ML20043A066
| ML20043A066 | |
| Person / Time | |
|---|---|
| Issue date: | 05/14/1990 |
| From: | Hurt R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Bixby W ENERGY, DEPT. OF |
| References | |
| REF-PROJ-M-32 NUDOCS 9005170290 | |
| Download: ML20043A066 (1) | |
Text
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Pr'oject M.32
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Willis W. Bixby, Director
- fT West Valley Project Office U. S. Department of Energy Idaho Operations P. O. Box 191 West Valley, NY 14171
Dear Dr. Bixby:
The enclosure is a review of the three site closure documents you sent us on August 17, 1989:
the Site Character 1 ration Plan-Phase 11, the Performance Assessment at the West Valley Demonstration Project, and the implementation Plan for the Environmental Impact Assessment-Phase 11. The review was performed by the NRC Division of Low.levol Waste Management and Decommissioning.
We appreciate your efforts to keep us informed of your plans for ultimate cleanup and closure of the West Valley site, and look forward to further interaction on this subject.
We will be pleased to meet with you or your staff to discuss the points raised in the enclosure.
Sincerely.
.NI
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R. Davis Hurt West Valley Project Manager Advanced Fuel and Special Facilities Section Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety
Enclosure:
NRC review of three site closure documents cc:
T. DeBoer, NYSERDA Distribution:
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/:y 4 Gr MEMORANDUM FOR:
Richard E. Cunningham Director DivisionofIndustrial and Medical Safety, NMSS TROM:
Richard L. Bangart, Director Division of Low-Level Waste fianagement and Decommissioning, NMS$
$UBJECT:
REVIEW 0F THE $1TE CLOSURE DOCUMENTS FOR THE WEST VALLEY DEMONSTRATION PROJECT Enclosed you will find our comments on the West Valley Denonstration Project (WVDP) package. The comments are based on a review of the following documents:
^
Site Characterization Plan, Phase II West Valley Demonstration Project, July 10, 1989.
Perfonnance Assessment at the West Valley Demonstration Project, A Review of Methodology and Potentially Useful Pathway Analysis Codes, July 10,1989.
l ImplementationPlanfortheEnvironmentalImpactStatement(EIS),
Phase !! of the West Valley Demonstration Project and Closure of the Western New York Nuclear Service Center, Rev.0 - Draf t B. July 1989.
Both your September 8,1989, memorandum (Cunningham/Bangart) and the follow-up meeting on January 30, 1990, statedthattheDepartmentofEnergy(DOE) requested that we formally review the Site Characterization Plan and the Performance Assessment Plan.
The primary focus of our review was to determine if the programs for site characterization and performance assessment that are being developed by DOE omitted any major areas in the submitted plans. As a result of the January 30, 1990 discussion, we also reviewed the Implementation Plan for the EIS. The Imslementation Plan for the EIS is an essential elenent in the evaluation of the dVDP and the closure of the Western New York Nuclear ServiceCenter(WNYNSC).
In supinary, 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.
Because of DOE's concern to move forward with the WVDP, DOE began revising the draft plans while the NRC's-review was being conducted. We understand that several of NRC's concerns are being addressed.
Generally the staff found the Site Characterization Plan (SCP) did not describe the scope of all the site characterization studies that are needed for decommissioning, 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
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o LP/ SITE MEMO model of the site.
This model will provide a basis for assuring that the final site characterization program addresses all information needs. The Performance Assessn4nt-Plan provides a general discussion of perfortrance assessment but should emphasize performance assessment in relationship to the WVDP. The Iciplementation Plan (IP) for the EIS does not identify ell the issues to be considered in the preparation of the EIS for the completion of the WVDP and the closure of the WNYhSC. The stiff has identified some additional issues that should be includeo in the prer*, ration of the EIS.
The IP discusses both j
environnental and safety issues.
Because of the differences in the regulations and the type and scope of informatin that would norme11y be required for an EIS as corr. pared to a Safety Analysis Heport, DOE should clarify the intent of the EIS.
Since our review has taken longer than initially anticipated, we would be happy to meet with DOE at the earliest convenient date to discuss our comments.
This meeting should provide a nachanism to expedite the review process.
1 If you have any questions on our connents, please contact Clayton L. Pittiglio on X-23430.
MMR REHMS L RWGW l
1 Richard L. Bangart, Director i
Division of Low-Level Waste Management
. i.
and Deconmissioning Office of Nuclear Material Safety and Safeguards
Enclosures:
As stated l
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COMMENTS ON kEST VALLEY CEMONSTRATION PROJECT _ DOCUMENTS
Background:
In response to the Ocpartment of Energy (DOE) request of August 17, i
1969, (Sixby/ Mort){ ration Project (WVDP) y Comission (hRC) has reviewed the the Nuclear Regulator West Valley Dertons package provided in the DOE request.
