ML20198L062
| ML20198L062 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 10/14/1997 |
| From: | Curran D, Walker N AFFILIATION NOT ASSIGNED, CITIZENS AGAINST NUCLEAR TRASH, HARMON, CURRAN, SPIELBERG & EISENBERG, LLP. |
| To: | |
| References | |
| CON-#497-18571 ML, NUDOCS 9710240230 | |
| Download: ML20198L062 (17) | |
Text
.
.1837/
UNITED STATES OF AMERICA U.S. NUCLEAR REGULATORY COMMISSION S
4 BEFORE THE ATOMIC SAFETY AND LICENSING BO g
)
OCT 141997 4
In the Matter of
)
Louisiana Energy Services
) Docket No. 7 4(070ADN0Qe0N8WR woma D'
(Claiborne Ennchment Center)
) October 14,1 7\\
McVeo
)
D liil \\6 CITIZENS AGAINST NUCLEAR TRASII'S REPLY PROPOSED SUPPLEMENTAL FINDINGS OF FACT AND CONCLUSIONS OF LAW REGARDING CONTENTIONS B AND J.3 I. INTRODUCTION 1.
Intervenor, Citizens Against Nuclear Trash (" CANT"), hereby submits the fol-lowing Reply Proposed Supplemental Findings of Fact and Conclusions of Law regarding Contentions B and J.3 (hereinafter " Reply Proposed Supplemental Findings"). These Reply l
Findings respond to Applicant's Proposed Findings of Fact on Remand (October 7,1997)
(hereinafter "LES Proposed Findings") and NRC Staff's Proposed Findings Addressing Issue in Commission Remand Order CL1-97-11 (October 7,1997) (hereinafter " Staff Proposed Findi[1gs").
II.
TIIE RECORD CONTAINS NO EVIDENCE TIIAT A MINE EXISTS WITII GROUNDWATER CIIARACTERISTICS FALLING WITIIIN TIIE EXPECTED RANGE.
2.
The Staff asserts that it performed an " analysis" on the geo'ogic formations of the states in the Central Interstate Compact ("CIC"), which "shows there are actual sites with values compatible to the FEIS analysis." Staff Proposed Findings at 7, par.17. This alleged
" analysis" consists of a report, submitted to the Board after the close of the 1995 hearing, which asserts that the Pierre Shale formation underlying nearly all of central and western Nebraska and northwestern Kansas, has features " compatible with the FEIS sandstone / basalt site." he report entitled Location of Compatible Disposal Sites in Member States of the Cen-tral Interstate Low-Level Radioactive Waste Compact (hereinafter " Staff Report"), attached as Attachment C to NRC Staff Memorandum in Response to Licensing Board Order Dated March 24, 1995 Regarding Legal Status of Depleted UF6 Generated at the Claiborne Enrichment Center and Legal Standard for Assessing Financial Qualifications (April 21,1995).
9710240230 971014 PDR ADOCK 07003070 A h C
PDR 1/
2 3.
The Staff's assertion and underlying report must be rejected out of hand, because none of this information is a part of the 1995 hearing record, to which this remand is restricted.
4 Moreover, the Staff Report was never reported in the FEIS, nor was it dis-closed by the NRC in time for its vague and generalized assertions to be subjected to discovery or cross-examination. Sg Citizens Against Nuclear Trash's Response hiemorandum Regard-ing the Effects of Low Level Radioactive Waste Policy Act on Depleted Uranium Tails Dis-posal at 8 to 9 (May 8,1995) (hereinafter " CANT Memorandum"). Accordingly, because this evidence was not disclosed in the FEIS or subjected to the rigors of discovery and cross-examination, we do not consider it valid or probative.
l 5.
In any event, we find that on its face, the Staff Report is utterly inadequate to i
provide a basis for concluding that there are actual sites in the U.S. with values compatible with the basalt and granite sites evaluated in the FEIS. The Staff neglects to mention that while the Hanford and Idaho sites are located in the arid west, the Pierre Shale is located in the bread basket of the country. Sg CANT Memorandum at 10. The Pierre Shale is overlain by, and intersects at various points, the High Plains aquifer system, which covers approximately D0,000 square miles in eight central and western states, and includes the Ogallala Aquifer, the large:t aquifer in the world. The Ogallala Aquifer is a pivotal resource supporting the Great Plains agricultural economy, and indeed the economy of the nation.11 Nowhere does the Staff's report compare the location, volume, or hydrology of the Ogallala with the location, volume, or hydrology of the sites evaluated in the FEIS. Nor does it discuss the potential environmental impacts of depleted uranium disposal on the quality of the Ogallala Aquifer, li 6.
