ML20043F386
| ML20043F386 | |
| Person / Time | |
|---|---|
| Issue date: | 06/14/1990 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Williams J MAINE, STATE OF |
| References | |
| REF-WM-3 NUDOCS 9006140457 | |
| Download: ML20043F386 (4) | |
Text
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. 8,.,n,y'o UNITED STATES
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g NUCLE AR REGULATORY COMMISSION g
E WASHINGTON, D. C. 20555 JUN 141990 k..... p Mr. John S. Williams, Executive Director Maine Low-Level Radioactive Waste Authority 99 Western Avenue, Suite 6
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PO Box 5139 Augusta, Maine 04332-5139
Dear Mr. Williams:
By letter to John Greeves dated May 8,1990 you requested that the Division of Low-LevelWasteManagementandDecommissionIng(LLWM)staffcommentonthe proposed site screening process developed for selection of a low-level waste disposal facility in Maine.
LLWM staff is pleased to comment within the following limitations:
(1) we are commenting only from the perspective of the utility of the process for selecting a low-level waste disposal facility; i.e., our comments are not directed at the use of the process and criteria for selecting a waste storage or other type of management facility; and (2) we are commenting only on the criteria that address or are related to siting criteria established in 10 CFR Part 61. We have not addressed the appropriateness or adequacy of criteria related to protected natural areas, scenic and cultural resources, or other limitations derived from other State or Federal authorities such as the l
Environmental Protection Agency or Maine Department of Environmental l
Protection.
The concept outlined in this document of narrowing in on acceptable low-level waste disposal sites through the use of exclusionary criteria, preference criteria, and avoidance criteria seems reasonable. We would suggest, however, that you consider a screening process for volunteer sites that is somewhat more rigorous than the one identified. Under such a process, it is possible that some volunteer sites would be eliminated as good candidate sites during an incremental screening due to the absence of " Preference" characteristics or the presence of " Avoidance" characteristics. Under the present process, all volunteer sites are automatically good candidates for detailed site screening.
The proposed siting methodology covers either explicitly or implicitly all of the siting criteria specified in 10 CFR Part 61. However, there is some inconsistency with the degree to which the criteria are addressed. The criteria exclude disposal within the 500 year floodplain, a restriction that goes beyond 10 CFR Part 61 regulatory requirements. On the other hand, tectonic concerns are dismissed as a criterion by virtue of the lack of seismic activity in Maine. Further, surface erosion processes are addressed only by avoiding very steep slopes. A more active evaluation to ensure the absence of tectonic concerns is warranted. Similarly, there are factors beyond slope d
steepness (e.g. soil characteristics, rainfall) that contribute to adverse surface geologic processes.
Pro)osed criterion A.1., related to disposal in the vicinity of aquifers and reclarge areas, could be overly restrictive depending on how "high yield bedrock aquifer" is defined.
LLWM staff suggests that you look carefully at the implications of criterion A.I. as it is currently written, p
k D#l**6u g_ d du}
2 it is noted on page 14 that the propos:d criteria exclude disposal belou the water table.
10 CFR Part 61 allows the flexibility for such disposal particularly in soils such as marine clays and glacial till that have pensability characteristics that allow for such disposal.
On page 15, the document implies that a risk analysis is mandatory for a Nuclear Regulatory Comission (NRC) low-level waste disposal license.
NRC has no specific requirement for risk assessment as part of site performance assessment.
On page 21, a response to comments by a CAG member expressed agreement on excluding areas with mining and quarrying operations. Areas having known natural resources, currently being exploited or not, are to be avoided (10 CFR Part 61 6 61.50(a)(4)).
Information available at the site screening stage is usually adequate to exclude areas of both active exploitation and high potential for exploitation.
It was also noted, on page 30, that there appears to be a misreference to 10 CFR Part 61. UnderG,LandUse,thedocumentlists10CFRPart61.5(a)(2) as part of the Regulatory framework.
In the context of the discussion, we believe the correct reference is 10.CFR 61.50 (a)(11).
With respect to the first performance factor favoring land having low permeability, NRC staff, in writing 10 CFR Part 61, envisaged disposal in a manner which reduced contact of water with the disposed waste and provided a long pathway for any water contacting waste and moving to a point of exposure of the public [561.50(a)(5), (7), and (8). An exception was provided to the groundwater requirements in 661.50(a)(7) ]or cases w1ere high groundwater f
would present difficulties in finding a disposal site. Avoiding areas of good drainage, thus favoring areas which by their very nature tend to have high water tables, seems contrary to the first intent of $61.50(a)(7). Maine Mght want to reconsider favoring such sites as such favoritism could prove controversial in the future.
We hope these coments will be helpful to you as you finalize siting criteria for t,e Maine Low-Level Waste Disposal facility.
If you have any questions, please do not hesitate to call ms.
