ML090990053

NYSERDA Comments on Phase 1 Decommissioning Plan for the West Valley Demonstration Project (Enclosure 1) to NRC and Us Department of Energy

ML090990053
Person / Time
Site:	West Valley Demonstration Project, P00M-032
Issue date:	12/03/2008
From:	State of NY, Energy Research & Development Authority
To:	NRC/FSME/DWMEP/DURLD
References
Download: ML090990053 (18)

Text

Enclosure #1: "NYSERDA Comments on the Phase 1 Decommissioning Planfor the West Valley DemonstrationProjectto the U.S. Nuclear Regulatory Commission and the U.S.

Department of Energy"

NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject, Dated December 3, 2008 S`cfton, -,

Tae,-Fi g'uir.-e) ~~ment Proposed, Reolution

'Pag # (Paragrah Line),,

General NYSERDA employed the technical support of an NYSERDA would appreciate written responses Independent Expert Review Team (LERT) to assist in describing how NYSERDA's comments, as well as the the review of the Phase 1 Decommissioning Planfor concerns raised by the IERT, were considered in the West Valley Demonstration Project (DP). The NRC's review of the DP.

IERT report, entitled "Independent Review of the Phase 1 Decommissioning Plan for the West Valley Demonstration Project," describes the approach and results of their review. NYSERDA is providing the IERT report as well as our comments (below) for consideration by the NRC in their review of the DP and development of a request for additional information. The IERT report and an expanded version of NYSERDA's comments are being provided to the Department of Energy (DOE) to be addressed in a future revision of the DP.

2. General The Derived Concentration Guideline Levels (DCGLs) identified for Sr-90 and Cs-137 are the DCGL values at year 2041, and not the values at the completion date for Phase 1 as indicated in the DP. Per the DP, Phase 1 is expected to begin in year 2011 and be completed in year 2018. Since the DCGLs are based on the concept of active management of the site until 2041, NYSERDA expects that DOE will provide the necessary monitoring, maintenance " and security controls until year 2041.

General The text on Page ES-19 (and in other sections of the Update the language in the DP to more accurately reflect DP) states that "and upon NRC approval of this plan, NRC's role.

DOE would begin Phase 1 of the proposed decommissioning in 2011 and it would last until 2018." This does not accurately describe NRC's role and responsibility under the West Valley Demonstration Project (WVDP) Act. Consistent with the WVDP Act, NRC has stated (publicly) that they Page 1 of 17

NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject, Dated December 3, 2008

- (Table, Figure) 'Commenti- ,ProPosed Resolution SqPage #(Pargraph, Line) will conduct an "informal review and consultation,"

after which they plan to issue a Technical Evaluation Report. Similar text on Page 7-48 references "NRC's approval of this plan."

General The DCGLs and cleanup goals in the DP are The DP should describe how the Phase 1 DCGLs allow for established such that the entire 25 mrem dose limit of possible Phase 2 actions that may leave radioactive material the License Termination Rule can be allocated to the in place.

Phase 1 removal actions. If the cleanup of the facilities and soils included in the scope of this DP achieves the DCGLs as presented, could that severely limit the allocation of dose to the Phase 2 decommissioning activities?

5. General Section 9 of the DP describes a process for developing NRC should be prepared to perform confirmatory surveys and implementing Final Status Surveys of remediated of the decommissioned areas of the WVDP.

areas. The DP states that arrangements would be made for any confirmatory surveys that NRC desires.

Since it is NYSERDA's intent that the units decommissioned per the WVDP policy statement would also be considered decommissioned for the termination of the NYSERDA CSF-1 license, NYSERDA requests that NRC perform confirmatory surveys during Phase 1 decommissioning activities.

Such surveys would be particularly important for excavations for Waste Management Areas (WMAs) 1 and 2 as well as the fill material for each excavation.

Conceptual Models: The validity of the DCGLs to be used to demonstrate compliance with the NRC policy statement and 10 CFR 20 Subpart E depends, in part, on the adequacy of the site conceptual models. Uncertainties in, or lack of accurate information on, the source terms and physical features of the site can limit the development of exposure scenarios used to establish adequate site conceptual models. Questions and comments presented below are aimed at clarifying factors that can affect the site conceptual models as presented in the DP. The IERT report presents additional observations regarding the adequacy of the conceptual models and engineered barriers presented in the DP.