We reject as disingenuous the Staff Report's claim that the Pierre Shale site is
" compatible with the FEIS sandstone / basalt site" because of " comparable geochemical condi-tions." Staff Report at C-4. As demonstrated in the FEIS, and as testified to by Dr. Mak-hijani, the Staff did not analyze the geochemical conditions of the Hanford sandstone / basalt
.. i site. Instead, it used surface water data, and ignored other data about the very sites on which it claimed to base the FEIS. FEIS at A 10, hiakhijani at 9-10. Having failed to analyze the geochemical characteristics of the Hanford site, the Staff has no grounds for claiming that the Pierre Shale is compatible because of similar geochemical characteristics.
7.
We find neither accuracy nor logic in the Applicant's argument that, given Congressional legislation ordering DOE to accept uranium tails under certain conditions, and given the size of the DOE tails inventory, it is reasonable to assume that a site will be identified "within the requisite time," k, by the year 2014. LES Proposed Findings at 6, par. 2.1. First, Congress directed DOE to accept the tails only if they are " ultimately determined to be low-level radioactive waste." Given the tails' unsuitability for near-surface disposal, and given their high specific activity and other characteristics, ses CANT's Petition l
for Waiver of 10 C.F.R. 6 61.55(a)(3) (January 17, 1995), it is highly questionable whether they will ultimately be classified as low level waste. hforeover, the fact that the DOE has accumulated a huge inventory of tails constitutes evidence of the difficulty of disposing of them, not evidence that a disposal solution is at hand. Finally, as Dr. hlakhijani testified, experience shows that fifteen years is a very short time to site a unique radioactive waste facil-ity such as this.1995 Tr. at 1212, 8.
Finally, the Staff asserts that "LES experts... had confidence that based on the Staff's analyses, a site can be located where the parameters are consistent with those used in the Staff's calculations in the analysis." Staff Proposed Findings at 6, par.16. There is no factual evidence in the record to support this proposition. Rather, the evidence is that the Staff took the smorgasbord approach to groundwater analysis, selecting data from disparate and inappropriate sources that would yield the result it sought, and ignoring unfavorable data from the very sites it had claimed to study in the FEIS.I In short, the hypothetical site created by the Staff is a Frankenstein's monster rather than a reasonable representative of existing deep 1
In this respect, the Staff borrowed more from Sweden than the Karn-Bransle-Sakerhet
("KBS") study.
- s i
..t,
mine conditions in the U.S. In the face of this evidence, it does not matter how many of LES's experts line up to express general " confidence" that a comparable site can be found.
Rather, a reasonable factual underpinning for that confidence must be offered. No such fac-1 tual support has been provided on this record.
III.
TIIE RECORD CONTAINS NO ANALYSES OF VARIATIONS IN SENSITIVE GROUNDWATER PARAMETERS.
9.
The Staff confirms that the record contains no calculations or results of calcula-tions regarding the effects of varying parameters on dose impacts. Staff Proposed Findings at 7, par.18. We find this to be a fatal deficiency in the analysis, 10.
LES also concedes that the Staff used a " single set of values." LES Proposed Findings at 8, par. 2.2.6. LES asserts that these values are " reasonably bounding" because they are " representative." As we have previously discussed, s.es CANT Proposed Supplemen-tal Findings at 8, there is nothing " representative" about the data used by the Staff. In any event, it is scientifically impossible for a calculation that uses only one set of numbers to be
" reasonably bounding." Implicit in the term " bounding" is the concept that the " bounds" or
" limits" of a range are established by the calculation, k, there is a maximum and a minimum value. A calculation which uses only one number is incapable of performing that function. At best, it only tells where the middle is.
IV.
TIIE RECORD DOES NOT SUPPORT TIIE STAFF'S ANALYSIS OF DOSE IMPACTS OF DEEP MINE BURIAL OF DEPLETED URANIUM TAILS.
I1.
According to the Staff, its analysis was " based on two hypothetical sites whose primary characteristics had been developed in prior studies of radioactive waste disposal."
