ML20214R330
| ML20214R330 | |
| Person / Time | |
|---|---|
| Issue date: | 05/22/1987 |
| From: | Davison N NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-PROJ-M-32 NUDOCS 8706080083 | |
| Download: ML20214R330 (6) | |
Text
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o Project No. M.32 N 2 2 I387 MEMORANDUM FOR: Paul H. Lohaus, Acting Chief l
Technical Branch i
l Division of Low-Level Waste Management i
l and Decomissioning, NMSS FROM:
Norman H. Davison NRC West Valley Project Manager i
Advanced Fuel and Special Facilities Section Fuel Cycle Safety Branch Division of Fuel Cycle, Medical, Academic, l
and Comercial Use Safety, NMSS l
SUBJECT:
WVDP POST. SOLIDIFICATION PROJECT DECOMMISSIONING ALTERNATIVES STUDY Enclosed is a copy of NYSERDA's coments on West Valley Den:onstration Project's (WVDP) Post-Solidification Project Decomissioning Alternatives Study.
I received these coments on May 7,1987, and arn providing them to you for your information.
I also received a telephone inquiry from 00E.WVDP on the same day. They would like to know when we can provide consultation on this alternatives study.
Please let me know so I can make appropriate arrangements.
Original Signed by
..DJuea R.TANu. _
)ANorman H. Davison NRC West Valley Project Manager Advanced Fuel and Special Facilities Section g6080083870522 Fuel Cycle Safety Branch l
N-32 PDR Division of Fuel Cycle, Medical.
l Acapmic, and Comercial Use Safety
Enclosure:
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" 0FFICIAL RECCR0 COPY I
4 New York Ctete i
Energy Roemerch and Development Authority Two Rockefeller Plaza. Albany. New York 12223 (5181465 8251 i
I WILLIAM D. COTTER 1RVIN L WHITE Chairman President April 29, 1987 Dr. Willis Dixby, Director United States Department of Energy West Valley Demonstration Project Office Post Office Box No. 191 West Valley, New York 14171-0191
Subject:
Draft Post-Solidification Project Decommissioning l
Alternatives Study Comments l
Dear Dr. Dixby:
l l
The Energy Authority has reviewed the referenced draft l
Post-Solidification Project Decommissioning Alternatives Study (" Study")
dated February 1987, and has provided copies to other interested State
(
agencies for review. The draft Study examines issues related to alternatives for meeting the mandates of Section 2 (a) (4) of the West Valley Demonstration Project Act and the DOE /NYSERDA Cooperative Agreement that facilities, materials and hardware used in connection with 'the WVDP be decontaminated and decommissioned "in accordance with such requirements as the (Nuclear Pegulatory) Commission may l
prescribe". The use of the term " decommissioning" appears to assume this context throughout the draft study and will be so used in these comments. Based upon our review, the following general comments and the specific comments in the attachment are submitted for your consideration.
o The Study correctly points out that the NRC has not yet
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l developed decommissioning criteria in the form of specific acceptable residual radioactivity levels. Therefore the study l
indicates that DOE will propose residual radioactivity level j
criteria for the NRC to consider for WVDP decommissioning.
In a more general respect, however, the NRC has developed decommissioning criteria that are designed to apply to all nucicar facilities, including 10 CFR Part 50 facilities such l
as the reprocessing facilities at West Valley which are being l
used in conntacticn with the WVDP. The requirements the NRC l
intends to apply to decommissioning of nuclear facilities are
[
set forth in its Notice of Proposed Rulemaking,
" Decommissioning Criteria for Nuclear Facilities," 50 Fed. Reg.
5600 (Feb.11,1985) ("NRC Decommissioning Criteria"). These requirements are not analyzed or referenced in the draft Study, however. The draft Study should be revised to take the NRC Decommissioning criteria into account.
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o Under the NRC Decommissioning Criteria, decommissioning would not be completed until the facilities are in a condition where the residual radioactivity levels permit license termination.
I and release of the facilities for unrestricted use. The l
criteria also indicate that these residual radioactivity levels must be achieved and decommissioning thus be completed within not more than about 100 years.
o It is recognized that the study is only a first step in i
analyzing options for meeting the decommissioning provisions of the WVDP Act.
Ultimately, adequate technical information and assessments will have to be developed to support conclusions that the option selected for the WVDP facilities can meet the NRC Decommissioning Criteria, and the performance objectives and residual radiation level standards being developed.
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o The NRC Decommissioning Criteria provide flexibility in selecting a decommissioning alternative and the time (from immediate to about 100 years) over which decommissioning may be completed. These criteria do permit selection of an alternative that would defer or delay the time by which acceptable residual radioactivity levels would be reached for occupational "ALARA" purposes, such as the Study suggests would be a benefit of the " Sealing" option for WVDP facilities.
It should be recognized, however, that under the NRC Decommissionir.9 Criteria a decommissioning option like
" sealing" (which is similar to "SAFESTOR" under those criteria), Project decommissioning would not be completed until any remaining residual radioactivity was within the levels which permitted release for unrestricted use and termination of license, as demonstrated by adequate technical information and analyses and a "terminsi radiation survey". Until that time the Project would not be completed and the costs of any required interim surveillance, monitoring, and maintenance, as well as any additional tail-end decontamination necessary to achieve prescribed residual radioactivity levels, would be continuing Project costs.
I If you or your staff have any questions regarding these comments, please call me or Dan Anderson,at (510) 465-6251.
Sincere 0D T.K. DeBoer Director Radioactive Waste Management program da/cm cc D.D. Anderson E. Maestas, WVPO R.G. Spaunburgh, WVDP
+,.
