ML111510249

B. Bower Ltr NYSERDA Comments on the Phase 1 Fssp for the West Valley Demonstration Project, Revision 1, Dated March 14, 2011

ML111510249
Person / Time
Site:	West Valley Demonstration Project, P00M-032
Issue date:	05/04/2011
From:	Bembia P State of NY, Energy Research & Development Authority
To:	Bower B NRC/FSME, US Dept of Energy, West Valley Demonstration Project
References
Download: ML111510249 (4)

Text

I\IY§ERDA l\Iew York !it:at:e Energy Research and De"elopment: Aut:horit:y Vincent A. Dclorio. Esq., Chairlllan Toll Free I (1\66) NYSERDA May 4.2011 Mr. Bryan C. Bower, Director U.S. Department of Energy West Valley Demonstration Project 10282 Rock Springs Road West Valley, NY 14171-9799

SUBJECT:

New York State Energy Research and Development Authority (NYSERDA) Comments on the Phase I Final Status Survey Plan (FSSP) for the West Valley Demonstration Project (WVDP), Revision 1, Dated March 14,2011 NY SERDA is providing the enclosed comments on the Department of Energy's (DOE) Phase I Final Status Survey Plan(or the West Valle.v Demonstration Project. Revision 1, dated March 14, 20l1.

NY SERDA respectfully requests that DOE provide a written response to the enclosed comments.

Any questions regarding the enclosed comment package should be directed to Andrea L Mellon at (716) 942-9960 extension 4054.

Sincerely,

( \ V A~L;.; SITE MANAGEMENT PROGRAM

~c '-1(;>XlLC1C' Paull Bembia, Director ALM/amd

Enclosure:

1. NYSERDA Comments on the Phase I Final Status SlIrvev Plan (FSSP)/or the West Valley Demonstration Project (WVDP. Revisioll I. Dated March 14,20] 1 PJB/} lamd018,alm Main Office West Valley Site  :\iew York Cit~' Buffalo Albany Management Program 4,,5 S,,\ cnth .-\ve., Suite 1006 Larklll at Exchange Budding

) 7 Columbia Circle I02Xl Ruck Springs Road Ne\\ York, N\' 10018 726 EXc'hangC' Slree!, Suite X2 I Albany, NY 12203-6399 \Vesl Valley, NY 141 1-()7'l9 Phone: (212) 971-5342 Buffalo, Ne\\' York 14210 Toll Free: I (366) NYSERDA Phone: i 716) 942-9960 Fax: (212) 97]-5349 Phone (716) X4::'-1522 Phone: (518) 861*1090 Fax. (716) 94:-9%1 Fax: (716) X-l2-0156 Fax: (518) 862-1091

NYSERDA Comments on the Phase 1 Final Status Survey Plan West Valley Demonstration Project, Revision 1, Dated March 14,2011

'Co~ment Page or Section/Para/ Commenter Comment Comment Response

1. Sheet Line # Name General General NYSERDA Results of the West Valley Demonstration Project 1.

Comment Comment (WVDP) Phase I Characterization Sampling and Analysis Plan (CSAP) data collection may determine that this Final Status Survey Plan (FSSP) needs to be modified. NYSERDA requests an opportunity to review and comment on the revised FSSP as well as any subsequent revisions of the CSAP or its suppOi1ing documents.

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fgeneral Comment I General Comment NYSERDA I The WVDP Phase 1 CSAP identifies subsurface soil contamination in a number of Waste Management Areas (WMAs), but stipulates that the extent of the contamination is unknown. The April 2011 CSAP acknowledges that a number of potential sources exist for this subsurface contamination. At some point, however, the other sources of subsurface contamination (e.g., WVDPlNuclear Fuel Services buried contamination and contaminated groundwater) will need to be evaluated to ensure that those areas found to contain subsurface contamination are identified, characterized, and remediated, as necessary. This evaluation will need to happen before a final status survey of each WMA can occur.