I

6. General The report raises severalPERT concers regarding the See the IERT report for additional details regarding their site conceptual models and the basis for certain analysis of the conceptual models and engineered barriers.

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NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject, Dated December 3, 2008 Section

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assumptions. For example, a feature of the West Either additional discussion is needed in the DP to support Valley site critically important to the transport and the basis for assumptions used or further calculations must release of radionuclides is erosion. The conceptual be performed to demonstrate the potential impacts of models ignore the potential impacts of gully erosion processes identified by the IERT on the dose calculations on dose calculations. Further, the conceptual model and establishment of DCGLs. The technical basis to for steam bed sediments assumes an unrealistic static support the effectiveness of engineered barriers should be condition of the river channel perimeter for extended enhanced.

periods of time.

The conceptual models exaggerate the extent to which contaminants originating in the surface soil are diluted in the farmer's well by groundwater.

The conceptual model for calculation of subsurface soil DCGLs ignores any dose contribution from groundwater transport of residual contamination in subsurface soils other than a limited quantity brought to the surface as cistern cuttings. Dr. Neuman, in the IERT report, presents a mathematical proof demonstrating that not only would contaminants at the top of the Lavery till be drawn to the well intake, the concentration would actually increase towards the well.

The hydrologic connections between the conceptual models employed, as per RESRAD, are physically unrealistic since they do not consider coupled surface-subsurface processes and resultant release scenarios.

The presence of actively-eroding gullies would greatly facilitate the communication of water downward into the subsurface or upward and outward onto the ground surface.

A major concern regarding the effectiveness of the Page 3 of 17

NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject, Dated December 3, 2008 Section,- Com~mient .

(Tbe iure Propo~sed,,,Res~olution:

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engineered barriers is that at the interface of the barrier bottoms and the till, groundwater could seep back into the excavation of WMA 1 and 2, become contaminated and continue to contaminate the excavation surfaces and till floor. Also, design details are lacking such as the thickness of the thickness of the barrier for WMA 2, the method of maintaining the necessary slope and support on the excavation side of the barrier wall, and the consideration of possible seismic loads and severe storms on the excavated walls.

7. Section 3.5.5, Page 3-5 1, Table This section indicates that erosion rates near the Clarify the limitations of the data provided in Table 3-13.

3-13 WVDP will vary over time due to various factors (e.g.,

stream valley widening, knick point advance, etc.). It is unclear from the data, however, whether the listed erosion rates are only applicable for the actual period used to determine the rate, or if they can (or will) be used to extrapolate future rates.

8. Page 5-14, Bullets and Page 5- The bullets on Page 5-14 summarize results from the Modify the DCGL exposure scenarios to include a scenario 23 through 5-28 EIS erosion modeling, which NYSERDA believes to where erosion impacts to the North Plateau bring be significantly flawed and not technically defensible. subsurface contaminants to the surface. The uncertainties The EIS erosion modeling results should not be used in long-term erosion modeling, as described in EIS to limit the exposure scenarios that are used to develop Appendix F (e.g., Pages F-30, F-59-60), should be DCGLs in the DP. In addition, even though these presented in the DP.

bullets recognize that the area of the lagoons could be impacted by erosion during the 1000-year evaluation period, a scenario where erosion uncovers buried contaminants is not considered in the derivation of subsurface DCGLs.

9. Section 5.1.7 This discussion of potential impacts to the Kent Discuss the potential for the 473 steel "H" piles to serve as Page5-16 Recessional from 'residual contamination doesn't a transport path for contaminants to the Kent Recessional mention the 473 "H" piles that were driven through the Sequence.

Surficial sand and gravel, through the Lavery till and Page 4 of 17

NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject, Dated December 3,2008

• Section, (Tbeiue ommn ProposdRslto Page#

(PragraphLie into the Kent Recessional Sequence. There is potential that these steel piles could serve as a pathway for contaminants to the Kent Recessional Sequence.

While Section 7.3.8 (Page 7-26) recognizes the importance of sampling around the "H'"piles, Section 5.1.7 should include a discussion of the "H" piles as a potential transport path for contaminants to the Kent Recessional Sequence.

