ML20247B974
| ML20247B974 | |
| Person / Time | |
|---|---|
| Issue date: | 06/15/1989 |
| From: | Silberberg M NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Surmeier J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20247B972 | List: |
| References | |
| REF-WM-3 NUDOCS 8909130199 | |
| Download: ML20247B974 (13) | |
Text
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f -g- NUCLEAR REGULATORY COMMISSION l, **5, j '+ WASHINGTON, D. C. 20655 i-g-
'JUN 151W 4 MEMORANDUM'FOR: John Surmeier, Chief Technical Branch Division of Low-Level Waste Management and Decommissioning- '
Office of Nuclear Material Safety and Safeguards !
FROM: Mel Silberberg, Chief Waste Management Branch Division of Engineering-Office of Nuclear Regulatory Research
SUBJECT:
REVIEW OF DOE'S DRAFT LLW MONITORING HANDBOOK SERIES ;
4 In response to your April 25, 1989 request for a review of the subject document, " Environmental Monitoring for Low-Level Waste Disposal Sites,"
h DOE /LLW-13Tg, Revision 1, Vols.. I and 2 Dr. Phillip Reed of my staff and ]
MIT's Professor. Dennis McLaughlin, an-LLW research contractor and consultant J to WMB, reviewed the document. Our review offers several suggestions, including.a possible reorganization, that we believe would make the document ~ j more useful as guidance to LLW facility operators for estabilshing environmen-tal monitoring programs. 1 l
WMB's John Randall coordinated the review, enclosed with this memorandum. I If you have any questions on the enclosed review, please contact Dr. Randall at x23873.
V' p Mel Silberberg, Chief <
Waste Management Branch Division of Engineering ,
Office of Nuclear Regulatory Research j cc: R.-John Starmer, NMSS/LLTB Yvonne Young, NMSS/LLTB
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I WMB Review of
" Environmental Monitoring for Low-Level Waste Disposal Sites,"
DOE /LLW-13Tg, Revision 1, Vols..I and 2 Material for this review was prepared by WMB's Dr. Phillip Reed and MIT's Professor Dennis McLaughlin, an LLW research contractor and consultant- to WMB.
'Dr. John D. Randall of WMB ((301 or FTS) 492-3873) coordinated the review.
Comments The stated purpose of this document is to provide guidance to people responsible for the safe disposal of LLW. The document-should help the parties involved to make decisions about environmental monitoring at specific LLW facilities. Although a general handbook can not anticipate all conditions at all possible facilities, it should give personnel at particular facilities the tools that they need to make specific design and operating decisions about environmental monitoring. The document provides a valuable service in identifying:the many issues that need to be considered when monitoring LLW facilities. However, the guidance that it offers could be sharpened.
% General Recommendations The document should be reorganized in such a way that it retains much of its worthwhile information while emphasizing more clearly that an environmental monitoring plan has three major objectives.
- 1) Identifying what should be sampled.
- 2) Identifying where should sampling be done.
- 3) Determining when should sampling be done.
Other issues, such as site preservation and well construction, also are important to LLW facility developers but are documented thoroughly in many standard documents. The document discussed here, on environmental monitoring of LLW facilities, should provide guidance in areas that are not covered elsewhere. For example, modeling and statistical concepts should be integrated into the decision-oriented chapters and should not be covered in isolated tutorial sections that borrow heavily frc;n text books.
Case studies could provide very useful guidance to designers of environmental monitoring programs at LLW facilities. The document's authors should consider' assembling any environmental montoring experience gained at
.the past and existing LLW facilities listed in Tables 1.2 and 1.3 into case
- studies. If such case studies can not be assembled from LLW facilities, similar experience at toxic waste sites may useful in establishing case studies. i In addition to providing case studies, the document should establish clearly the importance of LLW facility site characterization to environmental modeling. LLW facility monitors should be able to detect serious breaches o
through unexpected pathways unique to each facility. These pathways can be
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- l identified only if the geology,; hydrology' and. meteorology of the disposal '{
facility site are characterized properly before the facility'is operational,
,In orde.r to be responsive to these recommendations:provided in this
g PROPOSED OUTLINE FOR A REVISED LLW MONITORING HANDBOOK
+
Chapter : Topic and organization
{
1 -Introduction !
-- Similar to existing introduction 2 -LLW Monitoring Objectives
- Regulatory context
- Specific technical objectives (air, water, soil, biota, etc.)
