ML101090101

DOE Response to NYSERDA Comments on Phase 1 Fssp for Wvdp

ML101090101
Person / Time
Site:	West Valley Demonstration Project, P00M-032
Issue date:	04/12/2010
From:	Bower B US Dept of Energy, West Valley Demonstration Project
To:	Bembia P, Glenn C NRC/FSME/DWMEP/DURLD/MDB, State of NY
References
Download: ML101090101 (40)

Text

Department of Energy West Valley Demonstration Project 10282 Rock Springs Road West Valley, NY 14171-9799 April 12, 2010 Mr. Paul J. Bembia, Director New York State Energy Research and Development Authority 10282 Rock Springs Road West Valley, NY 14171-9799

SUBJECT:

Response to Additional New York State Energy Research and Development Authority (NYSERDA) Comments on the Phase 1 Decommissioning Planfor the West Valley DemonstrationProject,dated December 3, 2008

REFERENCES:

1) Letter (100671), P. J. Bembia to B. C. Bower, "Additional NYSERDA Comments on the Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject,dated December 3, 2008, " dated April 1, 2009.

2) E-mail (102830), P. L. Piciulo to M. N. Maloney, "EditorialComments on DP, Rev. 0," dated April 2, 2009

Dear Mr. Bembia:

Enclosed are the responses to your comments on the Phase ] Decommissioning Planfor the West Valley DemonstrationProject. These responses are based on Revision 2 of the Phase 1 Decommissioning Planfor the West Valley Demonstration Project,dated December 18, 2009.

If you have any questions, please contact Moira Maloney of my staff at (716) 942-4255.

Sincerely,

/ 1 C. Bower, Director sst Valley Demonstration Project

Enclosure:

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject cc: M. N. Maloney, DOE-WVDP, AC-DOE, w/enc.

P. A. Giardina, EPA, w/enc.

C. J. Glen, NRC, w/enc.

E. E. Dassatti, NYSDEC, w/enc.

G. A. Baker, NYSDOH, w/enc.

P. L. Piciulo, NYSERDA, AC-NYS, w/enc.

MNM:102835 - 450.4

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject Responses are provided below for NYSERDA's 72 technical comments (sent 4/1/2009) and 12 editorial comments (sent via 4/2/2009 email) on the WVDP Phase 1 DP. The associated changes were made in DP Revision 2.

(Table;- Figurie) Prooe dslto Page#(P~araph Linie).

General NYSERDA employed the technical support of an NYSERDA would appreciate written responses Independent Expert Review Team (IERT) to assist in the describing how NYSERDA's comments, as well as the review of the Phase I DecommissioningPlanfor the West concerns raised by the IERT, were considered in NRC's Valley Demonstration Project (DP). The IERT report, review of the DP.

entitled "Independent Review of the Phase 1 DecommissioningPlanfor the West Valley Demonstration RESPONSE: NRC included those NYSERDA comments Project," describes the approach and results of their relevant to the scope and objectives of NRC's review in review. NYSERDA is providing the IERT report as well RAI's. NRC provided a copy of the RAIs to NYSERDA.

as our comments (below) for consideration by the NRC in Copies of the RAI responses were also provided to their review of the DP and development of a request for NYSERDA. RAI responses related to specific NYSERDA additional information. The IERT report and an expanded comments are identified below.

version of NYSERDA's comments are being provided to the Department of Energy (DOE) to be addressed in a future revision of the DP.

2. General The Derived Concentration Guideline Levels (DCGLs) RESPONSE: The appropriate sections of the DP were identified for Sr-90 and Cs-137 are the DCGL values at revised (ES, Section 5, Section 7, Appendix D) to indicate year 2041, and not the values at the completion date for that the DOE will provide monitoring, maintenance, and Phase 1 as indicated in the DP. Per the DP, Phase 1 is security until 2041. The DP text was also revised to indicate expected to begin in year 2011 and be completed in year that the DOE will have a presence on site duringPhase 2 of 2018. Since the DCGLs are based on the concept of decommissioning.

active management of the site until 2041, NYSERDA expects that DOE will provide the necessary monitoring, maintenance and security controls until year 2041.

3. General The text on Page ES-19 (and in other sections of the DP) Update the language in the DP to more accurately reflect states that "and upon NRC approval of this plan, DOE NRC's role.

would begin Phase 1 ofjhe proposed decommissioning in RESPONSE: The DP text was revised to read "upon 2011 and it would last until 2018." This does not completion of the NRC review process related to this plan" accurately describe NRC's role and responsibility under to more accurately describe the NRC's role in the Page 1 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject

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(.Ta e,.figu .,i*  ; proposedResolution and DOE ?esponse Pr.oComment

'Pagek (Pr ra ine)~~--.,--

the West Valley Demonstration Project (WVDP) Act. decommissioning.

Consistent with. the WVDP Act, NRC has stated (publicly) that they will conduct an "informal review and consultation," after which they plan to issue a Technical Evaluation Report. Similar text on Page 7-48 references "NRC's approvalof this plan."

4. General The DCGLs and cleanup goals in the DP are established The DP should describe how the Phase 1 DCGLs allow for such that the entire 25 mrem dose limit of-the License possible Phase 2 actions that may leave radioactive material Termination Rule can be allocated to the Phase I removal in place.

actions. If the cleanup of the facilities and soils included RESPONSE: The entire 25 mrem LTR dose limit will not in the scope of this DP achieves the DCGLs as presented, be allocated to the Phase 1 removal actions. The proposed could that severely limit the allocation of dose to the soil excavations in WM[A I and WMA 2 will remove the Phase 2 decommissioning activities? entire surficialsand andgravel unit and extend at least one foot into the underlying Lavery till where residual radionuclide concentrationsare expected to be well below the cleanup goals. The estimateddoses from the remediated WMA 1 and WMA 2 excavations after completion of Phase 1 are expected to be smallfractions of the 25 mrem/yr dose

-- limit as discussedin Section 5.4.4 of the DP.

The cleanup offacilities and soil within the scope of Phase I would not limit allocation of dose to the Phase 2 decommissioning activities. The discussions in Section 5.1.3 on pages 5-12 and 5-13 are intended to address this matter, although dose allocation is not specifically addressed. The matter of dose allocation would not be an issue if the site-wide close in place or the site-wide removal alternatives were the selected Phase2 approach.

5. General Section 9 of the DP describes a process for developing NRC should be prepared to perform confirmatory surveys of and implementing Final Status Surveys of remediated the decommissioned areas of the WVDP.

areas. The DP states that arrangements would be made RESPONSE: These independent surveys are provided for for any confirmatory surveys that NRC desires. Since it is Page 2 of 39,

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject men posed Resolutionand D.E Response NYSERDA's intent that the units decommissioned per the in Sections 7 and 9 of the DP.

WVDP policy statement would also be considered decommissioned for the termination of the NYSERDA CSF-1 license, NYSERDA requests that NRC perform confirmatory surveys during Phase 1. decommissioning activities. Such surveys would be particularly important for excavations for Waste Management Areas (WMAs) 1 and 2 as well as the fill material for each excavation.

Conceptual Models: The validity of the DCGLs to be used to demonstrate compliance with the NRC policy statement and 10 CFR 20 Subpart E depends, in part, on the adequacy of the site conceptual models. Uncertainties in, or lack of accurate information on, the source terms and physical features of the site can limit the development of exposure scenarios used to establish adequate site conceptual models. Questions and comments presented below are aimed at clarifying factors that can affect the site conceptual models as presented in the DP. The IERT report presents additional observations regarding the adequacy of the conceptual models and engineered barriers presented in the DP.

6. General The IERT report raises several concerns regarding the site See the IERT report for additional details regarding their conceptual models and the basis for certain assumptions. analysis of the conceptual models and engineered barriers.

For example, a feature of the West Valley site critically Either additional discussion is needed in the DP to support important to the transport and release of radionuclides is the basis for assumptions used or further calculations must be erosion. The conceptual models ignore the potential performed to demonstrate the potential impacts of processes impacts of gully erosion on dose calculations. Further, the identified by the IERT on the dose calculations and conceptual model for steam bed sediments assumes an establishment of DCGLs. The technical basis to support the unrealistic static condition of the river channel perimeter effectiveness of engineered barriers should be enhanced.

for extended periods of time. RESPONSE: A number of alternative conceptual models The conceptual models exaggerate the extent to which (i.e., exposure scenarios) have been evaluated in response contaminants originating in the surface soil are diluted in to NRC's RAIs that addressed issues identified in the the farmer's well by groundwater. NYSERDA comment. DOE representatives discussed the The conceptual model for calculation of subsurface soil results of the alternatescenario analyses with NRC staff at DCGLs ignores any dose contribution from groundwater the 9/2/09 DOE-NRC meeting. The results have also been transport of residual contamination in subsurface soils incorporatedinto Revision 2 to the DP.

other than a limited quantity brought to 'the surface as Two of these analyses proved to be more limitingfor some cistern cuttings. Dr. Neuman, in the IERT report, presents radionuclidesthan the base-case residentfarmer scenario.

a mathematical proof demonstrating that not only would Page 3 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject (TaleFiure~Comment

.. Propoed Resolution and DOEResponse Page #'(Paragraph Line.) *&  ;

contaminants at the top of the Lavery till be drawn to the (1) One was the residential gardener scenario for well intake, the concentration would actually increase subsurface soil DCGLs. The results of this analysis towards the well. were taken into account in reducing the subsurface The hydrologic connections between the conceptual soil cleanup goals.

models employed, as per RESRAD, are physically (2) The other alternate scenario involved releases from unrealistic since they do not consider coupled surface- the bottom of the deep excavations. The results of this subsurface processes and resultant release scenarios. The alternate scenario analysis were used to further presence of actively-eroding gullies would greatly reduce the subsurface soil cleanup goals.

facilitate the communication of water downward into the Additional information on the alternative scenarioanalyses subsurface or upward and outward onto the ground can be found in the presentation slides used at the 9/2/09 surface. DOE-NRC meeting and the responses to the following A major concern regarding the effectiveness of the RAIs.

engineered barriers is that at the interface of the barrier SURFACE SOIL DCGLs:

bottoms and the till, groundwater could seep back into the RAI 5C4 - potential impacts of radioactivity in eroded excavation of WMA 1 and 2, become contaminated and surface soil on an onsite recreationist-hiker, continue to contaminate the excavation surfaces and till floor. Also, design details are lacking such as the RAI 5C4 - potential impacts of radioactivity in eroded thickness of the thickness of the barrier for WMA 2, the surface soil on an offsite receptor, and method of maintaining the necessary slope and support on RAI 5C18, evaluation of a residential gardener to the excavation side of the barrier wall, and the determine the impacts of a lower pumping rate.

consideration of possible seismic loads and severe storms SUBSURFACE SOIL DCGLs:

on the excavated walls. RAI 5C5 -potential acute dose to a cistern well driller, RAI 5C6 - potential impacts of radioactivity in deep gullies in the area of the WMA 2 excavation on an onsite recreationist-hiker, RAI 5C6 - potential impacts of radioactivity in deep gullies in the area on Lagoons 1 and 3 on an offsite receptor, RAI 5C8 - potential acute dose to a natural gas well driller,and RAI 5C18 - potential dose to a residential gardener Page 4 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject Sectin, (Tbe ~Comment iue Proe eouinand DOEt Response Page# (Paragraph;,

Line) using three different combinations of contamination zone area and thickness.

