submitted plans. As a result of the January 30, 1990 discussion, wa also reviewed the Implementation Plan for the EIS. The Implementation Plan for the EIS is an essential element l
in the evaluation of the WVDP and the closure of the Western New York Nuclear Service Center (WNYNSC).
In sumary, the staff has identified several concerns.
It is important to point out that the documents submitted by DOE for NRC's review were draft plans.
I Because of DOE's concern to move forward with the WYDP, DOE began revising the draft plans while the NRC's review was being conducted. We understand that
{ si several of NRC's concerns are being addressed. Generally the staff found the i
Site Characterization Plan (SCP) did not describe the scope of all the site-characterization studies that are needed for decomissioning, decontamination and closure of the WYDP. The staff recommends that DOE revisit and summarize the existing site data and based on this develop a conceptual 9ooso9o385 900504
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LP/ SITE MEMO 2
model of the site. This model will provide a basis for assuring that the final site characterization program addresses all information needs. The Performance Assessnient Plan provides a general discussion of performance assessment but should emphasize performance assessment in relationship to the WVDP. The Implementation Plan (IP) for the EIS does not identify all the issues to be considered in the preparation of the EIS for the completion of the WVDP and the closure of the WNYNSC. The staff has identified some additional issues that should be included in the preparation of the EIS.
The IP discusses both environmental and safety issues. Because of the differences in the regulations and the type and scope of information that would normally be required for an EIS as compared to a Safety Analysis Report, DOE should clarify.the intent of the EIS, Since our review has taken longer than initially anticipated, we would be happy j
to meet with DOE at the earliest convenient date to discuss our comments.
This nieeting should provide a mechanism to expedite the review process.
If you have any questions on our consents, please contact Clayton L. Pittiglio on X 23438.
l (SIGNED) FRCHMS L BANGAlW l
Richaid L. Bangart, Director i
Division of Low-Level Waste Management
^
and Deconnissioning Office of Nuclear Material Safety and Safeguards
Enclosures:
As stated Docket No. M.32 Distribution: Central File #110 NMSS r/f LLRB r/f LPittiglio TJohnson RBoyle JGreeves RBangart PLohaus JSurmeier MTokar RJStarmer JParrott JKane DHurt JAustin PDR YES X
NO Category: Proprietary or CF Only ACNW YES X
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SUBJECT ABSTRACT:
REVIEW CLOSURE DOCUMENTS FOR WEST VALLEY DEMO PROJECT l
- SEE PREVIOUS CONCURRENCE
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LP/ SITE MEMO characterization program.
The Performance Assessment Plan prAvides a general discussion but does not specifically address performance as,s6ssment in-relationship to the WVDP.
The Implementation Plan (IP) f the EIS does not adequately identify the issues to be considered in the eparation of the EIS for the completion of the WVDP and the closure of the 4YNSC.
The IP discusses and mixes both environmental and safety issues.
Cla fication of the EIS intent by DOE is reconenended because of the differ ces in the regulations and the type and scope of information that would norn* ly be required for an EIS as compared to a Safety Analysis Report.
If you have any questions on our comments, p ese contact Clayton L. Pittiglio on X-23438.
P chard L. Bangart Director ivision of Low-Level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards
Enclosures:
As stated Docket No. M-32 Distribution:
Cep ral File #110 NMSS r/f LLRB r/f LPittiglio TJohnson RFoyle JGreeves RBcngart PLohaus JSurmeier iTokar RJStarmer JParrott OKane DHurt LAltoft r/f l
-l PDR YES X
NO Category:
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ACNW YES-X NO j
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SUBJECT ABSTRACT:
REVIEW CLOSURE DOCUMENTS FOR WEST VALLEY DEM0 PROJECT
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i COMMENTS OH WEST VALLEY DEMONSTRATION
. PROJECT DOCUMENTS
Background:
In response to the Ctpartment of Energy (DOE) request of August 17, 1989, (Sixby/ Hurt), the Nuclear Regulator West Valley Dtmonstration Project (WVDP) y Commission (NRC) has reviewed the package provided in the DOE request.
The package consisted of the following documents:
(1). Site Characterization Plan, Phase II; Project; and (3)(2) Performance Assetsment at the West Valley Demonstration Implementation Plan for the Environmental Impact Statement (EIS),PhaseII.
The DOE letter requested that NRC formally review the Site Characterization Plan, and the Performance Assessment Plan.
The Implementation Plan for the EIS was initially included for information only and a review of this document was not requested.
