ML20202G102
| ML20202G102 | |
| Person / Time | |
|---|---|
| Issue date: | 03/11/1986 |
| From: | Tokar M 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 8607150303 | |
| Download: ML20202G102 (3) | |
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION n
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.>!AR 11 1986 MEMORANDUM FOR:
R. John Starmer, Section Leader D
Low-level Waste Projects Section, WMLU FROM:
Michael Tokar, Section Leader Design Section, WMEG
SUBJECT:
REVIEW 0F REVISED EA FOR WEST VALLEY - +
REFERENCE TAR WM-860173 As requested in your Technical Assistance Request, we are providing comments on the revisions made to the West Valley draft EA. The purpose of this follow-on review is to note changes, deletions, or additions to sections of the EA which we had previously reviewed and to determine if any alterations should be made to our earlier review comments provided to the Division of Fuel Cycle.
The consensus is that although our previous questions and comments have been addressed either in the revised EA or at the meeting in West Valley on February 20, 1986, concerns still remain because of (a) insufficient justification of a number of assumptions made in the EA and (b) lack of technical details which would allow for an independent analyses. Addi tional,
specific comments are enclosed.
Reviewers for WMEG include Roy Person, Derek Widmayer, and Stan Neuder.
Should you require further assistance, please contact Stan Neuder directly at x74533.
A Michael Tokar, Section Leader Design Section, WMEG
Enclosure:
As stated 8607150303 860708 PDR FOIA RESNIKO86-396 PDR
4, a
g SN/EA/ WEST VALLEY WMEG REVIEW 0F THE REVISED EA FOR WEST VALLEY Review comments made by(January 9,1986 Starmer to Clark) and is herein WMEG on the original EA were provided to the Division of Fuel Cycle by memo, referred to as " reference memo."
1.
With regard to reference memo, comment ID of enclosure 1, we note that additional information has been added in Section G.3.2.2.3 of the EA on the selection of PRESTO for analyses and the appropriateness of the code for modeling the West Valley site.
Staff still considers the application inappropriate without further substantiation that this application of a generic code to a site specific situation is valid.
2.
With regard to reference memo, comment 2A of enclosure 1, we note that additional presentation of the hydrologic characteristics of the site is given in the " companion" report entitled " Subsurface Characterization Report-Low Level Waste Disposal Area." Staff still considers the characterization of the weathered till to be inadequate, and the definition of the input values as determined from the hydrologic characterization to be inadequate.
It is still not possible to fully assess the proposed designs with the current modeling presentation.
3.
Regarding reference memo, comments 2C, 2C(1) and 2C(3) of enclosure 1, remarks which we have made above under item 1, with respect to the use of 1
the PRESTO code, apply here.
Presentation of the detennination of input
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values remains inadequate and the simulation of the physical processes
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at the site is not adequately described.
1 4
With regard to reference memo, comment 2F, enclosure 1, although WVDP has provided a performance assessment which includes the TRU source term for project waste, the basis for this source term estimate has not been detailed in the EA, 5.
Regarding reference memo, canment 2G, enclosure 1, this version of the EA does not include " braced trench walls." Delete our original comment.
6.
With regard to reference memo, comment 6, enclosure 2 WVDP appears to have addressed concerns regarding cap failure (due to chemical and weathering processes) by assuming a cap failure rate and assigning a corresponding increase in cap permeability. However, the technical basis q
and justification for assuming a specific cap failure rate over time and for the assignment of a permeability, has not been provided. The i
. s.
SN/EA/ WEST VALLEY conclusion that increased infiltration and additional leaching will result in lower leach rates for radionuclides should be technically justified.
i 7.
Regarding reference memo, coment 8 and coment 9, enclosure 2, explanations were 20, 1986 presentation at West Valley, NY for (a)given in the February the use of somewhat different sets of assumptions used for predicting dose from the tumulus and trench disposals, (b) the
" apparent" combination of pathway analysis, and (c) not making comparisons with the EIS for 10 CFR Part 61. Coments 8 and 9 may be deleted on these bases.
8.
With regard to reference memo, coment 12, enclosure 2, the potential for lateral infiltration of water into the trenches has been addressed in the revised EA in terms of vertical and horizontal flow velocities. However, the potential for long term accumulation of water in the trenches has not I
been discussed.
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