STREAMBED SEDIMENT DCGLs:

RAI 5C12 - impacts of inhalationpathway.

In addition, DOE made changes to the base-case deterministic conceptual models and recalculated the surface soil, subsurface soil, and streambed sediment DCGLs. The response to RAI 5C12 describes these analyses.

DOE also performed a comprehensive probabilistic uncertainty analysis, which is described in the response to RAI 5C15. The revised deterministic DCGLs and the probabilistic peak-of-the-mean DCGLs were used to establish new cleanup goals.

Information from these RAI responses was incorporated into Revision 2 of the DP.

Information on several related issues included in the NYSERDA comment is provided as follows:

Unrealistic static condition of river channel. The conceptual model assumes that the contamination zone is located on the stream bank and that the banks of the stream are steep such that home construction in the area is not plausible. Predicted long-term erosion is expected to result in downcutting and rim widening, neither of which would be expected to change the basic nature of the terrain.

Consequently, the conceptual model geometry would be expected to remain valid in the long term.

Streambeds within the project premises will be characterized in Phase I to evaluate the extent of contamination. The resulting data will allow refinement of Page 5 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject Section,-

(Table, Figure)  :~.Comment. ProposedResolution and DOEResponse Page# (Paragraph,Line)I-the conceptualmodelfor DCGL development Conceptual models exaiggerate contaminant dilution. This matter was evaluated in the residential gardener model, which makes use of lower pulping rates with less dilution, with the results noted previously.

Subsurface soil model ignores residual contamination.

Available data suggest that only low levels of residual contamination will be present in the bottom of the WMA 1 and WMA 2 deep excavations. Contamination is not expected upgradient of these units based on current knowledge. However, releases from the bottom of the deep excavations were evaluated, as notedpreviously.

Hydrologic connections are unrealistic. As noted previously, the impacts of long-term gully erosion in WMA 2 have been evaluatedfor both onsite and offsite receptors.

Both alternative scenarios,were found to less limiting than the base-casescenario.

Design details -arelackin-.Detailed design information is not appropriate for the Phase 1 DP, which describes proposed decommissioning actionsfor WMA 1 and 2. The detailed design will be prepared by the decommissioning contractorand will be detailed in various decommissioning work plan documents prepared to support Phase I decommissioning.

The DP was changed in Revision 2 as indicated in the responses to RAIs 7C1 and DC] to provide for NRC review of the detailed designs.

7. Section 3.5.5, Page 3-51, This section indicates that erosion rates near the WVDP Clarify the limitations of the data provided in Table 3-13.

Table 3-13 will vary over time due to various factors (e.g., stream RESPONSE: Table 3-13 reports historical erosion rates valley widening, knick point advance, etc.). It is unclear from the WNYNSC that were assumed applicable for from the data, however, whether the listed erosion rates Page 6 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject 401Ti,, Fgre) Comment .~ rpsd iResolto adDERsponse Page #Prgah, Line) ,~~~.3/4¶<

are only applicable for the actual period used to determine estimatingfuture erosion at the WNYNSC. The reference to the rate, or if they can (or will) be used to extrapolate the table on page 3-49 and the content of the table make it future rates. clear that the data provided are historicaldata.

8. Page 5-14, Bullets and The bullets on Page 5-14 summarize results from the EIS Modify the DCGL exposure scenarios to include a scenario Page 5-23 through 5-28 erosion modeling, which NYSERDA believes to be where erosion impacts to the North Plateau bring subsurface significantly flawed and not technically defensible. The contaminants to the surface. The uncertainties in long-term EIS erosion modeling results should not be used to limit erosion modeling, as described in EIS Appendix F (e.g.,

the exposure scenarios that are used to develop DCGLs in Pages F-30, F-59-60), should be presented in the DP.

the DP. In addition, even .though these bullets recognize RESPONSE: The alternateconceptualmodels for the that the area of the lagoons could be impacted by erosion impacts of gully erosion on onsite and offsite receptors during the 1000-year evaluation period, a scenario where discussedpreviously made use of maximum predicted erosion uncovers buried contaminants is not considered in erosion ratesfor conservatism. The resultingDCGLs were the derivation of subsurface DCGLs. still higher than the base-case DCGLs, indicatingthat the base-case scenario is more limiting.

9. Section 5.1.7 This discussion of potential impacts to the Kent Discuss thepotential for the 473 steel "H" piles to serve as a Page 5-16 Recessional from residual contamination doesn't mention transport path for contaminants to the Kent Recessional the 473 "H" piles that were driven through the Surficial Sequence.

sand and gravel, through the Lavery till and into the Kent RESPONSE: This matter is addressed with respect to Recessional Sequence. There is potential that these steel characterizationsurveys in the response to RAI 4C2, with piles could serve- as a pathway for contaminants to the respect to in-process surveys in the response to RAI 9C3, Kent Recessional Sequence. While Section 7.3.8 (Page 7- and with respect to final status surveys in the response to

26) recognizes the importance of sampling around the "H" RAI 9C4. These RAI responses identify the specific changes piles, Section 5.1.7 should include a discussion of the "H" that were made to the DP in Revision 2 to address the H-piles as a potential transport path for contaminants to the piles.

Kent Recessional Sequence.

10. Seismically induced slope failure could cause the Discuss whether seismically induced slope failure could exposure of buried contamination. Has the issue of expose buried contamination.

seismically induced slope failure been evaluated for the RESPONSE: Evidence for seismically induced ground North Plateau? failure, liquefaction, slumping, andfissuring has-not been observed on or near the WNYNSC dating back 12,000 Page 7 of 39

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-,section, (Table Figur) ~. Cmment ProposedResolution and DOE Rsos

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years. An evaluation of this type is not considered appropriatefor Phase 1 actions that involve the near total removal.of soil contamination resulting in minor residual contamination in the Lavery till. Slope failure in WMA 2 would expose residual contamination in the Lavery till similar to surface soil DCGL 's. A seismically induced slope evaluation may be considered appropriate if a site-wide close-in-placealternativewere selectedfor Phase 2.

11. In describing the "Subsurface ConceptualModel, "the DP The basis for the contaminated soil zone remaining more states that the scenario whereby a house constructed with than 10' below the surface should be clearly stated. The a basement extending into contaminated areas was uncertainties in long-term erosion modeling, as described in considered implausible because the contaminated EIS Appendix F (e.g., Pages F-30, F-59-60), should be subsurface soil would be more than 10' below the surface. presented in the DP.

Although not directly stated, this scenario assumes erosion RESPONSE: As noted previously, additionalmodeling was on the North Plateau would not thin the zone of clean fill performed as described in the responses to RAIs 5C4 and and subsequently move the contamination closer to the 5C6 to evaluate the potential impacts of radioactivity in surface. deep gullies in WMA 2 on both onsite and offsite receptors.

The most conservative predictions for gully development from the DEIS erosion modeling were used as the basisfor this dose modeling.

Based on current sheet and rill erosion rates at the WNYNSC, surficial erosion on the North Plateau over the next 1,000 years will not have a significantimpact on WMA 1.

12. The text identifies the manner in which buried radioactive The uncertainties in long-term erosion modeling, as material is addressed in the DP. Although not directly described in EIS Appendix F (e.g., Pages F-30, F-59-60),

stated, this discussion assumes that there will be no should be presented in the DP. The basis for the erosion on the North Plateau that would thin the zone of contaminated soil zone remaining buried should be clearly clean fill, and subsequently move the contamination closer stated.

to the surface. RESPONSE: As indicated in the response to comment 11, Page 8 of 39

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• i!i* il; Proposed Resolution- and DOE Response*

Section, .i:i .. ..

(Table,ý Figure) 1" ~Comment Rsos Page # (Paragraph, Line) it was not assumed that residual contamination at the bottom of the WMA 2 deep excavation will remain buriedas deep gullies could cut into the excavation bottom duringthe 1000 year complianceperiod.

13. The Streambed Sediment Conceptual Model (Page 5-29) Discuss the potential impacts to a recreationist that may hike assumes a recreationist as the average member of the along the streams both on and off the WVDP premises, and critical group. By design, the DP limits the recreationist calculate DCGLs for such a situation.

to streams within the WVDP premises (Page 5-9). While RESPONSE: The WVDP Phase I DP was prepared to the resident farmer is limited to only the remediated area address decommissioning activities within the project of the Main Plant Process Building (MPPB) or the premises. NYSERDA will be responsible for developing lagoons, the same requirement does not need to be applied DCGL'sfor closure of the remainderof the WNYNSC.

to the recreationist who could very well hike beyond the boundary of thebounaryof WVDP premises. Expanding the area for The final streambed sediment cleanup goals may be vVDPpreise.

he Epandng he reafor itable for later use outside of the project premises, the recreationist activities would support the evaluation of su cumulative impacts as it would consider seeps associated depending on whether the conceptual model used in their with the North Plateau Groundwater Plume (NPGP). development would apply to the conditionsin Franks Creek Such an analysis may provide DCGLS for remediation of downstream of the project premises and the conditions in accessible creeks throughout the Center.

Note that Figure 5-12 was added in Revision 2 to more precisely define where the streambed sediment cleanup goals apply on the projectpremises.

RESRAD Parameter Selection for calculating DCGLs: DOE has elected to perform a deterministic analysis using RESRAD rather than performing a probabilistic analysis. The defensibility of the dose assessment is in part dependent upon the defensibility of the RESRAD input parameters. The DP lists the parameter values used for the dose assessment and references general information about the site to support the parameter selection. Certain parameters, such as Kd values, can have a significant effect on the results of the DCGL calculations. The comments below question the adequacy of the level of justification presented in the DP to support the selection key parameters used for calculating DCGLs. The IERT report also presents concerns about the technical basis for parameter selection and the adequacy of the sensitivity analysis and lack of a probability based uncertainty analysis.

