ML16293A282

Radiological Survey and Dose Assessment Report for the Western New York Nuclear Service Center and Off-Site Areas in Follow Up to Aerial Gamma Radiation Survey Conducted in 2014, Rev. 0, Appendix a

ML16293A282
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Site:	West Valley Demonstration Project, P00M-032
Issue date:	08/22/2016
From:	MJW Technical Services
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
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Appendix A

• Appendix FS&DP

'. "> Appendix A -Field Sampling and Dose Assessment Plan fFoekl! SampHng and Dose Assessmenil: Pl,an foirthe Western New York Nudear Seruke Center In foUow Up to Aerrial Gamma !Radiation Survey Conducted irrl 2014 Rev.O October 1, 2015 New York State Energy and Research Developmlent Authority West Valley S.ite Manageme'nt Program MT2015-4008.002 9030..:s Route 219 I West Valley, NY 14171 243 Root St #100, Olean; NY 14760 243 noot Slreej, Suile 100 Olean, NY 14760-2436 Vnlr.A* 171ffl :17?-S:100 171fi) :-17?.;<;:107 Tnll Fmp* /Mfil .r:om Table of Contents 1. Background and Introduction ............................................................. : ............................................ 2 2. Project Objectives ......................................................... , ......................... ; ......................................... 2 3. Comparison cf Dose Assessments to Dose Standards .................................................................... 3 4. Safety and AlARA Objectives ........................................................... ............................................... 4 5. Quality Assurance Project Plan (QAPP) ............................................................................................ 4 6. Participants, Roles, and Responsibilities ................................... : ..................................................... 4 7.. Areas Selected for Ground Truth Measurements ................................................. .......................... 6 8. Areas of Known Contamination on the WNYNSC.. ........................................................................ 13 9. Areas Selected for Background Measurements ............................................................................ 13

• 10. Overview of Survey and Sampling Approach for Ground Truth Aerial Survey Results ................ 17 11. Dose Assessment Methodology ......... : ........................................................................................... 27 12. Potential Obstacles and Contingern;:y Strategy .............................................................................. 28 13. Applicable Field Procedures or Referenced Docume11ts ............................................................... 29 14. Reference Standards and Practices ..................... ; ............ ..... : ....................................................... 30 MT2015-4008.002 1 October 1, 2015 I ' Field Sampling and Dose Assessment Plan for the WNYNSC 1. Background and Introduction The New York State Energy Research and Development Authority (NYSERDA) owns the 3,300-acre Western New York Nuclear Service Center (Center) in the Town of Ashford. Since 1982, NYSERDA and the U.S. Department of Energy (DOE) have been working at the Center to conduct the West Valley Demonstration Project (WVDP), a high-level radioactive waste solidification and cleanup project. ln September 2014, DOE and NYSE RDA jointly initiated an aerial radiological survey to examine the radiological conditions of the Western New York Nuclear Service Center (Center) and adjacent areas, as well as Cattaraugus Creek from the Center Lake Erie in Western New York. This survey was conducted by the National Nuclear Security Administration's Remote Sensing Laboratory {RSL). The 2014 aerial radiation survey shows five limited areas outside the Center property with radiation levels that are slightly above the "background" radiation levels seen throughout Western New York1* Two of these areas were identified during the previous aerial surveys, and the three other locations were only identified during the 2014 aerial survey. The identification of the three new areas is likely due to either: the fact that the areas were not examined during earlier sUJveys; and improvements in instrument sensitivity since the time of the earlier surveys, or the deposition of additional contamination The purpose of this project is to collect information on radionuclide concentrations in the soil to verify whether the areas identified as having elevated !eve ls of radiation in the 2014 aerial survey are confirmed to have elevated levels of radionudides in the soll. If the radionuclide levels in the soil are elevated, a dose assessment will be conducted to confirm that there is no health and safety concern. It should be noted that a 1990s investigation of the largest of these areas (called the Cesium Prong) demonstrated that the area met all public heCJlth and safety standards. It is also important to note that the 2014 aerial survey results for the Cesium Prong, and for the other previously observed areas, are lower than observed in the previous surveys. The areas that have not been previously observed in aerial radiation surveys show radiation levels that are very low, just slightly above bac;kground. These activities wi!l be completed by MJW Technical Services (MJWTS), a radiation safety consulting company, under contract to NYSERDA. 2. Project Objectives The objective of this survey, sampling and dose assessment project is to provide additional data for the five areas that were identified for further evaluation. These areas were identified by RSL using the criteria described in Section 7. Background radiation is caused by naturally occurring radioactive materials like radon and from certain man-made radioactive materials that are found throughout the environm.ent today. MT2015-4008.002 2 October 1, 2015 Field Sampling and Dose Assessment Plan for the WNYNSC A summary of the data collection and evaluation approach is as follows: a) For Area 1 {the Ceslurn Prong, see Figure 1), soil samples wi!I be collected in several areas as described in Table 3. The analytica! results will be compared to the data collected during the 1995 Western New York Nuclear Service Center Off-Site Radiation Investigation (Dames and Moore, 1995) to determine whether the conditions in this area today are consistent with decay-corrected concentrations measured in the 1990s. Since this area has been extensively characterized and evaluated, a dose assessment will not be conducted unless the newly collected data identify conditions that are not consistent with previous results: b) For Area 2 (see Figure 2), the areas identified using the RSL criteria will be surveyed, and soil samples will be collected as described in Table 3. If elevated concentrations of radionuclides are identified in the sol! samples, a dose assessment will be prepared, as described in Section 11. c) For Area 3, located at the confluence of Buttermilk and Cattaraugus Creeks (see Figure 3}, the areas identified using the RSL criteria will be surveyed, and soils will be collected as described in Table 3. If elevated concentrations of radionudides are identified in the soil samples, a dose assessment wil! be prepared, as described in Section 11. Thls area was previously identified in the 1979 and 1984 Aerial Radiological Survey of the West Valley Demonstration Project and surroundi.ng Area (EGG-10617-1080, May 1991, see Figure 11, Area 2), but to date, this area has not been field surveyed or sampled. d} For Areas 4 and 5 (see Figures 4 and 5), which were not identified in previous aerial surveys, the areas identified using the RSL criteria will be surveyed, and soils will be collected as described in Table 3. If elevated concentrations of radionuclides are identified in the soil samples, a dose assessment will be prepared as described in Section 11. The sampling activity described in this plan is focused on areas identified through the aerial survey as having radiation levels above background. For areas identified outside of stream vatleys and floodplains, the primary samples collected will consist of soil. For areas within the stream valleys and floodplains of Buttermilk and Cattaraugus Creeks, the samples collected will likely consist of stream sediments. It should be noted that, as of the date of this Plan, coordination with property owners on the sampling activity is continuing. Changes in sampling strategy could be required if permission to sample is not obtained for each of the properties identified. 3. Comparison of Dose Assessments to Dose Standards The radiological surveys results and soil and stream sediment sample data will be used in a dose assessment (described in Section 11}. and compared to the dose limits included in 10 CFR 20.1402 -Radiological Criteria for Unrestricted Use. !n addition, the soil and sediment concentrations will be compared to the WVDP Phase 1 Decommissioning Plan, Revision 2, resident farmer scenario, Derived Concentration Guidelines MT2015-4008.002 3 October 1, 2015

