2008/03/12 Shieldalloy-DP - Table & Bridgeline Info for 3 ...

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John Hayes "David Smith" 3/12/2008 2:53:27 PM Table & Bridgeline Info for 3/13/08 calls ,

See attached for information on RAIs to be discussed on 3/13/08 during both calls Bridgeline No 888 810-3145 Passcode 24056 9 - 11 AM

Bridgeline No 888 928-9527 Passcode 24056 1:30 - 3:30 PM Thanks, Jack

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Table & Bridgeline Info for 3/13/08 calls 3/12/2008 2:53:27 PM John Hayes

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RAI Table on eligibility determination for restricted use 0312208.wpd

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DWS Input

page 1

draft 02/08/2008

RAI No. 7

Issue

Bases for radionuclide concentrations of materials proposed for consolidation in restricted area.

Reviewers Schmidt

8

Bases for volumes of Schmidt

contaminated

materials of

materials proposed

for consolidation in

restricted area.

9

Contamination in

Schmidt,

Hudson Branch &

Walker

meeting of

radiological criteria.

Discussion Topics/Issues

Specifics

SMC committed to obtaining additional characterization data, and committed to preparing a "source term document," an appendix to the DP.

NRC Staff: Approach appears acceptable. Staff will review source term document as part of DP Rev 1 b.

SMC committed to preparing a "source term document," an appendix to the DP.

NRC Staff: Approach appears acceptable. Staff will review source term document as part of DP Rev 1 b.

characterization and possible remediation, conclusion that meet unrestricted use criteria

SMC committed to obtaining additional characterization of Hudson Branch. SMC proposed comparing data to unrestricted use DCGLs, to determine if remediation is needed. SMC also will provide classification for FSS.

NRC staff clarifies: Approach appears acceptable, but the staff notes that SMC did not mention DCGLs specific to Hudson Branch. In its DP Rev 1b, SMC should justify the applicability of the DCGLs that are proposed for comparison of the soils and sediments along the Hudson Branch. Staff will review additional characterization and conclusions about remediation and FSS as part of DP Rev 1b.

DWS Input

page 2

draft 02/08/2008

RAI No. 10

Issue Data requirements for unidentified or insufficiently characterized soils

Reviewers Schmidt

27

?20.1403(a):

Schmidt

compliance method

Discussion Topics/Issues Characterization of areas not yet identified or insufficiently characterized

ALARA and net harm include more than the readily quantified benefits and costs

Specifics

SMC's response focused primarily on two specific areas. SMC committed to additional characterization and to revising discussion in Section 14.1 of the DP. SMC also stated that SMC is unaware of other locations on the property where slag may have been buried.

NRC staff clarifies: Approach appears acceptable, but staff notes that it is unclear if the DP Rev 1b will address the more general issue of uncharacterized areas (in addition to the 2 specific areas). SMC has not demonstrated (via historical information or characterization information) that there are not additional areas of contamination Staff will review additional characterization and conclusions about remediation and FSS as part of DP Rev 1b.

SMC stated that it it will rely on both eligibility criteria (net harm and ALARA). In discussing net harm, SMC discussed only the total risk of fatalities. In discussing ALARA, SMC stated that the LTC option provides the lowest cost and the lowest risk to a member of the public.

NRC staff clarifies: It appears SMC may not completely understand the RAI. First, meeting both criteria is not required. In addition, in the response to this RAI, the focus was on the more readily quantifiable costs and benefits (doses, accident fatalities). SMC should consider the issues raised in RAIs 28 and 32.

DWS Input

RAI No. 28

Issue

?20.1403(a): demonstrate net harm

page 3

draft 02/08/2008

Reviewers Schmidt

Discussion Topics/Issues

compare benefits to detriments, without cost of remediation

Specifics

SMC stated that collective dose from the LTC option is less than for LT or LC options and thus there is net harm. SMC is updating dose analyses, so final results are dependent on update. Part of SMC's response stated that SMC intends to make clear that there is "...net harm from implementing other than the LTC option due to higher cost and greater risk."