14. General The IERT expressed concern that the DP provides The technical basis for parameter selection should be inadequate information to support key assertions affecting expanded. Once the conceptual models are reviewed and the dose calculations and DCGL development. The revised as appropriate, a sensitivity analysis must be technical basis for changes of RESRAD default repeated. Consideration should be given to including a Page 9of 39

I Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject

1. (Table, Figure)., . Comment~ ProposedResolution and DOE Response Page,# (Paragraph,Line)-

parameters are poorly documented, and in some cases probabilistic uncertainty analysis perhaps using the (especially for Kd values), generic literature values appear probabilistic capability of the RESRAD code.

to have been used where site specific values were RESPONSE: The bases for selection of input parameters available. are identified in Tables C-i and C-2. The letter that The point estimates for parameter values used in forwardedRev 0 to the DP to NRC for review indicated that RESRAD may not have appropriately bounded the results DOE was still evaluating whether - the degree of of the analysis in which case an uncertainty analysis is conservatism in the input parameters was sufficient necessary to have confidence in the results. There is no (Attachment 1, page 2footnote).

evidence that the point estimates used were derived from Some model inputparameterswere changed as described in any such analysis and are therefore assumed -to be the the response to RAI 5C12. A probabilistic uncertainty analysts' "best estimates", not bounding values. Although analysis was completed as describedin the response to RAI the analysis is supported by substantial sensitivity 5C05. This analysis and its results were discussed with NRC analysis, that analysis varies only one parameter at a time. at the 9/2/09 DOE-NRC meeting. The probabilisticpeak-of-the-mean DCGLs were used in establishment of revised cleanup goals in Revision 2 to the DP.

15. Page 2-35, second In describing the source of the NPGP, the DP states that Provide a reference or other technical basis to support the paragraph "Less mobile radionuclides such as Cesium-137 are premise that the Sand and Gravel Unit has a high sorption expected to have remained beneath the immediate source capacity for cesium.

area due to the high cesium sorption capacity of the RESPONSE: There is no site-specific distribution minerals in the sand and gravel." Sorption capacity is coefficient data available for -cesium for the sand and typically expressed in terms of a distribution coefficient or gravel unit in the north plateau. However, cesium Kd value. While it may be true that the Kd value for distribution coefficients for sand are available from Cesium in the Sand and Gravel Unit is high, no reference Sheppard and Thibault 1990 and RESRAD default values is given to support this statement. Further, Table 3-20 are availablefor cesium in sand. These cesium distribution (Chapter 3, Pages 3-76 through 3-78) presents no data for coefficients are up to an order of magnitude greater than a Cesium Kd in the Sand and Gravel Unit. reportedfor strontium in similargeologic materials.

Note that the effects of distribution coefficient variability were evaluated in the probabilisticuncertainty analysis.

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(Tabl Figre) ' ComentPhiosed Resolution-land DO esponse;

'Page # Pragraph,iLine)," VA."~~

16. Appendix C, Section 1.0 In discussing the assignment of distribution coefficients Use more conservative distribution coefficient values to Tabulated Data, Page C-2, for the three RESRAD zones, the statement is made that represent stream bed sediment partitioning or provide better second paragraph the contaminated zone in the stream sediment analyses justification as to why the Lavery till values are and the subsurface soil analyses are assigned the Kd values representative.

for the Lavery till. One could argue that poorly RESPONSE: Erdman Brook and Frank's Creek are consolidated stream sediments would have sorption located entirely within the Lavery till within the project properties that were more similar to the sand and gravel premises. Field surveys indicate that stream banks and unit rather than the Lavery till. The assumption that the bottoms are dominated by glacial till material. Sands and Kd value for stream bank sediments can be represented by gravels are located in isolated areas typically associated the Lavery till needs further discussion in this section. with stream nick points.

Given the sensitivities of the stream bed sediment scenario to distribution coefficient (see Table C-99) the approach needs to establish that conservative values have been selected and analyzed.

17. Appendix C, Section 1.0 The text states that "The K4 values were selected to Provide a justification for using nonconservative values for Tabulated Data, Page C-2, represent the central tendency of the site-specific data... distribution coefficient in a deterministic analysis.

second paragraph " In its discussion of Deterministic Analyses, NUREG- RESPONSE: The probabilistic uncertainty analysis 1757, Volume 2, states that "it is important for the addressed the use of conservative distribution coefficient licensee to demonstrate that the single reported estimate values for the dose modeling in the DP. See also the ofpeak dose is likely to be an overestimation of the actual response to comment 14.

values based on peak dose." It is unclear how choosing Kd the central tendency of data will result in "an overestimation" of dose.

Radiological Status of the Site: Understanding the nature and extent of contamination is vital to planning for decommissioning. The following comments identify-data gaps and suggest a path for resolution. (Comments specific to the source and radionuclide inventory of the NPGP are provided below.)

18. General In the Phase 1 DP, there are multiple references to specific Describe the basis for developing anticipated/expected radionuclide ratios and inventory projections (i.e., source- radionuclide ratios, inventory projections and transport term assumptions) and suppositions regarding the mechanisms for WMAs on the North Plateau.

associated inter- and intra-transport mechanisms for the Site wide characterization surveys will improve the various WMA/units on the North Plateau. The basis for radionuclide inventories and can support the definition of Page 11 of 39

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1., e!ig)re)  ; oCommentossProposed Resolution andDOE Response agep establishing ratios is not well defined. radionuclide ratios and the understanding of transport mechanisms for each WMA.

RESPONSE: Existing radiological and hydrogeological data collected during facility and environmental characterizationprograms at the WVDP were the basis for the radionuclideinventory projections, ratios,and transport mechanisms describedin the WVDP Phase I DP.

Additionalfacility characterizationis plannedfor the waste tankfarm and the Process Building either before or during the implementation of Phase 1 decommissioning activities, which will supplement the existing facility radiological database.

The environmental radiologicaldatabase within the project premises will be supplemented with surface soil, subsurface soil, and stream sediment data that will be -collectedas part of the characterizationprogram designed and implemented to support Phase 1 of the decommissioning. This characterization program will be defined in the CharacterizationSample and Analysis Plan. A copy of the goals for this characterizationprogram was provided to NYSERDA and other agencies The CharacterizationSample and Analysis Plan is being prepared according to the objectives, guidance, and requirements described in Section 9.4 of the DP and the CSAP goals developed by Argonne NationalLaboratory.

19. Pages 4-35 and Table 4-12, "Above-Background Concentrations of Describe how representative isotopic profiles for WMA 1 4-36, Table 4-12 Radionuclides in Subsurface Soil at WMA I," identifies will be established. What surface and subsurface soil three sampling activities that provided the subsurface soil characterization will be performed?

data for WMA 1. Due to the limited data and the Page 12 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject

.eun FPue ~ CTable, rposed Res~olu tio i andDERsoe Pae#(PargAph Line).- ~

variability of this data (e.g., Cs-137 is not present in one RESPONSE: The surface soil, subsurface soil, and stream location, and is two orders of magnitude different in the sediment characterizationprogram to support the WVDP other two locations, etc.), conclusions related to Phase I Decommissioning will be defined in the radionuclide distributions are speculative. Additional Characterization Sample and Analysis Plan. More sampling in WMA 1 is needed to confirm the different definitive isotopic profiles will be developed once the isotopic waste profiles present in this area. characterizationsampling program is completed. See also the response to comment 18.

20. Page 4-36, The second paragraph states "No gross alpha This statement should be revised or removed.

second paragraph concentrations or concentrations of alpha-emitting. RESPONSE: No change is planned. Gross alpha radionuclides were observed at concentrations above concentrations were measured at each of these locations backgroundin surface soilfrom WMA 2." This statement and depth intervals and none were observed above is inaccurate as surface soil samples were obtained from background concentrations. While Ra-224 and Ra-226 Borehole Nos. 1, 2, 4, 8, 10A, 13, 14 and 33A in WMA 2; were the only alpha-emitting radionuclides measured at and of these locations, the only alpha analyses performed these locations, the gross alpha measurements suggest that were for radium (224 and 226) (see RFI, Volume 4, Low- alpha-emitting radionuclides that were not individually Level Waste Treatment Facility, Radiological Data). measureddid not exceed their backgroundconcentrations.

21. Pages 4-36 and Table 4-13, "Above-Background Concentrations of Additional characterization of soils in WMA 2 (including 4-37, Table 4-13 Radionuclides in Surface Soil From WMA 2" lists only analyses for alpha-emitting radionuclides) is needed to better concentrations of Cs-137 and Sr-90 for a number of understand the nature and extent of the contamination.

borehole locations in WMA 2. No data, however, are RESPONSE: Soil samples from WMA 2 were analyzed for provided for alpha-emitting radionuclides in the surface gross alpha and Ra-224 and Ra-226, and none of these soil. Additional sampling and analyses of different soil analyzed samples exceeded background concentrations.

depths and locations can provide more accurate Additional soil sampling and analysis will be performed in information on the radionuclide concentrations and WMA 2 to support Phase I of the decommissioning. The distribution in the WMA. sampling locations, number of samples, and analyte list will be described in the CharacterizationSample and Analysis Plan.

22. Page 4-41, This section states that "As seen in other areas, elevated Additional characterization of the radionuclide distribution in fourth paragraph levels of Cs-137 in surface soil were most likely surface soils from all WMAs is needed. Include the new attributable'toairbornedeposition (see Section 2)." Due background surface soil data along with the one existing Page 13 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject Se ti n,- ..... .. ...... ... ..... .... ........

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to the small number of surface soil samples taken, and the background location as this will support the defensibility in even smaller number of analyses performed on these determining a representative background sample.

surface soil samples, it is speculative to identify the source RESPONSE: The referenced text in the DP was revised to of Cs-137 solely as the airborne releases. specify "may be". However, it should be noted that the WVDP did not perform any radiologicaloperations in the referenced area and cesium is not a significant component of the northplateauplume.

23. Page 4-42, Table 4-18, "Above-Background Concentrations of Revise Table 4-18 to include the data from the 2008 Table 4-18 Radionuclides in Surface Soil, Sediment, and Subsurface background sampling activity. If BH-38 values are above the Soil at WMA 5," lists the background location (BH-38) as newly calculated background values, include BH-38 in the being above-background for radionuclides in surface soil, table, but add a qualifying statement indicating that it is one sediment and subsurface soils: in WMA 5. Why is the of the locations used to calculate background.

background location listed as being above-background? RESPONSE: Table 4-18 indicates that the concentrationof Also, in 2008, additional background soil samples were Cs-137 in surface soil at BH-38 exceeds surface soil obtained to determine more representative values for background concentrations. BH-38 is a background background. location for subsurface soil and not for surface soil The surface soil background locations are the offsite air sampling stations located at the perimeter of the WNYNSC to which the surface soil sample from BH-38 was compared. The 2008 background sampling results were evaluated and incorporated into Revision 2 of the DP.

However, the 2008 results did not change the interpretation presented in Revision 0 of the DP.

24. Page 4-43, The paragraph states "Ratios to Cs-137for Pu-238, Pu- Provide clarification for the assertion that the Fuel Receiving third paragraph 239/240, and Am-241 were similar for subsurface soil and Storage Building subsurface location is more central to samples taken near the Utility Room and the Fuel the NPGP.

