ML20206U879

Forwards Staff Comments on Repts,Submitted by ,Re Decision Analysis to Support End Point Development for high- Level Waste Tank Cleanup at West Valley

ML20206U879
Person / Time
Issue date:	05/20/1999
From:	Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Mazurowski B ENERGY, DEPT. OF
References
REF-PROJ-M-32 NUDOCS 9905260046
Download: ML20206U879 (5)

Text

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Ms. l$arbara A. Mazurowski, Director

U.S. Department of Energy West Valley Area Office i P.O. Box 191 West Valley, NY 14171-0191 7

Dear Ms. Mazurowski:

I U.S. Nuclear Regulatory Commission staff has completed their review of the reports, submitted by letter dated March 22,1999, on the decision analysis to support end point development for high-level waste tank cleanup at West Valley. The staff's comments are enclosed.

If you have any questions, please contact Jack Parrott at 301-415-6700. i Sincerely,

[ Original signed by:]

John W. N. Hickey, Chief  ;

Decommissioning Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards l l

l Project No. M-32

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Ms. Barbara A. Mazurowski, Director j U.S. Department of Energy  ;

West Valley Area Office P.O. Box 191 West Valley, NY 14171-0191

Dear Ms. Mazurowski:

U.S. Nuclear Regulatory Commission staff has completed their review of the reports, submitted by letter dated March 22,1999, on the decision analysis to support end point development for high-level waste tank cleanup at West Valley. The staff's comments are enclosed.

if you have any questions, please contact Jack Parrott at 301-415-6700. ,

Sincerely, I (eI/ i '

John W. N. Hickey, Chief Decommissioning Branch j Division of Waste Management  ;

Office of Nuclear Material Safety j and Safeguards

, i Project No. M-32 l

cc: P. Piciulo, NYSERDA P. Merges, NYSDEC  ;

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' . U.S.' Nuclear Regulatory Commission Staff Comments on the Decision Analysis to Support End Point Development for High-level Waste Tank Cleanup at West Valley The decision analysis model appears to be an acceptable method to provide tangible objective information for how much clean up is economically practical. These comments are not directed at the appropriateness or feasibility of the model but instead are aimed at completing the model. The analysis appears to provide an acceptable method to quantitatively evaluate the economic feasibility aspect of the first criterion for tank closure, however, the inputs into the method are currently incomplete. From the information provided, as well as, from the March 26, 1999, meeting between U.S. Nuclear Regulatory Commission (NRC) and U.S. Department of Energy, West Valley (DOE-WV) staff and contractors, several areas have been identified which require clarification or additional work / data.

Please note that staff recognizes that the results of the decision analysis are a strong function of the performance assessment (PA)in the draft enyironmentalimpact statement; staff has not evaluated the results of the PA. Additionally, staff notes that it would be more efficient to review the DOE-WV methodology for implementing all three incidental waste criteria simultaneously, rather than reviewing a single criterion as is the case here.

The following are comments staff has in regard to the 'mplementation of the decision model.

1. Staff recommends that a complete sensitivity analysis be performed. The latest version of the decision methodology," Decision Analysis to Support End Point Development for HLW Tank Cleanup:1999 Update," 15 February 1999, recognizes several parameters such as initial tank inventory and allowable inventory as being important input to the results of the model. Another such input is the maximum exposed population number. The maximum exposed population number is the only variable used to determine the value of avoided exposure per curie, which in turn is used to determine the gross social benefit.

Justification for the use of these numbers should be provided or an uncertainty analysis or bounding calculation should be performed.

2. The length of time required to reach a level of cleanliness was estimated from expert elicitation. Staff recommends that DOE-WV consider using other available data in addition to the results from the expert elicitation. Specifically, the Savannah River Site (SRS) has data on actual high-level waste tank cleaning including oxalic acid. This data should be used along with the DOE-WV expert elicitation results to better estimate cleaning time, or justification should be provided for its exclusion. Staff believes that information exchange between sites will help to develop more consistent tank closing methodologies.

3. The analysis model incorrectly assumes that the $2000 per person-rem value of health effects includes property cost. NUREG/BR-0058 Rev. 2 " Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission" states clearly that the $2000 per person-rem values only captures the health effects attributable to radiation exposure. The methodology should therefore account for anticipated property damage or demonstrate why no property damage is expected. Section 5.7.5 of NUREG/BR-0184 " Regulatory Analysis Technical Evaluation Handbook" may help in the estimation of offsite property damage. Also, as stated in Section 4.3.1 of NUREG/BR-0058 averted onsite impacts should be considered, and Section 5.7.6 of NUREG/BR-0184 may be used as guidance.

Enclosure L.

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4. The anticipated variable costs for implementing a technology are based on the time required to implement the technology. The variable cost may be a function of more than I just time. Other factors such as anticipated waste volume increases, waste treatment for proper glass chemistry, and nonradiological occupational impacts may need to be incorporated. Section 5.7.4.3 of NUREG/BR-0184 provides guidance on how to account  !

for nonradiological occupational impacts. A sensitivity analysis could also be used to I determine whether or not these new parameters contribute significantly to the variable cost.

