ML20247D066

Repts on 890425-26 Visit to Pacific Northwest Lab to Discuss Progress Under FIN B-2485.Meeting Agenda & Summary Meeting Notes Included in Encls 1 & 2

ML20247D066
Person / Time
Issue date:	05/18/1989
From:	Deering L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Starmer J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
CON-FIN-B-2485, REF-WM-3 NUDOCS 8905250146
Download: ML20247D066 (18)

Text

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MEMORANDUM FOR: John Starmer, Section Leader Technical Branch Division of-Low-Level Waste Management.

and Decommissioning, NMSS FROM: ?ynn Deering Technical Branch

. Division of Low-Level Waste Management and Decommissioning, NMSS

SUBJECT:

' REPORT ON VISIT TO PACIFIC NORTHWEST LABORATORY

.(PNL)'ON APRIL 25-26, 1989 on' April 25 and' '2 6, 1989, I met with Marcel Bergeron and other members of PNL staff in Richland, Washington to discuss progress under project FIN B2485. My primary objective of the trip was to provide technical. . direction to PNL in their effort to finalize draft products.

Copies of the meeting agenda and summary meeting notes are included in Enclosures 1 and 2, respectively. In addition, copies of the:

NRC comments on the Sheffield Geoscience Report, the Sheffield Performance . Assessment Report, and the West Valley Geoscience Report are included in. Enclosures 3, 4, and 5, respectively.

If you would like to diucuss any aspect of my trip to PNL, please let me know.

Ori 61nal Signed By Lynn Deering Technical Branch Division of Low-Level Waste Management and Decommissioning, NMSS-

Enclosures:

As stated b

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DATE:,,f/ } 89  : / /89  : / /89  : / /89 OFFICIAL RECORD COPY l

- . . ~ Cnele30s li AGENDA FOR APRIL'25-26, 1989 MEETING TO DISCUSS PROJECT FIN fB2485 Place: PNL, Richland,.WA

Participants:

M. Bergeron, PNL

-T. Cadd, PNL M. Kenner, PNL J. Smoot, PNL D. Holford, PNL L. Deering, NRC Tuesday, April 25 9:00- 11:00 am Discussion of NRC comments on the Draft Sheffield Geoscience Report 11:00-12:00 pm Discussion of NRC comments on the Draft Sheffield Performance Assessment Report 12:00-1:00 pm Lunch 1:00-3:00 pm Continue discussion of Draft Sheffield Performance Assessment Report 3:00-5:00 pm Discussion of NRC comments on Draft West Valley Geoscience Report, and development of West Valley Performance Assessment Report Nednesday, April 26 9:00-11:00 am Discussion of Hardware and Software Needs 11:00- 12:00 pm Demonstration of PCTRANSS 12:00-1:00 pm Lunch 1:00-2:00 pm Discussion of transfer of codes to NRC computers 2:00-3:00 pm Discussion of West Valley and Sheffield Databases 3:00-4:30 pm Discussion of . revised schedules and other administrative details a_. _____m__._ _.__m______ _ _ _ - _ . . _ _ _ _ _ _ _ _ _ _ _ _ . _

Endosx L .

SUMMARY

MEETING NOTES FOR MEETING ON APRIL 25 AND 26, 1989, AT PACIFIC NORTHWEST LABORATORIES (PNL) , RICHLAND, WASHINGTON On April 25-2G, 1989, Lynn Deering met with Marcel Bergeron at PNL in Richland, Washington to discuss work under project FIN B2485, Hydrogeologic Performance Assessment for LLW sites. A copy of the meeting agenda is included in Enclosure 1. The meeting was a follow-up meeting to the April 4-5, 1989 meeting held by L. Deering on M. Bergeron at NRC Headquarters in Rockville, Maryland. The primary objective of the April 25-26 meeting was for L. Deering and M. Bergeron to discuss final NRC review comments on the following PNL draft reports: Sheffield Geoscience Report, Sheffield Performance Assessment Report, and West Valley Geoscience Report.

Secondary objectives of the meeting included: discussion of development of West Valley Performance Assessment Report, status of transfer of codes to NRC, and code training, deliverable schedules, short-term technical assistance tasks, hardware and software needs, and administrative details of the project. The meeting is summarized below.