Staff Proposed Findings at 2, par. 2, However, the record clearly shows that the Staff ignored the geochemical characteristics of the groundwater at these sites, and instead selected data from other sites, including a site across the ocean Neither the Staff nor LES provide any plausible explanation as to why the Staff ignored geochemical data ; rom the very sites it
.. claimed to evaluate in the FEIS, As Dr. hiakhijani testined, there is an " enormous body of technical data" for the specinc locations cited in the EIS. 1995 Tr. at 1171-1173,1179.
12.
For example, the Staff ignored Hanford data showing pH values greater than 9.
hiakhijani at 10. The Staff also ignored Hanford data on retardation factors and used Swedish data that provided much higher retardation factors. Although the Swedish data may have some relevance to the calculation, the Staff provided no basis for utterly disregarding the data from the Hanford site, which after all constitutes the alleged model for the analysis. Similarly, the Staffignored relevant data on eH in uranium mines. In fact, although the FEIS claims to have considered uranium mine c mditions, the FEIS does not even report eH data for uranium mines, although such data was available to the Staff. The Staff even disingenuously mis-
[
represented the KBS eH data on which it claimed to rely. In short, the Staff abjectly failed to examine the conditions in the sites it claimed to study, or explain why those conditions were irrelevant to its analysis. Using this data would significantly expand the range of conditions that must be examined in the Staff's analysis. I,foreover, the Staff completely failed to identify or evaluate an appropriate range of conditions. Under the circumstances, there is no basis in this record for approving the plausibility of deep mine disposal.
13.
According to the Staff and LES, it is of no consequence that varying eH could significantly affect uranium doses, because it would not bring the uranium dose up to regulatory limits, and the dose is dominated by radium. Staff Proposed Findings at 5, par.10, LES Proposed Findings at 12, par. 2.3.5. We 6nd no assurance, however, in the extraordinarily low uranium doses calculated by the Staff. As Dr. hiakhijani testified, they are so low as to be facially incredible. Under these circumstances, it is of great significance that varying eH could affect tiranium doses by three orders of magnitude. We also credit Dr. hiak-hijani's unrebutted testimony that varying the parameters of the NRC's dose analysis could alter the results by even greater orders of magnitude. 1995 Tr. at 1182.
14.
Both the Staff and LES claim that the Staff's failure to analyze a range of values for groundwater parameters is sufficiently compensated for by the alleged conservatism
.. of the analysis. LES Proposed Findings at 10. par. 2.3.3; Staff Proposed Findings at 5-6.
As we have previously discussed, the use of conservatisms cannot be used to justify a scientific analysis whose basic elements are as fundamentally Dawed as this one. Moreover, as dis-cussed below, LES and the Staff grossly overstate, and even misrepresent, the use of conserva-j tisms in the analysis.
15.
We must correct the Staff's erroneous assertion that our previous decision, LBP-97-3, approved the conservatism of the Staff's analysis. Staff Proposed Findings at 5, par.12. As can be plainly seen from our decision, we did not address clairred conservatisms l
at all. We now address it here.
16.
We are disturbed that even at this late date, the Staff continues to claim that itt j
ar.alysis was conservative by virtue of the fact that it did not assume the existence of engineered bauiers. Staff Proposed Findings at 6, par.14. As the Intervenor has pointed out on several occasions, there is nothing conservative about assuming the nonexistence of barriers that are not intended to be used in the Orst place. The failure to abandon or correct this mis-representatic i causes us to question the scientitic integrity of the Staff's work in general, 17.
LES claims that the FEIS's use of a bulk density value for U308 of 3.0 3
grams / cubic centimeter ("g/cm ")is conservative. LES Proposed Findings at 10, par.
2.3.3.1, niing FEIS at A-7. The FEIS states that:
The quantity of uranium assumed to be disposed is the 30-year CEC tails inventory (the amount adoEted for analyzing the conversion of DUF6 to U308) or approximately 9.1 x 10 kg of U308. The crystal density of U308 is 3
reported as 8.3 g/cm (Katz and Rabinowitch,1951), while bulk density can be 3
as low as 3.0 to 4.0 g/cm (Chemical Abstracts,1986. In order to provide a conservative analysis, a bulk density of 3.0 g/cm was used in this analysis..
3 The U308 disposal volume is thus approximately 3.0 x 10 +4 and 2.7 x 10+14 Bq (2.6 x 10+4 and 7.3 x 10+3 Ci), respectively.
