ML20138C627

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Submits Comments Re 970224 Draft Rept from Chem-Nuclear Systems,Entitled Verification of Performance Objectives
ML20138C627
Person / Time
Issue date: 04/18/1997
From: Lohaus P
NRC OFFICE OF STATE PROGRAMS (OSP)
To: Autry V
SOUTH CAROLINA, STATE OF
References
NUDOCS 9704300158
Download: ML20138C627 (7)
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$PMo l pa anog g" t UNITED STATES g

't j NUCLEAR REGULATORY COMMISSION l

I WASHINGTON, D.C. 20555 4 001

Dear Mr. Autry:

In your letter dated February 24, 1997, you provided the U.S. Nuclear Regulatory Commission a draft report from Chem-Nuclear Systems, LLC (CNSI),

entitled " Verification of Performance Objectives" for our information and comment. Our comments, which follow, are principally directed at two performance objectives that relate to public health and safety and closure design of the facility. These are performance objectives E and H.

Performance objective E envisions that CNSI would demonstrate by measurement and/or modeling during operation and after site closure that concentrations of radioactive material which may be released will not result in exceeding an annual dose limit to any member of the public. To date, we understand that CNSI has performed predictive modeling only for tritium. CNSI's report references studies that characterize the tritium plume and calculate the potential dose. CNSI estimates the dose from the tritium plume at Mary's

' Branch Creek to be 60 mrem from ground water and 3 mrem from surface water.

CNSI further states that the real dose to the public is negligible because there is no current receptor. During our December site visitg staff was informed that tritium concentrations in the creek exceeded 10 pCi/L. Based on the tritium concentration trends, staff notes that the tritium concentrations may exceed the annual 10 CFR Part 20 effluent limits. This could require greater control over this area than currently exists, such as restricting access.

CNSI discusses methods that would be used to model the dose for certain radionuclides over a period of 500 years. As you are aware, NRC released a preliminary draft Branch Technical Position (BTP) on performance assessment for low-level waste disposal facilities in January of 1994 to Agreement States and Federal agencies. In addition, staff conducted a workshop in November of 1994 on the BTP. The final draft BTP is expected to be published shortly for public review and comment and should be finalized by the end of this year. It ,

appears from your letter and CNSI's report that CNSI plans to conduct a / /

performance assessment considering all radionuclides at this time and at site ' /,

closure. This approach is consistent with the methodology prescribed in the /#

BTP, in that the BTP recommends using performance assessment to predictively estimate dose both periodically during operation and at closure. A similar approach is identified for the US Ecology Hanford facility in the State of Washington license condition 66, which requires the performance assessment for this site to be updated periodically.

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"~2 9704300158 970418 PDR STPRG ESGSC 69- (WS-PDR

%. Adtry We have three comments on CNSI's plan to conduct the performance assessment. First, the time frame over which doses are projected should be in excess of the 500 years proposed by CNSI.

The NRC staff recommends that applicants use a time frame of 10.000 years for new sites. We l suggest that you consider, as a minimum, projecting potential doses through a 1.000 year time l period. Second, when no specific data are available. CNSI plans to use methods in NUREG/CR-4370. " Update of Part 61 Impacts Analysis Methodology." dated January 1986. This document was developed to sup) ort the environmental impact statement for Part 61. It cautions against using the analysis metlodology in a site-s)ecific application. Further, the staff discussed the inappropriate use of the IMPACTS metlodology and codes in the 1994 workshop. If CNSI plans to use the IMPACTS methodology, they should demonstrate why it is appropriate to use rather than a more site specific analysis for the Bernwell site. Third. CNSI plans to obtain the dose rates for C-14. I-129. Np-237. and Tc-99. In addition to these radionuclides. CNSI should also consider additional long-lived radionuclides such as Cl-36. U-238. Th-232, and Pu-239.

Performance objective H requires CNSI to eliminate the potential for erosion or loss of site or trench integrity from factors such as ground water, surface water, wind. subsidence, and frost action. CNSI's report references use of a 100-year storm event. This is inconsistent with the approach outlined in NUREG-1200. Rev. 3. " Standard Review Plan for the Review of a License Application for a Low-Level Radioactive Waste Disposal Facility." dated April 1994. Section l 5.1.1 of this NUREG references using the BTP " Design of Long-term Erosion Protection Covers for '

Reclamation of Uranium Mill Sites." which recommends using the Probable Maximum Flood (PMF) as a design basis. If CNSI alans to use the 100-year storm event, they should demonstrate why it is appropriate to use ratler than the PMF.

Finally, we recognize that CNSI's summary report is conceptual in nature, and our review is limited to the information contained in their report. As CNSI provides you with additional details, we would be pleased to offer additional comments. We will forward a copy of the final draft BTP on performance assessment to you once it is published.

