nrc review of draft waste determination6 review summary • draft waste determination for the idaho...

NRC Review of NRC Review of Draft Waste DeterminationDraft Waste Determination

Idaho Nuclear Technology and Engineering Center Idaho Nuclear Technology and Engineering Center

Tank Farm FacilityTank Farm FacilityIdaho National LaboratoryIdaho National Laboratory

Xiaosong Yin and Cynthia S. BarrXiaosong Yin and Cynthia S. Barr

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Consultation OverviewConsultation Overview

•• BackgroundBackground•• Review SummaryReview Summary•• General FindingsGeneral Findings•• Criterion OneCriterion One•• Criterion TwoCriterion Two•• Criterion ThreeCriterion Three•• Path ForwardPath Forward

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BackgroundBackground

•• Tank Farm Facility (TFF) Tank Farm Facility (TFF) Waste Storage Waste Storage

•• CleanClean--up Activitiesup Activities

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Background (cont.)Background (cont.)

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Background (cont.)Background (cont.)

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Review SummaryReview Summary

•• Draft waste determination for the Idaho National Laboratory Draft waste determination for the Idaho National Laboratory (INL) TFF in September 2005(INL) TFF in September 2005

•• NRC transmitted a request for additional information (RAI) to NRC transmitted a request for additional information (RAI) to DOE Idaho in January 2006.DOE Idaho in January 2006.

–– Waste inventory estimatesWaste inventory estimates–– Removal to the maximum extent practicalRemoval to the maximum extent practical–– Waste classificationWaste classification–– Performance assessment modelingPerformance assessment modeling

•• DOE fully responded to the RAI in July 2006 DOE fully responded to the RAI in July 2006

•• The TER was issued October 2006The TER was issued October 2006

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General FindingsGeneral Findings

•• NRC concluded that DOE can meet the NRC concluded that DOE can meet the NDAA criteriaNDAA criteria

•• NRC staff conclusions are based on NRC staff conclusions are based on multiple assumptions, which are listed in multiple assumptions, which are listed in the TERthe TER

•• Key areas were identified for monitoringKey areas were identified for monitoring

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DOE’s 4DOE’s 4--Step Closure ProcessStep Closure Process

1. Waste removal1. Waste removal

2. Cleaning of the tanks, 2. Cleaning of the tanks, piping, and ancillary piping, and ancillary equipmentequipment

3. Develop residual waste 3. Develop residual waste inventoryinventory

4. Stabilization of the tank 4. Stabilization of the tank and vault systemand vault system

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Criterion OneCriterion One--“waste…does not require permanent isolation in “waste…does not require permanent isolation in a deep geologic repository for spent fuel or HLW”a deep geologic repository for spent fuel or HLW”

•• NRC concludes that NDAA Criterion One NRC concludes that NDAA Criterion One can be met (provided NDAA Criteria 2 and can be met (provided NDAA Criteria 2 and 3 can be met)3 can be met)

–– There are no unique characteristics of this There are no unique characteristics of this waste that would require deep geological waste that would require deep geological disposaldisposal

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Criterion TwoCriterion Two––”waste…has had highly radioactive ”waste…has had highly radioactive radionuclides removed to the maximum extent practical”radionuclides removed to the maximum extent practical”

•• DOE provided information to support Criterion 2DOE provided information to support Criterion 2

•• NRC staff assessed DOE’sNRC staff assessed DOE’s–– Development of waste inventory, Development of waste inventory, –– Identification of HRRs, Identification of HRRs, –– Selection of waste treatment technology, and Selection of waste treatment technology, and –– Criterion 2 demonstrationCriterion 2 demonstration

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Criterion Two (cont.):Criterion Two (cont.):Tank Cleaning ChallengesTank Cleaning Challenges

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Criterion Two (cont.)Criterion Two (cont.)

•• Uncertainty in the waste inventory due toUncertainty in the waste inventory due to–– Difficulties in sampling solid residuals Difficulties in sampling solid residuals –– Inaccessibility of two contaminatedInaccessibility of two contaminated

sand padssand pads

•• Inventory uncertainty was managed withInventory uncertainty was managed with–– Conservative assumptions and Conservative assumptions and –– Additional analysis by DOE and NRCAdditional analysis by DOE and NRC

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Criterion Two (cont.)Criterion Two (cont.)

•• NRC evaluated cleanNRC evaluated clean--up costs (financial and up costs (financial and worker dose) and benefits (risk reduction)worker dose) and benefits (risk reduction)

•• Costs were relatively high, while risks were Costs were relatively high, while risks were relatively lowrelatively low

•• NRC staff concluded that NDAA Criterion Two NRC staff concluded that NDAA Criterion Two could be metcould be met

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Criterion ThreeCriterion Three--”waste…will be disposed of in compliance with ”waste…will be disposed of in compliance with the performance objectives set out in” 10 CFR 61, Subpart Cthe performance objectives set out in” 10 CFR 61, Subpart C

•• DOE Idaho used a performance assessment DOE Idaho used a performance assessment (PA) to demonstrate compliance (PA) to demonstrate compliance

•• NRC used NRC used

1.1. DOE’s PA,DOE’s PA,2.2. Analysis of recent monitoring data and modeling, Analysis of recent monitoring data and modeling,

and and 3.3. Its own independent analysis to reach its Its own independent analysis to reach its

conclusionsconclusions

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Criterion Three (cont.)Criterion Three (cont.)

