View source for NUREG/CR-5512, Submits Comments on NUREG/CR-5512,Vol 2, Residual Radioactive Contamination from Decommissioning - Users Manual,Draft for Review, Per 970203 Request

{{Adams
| number = ML20147F721
| issue date = 03/17/1997
| title = Submits Comments on NUREG/CR-5512,Vol 2, Residual Radioactive Contamination from Decommissioning - Users Manual,Draft for Review, Per 970203 Request
| author name = Greeves J
| author affiliation = NRC OFFICE OF NUCLEAR MATERIAL SAFETY &amp; SAFEGUARDS (NMSS)
| addressee name = Morris B
| addressee affiliation = NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
| docket = 
| license number = 
| contact person = 
| case reference number = REF-WM-3, RTR-NUREG-CR-5512
| document report number = NUDOCS 9703270155
| document type = INTERNAL OR EXTERNAL MEMORANDUM, MEMORANDUMS-CORRESPONDENCE
| page count = 8
}}

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   .. ..                                                                                                                                  l March 17, 1997                                                                    I l
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MEMORANDUM T0:         Bill M. Morris, Director Division of Regulatory Applications                                                                 l Office of Nuclear Regulatory Research FROM:                  John T. Greeves, Director                                                                         '
Division of Waste Management                  [0RIGINAL SIGNED BY MVF FOR:]
Office of Nuclear Material Safety and Safeguards

==SUBJECT:==
REVIEW OF NUREG/CR-5512, VOLUME 2, " RESIDUAL RADI0 ACTIVE CONTAMINATION FROM DECOMMISSIONING - USERS MANUAL, DRAFT FOR REVIEW" In response to your February 3, 1997, request, Division of Waste Management staff reviewed NUREG/CR-5512, Volume 2, " Residual Radioactive Contamination From Decommissioning - Users Manual, Draft for Review." Our comments are attached.
The comments were mainly generated by Duane Schmidt (415-6919). Robert Neel (415-6696) and David Fauver (415-6625) also contributed comments. Please
.              contact one of the above individuals if you have questions.
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DWM COMMENTS ON NUREG/CR-5512 USER'S MANUAL                                      1
!     COMMENTS ON THE NUREG/CR-5512 USER'S MANUAL J
: 1. Page 1.1, Second Paragraph l
This paragraph makes statements that may conflict with NRC intentions as to the applicability i     of the Dand D model. For example, it states that Dand D is to be used for licensees that
:   - must remediate. However, it is likely that the code could also be used to determine if           {
remediation is needed. in addition, the paragraph indicates the code would be used at sites
:     requiring unrestricted release. Would the code be acceptable for use at sites considering
. restricted release? In the third sentence of this paragraph, the annual dose limit for
;-    individuals is stated to be 15 mrem. This is the value from the proposed decommissioning          4 rule, and is subject to change when the rule is issued in final form. The introduction should be revised to better reflect NRC policy and intent regarding the use of Dand D.                   :
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: 2. Page 1.1, Second Paragraph and Third Paragraph l     The last sentence of the second paragraph and the third paragraph discuss the balancing of        :
costs and benefits. However, the benefits are usually considered to be savings of collective dose. The DandD code does not currently include calculations of collective dose, and the methodology is generally intended to estimate doses to a critical group, rather than to all       ,
j     persons around a decommissioned site. Therefore, it is unclear how the DandD code could i     be used to estimate collective doses for such cost-benefit comparisons.                           ,
!     3. Page 1.1, Fourth Paragraph                                                                     t The last sentence of this paragraph states: " Licensees must apply each level of screening until i     compliance is determined." This contradicts general discussions related to the " Decision r     Framework" work ongoing (in which Sandia has been involved), and there is no compelling j     reason that a licensee should be prohibited from starting modeling efforts at higher than the i     first screening level, or from skipping a screening level. Perhaps licensees should be encouraged to follow each screening level, as it may be to the licensee's benefit.
: 4. Page 1.1, Sixth Paragraph l
t The second sentence of this paragraph mentions a " generic modeling approach." This has not
:     been defined. It would be useful to at least refer to Volume 1, perhaps as follows: "The generic modeling approach of Volume 1 defines."
i i     The third and fourth sentences appear to indicate that each scenario (of the two building
;     scenarios) relates to both volume and surface contamination, which is incorrect. One scenario i     relates to volume sources and one relates to surface sources. The two sentences should be l      reworded.
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Also, in the last sentence, the word "a" should be deleted.
A'ITACHMENT l