FEIS at A-7. This language makes it quite clear that the conservatism of using a bulk density 3
factor of 3.0 g/cm for U308 relates to the volume of waste and the size of the disposal site
.. thereby required. The assumption is anti-conservative, however, with respect to determining the radioactivity of the tails for purposes of assessing appropriate disposal methods. For example, in LES's Exhibit 8, which is EG&G's report entitled Depleted Uranium Disposal Options Evaluation at 39-40 (1995), EG&G asserts that "it appears that DOE's DU would qualify as a Class 3 waste," based on a calculation of specific activity derived from the assumption that the density of the waste is 3 g/cm. If the density of the waste were 5 g/cm,
3 3
which is within the range specined in the FEIS, the specific activity would increase to 1.55 uCi/g. This is above the Class 3 limit as stated in Table 9 of the EG&G study. As even EG&G notes, waste of a higher specine activity would receive a higher classiGeation and may require " additional engineered features." 11 at 39. Clearly, the reqairement for additional engineered features would add costs to the disposal of the tails. Thus, a density factor in the middle of the range posited in the FEIS would invalidate any calculations, waste acceptance I
l assumptions, and disposal cost estimates that are based on the assumption that U308 meets the Class 3 limits. Accordingly, for purposes of determining the crucial factor of the specific activity of the depleted uranium tails, the FEIS's assumption regarding the density of the tails is not only unconservative, but anti-conservative.
18.
LES also claims that the NRC Staff's analysis was conservative by using " max-imum concentrations of radionuclides." LES Proposed Findings at 10, par,2.3.3.3, citmg FEIS at A-9. We do not 6nd any express assertion of this sort on page A-9 of the FEIS. Per-haps LES is referring to the :Jatement that in the Kozak analysis, ;,hich the Staff relies on to reject near-surface disposal of tails, "[r]elease of uranium was modelled as being controlled by its solubility." Aside from the questionable relevance of the Kozak surface disposal study to the analysis of deep mine disposal, there is no evidence in the FEIS or any record testimony that this assumption constitutes a conservatism. Therefore, LES's claims constitute an improper attempt to introduce new evidence into the record.2 2
Had the FEIS given adequate notice that the assumption was considered a conservatism, CANT would have introduced evi<lence that it is not. In particular, the National Acad-
.g.
- 19. We reject the Staff's claim that the Staff's retardation factor of 1200 was "cau-tiously " conservative." Staff Proposed Findings at 5, par. I1. It simply is not conservative, let alone cautiously conservative, to ignore data from the very basalt and granite sites sup-1 posedly considered in the FEIS, and instead use significantly different data for a granitic site in Sweden.3 A conservative analysis would examine all relevant data -- especially data from the very site claimed to form the basis for the analysis -- and either use it or explain why it is not reliable. This was never done.
III.
CONCLUSION 20.
The record shows that the Staff never used data from the sites it claimed to be studying in the FEIS, nor did it evaluate a range of values for sensitive groundwater parame-I ters. Instead, it picked and chose single values for surface water that were either outside the appropriate range of groundwater values, or not at the midpoint of the range. It appears that 1
the principal criterion for choosing these single values was not consistency or logic, but whether the data would yield the result sought. Various claimed conservatisms are either anti-conservative or non-existent. Finally, the analysis yielded uranium doses so low as to be facially incredible. In short, we tind the Staff's analysis lacks any credibility as a source of support for LES' waste disposal cost estimate or for the FEIS.
(continued) emy of Sciences' study of the Hanford site compares solubility-limited dissolution and congruent dissolution, and shows that the solubility-limited assumption is not conserva-tive. See attached Figures 9-4, 9-5, 9-9, 9-10, 9-11, and 9-13, from the National Acad-emy of Sciences 1983 report, "A Study of the Isolation System for Geologic Disposal of Radioactive Wastes." This study was referred to in Dr. Makhijani's testimony. 1995 Tr. at 1170-1173.
3 As we have previously discussed, this data is not only entirely outside the range of retar-dation factors measured at Hanford, but the lowest NAS estimate of retardation factor is more than 100 times lower than the value assumed by the NRC Staff in its calculations.