The package consisted of the following documents:
(1) Site Characterization Plan, Phase II; (2) Performance Assesstnent at the West Valley Demonstraticn Project;and(3)ImplementationPlanfortheEnvironmentalImpactStatement (EIS), Phase 11, i
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 docurLent was nct requested.
However, because the Implementation Plan is an essential element in the evaluation of the WVDP and the closure of the Western New York Nuclear Service e
Center, WNYNSC, the NRC reviewed this document and has included coments.
t Basis for Review:
The NPC review was conducted by comparing the submitted plans with"~tTe~ requirements of Title 10 of the Code of Federal Regulations, Part 61, " Licensing Requirements for Land Disposal of Radioactive Waste"; the informatich presented in NUREG-1199, Revision 1,." Standard Fornat 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.
.Tte use of these requirements and supporting guidance is based on the requirements of the West Yalley Demonstration Project Act (P.L.96-368) Section 2(a)(4)andthelegalopinionoftheOfficeoftheGeneralCouncil, dated October 2, 1987.
I conclusion:
The primary focus of the NRC's review of the WVDP package was to determirse 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 in.portant to point uut that the dccuments 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.
a understand that several of the NRC's concerns have already been addressed.
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 decommissioning, decontamination and closure of the WVDP.
The staff recormends that DOE revisit and sumarize the existing site data and based on i
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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inforniaticn reeds.
The Performance Assessment Plar, provides a general aiscussion of performance assessment but needs to on;phasize performance assessment in relatict ship to the WVDP.
The Implementaticn Plan (IF) for the EIS dcos not adequately identify all the issues to be cor.sidered in the preparation of the EIS for the WYDP and the closure of the WNYllSC. The st6ff h65 ident~ified some additional issues that should be included in the preparation of the Els.
The IP discusses and botii environmentc1 ar.d safety issues.
Because of the differences in the regulations and the type and scope of infctmation 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 Coments:
DOE states in the document that the purpose of the Site Characterization Plan (SCP) is to describe the scope cf the site characterization studies associated with the decommissioning, decontamination and closure of the Western New York f;uclear Service Center, WNYNSC.
The docurent also states that the intent of the SCP is to build on the many site characterization studies that have been performed by the WVDP, tiew York Geological Survey, the U.S. Geological Survey and others.
In support of this approach NRC recommends that the SCP should focus on sunnarizing existirg 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 recommended that 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 a 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. Af ter 1000 years, the
cocurent states that all but the very long half-lived isotopes will have cecayed to levels which will ret create an environmental it. pact.
Cor.sicering the large ar.our,ts of transuranic wastes to be left on the site, the impacts of failure are significant for nalf-lives greater than 1000 years.
The report aid rot provide an adequate basis that supports this time frame. The SCP needs to et.phesize the principal purpose of a site characterization program.
The puricse of site characterization is to establish site information (e.g.
geography, demography, meteorology, 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 time interval question is more appropriately related to the period th6t performance assessment studies shculd be conducted.
Specific Coraments:
1.
Page,,7,; Section 3.0:
Issues It is indicated in this section that the SCP was developed to provide input to support a performance assessment af ter closure and to address a series of technical issues.
This statement appears to omit SCP efforts 4
that would be needed to address design, construction, and closure considerations related to the oroposed alternatives of in situ stabilization or exhumation anc 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 t1at the SCP program be revised to clearly -indicate this objective.
2.
Page 9; Section 5.0:
A
_ pproach 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 Gereric) that are identified by DOE in the SCP reflect a very extensive and ambitious program for the West Valley project.
The four major programs are subdivided in the Appendix into a large number of individual studies and work activities that are to be completed by DOE.
The level of description of the studies and work activities in the Appendix is
essentially equivalent to brief statements on overall program objectives with pelimirary estimates of required DOE rescurces.
Projected schedules t
by DOE for completing the activitics htye been provided for only a stra11 portion of the identified studies.
The descriptions of the planned work cre not equivalent to initi61 cesign 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 WYDP, the items that are listed below are recomn.endations for the future planced activities ioentified in the I
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 l
are developed for the various listed activities.