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: 5. Page 1.2, Second Paragraph, and Page 1.3, Figure 1-1 The fifth and sixth sentences of this paragraph describe the food types considered for the j
residential scenario and the types of animal feed considered. It is not clear why it is not.
mentioned that the food types for food grown from irrigation water are the same. Actually,               I these details may not be needed for this section of the report. In contrast, for the building scenarios, only the general pathways are mentioned, not additional details.
A related comment applies to Figure 1-1. In this figure, there is a lot of detail provided about the food types and animal feed types that relate to the food ingestion pathways of the residential scenario. These details occupy a significant fraction'of the figure, even though the emphasis of the figure and text appears to be on the pathways related to each scenario. In                ,
addition, the sources of volume contamination and surface contamination are not shown, and               !
there should also be arrows from the soil box to the external exposure and inhalation boxes.             l
: 6. Page 2.1 n is In order to achieve rapid acceptance by the user of the basic operations in the code,4           /
recommendTat Section 2.1 be re-numbered (and perhaps to follow the current Section 2.3),
and that the excellent write-up in Section 2.2 follow Chapter 1, Introduction.
A number of reviewers were required to spend more time than seemed appropriate to understand the discussion in Sections 2.1.1, 2.1.2 and 2.1.3. These sections, although necessary to understand, should be clarified.
: 7. Page 2.2, Section 2.2 -
This section provides a tutorial in running a test calculation session. However, the session group file indicated, "testcase.grp," was not provided on the DandD Interim Release 1.0 disks (dated July 1996). The same operations could be performed using one of the other session groups provided.
: 8. Page 2.4, Second Paragraph The first sentence refers to the "Radionuclide Mixture button." This should be referred to as a " check box," rather than a button.
: 9. Page 2.7, First Paragraph In the third sentence, the reader is instructed to click on " View." This button actually says
           " View Report."
: 10. Page 3.27, Sections 3.2.2 and 3.2.3                                                                  ,
As indicated in the text, these sections were not yet provided. Thus, they have not been reviewed.                                                                                                l l
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       ' 11. Page A.1, Last Sentence This sentence indicated that changes in default parameter values, presumably from those           l values of Volume 1, were to be documented in Appendix D of the User's Manual. It is clear         !
that not all changes in default values were noted in Appendix D. For two values in Table          l D.5.1, it was noted that the parameter was modified, and the reader is referred to Appendix A. However, there was no information in Appendix A to discuss the changes in parameter values,                                                                                           j l
: 12. Pages A.3-A.5, Table A.1 This summary table does not include units for the parameters described. In addition, some of      l the parameter descriptions appear to be incorrect. As an example, DFGj is described as a dose, while in Volume 1 (page 5.57) it was described as a dose conversion factor. Table A.1 would be much more helpful if the parameter descriptions were checked and veri 6ed, and if        3 the units used were provided. See also later comment regarding Pages A.ll and A.12 and            !
Table A.I.
: 13. Pages A.6-A.7, Section A.3.3 This section describes the modification of the equation describing secondary ingestion of soil.
This subject is also discussed on pages 6.14-6.16 of Volume 1 (Kennedy and Strenge 1992).
It is not clear that the quantity of soil intake from secondary soil ingestion should be proportional to the total time on the contaminated site. It seems that soil ingestion might be primarily related to time spent outdoors and to the quantity of garden foods (grown on or near contaminated soil) consumed. Not enough details have been provided in Volume 1 and Volume 2 to support the change in Equation 5.73 suggested. It seems clear that the equation should be modified, but there is essentially no justification provided for the form of the proposed modification. If no additional supporting information can be provided, there should be statements to indicate such and to indicate why the proposed modification seems reasonable.
: 14. Page A.9, last Equation It appears that the last equation on the page should be numbered "(4.15 m)," rather than
          "(4.15)."
: 15. Page A.11, Paragraph Following Equation 4.13 The first six sentences of this paragraph provide a somewhat confusing description of the problem in Volume 1 and the changes made in the current report (User's Manual). One suggestion to improve this paragraph is to modify what is currently the fifth sentence, as follows, and move it to follow the current second sentence: "Thus, between Equations 4.6 and 4.13, the definition of C ;3 was changed."
In addition, the sixth sentence could be modified slightly to read as follows: "As a result, the C, term is now based."                                                                           ,
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: 16. Page A.12, Last Paragraph This paragraph presents a confusing description of problems in the equations for the residential scenario, related to inclusion of soil concentrations twice in the calculation of doses. The second and third sentences appear contradictory in the way they describe the basis of the calculations of Equations 5.90 and 5.92. Actually, it appears that the problem related to these equations is that the definitions of the units for the parameters A,y, A,3{ }, A,y, and S,3{ } were incorrect in Volume 1. The paragraph (of Page A.12) should be modified to state this, and to state how the units should have been defined.
In additL: in the fifth sentence of the paragraph, it is stated that Equations 5.90 and 5.92 are used " exactly as presented in Volume 1" Actually, they are used differently because the definitions of the concentration and time-integrated concentration parameters are being changed. This is an important difference and should be noted.
The changes to Equations 5.69, 5.70, 5.71, 5.73, 5.74, and 5.77 appear wa-           ed.
: 17. Pages A.11 and A.12 and Table A.1 The changes to equations described on pages A.11 and A.12 point out the frequent problem of incorrect or imprecise definitions of parameters and their units in Volume 1. This is an important reason to suggest that Table A.1 should include correct, verified definitions and units for all the parameters used in the models.
: 18. Page A.15, Equation Numbers in Section A.3.8 Since equation 5.74 has been separated into two equations, the two equations in this section should be labeled (5.74 ma) and (5.74 mb), as was done for Equation 5.82 later.
: 19. Page A.17, First Equation The first equation on this page should be labeled (5.82 mc), as it is the third equation of those replacing Equation 5.82.
: 20. Page A.17, Section A.3.10 The meaning of this paragraph is not clear. The first four sentences indicate that some equations in Volume 1 are incorrect, though a complete listing is not provided. The only three equations specifically mentioned (only as examples) were already discussed earlier in Appendix A of the User's Manual, so it is not even clear if there are additional problems in these or any equations, that would need to be corrected. The final sentence seems to indicate that the models implemented in the DandD code have used corrected equations, though again the correction and affected equations are not discussed. Also, since the " current equations" are not provided or described here, it is not clear what the " correct implementation of the methodology" is.
If the only purpose of this section is to indicate that the changes described earlier in parts of Section A.3 have been made, it seems that such statements could be added to the introduction

