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Category:Letter
MONTHYEARML23229A4712023-08-17017 August 2023 Change in the NRC Project Manager for the West Valley Demonstration Project IR 05000201/20230012023-03-28028 March 2023 West Valley Demonstration Project - U.S. Nuclear Regulatory Commission Monitoring Visit Report No. 05000201/2023001 ML23038A0402023-03-15015 March 2023 New York State Energy Research and Development Authority Results of a Teleconference to Discuss Disposition of Historical Records Related to the Former Nuclear Fuel Services, Inc ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities IR 05000201/20220032022-12-0606 December 2022 West Valley Demonstration Project - U.S. Nuclear Regulatory Commission Monitoring Visit Report No. 05000201/2022003 IR 05000201/20220022022-09-28028 September 2022 West Valley Demonstration Project - U.S. Nuclear Regulatory Commission Monitoring Visit Report No. 05000201/2022002 IR 05000201/20210012022-08-10010 August 2022 West Valley Demonstration Project: U.S. Nuclear Regulatory Commission Monitoring Visit Report Nos. 05000201/2021001 and 05000201/2022001 ML22180A1892022-06-21021 June 2022 Notification of Temporary Change in Radiation Safety Officer Position for New York State Energy Research and Development Authority'S Radiation Protection Program for the Retained Premises of the Western New York Nuclear Service Center ML22145A2972022-05-0202 May 2022 Letter from J. Dean to M. Pagels, Et Al., West Valley Supplemental Environmental Impact Statement Final Scope Dated 5/2/2022 ML21349B3442021-12-17017 December 2021 U.S. Department of Energy West Valley Demonstration Project - Demolition Readiness of the Main Plant Process Building Decommission and Demolition Plan (Docket No. 50-201 (POOM-032) ML21245A2462021-11-0505 November 2021 NYSERDA Retained Premises Radiation Protection Plan Amendment Package ML21202A2122021-07-15015 July 2021 Response to NRC Letter: Request for Additional Information Regarding the License Amendment to Incorporate Updated Retained Premises Radiation Protection Requirements (EPID L-2020-LLA-0029), Dated June 3, 20 ML21118A0762021-06-0303 June 2021 NYSERDA - Request for Additional Information Regarding the License Amendment to Incorporate Updated Retained Premises Radiation Protection Requirements ML21126A0232021-04-27027 April 2021 Us Dept. of Energy, West Valley Demonstration Project, Air Dispersion Modeling Performed in Support of West Valley Demonstration Project (Wvdp) Main Plant Process Building (Mppb) Demolition Preparations ML21105A3522021-04-0505 April 2021 Notification of Change in Radiation Safety Officer for the New York State Energy Research and Development Authority'S Radiation Protection Program for the Retained Premises of the Western New York Nuclear Service Center ML21012A3072020-12-15015 December 2020 Responses to NRC Comments on the West Valley Demonstration Project Main Plant Process Building Decommissioning & Demolition Work Plan, Revision 4 ML21012A2992020-12-14014 December 2020 West Valley Supplemental Environmental Impact Statement Schedule and Probabilistic Performance Assessment Technical Discussions IR 05000201/20200022020-11-0202 November 2020 U. S. Nuclear Regulatory Commission Monitoring Visit Report No. 05000201/2020002, West Valley Demonstration Project, West Valley, New York ML20311A2002020-10-28028 October 2020 Response to NRC Letter: Initial Review for NYSERDA Request for License Amendment: Retained Premises Radiation Protection Requirements (LAR-20-001), Dated March 11, 2020 (EPID L-2020-LLA-0023), Dated March 30, 2020 ML20261H5452020-09-24024 September 2020 Change in the NRC Project Manager for the West Valley Demonstration Project