Receiving and Storage Building (about 0.03 to 1, 0.04 to RESPONSE: Based on current groundwater mapping, the 1, and 0.2 to 1, respectively). However, the Sr-90 to Cs- FRS is more central to the NPGP than the Utility Room.

137 ratios for each were strikingly different.. Near the Groundwaterin the vicinity of the FRS, which is located in Utility Room, the ratio was about I to 1, but near the Fuel the "core" area of the plume, has a significantly greater Receiving and Storage Building the ratio was 133 to 1, Page 14 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject Sectioneý i(Tble, oFgr)Cmment Proposed Reouto DOE Repos -n suggesting that the Fuel Receiving and Storage Building concentrationof Sr-90 than Cs-137 resulting in the ratio of subsurface location was more central to the north plateau 133 to 1. The similarity in radionuclide ratios for the groundwaterplume." Given the historical leaks and spills immobile radionuclidesbetween the FRS and Utility Room associated with the general area between the Utility Room may be the result offalloutfrom pre-1963 nuclear weapons and the FRS, the groundwater flow paths for these areas, testing rather than additional radionuclide sources in the and the partition coefficient (Kd) values for Cs-137, Pu- area.

238, Pu-239/240 and Am-241 being significantly different than Sr-90, it is difficult to definitively state that the difference in the ratio of Cs-137 to Sr-90 is due to the Fuel Receiving and Storage Building being more centrally located to the NPGP. Specifically, Cs-137, Pu-238, Pu-239/240 and Am-241 are relatively immobile radionuclides and would not be expected to have traveled far from their source. The radionuclide ratios are approximately equal for both areas, but the reputed source of the NPGP is located closer to the Fuel Receiving and Storage Area. Why are the radionuclide ratios for the relatively immobile radionuclides similar near the Utility Room (which is located cross-gradient to the reputed source and at a greater distance from the source)? Either the source of these radionuclides is larger than anticipated (i.e., larger volume) or there are other sources that contributed these radionuclides throughout this region.

25. Page 4-44, Table 4-19, "Above-Background Concentrations of Perform additional sampling/radionuclide analyses of the Table 4-19 Radionuclides in Surface Soil, Sediment, and Subsurface areas in WMA 6 for inclusion in the scope of this DP.

Soil at WMA 6" lists sediment and borehole locations that RESPONSE: The extent of surface and subsurface soil exceeded background concentrations. Given the limited characterization and associated analytical parameters in data for this area and that the relative ratios for these WMA 6- will be identified in the CharacterizationSample radionuclides vary by location, additional sampling of and Analysis Plan.Please see the response to comment 18.

WMA 6 is necessary.

.26. Page B-7, The use of groundwater well WNW0204 as the Use WNW0402 as the background sample location for the Page 15 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject Section,1/4 (able,-Figure) *'~' Comment e~Prposed ~esolutioadDOi epos Pa# hý'F"9Line)

Section 1.4, first paragraph background sample location for the Lavery Till-Sand Unit Lavery-Till Sand Unit data and recalculate the background and Page B-15, Table B-7 is incorrect; WNW0402 has been identified in the data using this location. Revise Table B-7. Reevaluate the quarterly groundwater reports as the background location groundwater data originally identified as not having for this geologic unit. This well also appears to be exceeded background, and verify that the revised data still downgradient of a number of areas/facilities that could does not exceed background.

influence this location. Finally, the more recent data RESPONSE: Well WNWO204 is the correct background suggests that WNW0204 is higher in activity for gross well for the Lavery till sand. The aerial extent of the Lavery alpha and tritium, which could potentially bias the till sand was revised downward in 2008. Well WNW0402 background values high. Remove WNW0204 from the has been re-classifiedas a sand and gravel unit well. There data set and data source locations in Table B-7, are four wells currently monitoring the Lavery till sand:

"Groundwater Background Radionuclide Concentrations WNW0202, WNW0204, WNW0206, and WNWO208.

for the WVDP."

27. Section 5.1.3 The DP focuses on the remediation of WMAs 1 and 2, and Include the northern end of WMA 10 in the. sitewide Page 5-10 leaves the remediation of other soil and sediment as an characterization. If contamination is present, remediation of option (Footnote 3, Page 5-10). Figure 4-6 (Page 4-31) the area, as a Phase 1 activity, can reduce the potential of shows gross alpha and gross beta contamination in surface additional contamination migrating into WMA 1.

soil in the area (WMA 10) to the west of WMA 1. Given Incorporate remediation of areas (i.e., that may the direction of groundwater flow (Figure 5-4), surface recontaminate/impact WMA 1) as part of the Phase 1 contamination could impact the groundwater in this area activities.

that flows into WMA 1 can contribute, over time, to the RESPONSE: The Characterization Sample and Analysis dose in WMA 1. What does the potential effect of Plan will provide for characterization of surface and contamination in the WMA 10 have on calculating subsurface soil in the northern end of WMA 10. However, DCGLs for WMA 1? groundwaterfrom nearby wells WNW0402 and WNW0401 In the mid-1 990s, several "AA" trailers and trailers on the do not suggest that this surface soil contamination has west side of "Trailer City" were removed, and a portion of affected downgradientsoil andgroundwater.

the chain-link fence was moved east. The area between Describe available data for the area west of "Trailer City" the main parking lot and the fence was covered with grass. (i.e., where trailers were removed and the fence relocated).

Are there existing data to verify that this area will meet Include this area in the sitewide characterization as the site decommissioning criteria or will a Final Status appropriate.

Survey of the area be performed? RESPONSE: Available data from this area was evaluated and included in Revision 2 to the DP as a note to Table 4-Page 16 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 Decommissioning Planfor the West Valley DemonstrationProject KK "etion,. .-

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Source and Radionuclide Inventory of the North Plateau Groundwater Plume: The planning for the removal of contaminated soils from WMA I is supported by the understanding of the events contributing to the contamination and data describing the extent of the contamination. The following comments focus on clarifying information and data that help to characterize the source area of the NPGP.

28. Page 2-35, third paragraph The first sentence in this paragraph states that "An order- Clarify that Table 2-16, an estimate of the remaining of-magnitude estimate of the radionuclides and amounts inventory, only presents the-decay-corrected values from the released by the acid leak, and the estimated remaining Westcott (1998) report.

amount in 2011, are presented in Table 2-16. " In the RESPONSE: Note (1) for Table 2-16 was expanded to preceding paragraph, the argument was made that the clarify this matter asfollows:

more mobile isotopes (e.g., Sr-90 and tritium) were NOTE: (1) From Westcott 1998. Note that the values in migrating away from the source; therefore, the remaining Table 2-16 are based on a 1998 estimate of radioactivity in inventory (at the source) is actually a function of two soil and groundwater beneath and downgradient of the physiochemical processes: (1) decay, and (2)

Process Building that did not take into account radioactivity mobilization in the saturated zone. Table 2-16 (Pages 2-in groundwater that may have seeped to the surface and 35 and 2-36) attempts to estimate inventory solely based entered ditches or streams.

on decay. The text and the table should clearly indicate that the estimate of current inventory (in 2011) is based on decay-corrected values from the Westcott report and does not account for any inventory that has already migrated downgradient or off site.

29. Page 2-35, Table 2-16, "Released RadionuclideActivity Estimatesfor As characterization data from the source area of the plume Table 2-16 the North Plateau Plume," cites a reference by Westcott are obtained, the radionuclide inventory and radionuclide 1998. The D. R. Westcott work utilizes characterization ratios should be updated. The revised inventory and ratios data that was available for Tank 8D-2 to estimate the need to be used in the modeling and projections of the radioactivity present in the NPGP. The plume is a result nonsource area of the plume.

of one or more leaks in the acid recovery system, which RESPONSE: Comment noted. Radionuclide inventories may not be accurately represented by Tank 8D-2 data. and ratios will be updated provided the source area is Data obtained in the leaking source areas of the acid sampled during the soil characterizationprogram. The recovery system are likely more indicative of the extent of surface and subsurface soil characterizationand radionuclide inventory and radionuclide ratios for the associated analytical parameters in WMA 1 will be Page 17 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject Sectionj, * -

('fbl, Fgue)Comen~~Proposed Rsolution and DOE Response Page # (Paragraph, Line) 'T NPGP. identified in the Characterization Sample and Analysis Plan.

30. Page 2-36, second The statement that "In addition to the known acid spill Provide justification to support the assertion that these paragraph affecting the northplateau, during NFS operationsseveral "unintended operational releases" are so localized that they incidents such as inadvertent transfers of higher-than- have not contributed to the plume.

intended activity occurred in the interceptor basin system RESPONSE: The areafrom Lagoon 1 to the vicinity of the upstream of the lagoon system (Lewis 1967, Taylor 1967, Process Building is not considered part of the NPGP.

Wischow 1967). Documented accounts of leakage and Groundwaterflow in this area is towards the lagoons in spills in the area (Lewis 1967, Carpenter and Hemann WMA 2. Contaminated soil in this area resulting from 1995) corroborate the generally elevated observed "unintended operational releases" will be removed as part subsurface soil contamination in the area west of Lagoon of the Phase 1 excavations in WMA I and WMA 2.

1 to the vicinity of the Process Building. Such localized subsurface contamination can be attributed to these unintended operationalreleases," needs clarification. Are the documented releases/spills that contaminated the subsurface soil from the Process Building to the interceptor system and Lagoon 1 considered contributors to the total radionuclide inventory of the NPGP?

31. Page 2-39, In Table 2-17, "PrincipalRadionuclides in Major Spills Revise this section to be consistent with the information Table 2-17 Occurring During NFS Operations," the last column in provided in Chapter 3, Section 3.11.5.1 of the DEIS.

the last row states that: "Leakage did not result in any RESPONSE: Table 2-17focuses on events known to have known release to the environment." While it is unknown environmental impacts and those for which environmental whether this release affected the environment, arguably, it impacts likely occurred. Informationfrom Section 3.11.5.1 is also unknown that it did not. Specifically, the transport of the DEIS was added to the table as appropriate in mechanism (i.e., an expansion joint) discussed for the Revision 2 to the DP as follows:

primary leak also exists in this location. This leak "Leakage resulted in 555 gallons of liquid waste entering occurred on the first floor, not the fourth floor of the the ARPR sump and draining to the Old Interceptor building (as with the primary leak), and the volume (sufficient to read >- 100 mR/hr at the interceptor), and recovered by the interceptor (in addition to what remained rsuiring to bad to theProce ptor),ngfo in Tank total 7C-5) released volume accounts by for this approximately one third event. Finally, of the historical requiring treatmenL pumpout This eventback led to the Processof Building to installation 12 inchesfor of total v rconcrete shielding on the Interceptor floor. A radiation Page 18 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject Section, Lie

-(Table,'Figu;re!) Co'minent., ~ ~Proposed Resoilution and DOE Response Page # (Paragraph, e accounts attribute the poor condition of the floors and level of 408 mR/h was measured in the Interceptor in common wall between the Acid Recovery Pump Room 2003."

and the Off-Gas Blower Room to numerous acid leaks/spills. These accounts detail the addition of six inches of concrete to level the floor in the southwest corner of the Off-Gas Blower Room after it was destroyed by acid. In addition to leveling this floor, the concrete provided shielding from the high dose emanating from this comer (Riethmiller, 1981).