9 espectfully submitted, k
iane Curran Harmon, Curran, & S 2001 "S" Street N.W.pielberg Suite 430 Washington, D.C 20009 (202) 328-3500 h(Lkk 8. L]'AI fh(
W Nathalie M. Walker Earthjustice Legal Defense Fund 400 Magazine Street, Suite 401 New Orleans, LA 70130 (504) 522-1394 October 14, 1997-l 1
e
AStudyofthe Isolation Systemfor GeologicDisposal ofRadioactiveWastes l
Waste Isolation Systems Panel BOARD ON RADIOACTIVE WASTE MANAOEMENT Commission on Physical Sciences, Mathematics, and Resources National Research Council i
NATIONAL ACADEMY PRESS Washington, D.C.1983 INN POR ENERGY a ENVIRONMENTAL RESEARCH ans t w 4, I % Pett,MO toen
261 10*3 Np '
'37 g4 Congruent dissolution, jg rate = 10-4/yr 10*4 River flow a 3.8 x 10' rn /yr 8
k Groundwater flow =
l k
9.9 x 10 m /yr 4 3
~
g 10-5 12s 4
sn l
I tiscs X
10*1 g
t 10-6 Q 1T I
es Tc h
"se 2io Po 10-2 g i
10-7
\\C i~
\\\\
insi I
\\
\\
~
8
)
Pu 23sPu 848
~
334g 10*8
)
}
22sRa assam 10-4 l
1 I
l
{l I
l 10 102 joa 30 305 jos 4
107 Water travel time, yr FIGURE 9 4 Individual radiation dose as a function of water travel time in granite: reprocessing waste 8
from 10 Mg uranium fuel, congruent dissolution,no dispenien.
9.7.4.
Salt The calculated dose rates for a hypothetical salt repository are shown in Figure 9-5 as a function of water travel time for congruent dissolution. !!ere, for the purpose of comparing with other host sites, we assume that dissolution begins soon after emplacement. Because there is no groundwater in salt, dissolution by groundwater flow may never occur, or if tt does occur by unexpected intrusion of an aquifer from adjacent media, it may be delayed for a much longer time than assumed here.
Here the predicted dose for cesium-135 persists with little attenuation for much longer water travel tima than in the case of basalt or granito. This is a consequence of the 100-fold lower retardation constant for cesium in media through which saline water is flowing. The lower ratio of the radium retardation constant to that of uranium increases the dose from radiune 226 from a salt repository.
Neptunium-237 travels twice as f ar frora the salt repository, measured by water travel time, than from repositories in basalt and granite.
- p h.h.
eg
263 10-2 consruent dissolution rate = 10-4/yr 237pp ni,,r flow.
"C 8
3.2 x 10 m3/yr 10-3 O " "d * * '"
flow = 1.3 x 3
10 m3/y' - 102 Water b
g
'"' \\
5 t$
10-4 (ONWH
\\
.t.'
'\\
10 8
I
~
N
\\
\\
m g
10-5 _"
7 188c
}
234 U 22s Ra 210
~
Pb 10-6 12sgk k
{
j E
,=
1 r
f 242 10-1 3 Pu
\\
\\
10-7
\\
\\
- 43 l
Am 23sPu 10-2 II be 10-8 1
1 10 102 jn3 10' 105 los 107 Water travel time, yr FIGURE 9 5 Individual radiation dose as a function of water travel time in salt: reprocessing waste from 10' Mg uranium fuel, congruent dissolution, no dispersion.
The volumetric flow rate of surface water for the hypothetical salt 8
repositrary is 3.2 x 10 3
m /yr as recommended by S. Goldsmith (Office of Nuclear Waste Isolation, personal commur Ication to 0. O. Neff,1982) for repositories constructed in the bedded salt in the Permian or Paradox bas {/yr is estimated from data supplied by GThe flow rate of potent ns.
of 1.3 x 10
. E. Raines (Of fice of Nucluar Waste Isolation, personal communication to T. H.
Pigford,1982), f rom flow data for the Permian Basin. The river flow is 340 times less than the Columbia River flow associated with the basalt site, resulting in a correspondingly greater dose rate in surface water.
The dose rates in surf ace water for a site in domal salt would be ninefold less than those for bedded salt in Figure 9-5, because of the k
q',noted greater surface water flow for the domal salt site.