However, because the Inplementation Plan is an essential element in the evaluation of the WVDP and the closure of the Western New York Nuclear Service Center, WNYNSC, the NRC reviewed this document and has included consnents.
t Basis for Review: - The NRC review was conducted by comparing the 'submitteci plans with Th'e7equirements of Title 10 of'the Code of Federal Regulations, Part 61, " Licensing Requirements for Land Disposal of Radioactive Waste"; the i
informaticn presented in NUREG-1199, Revision 1, " Standard Format and Content of a License Applicatior for a Low-Level Radioactive Waste Disposal Facility";
and NUREG-1200, Revision 1, " Standard Review Plans for the Review of a License Application for a Low-Level Radioactive Waste Disposal Facility" as applicable.
The use of these requirements and supporting guidance is baseJ on the requirements of the West Valley Demonstration Project Act (P.L.90-368) Section 2 (a)(4) and the legal opinion of the Office of the General Council, dated October 2, 1987.
==
Conclusion:==
The primary focus of the NRC's review of the WVDP package was to Tetermine if the programs for site characterization and performance assessment that are being developed by DOE omitted any major areas of consideration from the submitted plans.
It is also important to point out that the documents submitted by DOE for NRC's review were draft plans.
Because of DOE's concern to move forward with the WVDP DOE began revising the draft plans while NRC's review was being conducted.
We understand that several of the NRC's concerns have already been addressed.
-l Generally the staff found that the Site Characterization Plan (SCP) does not l
adequately describe the scope of all the site characterization studies that are needed for deconunissioning, decontamination and closure of the WVDP. The staff reconnends that DOE revisit and sunmarize the existing site data and based on this develop a-conceptual-model of the site.
This model will provide a basis for assuring that the final site characterization program addresses all i
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-2 information needs.
The Parfannance Assessment Plan provides a general aiscussion of performance
- *ssment but needs to emphasize performance assessment in relationship _o the WVDP.
The Implementation Plan (IP) for the EIS dces not adequately identify all the issues to be considered in the preparation of the EIS for the WVDP and the closure of the WNYNSC. The staff has identified some additional issues that should be included in the preparation of the EIS. The IP discusses and both environmentel and sae'v issues.
Because of the' differences in the regulations and the type and scope of information required for an EIS as compared to a Safety Analysis Report, DOE should clarify the intent of the EIS.
Comments on:
Site Characterization Plan, Phase II, West Valley Demonstration Project General Comments.
DOE states in the document that the purpose of the Site Characterization Plan (SCP) is to describe the scope of the site characterization studies essociated with the decommissioning, decontamination and closure of the Western New York Nuclear Service Center, WNYNSC.
The document also states that the intent of the SCP is to build on the many site characterization studies that have been performed by the WVDP, New York Geological Survey, the U.S. Geological Survey and others.
In support of this approach NRC recommends that the SCP should focus on sunwarizing existing stuides and check the validity of and develop a conceptual model based on this available data.
Once the interpretation of existing data to determine site conceptual models is complete, then one can identify the areas of insufficient data.
It is reconsnended thei. the locations of existing and proposed data collection points used in both monitoring and site characterization be located on a site map so the location can be reviewed before additional data collection is initiated.
Next, the plans for further data collection should be reviewed before implementation of further data collection begins.
This process is an essential step in site characterization.
Where existing data is to be used the sources should be clearly referenced <
For data that will be collected as part of the site characterization process, the data collection and procedures have not been selected.
It is important that procedures be selected and reviewed before any data collection is initiated.
NUREG-1383, " Guidance on the Application of Quality Assurance for Characterizing a Low-Level Radioactive Waste Disposal Site" provides guidance in these areas.
Finally, the SCP selected t time limit of 1000 years and indicated that 1000 years is the point beyond which the consequences of failure of disposal or closure systems would no longer be time dependent. After 1000 years, the
. docur ent states that all but the very long half-lived isotopes will have cecayed to levels which will oct create an environmental irnpact.
Cor.sicering the large an.our.ts of transuranic wastes to be left on the site, the impacts of failure are sigt.ificant for half-lives greater than 1000 years. The report did r.ot provide an adequate basis tFat supports this time frame. The SCP netds to ernphtsize the principal purpose of a site characterization program.
The rurrese of site characterization is to establish site information (e.g.
geography, demography, ineteorology, climatology, geology, hydrology and geotechnical)' specific to a given site to characterize, model, analyze _and monitor the site.
Site characteristics can be modified by engineering design and construction activities ar.d impacted by naturally occurring events;,
however, the basic information required for site characterization is not limited to a specific time interval.
The tine interval question is more appropriately related to the period that perfortnance assessment studies should be conducted.
l Specific Comments:
i 1.
Pag,e,J,;Section3.0:
Issues It is indicated in this section 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 j
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 a > pear to be the case for the West Valley project, and it is recommended tlat the SCP program be revised to clearly indicate this objective.
2.
Pege 9; Section 5.0:
Approach Table 2 presents a list of site characterization reports that have been developed through the years for the West Valley Project.
