ML101090500

B. Bower Ltr New York State Energy Research and Development Authority (NYSERDA) Comments on the Phase 1 Characterization Sampling and Analysis Plan for the West Valley Demonstration Project

ML101090500
Person / Time
Site:	West Valley Demonstration Project, P00M-032
Issue date:	04/07/2010
From:	Bembia P J State of NY, Energy Research & Development Authority
To:	Bower B C NRC/FSME, US Dept of Energy, West Valley Demonstration Project
References
Download: ML101090500 (14)

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IN hERDA Niew York State Energy Research and Development Authority Vincent A. Delorio, Esq., Chairman Toll Free: 1 (866) NYSERDA www.nyserda.org

• info@nyserda.org April 7, 2010 Mr. Bryan C. Bower, Director U.S. Department of Energy West Valley Demonstration Project 10282 Rock Springs Road West Valley, NY 14171-9799

SUBJECT:

New York State Energy Research and Development Authority (NYSERDA)

Comments on the Phase 1 Characterization Sampling and Analysis Plan for the West Valley Demonstration Project NYSERDA is providing the enclosed comments on the Department of Energy's (DOE) Phase 1 Phase 1 Characterization Sampling and Analysis Plan for the West Valley Demonstration Project, dated February 3, 2010.NYSERDA respectfully requests that DOE provide a written response to the enclosed comments.Any questions regarding the enclosed comment package should be directed to Paul L. Piciulo, Ph.D., at (716) 942-9960 extension 4378.Sincerely, VALLEY SITE MANAGEMENT PROGRAM PLP/amd

Enclosure:

1. NYSERDA Comments on the Phase 1 Characterization Sampling and Analysis Plan for the West Valley Demonstration Project PJB/10amd020.plp Main Office Albany 17 Columbia Circle Albany, NY 12203-6399 Toll Free: 1 (866) NYSERDA Phone' (518) 862-1090 Fax:(518) 862-1091 West Valley Site Management Program 10282 Rock Springs Road West Valley, NY 14171-9799 Phone: (716) 942-9960 Fax: (716) 942-9961 New York City.485 Seventh Ave., Suite 1006 New York, NY 10018 Phone: (212) 971-5342 Fax: (212) 971-5349 Buffalo Larkin at Exchange Building 726 Exchange Street, Suite 821 Buffalo, New York 14210 Phone: (716) 842-1522 Fax: (716) 842-0156 Messr. Bryan C. Bower Page 2 April 7, 2010 cc: cK-7IMeC6-niillNRC, w/enc.M. S. Bellis, USDOE-WVDP, w/enc.M. N. Maloney USDOE-WVDP, w/enc.D. A. Munro, NYSERDA-Alb, w/enc.J. C. Kelly, NYSERDA-WV, w/enc.P. L. Piciulo, Ph.D., NYSERDA-WV, w/enc.A. L. Mellon, NYSERDA-WV, w/enc.PJB/IOamdO2O.plp NYSERDA Comments on the Phase I Characterization Sampling and Analysis Plan for the West Valley Demonstration Project April 7,_2010#~~PagI~etwn

~.. ~ ~ Heviewers Proposed R~esoluliwn

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~~> ~ omm11ents oil Chaplters 1. General Comment The Characterization Sampling and Analysis Plan (Plan) Consistent use of the terms "surface soil," "surficial uses the terms "surface soil," "surficial soil," "subsurface soil," "subsurface soil," and "buried soil" throughout the soil," and "buried soil." The use of the term surface soil in Plan will avoid confusion.

the Plan should be consistent with usage in the Phase 1 Decommissioning Plan (DP). Specifically the DP defines surface soil as the depth interval 0 -1 m. Care should also be taken. when using the term subsurface soil as the DP defines subsurface soil as soil deeper than 1 m, while the Section 6.6 of the Plan defines buried contamination as soil deeper than 1 m. The interchange of the terms can create confusion.

2. 5/Sect. 2.1/Para.