.. Field Sampling and Dose Assessment Plan for the WNVNSC .{DCGls) surface soil values for the current year, which represent radlonucllde-specific concentrations that would achieve the regulatory dose standard for release of a llcensed property and termination of the license without restrictions (i.e., < 25 mRem/year as per 10CFR 20.1402). 4. Safety and ALARA Objectives All project activities will be conducted in a safe manner, consistent with the ALARA principle of maintaining radiation exposures to a level that is as low as reasonably achievable, and MJW Technical Services' (MJWTS) commitment to safety as manifested in our corporate and project specific safety plans. MJWTS will conduct the survey and sampling activities under the MJW Technical Services' New York State Department of Health Radioactive Materials License and application for reciprocity filed with and approved by the U.S. Nuclear Regulatory Commission (NRC}. To ensure the health and safety of all staff working on this project, a project-specific Health and Safety Plan (HASP} has been prepared, and is available through MJW or NYSERDA. This HASP details the radiological and industrial safety requirements for this project. 5. Quality Assurance Project Plan {QAPP) The QAPP provides the project specific details on how the surveys and samples will be collected to ensure representativeness, traceability and reproducibility. The data quality objectives are also defined for this project in the QAPP, along with information detailing the data quality and validation processes for these activitres. A copy of the QAPP is available through MJW or NYSERDA. 6. Participants, Roles, and Responsibilities The project will be performed by MJWTS, with support by NYSERDA staff. Key positions for executing the project are: NYSEROA Project Manager The NYSERDA Project Manager will be the primary point of contact and coordination with the MJWTS Project Manager, and ensure that the MJWfS Project Manager is cognizant of relevant information, issues, objectives, requirements, and potential concerns or deficiencies. Project Manager The Project Manager jPM) bears overall responsibility for execution of the sampling and . exposure assessment activities, and is responsible for the health physics aspects of the execution of the sampling plan. The PM will ensure that the sampling plcins are adapted to meet the project objectives, and that the work is executed in a timely manner, in accordance with the project plan and in conformance with all applicable regulatory requirements. MT2.015-4008.002 4 October 1, 2015 Field Sampling and Dose Assessment Plan for the WNYNSC Project Safety Director (PSD) The Project Safety Director (PSD} will perform hazard and risk assessments as required, develop appropriate safety plans and mitigation methods, and will work with the Project Manager to ensure that the HASP is followed and adapted, if required, based upon unforeseen field conditions or situations. Project. Certified Health Physicist . The Project Certified Health Physicist {PCHP} will ensure that the collection and analysis of survey data and the derived dose assessments are conducted properly, and in accordance with appropriate professional and regulatory standards and practices to ensure that results are accurate and defensible. Project Radiation Safety Officer The Project RSO {PRSO) will ensure that all activities conducted will be in compliance with the MJWTS' radioactive materials license, under reciprocity with the requirements of the NRC. The PRSO is authorized to halt any action considered to be unacceptable from the standpoint of radiological safety or regulatory compliance. Project Health Physicist The Project HP {PHP) is responsible for the analysis of survey and laboratory data, and for the performance of the exposure assessments. Project Quality Assurance and Control Manager The Project Quality Assurance and Control Manager (PQA/QCM} will be responsible for all aspects of project Quality Assurance and Quality Controf actions, and will ensure that appropriate measures are implemented during survey operations, analysis operations as well as by the radiochemistry laboratory that is utilized. Project Data Validation Specialist The Project Data Validation Specialist (PDVS) will be responsible for the validation of data as required by accepted professionat practices and standards. Project Field Supervisor The Project Field Supervisor {PFS) wilf be responsible for the in-field conduct of survey and sampling operations, and will ensure that appl!cable safety, compliance, and QA/QC requirements are followed during the execution of field activities. The PFS will supervise the activities of radiological control technicians and any other staff working in the field. In addition, the PFS will ensure that all field operations are appropriately documented. MT2015-4008.002 5 October 1, 2015 Field Sampling and Dose Assessment P[an for the WNYNSC Project IT/GIS Specialist The Project IT /GIS Specialist {PITGIS) will be responsible for oversight of data file storage and the processing of acquired data, in particular, G PS-driven radiation survey data. 7. Areas Selected for Ground Truth Measurements As stated previously, five areas have been identified for further evaluation by RSl, with the following considerations: a} The "anthropogenic extraction algorithm" used by RSL in evaluating the aerial survey results has a large variance and can produce false positives jf used to look for a specific isotope (e.g., Cs-137). b) The "cesium-137 extraction algorithm" has a relatively smaller variance but can contain false negatives (e.g., where Cs-137 may be indicated in spectral data though not strongly within the photopeak}. As such, the following criteria were used by RSL to screen the aerial survey results and identify areas that warranted the follow up sampling: The areas identified for further evaluation are those areas where both the anthropogenic extraction and the Cs-137 extraction indicate results that are 2 standard deviations {2a) above background or greater (2! 1000 cps in the anthropogenic extraction 30 cps in the Cs-137 extraction). RSL indicated that these are very small deviations above background and could simply be due to expected statistical variance; but they recommended this as a conservative approach for identifying areas for further evaluation_ RSL also noted that applying these criteria strictly to the point-by-point GIS data is not suitable because of the averaging effects inherent in aerial data, sa they applied the criteria on a scale approximately between 300-3,000 feet. This allowed RSL to identify areas where the Cs-137 extraction exceeds 2cr above background at the same location or in dose proximity to areas where the anthropogenic extraction also exceeds 2a above background. Finally, because the 2a above-background !evels represent very small deviations above background, RSL applied a third criterion, and focused on those areas exceeding the 2o thresholds were clustered together or extended into an area. Maps of these areas were generated as shown in Figures 1 through 5. These areas and the current land use (as determined through aerial photos) are defined further in Table 1 and Figures 1 through 5 detail each specific area. Ml2015 -4008.002 6 October 1, 2015 Field Sampling and Dose Assessment Plan for the WNYNSC Area No. 1 >-* 2 3 4 5 Table 1-Locations Selected for Ground Truth Measurements *-.. **-**-*---**--....------*-.. * -*-*---*----....... ,_, --* .. ***--*-..... *****----......... -...... -.. Location -**---Cesium Prong Near Scoby Hiii Dam (new location likely an extension of the Cesium Prong) -Current ........ _. land Use Residential p roperties, and tree with cleared covered are as. -Varying in te tree cover. T are not resid rrain and hese areas ential. GPS Coordinates ______ (centroid 42°27'46.97" N 78°40'13.53" w 42°28'25.66" N 78°41'18.84" w *-----*-** Near confluence of Active agricu lture area. Buttermilk and 42°28'56.20" N 78°40'42.19 w Cattaraugus Creeks -*-* Cattaraugus Territory of Wooded are a that does --***** .. -----**----l--*****-**--the Seneca Nation of* not include r esidences. 42"32'23.84" N 79"02'13.07"W Indians ---*'---*** Cattaraugus Territory of Wooded are *-******-*--*--...... *--*--***--a near the Seneca Nation of residential p I Indians roperty. 42"31'12.94" N 78°58'25.11" W *--**** *---*-*--'---MT2015-4008.002 7 October 1, 2015 Field Sampling and Dose Assessment Plan for the WNYNSC Figure 1 shows Area 1, which is adjacent to-the WNYNSC site. This area is the off-site portion of the Cesium Prong, which was extensively characterized in the 1990s. The four confirmatory soi! sample locations are identified in Figure 1(locations1.1, 1.2, 1.3 and 1.4). The details regarding these sample locations are provided in Tables 2, 3 and 4. . )" *::.*:** 0 0 I *, ... ; . l,..OCATION 1.3 . *.**,* Area 1 Proposed Sampling Locations . New York Nuclaar Servi.ca Center ____.... Cesium Prong Area Previously Observe<.! and Evaluated @ Confinnalo,Y. Sample Loc,.tions Figure 1-Area 1, the Cesium Prong MT201S-4008.002 8 :, .. **:: . "!* .(':. *r **** X **,, ....... *{ *

• o soo* 1.000 October 1, 2015 Field Sampling and Dose Assessment Plan for the WNYNSC Figure 2 shows Area 2, one of the newly identified areas. This area is located at the outer edge of the Cesium Prong, and may be a linear extension of the Cesium Prong (Area 1). The identification of this area in the 2014 survey may be due to improvements in the sensitivity of the radiation survey