ML20268B2372020-09-24024 September 2020 Change in the NRC Project Manager for the West Valley Demonstration Project ML20265A3552020-09-22022 September 2020 Comments on Rev.4 Main Plant Process Building Demolition & Decommissioning Plan ML20115E4972020-04-27027 April 2020 Second Round of Comments on U.S. Department of Energy West Valley Demonstration Project'S Final Study Document: Vitrification Facility Air Emissions During Open-Air Demolition, Measured Vs Predicted, WVDP-579, Rev. 0 (Docket No. 05000201 (P ML20084G6412020-03-30030 March 2020 Letter, A.Snyder to P. Bembia, NYSERDA, Initial Review for NYSERDA Request for License Amendment: Retained Premises Radiation Protection Requirements (LAR-20-001), Dated March 11, 2020 ML20076C3102020-03-11011 March 2020 Resubmittal of Request for License Amendment: Retained Premises Radiation Protection Requirements ML20055E0492020-02-19019 February 2020 Response to Comments on U.S. DOE, Wvdp Air Study IR 05000201/20200012020-02-10010 February 2020 U.S. Nuclear Regulatory Commission Monitoring Visit Report 05000201/2020001, West Valley Demonstration Project, West Valley, New York ML20042D4972020-02-0606 February 2020 Western New York Nuclear Service Center - Request for License Amendment: Retained Premises Radiation Protection Requirements (LAR-20-001) ML19319A2932019-12-0404 December 2019 Comments on U.S. Department of Energy West Valley Demonstration Project Final Study Document: Vitrification Facility Air Emissions During Open-Air Demolition, Measured Vs Predicted, WVDP-579 ML19267A2102019-09-12012 September 2019 U.S. Department of Energy West Valley Demonstration Project Main Plant Process Building Decommissioning & Demolition Plan, WVDP-586, Revision 3 ML20265A3952019-06-19019 June 2019 June 19, 2019 Letter from Brian C. Bower to Amy Snyder, West Valley Main Plant Process Building, Rev. 3 IR 05000201/20190012019-06-18018 June 2019 U.S. Nuclear Regulatory Commission Monitoring Visit Report 05000201/2019001, West Valley Demonstration Project, West Valley, Ny ML19149A2362019-05-30030 May 2019 NRC Response Letter to DOE-WVDP on the Main Process Plant Demolition Work Plan ML19149A5552019-05-28028 May 2019 Vaughan Letter on CSM Corrections Needed - 5-28-19 ML18282A5232018-11-0707 November 2018 NRC Response to Nyserda'S Requests for Clarification of License Responsibility ML18290A5662018-11-0101 November 2018 Response to NYSERDA 10 CFR 50.59 Evaluation IR 05000201/20180022018-10-25025 October 2018 U. S. Nuclear Regulatory Commission Monitoring Visit Report No. 05000201/2018002, West Valley Demonstration Project, West Valley, New York ML18262A2542018-09-12012 September 2018 NYSERDA Letter Dated September 12, 2018 Requesting Clarification License Responsibility ML18236A3882018-08-27027 August 2018 U.S. Department of Energy West Valley Demonstration Project Main Plant Process Building Decommissioning & Demolition Plan, WVDP-586, Revision 1, Dated February 27, 2017 ML18179A3992018-07-26026 July 2018 Response Letter - the U.S. Army Corps of Engineers Buffalo District Design - Level Sediment Sampling and Analysis Plan - Springville Dam and Cattaraugus Creek Sediment Sampling, Dated April 2018 ML18222A2192018-06-19019 June 2018 NRC Solar Letter IR 05000201/20180012018-06-0707 June 2018 U.S. Nuclear Regulatory Commission Monitoring Visit Report No. 05000201/2018001. West Valley, Demonstration Project, West Valley, New York ML18192C1592018-05-0202 May 2018 May 2, 2018 Letter from NYSERDA Regarding Conforming CSF-1 to Current Site Conditions ML18087A6662018-04-0909 April 2018 Cover Letter TER for Wvnsnsc Off-Site Evaluation IR 05000201/20170012018-02-22022 February 2018 U.S. Nuclear Regulatory Commission Monitoring Visit