10. Seismically induced slope failure could cause the Discuss whether seismically induced slope failure could exposure of buried contamination. Has the issue of expose buried contamination.

seismically induced slope failure been evaluated for the North Plateau?

11. In describing the "Subsurface ConceptualModel," the The basis for the contaminated soil zone remaining more DP states that the scenario whereby a house than 10' below the surface should be clearly stated. The constructed with a basement extending into uncertainties in long-term erosion modeling, as described in contaminated areas was considered implausible EIS Appendix F (e.g., Pages F-30, F-59-60), should be because the contaminated subsurface soil would be presented in the DP.

more than 10' below the surface. Although not directly stated, this scenario assumes erosion on the North Plateau would not thin the zone of clean fill and subsequently move the contamination closer to the surface.

I The text identifies the manner in which buried The uncertainties in long-term erosion modeling, as radioactive material is addressed in the DP. Although described in EIS Appendix F (e.g., Pages F-30, F-59-60),

not directly stated, this discussion assumes that there should be presented in the DP. The basis for the will be no erosion on the North Plateau that would thin contaminated soil zone remaining buried should be clearly the zone of clean fill, and subsequently move the stated.

contamination closer to the surface.

t I.

The Streambed Sediment Conceptual Model (Page 5- Discuss the potential impacts to a recreationist that may

29) assumes a recreationist as the average member of hike along the streams both on and off the WVDP premises, the critical group. By design, the DP limits the and calculate DCGLs for such a situation.

recreationist to streams within the WVDP premises (Page 5-9). While'the resident farmer is limited to Page 5 of 17

NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject, Dated December 3, 2008 Section, (Table, Figdre) Commnt Pp* osedý e*solution

_____ Page# (Pragraph,Lie only the remediated area of the Main Plant Process Building (MPPB) or the lagoons, the same requirement does not need to be applied to the recreationist who could very well hike beyond the boundary of the WVDP premises. Expanding the area for the recreationist activities would support the evaluation of cumulative impacts as it would consider seeps associated with the North Plateau Groundwater Plume (NPGP). Such an analysis may provide DCGLS for remediation of accessible creeks throughout the Center.

RESRAD Parameter Selection for calculating DCGLs: DOE has elected to perform a deterministic analysis using RESRAD rather than performing a probabilistic analysis. The defensibility of the dose assessment is in part dependent upon the defensibility of the RESRAD input parameters. The DP lists the parameter values used for the dose assessment and references general information about the site to support the parameter selection. Certain parameters, such as Kd values, can have a significant effect on the results of the DCGL calculations. The comments below question the adequacy of the level of justification presented in the DP to support the selection key parameters used for calculating DCGLs. The IERT report also presents concerns about the technical basis for parameter selection and the adequacy of the sensitivity analysis and lack of a probability based uncertainty analysis.

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14. General The IERT expressed concern that the DP provides The technical basis for parameter selection should be inadequate information to support key assertions expanded. Once the conceptual models are reviewed and affecting the dose calculations and DCGL revised as appropriate, a sensitivity analysis must be, development. The technical basis for changes of repeated. Consideration should be given to including a RESRAD default parameters are poorly documented, probabilistic uncertainty analysis perhaps using the and in some cases (especially for Kd values), generic probabilistic capability of the RESRAD code.

literature values appear to have been used where site specific values were available.

The point estimates for parameter values used in RESRAD may not have appropriately bounded the results of the analysis in which case an uncertainty analysis is necessary to have confidence in the results.

There is no evidence that the point estimates used were derived from any. -such analysis and are therefore Page 6 of 17

NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject, Dated December 3, 2008 (TbeM igue .. ' omnroposed Resolution, Pag # (Pragraph line)- .

.assumed to be the analysts' "best estimates", not bounding values. Although the analysis is supported by substantial sensitivity analysis, that analysis varies only one parameter at a time.

