ML16293A131
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NYSE RDA ANDREW M. CUOMO RICHt:lRD L KAUFFMAN JOHN B. 1;iHODES Governor Chair President and CEO August 24, 2016 Mr. Matthew R. Meyer, Acting Chief Materials Decommissioning Branch Division of Decommissioning Uranium Recovery And Waste Programs Office of Nuclear Material Safety And Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852
SUBJECT:
Radiological Survey and Dose Assessrhent Report For the Western New York Nuclear Service Center and Off-Site Areas In Follow Up to Aerial Gamma Radiation Survey, Rev. 0, dated August 22, 2016
Dear Mr. Meyer:
NYSERDA is submitting the Radiological Survey and Dose Assessment Report For the Western New York Nuclear Service Center and Off-Site Areas In Follow Up to Aerial Gamma Radiation Survey Conducted in 2014, Rev.
0, dated August 22, 2016, accompanying references and appendices, and a matrix in response to your comments.
Please contact me or Andrea Mellon at 716-942-9960 extension 4900 or 4054, respectively, if you have any questions.
Sincerely, PJB/amd PJB/16amd024.amd New York State Energy Research and Development Authority
.Afbany Buffalo New York City West Va!ley Site 17 Columbia Circle, Albany, NY 12203-6399 726 Exchange Srree;: 1359 Broadway Management Program (P/ 1-866-NYSERDA I (F) 518-862-1091 Suite 821 19tl1 Floor 9030-B Route 219 Buffalo. NY New Yor~. NY West Valley. i'IY r;yserda.ny.gov I info~*nyserda.ny.gov 14210-1484 10018-7842 14171-9500 (P) 716-842-1522 (P) 212-971-5342 (P) 7*16-942-9960 (F) 716-842-0156 (t=) 518-862-'1091 (F) 716-942-9961
Mr. Matthew R. Meyer, Acting Chief Page 2 August 24, 2016 Attachments:
- 1. Radiological Survey and Dose Assessment Report For the Western New York Nuclear Service Center and Off-Site Areas In Follow Up to Aerial Gamma Radiation* survey, Rev. 0, dated August 22, 2016.
- 2. References 1-19.
- 3. Appendices A-1.
4;. NYSE RDA Responses to NRC Audit Comments on the Draft West Valley Soil Sampling and Dose Assessment Report, Dated 8/23/2016
- 5. Remote Sensing Laboratory GIS Project files
Reference:
- 1. Letter, Matthew R. Meyer, NRC, to Paul J. Bembia, NYSERDA, "Regulatory Audit Report- Review of Offsite Characterization and Public Dose Assessment Documentation and Processes for the Western New York Nuclear Service Center in Follow Up to the Aerial Gamma Radiation Survey Conducted in 2014 (CSF-1, Docket Number: 050-0020i Cost Activity Code: L53127)," dated July 14, 2016.
cc: J. A. Dean, NYSERDA-Albany (w/o att.) Janice.Dean@nyserda.ny.gov A. L. Mellon, NYSERDA-WV (w/o att.)Andrea.Mellon@nyserda.ny.gov N. C. Shaw, NYSERDA-Albany (w/o att.) Noah.Shaw@nyserda.ny.gov A. Snyder, NRC, (w/att.) Amy.Snyder@nrc.gov B. C. Bower, DOE-WVDP, (w/o att.) Brvan.Bower@wv.doe.gov DOESupporstaff@wv.doe.gov (w/o att.)
File: #30004-0210 (w/att.)
NYSERDA Responses to NRC.Audit Comments on the Draft West Valley Soil Sampling and Dose Assessment Report Dated 8/23/2016 No. NRC comme.nt'.
- 1 Provide documented data quality Section 4.0, Data Quality Objectives, of the August 22, 2016 Radiological Survey and Dose objectives for field measurements Assessment Report for the Western New York Nuclear Service Center and Off-Site Areas, and analytical measurements. and Section A.6:1, Data Quality Objectives, to the Quality Assurance Project Plan, were updated to include detailed la!lguage addressing the data quality objectives for field and analytical measurements.
2 Provide documented data quality See resolution information above. In addition, Appendix E, Field Sample and Instrument assessment methods and results Checks, has been updated to include a Project Data Quality Parameter Crosswalk Table for field measurements and that assesses field and laboratory data quality.
analytical measurements.
3 Clarify how results for All surface samples were analyzed for gross alpha, gross beta and gamma spectroscopy radionuclides besides Cs-137 were (all gamma emitters, including Cs-137). In addition, expanded analysis from each sub-area recorded and evaluated .. were collected and include radionuclide specific results for Am-241, C-14, 1-129, Np~237, Pu-238, Pu-239/240, Pu-241, Sr-90, Tc-99, U-232, U-233/234, *u-235/236, U-238, H-3, Th-229, Th~23o, Th-232, Ra-226 and Ra-228.
