ML20202D597

Responds to to Chairman Jackson Requesting Comments on Draft Ward Valley Sampling Protocols,Including Protocols for Tritum & chlorine-38 Testing

ML20202D597
Person / Time
Issue date:	11/25/1997
From:	Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	CALIFORNIA, STATE OF
Shared Package
ML20202D603	List: ML20202D597 ML20202D606
References
REF-WM-3 NUDOCS 9712050073
Download: ML20202D597 (14)

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Dear Sir 6r,

Madam:;

.g in a November 5, I'997,' letter to Chairman Jackson of the U.S. Nuclear Regulatory Co'mmissk n, Deputy Secretary of the Interior John Garamendi requested NRC comments on the draft Ward Valley Sampling Protocols, ine'uding protocols for tritium and chlorine-36 testing.

. The, protocols address sampling and ' study of the nature of water roovement in the unsaturated 1

f zone beneath the proposed Ward Valley low-level radioactive waste site in California. NRC staff and its contractor, the Oak Ridge Institute for Science and Education, developed the enclosed comments on'the protocols, for your consideration.

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l trust our comments will be useful in your efforts to address Ward Valley issues. If you have l

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any questions on the comments, or for any future suc!, requests, please contact John T.

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Greeves at 301-415-7437, it would also be helpfulif the Department of the Inteiior could also l

provide a point of-contact for Ward Valley matters.

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- 1 Sincerely, Originalsignedby)

Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards l

Enclosure:

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U.S. NUCLEAR REGULATORY COMMISSON STAFF COMMENTS ON THE DEPARTMENT OF INTERIOR / BUREAU OF LAND MANAGEMENT DRAFT SAMPLING PROTOCOLS FOR SCIENTIFIC STUDIES TO BE PERFORMED AT WARD VALLEY, CALIFORNIA General The protocol objectives may not be entirely consistent with those recommended by P National Academy of Sciences (NAS) in its 1995 Ward Valley report. As a result, the testing may not be conclusive when measured against the protocol's objectives, and may not be relevant to l

determining the performance of the facility in isolating low-level radioactive waste.

i Section 3.0 states that the objectives of the protocol are to provide sufficient data from the unsaturated zone to scientifically defend the movement of water through the unscturated zone.

Three models are postulated in the protocol to anticipate what might be concluded from the test results. The first modelis that periodic infiltration into the unsaturated zone rarely penetrates below the active rooting zone for plants, which is several meters in depth. The second is that deeper infiltration into the unsaturated zone occurs through ephemeral stream channels and/or l

along highly localized preferred pathways, such as root casts (cavities created by plant roots that enable water to penetrate farther into the soil). The groundwater may or may not be recharged under this model. The third is " widespread deep percolation of precipitation" below the active root zone that recharges the saturated zone of water.

The NAS committee concluded, from " multiple lines of evidence " that:

"...the unsaturated zone at the Ward Valley site is s ery dry, and that recharge or potential transfer of contaminants through the unsaturated zone to the water table.., is l

highly unlikely However, because of limitations of the data, the committee recommends i

specific... monitoring measurements.. to enhance the data base for monitoring the complex unsaturated zone." (p 2, NAS Report).

Thus, the NAS focus is not on precisely how water might move through the unsaturated zone (the focus of the protocols and a topic mainly of research), but discrete tests prescribed from the overall context and findings of its review. The staff notes that the two approaches are not mutually exclusive and understanding of infiltration mechanisms is important. At the same time,

he emphasis of the protocols appears to be somewhat different from the NAS report recommendations.

Further evidence of this broader emphasis in the protocols is the trench sampling in Section 7.0, which would determine infiltration from ephemeral washes. The NAS did not recommend this testing. In fact, the NAS noted that the nearest ophemeral wash, Homer Wash, may be recharging ground water, but that it was not important in the performance of the site. (See also comment # 1 on the following page).