NRC staff clarifies: The staff notes that SMC refers to "higher cost" as a basis for net harm. In addition, SMC's response focused on doses averted. However, the net harm analysis should include all parts of the ALARA evaluation that relate to costs to the public, but should not account for the costs of remedial action. The NRC staff will review the revision to be provided in DP Rev 1b with these points in mind.

DWS Input

page 4

draft 02/08/2008

RAI No. 29

Issue

?20.1403(a): incremental changes to proposed restricted use action

Reviewers Schmidt

30

?20.1403(a):

Schmidt

compare benefits

and detriments

31

?20.1403(a): minimal Schmidt

incremental actions

Discussion Topics/Issues

incremental changes to restricted use proposal

Specifics

SMC stated that it does not expect different conclusions from incremental analyses. Part of SMC's reasoning is based on rejection of certain options because the option does not permit unrestricted use. However, SMC committed to performing certain incremental analyses, after revising dose analyses.

NRC staff clarifies: It appears to staff that SMC may misunderstand the original RAI. The incremental changes to the proposed restricted use approach do not have to result in unrestricted use; in fact some potential incremental changes would still result in restricted use of the site, but with potential changes in doses or other costs or benefits. The incremental changes that SMC committed to evaluate may be appropriate. The staff will review the revision to be provided in DP Rev 1b.

SMC committed to providing a more detailed presentation of benefits of dose averted.

NRC staff: Approach appears acceptable. Staff will review revision to be provided in DP Rev 1b.

SMC refers to response to RAI 29.

NRC staff: Staff will evaluate with evaluation of the response to RAI 29.

DWS Input

page 5

draft 02/08/2008

RAI No. 32

Issue

?20.1403(a): other societal and socioeconomic considerations

Reviewers Schmidt

33

?20.1403(a): sale of Schmidt

slag to IUC mill

34

?20.1403(e): ALARA Schmidt

for controls not in

effect

Discussion Topics/Issues difficult to quantify benefits and detriments

feasibility of uranium recovery

Specifics

SMC provided a brief discussion of potential change in land values associated with unrestricted use of the site. SMC provided brief reasoning that public opposition will be reduced and that aesthetic benefits cannot be reasonably assessed.

NRC staff: The staff will review the section of the DP Rev 1b. Evaluation of the response will depend also on the response to RAI 13.

SMC's response discusses commercial viability of sending slag to a uranium mill for uranium recovery processing.

NRC staff clarifies: It is unclear from the response whether sending slag to IUC would be more cost-effective than sending for disposal as proposed. It appears to staff that the response addresses commercial viability rather than viability as a decommissioning alternative. In the Section 7.1.4 that SMC plans to add to the DP Rev 1b, SMC should clearly address viability as a decommissioning alternative. The point is whether this option might be more cost-beneficial than the disposal option (LT) or restricted use option currently described.

SMC committed to provide a demonstration of ALARA for controls not in effect in its DP Rev 1b.

NRC staff: Revision will be provided in Rev. 1b. staff will review DP Rev 1b.

DWS Input

page 6

draft 02/08/2008

RAI No. 35

Issue

ALARA/cost-benefit: doses should be over 1000 years

Reviewers Schmidt

36

ALARA/cost-benefit: Schmidt

consider land use

over 1000 years

37

ALARA/cost-benefit: Schmidt

provide comparison

38

ALARA/cost-benefit: Schmidt

use of zero or low

discount rate

Discussion Topics/Issues

Specifics

SMC committed to calculating doses or doses averted over the 1000-year compliance period.

NRC staff: Approach appears acceptable. Satff will review DP Rev 1b. The staff notes that this RAI may also depend on the resolution of RAI 18 (issue of 1000 years).

SMC referred to their response to RAI 13.

NRC staff: Evaluation is partially dependent on response to RAI 13. Staff will review Rev 1b along with revisions to DP described in response to RAI 13.

SMC committed to including a description of all costs and benefits in the DP Rev 1b.

NRC staff: Approach appears acceptable. Staff will review the DP Rev 1b.

SMC committed to revising Chapter 7, in the DP Rev 1b, to include an undiscounted cost of present worth of the doses. SMC committed that if discount rates are applied, they will use a 1% rate and/or perform a sensitivity analysis.

NRC staff: Approach, including the use of no discounting, as committed, appears acceptable. Staff will review the DP Rev 1b.

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