1/Line 2 The sentence reads "The level and vertical/lateral Correct the typographical error.distribution of contamination in Erdman Brook and Franks Creek sediments with the WVDP premises are not known." Change the word "with" to "within." 3. 6/Bullet #14/Line 5 The text states that if the subsurface contamination data Describe the process and/or criteria used to determine collected as part of the Permeable Treatment Wall (PTW) whether PTW contamination data are sufficient to project "are considered insufficient for the WMA 1 and support barrier wall designs.WMA 2 barrier wall design, then additional subsurface data will be collected from these areas." What criteria will be used to determine whether the data are sufficient (or insufficient) for the barrier-wall design?4. 8/Sect. 2.3/Para.

3/First Bullet The description of Waste Management Area (WMA) 2 Add language to the WMA 2 description to more closely refers to the excavation of Lagoons 1, 2 and 3; however, follow the scope discussed in the Phase 1 DP.Lagoons 4 and 5 also reside within the scope of Phase 1 decommissioning work.5. 9/Sect. 2.3/Para.

4/Fourth Briefly describe the construction activities planned for the Insert language pertaining to the construction activities Bullet high-level waste canister storage facility within WMA 6. that will. take place within WMA 6.6. 15/Sect. 3.3/Line 1 Will the Quality Assurance Project Plan be provided to Respond to question.NRC for review and comment?1 of 12

,, ~ ~. ReViewers Proposed-Resolution

7. 24/Table 2 Verify the data presented in "Table 2: ROI Samples Verify and revise the data presented in Table 2. Include Results from Three Locations (pCi~g)." Specifically,, the -other- Geoprobe locations where expanded-ROI -sample values identified for GP 78 and GP 30 appear to be in error results exist.for Sr-90. Also, include the other Geoprobe locations where expanded Radionuclides of Interest (ROIs) exist from the 1998 sampling effort, or provide the technical rationale as to why these data locations were omitted.8. 29/Sect. 6.5/Third Bullet Section 6.5 discusses the process that will be used to Clarify the term "very limited sampling." Will samples determine the extent of surface soil contamination, be collected at 0-15 cm and 0-1 m? Describe how the Specifically, if *areas are identified from the gamma sampling process will ensure that the extent of walkover survey (GWS) data that clearly indicate surface contamination exceeding CGw has been identified for the contamination above the cleanup guidance (CG) for the area/unit.

entire area/unit (i.e., CGw), additional sampling will be conducted to define the areas of elevated contamination and the lateral extent of this contamination.

This bullet states that "very limited sampling" will be conducted to confirm GWS findings.9. 30/Sect. 6.5/First Bullet/Line 3 In addition to areas such as hardstands and paved areas, Revise text to read "areas where surface cover limits the GWS data may be inconclusive in areas where the soil has utility of GWS such as hardstands, paved areas, and areas been reworked or contamination may have been covered by where surface soils have been reworked or covered." clean soil.10. 31/Sect. 6.5/Second Bullet/ The second line states that exceptions to using the surface. Define the exact cleanup criteria that would apply to the Line 2 soil CG requirements are "well-defined portions of Erdman "well-defined portions of Erdman and Franks within the Brook and Franks Creek within thle WVDP premises." WVDP premises." However, the text never provides alternative cleanup criteria for the portions of Erdman Brook and Franks Creek. Presumably, as per the text, the ."sediment" CG requirements would apply to these exceptions.

11. 3 1/Sect. 6.5/Para.

2/Second The description for drainage features does not address the Clarify how the old sewage treatment drainage would be Bullet old sewage treatment drainage that is identified elsewhere addressed under the Plan.in the document.12. 3 1/Sect. 6.5/Para.

2/Second.

A "0 -1 sample" is described without providing any units. Insert the correct -units (meters).Bullet/Last Line 13. 34/Sect. 6.6/Fifth Bullet This bullet states that "... the initial soil samples from a Clarify how "selected cases" are chosen and identify location will be anialyzedfor all 18 ROIs." In addition, the what criteria are used to, determine if additional analyses 2 of 12 11 o I I I o)111 I I$7~ Ic~W (I orcm t is a I Lii (.tintpo al doesni't ned a.t##ParaPran/Lie/Bullet.

lio'additional 12 potential ROIs will also be analyzed "in are to be performed.