4 For each sample area, explain how Uncertainty was evaluated for sample areas and all field and analytical measurements uncertainty was considered in the met the acceptance criteria identified in the Quality Assurance Project Plan and the GEL conclusions regarding health and Laboratory Quality Assurance Plan. An assessment of the criteria is also found in the safety risk. Project Data Quality Parameter Crosswalk Table located in Appendix E. Finally, regarding the conclusions reached for each sample area regarding health and safety risk, multiple survey and data collection efforts were implemented to independently calculate dose values that support these conclusions. These efforts include:
- Comparison of the aerial radiation survey data results to background aerial radiation survey results.
- Follow-up gamma walkover and tissue equivalent surveys completed for each area to d.etermine if any elevated locations were within an area, and to calculate the dose rates at each location.
- . Soil sample collection at either the elevated locations or at random locations determined based on the size of the sampling area.
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NYSERDA Responses to NRC Audit Comments on the Draft West Valley Soil Sampling and Dose Assessment Report Dated 8/23/2016 No. iNRCComment . *" *. ** .-*. *Resolution ofComment ** **** .*~
- In addition, sample collection and analysis at multiple depths to evaluate the potential for contamination at depth.
- Detailed radionuclide analysis were .completed for a minimum of 20 percent of each area.
- Background soil sample collection representative of the s*ample areas to remove contributions from the naturally occurring radionuclides and other environmental background constituents.
- Collection of deta.iled current land use information from the individual property owners to support the dose assessment.
- Calculation of a current land use dose assessment using the soil dat~, area geology and land use information.
- Calculation of a conservative reasonably foreseeable future land use dose assessment.
- Calculation of a dose for consumption of fish.
The multiple survey and data collection efforts implemented for each area support the conclusion that the each of the sampling areas do not pose a health and safety risk.
5 Additional information addressing An annual radiation dose for Areas 1, 2, and 3 from the consumption of fish has been the fish ingestion.pathway and included in the August 22, 2016 Radiological Survey and Dose Assessment Report for the other pathways that m.ay be Western New York Nuclear Service Center.and _Dff-site Areas (see Sections 7.1.5, 7.2.5 and important to potential receptors in 7.3.5).
the area based on reasonably foreseeable future land use.
6 Information on how land use Detailed land use survey information is provided for Areas 1, 2 and 3 in Appendix D. In survey and geographical data addition, an On-Site RESidual RADioactive material (RESRAD 7.0 Computer Code) dose helped informed development of assessment for Areas 1, 2 and 3 was calculated using the most conservative reasonably*
site-specific exposure scenarios for foreseeable future land use of a Resident Farmer (except as noted for Sub-area 2.1).
use in the dose assessment.
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o~~h~ Draft West Valley Soil Sampling and Dose Assessment i- ' ...
NYSERDA Responses to NRC Audit Comments Report Dated 8/23/2016
- No.- -._ * ..... *- _
- _ _ . -. Resolu_tion of.Comment - _. *: . . - . __ *::** ":
7* Provide rationale for selection of The rationale for using Am-241 and Pu-239 as' the most limiting alpha-emitting Am-241 or Pu-239 (alpha-emitting), radionuclides and Sr-90 as the most limiting beta radionuclides is included on Page ES-3 and Sr-90 (beta emitting) to of the Executive Summary.
represent the most limiting alpha-and beta-emitting radionuclides (e.g., other alpha-emitting radionuclides have lower Phase 1 U.S: Department of Energy's West Valley Demonstration Project Phase 1 Decommissioning Plan clean-up values or derived-concentration guideline levels).
8 Provide clarification on approach Section 3.1 of the August 22, 2016 Radiological Survey and Dose Assessment Report for used to identify areas of concern the Western New York Nuclear Service Center and Off-site Areas, details the criteria used for the purpose of conducting by the Remote Sensing Laboratory (RSL) to delineate the specific areas where follow-up walkover surveys including use of sampling was warranted. One of the criterion used was to determine the boundaries of 300 to 3000 ft range (see Section areas where there was evidence to support the Cs-137 and anthropogenic spectral 3.1 of Draft report). signature.s. For these areas, the distance between overlapping or in proximity areas was determined by RSL to be less than or equal to 300 feet. In addition, overlapping areas of concern were grouped together to the extent possible and gamma walkover surveys, tissue equivalent surveys, and soil sampling activities extended to beyond the delineated grouped area to ensure that the entire area of concern was evaluated.
9 RESRAD-OFFSITE input files A complete set of the RESRAD-OFFSITE Input files is included in Attachment H. _
associated with Appendix H used for dose assessment.
10 GIS Project file containing Remote The Remote Sensing Laboratory GIS Project files are enclosed as a separate CD in this Sensing Laboratory data, and shape submittal.
files used to delineate areas of concern.
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NYSERDA Responses to NRC Audit Comments on the Draft West Valley Soil Sampling and Dose Assessment Report Dated 8/23/2016 No. NRC Comment Resolution of .Comment 11 Spreadsheet of data linking In Appendix F, the global positioning system coordinates for each sampling location have Appendix F of the draft report been added to the Excel spreadsheet containing the sample identification information.
coordinates and Appendix B of the draft report sampling results.
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