Enclosure

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. Recommendation:

As written, the protocol objective is to provide sufficient data from the unsaturated zone to define which conceptual model(or " process scenario *) of water movement in the unsaturated zone is occurririg. The staff recommends that the Deprtment of Interior (DOI) reconsider the objectives of the protocolin light of the above comments, and the recommendations made by the NAS committee.

Soecific 1.

Section 7 of the protocols describes procedures for the construction, sampling and analysis of one or more shallow trenches. The stated purpose of the trench testing is to define the differences in water movement between an ephemeral stream channel, such as Homer Wash, and the adjacent interfluvial setting. The value of this trench testing is r,ot clear, for several reasons. First, the NAS (1995) report on Ward Valley states (on page 92) that active ground-water recharge may be occurring beneath Homer Wash.

Accordingly, it is expected that the data from the trench will show differences in infiltration between the ephemeral wash and interfluvial zone. Second, the protocol states in Section 2.0.2 that the existence and extent of preferential pathways such as root casts and fractures (in the interfluvial zone) cannot be predicted ano may be highly localized. The protocol then appears to imply that the data from the trenches will be used to deduce the likelihood of preferential flow, presumably in the interfluvial zone. At best, the staff believes that such a trench test program might indicate that infiltration could occur along preferential pathways, but would provide little or no information on the likelihood of such infiltration, nor the degree of infiltration. The issue of concern is whether there is deep infiltration occurring in the interfluvial zone. Deep boreholes should provide this information. Finally, this trench testing was not recommended by the NAS in its report on Ward Valley.

2.

In Sections 1.3 and 2.0.1, the protocols address the effect of a disturbed environment (from construction, testing, operation, etc.) on infiltration during the life of the facility.

The staff agrees that 5 formation on these disturbances may be useful and provide new information. At the same time, the revegetation of disturbed areas was specifically addressed by the NAS in Issue No. 7,'Revegetation." The objective of the protocols is not clear on this point, i.e., whether it is to revisit this issue, at least in part, or to be cognizant of new data obtained during the course of other recommended testing and to consider it appropriately for the revegetation issue. Some clarification of how this issue will be addressed would be helpful.

3.

It is not clear from the protocols whether the two deep boreholes (i.e., GB-01 and GB-

06) are planned as a continuation of two of the shallow boreholes (i.e., GB-01 and GB-06). If not, different designations should be used (e.g., GB-01S and GB-01D). If the two deep boreholes are planned as a continuation of the shallow boreholes, there is a discrepancy in the coring intervals listed in Sections 5.2.3 and 6.2.3. Further, the boreholes in Section 5.2.3 should be described as shallow boreholes instead of deep.

.y. V 3-4.

The draft protoco!s address sampling and mauurement of tritium and chlorine 36, two tracers recommended for further testing by NAS. The staff also notes that techniques have been developed for measuring chlorofluorocarbons (CFC), another man-made tracer in the environment that might provide useful results in infiltration studies. CFC's are effective tools to age-date and trace recharge mechanisms for shallow ground water (Plummer and Busenberg,1992; Plummer and Busenberg,1996). Both unsaturated zone air and ground water samples can be used together to differentiate between different potential recharge mechanisms (Plummer and Busenberg,1992; Busenberg et al.,1993). Sampling in the unsaturated and saturated zone and analysis protocols for CFC's, should be considered, and if developed, should follow those previously published (Busenberg and Plummer,1992; Busenbe 'g et al.,1993). See last page for references.

5.

Given the importance of the deep borehole (GB-06) elevation, the surveying should be done by a licensed land surveyor.

6.

The most recent ASTM methods should be cited; for example, D1587 94 (instead of D1587-83) and D4220-95 (instead of D4220-89).

7.

Page 6, second paragraph in Section 2.1.2, notes that for chlorine-36, the signature may be diluted by the large concentrations of chlorides at the site. It should be noted that the i

concentrations of chloridas could be so large as to make the chlorine-36 analysis inconclusive (See comment No. 4).

I 8.