A discussion of the criteria used in selected cases." Define the term "selected cases" and the selection process would assist the reviewer in clarify -what criteria will be used to determine if additional understanding the basis for this statement.

For example, analyses are performed.

are the cases selected based on process knowledge of the activities performed in the area/unit, etc.?14. 37/Lines 1-4 It is unclear why only one discrete sample will be collected Provide the rationale as to why only one discrete sample-for the stream area extending from the confluence of is being collected as being representative of the sediment Erdman Brook and Franks -Creek to the WVDP fence line, contamination in the specified area of the stream, and since the length of that area is about 200 ft long. Also, if why a sample would not be collected at depth if the the sample yields a result above background, wouldn't it be surface sample is above background.

Also, clarify the consistent with the balance of the creek sampling to collect criteria to be used for selecting the sample location, and and analyze a sample from the 0 to 1 m depth interval?

explain how this sample location is representative of heaviest sediment contamination in the 200-ft-long area.15. .40/Sect.

6.8/First Bullet This bullet states that "If buried infrastructure of potential Revise this bullet and expand the lateral/vertical extent of concern is identified that intersects the planned WMA 1 or these trenches to* outside the WMA 1 or WMA 2 WMA 2 excavation footprints, one of the trenches used to excavation footprint to ensure that all potential expose the buried infrastructure will be. along the planned contamination along this buried infrastructure has been excavation boundary and evaluated for the presence of identified..

adjacent soil contamination." 16. 40/Sect. 6.8/Para.

1/Line 2 The following sentence is awkward: "... contamination Correct the typographical error.does exist o the opposite the excavation footprint for slurry wall footprints." 17. 41/Sect. 6.10 Contamination status of all soils that may be affected by Revise this section to include evaluation of subsurface Phase 1 construction'needs to be determined.

Specifically, soils and surface soils greater than 15 cm to determine prior to using an area as a soils lay-down area, which contamination status prior to -use as a lay-down area would bury the existing land surface, contamination status supporting construction needs.should be determined and documented for surface soils greater than 15 cm as well as subsurface soils.18. 50/Sect. 7.1/Para.

3/Line 1 Provide an approximate slope angle (45 degrees?)

for the Provide an approximate slope angle for the southern side southern wall of WMA 2 similar to the discussion of the of the WMA 2 excavation.

WMA 1 sides.19. 52/Sect. 7.1/Para.

2 This section should include a description of the actions that Provide language in this section that identifies how will be-taken if contamination above the cleanup standards lateral contamination, if found in WMA 1 during Phase 1 is identified in the sloped soil walls of the excavation in activities, will be documented for inclusion in the Phase WMA 1. Specifically, if contamination is identified, but 2 DP process.3 of 12 the full lateral extent of the contamination is unknown and limited due to the sheet .pilings, the potential for lateral .contamination should be documented and continued in the Phase 2 DP.20. 58/Sect. 8.2/Third Bullet; Clarification is needed regarding the 20 composite samples Revise Section 8.3 to be consistent with Section 8.2, 59/Sect. 8.3/Para.

1 (10 at~ 15-cm soil. depth and 10 at the 1-in depth). including the 15 cm -1 in depth discrete random sample Specifically, Section 8.2 identifies that one sample from for these analyses.each of the original sample depth locations will be selected and analyzed at random for the 18 ROIs and the additional 12 ROIs; yet Section 8.3 states that only the 0-15 cm depth discrete sample will be analyzed at random for the 18 ROIs and the additional 12 ROIs.21. 59/Sect. 8.3/Para.