TUESDAY Administrative Details L. Deering and M. Bergeron began the meeting by discussion of funding remaining for the project. L. Deering informed M.

Bergeron tnat she is requesting obligation of an additional 50K for FY89 for the project; 20K of which will be for PNL to review the BGV PLASAR as a subtask under Task 8. The details of this short-term assignment will be provided later. M. Bergeron indicated that 30K is the approximate existing balance for the project. Marcel indicated that he felt that PNL could complete the work required in the SOW with the additional 30K to be obligated.

Sheffield Geoscience Report L. Deering provided M. Bergeron with a mark-up copy of the Sheffield report, along with written comments, which are included in Enclosure 2. L. Deering also provided a copy of the 1983 DOE report entitled, " Commercial Low-Level Radioactive Waste Sites:

No Longer Operating."

M. Bergeron indicated that overall he had no problems with the NRC comments, and felt that the author, Ellen Murphy, could probably address them in roughly one week's time. Ellen Murphy j was unable to attend the meeting due to other commitments. M.

Bergeron's response to significant comments is written on the enclosed copy of the NRC comments. L. Deering and M. Bergeron agreed to change the title of the report to," A Review of the  !

l

Geoscience Characteristics and Disposal Experience of ....,

They also agreed to eliminate the - Appendixes of the report because this information is available in the Sheffield Database.

-PNL will provide the Annotated Bibliographies included in the draft report to L. Deering separately. A revised deliverable schedule for this and other reports was agreed upon, and is summarized in Table 1 at the end of this report.

Sheffield Performance Assessment Report L. .Deering ~provided written comments to M. Bergeron and D.

Holford'on Chapters 4 and 5 of the Sheffield Report, and verbally presented discussion comments. Based on M. Bergeron and D.

Holford's response to the discussion comments, L. - Deering will prepare a final ~ set of NRC. review comments on the Sheffield report, and will provide PNL with a mark-up copy of the report.

L. Deering will send the final comments and mark-up to PNL no later than Friday,. May 5, 1989. Where significant, PNL's response to NRC comments is written in hand on the enclosed copy of NRC comments, included in Enclosure 3. See Table 1 for a revised deliverable schedule.

West Valley Geoscience Report L. Deering provided final NRC review comments and a mark-up copy of the report to M. Bergeron and J. Smoot. A copy cf these comments lip included in Enclosure 4, with PNL's response to these.

comments written in hand, where significant. A revised deliverable schedule is shown in Table 1. L. Deering also provided a copy of the DOE 1983 report to J. Smoot.

As with the Sheffield Geoscience Report, it was agreed to change the title of the West Valley Report to "A Review of the Geoscience Characteristics and Disposal Experience......," and to omit the appendixes. The Annotated Bibliography will be provided to L. Deering separately.

Database Reports M. Bergeron indicated that T. Cadd was working on developing a data entry / modification routine for the West valley and Sheffield Databases. He indicated that this routine should be provided separately from the databases, to prevent possible inadvertent damage to the databases. He also indicated that L. Deering.could talk with T. Cadd about the databases on Wednesday, April 26.

Codes / Training M. Bergeron indicated that M. Kemner had modified the TRANSS code to run on a PC, and to include a preprocessor. In addition, M.

Bergeron indicated that there are two versions of CFEST that NRC may be interested in: The VAX version, which needs to be

run on an IBM mainframe, and a propriety version, which could be installed to run on the INEL CRAY. Because of previous difficulty in trying to get the CFEST VAX version to run on an IBM machine at the EPA, M. Bergeron and L. Deering felt that the proprietary version would be the most suitable. M. Bergeron also indicated that the proprietary version of CFEST can run on a SUN system, and if available at NRC, would be the best option to go with during the training session. L. Deering agreed, and indicated that she would look into the availability of using a SUN for training of the code, which is to take place sometime after July,.1989.

West Valley Performance Assessment Report M. Bergeron and J. Smoot indicated that they were considering how to model the shallow pathway at West Valley. Based on a brief discussion, they indicated that they could approach the problem by making simplistic assumptions about post closure conditions, and the fraction of radionuclides available for release through the shallow pathway. L. Deering felt this was a good approach.

She indicated to J. Smoot that she will inquire about getting him to the West Valley site.