• equipment since the previous surveys were conducted in 1979 and 1984. The area identified by the blue contour in the middle of the map is not being evaluated because the property owner declined the sampling request. It may be possible to obtain qualitative information on conditions in this area through the evaluation of the sample results from Sub Area.s 2.1 and 2.2. The details regarding these sample locations are provided in Tables 2, 3 and 4. (l 2:'"..0 500 1 000 11m111111111ic:::==----** Feet MT2015-4008.002 Area 2 Proposed Survey and/or Sampling l.,ocations -2014Arn<is Meating Crilarm for Further Evatuat1011 Smvey and S1m1pling Sub-Areas SUB-AREA 2.1 Q SUB-AREA 2.2 Figure 2 -Area 2, Northwest of the Cesium Prong 9 October 1, 2015

• 1 Field Sampling and Dose Assessment Plan for the WNYNSC Figure 3 sho*ws the general location of Area 3 at the confluence of Buttermilk and Cattaraugus Cr.eeks. This area has been identified in previous aerial surveys, but has not been surveyed or sampled. These survey and sampling sub-areas are identified on Figure 3. This area is an active agricultural area, The details regarding these sample locations are provided in Tables 2, 3 and 4. SUS-AREA 3, 1 0 250 5l0

• 1000" .... *.':*i=ee1 **,; ::* Ar(!a 3 Proposed Survey and/or sampllng Locations -2014 Amas Critena for further Ev2tua\i:ln S!1r1ey and hg Sul;-Areas !kw Nuclear Service Cen!ar OSUB-AREA 3.2 s Figure 3 -Area 3, Near the Confluence of Buttermilk and Cattaraugus Creeks MT2015-4008.002 10 October 1, 2015 Field Sampling and Dose Assessment Plan for the WNYNSC Figure 4 shows the location of Area 4 on the Cattaraugus Territo1y of the Seneca Nation of Indians. These areas have not been previously identified. The survey and sampling sub-areas are identified on Figure 4. The details regarding these sample lor:ations are provided in Tables 2, 3 and 4. SUB-AREA 4.2 SUB-AREA4.1 0 00 SUB-AREA 4.3 a isn ' tooo ..._ Feet SUB-AREA 4.4 Area 4 Proposed Survey andfor Sampling Locations -Z014 Areas Mearmg f.;r F*.lliMt Sarnpftr.g SUB-AREA 4.5* 0 Figure 4-Area 4, located on the Cattaraugus Territory of the Seneca Nation of Indians MT2015-4008.002 11 October 1, 2015

. ' Field Sampling and Dose Assessment Plan for the WNYNSC Figure 5 shows the location of Area 5 on the Cattaraugus Territory of the Seneca Nation of Indians. These areas have not been previously identified. We note that this area is not within the historic floodpfain of Cattaraugus Creek, and RSL noted that there was not a strong cesium-137 signal in the aerial survey results. Because the RSL criteria were met, the area will be evaluated fu1ther. The survey and sampling sub-areas are identified in Figure 5. The details regarding these sample locations are o 2so soo. _. Fwt provided in Tables 2, 3 and 4. Area 5 Proposed Survey and/or Sampling locations -20 lol Areas MeetITTg for Fwther and Samp:ing Sub-Areas SUB-AREA 5.2 5.1 0 0

• SUB-AREA 5.3 0 Figure 5 -Area 5, located on the Cattaraugus Territory of the Seneca Nation of Indians MT2015-4008.002 12 October 1, 2015 Field Sampling and Dose Assessment Plan for the WNYNSC 8. Areas of Known Contamination on the WNYNSC In order to evaluate the aerial radiation survey results for areas with elevated concentrations of Cs-137, four known areas of contamination have been selected for analysis. These are "on Center" locations. In order to evaluate direct radiation dose rates in the areas of known contamination, microRem readings will be collected at ground surface and at one meter for each of these sample locations. Three soil samples will be collected from each of the four "on Center" locations (0-5 cm, 5-15 cm and 15-30 cm), with one subsurface sample collected for Location C-02 (30 cm -1 m). The details regarding these sample locations are provided in Figure 6 and Table 4. 9. Areas Selected for Background Measurements In order to determine if the five areas are above background for Cs-137, background survey and soil sampling data will be collected. Due to the variability of background, two background areas have been identified; one background area will be located on the WNYNSC for the elevated locations near the WNYNSC site, and one background area for the locations an the Cattaraugus Territory of the Seneca Nation of Indians. a) WNYNSC Background Area -This activity will use the background data collected and analyzed by the U.S. Department of Energy (DOE} to support the 2014 West Valley Demonstration Project Terrestrial Background Study (Safety and Ecology Corporation, 2014). The total area for the background reference location is 2,000 with 10 samples collected at equally spaced locations representing 200 m2* At each sampling location, one near surface sample was collected (0-15 cm) and one deep surface samp!e was collected (15-100 cm). Figure 7 shows the DOE background sampling location on the WNYNSC property. MTZOlS-4008.002 13 October 1, 2015 Field Sampling and Dose Assessment Plan for the WNYNSC '!. 0 025 1}5 *. i Potential Sampling Lc:icatio1_1s @ Potential Confirmatory Sample lor.allons . *.-2014 Areas Meeung Criteria for Furtt\i:r EvaltJallon v\leslern New York Nuclear Se1vice Center .... '*' Figure 6 -Known Contamination Sample locations located on the WNYNSC MT2015-4008.002 14 October 1, 2015 Field Sampling and Dose Assessment Plan for the WNYNSC -------.. *-**-*----******-****-**-*--\--.--\,/ \ \ ------*--****-' ,, '\,*,,, "'\ ......... . ............. \ '* .... .,, \ ........... , .... --... ... **-, Legend

• Background Reference Area 1 N Background Reference Area 1 Boundary 0 15 30 60 90 120 . 1*1D*c*mm:::===*** Meters 1,000 1,500 2,000 . . m:::mm::11m--c::==:::::111111111i11111 Metersi Figure 7 -DOE Background locations on the WNYNSC MT2015-4008.002 15 October 1, 2015

. . Field Sampling and Dose Assessment Plan for the WNYNSC B*210 b) Cattaraugus Territory of the Seneca Nation of Indians Background Area -There are 10 potential background locations on the Cattaraugus Territory of the Seneca Nation* of Indians. These locaticms are not in close proximity ta the sampling locations. Five of these locations are located within the Cattaraugus Creek valley, and_ represent similar soil and stream sediment characteristics. Five background locations are outside of the stream valfey. A minimum of two background samples will be collected at each location (0-15 cm and 15 -30 cm}, with three background locations collected for subsurface samples (30 cm -1 m). Figure 8 and Table 4 detail the 10 potential background samp!ing locations oli the Cattaraugus Territory of the Seneca Nation of Indians. 4.1-4.4 B-2.JG * . Potential Sampling Locations Na11an of lmran'"i C:1H.1rauous. Terr.:lor-J -.2014/J..roas Meflt\ng Cmit-na. Jbt il) 8a<CkfJr*J11nd Sur.,.t;y Uhd S:.Jrnpf:nij Sul>*A1u.a:; **. $6 S!Jll-AREAS 5.1

