ML22277A463
| ML22277A463 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 08/22/2022 |
| From: | Marlayna Vaaler Doell Reactor Decommissioning Branch |
| To: | Van Noordennen G EnergySolutions |
| Doell M, 301-415-3178 | |
| Shared Package | |
| ML22277A350 | List: |
| References | |
| Download: ML22277A463 (4) | |
Text
From:
Doell, Marlayna To:
Gerard P. Van Noordennen-ext
Subject:
RE: RE: [EXTERNAL] Additional Question for ES about WTB Sample Judgmental 16 Date:
Monday, August 22, 2022 2:11:00 PM Hi Gerry!
Thanks for the quick turnaround on this. Leah and I chatted this morning and if the Cesium-137 concentration result for the sample in question was just a typo then I think we are good to go without the need for most of the rest of the questions below, with the exception of three small items:
- 1. Could your folks confirm that the scans indicated in the figure your provided in the LACBWR Gamma Spec Typo document were taken in September 2017 as stated in the writeup, even though the figure is dated March 2019? I assume the 2017 scan data was just collated later in the project and then the figure was produced, but wanted to be sure!
- 2. Is Sample L1-010-101-FJ-GS-C16-SB still available in the sample inventory? There is no wrong answer to this one, just trying to figure out its availability to be re-sampled in case we get any push back from OGC on moving forward with docketing the explanation for the incorrect record of the survey result, which I do not anticipate.
- 3. Could you confirm that the other excavation side walls received the same type of scan coverage as the information provided for the WTB excavation? It seems pretty clear the answer is yes, but I think the team got worried when we didnt have the figure you provided today to reference for the scanning of the side walls of the WTB survey unitand in fact if you have the similar scan figures for any of the other excavation survey units could we have them (this is NOT a formal request, just a nice to have to confirm the 100% scan requirement, and only if easy to track down!)?
I am going to check with our OGC folks to see if just adding the info you provided to the docket is sufficient to reference in relation to the closeout of the review for this survey unit, or if we need something a little more formal for this specific item to note the incorrect record of the survey result.
If needed at all, I am envisioning that would just be submitting the same information under a cover letter, but I will let you know ASAP!
Given the resolution of most of the items below it is up to you whether you would like to keep the La Crosse call for this Wednesday to discuss this item or anything else that might be relevant to the scan coverage for the excavation survey units. I didnt realize this is a Zion heavy week, so if it is easier to cancel this conversation for now and/or wrap it into a larger final follow-up in the future that is fine toojust let me know!
Thanks again, sorry for the spin up over a typo, but glad we were able to get to the bottom of it!
Hope you had a great weekend otherwise and please give me a shout if you have questions or need anything additional!
- Cheers, Marlayna 301.415.3178
From: Gerard P. Van Noordennen-ext <gpvannoordennen-ext@energysolutions.com>
Sent: Monday, August 22, 2022 6:58 AM To: Doell, Marlayna <marlayna.doell@nrc.gov>
Subject:
[External_Sender] RE: [EXTERNAL] Additional Question for ES about WTB Sample Judgmental 16
- Marlayna, I put 2 files in BOX to respond to these questions.
Gerry van Noordennen Senior Vice President Regulatory Affairs EnergySolutions
121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Cell: 860-462-9707 gpvannoordennen-ext@energysolutions.com
- This e-mail and any of its attachments may contain EnergySolutions, LLC proprietary information, which is privileged, confidential, or subject to copyright belonging to EnergySolutions, LLC. This e-mail is intended solely for the use of the individual or entity to which it is addressed. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution, copying, or action taken in relation to the contents of and attachments to this e-mail is strictly prohibited and may be unlawful. If you have received this e-mail in error, please notify the sender immediately and permanently delete the original and any copy of this e-mail and any printout.
Thank You****
From: Doell, Marlayna <marlayna.doell@nrc.gov>
Sent: Tuesday, August 16, 2022 4:21 PM To: Gerard P. Van Noordennen-ext <gpvannoordennen-ext@energysolutions.com>; Sarah Roberts
<sroberts@energysolutions.com>
Subject:
[EXTERNAL] Additional Question for ES about WTB Sample Judgmental 16
EXTERNAL: This message is from a NON-EnergySolutions sender, please ensure it is from a legitimate source.