- Role.of uncertainty; cost-accuracy tradeoffs 3 Case Studies' .
This chapter should introduce important monitoring. issues by example, ..
- 1 illustrating problems that can arise at real LLW facilities such as those listed.in Tables 1.2 and 1.3 of the current draft. j 41 Selection of Monitoring Variables
- Site characterization variables. (geology, hydrology, meteorology, soil, _
biota,etc.)-
- Waste facility variables (LLW-source identity and radionuclides inventory)
- Chemical contaminants and tracers
- Radioactive contaminants 5 Design of Sampling Networks (Where to sample) _
- Site characterization, pre-operational monitoring networks
- Operational and remedial monitoring networks
. Facility decommissioning and post-operational monitoring 6 Design of Sampling Schedules (When to sample)
- Establishing time scales
- Detecting and responding to temporal changes 7 Sampling and Measurement Techniques
- Something more informative that Chapter 6 of the current draft 8 Quality Assurance
- Similar to QA chapter of current draft Appendices (As required, but pertinent to the main body of the document)
Specific Recommendations
The subjtet matter in the document is not well integrated. For example, the sections dealing with modeling and statistics seem to be isolated from each other ar.d from the document's other sections. Most of the recommendations given below are suggestions for integrating the document better.
o In Appendix 8, the discussion of hydrological modeling dwells too much on a triangulation method for estimating hydraulic gradients but devotes only two sentences to the very important problem of estimating hydraulic conductivities in the unsaturated zone.
o Neither Chapter 2 nor Appendix A makes any attempt to connect compartmental pathwe.y models to the monitoring guidelines discussed in Chapters 3 and 4.
The discussion of modeling in Chapter 2 and Appendix A refers to modeling of general and aggregated pathways (e.g. " groundwater to vegetation to. humans")
and should state clearly how such models would indicate where or when to sample groundwater.
' o Chapter 4 should identify the " groundwater analysis methods" that the reader should use or how such methods can be used to determine sampling locations and frequencies. On page 4-23, the following statement appears.
... locations and sampling frequencies for the sumps,,vados.e-zone monitors,- and the saturated zone monitors are determined for each '
site by groundwater analysis methods; and Tables 4-3 and 4-4 provide guidelines if no other information is available.
Tables 4-3 and 4-4 are of no help in this regard because they just state that sampling locations must be determined from "modeling results" without any further clarification.
o Appendix B, with its extensive discussion of numerical methods for extracting information from saturated-zone models, should tell how a groundwater model actually would help one locate sampling sites.
Furthermore, Appendix B should discuss un.:4turated-zone modeling so that it would be much more relevant to the sampling-location guidelines summarized in Section 3.7. Products from NRC's LLW research program could provide useful infonnation to the documents authors on the preparation of guidelines !
on the use of unsaturated-zone modeling in environmental monitoring. )
l o The discussion of statistics in Chapter 5 and Appendix F should emphasize i how geostatistical concepts can be used to identify sampling locations. The I discussion should deemphasize the traditional statistical problem of detecting subtle differences between background and affected areas or subtle temporal trends. The crucial monitoring problem, as illustrated in cases such as Sheffield and West Valley, is the detection of possibly important pathways of LLW transport that would be missed altogether without the monitoring. This detection problem must be addressed by a careful investigation that explicitly identifies uncertain but physically possible hydrogeologic scenarios that could lead to unacceptable releases of radionuclides from disposed LLW.
l 0 The model pathway analysis should include more specific infonnation l
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A
-regarding the transport, transfer, and uptake of radionuclides in soil, and-
. soil-to-plant systems. Reference should be made to' Regulatory. Guide 1.109 for approximate values for transfer coefficients.and uptake factors.
1 lo Table 2.4 should' include oxalic 6cid and picolomic acid in the chelating agent category listing.
o Table 4.2 Suggested Preoperational Analysis Schedule, should ' include more-radiological ~ analyses' for total alpha- and beta-particles. The total-gamma-ray analysis should include radiochemical analyses of those gamma-emitting radionuclides not detected by simple gamma-ray. spectrometry.
