ML110110072

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B. Bower Ltr Responses to the U.S. Nuclear Regulatory Commission Comments on Phase 1 Final Status Survey Plan and Characterization Sampling and Analysis Plan for West Valley Demonstration Project
ML110110072
Person / Time
Site: West Valley Demonstration Project, P00M-032
Issue date: 01/14/2011
From: Mcconnell K
NRC/FSME/DWMEP/DURLD
To: Bower B
US Dept of Energy, West Valley Demonstration Project
References
Download: ML110110072 (4)


Text

January 14, 2011 Bryan C. Bower, Director West Valley Demonstration Project 10282 Rock Springs Road West Valley, NY 14171-9799

SUBJECT:

RESPONSES TO THE U.S. NUCLEAR REGULATORY COMMISSION COMMENTS ON PHASE 1 FINAL STATUS SURVEY PLAN AND CHARACTERIZATION SAMPLING AND ANALYSIS PLAN FOR WEST VALLEY DEMONSTRATION PROJECT

Dear Mr. Bower:

The U.S. Nuclear Regulatory Commission (NRC) has reviewed the U.S. Department of Energy (DOE) October 21, 2010, response (ML103080093) to NRC comments on the Phase 1 Final Status Survey Plan (FSSP) and Characterization Sampling and Analysis Plan (CSAP) for the West Valley Demonstration Project. NRC has found DOEs responses adequate with the exception of the enclosed comments. We look forward to receiving DOEs revised FSSP and CSAP.

A copy of this letter will be available electronically for public inspection in the NRC Public Document Rook or from the Publicly Available Records component of NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html If you have any questions regarding this transmittal, please contact Chad Glenn at (301) 415-6722.

Sincerely,

/RA/ by P. Michalak for Keith I. McConnell, Deputy Director Decommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs

Enclosure:

NRC Comments cc: West Valley Distribution List

January 14, 2011 Bryan C. Bower, Director West Valley Demonstration Project 10282 Rock Springs Road West Valley, NY 14171-9799

SUBJECT:

RESPONSES TO THE U.S. NUCLEAR REGULATORY COMMISSION COMMENTS ON PHASE 1 FINAL STATUS SURVEY PLAN AND CHARACTERIZATION SAMPLING AND ANALYSIS PLAN FOR WEST VALLEY DEMONSTRATION PROJECT

Dear Mr. Bower:

The U.S. Nuclear Regulatory Commission (NRC) has reviewed the U.S. Department of Energy (DOE) October 21, 2010, response (ML103080093) to NRC comments on the Phase 1 Final Status Survey Plan (FSSP) and Characterization Sampling and Analysis Plan (CSAP) for the West Valley Demonstration Project. NRC has found DOEs responses adequate with the exception of the enclosed comments. We look forward to receiving DOEs revised FSSP and CSAP.

A copy of this letter will be available electronically for public inspection in the NRC Public Document Rook or from the Publicly Available Records component of NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html If you have any questions regarding this transmittal, please contact Chad Glenn at (301) 415-6722.

Sincerely,

/RA/ by P. Michalak for Keith I. McConnell, Deputy Director Decommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs

Enclosure:

NRC Comments cc: West Valley Distribution List ML110110072 OFC DWMEP DWMEP DWMEP DWMEP NAME GGlenn TRowe TCarter for PMichalak for PMichalak KMcConnell DATE 01/11/11 01/11/11 01/11/11 01/ 14/11 OFFICIAL RECORD COPY

West Valley Distribution List - Project Manager, Chad Glenn cc:

Stephen Gavitt, Director Bureau of Environmental Radiation Protection New York State Department of Health 547 River Street, Room 530 Troy, NY 12180 Barry Snyder, President The Seneca Nation of Indians William Seneca Building 12837 Rt. 438 Irving, NY 14081 Paul J. Bembia, Program Director West Valley Site Management New York State Energy Research and Development Authority 10282 Rock Springs Road West Valley, New York 14171-9799 Tim Rice, Chief Division of Solid & Hazardous Waste New York State Department of Environmental Conservation 9th Floor 625 Broadway New York, NY 12233-7250 Paul A. Giardina, Chief U.S. Environmental Protection Agency Radiation and Indoor Air Branch Region 2 290 Broadway New York, NY 10007-1866

Comments on U.S. Department of Energy Responses to U.S. Nuclear Regulatory Commission Comments on the Phase 1 Final Status Survey Plan for the West Valley Demonstration Project (December 2009)

Final Status Survey Plan (FSSP) Comment 5: It is stated in the response that:

DOE will use the CSAP data to establish the area-specific radionuclides of interest that will be carried into the FSS process. To be removed from consideration during the FSS process for a specific area, radionuclides would have to satisfy the following criteria:

  • Cannot be present above CGw standards
  • Cannot contribute more than 10% of the overall dose
  • Removal would not result in the changing of an SOR score from greater than 1 to less than 1.

Unresolved Concern:

It is not clear to what extent DOE will account for the dose contribution from radionuclides removed from consideration during the FSS process.

Path Forward:

DOE should ensure that the criteria listed in NUREG-1757, Volume 2, Section 3.3 (Insignificant Radionuclides and Exposure Pathways) are followed for any radionuclides removed from consideration and that doses from insignificant radionuclides are still accounted for. In order to account for the dose contribution from these radionuclides derived concentration guideline levels may need to be adjusted accordingly. A summary table provided in Section 3.3 reads as follows:

  • Licensees may eliminate insignificant radionuclides and exposure pathways from further detailed consideration. However, the dose from the insignificant radionuclides and pathways must be accounted for in demonstrating compliance with the applicable dose criteria.
  • Insignificant means no greater than 10 % of applicable dose criterion.
  • Ten percent is an aggregate limit; total dose contributions of all radionuclides and all exposure pathways considered insignificant should not exceed the 10 % limitation.
  • No additional limit on single radionuclides or pathways.
  • Licensees should also address potential for concentrations to increase during remediation activities.

Comments on DOE Responses to NRC Comments on the Phase 1 CSAP for the West Valley Demonstration Project (February 2010)

CSAP Comment 4: The NRC comment relates to the unresolved NYSERDA Comment 21 (Refer to NYSERDA letter dated November 23, 2010 - ML103350673). NRC anticipates the DOE response to NYSERDA.

Enclosure