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suspicious in any way.
Hi again!
So we have been scratching our heads a little this week about judgmental sample 16 from the original FSS data for the WTB, and how (whether?) the side walls of this (and other?) excavation survey units were included in the 100% coverage scans, as well as the handling of elevated areas per the LTP in general. Some of this may be based on a misunderstanding, but the main concern is that the data suggests the surveys may not be including the side walls in the scans of the excavations.
And importantly we have evidence that there was an elevated area in the side wall of WTB per sample 16. Accordingly, if you could take a look at the below as we prepare for an additional call next week I would appreciate it:
In the final responses to the NRC questions from June 7, in response to Question 3 the licensee provided a spreadsheet (attached) with the original samples that were taken for the WTB survey unit, collected 9/12/17 - 9/14/2017. Sample number L1-010-101-FJ-GS-C16-SB shows a concentration of 154 pCi/g of Cs-137. This sample is shown in the associated figure as being outside the boundary of the survey unit to the west. It is also outside the boundary of the part of the survey unit that was later remediated (which is shown in the dotted line). In the call on Friday, the licensee said that sample 16 was taken from the sidewall of the excavation on the west side.
- 1. If the spreadsheet is accurate and sample 16 was 154 pCi/g of Cs-137, please explain if the sample area was investigated per Section 5.6.4.6 of the LTP, which states that any samples above the Operational DCGL (17.39 Cs-137) would be investigated. (The Base Case DCGL for Cs-137 is 48.3 pCi/g.) If the sample area was not investigated please provide (1) information as to why not; (2) a bounding analysis for the potential area and volume of soil that could bound the elevated area near sample 16; and (3) an assessment of the potential dose contribution of this elevated area.
- 2. Please provide an analysis of why the licensee believes an elevated area was located on the WTB sidewall. The response to Question 11 discusses a general lack of oversight of the contractor performing the excavation of the WTB. Please indicate if additional contamination could have spread to the side walls during the excavation activities.
- 3. The licensee indicated that they could not locate the original gamma spec reports. Please indicate whether these can be identified with some additional effort or if they are no longer available. Please also indicate if the licensee is in possession of the original sample 16 and if so whether it could be recounted.
- 4. The license provided a map of the scan lanes for the original FSS in Figure 1 and for the remediated portion of the WTB in Figure 3. They also provided a photo showing that the scan lanes marked E and N showing a view facing east. The NRCs interpretation of this data is that the area to the west that contained the sample with 154 pCi/g of Cs-137 appears not to have been scanned, either in the original or post-remediation scans for the WTB. Note that MARSSIM states that Class 1 survey units should receive a 100% scan, and unless an argument
is presented that classifies the sidewalls differently, they would also be expected to receive 100% coverage. The survey classification of an excavation should consider whether the entire excavated area, including the floor and the sidewalls, has the same contamination potential.
In this case, the side walls are considered part of the same Class 1 survey unit and should have received a scan. Note that the release record states that soil scanning was performed on 100% of the total surface area in the survey unit even though the scans in Figure 3 provided only cover the remediated area. Please indicate whether the side walls of the excavation, especially to the west received a scan. Please provide additional information to support that acceptable levels of contamination remain in the portions of the survey unit that were not scanned (including the side walls).
- 5. Please clarify the extent to which the side walls were scanned for the other excavation survey units. If the sidewalls were not scanned as part of the 100% scan of the excavation, please provide a technical basis for why.
I am hopeful there is an easy answer to all of these but wanted to add them to the open item list while there is still an opportunity. Let me know if next week still works for a call and I can work to get something on the calendar. Much appreciated as always and please give a shout if you need anything in the meantime!
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Decommissioning Project Manager U.S. Nuclear Regulatory Commission NMSS/DUWP/RDB
Phone: 301.415.3178 Mobile: 440.668.7399 Home: 605.348.2334 E-mail: marlayna.doell@nrc.gov Office Location: Fulltime Telework from Rapid City, South Dakota!
Mail Stop: T-5A10