ML15257A168

Comments NYSERDA Draft Sampling and Analysis and Dose Assessment Strategy for Offsite Sampling (CSF-1, Docket No.: 050-00201, P00M-32)

ML15257A168
Person / Time
Site:	West Valley Demonstration Project, P00M-032
Issue date:	09/15/2015
From:	Norato M Division of Decommissioning, Uranium Recovery and Waste Programs
To:	Bembia P State of NY, Energy Research & Development Authority
Snyder A, 301-415-6822
References
Download: ML15257A168 (9)

Text

OFFICIAL USE ONLY - NON PUBLIC OFFICIAL USE ONLY - NON PUBLIC September 15, 2015 Paul J. Bembia, Director West Valley Site Management Program New York State Energy Research and Development Authority 9030-B Route 219 West Valley, NY 14171-9500

SUBJECT:

RESPONSE TO REQUEST TO REVIEW AND COMMENT ON THE DRAFT DOCUMENT TITLED, DRAFT FIELD SAMPLING AND DOSE ASSESSMENT PLAN FOR THE WESTERN NEW YORK NUCLEAR SERVICE CENTER IN FOLLOW UP TO AERIAL GAMMA RADIATION SURVEY CONDUCTED IN 2014

Dear Mr. Bembia:

On September 2, 2015, the New York State Energy Research and Development Authority (NYSERDA), provided an electronic copy of the subject draft plan, dated August 31, 2015, prepared by MJW Technical Services for the NYSERDA West Valley Site Management Program. NYSERDA asked that the U.S. Nuclear Regulatory Commission (NRC), along with other regulatory agencies, provide any comments on the draft plan.

Enclosed are our comments on this draft plan. Because the draft plan is not final, and you requested that our comments not be made public at this time, we will not make the letter or the enclosure publicly available. If you have any questions, please contact Ms. Amy Snyder, Project Manager for West Valley. She can be reached at 415-6822 or Amy.Snyder@nrc.gov.

Sincerely,

/RA/

Michael A. Norato, Ph.D., Chief Materials Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Number: 050-00201 License Number: CSF-1

Enclosure:

Comments on draft plan cc w/enclosure: BBower, DOE-WV, PGiardina, EPA, TRice, NYSDEC, DSamson, NYSDOH

OFFICIAL USE ONLY - NON PUBLIC OFFICIAL USE ONLY - NON PUBLIC September 15, 2015 Paul J. Bembia, Director West Valley Site Management Program New York State Energy Research and Development Authority 9030-B Route 219 West Valley, NY 14171-9500

SUBJECT:

RESPONSE TO REQUEST TO REVIEW AND COMMENT ON THE DRAFT DOCUMENT TITLED, DRAFT FIELD SAMPLING AND DOSE ASSESSMENT PLAN FOR THE WESTERN NEW YORK NUCLEAR SERVICE CENTER IN FOLLOW UP TO AERIAL GAMMA RADIATION SURVEY CONDUCTED IN 2014

Dear Mr. Bembia:

On September 2, 2015, the New York State Energy Research and Development Authority (NYSERDA), provided an electronic copy of the subject draft plan, dated August 31, 2015, prepared by MJW Technical Services for the NYSERDA West Valley Site Management Program. NYSERDA asked that the U.S. Nuclear Regulatory Commission (NRC), along with other regulatory agencies, provide any comments on the draft plan.

Enclosed are our comments on this draft plan. Because the draft plan is not final, and you requested that our comments not be made public at this time, we will not make the letter or the enclosure publicly available. If you have any questions, please contact Ms. Amy Snyder, Project Manager for West Valley. She can be reached at 415-6822 or Amy.Snyder@nrc.gov.

Sincerely,

/RA/

Michael A. Norato, Ph.D., Chief Materials Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Number: 050-00201 License Number: CSF-1

Enclosure:

Comments on draft plan cc w/enclosure: BBower, DOE-WV, PGiardina, EPA, TRice, NYSDEC. DSamson, NYSDOH DISTRIBUTION:

ML15257A168 OFC DUWP DUWP DUWP DUWP DUWP NAME ASnyder SAchten for CHolston MNorato CMcKenney ASnyder DATE 9/11/15 9/14/15 9/14/15 9/15/15 9/15/15 OFFICIAL RECORD COPY

OFFICIAL USE ONLY - NON PUBLIC Enclosure OFFICIAL USE ONLY - NON PUBLIC U.S. NUCLEAR REGULATORY COMMISSIONS COMMENTS ON THE REPORT TITLED, DRAFT FIELD SAMPLING AND DOSE ASSESSMENT PLAN FOR THE WESTERN NEW YORK NUCLEAR SERVICE CENTER IN FOLLOW UP TO AERIAL GAMMA RADIATION SURVEY CONDUCTED IN 2014, DATED AUGUST 31, 2015 General Comments:

1. The objective of the U.S. Nuclear Regulatory Commissions (NRCs) review of New York State Energy Research and Development Authoritys (NYSERDAs) Draft Field Sampling and Dose Assessment Plan (Draft Plan) is to provide comments regarding whether the NRC believes that NYSERDAs proposed strategy appears to be reasonable for 1) the characterization of the off-site areas of potential concern for use in its public dose compliance demonstration and 2) the associated public dose compliance demonstration to verify that there is not a public health and safety concern.