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5. The methodology does not include worker safety in the analysis. Although the exclusion l of worker safety may appear to be appropriate for criterion one, it is part of the l performance objectives stated in criterion three. The March 2,1993, letter from j R. Bernero/NRC, to J. Lytle/ DOE states criterion three as the " wastes . . . will be managed, pursuant to the' Atomic Energy Act, so that safety requirements comparable to the performance objectives set out in 10 CFR Part 61 are satisfied." Worker safety should I be included in the analysis or justification provided for its exclusion.

6. Finally, As part of the staff's review of the DOE-WV Decision Analysis, the staff also reviewed the supporting document, " Waste Tank Farm Transition End Points," WVD-267, I Rev. O, dated August 1997. Evaluation of the residue in the tanks is based on a DOE-WV defined " sum-of-fractions" rule, in which the curies of each radionuclide remaining in a tank are divided by the limiting curies for that radionuclide based on performance assessment results. The sum of the ratios for radionuclides of interest must be less than unity. Staff is concerned that use of the DOE-WV " sum-of-fractions" rule may lead to confusion with respect to the " sum of the fractions" rule for mixtures of radionuclides specified in 10 CFR 61.55 for waste classification, especially when criterion two,

" wastes . . . will be incorporated in a solid physical form at a concentration that does not

=1eed the applicable concentration limits for class C low-level waste as set out in 10 CFR Part 61," of the March 2,1993, letter from R. Bernero/NRC to J. Lytle/ DOE is evaluated.

In addition, the End Points document limited the sum to <0.9, and the Decision Analysis document limited the sum to unity, which is less conservative. Intemal consistency is recommended. Finally, the End Points document does not reference the incidental waste criteria of the March 2,1993, letter from R. Bernero/NRC to J. Lytle/ DOE, but lists an alternative rationale. There are three incidental waste criteria in the referenced letter which are currently being used by NRC staff to evaluate residual tank wastes at the DOE-SRS. Use of other criteria would not be consistent. It is important that future DOE-WV evaluations of residual tank wastes consider all three criteria.

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Department of Energy-Ohio Field Office - _ i West Valley Demonstration Project 7 [ x ,

                                                          . P.O. Box 191 -

b West Valley NY 14171. g%se[ March 22,.1999 Mr. Jack D. Parrott U.S. Nuclear Regulatory Commission

Room 8 C30,' TWFN/MS-8 F37, NMSS/DWM/LLDP -

Washington, DC 20555

SUBJECT:

Decision Analysis to Support Tank Farm Transition End Point Development for High-Level Waste (HLW) Tank Cleanup

REFERENCE:

Letter (63791), R. M. Bernero to J. Lytle, " States of Washington and Oregon: Denial of Petition for Rulemaking," datec March 2,1993 l

Dear Mr. Parrott:

The enclosed reports were prepared to support HLW removal from the HLW tanks at the West LValley Demonstration Project (WVDP). Enclosure I was prepared to evaluate the economically - practical clean-up criteria as delineated in the referenced letter. Enclosure 2 " Administratively Confidential" is provided because the decision analysis model hr.s confidential information E +l regarding operating costs at WVDP. Enclosure 3 is a recent update to the decision analysis l

            . model.                                         ,

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            ~ As you are aware, the decision analysis report for economic practicality is only one aspect of the             l determination regarding HLW tank clean-up at WVDP. Additional studies are underway to evaluate the remaining criteria cited in the reference. U.S. Nuclear Regulatory Commission                     ;

(NRC) feedback on the draft decision analysis model will aid the Project in finalizing the model.

             - A follow-up letter from the Project to the NRC will outline the proposed timetable for feedback               i
            . on the reports as well as the timing for the Project to provide the overall strategy for completion .

of HLW removal from the WVDP Waste Tank Farm tanks. - Enclosu:e 4 is a draft of the transition end points for the HLW tanks. This report focuses on developing both task level and numerical endpoints for the WVDP Waste Tank Farm using 1996 - and 1997 performance assessment results.

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c 7., ,- .. f March 22, 1999 - f

  . Mr. Jack D. Parrott
                                                          --2 NRC's review and feedback on the decision analysis model is vital to WVDP's success. If you have any questions regarding this matter, please contact me at (716) 942-4068 or J. J. May of my

, ' staff at (716) 942-2161. Sincerely, hW0. 5 Barbara A. Mazuro'wski, Director West Valley Demonstration Project

  ; cc: M. E. Rawlings, DOE-HQ,' EM-32,1188/CLOV, w/o enc.

E. A. Lowes, OH/WVDP, WV-37, w/o enc. 1 F. W. Damerow, WVNS, AOC-07, w/o enc.

Enclosures:

1. Draft Decision Analysis to Support West Valley Tank Fann Transition End

                            ' Point Development for HLW Tank Cleanup, dated April 24,1998

2. Draft Decision Analysis to Support West Valley Tank Farm Transition End

               .              Point Development for HLW Tank Cleanup, dated April 24,1998
                            -(Administratively Confidential)
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                      . 3. ' Draft Decision Analysis to Support West Valley Tank Farm Transition End Point Development for HLW Tank Cleanup: 1997 Update, dated February 15, 1999-

4. WVDP-267, Revision 0 (2nd Draft), Waste Tank Farm Transition End Points, dated August 1997

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