Page 7 Section 3.1: It is not clear whether the intent of collecting split samples is to characterize the tritium content cr to perform data comparisons between laboratories.

t The staff believes that statistically significant data compansons between any two 4

laboratories for tritium split samples would be difficult due to the multiple variables that may impact the samples. Thus, such data comparisons would not be useful for determining the acceptability of one laboratory compared to another.

9.

Page 7, Section 3.1: The second paragraph mentions the archival of a sample portion.

Tritium and chlorine 36 exhibit high volatility and extended archival may lead to the loss of sample integrity. The staff recommends that extended archival should specify the need for cryogenic storage and recognize that there may be product loss during this period. Perhaps a sample spiked with a known activity could be stored with the archived samples.

10.

Page 8, Section 4.3: The staff recommends that the patocols provide additional details regarding sample shipment. For example, will samples be cooled to minimize volatilization and what are the anticipated holding times?

11.

Page 8, Section 4.4: The specific definition for " environmentally controlled

• should be provided.

12.

Page 11, Section 5.2.4: The first paragraph specifies core samples are to be sealed in l

plastic. It is understood that the plastic sleeves are necessary to line the core sampler l

and minimize sample handling and disturbance. However, the staff recommends that

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. other containers be considered to prevent loss of water vapor and the ion exchange with hydrogen within the plastic container. Additionally, glass containers with Teflon closures would be the preft.* red container for ground water samples and the disturbed soil samples collected from the test trenches. (This comment also applies to Sections 6.2.4 and 7.2.2).

13.

Page 11, Section 5.2.4: The third paragraph states that at least two core blanks be handled similarly to actual core samples. This is to provide a means to evaluate potential contamination with assumed knowledge of core blank analytical results. The

'I staff recommends the addition of undisturbed trip core blanks as well as field core blanks into the sample stream. This would provide a more thorough approach regarding the assurance of blank preparation and analytical detection limits.

14.

Page 13, Soction 5.4: The staff recommends the use of desiccants instead of cold traps to remove atmospheric water vapor. Desiccants are easier to use and handle in field situations.

15.

Page 17, Section 7.2.2: This section is unclear as to which wall will be sampled. The section states that a gridded sampling network is to be installed along the east wall of the trench. Are samples only to be collected from the east wall? If this is the case and minimization of evaporation is a prinri?y as indicated by the installation of a tent, perhaps the north wcIl should be selected for sampling rather than the east wall. This section should also specify glass sample containers, dressing the surface prior to sampling in order to remove any soil that may have been transferred from another strata during excavat!an, and include additional sample shipment protocols as addressed in comment 10.

16 If the testing is performed in the trench (es), the protocol should state what will be the basis for constructing additional trenches.

References:

Busenberg, E. and L.N. Plummer,1992, Uv4 of Chlorofluorocarbons (CCl F and CCl F )

3 2 2 as Hydrologic Tracers and Age-Dating Tools: The Alluvium and Terrace System of f

Central Oklahoma, Water Resources Research, Vol. 28, pp. 2257-2283.

Busenberg, E., E.P. Weeks, L.N. Plummer, and R.C. Bartholemay,1993, Age-Dating Ground Water by Use of Chlornfluorocarbons (CCl F and CCl F ). and Distribution of 3

2 2 Cnlorofluorocarbons in the Ursaturated Zone, Snake River Plain aquifer, Idaho National Engineering Laboratory, Idaho, U.S. Geologica. durvey, Water-Resources Investigations Report 95-4054.

Plummer, L.N. and E. Busenberg,1992, CFC's-Tools for Age-Dating and Tracing Shallow Ground Water, in U.S. Geological Survey Yearbook, Fiscal Year 1992, Partnerships in the Earth Lciences.

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y November 25, 1997 Ward Valley Protocc!s Needles Field Cffice/ Bureau of Land Management 101 W. Spikes Road Needles, CA 92363

Dear Sir or Madam:

In a November 5,1997, letter to Chairman Jackson of the U.S. Nuclear Regulatory Commission, Deputy Secretary of the Interior John Garamendi requested NRC comments on the draft Ward Valley Sampling Protocols, including protocols for tritium and chlorine-36 testing.