It is recommended that a copy of each of the listed reports not sponsored by NRC be made available for future reference.
3.
Pace 9: Section 5.0: Approach The four major programs (Regional, Site, Facility, and Facility Ger.eric) thtt are identified by DOE in the SCP reflect a very extensive and arobitious program for the West Valley project.
The four major. programs are subdivided in the Appe.ndix inte a large number of individual studies and work activities that are to be completed by DOE.
The level of description of the studies and worir activities in the Appendix is i
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. essentially equivalent to brief statements on overall program objectives with preliminary estimates of required DOE rescurces.
Projected schedules by DOE for completing the activities have been provided for only a small portion cf the identified studies.
The descriptions of the planned work cre not equivalent to initisi design concepts which would appear to be the next major step by DOE in proceeding with the listed activities.
To assist NRC in review of the WV0P, the items that are listed below are recommendations for the future planned activities identified.in the Appendix of the SCP:
1)
DOE should keep NRC informed (e.g. through meetings and the providing of pertinent reports) as the conceptual plans and designs are developed for the various listed activities.
i 2)
DOE should schedule meetings with NRC's staff on a regular basis to discuss and address important design and review issues related to the planned studies and activities (e.g. the scope and details of the planned programs; identification, application, and interpretation of specific regulatory requirements and regulatory guidance documents; discussions on problems and unique environmental and safety considerations; and the clear identification of major or outstanding review concerns / issues.)
3) 00E should provide an estimated schedule for completing the activities identified in the Appendix of the SCP.
This would permit the NRC to estimate and schedule staff resources that would be required for future DOE requested review efforts.
4.
Page 2-1; Appendix, S,e,c,t, ion 2-0: Site Related Programs DOE has not proposed any activities or studies outlined in this plan that-deal with site geology and hydrogeology.
Perhaps the investigators feel it is well established but such studies wculd have many useful objectives and activities.
The objectives and activities are outlined below:
i Establishing the current state of knowledge of site geology Establishing the current state of knowledge of site hydrogeology Delineating the current state of ground-water movement with periodic contemporaneous sets of measurements in the:
surficial alluvial fan aquifer or the North Plateau unweathered till unit in the South Plateau
. weathered and fractured till near the state-licensed and facility disposal areas and other facilities in the South Plateau areas.
Establishing conceptual and numerical or analytical n.odels that would be appropriate for assessment of facilities situated within the North and South Plateau areas.
i Providing a site-wide franework for interpretation of data collected in facility specific studies, f
If these activities are already being addressed, the plan should provide the specific references.
5.
Page 2-1 Ap)endixi$ection2.1:
Characterization of Erosion Potential on Streams w11ch Dra,in[)he Site TheSiteCharacterizationPlan(SCP)indicatesthatthefocusofthe erosion study will be on defining the. mechanism and rate of erosion on the various small streams which are located adjacent to the disposal areas.
The study will attempt to use historical erosion data to determine if mitigative designs are necessary to protect the site from long-term erosion problems, s
While historical erosion data are interesting and sometines useful, such data have substantial limitations.
The use of 30-50 years of erosion data, for example, to predict site performance for a period of-300-500 years (in accordance with 10 CFR 61) nay result in the under-design of protective structures, unless very large floods have occurred and the rate of erosion for such large ficods can be determined.
t The questionable value of historic data is further evident when one.
examines the causative mechanisms of erosion.
Typically, a slope, channel, or stream bank will be stable until a threshold value of velocity or tractive force is surpassed.
If this threshold value has not been exceeded during the period in which the data are gathered, one could be i
misled into thinking that stability is a certainty, when, in fact, it is not.
Any long-term stability study should also consider that the designs selected must remain effective for hundreds of years following site closure,' without reliance on routine maintenance. -The study should thus consider various phenonena and failure modes which could occur over these long time periods, including gully erosion, sheet erosion, wind erosion, differential settlement creating preferential flow paths for drainage, headward gully advancenent, and lowering of base levels.
In designing against these phenomena, the use of models which are calibrated using historic data may not be adequate, due to the lack of a sufficient data
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. base. Procedures that attempt to expand the data base such as age dating i
of flood terraces also have limitations, since it is generally not enough to know that the most recent large flood, for example, occurred 435 years i
ago. This type of information may be interesting but is of limited value i
d when considering flood threats to the site. Only data with quantifiable hydrologic parameters, such as flow rate, rather than qualitative j
data, such as "large flood" can be used in estimating flood or erosion potential in a meaningful way.
Using historic erosion or flood data has severe limitations in selecting an appropriate design event.
For example, if a small probability of occurrence of 0.10 is desired, the design flood for a period of 300 years would have a recurrence' interval of 3000 years or more.
It is 'not likely that a 3000-year flood can be determined utilizing only 30-50 years of flood data.