•• DoseDose--based performance objectivesbased performance objectives: NRC : NRC evaluated DOE’s modeling to demonstrate evaluated DOE’s modeling to demonstrate compliance with standards related to compliance with standards related to –– Protection of the general population and Protection of the general population and –– Protection of individuals from inadvertent intrusionProtection of individuals from inadvertent intrusion

•• Other performance objectivesOther performance objectives: NRC also : NRC also evaluated DOE’s demonstration of compliance evaluated DOE’s demonstration of compliance with standards related towith standards related to–– Protection of individuals during operationsProtection of individuals during operations–– Stability of the disposal site after closureStability of the disposal site after closure

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Criterion Three (cont.):Criterion Three (cont.):Key Credits in DOE’s Basecase PAKey Credits in DOE’s Basecase PA

44––5 orders of 5 orders of magnitudemagnitude

1212--13 orders of 13 orders of magnitudemagnitude

6 orders of 6 orders of magnitudemagnitude

Total Barrier Total Barrier Performance Performance Expected for Expected for Compliance Compliance CaseCase




Natural SystemNatural System



11––44 orders of orders of magnitudemagnitude

Engineered Engineered BarrierBarrier




Total Barrier Total Barrier Performance Performance Needed for Needed for ComplianceCompliance

II--129129SrSr--9090TcTc--9999

rough estimates of barrier performance

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Criterion Three (cont.): Criterion Three (cont.): DOE’s Conceptual Release ModelDOE’s Conceptual Release Model

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•• Issue: NRC identified potential inconsistencies with Issue: NRC identified potential inconsistencies with DOE’s hydrogeologic conceptual model (HCM) and DOE’s hydrogeologic conceptual model (HCM) and recent monitoring datarecent monitoring data

•• Resolution: Resolution:

–– NRC considered overall system performanceNRC considered overall system performance----additional barriers additional barriers to contaminant release and mobility in the environmentto contaminant release and mobility in the environment

–– Model results were constrained using recent monitoring data and Model results were constrained using recent monitoring data and modeling activitiesmodeling activities

–– Uncertainties in natural system performance will be monitoredUncertainties in natural system performance will be monitored

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NRC concluded that all performance NRC concluded that all performance objectives could be met, including objectives could be met, including –– Protection of the general population,Protection of the general population,–– Protection of individuals from inadvertent Protection of individuals from inadvertent

intrusion, intrusion, –– Protection of individuals during operations, Protection of individuals during operations,

and and –– Stability of the disposal site after operationsStability of the disposal site after operations

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SummarySummary

•• Final TER was transmitted to DOE in Final TER was transmitted to DOE in October 2006October 2006

•• DOE issued its final Waste Determination DOE issued its final Waste Determination and began tank grouting operations in and began tank grouting operations in November 2006November 2006

•• Monitoring is ongoingMonitoring is ongoing

NRC Monitoring ActivitiesNRC Monitoring ActivitiesTank Farm FacilityTank Farm Facility

Idaho National LaboratoryIdaho National Laboratory

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INL Monitoring PlanINL Monitoring Plan

•• TER for INL INTEC TFF completed in TER for INL INTEC TFF completed in October 2006October 2006

•• Draft plan sent to Idaho DEQ in Draft plan sent to Idaho DEQ in January 2007January 2007

•• Feedback received in January 2007Feedback received in January 2007•• Final monitoring plan completed in Final monitoring plan completed in

April 2007 April 2007

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NRC’s Monitoring Plan at INLNRC’s Monitoring Plan at INL

Five key monitoring areas (KMAs) Five key monitoring areas (KMAs) determined by NRC staffdetermined by NRC staff

1.1. Residual Waste SamplingResidual Waste Sampling2.2. Grout Formulation & PerformanceGrout Formulation & Performance3.3. Hydrological UncertaintyHydrological Uncertainty4.4. Monitoring During OperationsMonitoring During Operations5.5. Engineered Surface Barrier/Infiltration Engineered Surface Barrier/Infiltration

ReductionReduction

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NRC Monitoring at INLNRC Monitoring at INL

•• 15 technical review and 11 on15 technical review and 11 on--site site observation activities are identified in the observation activities are identified in the current plancurrent plan

•• All the activities will not be initiated in the All the activities will not be initiated in the first yearfirst year

•• The first onsite observation will be focused The first onsite observation will be focused on KMAon KMA--2 & KMA2 & KMA--44

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Monitoring During Operations (KMAMonitoring During Operations (KMA--4)4)– Review DOE’s radiation protection program– Interview DOE’s site radiation protection

personnel– Monitor personnel for use of dosimetry

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Grout Formulation & Performance (KMAGrout Formulation & Performance (KMA--2)2)–– Evaluate significant deviations in the proposed Evaluate significant deviations in the proposed

grout formulation grout formulation –– Evaluate DOEEvaluate DOE’’s program for sampling, testing, s program for sampling, testing,

and accepting grout materials and accepting grout materials –– Evaluate DOE’s quality control procedures for Evaluate DOE’s quality control procedures for

mixing and placing the grout mixing and placing the grout –– Evaluate the adequacy of the silos or bins for Evaluate the adequacy of the silos or bins for

storage of the slag and cementitious materials storage of the slag and cementitious materials

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Concluding ThoughtsConcluding Thoughts

•• Monitoring: onMonitoring: on--going & dynamicgoing & dynamic

•• DOE interactions: frequent & consistent DOE interactions: frequent & consistent

•• State coordination: frequent & State coordination: frequent & collaborative collaborative

nrc review of draft waste determination6 review summary • draft waste determination for the idaho...

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