ML20202G141
| ML20202G141 | |
| Person / Time | |
|---|---|
| Issue date: | 12/20/1985 |
| From: | Knapp 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 8607150310 | |
| Download: ML20202G141 (5) | |
Text
DISTRIBUTION WM e/f (201.3)
WMGT r/f PDR 0
20 885 uMss r/f MEM0/STARMER WEST VALLEY REBrowning 33,11 1-J0 Bunting MRKnapp RLee & r/f PSJustus MEMORANDUM FOR:
John Starmer, WMLU PDR FROM:
Palcolm Knapo, Chief LHigginbotham LSaru N"O MFliegel
SUBJECT:
RESPONSE TO 00E RRIEFING ON PROPOSED nISPb5AL OF PROJECT LOW-LEVEL WASTE: WEST VALLEY, NY In response to the December 12, 1985 West Vallev Draft Environmental As'sessment (DEA) briefing by DOE and the December 13, 1985 meeting with Mr.
Browning, WMGT has developed the following comments.
The WMGT staff does not support the proposed action for the disposal of pro.iect low-level waste, cited in the West Valley DEA.
This is based on technical considerations addressing long-tem isolation of waste at the proposed location at the West Vallev site.
Specific nhenomena that may well ieopardize long-term waste isolation are erosion and gullying in the site area and a fluctuating near-surface groundwater table.
These phenomena are, or course, addressed in 10 CFR Part 61.
Additional concerns are enclosed; although we understand that 10 CFR Part 61 may not apoly to. the proposed action at the West Valley site, the concerns are presented in terms of their compliance with the technical reouirements of 10 CFR Part f61.
Our concerns address only the action proposed in the DEA and should not necessarily be construed as an indictment of the entire West Vallev site.
However, we have suf#icient concerns reoarding disoosal of low-level waste at West Vallev to seriousiv question continued investigations to tha+ end.
Althouch other disposal site locations or designs mav ba more suitable for disposal of proiect low-level waste, we recomend that alternatives to continued disposal at West Vallev receive more thorouah consideration.
Malcolm Knapp, Chief WMGT
Enclosures:
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1 PERFORMANCE OBJECTIVES Q61.41 Protection of the General Population from Releases of Radioactivity Insufficient documentation and supporting information in the DEA modeling (risk assessment) preclude any judoment as to whether this requirement has been met.
.661.44 Lonn-Term Stability The active and well-documented erosion problems of the site area indicate that this requirement would not appear to be met.
Futhermore, the heavy reliance of the ongoing active maintenance throughout institutional care - especially with respect to pumping of drain water and maintenance of surface water centrol features -
also contributes to the failure to meet this requirement.
TECHNICAL REQUIREMENTS 961.50(a)(2)
Site is Capable of Being Modeled, Characterized, ETC.
This requirement may be met at the site, however, the lack of documentation of the hydrogeology of the site precludes an assessment i
by the staff.
461.50(a)(3)
Site Unaffected From Future Population Growth We have not found evidence that this requirement wculd not be met.
Q61.50(a)(4)
Natural Resources i
We have not found evidence that this requirement would not be met.
961.50(a)(5)
Site is Well-Draired i
Marshy areas throughout the WNYNSC property were observed on a site visit. The presence or absence of these on the site itself, and how they might relate to the groundwater #1 w system, has not been 0
documented in the EA.
161.50(a)(6)
Upstream Drainage Areas Minimized i
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We have n'ot found evidence that this requirement would not be met.
661.50(a)(7)
Sufficient Depth to the Water Table This requirement does not appear to be met in terms of the class A trenches. On the contrary, it appears that these trenches are designed to be emplaced directly in the zone of water table fluctuation based on the information in Herbes and Clapp,1984, concerning the location of the water table.
The history of water accumulation in the trenches at West Valley will likely continue in the proposed trenches as the unstable Class A wastes collapse, causing trench cap failure.
661.50(a)(8)
No Groundwater Discharge to the Site This requirement does not appear to be met since the weathered till zone apparently discharges to the on-site gullies as was observed during a staff site visit.
In any case, there is insufficient hydrogeologic information provided in the DEA on groundwater flow through the weathered till zone to make a proper assessement.
561.50la)(9)
Tectonic Processes 4
We have not #ound any evidence that this requirement would not be met.
561.50f ail 10) Surface Geolooic Processes This requirement does not appear to be met due to the active erosion problems in the disposal site area such as lands 11dinn, headcutting, etc. and the apparent lack of adeauate enaineering designs to ensure adeouate mitfaation o' the problems.
$61.50la)(11)
Impacts # rom Nearby Facilities This requirement does not appear to be met.
The past disposal history and other activities at this site would likely cause a significant impact on the environmental monitoring program for the new LLW disposal area.
SITE DESIGN 661.51 (a)(1) and (alI5) Erosion Protection i
i
3 These requirements do not appear to have been met. While site integrity could oossibly be maintained under normal rainfall conditions, an occurrence of a large, intense storm could cause significant lateral and headward erosion to occur in the nearby gullies tcward the trench and tumulus covers.
In such an event, waste isolation could not be maintained with the current design. Our review of the design presented in the EA indicates that inadequate erosion protection has been provided for the gullies and the trenches to meet these requirements. The designs are based on historic rates of erosion and gullying which may not be representative of expected future erosion rates, particularly if an intense storm were to occur.
Based on such an occurrence we conclude that a significant amount of additional erosion protection is needed to adequately stabilize the site.
In order to meet these requirements (particularly the longevity requirements with no planned maintenancel, we further
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conclude that the required erosion protection should be designed to withstand the occurrence of very rare and intense local storm events, not just historic events.
(61.53 Environmental Monitoring The monitorino progran presented in the EA omits much of the basic information necessary to judge its adequacy.
This required information includes, but is not limited to, location of sampling points, methods of sampling, establishment of baseline in relationship to the site characteristics, settino of action levels, and contingency planning.
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References:
Herbes, S.E. and Clapp, R.B., 1984, " Draft Plan for Diagnosing the Solvent Contamination at the West Vallev Facility Disposal Area", Publication No. 7416, Environmental Sciences Division, ORNL.
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