1 This Section states that surface soil sample results are Provide the technI inale foru te 95% UTL in considered "inconsistent with background" if the activity addition to three times the uncertainty for the concentrations exceed their 95% Upper Tolerance Level anthropogenic surface soil radionuclides.(UTL) "by more than three times the reported error associated with the result." .Using the 95%-UTL in addition to three times the uncertainty for the anthropogenic surface soil radionuclides, could potentially create much larger"- background concentration levels for the nonnaturally occurring radionuclides.

22. 83/Sect. 11.5/First Bullet Additional information regarding how each control chart is Clarify how each control chart will be maintained and maintained should be included in the text; specifically a describe what documentation will be included for each description of how biased conditions, trends and out-of- detector.control situations, etc. are documented.

23. 87/Table 5 Target sensitivity values for plutonium' are incorrect in the Amend the references to 'footnotes for the plutonium footnotes.

The notes state that the reported value in the values listed in Table 5. Also, parentheses are missing for table is "25% of background for naturally occurring some footnotes in the Table.radionuclides." A naturally occurring background value does not apply to plutonium; the correct footnote should be"2" or 10% of the most restrictive radionuclide-specific cleanup goal.24. 89/Sect. 13 Will management of the characterization data include GIS Revise the text to more clearly describe characterization mapping similar to that described in Section 5.0 for the data storage/management.

4 of 12 buried infrastructure inventory?

+ -t 92/Sect. 14.0/Para.

1 Clarification of the corrective actions that will be conducted if performance falls outside of expected ranges is needed for this section.Describe the types of corrective actions that will be undertaken when "performance falls outside of expected ranges." In addition, how is the definition of performance falling outside of expected ranges being determined?

____ ~ $~~mmets ________________________________I General Comment The CG, Sampling protocol presented in the Surface Soil Reconcile the fact that surface soi Sampling sections of the appendices appears to be identical 1 DP as the interval from 0-1 m for all except WMA 3. Soil samples are collected at two locations where only the top 15 depths (0 -15 cm and 0 -1 m) when the GWS results the text to be consistent when a indicate surface soil contamination levels likely exceed rule -(i.e., where two samples surface soil CG,. However, when GWS results indicate the top 15 cm and the interval fi contamination levels above background but less than CGw, for sampling in areas where and when it is unclear that the contamination levels disturbed or covered with clean s indicated by the GWS results exceed CG,, only a 5- the 0 -I m depth interval.increment composite soil sample from a 0 -15 cm depth interval is collected.

The composite sample from a depth of 0 -15 cm does not meet the definition of surface soil presented in the DP and Section 6.5 of the Plan. How can you compare the contamination levels of the composite soil sample with the CGw values derived for surface soil defined as being the interval from 0 -1 m? Section 6.5 of the Plan states that the 0 -15 cm depth sample would be collected to: (1) assess direct exposure dose issues and (2)to limit dilutions; yet it also states that a two-sample per location requirement would apply to all locations except"areas where there is no evidence of historical contamination." The collection of soil samples from the two-depth intervals would be particularly important in those areas where the surface soil was reworked or where potential contamination may have been covered by clean soil.I is defined in the Phase while this Plan calls for cm are sampled. Revise pplying the two-sample vould be collected from orom 0-1 in). Procedures.the- surface soil was oil must address soils in 27. General Comment 1 In Appendices A through J of the Plan (all WMAs), the Describe the criteria that will be used to select samples to section entitled Required Laboratory Analyses states: "A be analyzed for the 12 radionuclides of potential interest.5 of 12 Commen ;-,i,6iit'6clariticationi prqba)'b1 3ý dEsnit'need a,1 select portion of the samples may be analyzed for the additional radionuclides of potential interest." What Provide an explanation of why analysis of. 10% of soil criteria will be used to select the samples for additional samples for the 12 radionuclides of potential interest is analysis?