• S:l 0 B-271) Figure 8.,.. Potential Background locations on the Cattaraugus Territory of the Seneca Nation of Indians MT2015A008.002 16 October*1, 2015 Field Sampling and Dose Assessment Plan for the WNYNSC 10. Overview of Survey and Sampling Approach to be used to Ground Truth Aerial Survey Results The approach and sequential process that will be used for each location (i.e., elevated, random, confirmatory or "on Center" locations) is detailed below: a*) GPS Survey of Areas -For sub-areas that have not been previously sampled {i.e., Sub Areas 2.1, 2.2, 3.1, 3.2, 4.1, 4.2, 4.31 4.4, 4.5, 5.1, 5.2 and 5.3), a walkover survey of each sub-area will be conducted, with a GPS system recording the coordinates as the survey is being completed. The general methodology to conduct the radiological surveys will be as follows: I. A course grid walkover survey (typically 20 to 30 meter spacing) will be conducted utilizing a 2"x2" Nal gamma detector, coupled with a Ludlum Model 2241-2 scaler/ratemeter. The count rate signal from the Ludlum 2241-2 will be transferred to a GPS instrument, which will simultaneously log the GPS positton and count rate. _The logged data will subsequently be transferred to. a computer to be displayed on a map and/or satellite image. Each count rate data point wil! be assigned to a count rate range. For example: 0-4,000 CPM, 4,001 to 8,000 CPM, 8,001to12,000, and greater than 12,000 CPM. These count rate ranges will be color coded (e.g., green/yellow/orange/red), and displayed as the proper colored dot on the map or satellite image. II. After the GPS survey results are completed, MJW Corporation will review the survey results to determine if elevated locations above background levels have been identified within the surveyed area. If elevated locations are identified, these locations will be sampled and direct radiation levels collected at the sample locations. If elevated locations are not identified, random locations will be selected for survey and sampling on a grid pattern commensurate the shape of the area, as well as terrain and related physical conditions. The minimum number of survey and sampling locations are subsequently described in Table 3. b) Detailed Survey and Sampling Locations Determination -Each location where elevated, random or known sampling has been identified will De surveyed and sampled using: i. Tissue equivalent micro Rem readings at ground surface and 100 cm elevation . . ii. Static 2" x 2" Nal detector readings at contact and 100 cm elevation. iii. Collection of soil and stream sediment samples (Oto 15 cm and 15-30 cm depths). iv. Subsurface soil samples (30 cm -100 cm depth). c) For Cesium Prong confirmatory locations, based on previous sampling efforts (see Offsite Investigation Report in Section2), the highest levels of radioactivity are 17 October 1, 2015

' . Field Sampling and Dose Assessment Plan for the WNYNSC expected to be located in the 0-5 cm soil layer. Samples for the confirmatory locations will be collected in three soil depth intervals, 0 to 5 cm, 5-15 cm and 15-30 cm. d) Sample Number Determination -The total number of samples that will be collected for each sub-area was determined based on the size/area (in m2]. The sub-unit size/area determinations are as follows: I. 0-2,000 m' in area -A minimum of four locations will be sampled for each area. II. 2,001-10,000 m' in area -A minimum of 15 locations will be sampled for each sub-area. Ill. >than 10,000 m2 in area -A minimum of 24 locations will be sampled for each sub-area The total number of samples from each sub-area are detailed in Table 3. e) Samp.le Analysis Strategy MT2015-4008.002 I. All of the 0-15 cm interval samples will be analyzed for gross alpha, gross beta and gamma spectroscopy. Based on these resutts, additional expanded analysis (detailed in Table SJ may be warranted. H. If any of the Cs-137 results are above background plus 2 standard deviations, then the next greater depth sample will be sent for analysis. Ill. ff the gross alpha or beta results are greater than background plus 2 standard deviations, then radiation doses will be calculated assuming that the gross beta background exceedance is attributed to Sr-90, and the gross alpha exceedance is attributed to the most limiting (i.e., most conservative} alpha-emitting radionuclide (Am-241 or Pu-239). IV. For the subsurface soil samples (30 cm -lm), each sampte will be surveyed using the 2"x2 Na! detector, and the region of depth with the highest elevated counts wifl be sent for analysis. If no elevated areas are identified, the 30 cm to 45 cm sample will be sent for analysis. i. Standard Analysis -All soil samples will be analyzed for gross alpha and beta and gamma spectroscopy. il. Expanded Analysis -Selected samples will be analyzed more extensively, based upon initial sample results, information gathered in the field, and project Quality Assurance/Quality Control requirements. At a rninitnum, two quality control samples from each sub-area will be sent for expanded analysis. Additional information related to the quality control samples is detailed in the QAPP. The expanded analysis wilt require a 20-day !ngrowth period for a precise analysis of some radionuclides, such as Radium-226, and as such will not be included in the dose assessment. If this analysis yields information that would have a significant impact on the dose assessment, the dose assessment will be revised. 18 October 1, 2015 Field Sampling and Dose Assessment Plan for the WNYNSC V. Based on the information detailed in Tables 2, 3 and 4, there will be 179 elevated or random soil samples, 23 SNI background, 5 "on Center" and 37 quality control soil samples that will be collected and initially sent for analysis. VI. In addition, all four Cesium Prong-confirmatory samples at 0-15 cm depth and one confirmatory sample at 30 cm -1 m depth will be sent for gross alpha, gross beta and gamma spectroscopy. All five have been selected for expanded analysis. VII. For samples that were analyzed for gross alpha, gross beta, and gamma spectroscopy only (i.e., that did not exceed background pfus two standard deviations}, the alpha activity will be attributed to Am-241, a second calculation will be performed assuming Pu-239 (the limiting alpha emitting radionuclide). Vil!.. For samples that were analyzed for gross alpha, gross beta, and gamma spectroscopy only (i.e., that did not exceed background plus two standard deviations), the beta activity will be attributed to Sr-90, the limiting beta emitting isotope. MT2015-4008.002 19 October 1, 2015 Field Sampling and Dose Assessment Plan for the WNYNSC Table 2 -Sub-Area Description, Survey and Results Comparison Approximate .. **Area General Description of Area Size of.Area Walkover Survey Compared :To (mi) and GPS .. 1.1 Cesium Prong ! NA NA Confirmatory 1995 Western New York Nuclear Service Center Off-Site 1 Location Radiation Investigation Summary Report ! 1.2 I Cesium Prong ; NA 1995 Western New York Nuclear Service Center Off-Site i [ Location Radiation Investigation swmmary Report I . 1.3 Cesium Prong NA . NA-Confirmatory 1995 Western New York Nuclear Service Center Off-Site ; I Location Radiation Investigation Summary Report i i 1.4 Cesium Prong ! NA i NA-Confirmatory ! 1995 Western New York Nu dear Service Center Off-Site I l Location i Radiation Investigation Summary Report Northwest of Cesium Prong i 42 Yes 2014 WVDP Terrestrial Background Study ! ' I : 2.2 ; Northwest of Cesium Prong i 350 Yes 2014 WVDP Terrestrial Background Study >----*-*-+--I : 3.1 ; Field at Confluence of Buttermilk 46,933 ! Yes 2014 WVDP Terrestrial Background Study ! 2014 WVDP Terrestrial Background Study =1 I : and Cattaraugus Creeks L-*--I : 3.2 i Elevated sub-area on Farm 1,028 : Yes r.--*--+-----I 4.1 12,913 'Yes

• Nation of Indians l 2015 Cattaraugus Territory of the Seneca Nation of Indians 1 Background Values 1 Cattaraugus Territory of the Se nee.a L I : 4.2 i Cattaraugus Territory of the Seneca 9,378 *1 Nation of Indians* : 4.3 ! Cattaraugus Territory of the Seneca 2,591 : Nation of Indians j Cattaraugus Territory of the Seneca 44,329 I Nation of Indians . 4.5 i Cattaraugus Territory of the Seneca 550 I I i Nation of Indians l ! Cattaraugus Territory of the Seneca 1,374 ; 5.1 i ! Nation of Indians i 5.2 1 Cattaraugus Territory of the Seneca 902 f 5.3 Nation of Indians -** Cattaraugus Territory of the Seneca 5,845 I Nation of Indians I MT2015*4008.002 : Yes 1 . i Yes ; Yes I -r-i Yes I Yes j Yes I 'Yes I 20 , 2015 Cattaraugus Territory of the Seneca Nation of Indians ' Background Values 2015 Cattaraugus Territory of the Seneca Nation of Indians

