ML11193A253

Responses to NYSERDAs April 20, 2011 Comments on the Phase I Characterization Sampling and Analysis Plan West Valley Demonstration Project, Rev. 1

ML11193A253
Person / Time
Site:	West Valley Demonstration Project, P00M-032
Issue date:	05/18/2011
From:	Argonne National Lab (ANL)
To:	NRC/FSME, US Dept of Energy (DOE)
References
Download: ML11193A253 (11)

Text

Responses to NYSERDAs April 20, 2011 Comments on the Phase I Characterization Sampling and Analysis Plan West Valley Demonstration Project, Rev. 1 Cmt. Page or Section/Para/

1. Sheet Line # Comment Comment Response 1 1 General Comment The West Valley Demonstration Project (WVDP) Comment acknowledged. The primary goal of the Phase 1 Phase 1 Characterization Sampling and Analysis CSAP is to satisfy Phase 1 Decommissioning decision-Plan (CSAP) identifies that subsurface soil making needs. The CSAP is not currently designed to contamination exists in a number of Waste answer all contaminant nature and extent questions that may Management Areas (WMAs), but that the extent of exist for the site, particularly for those that are primarily this contamination is unknown. At some point, the related to Phase 2 decision-making.. The assumption is that other sources of subsurface contamination buried additional data collection may be required beyond what is contamination and contaminated groundwater) need currently identified by the CSAP to support Phase 2 to be evaluated to ensure that those areas are decision-making.

identified and characterized.

2 General General Comment The predominant focus of the WVDP Phase 1 CSAP See response to Comment #1.

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 will be adequately characterized for decommissioning purposes. NYSERDA believes that additional sampling will eventually need to be done to ensure that all areas have been adequately characterized for the purposes of making Phase 2 decisions or in preparation for the Phase 2 Final Status Survey Plan (FSSP). WMA 5, for example, is known to have subsurface contamination, but the only subsurface sampling required is the area surrounding buried infrastructure. Contingent sampling is possible, but only if contamination has been detected in the surface soils.

NYSERDA believes that a second CSAP and FSSP will be needed to support the Phase 2 decisions for the remaining WMAs.

3 General General Comment The WVDP Phase 1 CSAP identifies that additional DOE will provide NYSERDA copies of the additional Comment documents (e.g., the Phase 1 Decommissioning Plan supporting documents.

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1. Sheet Line # Comment Comment Response Waste Management Plan, the Quality Assurance Project Plan, etc.) are planned. It is anticipated that these documents will provide additional detail about the Phase 1 areas (i.e., soil segregation and waste disposal pathways). NYSERDA requests an opportunity to review and comment on these supplemental documents.

4 General General Comment The use of the Gamma Walkover Survey (GWS) in The CSAP recognizes the GWS data collection would not Comment areas where saturated soils exist may be problematic be appropriate in areas where standing water or saturated and could lead to a large measurement error. soil conditions exist. Section 6.5 states that in areas with NYSERDA recommends a field walkover standing water or saturated soil conditions systematic inspection clearly delineating the wetlands or sampling will be used with a density of one sample per 200 ponded areas, or areas where soil saturation is m2. This density is less than required for Final Status Survey possible. If, after a field walk-over inspection, areas (FSS) Class 1 areas, but greater than what is required for are identified as having the potential for higher FSS Class 2 areas. If CSAP sampling in these areas levels of saturated soils, then NYSERDA identifies contamination above CG levels, then either recommends the completion of additional systematic remediation will take place, or additional sampling will take surface and subsurface sampling. place to better define the extent of contamination. Section 6.5 calls for sampling the 0-15 cm soil layer initially. If any of these sample results indicate contamination above background conditions, the 15-100 cm interval would be sampled. If those samples indicated contamination above background conditions, sampling would continue in one meter intervals vertically until contamination was bounded.

