ML20236D272
| ML20236D272 | |
| Person / Time | |
|---|---|
| Issue date: | 10/20/1987 |
| From: | Hurt R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Bixby W ENERGY, DEPT. OF |
| References | |
| REF-PROJ-M-32 NUDOCS 8710280103 | |
| Download: ML20236D272 (10) | |
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OCT 2 0 G67 Project No, M-32 Dr. W. W. Bixby, Director
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l V.S. Department of Energy 4
West Valley Project Office P. O. Box 191 l
West Valley, New York 14741-0191 l
Dear Dr. Bixby:
We have reviewed the " Post-Solidification Project Decommissioning Alternatives Study" sent to us on March 12, 1987. The Division of Low-level Waste Management and Decommissioning has made some fairly detailed comments, which I have attached for your consideration. My comments on your approach to decommissioning and the assumptions implicit in the Decommissioning Alternatives Study are contained in this letter.
The Nuclear Regulatory Commission's (NRC) general guidelines'for decontamination and decommissioning (D&D) are contained in " Decommissioning Criteria for Nuclear Facilities," a proposed rule published in the Federal Register on February 11, 1985. The main background document for the proposed rule is the " Draft Generic j
Environmental Impact Statement on Decommissioning of Nuclear Facilities,"
NUREG-0586, which defines in detail the three decommissioning options acceptable to the NRC:
DECON, SAFSTOR, and ENT0MB.
I believe that the criteria in the i
proposed rule and 'ts background documents are generally applicable to the facilities at Wes'; / alley and should be referenced in future West Valley Nuclear Services studies of post-project decommissioning.
The Decommissioning Alternatives Study states (pp.19, 20) that the surface contamination limits in Regulatory Guide 1.86 are not " technologically practical or cost effective" for West Valley.
I do not agree that Regulatory Guide 1.86 can be dismissed at this point.
It is true that the surface contamination limits in the Regulatory Guide are not applicable to some features of the site, such as the burial grounds and settling ponds. On the other hand, the limits would be directly applicable to the above-ground facilities at West Valley should you choose to decontaminate for unrestricted use, an option that should not be rejected untjl further analysis is done.
The Decommissioning Alternatives Study's speculation (p. 20) that j
" decontamination of Project facilities to an arbitrary level suitable for unrestricted access may impose occupational exposures which are not ALARA and l
costs which are not justifiable [ emphasis added]" is premature. Ine Decommissioning Alternatives Study recognizes (pp. 39, 40) that it will be necessary to prepare an Environmental Impact Statement (EIS) on final D&D and site closure, and that exposure pathways and D&D options other than the ones considered in this study will have to be included. The EIS should consider complete decontamination of the above-ground facilities as well as possibilities other than emtombment for the high-level waste tanks. The ultimate disposition of the plant lagoons should also be explicitly considered in an EIS, and long-term institutional responsibility j
for protecting the legoons from erosion or leakage should be established, j
i 8710280103 871020 PDR PROJ M-32 PDR j
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Dr. W. W. Bixby 2
OCT 2 0 W It is reasonable that the presence of radioactive waste burial grounds on the site could influence decommissioning strategy for the buildings and tanks.
Decommissioning of facilities on a multi-use site is in fact specifically considered in NUREG.0586, and in the case of West Valley it is clearly possible that the presence of large radioactivity inventories in the two nearby disposal areas could have an effect on the costs and benefits of the various D&D options.
I caution, however, that the assumption of 100. year institutional control of the site (p. 37) should be understood in terms of NRC's decommissioning criteria in the proposed rule. Specifically, the NRC's SAFSTOR option, which is similar in principal to your DECAP option, would allow sealing and monitored storage of the facilities for up to 100 years provided that at the end of the storage period they are decontaminated for unrestricted release. The NRC's ENT0MB option, which is similar to your DECSEAL, would allow entombment of the facilities provided that it can be shown that the entombed radioactivity will decay to insignificant levels in 100 years or less.
It is not clear that these conditions on the assumption of a 100-year controlled-access period have been considered in the Decommissioning Alternatives Study.
We will, as always, be pleased to discuss these matters further at your convenience.
Sincerely, N
R. Davis Hurt West Valley Project Manager 1
Advanced Fuel and Special Facilities Section Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, hMSS
Enclosure:
Division of Waste Management and Decommissioning Comments on WVDP Decommissioning Alternatives Study j
DISTRIBUTION Project M-32 PDR L(2//f(_,.
PLohaus, LLWM 1
LCRouse GATerry DHurt FBRown FCAF r/f FCSB r/f NMSS r/f JRoth, RI JShaffner, LLWN GSjoblom RCunningham ATClark
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DATE:10/lf/87 :
- 1 OFFICIAL RECORD COPY l
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. Comments on West Valley Post-Solidification Project Decommissioning Alternatives Study A.