• Background Values . 2015 Cattaraugus Territory ofthe Seneca Nation of Indians i Background Values 2015 Cattaraugus Territory of the Seneca Nation of Indians Background Values i 2015 Cattaraugus Territory of the Seneca Nation of Indians I Background Values i 2015 Cattaraugus Territory of the Seneca Nation of Indians Background Values 2015 Cattaraugus Territory of the Seneca Nation of Indians : Background Values October 1, 2015 Flt!ld Sampling and Dose Assessment Plan for the WNYNSC Table 3 -Sub*Area Description, Number of Sample Locations, Maximum Depth, and Total Number of Samples Approximate Total Sample Maximum Number of Samples: Total Samples Size of Area Locations Sample Elevated (E), Random {R), Collected Area General Description of Area (m:<) Depth or Confirmatory (C) and Oepths(m) 1.1 Cesium Prong NA 1 30cm 3 CSamples: 3 I 0-5 cm I I i i l j 5-15 cm I J j I . 15-30 cm : 1.2 ! Cesium Prong NA ! 1 , 30cm 3 CSamples: 3 i f j ' I 0"5 cm : ' t ! I 5-15 cm 15-30 cm I. 1.3 Cesium Prong NA 1 30 cm : 3 C Samples: 0-5 cm 1 I 5-15 cm 3 1 ; \ 1s-3o cm -------i r' '. 1.4 : Cesrum Prong NA 1 130 cm 3 C Samples: 3 1 0-5 cm ! 5-15 cm 15-30 cm 2.1 I 2.2 !. i I I Possible Cesium Prong Extension i Possible Cesium Prong Extension I Field at Confluence of Buttermilk ! and Cattaraugus Creeks MT2015* 4008 .002 42 350 46,933 I . I I 21 4 4 24 lm 1m lm 3 E or R Samples: I 0-5 cm i 5-15 cm, ! : 15 cm-lm 13 E or R Samples: I 0-5 cm i 5-15 cm, i l 15 cm-lm ; 24 E or R Samples: I I 0-15 cm 15-50 cm 6 E or R Samples: 12 12 60 October 1, 2015 I J Fir:;11.1 Samp!ing and Dose Assessment Plan for the WNYNSC Table 3 -Sub-Area Description, Number of Sample Locations, Maximum Depth, and Total Number of Samples Area 3.2 (4.1 I General Description of Area ! Elevated sub-area on Farm ! i Cattaraugus Territory of the I Seneca Nation of Indians* I : i . 14. 2 i Calta raugus Tmitory of the : I Seneca Nation of Indians I ! 4.3 14.4 i 'j Cattaraugus Territory of the Seneca Nation of Indians l Cattaraugus Territory of the I Seneca Nation of Indians MT2015-4008.002 Approximate Size of Area (m2) 1,028 12,913 9,378 2,591 44,329 Z2 Total Sample Locations 4 24 15 15 24 Maximum Sample Depth 1m lm 1m i 1 m ! Number of Samples: Elevated {E};. Random (R), or Confirmatory (C) and Depths {m) 30-60 cm ! 60 cm-1 m j 4 E or R Samples:

• 0-15 cm [ 15 -30 cm* I J 1 E or R Sample: 30-60 cm 60 cm-1 m 24 E or R Samples: 0-15 cm 15 -30 cm; 6 E or R Samples: 30-60 cm 60 cm-1 m 15 E or R Samples: 0-15 cm 15 -30 cm; 4 E or R Samples: 30-60cm 60 cm-1 m 15 E or R Samples: 0-15 cm 15 -30 cm; 4 E or R Samples: 30-60 cm; 60 cm-1 m 24 E or R Samples: 0-15 cm 15 -30 cm; 1 ! 60 38 38 60 Total Samples Collected 10 October 1, 2015 Field Sampling a.nd Dose Assessment Plan for the WNYNSC Table 3 -Sub-Area Description, Number of Sample Locations, Maximum Depth, and Total Number of Samples Approximate Total sample Size of Area locations Area General Desc:ription of Area (m:z} ' ' ! ' j I ' I ! l ! ; i I i 4.5 '. Cattaraugus Territory of the 550 4 I i Seneca Nation of Indians I l f 1 r i ' I Maximum Sample Depth lm I ' I Number of Samples: Elevated {E), Random {R), or Confirmatory (C) and Depths (m) 6 E or R Samples: 30-60cm 60 cm-1 m 4 E or R Samples: 0-15 cm 15 -30 cm; 1 E or R Samples. 30-60 cm Total *Samples Collected 10 I ! ; ; ! I. 60 cm -1 rn i 5.1 Cattaraugus --<---4----+-1-m----!-4-E_o_r_R_S_a_m_p_le_s_:----r-; ------1 I ; Seneca Nation of Indians 0-15 cm i 15 -30 cm; 5.2

• Cattaraugus Territory of the

• 902 Seneca Nation of Indians i I i I i "' --+ 5.3 ! Cattara ugu: of the , i Seneca Nation of Indians i I 5,845 I . I 4 1 rn 15 lm 1 E or R Samples: 30-60 cm 1 60 cm-1 m 4 E or R Samples: 0-15 cm 15 -30 cm; 1 E or R Samples: 30-60 cm 1 60 cm-1 m 11s E or R Samples: 0-15 cm 15 -30 cm; 4 E or R Samples: 30-60cm; , j 60 cm-1 m ! 10 : 38 Table 4-Sub-Area Description, Total Samples from Eac:h Sub-Area, Standard and Expanded Analysis and Dose Assessment MT2015-4008.002 23 October 1, 2015 i-.. ,::1d Sampling and Dose Assessment Plan for the WNYNSC Area 1.1 1.2 11.3 I i I 1.4 I ! i : 2.1 i 12.2 I t 3.1 I I 3.2 I i I 4.1 ' General Description of Area Cesium Prong I Cesium Prong ! I [ Cesium Prong i I IC . p : es1um rong '. ' -:. Cesium Prong ' Extension ( I Cesium Prong \ Extension ! ! I Field at Confluence of I Buttermilk and Cattaraugus Creeks l Elevated sub-area on ! Farm ' ! Cattaraugus Territory of the Seneca Nation of Total Samples from Each Sub* Area Sent for Standard Analysis Initial Analysis 1 Gross alpha, Gross Beta, Gamma Spec 1 Gross Alpha, Gross Beta, Gamma Spec 1 Gross Alpha, Gross Beta, Gamma Spec _" ____ ..... _ --1 4 . 4 30 s 30 Gross Alpha, Gross Beta, q_amma Spec Gross Alpha, *I Gross Beta, *Gamma Spec Gross Alpha, Gross Beta, Gamma Spec Gross Alpha, Gross Beta, Gamma Spec Gross Alpha, Gross Beta, r Gamma Spec Gross Alpha, I Gross Beta, I ________ _,___ ________ J_Gamma Spec MT2015-4008 .002 24 Expanded Analysis Dose Assessment Information If standard analysis data is> 1995 Use 1995 Western New York Nuclear values+ 10% decay-corrected values, Service Center Off-Site Radiation refer to Section 10. Investigation Summary Report If standard analysis data is> 1995 Use 1995 Western New York Nuclear values+ 10% decay-corrected values, Service Center Off-Site Radiation refer to Section 10. Investigation Summary Report If standard analysis data is> 1995 Use 1995 Western New York Nuclear values+ 10% decay-corrected values, Service Center Off-Site Radiation refer to Section 10. Investigation Summary Report J Background+ 2cr, refer to Section 10. l . J Assessment using RESRAD Calculation I i -I If standard analysis data is> 1995 Use 1995 Western New York Nuclear j values+ 10% decay-corrected values, ! Service Center Off-Site Radiation I refer to Section 10. i Investigation Summary Report ! If standard analysis data is> WNYNSC I Recreational Hiker Scenario Dose l Recreational Hiker Scenario Dose . j If standard analysis data is> WNYNSC ! Background+ 2a, refer to Section 10. I Assessment using RESRAD.Calculation I ! I i . I If standard analysis data is> WNYNSC I Resident Farmer Scenario Dose Background+ 2a, refer to Section 10. Assessment using RESRAD Calculation ! If standard analysis data !s > WNYNSC Resident Farmer Scenario Dose Background+ 2a, refer to Section 10. Assessment using RESRAD Calculation If standard analysis data is> SNI Recreational Hiker Scenario Dose Background+ 2cr, refer to Section 10. Assessment using RESRAD Calculation October 1, 2015 Fie1d Sampling and Dose Assessment Plan for the WNYNSC Table 4 -Sub-Area Description, Total Samples from Each Sub-Area, Standard and Ei<panded Analysis and Dose Assessment Area General Description of Area 4.2 Cattaraugus Territory of the Seneca Nation of Indians i 4.3 Cattaraugus Territory of the I Seneca Nation of Indians I I 4.4 Cattaraugus Territory of the ! Seneca Nation of Indians i i--------1--j 4.5 I Cattaraugus Territory of the i Seneca Nation of Indians L_J 1 5.1 i Cattaraugus Territory of the I 5.2 : 5.3 ; ; ......... ! i I j Seneca Nation of Indians I Cattaraugus Territory of the Seneca Nation of Indians l i Cattaraugus Territory of the ' S N t' f I d' I eneca a ton o n 1ans General Area Description : WNYNSC On-Center" i ; SNI Background Quality Control Samples I MT2015-4008.002 Total Samples from Each Area Sent for Initial Analysis I 19 i 19 i* ! 30 j I ' 5 5 5 19 ! I Total Samples I 5 i *1 23 l r I 37 Stantiard Analysis f Gross Alpha, Gross \ Beta, Gamma Spec ! Gross Alpha, Gross ; Beta, Gamma Spec j I Gross Alpha, Gross : Beta, Gamma Spec ; Gross Alpha, Gross i Beta, Gamma Spec ! I _; Gross Alpha, Gross ; Beta, Gamma Spec I *Expanded Analysis If standard analysis data is> SNI ! Background+ 2o, refer to Section 10. ! If standard analysis data is> SN! Background+ 2a, refer to Section 10. ; I ' ! If standard -analysis data is> SNJ Background+ 2a, refer to .Section 10. I j If standard analysis data is> SNI i Background + 2cr, refer to Section 10. ! Jf standard analysis data is> SN! I Background + 2a, refer to Section 10. Dose *Assessment Information Recreational Hiker Scenario Dose Assessment using RESRAD Calculation Recreational Hiker Scenario Dose Assessment using RESRAD Calculation j Recreational Hiker Scenario 1 Dose Assessment using I RESRAD Calculation ! Recreational Hiker Scenario ! Dose Assessment using ; RESRAD Calculation l Recreational Hiker Scenario ! Dose Assessment using ) RESRAD Calculation Gross Alpha, Gross If standard analysis data is> SN! .1' Recreational Hiker Scenario ; Beta, Gamma Spec ; Background+ 2a, refer to Section 10. Dose Assessment using . RESRAD Calculation I Gross Alpha, Gross . 8 t G S If standard analysis data is> SNI B k d+2 f t S t' ; Recreational Hiker Scenario 10 ' D A t I e a, am ma pee ac groun o, re er 0 ec ion ose ssessmen using

