ML20079H276

Safety Evaluation Review of the Prototype License Application Safety Analysis Report.Belowground Vault

ML20079H276
Person / Time
Issue date:	09/30/1991
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
References
NUREG-1375, NUREG-1375-V02, NUREG-1375-V2, NUDOCS 9110100255
Download: ML20079H276 (52)

Text

_

d' NUREG-1375 Vol.2 i

)

Sa:?ety Evaluation Review 0:? ~:he i

Pro ~:0~:y:pe License Ap; plica: ion Sa:?ety Analysis Report 1

Belowground Vault

.U.S.' Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguants August 1991 pa nccoq hb?r 2[: "!!!ai,Il '

mn

.w AVAILABILITY NOTICE -

Availability of Reference Materials Cited in NRC Publications Most documets cited in NRC publications will be available frorn one of the following sources:

l

.1,

~ The NRC Public Document Room, 2120 L Street. NW., Lower-Level, Was.hington, DC 20555 2.

The Superintendent of Documents U.S Government Printing Office, P.O. Box 37082, Washington, DC. 20013 7082 3.

The' National Technical Inforrnation Service, Springfield,' VA 22161 Although the listing tho' follows represents the majority of documerts cited in NRC publica-tions, it is not intendtd to be exhaustive.

Referenced documents availab!e for inspection and copying for a fee from the NRC Public Document Room include NRC corraspondence and internal NRC memoranda: NRC bulletins, circulars, information notices, inspection and investigation notices; licensee event reports

. venoor reports and correspondence; Commission papers; and applicant and !!consee docu-ments and correspondence, i

r

.The following documents in the NUREG series are available for purchase from the GPO Sales Program: - formal NRC staff-and contractor reports ' NRC-sponsored conf 3ence proceed-ings, international _ agreement reports, grint publications, and NRC booklets and brochures, Also available are regulatory guides, NRC regulations in the Code of' Federal Regulaflons,-

and Nuclear Regulatory Commission Issuances.

Documents available from the National Technical Information Service include NUREG-series reports and tSchnical reports prepared by other Federal agencies and reports prepared by the Atomic Energy Commission, forerunner agency to the fluclear Regulatory Commission.

Documents'available from pubile and special-technical libraries include all open literature items, such as books, journal articles, and transactions. Federal Register noticos. Federal.

[

and State legislation, and ' congressional l reports can usually be.obtained from these -

libraries.

Documents such as theses,2 dissertations,- foreign reports and translations, and non NRC'-

~

conference proceedings are_available.for purchase from the organization sponsoring the

__ publication cited, Single copies of NRQ draft reports are available free, to the extent of supply, upon written requ st t', one Office of Admin!stration, Distribution and Mail Servicos Section, U.S. Nuclear l Regulatory' Commission, Washington,- DC 20555.

[

' Copies of industry codes and standards used in a substantive manner in the NRC regulatory

~

r!

process are maintained at the NRC Library, 7920 Norfolk Avenue, Be:hesda, Maryland, for use by the public, Codes and standards are usually copyrighted and raay be purchased from the. originating organization or if they~ are American Natiorial Standards, from the I

American National Standards In'stitute,1430 Broadway, New York, NY 10018.

L

j m

,,,Wf,y m.ffk,h@,h i '

j

+

,yyg;g9g4 gg ag ppg p&gg w

p i

o) m a a;,a,a (g,-Q.

4<

,k pt y y

4,gy f,. :

pyy v

ug

-g-y y

e - g~3 4 1

u e

.s s

Y ' [j{ ]'

[..?

k y j {%. > $.

,a 7

p

,+

-m.

p jphfj $offdj

(

f k i

4:

I '

4 l> ; j w [gjf

)W h.

i j

~a il l"

. R}

r.

- i na 2

g 3

J s

w

~

aq a

c -

4 l

j9 l

j n

,e ;:

n a.

~;

4 y

y

f. e 1-

p

~

c'

.u t

4.

en y

f 5-jin j

s

. $.~

k

['

i y

," av 3,

$k g

1 4

ll, 3

I

.i _igdkggg y np ?

f'%%n.hY,a$a AgdQ yh, N$jp jgN4 f

N h

4

?%44i 9110100255 910930 p..

W Q # M[y{l W W M $p q @ % lik L O shhl;f;pp5 4Mr f

u PDR NUREG W W$$jdd

' %g$$$f$gj$hN hhf h

kI khh 1375 R PDR e

!r ifE[$$$EId7% Af a

I NUREG-1375 Vol. 2

~- -::

~~ :Z:. ::~L:_ z-.:. :: :::. ::

~~L

~~:-22 Sw?ety Eva.uation Review 0:' tae Prototype License Anication Sa'ety Analysis Reaort Belowground Vault

_-_ _ Tz :Z: -

-~-

z _.

U.S. Nuclear Regulatory Commission Ofuce of Nuclear Material Safety and Safeguards August 1991

.a"' %,,

%+

i AllSTRACT The U.S. Nuclear lleguh, Miry Commission (NIAC) staff

'the staff developed review comments and questions and consultants reviewed a l'rototype License Applica.

using the Standard lleview Plan (SitP), 'tev. I tion Safety Analysis lleport (PLAS All) submitted by the (NURl!G-1200) as the basis for evaluating the accept-U.S. Department of linergy (DOI!) for the belowground ability of the information provided in the liGV PLASAlt vault (IlGV) alternative method of low.lcsel radioactive The detailed review comments provided in this report are waste disposal. In Volume 1 of NURl!G-1375, the NitC intended to be useful puidance to facility developers and staff provided the safety review results for an earth-State regulators in addressing issues likely to be encoun-mounded concrete bunker PLASAll In the current tered m the review of alicense app!ication for alow-level-report, the staff focused its review en the design, con-waste disposal facility, struction, and operational aspects of the IlGV Pl.AS Alt.

D O'

iii NURI G-1375. Vol. 2

..... (7 m i

Contents l' age iii Alls' I R AC I'........................................

j 1 INiltODUCI10N TO NitC SAltlilY ltliVil!W COMMiiNIS AND QUliS'110NS..

2 NitC STAl'it ill!ViliW.......

I i

l.

3 DliSIGN AND CONSTitUC110N 2

4 1%CilllY Ol'lill ATIONS.,

16

$ SITli Cl OSUl(li l'I.AN AN D INSITIUl10N AI. CONiltol.S.....

23 6 SAliirlY ASSl!SSMiiNT.

27 7 OCCUI'ATION AI, it ADI A i10N l'ItOTliC110N 40 44 8 lllittlittliNCliS.............

b i

1 v

N Ulti!G -1375. Vol. 2

SAFETY EVALUATION ItEVIEW OF Tile PitOTOTYl'E 1.lCENSE Al'I't.lCATION SAFETY ANAIXSIS ItEl'OftT:

HEl.OWGitOUND YAUI T 1

INTitODUCTION TO NRC The staffs efforts in s eviewing the llGV PI AS AR did mit SAFETY ltEVIEW COMMENTS (idude the dmiopinent of safety esatuadon u*1wj AND. QUESTIONS (SPR) input for selected review areas. \\ olume.,

Uf NUld!G-1375 thus differs from Volume1 of NURI:G-1375. The decision to not include S!!R input in On November 7,19S8, the U.S. Department of linergv Vmume was governed byconsideration of available staff (DGli) submitted the following document., on low level resources, as well as the reahmtion that the staff had met radioactive waste disposal to the U.S. N uclear Regulatory its objectn e of demonstrating the nature (ed, scope and Commission (NRC) for review and comment: " Prototype style)of an FIIR for a low-level radioacuve waste disposal License Application Safety Analysis Report [PI ASAR]:

facility with the publication of the safety evaluation status lianh Maunded Concrue llunker[liMClif'and"Proto.

aport in Vohnne 1. Hence, that activity was not repeated type License Application Safety Analysis Report:

in Volmm' 2 llelowground Vault [IlGVj." liG& G Idaho, Inc., IX)li's lead contractor for the DOli low Level Waste Manage-2 NitC STAlT itEV1EW ment Program, was responsib!c for [ reparing the docu-ments. Subcontractors to !!G&G included libasco Serv-i es incorporated, the preparer of the l'MCit PLASAR, The N RC staff foc used its review on the design, construc-and Rogers and Associates lingineeri7g Corporation, the tion, and operational aspects of the 11G'/ PLASAR, as preparer of the llGV PI ASAR, The NRC staffs review had been agreed to with DGli during the car!y stages of comments and questions contained in this volume of the PLASAR development. The NRC staff thus did not NUREG-1375adJress the reviewof the llGV PLASAR. review all the sections in the llGV PI ASAR, The sec-

'lhe results of the NRC staffs review of the !!MCH tions that it reviewed and for which it developed review PI ALAR were pubhshed in Volume i of NURl!G-1375 comments and questions included Chapters 3, " Design in July 1989, and Construction"; 4, " Facility Operations"; S, " Site Clo-sure Plan and institutional Controls"; 6, " Safety Assew ment"; and 7. "Gecupational Radiation Protection."

The two PLASARs were prepared as part of IXTl!N Sevetal significant difierences between the development Technical Assistance Program to States and Compacts, under the low l.evel Radioactive Waste Policy Amend-of the liMCil Pl ASAR and the llGV PI ASAR influ.

ments Act of 1985. Both PI ASARs follow the format enced the focus of the staff's review of these documents provided in NRC regulatory guidance documents: (l)

For example, in the llGV PI ASAR certain specific re-NURliG-1199," Standard I ormat and Content [SF&Cl view topics (whh caution statements) that the NRC stalf q

of a 1.icense Apphcation for a Inw-l evel Radioactive was expected to address in its icview comments were Waste Disposal Facility-Safety Analysis Report"(Rev.

highlighted. In addition, unlike the liMCll Pl AS AR, the 1), and p) NURiiG-1200, " Standard Review Plan [SRPl MARRiliR computer code was used to assess t'ie long-for ae Review of a 1.icense Application for a Inw-Level term performance of the conerete vaults under the condt-tions assumed for the HGV subsurface environment.

Radioactive Waste Disposal Facility-Safety Analysis Report" (Rev.1).

This resulted in a number of very detailed comments on potential degradation mechanisms for concrete strue-tures (Comments 60 through 70). To obtain the most The primary obje<..ive of the staff's review of the benefit from the staff s review comments and questions, PLASARs was to proCde assistance to the States and re-they should be read along with the appropriale sections o' gional Compacts by (1) iaentifying acceptable and urac-the HGV Pl ASAR and SRP.

eeptable alternative design features and (2) demonstrat-ing the staff's use of the S!!P. Tne review of the The staffs attempts to respond to the topics (noted PLAS ARs also provided valuable licensing experience to abo,e) for which a comment was specifically desired by the staff and enabled weaknesses in the SRP to be identi-the DOli contractor, in sme cass s, resulted in htng and fied. In recognition of those weaknesses, the NRC staffis detailed comments. In an actual license application revising both the SRI and SF&C to improve its regula-review, these comments would be addressed by infarmal tory guidance, particularly in t he areas of performance as, interactions such as meetings and telecommunications sessment and occupational radiation protection.

between the NRC staff and the apphcant. Iack of mtcrac-tion with an applicant and elimination of the iterative i

NURiiG-1375 Vol. 2 I

.n 1,

l

}

they wilipertorm as intended. 'lhis information has process, during which two or more formal rounds of ques-not been provided in the PLAS AR for the traterials tions would typically be asked to resolve open issues, re-to be placed in the disposal umt cover or for the ma-suited n more detailed comments than would be made in terials to be used to form the moistute turrier. l'or the review of an actual safety analysis report (S AR) sub-example, descripuve mformation on the sod matcri-mitted wnh an application to license a low-levcl radioac-als propo>ed for the ws er system (e.g., sanJs, clays, tive waste dasjusal facdity. This ef fort to provide detailed grawls) would need to be provided m an actual li-comments was made by the NRC in the hope of offenng cense application mcluding (1)id..unca on of the n

the greatest assistance to the potential users of this docu. source locations of the proposed material, sup-ment.These detailed comments are included to assist fa-ported by results from explorations and field and cihty developers and State regulators in recogni/;ng is-laboratory testing; (2) the adopted engineering sues that shoald 13e addressed in an appheation for a properties and the basis for sclection; and (3) the lowJevel radioactive waste disposal facihty using enri-specibe construction methods and techniques to be neered concrete structures anu barriers.

used in the placement of these materials. l'or other proposed materials (e7., fledble membranes), in-The stalf of the Dividon of low-Level Waste Manage-formation on the manufacturer, the specific mate.

ment and Decommissioning deseloped the HGV rial type, the properties, the test methods to be fol-Pl.ASAR revivw comments and questions with the assis-hnved to demonstrc.te acceptable material tance in speciali/ed technical areas of NRC consultants, properties, and the construcuun methods to be used including the U.S. Army Corps of Engineers (COE), the for ir stallation would need to be provided, llrookhaven National 1.aboratory (IINii), Sandia Na-tional I aboratories (SNI.), and the Natienal institute of The supportmg basis.n the PLAS AR for the ap-Standards and Technology (NIST) proach used to mmimi/c water infiltration is unclear

'"

• h " * *"'" "d"P"Y" "I " " """"' " "} ~

DESIGN AND CONSTRUCTION:

draube conductivity de.ugn value for the clay mate-rial that is to be placed in the cover system over the 3

C,omment 1: Sect.mn 3.1 (p. 3-2)

Chss A vaults in comparison to the more conserva-tive hydraulic conductivity chosen for the clay over The'lype i and Type 2 drainage ditches (pp. 3-2 and the Class II/C vaults is questionable. This design ap-3-18)at the perimeter of the Chss A and Class H/C proach is questionable because 10 C17R 61.51(a)(4)

(a) vaults, respectively, are to be locateJ at the top of requires that covers over all classes of waste be de-the slope for the excavations of the vaults.This pro.

signed to mimmi/c water infdtration to the extent pracucable.

Iloth the provisions of 10 ClR posed locanon could allow large amounts of surface water runoff to cc' lect and flow ah,ag the plane of 61.51(a)(4) and the performance objectise (10 0FR the excavated slope. This condiuon should be 61.44) on long-term stability would encourage the avoided. One way te address this condiuon would he attainment of the more conservative, but reasonably tolaterally exten[l the h> cation of the ditchesbevond attainable, hydraulic conductivity for cmers over all I

the excavated slope mio the undisturbed soils and elasses of waste. Unless an adequate supporting ba-covering the excavated slope area with a low _

sis for the approach used in the Pl.AS AR were pro-f,crmeability clay coser material,1 inure 2.8.1 of vided m an actuallicense application, the staff would NUlWG/CR,-5041, Volume 2, provid'es a sectional not find the adoption of the less consersative hy-vie'v showing a preferable location for the drainate draulic conductivity design value acceptable.

Many of the quesuons and concerns relate 1 to the ditches.

(b) The description of the interim and final cover sys.

proper selection, placement, compaction, testing, tems on p. 3-2 of the PLASAR refers to a 3-foot and acceptance of soil materials proposed to be layer of clay with permeabilities not greater than placed in disposal end covers are addressed m to the 10A cm'sec and 103 cm/sec for Class A and Class NUREGICR-5432, " Recommendations blC vaults, respectively. Other materials and their NRC for Soil Coser Systems Over Uranium Mill thicknesses are also identified, but only in general Tailings and Low I evel Radioactive Wastes." This terms The matenals proposed for costruction repwt was publisheJ (February 1491) since the sub-need to be sufheiently ocseribed in an actual heense mittal of the HGV Pl.ASAR in 19%

application to provide reasonable confidence that The PLASAR's desenpuon of the design features (c) that are intended to mimmi/c infdtrauon does not reference specific drawings (e.g., Sheet 4 of 13 in

• Preparea by heph Kane. nim md er anetr (secnon 1h H*rishewmaker, semm stnicnual engne ise Appendix B) for either the surface water drainare uein widmayer, tnd egneer. sna >rryJohason. scnq y tace

{ r the reinfoiced cone ete disposal vaults vater h andet &chon 3 4x hyh g comments trom ( ot ard o.maa apnnaun poiechmcar enanter 2

MUREG-1375, Vol. ?

w (e.g., the construction and expansion joints on w di eventually he removed and replaced with drain-Sheets 2,3, and 6 of 13). These omissions make it age layer matenals duting placement of the final dJficult to understand how these features contrib-cover 'he portion of the irtenm cover that includes ute to f ulfilling the functional requiremem for mini-thei extde fabric and the materials beneath it is miting infiltration. A safety analysis report (SAR) to tuuain in place and be a part of the final cover.

for an actual license application would be signifi-Removing the entire natise soil layer to expose the cantly improved if it referenced pertinent drawings geotextile fabtic could be a difficult operation that and detail views.

could result in ripping or damagmg the geotextdc membranc. To avoid this potential damage to the Ctm1 ment 2: Sections 3.1 (p. 3-4) aini 3.1.4 geotextile, a layer of sand could be placed over the (p. 3-16) feotextile fabric so that the sand lay er may be lef t in place and all native sods in the interim cover above (a) In an actual license application, an apphcant should the sand layer could be re moved dunng construction describe in sufficient detail the m'terials, procc-of the final cover, dures, and controls needed to ensure the attainment of important properties for the materials to be Comment 3: Sections 3.1 (p. 3-5),3.1.2 placed in the disposal unit cover. As an example of a (p. 3-1l), and 3.1.3 (p. 3-14) control that could be improved, establishmg a mini-(a) In the discussions on structumt m.tegnty, neither the mum plasticity index of 18 for the clav barrier mate.

type of backfill nor its engineering properties or the rial (Table A5-2 in Appendix A of'the Pl.ASAR) comrols to be requ red in field placement (e.g., den-will not, in and ofitself, adequately ensure a desired fities, moisture content) for the backfdl to be plarc d level of impermeabihty or engineering properties of between and around the Class A vaults are de-the clay material. Comment 1(b) describes the type senbed. In addition. the structural fdl beneath the of info'rmation that would be needed for soil materi_

cencrete mat foundations of the Chss A vaults als proposed for placement in the cover nstem. Ad, needs tc be better desenbed (classification, prada-

~

ditionally, uescribing geosynthetic materials as im-tion linuts, and field placement contr ols on densit;es permeable membrancs or geotextile fabrics is not and moisture).

sufficiently detailed or quahtative to provide reason-able arsurance that these matcaals will perform as (b) It is not clear from the desenption of the construc-intended.

tion sequence in Section 3.12, nor from the notes at the bottom of Sheet 9 of 13 (Appendix 11). whether It appears nom the discussions in Section A5A of the entire reinforced concrete mat foundation for Appendh A that fac cover materials are to be de-the Class A vault will be constructed at one time, or signed and ungruevd under a quality assurance if each of the mats for the five structural!y independ-progrnm that remains to be developed. Typically, ent groups will be indn idually constructed. A clarifi-this i Jommon would be provided in the S AR.

cation and possibly a change'to the notes on Sheet 9 would be needed m an actuai license application.

(b) Section il A O.# IM of the Pl.AS AR indicates that the canhm irnr.m uvet wdl be placed as soon as (c) In an actual license application, the details for splie-pessible, but wi hin ? prs after the vault roofs bas e ing the polyethylene memhrancs (p. 3-17) in the t

i M n cons'ructed fn the Class A vaults.and v uhin 1 moisture barrier would need to be provided.

yNr atter um roofs have been cmnpleted oser the Chss !!iC uttits (d) The Pl.ASAR provides caution statements (pp.

3-12 and 3-15) for both Class A and Class ll/C

'IW docass on raises several questions that include vault <, indicating that because of the PLASAR's the W.lowag (i) What is the maximum time that will more extensive consideration of the need for water-be perrmited m elapse after filling, but before the Jghtness and long term durability, the vault's design s ault roofs are constructed? (ii) What constitutes the in the PLAS AR may be more conservative than that temporary weather shitiding (refer to Sheet S of 13 required by NRC's guidance documents. The staff of Appendix 11 and pp. 3-5, 3-11, and 3-34)1 (iii) agrees that the PLAS AR proposes the use of some Specifically how will the surface drainage be con.

design features that are more conservative than trolled durmg the period when the temporary those suggested by regulatory guidance documents weather shieldingis being used, up to the time that it (e.g., multilayered waterproofing for Class H!C will take for completing the interim cover?

vaults, more detailed cover cystem, and a more elaborate int"rnal vault drainage system). However, (c) The upper portion of the interim cover is to consist the Pl.ASAR does propose certain design features of native soile (2 feet. 8 inches thick) that are to be (e.g, the tse of Type Il cement instead of Type V placed over the geotextile fabric. The native soils and the design of the Class A vaults using American 3

N U RIE 1375. Vol. 2

l l

Concrete Institute (ACl) 318 rather than ACI 349)

The description of the drainage materials in tie per-that are less conservaCre than those suggested by colating water drainage sptem is insufficient, even NRC's guidance dmuments. The staffs comments allowing for the discussions in Chapter 115 of Ap-address the arer., where the Pl ASAR proposes less pendix 11 on this topic. Similar to the staff's Com-conservative enteria than those suggested by regula-ment 1(b), the information in an actual license appli-tery guidance documents. The staf f has not com.

cation should suff ciently describe the proposed mented on the areas where the Pl AS Ak proposes a construction materials to permit having reasonable more conservative design and leaves this decision to

<:onfidence in their performance. In addition to de-the individual designers. The staff has evaluated scribing the si/cr and the quality of the drainape ma-proposed design features that go beyond NltC's tetials, tl.e results of the fdter design shouk' be pm-guidance documents to ensure that the capabi!ity of vided. Potential clogging of drainage materials the feature to meet the regulatory requirements will resulting from the presence of suspended solids in not be adversely affected, any collected leachate. coupled with the growth of anaerobic bacteria, should also be addressed. 'lhis (c) Detail 11 for the vault roof settlement momtor on clogging phenomenoa is not well understood, but is a

Sheet 5 of 13 (Appendix B) shows an 8-inch-being obsened at waste disposal facilities even diameter concrete pipe extending from the vault where the drainare ma:erials were properly de-roof up through the cover layer to a level just almve signed to meet specified filter criteria.

the fmished grade. The detail for the waterstop in the clay layer on Sheet 5 shows a 1/2-inch thick (lc) llecause of the inconsistencies in the description of polyvinylchloride (PVC) seepage collar around w hat the permeable layer in the percolating water drain, appears to be a 6 inch-diameter PVC pipe,In an ae.

age system,it is unce rtain what constitutes this layer, tual license app!ication review, the inconsistencies

! or exampic, Section 3.1.6 refers to a fine gravel between the types of pipe mateiials and diameters layer on top of the vault roof. The continuation of for the pipe penetrating the cover layer would need this layer on Sheet 5 of 13 in AppenJix 11 for the cell to be resolved.

drainage detail (F)is identified as a 2-foot-thick s;md layer, whereas the cover system detail on Sheet 3 of (f) The terms "senice life" (p. 3-5) and "hfe expec.

13 identifies this layer as sand or fine gravel. This in-tancy"(p. 3-6)in the Pl.AS AR need to be better de.

consistency, which stems from the lack of specificity fined Does " service life" refer to a penod of time m descriptions of materials previously iJentified in when reasonable assurance exists regarding the safe Comment 1, would need to be resohed, performance of a structure or component as de-signed, and does " life expectancy" refer to a perial W The " drainage detail in low er end" that is aJiacent to S&Wn A-A on Sheet 3 01 13 for the Class ll/C of time over which the structure or component is hkely to perform, based on judgment, but the exis-vauhnhows that thnollection pipe is hicated in the tence of this period cannot be stated to provide rea, 4mch4 hick gravellayer that is on the topof the sub-sonable assurance? In an actuallicense application, gmde below the vault footing. Is this the intended 10-this would need to be clarified.

cation or would it be beneficial to place the pipe in the grrel ' train adjoining the structural fill beneath the fouiWation, that it at a hwation sinular to that of Comment 4: Sections 3.i (p,3-5) aml 3.1.6 ine French drain?

3 Duat precipitation into the open excavations for (a) It is not clear from the infornntion in Pl.AS All Sec-t hposal unit vaults can be expected, in an actual tion 3.1 whether temporary shieldine will be re.

nw appheanen, opembons for safely h mdling quired during the we nlaecment bperations in the mynted drainage (e.g., pumping) and f;or test-Class A disposal units.. an actual license applica-ing ana possibly treating the collected flows would lica, this would need to be clanfied, along with the need to be described.

coord; nation of this information with the details shown on Shcet 8 of 13 in Appendix il, relative to the Comment 5: Section 3.1 (p. 3-8) use of temporary weather shicidm.p, It is estimated that the vertical permeabilities are 1 m/yr (b) 'l ne information in Section 3.1.6 on the percolating and 3 m/yr in the native matenals and aquifer, respec-water dr,sinage system appears to mclude the can-tively, in the buffer zone area. The value of I m/yr cone-servative assumption that no credit is taken for the sponds to 3x IO S cm/see, which is considerably lower than moisture barners in minimi/ing water mfiltration the values given in Chapter 2 for the native materials into the disposal vaults.The reasons for this assump-from the permeabihty tests.The Pl ASAll is not clear on tion and its rationale would have to be provided in an how the estimated permeability values in Chapter 3 were actual license apphcation.

denved. In addition, it is not clear whether the values NUlt!!G-1375, Vol. 2 4

1 1

i

given m Chapter 2 are intended to represent horizontal or age system and procedures for acceptable resolution vertical or avuage permeability values. In an actual li-of NRC staff review concerns are given in Comment cense application, this concern would nced to be ad-

71. In keeping with Ihe concerns addres$cd in Com-dressed and an effective vertical coefficient of permeabil-ment 71, the staff would prefei thet the design of the ity calculated for the multi-layered condition.

drainage system durmg the operational period cor-respond with the design that would be used follow.

Comment 6: Section 3.1.5 (p. 3-19) ing site closure.)

(p The PLASAR indicates that the value for the (d) The Pl ASAlt indicates that the drainage ditches 100-year,6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> rainfall is 26 inches. This value is might become clogged after the closure period and more representative of the Probable Maximum Pre.

that the resulting infiltration rates could increase.

cipitation (PMP).1lowever, the calculated value of The statement i1 the Pl.ASAll that no problems rainfall intensity of 26 divided by 6 is not as great as would result from such conditions has not been ade-the actual 100ccar tainfallintensity for several min-quately justified. Since credit cannot be given for utes. This is not the correct method for determining maintenance following closure, it appears that sig-the rainfall intensity for short times of concentra-nificant increases in infiltration rates could occur.

tion. 'lhe correct method is t o determine the rainfall Additional information and analyses would need to associated with the time of toncentra, ion and to be provided in an actual license application to justify then compute the rainfall intensity associated with the position that no prob! cms would ensue following the time of concentration. Appropriate revisions blockage of the ditches. Detailed analyses of runoff would need to be made in an actual license applica.

patterns, flow rates, infiltration rates, degree of tion to refleu the proper rainfal and rainfallinten-diten blockage, and t.o forth, wouki need to be pro-sity, Various publications of the National Weather vided to demonstrate that blockage will not be a Service are av'ilable to determme these rainfall problem. Comment 71(a) provides additional infor-amounts and intemitics, mation and discussion of acceptable resolution pro-cedures for justifying floods less than the PMF. Ad-(b) The Pl.AS AR indicates that the surface water draim ditional discussion, comments, and acceptable age system has been designed for an occurrence of reso'ution procedures regarding long term stabihty the 100-year,6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> rainfall event. On the basis of and f he need for designing for no maintenance me the staff's review, it appeats that the peak rut.off also given in Comment 71.

rate has not been properly calcula*ed and, as noted in Comment 6(a), the valuc of the 100.) ear event is

@) A 6-inch-t hick !ayer of riprap is spec 4d asa protec-U"' hner for the surface drainap ( Mes. It is un-not correct, Additionally, the staff questions the use

. lear from Oc mformanon in the Pl AS Albhether of such an event to ensure ades -te protection and the design of the protective liner includes a filter has recommended in Sumdard 1(eview Plan (SRP) layer to protect the unJerlying soil from erosion and 3.2 that the design-basis hydrologic esent be the piping. In an actual licciue application review, the PMP for abnormalconditions. On the basis of a re-st ff would need to evaluate tuis concern regarding view of the information in Appendix fi(p.14113),it protection of the derlying soil and possible need also appears that the rainfall has not been properly I"I"fillCI distributed within the 6-hour period.The design of the ditches may need to be resised to accon.modate

(?ommer

' Section 3.2,1 (p. 3-23) the larget ilo.vs that would be computed using the correct method.