The protocols address sampling and study of the nature of water movement in the unsaturated l

zone beneath the proposed Ward Valley low-level radioactive waste site in Califomia. - NRC staff and its contractor, the Oak Ridge Institute for Science and Education, developed the enclosed comments on the protocols, for your consideration.

I truv our comments will be useful in your efforts to address Ward Valley issues. If you have any questions on the comments, or for any future such requests, please contact John T.

Greeves at 301-415-7437, it would also be helpfulif the Department of the Interior could also l

provide a point of contact for Ward Valley matters.

Sincerely, Original signed by)

Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards

Enclosure:

As stated cc:

John Garamendi, DOI DISTRIBUTION EDO G970799 Central File DWM r/f MBell MFederline NMSS r/f WReamer NJensen SSalomon EDO R/F CPoland THarris RBangart DWM t/f PNorry SBurns AThadani EMerschoff, RIV SECY PUBLIC HThompson JCallan PTressler

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%..O November 25, 4 Ward Valley Protocols Needles Field Office / Bureau of Land Management 101 W. Spikes Road Needles, CA 92363

Dear Sir or Madam:

In a November 5,1997, letter to Chairman Jackson of the U.S. Nuclear Regulatory Commission, Deputy Secretary of the Interior John Garamendi requested NRC comments on the draft Ward Valley Sampling Piotocols, including protocols for tritium a: d chlorine-3S testing.

The protocols address sampling and study of the nature of water movement in the unsaturated zone beneath the proposed Ward Valley low-level radioactive waste site in California. NRC staff and its contractor, the Oa) *,dge Institute for Science and Education, developed the enclosed comments on the protocols, for your consideration.

I trust our comments will be useful in your efforts to address Ward Valley issues. If you have any questions on the comments, or for any future such requests, please contact John T.

Greeves at 301-415-7437. It would also be helpfulif the Department of the Interior could also provide a point-of-contact for Ward Valley matters.

Sincerely,

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W Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards

Enclosure:

As stated cc:

John Garamendi, DOI 9

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S Ward Valley Protocols Needles Field Office / Bureau of Land Management 101 W. Spikes Road Needles, Califomia 92363

Dear Sir or Madam:

In a November 5,1997, letter to Chairman Jackson of the U.S. Nuclear Regulatory Commission, Deputy Secretary of the Interior John Garamendi requested NRC comments on the draft Ward Valley Sampling Protocols, including protocols for tritium and chlorine-36 testing.

The protocols address sampling and study of the nature of water movement in the unsaturated zone beneath the proposed Ward Valley low-level radioactive wasts site in California, NRC staff and its contractor, the Oak Ridge institute for Science and Educatioit, developed the enclosed comments on the protocols, for your consideration.

I trust our comments will be useful in your efforts to address Ward Valley issues. If you have any questions on the comments, or for any future such requests, please contact John T.

Greeves at 301415-7437. It would also be helpfulif the Department of the Interior could also provide a point-of-contact for Ward Valley matters, Sincerely, Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards

Enclosure:

As stated cc:

John Garamendi, dol DISTRIBUTION: EDO G970799 Central File DWM r/f MBell MFederline NMSS r/f WReamer NJensen SSalomon EDO R/F CPoland THarris RBangart DWM t/f PNorry SBums AThadani EMerschoff, RIV SECY PUBLIC HThompson

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Ward Valley Protocols Needles Field Office / Bureau of Land Management 101 W. Spikes Road Needles, Califomia 92363

Dear Sir or Madam:

In a November 3,1997, letter to Chairman Jackson of the U.S. Nuclear Regulatory Commissio Deputy Secretary of the Interior John Garamendi requested NRC comments on l

. draft protoco or tritium and chlorine-36 testing. The protocols address sampling and study of j

the nature of wa r movement in the unsaturateo zone beneath the proposed Ward Valley low-l level radioact;ve w te site in California NRC staff and its contractor, the Oak Ridge Institute i

for Science and Edu lon, developed the enclosed comments on the protocols, for your

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consideration.