Also, for WMA 1, 2, and 3, the Plan states: "In not required for WMA 4, 5, 6, 7, 9, 10, and 12.addition, ten percent of the soil samples ... will also be analyzed for the 12 radionuclides of potential interest..." The requirement for analyzing 10% of soil samples for the 12 radionuclides of potential interest is not included for WMA 4, 5, 6, 7, 9, 10, and 12.28. General Comment For consistency purposes, refer to Section 2.3 of the Phase To provide consistent language when discussing known I .DP and Chapter 3.11 of the Final Environmental Impact or suspected releases, the Phase I DP and the FEIS Statement (FEIS) when discussing known or suspected should be reviewed, and the information contained releases in each of the WMAs. therein incorporated into this section of the Plan.29. A-I/Sect.

A. I/Para. 2 The first sentence states that "Descriptions of the various Correct the error in the text.features of WMA 2 follow and are taken from the Phase 1 DP." This statement should apply to WMA 1, not WMA 2.30. A-4/ Sect. A.4/Para.

2 The statement that "This leak also contributed to sewage Revise this statement attributing the sewage treatment treatment system contamination" is misleading.

While the system contamination to the failure of-the sanitary sewer Line 7P-240 failure may have contributed to this line.contamination,, the failure of the sanitary sewer line (located south of the Line 7P-240) is the cause of this contamination.

There were multiple leaks or spills in the area that likely contributed to the contamination that entered the failed sanitary sewer line.31. A-9/Sect.

A.9. 1/Last Sentence The last sentence in this paragraph should be amended to Correct the grammatical error.state "... wastewater lines as well as buried utilities." 32. A-1O/Sect.

A.9.3/Second For the CG, sampling, the analytes are not explicitly Add additional language under this bullet for the list of Bullet identified.

Under the previous bullet for Hot Spots (CGemc), radionuclides.

the samples are analyzed for the 12 potential radionuclides as well as the 18 ROIs. The description for CGw sampling is silent on the appropriate analyte list.33. A-10/Sect.

A.9.3 Areas in WMA 1 have been reworked or covered with soil. Amend the CGw Sampling protocol to assure the The surface soil sampling protocol should systematically collection and analysis of soil samples in the 0 -1 m address the 0 -1 m depth interval (see General Comment depth interval.6 of 12 Pa e--inl4ý~jiýa~

[ f-1,h bi 1C, PaarahLine/Blullet

i. .-~ ii~i~e~#26).A-12/Sect.

A.9.4/First Bullet What is the basis for cutting off the subsurface soil Provide the technical rationale for limiting subsurface sampling under paved areas at 1 m? For reasons already soil sampling to depths of 1 m in paved areas of WMA 1.identified in this Plan (e.g., past practices of placing clean fill over construction areas and the spreading of the North Plateau Groundwater Plume), it seems plausible that contamination could be found at depths greater than 1 m beneath paved areas in WMA 1.A-12/Sect.

A.9.4 Under the section describing subsurface soil sampling, there does not appear to be a defined methodology for sampling the -area surrounding the foundation pilings in WMA 1. The Plan discusses subsurface areas below paving, sampling for waste- characterization, and subsurface sampling along the boundaries of the excavation, but no methodology is provided for assessing potential contaminants that may have traveled down along the foundation pilings (of the Main Plant), and into the underlying Lavery Till and Kent Recessional.

Section A.7 states that the pilings will be evaluated during excavation, but no further details are provided.Identify the process for assessing the contamination once the foundation pilings are exposed. As with the buried infrastructure, little is known about the pilings until excavation has begun.36. A-13/Sect.

A.9.4/Second The last sentence states that that these data will be used "to Correct the error in the text.Bullet/Last Sentence estimate waste stream volumes resulting from the excavation of WMA 2." Appendix A should be referring to WMA 1 (not WMA 2).37. A-14/Sect.

A.9.4/Additional Under the first sub-bullet, the Plan states that "if any 0-15 Explain why it is appropriate to collect samples from the Contingencies cm surface soil sample result indicates contamination top 15 cm of soil in areas that are clearly disturbed from impacts above background levels and there was not a 0-1 past construction and soil management activities.

m sample collected from that location, a 0-1 m sample will be collected from that location following the protocols used for the original 0-15 cm surface soil sample." This statement implies that there could be a scenario where a 0-15 cm sample is collected, and if no contamination is found, then a 0-1 m sample will not be collected.