15. Page 2-35, second paragraph In describing the source of the NPGP, the DP states Provide a reference or other technical basis to support the that "Less mobile radionuclides such as Cesium-137 premise that the Sand and Gravel Unit has a high sorption are expected to have remained beneath the immediate capacity for cesium.

source area due to the high cesium sorption capacity of the minerals in the sand and gravel." Sorption capacity is typically expressed in terms of a distribution coefficient or Kd value. While it may be true that the Kd value for Cesium in the Sand and Gravel Unit is high, no reference is given to support this statement. Further, Table 3-20 (Chapter 3, Pages 3-76 through 3-78) presents no data for a Cesium Kd in the Sand and Gravel Unit.

16. Appendix C, Section 1.0 In discussing the assignment of distribution Use more conservative distribution coefficient values to Tabulated Data, Page C-2, coefficients for the three RESRAD zones, the represent stream bed sediment partitioning or provide better second paragraph statement is made that the contaminated zone in the justification as to why the' Lavery, till values are stream sediment analyses and the subsurface soil representative.

analyses are assigned the Kd values for the Lavery till.

One could argue that poorly consolidated stream sediments would have sorption properties that were more similar to the sand and gravel unif rather than the Lavery till. The assumption that the Kd value for stream bank sediments can be represented by the Lavery till needs further discussion in this section.

Given the sensitivities of the stream bed sediment scenario to distribution coefficient (see Table C-99) the approach needs to establish that conservative values have been selected and analyzed.

17. Appendix CG, Section 1.0 -The text states that "The Kd values were selected to Provide a justification for using nonconservative values for Tabulated Data, Page C-2, represent the central tendency of the site-specific data. distribution coefficient in a deterministic analysis.

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NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject, Dated December 3, 2008 Section,

(.Table, Figure) f-,. - C'.omment, - Pr6vosed- Resolutionv.

Page: # (paragaph, Line)*-

second paragraph . . . In its discussion of Deterministic Analyses, NUREG-1757, Volume 2, states that "it is important for the licensee,to demonstratethat the single reported estimate of peak dose is likely to be an overestimation of the actual peak dose." It is unclear how choosing KI values based on the central tendency of data will result in "an overestimation" of dose.

Radiological Status of the Site: Understanding the nature and extent of contamination is vital to planning for decommissioning. The following comments identify data gaps and suggest a path for resolution. (Comments specific to the source and radionuclide inventory of the NPGP are provided below.)

18. General In the Phase I DP, there are multiple references to Describe the basis for developing anticipated/expected specific radionuclide ratios and inventory projections radionuclide ratios, inventory projections and transport (i.e., source-term assumptions) and suppositions mechanisms for WMAs on the North Plateau.

regarding the associated inter- and intra-transport mechanisms for the various WMA/units on the North Site wide characterization surveys will improve the Plateau. The basis for establishing ratios is not well radionuclide inventories and can support the definition of defined. radionuclide ratios and the understanding of transport mechanisms for each WMIA.

19. Pages 4-35 and Table 4-12, "Above-Background Concentrations of Describe how representative isotopic profiles for WMA 1 4-36, Table 4-12 Radionuclides in Subsurface Soil at WMA 1," will be established. What surface and subsurface soil identifies three sampling activities that provided the characterization will be performed?

subsurface soil data for WMA 1. Due to the limited data and the variability of this data (e.g., Cs-137 is not present in one location, and is two orders of magnitude different in the other two locations, etc.), conclusions related to radionuclide distributions are speculative.

Additional sampling in WMA 1 is needed to confirm the different isotopic waste profiles present in this area.

20. Page 4-36, The second paragraph states "No gross alpha This statement should be revised or removed.

second paragraph concentrations or concentrations of alpha-emitting radionuclides were observed at concentrations above background in surface soil from WMA 2." This Page 8 of 17

NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject, Dated December 3, 2008 STbec, Figurke) . omen 'rpsdk eslition:

Pae#(aragraphLn) .

statement is inaccurate as surface soil samples were obtained from Borehole Nos 1, 2, 4,-8, 10A, 13, 14 and 33A in WMA 2; and of these locations, the only alpha analyses performed were for radium (224 and 226) (see RFI, Volume 4, Low-Level Waste Treatment Facility, Radiological Data).