• I ! ;* i RESRAD Calculation I ! Standard Analysis Expanded Analysis [ Gross Alpha, Gross Two sent for Isotopic Analysis i N/A . Beta, Gamma Spec i j Gross Alpha, Gross 10% or three sent for Isotopic N/A ; Beta, Gamma Spec Analysis ! Gross Alpha, Gross 100% sent for Isotopic Analysis 'N/A Beta Gamma S ec p 25 October 1, 2015 ! t i ! j i ; ' I ! I Field Sampling and Dose Assessment Plan for the WNYNSC Table 5-Standard and Expanded Analysis Information r--*---.. ................ --*--***-*** * --r ---**----** ** -*-r-------* Analytical Parameter Method MDC Units ........ -----------.............. _____ ,J ______ *-**-,......_--*-** -.--*-Standard Analysis --* Gross Alpha EPA 900.0 Mod/SW 4 pCi/g Gross Beta (Nonvolatile Beta) EPA 900.0 Mod/SW 10 pCi/g Gamma scan (Cs-137, Ac-227, Co-60, Cd-113m, Eu-DOE HASL 300 0.1 (Cs-137 pCi/g _:J.._.?4, Pa-231, Sb-125, Sn-U_91 4.5_):.3/Ga-01-R Onlvl Expanded Analysis Am-241,Cm-242,Cm-243/244,Cm-245/246 DOE HASL300 1 pCi/g Am-05-RC Mod C-14 EPA EERF C-01 Mod 2 pCi/g -*-1-129 DOE HASL 300 1-01 1 pCi/g Np-237 DOE HASL300 1 pCi/g Pu-238, 239/240 DOE HASL 300 1 pCi/g Pu-11-RC Mod Pu-241 DOE HASL300 15 pCi/g Pu-11-RC Mod Sr-90 EPA 905.0 Mod 2 pCi/g -Tc-99 DOE HASL300 5 pCi/g Tc-02-RC Mod U-232 DOE HASL 300 1 pCi/g U-02-RCMod U-233/234, U-235/236, U-238 °DOE HASL300 1 pCi/g U-02-RCMod H-3 EPA 906.0 Mod 6 pCi/g Th-229 DOE HASL 300 1 pCi/g Th-01-RC Mod Th-228, Th-230, Th-232 DOE HASL 300 1 pCi/g Th-01-RC Mod -Radium 226 (20-day ingrowth) DOEHASL 300 1 pCi/g 4.5.2.3/GA-01-R Radium 228 DOEHASl300 3 pCi/g 4.5.2.3/GA-01-R MT2015-4008.002 26 October 1, 2015 Field Sampling and Dose Assessment Plan for the WNYNSC 11. Dose Assessment Methodology a) For the Cesium Prong, which has been previously evaluated, the data evaluation approach will be : I. Estimation of annual exposure based upon the aerial survey data. II. Estimation of annual exposure based upon the micro Rem meter readings. Ill. For Area 1, compare the decay corrected isotopic concentrations from th.e 1995 study to the new isotopic concentrations. further analysis by RESRAD or generally accepted methodologies may be apprnpriate if wmparison yields a new isotopic concentration in excess of 10% of the decay corrected 1995 data. IV. For Area 2 (sub-areas 2.1 and 2.2}, a site-specific Recreational Hiker land use scenario will be evaluated using RESRAD; where appropriate, site-specific parameters will be entered into RESRAD (e.g., hydrology, occupancy and consumption) in order to give a more specific estimate of the Recreational Hiker's exposure. These parameters will either be adjusted based on published references for the region or historicat site specific data. This area wiH be calculated using the arithmetic mean for the data analyzed. b) For Area 3 (sub-areas 3.1 and 3.2} the primary method of dose assessment will be: MT2015-4008 .002 I. Estimation of annual exposure based upon the aerial survey data. II. Estimation of annual exposure based upon the microRem meter readings. Ill. A site-specific Resident Farmer land use scenario will be evaluated using RES RAD; where appropriate, site-specific parameters will be entered into RESRAD (e:g., hydrology, occupancy and consumption) to give a more specific estimate of the exposure. These parameters will either be adjusted based on published references for the region or historical site specific data. Trend analysis of the expected annual exposure rate over time will be made to determine if a member of the public would be expected to exceed the 25 mrem/year limit currently or in the foreseeable future. These areas wil I be calculated using the arithmetic mean for the data analyzed. 27 October 1, 2015

' ' Field Sampling and Dose Assessment Plan for the WNYNSC c} Areas 4 and 5 (sub-areas 4.1, 4.2, 4.3, 4.4, 4.5, 5.1, 5.2 and 5.3.) the primary method of dose*assessment will be: I.. Estimation of annual exposure based upon the aerial survey data. 11.*