2. The NRC does not approve characterization plans. Licensees can summarize their data and conclusions in a document; however, upon NRC staff evaluation of submittals or upon inspection, details, such as actual data sets, may be requested.

3. Does NYSERDA plan on submitting its dose assessment to the NRC or have it available for inspection? The NRC estimates that it will need approximately 10 - 30 business days to independently evaluate the land use survey, characterization and dose assessment information.

4. Will the work be conducted under a health and safety plan? If so, what is the health and safety plan based on and clarify whether NYSERDA will require that it be used for the activities.

Dose Assessment Methodology

1. The Draft Plan indicates that radiation exposures to members of the public will be determined using the current land use specific to each area (page 3). However, no detailed discussion was included in the Draft Plan on methods used to determine current land use.

Licensees may confirm current land use through the use of land use surveys, or interviews with members of the public in affected areas.

2. Current land use should be considered in calculating exposure from discharges of radioactivity and radiation resulting from site operations for evaluation of compliance with 40 CFR 190 (and 10 CFR 20.1301(e)). As stated in Comment 1, to better understand current land use, one could conduct land use surveys or perform interviews with persons residing in the area to better understand pathways of exposure. For example, consultation with the Seneca Nation of Indians was conducted during preparation of the West Valley Environmental Impact Statement (EIS), and Final EIS assumptions regarding pathways of exposure for this population may be sufficiently supported for use in this assessment.1 1 The U.S. Environmental Protection Agency should also be consulted to determine appropriate methods to assess compliance with the 40 CFR 190, Environmental Radiation Protection Standards for Nuclear Power Operations.

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3. The pathways of exposure assumed for evaluation of compliance with 40 CFR 190 (and 10 CFR 20.1301(e)) should be listed in the Draft Plan. For example, item 3 on page 12 of the Draft Plan indicates that the Derived Concentration Guideline Levels (DCGLs) listed in Table 5-11a of the Phase 1 Decommissioning Plan (DP) will be used in assessing the dose for the resident farmer exposure scenario. However, no reference is made to DCGL tables in the Phase 1 DP under item 2 when referring to a hiker exposure scenario, and no detail is provided on how hiker doses will be assessed. Therefore, it is not clear how the dose estimates will be determined for the hiker scenario listed in Table 2 (second to last column labeled 40 CFR 190) for evaluation of compliance with the uranium fuel cycle standard in 40 CFR 190.

4. The fish pathway was determined to be an important pathway of exposure to the Seneca Nation of Indians population potentially affected by West Valley Demonstration Project (WVDP) decommissioning in the FEIS. However, it is not clear if the fish pathway is being considered for calculation of potential doses to receptors who may reside or participate in activities in areas along Cattaraugus Creek. Information from the WVDP Annual Site Environmental Report may be used to evaluate the potential risk significance of this pathway based on environmental sampling.

5. The last column of Table 2 of the Draft Plan (page 13) indicates that WVDP Phase 1 DP DCGLs will be used to assess dose. Reasonably foreseeable land use should be considered for comparison against radiological criteria for license termination. The WVDP Phase 1 DP DCGLs were derived for specific areas of the Project Premises or site. Table 2 of the Plan should provide additional detail on what Phase 1 DP DCGLs will be used and provide support for use of those DCGLs in areas outside of their intended use.2 For example, the recreational scenario evaluated in the Phase 1 DP for streambed sediments is applicable to on-site areas with steep slopes. The Phase 1 DP rationale for use of a recreational scenario in these areas was based on the argument that a resident would not be able to construct a house in certain areas next to site streams due to uneven and steep topography. Additionally, recreational use of the site as well as residential use of the site was considered in a limited site-wide dose assessment where a portion of the total dose limit was apportioned to recreational uses, while the remainder was associated with residential use of the site. If the streambed DCGLs in the Phase 1 DP will be used to calculate a dose for the hiker in this assessment, rationale should be provided on why these areas could not support residential use. Most of the boxed areas (survey boxes) appear to be located near residential areas, and many of the boxed areas are located in regions that could support a residence in the future (see Figures 1 and 2).