You indicate that you are working with CNSI to establish a time frame for completing these items. We would appreciate further information abwt the expected time-frame for CNSI's completion of the analyses and your review. We would be pleased to provide technical ,

assistance to you in reviewing this work, if requested. If you have any questions or comments, please contact me at (301) 415-2326. l l

1 Sincerely. )

[ Original Signed By]Cardelia Maupin~for] i Paul H. Lohaus. Deputy Director l Office of State Programs TICKET: DWM-090' DISTRIBUTION:

Central. File > LLDP r/f MFederline JAustin NMSS r/f i JKennedy DWM r/f ACNW OSP r/f DOCUMENT NAME:s:\dwm\1ldp\teh\autry1.let *see previous concurrence CP/ PROOFED / april 14, 1997 OFC LLDP' TECHED' LLDP' LLDP* DWM' OGC+

NAME THarris/crv EKraus RNelson JHickey JGreeves WRearner DATE 4/1/97 4/1/97 4/2/97 4/2/97 4/7/97 4/8/97 )

OFC NMSS* OSP' OSP' NAME CPaperiello PLohaus RBangart DATE 4/15/97 4/18/97 4/18/97 OFHC AL R'ECORD COPY ACMW: YES X NO IG : YES NO X LSS : YES _ NO .)L

I V. Autfy l

. We have three comments on CNSI's plan to conduct the performance assessment. First, th ime frame over which doses are projected should be in excess of the 500 years proposed by SI. l The NRC staff recommends that applicants use a time frame of 10,000 years for new ' es. We l suggest that you consider, as a minimum, projecting potential doses through a 1, 0 year time period. Second, when no specific data are available, CNSI plans to use metho in NUREG/CR-4370, " Update of Part 61 Impacts Analysis Methodology," dated January 1986. his document was developed to support the environmental impact statement for Part 61. It utions against using the analysis methodology in a site-specific application. Further,'the 'aff discussed the inappropriate use of the IMPACTS methodology and codes in the 1994 wo shop. If CNSI plans to use the IMPACTS methodology, they should demonstrate why it is appr riate to use rather than a more site specific analysis for the Barnwell site. Third, CNSI p ns to obtain the dose rates  ;

for C-14, I-129, Np-237, and Tc-99. In addition to these radio clides, CNSI should also  !

consider additional long-lived radionuclides such as Cl-36, U- 38, Th-232, and Pu-239.

Performance objective H requires CNSI to eliminate the po ntial for erosion or loss of site or j trench integrity from factors such as ground water, surf ce water, wind, subsidence, and frost action. CNSI's report references use of a 100-year st m event. This is inconsistent with the approach outlined in NUREG-1200, Rev. 3, " Standard R iew Plan for the Review of a License Application for a Low-Level Radioactive Waste Dispo al Facility," dated April 1994. Section 5.1.1 of this NUREG references using the BTP ' Des' n of Long-term Erosion Protection Covers for i Reclamation of Uranium Mill Sites," which reco nds using the Probable Maximum Flood (PMF) as I a design basis. If CNSI plans to use the 100- ar storm event, they should demonstrate why it is appropriate to use rather than the PMF.

Finally, we recognize that CNSI's summary eport is conceptual in nature, and our review is limited to the information contained in eir report. As CNSI provides you with additional details, we would be pleased to offer ditional comments. We will forward a copy of the final l draft BTP on performance assessment t you once it is published. '

You indicate that you are working th CNSI to establish a time frame for completing these items. We would appreciate furth information about the expected time-frame for CNSI's completion of the analyses and y ur review. We would be pleased to provide technical assistance to you in reviewing his work, if requested. If you have any questions or comments, please contact me at (301) 41 2326.

/

Sincerely, (Original Signed By]

Paul Lohaus, Deputy Director Office of State Programs TICKET: DWM-090 DISTRIBUTION:

Central File ( DP r/f MFederline JAustin NMSS r/f JKennedy DWM r/f ACNW OSP r/f DOCUMENT NAME: s :)('dwm\1 l dp\ teh\ aut ryl . l e *see t previous concurrence CP/ PROOFED / APRIL 14, 1997 OFC LLDP* / TECHED' LLDP' LLDP' DWM' OGCI NAME THarri crv EKraus RNelson JHickey JGreeves WReamer DATE 4/1 97 4/1/97 4/2/97 4/2/97 4/7/97 4 / Pf/97 OFC /Nh8S OSfh OSP f(

  • s MAME CPap eho PL RBange DATE 4/h7 4/k9 4/ /97 OFFIC AL RECORD COPY ACNW: YES X No IG : YES NO X LSS : YES NO X

T. Autry We have three comments on CNSI's plan to conduct the performance assessment. First the time-frame over which doses are projected should be in excess of the 500 years proposed by CN51.