WEDNESDAY Hardware and Software M. Bergeron and L. Deering discussed the following hardware and software needs:

Graphics Software- M. Bergeron demonstrated Surfer and Grapher capabilities on his workstation. He recommended purchasing these graphics packages for inclusion into the work station. L.

Deering agreed, and authorized M. Bergeron to purchase the packages. Because these packages are not copy protected, it was decided to purchase only a single copy, and share the documentation between the two work stations.

Geostatistical Software- M. Bergeron recommended a shareware package developed for EPA called Geoease. He provided L. Deering with a copy of the software and documentation for her to try.

The software is cost free to the NRC.

Statistical software- M. Bergeron and L. Deering reviewed the available literature for three packages: Statgraphics, CSS, and Minitab. Statgraphics was eliminated from contention because it was more expensive than the others, and did not appear superior to the others. L. Deering and M. Bergeron agreed to defer the decision until M. Bergeron obtained demo disks and more information about both Minitab and CSS. M. Bergeron will contact L. Deering after he has obtained the additional information.

4 Digitizer Pad- L. Deering indicated to M. Bergeron that, because purchase of a digitizer was not explicitly stated in the original agreement, a digitizer should be purchased only if sufficient funding is available. M. Bergeron and L. Deering agreed to defer the decision to buy a digitizer until a later date. L. Deering agreed. M. Bergeron indicated that he would obtain a price listing for Calcomp's digitizer pads to compare with the Kurta prices. M. Bergeron and L. Deering also agreed to find out more about the capabilities of DIGITIZE, the software package, too determine if it is suitable for NRC's needs.

Transs- M. Kemner demonstrated the PC version of TRANSS, using sample input deck. He provided a copy of the code to L. Deering.

He indicated that the existing version has several problems; the barrier option currently does not work, and the code will not except E notion. However, he is working on these minor problems and will provide an updated version of the code in the near future.

OS2 (Operating System)- Based on M. Bergeron;s description of OS2, L. Deering indicated to M. Bergeron that she would be interested in purchasing a copy of OS2 for the work stations to replace the dos operating system, if funds are available. OS2 is able to access more available memory than DOS, thus allowing for access of more than one program at a time, such as LOTUS and DBASE III. This would facilitate use of the databases.

Databases L. Deering and M. Bergeron spoke with T. Cadd, database developer, about the status of the databases. He indicated that if the database structure needs to be augmented or modified in the future, this would need to be done by an experienced database user. However, he indicated that he would prepare documentation on how the databases were developed, so that an experienced NRC DBASE user could later modify the databases.

NRC ACTION ITEMS

1. L. Deering to send final NRC review comments and mark-up of report to M. Bergeron no later than May 5, 1989.

2. L. Deering to include in her response to the March Monthly report a copy of the summary meeting notes for the April 4-5 and April 25-26 meetings. g

3. L. Deering to contact D. Updegraph of SNL concerning PNL's involvement in SNL code recomi.odation task.

4. L. Deering to inquire about J. Smoot visiting the West Valley site.

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1 Table 1

. REPORT / ACTIVITY DUE DATE'.(FY89)

- 2ND DRAFT NRC REVIEW FINAL Sheffield.Geoscience 5/31 6/12 7 /.10 .

Sheffield P.-A. 6/30 7/14 8/18 W.. Valley Geoscience ---- ----

6/30 W. Valley P. A.- 5/31 7/15 9/1.

W. Valley Database ---- ----

6/16.

Sheffield Database' ---- --- -

5/19 Source Term Letter R. ---- ----

TBD Codes Transmitted ---- ----

7/15.

Code Training ---- ----

TBD Beatty Geoscience ---- ----

TBD 1ST DRAFT FINAL PLASAR REVIEW 6/30 8/30

• OTHER POSSIBLE REPORTS UNDER TASK 8 Modeling insights report Peer review and input of SNL Methodology l

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NRC COMMENTS ON THE REPORT ENTITLED, "A REVIEW OF ENVIRONMENTAL CONDITIONS AND PERFORMANCE OF THE COMMERCIAL LOW-LEVEL RADIOACTIVE WASTE DISPOSAL FACILITY NEAR SHEFFIELD, ILLINOIS"

1. General The Sheffield report needs to be carefully edited; it contains numerous spelling errors, inconsistencies, and redundancies throughout the text. The inconsistencies include frequent referral to figures and tables that are not as they are described in the text, use of both metric and english units, and both symbols and words for radiological constituents. Many of the spelling errors and redundancies are marked in the margin of the text. PNL should edit the report to correct spelling errors and other inconsistencies appearing in the text and figures.

