ML20196B499
| ML20196B499 | |
| Person / Time | |
|---|---|
| Issue date: | 04/13/1999 |
| From: | Vietticook A NRC OFFICE OF THE SECRETARY (SECY) |
| To: | Vaughan R COALITION ON WEST VALLEY NUCLEAR WASTES |
| Shared Package | |
| ML20196B428 | List: |
| References | |
| REF-WM-3 NUDOCS 9906230207 | |
| Download: ML20196B499 (1) | |
Text
- E & '
p5 '%"
UNITED STATES f n NUCLEAR REGULATORY COMMISSION
{ j WASHINGTON, D.C. 20555-0001
\,
/ April 13, 1999
. SECRETARY Mr. Raymond C. Vaughan j Coalition on West Valley Nuclear )
Wastes Sharp Street s East Concord, NY 14055
Dear Mr. Vaughan:
This is to acknowledge receipt of your letter dated April 7,1999 to Chairman Shirley Ann Jackson concerning NYSERDA's comments on the Environmental Impact Statement.
A response is under preparation which will be forwarded to you shortly.
Sincerely, L, A_ ,m-Annette L. Vietti-Cook l
_S 9906230207 990618 PDR WASTE WM-3 PDR
r:g - , ,
e i
April 20, 1999 To: Steve Abt, Colorado State j Paul Bembia, NYSERDA '
Jon Boothroyd, URI Robert Fakundiny, NYSGS Lisa Hubbard, Corps of Engineers Carol Mongerson, CWVNW Jack Parrott, NRC Ray Pilon, Corps of Engineers Joe Price, SAIC Pat Primi, NYS Office of Atty. General Tim Rice, NYS DEC Rudy Slingerland, Penn State Dan Sullivan, DOE Garry Willgoose Mike Wilson, SUNY Fredonia Eric Wohlers, CTF Michael Woldenberg, SUNY Buffalo From: Ray Vaughan, CWVNW and CTF ^
Subject:
Comments on West Valley application of SIBERIA model and on sources needed for its evaluation
- 1) Sources needed for evaluation of this SIBERIA application l SAIC's Draft " Landscape Evolution Modeling of the Western New York Nuclear Service Center," Rev. 5, March 8, 1999, lists i i
only Parts 2 and 3 of the' Hydrology EID (Environmental Informa-tion Document) , WVDP-EIS-009.
I strongly recommend that reviewers of the SIBERIA erosion model look at Part 1 as well:
l West Valley Nuclear Services, Inc., Environmental Informa-tion Document, Volume III, Hydrology, Part 1: Geomorphology of Stream Valleys, WVDP-EIS-009, West Valley Nuclear Serv-ices, Inc., West Valley, New York, January 1993.
Those from the Corps of Engineers may have already requested this Part 1 volume (I talked to Ray Pilon about its importance in a phone. conversation on April _14) and others should likewise re-quest it.
The' Geology EIDlis very useful for understanding the com-plexly layered soils that underlie the site:
West Valley Nuclear Services, Inc., Environmental Informa-tion Document, Volume I,' Geology, WVDP-EIS-004, West Valley h j
. , 4
?
?
Nuclear Services, Inc., West Valley, New York, March-April .
1993.
The following sources are less relevant to the specific West j
Valley application but may be useful for general background information on this type of modeling:
Ignacio Rodriguez-Iturbe and Andrea Rinaldo Fractal River Basins: Chance and Self-Orcanization Cambridge University Press, 1997 Rudy Slingerland, John W. Harbaugh, and Kevin P. Furlong
' Simulatina Clastic Sedimentary Basins: Physical Fundamentals and Computer Procrams for Creatino Dynamic Systems PTR Prentice Hall, 1994 l
Naomi Oreskes, Kristin Shrader-Frechette, and Kenneth Belitz
" Verification, Validation, and Confirmation of Numerical Models in the Earth Sciences," Science 263, 641-646 (Feb. 4, 1994)
- 2) Calibration of model acainst known downcutting Page 13 of SAIC's Draft " Landscape Evolution Modeling of the Western New York Nuclear Service Center," Rev. 5, March 8, 1999, compares West Valley erosion rates predicted by SIBERIA to those
" predicted" by other studies. One of these other studies is not t strictly a prediction but an extrapolation from a direct measure-ment of downcutting along Franks Creek over the ten-year period frem 1980 to 1990. Based on this comparison, it appears that the S18tRIA model is currently miscalibrated by about a factor of 6.