32. Section 3.7.7 Numerical Analysis Techniques includes a brief reference Discuss the groundwater model calibration and describe the Page 3-72 to modeling of the NPGP using both 1994 plume sensitivity of the model to changes in source concentration.

concentration data and source activity of 500 Ci of Sr-90. How does the sensitivity of the groundwater model affect the The text goes on to describe how model calibration was calculation of DCGLs?

performed. Based on Section 2.3.1, Page 2-35, the source RESPONSE: Section 3.7.7 was completely revised to of the plume in 1972 included approximately 200 curies. descrbe the three dimensional far-field and near-field The text, in Section 3.7.7 lacks a discussion of how a groundwater flow and transport models developed to variation in the source concentration affects the support the preparationof the decommissioning EIS.

calibration of the groundwater model. The sensitivity of the groundwater model described in Section 3.7.7 does not have any effect on the calculation of the DCGLs which are derivedfrom through the use of the RESRAD model.

33. Page 4-13, The text states "These data were used for all Provide: the technical rationale for using acid third paragraph, radionuclides of interest in spent fuel except U-235 and recovery/recycling lines and data from the Acid Recovery Spent Fuel Distribution U-238, which were derived from NFS records for Pump Room to calculate the spent fuel profile ratios. Also, recovered and unaccountedfor losses of uranium, and U- provide the technical rationale for why the Acid Recovery 232, U-233, U-234, and U-236, which were established Pump Room data are conservative.

based on analytical results showing the U-232 to U- RESPONSE: When the spentfuel distribution was 235/236 ratios from samples collected in the Acid developed in 2002 (Mahoney 2002), analyticaldatafor Recovery Pump Room of the Process Building." What is many areasof the Process building were limited. Datafrom the technical basis for using the ratios from the acid the ARPR were used in estimating the distributionof recovery/recycling portion of the reprocessing activities, Page 19 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject Section,~r~

(Table, figure) Comment Proposed Resolution and DOE Response Page #-(Paragraph, Line) instead of using ratios from areas where product uranium radionuclidesas indicatedin Table 2 in the extractions occurred (e.g., Extraction Cells 1, 2, and 3, Mahoney memo. This memo states that "The uranium and the Product Purification Cell)? The analytical data bounding values may need to be updatedas other obtained from sampling the Acid Recovery Pump Room information is collected during the facility characterization would likely represent contaminants in spent acid that effort."

leaked or spilled from process lines, rather than higher Additional data are now available that would produce concentrations of product materials prevalent in other somewhat different ratios.For example, analytical datafor areas of the Main Plant. Also, what is the basis for stating samples collectedfrom the walls andfloorof the Product that these ratios are conservative? Purification cell, as reportedin Table 1 of RIR-403-022, would produce higher ratiosof U-232, U-233, U-235, and U-236 to U-238.

This matter was evaluatedfurther as Revision 2 to the DP was prepared. Changes were made on pages.4-14 and 4-15 to address this matter. Revisions to the uranium radionuclideinventory estimates were determined not to be useful Site Features: A description of site features is required in the DP. The following comments focus on data gaps in the information describing site features.

34. Section 3.6.3, Page 3-65 In discussing the probable maximum flood, the cited Use the most current information to describe the influence of reference is a report that was generated in 1983. Why flooding at the site.

doesn't this plan use the most recent probable maximum RESPONSE: Section 3.6.3 on page 3-68 of the DP was flood model developed in 2008 and cited in the current updated to include more recent information on the probable DEIS? The reference is URS, 2008, "Memorandum to maximum flood describedin the.2008 DEIS.

Science Applications International Corporation,

Subject:

Probable Maximum Flood Inundation Study," West Valley, New York, August 28.

35. Section 5.1.6, The first paragraph of this section and Figure 5-5 Provide a framework for the significance of the 1994 work Page 5-15, reference the 1994 Dames and Moore North Plateau by Dames and Moore, and comment on flow observed today Figure 5-5 Groundwater Seepage Survey. A text box in the Figure from seepages along Erdman Brook and Frank's Creek.

states that "the 3 seepage points near the lagoons . . . Incorporate more recent flow data for the seepage points, if Page 20 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject (abeFigure) Coment, co ~: ~ 'A osed Resolution 'and DOE Responýse*.;

i-Page #(argpf, r Line) exhibited little or no flow in .1994. The information available. Update the map as necessary.

shown on this figure is now 15 years old. What is the RESPONSE: The 1994 Dames & Moore report was the last significance of the flow characteristics in 1994? Have the comprehensive seep survey performed at the WVDP.

locations of seeps been checked in the field to confirm SAIC/WSMS evaluated whether any additional seep data that the information on this map is still accurate? " has been collected since 1994 and found no additional data were available.

Site Characterization: Adequate site characterization is needed in the planning for remediation and defensible final status surveys verifying that any residual contamination meets the requirements of the West Valley policy statement andlOCFR20 Subpart E. The following comments identify limitations in characterization data.

36. Page 9-6, Characterization Surveys are identified in Section 9.2.4. The four cited survey activities should be considered scoping Section 9.2. 4, second .The second paragraph states, "Four WVDP surveys and the data from these survey activities can be used paragraph characterizationsurvey programs have been completed: to design the Characterization Surveys as defined in (1) the characterizationprogram for the underground MARSSIMs.

waste tanks, (2) the Facility CharacterizationProject, (3) RESPONSE: No change made. The text in Section 9.2.4 a series of Resource Conservation and Recovery Act does not identify the four referenced "Characterization (RCRA) facility investigations performed in the 1990s, Surveys" as being MARSSIM type characterizationsurveys.

and (4) investigations of the north plateau groundwater These four surveys were used to characterize the nature plume using a Geoprobe." The survey activities and extent of residual contamination in portions of the completed thus far do not appear to have the necessary WVDP. Each program had detailed survey designs and components as specified under NUREG-1575, the Multi- stringent QA/QC requirements that controlled these Agency Radiation Survey and Site Investigation Manual characterizationprograms.

(MARSSIM) to be identified as "Characterization.

The Characterization Management Plan for the Facility Surveys." Specifically, these. activities did not include CharacterizationProject included all applicable MARSSIM survey designs that ensured that: . representative guidance, based on the peer review team's evaluation. The background/environmental media specific measurements work plan for the RCRA Facility Investigation was were obtained, acceptable Type I and Type II errors were reviewed and approvedby the NYSDEC.

identified, and contaminant variation in each survey unit was adequately addressed (using statistical testing of the survey unit).

Similarly, language on Page 8-8 references the underground waste tank farm data as being similar in Page 21 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject Resolutio>. -Re~n r(Table,.ig Comment-: A.- .. Proposed Resolution and DOE Response

,ae# ,(Pararp ie ~.

quality to MARSSIMs. Clarification of what "similar" means should be provided.

37. Page 9-15, This section defines the use of "In-Process Surveys" and Provide the detailed Quality Assurance requirements for Section 9.5 states that these surveys would be performed to "... conducting "In-Process Surveys."

determine when remediation to field goals . . has been RESPONSE: The response to RAI 9C3 describes changes attained." What are the QA requirements for conducting made to Section 9.5 of the DP to provide additionaldetails this type of survey? Specifically, since this type of survey on in-process surveys including quality assurance is not defined in MARSSIMs, are the QA requirements provisions. These changes appear on pages 9-20 through 9-consistent with Characterization Surveys and/or Final 23 of Revision 2 to the DP.

Status Surveys, and how will the results be utilized for final status of the survey unit?

38. Page 9-31, last paragraph Characterization of the soils remaining in WMAs 5 and 6 The soil areas remaining from excavation of the foundations, and (after the excavation of the foundations, slabs, hardstands slabs, hardstands, and gravel pads in WMAs 5 and 6 need to Page 9-32 and gravel pads were removed, prior to the start of be characterized.

decommissioning) need to be conducted. Historical RESPONSE: The Characterization Sample and Analysis records identify these areas as potentially impacted by Plan will provide for soil samples to better determine the radiological constituents. Little data exists to help extent of contamination and the radionuclidedistributions determine the extent of the contamination and whether the in these areas.Please see the response to comment 18.

radionuclide distribution is the same or different than other areas of the site.

39. Page 9-32, Section 9.7.5 details the characterization activities defined Describe the process for characterizing the subsurface piping Section 9.7.5 for WMA 6: the Central Project Premises, which the WMA 6.

encompasses the Sewage Treatment Plant, the RESPONSE: There are no plans for characterizing Equalization Basin, the Equalization Tank, the two subsurface piping for those facilities identified in WMA 6.

demineralizer sludge ponds, the south Waste Farm Test However, the ends of lines at the sides of the WMA 1 and Tower, floor slabs and foundations and the underground WMA 2 excavations are required to be characterizedwhen structure of the Cooling Tower (which has been identified the slurry walls are installed (now pages 7-26 and 7-35, as being impacted by radioactivity). The DP does not, respectively). This effort will provide characterizationdata however, identify the characterization process for the for undergroundlines in northern end of WMA 1.

subsurface piping associated with this waste management Page 22 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject Section/~~3/4 i**!*o"*, ;5** :*:* C*iomment * **,Proposed Resolution and DOE Response Page # (Paragraph Line area.

-!Section;--. -

-(It~Table;Fgr) Coment Proposed Resolutio aDDE Response Page P#rp(iNne

40. General The tank and vault drying system is important to help Revise statements in the Executive Summary, and Chapters maintain the integrity of the high-level waste .(HLW) 1 and 3 to more accurately describe the tanks' contents both tanks. Throughout the DP, statements are made about during and after the interim end state. Remove all language the tank and vault drying system being operational in the from the DP that states the tanks will be empty (i.e., not interim end state, and the tanks being empty. Such contain liquids) in year 2011.

statements are inaccurate. The tank and vault drying RESPONSE: The proposed changes were made in system may be operational before 2011, but significant Revision 2 using the latest available information on tank heels consisting of liquids and solids (sludge) will remain status andplans for installationof the tank and vault dry in the tanks well beyond the interim end state. system.

"The tanks and vaults are expected to be in a dry condition several years after the start of Phase 1 of the decommissioning. The Tank and Vault Drying System will then maintainthe tanks and vaults in a dry state."