The hydrologic data for domal salt are for a site not now under I
consideration by DCE, as data for dott.al salt sites under actual
{
consideration are not now available (S. Goldsmith, Office of Nuclear I
Waste Isolation, personal communication to J. O. Nef f,1982).
i
-+
=-
r_-__
274 1
1 1
1 I
I Dissolution rates:
C:= 104/yr 10 All others solubility 10-6
- sig, limited h
j k
River flow = 1.1 x 1011 3
m /yr va Groundwater flow = 3.2 a 10 m /yr g73 4 3 g 10 7 Ra D = 50 m /y, 2
104 14 C
k j 10-8 PNL estimate of l
237 1
Np BWIP water travel time h
10-2 !
N HMO estimate of 8
10 9
'Pu BWIP watet j
E tra vel time w
10-3 12ssn 10-10 79 '
8 10-4 243Am 10-11 10 102 103 104 105 106 107 Water travel time, yr FIGURE 9 9 Individual radiation dose as a function of water travel time L basalt: reprocessing waste from 8
10 Mg uranium fuel, solubility limited dissolution, appear in the environment is by transport of 80,000 year thorium-230 directly from the waste. This is possible only for relatively short water travel times, of the order of a few hundred years. Consequently, when uranium is solubility limited, radium-226 is a principal contributor tc.
8.ndividual dose only for water travel times of a few hundred years and less, as shown in Figure 9-9.
Based on these predictions, and based on the estimate by project of a water travel time to the environment of 1.5 x l{ghe BWIP
- years, the maximum individual dose in river water will be about 10~
Sv/yr, a factor of 10 million below the radiation dose criterion of 10-4 Sv/yr adopted for this study.
For the average groundwater travel time to the Columbia River of 1.5 x 104 years estimated by Pacific Northwest Laboratory (Dove 1982, Dove et al.1982), the maximum dose to the individual will be about 3 x 10-9 Sv/yr, over four orders of magnitude below our individual dose criteeion.
~-
j 376 10~3 -
i i
j Dissolution rates:
Cs = 10-4/yr jg 10'4 All others solubility timited i
210 y
River flow = 3.8 x 10s m3/yr
(
Q Groundwater flow = 9.9 x 10 m3/yr 4
D = 50 m /yr
,p 3
10-8 g
I ass,
g a
j 10*1 s
1 14 3
e 10-2 f 10-7 337 i
Np s
j b
d
}
10-3 10-8 2 sp, 12s h
"8' sn 10*4 10-8 10 102 103 104 105 106 107 Water travel time. yr from 10' Mg uranium fuel, solubility limited dissolution, FIGURE 91 se greater than 105 years.
It is apparent that determination of the a salt repository. appropriate dissolution rate for cesium-135 is of special importa cesium dispersion is not sufficient to result in the insensitivity of predicted doses to the dissolution rate of cesium.
9-11 are those listed in Table 9-4 for a generic reposito e
salt.
estimates for a generic repository in domal salt by applyin e e hydrologic data for domal salt in Table 9-4.
Water intrusion into salt and the resulting hydrogeologic tra of radionuclides is not an expected event, as discussed in Section 9 7 4 nsport 9.10.8.
Tuff Adopting the solubility-limited dissolution rates of Table 9 5 calculated doses for a tuff repository at the Nevada Test Site are shown
, the
F 377 10-2
}
103 Dissolution rates:
4 C = 10 /yr All others solubility 10-3 limited River flow = 3.2 x 10s m3/yr g2 21oPb 22s Groundwater flow =
Ra 3 3 1.3 x 10 m /yr 10-4 D = 50 m /yr j
2 l
10 2
135 I
C 10-6 I
"c 1
S th 10-s g
a 23sPu a
3 10-1 3 J
7s,
237 s
Np E
f10-7 12e sn 10-2
^*
10-s Water trevel time.
ONW1 salt site 10,3 ssTe
\\l
\\\\\\ \\
\\,
,o-,
x i
10 102 103 104 105 106 107 Water travel time, yr FIGURE 911 Individual radiation dose as a function of water travel time in salt: reprocessing waste from 10s Mg uranium fuel, solubility limited dissolution.
in Figure 9-12 The relative values of the doses from individual radionuclides vary with water travel time in the same way as for the basalt and granite repositories. We have no estimates of groundwater flow rate for a tuff site, and it appears that there is no surface water into which potentially contaminated groundwater can discharge.
Attention must be focused on possible use of the potentially contaminated groundwater by humans, for potable water and irrigation.