'o Table 4.3, Suggested Environmental Sampling Program and Site, should include columns listing specific alpha- and beta-particle and gamma-ray spectrometry analyses. for radionuclides expected in the Sample-type categories listed in the Table, o In Chapter 5, the analytical sensitivities for radionuclides listed in Table 6.3 do not list values for the beta-particle emitting. radionuclides C-14 or tritium.- Also, data are only presented for the gamma-ray emitting radionuclides Co-60 and Cs-137, which values.should also be listed for the radiochemically determined gamma-ray radionuclides (e.g., N1-63).
o The document should contain a table similar to Table 6.3 for analytical sensitivities for chemical measurements of chemically stable elements and compounds, including chelating agents. Such a table would strengthen the document considerably.-
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1
- LLTB'S SUMMARIZED REVIEW COMMENTS ON DOE'S DRAFT LLW MONITORING HANDBOOK SERIES l l
Summarized Review Comments Information presented in the draft handbook could be better organized in the following manner:
(1) The definition of monitoring presented in section 1.1 on page 1-3 could be moved to the introduction section on page 1-1. Also, much of the general information on monitoring, which is scattered throughout the document could be consolidated in the introduction.
(2) Information in the third paragraph, page 1-6, regardin implementation of Environmental monitoring programs...g " design and
.. driving force behind a monitoring," could be moved to the first paragraph on page 2-1, with.the subject heading, " Design and Implementation of Environmental Monitoring Programs." Also, the discussion of.the site characterization data on page 2-1 should include mention of the ecology, climate, geology, and geochemistry, including a requirement for a twelve-month period of data for those characteristics that are subject to seasonable change, as required by 10 CFR Part 61.53 (a).
(3)- Discussion of low-level radioactive waste in the introduction section on page 1-1 should be clarified. For example, the handbook discusses the definition of low-level radioactive waste in the the following manner: (a) definition of low-level waste, (b) definition i of high level waste, (c) discussion of the composition of low-level waste (e.g., transuranic elements such as uranium-235, uranium-233, natural uranium, etc.); (d) discussion of how wastes are- I generated; (e) a discussion of the non applicability of transuranic elements to the definition of low-level waste. We suggest (d) could follow (e) or precede (c).
(4) Use of "the NRC rule, 1981," and the 10 CFR Part 61 should be clarified. For example, the handbook discusses the definition of low-level radioactive waste presumably from 10 CFR Part 61, and the limitation of definitions applicable to the NRC rule, 1981.
(5) Discussion on the Radioactive Waste Policy Act of 1980 in the I introduction section and the discussion of the Radioactive Waste Policy Amendments act of 1985 on page 2-1 could be consolidated.
(6) The discussion on the chemical properties of radionuclides is not clear. For example, on page 2-26, it is mentioned that the chemical properties of radionuclides are frequently ignored while 'l pathways analysis for radionuclides are emphasized for controlling I radiation exposure from low-level waste. However, page 2-6 i mentions several studies by the NRC which include detailed i I
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- , characteristics of waste received by low-level waste' facilities,'which
' emphasize the chemical-properties of the waste.
Further, section-2.6 of page 2-22 mentions that the low-level waste disposal site operator can use the Appendix G outline in determining which wastes-
- are considered hazardous.under the resource Conservation and Recovery Act (RCRA), which are subject to mixed waste management rules.
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9 L .
. WMB Review of
" Environmental Monitoring for Low-Level Waste Disposal Sites,"
DOE /LLW-13Tg, Revision 1. Vols. 1.and 2 Material for this review was prepared by WMB's Dr. Phillip Reed and MIT's Professor Dennis McLaughlin, an LLW research contractor and consultant to WMB.
Dr. John D. Randall of WMB ((301 or FTS) 492-3873) coordinated the review.
Consnents The stated purpose of this document is to provide guidance to people responsible for the safe disposal of LLW. The document should help the parties involved to make decisions about environmental monitoring at specific LLW facilities. Although a general handbook can not anticipate all conditions at all possible facilities, it should give personnel at particular facilities the tools that they need to make specific design and operating decisions about
= environmental monitoring. The document provides a valuable service in identifying the_ many issues that need to be considered when monitoring LLW facilities. However, the guidance that it offers could be sharpened.
General Recommendations The document should be reorganized in such a way that it retains much of its worthwhile information while emphasizing more clearly that an environmental monitoring plan has three major objectives.
- 1) Identifying what should be sampled.
- 2) Identifying where should sampling be done.
- 3) Detennining when should sampling be done.