41. General While NYSERDA is identified as the owner on the Revise the text on Pages ES-10, 1-4 and 2-4 to clarify the Provisional Operating License Number CSF-l, transition of responsibility for operations at the site to be NYSERDA has never had responsibility for the day-to- consistent with the following: In 1976, Nuclear Fuel day operations of the reprocessing facilities. The text on Services informed New York State that it intended to leave Page 23 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject (Table, Fgr) * .r Comm ent -~ ~ Propo0sed`Resoludon~and DOE ,Respns Page ES-10 states: "In 1976, without restarting,Nuclear the reprocessing.business and not renew the lease when the Fuel Services withdrew from the reprocessing business initial term expired at the end of 1980. The West Valley and returned control of the facilities to NYSERDA, the Demonstration Project Act was enacted in 1980 providing successor to the New York State Atomic and Space for solidification of the. high-level liquid radioactive waste Development Authority." from reprocessing, then decontamination and decommissioning of the facilities used in the solidification s1-4 and 2-4. The text effort. In February1982, Nuclear Fuel Services transferred Similar text appears on Pages 2-4.site texton oemand possession of the reprocessing facilities to the U. S.

Page 2-4 explains that NFS remained the site operator Department of Energy (DQE)for that purpose.

until 1982, since no license amendments were made from 1976 to 1981. License Amendments 31 and 32 RESPONSE: The proposed changes were made in transferred the project premises to DOE, and terminated Revision 2 with minor editorialchanges.

the authority and responsibility for NFS (under the license) effective upon DOE's assumption of exclusive use and possession of the Project premises. While NYSERDA is identified on the CSF-1 as the owner of the property, NYSERDA has never had direct control of site facilities.

Executive Summary

42. Page ES-8, Waste In order for the decommissioning of the MPPB to be Add a brief discussion to the Executive Summary regarding Management Area 6 successful, the HLW canisters must be relocated to the transfer of the 275 HLW canisters to a new location on Waste Management Area 6 (WMA 6). Since the new the.Project Premises.

canister storage area is proposed for WMA-6, insert RESPONSE: The following text was added to Revision 2 dialog on the new interim storage facility (on Page ES-8) on page ES-13:

in the discussion on the WMA-6. "Before much of the work to remove the Process Building is undertaken, the 275 vitrified HLW canisters will be relocated to a new Canister Interim Storage Facility to be establishedon the south plateau. The canisters will remain there until a decision is made and implemented with regardto theirfinal disposal" Page 24 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject CVoimment rpse R?esolution' and DOE Re"sp~ons~e';

, ý Section 1

• 43. Page 1-5, second paragraph The information related to the leak (which is the source Revise this section to state, "This contamination likely of the North Plateau Groundwater Plume [NPGP]) is resultedfrom multiple leaks of nitric acid solution...

inconsistent with Table 2-17 (Page 2-39) of this DP as RESPONSE: The proposed change was made in Revision well as Chapter 3, Section 3.11.5.1 of the 2008 Draft 2 on page 1-5.

Environmental Impact Statement (DEIS).

Documentation exists to support that multiple leaks occurred during the acid recovery process, thereby contributing to the NPGP.

44. Page 1-6, first paragraph The information related to the ventilation system Revise this section to state, "The cesium prong is an accident is inconsistent with Table 2-17 (Page 2-40) of impacted area that extends northwest of the Process this DP and Chapter 3, Section 3.11.5.1.of the 2008 Building as a result at least two ventilation system accidents DEIS. Specifically, there were at least two ventilation that occurred in 1968."

system accidents that contributed to what is known today RESPONSE: The proposed change was made in Revision as the "cesium prong." 2 on page 1-6.

45. Page 1-9, Section 1.6, Project In the discussion on implementing plans, the list should Add "Waste Management Plan" to the list of implementing Management and include a "Waste Management Plan." Per DOE Order plans in Section 1.6.

Organization 435.1(4), a Waste Management Plan is needed to ensure RESPONSE: The proposed change was made in Revision that "DOE radioactivewaste management activities shall 2 on page 1-10.

be systematically planned, documented, executed, and evaluated."

46. Page 1-11, Section 1.7, The DOE .Policy 450.4, Safety Management System Incorporate ISMS requirements into the overall Health and Health and Safety Program Policy, should be included in the list of applicable Safety Program.

requirements. This policy requires incorporation of an RESPONSE: The proposed change was made in Revision integrated safety management system (ISMS) into 2 on page 1-12 (citing DOE Policy 450.4).

management and work practices at all levels.

Section 2 Page 25 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject

,Section,.

1' igue)

Tabe, ~ ~c1..:Co Mment ýNProposed Resolution andDOE Resons Page # (Prgrp, ie

47. Page 2-8, third paragraph This section states that "Neutralizing the acid high-level Revise this section to include actinide concentrations in the waste prior to transfer caused most of the fission product acidic HLW stream.

elements (the major exception was cesium) to precipitate RESPONSE: The proposed change was made in Revision out andform sludge at the bottom of Tank 8D-2." This 2 by addingthe following footnote on page 2-8.

statement is inaccurate as this acidic HLW contained "Actinides were also precipitated out. into the sludge.

more than the fission product elements, specifically Table 4-9 shows estimates of residual radioactivity in the actinides. When the acidic waste was neutralized during undergroundwaste tanks as of 2011.

reprocessing activities, concentrations of actinides precipitated out into the sludge and were found at the bottom of Tank 8D-2, where residual amounts remain today.

48. Page 2-10, Table 2-5, "Estimated Radionuclide Content (in Curies) Use the report Rykken, L. E., "High-Level Waste Table 2-5 of Tanks 8D-2 and 8D-4 at the Completion of Characterization at West Valley," June 2, 1986 for the Reprocessing," cites a reference by Eisenstatt, 1986. inventory in Tanks 8D-2 and 8D-4.

Historically speaking, the characterization report written RESPONSE: The Eisenstatt work was based on historical by L. E. Rykken in 1986 has been the more widely used data from process sample data fides. The two reports are reference for inventory data. The Rykken report is based considered to be essentially equivalent. However, the on physical sampling conducted for the HLW tanks, proposed change was made in Revision 2 for consistency while Eisenstatt's work does not appear to be based upon (Table 2-5 was revised accordingly).

any physical sampling.

49. Section 2.3.2, The text describes the placement of "atleast threefeet of Clarify the cleanup goals (for such areas as the drainage Page 2-37, third paragraph soil" over the contaminated sediments in the drainage channels), when conditions vary from the conceptual site channel. While the soil layer may exceed the one-meter model used to develop DCGLs.

thickness used for development of surface soil DCGLs, RESPONSE: Clarifying words were included in Revision 2 the remediation of areas like the drainage channel can as a new footnote on page 2-36. (The comment actually achieve the surface soil DCGLs. concernedthe thirdparagraphon page 3-36.)

"Section 5 describes cleanupgoalsfor surface soil (within one meter, or approximately 3 feet of the surface) andfor subsurface soil in the deep WMA 1 and WMA 2 excavations. Section 5 does not provide cleanup goalsfor Page 26 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase1 DecommissioningPlanfor the West Valley DemonstrationProject SProposed Resooution-and DOEesponse R

near surface soil contamination below 3 feet from the surface such as that expected to be present in the old drainage channel. Remediation of this contamination is not within the scope of Phase I decommissioning activities".

Page 2-39, In Table. 2-17, "PrincipalRadionuclides in Major Spills Amend the table as indicated.

Table 2-17 OccurringDuring NFS Operations," the second row of RESPONSE: The proposed change was made in Revision the last column states that "Line 7P-240-1-Cfailed inside 2. (This partof the table is now on page 2-38.)

the OGA in January 1968, and leakage drainedfrom the OGA through the ARPR to the underlying soils." This statement is inaccurate. The OGA would have drained through the Off-Gas Cell.

Section 3

51. Page 3-11, fourth paragraph The Groundwater Pump and Treat System description Correct the text.

states that there were two recovery wells in the western RESPONSE: Only two recovery wells are in use. No lobe of the plume. A third well was installed shortly change to the text was made.

after the start of the pump and treatment system began operation to improve the groundwater recovery from the plume.

52. Section 3.1.3, Page 3-12, fifth In the discussion on. treatment of contaminated Integrate updated information on the design of the swamp full paragraph groundwater in the swamp ditch, the text states "'The ditch mitigation measure into the document as suggested by permeable reactive barrier,which will be composed of footnote found on Page 3-12.

zeolite and aggregate and approximately 175 feet in RESPONSE: The information on the PRB was deleted in length, will be installed along the seepageface to reduce Rev 2 to the DP and the text describingthe PTW modified by ion-exchange the amount of Sr-90. . . " The results as follows:

from recent sampling activities (completed November "A full-scale passive permeable treatment wall is expected 2008) along the leading edge of the plume have shown "A full-scale passie Pe abe treatme issexpecte that the lateral extent of the contamination in the ditch is to be installed before Phase 1 of the decommissioning to much less than previously thought, and the lateral extent mitigate the off-site migration of Sr-90 contaminated of the mitigation is likely to be far less than what is groundwater in the sand and gravel unit in the north Page 27 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject currently published in this DP. plateau.

The permeable treatment wall is planned to be located in WMA 2 immediately south of the ConstructionDemolition and Debris Landfill in WMA 4 approximately perpendicular to the flow path of the north plateau groundwaterplume. It will be approximately 750 feet long in a northwest-southeast direction. The permeable treatment wall will be two to four feet thick, extend down into the underlying unweathered Lavery till, and be composed of granular zeolite to reduce Sr-90 concentrationsin groundwaterthrough ion-exchange.

Alternatives for potential mitigation of Sr-90 in surface water in the swamp ditch west of the Construction Demolition and Debris Landfidl and downgradient of the permeable treatment wall will be considered after installationof the permeable treatment wall" 4 .

53. Section 3.1.3, Page 3-21,third The last paragraph describing NFS Special Holes states Incorporate a discussion of how and where the investigation paragraph that contaminated soil, tanks, and other materials were waste was disposed in this section.

generated during the n-dodecane and tributyl phosphate RESPONSE: This information was added in Revision 2 on leak investigation in 1983; however, no mention of how page 3-22 as follows:

or where the waste materials were disposed of is "Low level waste generatedduring this removal was either included.

disposed of at the Nevada Test Site or the EnergySolutions Clive, Utah disposal site1, or remains in storage at the WVDP awaiting disposal Transuranic waste remains in storage at the WVDP awaiting a path for disposal as WVDP transuranic waste is currently not approved for disposalat the Waste Isolation PilotPlant."

1Which was the Envirocare Clive, Utah site at the time.

Page 28 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject T

Comment: 4 ~ProposedResolution and DO espoizse.