(a) Tables 3.2-1 thtcupb.O-6 in the pl.AS AR rumma-rize the design crite!ia < hat were selected for the de-(c) In the PLASAR, a flood less than the Proluble sign of the principal design features.The staff con-Maximum Flood (PMF)is proposed for the design of siders that the summary of the de,ign criteria in the drainage features, whereas SRP 3.2 indicates that tables wil; be very helpful in the saf ety resiew of an the PMF provides an acceptable design basis durmg actual license application. Ilowever, it is not clear the operatmnal period. Although use of the PMP is why the design criteria in the tables of Section 3.2.1 not a requirement, the use of lesse: floods would are differ en' trom those in simila iles in Chapter need to be justified, in light of the risks of surface A5. These differences are icvealco by comparing water r moff imo the excavated areas daring the op-the tables giving the design critena for disposal unit cratmnal period. Accordingly, an actual license up-covet systems (Table 3.2-3, p. 3-E, against Table phcation would need to include justification for use AS-2, p. A-65). In an actual license application re-of floods sn. aller than the PMF, or alternatively, the view, the staff would ask for a clarification of these drainage system would need to be designed to ac-differences in the tables, and also look for expanded commodate the PMF peak flow rate. (Additional discussions m Section 3.2 that would cicarly describe comments regarding the adequacy of the site drain-the signific:mcc of, and relationship Setween, the 5

NllitlE1375, Vol 2

4 l

4 design criteric that are selected to help ensure the er or barrier system. It also found no information re-performance objectives in 10 CM( Part 61, Subpart garding an estimated degradation rate for the per-C, are met.

manent boundary mrkers that are to be made of an 8-inch-diameter granite cylinder,2 feet long, set into (b) The PLASAR contains references to the Uniform concrete with 1 foot embedment An actual license Building cme (UBC) in various locations such as application should provide desigt. -iteria that would Table AS-1(p. A-57)in regard to seismic design cri-identify the bounding or potential range of degrada.

teri: However, it does not reference the specific tion rates for the intruder barrier and markers as sections of the UBC document that are to be used.

suggested by SRP 3.2, with information to support In addition, the UBC and the ACI codes are not nec.

the bases for the adopted design criteria. If the sup-essarily identical in all arcas and, as a result, conflicts poning basis for the criteria is to be provided with may arise regarding which code governs. In an actual information from ciicd references, the appropriate license application, the SAR should indicate which sections and pages of the cited references sh Juld be provisions of the referenced documents were used, given in the license application, if the entire document does not apply.

O,., men 18: Seetion 3.2.2 (p. 3-32)

(c) Table 3.2-5 (p. 3-30) provides the design criteria and design conditions for one of the principal design (a) Chapter A5 of the PLAS AR provides the structural features of the f acility, that is, the percolating water design criteria and is referenced m Section 3.2.2, dramage system.This table is not consistent with Ta-Section A5.2.2," Design Criteria," referencesTable 4

ble 3.1-1 (p. 3-3) which identifies the four required A5-1 as providing the summarized design criteria functions that are to be addressed by this principal for Class A vaults. Table A5-1 provides a listing of design feature, Table 3.2-5 identifies only one of the magnitude of the various types of loads within the four required functions and omits si:e drainage, the various load categories, such as dead load and long-term maintenance, and site r:onitoring. For live load. Section 4.3.1 and Sheet 8 of 13 in' Appen-i completeness in enveloping the design criteria for dix B indicate that a gantty trane will be used to han-the principa'. design features. Table 3.2-5 woubl re-die waste packages for offloading from a carrier ve-quire revisions to acceptably cover all the functional hicle and to place the waste pachages in the vau;ts.

requirements that would need to be addressed b".

this principal desQq feature in an actual license ap It is not clear from the information in the above-plicadon.

cited sections of the Pl.AS AR 1 hat the loading from the pantry crane has been considered in the various (d) Tabic 3.2-4 (p. 3-29) identifies the design criterion contributions to the live loads for which the vaults for the surface water drainage system to be either must be designed. In addition to the stresses arising the 100-year,6-hour rainfall event or the PMP. Tlw fro n the gantiy crane loading, consideration shoald staff's concern abv ske adequacy of the selected be given to the resulting deflections and rotations design criterion for (

evere stona is stated in experienced by the vauP walls and construction Comment 6(c), and the 4T comments related to joints such as those kicated at the wall-base slab in-the PLASAR's analyses o. infiltration are provided terface. It is also not clear whether any impact load-in Comment 47.

ing has been considered for the placement of waste packages on the base slab ot the placement of tne During printing of the PLASAR, pmtions of the ia.

temporary precast shielding panels on the vault tended information in Table 3.2.4 were obliterated, walls. These conditions represent actual loads that To folly understand the intended information, a would occur and, therefore. should be included in compicie, clearer n.ble would need to be provided.

the design.

(c) The functional design requiremnt for the inadver-In an actual license application review, the staff l

tent intruder barrier for the Class B/C vault is briefly would ask the applicant to list these loadings and described in Section A5.3.1 (p. A-61); the details of magnitudes or to provide an explanation that dem-the physical design criteria are obscured in the strue, onstrates how these magnitudes are encompassed by tural design criteria of Section 132.4 (p. F-60). AdJi-other values and that the logical load combinations tional information en intruder protection is pro-have been adequately addressed.

vided in Section 6.2 (p. 6-59).

/

E (b) The same comments as those above appiy to the in its review of the PLASAR, the staff fodpd no in-Class H/C vaults with regard to the truck-mounted formation that would give a range of or bounding boom crane. Sections A5.3.2 and 4.3.2 are the rele-limits to the degracation rates for the intruder barri-vant PLASAR sections for the Class BiC vaults.

4 NURiiG-1375, Vo. 2 6

r t

I (c) Section A5.33 (p. A-62) providcs the hudmg com-t ecommend the use of ACI 349-85. Using a less con-binations for the Class ll/C nmh structure. Two of servative design approach for Class A vaults in com-the load combinations omit the loads due to the parison to that used for the design of Class ll/C pressure ofinciJentalliqu due.g., water pressurcs),

vault < not consistent with as low as is reasonably whereas the two initial load combinations aHow for achevaule (A1. ARA) principles. Nor is a less con-consideration of lignid pressures. In an actual li-servative approach considered advisable in recogni-cense application, the reason for this inconsistency t on of the performance objective in 10 CI~It 61.44, i

would need to be explained, which regmres the achievement of long term stabil-ity for the overall disposal facility.

The stalf noted that, in the Pl.AS AR defmition el the term "17," which reprexnt s the incidental liquiJ Although departures from the SRP guidance on hud, the "F" load is assumed to be /cro, since the loamng combinations are possible, it is the responsi-vault structure is, according to 10 CI:R 61,50(a)(7) bihty of an appheant to provide justification why its requirements, to be sited above the water table.

alternative proposed enteria should be adopted. No Section 3.2.1 of SRP 3.2A indicates that this "F" jusufication for the deviation was found in Section load was included to provide for engmeering conser.

A5.2.3 of the Pl ASAR and would need to be pro-vatism in design, even though it is anticipated that vided in an actual bcense apphcation.

liquid pressures may not develop. The intent of this design conservatisr5 was to provide a safety margin (f) The Pl.ASAR states that for regulations and design in the unlikelv event that percolatingwater would be codes, the latest revision of the standards shall be retained in th'e pervious granular backfill outside the used. Iiowever, the latest edition of ACI 349 was vault walls. Possibly becau;: of a reducuon in the not used in the design of the reinforced concrete str uct er os.

long-term effectiveness of the subsurface drainage s3 stem. In an acMIlicense appbcanon review, the s'taff would ask the applicant to provide the basis for ACI 349 is listed on p. A-1! as the document that rejectmg the recommended conservatism of allow, wdl be used, as modihed by NURiiG/CR-5041. In NURl:G/CR.-5041, Volume 1, p. 2.1-1, ACI ing for the Uquid pre.ssure buildup.

34485 is cited as an appropriate applicable code.

(d) Tab!c A5-1 (p. A-57) provides the Class A lateral U". PP A

, li-60, and li-135 of the Pl.ASAR, 1

AU 349-80 is cited as the basis for design. In an ac-load magmtudes for sescral load sources. The lat-taal enw appucation, cither the 1985 edition of eral load for waste and backfill within a cell acting on AG a mm et dion vouM be opnkd a rigid wa:1 is an equhalent liquid density of 45 to be used in the design of reinf orced concrete waste pounds per cubic foot (pcO. For a lateral load acting d'3P"""I Slf"'l"I'h' on a wall that is considered to be flexible, the equiva-len /alue shown in Table A5-1 is 30 pcf. These (g) In the description of the coues, standards. and regu-egmvalent loadings appear low and may be uncon-latog gWance in Appendix A (p A-1i), Applied servative and not large enough to represent the ac-

.i echnology Councd,s A,1( 3-06, " Tentative Provi-tuallateralloads. Additionm information would be Mons for the Development of Seismic Regulations necessary to support these equivalent loadings, in.

f or lluildings, 1978 is not addressed. It is not clear ciudine identification of the adopted bacWll soil and whether ATlrO6 was mtentionally omitted be-waste inaterial engineering properties.

cause the Uniform liuilding Lode was substituted in (c) Section A5.2.3 (p. A40) provides the loading com-Sinations for the Class A vault structure, which are The ATC document, as indicated in SRP 3.2A (p.

based on ACI 318-83, ligaations 9-2,9-4,9-5, and 3.2 A-3), is one of five documents considered apph-9-6. These basic loadmg equation combinations are cable for the structural design of a llGV. In an actual 5

then used, for example,in the design of the Class A license application, the applicant shsutd indicate HGV roof slab as indicated in Tables 111-1 through whether the provisions of recommc nded codes were lil-9 (pp. li-lb to li-27). Scction A5.3.3 (p. A-62) used and should identify the specific provisions that provides the loading combmations for the Class ll/C were used. If the recommended code or standard vault structure, which are generally based on the was not used, the applicant should explam why.

guidance provided in SRP 3.2A as the regulatory evaluation criteria.

(h) 'lhe Pl.ASAR (p. A-14) indicates that the applica-ble standarda of the American Water Works Asso-The structural design philosophy adopted for the ciation (AWWA) wdl be used. Ilowever,it does not Class A vaults is not consistent with the regulatory indicate what subject mat;er or specine standards of guidance and evaluation entena in SRP 3.2 A, which the AWWA are intended for use. An actuallicense 7

NURl!G-1375, Vol. 2

l l

application would need to desenbe the speafic pro.

Class 11 creater than 1500 ppm, visions of the AWWA standard that were used.

but less than 10,lHHI ppui Class A greater than 10,000 ppm (i).lhe Pl.ASAlt,in aJJressing seismic loads, m. dicates that the magnitude of the lateralloads from seisnue These clawes are used to defmt the type of cemen-loading is determined by the product of the lateral titious materials that should be used in a concrete acceleration and the sum of the weight of the w; dis mit The l' ort Collins and Greeley, Colorado at cas and the lateral soil pr essure This analytical method base values of 15,000 ppm for suHates, as an exam-d is a pseudo-static load method that is used to simu-I e.

late seismic loadmg. Powble dynanne c!fects of Ihe surrounding soil on th dynamic :esponse n' the in an auual hcense apphcation, the stalf would look vault are not reahstically considered when tlus for further danhcation on the proper characteriza-method is used.

tion of the conditions of a project site, m order to clawfy the sulfate enuronment.

SRP 2.3.2 panides the puiJance for estabhshmg the (k) in Section lil.4," Structural Design" (p. IF12), the vibratory ground motion of the design earthquake.

A suitable dynamic analysis method shonld be used uruduia! analym of On: v,mit ool (p. Ibl3)is dis-enciin a sub,ce' on, the structural analysis of the that considits this s ibratory motion and the dynamic exterior waHs ([t 1. -15) is adJtessed. Another sub-response of the vault, the soil, and the inttraction sedion, "Structucal Analysis of Interior Walls, is between them when loadmps are defmed if a dv.

nanne appnm h is not used, an equivalent static lo$d pniuded on jupe F M method may be acceptable; howevei, justification is I"

"INC *"

U" necessary to demonstiate that the structme anJ its tund an ym of nh'nor wA, h su udural surrounding media have been renhsticalb teive-

~

anahm p wp

.w h cab for conWasn of sented in the equis alent static method, su as to esult Mo YJpp9d WDOons, U (ntudud % onh one in conservative results, in some situation *, where suppon mn on n ntWd the dyn.unie effects have tan been propeoy consid-cred, the resulting load amphhcation due to uhra-it is apparent that ten t, nussmg m tne dncussions lor) mouon inay be underestimattd. 'I he seismic on h inuim w dNesp No adu d hmnse apph-loads m design should be based on a suitable utio 4 review. the Paff would ask tue applicant to dynamic analysis, as jeconunended in NURI G/

proside the missmg text and examine it to be certain CR-501I O/ol,1, p. 254k or justifkation should be hddre ;ses the detailed issues that anse m the strue-provided :,o that the stah can assess the adequacy of

. d modchng and analysis.1-or exa.aple, what is the cquivalent static methou of analysis' the impact on the analys'is if the verocal expansion jomt or an adjacent wall proviJes no support? Such (j) In the Pl.ASAR, two values for sulfate concentra' n

Mn h MW W N SRP 3M m Section tions in the rround water arc used. A sulfate concen-3g 33g..;)cs;rn' and Analy'ical Procc-tration of 3tH) parts per million(ppm)(p in 28)is the dures7 which notes that the design awumptions, in-assuraed value assocu3d wah the hypotheoca site duding the boundary condiuons and the bases for conditions. A value o! 1000 ppm is characten/ed as the adumption, should be prouded.

a high sulfate enuronment in Volume lit ol the Pl.ASAR (Chapter 4).

p g gi,,3?,,g 9; gggg;g3, 3,3, g g p, 3_33)

!!ven assuming that the anaiysis for sultate attack (a) The Pl.AS AR (p. 3 -32) states that the site prepara-completed for the PI ASAH is correct, the staff does tion cons:derahons woulJ be mmunal because of the not contider that the value of 1000 ppm signifi ; a sne characterisua high sulfate environment, so that results frori such an analysis do not defn-e behanor in hwh sulfate co-Ihe procedtu es that would be followed to backhlt viron ments, and seal any existing wel;s or exploratory boreholes are nat mentione,' Adequate seahng of any pene-Au example of the range of a"tual values that may he uanons into and thiough the lower 1htrot aquitard ent;ountered in the field is mm e clemly diustrard by would hase to be accomphshed and conuolled to the values reflected m a U.S. liureau of Recl'ma-protect the major Gamma IWmat on aquifen tion document (1975) used for underground dram systems 'lbree classes of envuomnent are estab-(h) I he Pl.AS AR (p 3 -32) mthe-acs that surlace water lished on the basis of sulfate content.

drainare mto the excavations for the vaults is imni-mi/ed by lasorable sitmg. It is not clear to wh it ex-Cla w C less than 1300 ppm tent the weather shtcld will proude coser to pt event NURiiG 1375, Vol. 2 K

M

~ '

.s y

'9

the precipitahon from falhng directly into the exca-tions of the effects of sulfate attack do not reflect a vations. In an actual license application, a clearer difference bet.ccen the performanec of aType li ce-and expanded discuwion on handling surface runoH ment (with ut additnes) vault and tlut of a Type V and direct precipitation into the excavations for the cement vault.

vaults would need to be provided.

(d) Sheet 7 of 13 in Appendix 11of the Pl ASAlt,which (c) Section 3.3.1,in the discuwion of the concrete con-apphes to the Chiss ll/C vault, specifies epoxy, struction to be canied out, indicates, by referrmg to coated icinforcing steel in Note b on the drawing.

Appendix A, that Type 11 cement will be used for the Sheet 6 of 13 in Appendix 11, which applies to the Class A vault. This fact is noted on p. A-56 where Class A sault, does not contain such a specihcation.

the design cr.;cria are addressed (it is also reflected No ha :s for the differ ence is dkcusscd. atthough dc-on p. Ib12). Section A5.3.2(p. A-h2)indicatesType sign Jespans me different.

V, sulfate-resistant cement will be used for Class II/C vaults. In the discussion of degradation in Chap-SRP 3.3 A, in providmg gmdance on construction

/

ter 4 of Volume ill of the Pl.ASAR, it is noted that, materi.us, reconunends the use of epos) coated re-in this protol) pc study situation, sulfate attack is the inforcing steel in engineered belowground situc-2 primary mechanism by which the concrete degrades tures to estend the structoies' ahdity to resist corro-and loses strength. 'Ihe lonycterm behavior of the sion by many scars, vau!ts under the by pothetical subsurface conditions was investigated using calculations in w hich two dif-

'lhe rationale for omittuy'. the epos). coated rein-lerent concentrations of sulfate ions were tued A forcing steel in the Clavs A vault would need to be summary of the rmuhs of these calculations for the provided m an actual license appFration in recogni.

Claw A and the ass ll!C vaults for the two sulfate tion of the long penod of perfor mance that would be concentrations i~ presented in Tables 4-4 through expected of the Class A vault.

4-7 of Volume lli of the Pl.ASAR.

(c) Sheet 6 of 13 m Appenda 11 provides the typical ex-The Class A vault is defmed in the Pl.AS AR as hav-pansion jomt detad, which apphes is both the Claw ing a postulated fadme time (design service hfe) of A and the Class ll/C vaults, escepi for the number of 200 yeat s that, on the basis of the techniques used m I ta, layers and the use of waterpioof membrane cr the Pl ASAR,is predicted to actually be 1220 years la,ers. A 1/2. inch wide expansion jomt is shown; the for the specific adopted conditions. In the case of space n hiled with a lomt Idler, and the jomt is the Class II/C vault, the tunes are 500 years for the scaled with a sealant across the adjacent faces of the design life and 1420 years for the predicted hic. Au concrete. The joint and the sealant are then covered examinatien of the data.n tb calculation summat) by the extenor sault surface waterpioohng mem-tables indicates that for the loss in tSickness of con-hiane, The walls of the ahu ting adjacent vaults are crete from sulfate attack, at concentrations of 306 not considered as esterior vault walls and are of re.

ppm, for the period from 100 years to 2000 years, duced thickness, and the adjacent vault walls are not there k no difference for either the Class A or the waterpt oofed.

Class 1./C losses. This is apparently t' e case even though the Class ll/C vault is constrooted of sulfate-The capabihty of the waterproof coating to mamtam resistant cement. The same holds true fo :ulfate as integrity across the 1/2-inch espansion joint, if concentrations af 1000 ppm. No explanation of this upnificant differentui mavement were to occur m discrepancy is provided in the presentation of these the joint, is not assessed and would need to be pro-results. In an actual hee se appheation review, the vided in an actual hcense appheation.1)esign infor-staff would ask the appitant for an explanation to mation for the joint. as well as the capabilities of the resolve this apparent Jiscrepancy.

matenals, would also need to be provioed.

SRP 3.3 AArough reference 1U Rl!G/CR-5041, comment 10: Section 3.3.1 (p. 3-33)

Voleme 1, mdicates Type V coacnt should he used or, alter natively,Ty pe 11 cement may be justified on (a) Shects 6 and 7 of 13 in Appenda 11 contain a note the basis of the use of additives such as whca fume or (Note 3) that mdaate s ihat the base mat, the pouolans that wolld provide comparatde s lfate extenor walls, and the root slahs would each he con-protection.

struct ed monolithicahy (without construction jomts). I he other drawmys m Appendn 11 appear to The PI AS AR shotdd have contained a rationale for conform to that concept El his means that the follow-the proposal to use Type 11 cement f or the (' lass A mg geometnes of reinforced concrete so uctural ele-vault, as well as an explanation as to why the calcula-ments would he cast rnonoitthically.

I 9

NtiRIE1375, Vol 2

I.lcment Class A huit Claw II/C Vault vauh wadi to evaluate design execution A calcula-tion of the percentage of stcci piovided in the hotb

/onW dunnon el an ruoi wJ 75 fe(I long liase Stab 73' x 78' Slab 31' x 75, mat x 3'T' x 31" yielded a valut of appiosimately 0.5 percent for the total steel. The 0.5 percent n the area of steel for ex-IWterior l'our walls of 1:our walls of ternal loadmg, as wcu as wl.at inay lutve been pro.

walls apprmurmtely apprmiumtely vided to take into acmunt internal cifects such as squate box 72' tectangulat box temperature ami shtmkage. Section A$.3.3 (p.

iM Mam dat %c naw K muhs dmu be 6

/

x p th I hx t Kk signed and mnsnuned io satisiy ine icquirements lhiof Flab 73' x 73' Slab 27' x 73' of ACI 3$013? 'liible 2.$.1 of ACI 350 43 mdicates x2 x 2'6" lint where the slucing ol joints eseceds $0 f eet, the

__._.__'2"---

nnonnom pcuentage of trintoumg taking into ae-muut thrinkage and teroperature shoukt be 0.6 per.

Monohthic otructural elements oi such w/c mn! pnb cent, which is gr cater than the total percentage lu o-portions present the nced f or specul mtraderation vided in the U(iV pl.ASAR dcugn. Ihn lower of several topics, such as the effects ol drymn shnnk-percentage rancs a question el whether slainkage age, the magnitude of tenute sues es created, and was considered ulevant to the praposed configura-shnnkage cracking. 'lhe lesel of tensile stiess is a tion of the Class It/(' vaults function of sesetal factors, mcludmp. the amount of shnnlage in the conesete, the degree of restramt of To mkhess tiu macun irganhng the development the structural element, the modulus of clasticity of of cratkmg tesultmg hom large monohthic place.

the concrete, and the creep oi the conercie. liath of inents, the considerahons that were made with re-these fattors is aho influenced by various parame-spect to AFI 350 83 piovnions would b nc to be dis-ters. l'or mstance, slainkage in the mucietc is mflu-cuwed and resobed m an actual hcense apphration, enced by the specific cement used, the specific type Although the dernion to place cat h of these thice of aggt egate, the aggregate u/c, the total volume of structural elements monohthically was likely diiven marse aggregate, the water content, the tempera-by the desire to nuninu/c mostinction joints, the tute of the phnlic concrete, the effect of chemical ptohlcms that c.m he awocuted with large tuono-adnmtmes, the cucct of po//olans, the M/e of the hihic placements would have to be hdly athhessed steuetural element, the duration of the cutmg. and and balanced against the posuble piohicms awoci-the consttaction ptactices toed.

ated with the natalianon of consuuction jomts at typically rccommended closes spacmgs (YmnataLL

't he pl.AS AR addicsses enn kmg caused by liesund p)S6).

and tensile sticsses in the reinforcing steci that anse t) Sheets 2 and 3 of 13 m Appendix il proude the de-fmm the cuernal loads and follows the cited prow h

nons of ACI 31S H3 and A('l 34% 50 (Sections tails of the plans and sect ons foi the s' lass A and lukt and 10.6S) that conaol the dntuhution of Claw II/r vaults. s cspecovely. These drawings mth-flexural reinfordng steel. For the internal muses of cate that the base slah of the vault wdl extend 2 feet crackmp, however, it is not clear that all potential or more beyond the outside senical fate of the vault phenomena have bc< = onsidered. I his would no walls. It is t ecogm/cd that a low-per meabihty mem-clude such items as iaternal temperature ciftets brane is caued foi to (met thn jomt, but cracks, from heat of hydmtion, shrmkage, and internal re-tears. or other unperfecuons in the membrane in straint.

thn area could allow entry of water into the vault, it is aho accorm/ed that Sheet 6 of 13 (Section 1 for

'Ibrough wall cracking in heavy concrete construc-the Claw A vault details), showmg the typical con-tion wheie the vanous elements are restrained has struction loint key detail at the wall to slab joint,in-occurred and can he piedicted.Tius type of cracking dicates that the ledge will base a concrete surface has occuncd before any signif cant extetnc.l loads with a 1-pescent slope away hom the jomt. A possi-were impmed on the elements. In one case, a slah ble alter natn e to this conhgurahon would bc to con-approxirnah h 6 1/2 f eet lluck, wah an approw struct the wall and stah with a contmuous vertical mately 5-foot.tinck wall cast about I month later on face that n finsh,to muunnie the possihdity of water the slah, exhibited throuph-wah ciacks of ponding on the estended ledge and serping unde 0.0010 -0 0013 inch, w hich wer e spat ed at 6 to 7 Icct, the wall within 6 days altci the wall was cast.

t he concer n n t hat, m constn ctmg the ledge -- even in reviewing the mformanon m the pl.ASAIL the with the lammble slope and esen wah the low-staf f perfonned a check evahulion of a (' lass 114' pcttucabiht'/ menibrane over the wall to the slah NilRIGl375, Vol. 2 10

4 nw

'O A 'as y;N, vh IMAGE EVAL.UATION

,;. 3y

((%g// 4,jle?,

/

f4

\\x \\

, T(.[ tjI$

TEST TARGET (MT-3) 2f Q

b, f,I n

nN,, qf g

N'\\#>@

44 49 4e 1.0 it W S e m gL2=n u

E N2 e '- {60 IaI t.

F l.8 I

l!. >===

1.25 I.4 p' i.6 d=

=

150mm 4

~*

4 6"

4$

/ S4'

,p p 3p% L _ -

.s ;m_A

,o y, xg'N 4

gy 9 ; v'

..y

h@ #<..

A

$g)A "A ks i, sv V IMAGE EVAL.UATION

/

/$$,,,y*6

'A

/

QII' TEST TARGET (MT-3) x\\\\///

f g,

//

/ P Yg W Qr $-

s 1.0 EB W m m nu i!W3s g

E fl.2 fkh;0 i t-1.1 L

liq l.8 Lgis

' l.25 I.4 rl.=I.6 li

==

., = =

4 150mm 4-6" A,sm> %@}e e + /,Ao r

a s )'3

- ~ ~ - - - ~,..

g,4a.

%,f9 p

V/,/

e ',.

e-

1. 3 %

(a

'e a vx i

'Y h

'b' V

!//

<p

g..

I'. +,:.

24'kfd A*'-'u

~

A y.

1. 65*

/

A~e%

do

%l& *as q

[g /

/).$f ' (g A?S g

+;. &

IMAGE EVALUATION yff v'W@

TEST TARGET (MT-3)

)

.s <;

y 4,

=

\\\\' N #g #

/g 4 tu lt- [ gum, l.0 u

.m t

t rn p*2p l.1

'~

gg

+=

ai= =

I.25 11.4 l'l y.6 l

i===

i e

4 150mm 4

6' p&>44

1. ++<,A+

4f

~ p.s'v',o., ;;\\

ps way.x o

,e.

w" i' %y /

OfL yjg

\\

7 0

i gg M

A l1%

,52 l s

construction joint-a structural detail has been sidered in the dnirn. A posuble resolution of the created that could lead to water entermg the vault.

abov': bar extension concern woulJ be to K.nc the This concern is heightened. considering the planned bars vertical and then fielJ bend the lurs m place construction and operations sequence. As show n in when the roof ts to be placed. Another soluuon Sheet 8 of 13 in Appendix 11 and as discuwed m would be to use an approved sphce system.

pl.ASAR Chapter 4. the extenor backfdl woulJ be placed and compacted against the wall before waste Comment 11: Section 3.3.1 (p. d-3M packages and interior backfdl were placed and be-W Section 3.3.1 (p. 3-35) inJiattes that conuruction fore the nef was placed. This method of construe-materials will be as required m AppenJn A.Seethm tion would result in inward rotation of the wall, A2.l of Appendn A states that ACl 212.2R," Guide

' shen, when the wastes and interior br.ekfdl were for Use of Admntures in Concretc," w di be used m pbeed,4e walls might rotate outward.

conjunction with the mattnaF and processes for conert 'e production.

m an actual license applicatien review, the staff.

would likely request reconsiJeration of the strue-As noteJ m the referenecJ ACI document, about 20 tural detail that w ould include a vertical plane along important functional classt : cations defmc or iJen-r the cuter wa!! face and ba:e slab to minimi/e the po-tify the purpose for an admixture bemg used. Many tentirJ for water entering the vault, commercial claims are made almut the capabihty of various proprietary admixtures to impart enhanced (c) Sneet-2 (Co<ss Section C),3 (Cross Section 1L11),

enaracteristics to concrete. but the deemon to use a and 5 (htio" D)of 13 in Appenda l! show sectional particular aJmature should be bascJ on an evalu-views that :riciade installed standptpes for the draiS ation using the actual mgredients that w di be used in ege systu n r onitors 'l' e momtors are shown as the concrete mix, since the resuhs obtamed are m-vertical L-in$hameter PVC pipes rismg up fluenced to a great deptee by the actual charactens-through tu Sacv.:1.

ties of the cement and appregates used.