Page 13 of SAIC's Draft describes the approximate erosion rates predicted by the SIBERIA model: 30 ft per 1000 yr in lower Franks and Quarry Creeks, and 12 ft per 1000 yr in upper Franks Creek and Erdman Brook. One of the comparisons made is to
" longitudinal studies."
The " longitudinal studies" appear to be the direct measure-ments (by surveying) of the longitudinal profile of Franks Creek.
See the Hydrology EID, Part 1, esp. pp. 1-4 and 23-24 and Figure 3-1. (Note that this Figure 3-1 is also reproduced in Part 3 of the Hydrology EID as Figure 5-3.) The results are summarized as follows in Part 1 of the Hydrology EID, page 23: " Initial re-sults from the 1989/1990 profiling indicate that Frank's Creek has downcut about 0.61 meters (2 ft) over the past ten years from the Quarry Creek confluence to the F48 knickpoint complex.
Upstream of this knickpoint, in the floodplain area, downcutting has been minimal (less than .5 ft) over the past ten years."
The observed rate of 2 ft per 10 yr can be extrapolated to 200 ft per 1000 yr, essentially equal to the "199 ft per 1,000 years" cited in SAIC's Draft, p. 13, and roughly 6 times greater than the 30 ft per 1000 yr predicted by the SIBERIA model. Based 2
ov. .
.s '
on this. discrepancy, I conclude that the SIBERIA model is seri-ously miscalibrated (by about a factor of 6).
Many questions can be raised about extrapolation from 10 ;
years to 1000 years,-about urbanization of the watershed, about the balance between erosion and deposition, etc. These are indeed valid questions. I invite discussion but in the meantime 1 think that the observed downcuttina rate of 2 it per 10 years in lower Franks Creek is the b_est currently available benchmark acainst which the model can he calibrated. In part, it is best l because it effectively intecrates erosion over 10 years. Ten {
years is much less than 1000 years but is far more representative i than discrete measurements of water flow and sediment loading. l I
1 would add a) that the opportunity exists to re-survey the Franks Creek profile to see what has happened during the past 9 years; b) that long-term net deposition in apper Franks Creek is unlikely given the predominantly bedrock watershed upstream and the active downcutting (steepening) in lower Franks Creek; and c) that any idea that reforestation would solve the " urbanization" problem is oversimplified, given the need to keep deep-rooted plants out of waste disposal areas and given the role that trees can play in slumping processes.
- 3) Calibration of model against landform evolution in Buttermilk Creek slump area Boothroyd and others placed a surveyed grid of stakes on the d Buttermilk Creek slump area. If their surveyed grid was tied to d permanent monuments, then the opportunity exists to re-survey the slump area to determine the backcutting rate of this section of the ravine wall over a period of about 20 years. This may pro-vide an' alternative way to check the calibration of the SIBERIA model.
- 4) Omission of ceak flows in current model application i Previous work by the West Valley Demonstration Project looked at 2-year, 10-year, 100-year, and PMP storms: See Hydrol- !
ogy EID, Part 3, pp. 41-44 and 150-151 (Tables 3-4 and 3-5).
This information shows that PMP flow rates and sediment loads are up to 10 times higher than the flow rates and sediment loads associated with a 100-year storm.
The current SIBERIA modeling work, as described in SAIC's Draft, pp. 7-9, ignores PMP events and thus loses the high-flow end.of the. spectrum. This may seriously distort the calibration.
- 5) Role of bed load in sediment transport During the April 15 site walkover, I said that I had seen 3
. . 4 i
many cobble-sized clasts of clay or till in the bed of the tribu-tary stream that enters Buttermilk Creek from the east opposite the slump area on Buttermilk.