Y Section 3.5.5, Page 3-58, Additional historical earthquake data can be found in the Add additional earthquake data from the data compiled by Table 3-15 database for the National Center of Earthquake the National Center for Earthquake Engineering Research.

Engineering Research. Several earthquakes with RESPONSE: Six additional earthquake records were magnitudes greater than three are missing from the years addedto Table 3-15 on page 3-62 in Revision 2.

1954 and 1958.

Section 3.6.1, Page 3-63, The text states that the Bulk Storage Warehouse (BSW) The paragraph should mention that the BSW was used as a second last paragraph was used for general equipment and furniture storage PSF as well as a storage facility.

without mentioning its original use as the plutonium RESPONSE: This information was added in Revision 2 on storage facility (PSF). page 3-26 as follows:

"The Bulk Storage Warehouse was formerly called the Plutonium Storage Facility and it was used by NFS in the late 1960s and early 1970s to store plutonium nitrate solution recovered from its nuclear fuel reprocessing operation. The plutonium nitrate solution was contained in 10-liter doubly sealed polyethylene bottles that were stored in containers consisting of two 55-gallon stainless steel drums welded end-to-end and filled with concrete except for a void formed by an embedded 7-inch pipe. In 1974, the Plutonium Storage Facility was deactivated and all stored plutonium nitrate was removed. The building became known as the Bulk Storage Warehouse as it was used by the WVDP as a warehouse to storefiles and office equipment and was also used as a primary emergency assembly areafor the WVDP. "

Section 4

56. Page 4-3, last paragraph This section states "Available radiological data on Correct this information to indicate that additional sampling facilities,, systems, and equipment are generally and analyses will be conducted for the underground waste considered to be scoping data, with the exception of data tanks.

on the underground waste tanks, which have been RESPONSE: The information related to the underground Page 29 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject

- . K.... ~4Tabl;Fzgue)~~ ommnentProposed Resolution and DOE.Response

_0ge#~(agra .,h -

appropriatelycharacterized." This statement is incorrect waste tanks was clarifiedby adding information on page 4-for at least two of the underground waste tanks (HLW 21. The new information addresses current tank liquid Tanks 8D-1 and 8D-4), as these tanks have levels, expected additional characterization,and expected received/processed additional waste since the sampling changes from operation of the Tank and Vault Drying activities were performed. Further, these tanks have not System.

been physically sampled or analyzed, even though it is likely that there is residual solid waste affixed to the walls or physical structures in the tanks. All of the HLW tanks and equipment must be adequately characterized.

57. Page 4-15, Table 4-3, "Relative Fraction of Process Building Provide the technical rationale that supports the assertion secondfull paragraph Dominant Radionuclides" lists values that were that the geometric mean for the aboveground portions of the calculated based on geometric means of radionuclide MPPB is representative and conservative of below-grade of distributions in the various Process Building areas. The the MPPB.

first sentence of the second paragraph on Page 4-15 RESPONSE: The DP does not contain the assertion that states "There are substantial variations among the geometric means in Table 4-3 are representative and distributions in different areas." Why are geometric conservative for either the above-ground or below-ground means being calculated for the radionuclide distributions portions of the building. The table was included because it in the MPPB, and why are these distributions was considered to contain useful information. The conservative? In addition, will these aboveground statement about variationsbetween areas was includedfor MPPB ratios be used to determine the radionuclide ratios context.

below-grade of the MPPB?

58. Page 4-19, This section states that "The Old Interceptor is expected Include information regarding the release of radioactive sixth paragraph to contain a significant amount of radioactivitybased on contamination to the Old Interceptor in Chapter 2, Section availabledata, which include a gamma radiationlevel of 2.3.

408 mR/hr measured near the tank bottom in 2003 RESPONSE: This information was incorporatedin Table (WVNSCO 2003). As noted in Section 2, 12 inches of 2-17 on page 2-39 in Revision 2 asfollows:

concrete was poured on the tank floor by NFS as "Leakage resulted in 555 gallons of liquid waste entering radiation shielding. The New Interceptors and the the ARPR sump and draining to the Old Interceptor NeutralizationPit are both expected to contain low levels (sufficient to read >- 100 mR/hr at the interceptor), and of radioactive contamination." This statement relates to requiring pumpout back to the Process Building for a release that occurred on February 14, 1967, and should reatmeng phspout led to the of 12 ing f etreatment This event led to installation of 12 inches of Page 30 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject 2 ~ ~ ~~~~~~PrpsdRes-olu-tion 67izl

-;~ uzntd'DOE.Resvponse be included in Chapter 2, Section 2.3 "Spills and concrete shielding on the Interceptor floor. A radiation UncontrolledRelease of Radioactivity." level of 408 mR/h was measured in the Interceptor in 2003."

59. Page 4-20, Values for Am-241, Cs-137 and Pu-241 differ in Table Compare the values in Table 4-9 against the data in the 2008 Table 4-9 4-9, "Estimated Radioactivity in the Underground Waste DEIS (Appendix C, Table C-8), and update the table as Tanks" as compared to the 2008 DEIS. Even with appropriate.

rounding to two significant figures, these values do not RESPONSE: The differences were reconciled and Table agree. 4-9 correctedin Revision 2.

60. Page 4-22, Values in Table 4-10, "Estimated Radioactivity in the Compare Tables 4-10 and Table 2-21, and revise as Table 4-10 NDA," and Table 2-2, "Estimated Radioactivity in the appropriate.

NDA," (Page 2-45), are identified as containing the same RESPONSE: The differences were reconciled and Table information, yet do not agree. 4-10 was made consistent with Table 2-21 in Revision 2.

61. Page 4-34, All of the data from the 1998 Geoprobe sampling activity Utilize all of the 1998 Geoprobe data to establish that the Figure 4-8 was not included in the evaluation. Specifically, excavation area has been designed to capture all potential Geoprobe Points 29 and 80 appear to increase in Sr-90 below-grade concentrations exceeding the DCGLs.

concentrations as the depth increases, up to Include an evaluation of the 1994 Geoprobe data to support approximately 30-40 feet below-grade. The potential planning the excavation area.

increase in Sr-90 concentrations in these areas should be considered when designing the extent of the excavation RESPONSE: With regard to Figure 4-8, all available depth and area. subsurface soil data were considered in the evaluation

. (i.e., data from the 1993 RFI and 1994, 1998, and 2008 Also, an evaluation of the 1994 Geoprobe data may help Geoprobe sampling programs). However, only data from verify that the 1998 Geoprobe data has adequately points lying close to a cross-section through the plume in bounded the soil and groundwater conditions for the WMA 1 were included on the figure. For Revision 1, 2008 extent of the excavation depth and area. Geoprobe points were added and some historicalpoints were dropped (1994 points GP75, GP78, and GP80). The maximum concentration observed in the ULT from all Page 31 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject (Tb~jtue Comment.,.-- Proposed'R lution ýand DOE Response

ý Tb. e Figu e),z' Pg#(Paragraph, ie evaluated points (59 pCi/g, at GP3098, 38.5-39' depth) is shown on Figure 4-8. Sampling in 2008 at GP30-08 at the same depth showed a concentration of 1. 7 pCi/g (rounded to "2" on Figure 4-8). This location was not sampled in 1994.

The Characterization Sample and Analysis Plan will providefor additionalsampling at the planned boundaries of the WMA I and WMA 2 excavations so the resulting analytical data can be used to support the detailed design of the excavations.

Section 6

62. Section 6.1, Page 6-2 Under the section on Applicable Requirements and Evaluate whether the 1997 DOE Standard is applicable to Guidance, the author cites NUREG/BR-0058 as the this DP. The Standard does not appear to have been issued applicable source for the value in dollars for a person- as a final document - yet its use at other DOE sites is rem avoided. However, the DOE Standard (DOE-STD- widespread and well documented.

ALARA 1) titled "Applying the ALARA Process for RESPONSE: Based on this comment, the information in Radiation Protection of the Public and Environmental the draft DOE standardwas considered,as well as the case Compliance with 10 CFR 834 and DOE 5400.5 ALARA studies in the companion draft DOE-STD-ALARA2draft ProgramRequirements, Volume 1, recommends applying of April 1997. DOE-STD-ALARAidraft states that "For a range from $1,000 to $6,000 per person-rem for most cases, the $2000 perperson-rem recommended by the ALARA evaluations. Commission [NRC] is acceptable." Application of the

$6000 per person-rem upper limit in place of $2000 per person-rem would not change the outcome of the preliminaryanalyses described on pages 6-8.through 6-10.

A change to Section 6.2.2 on page 6-6 was made in Revision 2 to consider DOE guidance in DOE-STD-ALARAldraft.

Section 7

63. Section 7.3.2 What is the process for identifying a location for the new Describe the process and characterization activities that will Page 32 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject A(abe Fgie~ ~'h~e~t rpoe Resolution ad DER Rponse.-.

Page,# (ParagrphLie Page 7-10 Canister Interim Storage Facility? What soils be performed to identify the location for the new Canister characterization will be performed to support the Interim Storage Facility.

process? RESPONSE: Reference was made on page 7-12 to the new evaluation report -(WVES. 2009b), which describes the recommended locationfor the facility. WVES is providing for characterizationsamples at the planned location. The goals for the CharacterizationSample and Analysis Plan also include determining the contamination status in the area.

64. Section 7.3.3, Pages 7-14 Throughout the overall discussion of hazardous material Incorporate language into the DP acknowledging that through 7-19 removal (e.g., lead shielding) and equipment removal potential recycling/reuse opportunities may be pursued for from the Process Building, there is no mention of metal items and surplus equipment.

recycling. The DOE National Center of Excellence for RESPONSE: The proposed change was made on page 7-8 Metals Recycle, based in Oak Ridge, has been in Revision 2 asfollows:

instrumental in recycling lead and other metals within the "DOE policies on waste minimization, pollution DOE complex. Even items that cannot be free released prevention, and recycling will be followed as specified in have been reused within the complex at a significant D oE anu 435.1-1 Rioatie was Mnemen savings to the Department. In one year, the Center found DOE Manual 435.1-1 Radioactive Waste Management a use for over 54,000 metric tons of metal and equipment as radioacycoan a leadin accordanceswih asproate contaminate led i including suspect-contaminated lead, copper, hard drives, fume hoods, etc. At least two commercial facilities are licensed to receive contaminated lead and reprocess it into lead-lined shielded containers (beneficial reuse). At a minimum, this DP needs to make mention that recycling and reuse opportunities for metals and surplus equipment will be explored during decommissioning.

65. Section 7.3.3, Page 7-15, Removal of additional items (e.g., mercury switches, Address removal of additional hazardous materials that are Removing Hazardousand fluorescent lamps, circuit boards, and lead-based paint, likely to be present in the Process Building.

