ML15264A520
| ML15264A520 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project, P00M-032 |
| Issue date: | 09/14/2015 |
| From: | Bower B West Valley Demonstration Project |
| To: | Norato M NRC/NMSS/DDUWP/MDB |
| Amy Snyder | |
| Shared Package | |
| ML15264A554 | List: |
| References | |
| Download: ML15264A520 (7) | |
Text
Department of Energy West Valley Demonstration Project 10282 Rock Springs Road West Valley, NY 14171-9799 September 14, 2015 Mr. Michael A. Norato, Ph.D., Chief Materials Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office ofNuclear Materials Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-000 1
SUBJECT:
Transmittal of U.S. Department of Energy (DOE) Responses to U.S.
Nuclear Regulatory Commission (NRC) Comments on Radiological Characterization Reports for Portions of the West Valley Demonstration Project (WVDP)
REFERENCES:
- 1) Letter (365938), M. Norato to B. C. Bower, U.S. Nuclear Regulatory Commission Comments on U.S. Department of Energy West Valley Demonstration Project Radiological Soil Characterization Reports for Portions of the West Valley Demonstration Project, dated June 30, 2015 2)
SEC-RCR Radiological Characterization Report for the High Level Waste Canister Interim Storage Area for Task Order 9, Revision 1, April, 2014 3)
SEC-RCR Radiological Characterization Report for the Balance of Site Facilities (BOSF), Revision 3, July, 2014
- 4) Phase 1 Decommissioning Plan (DP) for the West Valley Demonstration Project, Rev. 2, December, 2009
Dear Mr. Norato:
This letter transmits DOE-WVDP responses to the June 30, 2015, NRC technical comments (Reference 1) on the Radiological Characterization Reportfor the High Level Waste Canister Interim Storage Areafor Task Order 9, Revision 1, April, 2014 (Reference 2) and the Radiological Characterization Reportfor the Balance ofSite Facilities (BOSF), Revision 3, July, 2014 (Reference 3). These documents were submitted to the NRC for informational purposes to partially fulfill requirements of the Phase 1 Decommissioning Planfor the West Valley Demonstration Project, Rev. 2, December, 2009 (Reference 4).
The Radiological Characterization Reportfor the High Level Waste Canister Interim Storage Areafor Task Order 9 describes the soil radiological characterization performed at the base of the excavation for the WVDP High-Level Waste (HLW) canister storage
Mr. Michael A. Norato
- 2 September 14, 2015 area and its associated excavated spoils pile. The Radiological Characterization Report (RCR)for the Balance ofSite Facilities (BOSF) describes the soil radiological characterization performed after the latest removal of the BOSF at the WVDP. The BOSF include buildings, site infrastructure, and gravel/concrete pads that are scheduled to be removed by the WVDP site contractor, CH2M HILL BWXT West Valley, LLC (CHBWV). Revision 3 of the BOSF RCR includes the characterization results collected after the removal of the T-FS-04 Building, the Biovent System Shack, and the Expanded Environmental Laboratory footings.
Please let us know ifNRC needs any additional information regarding this correspondence. Please refer any questions about this correspondence to Moira Maloney of my staff at (716) 942-4255.
Sincerely, 1
Br C. Bower, Director West Valley Demonstration Project
Enclosure:
DOE Responses to NRC Comments on the WVDP Radiological Characterization Report for the HLW Canister Interim Storage Area Rev. 1, April 4, 2014 and the Radiological Characterization Report for the BOSF, Rev. 3, July 2014 cc:
R. E. Holland, DOE-EMCBC, Office of the Director, w/o enc.
J. S. Kang, DOE-HQ, EM-41, CLOy, w/enc.
M. N. Maloney, DOE-WVDP, AC-DOE, w/o enc.
L. Camper, NRC, w/o enc.
D. Persinko, NRC, w/o enc.
A. Snyder, NRC, w/o enc.
P. J. Bembia, NYSERDA, AC-NYS, w/enc.
ZZZ:336158 450.4
DOE Responses to NRC Comments on the WVDP Radiological Characterization Report for the High Level Waste Canister Interim Storage Area Rev. 1, April 4,2014 and the WVDP Radiological Characterization Report for the Balance of Site Facilities (BOSF), Rev. 3, July 2014 Number Comment
Response
WVDP Radiological Characterization Report for the High Level Waste Canister Interim Storage Area Rev. 1, April 4, 2014 Page 2-13, the report states that
... thorium-232 There were no other analyses or evaluations performed during results were inferred from the gamma spectroscopy this investigation to determine that secular equilibrium was results for radium-228 and therefore, these two applicable to these disturbed soils.
radionuclides are the same. To make such an inference, were any other analyses or evaluations DOE-WVDP is not currently performing, and has not performed to determine that secular equilibrium applies performed, final status surveys at the WVDP. DOE-WVDP has to these disturbed soils or establish that such a been performing remedial action surveys as described in the relationship is appropriate? We understand that the Phase 1 Characterization Sampling and Analysis Plan for the purpose of the characterization that the U.S.