• Estimation of annual exposure* based upon the micro Rem meter readings. 111. A site-specific Recreational Hiker land use scenario will be evaluated using RESRAD; where appropriate, site-specific param.eters will be entered into RESRAD (e.g., hydrology, occupancy and consumption) to give a more specific estimate of the Recreational Hiker's exposure. These parameters will either be adjusted based on published references for the region or historical site specific data and in consultation with the Seneca Nation. These areas will be calculafed using the arithmetic mean for the data. d) Each sub-area dose assessment will be compared to the surface soil decay-corrected values in Tab!e 7 (Table ES-1 the DCGLw Peak-of-the Mean) of the WVDP Phase 1 Decommissionrng Plan for comparison purposes. The peak-of-the mean values are the most conservative DCGLw values provided in the Phase 1 WVDP Decommissioning Plan and are for a resident farmer scenario. 12. Potential Obstacles and Contingency Strategy One potential obstacle to performing the radiological surveys is inadequate GPS signal ("dead zones"). This may occur in areas where there is excessive tree cover, or geological feature such as ridges, that may obstruct the GPS Satellite signals. If this occurs across a very limited section of a Subzone, the survey team wil[ obtain GPS coordinates at the edges of the dead zone and will note them in the survey logs. If low precision or cell tower based location information is. available, the grid lines will be mapped and readings will be logged by hand at 20 meter intervals. If the dead zone is substantial, GPS Survey will be conducted in the areas where it is possible, and grid lines will be established and walked down manually recording the data. A second potential obstacle will be field conditions encountered that hamper the ability to collect readings in the prescribed geometries. For example, heavy vegetation may hinder the ability to obtain measurement at the prescribed 1 cm and 100 cm elevations. Field personnel will make their best effort to achieve the geometries; but there may be some deviation which will be noted. MT2015-4008.002 28 October 1, 2015 Field Sampling and Dose Assessment Plan for the WNYNSC . Table 6 -DCGLw Peak-of-the Mean values of the WVDP Phase 1 Decommissioning Plan, Rev. 2 for 25 mRem/year (pCi/g) llJ NOTES: Nuclide Am-241 --*----**---C-14 Surface Soil 2.9E+01 1.6E+Ol 3.SE+01 **-*-*** ... ***--* ***-*-*-****---Cm-244 6.SE+Ol cs=i3*7t2r... 1.si::;:-51*--**--**-------******---*--* 1-129 3.3E-01 \-------***-****-**-*-****----* ___ _ __, Pu-238 4.0E+Ol *-_,,, __ , ............... -***-*. **--*' ..................... -* Pu-239 2.SE+Ol Pu-240 2.6E+01 Pu-241 l.2E-t*03 -.... *s;:=-9Qf11-** ...... *4:i -*-***-* *.*** ......... . Tc-99 2.lE+Ol -**---****----*--***** .. ******----U-232 l.SE+OO U-233 8.3E+OO U-234 8.4E+OO U-235 3.SE+OO ...... _., ......... ,_,_______ -* --*--*** .. **-U-238 9.8E+OO (1} The DCGLw is the DCGL applicable to the average concentration over the survey unit. {2) WVDP Phase 1 DP DCGLs for Sr-90 and Cs-137 apply to the year 2041 and later. 13. Applicable Field Procedures or Referenced Documents MJW Field Procedures applicable to the work will include: ci GPS Enhanced Overland Gamma Radiation Survey-Including Preparation and Assessment of Radiological and Geographical Data" o "Instrument Operation Procedure-Ludlum 2241-2 Ratemeter/Scaler Coupled with Ludlum 44-9 or Ludlum 44-10 2x2 Nal Detector" * "Instrument Operating Procedure -Bicron MicroRem Meter"

• Project Specific Sample Collection Procedure

• Quality Assurance Project Plan

• Health and Safety Project Plan MT2015-4008.002 29 October 1, 2Q15 Field Sampling and Dose Assessment Plan for the WNYNSC Other referenced documents include:

• 1995 Western New York Nuclear Service Center Off-Site Radiation Investigation Summary Report is available through NYSERDA (Dames and Moore]. o 1984 Aerial Radiological Survey of the West Valley Demonstration Project and Surrounding Area (EGG-10617-1080) May 1991. o EG&G Energy Measurements Group, A Comparison of Aerial Radiological Survey Results of the Nuclear Fuel Services Center (NFS} and Surrounding Area, West Valley, New York, September 1979.

• West Valley Demonstration Project Terrestrial Background Study for Task Order No. 5, Rev. 1, (Safety and Ecology Corporation), July 2014.

• Phase 1 Decommissioning Plan for the West Valley Demonstration Project, Rev. 2, December 2009. 14. Reference Standards and Practices

• NCRP Report No. 50, "Environmental Radiation Measurement," December 1976.

• NUREG 1507,"fV!inimum Detectable Concentrations with Typical Radiation Survey Instruments for Varfous Contaminants and Field Conditions," December 1997. o National Council on Radiation Protection and Measurements Report NCRP No. 129, Recommended Screening Limits for Contaminated Surface Sotl and Review of Factors Relevant to Site-Specific Studies, Washington, DC, 1999.

• NUREG 1506, "Measurement Methods for Radiological Surveys in Support of New Decommissioning Criteria."

• NUREG-1576-Multi-Agency Radiological Laboratory Protocols Manual (MARLAP}. * "WVDP-065, Manual for Radiological Assessment of Environmental Releases at the WVDP," Rev. 3, August 2000. ca U.S. Nudear Regulatory Commission, Standards for Protection against Radiation, CFR Part 20, November 16, 2005. o EPA SOP #2001, General Field Sampling Guidelines, August 11, 1994.

• EPA SOP #2012, Soil Sampling, February 18, 2000. MTZ015-4008.002 30 October 1, 2015 Appendix Summary of Changes FSDAP Appendix A-Summary of Changes to Field Survey and Dose Assessment Plan, Rev. 0 The following is a summary of changes to the Field Survey and Dose Assessment Plan (FSDP) issued on 10/1/15, and reasons or basis for the changes: 1. Area 1 Field Survey Operations: The FSDAP called for the collection of direct radiation measurements and soil samples from 4 discrete locations (1.1, 1.2, 1.3, and 1.4). The survey team was not able to access location 1.4 because the property owner declined to provide permission to access the property, and therefore it was not surveyed. 2. Area 1 RESRAD Based Dose Assessment: The FSDAP indicated that ifthe soil concentrations measured in Area 1 exceeded the decay corrected 1995 Data (Reference 3 -1995 Western New York Nuclear Service Center Off-Site Radiation Investigation Summary Report) by more than 10% that further analysis by RES RAD or other generally accepted methodologies may be appropriate. Since the soil concentrations did exceed this level, a dose assessment was performed. Although not strictly a change from the FSDAP, it was initially anticipated that such a calculation if necessary would be performed using a Recreational Hiker scenario anq as a consequence the annual exposure time for dose assessments based upon aerial survey data and direct readings would be 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year. Based on further discussion and analysis the RESRAD calculation was based upon a Resident Homemaker scenario which assumes that an individual is present in the contaminated area for 8,760 hours0.0088 days <br />0.211 hours <br />0.00126 weeks <br />2.8918e-4 months <br /> per year as opposed to the recreational hiker scenario basis of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year. MJW determined that this was a more conservative and representative basis to determine the dose. 3. Area 2.1-Not Able Collect all Samples The FSDAP called for collection of a sample in sampling location 2.1.4 from the 15-100 cm depth. Due to the extreme slope of this location it was not feasible to collect this sample. 4. Area 2 and Area 3 -Revision of Sampling and Analysis Strategy

• On October 15, 2015 Table 3 of the FSDAP "Sub-Area Description, Number of Sample Locations, Maximum Depth and Total Number of Samples" for areas 2 and 3 were revised. The area sizes were reduced; however the number of sub-area samples and quality control samples remained the same. (revised table provided below)

• On October 29, 2015 Table 3 was again revised to reflect changes in the sampling for area 4 and area 5. These changes were made based on further analysis of the aerial survey data by RSL. Simultaneously new figures were incorporated to describe the sub areas to be sampled and surveyed in area 4 and area 5. Within these areas "polygon" shapes were introduced that surro'unded each sub area. These polygons were design"ated to be the boundaries of the walkover GPS surveys. (revised table and figures provided below)

Appendix A-Summary of Changes to Field Survey' and Dose Assessment Plan, Rev. 0 5. Determination of Background Dose Rates and Soil Concentrations for Comparison to Data from Areas 1, 2 and 3. As is describe in the body ofthis report, the initial intent was to compare data from areas 1, 2 and 3 to background levels established in the 2015 DOE Background Study (Reference 4). Because this study did not provide background concentrations for gross alpha and gross beta activity, the two site background areas were surveyed and sampled as described in the report, and this data was used to subtract background from the area 1, area 2, and area 3 data. 6. Revision of Sample Analysis Strategy Section 10 e) IV of the FSADAP called for the scanning of samples from the 30-100 cm depth to determine which elevation was the highest, so that sample could be sent to the lab for analysis. By default if an elevated sample was not identified the 30 to 45 cm depth samples were to be sent for analysis. This step was not performed. There were no samples collected from the 30 to 45 cm depth. Samples were submitted to the lab for analysis based upon the revised table 3 requirements. 7. Changes to the location of two SNI Background Locations

• The location of SNI Background Location 20 was relocated because a building was under construction in the area, and it was determined thatthis location was not suitable for determination of unperturbed background conditions. A new location was selected and incorporated into the Field Guide.