5 General General Comment The GWS is not the most optimum tool for selecting The CSAP does not propose to use GWS data collection as Comment subsurface sample locations "to maximize the the means for identifying areas where subsurface possibility that contamination will be encountered," contamination is a potential concern. DOE is also not as subsurface soils and infrastructure may have been proposing to systematically sample the subsurface across the backfilled with clean fill. The process of subsurface entire WVDP premises. DOE is committed to exploring the sampling along buried infrastructure is best possibility of subsurface contamination in those areas where performed systematically. Phase 1 Decommissioning decisions may be made and there is a reason to believe that subsurface contamination may be present. Example areas identified in the CSAP include buried infrastructure , areas where there is evidence of historical fill activities (e.g., in WMA 5 and WMA 2), areas where it is known that contamination was buried (e.g.,

WMA 5 and WMA 6), and areas where historical data collection suggest buried contamination might be present May 18 2011 Page 2 of 11 Response to Comments

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1. Sheet Line # Comment Comment Response (e.g., the western edge of WMA 12, etc.). If NYSERDA is aware of other areas where potential contamination may be present, these should be identified and demarcated so that they can be properly addressed as CSAP Technical Task Orders are prepared for those areas. In the case of buried infrastructure, the CSAP calls for systematically trenching buried infrastructure of potential concern to determine whether contamination is present.

6 General General Comment The CSAP repeatedly refers to "area[s] where The CSAP expects that standing water/saturated areas will Comment standing water or saturated soil conditions prevent be identified and delineated as part of GWS work. Note that GWS data collection." How these "areas" are for portions of the site, inaccessibility for GWS surveys defined is unknown. To the reader, it appears that because of saturated soil conditions is a seasonal concern; the CSAP assumes these areas to be relatively small, consequently, GWSs will be conducted when access is discrete areas, as a maximum of five surface anticipated to be best (e.g., late summer). The CSAP does samples is called for. In reality, these areas may be not anticipate small areas will be saturated - 5 samples at very large, contiguous areas (e.g., the Erdman Brook 200 m2 per sample is 1,000 m2. To address NYSERDAs valley). In such cases, a much larger number of concern that large areas maybe under-sampled, DOE samples would be more indicative of the areas proposes to add text that at minimum one sample will be sampled. It is recommended that the text "and at collected per 500 m2 for areas exceeding 2,500 m2 in size, most five" be removed from each discussion of the which would be the equivalent of 20 samples per Class 2 Surface Soil Sampling in Wetlands. The sampling area, a sample density that is higher than would be density of 200m2 should reference the number of anticipated for demonstrating FSS closure if none of the samples in a saturated "area." samples yielded results greater than the CG requirements.

Note that the largest contiguous areas that are potentially inaccessible to GWS data collection are in WMA 4 and WMA 12, areas where impacts above CG requirements are not expected.

7 4 Para. 1 Due to the variations in historical operations, it is This comment is presumably focused on the potential use of likely that the concentrations of each of the surrogates at the site. At this stage it is not DOEs radionuclides of interest (ROIs) vary by site expectation that surrogates will serve a useful purpose.

location. Therefore, NYSERDA recommends that a However, per NYSERDAs request, text will be added to second sample be collected immediately the appropriate WMA appendix requiring an additional downstream of the EQ-1 discharge to Erdman sample to be collected immediately downstream of the EQ-1 Brook. Erdman Brook discharge.

8 15 Section 3.2/ This section states that DOE and/or its contractors DOE will provide NYSERDA access to the administrative Lines 6-9 will maintain an administrative record of record referenced, including permission to copy records that characterization activities, including electronic and NYSERDA would like.

hardcopy documents, data sets, and related May 18 2011 Page 3 of 11 Response to Comments

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1. Sheet Line # Comment Comment Response information such as maps, diagrams, geologic logs, field notebooks, and photographs. NYSERDA requests the opportunity to review, and possibly obtain copies of these records.

9 40 Para. 2 Due to the expected "bathtub ring" of contamination Bathtub rings of contamination have been encountered at (as described in Section J.7, 5th paragraph) from other DOE sites. These are difficult to identify via sediments surrounding the stream channel systematic sampling since they typically are very spatially centerline, NYSERDA recommends that systematic discrete in nature and usually have no visual indication.

sampling be conducted laterally outward orthogonal They are easiest to identify by a combination of GWS and to the stream centerline extending to the potential biased sampling. By their nature they exist in soils that are high watermark during a flood event such as the typically not saturated and so can be scanned. DOEs August 2009 event. preference would be to rely on the GWS protocols as described. If there are specific locations of particular concern to NYSERDA, DOE would recommend calling these out for biased sampling as Technical Task Orders for those areas of potential concern. Alternatively if NYSERDA already knows locations that should be biased sampled, they could be incorporated as additional sampling requirements in the appropriate WMA appendices.