Toxic Materials etc.) that may be found in the Process Building should be RESPONSE: Additional information was included in addressed in this section. Revision 2 on page 7-17for hazardous materials removal, with clarifying words about those materials that would be Page 33 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject Section -

• (abeFigre - Comet ..- ~ roosed4 Resolution anddO Response

,,Page (PaagahLne acceptablein demolition debris.

66. Section 7.3.8, Page 7-24 When the underground waste lines are located and Provide more information on the steps to be taken if removed to make room for the installation of the barrier contamination, either radiological or chemical, is found in wall, what happens if the characterization measurements the liquid transfer lines. It may be prudent to remove the show radiological or chemical constituents in the lines if you already have the excavation open, crews remaining sections in the ground? Will the Project mobilized and waste boxes staged.

continue to remove sections of the piping, or simply cap RESPONSE: All of the lines within the excavation area the lines and leave the contamination underground? It is will be removed. This matter is addressedfor WMA 1 on unclear as to what would be done with the information page 7-29 andfor WMA 2 on page 7-36.

gathered from the characterization measurements.

67. Section 7.3.8, Page 7-25 The third bullet states that "Disposing of the Consider using the clean soil from the Slurry Wall uncontaminated soil at an appropriate offsite disposal construction as backfill for the soil and sediment excavation facility" will take place during construction of the slurry projects.

wall. It seems illogical to haul clean material off-site, DOE RESPONSE: Consideration was given to reuse of then turnaround and haul material from off-site back on- clean excavated soil duringpreparationof the Phase 1 DP.

site to fill excavations. Since clean backfill material However, it was determined to be better to use only clean (similar to native geologic material) is needed throughout imported soil as backfill to avoid potential issues relatedto Phase 1 activities, why not stage the clean soil from the verifying that excavated soil was totallyfree of radioactive slurry wall construction for later use as backfill material? contamination and later questions that might arise on this What criteria would be used to screen soil for use as subject.

backfill?

68. Sections 7.11.3 and 7.11.4, The discussion of cutting and decontamination methods Add a brief description on the liquid nitrogen-based cutting Pages 7-43 through 7-46 does not mention liquid nitrogen-based cutting and and decontamination systems.

decontamination systems. As the Nitrocisiont systems RESPONSE: The proposed change was incorporated in were essentially developed under a DOE-sponsored Revision 2 on pages 7-48 and 7-53 asfollows:

program at Idaho National Environmental Laboratory in "A liquid nitrogen cutting and cleaning system such as the early nineties and considered a cutting edge to technology, it may be prudent to mention them in this that offered by Nitrocision can be used to cut metal and section of the DP. Further, the WVDP is in the process decontaminate concrete without producing a secondary of procuring a Nitrocisiont' tool. waste stream. This system can be used either manually or Page 34 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase I DecommissioningPlanfor the West Valley DemonstrationProject Section, .-

'(Table, Figure) Comment Proposed Resolution and DOE Response Page # (Paragraph, Line) robotically and can be equipped with a vacuum capture system to collect decontamination debris. A Nitrocision liquid nitrogen cutting and cleaning system is expected to be in operation in support offacility deactivation work at the WVDP in late 2009 or early 2010."

69. Section 7.12, Figure 7-15, The proposed schedule does not capture the installation Incorporate the installation of the hydraulic barrier on WMA Page 7-49 of a hydraulic barrier on the northwest side of the WMA 2 into the schedule in a manner similar to that for the barrier 2 excavation. installation on WMA 1.

RESPONSE: The proposed change was incorporated in Revision 2 on page 7-56.

Section 8

70. Page 8-9, Section "Quality. This section states, "Acceptance criteria would be Revise this statement.

Control" established to ensure repeatability of the, data." RESPONSE: The proposed change was incorporated in Acceptance criteria do not ensure data repeatability, Revision 2 on page 8-9 as follows:

rather they assure that data are within certain bounding "Acceptance criteriawill be established to ensure data are conditions. Repeatability someformof in dpliate samples is determined by nalyeswithin appropriatebounding conditions."

some form of duplicate analyses.

Section 9

71. Page 9-20, The first sentence of the last paragraph states, "The Provide justification for usage of the reference cited in the last paragraph amounts of 1-129 and Np-237 that might be found in Phase I DP, instead of the historical reference. The surface soil contamination, if any would be small." rationale should confirm that the report represents a Although this statement is accurate given the relative conservative approachto the Np-237 concentrations on this amount of other radionuclides present; the Np-237 values site.

cited in the reference document for this Phase 1 DP are RESPONSE: Np-23 7 was dropped from the discussion, significantly less (. 50%) than the concentrations present which now appears on page 9-29. The statement about I-in other characterization documents for the site (Rykken, 129 remains correct -with the data revised as Table 2-5 L. E., "High-Level Waste ,Characterization at West Page 35 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject Section, -... . .

abe.Fge)Comment Proposed Resolu~tion aSdDOE Response

_____ Page# (Paragraiph,Line)~j .

Valley," June 2, 1986) from the Rykken report.

72. Page 9-28, fifth full The approach used to characterize subsurface piping in Explain the rationale for not including pipe probe paragraph; WMAs 2 and 5 differs from the approach used in WMA measurements to determine the total beta activity in WMAs Page 9-30, last paragraph 1 (Page 9-26) in that a pipe probe is used to determine 2 and 5. Are the beta contamination measurements total beta activity (along with smears samples for alpha conservative without this type of measurement?

and beta activity and exposure rates) in WMA 1, but is RESPONSE: The pipe probe measurements would be not employed for WMAs 2 and 5. more useful in WMA 1 because of the potentialfor much higher contamination levels in the subsurface piping in that area than for piping in W9MA 2 and WMA 5. Smears and exposure rate measurements would be adequate for WMA 2 piping. The measurementsfor WIMA 5 piping are aimed mainly at determining whether the piping had been contaminated or not. Smears and exposure rate measurements will be sufficientfor waste characterization purposes.

Section,,.

( Table, Figure) Editorial Comments Proposed Resolution and DOE Response Page # (P~aragraph,.Line):

Page ES-i First paragraph, third line, duplication of "Public Law. Remove one of the "Public Laws."

1 RESPONSE: This comment was incorporatedin Revision 2 to the DP.

2 Page ES-5 Fourth full paragraph, third sentence, "(Waste Identify Waste Management Area #12 on Figure ES-3 (i.e.,

Management Area 12) is partially within the project use the waste management outline identified in the legend),

Page 36 of 39

ýC. . ;

Responses to NYSERDA Comments on the Department of Energy's Phase1 DecommissioningPlanfor the West Valley DemonstrationProject Section, -- 4

1. (Table, Figure),)~ Ed'itorial Comment~ 'Proposed Resolution and DOE Response premises, as shown in FigureES-3." then insert a label for Waste Management Area #12.

RESPONSE: This comment was incorporatedin Revision 2 to the DP by identifying the Drum Cell on FigureES-3.

Page ES-8 Fourth full paragraph, third sentence, "the Drum cell,. The Drum Cell is not identified is not identified in Figure identified in FigureES-3." ES-3. Either change the reference to Figure ES-2 or label 3 the Drum Cell on ES-3.

RESPONSE: This comment was incorporatedin Revision 2 to the DP.

Page ES-16 Second paragraph, third line, "activities are designed.. Correct spelling of activities.

4 jj .*" " RESPONSE: This comment was incorporatedin Revision

_2 to the DP.

Page ES-19 First paragraph, fourth line, "would be no more that Replace "that" with than.

5 the dose..." RESPONSE: This comment was incorporatedin Revision 2 to the DP.

Table 1-1, WMA 1, third column, fourth paragraph, states that Revise text to read "north and east side... .

6 Page 1-19 the hydraulic barrier wall is installed on the "north RESPONSE: This comment was incorporatedin Revision and west side. " Based on the DP, the hydraulic barrier 2 to the DP.

wall will be installed on the "north and eastside. '"

Section 3.2.2, Page 3-32, 0st The paragraph states the population density in metric Units should be consistent, either use Imperial. (i.e.,

7 paragraph units of square kilometer immediately followed by standard or English units) or metric.

distances in miles. RESPONSE: This comment was incorporatedin Revision 2 to theDP.

Section 3.5.4, Page 3-53, In describing the dip of the fold limbs, an incorrect Make the correction in the text.

third paragraph symbol for degrees is noted. Change the symbol to RESPONSE: This comment was incorporatedin Revision Page 37 of 39

Responses to NYSERDA Comments on the Department of Energy's Editorial Comment~ [Propose Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject

1. STbefikure Page # (Paragraph, Line) -~V indicate that the folds are dipping a gentle 1 to 2 2 to the DP.

degrees.

Section 3.5.4, Page 3-57, A dip of 8945 degrees is indicated for these faults. Make the correction in the text.

9 fifth paragraph The number should have a decimal point indicating RESPONSE: This comment was incorporatedin Revision that it is slightly less than 90 degrees. 2 to the DP.

Section 3.5.5, Page 3-58, There are no units associated with the "Depth" column Add units for depth.

10 Tabl 3-15 in the table. RESPONSE: Km was added to the Depth column of Table 3-15 in Revision 2 to the DP.

Section 3.7.1, Page 3-67, The figures cited in this paragraph should be 3-6 and Correct the figure numbers in the text.

11 second paragraph 3-7 (not 3-5 and 3-6). RESPONSE: This comment was incorporatedin Revision 2 to theDP.

Section 5.3, Page 5-43 The first sentence states that the integrated dose Change the opening statement in this section to state that assessment was performed to "ensure that criteria options in "Phase 2" would not be limited.

used in Phase 1 remediation activities would not limit RESPONSE: This comment as,incorporatedin Revision 2 12 options for Phase 1 of the . proposed to the DP.

decommissioning." Given the discussion throughout the rest of this section, it would appear that the author meant to reference options for Phase 2.

Section 5.4, Page 5-49, Footnote (2) of Table 5-14 states that the CG, values Correct footnote (2) of Table 5-14.

Table 5-14 for surface soil and streambed sediment are the same RESPONSE: This comment as incorporatedin Revision 2 13 as the limited dose assessment DCGL values in Table to the DP.

5-11. Table 5-11 provides a summary of sensitivity analyses. The correct reference for the limited dose assessment DCGL values is Table 5-13.

Page 38 of 39

Responses to NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject (alFgr)ditoriiJ To'in Prpsed.iResoltidn and DOE Respon'se Page A-5 Checklist items 2 and 3 refer to Section 2.2.1 on Page RESPONSE: This comment was incorporatedin Revision 14 2-5. The Section should be 2.1.1. 2 to the DP.

Page A-6, Italicized note, "The locations of major spills are shown in the Correct the spelling of Figures.

15 first line Figurerslisted." RESPONSE: This comment was incorporatedin Revision 2 to theDP.

Page 39 of 39