Similarly, using 30-50 years of erosion data may not be i
adequate to design for a period of 300-500 years with a very small probability of failure.
The NRC staff's experience with long-term stability considerations for uranium mill tailings projects leads us to conclude that the site design should be based on preventing the initiation of erosion by employing a stable design configuration.
While the staff considers that the data on historic erosion rates will provide some useful information, the data 4
will need to be supplemented with a considerable amount of additional data.
6.
Page 2-2; Appendix, Section 2.1.1:
Distribution'and Characteristics'of
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Past,,and Present Erosion As previcusly discussed, the usefulness of limited historic data for evaluating long term performance can be limited.
Additional efforts should be devoted to determining the threshold values of velocity, tractive force, or flood discharge that a particular s1. ope or-channel has withstood in the past.
This value will vary across the site depending on stream and slope characteristics such as particle size, allowable tractive i
force, cohesion, vegetation density, etc.
(The staff notes that threshold t
value determinations are proposed to be developed as part of the activities discussed in Section 2.1.3 for use in evaluating current erosion.)
Based on staff experience with design of stable slopes and channels, the long-term stability design will be controlled by the capability of the i
site to withstand the effects of a single large flood event, such as the l
probable Maximum Flood (PMF).
It would be prudent to direct data-gathering l
efforts to determine the capability of the site to withstand such a large event.
The determination of site stability can then be supplemented with the historic data gathered in this task.
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4 7.
Page 2-5;-Appendix,,_,Section 2.1.2:
Flood Routing,, Calculation It is noted that the principal objective of this activity is to determine the discharges associated with floods of various magnitudes in the site vicinity. As part of this activity, the staff suggests that the velccities and shear stresses produced by a range of floods also be determined. This will aid in determining the need for flood protection measures.
The staff also emphasizes that the water levels and velocities associated with major floods will be significantly affected by the flood protection that is ultimately implemented at the site.
For example, if a diversion channel becomes part of the design for diverting floods away from waste disposal areas, it is likely that the diversion. channel could cause significant changes to flood velocities and levels at various places in the site area. Therefore, the flood analyses proposed as part of this task may.be of little value for final design purposes.
It would be prudent to develop a conceptual design at this point to determine the effects of flooding on a flood-protected site.
In short, it is prudent to perform fewer flooding analyses for the site as it currently exists and i
1 more analyses for the site as it will exist in its post-closure state, based on at least a preliminary conceptual design.
It is also important to note that the final design configuration could cause increases in flood velocities or flood levels which will need to be accounted for in assessing erosion rates immediately downstream of a diversion channel.
E.
Page 2-7; Appendix. Section_2.1.3: Monitoring of Curren,t_ Erosion As previously discussed, the staff questions the value of using current erosion rates to determine designs for site stability for long periods of l
time.
However, the activities proposed in this task to determine l
threshold values of precipitation and discharge levels may be useful, particularly if a flood of sufficient magnitude occurs and causes erosion.
The staff recommends that the proposed data be supplemented with threshold values of stream velocity and tractive force, since the major design parameters are usually not flood levels.
9.
,P_ ace 2-9; Appendix, Section 2.1_.4:
Characterize Stability o,f,, Stream Bank and Bed As previously discussed above, the characterization of stream materials should'also include a determination of the allowable velocity or tractive force.
These parameters are usually a function of the soil particle size, cohesion or clay content, and vegetation cover.
We note that the suitability of using concrete as erosion protection will be evaluated.
Based on staff experience with long-term stability designs, L
it is unlikely that concrete can be:used as erosion protection fcr long l
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seriods of tirae without maintenance (as required by 10 CFR Part 61).
- nicss e-type.of concrete can be developed te withstand chemical and physical weathering fcr periods of 300-500 years, without the use of maintenence to repair and replace it, the staff suggests that high quality rock sources in the area be investigated.
If no suitable rock exists onsite, a search should be conducted for acceptable sources.
NRC criteria currently exists for quantitatively determining tte quelity of rock riprap.
10.
Page 2-12; Appendix,Section 2.1.5:
Develop Eros,1,onJcdel It is noted that models will be developed to determine erosion rates as a function of storm magnitude.
However, it should be poir;ted out that other erosien models, such as the Universal Soil Loss Equation, have been used to estimate soil losses under a wide range of conditions; it has been determined that such models are of limited value when try'ag to predict soil losses in channels and gullies over a long period of time. The value
,l of such models trey also be questionable where super critical flow occurs.
flodels such as HEC-0, for example, may be of limited value when trying to
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predict the long term performance of steep stream channels for a long period of time and for a wide range of storm and flocd events.
11.
P, age 2-16; Appendix, Section 2_._2:
Geochemical Characterization l
Are the chemical parameters slated to be analyzed in this section compatible with the chemical parameters of the source term? Without a conceptual model of what is in the source term, deciding which chemical and radiological parameters to test will be difficult.