2. General The report contains many unreferenced figures and tables, as well as unreferenced statements. PNL should revise the text and figures of the report to properly reference assertions, figures and texts.

3. Section 2.4.2, p. 2.15 The report indicates that, prior to the unsaturated investigations, recharge estimated by Foster et. al. (1984) was between 1 and 2 inches per year. However, the report does not indicate whether this estimate is still appropriate based on more current information. PNL should revise the report to indicate what is the more accurate estimate of recharge. 700 t.oltl [afed d +hy f b 7d ', '

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4. Section 2.0, Figures The report does not provide a figure showing the layout of the trenches, and how they are numbered. This type of figure should be included before the cross-sections in figures 2.15 and 2.16, because it is not evident where the trenches actually are in these two figures. pg w,ff %, wy7 7, ,

5. Section 2.0, Figures The report does not include a figure showing a map view of the location of the tunnel, and the locations and numbers of tensiometer and lysimeters. THe report should be revised to include such a map. gyp g,uat 4 3 C cp / -M;, .

6. Figures 2.15 and 2.16 Figure 2.15, and 2.16 should be revised to show vertical scale, and the numbers of the tensiometer.

7. Figure 2.20

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-Figure 2.20 should be revised to indicate Whether the ~ numbered

.' wells shown include tensiometer or lysimeters in addition to

. wells.

8. Section 3.1, p.'3.1 The text indicates that the Sheffield site was' closed in April, 1978; however, Table 3.1 indicates that the site was closed in March 1979. The report should be revised to resolve this apparent

discrepancy.

9. Section 3.1, p.3.2 The report provides an historical account of the events leading up to facility closure, but does not include information on the physical problems that resulted in the- site being closed:

degradation of trench caps and subsequent discovery of tritium migration from trench 11.- This information can be found in the report prepared by the National Low-Level Radioactive Waste Management Program, 1982, entitled, " Low-Level Radioactive Waste Disposal: Commercial Facilities No Longer Operating."

10. Section 4.0, p. 4.1 The introduction of Section 4.0 indicates that three major problems have.resulted from physical waste disposal: subsidence, erosion, and contaminant migration. However, the report discusses a forth area, Waste Leachage characteristics, which is inconsistent..with the three problems identified in the introduction.

NRC staff recommend that PNL revise the introduction of the report

'to read, "In the disposal history of Sheffield, physical problems have resulted from waste disposal, including erosion, subsidence, and contaminant transport. The following discussion focuses on erosion, trench cap subsidence, trench leachate composition, leachate characteristics, and subsequent migration."

11. Section 4.4.1, p. 4.11 The report indicates that ~ Mills and Healy (1987) calculated a tritium flux through the tunnel area sediments by assuming a recharge value of 118 mm/yr; however, the report indicates in Section 2 that annual recharge is approximately 232 mm/yr. PNL should revise the report to either resolve or explain this discrepancy in annual infiltration.

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12. Section 4.4, p. 4.11-4.18, The report discuses vapor phase transport of contaminants through the unsaturated zone, and organic and inorganic contaminant

! transport of contaminants through the saturated zone. However, the report does not conclude whether or not there is significant migration of organic and inorganic constituents in groundwater, or N___- - _ _ _ _ _ - _ _ _ - _ - _ _ - _ -_-

whether contaminant migration in the vapor / gas phase is a significant problem at the Sheffield site. In addition, the report does not indicate whether any radionuclides other than tritium have been detected in groundwater.

PNL should revise the report to include more conclusive information on transport of radiological and nonradiological contaminants through the saturated and unsaturated zones. Concerning conclusions on transport of organic constituents, PNL should include information from Goode (1986). Goode (1986) concludes that overall, there is significant organic chemical contamination-of groundwater at Sheffield, and that organic chemical concentrations of TOC and 1,1,1 trichlorethane are positively correlated with triticum measurements.