Other issues, such as site preservation and well construction, also are important to LLW facility developers but are documented thoroughly in many standard documents. The document discussed here, on environmental monitoring of LLW facilities, should provide guidance in areas that are not covered elsewhere. For example, modeling and statistical concepts should be integrated into the decision-oriented chapters and should not be covered in isolated tutorial sections that borrow heavily from text books.
Case studies could provide very useful guidance to designers of environmental monitoring programs at LLW facilities. The document's authors should consider assembling any environmental montoring experience gained at
- the past and existing LLW facilities listed in Tables 1.2 and 1.3 into case studies. If such case studies can not be assembled from LLW facilities, similar experience at toxic waste sites may useful in establishing case studies.
In addition to providing case studies, the document should establish clearly the importance of LLW facility site characterization to environmental modeling. LLW facility monitors should be able to detect serious breaches through unexpected pathways unique to each fuility. These pathways can be 4
) ,
. y
, q f W identified only if. the geology, hydrology and meteorology of the disposal facility site are characterized properly before the facility is operational.-
In order to be responsive .to these' recommendations provided in this.
4
. monitoring document.
PROPOSED OUTLINE-FOR A REVISED LLW MONITORING HANDBOOK Chapter- Topic and. organization
- 1 Introduction
- Similar to existing introduction-2- LLW Monitoring Objectives.
- Regulatory context
- Specific. technical objectives-(air, water, soil, biota, etc.)'
- Role of uncertainty; cost-accuracy tradeoffs j
3- Case Studies.
This chapter should introduce important monitoring issues by example, e ' illustrating problems that can arise at real LLW facilities such as those listed in. Tables 1,2 and 1.3 of the current draft.
4- . Selection of.MSnitoring Variables-
- Site characterization variables'(geology, hydrology, meteorology, soil, biota,etc.) ,
- Waste facility variables' (LLW~ source identity and radionuclides inventory) '
Chemical contaminants and tracers
- Radioactive contaminants 5 Design of Sampling Networks (Where to sample)
- Site characterization, pre-operational monitoring networks
- Operational and remedial monitoring networks
- Facility decommissioning and post-operational monitoring ]
{
)
6 Design'of Sampling Schedules-(When to sample)
- Establishing time scales
- Detecting and responding to temporal changes 7 Sampling and Measurement Techniques
- Something more informative that Chapter 6 of the current draft !
8 Quality Assurance i
- Similar to QA chapter of current draft Appendices (As required, but pertinent to the main body of the document)
Specific Recommendations i
g :Y' l
.# j 1
The subject matter in the document is not well integrated. For example, '
.the sections dealing with modeling and statistics seem to be isolated from each other and from the document's other sections. Most of the recommendations .
given below are suggestions for integrating- the document ~ better.
~
o In Appendix B, the discussion of hydrological modeling dwells too much on a {
triangulation method for estitaating hydraulic gradients but devotes only two J sentences to the very important problem of estimating hydraulic 'j conductivities in the unsaturated zone.
-o Neither Chapter 2 nor Appendix A makes any attempt to connect compartmental {
pathway models to the monitoring guidelines discussed in Chapters 3 and 4. l The discussion of modeling in Chapter 2 and Appendix A refers to modeling of' general ~and aggregated pathways (e.g. " groundwater to vegetation to humans") l and should state clearly how such models would indicate where or when to '
sample groundwater.
o Chapter 4 should identify the " groundwater analysis methods" that the reader should use or how such methods can be used to determine sampling locations and frequencies. On page 4-23, the following statement appears.
... locations and' sampling frequencies for the sumps, vadose-zone monitors, and the saturated zone monitors are determined for each site by groundwater analysis methods; and Tables 4-3 and 4-4 provide.
guidelines if no other information is available.
Tables 4-3:and 4-4 are of no help in this regard because they just state that sampling locations must be determined from "modeling results" without any further clarification.
o Appendix B, with its extensive discussion of numerical methods for extracting information from saturated-zone models, should tell how a groundwater model actually would help one locate sampling sites.