Sincerely, F/h H. LCHAUS Pau(ski 1D)haus, Chief l
l H. Lo Operations Branch Division of Low-Level Waste Management and Decomissioning, HMSS i
Distribution:
Central file J409;201 NMSS r/f LLOD r/f JShaff ner JKennedy PLohaus JStarmer JSurmeier JAustin JGreeves RBangart FConbs MTaylor, R I PDR Yes:
X PDR No:
Reason: Proprietary or CF Only ACNW Yes:
X No:
j SUBJECT ABSTRACT:
Proposed Site Screening Process for State of Maine
- See Previous Concurrence
- LL{/p 0FC :LLOB*
- LLTB*
- {L
~
- PLohaus NAME:J5haHner/lj
- JStaruer
- J nne( :TC@ {
(,/@90
- (f /Q/90
- () /J/90 DATE: 06/06/90
- 06/06/90 0FFICIAL RECORD COPY
2 It is noted on page 14 that the pr: posed criteria exclude disposal below the n
watat table. 10 CFR Part 61 allows the flexibility for such disposal partfolarly in soils such as carine clays and glacial till that have i
permea 11ty characteristics that allow for such disposal.
On page 1 the document implies that a risk analysis is mandatory for a Nuclear Reg latory Commission (NRC) low-level waste disposal license.
NRC has no s cific requirement for risk assessment as part of site performance assessment.
On page 21, a res nse to a comment by a CAG neW6er agreed to exclude mining
/
and quarrying opera ons. Areas having known r$ ural resources, currentl616 61.50(a)(4))y being exploited or n are to be avoided (10 CFR Part Information available ( the site screening stage is usually adequate to exclude areas of both act ve exploitation and higher potential for exploitation.
It was also noted, on page 30, that there appears to be a misreference to 10 CFR Part 61. Under G Land e,thedocumentlists10CFRPart61.5(a)(E) s as part of the Regulatory Framewo In the context of the discussion, we believe the correct reference is 1 R61.50(a)(11).
NRC with respect to the first performa ce factor favoring land and having low perneability staff in writing 10 CFR Part 61 staff envisaged disposal in a manner which reduced contact of water with he disposed waste and provided a long pathway for any water contacting waste k,V moving to a point of exposure ofthepublic(561.50(a)(5),(7),and(8)]. An exceation was provided to the groundwater requirements in L61.50(a)(7) for cahs w1ere high groundwater would present difficulties in finding a disposal h te. Avoiding areas of good drainage, thus favoring areas which by their very niture tend to have high water tables, seems contrary to the first intent of (61.50(a)(7). Maine might want to reconsider favoring such sites as such favoritl6m could prove controversial in the future.
We ho)e these coments will be helpful to you as you finalhe siting criteria for tie Maine Low-Level Waste Disposal facility.
If you have any questions, please do not hesitate to call me.
Sincerely, Paul H. Lohaus, Chief i
Operations Branch l
Division of Low-Level Waste Management and Decomissioning, INSS 1
Distribution: Central File #409.20 NMSS r/f LLOB r/f J$haffner JKennedy PLohaus JStarmer JSurmeier JAustin JGreeves RBangart FCotbs MTaylor, R I PDR Yes:
X PDR No:
Reason: Proprietary or CF Only ACKW Yes:
X __
No:
SUBJECT ABSTRACT: Proposed S Fe~5creening Process for State of Maine
- See Previous Concurrence OFC :LLOB*
- LLTD*
- LLOB
- GPA
- LLOB NAME:JShaffner/lj
- JStarmer
- JLennedy
- fCombs
- PLohaus DATE: 06/06/90
- 06/06/90
/ /90
/ /90
/ /90 0FFICIAL RECORD COT)Y
m, r
) ;c.. : s-4 L
JS/ WILLIAMS.LTR
-P-
- V Mr. John S. Williams Itisaisonotedthattheproposedcriteriaexcludedisposalbelowthewater table.
10 CFR Part 61 allows the flexibility for such disposal particularly in soils such as marine clays and glacial till that have pernmabfiity characteristics that allow for such disposal.
It was also noted, on pr. '), that there appears to be a misreference to 10 CFR Part 61.
UnderG,LandUse,thedocumentlists10CFRPart61.5(a)(2)as part of the Regulatory framework.
In the context of the discussion, we believe the correct reference is 10 CFR C1.50 (a)(11).
We hope these consents will be helpful to you as you finalize siting criteria for the Maine Low-Level Waste Disposal facility.
If you have any questions, please do not hesitate to call me.
Sincerely, x
\\
Paul H. Lohaus, Chief Operations Branch s
\\
Division of Low-Level Waste. Management
\\
and Decounissioning, NMSS NNSS r/f LLOB r/f Distribution: Central File f409.20
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JStarmer JSurmeier JShaffner JKennedy PLohaus x FCombs JAustin JGreeves RBangart
.PDR Yes:
X PDR.
No:
Reason:
Proprietary or CF Only ACNW Yes:
X No:
L SUBJECT ABSTRACT:
Proposed Site Screening Process for State of Maine x
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- LLTB
- LL'0B
- GPA
- LLdB 0FC:LLOBcg g
NAME:JShaffner/lj
- JStarmer ~^(/':JKennedy
- TCombs
- PLohaus
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/ /90
/ [9'O DATE: //I/90
- 4/4/90 0FFICIAL RECORD COPY
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