6. For Box Area 1, results of a previous assessment (Dames and Moore, 1995) will be relied on for the Cesium Prong area of the site. It is not clear how methods used to estimate dose in the 1995 study compare to currently proposed methods. Some discussion regarding differences in scenarios and assumptions would be beneficial to better interpret differences in results.

7. For samples that will be analyzed for gamma scan [spectroscopy], gross alpha, and gross beta (and the gross results statistically exceed background), Am-241 and Sr-90 are selected 2 Page 12, item 3, indicates that Table 5-11a surface soil DCGLs will be used for the resident farmer exposure scenario. However, boxed areas 2, 4, and 5 are associated with a hiker scenario. Therefore, it is not clear what DCGLs will be used for comparison against sampled concentrations in boxed areas 2, 4, and 5.

OFFICIAL USE ONLY - NON PUBLIC OFFICIAL USE ONLY - NON PUBLIC as limiting alpha and beta emitting radionuclides for the purpose of calculating dose (page 12). However, the basis for selection of Am-241 and Sr-90 are not provided.

8. It is not clear how source concentrations will be calculated for use in the dose assessment or how doses will be directly calculated. For example, on page 12, item #2, three different methods are listed for calculation of exposure rates. Insufficient detail is provided on how data from different sources will be integrated and processed for development of source concentrations or for calculation of dose.

9. It is not clear how samples will be spatially averaged for comparison against DCGLs. It may be appropriate to consider average concentration for comparison against DCGLs for larger areas and point measurements for comparison against Elevated Measurement Comparison (EMC) DCGLs for smaller, elevated areas of residual radioactivity.

Sampling Strategy Comments

10. The Draft Plan indicates that survey and sampling actions will be more extensive in survey areas that have not been historically evaluated or where the historical data is sparse compared to areas that have previously been well characterized. With regard to confirmation sampling of previously characterized areas, licensees should also consider the quality of the data when determining the extent to which additional samples need to be taken to confirm previous sampling. Licensees who plan to use supplemental sampling, should also provide decision criteria on how supplemental sampling will be used to confirm previous sampling results, and when additional sampling should be conducted when sampling results support variability from previously measured values.

11. It is not clear why subsurface samples from 0 to 1 m are planned for Survey Box 3, while depth discrete samples from 0 to 15 cm and 15 to 30 cm are planned for other Survey Box areas (page 10). Depth of sample collection should be based on the depth of residual radioactivity above background. Page 27 of the Aerial Radiological Survey of the Western New York Nuclear Service Center indicates that Cs-137 activity along Buttermilk Creek and areas southeast of Scoby Hill Dam and north of Schwartz Road may have migrated deeper into the soil column or into creek bed sediment over time as an explanation for differences in the Cs-137 versus anthropogenic extraction figures produced in the report. Areas of potential subsurface Cs-137 may, therefore, be located in Survey Box Areas 2 and 3 (see Figure 1 below).

Survey Box Area 3 may have been selected for subsurface sampling, because this is the only Survey Box Area where the residential scenario was selected for use. However, the depth of sampling should not be based on the exposure scenario. Furthermore, DCGLs developed in the Phase 1 DP for surface soil and streambed sediments were both based on a 1 m source. As stated in the NRC staffs Technical Evaluation Report for the Phase 1 DP, the vertical and lateral extent of the source will need to be confirmed in the field to ensure the source concentrations and resulting doses are not underestimated.

Irrespective of the rationale for the depth of sampling, elevated surface radioactivity, if it exists, should not be diluted in a 1 m column of soil if significantly lower concentrations exist below the surface. Information on variability in concentration with depth is needed to justify the sampling approach. Insufficient detail is provided in the current Draft Plan to determine the manner in which samples will be taken, composited, and otherwise processed; and information on soil concentrations extracted for use in the dose assessment.

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12. Page 11 of the Draft Plan indicates that at least 1 sample will be collected for each sub zone. However, it is not clear what constitutes a sub zone. Please define this term in the Draft Plan.

13. The types of environmental media to be sampled (i.e., soil, sediments, etc.) and methods to be used to perform the sampling are not discussed in sufficient detail in the Draft Plan. Box Areas are located at various distances from affected streams (see Figures 1 and 2).

Additional detail is needed to better understand the sampling strategy.

14. On Page 3: Calculation of maximum exposures are not necessary. Still, it is not clear that maximum exposures are being calculated.

15. On Page 2: Although not required, use of MARSSIM protocols to conduct the radiological survey should be considered to ensure proper source characterization for the purpose of developing source concentrations for use in dose modeling.

16. On Page 4: It is stated that all activities will be completed per the requirements identified in the QAPP [Quality Assurance Project Plan]. A description of the QAPP should be included to understand how the QAPP applies to the sampling and analysis plan.

17. On Page 6: Survey Box 4 seems to also be near residential property, similar to Survey Box 5; yet not described as such as with Survey Box 5.