          .to Section A.3, on page A.2, and Section A.3.10 could be deleted. If, instead, Se A.3.10 is actually describing additional problems and corrections in equations, th should be provided, as was done in Sections A.3.1-A.3.9.
: 21. Page B.4, Third Bullet of Section B.3.1.3 It appears that this statement should indicate scaling against "the default cultivated area of 3800", rather than "the default site area of 3800."
: 22. Pages B.15-B.18, Sections B.4.1.3-B.4.1.6                                    -
It appears that sections B.4.1.3-B.4.1.6 should all be subsections of Section B.4.1.2 (Sealed Source Manufacturers). If this is correct, the sections should be reorganized or renumbered.
: 23. Appendix C                                                                                    )
Appendix C presents tables of dose conversion factors used in the dose calculations. It would     !
be helpful if there was some cross-referencing between the parameter list of Table A.1 of l
Appendix A with the tables of values in Appendix C, to at least indicate the variable names       !
for the parameters given in the tables in Appendix C.
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: 24. Appendix D, References for Default Parameters                                                 l For most of_the parameters listed in Appendix D, references for the justification of the default Value'have not been provided. This is a serious omission, because the values chosen       l as dt: faults are very important to the results calculated using the DandD code. In some cases,   l it appears that Volume 1 (Kennedy and Strenge 1992) has been referenced, though the notation of "[1]" is inconsistent with the format of the reference list at the end of the Appendix.
In addition, it appears that some of the default values listed in Appendix D have been modified from those of Volume 1. As noted previously, on Page A.1 it was stated that such         !
changes were to be documented in this Appendix D. However, no such documentation has teen provided. For two values in Table D.5.1, the reader was referred to Appendix A for information on modification of the parameter values. However, no discussion of these parameter values was found in Appendix A. If default values have been changed from the values of Volume 1, such changes should be described.
It is recognized that additional work has occurred on parameter values, and that work will be continuing (NUREG/CR-5512, Volume 3). However, this current report (Volume 2) and the first report (Volume 1) will be used in the interim before Volume 3 is finalized. Thus, the justification for default parameter values is extremely important. Appendix D should either provide justification for each parameter value, or should provide a correct reference for the justification. If the parameter values are not justified, the calculation results are meaningless.
: 25. Appendix D, Parameter Names, Variable Names, and Parameter Units i
Appendix D lists the parameters used in the models implemented in the DandD code. It