13. Section 5.0, p. 5.1 NRC staff recommend that PNL remove Section 5.0 from the report.

Section 5.1 could be merged with Section 2.3.3, and Sections 5.3 and 5.4 merged with Section 4.3. In addition, Section 5.2, Sorption, and Section 5.5, Radionuclides Decay, should be removed from the report because much of this information is not specific or unique to the geoscience characteristics of the Sheffield site.

An exception to this is the site-specific Kd values for Sheffield soil measured by PNL, which should be kept in the report and merged into Section 2.0. NRC staff would like to discuss this with PNL.

14. Section 7.0, p.7.1 The report indicates that data gaps fall into three major categories; however, the reports actually address four categories of data uncertainties. THe report should be revised to resolve this discrepancy.

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NRC DRAFT ' COMMENTS J ON ' CHAPTERS 4 AND 5 OF THE DRAFT ' REPORT ENTITLED, " PERFORMANCE LASSESSMENT ANALYSIS OF THE LOW-LEVEL RADIOACTIVE WASTE DISPOSAL FACILITY NEAR SHEFFIELD, ILLINOIS" 1.

Title:

'The. title of the report should be revised to read, "Hydrogeologic Performance Assessment ........"

c 2. General A

" The report ' frequently cites incorrectly the tables and figures appearing throughout the text. PNL should carefully edit the draft

. report to resolve these inconsistencies.

3.. Section 4.1, p. 16 The report _ quotes performance objective 10 CFR Part 61.41, but does not reference 10 CFR Part 61.41. The report should be revised to properly cite 10 CFR Part 61.41.

4. Section 4.2.2.1,.p 18 The report discusses _Garklavs and Healy's modeling of Sheffield, but does_not indicate what groundwater flow code they'used. The-report should be revised to indicate what code was used.

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5. Section 4.2.2.2, p., 20 M A9 -

The' report' describes the six zones that Garklavs and Healy used in

'the.ir modeling, but does not provide the hydraulic conductivities assumed for each zone. PNL should expand the report to include hydraulic conductivity values assum

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6. Section 4.2.2.2, p. 21 The report indicates that the water levels computed by the model compared fairly good to water levels measured in June, 1982; however, no figure is provided showing this relationship. PNL should revise the report to include such a figure.

f p L ta.u. ti w ie. M tL M VGJ.t1 ot PLN.C. N h*' O W" Section 4.2.3.4, p. 29 **'I # '

7.

The report indicates that if the lake level was assumed to be .

higher in the three dimensional modeling, calibration of observed I head values might have more difficult than it was. The report does not go on to explain why the calibration would be more difficult.

The report should be expanded to explain why this is so.

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. 8. Section 4.3.1.5, p. 34 The references cited in the text, Martin, (1988) and Serne, et.

al., (1987), aren't included in the reference section of the text.

The report should be revised to include the references.

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[p 9 Tables 4.6 and 4.7, p. 116-117 v F k The half-lives are reported incorrectly for many radionuclides in tables 4.6 and 4.7, and the diffusion coefficients reported in."

N Table 4.7 may be too low, based on literature values. These tables!

should be revised to reflect accurate information, and'should be, referenced. If PNL determine that the diffusion coefficient values should be changed, then it should perform additional calculations using the revised values to determine if radionuclides other than tritium could diffuse through a cement waste form in significant activity. Finally, Table 4.7 should also list the original /

activity values for the radionuclides listed.

10 Section 4.3.1.2, 4.3.1.3, p. 30-31, Section 4.3.3.2, p. 40, and'Section 4.3.3.3, p. 41 The report appears to refer to the term " waste stream" in place of waste container or waste form. Interchanging these words is confusing to the reader. PNL should revise the report to refer

• • 1. 1. • • Y 3- * * '.uhek 3 LWir 7'*H N M W ' L 11 Section 4.3.3.3, p. 41 The report provides the values assumed for infiltration and moisture content, but does not provide explanation or justification for the values assumed. The report should be revised to jusitify use of these values.

12 Section 4.3.3.3, p. 41 The report describes the assumptions for cases 1 through 4; however, it does not indicate which of these cases, if any, assumes transport through the unsaturated zone. The report should be revised to indicate whether credit was taken for transport through the unsaturated zone in any of the cases. .rv.

