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 of Nuclear 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 Area for 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 Plan for 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 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 if NRC 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
B r 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
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.
2 In the Executive Summary of the report it states that This area was considered a MARSSIM Class I Area, or the area was considered a Multi-Agency Radiological impacted area, after radioactive contamination was detected Site Survey and Investigation Manual (MARSSIM) while soil was being excavated. As stated in the Executive (EPA2000) Class I Area, or impacted area. In Section Summary The purpose of the radiological survey was to 2.1 page 2-1, the report states that SEC [Safety and characterize the condition of the soils that underlay the Ecology Corporation] performed a GWS [gamma concrete pad and the soils that were excavated to allow walkover survey] of 100% of the accessible area of construction of the pad. The entire excavation for the HLW ground surface formed after excavation in the HLW canister storage area was not considered a single Class 1 Canister Interim Storage Area was completed with a survey unit, nor was it divided into two 2000m 2 Class I survey FIDLER detector. The entire survey unit is 4,485 square units, as this radiological survey was not intended to be a final meters (m2) and 3,234 m2 were surveyed [clarifying status survey as the DOE-WVDP was not planning to release text added]. Please explain why the entire 4,485 m2 this portion of the WVDP at this time. This area was selected storage area was considered as a single class 1 survey for the interim storage area for the canisters of vitrified high-unit instead of two survey units since the maximum level waste currently stored in the Main Plant Process area recommended for land areas in Section 4.6 of Building.
MARSSIM is 2000 m2? What are the impacts, if any, with regard to the data evaluation? 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
locations not fewer than one per 100 m established on a 100 2 triangular spaced grid.
m 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.
3 The report states that Field Instrument for the Detection A Cs-i 37 source was used to calibrate the FIDLER detectors.
of Low-Energy Radiation (FIDLER) detectors were used Due to the potential presence of multiple radionuclides with a for the gamma walkover surveys. On page 3-5, the wide range of energies no energy window was set for the report states that each detector was calibrated in GWS to guide biased soil sampling. The scanning minimum accordance with the manufacturers specification and detectable concentration (SDMC) used in this investigation SECs Instrument Quality Assurance Plan, using was provided in Table 4-i of the Field Sampling Plan for Task National Institute of Standards and Technology (N 1ST)- Order 9 Site Characterization Services West Valley traceable standards. Also, on page 4-1 of the Field Demonstration Project West Valley, New York, Rev.0 Sampling Plan, it states in Section 4.1 that the gamma September 2013, and is reproduced below.
walk over surveys will be used to determine areas that are not consistent with background conditions. What Radionuclide Type of Detector Scan MDC (pCi/g) energy range or specific radionuclide source(s) was Am-241 FIDLER 30 used to calibrate the FIDLER detectors? Were these C-i4 NA detectors calibrated in an appropriate energy range so Cm-243 2x2 Nal 50 that the instrument could be used to guide the biased Cm-244 FIDLER 300 soil sampling? When using the FIDLER to detect areas Cs-i 37 2x2 Nal 7 not consistent with background, what Scan Minimum 1-129 FIDLER 60 Detectable Concentration (MDC) was used to Np-237 FIDLER 30 determine a need for collection of a soil sample and Pu-238 FIDLER 100 why? Pu-239 FIDLER 200 Pu-240 FIDLER 100 Pu-241 NA Sr-90 NA Tc-99 NA U-232 FIDLER 60 3
U-233 FIDLER 500 U-234 FIDLER 60 U-235 FIDLER 30 U-238 FIDLER 60 4 In Section 2.2.1 of the report it states that When The referenced language in NRC comment 4 is not present in systematic sampling is performed, one sample per 200 Section 2.2.1 or other sections of the Radiological 2 area will be collected to a depth of 15 cm and m Characterization Report for the High Level Waste Canister submitted for analysis in accordance with the CSAP. Interim Storage Area. Similar language to NRC comment 4 is What is the basis for the sampling frequency sample found in Section 4.2.3, Systematic Soil Sampling, of the Task per 200 m 2 and how will the sample results contribute to Order 9 Field Sampling Plan which reads When systematic meeting the objective of the characterization as stated characterization sampllng is performed in a remedia ted in the Section 1.2 of the report? How will the data from area, one sample per 200 m 2 area will be collected to a depth such samples be used with regard to remediation and of 15 cm and submitted for analysis in accordance with the final status survey? Does DOE plan on performing CSAP.
further characterization in this area?
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 m 2 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
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 The soil data obtained from the base of the excavation during Phase 1 DP has provisions for performing a final dose this investigation was collected following FSSP protocols for assessment for the residual radioactivity remaining in Class 1 areas and is expected to be of sufficient quantity and WMA I and WMA 2 excavations using final status quality to accurately assess the presence or absence of survey data. Since no gamma scans or soil samples radiological contamination above the Phase I surface soil were performed on its side walls of the excavation CGs for unrestricted release and to support the preparation of where the HLW Canister Interim Storage Pad is now a final status survey once the HLW canisters have been located, and no subsurface soil Derived Concentration relocated to a federal repository. Additional characterization of Guidelines Levels (DCGL5) have been developed, what subsurface soils including the sidewalls of the excavation and are DOEs plans with regard to any further soils surrounding the concrete storage pad will be performed characterization to support a final status survey or during the final status survey of this area after the HLW performance of a final status survey for any residual canisters have been shipped.
radioactivity remaining under the HLW Canister Interim storage pad and sides of the excavation?
WVDP Radiological Characterization Report for the Balance of Site Facilities (BOSF), Rev. 3, July 2014 1 Although we understand that the Balance of Site MARSSIM classifications were not made for the BOSE as Facilities (BOSF) Radiological Characterization Report these soil characterization activities were not final status is a living document that will be updated periodically to surveys but remedial action surveys to characterize the document the remedial action surveys that are presence of radiological contamination at the base of the performed as BOSFs are removed from the West Valley excavations. The High Level Waste Canister Interim Storage Demonstration Project, it is unclear why the report does Area was identified as a MARSSIM Class I or impacted area not identify MARSSIM classifications for the survey based on the detection of contamination during excavation units in locations were samples were collected as does activities. Soil characterization at the base of this excavation the Radiological Characterization Report for the High was performed following the survey and sampling protocols in Level Waste Canister Interim Storage Area. 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.
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 Report. During Phase 2 decommissioning DOE-WVDP may characterization is completed on a specific BOSF. choose to perform final status surveys in the areas of the Does complete mean that no additional BOSFs.
characterization will be conducted in the specific BOSE that has been added to the attachment to this report? DOE-WVDP will include the remedial action survey data What are DOEs plans to perform remediation, if collected to evaluate the effectiveness of any soil remediation applicable? In cases where remediation is necessary, performed at a BOSE in the BOSE Radiological usually remedial action surveys are conducted to Characterization Report.
determine the effectiveness of the remediation. We recommend that such data should also be included in After evaluation of the characterization data collected from the the appropriate attachment of this report. In cases BOSFs, DOE may decide to establish that these areas meet where DOE believes that characterization is complete the surface soil CGs. In this case the NRC would be notified and no remediation or no further remediation is and Phase 1 Final Status Surveys would be performed in the necessary, what are DOEs plans for final status area. Arrangements would be made with the NRC for surveys in such BOSFs? For those BOSFs with confirmatory surveys, the Final Status Survey report prepared characterization data that show for each survey unit only after all issues had been resolved concerning the Final that the individual data points are below the DCGL, Status Survey results.
what controls does DOE have in place to ensure that such BOSFs will not be cross contaminated while other DOE has administrative controls in place for those BOSEs parts of the site are in active decommissioning? 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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