Tw dra'aare o, tators are a necessary component Care must be exercised in the selection anJ use of ci the environmental monitoring program requi ed admatures, particu'arly wnh respect to long term by the re;uNons. llowever, installation of mom-degradation effects. 'lhe chances of long term dep-tors c this i)% preunts sescrai difficult problems radation can be decreased by careful serecrung and 4

(c.6 sca9ng or penetrations throuph the coser sys-testing of vanous admixtures. In an actual heense ten, backfilhng, and compacting around the user application resiew. the sta!f would ask the applicant pmes) that need to be carefully addressed through n' praide the rationale for the seicetion and use of planning, design, and construction considerations, any aanture, along with discussions of the per-The details for addressing these consiJerations are formance of the adnuxture and the 'ests and esalu-

~

not sufficiently desenbed in the PI / S AR, in an ac-ations that were completed.

tual heense application review, the staff would inter-W. W AR $3

) mdn'am that the conmun act with the applicant to tesohe these details. The tior, specifications are presented in Appendix A.

staff would be guided by the U.S. Army Corps of En.

However, Appendix A contains mainly a restate-gineers recommendations in NUREG/CR-5432, mert of the fundsnal requirements, the peneral Volume 3, in addressing the important instalianon design criteria, and the design codes and standards details for the drainage system monitors.

that will be used.

(d) Sheets 6 and 7 of 13 in Appenda 11 show the typical Construction specifications are tspicalh an output remforcing r.tcel for the Class A and Class H/C (kxumer.t from a design that are miended to pre-

~

vaults, respectively. The reinforcing details provide scribe what the designer expects and requires from for corner bars cxtercJing from the verticad outside the constructor m order for the design condnions to face wall reinforcing to 'Le roof outside face rein-be met, foremg (top steel), via a 90 degree bend. This i de-tailed to provide for over 7 feet of embedment into Specifications generally address the manner of con-the nef slah This leaves a 5-foot 6-inch leg of the struenor, the scuuence, material requirements, 90 degree bar extendmg over the vault wall while construction controls, and other comhtions that the the vault filling operations are under way. This engineer has de' tmined must he met and are, could result in damage to the bar, the concrete, the therefore, specihed. 'Iyr'eally, specifications are wall, and possibly a waste package.

prepred for matenals and major construction ae-tivities. Construction speofteations typically form The condition of the structures during the phases of part of the techrucal bases of the legal contract be construction and disposd operations should be con-tween the owner and the budder, 1I N U Rl'G - 1375. Vol. 2

~..-. -

~.- _ - -.--- - -.- - -.---

._-~-

llecause of the intended hypothetical nature of the percent, based on volume, and the wat er-ccment ra-PIASAR, no factual construction specifications are tio is to t~ less than 0.5.

provided in the document. _NURiiG-1199 indicates that construction specifications for activities where it is unclear from the PI AS AR what other parame.

_ public health and safety are involved should be pro-tera that aie discussed in the referenced ACI docu-vided and should be compatible and consistent with ment, which is a guide and provides secommenda.

the design, construction, and operational require.

tions on how to prevent damage from freezing and

ments, thawing, have been considered in the Pl ASAR de.

selopment. Without specifie citations of the ACI The PIASAR notes that the details on formwork, document m incorporation of specific provisions steel reinforcement placement, formation of j ints from the ACI uocument that are intended for use in in concrete, concrete mix proportioning, batching, the HGV structure, it is ddhcult to assess whether mixing and castkg, form removal, and moisture bar.

the pertinent parameters have been considered ap-rier placement s.re to be deferred until construction propriately.

specifications e written. In an actuallicense appli.

ACI 201,2R-77 recommends th..t six different as-

- cation, the apj tcant would be expected to provide pertinent cons uction specifications to allow for a pcets be assessed to proJuce durable structures wnh regulatory revih of the design of the waste disposal respect to freezing and Ihawing. These asptets m-facilityi clude the following: (i) the design of the structure to minimize expmure to moi.;ture, (ii) low water.

" * '"' " U"' M " E '"""i" "*" @ ) ""'"N * * '

Comment 12: Section 333.1 (p. 3-39) terials (v) adequate curing.and(vi)specialattention (a) Section 3.3.3.1 (p. 3-39) addresses Section 3 3 A of to wnsuuedon practiceCl he hrst aspect is noted in NURiiG-1199, llowever. construction and installa-the PI ASAR as being addressed elsewhere. t he water-ccment ratto is nct ed to be less than 0.5, w hich tion of the monitoring wells are not discussed.

NUREG-1199 indicates in Section 3.3A (p. 3-11) shouid ensure suryivability through at least 2000 I'"'C # "* W '* IhC U5 '"I""I"II"*S'hC ^CI l

that an applicant should describ: the major con.

struction methods for the installation of monitoring recommendation, but the basis for stating that such

gegg, a water-cement ratio ensures 2000 free /c thaw cy-cles is not provided. Air entrainment is, oted as he.

ing set at a nunimurn of 5 percent by velume. It

-(b) The PI ASAR (p. 3-39) states that disposal opera' would appear that the concrete considered in the tion pro (

ares will be prepared to be ser snive to Pl ASAR has been categorized as being in a moder-the imr

-haracteristics of the structure, to ate exposure condition. and, with a-value of maintait

• cupational radmuon exposure, 5-percent air, would also apparently indicate that However.

.ould not determine Dom the m the intent is to use an aggregate with a maximum site formation m % 1ASAR what the interaction be.

- of 3/4 neh, although these facts are not given in the tween simultaneous tonstruction and waste disposal PIASAR For the remainder of the aspects to be filhng operanons will be, or what specific measures considered, no information is orevided that ad-or features have been considered to maintain dresses freezing and thawmg. Smee the materials AIARA occup tonal radiation exposure, thm make up the concrete mixture play a major role in the capabilit'y of the resultiigconcrete materialto NURUG-1199 imCeates that the applicant should resist freezing and thawmg, the PI ASAR should describe the construction methods and operations, have provided more than just a reference to ACI including placement of packages, closing of vault 201.2 R-77.

openings, placing and : Wapacting of fill, and meas-urcs to protect facility workers. Discussions relatinE lt is also not clear whethe r the aggregates to be used operations to potential worker exposure would need would be tested under American Society for Testing to be provided in an actual license application -

and Materials (ASTM) Cl27 and Cl28, as recom-mended in NURI:G/CR-5041. It is not clear Comment 13: Section 333.1 (p 3-39) whether tests of the concrete material wdl be per-formed under CRD-C20, as noted in NURiiGi

_ (a) The PIASAR (p.3-34) refers to ACI 201.2R-77 as CR-5041. and whether the tests discussed in ACI a document that is apparendy being treated as a re-201.2R-77, such as those under ASTM C666, Ch71, quirement for material specifications to prmide as-and C6S2, would be used. Clanlication is also surance of free /c thaw durability of reinforced con-needed in the Pl ASAR as to whether petrographic crete structures. Two specific parameters are analyses of the constituent materials and the result-addressed: air entrainment is to be a mmimum of 5 mg concren wouM be required. S.mdar comments NURIIG-1375 Vol. 2 12

could be made for the other proposed PLASAR ma.

PLASAR on these materials. It is unclear if there is terials, as well as for the other parameters not ao.

an intent tc, use material snecting AKl%1 D3NO, dreued, such as curing and construction practices.

u hich is referenced in Section A2.1 as the appropri-ate standard for polyethylene sheet membrane, or The PLASAR should have provided specific infor.

whether that material is for onsite surface water cob mation, relative tc me constituent materials and the lection, storage, and control during construction. In resulting concrete, that addresses factors that influ.

adJition to the incomp!cto ir.iormation on the basic ence the behavior of the concrete structures in a materials to be used for v aterproofing,information frecte-thaw environment. This would have included that addresses the surface preparation, installation, the identification of all testing requirements, num, inspection, testing, and acceptance procedures to be bers of tests, acceptance / rejection criteria, and so used is lacking. It is not clear how ACI $15.1R is be-forth, that would be used to make decisions anJ to ing used or what specific guidance from that docu.

. provide the basis for the use of the materials in the ment has been incorporated mio the design, since design. In addition to addressing these issues that re.

this standard contains mar,y recommendations. For late to the initial matenal selections and the testing example, the ACI document notes that good barrier and qualification requirements. the PLASAR performance depends on proper surface prepam-should have contained information about the con.

tion. At least four ddferent procedures for surface trol of the materials during construction to produce preparation are discussed in the document, and

. a quality and durable product.

some information on adwmtages, disadvantages, limitations, and cautions for these alternatives is (b) _ Section 3.33.1 indicates that humidity and moisture provided.The Pl.ASAR is silent on this aspect of the barrier matc riats will be used to provide waterproof, waterproofing system, which is an important aspect ing on the exteriot of the Class A and Class H/C that can conttol the success or failure of the de-vaults, in Section A2.1 (pp. A-12 and A-13)it ap.

signed system of waterproofmg.

. pears, on the be. sis of the indusuy standards refer-

- enced (ASTM D449 and ASl%1 D2178), that an as.

An SAR should provide specific information on the phalt system has been selected for use. Sheet 5 of 13 hasis for the selection of the materials to be used in in Appendtx 11 specifies the waterproofing materials the waterproofing syvem to reflect the specific site under Schedule A.The Clas,s ll/C vault is stated to conJitions, design, construction methoJL and long-be designed with three layers of coal tar and two lay-term performance objectives. Important conditions ers of polyethylene material. Section A2.1 also re-that should be addressed include aging. chemical at.

fers to ACI 515.1 as a document that will be used.

tack, raJation, biodegradation, and cracking, as w ell as installation conditions during construction.

There appeats to be a conPiet in the information subraitted about the waterproofing materials that (c) The Pl.AS AR (p. 3-34) addresses aging by mention-will be used.11 is also not clear how ACl ing two characteristics of concrete that are affected 515.lR-79(85) " Guide to the Use of Waterproof.

by the element of time. Continued hydration and the ing, Dampproofing; Protective and Decorative liar-effects of creep and shrinkage are the characteristics 4

rier Systems for Concrete " was used.

discussed.

If asphalt materials are to be used, the PLASAR No information is provided on aging with respect to does not provide sufficient information.

some of the other materials being proposed for use, NUREG-1199 states that materi;ds should be de.

For example, what are the effects of aging on the ea -

wribed by their properties and engineering charac-pability of t_he waterproofing membrane, the watert teristics with supporting data and test results, in-proof coatmg mastic or adhesive material (coal tar, ciuding performance' records. Although ASTM asphalt, eteJ), water stops, drain piping' installed l

standards have been referenced, the depr ec of speci.

through a cell wall, joint filler, joint scalant, and ficity necessary to derme and understard the materi-geotextile fabric to meet the target design life of 500 als is not sufficient,'lhe standards actually provide years in the case of the Class H/C vaults?

for several types of materials that exhibit somewhat different properties 'lhus, to refer to the AS111 SRP 33 A states that an applicant should provide i_n-standard that may address several types of materials formation on the materials to be used in a llGV so without providing additional specific information is that the properties, quality, and durability of the not adequate.

construction materials can be assessed. The infor-mation should include supporting data such as test if theintent is to use coal tarand polyet hylene, there results and mservice performance record 3. An SAR appears to be no additional information in the should address aging for all materials proposed in a 13 NURliG-13 /5, Vol. 2

_ = _

BGV system where continued safe performance standard tests is one way to obtain that data, in some could be affected by aging.

eases, for certain materials where a specilic characteristic is desired to satisfy the design requirements, standard (d) ; 'Ihe PLASAR (p. 3-40) addresses fatigue of the re-tests may not be available or standard tests maj need to be v

inforced concrete vaults for both Class A and Class modified. In these cases, additional information would B/C categories,This phenomenon was addressed by need to be provided in an actual license application for a evaluating the stress range the structures will expe-staff c'.aluation to be made, rience and determining the allowable number of cy-s cles permitted in that stress and service range.'the Comment 15: Section 3.3.3.2 (p. 3--41) projected number of lifetime h3ad cycles was then estimated and compared to published data, as refer.

(a) 'the Pl.ASAR indicates that disposal unit closure is enced in the PIASAR.

addressed in Secuons 3.1 and 3.3.1 and Appendtx lj.

There is difficuhy m locatmg some mformanon m y

The materials the PLASAR addresses for fatigue the PLASAR, particularly where the PLASAR consideration are concrete and reinforcing steel; review topics are discussed at kications different from those suggested in NURliG4149 and however, other materials should also have been evaluated for fatigue considerations, Other cle-NURilG-1200. More specific references, by page ments encompassed within the vault design for long.

number, in an SAR would significantly help a regu-term capability should have been evaluated and re, latory review er w hen the infotmation is not provided sults described with regard to repeated kiads that as suggested ;n NURliG-1199 and NURiiG-1200.

could cause deflections as well as stress. For exam-

.lhe PI ASAR (p. 3-41) indicates that waste disposal ple, metal water stops should have been evaluated as operations are disc 5 sed in Chapter 4. The well as the waterproofing seals at the kication of ex-p gg g gg ;

g g

pansion joints' heen placed, backfill would then be"placed in the cell t

t soids between packages. A crane would (c) The PLA5AR (p, 3-41) addresses the considera, dump the fill from a bucket. the crane operator tions given to the biodegradauon mechanism of a would spread and level the fill with the bucket, but vadt in terms of the additional protection afforded would not attempt compaction. This backfill is in-y the waterproofing membrane applied to the vault.

b'xterior. However, the biodegmdation considera-unded to be he Cowing because of its physical c

characteristics and particle site distnbution.

tions for other important materials in the disposal facility do not appear to have been addressed.16r No description is provided for the fill material to example, the expansion joini seals and the water' demonst rate its capabihty to fill void spaces. It is not proofing materials are not identified as having been know n if particle shape, moisture content, hcipht of evaluated for biodegradation consideration. ihe ef-drop, and other parameters would ultimately be de-fect of biodegradation on susceptible materials fmed.

would need to be addressed in an actual license ap-plication.

NURI!G-1199 suggests that the applicant provide-information relative to the construction controls Comment 14: Section 3.3.3.1 (p. 3-40) that will be requhed to ensure proper pradation and moisture contr>l of backfill materials to be placed The PLASAR provides only minimal information on the

-around the wane containers. In an actual license ap-majority of the 13 considerations recommended in Sec~

plication revkw, the applicant would be expected to tion 3.3 A of NURF.G-1199 with regard to the quality and prowide additional information, such at the con-durability of construction materials. The Pi ASAR (p. 0-struction specification that would cover the backfill

40) notes that the considerations need to be supported by material, as well as the construction placement the results of specific testing of the actual materials to be methods and controls to be required.

used, utilizing standard accepted test methods. It is not clear from the brief discussions in the PIASAR whether Comment 16: Section 3.4.1 (p. A4l) the correct mdustry standards would be used m such a testing program, since the standards are not specifically -

'the NRC staff reviewed the information on utility sys-identified for each material to be taed in the construction tems proposed to he used at the llGV PI AS AR facility to of the disposal facility, verify that thedesign bases and criteria foreach utihty sys-tem would be adequate to ensure worker safety and to-NURl!G-1199 indicates that information should be pr+

chetk that any potential aJverse effects from malfunc-vided on the proposed materials to doeurr.em the mate-tionmg or failure of the utility systems would not sigmfi-

-ial properties and performa ncc characteristics relahyc to cantly degrade or impair the sale performance of the quahty and durabdity. The development of results frorn waste disposal fvility. On the basis of these review NUREG-1375, Vol. 2 14 s

l l

objectives, the staff developed the following comments time of site closure and stabili/ation should be de-on the information in the Pl.ASAR.

scribed.

(a) The information in the PLASAR on the electricity (f) the information to be provided in an actuallicense supply is too general and not specific to 'he pro-application should include a description of the de-posed facility. Although portable backup power tails (e.g., location, raaterials, design, applicable would be made available in the event of the loss of codes)of the tanks and pipelines to be used to store offsite power, the details of the system are missing.

contaminated liquids. 'lhe design details of tne In an actual license application, sufficient details on berms andi ctention area intended to pr event migra-the electrical and backup systems would need to be tion of any tank leaks should also be desenbod, along provided.

with the plans for dispsng of the tanks and pipe.

hnts at the time of site clmure-(b) More specific information on the design details of l

the natural gas supply system should also be pro-Comment 17: Section 3.4.2 (p. 3-44) vided in an actual hcense apphcation. The informa' (a) It is undear why the PLAS AR daes not provide in-tion should mclude the actual kication of the gap lines, a discussion of how the provisions of the apph-formation on the truck wash water treatment plant, imd maintenance and steel fabrication buildmg. In cabic and pertinent codes and standards would be an actual license application, it is expected that in.

met with the mstallation of the proposed pas supply fin mation would be provided on the cales and stan-system, and a discuvion that supports the position that malfunctioning or fadure of the gas supply sys' tards that these buildings would be designed to meet and how the actual designs meet the applicab!c code j

tem would not _impa;r the safe performance of the requirements. Any potential ciTects from malfunc-waste disposal facibiy.

doning or failure o'f these buddmgs on overall opera-(c). Information on the specific communication swtem tions of the waste disposal facility would need to be to be installed at a proposed facility would need to be discussed. and sulfteient mformation provided to provided in an actual license appt'ication. The stan-show that problems mth facility performance would dards or accepted practiec to be followed in install-ing the system and information on the offsite alarm W Information about equipment important to radia-for notifying faci!ity emerpency personnel would tion sMety that is planned for use m the administra-need to be provided.

tion / health buddmg and the guard house should be provided in an actual license apphcation. This infor.

(d).Ihe m. fonnation on the water supply system would rnation would typicahy be meluded in Chapter 7, need to be expan;ded m an actual heense applicanon

,' Occupational Radiation Protection," with appro-to provide specific mformation on the proposed ma' priate references to Section 3 41 terials and the construcuon of the supply hnes, pumping, and storage comptments. In addaion, the Commeni 18: Section 3.4.3 (p. 3-48)

- SAR should desenbe how the proposed water distn-bution system meets applicable codes and orde Section 3A.3 of the PLAS AR provides information on the nances. A discussion should be provided em nng fire protection system proposed to be uscJ at the llGV

the adverse effects a fai'ure of the water supply sys.

facihty. This information includes a list of the fire sup.

tem could have on faciLty perfe.mance (e.g4 truck pression systems for the buildings and disposal areas at wash or concrete placement'in vault structured the facihty and some details on the response of facility l

I The apparent discrepancy in the actual hdtion of personnel to a fire emergency. Several topics are also tl'e water supply tank would need to be resobed.

listed thet should be treated in more detail in an SAR (Section 3A.1 indientes that the water storage tank relative to an emergency response plan for toc facihty, in-would be h3cated in the administrative area, and Ap-ciudmg personnel training; alarm systems, evacuation pendix A (p. A-73) indicates an offsite h> cation.)

plans, administrative controls, fire suppression equip-ment, and procedures for respondmg to a fire emetgency.

(c) Sufficient information on the design of the vehicle An actual heense application would provide these details

- fuel system should be provided in an actual license m an emergency response plan and would include appns application to support the statement that the stur-priate references to Section 8A,"limergency Planning "

age tank failure would not affect disposta unit pm

- Section 3A.3 et an actual heense application would also

- formance. This information should mclude actual be expected to include details on how the prescribed pro-hict.tions of the underground tanks; typicid detads sisjons had recommendations of Nanonal 1 ire Protection on tank design, materials, and installation; and ap-Association (Ni PA) bl)l--108(n " Recommended Nrc plicable codes and standards to be met. The dispm-Protection Practice for I acilities Ilandling Radioacuve tkm of the tanhs and underground fuel Unes at the Materia!%" and NI'PA 901-- 1981, " Uniform Codmg for 15 N URl1G--1375, Vol 2 1

m m.-~-.,

-w=

m u e e

-w-----w

---,--e----m-----

m ---*m-w---

r-u

t 3

- Fin e Protection," would be implemented for the fire pro-not likely be acceptable as part of the erosion pro.

tection system proposed for the."acility, tection material because its durabihty is question-able. If concrete is to be used,its use shond be justi-Comment 19: Section 3.4.4 (p. 3-50) fied in an actual license application taking into -

consideration that the concretc must t.ot weathet Section 3.4.4 of the plASAR covers crosion protection, significantly and must perform its crosion protection as affected by streams in the vicinity of the site. On the function without reliance on routine mainanance, basis of the staff's review of the infonnation provided, it is Additional comments and discussion addressirqt the not clear what is being protected and how the assump-use of concrete for long-term applications are pro-tions used arc iclevant to the design proposed -

vided in Comment 71(f).

(a) First,it is not clear where the erosion protection that is being proposed will be placed. No drwings, cross.

4 FAClLl,1,i,01 ERA,I, IONS

• sections, or information has taen provided to de-Comment 20: Section 4,1 (p. 4-D lineate the areas that will be protected. No mforma.

tion has been provided to state what is being A statement is m:& m G.rpter 4 that facitdrSPCCtfic protected and why erosion will exist at the site. It i' operatmg pocedures identified a necessa y in not clear if the crosion pro!cetion is needed to pre-NURFG-1199 were intentionally omitted - in the vent lateral or vertical erosion and if such erosion PLASAR because of the hypothetical nature of the facd-could adversely affect the site.

ity. Therefore. the staff is unable to provide specificcom-ments on operating proecdures that would be expected in

- (b) Second, the assumptions used to determine the rock im actual license application and that would typically in-size may not be appropriate. Although it is very ciude procedures for (l) visual examination of waste ship-

- likely that the proposed 40-inch riprap is adequate ping documents:(2) visual examination of waste packages

~ to provide the necessary erosion protection, the for trregularities (e.g., markings, labels. probable con.

streara cross-section that was used to determme the tents) and for descriptive information (e.g., size. type, flood vehieity and erosion petion requirements contents); (3) verifica' ion surveys of radiation levels on is located nearly a mile away (PIX %R Figure shipped containers:(4) testing and test equipment to ver-3,4-1)from the site,It is not hkely that such a section ify wute classification on mamfest; and (5) verification to would be appropriate, since it could be significantly determine if waste charactenstics and waste form re-different in the site vicinity. If crosion in the site vi' quirements meet applicable regulations 'Ihc following cinity could be a problem, a section closer to the site staff comments are provided in response to the specific should be used for design-information that was provided in Chapter 4.

I

.(c) Third, the use of the rock durabihty criteria of the (a) Although the PLAS AR identifies certain personnel U.S. Bureau of Reclamation (USftR) may not be positions for various responsibilities in overseeing adequate for longterm stability applications, and the receipt and inspection of waste, it is not pssible this approach should be furtherjustified in an actual to complete an evaluation of this aspect because the license application'.The NRC staff has recently de-identified positions in the PI ASAR -are tTot de-veloped procedures for evaluating = rock quality.

scribed in relation to the organizational structure l

These procedures are presented in a final Staff that would typically be provided in Cha pter 8, ' Con-Technical Position. " Design of Erosica Protection doct of 0perations?' 't he organizational structure is Covers for Stabdization of Uranium Mdl Tailings needed to understand the functions, responsibili-Sites " and provide an acceptable method for deter-ties, and lines of authority of the identified facility mining rock durabbity for the long periods associ-pmitions.

ated with site closure. The rock quality should be evaluated using these procedures or, ahernatively, (b) Figures 4.1-1,4.1-2, aad 4.1-3 in the Pl ASAR de,

. the useof the proposed USUR critena should be jus-pict a cornplex process for waste receipt, examina-tified.

tion, and placement. Procedures fu these activities and ajustification for the propo sed double and triple (d)L Fourt' 'he Pl AS AR indicates that concrete may be handling of the waste when it is received, consider-used as erosion protection. Although this may be ac-ing the goals of the applicant's AI. ARA program, ceptabk'when active maintenance is being per-should ec induded in an actual license application.

formed, it is not likely to be acceptable for the postektsure period. Concrete is subject to weather-

• Wepared by Iwrch manmer. eka enmeer. and Enn watfner, ing when exposed and is not likely to survive for sev_

pny,:t enanager tsecnons 4 t ma 4 2 x utatmact uucm eny-neer(secmm a md thra shum.wm envemental enpneer.

- eral_ hundreds of years without mamtenance. Con-anwd1%dgrammsconn 4 4 Includemnenw tmm crete that is exposed to weathering elements would SNI,and DNL NUREG-1375, Vol. 2 16

This just fication would include comder. tion of anee in NURILil49 and NURI:G -1200, more worker skills, number of indindual, en sed, types detailed informahon about the sisual inspection of required equipment, dose commitmc k contm-procedures would need to be prouded in an actual gencies, and quahty assurance, heense appheauon This infonnation should include detads un the dif f erences betv cen the inspections of (c) Sheet 12 of 13 in AppenJn 11 ptosides a draw.ng of open trucks at the guard house and the mspections the receiving and stoiage buildmg ef the itGV iacd.

of dosed vans at the inspeenon stauon of the receiv-ity, and Figures 4.1--1,4.14, and 4.1-3 meluJc mfor.

mg and sterare budding, the personnel w ho will con-rnation on actiuties that would be conducte J m ilus duct the vi.sual mspection and to whom they wdlie-building. Other than these drawmps and figures. ht-iwt, the dwcklists that udl be used for the visual tie descuption or mformahon about the design of inspection, the late of waste that does not pm usual the buddmg of other informahon necessar) to make inspect on, anJ the penalues for wastes that do not a regulatory resiew of the achuties to be conducted paw the inspat on.

in the budthng is provided. Additional informatica describing the functions and activines of this budd-g lW@ 42 and Ll-3 W N clMAR present ah-ing anJ information on deygn entena, codes, and brenated hsts of the routme deternunations ' hat stand.uds that were used m the design should be woulJ be made dur my sisual cuminations of pack-pt ovided m, an actual hcense appigatign. l'he mlor-ges ad tW achons to be pfunned upon receipt of mation to lle phyvided is iJentihed m SRP 3.4.2, a packare. The tables proude pencral summeu tes of Auuliary 1.acthnes _ and w ou!J incluJe drstussions mlotmation wnt.uned m 10 CFR 71.S7 and 10 CFH of any potential ath erse c!!cets on overaH waste dis-2020i mpectM4 Detaded pnNedmes on how pos;d laeility perf ormance if the recoving and stor-exh of ik reded Otonsnm W ne age budJmg beerne moperanve' wuM utm% N' N mW hu P" pW in f

(d) Section 4.1.1 of the P! AS AR presents a boel de setiption of acuvines that would take pbcc when W111nteilt 22: Section 4.1.3 (p. 44) waue shipments arnve at the llGV facihty and the examination of shippmg documents epon us arnval.