The NRC staff recommends that applicants use a time-frame of 10.000 years for new sites. We suggest that you consider, as a minimum, projecting potential doses through a 1.000' year time i period. irf NUREG/CR-4370. " Update of Part 61 Impacts Analysis Methodology." dated January prf 1986.Secon developed to sup] ort the environmental impact statement for Part 61. It caut1ons against using the analysis metlodology in a site-s]ecific application. Further, the staff discussed the inappropriate use of the IMPACTS metlodology and codes in the 1994 workphop. If CNSI plans to use the IMPACTS methodology, they should demonstrate why it is approppiate to use rather than a more site specific analysis for the Barnwell site. Third, CNSI plans to obtain the dose rates for C-14, I-129. Np-237 and Tc-99. In addition to these radionuc consideradditionallong-livedradionuclidessuchasCl-36,U-23,/ ides.CNSIshouldalso Th-232, and Pu-239.

Performance objective H requires CNSI to eliminate the poten'~al for erosion or loss of site or trench integrity from factors such as ground water, surface ater, wind, subs.idence, and frost action. CNSI's report references use of a 100-year storm vent. This is inconsistent with the approach outlined in NUREG-1200, Rev. 3. " Standard Revie Plan for the Review of a License Application for a Low-Level Radioactive Waste Disposal acility," dated April 1994. Section 5.1.1 of this NUREG references using the BTP " Design Long-term Erosion Protection Covers for Reclamation of Uranium Mill Sites," which recommends using the Probable Maximum Flood (PMF) as

.a design basis. If CNSI 31ans to use the 100-year torm event, they should demonstrate why it is appropriate to use ratler than the PMF.

Finally, we recognize that CNSI's summary repo - is conceptual in nature, and our review is limited to the information contained in their report. As CNSI provides you with additional details.. we would be pleased to offer additi nal comments. We will forward a copy of the final draft BTP on performance assessment to you nce it is published.

You indicate that you are working with SI to establish a time frame for completing these items. We would appreciate further in ormation about the expected time-frame for CNSI's I completion of the analyses and your r view. We would be pleased to provide technical assistance to you in reviewirg this ork, if requested. If you have any questions or comments, l please contact me at (301) 415-23 Sincerely,

[0riginal Signed By]

Paul Lohaus. Deputy Director Office of State Programs TICKET: DWM-090 DISTRIBUTION:

Central File LLDP r/f MFederline JAustin NMSS r/f 3 JKennedy DWM r/f ACNW OSP r/f DOCUMENT NAME:s:\dwA lldp\teh\autry1.let *see previous concurrence OFC ~ LLDP* TECHED' LLDP' LLDP* DWM' OGh WAME THarris/cr/ EKraus RNelson JHickey JGreeves WReamer  ;

DATE 4/1/9[ 4/1/97 4/2/97 4/2/97 4/7/97 Ik /d/97 OFC NblSS OSP OSP NAME MPaperiello PLohaus RBangart DATE / 4/ /97 4//97 4/ /97 OFFIC AL RiCORD COPY ACMW: YES X NO IG : YES NO X LSS : YES NO X

il. AutFy '

i We have three comments on CNSI's plan to conduct the performance assessment. First, the time-frame over which doses are projected should be in excess of the 500 years proposed by CNSI.

.We TheNRCstaffrecommendsthatapplicantsuseatime-frameof10,000year suggest that you consider, as a minimum, projecting potential doses through a 1,000 year period. Second, when no specific data are available, CNSI plans to use methods in NURE /CR-

4370, " Update of Part 61 Impacts Analysis Methodology," dated January 1986. This docu ent was
developed to support the environmental impact statement for Part 61. It cautions ag nst using the analysis methodology in a site-specific application. Further, the staff discus d the
inappropriate use of the IMPACTS methodology and codes in the 1994 workshop. If SI plans to use the IMPACTS methodology, they should demonstrate why it is appropriate to u rather than a more site specific analysis for the Barnwell site. Third, CNSI plans to obta the dose rates for C-14, I-129, Np-237, and Tc-99. In addition to these radionuclides, CN should also consider additional long-lived radionuclides such as Cl-36, U-238, Th-232 and Pu-239.

Performance objective H requires CNSI to eliminate the potential for osion or loss of site or  !

trench integrity from factors such as ground water, surface water, nd, subsidence, and frost action. CNSI's report references use of a 100-year storm event. his is inconsistent with the approach outlined in NUREG-1200, Rev. 3, " Standard Review Plan r the Review of a License 1

, Application for a low-Level Radioactive Waste Disposal Facili ," dated April 1994. Section  ;

5.1.1 of this NUREG references using the BTP " Design of Lon -term Erosion Protection Covers for Reclamation of Uranium Mill Sites," which recommends usin the Probable Maximum Flood (PMF) as i

. a design basis. If CNSI plans to use the 100-year stor event, they should demonstrate why it is appropriate to use rather than the PMF.