Furthermore, Appendix B should discuss unsaturate % zone modeling so that it would be much more relevant to the sampling-location guidelines sumarized in Section 3.7. Products from NRC's LLW research program could provide useful information to the documents authors on the preparation of guidelines on the use of unsaturated-zone modeling in environmental monitoring.
o The discussion of statistics in Chapter 5 and Appendix F should er@asize how geostatistical concepts can be used to identify sampling locations. The discussion should deemphasize the traditional statistical problem of detecting subtle differences between background and affected areas or subtle temporal trends. The crucial monitoring problem, as illustrated in cases such as Sheffield and West Valley, is the detection of possibly important pathways of LLW transport that would be missed altogether without the monitoring. This detectior, problem must be addressed by a careful investigation that explicitly identifies uncertain but physically possible hydrogeologic scenarios that could lead to unacceptable releases of radionuclides from disposed LLW.
o The model pathway analysis should include more specific information I
l regarding the transport, transfer, and uptake of radionuclides in soil, and !
soil-to-plant systems. Roference should be made to Regulatory Guide 1.109 !
for approximate values for transfer coefficients and uptake factors, l o Table 2.4 should include oxalic acid and picolomic acid in the chelating agent category listing.
o Table 4.2, Suggested Preoperational Analysis Schedule, should include raore radiological analyses for total alpha- and beta-particles. The total gamma-ray analysis should include radiochemical analyses of those gamma-emitting radionuclides not detected by simple gamma-ray spectrometry. ,
o Table 4.3, Suggested Environmental Sampling Program and Site, should include c.alumns listing specific alpha- and beta-particle and gansna-ray spectrometry analyses for radionuclides expected in the Sample-type categories listed in the Table, o In Chapter 5, the analytical sensitivities for radionuclides listed in Table 6.3 do not list values for the beta-particle emitting radionuclides C-14 or tritium. Also, data are only presented for the gama-ray emitting radionuclides Co-60 and Cs-137, Mich values should also be listed for the radiochemical?y determined gamma-ray radionuclides (e.g., Ni-63).
o The document should contain a table similar to Table 6.3 for analytical sensitivities for chemical measurements of chemically stable elements and compounds, including chelating agents. Such a table would strengthen the document considerably.
4
,. l 1 I LLTB'S SUMMARIZED REVIEW COMMENTS ON DOE'S DRAFT LLW MONITORING HANDBOOK ,
a Summarized Review Comments }
Information presented in the draft hancbook could be better organized in the following manner:
(1) The definition of monitoring presented in section 1.1 on page 1-3 could be moved to the introduction section on page 1-1. Also, much of the general information on monitoring, which is scattered throughout the document could be consolidated in the introduction.
l (2) Information in the third paragraph, page 1-6, regardin implementation of Environmental monitoring programs...g " design and
.. driving force behind a monitoring," could be moved to the first paragraph on page 2-1, with the subject heading, " Design and Implementation of Environmental Monitoring Programs." Also, the discussion of the site characterization data on page 2-1 should include mention of the ecology, climate, geology, and geochemistry, ' including a requirement for a twelve-month period of data for those characteristics that are subject to seasonable change, as required by 10 CFR Part 61.53 (a).
(3) Discussion of low-level radioactive waste in the introduction section on page 1-1 should be clarified. For example, the handbook discusses the definition of low-level radioactive waste in the the following manner: (a) definition of low-level waste, (b) definition of high level waste, (c) discussion of the composition of low-level waste (e.g., transuranic elements such as uranium-235, uranium-233, natural uranium, etc.); (d) discussion of how wastes are generated; (e) a discussion of the non applicability of transuranic elements to the definition of low-level waste. We suggest (d) could follow (e) or precede (c).
(4) Use of "the NRC rule, 1981," and the 10 CFR Part 61 should be clarified. For example, the handbook discusses the definition of ;
low-level radioactive waste presumably from 10 CFR Part 61, and '
the limitation of definitions applicable to the NRC rule, 1981.
l (5) Discussion on the Radioactive Waste Policy Act of 1980 in the t
introduction section and the discussion of the Radioactive Waste Policy Amendments act of 1985 on page 2-1 could be consolidated.
(6) The discussion on the chemical properties of radionuclides is not clear. For example, on page 2-26, it is mentioned that the l chemical properties of radionuclides are frequently ignored while pathways analysis for radionuclides are emphasized for controlling radiation exposure from low-level waste. However, page 2-6 mentions several studies by the NRC which include detailed l I l
l
g 4 ,: :,
- t. .
2
-r{
characteristics of waste received by low-level waste facilities, which emphasize the chemical properties of the waste. Further, section 2.6 of page 2-22 mentions that the low-level waste disposal site operator can use the Appendix G outline in determining which wastes are considered hazardous under the resource Conservation and Recovery lAct (RCRA), which are subject to mixed waste management rules.
1