In accordance wah the cuidance m NURIElluu Sethon 4.1.3 of the PLAS AR pitsents mfor mahon on the and NURIE1200, more specific mformation on seriheauon survey s that would be conducted when pack-the actual proecdures to be used for these activines arcs are receised for disposal. More det.nled procedures w ou!J need to be provided in an actual heense upph.

on completmg venfication surveys would need to be pro-edeJ m an actual hccw ppheation. Wee cet.nleJ pr o.

cation. These procedmes should address the prou.

sions for informing the facdity raJution safety offi.

eedures shouU include imonnahon on t he personnel w ho cer (RSO) of the waste slupment mformation and wdl conduct the survep, the peisons to w hom they wdl the RSO's associatcJ actions the asso,ance that ieport, and the traming that wdl be given to these person -

only scheduled shipments wouM be aHowed access nel Documentation of the sur ey rc3ults should be pro-to the facdity, the provisions for returning unsched.

uded, along wah information on the eqmpment to be uled shipments to the originator, the acuons to be used, on how cask hJs ate to he removed and replaced, taken should discte pancies be found on the slupping and on how mspections of the diflerent trucks that are ev documents, the acknowledgment of receipty, the in.

pected wdl be conducted. The procedures should also formation flow in case a schedulcJ shipment did not cover the proecss for iJentify my packages not in comph.

arrive, and the maintenance of coptes of mamfests ance, the hierarchy of siolanons,and the nonfication pro-and associated documents, cedures to be used m case of noncompliance.

(c) Table 4.1-1 in the P' ASAR presents a summary hst Cominent 23: Section 4.1.4 (p 4-7) of the information from 10 Cl R 20 311 that is re-quired to be on a waste matufest. A sample of the Secuon 4.1.4 of the Pi ASAR desenbes waste clasufica-actual manifest fann to be used at the facihty shoidd tion verification activines that are to be conducteJ at the be provided in an actual heense appheation-pomt of waste pencration and mehides some mformation on the frequency of mspecuons. An actual heen3e apph.

Conunent 21: Section 4.L2 (p. 4-1) canon wouu be espeued to inelede a program of waste eksnification senficauon to be implemented at the dis (a) Secuon L1.2 of the PI AS AR provides bnel dcwnp-posal !acihty 'I he program shonM include putedures, tionsol protedures that wdl be m place for the BGV trequena of apphcanon, equipment to independently facihty reptdmg the visual th::k of waste ship-detenume waste daw, and prousions to deletmine any ments at the fadhty; in accordance with the gmd-Mgmheant chenucais m the waste.

17 N t TRIG-1371 Vol. 2 L

Conintent 24: Section 4.1.5 (p. 4-9) op ranons and tn) procedmes for mspectmg anJ de-contaminating these trucks as necewary.

Section 4.1.5 of the Pl.AS AR describes the activities that would be undertaken at the disposal faciht) to estabhsh (c) Section 411 l'nefly desenbes the segregatnin of the ddferent deses of waste that will be recehed at the the characteristics of wage packages that wete consid.

cred questionable or msufficiendy known followmg the IRW facihty. An actual bcense application would be point-of-origm and stapment mspections. ~1 he waste expected to provide adJttional information on the charactertsites exurunations to be perforined by tbc facd-segreg stion of 0) wasto that wdl be iceen ed on un.

ity contractor as indicated m the Pl.AS AR wou!J melude shicucJ flatbed trucks that wdl be alhmed to pro-p'rocedures to confirm 0) that hmits on fretstandmp hq.

ceed dMecd) to the dnpool at ca: 00 Class B wetes from Claw C wastes; tnd stable, sohdified Class A uid and requirements for wete form staNhty h.ne been I

wastes fmm nonstable ( h A wetes; (n ) Iqh ae-met and (M that liigh Internty Contamers uruhcates hase been comphed with. Ihese examinations may in linty wastes from ot her wetes m a slapment and b )

clude destruethe tecamques (c.p., cutting. cormg. s.un.

wetes that may reqmre segr egation tot adminit tia-ta c remons wh m weto dut eatinn ehdates of plmp), although nondestructn e meth4 $ds ten ultrasonic eik orhmh.

testing)would be pr efetable. The sLdl agrees with the a; tlVities proposed W the Pl.AS AR [of s enisine w aste clui-actetisties but expects the specthe proccJhres anJ eqmp-Cotiinient 27: Stelion 4.2.2 (p. 4-1l) ment for the identcied tesung to be aJequatch descnbed UO Snuun 42 of Ow M.AW adaeun the intenrn in an actual hcense apphcanon. '!hese procedures oere

• ""fC "! ""4cs that in.a be necessat3 undct cer net meludeJ in the Pl.ASAR.

tain conathms at the IMW laedny. AJJmonal de-t.u!s on the procedures f or inteum storare of wete Conunent 23: Seelion 4.1.6 (p. 4-H shouM be pmuded m an aacal hense appheauon.

't hese detaik thouu mduJe 0.e appheant's plans Sectio 14.1.6 of the Pl AS AR presents a hnef discusen f or inomtennp uw ston.d wastes. tor tra kmp the of waste Meeptan: enteria dut wouM be uscJ at the stored waste to ensurt that the matmum stotapc BGY facilny the h t is tuucalh the same as Out m SRP ume of 4h daysdest lated m the M AS AR is not n-4.1, Section 416. Specihe pmcedmes need to is pm-t.eeded, and f or pmtechnp wor ker s. I he uJonnation sided in an actual heense apphcanon that cover faahty should aho melude deta.h on the mspechon el pack-specibe receipt constior s that for cam;te, nupht cause apes bemp remm ed hom storas and how the pack.

some packages to be rotncted baauw of the eqmpment apes me to be prottaed fmm dam 4pe dunnp han-to be used, or cause restncuans based on the Al.AR A dhng whde m stor. pc. Apparent mconsstenetes m propram. The infor mauon s hould mdude det.uk on how the Pl AS AR tepardmp the capacay of the storage these restnetions w ou!J be enf orccJ and how noncomph-area idso wouM need to be adJn:ued Pl.AS AR See-ante wouM be hanJ!cd.

tion 4.2.2 st.u cs that the stoiap. mea can hoM a 1-month mventury. w he:cas Pl.AS AR Secuan 11.7 m ' hat u on hoy a 2-nlonth mu nug Hw Conuuent 26: Section 4.2.1 (p. 4-l@

eqmpment to be used ior the storare of t,aste shouM be dts u3 sed, and the capabihues and hmnahons of s

Section u,.1 of the M.A, AR desenbes the handlmn tho equipmera shouM be sununame i Dus inlon S

.(a)

- of wane at the :acd.us after u o recen ed N1 ore spe"-

r manon coulu3 N supphed m response to (,omment etf e details about in'c actu;d wete-handhng proce-M, a)and applopTlatcl) Ieleienced in other 5ccllons dures shou!J be pmuded m an actual heene apph-o, an att ual hense app,us anon t

calloll..Ihese Jetain shouW tnetuJe inf.ormanon about the personnel wha wiu perform cert.dn func-du Secuon 4 a, ; states Ihat no (.,uw B. t-usu,, or lugh-tions and to whom thev wth icport the ocecpauonal panuna (,lau A waste V dl be shited iii the f eten tny

~

exposure consideranons of the actnnie3 desenhed.

and stm are budJmp and then mJicates~ that stuelJs,d the cqmpment to be used for oi.noading mspection.

waue w di he stored outdoor s unide the dnposal area and worker pmtection hne:udmp meihead tranes tenme m ihe mic um. AJ1tional mfonnation needed and [orkliIts); arid the standards anu code,. thal tlas would melude how wastt s suncJ muJe the thsposal cuuipment wu,l meet rea [eWic w dl h-? p?otec!cd hom surlaCe watel, how Jus waste u m he irr:ked and momtored, and how lb) SCelion a.2. ! ploV1 des a d; sci WoD im the Use td U wirrkets wdl be protennj iI was!c h stored m this cdity operated flathed innks hu waste hanJh J op teh;on Aho..acuu! hse sc apphcahon w ould bc ctauon, An actual h.;cr^e apphJanon wouU bc w npcetcJ to unh* pmeedorn f or the contingeneT peeted to desenhe n i the (anthd; !

d ihese u % ks m m s m m of M! d e s of wews me hc m cev.ary since they are an integral part of the w; sicaandhn2 at nmes and that othcr wws aho nuy regnu e NURIX i 1375. Vol. 2 W

% R i

=,

i ctorage for administrative rcasons, such as awaiting fying the generator whose package was damagcJ.

return to a generator after a finding of noncompli-recordkeeping for damaged packages, and protec-ance at mspection.

tion of workers from occupational exposure dunng these procedures.

(c) The description of the handling of wastes during storage includes a mention of removable wall panels (b) Sheet 12 of 13 in Appenda 11 shows the remedial ac-to allow wast es to be transported inside the receivmg tion area designated in betion 4.2.5 for iepacLaping and storage building. The information that would be damaged packages. Ab.o chown on the drawmg is a supphed in an actuallicense appheation in r esponse hot cell. An actual beense a 3phcation would need to contain more information about the activities that to Comment 20(e) should include details of this im-are intended for the hot cell and how a package is to portant feature. The effects of this feature on worker protection and the ALAR A program should be transported from the hot cell to the remedial ac-also be addressed.

tion area, if sepackaging or decontamir.ation is needed.

Comment 28: Section 4.2.3 (p. 4-11)

Comment 31: Section 4,3.1 (p. 4-13)

Section 4.23 of the PLASAR provides a brief description (a) Section 43.1 of the PLASAR states that a remotelv of the training that workers will be required to take and of controlled gantry crane will be used for emplacin'g the protective clothing that they will be required to wear all Class A wastes. The crane operator will view during waste handling. More details should be provided closed ciretut television to couple the waste pack-on the training that workers will be required to take be-ages to and from the erane's hfting mechanism and fore handling and storing wastes. It would be appropnate to carefully stack them in the disposal unit. Auto-to address these details on facihty traming m Chapter 8 of inatic grappling and decouphng devices are to be an actual license application and to ref erence this infor-used to handle the packages.

mation in Section 4.23. It would also be appropriate to include more details on worker protection in Chapter 7 The staff questions the use of a hirhly sophisticated and to reference the information in Sections 4.1 and 4.2.

temote handling system to handle all the Class A wastes. 'lypically, the more complex a system is, the Commeni 29: Section 4.2.4 (p. 4-12) greater the probability of dewn time due to repairs Most of the Class A wastes can be handled routmely Section 4.2.4 of the PLASAR provides a brief description with o!f-the-shelf construction and industnal equip-of the handling process for three catepones of packages.

ment and minimal health physics precautions. The An actual license application would be expected to more implementation of st.ch a complex handling systern fully document the procedures to be used in the handling would require the appheant to discuss the probabil-of these packages. The details to be provided include the in of equipment breakdown, expected down times, number of workers the applicant anticipates will he Ed contingency plans during down times, needed for the handhng operations, how the appheant will ensure that all waste packages can be safely handled Additional details describing the remote waste dis-with the equipment proposed to be used, and the contin-pos;d procedures should be piovided in an actualli-gencies to be addressed where specud adaptations or censc application and include (i) types of remote ser-emergency procedures will be needed. In adJition, there vomechanisrns to he used to accommodate various would need to be appropriate references to information hfting desices on waste packages;(ii) lifting device supplied in other paruf an actual license application on requirements that would be imposed on the waste the equipment to be ur.ed in the handling of these pack-shipper to accommodate the remote servomecha-ages. There would also need to be explanations of how nisms (PLASAR Section 4.2.4 does require "stan-packages will be protected from damage during all stages dard" lifting points, but the standard is not speci-of waste handling.

fied); (iii) procedures for handling oversized and overweight packages;(iv) the p'ocess and sequence Comment 30: Section 4.2.5 (p. 4-12) by which a shippmg cask hd would be removed, the liner unloaded and placed in a disposal cell, the lid (a) Section 4.2.5 of the PLASAR contains a brief de-replaced, and the d:sposal unit backfdled; and (v) the scription of the process for handling damaged pack-number of workers involved and the training re-ages at the BGV facility, in an actual license appli-quired.

cation, more details would be needed on this process, includmg more information on the decon-(b) Regardmg waste pxkage mtegnty, PLASAR See-tamination of containers, the repackaging of dam-tion 4 3 I simply states that care is to be taken not to aged packages, the handling of waste generated by compromise pxkage mtegnty durmp waste em-repackaging or onsite spills. tne pn>cedures for noti-placement. Pl.ASAR Secoon 4.2.5 mentions !! at 19 NU RIG 1375, Vol. 2

damaged packages may be handled on site in the re-ling placement of the various size and shape pack-ceiving and storage building, where repacking will ages are inadequately discussed in the pl ASAR, primarily be a matter of overpacking into a larger container and filling excess voij space.

Chapter 3 of the PLASAR is cited as containing crane specifications. The review of an actuallicense In an actuallicense application, the applicant would application would be facilitated if the applicant ref-be expected to discuss in more detail the specific erenced the specific section(s)in Chapter 3 that con-types of waste packages to be used for Class A waste tam mformation on the crane.

and the steps to be taken to prevent any damage to the container during emplacement and backfill op.

(f) Section 4.3.1 does not adequately discuss, or provide crations. More detail would clso be crpected in de-a reference to a section that covers, the engmeermg scribing the actions to be taken if a package is dam-properties of the backfill materials used for filhng ged' v id spaces between waste containers. An actual h.

cense applicatim wouM be expected to provide in-mWm m ms m as th &nsh, mohe (c) More detail on measures to be taken to minimize l

c mpre y,an pemea y

arap C

U worker e*P sure during waste emP acement should tenstics of the backfill m order to demonstrate their be provided in an actual license application, includ-capability to contribute to long. term stability and to ing the types and thicknesses of the special shielding minimize subsidence, that wdl be used when emplacing high gamma wastes. Any protective clothing worn by the worker (g) Waste placement operations should include the sur-would be discussed in this section or referred to in vey and decontammation of the truck and shipping another section of the SAR. The applicant should cask used to transport the waste to the disposal unit.

also discuss the expected and permissible worker Trucks and shipping casks (when used) must be sur-doses for both routine and high radiation shipments.

veyed before they are released and decontaminated as necessary, An actuallicense application would be (d) Section 4.3.1 discusses the possibility of rain water expected to provide procedures for performing the entering the cell that was being fdled. It is unclear, survey and possible decontamination.

however,if placement of waste packages would take place while it was actually raining. If so, measures (h) Wooden pailets if used ani then left in place will de-should be taken to minimize exposure of the pack-compose and leave void spaces. In addition, the de-ages to rain water during this period, composition of the wood could produce chemicals that may abet vault deterioration. In an actual li-This section states, "A temporan weather shield cense application, the npplicant would be expected structure can be placed over the active cell to ex.

to evaluate this possibdity and the resulting adverse clude water or snow from large storms." A policy for impacts,if any.

covering or not covering active cells to protect them from rain or snow should be firmly established in an Contment 32: Section 4.3.2 (p. 4-15) act uallicense application. Also,an acceptable mois-ture environment entenon for the disposal cell be-Section 4.1.5 of the Pl.ASAR discusses pnxtuct accept-ability for Class A waste and Class ll/C waste. It states

~

fore waste emplacement should be established.

Rainfall may result in various moisture envtron-that "should the point-of-origin / shipment inspection be ments withm the active cells, ranging from a damp considered insufficient, or if a received package is consid-environment (rcsulting from past or hght rainfall) to cred suspect, procedures shall be in place to provide con-g g

g g g sheet fhxxling (resulting from quick bursts of heavy rain) to ponding (resulting from extended heasy tics testing " As part of the waste emplacement rains). In an actual license application. the applicant operations, the applicant would be expected to incorpo-would be expected to provide a rationale for the rate verification proedures for routine random inspec-tions of other types of' packages, not just suspect pack-moisture environments that would be acceptable in the cells before waste packages would be placed.

ages, to determine product acceptability, (c) This section states that the waste pnckages are to be carefully and individually placed into their disposal (a) Section 4.3.3 of the PLASAR states that there will cells; however, it does not adequately discuss how be three permanent survey marker control points.

careful placemen t and stacking would be specifically An actual license application would be expected to controlled. Specifications for the equipment to be provide in more detail the procedures that are pro-used during waste emplacement are found in

30 sed to accurately hicate, map, and mark the dis-Pl ASAR Section 3.3.2, but measures for control-posal units and facility boundaries. Information NUREG-1375. Vol 2 20 I

l would include the times the field surveys are to be three areas. When referencing information,it would performed and the procedures and documentation expedite the review if the applicant referenced the for developing a permanent office record of loca-specific section(s) of each chapter and appendix tions of the disposal units and boundary markers, where more detailed information could be found.

(b) This section states that the survey will be performed (b) Information cited in Pl.ASAR Chapter 3 regarding to a third-order level of precision. Ahhough this the buffer rone does not provide the amount of de-meets the minimum guidance of SRP 4.2, Section tail required for Section 43. Although the informa.

13.4, the NRC consultant recommended in tion provided includes the width of the rone and the

. eUREG/CR-5041, Volume 1. Section 2.4.2.2.1, vertical water velocatics at the site and at the aquifer j

that the control network be surveyed to second, below the site, other ia.portant information is not in-order precision, using mixed triangulation.

c!uded. In an actual license application, the appli-

~

trilateration observations The higher level of survey cant would be expected to adequately discuss (i) all three dimensions of the zone and how the buffer accuracy should be considered to permit greater pre.

cision in the recording of structural movements that zone beneath the disposal units will limit offsite mi-in turn will allow more accurate estimates of changes gration;(ii) the capabihty of the buffer zone areas to in stresses and strains of the vault to be made.

permit construction and mitigatise measures to be taken if the iesults of monitoring show remedial (c) The boundary marker described in this section con.

measur es are required:(iti) how other waste disposal activities will not interfere with these measures if sists of an 8 inch-diameter granite cylinder,2 feet in length, with a mounted bronze plate containing the taken; and (iv) how the following were consiJered in required information. The cylinder is to be set into the development of the buffer zone dimensions: site concrete. There is some question about the durabd.

geology and topography; natural soil and rock char-ity of the marker over a long period of time because acteristics; direction, depth, and vekicity of ground of its relatively long, thin geometry and potentially water; and hication of wc!!s and water users, separable bronze information plate. Over time, the (c) Inf rmation cited in PIASAR Chapters 3 and 5 on gramte cylinder may be snapped off the concrete disposal site closure and stabilization is generally ac-setting, or the attached bronze plate may be de-ceptable. One area that is not adequately discussed tached from the cylinder. A thicker and firn$ct cylin-is how disposal unit closure and stabilization procc-der with the information engraved into the granite dures wdl not disturb completed umts. Section 43 maY provide greater assurance of long-term durabil-ity[An actual license application would need to ad-muely M tes, tosure acsities wW be sequenced m praem Wstuption of prniously closed areas?

dress the length of durability of the markers and pro-nha mformation, consisting of pertinent draw-vide the supporting basis for its service-life claim, ings and sketches and a description, would be en addressing both durabihty and legibility.

peeted to show clearly how this is to be accom-plished.

(d) Referenced Chapter 8 of the PLASAR does not contain information on the skills and training of the Comment 35: Section 4.4 (p. 4-18) persons participating in the land survey. This mfor-i mation should be provided in an SAR t response to With the exception of the PLAS AR statement: "Most of SRP43,aswellasthe numberof pc. 6nuelinvolved the new monimring will be related to direct releases frorn in the survey.

incoming vehicles, waste containers, and handling equip-ment"(during the operational monitoring phase), there is Comment 34: Section 4.3.4 (p. 4-17) little discussion in Section 4.4 on monitoring for worker exposures during site operations. Consequently, the staff (a) Section 43.4 of the PLASAR defers all discussion comments on operational monitoring and surveillance on disposal unit closure and stabilization and the that follow are primarily directed at environmental moni.

buffer zone to the following sections:

tormg as defined in NURiiG-1388, "Ilranch Technical I

Position on linvironmental Monitoring of Low Level Ra.

disposalunit closure: Appendices 11and E,and dioactive Waste DisposM Facility," and not monitoring j-Chapters 3 and 5 for facility worker exposure. The staff does provide com-mNs on wcupa nal m on protection in Chapter 7.

disposal unit stabilization: Chapters 3 and 5 NLIRIIG-1388 states that the major objectises of an buffer zone: Chapter 3 operational environmental momtormg program are to De review of an actuallicer'se applicatkm would be (1) demonstrate compliance with applicable standards, i

facilitated if the apphcant provided in Section 4.3.4, (2) obtain data on critical pathway parameters to allow at a minimum, a summary of the aforementioned more accurate evaluation of radiation dose to the general 21 NURiiG-!375, Vol. 2

l public, and (3) provide secords for public information.

2.4.2.3.2) are monitormg areas that should also be Specific considerations in designing an operational moni-considered durmg the operational phase. In addi-toring program should incluJe a radiological pathway tion, ndose mne moniloting with the suction analysis, identification of critical radionuclides, and ac-lysimeters (I igure 2.9-1)is not discussed. l'inally,to tion tevels for sampled media to provide cally warnmg of determine if the site is performing as predicted, releases. The monitoring program should be designed those aspects of preoperational environmental t

and operated under a quality assurance!quahty control monitoring related to perfonnance assessment program.

should be continued.

A In an actual license application, information sunilar to Additions to the preoperational monitonng pro-that in the PLASAR would need to be modtfied to dem.

gram arc included in the effluem monitoring and onstrate that a detailed radiological pathway analysis was site waltos ers; how ever, no information on location conducted and used to design the environmental moni.

or frequency of this aJJitional monitoring is pro-toring prograin. This would include a discussion of how vided.

environmental monitoring would be used to demonstrae compliance with applicabie standards.

(c) In the Pl.AS AR, effluent monitonng is incluJed un4 der the environmental monimring program Smee Comment 36: Section 4.4.1 (p. 4-18) effluent inonianiag inpuiricaugquired under 10 CFR 61.12(k), this type of momtonng should also be The PLASAR states that organizational infortnation on addressed in Section 7.3.

responsibilities and qualifications of monitanng person-Comment 38: Seetion 4.4.4 (p. 4-20) nelis given in Section 2.9. Pl.ASAR Section 2.9 refers to Chapter 8; however, Chapter S is not developed in the NURl!G-135S on juge 8 presides cuidance on an appli.

Pl.ASAR. The staff, therefore. cannot evaluate the or-cant's quahts assurance /qtuhty co'nnol (Q A/QC) pro-ganization. In an actuallicense application, details of the gram and indicates that a O A>QC program is neeJed f or organizational structure shoulJ be provided, incluJmg tr.e followmg reasont (1) to identify persomel response (1) levels of organiational structure. (2) responsibility ble for dehciencies in the sampline, and caeasuremcot and reporting requirements for each umt, (3) personnel processes so that correctise action c$n be taken and (2)to quahfication and (4) review procedures for momtermp provide a measure of e mfiJence in monitonng programs, results' in order to assure r egulatory agencies and the pubhe that monitoring results m e valiJ.

Comment 37: Sect,mn 4.4.a, (p. 4-18)

The design of a Q A program 1or an environmental morn-(a).I'he PLAS AR does not provide enough information toring program should take the following factors mio ac-on preoperational environmental monitoring to ad-couni: (1) the quahty of equipment a'nd instruments, dress the requests for ;nformation and review que" (2) trainmg and espenence of personnel, (3) senheation tions contained in SRP 2.9Jlherefore, the staff can-of procedures by routme anahsis of control samples and

~

not evaluate the overall acceptability of those the use of stan'dard anahsis methoJs, (4) frequency of

~

aspects of the preoperational environmental moni-calibration and maintenance of equipment and instru.

tonng program carried over into the operational en-ments,(5)need for traceabihtv of momtoring program re-vtronmental monitonng and surveillance propram of sults to a national standard and <b) degree of documenta-Section 4 A.

tion needed to demonstrate that required quahty wdl be (b) Section 4.4 of NUREG-il99 states tnat any rnadtfi-canons to the preoperational moratonng plan for QC applies to all steps of a monitanng program. 'lhese onsite and offsite environmental momtoring should steps mclude sampling procedures, precautions to be be thoroughly dhcussed and justified. The opera-taken in transport of samples, mitial phmeal or chemical tional monitoring plan desenbed in the PLASAR pceparation, radiochemical sepatation, measurement of st;.tes that the preoperational monitoring ptogram activity, data interptetation, reporting. and recordkeep-described in Section 2.9 will be continued throagh-mg out the operational phaseflhe Pl.AS AR is not clcar about the continuation of preoperational environ-In the PI AS AR, the only momtoring eqmpment hoted is mental marutonng dtscusscJ in other sections of in the general hst contamed in Section 2.4 (p. 2-141).

Chapter 2. Meteorological monitormg (Secuon Other than a statement that con cet umts will be used and 2.2.2.1), stream gaugmg (Section 2A.I.1), water ta-that data wdl be stored on a computer no information on b!e elevations iSecuons 2 A.2.2.3.3 and 2 A.2.3.2),

monitonng procedures is given in the Pl.ASAR. Raw tensiometer (tens on head patenhal)and water con-data wheeted danng the preoperational momtoring tent measurements in the vadose zone (Sectior, phase. saleuiations perf ormed, and the fmal values NUREG-1375 Vol 2 22

i recorded should be presented m an SAltflhere is a com-bciently stable to prosiJe the required long-term stabil.

mitment in PLAS AR Section 4.4.4 to participate in inter-ity. Comments addressmg this aspect of the design and ac-laboratory programs of sampic analysis. In an actual ecptable methods of reselution m e pmvided in Comment license application, specific details would need to be 71.

given.

Comment 41: Section 5.1.2.1 (p. 5-2)

Comment 39: Section 4.4.5 (p. 4-20)

'the maximum allowable ddferential settlement is g.iven d 'lhe PLASAR indicates that under the environ-as 1.5 percent of the total cover thicknessJlhe rationale mental monitoring program water could be sampled and justification for this value are unclear.The emer will in the unsaturated tone as wc!! as the satmated consist of both clay and gravelly materialsflhe settlement zone. Sampling in the unsaturated tone can be a dtf-of the gravelly material could take place immediately, ftcult task, and the method that is intenJed to be whereas the settlement of the clay would tend to be time used should be elaborated on in an SAR.

dependentJiherefore, the inaximum allowable differen-tial settlement for the coser should be a function of the (h) To provide an early warning of operational releases thicknessof the claylayer. iktimatesof the allowabled:f-so that mitigating measures can be taken m a timely ferential settlements should be based on the thickness of manner, meaningful action lesels should be set for the clay layer and total settlement considerations, as well key environmentel media. In the P1 ASAR, action as the areal dimensions of the vault and cover. Gtudance levels are set at two standard deviations above mean on the issues to be addressed in minimDing differential background, and no statistic;d or technical basis is

. settlements of waste cmcr systems can be fetmd in Vol-given. NURl!G-13SS on page 8 recommenJs that umes 1 and 2 of NURl!G/CR-5432, action levels be set at two levels: the inggeling level and the reporting level. The triggeting level should Comment 42: Section 5.1.2.2 (p. 5-3) be set, based on a fraction of applicable dose hmit The statement in the last sentence of the first paragraph standards or taultipes of ba:kground, so that, if it is exceeded, an investigation bj the licensee would be on page 5-3,"I ield tests of the dramage system and dis-required. The reportmg level is set at or near appli_

pyd unit cosers ate yet to be conducted, is not clear.

cable standards, and, if exceeded, the licensee is re.

I unher exp!jmation and chnheation of this item would quired to report immediately to the reputaton be espected m an actual heense apphcation.

authority the results of monitoring, investigations Comment 43: Sect. ion 3.2.1 (p. 3-3) and findmgs, and mitigating measures taken to cor.

rect the problem, Details of potential mitigating ac-(a) The PI ASAR indicates that a cover setdement tions and a commitment to reporting should be pro ~

monitor g etem will be used independently of a uded in an actual beense application, mise'Jemem momtonng system, so that dfferen-tial settlements between the cover and vault can be 5

SITE CLOSURE PLAN AND det" mined Detad ^ on Sheet S of 13 m ^ Prenda f ounded on the top o! the 6-m? P*""'

'h"' *i" h*

9 P*"*' 'h' d"8" "I th 1NSTITUTIONAL CONTROLS

• ch s.md layer that wili be above the 3 foot clay layer.