Finally, we recognize that CNSI's summary report

  • conceptual in nature, and our review is i limited to the information contained in their re ort. As CNSI provides you with additional details, we would be pleased to offer addition comments. We will forward a copy of the final draft BTP on performance assessment to you o e it is published.

You indicate that you are working with CN to establish a time frame for completing these items. We would appreciate further inf mation about the expected time-frame for CNSI's  ;

completion of the analyses and your r iew. We would be pleased to provide technical '

assistance to you in reviewing this rk, if' requested. If you have any questions or comments, l please contact me at (301) 415-232 . I Sincerely,

[0riginal Signed By]

Paul Lohaus, Deputy Director Office of State Programs DISTRIBUTION:

Central File LLDP r/f MFederline JAustin NMSS r/f JKennedy DWM r/f ACNW OSP r/f DOCUMENT NAME: s : \dwrfi\ l l dp \ te h \ au t ryl . l e t *see previous concurrence 1 OFC LLDP' '

TECHED' LLDP' LLDP' p OGC NAME THarris/ cry EKraus RNelson JHickey ev s WReamer DATE 4/1/97

! 4/1/97 4/2/97 4/2/97 / /97 4/'//97 OFC / NbSS OSP OSP NAME/ IPaperiello PLohaus RBangart 7 4/ /97 4/ /97 4/ /97 i OFFICIAL RECORD COPY ACNW: YES 1 NO _ IG : YES NO X LSS : YES NO X i

l V. Autty l Se have three comments on CNSI's plan to conduct the performance assessment. First, the< time-frame over which doses are projected should be in excess of the 500 years proposed by NRC staff recommends that Applicant's use a time-frame of 10,000 years for new sites.,CNSI. We The suggest that you consider, as a minimum, projecting potential doses through a 1,000 year time period. Second, when no specific data are available, CNSI plans to use methodsAn NUREG/CR- ,

4370, " Update of Part 61 Impacts Analysis Methodology", dated January 1986. .This document was developed to support the environmental impact statement for Part 61. . It cautions against using '

the analysis methodology in a site-specific application. Further, the staff discussed the inappropriate use of the IMPACTS methodology and codes in the 1994' workshop. If CNSI plans to use the IMPACTS methodology, they should demonstrate why it is appropriate to use rather than a more site specific analysis for the Barnwell site. Third, CNSI/ plan's to obtain the dose rates for C-14, I-129, Np-237, and Tc-99. In addition to these radj6nyclides, CNSI should also consider additional long-lived radionuclides such as Cl-36,,U-238, Th-232, and Pu-239.

Performance objective H requires CNSI to eliminate the poth,ntial for erosion or loss of site or trench integrity from factors such as ground water, surface water, wind, subsidence, and frost action. CNSI'sreportreferencesuseofa100-yearstorgevent. This is inconsistent with the approach outlined in NUREG-1200, Rev. 3, " Standard Rev Application for a Low-Level Radioactive Waste Disposal)4w Plan Facility", for the dated Review April 1994.of aSection License 5.1.1 of this NUREG references using the BTP "DesigVof Long-term Er.: fon Protection Covers for Reclamation of Uranium Mill Sites", which recommerjds using the ProbEe Maximum Flood (PMF) as a design basis. If CNSI plans to use the 100-year storm event, they should demonstrate why it is appropriate to use rather than a the PMF.

Finally, we recognize that CNSI's summary repo/rt is conceptual in nature, and our review is

/g limited to the information contained in their report. As CNSI provides you with additional details, we would be pleased to offer additional comments. We will forward a copy of the final draft BTP on performance assessment to ydu once it is published.

You indicate that you are working with NSI to establish a time frame for completing these items. We suggest thet CNSI's verifjcation and South Carolina's review be completed in the near term, preferably before our next review cycle. We would be pleased to provide technical assistance to you in reviewing thii work, if requested. If you have any questions or comments, please contact me at (301) 415-2326.

/

Sincerely,

[0riginal Signed By]

/ Paul Lohaus, Deputy Director

/ Office of State Programs DISTRIBUTION:

Central File LLDP /f MFederline JAustin NHSS r/f JKennedy DWM,//f ACNW OSP r/f DOCUMENT NAME:s:\dwm\.11dp\teh\autryl.let f f OFC LLDP TECHED LLD / LL DWM OGC NAME THarris/ [ EKraus RNelso JHic[e JGreeves WReamer DATE 4/ U97  ! 4/US7 4/he7 4/ /97 4tf/97 / /97 OFC NMS OSP OSP NAME CP riello PLohaus RBangart DATE / /97 4/ /97 4/ /97 OFFICIAL RECORD COPY ACNW: /ES X No IG : Ypt __ NO _X._ Delete file af ter distribution: Yes __ No _.,

LSS : YES NO X

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