WVDP (CSAP), Rev. 1, June 201 1 for soils underlying the Department of Energy-West Valley (DOE-WV) is Balance of Site Facilities (BOSF) that have been removed as conducting now is to support remedial action surveys part of Phase 1 decommissioning activities. The BOSF include and final status surveys. However, it is important to ancillary buildings, site infrastructure, electrical substations understand that for final status surveys, the NRC and gravel and concrete pads scheduled for removal during expects that such a justification is either included or Phase I decommissioning. The purpose of these remedial referenced in the final status survey report for the action surveys is to characterize the contamination status of survey unit.
the soils exposed during BOSF removal to support future Phase I FSS data collection should DOE choose to perform Phase 1 FSS activities at a later date.
The gamma walkover survey and soil sampling at the base of the excavation of the High Level Waste Canister Interim Storage Area was performed to characterize soils prior to the construction of the storage pad. This investigation was not intended to be a remedial action survey or final status survey as this was a site construction activity and the DOE-WVDP was not planning to release this portion of the WVDP. This soil characterization work was performed consistent with the sampling protocols identified in the Phase 1 Final Status Survey Plan for the WVDP Rev. 1, May2011 (FSSP). The soil 1
In the Executive Summary of the report it states that the area was considered a Multi-Agency Radiological Site Survey and Investigation Manual (MARSSIM)
(EPA2000) Class I Area, or impacted area. In Section 2.1 page 2-1, the report states that SEC [Safety and Ecology Corporation] performed a GWS [gamma walkover survey] of 100% of the accessible area of ground surface formed after excavation in the HLW Canister Interim Storage Area was completed with a FIDLER detector. The entire survey unit is 4,485 square meters (m2) and 3,234 m2 were surveyed [clarifying text added]. Please explain why the entire 4,485 m2 storage area was considered as a single class 1 survey unit instead of two survey units since the maximum area recommended for land areas in Section 4.6 of MARSSIM is 2000 m2? What are the impacts, if any, with regard to the data evaluation?
data collected is expected to be of sufficient quanfity and quality to accurately assess the presence or absence of radiological contamination above the Phase 1 surface soil CGs below the concrete pad and to support the preparation of a final status survey once the HLW canisters have been relocated to a federal repository.
DOE-WVDP will identify all assumptions in its final status survey analyses and provide justification for these assumptions in the Final Status Survey Reports to be submitted to the NRC.
This area was considered a MARSSIM Class I Area, or impacted area, after radioactive contamination was detected while soil was being excavated. As stated in the Executive Summary The purpose of the radiological survey was to characterize the condition of the soils that underlay the concrete pad and the soils that were excavated to allow construction of the pad. The entire excavation for the HLW canister storage area was not considered a single Class 1 survey unit, nor was it divided into two 2000m 2 Class I survey units, as this radiological survey was not intended to be a final status survey as the DOE-WVDP was not planning to release this portion of the WVDP at this time. This area was selected for the interim storage area for the canisters of vitrified high-level waste currently stored in the Main Plant Process Building.
The soil characterization performed in this area was consistent with the sampling protocols identified in the Phase 1 Final Status Survey Plan for the WVDP Rev. 1, May 2011 (FSSP).
For Class 1 survey units the FSSP required 1) the collection of gamma walkover survey (GWS) data, 2) the collection of biased soil samples in areas where the GWS indicated gross gamma activities that might be indicative of CG exceedances, and 3) the collection of systematic soil samples representative of a depth of 0 tol_meter with the number of sampling 2
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The report states that Field Instrument for the Detection of Low-Energy Radiation (FIDLER) detectors were used for the gamma walkover surveys. On page 3-5, the report states that each detector was calibrated in accordance with the manufacturers specification and SECs Instrument Quality Assurance Plan, using National Institute of Standards and Technology (N 1ST)-
traceable standards. Also, on page 4-1 of the Field Sampling Plan, it states in Section 4.1 that the gamma walk over surveys will be used to determine areas that are not consistent with background conditions. What energy range or specific radionuclide source(s) was used to calibrate the FIDLER detectors? Were these detectors calibrated in an appropriate energy range so that the instrument could be used to guide the biased soil sampling? When using the FIDLER to detect areas not consistent with background, what Scan Minimum Detectable Concentration (MDC) was used to determine a need for collection of a soil sample and why?
locations not fewer than one per 100 m established on a 100 m2 triangular spaced grid.
