ML16293A131
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ANDREW M. CUOMO Governor NYSE RDA RICHt:lRD L KAUFFMAN Chair JOHN B. 1;iHODES 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 17 Columbia Circle, Albany, NY 12203-6399 (P/ 1-866-NYSERDA I (F) 518-862-1091 r;yserda.ny.gov I info~*nyserda.ny.gov Buffalo 726 Exchange Srree;:
Suite 821 Buffalo. NY 14210-1484 (P) 716-842-1522 (F) 716-842-0156 New York City 1359 Broadway 19tl1 Floor New Yor~. NY 10018-7842 (P) 212-971-5342 (t=) 518-862-'1091 West Va!ley Site Management Program 9030-B Route 219 West Valley. i'IY 14171-9500 (P) 7*16-942-9960 (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.)
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NYSERDA Responses to NRC.Audit Comments on the Draft West Valley Soil Sampling and Dose Assessment Report NRC comme.nt'.
- Provide documented data quality objectives for field measurements and analytical measurements.
Provide documented data quality assessment methods and results for field measurements and analytical measurements.
Clarify how results for radionuclides besides Cs-137 were recorded and evaluated..
For each sample area, explain how uncertainty was considered in the conclusions regarding health and safety risk.
Dated 8/23/2016 Section 4.0, Data Quality Objectives, of the August 22, 2016 Radiological Survey and Dose Assessment Report for the Western New York Nuclear Service Center and Off-Site Areas, 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.
See resolution information above. In addition, Appendix E, Field Sample and Instrument Checks, has been updated to include a Project Data Quality Parameter Crosswalk Table that assesses field and laboratory data quality.
All surface samples were analyzed for gross alpha, gross beta and gamma spectroscopy (all gamma emitters, including Cs-137). In addition, expanded analysis from each sub-area 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.
Uncertainty was evaluated for sample areas and all field and analytical measurements met the acceptance criteria identified in the Quality Assurance Project Plan and the GEL Laboratory Quality Assurance Plan. An assessment of the criteria is also found in the 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 iNRCComment Additional information addressing the fish ingestion.pathway and other pathways that m.ay be important to potential receptors in the area based on reasonably foreseeable future land use.
Information on how land use survey and geographical data helped informed development of site-specific exposure scenarios for use in the dose assessment.
Dated 8/23/2016
- Resolution ofComment
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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.
An annual radiation dose for Areas 1, 2, and 3 from the consumption of fish has been included in the August 22, 2016 Radiological Survey and Dose Assessment Report for the Western New York Nuclear Service Center.and _Dff-site Areas (see Sections 7.1.5, 7.2.5 and 7.3.5).
Detailed land use survey information is provided for Areas 1, 2 and 3 in Appendix D. In addition, an On-Site RESidual RADioactive material (RESRAD 7.0 Computer Code) dose assessment for Areas 1, 2 and 3 was calculated using the most conservative reasonably*
foreseeable future land use of a Resident Farmer (except as noted for Sub-area 2.1).
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10 NYSERDA Responses to NRC Audit Comments o~~h~ Draft West Valley Soil Sampling and Dose Assessment Report Provide rationale for selection of Am-241 or Pu-239 (alpha-emitting),
and Sr-90 (beta emitting) to 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).
Provide clarification on approach used to identify areas of concern for the purpose of conducting walkover surveys including use of 300 to 3000 ft range (see Section 3.1 of Draft report).
RESRAD-OFFSITE input files associated with Appendix H used for dose assessment.
GIS Project file containing Remote Sensing Laboratory data, and shape files used to delineate areas of concern.
Dated 8/23/2016 Resolu_tion of.Comment The rationale for using Am-241 and Pu-239 as' the most limiting alpha-emitting radionuclides and Sr-90 as the most limiting beta radionuclides is included on Page ES-3 of the Executive Summary.
Section 3.1 of the August 22, 2016 Radiological Survey and Dose Assessment Report for the Western New York Nuclear Service Center and Off-site Areas, details the criteria used by the Remote Sensing Laboratory (RSL) to delineate the specific areas where follow-up sampling was warranted. One of the criterion used was to determine the boundaries of areas where there was evidence to support the Cs-137 and anthropogenic spectral 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.
A complete set of the RESRAD-OFFSITE Input files is included in Attachment H. _
The Remote Sensing Laboratory GIS Project files are enclosed as a separate CD in this submittal.
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11 NYSERDA Responses to NRC Audit Comments on the Draft West Valley Soil Sampling and Dose Assessment Report NRC Comment Spreadsheet of data linking Appendix F of the draft report coordinates and Appendix B of the draft report sampling results.
Dated 8/23/2016 Resolution of.Comment In Appendix F, the global positioning system coordinates for each sampling location have been added to the Excel spreadsheet containing the sample identification information.
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