21. Pages 4-36 and Table 4-13, "Above-Background Concentrations of Additional characterization of soils in WMA 2 (including 4-37, Table 4-13 Radionuclides in Surface Soil From WMA 2" lists only analyses for alpha-emitting radionuclides) is needed to concentrations of Cs-137 and Sr-90 for a number of better understand the nature and extent of the borehole locations in WMIA 2. No data, however, are contamination.

provided for alpha-emitting radionuclides in the surface soil. Additional sampling and analyses of different soil depths and locations can provide more accurate information on the radionuclide concentrations and distribution in the WMA.

22. Page 4-41, This section states that "As seen in other areas, Additional characterization of the radionuclide distribution fourth paragraph elevated levels of Cs-137 in surface soil were most in surface soils from all WMAs is needed. Include the new likely attributable to airborne deposition (see Section background surface soil data along with the one existing 2)." Due to the small number of surface soil samples background location as this will support the defensibility in taken, and the even smaller number of analyses determining a representative background sample.

performed on these surface soil samples, it is speculative to identify the source of Cs-137 solely as the airborne releases.

23. Page 4-42, Table 4-18, "Above-Background Concentrations of Revise Table 4-18 to include the data from the 2008 Table 4-18 Radionuclides in Surface Soil, Sediment, and background sampling activity. If BH-38 values are above Subsurface Soil at WMA 5," lists the background the newly calculated background values, include BH-38 in location (BH-38) as being above-background for the table, but add a qualifying statement indicating that it is radionuclides in surface soil, sediment and subsurface one of the locations used to calculate background.

soils in WMA 5. Why is the background location listed as being above-background? Also, in 2008, additional background soil samples were obtained to determine more representative values for background.

24. Page 4-43, The paragraph states "Ratios to Cs-137 for Pu-238, Provide clarification for the assertion that the Fuel Page 9 of 17

NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject, Dated December 3, 2008 (TblFiur)~ omen't Pý.,roposed Resolution

______ Page (,#i(argraph, Line) third paragraph Pu-239/240, and Am-241 were similarfor subsurface Receiving and Storage Building subsurface location is more soil samples taken near the Utility Room and the Fuel central to the NPGP.

Receiving and Storage Building (about 0.03 to 1, 0.04 to 1, and 0.2 to 1, respectively). However, the Sr-90 to Cs-137 ratiosfor each were strikingly different. Near the Utility Room, the ratio was about 1 to 1, but near the Fuel Receiving and Storage Building the ratio was 133 to 1, suggesting that the Fuel Receiving and Storage Building subsurface location was more central to the north plateau groundwater plume."

Given the historical leaks and spills associated with the general area between the Utility Room and the FRS, the groundwater flow paths for these areas, and the. partition coefficient (Kd) values for Cs-137, Pu-238, Pu-239/240 and Am-241 being significantly different than Sr-90, it is difficult to definitively state that the difference in the ratio of Cs-137 to Sr-90 is due to the Fuel Receiving and Storage Building being more centrally located to the NPGP. Specifically, Cs-137, Pu-238, Pu-239/240 and Am-241 are relatively immobile radionuclides and would not be expected to have traveled far from their source. The radionuclide ratios are approximately equal for both areas, but the reputed source of the NPGP is located closer to the Fuel Receiving and Storage Area. Why are the radionuclide ratios for the relatively immobile radionuclides similar near the Utility Room (which is located cross-gradient to the reputed source and at a greater distance from the source)? Either the source of these radionuclides is larger than anticipated (i.e.,

larger volume) or there are other sources that contributed these radionuclides throughout this region.

25. 1 Page 4-44, Table 4-19, "Above-Background Concentrations of Perform additional sampling/radionuclide analyses of the Page 10 of 17

NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject, Dated December 3, 2008 Sectn, -

(TaleFigre)Commenit Prpoed Resolution Table 4-19 Radionuclides in Surface Soil, Sediment, and areas in WMA 6 for inclusion in the scope of this DP.

Subsurface Soil at WMA 6" lists sediment and borehole locations that exceeded background concentrations. Given the limited data for this area and that the relative ratios for these radionuclides vary by location, additional sampling of WMA 6 is necessary.