The soil data collected according to FSSP protocols during this investigation is expected to be of sufficient quantity and quality to accurately assess the presence or absence of radiological contamination above the Phase 1 surface soil CGs below the concrete pad and to support the preparation of a final status survey once the HLW canisters have been relocated to a federal repository.
A Cs-i 37 source was used to calibrate the FIDLER detectors.
Due to the potential presence of multiple radionuclides with a wide range of energies no energy window was set for the GWS to guide biased soil sampling. The scanning minimum detectable concentration (SDMC) used in this investigation was provided in Table 4-i of the Field Sampling Plan for Task Order 9 Site Characterization Services West Valley Demonstration Project West Valley, New York, Rev.0 September 2013, and is reproduced below.
Radionuclide Type of Detector Scan MDC (pCi/g)
Am-241 FIDLER 30 C-i4 NA Cm-243 2x2 Nal 50 Cm-244 FIDLER 300 Cs-i 37 2x2 Nal 7
1-129 FIDLER 60 Np-237 FIDLER 30 Pu-238 FIDLER 100 Pu-239 FIDLER 200 Pu-240 FIDLER 100 Pu-241 NA Sr-90 NA Tc-99 NA 3
U-232 FIDLER 60 3
In Section 2.2.1 of the report it states that When systematic sampling is performed, one sample per 200 m2 area will be collected to a depth of 15 cm and submitted for analysis in accordance with the CSAP.
What is the basis for the sampling frequency sample per 200 m2 and how will the sample results contribute to meeting the objective of the characterization as stated in the Section 1.2 of the report? How will the data from such samples be used with regard to remediation and final status survey? Does DOE plan on performing further characterization in this area?
The referenced language in NRC comment 4 is not present in Section 2.2.1 or other sections of the Radiological Characterization Report for the High Level Waste Canister Interim Storage Area. Similar language to NRC comment 4 is found in Section 4.2.3, Systematic Soil Sampling, of the Task Order 9 Field Sampling Plan which reads When systematic characterization sampllng is performed in a remediated area, one sample per 200 m 2 area will be collected to a depth of 15 cm and submitted for analysis in accordance with the CSAP.
The referenced language in NRC comment 4 and Section 4.2.3 of the Task Order 9 FSP applies to the sampling density and depth for remedial action surveys performed at the WVDP as documented in Sections 7.1, WMA 1 and WMA 2 Excavation Support, and 7.3, Buried Infrastructure Footprint Contamination Status, of the CSAP. The work performed at the HLW canister storage pad was a construction activity and not a remedial action. The data collection activities at the bottom of the excavation were designed to support a future final status survey for the area once the canisters of HLW have been relocated to a federal repository. Consistent with this strategy the data collection activities followed the sampling protocols in the FSSP. As discussed in Section 2.2, Soil Sampling, of the HLW Canister Storage Area Report, soils from 0-100 cm below the excavation surface were collected from a total of 41 systematic soil sampling locations established on a 100 m2 triangular spaced grid which is consistent with the objectives of Section 1.2. The soil data collected as part of this investigation is expected to be of sufficient quantity and quality to accurately assess the presence or absence of radiological contamination above the 4
U-233 FIDLER 500 U-234 FIDLER 60 U-235 FIDLER 30 U-238 FIDLER 60 4
Phase 1 surface soil CGs below the concrete pad and to support the preparation of a final status survey once the HLW canisters have been relocated to a federal repository.
Future DOE soil characterization activities will include the excavated soils pile adjacent to the High-Level Waste Canister Interim Storage Area and the in-situ soils surrounding the High-Level Waste Canister Interim Storage Area after the HLW canisters have been shipped to a federal repository.
5 In the Executive Summary of the report it states that DOE-WVDP will be characterizing the spoils pile as part of site radioactive contamination was found approximately 7ff characterization activities being performed under the Phase 1 below the original ground surface in the HLW Canister Characterization Sampling and Analysis Plan for the WVDP Interim Storage and was removed as practical using Rev. 1 June 201 1 (CSAP). Once excavation activities were gamma radiation measurement to guide the excavation, completed in 2013 the spoils pile was hydroseeded and straw Also, the report states that Some of the contamination bales placed around the perimeter of the pile to prevent was spread to the spoils pile before it could be detected erosion and soil runoff. The straw bales were subsequently during the gamma walkover survey on the spoil pile.
removed after vegetation had established itself on the spoils The contamination on the spoils pile was removed pile.
using the gamma walk over survey data as a guide.
Contamination detectable by surveying for gamma radiation was removed. No soil samples were collected.