Report No. 05000201/2017001, West Valley Demonstration Project, West Valley, New York ML18092A0562018-02-0505 February 2018 U.S. Department of Energy West Valley Demonstration Project (DOE-WVDP) Responses to U.S. Nuclear Regulatory Commission (NRC) Comments on DOE-WVDP Main Plant Process Building (Mppb) Decommissioning & Demolition (D&D) Plan ML17347A1252018-01-16016 January 2018 Letter to Us Army Corps of Engineers - NRC Comments on Springville Dam Sampling and Analysis Plan ML17270A1192017-09-28028 September 2017 NRC Comments on the U.S. DOE West Valley Demonstration Project Main Plant Process Building Decommissioning & Demolition Plan, WVDP-586, Revision 1 (Docket No. 05000201 (POOM-032) ML17227A3182017-08-18018 August 2017 U.S. Department of Energy West Valley Demonstration Project Vitrication Facility Decommissioning and Demolition Plan, WVDP-575, Revision 4 and Associated Air Modeling Evaluations (Docket No. 05000201 (POOM-032) ML17221A0752017-07-31031 July 2017 Letter from DOE Document, Features, Events, Processes, and Scenarios (Reps) Analysis for the West Valley Site and Conceptual Site Model for the West Valley Site 2023-08-17
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 26, 2018 William T. Frederick, P.G.
Hydrogeologist U.S. Army Corps of Engineers Buffalo District 1776 Niagara Street Buffalo, N.Y. 14207
SUBJECT:
THE U.S. ARMY CORPS OF ENGINEERS BUFFALO DISTRICT DESIGN -
LEVEL SEDIMENT SAMPLING AND ANALYSIS PLAN - SPRINGVILLE DAM AND CATTARAUGUS CREEK SEDIMENT SAMPLING, DATED APRIL 2018
Dear Mr. Frederick:
The U.S. Nuclear Regulatory Commission (NRC) received the U.S. Army Corps of Engineers (USACEs) email (Agencywide Documents Access and Management System [ADAMS]
Accession No. ML18179A117), dated April 27, 2018, requesting that the NRC and other stakeholders review the subject document and provide feedback. Attached to the email were several documents to include a letter from the USACE showing how the USACE dispositioned the NRCs recommendations on the earlier version of the sampling and analysis plan (SAP), a project quality assurance plan (QAPP); and the contamination contingency plan that identifies the USACE civil works policy for HTRW [Hazardous, Toxic and Radioactive Waste] impacts discovered at civil works projects.
As indicated in the SAP, [t]he project goal is to retrieve sediment samples from the channel of the Cattaraugus Creek at specific locations to determine whether sediments targeted for future removal meet the New York State criteria for a positive beneficial use determination (BUD) and thus uncontrolled re-use at an upland site. As noted in our January 16, 2018, letter (ADAMS Accession No. ML17347A125), the NRC would become involved in this activity, if offsite residual radioactivity was identified that was shown to be associated with the former West Valley reprocessing plant (NRC License CSF-1, Docket 50-0201). The NRC staff (staff) agreed to conduct a courtesy review of the USACE sediment SAP and contingency plan once these plans were finalized.
The staff completed its review of April 27, 2018, submittal. The staff found that the USACE generally addressed the staffs January 16, 2018, comments on the October 2017 version of the SAP. Specifically, the USACE updated the SAP to include 1) subsample retention, 2) field instrument applicability and scanning methods, 3) equal subsample mass in the composite, and
- 4) comparison of results to the chemical criteria and radiologic background ranges to address
W. Frederick NRCs comments. Additional edits were made by the USACE, such as the addition of the QAPP and Appendix A which provides details on the field scanning methodology materials, to address NRCs comments.
