ML20198M706
| ML20198M706 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project |
| Issue date: | 02/03/1986 |
| From: | Clark A NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Starmer R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20198M712 | List:
|
| References | |
| FOIA-86-396, REF-PROJ-M-32 NUDOCS 8602100522 | |
| Download: ML20198M706 (3) | |
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FEB 03 W86 Project M-32 NMSS R/F FCAF R/F ATClark LCRouse RBoyle, WMRP JRoth, Reg. I MEMORANDUM FOR:
R. John Starmer, Section Leader IE Reg. I Low Level Waste and Uranium Recovery Projects Branch NDavison Division of Waste Management FBrown RECunningham FROM:
A. Thomas Clark, Jr., NRC West Valley Project Manager DRChapell Advanced Fuel and Spent Fuel Licensing Branch REBrowning Division of Fuel Cycle and Material Safety LSaraka, WMLU
SUBJECT:
DISPOSAL OF LOW-LEVEL RADI0 ACTIVE WASTE AT WEST VALLEY -
REVIEW 0F DRAFT ENVIRONMENTAL ASSESSMENT The purpose of this memorandum is to discuss some of the issues you have raised in your memorandum to me, dated January 9,1986.
I think it also might be helpful to provide some background information to afford you an enlarged perspective on the difficulties involved in disposing low-level waste at West Valley.
The Site Some of your reviewers dismiss the site out of hand with statements such as "it will be difficult to demonstrate that the specified site can meet the Part 61 technical requirements for siting" or "a site that has a history of unacceptable performance." Neither of these statement should automatically disqualify the site. As nearly as I can discern, the two main negative physical aspects of the site are its " wetness" and the extremely tight clay disposal medium. Within the strictures of 10 CFR Part 61 (Section 50(a)(7))
waste is never to be placed in a position in which the water table fluctuates through the waste and the West Valley disposal may be in just such a position.
As you are probably aware, the Lavery Till clay deposit underlying the site is virtually impermeable to ground water flow. This is the geological stratum into which the waste is being placed. Therefore, there has been little concern about liquid pathways draining downward through the Till, carrying leached radionuclides with it.
Previous site work has investigated the potential for
" sand pods" or vertical fractures to significantly increase the Till's permeability. Such features are unlikely to be significant.
In a realistic sense the principal concern related to the safe confinement of the buried wastes is that of " bath-tubbing," i.e., the overflowing of ground water leachate from the waste-filled disposal holes or trenches into the shallow, weathered soil layer above the Till.
It appears to me that if this phenomenon can be prevented, a long stride would have been taken toward assuring the safe confinement of the disposed radionuclides. Granted, other phenomena, such as erosion, need attention also, but, at the moment, collecting sufficient data to properly model the site and develop a method (capping or otherwise) whereby 3
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" bath-tubbing" will not occur, is the first priority.
Regardless of the particular requirements of 10 CFR Part 61, if the wastes can be adequately confined as described above, that should be a sufficient reason for acceptance of that disposal method at West Valley.
The implication that other locations at the West Vriley site (Western New York Nuclear Service Center) should be investigated suffers from two defects; 1) the geohydrology is similar everywhere at the site, and 2) all the same questions would pertain, requiring the collection of a tremendous quantity of new, but similar, data as has been obtained for the existing disposal area.
EA Scope Some questions seem to have arisen concerning the scope of the EA. These questions are not unreasonable.
DOE has decided to limit the scope to the decision about the disposal of Project wastes, that is, those low-level wastes generated as a result of the solidification of the high-level wastes. A large fraction of these wastes are the cemented salt solution from the processing of the high-level supernate. We have received and reviewed Volume IV of the SAR modules on Cement Solidification for which we evaluated information on process control and waste form qualification testing.
The topic of the additional wastes generated by decontamination and decommissioning activities is not within the scope of the_ES. As is apparent, this is an important topic. Until more is known about the technical capabilities to remove high-level waste sludges and decontaminate the old reprocessing plant cells, a definitive statement cannot be made about the nature of these D&D wastes, their packaging, or their volumes.
The site contractor has been making progress on these topics, however, and we expect discussions soon that may help us better understand the contribution of the D&D wastes to low-level disposal. I suppose this would also be helpful for determining the " full life cycle costs," though I doubt that Congress intended our role be expanded to include this economic concern.
Commitment to 10 CFR Part 61 In Section 3.1.3 of the draft EA DOE states that it intends "that the facility conform to the performance criterir specified in 10 CFR Part 61."
It appears to me that what is meant is that DUE intends to meet the requirements in Subpart C - Performance Objectives of 10 CFR Part 61.
I agree that this should be clarified.
It should be kept in mind that 961.1 states specifically that
" applicability of the requirements in~ this Part to Commission licensees for waste disposal facilities in effect on the effective date of this rule will be determined on a case-by-case-basis..." The perspective of the NRC should be that the requirements of 10 CFR Part 61 which should apply are those which are important to the safe confinement of the waste.
Since it is the NRC which has promulgated this regulation, understands its complexities, and has been preparing interpretations of the rule in the form of branch technical o
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if FEB 0 31986 positions, it is our duty under the provisions of Section 2 (c) of the West Valley Demonstration Project Act to consult with DOE on the importance of each Part 61 requirement which the NRC believes should apply to the disposal of low-level waste at West Valley.
TUMULUS The concept of above-grade waste disposal in an engineered berm was not specifically considered in the development of 10 CFR Part 61.
Since such a proposal is obviously an attempt to divorce the disposal from negative site characteristics (in this instance an uncertain water table and " bath tubbing"),
it seems counter-productive to insist that those same negative site characteristics must apply to the berm (tumulus). This is a perfect example of being wedded too closely to 10 CFR Part 61, which in this instance should not be at all applicable.
The tumulus must be judged on its own merits.
A second aspect which has been raised is the " fairness" of the comparison between disposal in a tumulus and disposal by shallow land burial.
I think it is patently unfair to insist on common failure modes when the principal purpose of the design is to avoid that mode.
I believe that the " fairest" comparison would be to examine the more likely failure modes for each concept.
Considerable technological judgement will have to be exercised for such an evaluation.
I suggest that we meet soon to continue our discussions in order to prepare for further discussions with DOE at West Valley.
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A. Thomas Clark, Jr.
NRC West Valley Project Manager Advanced Fuel and Spent Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS OFC: FCAf
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