With the extensive historical information regarding reworking of soils for construction activities in WMA 1, this sampling 7 of 12

<Pae/SctdiI:

~~ 4c-Rev-iewers Pr~posed esolution4 CJ§ ' (1 Y4'*"44TII~

IS a,2~ P0ointbf0TMifj1Ai~natfip ba~ly d&snl't needia-method, which may be suitable for undisturbed portions of the site in WMAs 4, 10 and 12, seems inappropriate for, .WMA 1.38. A-15/Sect.

A.9.5/Firstbullet The first sentence under this bullet should'be amended as Correct grammatical error.follows: "Three locations along each piece of buried infrastructure...." 39. A-43/Figure A.23 While soil core locations for the Sheet Piling Footprint Since a description of the Slurry Wall Footprint Characterization are depicted in Figure A.23, there is no Characterization is included in Section A.9.4, revise similar depiction of the soil core locations for the Slurry Figure A.23 to show sampling locations for the Slurry Wall Footprint Characterization on the northern and Wall.eastern sides of WMA 1.40. B-2/Sect.

B.1/First Bullet Clarify that the materials exhumed from WMA 5 (i.e., the Include contaminated asphalt in the description of the Old Hardstand) were used as fill for Lagoon 1. materials used to fill Lagoon 1.Specifically, add contaminated asphalt to the debris description that was used as fill in Lagoon 1.41. B-2/Sect.

B. 1/Second Bullet To be consistent with the descriptions provided for Amend the language describing Lagoon 2.Lagoons 1 and 3, include language that Lagoon 2 was fed directly by Lagoon 1 and contains contaminated sediments from the 1984 Lagoon 1 Closure.42. B-6/Sect.

B.1/ Continued Include language related to the current use of the leachate Append the text to include language specifying the Bullet transfer pipeline.

Specifically, that the pipeline currently current use 6f the leachate transfer pipeline.transfers liquids collected in the NRC-Licensed Disposal Area (NDA) Interceptor Trench to Lagoon 2 for treatment.

43. B- 14/Sect. B.9. 1/Last The last sentence in this paragraph should be rewritten as Correct the grammatical error.Sentence follows: "This infrastructure would. include wastewater lines as well as buried utilities." 44. B-16/Sect.

B.9.3 Areas in WMA 2 have been reworked or backfilled with Amend the CGw Sampling protocol to assure the soil as stated in Section B.3. The surface soil sampling collection and analysis of soil samples in the 0 -I rn protocol should systematically address the 0 -1 m depth depth interval.interval (see General Comment #26).45. B-17/Sect.

B.9.4 Expand* the sampling efforts to include the soils Provide details within the document describing additional surrounding Lagoon 1 to define the lateral and vertical subsurface sampling of the soils surrounding Lagoon 1.extent of contamination around Lagoon 1. This sampling 8 of 12 CoII Il -- 11 hmnt~ ",Ill your a~on.fý o'will identify any potential migration of contaminants from Lagoon 1 or the fill placed in Lagoon 1.46. B-18/Sect.

B.9.4/First Bullet In assessing the 1.7 acres in the western area of WMA 2, Provide a technical basis for subsurface sampling down what is the basis for collecting a sample to a depth of 1 m? to 1 m.Given the reworking of soils in the area and spreading of.. the North Plateau Groundwater Plume, it would seem plausible that contaminiation could exist below 1 m.47. B-21/Sect.

B.9.6/First Bullet Modify the first sentence under this bullet to read: "Three Correct the grammatical error.locations along each piece of buried infrastructure that is of concern within WMA 2 will be trenched." 48. C-10/Sect.