CfL W VA5 HoY"Thiid f WJ f cYMi b/l' !$ C w isin 13 Section 4.3.4.1, p. 43 Mc M N The report specifies that no credit was taken for controls other than those controls that were strictly known. However, the report does not specific what these controls were, e.g. , distance to lake, initial inventory, etc. The report should be revised to specify what the known controls were.

_. wus gecA P Y 14 Section 4.3.4.1, p. 43, and 45 The maximum predicted concentrations of tritium and carbon-14 for case 2 are higher than the maximum predicted concentrations for case 1, even though case 1 is alledegly more conservative than case

1. PNL should revise the report to explain why the predicted concentrations for these radionuclides are higher for case 2 than -

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15. Section 4.3.4.1, p. 46 ' mao g g(D

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The report specifies that a solubility limit of 7.0 E-11 ci/ml was F( 9 assumed for modeling the release of Carbon-14 at the Hanford site. ; pI this value being the maximum measured trench concentration of,,,l#

Carbon-14 in trench water at the West Valley LLW site. PNL alsof assumed this value in performing release modeling of Carbon-14 for P ',.

Sheffield. However, the text on p. 36 reports a solubility limit r d ;

• for Carbon-14 for soils similar to Sheffield soils of 1.0 E-4 M, g k or converted to a concentration, 5.35 E-6 ci/ml. PNL should run TRANSS assuming the higher solubility value reported on p. 36 to h r.

predict carbon-14 concentrations in groundwater assuming solubility y $ g' controlled release.

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16. Section 4.3.4.1, p. 48 The report implies that 4 mrem was used as a threshold limit below which radionuclides could be ignored in their analysis. The report, however, does not indicate why 4 mrem is used as a regulatory dose limit, and furthermore, what assumptions were made to convert concentrations to dose limits. The report should be revised to explain why 4 mrem is used as a threshold limit, and discuss the assumptions involved to convert the concentrations to dose. _g-

17. Section 4.3.4.1, p. 52 The report is not clear as to whether solubility controlled release was assumed for the radionuclides examined. The text indicates on

p. 40 that solubility controls could not be justified because information on chemical form of the radionuclides was generally not available, and on p. 52 and 37 the report implies that solubility controlled release was assumed for Carbon-14. The report should be revised to clearly specify for which radionulcides solubility controlled release was assumed, and why.

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NRC COMMENTS ON THE REPORTJ ENTITLED," REVIEW OF THE ENVIRONMENTAL CONDITIONS AND PERFORMANCE OF THE COMMERCIAL LOW-LEVEL RADIOACTIVE WASTE DISPOSAL FACILITY NEAR WEST VALLEY, NEW YORK" i

1. General Many of the figures presented in the report'are not numbered as-indicated in the text of the report and the List of Tables. 'The report should be revised to include figures that are consistent with the text and List of Tables.

2. Section 2, p. 2.1 The' report does not describe the Commercial LLW site as being part of a larger entity, the Western New York Nuclear Services Center (WNYNSC). The report should be revised to include a discussion of the Nuclear Services Center as a whole, making mention of the now defunct spent fuel reprocessing plant, both the Facility Disposal Area (FDA) for reprocessing wastes, and the State licensed Disposal area (SDA), and the West Valley Demonstration (WVDP) Act. A good overview of this information is provided in Nicholson and Hurt (1985). The. report should also summarize the current status of the WNYNSC, such'as the joint effort between DOE and the State to prepare.an EIS, which has caused DOE to delay disposal of project LLW generated from the on-site solidification of high level liquid wastes.

3. Section 2.3.2, p. 2.3 The report currently provides no information on the thicknesses and geometries of the stratigraphic units, .particularly in relationship to the trenches. For example, the Lacustrine unit is approximately 23 meters below the trench floor (Nicholson and Hurt, 1985). This information is important to describe a conceptual model of groundwater pathways for radionuclida migration, . The report should be expanded to include this information, which can be found the Nicholson and Hurt'(1985) on p. 19-20.

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4. Section 2.4.1, p. 2.5 The report provides a sentence indicating that Boothroyd et al.