3.

General I General NYSERDA I The predominant focus of the WVDP Phase 1 CSAP Comment Comment is to obtain samples from each WMA, which will provide additional information for all areas. This process does not necessarily ensure that all areas have been adequately characterized. For example, WMA 5 is known to have subsurface contamination, and the only subsurface sampling required is the area surrounding buried infrastructure. In this case, contingent sampling is only required if contamination has been detected in the surface soils. NYSERDA believes that additional sampling will be necessary to ensure that all areas have been adequately characterized for the purposes of making Phase 2 decisions or in preparation for the Phase 2 FSSP.

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NYSERDA Comments on the Phase 1 Final Status Survey Plan West Valley Demonstration Project~ Revision 1, Dated March 14,2011 Comment I Page or Section/Para/ I co.mmenter Comment Comment Response

1. Sheet Line # ----J.m Name 1

... NYSERDA also anticipates that, at a I11I1UmUm, a second CSAP and FSSP will be generated to support the Phase 2 de~isions for the remaining WMAs.

General General NYSERDA I The use of the Gamma Walkover Survey (GWS) in 4.

Comment Comment areas where saturated soils exist may be problematic and could lead to a large measurement error.

NYSERDA recommends that a field walkover inspection be obtained for areas 1",,,.1 " ...".J" ,..r ",,,,,,"IAr!

where soil saturation is If soil moisture measurements are not obtamed, a correct lnterpretation of the GWS data may not be possible.

and the FSSP should reflect additional systematic surface and subsurface 5.

General NYSERDAtTil~WVDP Phase 1 CSAP identities that the 18 Comment I Comment Radionuclides of Interest (ROls) will be perfon11ed for the various WMAs as well as an additional 12 ROTs. If the CSAP analysis identities a specific ROJ that provides a b'Teater added to the CUtTent list of ROls 12 3.I/Para.1I NYSERDA 6.

Lines 10-12 DP also includes derived stream sediment CGs, there will be no FSS data collection in Franks Creek or Erdman Brook as part of the Phase 1 activities."

Based upon this statement, NYSERDA understands that FSS data collection in Franks Creek and Erdman as part of a separate Phase J Phase 2 FSSP. If as to 1-------+1 7.

14 1

3.4/Paras. 2 I* * *

• NYSERDA efforts will occur.

paragraph of the FSSP states, "The Phase and 4 is not applicable to any areas outside the WMA 1 and WMA 2 excavations where there is evidence of contamination impacts above background conditions at depths exceeding I m." The exception to this statement is for soil lay-down areas, which 2 of3

NYSERDA Comments on the Phase 1 Fillal Status Survey Plan West Valley Demo1lstration Project, Revision 1, Dated March 14,2011 Comment Page or Section/Para! Commenter Comment Comment Response

1. Sheet Line # Name will undergo a contamination status detennination.

The fourth paragraph states that "FSS data collection within FSS units applies to exposed soils to a depth of 1m."

Per areas. This indicates that those units with the for subsurface contamination is unknown a number of WMAs, and will need to be detennined an additional FSSP.

~9 5.3/Para. I NYSERDA I The FSSP states "All FSS GWS will be electronically 8.

Lines 4-5 logged with suitable coordinate recording equipment that provides a minimum precision of +! I accuracy." Provide an example of what constitutes

"+1- I accuracy" or clarifv the section.

51 6.2!Para. I NYSERDA I This section references NUREG-9.

Detectable Concentrations Survey lnstmments fbr Various Contaminants and Field Conditions." Include NUREG-1507 in the of reference documents on Page 65.

52 Table 4 NYSERDA I Table 4 lists the target sensitivities for the 18 Rors.

10.

Footnote NO.4 is used for Pu-238, Pu-239/240 and Pu-241, which states that of background for naturally occuning radionuclides." This footnote is inaccurate for these four radionuclides. Evaluate and revise the table, as ,,,nlr1r,'I1'

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