Comment 40: Sect,mn 3.1.1 (p. 3-1) the discussion of monitors in Section 3.2.1 refers to Section 5.1.1 of the PLAS AR indicates that sheet erosion

- et of m Appen W

wm, et W has been considered and that the covers will be adequate es n ow can n o a cova momtodut for a 1500-year period. 'Ihe rate of soilloss was computed onh shows Rose monnonng &sn founded at the using the Universal Soil less Equation (USLli). This U"*

method af analysis is not considered adequate to assess mm monne am not d6M in tM i WR in the long-term stabihty of the site for this period of time, an actual knm apphcation, such infoimation since it does not take into account gully crosion resultmg o e pnMded. It would appear that the wo n

from severe rainfall events. Additionalanalyses would be mm numdors would have to be pheed near the needed in an actual lietnse application to demonstrate t M dmm nmmtm, but m gnnah k that the proposed soilcovers for the llGV facihty are suf-intent and use of the mwitormg records are not well defmed in the PLASAR.

' Prepared by' terry Johnwnaennr sutbce w:oer hydnest ascenon 5.1.1tuanad Japonaih, peotechracat enoncer (seciu m 5.t A 11 ts also not clear ahat parameter (s) wdl be tr,oni-Robert Shewmaker,w mot stiochnal enencer tscenon sf.'t and lit-toted mmy the mver settlement monitoring system.

maid Shum. senu ir envuonme ntal engmcer. and I red i< ow hydnget@t (Snhon 3 4 Includes commtnu imm SNI., Wii other than vertical elesation. Smcc the settlement and berh Eanc. semor cad ensnen of the 24 inch by 24 mch beanng surface on the 23 NUREG-1375, Vol 2

pedestal cannot be assumed to remain horizontal ment pipe with an inside dmmeter of 8 inches, pro-during any possible settlement of the cover,it is not viJes only a M-inch vertical gap between the monu-clear from the PLASAR discussions how the rota-ment stainless steel top plate and the upper end or tional movement will be tnonitored in order to be shoulder of the ecment pipe At the bottom end of able to define the vertical settlement occuning bc-the approximately 7% foot-long standpipe, there is neath the pedestal.The staff notes that the pedestal no connection to the vault teof, since the pipe end is will be surrounded by granular and fine soil materi-shown to rest on the waterproofing membrane.

als in the final cover, over approximately a 2-foot 8-inch length of its height, Because of this lateral

'this monitonng installation configuration could confmement provided by the surroundmg matenals, limit the cf fective vertical mevement to M inch, if skin friction could develop and the pedestal might the standpipe or sleese remained bound to the con-not be able to move independently either sertically fining 7X-foot long column el cover soil. If the or in a rotational mc.de. 'this potential developmen't Sinch magmtude of settlement were to occur, the monitor's vertical element would become a load-and impact on settlement readines would need to be addressed in an actual bcense appheation.

canymg tensile member, which is undesirable for this settlemsnt measuring device. This value of M In addition to the above ccmments, the PLASAR inch for vertical movement appears to be too limit-does not addren the following topics for the coser ing. and in the review of an actual license applica-tion, this detail would r ced to be resolved.

settlement monitoring system; e vauh w

mmt mmer mcp as pm the frequency and duration of the settlement senteJ is uncicar as to how the cement standpipe or e

monitorina activities sleeve would be isolated from the vault roof so that it the procedures to be followed in evaluating the would not interact with the vertical element of the e

monitoring data monitor and cause erroneous readings of move-ment. 'lhe erroneous readmps could result from tbc establishment of limiting values for the translation of the stanJpipe or sleeve, as well as o

monitored parameters and the bases for them rnos ement ti a w ould rotate it into a r.onvertical po-sition. The PIASAP also indicates that limite have the experience and qualification requirements e

of the personnel responsible for obtaining, been set as design critena for the monitoring system evaluatine, and responJmp to the swnificance to record pure translational movements, although of the data the Hmits are not defined Design hmttations for the the applicant's plan for corrective action or re-e placement of defective or moperative monitor-Detail B on Sheet 5 does not indicate whether the ing mstallanons Efoot-long by 8-inch-inside diameter cement standpipe will be one section without jomts, or the remedtai action procedures to be followed whether jomts will be necessary.

o when limiting values are exceeded opm annulu space wun the wnd &

'the aforementioned informatian, which is iJenti-mmt Mie monhor and the cement sleeve pipe is a fied in NUR11G-1199, Section 5.l A. would be ex-

"F"

• C U "' * "

S pected to be furnished in an SAR.

water, could accumulate and begin a downwarJ at-(b) Detail B en Sheet 5 of 13 in Appendix B does not grouting forclosure. I he staff notes that thc spectf.c

' provide for a water stop rmg or a deterrent to pre-detail of the vaterproofing at the base of the 4-inch-scnt water from flowmg along the periphery of the (hameter standard pipe is not provided at the bottom outer cement pipe sleeve for the vault roof settle-of the annular space on Sheet 5.

ment monitor, in the zone where the clay layer is pencuatei '!him m contrast to the watet stop rinf in addition to the informadon provided for the vault that is shown in Detail D on Sheet 5 for the well roof settlement, an actuallicensc application should monitoring device. In the review of an actuallicense address (Fe followmg:

appheation, the staff would question the basis for typical installation procedures to adJt ess not instalhng a deterrent to vertical water flow e

around the vault.oof momtor-w hether the momtoring element.; and the asso-ciated cement standptpes or sleeves are to be (c) Detail B on Sheet 5 of D in Appendix H provides the budt in sections as the fill m placed in vertical configurauon of the vault roof settlement momtor layers, or whether the momtors are to be free-device. The standpipe or outer sleeve, which is a cc-standmg as the fdt is placed NURl!G-1375. Vot 1 N

I procedures for evaluating the data and obser-(g) Sheet 10 of 13 in Appenda 11 indicates that strain /

a vations stress meter wire conduits will be located at two po-sitions on a Class A vault and at one position on a frequency of data collection, followed by the Claas ll/C vault. Section 5.2.1,' Structural Perform-e procedures to be used in data reduction, evalu-ance Monitoring." does not adJtess the use of stsess ation, and followup recommendations or strain metering devices. Although a brief sum-mary paragraph on stress 4 train rnonitoring is pro-limiting values of the measured parameters vided in Section 3.1.2 of the Pl ASAR, the mforma-e and the basis for their establishment tion is sery general.

(d) Sheet 5 of 13 in Appendix Il shows that the stand-On the basis of the information in the PI ASAR, the pipe or pipe sleeve that will house the vault roof set-staff can conclude that there is an intent to provide llement monitor is to be constructed of a cement (i) some solid. state resistance-type strain gauges pipe with %-inch-thick walls. Section 5.2.1 of the that will measure stmin in concrete elements and (ii)

PI ASAR does not define the design senice hfe of stress measurements on designated high stress ar-the structural monitoring system; the staff, there-cas on the free faces of conctete. Ilowever, it is not fore, cannot assess the adequacy of the relatiscly clear f rom the one manhole location shown for each thin protective pipe against the in-ground conditions clast, vault on Sheet 10 of 13 in Appenda 11 whether above the vault and their effect on the vault. In an the hications of the strain / stress meter wne conduits actual license application, this concern about the and the pmition of the monitoring manhole are re-adequacy and durability of the structural monitoring lated or not. Section 3.1.2 raates that manhole access system would need to be resolved.

will be provided to the points when instruments at e applied to minimize the length of lead wires to the recording / readout instrument;. Information in the (c) Section 5.2.1 of the PLASAR indicates that for the PLAS AR t ext and the drawings on how the lead wire Class A disposal vaults, one vault roof settlement lengths will be minimized appears to be inconsistent.

monitor wtil be placed over the center of each roof segment, and that for the Class ll/C disposal vaults, AdJ;tionally, if the manholes are to be actually lo-a similar monitor will be placed oser the center of cated as indicated in the PLAS AR, directly adjacent each cell roof. Sheet 10 of 13 in Appendix 11 shows a to an estwier wall of the vault where the strew or different geometrical layout and location of the otrain measurements are to be made, it is not clear monitors. In an actuallicense application this dw why the resulting measured values would be repre-crepancy would need to be rerolved, sen'taa 3ince the vertcal cylindrical manhole structure would provide load relief for the adjacent (f) The capabilities of the structural monitoringdevicer, wall by reacting to the soil lateral loads, the actual vaku's of wall stresses and strains would be masked.

for deflection and settlement, as presented in the PLAS AR, are inadequate to define several parame-

,De staff considers that tne imormation in the ters that are considered necessary to assess the structural stabi!ity of individual vaults m the llGV PI AS AR on the application of stress / strain meters for structtral momtormg of the two types of vaults is system.The monitoring presented doer not have the capability to determine whether an observed sett!c, inadequate.. As recommended in NUREG-l199, the followmg information should be provided in an ment is the result of the foundation materials be-neath the base slabs of the vaults or w hether there is actual hcense application to permit assessment of an actual loss in structural capability of the vault.

the proposed monitoring:

Tljere is also no way to determine the actual dMh& nd ismqpnd h e

mtdspan deflection of a sault roof, that is, its post-tion relative to the position of the roof slab cdge sup-Jescription of the scope of the monitoring that ports (the vault walls). Translational and rotational e

movements of the vaults are also not adequz.tely ad-would clearly discuss the intent and goals of the drassed in the proposed structural monitodng pro-monitoring program E**'

identification of the actual parameters to be e

monitored in an actual license application, it wuuld be neces-al immilation details and installation pro-e sary to more adequately address the issues identified cedures for each type of instrument above, so that the potential movements of each frequency and duration cf the proposed moni-llGV could be monitored and the results evaluated e

relative to actual structural performance.

tormg 25 N Ukl!G-!375, Vol. 2

plans for correcting or replacing inoperative in.

provided in Section 2.4.7 of NUREG/CR-5432, e

struments Volume 3.

procedures for evaluating recorded data and Comment 44: Section 5.2,2 (p. 5-4) o observations (a) The PIASAR indicates in Chapter 115 (p.11-118) established limiting values of the measured pa' that 4. inch-diameter pipes will be used for the pip-e rameters and the basis for their establishment ing in the percolating water drainage system. It also indicates that the vault cell floor drains and the sec-g remedial action procedures to be followed re, e

lated to the llGV structures, based on evalu.

ondary drains that penetrate the cell walls will be fit, ted with screens.

ation of the recorded data experience and qualification requirements for The PIASAR is deficient in that only limited infor.

e pers(mnet involved in the observation and mation, such as the reference standards and test evaluation of data methods,is provided on the proposed materials. An evaluation of the materials' performance over (h) The P!ASAR does not discuss or provide any ra-the life of the facility, including tesistance to corro-tionale for omitting the monitoring of the move-sion, bacteriological clogging, and encrustation, is ments of the concrete vault walls. These movements needed. Also, no discussion or information is pro-could be vertical, horizontal, rotational, or any com-vided on measures that could be taken to restore ef-

~s bination thereof. In addition, the PI AS AR provides fective drainage capability, A standard is referenced no information on the basis for omitting the moni-in Section A5.6.3 (p. A-68) regardmg a recom-toring of differential movement across the construc-mended practice for making solvent ccment joints tion and expansion joints that separate units oi nine for PVC pipe, yet no PVC pmc standard is ref-cells in a Class A vault or units of three cells in a crenced. Whcie a thermosetting resin pipe is noted Class II/C vault. The movements of these joints in the standards in Appendix A (p. A-68), testing the could be both horizontal and vertical and could also material for chemical resista ce under ASTM include rotational movement.

D36S1 is not indicated.

In an actuallicense application, the applicant would (b) The Pl.AS AR provides a general description in Sec-be expected to address these elements of the llGV tion 3.1.6 (p.3-?O)of the granular materials that will and if this type of instrumentation were not to be be used in the construction of the llGV, including provided, te give the basis for its omission.

those associated viith the percolating water drainage system. It, however, does not include details related (i) Although Section 3.1.6 of the PIASAR indicates to the testing of the granular materials for gradation, that water collected in the perco!ating water drain.

durability, compaction, and other engineering pmp-age system will be monitored for radioactive con.

uties that are necessary for the initial qualification taminants and the contaminants will be actively rc of materials, as well as the basis for their control and moved, there is no discussion in the PI ASAR on acceptance during field construction, how the collected liquid would be sampled and r

Comment 45: Sect, ion 5.4 (p. 5-10) tested.

Section 5.3 of NURiiG-1 IW states that a license applica-In addhion, the operations that would be completed tion should describe how a postoperational environ-to remove the radioactive contaminants are not de-mental monitonng and surveillance program will be used scribed in the PIAS AR. In an actual license appli-to demonst rate that t he sue is stable and ready for institu.

canon, the applicant would be expected to provide tional control. In an actual becnse application, the follow, the details and procedures for the sampling and test-mg information should be provided: (1) how the physical ing of the collected liquid and removal of contami-and chemicci characteristics of the waste inventory are re-nams.

flected in the design of the monitoring program,(2) how well the mathematical models used to estimate radio-ne PLASAR also does not provide sufficient de-miclide concentrations in various media are confirmed by tails on the installation procedures for the subsur-the results of monitoring measurements, (3) reasons for face drainage sump monitoring wells.1 or example, any differences between operational and postoperational it is unclear whether the standpipes would be in-monitoring plans,(4) the statistical method for differenti-stalled at one time, for their nearly 35-foot height.or ating between measured and background concentrations, whether the installation would be meremetaally (5) pngram emphasis on monitoring radionuclides that completed as backfilling around the vaults proceeds.

are poorly retarded in the soil.(h)a discussion of the use Guidance for seahng and extending nser pipes is of highly sensitive and in situ senmrs that telemeter data NURl!G-1375, Vol. 2 26

---.. --~.- - - -

to r central analysis station, and (7) qualibcations of the

- ment percentage of uraniurn-23% in the waste, people who will implement the program, if they are dif-These concerns are further discussed in the review ferent from those employed during the operational comments for subsequent' sections of Pl ASAlt phase.

Chapter 6.

P flecause there are no operational and postoperational (c) Section A33 of the Pl.ASAR (p. A-25) cites the data for the hypothetical llGV site, most of the afore-waste acceptance criteria of 10 Cl 11 til.56 as proviJ.

mentioned items are treated in limited detail in the ing the limitations on the waste torms allowed into P! ASAR. In an actuallicense application, the following the facility. In an actual license application. the ap-items should be described in greater detali: (1) how the plicant would be expected to discuss all such limita-physical and chemical characteristics of the waste are re.

tions,if proposed and relevant to the proposed de-flected in the monitoring program, (2) how well predic-sign.

tions of performance assessment models are validated by previous monitoring data, (3) the statistical basis for dif.

(d) PI ASAR Section A3.S (p. A-25) states that the an-nual ute volumes and characteristics are assumed ferentiating between background and measured concen.

trations, and (4) qualifications and training of personnel to remain constant over the operaung life of the fa-conducting monitoring activitica edity. On the basis of past trends, this assumption seems unlikely to be realized in an actual facility. In an actual license application, the applicant would be 6

SAFETY ASSESSMENT

• expected to provide information supporting what-ever predicuans are made regarding future waste Comment 46: Section 6.1.1 (p,6-1) volumes and characteristics.

(a) PI AS All Section 6.1.1 defers virtually all discussion (c) Althcugh source term volumes and radionuclide on waste inventory to Appendix A and Supporting concentrations are based on " actual data," as devel.

Information Package 1. An actual license apphea-oped in the environmental impact statement con-tion would be expected to, at a minimum, provide a cerning nuclear waste originating at nuclear waste summary table in the main body of the SAR that cenerators, the source t erm is, nevertheless, generic summari/es information for each of the major areas

[md represents typical low-level radioactive waste-identified in SRP 6.1.1 (p. 6J.1-3). Ihamples of the llecause of the hypothetical nature of the Pi ASAR, majorareasinclude (i)the identification of the waste this is an acceptable approach. An actual license ap-streams and information on the physical, chemical, plication would, however. be expected to include a and radiological haractenstics of each waste smvey of u aste inventory from the actual waste pen-stream; (ii) annual volumes and estimated future crators that would he beensed to use the disposal trends of the waste streams; and (iii)information on

sjic, the waste generators and any limits imposed on waste receipt.

Conunent 47: Section 6.1.2 (p. 6-2)

When referentng an appendix or support informa.

(a) Section 6.L2 of NUlWG-1199 states that an infil-tion, an actual license application would be helpful if tration analysis should contain a description of the j,

it identified the specific scetion(s) or page(s) where conceptual modelfanMytical or numerical methods the referenced information could be found. This used, boundary conditions, assumptions, governing would greatly facilitate the technicid review, equations, mid all data used to estimate infiltration.

Results should be in a format of flux per annum, (b) There are staff concerns regarding the selection and length of time between deepinfiltration events,and

- concentrations of several radionuclides, listed in Ta.

Jones of potentially high percolation.

- ble A3-2, that include the omission of uranium-234 from the waste streams and the possible omission of This information is not provided in the PLASAR.

additional neptunium-237 concentrations from the.

The PI ASAR in Section 6J.2 states that the IELP in growth of americium-241. Uranium-234 should model was used to evaluate the percolation of water be included and adjusted on the basis of the enrich.

through the vault covers and tnrough the undis-turbed portions of the site. The UNSAT-il model was used to calculate the soil moisture as a function

• Prepared by Keith hicDaniel. nuclear engineer (Sectv m 6.1.1); Fred of depth beneath the surface. No information is pro-Rces, hydrogeokpst (Sechon 6.1.2); Edward Shum, scrdor ensirun-Vided on the relationshi) betwecn the 1IfiLP and I

mental engmcer. and Fred Row (Scenons 6.1.3,61 A 61.54 and 6,1.0); Derek Walmayer, cM engineer, and Robert Shewmaker.sen, UNSAT41 codes, or on why two separate water ior structural engineer (Section 6.2r. Tcny Johnsot. semor sutface budget codes were needed. No information is pro-water hydroket (Section b 11) and flanad hgannath.geotechmcal vided on model Vahdation to I'ustify the use of the engineer (Sechons 612 and 6 3 3) Indades comments from r Gh and SNI I EhP code.

27 NURiiG-1375, Vol. 2

1 l

The 11111 P code makes several simphfications that should be considered in inidtration analyses. l'or are questionable or ar e tused on highly empirical ie, long-term predictions of mfduation, elfccts of cro-lationships. The PI ASAR should demonstrate that sion, burrowing ammals, and plant ecology should these simplifying assumptions are consenathe.

also be consiJered. major cos er repair should not be These assumptions include (i) 7ero hydraube con-assurned af ter the start of the actise institutional ductivity at "lield capacity"; (ii) a linear relationship control perial.

between conductwiry and water content:(ui) PliT as a function of solar radiation only, as opposbd to tbc MAR Table 6.1-7 (p. 6-13) gaes radionuclide parameters of the " unmodified Penman equation-piaw yab for the alwl unnmer time. In an

)

(soil heat flus vapor density, wind speed, air tem-auual base appheahon, n would be necessary to perature, net radiation, and sensible heat flud (iv) pawMe @ the mtegrated release of entical rathonu-use of a runoff number;(Oscaling of PliT with I Al; chJes with respect to total ins entory and (ii)detaded and (vi) LAI relation. ships and rootinn depths and puh,'atMn wh onjy s radamuchh an' dan as density.

enucal rahmuchJos.1:urtherrnore, the origin of neptunium-237 is not clear. If neptunium-237 (b) The PLASAR in Section 6.1.2 states that coser sys.

comes from the decay of ameriemm-241, then Tahic tems are designed to minimize percolanon of water h I-7 shoulJ also hst ameriaum-241 as a Ley through the disposal urats. Water infdtratmg the up.

rahmuchde,andTable A3-2 in AppenJis A should per coser lavers will be directed away from the dis.

be adjusted to account for the m-growth of posal units b'v eover las errg of low-permeabihty and neptunium-237. A detailed release mecharnsm for drainage soils. In addition to the coser system. the neptunium-237 should be included in the analpis.

vaults wdl be topped with mosture barriers consist.

Hem the pround uater pathway code includes ing of two lasers of tml cual tar for the Class A da-daghter pmJucts americium-241 shoalJ be hsted posal units, and three layers of hot coal tar and hvo in TaHe h 1-7.

impermeable memb anes fo-the Class il/C doposal Coinment 48: Seelion 6.1.3 (p. 6-5) tmits. These moisture bamers wdl be topped by a lower coser dramage layer to conduct infdtration Sectun 6.1.3 (p.6-5)of the 11 ASAR mJicates that naid away from vault nofs to the French drains.

chng of the IRW facility for release of radionnehdes was for a perns.1 of approdmately RK)0 y cars beyond the estu The Pl.ASAR in Section 6.1.2 (p. 6-2) states that mated fadure time of the concrete vaults Smee the vault two components of deep percolation are iJentified:

hfetunes were calcula;cd to be up to 1220 and 1421)) eats percolation through the uncovereJ portmns of the for ine C! ass A and Class li'C saults, respectively, tlus e.

site and percolation through the covers anJ dnpasal sults in a period of analpes o! 2500 years, units, Anahses of deep percolation through natural soils (18inj rh through the Class A waste cover su-The hau, for selecting the IbOO yeais bgond the oli.

y tem (10 in./yr), and through the Class IliC waste makd fadun ame of the conmu mb B not diwusscJ cover system (1.5 in./yr) are desenbed. llecause the in the PI AS AR.The NRC staf f anticipates that, m an ae vault roofs and moisture barners do not appear to be tua! heense appWauon, funne unanmwould be consid -

included as pan of the cover splem, the Pl ASAR is cred and performance acessments performed suffu unclear about how much cover percolation actually ciently long enough into the future to demonstrate that nmu un da ram wouM not meed reputatoiy hnuts.

enters and percolates through the thspos;d units to the water table. Furthermore, no disp'osal unit pet.

k a ownw appNanon, plots of Ju me versus time colation values are specifically identtfied in the wouM N um uMut to graphically portray the actual analyses of infiltration or in the'analvsn of releases trends and aid in the regulatory evaluauon of the maxi.

to t'he ground water pathway (PLhSAR Section mum dm rate 6.1.3.1). NURF.G-Il94 in Section 6.1.2 states that Comment 4% Section 6.1.3.1 (p. 6-5) for predteting ground water mass transport of radm.

nuclides from the dispmal sne, an applicant shoulJ The Pi ASAlfs deserirtion ar J assessment of rado.

estimate volumes of water enterme the waste h nuchde releases to the pround water pathway can be im.

pos;d umts.

proved because (1) htile information is provided to justify the conceptual model and assumptions goverrung the (c) Infiltration anal)se.s presemed in the Pl.AS AR ap-analyus;(2) no Jusufication for the mput data is prodded, pear to be based on mean monthly precipitahon val.

such as the radmnuclide di!fouon teach rates or the sorp.

ues. Extreme precipitation events and long. term tion equihbnum leach rates:(3) no considera"on is pn en predictions of cover performance are not consd to the possible efleus of thelaung apents or other mecha-cred. SR P 6J.2 states that temporal distnbutions of nisms that may enhance ic! case rates; anJ (4) rio analpis probable rainfall c',ents, incluJmp de 4en-basis of the percolatun acto dly entenng and leaving the ihs-events such as Probable M comurn Precipnapon, posa! units o prouded (see ('ommern 47thh NURiiG-1375. Vol. 2 28

Comment 50: Section 6.1.3.2 (p. 6-14) natio, tclease estimates and event frequencies should be generated that are reasonable,yet conservative. Informa-In the PI ASAlt, operational spdlage of unconsolidated hon n also needcJ on the quantification of the source Class A waste is identified as the major mode of atmo-term for cath scenario and pathway, spheric release it is assumed that a 10J fraction of the Class A waste inventory is released to the atmosphere,

'ihe Pl ASAll discusses an adequate spectrum of acci-but no support is provided for the selection of this calne.

dents, and the scenario probabihties ate casonable, in Section 4.4 of the PI ASAll (p. 4-IS). Other impor tant Ilowever, some of the accident consequences appear op-modes of atmospheric releases are identified, such as di-timistic, and no suppot! for the acciJent assumptions is rect releases from incoming vehicics, waste cimtainers, provided. l'or instance, the decontaminauon und storare and handling equipment. that are tot evaluated. Modes room fire scenario assumes that one twn of Class A waste of atmospherie releases, such as those iJentified in Table is burned and released through the sentilation system, 6.1 of NUIEG-1199, also are not considered without jus-and that the high efficieng particulate aii (ill!PA)h1ter tification.

is desnoyed by fite, llecause it would take a substantial hre todestroy the 1iliPA filterimd the ventilation system.

An actual license application should include an evalu-for this type of scenano the consequences of other bines ation of the vanous modes of atmospherie r eleases identi-of waste m the stotape area being burned and the noten-fied in Table 6.1 of NLl&G-1149 and justtheation that tial teleases s'aould be considered.

the source term esumates are conservative. An actualli-cense application should describe how the proposed

(?omment 54: Section 6.1.5.1 (p. 6-28) effluent and environmental momtoring programs wil!

provide assurance that the predicted releases are insig.

On The total annual inventory of amenemm-2 tl and nificant.

neptunium-227, as indicated in Pl ASAll Tahle AL2 of Appenda A, is about 1.1 (uties and 1.4 i 10 7curi, respectnely. Itecause the imualins ento 9 Comment 51: Section 6.1.33 (p. 6-14) of americiuw241 istrders of marmtude larper than In the PI ASAlt, Class A waste-contanunated surface that of neptunium 237, the PI AS All shotdd ex.

runo3 and contronmated pronnJ water are identified as plain why ameneium-241 is not considered in Tah!c two modes of releases to the surface v.ater pathway.

h.1-7 as part of the inventory of teleases from the Other modes of surface water contamination idenafied m dnpmal unns (aho see Comment 47(d4 In an actual Section 6.1 of NUIEG-1199 are not addressed.

license apphcation, there should be a det;uled on-cussion af the key parameters and their transtwnt Other operanonal releases to surface water, such as sur.

mechanisms in pound water, and on raJioactive de face runoff from rain-washed contammated ec.ntamers cay and mventon changes, to provide explanations aad equipment surfacer, contaminated sanitary waste that are important, such as for the behaviot of containing laundty water, and contaminated water that neptunium-237 and americium-241 during ground has been treated should be consider ed in an actual license watet transport.

apphcation. listimates should then be checked by the op-erational effluent monitoring to ensure that the surface PI ASAllTable h.1-14 should include maumum or, water source term prediction u reasonably accurate, pan dose to demonstrate compliance with 10 CI R 61.41. The major concern is for carbon-14. Ab Comment 52: Section 6,13.4 (p. 6-151 though the effectise whole-body equivalent dose of 13 mremlyr is lulo.v the 25-rmemlyr wholobal)

The PLASAR discusses the use of thermoluminescent uose, the organ dese, such as the bone dose, may ex-dosimeter (ILD) badges to monitor workers. In add tion ceed the 25-mrem /> r organ dose. The same concern to TLD moni'oring of wmkers, NURF.G-1199 calls for exists for neptunium-237 and technetium-99 other external gamma monitoring, such as monitonng of waste-canymg trucks for contamination and momtonng (b) 'lhe Pi ASAlt's assessment of ground water trans-of site residual contamination. As stated m Section 7 of port contains msulficient information on how aqui-NUlWG-1199, the aforementioned information would fer dilu

) of radionuclides during transport be-be expected to be presided in the section on occupational tween t e site and the nearest offsite well is radiahon protection in an actual license application.

calculated. Independent corroh nation, based on the PI ASAll conceptual model cannot be per-Comment 53: Section 6.1.4 (p. 6-15) formed becau<e of insulheient informanun. Input parameters selmted for the transport analy sis.