Cover Letter "We consider Suggest rewording first sentence of the fourth paragraph as:
that the presence of the radioactive waste burial grounds could influence f
decommissioning strategy for the buildings and tanks." The concerns and conclusion under comment B.2. below should also be highlighted in the letter.
B.
Post-Solidification Decommissioning Report j
1.
Section 1.0, p.5 At least.one alternative should consider the removal of the HLW tanks.
Has a complete 10 CFR Part 61 pathway analysis been completed to justify the entombment option?
2.
Sections 4.1 and 4.2 - General Comments The document is correct that EPA and NRC regulations do not address criteria for residual activity at decommissioned reprocessing facilities and that no directly applicable generic criteria exist.
Thus, we agree that ad hoc criteria are needed and that such criteria should take into account existing standards and guidelines that have been developed for dealing with exposure of members of the public.
The criteria developed must fully consider all the appropriate radiation protection principles and be stated in a manner that clearly defines the applicability and how they are to be implemented. As
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1 2-described in Section 4.1 and Table 4-2, the criteria do not clearly reflect all relevant principles and their application is somewhat uncertain.
Specifically, the criteria do not address considering cumulative j
population exposures and maintaining public exposures -as low as _is reasonably achievable (ALARA). Based on the discussion on page 23 concerning the "Vaughan Memorandum", 00E is committed to following
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the recommendations of the National Council on Radiation Protection and Measurements (NCRP) in matters concerning radiation protection.
In its June 1, 1987 recommendations (NCRP Report No. 91, Recommenda-tions on 1.imits for Exposure to Ionizing Radiation), the NCRP reaffirmed the "need to reduce the total radiation detriment from such justifiable activities or practices to as low a level as is reasonably f
achievable (ALARA), economic and social factors being taken into account" (see page 5).
The NCRP also states on page 39 that exposures to members of the public "are subject to the application of ALARA considerations in the same way as for occupational exposures."
In describing the 100 and 500 mrem / year values, the NCRP also indicates l
on page 5 that the limits are "to be considered a boundary condition, rather than a design criterion." The limits apply to all sources' of l
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exposure except medical and natural background.
Even though the DOE proposed off-site limit for an individual member of the public is 25 mrem / year, which is a fraction of 100, it is not clear how the limit was selected and why. The rationale supporting the performance objectives needs to be expanded to consider the above and other factors such as how the difference between operational releases and exposures where controls are possible and residual.evels in l
unrestricted areas where no controls are possible influence the exposure levels selected.
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1 NRC is currently reviewing. for concurrence the EPA " Interim i
Recommendation on Doses to Persons Exposed to Transuranium Elements in the General Environment" and'we assume DOE is also reviewing the document. The discussion in this document might be helpful in presenting the rationale'for criteria proposed. The. document might j
be directly applicable if the principal contamination of the-facilitiesorareasreleasedforunrestricteduseinvAlvis' transuranic radionuclides.
The major uncertainty in implementation of the criteria is how multiple facilities and practices' are to be treated. The discussion is unclear on whether the proposed dose limits will apply to the site as a whole, each facility, or parts of facilities.
It appears -
l to NRC that in order to meet the requirements of EPA's fuel cycle standards in 40 CFR Part 190 and maintain doses equivalent to 10 CFR Part 61, all activities need to be considered collectively because each will have its own incremental effect. The discussion'is also unclear on how they apply to release for unrestricted use.
For example, on page 24 the document refers to application to facilities which have been decontaminated or stabilized. The criteria seem to address cleanup of facilities that will not be released since they address off-site exposures and intruders.
Persons occupying or usiyg facilities that will be released for unrestricted use would not be intruders. These points should be clarified. These implementation l
matters affect any NRC judgment on the appropriateness of the criteria.
In view of the comments above, NRC cannot concur in the criteria developed in Section 4.
3.
Section 4.1, p. 19 The statement ~beginning on the bottom of page 19 that concludes that application of the guidance in Regulatory Guide 1.86 is not practical or cost effective is a ve.ry important one. Any technical analyses
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4-performed to support this finding'should be referenced 'and provided
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+o NRC for review. Any' analysis' showing that this finding.'is'
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consistent with the West Valley Demonstration Project Act should also f
be provided for NRC review.
4.
Table 4-1 and Section 4.1, p. 23 We note that the discussion of the 10 CFR Pa.+ 61 release performance
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objective in Section 61.41 omits the ALARA provisica of the objective.