(1979, 1982) have investigated the potential for erosion resulting

.from stream processes and landslides, but provides no further information. The report should be expanded to provide a summary of the geomorphic conditions at the site and their potential to compromise the integrity and long- term stability of the site, based on the Boothroyd studies. In addition, a more detailed discussion of geomorphic processes as a disposal performance problem should be provided in Section 4.0 (see comment # 10).

Nicholson and Hurt (1985) provide a good account of geomorphic processes at West Valley.

5. Section 2.4.2.1 and 2.4.2.2, p.2.5-2.6 The report does not provide sufficient detail to describe the hydrogeologic units at the West Valley site. The report should be i

revised to provide more detailed information on the hydraulic l properties and physical characteristics of the important hydrogeologic units, the weathered till, the unweathered till, and ,

the Lacustrine unit. The information provided should include l thickness of units, estimated hydraulic conductivities based on lab and field measurements, hydraulic gradients, directions of i groundwater flow, recharge and discharge, effective porosity, and I

measured. water level fluctuations. In addition, the physical l characteristics of these units should be described, such as detailed information on the fractures in the weathered till zone, and the tendency for perching of the water table in this zone, f characterization of sand pods and sand lenses in the till matrix, and heterogeneities in the Lacustrine unit.

The above information can be found in Prudic (1986) and Nicholson  ;

and Hurt (1985). l l

6. Section 2.4.2.2, p. 2.6 i The title of this section might be more appropriately titled," Groundwater Occurrence and Direction of Flow."

~

7. Figure 1., p. 2.9.

Figure 1 does not show enough detail to depict the surface water features in and around the commercial site, described on p. 2.1. ,

PNL should include an additional figure, which provides more detail l of surface drainage on site, including Frank's Creek, Erdman's Brook, and Lagoon Creek. A map of this type can be found in ]

l Albanese et al., (1983), which also depicts both the Federal and l State licensed burial sites and the WVDP Plant.

8. Section 3.1, p. 3.1 The report currently does not provide average trench dimensions, and should be expanded to do so. This information can be found in found in Nicholson and Hurt (1985) and DOE (1983).

9. Section 4.0, p. 4.1 This section does not address erosion as a potential performance problem. This section should be expanded to include discussion of i erosion and slumping as a potential performance problem, if these i processes were to compromise the long-term stability of the disposal site.

10. Section 4.1, P. 4.1. l l

The report does not provide enough detail on the history of water

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accumulation in trenches. The repoit should be expanded to provide more detailed information on the trenches.first overflowed, which trenches were involved, patterns of trench accumulation, historical and .present pumping of trenches, consequences .of water accumulation, such as possible lateral migration of leachate to

? nearby streams, and need-for long-term maintenance of the site, thickness of trench caps, addition of thicker cap material, rate of overflow, etc. This information can be found in Nicholson and

' Hurt (1985), and DOE (1983). l i

11. Section 4.2, P. 4.2 The report states that the trench leachate is very complex due to the presence of natural organic materials, organic solvents and pesticides, and inorganic wastes, and radionuclides. However, the report provides no . detailed information on nonradiological constituents. The report should be expanded to include a discussion of the nonradiological constituents measured in trench water, and discuss known migration of these constituents in Section 4.3, if data is available.

12. Section 5.1, p. 5.1 The report does not indicate what value was assumed for infiltration, and should be revised to do so.

13. Section 5.2, p. 5.2 The report does not indicate'what initial concentration was assumed for the radionuclides modeled. The report should include this information.

14. Section 6.0, p. 6.1 PAL should include information from Herbes and Clapp (1986) on data uncertainties.

15. Section 6.1, p. 6.1 The report does not include characterization of geomorphic processes as an area of uncertainty. The report should be expanded I to include geomorphic characterization as an area of uncertainty.

According to Nicholson and Hurt (1985), the extent and rate of mass wasting in the vicinity of the commercial disposal area have not been estimated. These processes could shorten groundwater pathways or even possible uncover buried wastes.

I i

4 REFERENCES Herbes and Clapp, 1985, "Reasearch Plan for Investigating Radionuclides Migration at the West Valley Facility Disposal Area,"

Oak Ridge National Lab.

National Low-Level Radioactive Waste Management Performance Assessment Project, DOE, " Commercial Low-Level Radiaoctive Waste Sites: No Longer Operating," 1983 Nicholson and Hurt, 1985 Prudic, 1986 e

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