2)
DOE should schedule meetings with NRC's staff on a regular basis to discuss and address isnportant design and review issues related to the planned studies and activities (e.g. the scope cnd 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 outstandirig reviewconcerns/ issues.)
3) 00E should provide an estimated schedule for completing the 6ctivities 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. Se,c,tjon 2-0:
Site Related Programs 00E 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:
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 movernent with l
periodic contemporaneous sets of measurements in the:
surficial alluvial fan aquifer or the North Plateau unweathered till unit in the South Plateau l
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. l weathered and fractured till near the state-licensed and facility disposal areas and other facilities in the South l
Plateau areas.
j Establishing conceptual and numerical or aralytical n.odels that l
would be appropriate for assessment of facilities situated within the North and South Plateau areas, i
Providing a site-wide framework for interpretation of data collected in facility specific studies.
If these activities are already being addressed, the plan should provide the specific references.
Page2-11Ap)endix,'fn'TheSite 5.
Section 2.1:
Characterization of Erosion Pctential on Streams witch Ona The Site Characterization Plan (SCP) indicates that the focus of the erosion study will be on oefining the mechanism and rate of erosion on the various small streams which are located adjacent to the disposal areas.
i The study will attempt to use historical erosion data to determine if mitigative designs are necessary to protect the site frcm long-term erosion problems.
While historical erosion data are interesting and sometimes useful, such l
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) may result in the under-design of protective structures, unless very large floods have occurred and the l
rate of erosion for such large floods can be determined.
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The questionable value of historic data is further evident when one examines the causative mechanisms of eresion.
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 phenomena 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 advancement, 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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~6-base.
Procedures that atterupt to expand the data base such as age dating of flood terraces also have limitations, since it is generally not enoug1 to know that the most recent large flood, for example, occurred 435 years This type of information may be interesting but is of limited value ago.
when considering flood threats to the site.
Only data with quantifiable hydrologic parameters, such as flow rate, rather then qualitative 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 sailecting 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 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 will need to be supplemented with a considerable' amount of additional data.
6.
Page 2-2: Appendix.Section2.J.1:
Distribution and Characteristics of 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 slope 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 force, cohesion, vegetation density, etc.
(The staff notes that threshold 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 site to withstand the effects of a single large flood event, such as the ProbableMaximumFlood(PMF).
It would be prudent to direct data-gathering 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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Fage 2-S; Appendix,,,,Section 2.1.2:
Flood Routing,, Calculation It is noted that the principal objective of this activit) is~to determine the discharges associated with floods of various magnitudes in the site i
vicinity. As part of this activity, the staff suggests tht.t the telccities 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 c.hanges to flood velocities and levels at various places in the site area.
Therefore, the flood analyses proposed as part of this i
task may be of l'ttle value for final design purposes.
It would be prudent to develop a conceptual design at this point to determine the t
effects of flooding on a flood-protected site.
In short, it is prudent to i
perform fewer flood.ng analyses for the site as it currently exists and 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 r.ote 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, i
E.
Page 2-7; Appendix. Section 2.1.3:
Monitoring of Current Erosion As previously discussed, the staff questions the value of using current-erosion rates to determine designs for site stability for long periods of time.
However, the activities proposed in this task to determine threshold values of precipitation and discharge' levels may be useful, l
particularly if a flood of sufficient magnitude occurs and causes erosion.
The staff recommends that the proposed d6ta be supplemented with threshold values of stream velocity and tractive force, since the major design i
parameters are usually not flood levels.
9.
Pace 2-9; Appendix, Section 2.1.4:
Characterize Stability of 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 carticle 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, it is unlikely that concrete can be used as erosion protection fcr long
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aeriods of tir.e without maintenance (as required by 10 CFR Part 61).
,nlus e type of concrete can be developed to withstand chemical and physical weathering for periods of 300-500 years, witbcut the use of ir.aintuence 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.
NPC criteria currently exists for quantitatively determining tre quality of rock riprap.
10.
Page2-12; Appendix,,,jection2.1.5:
Develop Eros,ipn,Mcc'el It is noted that models will be developed to determine erosion rates as a function of storm magnitude, liowever it should be pointed 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 trying to predict soil. losses in channels and gullies over a long period of time. The value of such models trey also be questionable where super critical flow occurs.
flodels such as HEC-6, for example, may be of limited value when trying to predict the long term performance of steep stream channels for a long period of time and for a wide range of storm and flood events.
11.