C.9.3/First Bullet In describing the analytes for the samples collected to Provide a list of analytes for the 0-1 m samples.assess hot spots, the text states that the 0-15 cm samples will be analyzed for the 12 potential radionuclides as well as the 18 ROI. The text does not mention the target analytes for the 0-1 m samples.49. C-A 1/Sect. C.9.5/First Bullet Reword the first sentence under this bullet to state: "Three Correct the grammatical error.locations along each piece of buried infrastructure that is of concern within WMA 3 will be trenched."_ ALpnA;_ f) Coninipnca s 50. D-2/Sect.

D.3 The area history, as conveyed through a description of the Provide additional details on the operational history of various aerial photographs, doesn't capture the fact that the CDDL.disposal operations at the Construction and Demolition Debris Landfill (CDDL) began as early as 1963, and continued through 1981 (under Nuclear Fuel Services) and 1984 (under the U.S. Department of Energy).51. D-8/Sect.

D.9.2 Areas in WMA 4 have been reworked or backfilled with Amend the CG, Sampling protocol to assure the soil and have been impacted by groundwater contamination collection and analysis of soil samples in the 0 -1 m that has surfaced into drainage areas. The surface soil depth interval.sampling protocol should systematically address the 0 -1 m depth interval (see General Comment #26).52. E-3/Second and Third Bullets The two bullets make one sentence.

Correct the grammatical error.53. E-12; Sect. E.9.3 j As stated in Section E.2, the soils in WMA 5 have been Amend the CGw Sampling protocol to assure the 9 of 12

__77 1?h Re)vze 't"sProp'sed esoldii oil 2~lein C~~Yommlent',ý dl %111 ý ,(I1yourcommet -is apoiht-fc~aificationiit~probb6 dentaec reworked at least once since the inception of the site. The collection and analysis of soil samples in the 0 -1 m surface soil sampling-protocol should systematically depth interval.address the 0 -1 m depth interval (see General Comment#26).54. E-16/Sect.

E.9.5/First Bullet Reword the first sentence under this bullet to state: "Three Correct the grammatical error.locations along each piece of buried infrastructure that is of concern within WMA 3 will be trenched." 55. F-I/Sect.

F. 1 This section should include a description of the Old Amend the text accordingly.

Sewage Treatment Plant (STP), the area surrounding the Old STP and the current radiological condition of this area.56. F-2/Sect.

F. I Clarify if any actions are planned for the North Waste Tank Describe any proposed actions for the North Waste Tank Farm Test Tower Foundation.

Will this foundation also be Farm Test Tower Foundation.

removed during the Phase I activities?

57. F-12/Sect.

F.9.3 Areas in WMA 6 have been reworked or backfilled with Amend the CGw Sampling protocol to assure the soil (e.g., Old Sewage Treatment Plant drainage channel).

collection and analysis of soil samples in the 0 -1 m The surface soil sampling protocol should systematically depth interval.address the 0 -I m depth interval (see General Comment#26).58. F-17/Sect.

F.9.6/First Bullet Reword the first sentence under this bullet to state: "Three Correct the grammatical error.locations along each piece of buried infrastructure that is of concern within WMA 3 will be trenched." 59. G-12/Sect.

G.9.3 Areas outside the geomembrane cover (in WMA 7) have Amend the CGO, Sampling protocol to assure the been reworked or backfilled with soil. The surface soil collection and analysis of soil samples in the 0 -I m sampling protocol should systematically address the 0 -1 depth interval.m depth interval (see General Comment #26). *60. G- 14/Sect. G.9.5/First Bullet Under the first bullet, the text states that ditch sampling Explain why the northern boundary drainage features do along the eastern boundary will include samples not require samples of a greater depth interval.

Again, it representing a 0-1 m depth interval.

It is unclear why other is unclear why application of the two-sample approach is drainage locations would not require samples from the 0-1 inconsistent in those areas where soils are reworked or m depth interval, active sediment deposition is occurring.