10 56 Section 7.1/ The text states that remedial action survey identified The referenced paragraph talks about submitting samples Para. 3/ for WMA 2will be submitted for quick-turnaround from both WMA 1 and 2 for quick turnaround Sr-90 Lines 7-8 analysis of Sr-90. Please explain the technical basis analysis. The purpose in both cases is to determine whether for solely analyzing for Sr-90, whenCs-137 and off- there is obvious contamination that should be immediately site analysis for all 18 ROIs are identified in the addressed. In neither case do the quick-turnaround analyses remedial support surveys for WMA 1? substitute for off-site analysis for all 18 ROIs to determine the residual activity concentrations of the dig face as part of the FSS process once excavation is believed to be complete.

11 57 Section 7.1/ The remedial action survey identified for the 476 See response to comment #10. Samples from the piles will Para. 1/Lines foundation pilings in WMA 1 will be submitted for be submitted, eventually, for analysis of all 18 ROIs as part 5-6 quick-turnaround analysis of Sr-90. Please explain of the FSS process. The purpose of the initial screen for Sr-the technical basis for solely analyzing for Sr-90, 90 is determine if there is unacceptable contamination prior when Cs-137 and off-site analysis for all 18 ROIs to submitting the sample for a full suite analyses.

are identified in the remedial support surveys for WMA 1?

12 63 Section 8.3/ This section states that If the application for the DOE has not established what would be an unacceptably Para. 2/Line rule described above results in an unacceptably high high false positive rate, and would prefer to leave this until 8-10 rate of false positive hits for Pu-239, the actual CSAP data are collected and available for review.

comparison process may be modified to also Text can be added that the process would not be modified May 18 2011 Page 4 of 11 Response to Comments

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1. Sheet Line # Comment Comment Response account for measurement uncertainty. Clarify what without prior consultation with NYSERDA in the event that constitutes unacceptably high rate of false positive false positives are observed. Pu-239 is a potential issue hits? Also, please explain why Pu-239 may because it has measureable activity concentrations in require a different statistical approach (i.e., the 95% background soils, but is a measurement with significant UTL or three-times-uncertainty rule). measurement uncertainty at those levels. For most background radionuclides (e.g., U-238, Ra-226, Th-232, K-40, Cs-137, etc.) the variability observed in off-site laboratory analyses of background samples is driven by the heterogeneity present in actual background activity concentrations, not measurement error. With Pu-239, the reverse will likely be true; consequently, small changes in laboratory performance for individual samples can result significant changes in analytical error for individual Pu-239 results. This in turn can lead to the appearance of Pu-239 above the 95%UTL as calculated from a background data set when in fact the higher value simply reflected higher measurement uncertainty. Whether this becomes an issue or not for the site is difficult to say without actually having CSAP surface soil data in hand to review, particularly the estimated measurement error associated with Pu-239 results and the degree to which that error is relatively constant across samples or shows wide variability itself.

13 65 Section 9.1/ It may be worthwhile to note that a comprehensive Thanks, will add text acknowledging the LiDAR.

Items #1&2 high resolution Light Detection and Ranging (LiDAR) topographic survey and orthophotography was conducted in November 2010, and will be used to support CSAP activities.

14 67 Section 9.3/ To ensure that datasets are spatially rectified to a Will add requirement that maps be delivered in both Para. 2 projected coordinate system and usable across AutoCad and ESRI shape file formats, with coordinate computing platforms, electronic maps need to be systems consistent with the sites State Plane requirements.

delivered in ESRI ARC map documents, with associated layer files, in addition to being delivered in AutoCAD .dwg format.

15 79 Section Based on the extent of perennially saturated soils in Will add a requirement to obtain soil moisture estimates as 11.1/Para. 1 the valleys of Erdman Brook and Frank's Creek, an part of GWS data collection.

estimation of "accessible portions of the site" for GWS of 140 acres is likely an overestimation. This "accessible area" may be as small as 110acres. As May 18 2011 Page 5 of 11 Response to Comments

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1. Sheet Line # Comment Comment Response previously mentioned (see General Comment #4, to achieve the proper interpretation of the GWS data, it would be beneficial to conduct a soil moisture measurement immediately before or during the GWS at each measurement location.

16 A-19 Sect. A.9.5/ What is the technical basis for sampling only two Size of the area of interest - which is just that portion of 1st Bullet locations of buried infrastructure in WMA 1, when WMA 1 that will not be excavated (which does not leave all other WMAs identify three sampling locations? much area left).