Page 2-16; Appendix. Section 2.2:
Geochemical Characterization 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 2-1,6,; Appendix. Section 2.2.1:
Ground Water Characterization _(0_bjectives)
This section states that flow through the fractured, weathered till is important; however, the section should state that this is cnly in,portant to facilities situated in the south plateau.
In the north l.
plateau, the most significant unit is the surficial alluvial fan unit.
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13.
Page 2-18; Appendix,,Section 2.2.1: GroundWaterCharacterization(Description) i It is important to point out that evenly distributing wells among the three units may not be the most appropriate approach to characterizing I
the geochemical conditions and evolution within each major hydrogeologic unit from recharge to discharge point.
It is recommended that such a program give careful and thoughtful consideration to potential contributions from various facilities situated above each unit.
- 14. Page 2-20; Appendix, Sec,t,1pn 2.2.2: Surface Water Chemistry Characterization l
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The section should describe more fully the sampling equipment, sampling procedures and decontamination procedures.
It is diso reconsended that-this section describe the methods used for all parameter analysis.
Also describe the method used to determine sorption and ion exchange parameters.
15.
Face 2-23; Appendix, Section 2.2.4:
Solute-Gro,undwater-Seil Interactions
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(Descript1_o_nj n
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 a modification to evaluate the impact of fracturing. pproaches may require 16.
Page 2-24; Appen,d,ix, Section 2.2.4t Solute.Gr_oundwater-Soil Interaction (Description)
This is the first mention of geohydrologic paraneters in this section.
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How will the database originate for these parameters?
If it comes from past studies, this should be stated and the references included.
How will they be used?
The models mentioned 1rter in the section are purely geochemical models.
Will numerical or ana?ytical models of transport be developed under this activity?
17.
Page 2-24; Appendix. Section 2.2.4:
Solute-Groundwater-Soil Interactions TDescrrption) 1 The peer review process should be described in more detail, and a list of participants should be included.
18.
Page 2-2a; Appendix. Section 2.2.4:
Solute-Grou,ndwater-Soil Interactions
_(Description)
There is some concern that the proposed contaminant transport models are not sufficiently rigorous to deal with the geologic conflexity of the site.
Any contaminant transport model proposed to be used should be calibrated using existing site data in order to demonstrate its validity at this site.
- 19. _Page 2-25; Appendix. Section 2.2.4:
Table 2-1,1 In this table it was not clear what was meant by calibration of models.
The purpose of geochemical modeling is more along the lines of hypothesis testing.
Given a certain water chemistry and soil composition, the models are used to identify important chemical reactions and to establish other
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4 important geochemical parar..eters such as solubility-lin.iting concentrations or adsorption-desorpticn relationships.
Results of this type of tredeling can be used as a bar,is 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 cument applies to points number 13 and 14 in Table 2-12.
- 20. Page 2-27; Appendix Sect,1,on 2.3: Evaluate Unsaturated,, 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 rouch 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 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.
22.
Page'2-28;Ap;endix,{Section2.3.1:
Development o,f_ Water Budget and Infiltration Est,1, mat s Should this be the re16'tionship of water content pressure, and hydraulic conductivity (i.e., soil characteristic curves)?
- 23. Section 2-28; Appendix Section 2.3.1:
Development of Water Budget and
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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,lopment 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 fractured till system and to estimate flectuations in the water table.
How will boundaries be handled to account for lateral fluxes?
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Pa g 2-28; Ap)erdix.Section 2.3.1:
Deve_loptrer.t of Water Budget and Infiltration Estimates 8!sase list other tests that will be used.
26.
Page 2-29; Ap>endix, Section 2.3.1:
Development of Water, Budget and in,f,i,Ltration Estiinates
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The proposed data collection activity seems inconsistent with the modeling approach proposed in paragraph 1.
Please clarify how the proposed modeling approach will use this data.
27.
Tiige 2 29; Apsendix. Section 2.3.1:
Development of Water Budget and Pa iTt'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._21, Fracture Flow Investigations (Parameters)
In addition to the paraneters listed, another parameter that will need to be evaluated is the characteristic relationship $ of moisture content, j
pressure, and hydraulic conductivity of the weathered, fractured till in order to understand in transient flow phenomena in the shallow till system.
I 29.
Page 2-30; Appendix, Section 2.3.2:
Fracture Flow Inves,t,13ations (Parameters) l What is the relevance of nominal travel time and flow rate of groundwater through the time estimated for a unit gradient when examining vertical movement or lateral movement?
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30.
Page 2-30; Appendix, Section 2.3.2:
Fracture Flow Investiga,tions (Parameters) l l
Please clarify what is meant by spatial and temporal distribution of transient water tables. Does this apply to the entire south plateau area?
p 31.