26. Page B-7, The use of groundwater well WNW0204 as the Use WNW0402 as the background sample location for the Section 1.4, first paragraph background sample location for the Lavery Till-Sand Lavery-Till Sand Unit data and recalculate the background and Page B-15, Table B-7 Unit is incorrect; WNW0402 has been identified in the data using this location. Revise Table B-7. Reevaluate the quarterly groundwater reports as the background groundwater data originally identified as not having location for this geologic unit. This well also appears exceeded background, and verify that the revised data still to be downgradient of a number of areas/facilities that does not exceed background.

could influence this location. Finally, the more recent data suggests that WNW0204 is higher in activity for gross alpha and tritium, which could potentially bias the background values high. Remove WNW0204 from the data set and data source locations in Table B-7, "Groundwater Background Radionuclide Concentrationsfor the WVDP."

27. Section 5.1.3 The DP focuses on the remediation of WMAs 1 and 2, Include the northern end of WMA 10 in the sitewide Page 5-10 and leaves the remediation of other soil and sediment characterization. If contamination is present, remediation as an option (Footnote 3, Page 5-10). Figure 4-6 (Page of the area, as a Phase 1 activity, can reduce the potential of 4-31) shows gross alpha and gross beta contamination additional contamination migrating into WMA 1.

in surface soil in the area (WMA 10) to the west of Incorporate remediation of areas (i.e., that may WMA 1. Given the direction of groundwater flow recontaminate/impact WMA 1) as part of the Phase 1 (Figure 5-4), surface contamination could impact the activities.

groundwater in this area that flows into WMA 1 can contribute, over time, to the dose in WMA 1. What does the potential effect of contamination in the WMA 10 have on calculating DCGLs for WMA 1?

In the mid-1990s, several "AA" trailers and trailers on Describe available data for the area west of "Trailer City" Page 11 of 17

NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject, Dated December 3, 2008 Sectio.,.. ,,e P Page F#(Pragraph, Line) - *- .-

the west side of "Trailer City" were removed, and a (i.e., where trailers were removed and the fence relocated).

portion of the chain-link fence was moved east. The Include this area in the sitewide characterization as area between the main parking lot and the fence was appropriate.

covered with grass. Are there existing data to verify that this area will meet the site decommissioning criteria or will a Final Status Survey of the area be performed?

Source and Radionuclide Inventory of the North Plateau Groundwater Plume: The planning for the removal of contaminated soils from WMA 1 is supported by the understanding of the events contributing to the contamination and data describing the extent of the contamination. The following comments focus on clarifying information and data that help to characterize the source area of the NPGP.

28. Page 2-35, third paragraph The first sentence in this paragraph states that "An Clarify that Table 2-16, an estimate of the remaining order-of-magnitude estimate of the radionuclides and inventory, only presents the decay-corrected values from amounts released by the acid leak, and the estimated the Westcott (1998) report.

remaining amount in 2011, are presented in Table 2-16." In the preceding paragraph, the argument was made that the more mobile isotopes (e.g., Sr-90 and tritium) were migrating away from the source; therefore, the remaining inventory (at the source) is actually a function of two physiochemical processes:

(1) decay, and (2) mobilization in the saturated zone.

Table 2-16 (Pages 2-35 and 2-36) attempts to estimate inventory solely based on decay. The text and the table should clearly indicate, that the estimate of current inventory (in 2011) is based on decay-corrected values from the Westcott report and does not account for any inventory that has already migrated downgradient or off site.

29. Page 2-35, Table 2-16, "Released RadionuclideActivity Estimates As characterization data from the source area of the plume Table 2-16 for the North Plateau Plume," cites a reference by are obtained, the radionuclide inventory and radionuclide Westcott 1998. The D. R. Westcott work utilizes ratios should be updated. The revised inventory and ratios characterization data that was available for Tank 8D-2 need to be used in the modeling and projections of the to estimate the radioactivity present in the NPGP. The nonsource area of the plume.

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1. (Pagrap h Line) plume is a result of one or more leaks in the acid recovery system, which may not be accurately represented by Tank 8D-2 data. Data obtained in the leaking source areas of the acid recovery system are likely more indicative of the radionuclide inventory and radionuclide ratios for the NPGP.

30. Page 2-36, second paragraph The statement that "In addition to the known acid spill Provide justification to support the assertion that these affecting the north plateau, during NFS operations "unintended operational releases" are so localized that they several incidents such as inadvertent transfers of have not contributed to the plume.

higher-than-intended activity occurred in the interceptor basin system upstream of the lagoon system (Lewis 1967, Taylor 1967, Wischow 1967).