12.
Pace 236; Appendix,Section2.2.1:
GroundWaterCharacterization_(.0bjectives)
This section states that flow through the fractured, weathered till is important; however, the section should state that this is only in'portant to facilities situated in the south plateau.
In the north plateau, tb most significant unit is the surficial alluvial fan unit.
I 13.
Page 2-18; Appendix _, Section 2.2.1: GroundWaterCharacterization(Description)
It is.important to point out that evenly distributing wells among the three units may not be the most appropriate approach to characterizing the geochemical conditions and evolution within each trajor hydrogeologic unit from recharge to discharge point.
It is recomended that such a program give careful and thoughtful consideration to potential contributions j
from various facilities situated above each unit.
1 14.
Page 2-20; Appendix, Sec, tion 2.2.2:
Surface Water Chemistry Characterization-1
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The section should describe more fully the san'pling equipment, sampling prccedures and decontamination procedures.
It is also reconmended that this sEction_ describe the methods used for all parameter analysis.
Also describe the method used to determine sorption and ion exchange parameters.
IE.
Fage 2-23; Appendix, Section 2.2.4: Solute-Groundwater-Soil Interactions (Description) _
It is not clear whether borings will be made specifically for this activity or whether they will be done as a part of another activity.
This should be clarified. With-regard to facilities in the South Plateau, special consideration should be given to geochemical soil analysis of the weathered, fractured till.
Standard procedures used in batch testing will' not be appropriate and normal column testing approaches nay require modification to evaluate the impact of fracturing.
16.
Page 2 24; Appendix, Section 2.2.4: Solute, Groundwater-Soil Interaction (Description)
This is the first mention of geohydrologic parameters in this section.
How will the database originate for these parameters?
If it comes 1
from past studies, this should be stated and the references included.
How will they be used? The models mentioned later in the section are purely geochemical models. Will numerical or analytical nodels of transport be developed under this activity?
l 17.
Page 2-24 A pendix, Section 2.2.4:
Solute-Groundwater-Soil Inter, actions (Descript on; t
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'he peer review process should be described in more detail, and a list of-participants should be included.
18.
Page 2-24; Appendix, Section 2.2.4:
Solute-Groundwater-Soil Interactions
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(Description)
There is some concern that the proposed contaminant transport models are not sufficiently rigorous to deal with the geologic complexity of the site. Any contaminant transport model proposed to be used should be calibrated using existing site data in order to demonstrate its validity l
ct this site, t
19.
Page 2-25; Appendix, Section 2.2.4:
Table 2_11 In this table it was not clear what was meant hy calibration of models.
l The purpose of geochemical modeling is more along the lines of hypothesis testing.
Given a certain water chemitid +nd soil composition, the models
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are used to identify important chemics!
etctions and to establish other I
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important geochemical paranieters such as solubility-limiting concentrations or adsorption-desorption relationships.
Results of this type of modeling can be used as a basis for geochemical aspects of contaminant transport analysis and final performance assessments.
Calibration of such models is not appropriate but they can be used to establish a working conceptual nodel of geochemical and geohydrologic relationships.
This san.e comnent applies to points number 13 and 14 in _ Table:2-12.
- 20. Pace 2-27; Appendix, Sec_ti,on 2.3:
Evaluate Unsaturate,d,, Zone Characteristics It should be pointed out that the upper 2 to 3 meters of weathered, fractured till also has a relatively high moisture content, not much different than the unweathered till. Also, it is not appropriate to call it an aquifer. Although it represents a pathway, it is not a meaningful water-bearing unit.
- 21. Page 2-28; Appendix, Section, 2.3:
Evaluate Unsaturated Zone Characteristics Without the benefit of the tensiometric data,-it is difficult to support l
your conclusion regarding contaminant migration to land surface. Similar tension data could be used to argue that water drains to a shallow fracture system which carries the water to nearby streams without surfacing. Also, plant uptake-is certainly another process which would contribute to a shallow tension field.
Page 2-28; Ap:endix,'e'Section 2.3.1:
Development of Water Budget and 22.
Infiltration Estimat s Should this be the relationship of water content pressure, and hydraulic conductivity (i.e., soil characteristic curves)?
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- 23. Section 2-28; Appendix, Section 2.3.1:
Development of Water Budoet and Infiltration Estimates Which chemical tracers will be used in the' trench tests and how can their sorption behavior be correlated to the sorption behavior of the various radionuclides found at the site?
24.
Page 2-28; Ap>endix, Section 2.3.1:
Dev,e;1opment of Water Budget and Infiltration Estimates It is not clear how a one-dimensional model like UNSATID can be used to develop an understanding of moisture flux through the weathered and r
fractured till system and to estimate fluctuations in the water table.-
How will boundaries be handled to account for lateral fluxes?