61. G-15/Sect.

G.9.6/First Bullet Reword the first sentence under the first bullet to state that Correct the grammatical error."Three locations along each piece of buried 10 of 12 infrastructure..." G-20/Table G.2 Table G.2 "Sample Number Estimates," identifies that Verify that information presented in Section G.9.5 and there are no biased sediment samples for the 0-1 m discrete Table G.2 is both accurate and consistent.

depth interval, yet in Section G.9.5, 0-1 m, discrete depth interval samples are taken of the NDA Eastern Ditch Boundary.

Verify the information, and be consistent in the data presented in Section G.9.5 and Table G.2.Appjndix Htomets 63. H-3/Sect.

H.4/Line 1 The first sentence in this section should be revised to read: Correct the grammatical error."The Drum Cell is the only building in WMA 9 and is targeted for removal during Phase 1." 64. H-7/Sect.

H.9.2 The statement is made that "If GWS results indicate no Amend the CG, Sampling protocol to assure the evidence of contamination impacts above background collection and analysis of soil samples in the 0 -1 m levels, no additional surface soil sampling will be required depth interval.other than to address areas too wet to perform a gamma walkover survey." Given that both the Subcontractor Maintenance Area and the NDA Trench Soil Container area have had soils and gravel placed on top of them, it seems unwise to eliminate these areas based on a walkover survey. The surface soil sampling protocol should systematikally address the 0 -1 m depth interval (see General Comment #26).65. H-7/Sect.

H.912/Second The last sentence under, this bullet states that Correct the text accordingly.

Bullet/Last sentence "...contamination exceeding surface soil CG, requirements are along the boundary between WMA-1O and WMA 1, 3, and 5." This appendix applies to WMA 9 and should not refer to WMA 10.66. 1-10/Sect.

1.9.3 Section 1.4 states that surface soils may have become Amend the CG, Sampling protocol to assure the contaminated from airborne releases.

There are areas collection and analysis of soil samples in the 0 -1 m within WMA 10 where trailers were installed and later depth interval.removed, and the surface soils were reworked.

The surface soil sampling protocol should systematically address the 0-1 m depth interval (see General Comment #26).II of 12 k ~ j>Re~iWeI~ProoJsed Re z toltwn"'-~ ~ ~ .~ommnt If ourc~tsa ihtfi~aiiicaionit probal doesn tineed~a 67. J-2/Sect.

J.3/Para.

3 Figure J.3 shows WMA 12 in -1966, and identifies a "soils Vrify the source of the contamination.-

push-out' area being visible from WMA 2 into WMA 12.Further, this section states that "This push-out area is of significance because it corresponds to elevated direct gamma reading collected in 1990-1991." Since the push-out area was created prior to the 1968 air stack release, have other potential sources of the contamination been/detected?

68. J-5/Sect.

J.7 Provide data to support the statement that "No Provide data to support -that there have been no environmental releases of contamination within WMA 12 environmental releases of contamination within WMA are believed to have occurred." This statement seems to 12, or amend this language to be consistent with Figures contradict Figures J.5 and J.6, and should be resolved for J.5 and J.6.consistency.

69. J-9/Sect.

J.9.2 Areas in WMA 12 have been reworked or backfilled With Amend the CG, Sampling protocol to assure the soil (e.g., the soils push-out area near WMA 2 and areas collection and analysis of soil samples in the 0 -I m north of WMA 7). The surface soil sampling protocol depth interval.should systematically address the 0 -1 m depth interval (see General Comment #26)..70. J-13/Sect.

J.9.5 Section J.9.5 states that "Figure J.13 identifies those Provide the rationale for not performing sediment portions of Erdman Brook and Franks Creek where sampling on the identified portions of WMA 12 to sediment CG requirements apply." The western areas of confirm the lateral extent of contamination and areas of Erdman Brook are not included in the sampling areas potential remediation.

shown in J.13. There is known sediment contamination present in the Old STP Drainage Channel, which extends from WMA 6 into WMA 12. Additionally, the tributary of Erdman Brook that extends northwest toward WIVIAs 2 and 6 are not included in the sampling areas. Figures J.5 and J.6 suggest contamination in that stream area.71. No comments 12 of 12