The occasion on which I had seen these cobble-sized clasts of clay or till in the bed of the tributary stream was a prior walkover on July 15, 1998. This was a few weeks after the in-tense local storm of June 26, 1998, and I assumed on July 15 that the clasts I saw had washed down during the storm. I regret that I took no samples or photographs and that the clasts are now gone (presumably broken up and/or dispersed downstream).
A likely source for such clasts would be a slump area that can be seen along this tributary stream. Primatic jointing and irregular desiccation cracks in the slumping till may have al-loved cobble-sized pieces to be pried loose by the torrential flow of June 26, 1998, and carried along as bed load. I believe I saw evidence of the deposited bed load on July 15, 1998, but recognize that more tangible evidence is lacking at this point.
Thus, it is my opinion that high flow rates can and will carry a bed load of sediment (cobble-sized rip-up clasts) which has not been recognized in the model's betal value. Slumps may be needed as the source areas for such clasts. If so, there are many slumps throughout the modeled area. See the Hydrology EID, Part 1, Plate 3, and a smaller but similar map in the 1996 Draft 4 EIS, Vol. II, page L-6 (Figure L-1).
1
- 6) Lack of distinction amonc different soil tvoes in current model application .
As currently cet up, the model has an adjustable parameter to distinguish between the different erodibilities of bedrock and soil. A similarly adjustable parameter is needed to distinguish between the different types of soil or unconsolidated material (sand, till, etc.) which are found on the site and which exhibit substantial differences in erodibility.
- 7) Rectilinear bias of model Models of this type tend to have a rectilinear bias imposed by their rectangular coordinate grid. The SIBERIA model should be re-run with the coordinate grid rotated 45 to see how this would affect results. (A rotation of 45 would, incidentally, j provide a better match to the preferred orientation of jointing !
inferred by Fakundiny et al.)
Another potential concern about the orientation and spacing of the coordinate grid is suggested by a discussion in the Hy-drology EID, Part 2, p. 17, where certain recommendations are made with respect to the Corps' HEC-2 model and its ability to "have a sense of stream meander and conveyance."
4
f p on .
I Ii b
l
- 8) Potential for stream capture The question of whether or when Franks Creek will find a
, shorter, steeper path to Buttermilk Creek (most likely in the 1 l vicinity of the Buttermilk Creek slump area) is very important in l any assessment of long-term site integrity. Part of the question involves the relatively erodible layers (the well-known Kent Recessional and the poorly delineated " Lacustrine or overbank i deposits" shown in the Geology EID, cross-sections D-D' and E-E', I Figures 4-6 and 4-8) that exist in or behind the slope now being I affected by the Buttermilk Creek slump area. More work needs to
! be done to characterize the layered units in this slope and to !
l ensure that the model treats them in a realistic manner. l l
- 9) Likelihood that the entire Cattaraucus Creek watershed will continue to downcut and evolve l
The current application of the SIBERIA model does not look beyond the Buttermilk Creek watershed into the larger Cattaraugus Creek basin. A detailed look at the evolution of Cattaraugus l Creek is not warranted in this modeling effort, but, at the same time, it should not be assumed that Cattaraugus Creek near Springville has reached a stable base level or profile. Possible removal of the Springville Dam knickpoint is one consideration.
Other important considerations are the overall gradient and I l I profile of the creek and the bed material into which the creek is downcutting.
The overall gradient of Cattaraugus Creek from Springville d to Lake Erie is fairly steep (about 530 feet in 40 miles). I have requested but not yet received a profile of the creek from the Corps. It is my understanding that the profile is convex upward between Springville and Gowanda (i.e., steeper in the downstream reach from Zoar Bridge to Gowanda than in the upstream reach from Springville to Zoar Bridge). The bed material is variously glacial fill and bedrock (interbedded shales and thin siltstones) of the Canadaway Formation. The bedrock exhibits many joints and shows some effects of an old shallow thrust fault (Bass Island Trend) that passes through the watershed between Springville and Gowanda. In general, it seems safe to say that
-Cattaraugus Creek is not a mature stream; it will continue to downcut for several millennia.