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You should also be aware that the cumulative impacts of fert.61 sites l
will be addressed in the site-specific environmental impact statement.-
Part 61 is a health and safety regulation.
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5.
Section 4.2, p. 25 i
We agree with the approach in Section 4.2 that doses from each radionuclides should be summed but the document is not completely clear on how doses from multiple pathways will be summed. As.noted earlier, it is also not clear how all activities will be treated. We
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did not compare the pathways described with all pathways considered in Part 61 since the discussion appeared to be illustrative. We note that ground and surface water pathsays were not. emphasized.
You may wish to consult the Part 61 analyses to be sure no applicable pathways are overlooked. We agree that pathway analyses should be j
site specific. The documents referenced in the third paragraph, second sentence, should be provided. for NRC review.
6.
Table 4-2, Footnote 4, p. 26 Based on Footnote 4, intruder occupancy of up to one. year is expected.
Annual inspection implies a lax institutional control. Also, is it intended that there will be different access levels in different
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areas of the site? What is being proposed for the areas containing the Hl.W tanks and the disposal areas? These details need to be j
provided. Definition of " effective dose equivalent commitment" 1
would aid the reader in understanding the criteria.
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7.
Section 4.2,1st Paragraph, p. 27
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Why are different criteria being proposed based on site-specific l
conditions? Why doesn't consistent criteria apply to all activities?
This statement should be explained in more detail.
8.
Sections 4.2.1. and 4.2.2, pp. ' 27-30 Suggest using the exposure pathways described in the Environment j
Impact Statements (EIS's) supporting 10 CFR Part 61. Also the dose analyses should include sources applicable to all West Valley site activities.
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9.
Section 4.2.2, p. 30 Will the explorer intruder scenarios apply to the HLW tank area and disposal sites?
- 10. Section 5 1
The analyses should include all site activities not just those required under the West Valley Demonstration Project Act.
- 11. Section 5.3, pp. 37-40 The discussions included in this section raise very important issues.
l In fact, without resolution of these issues it is difficult to 1
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,, _ 4 understand how a credible decommissioning plan can be prepared. What are the schedules for resolution of these issues and how will the decisions be factored into post-solidification decommissioning planning?
- 12. Section 5.4, 2nd Paragraph, p. 40 A HLW tank removal option should be considered as an alternative in this study.
What is the basis tior considering' releases from the HLW tanks for only 200 years? This is inconsistent with the approach taken in the development of 10 CFR Part 61.
- 13. Section 6.1, 2nd Paragraph, p. 47 How much activity is expected to be removed from the HLW tanks prior to entombment? How much will remain?
- 14. Section 6.1, Last Paragraph, p. 48 Note that 10 CFR Part 20 requires a 2 mr/hr dose rate in unrestricted areas where continuous exposures are possible.
Why,then,isaid-,
mr/hr level used? Note also that the tabli in' Appendix B, p. AP-8-1, shows hot spots may 4pproach 50 mr/hr. This apparent contradiction should be clarified.
The smearable limits appear reasonable choices considering the lack of specific regulations and generally applicable standards for residual contamination. These contamination levels are significantly-below those referenced in 10 CFR Part 71 for transportation.
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- 15. Section 6.1, 2nd Paragraph, p. 49 Is the license termination process described here consistent with NRC policy?-
- 16. Section 6.1, 3rd Paragraph, last Sentence, p. 49 The statement that the generation and removal of additional wastes to the on-site. disposal area was not considered reasonable in light'of-the criteria in Section 4.0 should be explained in more detail.-
- 17. Section 6.3, Last. Paragraph, p. 51
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See comment 14.
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- 18. Section 6.3,1st Full Paragraph, p. 52 See comment 15.
19.
Section 7.1,1st Paragraph, 2nd Sencence, p. - 52 What is "Y0E D0LLARS"?
20.
Table 7.2, p. 55
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What is the basis for assuming WV0P wastes will account for 35 percent of the wastes in the NOA?
Note also that the uncertainties in this analysis are inconsistent with your cost calculation in seven significant figures. Suggest:
i using two significant figures throughout the report.
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- 21. Section 7.1, p. 56 j
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The reason why virtually identical alternatives (DECAP0Y and DECAP 95; DECSEALOY and DECSEAL 95) have cost differences of approximately 30 percent should be explained in more detail.
- 22. Section 7.2.c, p. 58 The totals given apparently do not include contingencies, fees, G/A-and DOE management reserves. Why are these not included?
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- 23. Appendix A, Last Paragraph, p. AP-A-3
'Why do remote operations require less technical. supervision? It l
l would appear that activities involving high radioactivities would require a higher level of supervisory oversight.
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