17 D-2 Section D-3/ The "scarring" in the 1966 aerial photograph that Comment acknowledged. This does not have an impact on Para. 3 "potentially indicates limited disposal operations" is proposed CSAP activities in WMA 4.

not within the boundary of the CDDL as drawn on all CSAP maps. To incorporate the scarred area, the CDDL boundary needs to be expanded.

18 E-11 Section E.7/ The fifth bullet states that the subsurface soils in See response to Comment #1. Delineating the extent of 5th Bullet WMA 5 may be contaminated by subsurface groundwater contamination beneath WMA 5 is beyond the releases from the Process Building, and that the scope of the CSAP and is not required to support Phase 1 western and northern extent of these subsurface soil Decommissioning decision-making.

impacts is unknown. Yet, the required sampling for WMA 5 only consists of buried infrastructure soil sampling below one meter. Based on surface soil results, there are 18 contingent samples identified. It is NYSERDAs opinion that the number of subsurface soil samples may not be sufficient to adequately characterize WMA 5.

19 E-11 Section E.7/ The sixth bullet identified that low-levels of Sr-90 See response to comment #18.

6th Bullet and H-3groundwater contamination exist in the eastern half of WMA 5.The potential sources of this contamination include hardstand spills, WMA 3, buried infrastructure or other undocumented releases. Yet, the required sampling for WMA5 only consists of buried infrastructure soil sampling below one meter. Based on surface soil results, there are 18 contingent samples identified. It is NYSERDAs opinion that the number of subsurface soil samples may not be sufficient to adequately characterize WMA5.

20 F-7 Section This paragraph states ". . . radiation levels from soil Drawing 40A-S-29 indicates that the stretch of sanitary line May 18 2011 Page 6 of 11 Response to Comments

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1. Sheet Line # Comment Comment Response F.4.3.1/ Para. contamination hampered the project." Was the line 15WS902-6-A10 from the office building south to 2 repair made? What is the current status of this Manhole D was sleeved with 4 coiled black plastic. These broken sewage line? repairs are believed to have been made in 1974.

21 F-13 Section F.9.3 Due to the current activities and the addition of a Soils beneath hardstands will be characterized after the potentially clean backfill, it may be beneficial to removal of hardstand materials. Soils in the vicinity of the conduct the systematic surface and subsurface Low-Level Radioactive Waste Rail Packaging and Staging sampling at and around the Contractor Access Area will be sampled at least to a depth of 1 m as part of Hardstand and Low-Level Radioactive Waste Rail characterization work to support the planned HLW Canister Packaging and Staging Area (as identified in Figure Interim Storage Facility per a CSAP Technical Task Order F.1 for WMA 6), regardless of the GWS results, as that has already been prepared.

these areas are currently being used for waste storage.

22 F-16 Section This section describes the collection of soil cores There was historical data from the immediate vicinity of the F.9.4/2nd around the New Sewage Treatment Facility, yet no New Sewage Treatment Facility that suggested Bullet known contamination or suspected release is contamination might be present in the subsurface. The mentioned for this area. Please clarify the sampling purpose of these cores is to definitively establish that soil rationale. contamination is not associated with this facility.

23 F-40 Figure F.16 Clarify the reason for the "possibly > background" See response to Comment #22. Figure will be modified to classification around and leading from the New reflect the fact that contamination above background is Sewage Treatment Facility as there is no known likely associated with the Old Sewage Treatment facility contamination or suspected releases identified for and associated waste line. Typographical error will be this area. Similarly, why is the area around and corrected.

leading from the Old Sewage Treatment Facility not classified as "possibly >background" given the significant contamination known to exist in that area?

Also, correct the typographical error in the key.

Possibly >bakcground should be amended to read Possibly > background.

24 G-3 Section In addition to the volume, it would be helpful to The report, Estimated Radionuclide Inventory for the G.1/WVDP know the type of waste (e.g., vessels, equipment, NRC-licensed Disposal Area at the West Valley Caissons/ PPE, etc.) placed in the Caisson 1. Demonstration Project (Wild 2000), indicates that drums Para. 2 containing approximately 823 ft3 of general waste and sludge from the O2 Building (the original Low-level Waste Treatment Facility) were placed in Caisson 1.