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. 25.
Page 2-28; A p endix, Section'2.3.1:
Deve_1npitent of Water Budget and Infiltration Estimates Please list other tests that will be used.
26.
Page 2-29; Ap)endix, Section 2.3.1:
Development of Water Budget and J_nf,i,ltration istimates The proposed data collection activity seems inconsistent with the modeling approach proposed in paragraph 1.
Please clarify how the proposed nodeling approach will use this data.
Ja e 2-29; Ap>endix, Section 2.3.1: Development of Water Budget and 27.
P IniiTt'r'ation Estimates It does not appear that the proposed modeling approach will achieve the goal of determining the net infiltration on the till.
A detailed description should be provided.
28.
Page 2-30; Appendix, Section 2.3.2,:,,fractureFlowInvestigations(Parameters)
In addition to the parameters listed, another pararneter that will need to be evaluated is the characteristic relationships of moisture content,
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pressure, and hydraulic conductivity of the weathered, fractured till in order to understand in transient flow phenomena in the shallow till system.
29.
Page 2-30; Appendix, Section 2.3.2:
Fracture Flow Inves_t_ipations (Parameters)
What is the relevance of nominal travel time and flow rate of. groundwater through the time estimated for a unit gradient when examining vertical l
movement or lateral movement?
30.
Page 2-30; Appendix, Section 2.3.2:
Fracture Flow Investig,a,tions (Parameters)
Please clarify what is meant by spatial and terrporal distribution of transient water tables.
Does this apply to the entire south plateau area?
31.
Page 2-31; Appendix, Section 2.3.2,:,, Fracture Flow Investigation (Parameters)
Item 3 in the paramcter list on p. 2-30 is very general.
Describe the scope of the experiments that will try to address this item.
This does not appear to bc addressed in the current plans.
32.
Page 2-31; Appendix, Section 2.3.2:
Fracture Flow Investigation (Description, Sentence 1)
Suggest that term " unit" be omitted form the sentence.
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Page 2-31; Appendix, Section 2.3.2:
Fracture,,F,lowInvestigation(Descriptio,n]
l Will the flow rate actually be monitored or estimated?
If direct monitoring will be done, please clarify how.
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- 34. Page 2-34;, Appendix, Section 2.3.3:
Develop Unsaturated Zone Model e
(Description)
It would be more appropriatr Ic refer to the groundwater codes as
" generally accepted" or "widely used" instead of " validated."
l 35.
Page 2-34; Appendix, Section 2.3.3: Develop Unsaturated Zone Model-(Description)
'The SUTRA code is the only code in the list that is capable of simulating unsaturated flow and transport.
It is recomended that DOE consider using the FEMWATER/FEMWASTE codes.
These codes have been used at the site in the past.
36.
Page 2-34; Appendix, Section 2.3.3:
Develop Unsaturated Zone Model 1, Description)
This section should include a detailed description of how geostatistical or stochastic approaches will be used.
37.
Page 2-34; Appendix, Section 2.3.3:
Develop Unsaturated Zone Model
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(Description)
Will a model be developed for each trench experiment, or will a single l
numerical model be used to simulate all experiments?
38.
Page 3-1; Appendix, Section 3.0:
Facility Re, lated Programs Plans to characterize individual solid waste management units are good.
It is recomended that a map showing the location of each of these units on the site be included.
This would help in the review'of the plans for the site.
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Page 3-1; Appendix, Section 3.0: Facility Re, lated Programs i
How will closure scheme /remediation' alternatives for the decommissioning and decontamination (D&D) portion of the EIS be evaluated? It is reconmended that these alternatives be identified and reviewed before implementation of site characterization if the goal of the site characterization is to support potential remediation schemes.
40.
Page 3-1; Appendix, Section 3-1:
Facility Related Programs l
Describe any post D&D confirmatory surveys. hat will be done at this site.
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Pape3-]; Appendix,Jection3.0_:
Facility-Related Programs The discussico of all facilities of concern is a fairly comprehensive description of potential scurces of contaminants on the site.
- However, what is missing and what would be particularly useful in evaluating'this plan is a sequence of maps or perhaps two maps (north and south plateau) which would be referred to in'the discussicn.
The maps could help in
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establishing the location, proximity, and relationship of all.the facilities to each other and across the site.
j In addition to map information, it would be particularly useful to have a list of potential contaminants associated with each facility. This is n:entioned for some facilities but not others.
42.
Page 3_-21 ppendix, Section 3.1:
North Plateau A
This section provides a description of the hydrogeologic setting of the north plateau which is useful in understanding the potential migration of contaminants from the various operation and facilities.
However, for many of the facilities described, their relation to the surficial deposits (alluvial fan or lavery till) is not discussed.