The ongoing evolution of cattaraugus Creek implies a gradual steepening of the modeled watershed. In other words, if the West Valley site facilities on the North and South Plateaus remain at constant elevation while downstream channels continue to downcut, the modeled topography will become progressively steeper and water velocities will increase accordingly. The SIBERIA model presumably takes this trend into account.
5 L
. .6, I l
4 l
- 10) Inability of the model to conserve flow at closed depression 1 1
SAIC's Draft, p. 3,-states that " Accumulation of water is not modeled and the water balance'is not maintained at closed j j
depressions." The following sentence asserts that the West Valley study area does not have closed depressions. On the j contrary, there are several shallow closed depressions (wetlands) in critical areas of the site. SAIC's Draft, p. 5 (Figure 2),
shows a " Low Wet Area" along upper Franks Creek, and.we saw a number of wetland-delineation markers on our April 15 walkover.
See also the 1996 Draft EIS, Vol. II, Appendix P.
It is important.that the model be able to handle closed depressions of the type found on the site.
t I
f i
6
-__-____-_--__________-_______-__-___-__-__-_____J
I,a-
.C p arat,,9 g 4 UNITED STATES g
j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055W1 4
9 * * * * * ,o April 20, 1999 Mr. Raymond C. Vaughan Coalition on West Valley Nuclear Wastes 4 10734 Sharp Stroet East Concord, New York 14055 {
l l
Dear Mr. Vaughan:
I am responding to your memorandum to the Chairman, dated March 29,1999, l I'
transmitting the comments of the Coalition on West Valley Nuclear Wastes on the U.S. Nuclear Regulatory Commission staff's supplemental Commission Paper (SECY-99-057) on decommissioning criteria for the West Valley site. The NRC staff response to some of your comments is enclosed. We willinform you of the Commission's decision on SECY-99-057 in the near future.
Sincerely, A
Carl aperiello, Director Office of Nuclear Material Safety .
and Safeguards l
Enclosure:
As stated l cc: T. Attridge, NYSERDA (for the CTF)
3 q R'
r- 3
- c. yl
, i
<1 NRC STAFF RESPONSES TO ,
i COMMENTS FROM THE COALITION ON WEST VALLEY NUCLEAR WASTES Below are responses from the U.S. Nuclear Regulatory Commission (NRC) staff on the comments numbered 7 through 17 in the Coalition on West Valley Nuclear Wastes memorandum letter to the Chairman dated March 29,1999. The staff plans to consider the remaining comments in the context of the Commission's decision on SECY-99-057.
7, Section 2(a)(4) of the West Valley Demonstration Project (WVDP) Act addresses.a U.S.
Department of Energy (DOE) responsibility under the WVDP. DOE must decide how the l low-level and transuranic waste produced by the solidification of the high-level waste l under the project is to be disposed, and that decision will determine what licensing i requirements are applicable. The Act does not require NRC to prescribe licensing requirements for waste disposal, but this issue is addressed in both SECY-98-251 and SECY-99-057,
- 8. Even though Section 2(a)(5)(C) of the WVDP Act says "...in accordance with such requirements as the Commission may prescribe," the NRC staffs view is that NRC should prescribe the D&D criteria for the WVDP project.
- 9. As stated on page 5 of SECY-98-251 and in Section 4 of SECY-99-057, the NRC staff's proposed criteria for onsite disposal of wastes generated by the WVDP are the performance objectives of 10 CFR Part 61.
- 10. Section 20.2002 applies to licensees and is a licensing requirement.
- 11. See answer 9 above.
12.,13.,14.,15. Although the NRC is not authorized to determine whether or when DOE has completed decontamination and decommissioning for the WVDP, the NRC staff agrees that NRC should prescribe appropriate decommissioning criteria for the WVDP, and that DOE's implementation of the criteria will affect other parties including the licensee under the reinstated license.
- 16. The scope of the NRC staff proposed decommissioning criteria for the site is described in both SECY-98-251 and SECY-99-057.
- 17. The NRC staff agrees that reinstatement of the NRC license at West Valley should follow all applicable procedures, and that the decommissioning requirements for DOE, under the WVDP Act, should be compatible with the anticipated reinstatement of the license.
Enclosure