ML20197H267
| ML20197H267 | |
| Person / Time | |
|---|---|
| Issue date: | 12/15/1997 |
| From: | Jack Parrott NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Mackin P CENTER FOR NUCLEAR WASTE REGULATORY ANALYSES |
| References | |
| REF-PROJ-M-32 NUDOCS 9712310234 | |
| Download: ML20197H267 (3) | |
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UNITED STATES
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j NUCLEAR REGULATORY COMMISSION WASHINoToN, D.C. 20MH001 g
December 15, 1597 MEMORANDUM TO: Patrick C. Mackin, Assistsr.: Diroctor Cer:ter for Nuclear Waste Regulatory Analysis M-WO FROM:
Jack D. Parrott, Project Scientist Low-Level Waste and Decommissionini; Projects Branch Division of Waste Management Off;ce of Nuclear Material Safety and Safeguards
SUBJECT:
COMMENTS ON EVALUATION OF NRC-PROPOSED DECONTAMINATION AND DECOMMISSIONING CRITERIA FF WEST VALLEY AND PRELIMINARY EVALUATION OF U.S.
DEPARTMENT OF ENERGY APPROACH TO PERFORMANCE ASSESSMENT AT THE WEST VALLEY DEMONSTRATION PROJECT U.S. Nuciear Regulatory Conimission staff has reviewed the Center for Nuclear Waste Regulatory Analysis'(CNWRA)" Evaluation of NRC-Proposed Decontamination and Decommissioning Criteria for West Valley " Overe", the CNWRA's comments were found ic be very helpful and the NRC staff has no technical comments on tne document. However, some comments represent CNWRA's interpretation of NRC regulations that may not necessarily be those of the NRC staff. Therefore, a disclaimer statement that the comments are the opinion of the CNWRA staff, but not necessarily those of the NRC, should be put into the iritroduction.
NRC staff has also reviewed the CNWRA's " Preliminary Evaluation of U.S. Department of Energy Approach to Performance Assessment at the West Valley Demonstration Project."
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Below are the NRC staffs comments.
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Overall imoression 9/
Generally a good and thorough analysis, however, there is too much extraneous detail.
Sections 2 and 4 are not needed and Attachment 1 can be referenced, but it is not necessary to /k/ Uh;
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incluie it.
Section 3 The second introductory paragraph irr. plies that the CNWRA believes that only the DEIS altematives that call for onsite disposal of waste need W be evaluated for the conceptual approach to performance assessment. However, all the attematives, including the removal and
Contact:
Jack D. Parrott, DWM/NMSS (301) 415-6700 hk[
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Section 3 The second introductory paragraph implies that the CNWRA believes that on!y the DEIS -
attematives that call for onsite disoosal of waste need to be evaluaied for the conceptual -
approach to performance assessment. However, all the altematives, including the rem aland unrestricted release alternative, involve the analysis of dose from residual contamina ' n and a performance assessment.
COMMENT 1: It is premature to comment on the integration of PA with siteth cterization and engineering design for site closure until the EIS is complete and a attem ive for the site is determined. (see also COMMENT 3 (v) and COMMENT 7)
COMMENT 2: NRC is also interested in what the CNWRA would like to ee in terms of a ratio'n and a omation of the system quality assurance strategy for implementing module integ/
code.
it may be premature to require DOE to'/
analyze emative conceptual models at COMMENT 3:
this stage (i.e., in the EIS) of its assessment of the siternative or the site. This will be appropriate when they do performance assessments for the referred alternatives. The important thing now is that they are looking at conservativ conceptual models and that they are thinking about appropriate attemative conceptual m els for their more detailed analysis.
i Section 5 Quality assurance review of code development ' d integration should be added to the list of priorities.
/
cc:
J. Linehan, PMDA,
- S. Fortuna, PMDA B. Meehan, AD_M
/
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P. Mackin 2
unrestricfed release alternative, involve the analysis of dose from residual contamination and a performance assessment.
COMMENT 1: It is premature to comment on the integration of FA with site characterization and engineering design for site closure until the EIS is complete and an altemative for the site is determined. (see also COMMENT 3 (v) and COMMENT 7)
COMMENT 2: NRC is also interested in what the CNWRA would like to see in terms of a quality assurance strategy for implementing module integration and automation of the system code.
COMMENT 3: It may be premature to require DOE to analyze alMmative conceptual models at this stage (i.e., in the EIS) of its sssessment of the alternatives for the site. This will be appropriate when they do performance assessments for the preferred alternatives. The important thing now is that they are looking at conservative conceptual models and that they are thinking about appropriate alternative conceptual models for their more detailed analysis.
Section 5 Quality assurance review of code development and integration should be added to the list of priorities.
cc:
J. Linehan, PMDA S. Fortuna, PMDA B. Stiltenpole, PMDA B. Meehan, ADM TICKET: CNWRA #970106
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