ML110811039

B. Warren Ltr Citizens' Environmental Coalition (CEC) Comments on Phase 1 Characterization Sampling and Analysis Plan for the West Valley Demonstration Project (Wvdp) and West Valley Phase 1 Studies

ML110811039
Person / Time
Site:	West Valley Demonstration Project, P00M-032
Issue date:	03/18/2011
From:	Bower B US Dept of Energy, West Valley Demonstration Project
To:	Brenett Warren Citizens' Environmental Coalition, NRC/FSME
References
Download: ML110811039 (3)

Text

Department of Energy West Valley Demonstration Project 10282 Rock Springs Road West Valley, NY 14171-9799 March 18/ 2011 Ms. Barbara Warren, Executive Director Citizens' Environmental Coalition 33 Central Avenue, 3rd Floor Albany, NY 12210

SUBJECT:

Citizens' Environmental Coalition (CEC) Comments on the Phase 1 Characterization Sampling and Analysis Plan for the West Valley Demonstration Project (WVDP) and West Valley Phase 1 Studies

REFERENCES:

1) E-mail (105086), B. Warren to M. N. Maloney and B. C. Bower, "Phase I Studies," dated March 2, 2011

2) Letter (103112), B. Warren to B. C. Bower, "CEC Comments on the Characterization Sampling and Analysis Plan," dated May 11, 2010

3) Letter MNM: 103221 - 450.4, B. C. Bower to B. Warren, "Citizens' Environmental Coalition Comments on the Phase 1 Characterization Sampling and Analysis Plan CCSAP) for the West Valley Demonstration Project," dated July 7, 2010

4) Informal Memorandum (105089), B. C. Bower to B. Warren, "Nondeliverable Response Letter," dated July 22, 2010

Dear Ms. Warren:

The U.S. Department of Energy (DOE) thanks the CEC for its continued interest and input into the development of the "Phase 1 Characterization Sampling and Analysis Plan, West Valley Demonstration Project". The February 2010 draft of the CSAP is being revised considering technical comments submitted by the U.S. Nuclear Regulatory Commission (NRC), the New York State Energy Research and Development Authority (NYSERDA), and public stakeholders, including the CEC. The DOE expects to submit the next CSAP revision to the NRC in April 2011.

As you are aware, the DOE has responded to your earlier CEC correspondence and has atTorded you several opportunities to discuss the content of the CSAP with DOE and our consultant, Argonne National Laboratory (ANL). At the Citizen's Task Force meeting held on March 24.2010, which you attended via telephone, DOE's consultant ANL, provided a presentation to the public on the CSAP. Similarly, at your request, DOE had ANL discuss the CSAP at our Quarterly Public Meeting held on August 3, 2010. You attended via telephone.

Additionally, representatives of DOE and NYSERDA personally met with you on lVlay 4,2010 to discuss the content of the CSAP. The DOE responded to your May 11, 20 I 0 and June 7, 2010 correspondence on July 7,2010. This correspondence was returned to the DOE on July 20, 2010 after Federal Express failed in several attempts to deliver the letter to the CEC address at

Ms. Barbara Warren Macch 18, 2011 33 Central Avenue, 3rd Floor, Albany, NY 12210. On July 22,2010 the DOE sent the letter via U.S. Mail and Federal Express to your personal address at 422 Oakland Valley Road, Cuddeckbackville, NY 12729. During an October 25, 2010 telephone call with you, Moira Maloney of my staff correctly described the CSAP as a support document for the Phase 1 Decommissioning Plan for the WVDP (DP) and is not to be considered as a Phase I Study. In an e-mail response to you on May 12,2010, Paul Piciulo of NY SERDA explained why the NYSERDA-managed Waste Management Area (WMA) 8 and WMA 11 are not included in the CSAP, which is a required document for the Decommissioning Plan (DP).

As discussed with you previously, the CSAP describes the radiological environmental data collection activities that will specifically support the implementation of the Phase I decommissioning actions within the WVDP project premises which are described in the DP.

Section 9.0 of the DP, Facility Radiation Surveys, identified the various facility radiation surveys (background, characterization, final status) that are required to support the Phase 1 Decommissioning of the WVDP. The DP required the preparation of two supplemental documents, the CSAP and the Phase 1 Final Status Survey Plan (FSSP), which would provide the specific details of the sampling activities to support Phase 1 decommissioning.

Phase 1 activities to facilitate Phase 2 consensus decisionmaking will be addressed in the joint DOEINYSERDA Phase 1 Studies process that was described to the public during the February 23, 2011 quarterly public meeting, of which you were a participant. Additional characterization studies have been identified as a Potential Area of Study (PAS) for the Phase 1 Study Process as discussed during the February 23, 2011 quarterly public meeting. DOE encourages the CEC to make recommendations for additional site characterization studies as part of the Phase 1 Studies Process.

It should be made clear that a deadline for submission of comments on the Phase 1 Studies has not been established. The March 25,2011 deadline established during the February 23, 2011 quarterly public meeting on the "Phase 1 Study Process and Potential Areas a/Study" was for submission of comments concerning issues discussed during the February 23, 20 II meeting.

The DOE encourages the continued valued participation of the CEC in both the Phase 1 Decommissioning of the WVDP and the joint DOEINYSERDA Phase I Studies Process.

Should you have any questions or comments regarding this transmittal, please contact Moira Maloney of my staff at (716) 942-4255.

Sincerely,

~c:Z,---~-

I G.J.n C. Bower. Director West Valley Demonstration Project cc: See Page 3 MNM: 105088 - 450.4

Ms. Barbara Warren -3 March 18, 2011 cc: M. N. Maloney, DOE-WVDP, AC-DOE Z. Z. Zadins, DOE-WVDP, AC-DOE P. Giardina. EPA, Region 2 C. Glenn. NRC K. 1. McConnell, NRC P. J. Bcmbia, NYSERDA, AC-NYS MNM: 105088 - 450.4