25 G-7 Section G.4.2 Being in such close proximity to the SDA, it is The CSAP was intended only to discuss WMAs within its suggested that WMA 8 be included in the scope, but WMA 8 will be added for completeness per the May 18 2011 Page 7 of 11 Response to Comments

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1. Sheet Line # Comment Comment Response Potentially Affected WMAs. suggestion.

26 G-22 Figure G.2 Assuming that radiologically controlled means The radiological controlled areas are areas defined by roped off (fenced) and posted, it is unclear why half WVES and roped off and posted.

of the NDA cover is radiologically controlled and the other half is not. Please clarify why the NDA is not radiologically controlled. [Resolution of this comment may affect Figure 7 on P. 79 and Figure J.1 on p.J-19.]

27 H-2 Section H.2/ For informational consistency between appendices, Text will be added as suggested.

Para. 2 suggest adding the following sentences to the end of the paragraph. Groundwater flows vertically through the unweathered Lavery Till to the Kent Recessional Sequence. The Kent Recessional Sequence is more permeable and does transport groundwater in a northeasterly direction, discharging to Buttermilk Creek.

28 J-1 Section J.2/ Replace west/northwest with north/northeast. Thank you. Text will be corrected as indicated.

Para. 3/ Line 7

29 J-1 Section J.2/ A few man-made features currently exist in WMA Text will be modified to reflect the information in the Para 4/Line 1 12 South: comment.

1) A buried natural gas line services the West Valley Demonstration Project. The line crosses Franks Creek on the east side of the SDA, then crosses Erdman Brook just north of the SDA, and continues across WMA 12 to WMA 1.

2) An actively used, buried leachate transfer line is used to transfer leachate from the NDA interceptor trench (WMA 7) to the Liquid Waste Treatment Facility (WMA 2). The transfer line crosses Erdman Brook northwest of the NDA and continues in a northerly direction to WMA 2.

3) In 2009, NYSERDA and DOE completed erosion mitigation work on Erdman Brook and part of Lagoon Road Creek, just to the northwest of the NDA and SDA. The work included the realignment of the stream channel, May 18 2011 Page 8 of 11 Response to Comments

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1. Sheet Line # Comment Comment Response grading of a knickpoint, lining the new channel with geotextile and placing medium stone fill on top. The work was necessary to keep surface water flow in a central channel to ensure continued stability of the North Slope of the SDA.

30 J-1 Section J.2/ Records indicate that WMA 12 was disturbed by It would be helpful if NYSERDA provided the referenced Para. 4/ Nuclear Fuel Services (NFS) during disposal photographs. The question is what potential contamination Lines 1-3 operations at the SDA (1963-1969). From the issues this raises for WMA 12, and exactly where those historical photographs, trucks and heavy equipment contamination concerns would be. The topic warrants could access the northern trenches of the SDA using further discussion with NYSERDA prior to modifying the a road (presumably called Lagoon Road) that CSAP.

crossed over Erdman Brook just west of what is now known as Lagoon Road Creek. While it is unclear if trucks carrying waste used this road, the road was built by NFS for the purpose of accessing the SDA and most likely the NDA, too. Historical photographs from 1980 show that significant re-grading work was completed in the Erdman Brook corridor northwest of the SDA and NDA, and show Lagoon Road no longer in place. In addition, historical photographs also show that some of the soil excavated from the trenches (for the purpose of disposal at the SDA) was pushed over the side of the embankment that is currently known as the North Slope. [NYSERDA can provide the historical photographs referenced in this comment, should DOE decide they want them]

31 J-2 Section J.4.1/ Insert and Frank's Creek after . . . and banks of Text will be modified as requested.

Para. 2/ Line Erdman Brook).

1 32 J-2 Section J.4.1/ Suggest changing "possible" to "known" as there is Text will be changed as requested.

Para. 3/ Line a known area of radiological contamination on the 1 east side of WMA 12south extending from WMA 7 to the Erdman Brook channel.

33 J-4 Section J.4.4/ See Comment #20. See response to Comment #20.

Para. 2 34 J-5 Section J.5/ Was this hot-spot marked? With the hot spot being A hot spot of this size would likely not be found with May 18 2011 Page 9 of 11 Response to Comments

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1. Sheet Line # Comment Comment Response 4th Bullet located so close to the stream channel, GWS may systematic sampling. However, if activity concentrations are not be appropriate to locate is or characterize its what is described, it would clearly be identified by the extent. It is suggested that systematic surface soil GWS. Note that the GWS protocols require complete sampling be conducted for this area. coverage of surface areas.