Page 2-31; Appendix, Section 2.3.2,:,, Fracture Flow Investigation (Parameters)
Item 3 in the parameter list on p. 2-30 is very general.
Describe the i
scope of the experiments that will try to address this item.
This does not appear to be addressed in the current plans.
32.
Page' 2-31; Appendix, Section 2.3.2:
Fracture Flow Investigation (Description, l'
Sentence 1)
Suggest that term " unit" be omitted form the sentence.
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, 33.
Page 2-31; Appendix, Section 2.3.2:
Fracture, F, low Investication (Description]
Will the flow rate actually be monitored or estimated? If direct l
monitoring will be done, please clarify how.
34.
Page 2-34;'o, Appendix, Section 2.3.3:Develop Unsaturated Zone Model (Descript'i n)
It would be more appropriate to refer to the groundwater codes as
" generally accepted" or "widely used" instead of " validated."
35.
Page 2-34; Appendix, Section 2.3.3:
Develop Unsaturated Zone Model (Description)
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The SUTRA code is the only code in the list that is. capable of simulating unsaturated flow and transport.
It is recommended 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 Unsatu,ra_ted Zone Model (Description)
This section should include a detailed description of.how geostatistical or stochastic approaches will be u:ed.
37.
Page 2-34; Appendix, Section 2.3.3:
Develop Unsaturated Zone Model (Description)
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t Will a model be developed for each trench experiment.or will a single numerical model be used to simulate all experiments?
38.
Page 3-1; Appendix, Section 3.0:
Facility Related Programs-Plans to characterize individual solid waste managemer.t units are good.
It is recommended 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.
- 59. _Page 3-1; Appendix, Section 3.0: Facility R,e, lated Programs How will closure scheme /remediation alternatives for the decommissioning and decontamination (080) portion of the EIS be evaluated? It is j
recommended 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 Describe any post D&D confirmatory surveys that will be done at this site.
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, 41.
Page,3-1; Appendix. Sectfon 3.0,:, Facility-Related Programs The discussicn of all f acilities 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 discussion.
The maps could help in establishing the location, proximity, and relationship of all the facilities to each other and across the site.
In 6ddition to map information, it would be particularly useful to have
.a list of potential contaminants associated with each facility. This is tcentioned for sorre facilities but not others.
42.
Page 3_-_2,;, Appendix. Section 3.1:
North Plateau This section provides a description of the hydrogeologic setting of the north plateau which is useful in undarstanding the potential migration of contaminants from the various operation and facilities.
However, for many of the facilitics described, their relation to the surficial deposits (alluvial fan or lavery till) is not discussed.
These relationships should be described.
43.
Page 3-8; Appendix,,,Section 3.1.2: Maintenanc,e_,Sh_op Sanitary Waste Leach Field Will any soil samples be taken from this area? There may be residual contamination in the unsaturated zone between the leach field and the water table.
44 Page 3-9; Appendix. Section,,3.1.2:
Low-Level Waste Hardstand-It is reconsnended 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 mary of the facilities described, their relation to the surficial deposits (alluvial fan or lavery till) is not discussed.
These relationships should be described.
l 46.
Page 3-28; Appendix. Section 3.2.1:
NDA-WVDP Potential Disposals s
It is regommended 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
o
, interceptor trench excavation.
This should be done for a complete site and source term characterization.
The use of geophysical methods as were recently applied to the state disposal area should be considtred fer use at the flCA area to help characterize that area.
47.
Pace 4-2: Appendix. Section 4.2.2:
Evaluate Effects of Low-Level Radiation on HDFE It is recommended that DOE review a copy of the report prepared by liRC's consultant, Dr. Stewart Silling, regarding the structural stability of the HDPE High-Inttgrity Containers (HIC).
The June 10, 1988 rt) ort by Dr.
Silling titled, " Review of the Structural Designs of Polyettylene High 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:
"Perfnrmance Assessment at the West Valley Demonstration Project General Comments:-
The document's discussion of the present direction of the performance assessment program at the WVDP is very general.
NRC recommends that the document define up-front the applicable criteria or standards and the time period for the analysis, as well as, providing a documented basis for the selection of this period of performance.
Also, the assessment should focus on the WVDP and include discussions of residual contamination, including existing 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, i
and that simplistic codes may not be technically defendable without complex analyses to support the use of simple models.