Also as noted in our January 16, 2018, comment letter, field screening may be beneficial for various purposes. This comment applies to samples that are not saturated. The staff note that, when handling saturated sediment samples, it is very unlikely there would be any detectable resuspension of environmental radiological contaminants and doesnt expect any radiological health and safety concerns to arise. However, it is presumed that typical sampling PPE and protocols will be utilized that normally include the use of latex gloves, decontamination steps, and contamination surveys. The staff also note that the SAP appeared to require alpha/beta surface activity scanning for each sample core as well as gamma scanning using a 2 x 2 Sodium Iodide detector. It is the staffs experience that alpha/beta scanning of damp sediment is unlikely to provide useful information. For damp volumetric contamination, the surface efficiency for alpha/beta is much lower than what is presumed in the minimum detectable concentration calculations and scanning the sample core for surface alpha/beta activity is likely not necessary. However, the gamma scanning can provide useful information and should be retained.
The USACE letter dispositioning the NRC comments alludes to NRC guidance and notes that for three subsamples from a single core location in a composite that investigation levels for Class 1 and Class 2 areas would be divided by 3. However, USACE also makes arguments as to why the screening ranges based on background are orders of magnitude below any risk-based criteria. It is NRC staffs understanding that USACE intends to retain background ranges as the screening criteria for comparison against composite sample results and has provided justification for why these screening criteria are protective of members of the public. Also, the staff noticed an apparent inconsistency between the value of 14.2 in Section 8.3 of the SAP and the value of 15.2 in footnote c of Table 3 in the SAP.
The staff also note, if the USACE is not using the same analytical laboratory used by DOE for the background determination, then bias can be introduced. This may occur when different laboratory methods and calibration sources are employed. Bias could also arise from the decay of some contaminants and sediment transport and deposition since the time that the WVDP samples were taken. These potential biases should be considered when comparing the Springville Dam Restoration Project sediment data to the WVDP data. The USACE should be aware that these biases could be present and may need to evaluate the data and laboratory reports to try to ascertain whether small variations outside of the background ranges appear to have a natural cause or may be due to licensee radiological activities or analytical bias.
Based on the PowerPoint presentation, Springville Dam Restoration (ADAMS Accession No. ML18179A118) and USACEs Water Resource Policies and Authorities HTRW Guidance for Civil Works Projects, dated June 26, 1992 (ER 1165-2-132) (ADAMS Accession No. ML18179A120), included in the April 27, 2018, submittal, it is the NRCs understanding that these two documents represent the USACEs contingency plan. Further, we understand that the project partners (USACE, New York State Department of Environmental Conservation [NYSDEC], and Erie County) plan is to monitor for HTRW materials and if they are
W. Frederick found during the implementation of the project, it will be up to the project partners to decide what to do and how to pay for the clean-up, should it be needed. The staff requests that the USACE notify the NRC if the project partners determine that the material in question is offsite residual radioactivity shown to be associated with the former West Valley reprocessing plant.
The staff would then determine if any further actions are necessary.
In accordance with Title 10 of the Code of Federal Regulations Part 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
You indicated that NRC comments on the earlier version of the SAP improved the sampling plan and strategy. We hope that our additional comments will also assist the project partners. We appreciate the opportunity to comment on this version of the SAP and do not expect to see a revised version of the SAP again because of the general nature of our comments. If you have any questions, please contact Ms. Amy Snyder, Senior Project Manager of my staff. She can be reached amy.snyder@nrc.gov or 301 415-6822.
Sincerely,
/RA A. Snyder for/
Stephen Koenick, Chief Materials Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket No. 50-0201 License No. CSF-1 cc:
P. Bembia, NYSERDA B. Bower, DOE-WV A. Iglesias, EPA T. Rice, NYSDEC D. Samson, NYSDOH
ML18179A399 OFC DUWP DUWP DUWP DUWP OGC DUWP (NLO)
NAME A. Snyder C. Holston S.Koenick C.McKenney S.Clark S.Koenick A Gross for Amy via email Snyder for:
DATE 6/26/18 7/5/18 7/8/18 7/10/18 7/24/18 7/26/18