ML20148D508
| ML20148D508 | |
| Person / Time | |
|---|---|
| Issue date: | 05/19/1997 |
| From: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rowland T ENERGY, DEPT. OF |
| References | |
| REF-PROJ-M-32 NUDOCS 9705300264 | |
| Download: ML20148D508 (6) | |
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i May 19, 1997
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l Mr. T. J. Rowland, Director U.S. Department of Energy West Valley Area Office P.O. Box 191
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West Valley, NY 14171-0191 i
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Dear Mr. Rowland:
j The U.S. Nuclear Regulatory Commission has completed its review of the i
Drum Cell and NDA and SDA Issues Papers. My staff's comments are enclosed.
My staff also reviewed the preliminary outline of the Supplement to the Draft j.
EIS and had no comments.
If you have any questions, please contact I
Jack Parrott at 301-415-6700.
j Sincerely, t
[0RIGINAL^ SIGNED BY:]
l John W. N. Hickey, Chief i
Low-Level Waste and Decommissioning l
Projects Branch i-Division of Waste Management Office of Nuclear Material Safety j
and Safeguards Docket No. M-32 i
Enclosure:
As stated cc:
P. Piciulo, NYSERDA hf k
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NUCLEAR REGULATORY COMMISSION
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May 19, 1997 4
Mr. T. J. Rowland, Director U.S. Department of Energy West Valley Area Office P.O. Box 191 l
West Valley, NY 14171-0191
Dear Mr. Rowland:
The U.S. Nuclear Regulatory Commission has completed its review of the Drum Cell and NDA and SDA Issues Papers. My staff's comments are enclosed.
4 My staff also reviewed the preliminary outline of the Supplement to the Draft EIS and had no comments.
If you have any questions, please contact i
Jack Parrott at 301-415-6700.
Sincerely, l
Y/
John W. N. Hickey, Chief l
Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards Docket No. M-32
Enclosure:
As stated cc:
P. Piciulo, Ni iRDA
i Drum Cell Issues Pacer Comments Section 9.1.2.1. 2nd Para.. o. 1 The document states that commercial waste disposal sites have already performed performance assessments to establish waste acceptance criteria.
Note that no performance assessments have been performed for the Barnwell site to allow drum cell wastes.
Barnwell is allowed to accept only wastes with incidental concentrations of TRU nuclides (generally less than 1 percent of the total activity).
In addition, the State of South Carolina desires to minimize the total TRU inventory at the Barnwell site, and, therefore, the acceptability of the drum cell wastes is uncertain.
If DOE proposes to use the Barnwell site, further discussions with the site operator and the State of South Carolina should be undertaken to resolve the acceptability of tnese l
wastes at Barnwell.
The issues paper should also be revised to reflect the uncertainty of the acceptability of the drum cell wastes at Barnwell.
Section 9.1.2.2. r 2 We suggest presenting costs for 'ooth disposal at Barnwell and at a DOE facility. Costs for transportation should include both rail and truck options.
For transportation to Barnwell, we suggest using the actual mileage.
i For transportation-to a DOE facility, the 2500 mile value is acceptable.
I Section 9.1.3.1. o. 2 To resolve the 10 to 100 nCi/gm issue, if a commercial waste disposal site is selected, DOE will need to work with the disposal site operator and the applicable regulatory agency to perform the performance assessment.
NRC staff is prepared to review the completed performance assessment, and, if j
acceptable, to concur in the resolution of the issue.
If a DOE disposal site is selected, DOE should provide an appropriate summary of the performance assessment used to demonstrate that the DOE site is suitable for the drum cell wastes.
NRC will review and, if acceptable, provide a concurrence to resolve the issue.
Section 9.2.3.1.b. o. 5 The issues paper assumes that after the 100 year institutional control period the NRC license will be terminated.
If materials remain onsite that are above NRC regulatory levels, NRC would not terminate the license.
Suggest deleting the phrase, "at which time the NRC license would be terminated and intruder scenarios are assumed to begin."
Section 9.3a.3.2.c.
D.
9 The issues paper assumes that after the 100 year institutional control period l
the NRC license will be terminated.
If materials remain onsite that are above l
NRC regulatory levels, NRC would not terminate the license.
Suggest deleting l
the phrase, "at which time the NRC license would be terminated and intruder 1
Enclosure
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s scenarios are assumed to begin."
i Section 9.4.3.1.a. o. 12 The issues paper assumes that after the 100 year institutional control period the NRC license will be terminated.
If materials remain onsite that are above i
NRC regulatory levels, NRC would not te-inate the license. Suggest deleting i
the phrase, "at which time the NRC license would be terminated and intruder l
scenarios are assumed to begin."
c 2
l NDA and SDA Issues Paper Comments Section 7.1.1. o. 1 The issues paper discusses the Container Management Area, which will be used for treatment and packaging. Have the proposed treatment techniques been analyzed on a cost-benefit basis? Arbitrary selection of treatment processes can artificially raise the costs for this option. Also, disposal costs should be presented for both Barnwell and a DOE site, and transportation costs should include both rail and truck shipments. Disposal costs for soils should use typical costs for disposal at the Envirocare facility. DOE regularly uses Envirocare and should have representative pricing data that would be suitable for the cost analysis.
i' Section 7.1.2.1.a. 1st Para.. o. I 10 CFR 61 waste classification guidance does not apply to reprocessing wastes of the type in the NDA.
Section 7.1.2.1.a. 2nd Para.. o. 1 Suggest adding that under the low-Level Radioactive Policy Amendments Act, DOE is required to accept for disposal commercially generated Greater Than Class C (GTCC) wastes, a
Section 7.1.3.1.b. 2nd Para..
p.
3 Note that the operator of the Hanford commercial LLW disposal site is USEcology not Ecology and Environment.
The issues paper states that Envirocare is unsuitable at this time for the wastes in this alternative.
Note that the Envirocare site would be suitable for the low-activity soils assumed to be generated under this alternative.
It would be reasonable to assume disposal of the soil wastes at Envirocare to i
reduce costs.
In the past, DOE has used the Envirocare site for low-activity waste disposal.
General DOE should consider the option of partial exhumation of wastes in the NDA and SDA. Wastes that might be considered include the spent fuel, the cladding hulls, other GTCC wastes, and other wastes that present unusual long-term hazards, such as the solvent tanks.
Section 7.3.3.1. 1st Para.. o. 8 In the third sentence, reference to 20.304 should be 20.302.
10 CFR 20.304 was applicable to onsite disposals that were limited by regulation.
The West Valley NDA was licensed under 20.302.
1 Enclosure
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1 Also, the issues pape'r proposes petitioning the NRC under 20.2002 for a perpetual license. We will need to further discuss this procedural mechanism
. with our Office of the General Counsel to determine the appropriate licer. sing process for this alternative.
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