These relationships should be described.
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45.
Page 3-8; Appendix Section 3.1.2:
Maintenance Shop Sanitary Waste Leach Field x
Will any soil samples te taken from this area? There may be residual contamination in the ursaturated zone between the leach field and the water table.
44.
Page3-9; Appendix,Section,,3.1.2:
Low-Level Waste Hardstand It is recommended that soil in surface drainage channels away from this site be checked for radioactivity since it may have been washed off this area.
45.
Page 3,-_27; Appendix, Section 3.2:
So,u,th Plateau This section provides a description of the hydrogeologic setting of the south plateau which is useful in understanding the potential migration of contaminants from the various operation and facilities.
However, for many of the facilities described, their relation to the surficial deposits (alluvial fan or lavery till) is not discussed.
These relationships should be described.
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46.
Page 3-28; Appendix, Section 3.2.1:
NDA-WyDPPotentialDisposals It is recommended that areas of soil contamination associated with the NDA area but are outside the boundaries of that area should be evaluated.
For example, the contaminated fill material that was discovered during the
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L interceptor l trench excavation.
This should be done for L complete site and source term characterization.
The use.of geophysical methods as were recently applied to the state disposal area should be considered for use l
at the NDA area to help characterize that area.
'47 Page 4-2; AL; ?ndix, Section 4.2.2:
Evaluate Effects _of_ Low-Level Radiation on HDPE It is recommended that COE-review a copy of the report prepared by NRC's consultant, Dr. Stewart S1111ng. regarding the structural stability of the HDPE High-Integrity Containers (HIC).
The June 10,~1988 report by Dr.
Silling titled, "Revict of the Structural Designs of Polyethylene High
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Integrity ~ Containers," should prove helpful.to DOE in identifying problems with HDPE materials in DOE's efforts to evaluate the effects of low-level.
radiation on HDPE.
Comments _on:
" Performance Assessment at the West Valley Demonstration Project-General Comments:
The document's' discussion of the present direction of the perfo'rmance assessment ~ program at the WVDP is very general.
NRC recommends that the document define up-front the applicable criteria or standards and the time I
period for the analysis, as wellLas,.providing a' documented basis for the selection of this period of performance.
Also, the assessment should focus on l
the WVDP and include discussions of residual contamination, including existing-i' disposal at-the site and any-other proposed disposal.
The NRC staff cautions that the WVDP site-is hydrological complex, the source term is not well known, and that simplistic codes may not be technically defendable without complex analyses to support the use of simple models.
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Also, the NRC staff would like to point out that the design basis for L
low-level waste (LLW) disposal facilities is 500 years-(47 FR 57446). The NRC o
L staff assumes.that performance of a LLW facility would be analyzed-for at least that time. When establishing analysis time, and time increments,'the analy(2) st L
.(1) half-life of the radionuclide, would need to consider the following:
I behavior of the released nuclide in the biosphere, (3) waste packaging and waste. form (4) containment provided by engineered features of the facility design and (5) the increasing uncertainty of predictions with increasing _ time.
Data points andEtime increments should be 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 the impacts for long-lived isotopes. NUREG/CR-5453 " Background Information for the Development.of a Low-Level Waste Performance - Assessment I
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. i l-Methodology" provides guidance on-these areas.
DOE has stated, as a matter of~
policy, it will conform to 10 CFR Part 61 in any disposal of low-level radioactive waste at its WVDP site.
Section 61.41 of 10 CFR Part 61, " Protection of the General Population from Releases of Radioactivity," states:
?
" Concentrations of radioactive material which may be released to the general environment in ground water, surface water, air, soil, plants, or animals must not result in an annual dose exceeding an equivalent of 25 millirem to the whole body, 75 millirems to the thyroid, and 25 millirem to any other organ of any member of'the public.
Reasonable effort should be made to maintain releases ~of radioactivity in effluents i
to the general environment as low as is reasonably achievable."
No time period is specified in Section 61.41 for' meeting the 25-75-25 millirem-per year dose release requirement.
Under $61.42 DOE should demonstrate that the 25-75-25 millirem per year dose-
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limit can be achieved for a disposal facility _ that will have significant quantities of long half-life radionuclides, particularly the transuranics wastes.
The migration of-such radionuclides in sufficient quantities from the disposal site and the possible release to the accessible environment could take several thousands or more years before the dose limits might be exceeded. Without providing a performance assessment of the LLW disposal facility for such a time period, DOE would not be in a position to demonstrate i
that the 561.41 would.be met.
DOE should develop the 25-75-25 millirem per year dose limit criteria in a manner such that the disposal of long-term half-life radionuclides could be analyzed to demonstrate that $61.41 would be met.
Specific Comments:
l 1.