Documented accounts of leakage and spills in the area (Lewis 1967, Carpenter and Hemann 1995) corroborate the generally elevated observed subsurface soil contamination,in the area west of Lagoon 1 to the vicinity of the ProcessBuilding. Such localized subsurface contamination can be attributed to these unintended operational releases," needs clarification. Are the documented releases/spills that contaminated the subsurface soil from the Process Building to the interceptor system and Lagoon 1 considered contributors to the total radionuclide inventory of the NPGP?

31. Page 2-39, In Table. 2-17, "Principal Radionuclides in Major Revise this section to be consistent with the information Table 2-17 Spills Occurring During NFS Operations," the last provided in Chapter 3, Section 3.11.5.1 of the DEIS.

column in the last row states that: "Leakage did not result in any known release to the environment."

While it is unknown whether this release affected the environment, arguably, it is also unknown that it did not. Specifically, the transport mechanism (i.e., an expansion joint) discussed for the primary leak also exists in this location. This leak occurred on the first Page 13 of 17

NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley Demonstration Project, Dated December 3, 2008 P kage ectron ýJComment, Proposed Resolutionh

1. (Paagrah, -ine floor, not the fourth floor of the building (as with the primary leak), and the volume recovered by the interceptor (in addition to what remained in Tank 7C-

5) accounts for approximately one third of the total volume released by this event. Finally, historical accounts attribute the poor condition of the floors and common wall between the Acid Recovery Pump Room and the Off-Gas Blower Room to numerous acid leaks/spills. These accounts detail the addition of six inches of concrete to level the floor in the southwest comer of the Off-Gas Blower Room after it was destroyed by acid. In addition to leveling this floor, the concrete provided shielding from the high dose emanating from this comer (Riethmiller, 1981).

32. Section 3.7.7 Numerical Analysis Techniques includes a brief Discuss the groundwater model calibration and describe the Page 3-72 reference to modeling of the NPGP using both 1994 sensitivity of the model to changes in source concentration.

plume concentration data and source activity of 500 Ci How does the sensitivity of the groundwater model affect of Sr-90. The text goes on to describe how model the calculation of DCGLs?

calibration was performed. Based on Section 2.3.1, Page 2-35, the source of the plume in 1972 included approximately 200 curies. The text in Section 3.7.7 lacks a discussion of how a variation in the source concentration affects the calibration of the groundwater model.

33. Page 4-13, The text states "These data were used for all Provide the technical rationale for using acid third paragraph, radionuclides of interest in spent fuel except U-235 recovery/recycling lines 'and data from the Acid Recovery Spent Fuel Distribution and U-238, which were derivedfrom NFS recordsfor Pump Room to calculate the spent fuel profile ratios. Also, recovered and unaccountedfor losses of uranium, and provide the technical rationale for why the Acid Recovery U-232, U-233, U-234, and -U-236, which were Pump Room data are conservative.

establishedbased on analytical results showing the U-232 to U-235/236 ratiosfrom samples collected in the Acid Recovery Pump Room of the Process Building."

What is the technical basis for using the ratios from Page 14 of 17

NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject, Dated December 3, 2008 Sýecto,-

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'Line),, __ _ __ _ _ ......_

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Pae#(Paragraph the acid recovery/recycling portion of the reprocessing activities, instead of using ratios from areas where product extractions occurred (e.g., Extraction Cells 1, 2, and 3, and the Product Purification Cell)? The analytical data obtained from sampling the Acid Recovery Pump Room would likely represent contaminants in spent acid that leaked or spilled from process lines, rather than higher concentrations of product materials prevalent in other areas of the Main Plant. Also, what is the basis for stating that these ratios are conservative?

Site Features: A description of site features is required in the DP. The following comments focus on data gaps in the information describing site features.

34. Section 3.6.3, Page 3-65 In discussing the probable maximum flood, the cited Use the most current information to describe the influence reference is a report that was generated in 1983. Why of flooding at the site.

doesn't this plan use the most recent probable maximum flood model developed in 2008 and cited in the current DEIS? The reference is URS, 2008, "Memorandum to Science Applications International Corporation,

Subject:

Probable Maximum Flood Inundation Study," West Valley, New York, August 28.