Section 6.1.4 in NUlWG-1199 sugpests that a suite of ac-particularly for the unsaturated mne C ere no sue cident scenanos he identihed from which a number are data are mailable, me not supponed there are chosen as representative and boundmg.1 or each sce.

insufficient data in the PIASAR to suppor t 29 NURI E - 1375, Vol. 2

+

unsaturated rone ground water flow and transport litype atmosphene stabihty and wmdspeeds of 1 misce, modeling.

should be conadered.

Although the PLASAR states that longitudinal dis-Comment 56: Section 6.L5,3 (p. 6-43) persion occurs, no disperrion coefficients are re-ported, and it appears that dupersion is not consid.

The PLASAR does not provide the information recom-cred in the radionuclide tansport model. lleid mended in Section 6.1.5.3 of N URlL1199 on calculat-measurements of dispersivity would be required to ing raJionuchde conctntrations in surface water at hu-3 determine actual dilution of radionuchJes in the taan access locations. Speaficauy,(1) the theory used is aquifer dunng transport.

not described;(2) the conceptual model is not described, (3) moJet assumptions, hmitations, or uneettainties are Several waste distribution coeffiaent (Kd) values not addressed, and (4) model input data are not sup-are markedly different from the Kd values selected ported, in an actual beense appheatim, the appliamt for the surrbunding soil. No justification for these would be expected to proviJe this mformat;on, differences is given. Because doses from drinking well water appear to depend strongly on waste Kds, Comment 57: Section 6.L6 (p. 6-,17) greater justificanon for Ed values selected should be provided. An upper and lower bound evaluation, Section b.l.6 of NURIhllW provides guidance on tal-based on selected Kd valu es. that also conside rs vari.

lating radioingical effccts on man and on the orgawa-ations in Kds from waste heterogeneity, should be non of this mformation m an acceptable way. 'l ransfer performed.

nwdcls, analytical raetho<Js, and assoaated assumptions are evpected to be m accordance with NRC Regulatory Guide 1.109. Ibse conversion factors for esternal beta Hecause none of the key radionuchdes, except neptunium-237, are stronily retarded m the aqui-and gamma radiation should be in accordance with fer,it is reasonable to expect peak doses from Class NURl!G CR-1918 or equivalent; exposures due to in-B/C wastes to occur together. In the PI AS Alt, how.

haled and ingested radionuchJes should be based on in-t ern.umnal Comnwion on Rashological Protection ever, the peak concentration of iodme-129 at the nearest well occurs 820 years af ter tne Class H/C tICR P) Pubheauon 30. NURl!G - 1199 also calls for con.

sault fails, whereas peak concentratians of some ceptuM modebanJ exposure scenarios. Impacts from re-other key radionuclides occur much sooner. The leases are expected to be demonsuabh within appropri-PLASAR prosides no satisfactory explanation for ate ugulators enteria.

the longer iodine-129 travel ume.

The PI ASAd hsts only whole-body eqmvalen; doses.

Conunent 55: Section 6,1.5.2 (p. 6-36)

Dos es to other organs appear to have been calculated, but are not phen. There is no reference for the dose com er-Section 6.1.5.2 in NUREG-11W suggests that a descrip-sion factors listed in Pi ASAR Table 6.1-21 Ahhough tion of the mathematicd and numerical methods that are these factors are differem from the dose conversion fac-used in atmosphetic transfer calculations be prouded.

tors for inhalation found in NURI G!CR-0150, Volume Both routine and accidental releases should be analyzed.

3, uhich are based on ICRP Pubhcation 30, these 6ffer-Detailed guidelines are given for the types of data and ences are not discussed. No reference is given for gamma processes that should be reported. Spcofit guidelines are dose conven. ion factors; these factors are not taken from -

given for the locations where concentrations should be NUREG/CR-1918. 'the reported dose comersion fac-calculated.

tors are not hrked to specific organs, and consumpuon rates (PI ASAR Table 6.1-12, p. 6-30)are not conustent The theoretical bases for estimating at rnospherie releases with Regulatory Guide 1.109. To dernonstrate compli.

in the PI AS AR are documented by referenec only.Ther e ance wuh the 25.mremlyr regulatog limit t.10 CFR is no discussion of or justification for the assumptions ot 61 A 1), the maumum organ dose should be g:ven. Eva'u-parameters chosen. The PI AS AR is not clear about how ation of Ihe Pi ASAR dose data suggests that some organ the annual concentration of radionuclides is derived for doses, such as bone and thyroid doses. may has e exceded routine releases. The PI AS AR hsts only the x/O values, regulaton limits.

the fraction of inventory deposited on the ground (with-out any assumption on area source), and mass loading.

Comment 58' Section 6.2.1 (p. 6-59)

The release rate from accidents is not listed, and it s not clear if the same type of meteorological conditions used (a) Section 6.2.1 of the Pl ASAR contams three differ-for routine releasc apphes to accidental release. Because ent definitions of the term " failure" of the vault.

an objective of accident analyses is to determme the ne-Two defnntons are related to the loss of the vault's cessity for emergency planning, in an actual license apph-capability to sustain statin loads tmposed on it, while cation, more adverse meteorological condiuons, such as onr. is related to the tirnt aben tracks first penetrate NU REG-1375, Vol. 2 30 l

l the entire thickness of the concrete, allowing water staff would icview the results of long-term perform.mce to percolate into the waste. the stated vauh hfe in predictions by the D ARRii;R computer coJe wth cau-the PLASAR after detailed llARRIER computer non in an actual liceme application, code analysis appears to be related to the definiaon of fadure associated with the time when water will

'lhe stafl would attempt to supplement the analytical percolate into the waste. 'lhe definition of vault fad.

computer results wah a more traditional engineering ap-ute for the purposes of intruder protection should proach. This approach would indude -(l) desigmng and not be related to the ingress of percolating wc.ter constructing the proposed disposal structures to perti-into the waste. With respect to intruder prottction, nent budJing coJe requirements that would be consistent an actual license appheation should cicarly defme with accepted engmeeting and construction practice, vault failure related to the loss of the intruder barri-(2) requiring consuuction materials of high quahty and er's capabihty to prevent madvertent intrusion, durabihty characteristics, and Q) ensurmg that an overall quality assurance program would be properly impic-(b) Section 6.2.1 prosides a defimtion of the safety fac-mented to provide reasonabic confidencc of the long-tor for vault failure as the ratio of the concrete term safe performance of the dimosal facihty.

strength to the load imposed on the concretc.1his defirution is not appropriate for a structure com-Cominent 60:* Section 6.2.1 (p. 6-59)

[wed of several materials and formeJ as a umt of in the Pl.ASAR. the D ARRIE R comput er code is used to variour structural elements, because the propo3cd evaluate the depth of concretc degradation resultmg definit;on addresses only the concrete matenals and from umtact mth ground water containing sulfates. 'the does not reflect the interaction of different materi_

depth of degradation is used in projectmg hfe expectancy als and structural e!ctner.ts. A revised definition of of the concrete structurcs. Various parameters related to

" safety factor" for sault failure that states that "the

~

the chemical and physical composition of the ground safety factor is the ratio between the maximum load water and the concrete are used m the evaluation.

(or load related terms) that produces the defmed failure and the imtTosed load (or load-related

'* " U """ "I Ih' 'd"U" " D '

""" th C W

termsh" for the con [htion being evaluated or de-mne pawnders used in the D AN RIER coJe was fined, may be more appropnate.

dese!oped in the t;mted h,mgdom into an equation baseJ on emph usuus dsed nom bbmatog Comment 59: Section 6.2.1 (p. 6-59) tesung. Fne test program s origmal scope was to simulate the conditions that might be present where In the PLAS AR, the B ARRIER computer code is used to concr ete was buned in clay and was in contact with assess thelong-term performance of the proposed below.

ground concrete saults under conditions asumed for the ground water containmg sulfates. The projected BGV subsurface emironment.The staff and its consult-concentranon of su!f ates in the clay sod research en-nronment was expecteJ to be nearly equal to 0.02 ants have reviewed the information on the BARRIER mole /14 howewr, m order to accelerate the cifects code provided in the PLASAR and in supporting com.

of sulfates in testing, the concentrations were in-puter code documents. The BARRIER computer code represents a linked methodology of various aggressive creased by nearly a factor of 10. Data over a 5 ear 9

degradation mechanisms that are based on short-term penod were used in the formulation of the govern-empiricadly derived equadom that are used to predict the ing empirical equation. 'Ihe derived equation has also been verified again3t a single mass of concrete long term decradation of concrete.

buried in clay for over 40 years. The Pl.ASAR and its cited references contain several equations with The staff considers the B ARRIER computer code to be a tool to assess the sensitivity of impacts on the loading the same basic format, but adjusted for parameters such as water-cement ratio or the diffusion coeffi-capabi!ity and durability characteristics of remforced con.

cient of sulfate through concrete. Page 1129 of Ap-crete structures from mechamsms that can degrade concrete.The BARRIER code assumes each of the der-pendn E of the Pl.ASAR presents a formulation radatton mechanisms has been charactented on an equal that adjusts the depth of degradation based on a Im-car function of water-cement ratio, whereas Reler-basis. Ilowever, the sta!f recoenizes that the B ARRIER code has sigmficant limitations (e.g., it is based on a scar.

ence 4 of Volume I!!, Chapter 4 of the B ARRIER city of long-term performance data with regard to degra-

• commenu 60 throug h 70 reIvescnt 0:e statrs and us consutunince dation mechamsms) and large uncertainties (assumed on veihe wretni uie tARRll R tomputer cate It should be structural and matcrial property conditions, the synergis-n*J th.o the cramenn are romanly dureted at the structuialin-P"'#' '" # *"" "" ""

""4

'"P* * "" "^"" '"*d Inunp >rt p u hons of the tic effects of concurrent degradation mechanisms, etc.)

radionuchde contammani Icachuu; an that place bounds on the assurance that can reastmably be HAIOWR cute nic comments on ihr unous acpadanoo rnccha-

'""'"h"" C h " e * 'd M b"' '" c """c d *""* "I "# "" P

• developed from the predictions by the B ARRIER code tant c in mag the lung tenn p rtormance of conacte wetc dn-on long-term safe performance.1 or these reasons, the pa unetum.

31 NUREG-1375, Vol. 2

_-__m_

User's Manual, and its reference, I!!cctric Power An applicant atternpting to use the H AltR! lilt code Research Institute Report NP-5365S, provide a for-would be required to prmide the basis for the selec-mutation that is a function of the diflusion coeffi-tion of the diffusion coefficient, as well as the influ-cient.

encing parameters and the expected range of values, in an actual license application.

- It is not clear what basis is used in the Pl.ASAR to determme the loss of cross-secuan thickness, nor is

@ Volume IV of the Pl.ASAR indicates that two con-the relationship between these two formulations crete mix designs were used in the measurement of clear, although there is no doubt that some correla-concrete properties. llowever, these materials ap-tion does exist between diffusion porosity and water' parently differ from the ordinary Portland cement cement raho. The relationship, however, is not be-concretes that were used to develop the empirical lieved to be linear and is influenced by other formula for calculating the depth of degradation.

additional parameters. To better understand how The mixes proposed in Volume IV contain either the IIARRIER code works, these considerations nuerosilica (silica fume) or puolanic materials as edn.ixt ures."1hese materials w ould have an effect on would have to be addressed m an actual beense ap' plication.

the empirical relationship defined in the formula in which the water-cement ratio is used as a variable, (b) The development of the empirical relationships that Although there is some evidence in the concrete in-form the basis of the equations discussed in Com-dustry that supports the belief that the PI ASAR nd-ment 60(a) above was based on the depth of degra-ditives would improve the capability of the concrete i

dation of the concrete that was visually determined.

to endure sulfate exposures with less material loss, i

The depth of actual degradation is typically detect.

no specific documentation or discussion of this has able only by microscopic examination. Conse-been provided in the Pl.ASAR. In an actual license quently, the formulations based on visual determi-application, it would be necessary to justify the se-i nation will tend to underestimate the true depth of lection of proposed formulations and adJress the concrete degradation. In an actual license applica-potential loss of concrete cross < ction that could tion, this concern would need to be addressed either occur as the result of sulfate attad.

by providing additional information or by quantifv-ing the magnitude of the potential error, when only (e) In the Pl AS AR, a formula on page Ib29 of Appen, visual observations were made.

dix li is used to compute the depth of concrete deg-radation that will occur over the riesign life of the (c) The formulation for the depth of degradation that E*P"#

Y '*'""

U""

uses the diffusion coefficient for sulfate requires mg stM em a recommen to ok Ou' lod that this parameter be determined for the concrete section. As noted m the basic I LAS Alt-referenced material being used On the basis of the formula,the research work by Atkinson et al.(1984), the variabil.

depth of degradation can then be calculated. Table y

prektbns was expected to range over -

4-2 of Volume III of the pl.ASAR lists the value of 130 percent for the specific conditions that formed the diffusion coefficient for sulfate in concrete as 3 x the Nu4 of dut temno N M.AM h-10J cm4sec, but the source of this value is not pro-not address ths 130 percent band, nor does it ad-

- vided. There is great difficulty in determining the dress the specibe conditions and boundary etmdi--

tions r limits of applicability for the formulatmns.

diffusion coefficient for sulfate ions in concrete, be-

+

cause of the sulfates that are inherently present in An actuailicense application would be expected to Portland cement concrete, and the resultant diffi

-culty in identifying the source of the ion (i.e.'

address the 130-percent variability range that was noted by the authors of the original formulation.

- whether it is inberent or is a migrant ion from an ex-

_ternal source). A study (Spinks et at,1952). which (f) The Pl.ASAR proposes the use of a Type II cement

.was conducted using radioactive tracers. provides modified by a 15 percent by weight addition of silica

. some values for the diffusion coefficient for sulfate; fume (microsilica). It states that the basis for the use l

The values determined for diffusior> in cement mor-of the microsilica isa numberof studies that have in-e tars for sulfate ranged from 6.1 x 10M to 3.5 x 105 dicated that concretes formulated with silica fume em4sec. The diffusion coefficient for sulfate ions have resulted in concretes with improved (lower) willvary nonlinearly with the water.ccment ratio, clues for permeability. The PI AS AR does not pro-since the ratio has an influence on the pore structure vide a similar basis for use of the proposed additives of the hardened cement paste of the concrete.

from the standpoint of theimpact of silica fume on

-Other parameters also have an influence on the the durability of concrete. Information available in pore structure, such as the variousadditis es that may the concrete industry indicates that concretes for-he used with the basic Portland cement.

mutated with microsilica exhibit an impaired NURl!G-1375, Vol 2 32

resistance to magnesium s.11 fate ainck when com-quahtamely aJdress this aspect of the steel cono-pared to normal concrete formulations.

ston process, as necessar for a llGV concept.

Work in this area was ininated w hen it was reah/ed the cf fccts of carbonanon need to be considered in that information on the durainlits of concretes for.

any moJel mcJ to predict the onset of thloride-mulated with microsibea material was hmited. In mduced conosion of the remfoning steel.

one study (Cohen et al,198M. hpe 1 and Tspe V Portland cements with 15 percent tw weight of sihca

.the basic formula used m the itARRil R wJe to M

lume were exposed to solutions of shhun5 and mag-prcJict concrete perl.otmance was developed from the testing programs conducted in the field of high-nesiurn sulfate, Data wcre observed at vanous mter-

• 4 '"E*" N "3.

P W""" "*

vals of time up to 140 days after the exposures, an attempt to defme the cr uical parameters leadmg to conosion and failute of bridge decks and highw ays Changes m stram, strength, and volume were evalu-in general. Another pmeram todch.ne and evaluate ated, and k. ray diff.rachon analyses wer e conducted to detect the p'resence of the products of sulfate at-O' ""P"I""I P""" "

• N W

T

'*"# k ""

tack (ettringite, monosulfate, and n' psumt On the conducted h the I ederm !b"hway Administration basis of this s esearch, the conclusion was that Ihe use r

d.11%, A). As a t esult of the 111%, A stutJies, the em-of silica fume increased the strength loss and mes pirical formula from the L,ahfornia pmgram was loss by a factor of 5 to 10 when the cements w etc en modihed. and n is the modihed tonuuta that is used posed to the magnesium sulfate soluunn.

in the ll ARRil R code. No explanation is provided m the Pl.ASAR on the appheatuhty of the formula in an actuallicense application. the apphcant would 1or the proposed enpmeeted itG\\; cencept, whit.h need to address the effects of vanous aJditnes pro.

u u yonm son ons tangm4 posed to enhance certain properties of the concrete.

'" " I m nt mm those enmuntmd in in@we This is especially true when long-ter m performance

" W "" * " '

projcetions and des'ted service hfe of the em,erete depos:d structure are concer ns.

In an actuallh ensc apphcanon w here a numerical or a quannhed detct mmanon of the service hfe is to be (g) In regard to magnestum ion concentrations there mA an appheant would hase to clearly desenbe appears to be a dtscrepancy in the Pl.AS AR Appen' and defme the hminne conJiuons of any formula be-dix E. Section El.5, page EO, mtheates that the ing used. The bound $ry condaions andassumpoons magnesium ion contentration is taken as 20 pats would also have to be clearh defined.

per million (ppm). whereas in Secuon 621 l'able 6.2-3, and in Volume 111, Table 4-3, page 4.3, it is (c) In the formulation used m the ll ARRIER code, the noted as 5.8 ppm.

time to imuation of corrosion is considered to be a hnear iuncuon of the water.ccment ratio The staff, in reviewing an actual license applicanon, this ap-how eser, does not consider the water-cement ratio parent discrepancy would neeJ to be resohed, and to he a subsutute paramcter for the diffusion coefh-the applicant would need to provide the bass for the cient for chlonJe ions in concrete: consequently, it use of any material that has not been shown by expe-does not consider the moJel used to dehne con osion nence and performance to not be deletenous to the to be suffteient m predicting the initiation point m desned characteristics of the reinforced concre'e time of corrosion, smee diffusion wiH be the mecha-

IlGV, msm for chloriJe transport. The model would have to be refined further if it is to reasonably pmject the i

Comment 611 Section 6.2.1 (p. 649) senice hfe of the remforced concrete vault.

In the Pl ASAR, an empuical formula is used m the (d) The Pl.AS AR does not doectl provide the formula-3 li ARRiliR codc to compute the onset of reinforcmg steel tion that is used in the ll ARRIER code to predict corrosion resultir.g from chloride attack. The vanables the rate of corrosion of the reinforemg steel. Af ter are the concrete cover, the water-cement rauo, and the considerable rescanh and check of references, the chloride ion concentretion.

staff was able to determme that the formulation used in the llARRIER mde to predict the corro.

(a) in the formula used in the ll ARRIER code as pro-sion rate of the remforcmg steel onginated in Elec-vided on page 1630 of Appenda E, the micracuan inc Pow er Research institute (EPRI) Repor t or influence of the extent of carbonanon that can de-NP-5365S. The formulauon is based on the follow-crease the time to imtiation of corrosion by lowenng mg assumpuunv 0) the growth of the iron oside the pH of the pore water solunon is not considered.

product la,cr on the reinforemp steel must be slow Also, there is no discussion that would attempt to compared to t he rate of oxygen diffuuon through the 33 NU RI 4 i -lD5. Vol. 2

layer: (ii) the rate of oxygen diffusion through the ucs included are for a loss of yield strength due to product layer is fast compaied to the diffusion rates leaching expressed as a percentage of the original of oxygen through the concrete matrix containing strength.The staff does not understand the use of the cement paste; and (iii) the rate of oxygen con-the term

• yield strength" because in structural sumed by the conosion reaction is greater than the analysis, concrete matenals are not normally charac-rate of diffusion of oxygen to the reaction interface, terized by a defmable yield strength, Clarification oi so that the corrosion rate islimited by the flux of oxy-this terminology based on the purpose of the term is gen. No information on the validtty of these assump-needed and clarification coulJ be based on compres-tions is provided. In an actuallicense application. it sive strength, an accepted measure of structural would be necessary to provide supporting informa-integrity of concrete materials. The term could be tion and tuckground for these assumptions, either in expressed as a percentage loss of specified compres, the SAR or in reference documents.

sive grength (f O for a degraded value of strength caused by teaching. Or additional information could Comment 62: Section 6.2.1 (p. 6-59) be provided that bases the term on percentage loss in yield strength of a reinforced concrete structural (a) In using the ll ARRIER computer code, a model is member, such as a roof. The additional information considered for the degradation of concrete that can would need to include consideration that, according

- arise from the leaching of calcium hydroude. 'lhis to the tables, no tension steel area remains after 100 degradation process can result in the loss of strength

-years.

of the concrete, since a portion of the matrix is lost.

Comment 63: Section 6.2.1 (p. 6-59) -

The formulation used in the llARRiliR code is based on diffusion leaching; the assumption is that The llARRIER computer code does not specifically ad-the loss of calcium hydroxide is controlled by the dif-dress the phenomenon of alkali. aggregate reaction that fusion into the surrounding soil matenal (i.e., the may arise frorn the reaction of the constituents of the cc-dif fusion is from a fixed concentration into a semi-ment and the aggregates. At this time, no known analyti-mfmite domain). A conclusion in the EPRI report is cal model exists to predtet the failure time of concretes that when 33 percent of the calcium hydroxide has that may be reactive as a result of various quantities of so-been depleted, the concrete strength has been dium oxide and potassium oxide (alkalts)in the cernent decreased to one-half its original value. On the basis and certain sihecous and carbont te constituents of the ng-of the EPRI report, diffusion would dominate the gregate. Consequently, although the li ARRIER code teaching process only when the conditions in the does not address this mechanism, w hich could disrupt the ccmcrete matrix were such as to provide a fluid (in integrity of concrete and shorten its senice life,it does re-this case the ground water) flux density of less than flect the current state of the art m that no known models

- 103 cm/sec.

exist for predicting lifespan relative to alkali. aggregate reactions. One of the reference documents secondary to in the formulation used in the ll ARRil!R code, the the PLASAR, EPRI Report NP-5365S, desenbes in

_ possibility that there will be adverse effects from Chapter 7 the degradation that can result from alkali-chemicals in the fluid contacting the concrete with aggregate reactions and the major influencing parame-respect to the potential teaching of the calciurn hy-ters. This relut concludes by stating that the degrada, droxide is not considered. An acidic fluid contacting tion mechanism can be desenhed as one similar to that the concrete early in life will move the time scale -

used for calcium hydroude leaching, which resuhs in a

- radically forward, giving unconservative results with loss of strength of concrete as a function of time. Such regard to lifespan predictions.

formulation, however, apparently was not used,

~

in an actual license application, the use of the for-

'lhe treatment of this topic in the Pl.ASAR could be im-mutation would have to be reexamined. Other for-proved by using the knowledge that does exist on prevent-mulations for leaching may nave to be considered in ing, mmimizing, or specifically addressing the alkali-order to represent actual field conditions, such as -

aggregate reaction -for siliceous materials. - Certain cracking and kscal porosity and wids that may be Americtm Society forTesting and Materials (ASi hl) test-

- present in an actual structure.

- ing standards are available for identifying potentially re-active aggregates and for testing aggregate ccment com-(b) - Section _6.2.1 (p. 640) refers to Tables 6.2-4 and binations. Section A2.1 (p. A 11) of the PLASAR does 6.2-5 assummaricsof the resultsof structuralanaly.

not specifically include these standard = tests as being

=

sis of vaults as they degrade over hunoreds of years.

required for the concret e materials to be used in the llGV One parameter determined to he relevant in pre-structures. 'ihe specific available standards include dictmg the life of the vault is the effect of calcium the following: (1) ASTM C227, ? Standard Test Metimd hydroxide teaching. The tables indicate that the val.

for Potential Alkali Reacthity of Cement-Aggregate NUREG-l375. Vol 2 34

i Combinations (hlottar Han hiethod)"; (2) ASl'h1 C2S9, remforced concrete propenies with regard to the "StandardTest hiethod for potential Reactivity of Aggte-wcather icsistance of the arrtegate are such as to be gates (Chemical hiethod)"; and (3) ASTN1 C295, "Stan-acecptable for at least 300 freeze-thaw evcles. It is

~

dard Practice for l'etrographic lixammation of Aggre-nuldcat whether thisisintended toindicate that the gates for Concrete " I or the effects of alkali-carbonate appt epate alor s t 'o be " tested" for this hfesp.m, or reactions that nny arise from the reaction betw een the al-whether this refers to the entire concrete mattis, it kali in the cement and/or an external source and certain is also not clear how this 3to ewle value is related to reactive carbonate rocks, other tests can be used to pro-any analysis per fot med for the'llGV usmg the ll AR.

vide data on which to judge acceptabihty, in addition to RlliR ende.

ASTM C295 ASThi C5S6, " Standard Test hiethoJ for in an actual license application, it would be neces.

Potential Reactivity of Carbonate Rocks for Concrete Mr) to cleatly mdicate what considerahons for Aggregate (Rock C fmder MethoJ)." and a Canadan free /c thaw effects wcre made. 'lhis mformauon 3

Standards Association standard, CS A A23.2-11 A could wvuld be needed to allow an assessment of the spc-be used. ASThiis developing a new standard test method cine conJttions governing the actuM ltGV sac and (P 214)that will basically iaeasure the change in length of wndaions to be muipleted a standard form resulting from alkah-sdica n(k reactions.

(b) For conJitions w here the it ARRil R code woulJ be Data obtained from ihe application of the standards and used to compute the fice/e-thaw effects on the mte practices eited alw e wdl aid m idenufymg potential reae-of conctete deeradation, a computation is per-tive aggregates; however, even these stand.uds may not formed to detennine the aserage thickness of the identd) all reactise combinations, since some appregates annual concrete hws hom a structural secuon. 'the react very slowly or there may lie unknown sources of al' basis for the equation used is a seties of test data,as-kabs and moisture transport, and moisture transpon can sumphons, and theoretical development that are concentrate alkahs, wiuch can then attack the concrete not necessanly compatible or consistent wah those matnt t elated to wastt disposah aults. I irst, the number of frecie thaw cycles to cause concrete failut e is baseJ In an actual license application, tbe apphcant would be on test data dsuhing from a specific test procedure expected to more clearly evaluate ine alkah. aggregate re' ht is intenJed to reduce the dynamic modulus of action phenomenon for its effect on the seruce hfe of the clasueuy by one half.Second,the number of free /c-HGV structures' Ihaw cycles to reach this level of t eduction in the dy-namic modulus of clasucits is further defined to be a C,omment 64: b,ection 6.2.1 (p. 6-09.)

funcuon of the entramed air content and the water-cyment raho A ponion of this relauonship is de-Within the BARRillR code logic is the capability to cal-Gne@pmc tWay Am46 ponMn ofik &

culate the loss of conctete thickness that might occur as a nondup is denved f rom a generah/ed handbook resuh of the frec/c thaw attack. The calculation is con-eun e that was miended to dlustrate the relanonship trolled partly by the parametcr "lCYC," w hich is defined of air entrainment and water-ccment ratto to dura-as the numlierN sigmfteant freeze-thaw cycles per year.

bih:y. l'est data, the test parameter range, and so fonh. an' nm i&ntkd Fmn an amnued number (a) The PLAS AR does not provide a complete listmp of of Wgnifi ant annual free /cuaw eycles peryear,the the input for the specific studies using the li AR-total wtw hfe in yars is to be Nnained RitiR code, but instead provides a sciccuve listing of the input parameters. Reference document liPRI At this point in the B ARRil!R formulation,another Report NP-6218-CCMI, page 4-19, indicates that computer technique. UNS AT 't I, is miroduced as a the parameter "ICYC"is input on Record Number means to compute the depth of water penetiation 37, which is only used in the case where the parame-into the strue'tural concrue. The parameters de-ter "Kl;l AG" is equal to the salue of 2, which im~

nned as the major mfluences are the amount of re-plies an aboveground sault. On this basis. it appears sidu.d moisture m the concrete and the porosity of that for a llGV, where "RFLAG"is equal to 3, no the concrete These parameters are used to defme computations are performed for free /e-thaw degra-the depth of concrete initially affected by freeze-dation. For a HGV installation, however, there may thaw conditions. l~ rom this, an annual rate of degra-he exposure of vanous portions of the vault to dation is computed.

weather during and after construction and perhaps before the f mal cover is placed.

