ML20245H542
| ML20245H542 | |
| Person / Time | |
|---|---|
| Issue date: | 04/27/1989 |
| From: | Shum E NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Starmer R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-3 NUDOCS 8905030427 | |
| Download: ML20245H542 (5) | |
Text
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MEMORANDUM FOR:
R. John St'rmer, Section Leader Technical Branch Division of Low-Level Waste Management and Decommissioning, NMSS FROM:
Edward Y. Shum Technical Branch Division of Low-Level Waste Management and Decommissioning, NMSS j
3UBJECT:
REVIEW AND RESOLUTION OF COMMENTS ON THE DRAFT l
TECHNICAL BRANCH POSITION PAPER ON ENVIRON-MENTAL MONITORING OF LOW-LEVEL RADIOACTIVE WASTE DISPOSAL FACILITIES l
Backaround On November 5,
- 1987, the Nuclear Regulatory Commission (NRC) i announced in the Federal Register (FR42486) the availability of a draft Branch Technical Position (BTP) paper on Environmental Monitoring of Low-Level Radioactive Waste Disposal Facilities and requested for public comments. Thirteen organizations / agencies and several individuals commented on the draft BTP.
Subsequently, the NRC's Advisory Committee on Nuclear Waste (ACNW) reviewed and I
commented on the draft BTP.
1 I
The staff has reviewed all these comments and the transcript of the ACNW meeting.
The final BTP is revised substantially taking into
)
consideration of the comments.
The following is a summary of the comments from various organizations / agencies and the staff's i
response and resolution to these comments.
General Comments of the Draft BTP 1.
The intent of the BTP should be stated clearly.
Commenters: Department of Nuclear Safety (State of Illinois) ;
ACNW I
Staff Response:
The staff has revised section 1.2 and has defined the purpose and scope of the BTP.
The staff has made it clear that the BTP is non-prescriptive and only general guidance is given.
2.
The BTP should provide more specific guidance.
Commenters:
EPA; ACNW; Chem-Nuclear Systems, Inc.
(South Carolina) ;
U.S.
Department of Interior (Fish and Wildlife Service); Department of Nuclear Safety (State of Illinois);
Department of Ecology (State of Washington).
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R. John Starmer Staf f Response:
The staff has defined the objectives of three phases of the monitoring program and provides general guidance and examples on how to meet these objectives.
In addition, literature references are provided for more detailed design and implementation of the monitoring program.
The staff recognizes that an environmental monitoring program for a low-level waste disposal facility (LLWDF) is site specific (see section 1.2) and has suggested that the general guidance should be applied with flexibility.
3.
The objectiver of monitoring is unclear.
Commenters:
Department of Ecology (State of Washington) ;
ACNW; Department of Nuclear Safety (State of Illinois).
Staff Response:
The objectives of three phases of the monitoring program are defined, (see section 2.3).
These objectives constitute an acceptable basis for use in establishing an environmental monitoring program.
4.
The document should cle.rify NRC's role and authority for requiring nonradiological monitoring.
Copmenters:
The role is clearly stated in sections 1.2; 4.1.
The requirements for nonradiological monitoring are under the authority of the state and EPA. The nonradiological parameters included in the BTP are limited to the extent that they serve as indicators for waste migration or site i
characterization purpoces.
5.
One year of preoperational monitoring should be extended to define baseline information.
Commenters:
EPA; U.S. Department of the Interior; Department of Ecology (State of Washington);
Department of Health Services (State of California).
Staff Fesponse:
The staff has revised the BTP to clearly encourage the applicant to carry on the preoperational monitoring on certain parameters to beyond the requirement in the regulation.
In addition, some of the measurements, such as wind speed-direction-stability, groundwater parameters and radiological background characteristics should be carried on through the license review period and the operational phase.
6.
General lack of specificity on overall monitoring program.
4 R. John Starmer Commenters: EPA; Chem-Nuclear Systems, Inc. (South Carolina) ;
Department of Ecology (State of Washington).
Staff Response:
The BTP is extensively revised to separate each phase of monitoring to provide more specific guidance.
In addition, examples of suggested programs are given and literature references are provided.
'7.
BTP should consider all critical pathways of radiation to the public.
Commenters:
ACNW Staff
Response
Critical pathways are considered and discussed in section 4.2.1 along with other considerations, such as critical groups and nuclides.
8.
BTP should provide other literature references for more detail design of an environmental monitoring program.
Commenter:
ACN'i Staff Responses:
Literature references are provided in the revised BTP.
Other Specific Comments:
1.
Meteorological data should include measurement of atmospheric stability.
Commenter:
Georgia Power Company Staff Resoonse:
The measurement of atmospheric stability is included in section 3.2.1.
2.
The BTP should link the monitoring program with the modeling of site behavior prior to licensing.
Commenter:
The subject is considered in the pathway analysis discussion in section 4.2.1.
The staff agrees that an effective environmental monitoring program should be linked and related to the modeling of radionuclides transport at the site (pathway analysis).
3.
It would be helpful to site operators to include a
bibliography on specific tecaniques and equipment for the various monitoring requirements.
l i
i O
R. John Starmer Commenter:
EPA I
Staff Resoonse:
This guide is intended for applicants or their consultants to design an acceptable monitoring program 1
to meet NRC's requirements and objectives.
Operating l
procedures and specific techniques for measurement are not provided but can be found in the staff's suggested literature references.
The NRC's Regulatory Guide 4.15 on quality assurance / quality control should ensure that the applicant's i
monitoring program is implemented in an acceptable manner.
4.
There is no regulatory requirement that a statistical data base be developed or that statistical analysis be performed.
If the NRC wished to encourage this kind of analysis, much more detail should be included or referenced.
Commentgr_;_
EPA 1
Staff Response:
The referenced statement was deleted as part of the major revision of the BTP.
Data collection; compilation and analysis, however are integral of the overall monitoring program.
The staff has referenced the NRC Regulatory Guide 4.15 on quality assurance / quality control in Section 4.2.3 which provides acceptable approaches covering the above areas.
5.
The monitoring program components listed on this page are the subject of this Technical Position Paper. As our cover latter points out, most of those components are discussed in a cursory fashion, providing little guidance or detail on the baseline characterization / monitoring systems that the NRC would consider adequate.
We also note that three of the listed components (geology, geochemistry, and seismology) are not addressed at all.
Staff _Itesconse:
Section 3.2 supplements the omission on geology, geochemistry, and seismology.
Staff has provided more detail throughout the document.
6.
Action levels for investigative or mitigative action should be referenced to the site boundary drase limit, not to the background. levels.
.Qommenter:
Chem-Nuclear Systems, Inc.
Etaff Rescopse;_
The staff redefines action level such that I
a percentage of applicable dose limit or multiples of background levels can be used for references in setting an action level.
l
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- i" 3
L
.f R. John Starmer.
p i-t'~
Other miner comments are also evaluated and; major revision of the l
BTP is done by the staff to take -into consideration of these comments.
Sincerely, I
e
,, p
-1 n\\
n Edward Y. 5 um-Technical' Branch Division of Low-Level Waste Management and Decommissioning, NMSS 1
Distribution:
3CentralnFiles:
LLTB r/f' NMSS r/f JSurmeier, LLTB EShum, LLTB l
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PDR Yes:/
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PDR No:/
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Reason:
Proprietary /
_/ or CF Only /
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ACNW Yes:/ //
No:/
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SUBJECT ABSTRACT:
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