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iin.st our Nmments will be us ut in your efforts to address Ward V911ey issues. If you have any questions on the comments, or any future such requests, please r,ontact me at -

301-415-7437. It would also be help if the Department of the Interior could also provide a point-of<ontact for Ward Valley matters.

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. John T.: Gr ves, Director Division of Wa Management Office of Nuclear terial Safety

Enclosure:

As stated cc:

John Garamendi, DOI DISTRIBUTION: tiDO G970799 Central File DWM r/f MBell MFederline.

NMSS r/f WReamer NJensen SSalomon EDO R/F CPoland THarris RBangart DWM t/f PNorry SBums AThadani EMerschoff, RIV SECY PUBLIC HThompson

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i 5-i Plummer, L.N. and E. Busenberg,1996, Chlorofluorocarbons (CFC's) as Tracers and Age-Dating Tools for Young Ground Water: Selected Field Examples, in Stevens, P.R.

and T.J. Nichols, eds., Joint U.S. Geological Survey, U.S. Nuclear Regulatoy Commission Workshop on Research Related to Low-Level Radioactive Waste Disposal, May 4-6,1993, Reston, VA, U.S. Geological Survey Report 95-4045, p. 65-71.

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t.. h Needles Field Office, BLM Sincerely, 1

Shirley Ann Jackson l

Enclosure:

As stated cc:

John Garamendi, DOI DISTRIBUTION: EDO G970799 Central File DWM r/f MBell MFederline NMSS r/f WReamer NJensen SSalomon EDO R/F CPoland THarris RBangart DWM t/f PNony SBums AThsdani EMerschoff, RIV SECY PUBLIC

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Ward Valley Protocols Needles Field Office / Bureau of Land Management 101 W. Spikes Road Needles, Califomia 92363

Dear Sir or Madam:

In a November,1997, letter to Chairman Jackson of the U.S. Nuclear Regulatory Commission, Dep Secretary of the Interior John Garamendi requested NRC comments on draft protocols for triti and chlorine-36 testing. The protocols address sampling and study of the nature of water mo ment in the unsaturated zone beneath the proposed Ward Valley low-level radioactive waste sit n California. NRC staff and its contractor, the Oak Ridge Institute for Science and Education, eloped the enclosed comments on the protocols, for your consideration.

I trust our comments will be usefulin ur efforts to address Ward Valley issues. If you have any questions on the comments, or for a future such requests, please contact me at 301-415-7437. It would also be helpfulif DOI could o provide a point-of-contact for Ward Valley matters.

Sincer John T. Greeve Director Division of Waste nagement Office of Nuclear Mat 'al Safety and Safeguards

Enclosure:

As stated cc:

John Garamendi, DOI DISTRIBUTION: EDO G970799 Central File DWM r/f MBell MFederline NMSS r/f WReamer NJensen SSalomon EDO R/F CPoland THarris RBangart DWM t/f PNorry SBums AThadani EMerschoff, RIV SECY PUBLIC

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@OR SIGNATURE OF :

• • PRI CRC NO: 97-1095 Chnirman lESCt.

ROUTING:

REQUEST FOR COMMENTS ON THE DRAFT WARD _ VALLEY SAMPLING PROTOCOLS Callan Thadani Thompson Norry Blaha Burns LATE: 11/13/97 Merschoff, RIV QSSIGNED TO:

CONTACT:

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DEPT OF-INTERIOR ADDRESSEE:

CHAIRMAN JACKSON LETTER DATE:

Nov-5 97 FILE CODE:

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SUBJECT:

DOI REQUEST FOR COMMENTS FOR THE DRAFT WARD VALLEY SAMPLING PROTOCOLS ACTION:

Signature of Chairman DISTRIBUTION:

CHAIRMAN, COMRS, OGC, RF i

SPECIAL HANDLING: SECY TO ACK CONSTITUENT:

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