18. Clarify the descriptions of the survey boxes. The NRC staff could not find the basis for the selection of boundaries of each survey box.

19. In Section 8.b, Survey and Sampling Strategy, the rationale for the size of the grid spacing for the gamma walkover survey should be provided. Not enough information is provided to evaluate whether or not the grid size is appropriate with regard to detection of elevated measurements that could exceed the dose limit. Will the grid spacing be used for other purposes?

20. On Page 9: It is unclear how much of each survey box will be scanned or the percentage of land surface area that will be covered by gamma surveys in each of the survey boxes.

21. Since the survey boxes are in flood plains and some survey boxes show stream systems, how will scanning be addressed under wet conditions?

22. It is unclear how the detection sensitivities of equipment used for dynamic and static measurements will be determined for the field survey activities.

23. On Page 9: It is unclear when sediment samples will be taken, how many will be taken, where they will be taken and what they will be analyzed for, and how they will be used to characterize each survey box.

24. Clarify whether sediment samples will be collected for the purpose of background evaluation.

25. In the Survey and Sampling Strategy Section, it states that if all count rates are low, a limited number of samples and static survey points will be taken. What is considered low

OFFICIAL USE ONLY - NON PUBLIC OFFICIAL USE ONLY - NON PUBLIC and what is meant by limited? Not enough information is provided regarding the technical basis for determining the number of samples to take for each survey unit and the selection of sampling locations and static measurement locations. Provide the criteria that will be used or the rationale regarding the number and location of sampling and static measurements.

26. In Section 8.c.2, Expanded Analysis, it states that selected samples will be analyzed more extensively, based upon initial sample results, information gathered in the field, and project Quality Control Requirements. Not enough information is provided regarding the technical basis or decision criteria for determining which samples should be screened or evaluated further for an expanded analysis.

27. On Page 11, Table 1: Rationale for the selection of the list of analytes should be provided.

28. On Page 11, Table 1: Standard and Expanded Analysis Information, in third column, NYSERDA listed certain minimal detectable concentration (MDC) values. The basis for the MDC values should be provided.

29. It is unclear what radionuclides will be measured or accounted for the dose assessment.

Clearly identify the radionuclides that NYSERDA will require be included (measured or accounted for) in the dose assessment for each survey unit. If the radionuclides differ from those identified in the Phase I DP, explain why.

30. The Draft Plan lists methods of soil and sediment analysis in Table 1. EPA 900.0 Mod/SW 9310 Mod are listed. It appears these methods are for water and not for soils and sediments. Please clarify how these methods will be used to measure radioactivity in soil.

31. Please indicate how the suite of standard analysis (gross alpha, gross beta, and gamma scan [spectroscopy] will be sufficient to detect all radionuclides of concern.

32. The Draft Plan should address how the measurement results will be reported. For example, per MARLAP (Multi-Agency Radiological Laboratory Analytical Protocols Manual, NUREG-1576), the reported value of a measurement result: (1) be reported directly as obtained, with appropriate units, even if it is are negative, (2) be expressed in an appropriate number of significant figures, and (3) include an unambiguous statement of the uncertainty.

33. Clarify whether NYSERDA will require the list of applicable procedures listed in Section 10, Applicable Field Procedures, be used. How do the applicable procedures relate to the New York State Service Providers license requirements?

34. How does the Draft Plan and associated procedures relate to the reference standards and practices listed in Section 11, Reference Standards and Practices?

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REFERENCES:

Dames and Moore, 1995, Western New York Nuclear Service Center Off-Site Radiation Investigation, Volume 1: Summary Report, Dames and Moore: Pearl River, NY, December, 1995.

DOE, 2010, Final Environmental Impact Statement for Decommissioning and Long-term Stewardship at the West Valley Demonstration Project and Western New York Nuclear Service Center, DOE/EIS-0226, January 2010.

DOE, 2009, Phase 1 Decommissioning Plan for the West Valley Demonstration Project, Revision 2, Prepared by Washington Safety Management Solutions, URS Washington Division, and Science Applications International Corporation, December 2009.

NRC, 2010, U.S Nuclear Regulatory Commission Technical Evaluation Report on the U.S.

Department of Energy Phase 1 Decommissioning Plan for the West Valley Demonstration Project, Letter to Bryan C. Bower from Keith I. McConnell, US NRC: Washington DC, February 2010.

An Aerial Radiological Survey of the Western New York Nuclear Service Center, For Customer Review Only, US DOE-WV and NYSERDA, (draft, no date)

OFFICIAL USE ONLY - NON PUBLIC OFFICIAL USE ONLY - NON PUBLIC Figure 1 Location of Box Areas 2 and 3 Figure 2 Location of Box Areas 4 and 5 2

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