Page 5; Section 2.1:
Pathway Analysis. Performance Assessment and Site Characterization Section 2.1 provides an outline of possible pathways.
It does not discuss scenarios.. A section on scenarios should be added.that is appropriate to the WVDP.
2.
Page 9; Section 3.01, Performance Assessment Methodology This section should provide the basic outline for the. discussion of performance assessment for the WVDP.
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Page 15, Section 4.1:
Specific Data Requirements
-i The WVDP staff should define a conceptual model using'the data that is 1
available and base performance modeling-requirements on that model.
This j,
would then put some realistic boundaries on actual site specific characterization needs.
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4.
Page 25; Section 5.1: No,d,els
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The treatment models in this section are very complete but are generic.
This section should relate the discussion of models to site specific-modeling needs.
5.
Page 30; Section 5.2: Computer Codes Appli, cable to Performance Assessment The emphasis on systems models in this section lacks any justification.
Based on the preceding discussions in Sections I through 5 of the document, it would appear that systems codes could only be justified-
-i after considerable site characterization and complex modeling, at least for the groundwater pathway. The' poorly understood complex system of sand lenses in the Lavery Till and.the unknown nature of the fracture system in the till related to 01acial unloading and weathering phencmena suggest that for the groundwater pati,way use of simple models for analysis will not be justifibble.' The information presented in :this 4
document does not support the use of systems models, q
Comments on:
Implementation Plan for the Environmental Impact Statement (EIS),PhaseII General Comments:
w The introduction of the Implementation Plan (IP) for the EIS states'that the emphasis of the IP is to identify the issues to be 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. The focus of NRC's review and comments addressed the type of information that would be-included in developing-an EIS. NUREG-1300, " Environmental Standard Review Plan for the' Review of a License Application for a Low-Level Radioactive Waste Disposal Facility,"
i provides guidance on the type of information, as well as, how the NRC staff-p would review the information provided in an EIS.
The discussions in the IP attempt to address safety review considerations as-well as environmental issues.
DOE also states in the IP that both the g
environmental and safety reviews will be completed by December 1994, i
NRC recommends that safety issues be separated from the IP and the EIS, and that DOE use-NUREG-1300 as a bases for developing the EIS.
DOE is encouraged to clarify how the safety review issues would be addrcssed.
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Specific Coments:-
- l 1.
Page 15; Section 3.2.2: Management of Prior Disposal and Areal-
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Contamination Does management of localized " hot spots" and area contamination in the State-licenseddisposa1' area'(SDA)-andNRC-licensed-disposalarea(NDA)'
imply ultimately meeting ~ Performance Objective 61.44, Stability of the Disposal Site af ter Closure't 2.-
Page 17; Section 3.2.6:
Removal of High-Level and Grea,ter than Class C Wastes _f, rom the WNYNC The disposition of the high-level waste tanks, following removal of the -
high-level waste liquids and sludges, should be-addressed.in this section.
3.
Page 24; Section 3.3.3:
Existing Disposal Areas-To -help' better understand the subalternatives, within the broader alternatives of in-place stabilization, and. exhumation and-.redisposal;for the existing SDA and NDA' disposal areas,:the staff requests that referenced reports Grant and Blickwedehl, 1988; DOE, 1986; and Envirosphere, 1986 be provided.
4.
Page 31; Section 3.5.1.2:
Site Characteristics In expansion of the site characterization data base land information that I
is planned by DOE, it is recommended that the' developed information be comparable to the information that is identified in NUREG 1200,-Rev. 1 Section 2, " Site Characteristics."
n 5.
P_ age'32; Section 3.5.1.3:
Disposal and Closure System Charac_teristics It is recommended that the information to be developed 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 ir. formation needs identified in'NUREG-1200, Section 3, a
4:
Design and Construction; Section 5, Site Closure Plan and-Institutional Controls; and pertinent portions of Section 6, Safety Assessment.
6.
Page 32;_S,e,ction 3.5.1.4:
Performance Objectives The IP states.that "The EIS will propose a site performance objective for-releases, and facility objectives for accessible contamination."
It is-recomended that this statement be expanded-to cover whether it is intended that 10 CFR_Part 61 Performance Objectives'are to be met,-or if some other performance objectives are intended.
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Page 37; Section 3.,5,2.6:
Definition of Transuranic Waste This section discusses the planned activities for' defining the definition, of transuranic waste but states that regulatory questions will remain to' be worked out.
This section should reference the process set out=in the West Valley Settlement Agreement (Bixby/Knapp August 18, 1987). The-l agreement is c' result of the Stipulation of Compromise Settlement:-
i Coalition on West Valley Wast _e_s, et al v. U.S. Department of Energy, July 14, i
T987. This process identifTes.the technical analyses to be performed by i
DOE and the regulatory role of the NRC in reviewing the DOE analyses.
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