In an actual hcense apphcation, where the effects of free /e-thaw are a concern, it would be necessary to Appendix A. Secuan A52.2 (p. A-56) m Volume II prouJe a correlation between the depth and degree presents the design enteria that are summan/ed in a f saturanon that weurred in the test specimens Table AS-1. The table (p. A-50 mdicates that the used to develop the 5ttpercent reduction in the 35 N U R I E 1375, Vol. 2

dynamic modulus, and the values assumed in the Comment 66: Section 6.2,1 (p. 6-59)-

UNSAT-Il calculations. Additionally, the validity of using UNSAT-!! for the concrete would need th

'lhe Pl.AS All and the B AkitillR computer code do not be demonstrated,and the range of concrete parame-address the mechanism of reinforced concrete degrada.

ters that was used would have to be proviJed.

tion that is associated with acid attack. 'the acids of par-ticular concern would be those of sulfur and nitrogen. It Comment 65: Section 6.2.1 (p. 6-59) should be noted that the type of degradation that can re.

sult from the effects of sulfuric acid mclude the attack The PLASAR and the llARittliR computer code do not m^"hanism considered (indirectly)in the sulf ate attack on y

address the mechanism of reinforced concrete degrada.

concrete, as well as those effects associated directly with tien that is associated with carbonation. The major effect sulfuric acid. It is the acid aspects that hase no' been ad-from this processisaloweringof the pH ef the matrixand dressed in the it AltRillit computer code; how ever, rmd-the pore water, as well as a det.rease in the pro,eetion pro.

els for such degradation methods have not yet been devel-vided to the reinforcing steel.The reaction between car.

oped in any detail, and only some of the vanables have lxm dioxide and cement components such as ralcium been identified. A ven simplistic relationship has been hydroxide and water to pr oduce carbonie acid and carbon.

developed (Raju and Dayaratnam,1984) to estimate the ates. such as calcite, also produces physical and volumet.

seqcited minimum cover for remforcing steel the de.

ric changes.The rate at which carbonation proceeds is pri.

gree of deterioration of the cover was assumed to be line-marily a function of the supply of carbon dioxide (whether atly related to the depth of penetration of sulfuric acid, from the air or the decomposition of organic materials in with full sulfut ie acid. cement reaction occurr ing at the ed soils or wastes), the diffusion rate of the carbon dioxide posed surface and 7ero reaction at the masimum depth of through the concrete, the permeability of the concre,c',

acid penetration. Some h 'havior has been reported (Fat.

the degree of saturation of the coneretc, and the effective tuhl and Ilughes,19S8; Alkgbe and Ri/kalla,19SS) that 141 of the concrete in the basic range. 'the depth of car.

appears to be contrary to vu tt would be expected, yet the bonation is also a function of time, progressmg roughly preponderance of empirica. lata from a significant series proportionally to the square root of time based on some of tests supports the view that acid attack is a viable degra-formulations.

dation mechanism.The data appear to indicate that an in-crease in the cement factor (the amount of cement used Although carbonation may not be identified as a domi.

per cubicyard)would increase the amount of degradauon nant degradation mechanism leading to fadure of a rein.

(for certain values of the cement factor)with the plIlevel forced concrete llGV, the existence of the mechanism in the acidic range.

should be recognized and considered in any analysis for deterr-ining the longevity of the reinforced concrete The acid attacks can originate f rom various sources de-pendmg on the hication of the remforced concrete mem.

structure.

ber. Airborne acids can be deposited sia contaminated The ll ARRIER computer code does not at this time con, namral precipitation as in acid rain, 'the attack may arise sider urbonation as a mechanism that could lead to the.

from a gaseous state in the form of sulfur dioxide For degradation of a reinforced conctete HGV, either as a ahweground structures, repeated wetting with acidic separate mechanism actine alone or in combination with water is a possible condition. For structures that are but-chlorides in the attack on 'the reinforcing steel Work to ied and are intended for a senice hfe of hundreds of define a formulation describimt the depth of carbonation -

years, the acidity of the carth and contained ground water with respect to time is discuss'ed in a research paper by rnay mcrease with time. The acid source may emanate Ying-Yu and Qui-dong (1987).

from acids or ehemicals in the wastes that can react and form acids, or the source may be the leaking of acids and

-henucals from an industrial use.

Some laboratry data are available to support the equa.

tions and the associated constants; however, at this time, an actuM heenw apphcanon, tNm appkant proposes -

work in this area is not considered to be sufficiently ad-using the BARRiliR computer code for predicting con-vanced to enable the deselopment of a govening equa-crete degradation, the appheant would be expected to

- tion to define the depth and rate of carbonation for a mostder the e:lects of acid attack and to conservatively given set of material and envimnmental condinons, bound them m the facdity design.

In an actual license applicotion, if the applicant proposes Comment 67: Section 6.2.1 (p. 6-59) using the llARRiliR computer code for predicung con-crete degradation,it would be expected that the effects of The PLAS AR and the 11 AltRIER cornputer code do not carbonation would be considered at least quahtatively, if address the degradation process on remforced concrete not quantitatively, and the potential effects would be ad-that can be imuated and sustained by biological condi-dressed conservatively in the design of any concrete struc-tions ~lhese biological effects can rciutt m an attack of s

ture, the concrete or the remforemg stcel or both. I hstorical NUREG-1375, Vol. 2 M

I

cvidence indicales that of the four general groups of mi.

setTe to shield the sulfate educers from air, thus allowing crobiological organisms (bactcria, fungi, algae, and the anaerobielueteria to thrive. AdJitionally,one cannot yeastst the most likely to be of concentat e bacteria that easily justify that an environment for microbiological at-are sulfate reducing. The ene.gy for the hfe processes of tack is not possible becauce there is no moisture. Trace these bacteria is derised from the oxidation of some cle-amounts of moisture are sufficient to quahfy a system as rnent other than carbon, and those of particular concern aqueous when consiJeration must be made on the micro-thrive under certain conditions on sulfur, The bactena organism Ic 4 that have been f,und to be most destructive to reinforced concrete are those of the genus Thiobacillus. In general, Ahhough the mstances of microbiological attack on rein-the sulfur bacteria are likely to be found wherever forced cencrete are not documented as a widespread warmth, moisture, and teduce' compounds of sulfur are problem, there are many instances of an inappropnate in-d present. 'the sulfate reducers are found world wide in vtstigation of the distress, degradation, or f adure, since soils and waters and represent some of the most ancient the usual response by an owner is to correct the problem.

of the living orgamsms on earth. Cond tions needed te Money is spent to remedy the problem, rather than to in-sustain the degradation process by the Thio!willus bacte-vestigate its cause Consequently, hrstorical da'.a rnay not ria are sufficient moisture, to prevent the desiccation of reflect the past accurately with respect to biological ef-the bacteria, and adequate supphes of carbon dioxide, fccts.

Oxygen, nitrogen compounds, and hydrogen sulfiJe. Sol-I.or an actual beense application, where there is an em-uble cornpounds of phosphorus, iron, and other trace ele.

phas on longtenn durabihtb it would be important to mcnts are also needed in the moisture film. A source of adJress the luological mechamsm when attempting to de-hydrogen sulfide necessary for the conJitions to suptwt Imc the projected hfe of engmected remforceJ concrete the Thiobacillus bacteria is' another genus of sulfur hatte.

baniers. Parallels of the above docussions exist with re-ria; however, these bactena are anaerobie as opposed to the aerobic Thiobacillus hacteria.These are known as sul.

spect to the corrosion of steel by sulfate-reducing bacte-Md-fate reducers and are of the genus thsulfotomaculum-These bacteria have the ability to reduce sulfates that are Comment 68: Section 6.2.1 (p. 6-591 present in natural waters or t he surrounding environment and tc, produce hydrogen sulfide as a waste product An

.lhe PLASAR and the ll ARRiliR computer code do not environment where reinforced concrete custs with these spec.f cally address the considerations that should be conditions having a pli of about 9 will allow for the growth made concerning a range of chemicals and mateuals that of Thiobacillus thiopams, which uses the hydrogen sulfide can degrade concrete. An estensive hst of ther e matenals and generates thiosulfuric and polythionic acid. As the is asailable m publications of the Portland Cement Asso-growth of these bacteria continues, the pil will continue ciation (19M)anJ the American Concr ete Instimte ( ACI to decrease;if it reaches a value of approumately 5, th:s 201.21M7) Sources of such harmful chemical materials should create conditions for the growth of another should be precluded from the environment of a llGV, or of the genus Thiobacillus, namely, Thiobacillu.s alternatively, the degraJation effects of these materials co*

crctivoroua. These bactena produce high concentrations should be constJeted in any prediction of the seruce life of sulfurk acid and can decrease the pH to a level of 2 or of the reinforced concrete.'

less, Dus condition then creates the sulfuric acid degra.

dation mechanism where the decomposition and destruc' Consideration should also be given to conditions unds tion of the adcium silicates and aluminates in the cernent w hich one of the chemicals meht be mtroduced to the en-matrix take place, nronment of a proposed dispo'sid vault af ter construction, whether by inadvertent dumping oi by formation from nstituent matenals in the natural environment of the One of the unique features of the microorganisms is their small size, which permits them to exist in small areas and grow. If locali/cd effects can be important to the proper in an actual license application, consideration should be functioning of construction materials, then these micr"-

gisen to the various chemicals and matetials that are orgamsms can have significant impacts. Consequently, I sted in the htcrature that can degrade reinforced con-what are generally beliesed to be the prevaihng environ' crete and assurance should be provided that adequate mental conditions on ine global sade may not be a good steps would be taken to preclude any unacceptable ef-

~

predictor of what may exist on the smaller scale where fects on the performance of the concrete structure.

bacteria growth may he fostered. I or example, the an-acrobic sulf ate reducers can exist under conditions that Comment 69: Section 6.2.1 (p. 6-5W normally would be considered obviously aerobic. Sulfate reducers have been found under slime deposits and iron The P1 AS AR and the H ARRil R computer code do not bacteria colonics in cerated water systems such as those address the mechamsm of s;dt crystatioation that has re-served by cooling towers. The slime or other colonies cently been sSgested as a ponible cause of increased l

37 N URIiG-1375, Vol. 2

internal stressee in the concrete matrit This degradation would tequire that some time be allowed to pass after concept is based on the precipitation of dissolved soluble construction, before such testung could be performed.

salts in the pores of the concrete matrix as a result of The testing for this fourth stage should wnsist of a water eva;mration Once the pores have been fdled with preplanned program that had been formulated during the the salt crystals, additional crystal growth may result in design phase, so that all important parameters that may the development of internal stresses that may lead to influence the behavior of the llGV are acceptably veri.

crackingof theconcrete.if thetensilestrengthof thecon-fied.This program could involve the use of impact echo or crete matrix is exceeded. His mechanism has been noted pulse echo inhniques, impact hammers, penetration de-as a major cause of stone aggregate deterioration For vices, testing of cast-in-place specimens, coring, and pe-d typical llGV conditions, if such an attack mechanism tregraphy.

w cre to occur, the salt buildup wvuld hkely occur on the inner surface of the vault walls, as water passed through Such an avbudt program should address issues that to a surface exposed to drier conditions than the outside would, for example, include the in-place compressive 1

of the vault.

strength; the degree and unif ormity of consolidation; the l

air content: the h> cation, size, and orientation of crack in an actuallicense application, it would be expected that information on any cold joints; und the construction l

this newly identified degradation mechanism (Winkler, joints An evaluation of the permsbility of the as-built 1973: Sayward,19M), which may be a contributor to con.

IlGWould be considered in order to assess the capability crete degradation under certain conditions, would be ap-of the structure to retard any gmund water flow, propriately considered.

In an actual hcense appheation, it would be necessary to Conunent 70: Section 6.2.1 (p. 6-59) address the powedures that wotdd be used to determine the as built conditions of a llGV m order to provide rele-The Pl.ASAR and II ARRIliR computer code appear to vant information to asse;s the structure's capability to address the determination or projection of the servicc hfe perform as intended. If a computer code such as the of the reinforced concretc on the basis of what can be con.

II ARR!l!R code had been used m the design plax, then sidered to be nearly ijeal construction and operational it could be used agam in conjunction with the estabhshed conditions. Provisions do not appear to have been pro-avbuilt conditions that would be imposed on the ongmal posed for a way of integrating the use of posteenstruction analytical model. If some other form or type of analysis testing to assess to what degree the design assumptions had been made, that, too, should be reevaluated on the related to the construction materieds, construction meth, basis of the established as-built conditions. A final step in ods, quality assurance! quality control, and so forth, would this pntess would be the declaration or certification by be met in the field to produce an acceptabic llGV. Until the designer and constructor that the IlGV meets the de-such an assessment is performed on each completed hifn requirements and is ready to receive waste.

ItGV, the structures should not he assumed to have met Conunent 71* S,ect. ion 6.3.1 (p. 6-66) the design regt.irements and be ready to receive wastes.

The JafPs review of the information on surface drainage The first level of assessment would typically include the and crosion protection m Section 6.3.1 and the support-evaluation of the observations made during such activities ing documentation in Appendix E of the Pl.ASAR indi-as concrete production, t ransport, and placement and the cates that an adequate design for long-term stability has completion of an acceptable concrete control testmg pro-not been provided anJ that addnional justification anJ!or gram. The second level of assessment would include a vis-revised anal)ses ate needed m several atcas of the pro-ual survey of the concrete surfaces, once the construction posed design, forms were removed. All defects that could cause a reduc-

- tion in t he materiali physical or chemical properties that (a) l'irst, the storm drainage system does not appear to were assamed in design would be recorded, so that the in-be adequate because many ditches and collector formation could be used in an analysis of the resulting thannels are designed for only a 100 year flood llGV to determine if it would perform as designed. The event An occurrence of the Probable Maumum

third assessment would include anot_her complete visual 1%1(PMI)(or any flood larget than the 100-year survey, once the prescribed curing had been completed.

flood)could cause signif cant crosion and damage to Since the quantitative salues of the parameters necenary the ditches. Such erosion could affect the stabihty to evaluate the important characteristics for the satisfac-of the protectise soil covers over the llGV. Since tory performance of a liGV would need to be evaluated, the ditches must perform their function without various testing methods would need to be introduced to maintenance for hundreds of years following clo-determme the actual as-built eonditions of t he completed sure, tht: staff concludes that designing for a very structure. Such tests should, in most cases.only be per-rare flood event, such as the PMit is appropriate.

formed atter dye HGV had stabilized from the standpoint The design of the dithes in an actual heense ap-

- = of curing, moisture toss shrinkage, and so forth, 't his plication would need to be reused. Alternativel),

N URiiG -1371 Vol. 2 38

adJitional justificathvi and detailed anabscs of the ous conwnatiuns need to be used when descump mitially propmed design shoulJ he prosided to for lony perioA, when no a hance can be placed on document the sapabday of the dinhes to perlorrn active snamicnante.

their intended function for several hundred years tdi in 0 ruhy oto3 ion mo&l used to prcdut depths of followiny ute desure.

etoqon (p. !?lD% rare rainf.dl events are nat con-siden d: on1r a series of ramtall esents of Icwer in.

(h) Second, th pl.ASAR (p.111i6) indicates that tenuty o EndJetcd 'lhe staH quesho's the use of

(

some portions of the dramare systern w dl be capable m h a rm> Jet w hen deurnir; for long tiemids as re-I of withManding vehscities awoctated with the PMI',

quircJ by the repuhition, without schance pl.n ed on

}

li states that some of the riprapean withstand vs hici-xtne mamtenance. The pl.AS?.it idso indutes ties of up to 20 f t/sec. Althourh ihis may be truc *"

that rully croston wdl not espw the sault roof, some cases, it is not true in nest cases, unless the s nce the vault roof will he below lbe natuial praJe rock is very larre. The siting of crouon protection is of the ute. Ahhough 11. uv be true,it also m.o be dependent on many factors, int 1; ont tpth of flo%

ponhle that crosum m the inuncdote ute ncin,;v d

~

flow velocity, amount of turbulence, t hannel slope, could cme a low enni. of loc d bec iculs, u sulun'y and scour depths. It is hkely that, in this case, the in mercard rulhmg'potenti'd aral powible estwo proposed ditch design is not adequate because the sun ci the vaui Additamally,tu n if the vaults are rock doc s not appear to be large enough to withstand not esposed,it h possible that anercases in inhltra-the PMF whhout sigmbcant damare and also be-tion toub' occur a a resuh of ruuy cunhm and re-cause no rock is provided on.ne thannel bottorn. In sultmp corcennatmn of flou or ponJmg m a pat-an actual beense apphcation, the destru of the cr"'

ucular eraJed atea of the ute.The stal' concludes sion ptotection woulJ neeJ to be revised to proude that the cowr slopes for the loMercl waste dope stable channels that do not crode or su!!ct esternn e fdm should be designed to be stable and thes o damare dunny rare Iked events.The staf f suprests Upnificant crosion wdl be prevented.The ruidance use of the Eticty I actors MethoJ f or designmr d:tth m the aferementioned hnal staf f technical posinon ripcap, since h can take into account the lactors d'"

my be uted to desirn such stable slopes.

cussed abose Alternauvely, adthtional documenta-non could be provided to justtfy the use of the pro-(c) 'lhe Pi AS AR (p.1 112) inJicates th:.1 the Type 1, posed ero.sion protection. Analysts and detaded 11, and lH Otthes ate designed for the IOO-year calculatiom that discuss the actual depths of flow fhiod As noted earher, the stall doc 4 not con,.'er and the shear stresses produced on the rock would this deurn to be adequate. In Comment 6, the sta!!

neeJ to be proviJed in an actual hcense apphcation.

pmvides adJiuonal dr.cu'sion anJ inf ormation re-pardmr the use of deupn criteria anJ suprests aeth-(c) Third, the design of the top and side slopes f or tdl of os for naptable resolunon.

the dispod u'uts has nat beci. adequately justified.

The Pl.ASAR (p. I!-117) mJicates that concrete lhe top slo; es inte been designed on the basa that ims wdl N md to Mla m um kUow ute they wdl lumt sheet erosion and gully crosion that losure and wdl replace the conciete cuherts in the result from a series of mour storm e,ents. Ihe ddnm Anuk 'the fords wdl be constructed of Pl.AS AR f,ide slopes were selected basec on the f act onct c'te anJ wdl serse as roadways for access to the that steeper slopes has e been approved by the NRL, site. The fords wdl be construetaidu ectly across the in other program areas. lhe Pl.ASAR methoJ of se-

@nncis. and accordmp to the pl.AS Al( their der-lecting and designing soil mver slopes are not con-radation w di not imp.or the abihty of the channeh to sidered to be acceptabk.

ctual heense apphea' ctform their requued f unction.

iien should provide a,

nled deurn anaiysis of ill of the disposal uruts in pencral, such structures are not wnducae to stable top and side slopet s

and should pros ide a ratior.att and struct ured deurn longter m stabihty becapse they wdl lose their elfec-approach. The NRC staff has deseloped guidance tivenew unlea toutine maintenance is pe* formed, on the design of stable sou slopes. 'this ruidance is If the fo.d simply becomes part of the charmct, the presented m "l mal Staff Technical Position, Design concrete (probably in a derraJed condioon) will be of litosion Protection Covers for Stabih/ation of eqused to croswe farces durmy flood events. The Uraniuni Mil! Tailings Sites," May 1990, and is ree-statement m the Pl.ASAR that no adverse effects ommended, s.nce it addresses various factors associ*

wdl occur is, ther efore, not adequately justihed.

ated with long term stabihty, ine'udmr allowable

~

shcar stresses, Probable Meimum Precipitation in an actual hcense appbeation the design of the rainfall intensities, flow cont ent ration. pullymp, and channels would need to be revised to elimmate the slope !cngth, in the document, the staff also dis-concrete fords and designs provided that w di ensure cowes many dedgn areas and recom.nent t hat van-stahdity over a long penoJ. Instead of conciete w

NURihl375 Voh 2

fords ihe staff surrests the use of a sock-protected ment of die backhti and cmei 33 stem should be ade-ditch crossing. 'the entire ditch could be protected quately evaluated in an actual hcense appheation.

with normal tiprap, and at the ptoposcJ crossing points, the ri rap mds could be (died with sod or 7

OCCUPATIONAL lt Al)I ATION P

graveltc

.sw vehicles to paever the s ock. Suth a design wdl be caluble of lasting a long time wahout I'l(OTECTION*

i maintenance. 'the enteria for such designs are simi.

L,ununent 74: b.eellon 7 (p. 7-1) lar to those for normal ripnp desirns.

'the occupational radutron protection prograe. deset tbed Coturnent 72: Secllon 6.3.2 (p. 6-6M

'" U"PIC' 7 "I 'hC PI ^S^" C""d* "I f C " C ' """"

ments ppuently designed to addrus key components of that scolon as set forth in NUltihll99 llowever, the i

• the PLASAlt does not provide information on the evalu-Pl ASAlt (particularly Sectiond.

d 7A bearcely pro-atton of slope stability from a petechnical enp,neenna vides % inuch iaf'ortnation

.nt presented iri

)

- perspertise. llecause of the hypothetical nature of the NUl(HL1199. In many instantes teierences ate made site. flat. rentle natural stopes m the ttnmedette vicinity oI to selated informtion hintamed in appendices or the the disposal facihty were anumed. 'lhese slopes are ce supr tting information pacLares. Ilokeser, these refer-pected to be stable and not have nn adverse impact on the enc's are not detaded enouth to fanlitate line item re-e pet form mec of the disposal facihty.The rnaumum slop" view as would be ieyst ed in an actual license appheation of Ihe cover system is 15 percent and is espected to be sta' eview process.

blr. Ilowever, there is no analysis m the Pi ASAlt to sup-

. port this position, as would be expected m an actual Salt.

An actual licente applicauon would need to have much

'lhe stability of the construction slopes was not w.duated, more detailed information than that presented in Chap-liceause of the long time anticipated for facility opera

• ter 7. NUl(IMUCR-3kt3, N Ult ui-1149, and NUltt h tion, the statiility of the consuuction slopes should be IMO provide ruidance on the level of detail expected in evaluated in an actual ibnse appication, if the shipes an actual license applicati m. Sinularly, in un actual li-could have an impact. In addiuon, the geotechtscal stabil.

cense appheation, Chapter 7 should be des eloped m suf-ity of.the natural slopes at the site, the cos er slopes and heient detail to ensure mip ementation of the radiation i

the construction slopes should be adequately addressed-safety program. Chaptm ? of the Pl ANAR does not de-scnbe piogram scadily aUowm;' implementation, not is Colnutent 73: Section 6.3.3 (p. 6-67) u nu edy spm oaD hunty.

Consequently, not enough information is presented in

.the settlement and subsidence evaluation for 11 e llW the PI ASAll to allow a thorough and independent tech-design has beenimplified by assuming a uniform straDP nical assessment, since an mtent of NI(C's review of the raphy and a vcq general description of the geotechmeal l'I ASAR is to esaluate the calibet of the information to.

engmeermg charactenstics for the hypothetical site. '!he be submitted in an actual license applicauon. llepardless magmludes of the total and d4fletenual settlements pre-of the dehciencies the NRC staff has unde:taken, to the sentcd m the Pl AS AR are calculated and accounted for extent practicable, a review of the subnutted protection in the structural design of the sault inat foundation-program. 'lhe stalli comments foHow.

'these settlements are the deflections experienced by the i

mn. as a result of transferringloads to the immediate sub-Comment 75t Section 7.1.1 (p. 7-1) grade. Most of these deflections are expected to be apt-l rienced within a short time of imposed hsading. and they (a) 'the hrst paragraph of ths section of the pl ASAR do not include the time-dependent settlement of the mal sets fonh a general commitment to maintain radia-l as n result of consolidation and cornpression of the thick tion exposures as low as is seasonably achievable I

clayey s:md stratum beneath the vault, An acceptab!c set.

(A! Al( A) as tequired in 10 Cl R 20.l(C). In addi-tiement evaluation in an acteA iieense application should tion, a commitment to the Al AR A principle is sup-

. include (1) determination of both short term and time.

posediy to be expr essed in various pobey statements dependent settlements,(2) consideration of variations in to be trued by site and corporate management.

the thittness of the compressible stratum. (3)considera-Ih'*ever, insulhcient detail is provided regarding -

tion of the time-dependent huding such adtress relief as how A1 ARA objectnes wdl be n et thtough an in-a result of staged escavation, and (4) construction of con ter face between policy, design, and operational con.

ddeianons crete vauhs in stages during the operating hfe of the facil-ity. Since the vault subgrade and lirench drain systems will be constructed before the vaults the ddferential set-10'" W * "h W O *" W d d I and M **l Wi* *'M l'..,"nmicmm9nm pn nous u ana""a 1nciaancon3 tlements to be experienced by lhe 1 reneh drain pipe ; s a w nu wn result of the staged construction of the vaults ano. pitcc-menu s,m n<nnn warnkrar. heam, pyws N U RIG 1375, Vol. 2 40

(b) The sccend patagraph states ttut the patou d faul-anJ nleicnces Regulauny (imJcs NA anJ S.lu and ity organizational structure for achinmp Al AR A Nl RIMRJ343 as aJJiuenalymdante Altiniurh pre-objcitives is descnbeJ by reference to Chaptc b,

was operanonal espencnce is pren as a bam for unple.

l

'ConJuct of Operations." t hmeser, Chapter 6 of menting the Al AR A proriam, the soutte of the expen-the Pl.AS AR cont.uns a snajor cascat w anung of its ence ts not dinhtd.

mcomplete status. In fact, the only information on organizational structure provided m Chapter b is a The unplementauon of epcianons in an Al.AR A puu refetence to lme,tems set frrth m Nt!Kl G 11W riam begun with the da lopmt nt ef site-specihc opciat-and NURl:G-12bO. 'lherefot e, no review of the el-my pniccdur es enJoiwd ov maiurement and car ried out gani/ational st r ucture to be uscJ te achies e Al.AR A by the f acihty raJunon safety othcer. Standaid opt ratmp objectives m the luiV lacdity is posuble.

procedures (SOP ) need to be descloped miJ subnutted with the attual heense application for all phases of waste l

(c) The hIth paragraph addresses management r es pon-handhng. SOPS should incluJe a det.ukd descuption of nbdities that are pnmardy a recapitulation of pn-the consu,unts on th( tr use (e p., when specul wor L per-mary program clernents identificJ in NRC Reruto imts should be used) In the discusuon of an operational tory GuiJe h.S and NtlRihl199. In an actual Al AR A program, the followinr should be considered:

heense application, these iesponsduhties and all (1) personnel aw ar enew. (2) pnf or nance auditi,, (3) ra.

aspects o! "te Al.AR A psdicy should be clearly iden-dution proicction capainhty, (1) trammp, 0) RSO tihed in wntten aJmimstrauve pnsedures anJ in-authonly, and tM modiheauons to operations.

structions for operations mwhmp potential expo-i sute of personnel to radution, l mthrimote, progr untuatic m!ormauon m an actual h-cense apphGittort should be sel[ contained, where poski-(d)

'I he snth pararraph (p. 7-2), Jcntihed as "Pctson-ble. The appheation may mcor por ate, by ref er ence, mfor-nel Ouahheations," states that quahhtauons for the nuuon wnt.uned ekcwhere, such as in prevnius site radtauon uftty olhccr (RSO) are cont;uned m appheations, statemt nts, of 1epoits hicJ with the Com-Chapter b of the Pl AS AR and are based on rctono numon. only d suth references are dear and specif c.

mendations m ANSI /ANS 3.1-l%1 and Regulatory GuiJe 1. A. This presents tw o majoi r eview problems

('omment 7S: Section 7.l.4 (p. 7-4) to the staf f. l'irst, Chapter h is meomplete and does not contain ari) Inf ormation rc[Ardmp qualifications Sygggggg 7,},4 pr the Pl AS AR Intrelv references a oitn-foi the RSn Second, the cutena in the citcJ docu-mitment to a radutnin protecuon pl5 conustent w uh the ments are desifned pruna'dy for reactor facihties, UConunendations of NliRI (i4 R-3343, The actual ra-rather than low-les el waste (11W)dapo,d sues. In duuon piotccuon plan n un be descobeJ m Secuon 7.4 of an actual bcense apphcation, it would be necesar7 an actu;d hcense apphcanon. Secuon 7.1.4 should de-to identify minimum acceptable trauunt and espen-senhe how the mJuhon protection prograin in Section ence cntena for the iLW die RSO and other teth-7.4 wdl prouJe the infonnanon and wouok to m;untam nical personnel.

occupatr, d doses Al.AR A.