Also, the NRC staff would like to point out that the design basis for low-level waste (LLW) disposal facilities is 500 years (47 FR 57446). The NRC 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 would need to consider the following:
(1) half-life of the radionuclide, 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 and time increments should be such that reasonable extrapolaticns 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 m..
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, i 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 Peleases of Radioactivity," states:
" Concentrations of radioactive material which may be released to the general environment in ground water surface water, air, soil plants, or animalsmustnotresultinanannualdoseexceedinganequivalentof25 millirem to the whole body, 75 millirems to the thyroid, and 25 c.1111 rem to any other organ of any member of the public.
Reasonable effort should be made to maintain releases of radioactivity in effluents to the general environment as low as is reasonably achievable."
tio time period is specified in Section 61.41 for meeting the 25-75-25 millirem per year dose release requirement.
Under $61.42 COE should demonstrate that the 25-75-25 millirem per year dose 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 tin:e period, DOE would not be in a position to demonstrate that the 961.41 would be met.
I 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 561.41 would be met.
Specific Comments:
1.
Page 5; Section 2.1:
Pathway Analysis. Performance Assessment and _ Site l
Characterization l
Section 2.1 provides an outline of possible pathways.
It does not discuss l
scenarios. A section on scenarios should be added that is appropriate to l
the WYDP.
I 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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P_aoe_15. Section 4.1:
Specific Data Requirements The WVDP staff should define a conceptual nodel using the data that is l
available and base performance modeling requirements on that model.
This would then put some realistic boundaries on actual site specific characterization needs.
4.
Page 25; Section 5.1:
Mo,de,1s i
The treatment models in this section are very complete but are generic.
This section should relate the discussion of nodels to site specific t
modeling needs, t
5.
Page 30; Section 5.2:
Computer Codes App,1,1, cable to Performance Assessment l
The eniphasis on systems models in this section lacks any justification.
l Based on the preceding discussions in Sections I through 5 of the document, it would appear that systems codes could only be justified 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 glacial unloading and weathering phenomena suggest that for the groundwater pathway use of simple models for analysis will not be justifiable.
The information presented in this document does not support the use of systems models.
Coornents on:
Implementation Plan for the Environmental Impact Statement (EIS),PhaseII General Conenents:
t The introduction of the Implementation Plan (IP) for the EIS states that the I
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 convents 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 "
provides guidance on the type of information, as well as, how the NRC staff i
would review the information provided in an EIS.
i 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 environmental and safety reviews will be completed by December 1994.
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 addressed.
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- 17f-a Specific Conments:
1 1.
Page 15: Section 3.2.2: Management of Prior Disposal and Areal
_ Contamination
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Does management of localized " hot spots" and area contamination in the State-licensedoisposalarea(SDA)andNRC-licenseddisposalarea(NDA) imply ultimately meeting Performance Objective 61.44, Stability of the
]
Disposal Site after Closure?
t 2.
Page 17; Section 3.2.6:
Removal of High-Level and Gre,a,ter than Class C Wast's im m the WNYNC The diroosition of the high-level waste tanks,-following removal of the high-level waste liquids and sludges, should be addressed in this section,
~m
-3.
Pace 24; Section 3.3.3:
Existing Disposal Areas To help better understand the subalternatives, within the broader
-k alternatives of in-place stabilization, and exhumation and redisposal for i
the existing SDA and NDA disposal areas.the staff requests that referenced re Envirosphere, ports-Grant and Blickwedehl, 1988; DOE, 1986; and 1986 be provided.
I 4.
Page 31; Section 3.5.1.2:
Si,te Characteristics In expansion of the site characterization data base and.information that s p anned by DOE, it is recommended that the~ developed information be comparable to the information that is identified in NUREG 1200*' Rev* 1*
a Section 2, Site Characteristics."
i 5.
Page 32; Section.3.5.1.3: Disposal and closure.S_ystem Characteristics It is recommended that the information to be developed by DOE on engineering details and the anticipated )erformance of the disposal units, i
waste cover cap, and other portions of t1e closure system be comparable to the applicable information.needs-identified in NUREG-1200, Section 3, 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 i
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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7.
Page 37; Section 3.5.2.6:
Definition of Transuranic Waste t
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 Settlecent' Agreement (Bixby/Knapp August.18,1987). The
'3 agreement is a result of the Stipulation of Compromise-Settlenant:
Coalition on West Valley Wastes, et' al v. U.S. Department of Energy, July 14, T987.
4 This process identifTes the technical analyses to be performed by DOE and the regulatory role of the NRC in reviewing the DOE-analyses.
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