It is reasonable to suspect that some contamination above background remains. Further on page 2-3, the report states that No soil sampling was performed to verify that the contaminated material was removed because laboratory results could not be obtained immediately and further excavation and deposition on the spoils pile could not cease due to work scheduling needs. What are DOEs plans regarding further characterization of the spoils and what controls are in place to prevent spread of contamination due from potentially contaminated spoils?
6 DOE stated in response to NRC comment # 14 on A final status survey will not be performed at and around the DOEs Technical Evaluation Report for Phase I
HLW Canister Interim Storage Area until after the HLW Decommissioning Plan for the West Valley canisters have been shipped to a federal repository.
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Demonstration Project, dated June 3, 2010, that The Phase 1 DP has provisions for performing a final dose assessment for the residual radioactivity remaining in WMA I and WMA 2 excavations using final status survey data. Since no gamma scans or soil samples were performed on its side walls of the excavation where the HLW Canister Interim Storage Pad is now located, and no subsurface soil Derived Concentration Guidelines Levels (DCGL5) have been developed, what are DOEs plans with regard to any further characterization to support a final status survey or performance of a final status survey for any residual radioactivity remaining under the HLW Canister Interim storage pad and sides of the excavation?
The soil data obtained from the base of the excavation during this investigation was collected following FSSP protocols for Class 1 areas and is expected to be of sufficient quantity and quality to accurately assess the presence or absence of radiological contamination above the Phase I surface soil CGs for unrestricted release and to support the preparation of a final status survey once the HLW canisters have been relocated to a federal repository. Additional characterization of subsurface soils including the sidewalls of the excavation and soils surrounding the concrete storage pad will be performed during the final status survey of this area after the HLW canisters have been shipped.
WVDP Radiological Characterization Report for the Balance of Site Facilities (BOSF), Rev. 3, July 2014 Although we understand that the Balance of Site Facilities (BOSF) Radiological Characterization Report is a living document that will be updated periodically to document the remedial action surveys that are performed as BOSFs are removed from the West Valley Demonstration Project, it is unclear why the report does not identify MARSSIM classifications for the survey units in locations were samples were collected as does the Radiological Characterization Report for the High Level Waste Canister Interim Storage Area.
MARSSIM classifications were not made for the BOSE as these soil characterization activities were not final status surveys but remedial action surveys to characterize the presence of radiological contamination at the base of the excavations. The High Level Waste Canister Interim Storage Area was identified as a MARSSIM Class I or impacted area based on the detection of contamination during excavation activities. Soil characterization at the base of this excavation was performed following the survey and sampling protocols in the FSSP and is expected to be of sufficient quantity and quality to support the preparation of a final status survey once the HLW canisters have been relocated to a federal repository.
1 2
In the Executive Summary of the report, it states that Complete does not mean that no additional characterization This report is a living document because the BOSE will will be performed for those BOSEs described in the be removed at various times during the life of this attachments to the BOSE Radiological Characterization 6
project. Attachments will be added to this report when characterization is completed on a specific BOSF.
Does complete mean that no additional characterization will be conducted in the specific BOSE that has been added to the attachment to this report?
What are DOEs plans to perform remediation, if applicable? In cases where remediation is necessary, usually remedial action surveys are conducted to determine the effectiveness of the remediation. We recommend that such data should also be included in the appropriate attachment of this report. In cases where DOE believes that characterization is complete and no remediation or no further remediation is necessary, what are DOEs plans for final status surveys in such BOSFs? For those BOSFs with characterization data that show for each survey unit that the individual data points are below the DCGL, what controls does DOE have in place to ensure that such BOSFs will not be cross contaminated while other parts of the site are in active decommissioning?
Report. During Phase 2 decommissioning DOE-WVDP may choose to perform final status surveys in the areas of the BOSFs.
DOE-WVDP will include the remedial action survey data collected to evaluate the effectiveness of any soil remediation performed at a BOSE in the BOSE Radiological Characterization Report.
After evaluation of the characterization data collected from the BOSFs, DOE may decide to establish that these areas meet the surface soil CGs. In this case the NRC would be notified and Phase 1 Final Status Surveys would be performed in the area. Arrangements would be made with the NRC for confirmatory surveys, the Final Status Survey report prepared only after all issues had been resolved concerning the Final Status Survey results.
DOE has administrative controls in place for those BOSEs that have been characterized as being below the Phase 1 CGs to prevent their potential cross contamination from active decommissioning occurring elsewhere on the site. The site operations contractor requests DOE approval for any proposed operational use for such locations. It is expected that footprints of former BOSF will be incorporated into the site classification of areas for FSS.
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