NEW YORK STATE COMMENTS ON DRAFT "C" p0ST SOLIDIFICATION D&D ALTERNATIVES STUDY, DATED FEBRUARY 1987 l
l Summary Pago, paragraph 2-Should also note that proposed criteria have aircady been developed by NRC (except residual radioactivity level standards) in Notice of Proposed Rulemaking on " Decommissioning Criteria j
for Nucicar Facilities",50 Fed. Reg. 5600 (Feb.11,1985).
I Page 1, Section 1.0, paragraph 2-change to read: "In this study it was l
assumed that the major activities in the post-Solidification period I
include the followings" Pago 4, Section 1.0-The completion date (2004) for Alterra;ives 1 and 3 should be reevaluated to determino whether it is still ).talistic in light of latest available information on Federal repositor,' development and acceptance queue.
Page 7, References - Should cito USNRC's "Docommissioning Critoria for Nuclear Facilities",50 Fed. Reg. 5600 (Feb.11,1985).
Page 8, Section 2.0 -The definition provided for "docommissioning" is not consistent with the NRC definition in the NRC Decommissioning Critoria. Change to read: " Decommissioning"- the removal of nucioar facilities safely from service and reduction of residual radiation to a level that permits release of the property for unrestricted use and termination of the license".
Pago 8, Section 2.0 -The definition of "Soaling" is questionable, in that it does not seem possibio literally to " permanently closo" all oponings in the facility.
It seems technically impossible to effectuato "permanont" closure becauso all means of closure will deteriorato and eventually fail, resulting in release of residual contamination that may remain.
Page 11, Section 3.2 -There is no mention of the Project use of the NDA in the Description of Facilities.
Page 13, Section 3.2.4 -Is it accurate that the supornatant Troatment System building is supported by the storage vault for Tank BD-27 Page 15, Section 3.2.5.2, 6th bullet - Aren't there two storago buildings for temporary storage of rad wasto?
Pago 19, Section 4.0 - As written, this paragraph sooms to inply that WVHS' recommanded performance objectivos for decommissioning are based solely on DOE guidance critoria for the decommissioning of other types of D00 facilities, contrary to the implications of the references to guidance of HRC and EPA, as listed in Table 4-1. This should be clarified. In addition, this paragraph should be revised to recognize l
that, except for residual radioactivity level standards being developed I
by NRC and EPA, the NRC has developed the "Doconmissioning Criteria for Huclear Facilition" set forth at 50 Fed. Reg.5600 (Feb. 11, 1985).
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Pages 19-20, Section 4.1 - This section should be completely rewritten to reticct the NRC Decommissioning Critoria, which makes clear that decommissioning will not be complete until the facilities are in a condition where their residual radioactivity levels would permit licenso termination and release for unrestricted use. Sco general comments in the lotter to which these specific comments are attached.
Page 20, Section 4.1, paragraph 2 - It is not clear what decommissioning criteria are referred to in the Study as " arbitrary".
Nor does there appear to be any basis for assuming that residual radioactivity lovels to be developed as standards permitting release for unrestricted use would be " arbitrary".
Page 27, Section 4.2.1, paragraph 1-It is suggested that considoration be given to dovoloping possible reduced WNYNSC boundaries based on current land features (e.g., Rock Springs Road to Thompson Road; to
- intersection of Buttermilk Road and Duttormilk Creeks to a short distance beyond confluence of Duttermilk Creek and Franks Creeks to Rock Springs Road) as an alternativo to be ovaluated in performing pathway analyson.
Page 37, Section 5.3.1-This section should be reconsidered and ravised l
in light of the NRC Decommissioning Critoria and the related generai comments in the letter to which those specific comments are attached.
Pago 30, Section 5.3.2, bullet 3 - It is not cicar what in meant by this " bullet" about SDA leachato treatment or how it is viewed as relating to the subject of the Study.
Pages 45-52, Section 6.0 -Under the NRC Decommissioning Critoria, the WVDP Act, and the Cooperative Agreement, the Project and decommissioning will not be completed until the Project facilities are in a condition where their residual radioactivity levels would permit license termination and reloano for unrestricted use. Soo general comments in the letter to which thoso specific comments are attached. This section should be revised in light of the NRC Decommissioning Critoria.
Page 49, Section 6.1.2, paragraph 2-To the extent that a "prasession only" Licenso would be regnirgd t r Pr ject facilities, decommissioning r
in accordance with the NW: Deedpmissioning critoria, the WVDP Act, and the Cooperative Agrooment would,not be completods and thus the Project would not be completed.
Page 54, Tablo 7-1 -It is not cicar whether costs of HLW and TRU wasto shipments are included in this task.
It is also not entirely clears how cost of " closure of the WVDP portion of the NDA" ($5,100,000) was datorminods what this work includos; or whether the difference betwoon the $5.1 million figuro in Pago 54 and the $3,091,475 figure on Pago 55 is attributable only to contingency, fee and C/A, and DOE management l
reservo.
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Pagos 54,55,57 -The proper way to apportion decommissioning costs i
would be to determine the cost to decommission on the Project portion of the NDA as a stand-alone facility and then to determine the incremontal
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cost of extending the effort into the area of prior disposed wastes. The method used in the Study also seems to overlook including the areas of the NDA occupied by the proposed Class A trenches.
In addition, it is not cicar that the separato estimates related to closure costs for the "WVDP portions of the NDA" and for the tumulus (or " Drum Storage cell")
portion of the expanded NDA adequately account for any intorrelationships in cumulative or integrated closure requirements for the NDA tronches and tumulus.
Page 50, section 7.2.c - The " post closuro care" costs would be Project costs.
Pago 59, riguro 7 The schedulo should be updated.
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