seems,that the parameters listed should be consistent with the list in Table A.I. However, some parameters listed in Appendix D, including those of Table D-1, are not listed in Table A.1 (there may be more examples-we have not checked all).
In addition, the parameter descriptions sometimes differ between Table A.1 and the tables of      ;
Appcndix D.                                                                                        .
I And, the variable names provided in the tables of Appendix D are all shown without subscripts.
In Tables D-19 through D-22, the parame'ter variable names are not pravided.                      ;
In Tables D-21 and D-22, the units of the parameters are not provided.
: 26. Page E-23, Section E.6 This section of Appendix E discusses the history file. The history file appears to be the only place that a user can readily find dose results broken down by pathway and by radionuclide (the usual summaries provide either a pathway breakdown for all radionuclides or a radionuclide breakdown for all pathways). Sometimes, these additional details would be very helpful to the      ,
user of the DandD code. Thus, it would be quite helpful if Section E.6 provided a complete        l description of the history file format, enough that the meaning of each value in the history file !
can be determined. Currently, Section E.6 only provides a general description of the contents of each record (row) of the history file.                                                         ,
ADDITIONAL COMMENTS ABOUT DANDD CODE                                                              l
: 27. Meaning of Year Zero In reviewing Volume 2, a number of the provided test case sessions were opened and executed.
In viewing the graphical display of results, it appears that the calculated doses for year 0 may always be zero. The meaning of the year 0 doses has not been described in the User's Manual       ;
,     (or this reviewer missed such description). Since doses for year 0 are provided, one might assume that these are the annual doses immediately following cleanup and release of the site.
However, since the doses for year 0 seem to be zero doses, this interpretation appears incorrect.
If the doses for year 0 provide useful, meaningful results, their meaning should be described in the User's Manual. If the doses for year 0 are not meaningful (e.g., if the year 1 doses are the doses for the first year following site release), then perhaps the results for year 0 should be eliminated from the calculations and/or presented results.
: 28. Nonstandard " Buttons" The main session window of the graphical interface (see page 2.4 of the User's Manual) includes nonstandard usage of Windows check boxes. On the right side of the main session window are many check boxes. Some of these turn on scenarios that will be evaluated. These appear to be a reasonable use of check boxes. However, most of the check boxes open windows to modify parameters, execute the calculations, or generate reports. These latter usages are not standard.

Check, boxes are usually used to indicate options, which can be turned on (checked) or off
                    '(unchecked). Buttons or menus are usually used to open other windows or execute other parts of the' program. Using standard Windows conventions may make the software easier for new                j l-                   users to learn.                                                                                         I In addition, it is not clear why the buttons for executing scenarios and generating reports on the left side of the main session window are duplicated with check boxes on the right side of the window to perform the same functions.
EDITORIAL COMMENTS
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: 29. Table Numbering and Page Numbering                                                                  ;
I l                    It was noted that the table numbering system is not consistent throughout the document. For example, Table A.1 is a different style of numbering than Table D-1.
Also, the page numbering of Appendix E is inconsistent with the majority of the document.
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