35. Section 5.1.6, The first paragraph of this section and Figure 5-5 Provide a framework for the significance of the 1994 work Page 5-15, reference the 1994 Dames and Moore North Plateau by Dames and Moore, and comment on flow observed Figure 5-5 Groundwater Seepage Survey. A text box in the today from seepages along Erdman Brook and Frank's Figure states that "the 3 seepage points near the Creek. Incorporate more recent flow data for the seepage lagoons ... exhibited little or no flow in 1994." The points, if availablL. Update the map as necessary.

information shown on this figure is now 15 years old.

What is the significance of the flow characteristics in 1994? Have the locations of seeps been checked in the field to confirm that the information on this map is still accurate?

Page 15 of 17

NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject, Dated December 3, 2008 ecti'on, SS 1.rpsdRslto (Tbe,Fiure Commentýdtii

____ Pg #-(Paragraph,, Line),_ t, 0. __________________

Site Characterization: Adequate site characterization is needed in the planning for remediation and defensible final status surveys verifying that any residual contamination meets the requirements of the West Valley policy statement andlOCFR20 Subpart E. The following comments identify limitations in characterization data.

36. Page 9-6, Characterization Surveys are identified in Section The four cited. survey activities should be considered Section 9.2.4, second paragraph 9.2.4. The second paragraph states, "Four WVDP scoping surveys and the data from these survey activities characterization survey programs have been can be used to design the Characterization Surveys as completed: (1) the characterizationprogram for the defined in MARSSIMs.

underground waste tanks, (2) the Facility Characterization Project, (3) a series of Resource Conservation and Recovery Act (RCRA) facility investigations performed in the 1990s, and (4) investigations of the north plateau groundwaterplume using a Geoprobe." The survey activities completed thus far do not appear to have the necessary components as specified under NUREG-1575, the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) to be identified as "Characterization Surveys." Specifically, these activities did not include survey designs that ensured that: representative background/environmental media specific measurements were obtained, acceptable Type I and Type II errors were identified, and contaminant variation in each survey unit was adequately addressed (using statistical testing of the survey unit).

Similarly, language on Page 8-8 references the underground waste tank farm data as being similar in quality to MARSSIMs. Clarification of what "similar" means should be provided.

37. Page 9-15, This section defines the use of "In-Process Surveys" Provide the detailed Quality Assurance requirements for Section 9.5. and states that these surveys would be performed to ". conducting "In-Process Surveys."

• . determine when remediation to field goals ... has Page 16 of 17

NYSERDA Comments on the Department of Energy's Phase 1 DecommissioningPlanfor the West Valley DemonstrationProject, Dated December 3,2008 Secio,ýRue .omnent, Prpoe Rolution&-

been attained." What are the QA requirements for conducting this type of survey? Specifically, since this type of survey is not defined in MARSSIMs, are the QA requirements consistent with Characterization Surveys and/or Final Status Surveys, and how will the results be utilized for final status of the survey unit?

38. Page 9-31, last paragraph and Characterization of the soils remaining in WMAs 5 The soil areas remaining from excavation of the Page 9-32 and 6 (after the excavation of the foundations, slabs, foundations, slabs, hardstands, and gravel pads in WMAs 5 hardstands and gravel pads were removed, prior to the and 6 need to be characterized.

start of decommissioning) need to be conducted.

Historical records identify these areas as potentially impacted by radiological constituents. Little data exists to help determine the extent of the contamination and whether the radionuclide distribution is the same or different than other areas of the site.

39. Page 9-32, Section 9.7.5 details the characterization activities Describe the process for characterizing the subsurface Section 9.7.5 defined for WMA 6: the Central Project Premises, piping the WMA 6.

which encompasses the Sewage Treatment Plant, the Equalization Basin, the Equalization Tank, the two demineralizer sludge ponds, the south Waste Farm Test Tower, floor slabs and foundations and the underground structure of the Cooling Tower (which has been identified as being impacted by radioactivity). The DP does not, however, identify the characterization process for the subsurface piping associated with this waste management area.

Page 17 of 17