35 J-6 Section J.5/ Qualify "groundwater" with "shallow" in this Text will be qualified as indicated.

Last Para. context.

36 J-7 Section J.7/ This section states "Any soil contamination present Note that the first paragraph of this section states that Para 3 is expected to be limited to surface soils. Given the subsurface contamination may exist along the border with interpretation of the air photos, this is not a WMA 2. Note too that significant subsurface reasonable expectation. Clearly, there was a characterization will occur along the border as part of WMA significant amount of soil pushed out of an area of 2 sampling activities, and that as part of WMA 2 known contamination, which would infer an characterization activities this subsurface sampling may expectation that contamination exists below 1m. extend into WMA 12 to bound the lateral extent of Therefore, it would seem logical to sample to depth contamination as necessary. Finally, any surface soil in this area, regardless of the sample results from contamination will be sampled and pursued to depth until WMA2 along the boundary of WMA 12 South. vertically bounded. The contamination impacts in this area based on historical information have a surface expression; consequently, DOE believes the possibility of subsurface contamination and its lateral and vertical extent along the border of WMA 2 will have been adequately addressed with the activities as proposed.

37 J-8 Section J.7/ This section states "Because Erdman Brook and To reflect the presence of knickpoints in Erdman Brook, the Para. 1 Frank's Creek are primarily eroding features . . . one proposed sediment sampling will be modified to include would not expect to see contamination extending both a 0-15 cm sample and a 25-100 cm sample.

more than one meter into the subsurface. This expectation does not seem realistic as the knickpoint scour pools (often deeper than 1m) observed on these stream systems are routinely filled with deposited sediments when the knickpoints migrate upstream.

38 J-8 Section J.7/ This section states "Because Erdman Brook and If NYSERDA has information/photos showing the location Para. 1 Frank's Creek are primarily eroding features . . . one of valley reworking, this would assist in developing a would not expect to see contamination extending systematic subsurface sampling program for those portions more than one meter into the subsurface. There is o of the valley that might be of concern. Without more significant photographic evidence that large areas of definitive information regarding the location and extent of the Erdman Brook valley were reworked with heavy reworking activities it would be difficult to design a equipment in 1980, which may have spread sampling program that would be effective in finding any contamination across the valley and to a depth buried contamination that might be present.

May 18 2011 Page 10 of 11 Response to Comments

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1. Sheet Line # Comment Comment Response greater than 1m.It is suggested that systematic subsurface sampling of Erdman Brook Valley be conducted.

39 J-9 Section J.9.2/ Perennially saturated soils may constitute 50 percent See response to Comment #6.

1st Bullet of the surface area of WMA 12 South. Given the fact that GWS is not appropriate for these areas, and the fact that large areas of the Erdman Brook valley were reworked with heavy equipment in1980, it is suggested that systematic surface soil sampling occur in these areas.

40 J-10 Section J.9.2/ This section states ". . . other than to address area Additional text will be added to reflect this observation.

3rd bullet too wet to perform a gamma walkover survey. It should be noted that these areas include groundwater seep areas downslope from WMA 2 that are likely contaminated and too wet for GWS to be appropriate.

41 J-13 Section J.9.4/ Frank's Creek and Erdman Brook sediments should See response to Comment #9. Sampling density will be 2nd Bullet be sampled at least every 10m, not 30m, and, given increases to one sample per 10m per NYSERDA request.

the bathtub ring effect, lateral bounding samples should also be collected. (See Comment #9.)

42 K-1 Section K-2/ A more accurate description of the surface drainage Text will be modified as suggested.

Para. 2 for WMA12 North would be stated as it drains to the southwest throughNP-1 gully into Quarry Creek.

43 K-8 Section K.9.3 Figures D-4 and D-5 (p. D-20 and D-21) indicate a Based on DOEs interpretation of those photographs, NA 12 road leading from the scarred area in WMA 12 North appeared to be used as a borrow area for clean soils.

North to the Lagoons inWMA2. Given that DOE does not see a reason for systematically sampling the materials may have been transported to/from subsurface.

WMA 2 and significant reworking of surface soils in WMA 12North has occurred, it is suggested that a systematic subsurface sampling be conducted in WMA 12 North.

May 18 2011 Page 11 of 11 Response to Comments