EIS-0113_Section_11 - Hanford Site

P
!.
223 223
The DOE analysis does not consider those errors in determining the
lower end of the predicted values. The significance of this is
that they maybe underestimating the peak arrival times,
concentrations and flux rates in their transport assessment.
3 ' S . 2 ' 3
Another co mm ent regarding the Delegard and Barney data is in
regard to Table 2. The values for the He and the CEC do not
correspond to what is given in their reference to this Table
(Routson at al l 1981). For example, Bentsen at al. has values of
Kd for the referenced solution matrix of 0.09 for Sr and 27 for Cs
for sediment type 5 and P, respectively. Delegard and Barney list
values of 0.32 (Sr) and 35 (Cs). The result of these differences
is that the accuracy . of the data used in the study is suspect.
Based on the above discussion, it is questionable whether the
authors have taken a conservative app roach in selecting the Kd
values used in the analysis. A good .argument could be made that
they have not done so. A more conservative Kd would yield higher
concentrations sooner and result in higher dose rates and
consequently a more serious impact on public health antl safety.
To assume that TRU wastes are uncomplexed is not accurate, and
would not be a conservative assumption in any case. If this
assumption is disregarded, the result to the analysis would be
that many of the scenario results in Appendix q which Show small
or no o
n e
imoactSm
References Used:
Martin, E.C. 1985. Complexanf stability investigation. Task 2 -
Organic complexants. Pacific Northwest Laboratory, Battelle
Memorial Institute.
Schell ,W.E., T.H. Sibl my, A.L. Sanchez, J.R. Clayton, Jr., A.E.
Nevissi, and E.A. Wertz. 1982. Distribution coefficients for
radionuclides in aquatic environments, final su mm ary report.
NUREG/CR-1869, U.S. Nuclear Regulatory Co mm ission, Washington,
D.C., 21 pp._
CT
co
2. The second conservative assumption is that the organ"c complexing
on pages P.2A and P.26 it is stated that TRU wastes in double-shell
agents will break down under .prolonged radiation and not maintain
Yanks are assumed to be equivalent to dilute, noncomplexetl HIM contained in
their complexing ability. no 0 te A recent Battelle report (Martin,
double-shell tanks at Hanford However, Shulz 1960 (Reference 22.14
3 .5.O 37 985), which was not cited in the E18, shows that . by 1980
L J
indicated that Tank 101-SY (a double-shell tank) has an organic carbon
(Delegard, 1980) At was known that one of the main complexion concentration of 1.19M which is equivalent to 0.12MEDTA+HEDTA This is a
agents HEDTA (N-hydroxy ethyl. ethylenediammetri acetic acid). does
complexed solution accerding to Deleoard and Barney 1983 (Reference 5.7),
undergo oxidative decomposition in simulated double shell. tanks
which uses a value of 0.15M HEDTAtEDTA to indicate a complexed solution. In
(DST) mixtures to a chemically similar complexant,
addition, the reported concentrations of Nat and NaAlo? and NaGHwould
ethylene d amrnetri acetic acid. This compound was also found. to
indicate a concentrated. solution. Therefore, the Kd's should be much .lower.
_ be the principle complexant degradation p roduct in a LLW burial
site at Maxey Flats, Kentucky.
Ouestlnn5
Therefore, there is no evidence at this time which would indicate
a loss of complexing ability of waste solutions over time. The
ITS conservative assumption regarding breakdown of .organic
complexing agents is unfounded and should not be conside re d as a
conservative assumption at this time.
P-1 Give the on-conservative. approach in choosing molecular
diffusion coefficients and Kds, how Will 11 choosing more
cdnservat i ve values affect the release and oo sin gomo scenarios}
P-2 What effect would the use of the .relative errors of the Ktl values.
(statistical uncerta in ty) shown in your reference (Delegard and
3. The final assumption concerns TRU wastes which, according to the Barney) have on the re sults of your release and transport
EIS, are assumed to contain no. complexing agents. From the
modeling?
description of the past waste handling practices in Volume. 1, it
would appear contrary to the DEIS, that all wastes are complexed.
3.5.2.37 p_3 Please correct the Uvalues taken from the Bentsen at al.
Page. 3.4 the{^ DE ] tl escribes LLW solutions being generated by
Q^
reference which were incorrectly quoted.
removing Sr and Cs from tank supernatant and disposing n ami of the
supernatant as LIN. Page 3.9 (usu.... contaminated uti soil
p.a What effect would variations an reliability of the analytical
site as a to Which
(usuall
so
beenrx liquids ally y aqueou s solutions
techniques used in determining the Kd values have on your
classifieds
had released.' Since these solutions came
conclusions?
from the tanks, they ,will be a o oil ma d solution according to
" Schultz (1980) This in also coonil in the preceding p.5 What was the hales for your an that complexing solutions
d iscussion sectio n which pomplea siteradatl on products were
would lose complexing ability ity and woulld Would break down and release
present at the Maxey Flats LLW burial site.
bound radionuclides?
3.5.2.37
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