Comment 76r Section 7.1.2 (p. 7-2)

Conunent 79: Section 7.2 (p. 7-4)

The information in Section 71.2 of the Pi.AS AR pnmat-Secuon 7.2 of the Pl.AN AR states tlut Se~ on h1.1, Ap-ily focuses on radution safety tramma A f cw esamples of pendn A,and the suppoinng mfoimation padare(SIP)I design criteria are riven (e p, thick blankt of coser oser contain radiotopcal source teim mf ot mahon, Connary waste before roof is constrected), but this mformat on b to the rmdance in NLiRI G 1199 and Nt1Rin 1200, of minimal value for itGV desigtn with regard to Al.AR A Section 7.2 of the Pl.ASAR does not adequately desenhe concepts. In an attual heente apphcation, detaded in-radution sources that are the design baus of the IKW f a-formation clarifymy the relationship of f aciht) de:ipn cdityN udubon protecuon program. Such factors as features and radioactive-waste handhng procedures to stueldme, senulauon setems, special stoge hications Al. ARA principles and objectises woulJ h espected, anj con'Jitions, trattie'or access coauo!, specul plans, Typically such informanon should be presented in detail mor oring eqmpment, cuahhshment of faahty design in Section 7.3, with a summary of the unpact on Al.AR A features, deselopment of plans and procedures, anJ av principles m Section 7.1.2.

sessments of occupational radiation epsucc thou!J be conudered. Nor does this secuon adJtess all of the Comment 77: Section 7.1.3 (p. 7-3) udionuthdes te r, uramum 234 and thonune230)in the source It im inser, tory or piouJe justiheation for the use Secuan 7.1.3 of the Pl.AS AR prouJes a Icw peneralcom -

of avetape rathonuthJe wna ntranon and content values ments on implementmg an opetational Al AR A prornun as input m the deugo pro en shieldmg codes.

4i N t ? Rih 13 75, Vol..'

I Comment 80: Section 7.2.1 (p. 7-4)

(1) aanstwt selnde demntananahon lacihues, m the herith physics f acihty,0) the dnposal bunker facihties, (a) Section 7.2.1 of the PI AS Alt desenbes the d,ul3

(.1)other l'acihty designs to ensme Al.Al( A occulut onal amount of waste to be hanJied at the llGV faciht) n posur e% (5 ) radution ione designations and r elated t'e-on the basis of the source tot m desenphon in Section urn dose rates and (6) tadauttn e inomionny equipment 6.1.1. The evaluatmn of the source term insentory b m accordance with itepulaton Gmde 8x The deupn and discussed in Comment 46. Ilowtu r, descriphons in operation of the ItGV facilitiappear to be somewhat in.

Section 7.2.1 applicable to the radunon safety pn*

dependent of the radiauon s'ources that are identihed in gram described in Sl(P 7.2 should melude (i) scaled Secuon 7.?

drawings of the facihty that can be rtlated to tabHs containing the pertinent quantitative soutec p,o Comment 83: Section 7.3.2 (p. 7-10) rametet s and (ii) descriptions of the sout ees, includ-Section 73.2 of the Pl.ASAlt describes slueldmg as an ing their h> cations.

adJmonal benefd to the Al AllA design process and (b) The Pl.ASAll does not prevn clear jusubcation speulies the MlCl(OSillliD wmputer code for use la for(i)the use of averageconcen itions and nuthde determmmp the shiclJmg calcuLuont Ilowever,it does content values as input to shiel a design (til the not luovide the assumpoons and the para.neters chosen significance of exposure ratesdA > ed in other sec.

for the Hueldmg udeulationt Adequate slueldmp de-tions of the Pl.ASAll such as those hsted in Section senptions would include discussions of (1) the slucid 73 and (ui) the exposure rate distnbunon of the thi,.knesses for pronu ray sources deternuned f nun the pxlages at the highest and lowest extremes of the calculational codes, (?) why pmdance en the fahneation tantes discussed in Appendix F (i.e.,

10 IUhr anJ and installation of concrete slucids for o,cupational ta-

< 10 mlUhr, respectively). In an actual license ap, d atum puneetton at the itGV f acihty was or was not fol-plication, these issues would need to be tesoh ed.

lowed in ace <udance with l<eputatory Gmde 1.69 and AN SI N 101 6 - 1972, and (3) w hy addinonal a ppheable er e Comment 81: Section 7.2.2 (p. 7-5) l'"" on Middmr and noptum for raJation protecuen weie or were not followed m accotdance with any other Section 7.2.2 of the PLASAll assumes that (cuept for puidant e (i c.,Itepu!atmy Gmde KN). Also, there e, not a airborne releases frem a sigmhcant sospembhle compo.

ricat dNuuson of the dose toducuan resuhing hom the nent of Class A dry waste or imm sources inwhmp dam.

shieldmp desipucJ mto the facihty.

aped wntainer waste pacLapes or those not m comph-ance) accident conditions wdl be rare, since all raste Comment 8l: Section 7.3.3 (p. 7-1l) daues would be solidthed or shipped in high mteprit)

^" " ""IE"" * " """"

4 wntainers. Hecause of this awumption, minimal mfor.

non on una anon, ewept f or a statement that negatne ination is provided nbout the design of ventilanon systems E#"" ""

b ' " " U E'"

"I"k "E or personnel prottetive measut es, although (et tam at cas muon o tk Nom 4 n to N guoviJed for all areas of of the llGV (e.g., the decontamination mea or container te ny an Morag buddmp, in f act, this section inspection areas) should be designed with auborne con-wntas a mNor mw, waining W,4 sud uhnuson n tanunation in mind.

omitted because it n not relesant for the aucwnent of doposal technolog'y, Itoundmg cases for opeiational occurrente and acetdent conditions are diset.ssed in Chapter 6. The NRC staff has in an atu.d licens.e appliation, a dcwnption ni the fob included a number of comments in its resiew of Chapter 6 low mg sould be provided (1) personnd protecnon ha-reprdmg dose factms and pisuheation of auurnptions tmes of the venubuon nuem deugn, W dnian aspects used for Jose awessments for wortets.

appheable to the renanal of anborne radiostmty hom eqmpment, conidors and operatmg areas mdudmp dis-Comment 82: Section 7.3 (p. 7-5) poed unns occupied by personnd, p) design featmes for controlhny contentrabon lesels for the aboce aten Sect on 73 of the PI ASAll descobes the ra>Jution pro-61)deang Wem design with dlustratne samplo and tection desipn features that wdl ensure Al All A oseupa-Wom (i f diers, mounnnp accew doors, sco.ces pal-tional ex[wur es at the HGV f acility, Ilow ever,it does not di etu and W pmsom for wm', wunon, s.

adequately describe the objectnes of the tadution pro' mntmemom and w fod tection design feattues as dehneated in NUltlEll49 and NUltl&l200. In addnion, the description of these fonunent 83* Section 7.34 (p. 7-l1) design features should melude consideiation of the nerJ to allow qual entry and easy access to ensute Al All A 11 wept for the merunn that arca ndiauon monitors and occup dional esposures. I his secuon, m an minal heetne anborne a lioastiuty monnour.y are to be ptosiJed apphcanon, should also indude adequate descnpuuns ol m the ru en mp and mspectvn, decontanunanon and NURih 1375, Vol 2 C

l

l tepackaging, and storage areas, the Pl.ASAlt does not the sources, usuy' eperating espetience where apphea-provide mfor mation on area radiation and.Jr boi ne raJe ble. In aJJition, the ilG\\"s operanonal pt oceduns Io en-actinty rnonitormg mstrumentauon, Aram, tins secuon sure comphance wah the Al Al( A prmeiples repatJmp contains a major caseat, wanung that det.uted mforma-raJiation tyvsures to workers must be addres3rd. Ilow-tion as regt.9J m Sl11(1:G-1144 is omitted because it es er, the ept r ational pr occJurcs ar e to be pn en in Chap-is not neces f or the a(sessme nt el dnIwl t ec hnology ter 4, win,h contams a nujor e,ncat, warnmg of then ornisson becaute of tne hypotheucal nature of the in an actual license appheation, mf ormation on aduuan F1,AS Alt, protection faahties, mstrumentation, and eqmpment should be proviJed as tequested in NUlti G-1200, Commeint 88: Section 7.3.5.2 (p. 7-12)

NUlti!G-1199, and 1(erulatory Guide 6 S (pp. 8L14 hWUPU 7 3 b 2 CI IhC I'A 'AS Alt discuucs the computer and 8115)O..t. the r anges for portable instruments anJ ruoJ A usN for anewng w orkn owupahonal dmes itel-personnel momtonne m>trurnentation and a complete mnce is ade to an electtome sprcad shnt idenufymg hst of instruments and equipment L lt would be helpf ul m number 5 of worLets, durabons of eac h actnity, and dme the revitw procca if these d ita were provided in tabular rates at Yarlous distances trem the Waste 1lo% ever, some

{ gym, of the data (e.p, lable Gl-1 of AppenJix G) on the N"'"d 5"nf ate not m4 relatN to on> humon in Comment 86: Sectiott 7.3.5 (p. 7-11) the test of the Pl.ASAlt and are not presentcJ in a sys-tenmue w4 or considenng ana evaluatmg dose rcduemg f

Section 7.3.5 of the Pl.AS All briefiv desenbes the shielJ.

mg calculation code ISOSIil D used for dose aucuments thanges m Iadily operations and desTn. Documentabon for ILW workers. Although this section references Ap.

icquaements renew pioceduies, and the puncipal dose per Jices 1:and G and 51P.s 4 and 5, the assumphons m the assessments related to (hanres that ensuie the Al.All A references arc not clear, Also, a summary of esposure objettnes wdl be met should be specihculy identihed m calculations is rderenced, but not clearly ideradied. It h an actual beense appheation.

assumed that the information citedin tht efetences k set C.ontmellt 8% Section 7.3,5,3 (p. 7-12) forth in Tables ?.3-2,7.34, anJ 7.3-4, An adequate dose assessnient in an actual heense apphcahon would mdude Secuan 7.3.5.3 of the Pl ASAll references the proces, documentation of all auumptiom presented, calculatiom Hoded M idm@ mme 0 ecipt, handhng, prot ess.

used m the assessments, radiation zone resuhs traluJmg mg, and dnposal dinities at the llGY faahty as eu numbers and types of workers, espected and design dose lamed m ( hapter 4. Ilowen t, nenhei Chapter 4 nor rates, and prejected person rem doses, mduJmp legmle S non 7.3.5.3 prondes det.nled operating pnvedures mforrnation that can casd) be r elated to the oppheable r +

necessary to understand the manarement anJ control of bles provided. I urther, the SIPS are not clear on hoa the waste-handhng actnmes w thin the ilGV laciht). (See exposures from emplaced or stored waste were included Umoments 26 through 29.) in an a;tual beense appbca-in the dose assessments for worLeis' u

watchndW xue huld k dmbN m 6 t:ul in Secuon 4.2 and their impact on occupanongi expo.

b,eet,on 7.3.5.1 (p. 7-12) sure shoulJ be summanicJ in Section 7.3.5.

C,omment 87:

i Section 7.3.5.1 of the PLAS Alt states that Section 6.1.1 Comment 90: Section 7.3.5,4 (p. 742) describes the source term. Howeser, Section 61.1 con-ta ns only background inform..on, which is inadequate The Pl.ASAll rives estimat es for the number and dasuh-for detennining worker doses. Informanon on the soutce cation of wo:Lers, meluJmg the aserare datances from term is ph en throughout Chapter 6 (e.g., information on each radauon esposure source and ume spent on the op-waste packapes is provided in Chapter 6, Tab!c b-19), and cration at these distana m information on the source term for workers is provided in vanous other sections (appendices and SIPS). Therefore, in an actuallicense appheation, the diwr epancy between it is unclear what 'nformation is to be used to determine the mlorm stion in Secuon 7.3.5 4, page 7-12, and thaiin the occupational source term for the different aspats of Section 01.4, pare 0-20, of the Pi ASAl( would need to facihty operation. The few sample sheets of the be clanhed. Specifically, Secuon 7.3.5.4 states that there MICl(OSHililD code and some of the computauons are 22 work actnity clambeauons and 35 speethe opera-prodund from this code cannot be casily r elated to tables tions, whereas Section Gl.4 identthes 26 woil attivity containing pertinent quanutathe source parameters. In classifications and 20 specibe optrations. Aho, a dear an actual heense apphcation, plans and drawings should and more detaded explanation of mformation presented include source desenptions that can be cauly identdied in the s.unple sheets shoulJ be prouded.

and related to information prouded on the source term \\

quantitalhe parameters. Also, the application should I orther, th;s section of the Pl,ASAll does not state that adequately desenbe the shapes anJ approumate sucs of information or worLer exposure is aho containcJ m 43 Nt !RI G-1375, Vol, 2

~>""4W.fmmmJuk n.3m

~

Appenda G. In Appendts G umts for eyetae calcula-Comtnent 95: Section 7.4.1 (p. 7-14) tions are espressed in different terms (i.e.. R/hr or R/yr t which ate not clanned in Section 7.3.6 4.

'the infor mauon m Secuon 7.4.1 of the Pl.AS AR is inade-quate. ~lhis section states that the sadiation protection prornun is tused en NUltlRCR 3313, but does not Corninent 91: Section 7.3.5.5 (p. 7-12) claborae on the urious Pf ort.un ticments outhned in that document. Most of the test m this secuon is a vertw Section 7.3.5.5 of the Pl ASAR desenbes shielJmp and tim icatration of the mfiurnation in Section 7.4 of datance dose conhputations llowever. it does not aJe-N U RI T1 1199, although certain opetauenal heahh quately desenbe shieldmg and distance dine confyura-phpics conectns suc h as control of esternal esposure ate tions during "patticular operations

• in the presence of an hsted open tell of emplaced waste m a disposal vault, er through the toof of a closed vault, et for other conhguia-tions m terms of Imoting wo:Ler exposure as rtcom.

8 ItEl'EltENCES rnended m NURiiG-IN)0. It also fads to descobe the im-plementation of an Al ARA design pinlosophy, which Ahiogbe, l', and S. Itiikalla. " Response of Concrete to would need to be described m an actual hcense apphca.

Sulfunc AaJ Atta k," Matenah leumd of the simon o9 non.

Com'ctc lutitutc. ~litle No. 85' h146, p. 4S t. November /

licccmber 1%S.

Connnent 92: Section 7.3.5.6 (p. 7-14)

Appherlwhdory Counca AIC3 bo,"lintatne Pai-udons for the lieselopment of Seismic Regulations for Secuon 7.3.5.6 of the Pl.ASAR auumes that the per' Huddings," Palo Alto, Cahfonna,1978.

formance objecuves of the appropnate sections of 10 Cl'R 61.43 w di be met because of the detailed annual cu-AtLmun, A, and L A. lie.u ne, An Assewment of the mulative w ot Ler dose assewments for all rootine disposal i ong. Ielm Durabihty of Conciete in RadionuchJe operations iWables 73-2,73-3, and 73-4. In an actual Waste Repmitones? Umted Kinrdom Atomic 1.ncit~y bcense apphcalmn, this scetion should demonstaate that Authonts, ()dobu F)S4.

all assumptions are saliJ nnd rcasonable. includmg ielcr-encing other secuons rcpardmg worLer d,we estimates, as t 'ohen, M. I L, and A. lientur,"Dur abiht) of Poilland Ce-appropriate. Infonnauon in the vanous secuons o! tbc h' ment Sihca i ume Postes in Marnesium Sulfate and So-cense appucatun should be conmtent.

dium Sulf ate Solunons," Matamh >ournd of untriwin air

('onoctc hnhtatc, pp.14s - 157, Maglune 10SS.

Comment 93: Section 7.3,6 (p. 7-14) t h tnc Powcr Rescatch Insutute, Report No.

C "E yns and Com oI1 ow-l es el Waste 1)is-Section 7.3h of the Pl.ASAR identibes only three ref er.

ence docutnents and does not mclude au of'the appropri-P#'al 1 anhug Palo Aho, CaMunia. August 10S7.

(Propnetary mlormahon. Not pubhcly available) ate sectinns of the Pl.ASAR that are apphcable.

-., Report No. NP4218-CCMI, "lhe ll ARRil:R Comment 941 Section 7.4 (p. 7-14)

Code A loot hir lisumaunt the 1 ont lenn Pedonn-ance of I ow-l nel Radioactive Waste Dis}w at I aahties, Seehon 7.4 of an actual hcense application shoulJ include User's ManualJ Palo Alto, California, l~chruary 1959 a detailed desenpuon of the administratise orgam/ation (Ptoprietary mformation. Not pubbely avmlable) tc*ponslblC for the ladiation protection prortam, in+

cludmp the authonty and responubdity of the mdwuloal l'attuht, N. l., and it, P. Ilughes,"Ordmary Porlland Cc-occupymg cach posinen. In addition,it should proude a ment Mnes With SelectcJ AJnustures Subjected to Sul-detaded descriphon of all sue-speahe health phpics pro-fune And Attac L," Matenalsloarnalof the <lmnican Con-cedures designed to satisfy the ruidehnes in NURI GI octc

Insntate, htte No.

85-M50 p.

$12.

CR-3343, NURI:G-1199 and NURIE120R Such in.

November /Dccc mber,19%R 4

formahon should include a list of all equipment, mstrumentation, and fachties used in conducting the International Comunwon on Radioloreal Protection, program. Substantial discuwon should be devote? o in.

Puhucation 30, l.imin for lotaicwf Radmnuc/n/cs ly IPor A -

ternal and esternal personnel momto'mp, inaudmp t rs. Petramon Prcss, Odord, linpland, J uly 1978.

methods of recoidmg. reporting, anJ analyring t esults. as well as all requirements set forth m 10 C1'R Part 20.

Portland Cement Awocution, PCA 15()01, "Hfects of

/diove all, the described raJianon saf ety pr ogram must be Substances on Concrete and (imde to Protectke iteat-capable of being implernented at the HGV fachty, ments," M okie, llhnos,1W.

N U RI E 1375. Vol. 2 44

Raju, P S. N., and P. Ibyaratnam, "Durabihty of Co+

Standard for Selection, Quahfication and I r.uning of Pet.

crete lhposed to lhlute Su!furie Aad,"Itui! Jug unJ Dwi-wnnel for Nuclear Power Plants," New T o:L,1981, renment, Vol.19. Nt 2, pp 75-74,1934.

Amenean Soact) for lestmp anJ Materials, ASIM Saynard, L M.,

• Salt Action on Conacte," Speaal Re-Cl274S, " Standard Test Method foi Speohe Grauty port 84-25. U.S. Anny Cold Regions llesearch and l'nge anJ Abepiian of htute Arricrate," Phdade!phia, necrmg laboratory, Ilanover, New Ilarnpshue, IV A4.

Pennsylvama,195N Spinks et al,'Tiaccr Studies of thf f usion in Set Portland

-, ASI M Cl254S " Standard 'lest Method for Spe-Cement," Canadian Awnalef Tn hnolog, Vol. 30. No.1, ethe Giavity and Absor ption of I me Arfrerate," 195S.

pp.20-28,1952.

--, ASl'M C22747,"StanJ.ud l est MethoJ for Poten-lLS. Ilureau of Reclamation, Com tric Afamtal, bth I'di.

tial Alkali Reactmty of Cement Arrrerate Condnna-non, Denver, Crjorado,1975.

tions (Mortar -llar MethoJh* 14S7.

Winkler, E. M., Stone l'rojuracs. DroNiay in Man 's I:m-i.

-, ASTM F269 57," Stand ud i t st MethoJ for Poten-ronment, Spnnper Verlap Vienna,1073.

tial Ratmty of Arrrerates (Chenucal Method" 19R Yama/ali, M.,' Thermal Crackm t of a i hna Wall," Con.

-, ASTM C2954N " Standard Praethe for Petro-urteln:rmational. American Coner ete Institute,Vol. h. p.

Praphic lianonation of Aprtcrates f or Cont rete," 19k5.

40 Aucust 1966.

-. AS'l M C55646" Standard Test Method f or Poten-Ying Yu. l_, and W, Qui dong,"lhe Mechanism of Car-tal Allah Reactmty of Carl >onate Roch for Concrete bonat on of Mor tars and the Dependence of Carbonation Argtcrate (Rod C)hndet MethoJ h" 1950.

on Pore Structure," SP100-95 American Conetetc Inun

.A O>NW. " Mand ud Te>t MethoJ io Rew tance of@Loneretc to Rapid 11ce/mp and thawmr." lost tute, Detroit, Michiran, Vol 2, p.1915,19 A7.

CODI S AND SI'ANDARDS

, ASl M C67146," Standard Test Method for Onto I

on of onack Spwunens pied to Fin /-

Amentan Concrete Insutute, ACI 20 L 2 R "/ 7 82),

t mr, 1 %6.

" Guide to Durable Concrete, Detroit. Michiran,197 7 with remions of 1952.

_., gg pg

,' R dM Puh M

"." " " ""h t."

"'uw Arru7ain m ACI 212 2R41(Xb),

• Guide f or l!se of Adn ium es onen t nWal anon hoM ures, jnkune

^

in Concrete," 1981 wnh reuuons of 1986.

19S7.

, ACI 31843 "lluildmr Code Requacments for Re-ASTM D444 7409% StanJard 3penheation f or inforced L uncrete, 19S3.

Asphalt Used m D.unpproofmy anJ Watetproohny,"

19'i9 anJ tcapptoved in 1983.

--, ACI 34940, "t, ode Requirements for Nuclear Safety Related Concrete Structures " 1950.

--, ASTM D2176 SS," Standard Speaheahon for As phalt Glass (l'elt) Used in Roofmp and Waterproohng,"

, Al,l 34945, "l,m.e Requirements f.or N.uclear 19 9,

Safety Related Concrete Structures," 1985.

, ASTM D3020- 85,"StanJard Spcof cat on for Poly-

, ACI 350R43, " Concrete Sanitary lingineerinP ethylene and 1 thylene Copoluner Plasue Shet. inn for Structures," 1953, Pond, Canal and Reser voir 1.irling." 1%5.

ACI $15 lR-79(SS). "GuiJe to the Use of Water-ASTM I)3M183, " Standard Tnt Method for proofing Dampproofing Protective and Decoratne liar-Chenucal Redstance of Remforced Ihermosettmp Resm rier Systems for Concrete," 19 /9 with revidons of 19S5.

Pipe in a Deflected Condition," 1%3.

American National St mdards institute, ANSI

-, ASTM P214. " Proposed 'l est Method for Acceler.

N101.h-1972, " Concrete Radiation Shields," New York, ated Detection of Potenttalb Deleterious inpansion of 1972.

Mortar liars !)ue to Allahdihea Reaction.' 1990.

American Nanonal Standards insutute/Amencan Nu-Canadun Standards Awociatu m. CS A A23.2-14 A, t in-clear Society, ANSI /ANS 3,1-1981, " Amenean Nation:d tano, Canada.

45 NURI-G-1375 Vol 2

i 1

l i

j International Conference of ituildmg Offielais," Uniform

-. NI:l'A901-1981. *l]niform Coding foi l'irc l'rotec.

[

lluilding Cale " Whittier. Cahfornia,19RS.

tion."

l i

ll.S. Army linginecting Waterways thperiment Station, l

National l' ire l'rotection Association, Nil'A 801-1956, flandlwa fw Conrirre und Cornent, llequirements, Stan-

• llecommended 17 ire l'iotection l'ractue in l'acilities dard l'ractees, Tetts and Test hiethnis, CitD-C 20, I

llandling 1(adioactice hiatetials." Qumey, hinnachu-

" Test hlethal for l(esistance of Concrete to llapid itt ect-l

setts, ing and'lhawing." Vicksburg, hiiniuippi,1949.

!~

l i

i I

l l

l i

i p

1 1

l-1 l

l i

i l-l t

NUltlIG-1375 Vol. 2 46 i

tec +ono us v s uveti Au m co. Aic.nv couuuou i emna rwm n h.%. Iter. elu. Ad,1 Vol.

{Assvied by t (f-60) igi A3 terW1.rn f 40m.

Of4 M 1100 t**- d a"r )

2". W BIBLIOGRAPHIC DATA SHEET NUlti!G-137$

ist nowum. m e,,

..,,,wi Y"I' 2 t ina Anu usuin a a van no vo evo w itu Saf(ty 1: valuation lieview of the l

Yl ^"

MONT "

Prototype 1.icense Application Safety Analysis heport:

llelowground Vault September 1991

4. t P4 On GntANI tageant n kAVINHoI t,

I s PL Ot nL> pn I 17 nal t

r. iwoo covt nt u e,cas4. o.i..i NAMt_ ANU ALoul S $ pt Ne10. ger,ac Divmm, On.c. or ns gim. U is tu. sear nepavy L :e4 6s.m.. d 6 *t.n> On%NG On3 Ar4/ Al tun 0

m a v o n n. n em e ew. nom u a.m..no menno.

• o 3 ihvision of low-1.evel Wt.ste Management and Decommisi.ioning Office of Nuclear Material Safety and Safeguards U.S. Nudcat Regulatory Commission Washington, DC 20555 y e..wsonex. Una Amwi. aA,.s Ana Arm ss ne on1 im.

cw,....w..-

o t w o.ox o w,0.,,w %s,an. oeu. y n,m.

u a tw..r nuvoi.wr emenm. eno mam.*eu 1 Same as nbove 1(L bui4 'LL Mt N T A H f f 4Ul 4. S Nor_e

11. ADS 1nACT (?ce wmos or 6est)

The U.S. Nuclear Reputatory Commission (NitC) staff and consultants reviewed a Prototype Ixense Appheation Safety Analysis iteport (Pl.AS AR) submitted by the U.S. Department of linetry (DOII) for the below ground vault (llGV) rdter na-tive method of low level radioactive waste disposal. In Volume 1 of NUltr.G-1375. the NitC stalf piovided the safety review results for an carth mounded concrete bunker Pl.ASAR. In the current report, the staf f focused its eview on the design, construction, and operational aspects of the !!GV Pi AS AR. The staff developed review comments and questions using the Standard Review Plan (SRP), Rev.1 (NURIIG-1200)as the basis for evaluatmg the acceptahdity of the informa-tion provided in the llGV PLASAR. The detailed teview comments pr ovided in this t eport are intended to be useful guid, ance to facility de elopers and State r egulators in addressing issues hkcly to be encoumeird in the icview of a license appli.

cation for a low level waste disposal facihty.

O AV ALAllilll Y %)I All ML NT

12. Kf Y WORDS/DE SCalPioR$ 6.tst wards y phe.s.s that *dt.uist fesearvfp g en loculug the repw t )

Iinhmited low-level radioactive waste dispos.al, belowground vault, NitC staff safety u st conav et mesoention review comments, prototype beense application a m noo Unclassified a us n,.mo Unclassified n rma n o, t u.t e.

16 6HKl fJC F OflM 336 (2-B9)

E

l THIS DOCUMENT WAD PRINTED USING RECYCLED PAPER

I f

UNITED STATES

~AG em.. ma.

7 NUCLEAR REGULATORY COMMIS510N

"'"A*ja;p**^*

$M WASHINGTON, D.C,20M6 9

n -....,

h

. OfflCIAL DUCINE SS PENALTY FOR PHrVATE USL 6300 P<b 64 1

1 l

y 'l; e,'

M g

'OZ.

aa

.O m

d R

wm O-O d

4#

cni 9W

%\\

EI I

OZ

_-