Tentatively adopting 4,300 years as the possible water travel time f rom a repository in saturated tuff to an off-site well, the radiation dose will be dominated by carbon-14 or, depending on its dispersion coefficient, by cesium-135. Adopting 2.1 x 104 years as the possible water travel time to the same off-site location from a repository in unsaturated tuf f, the carbon-14 dose is attenuated so that it is ll
-m
'5 381
!)
10 i
i 1
4 i
Congruent dissolution 83'Np rate = 10-d/yr 102 10-5
?
'*c 210 Pb d 10-6 239Pu f
g
'8'sn I
1 I 10-7 1sse g
b W
\\
33'u
\\
10-1 1 3
- es7, t
g 22sRa 3,
l 10-8
=
l 3
12sl 10-2 a 2
N 3
5 10-8
/
2 l
8
- 242p, y,,
l 10-3 O PNL estimate of RHO estimate of 283 10-10 Am swlP water swir water travel time travel time I
10~4 1
10-11 10 102 103 104 105 106 107 Wster travel time, yr FIGURE 913 Individual radiation dose as a function of water travel time in basalt: unreprocessed spent 8
fuel from 10 Mg uranium fuel, congruent dissolution, no dispersion.
l In comparison with similar data in Figure 9-3 for a basalt repository j
loaded with reprocessing wante, several differences are apparent:
i l
The maximum dose rate from neptunium-237 is increased threefold o
because all of the plutonium-241 in the spent fuel is available to decay to americium-241 and thence to neptunium-237.
Neptunium-237 remains the i
most important radionuclide for water travel times up to several hundred thousand years.
o The maximum dose rate from plutonium-239 increases 37-fold because all of the plutonium-239 in spent fuel is loaded into the repository. For reprocessing waste most of the plutonium-239 reaching the groundwater results frem the decay of americium-243 initially in the waste. Plutonium-239 is important only in the near field for water travel times of a few hundred years or less.
I CERT!PICnTE OF SERVICE 1, Diane Curran, certify that on October 14,1997, copies of the foreg nit CITIggNS AGAINST NUCLEAR TRASH'S REPLY PROPOSED SUPPLEh1ENTA F1 DINGS OFWEo FACT AND CONCLUSIONS OF LAW ON CONTENTIONS J.9, B., AND J.3 we6 Fegd j
IS97 by first-class mail and/or FAX on the following parties, as indicated below:
A C
l
' Thomas S. hicore, Chairman Off. of Abellate Ad,udicati Atomic Safety and Licensing Board U.S. Nuc r Regulatry Comm.
U.S. Nuclear Regulatory Commission Washington, D.C. 20355 JT b
Washington, D.C. 20555 Ndl-
- Richard F. Cole Robert h1 organ 1
Atomic Safety and Licensing Board Duke En ;ineering U.S. Nuclear Regulatory Commission 230 Sout1 Tron Street Washington, D.C. 20555 P.O. Box 1004 j
Charlotte, NC 28201-1004
' Frederick J. Shon Atomic Safety and Licensing Board W.H. Arnold, President U.S. Nuclear Regulatory Commission LES, L.P.
Washington, D.C. 20555 2600 Virginia Ave. N.W.,
l Suite 608 Washington, D.C. 20037
- Secretary of the Commission Rulemaking and Adjudications Section U.S. Nuclear Regulatory Commission Nathalie bl. Walker, Esq.
Washington, D.C. 20555 EJLDF 400 hiagazine St., Suite 401 New Orleans, LA 70130
- Richard Bachmann, Esq.
Office of General Counsel hiarcus A. Rowden, Esq.
U.S. Nuclear Regulatory Commission Fried Frank. Harris, etc.
Washington, D.C. 20555 1101 Pennsylvania Av. N.W.,
Suite 900S Washington, D.C. 20004
- J. hiichael hicGarry, Ill, Esq.
David Bailey, Esq.
Robert L. Draper, Esq.
Thomas J. Henderson, Esq.
Winston & Strawa Lawyers' Committee for Civil 1400 L Street N.W.
Rights Under 12w Washington, D.C, 20005-3502 1450 G Street N.W., Suite 400 Washington, D.C.
Ronald Wascom, Deput Office of Air Quality &y Asst. Secretary Radiation Protection Department of Environmental Quality P.O. Box 82135 Baton Rouge, LA 70884 Diane Curran