• Similarly when the original SNI Background Location 24 was sampled, subsurface building debris was encountered, so this location was also relocated to a more appropriate place. The SNIB Background locations map was updated and incorporated into the project report .. 8. Additional analysis of Sample 3.l.1E4 Sample 3.l.1E4 was located in Area 3.1 in a region identified by GPS survey to be elevated compared to other areas within 3.1. It was collected from the 60-100 cm elevation. This sample exhibited elevated gross alpha concentrations that were contrary to expectations. A split field duplicate of this sample, did not show elevated activity. Two additional aliquots were drawn and analyzed by Gel laboratories, and neither sample showed elevated gross alpha activity. As a consequence it was determined that the initial elevated assay was invalid, and the alternative data was utilized.

Appendix A-Summary of Changes to Field Survey and Dose Assessment Plan, Rev. 0 Table 3 -Revision October 15, 2015 Maximum Number of Samples: Elevated General Description of Area Approximate Size Total Sample Sample (E}, Random (R}, or Total Samples of Area (m2} Locations Confirmatory (C} and Depths Collected Depth (m) Cesium Prong -Sub-Area 1.1 NA 1 30 cm 3 C Samples: 3 0-5 cm 5-15 cm 15-30 cm Cesium Prong -Sub-Area 1.2 NA 1 30cm 3 C Samples: 3 0-5 cm 5-15 cm 15-30 cm Cesium Prong -Sub Area 1.3 NA 1 30cm 3 C Samples: 3 0-5 cm 5-15 cm 15-30 cm Cesium Prong -Area 1.4 was NA +/- 3 C Samples: 3-deleted as the property ownder 0 S cm denied access S lS cm lS 30 cm Possible Cesium Prong Extension -4 lm 3 E or R 12 Sub-Area 2.1 22 1 5 cm (all sent for gross alpha/beta and gamma) 1 15 cm 1-15 cm -lm Sent for 4-0-5 cm for standard analysis Archive Total 2 -QC Samples for 4 -Remaining 5-15 cm Expanded Analysis 4 -Remaining 15 cm -lm (0-5 cm and 5-15 cm)

Appendix A -Summary of Changes to Field Survey and Dose Assessment Plan, Rev. 0 Maximum Number of Samples: Elevated General Description of Area Approximate Size Total Sample Sample (E), Random (R), or Total Samples of Area (m2) Locations Confirmatory (C) and Depths Collected Depth (m) 6 Total Possible Cesium Prong Extension -4 lm 3 E or R Sam(!les: 12 Sub-Area 2.2 194 1 5 cm (all sent for (NYSDOT location) standard analysis) 1-5-15 cm 1-15 cm -lm Sent for Analysis Archive Total 4-0-5 cm for 4-5-15 cm standard analysis 4 -15 cm -lm 2 -QC Samples for Expanded Analysis (0-5 cm and 15 cm-lm) 6 Total Field at Confluence of Buttermilk 24 lm 24 E or R Sam(!les: 60 and Cattaraugus Creeks -Sub-Area 25833 1 15 cm (all sent for 3.1 standard analysis)

Appendix A-Summary of Changes to Field Survey and Dose Assessment Plan, Rev. 0 Maximum Number of Samples: Elevated General Description of Area Approximate Size Total Sample Sample (E}, Random (R}, or Total Samples of Area (m2) locations Confirmatory {C} and Depths Collected Depth (m) 1 30 cm (4 sent for Sent for standard analysis) 24 15 cm for standard analysis 6 E or R SamQles Total 4 30 cm sent 6 60 cm for standard analysis 6 -60 cm -lm (4 sent for 4 -60 cm -lm sent standard analysis) for standard analysis Archive Total 4 -QC Samples for 20 -Remaining 15 -30 cm Expanded Analysis 6-30-60cm (2 15 cm 2-Remaining 60 cm -1 m 1-15-30 cm 1-60 cm-lm) ' 36 Total Elevated sub-area on Farm -Sub-+/-;W& 4 lm 4 E or R SamQlesLlocation: 10 Area 3.2 511 1 15 cm (all sent for standard analysis) 1 30 cm 1 E or R SamQle Total 30-60 cm Appendix A-Summary of Changes to Field Survey and Dose Assessment Plan, Rev. O Maximum Number of Samples: Elevated General Description of Area Approximate Size Total Sample Sample (E), Random (R), or Total Samples of Area (m2) Locations Depth Confirmatory (C) and Depths Collected (m) 60 cm -1 m (1 sent for Sent for Anall£sis standard analysis) 4 15 cm for standard analysis Archive: 1 -60cm -lm sent 4-15-30 cm for standard analysis 1-30-60 cm 2 -QC Samples for Expanded Analysis (1-0-15 cm 1-60 cm -lm) 7 Total Appendix A-Summary of Changes to Field Survey and Dose Assessment Plan, Rev. 0 Table 3 -Revision October 28, 2015 General Description Approximate Size Total Maximum Sample Number of Samples: Elevated (E), Total Samples of Area of Area (m2) Sample Depth Random (R), or Confirmatory (C) and Collected Locations Depths (m) AREA4 BOX 1 4.la 886 4.lb 5,948 4.lc 6,781 4.ld 4,936 TOTAL 18,551 24 lm 24 E or R Samples: Sent for 1 15 cm (all sent for standard 24 15 cm for analysis) standard analysis 1 30 cm (4 sent for standard 4 30 cm sent analysis) for standard analysis 6 E or R Samples Total 4 -60 cm -lm sent 6 60 cm for standard 6 -60 cm -lm (4 sent for standard analysis analysis) 6 -QC Samples for Archive Total Expanded Analysis 20 -Remaining 15 -30 cm (2 15 cm 6-30-60cm 2-15-30 cm 2-Remaining 60 cm -1 m 1-30-60 cm 1-60 cm-lm) 38 Total BOX2 4.2a 1,466 4.2b 8,375 Appendix A-Summary of Changes to Field Survey and Dose Assessment Plan, Rev. 0 General Description Approximate Size Total Maximum Sample Number of Samples: Elevated (E), Total Samples of Area of Area (m2) Sample Depth Random (R), or Confirmatory (C) and Collected Locations Depths (m) 4.2c 232 TOTAL 10,073 24 lm 24 E or R Samples: Sent for Anall£sis 1-0-15 cm (all sent for standard 24 15 cm for analysis) standard analysis 1 30 cm (4 sent for standard 4 30 cm sent analysis) for standard analysis 6 E or R Samples Total 4 -60 cm -lm sent 6 60 cm for standard 6 -60 cm -lm (4 sent for standard analysis analysis) 6 -QC Samples for Archive Total Expanded Analysis 20 -Remaining 15 -30 cm (2 15 cm 6-30.,... 60cm 2-15-30 cm 2-Remaining 60 cm -1 m 1-30-60 cm 1-60 cm -lm) 38 Total BOX3 4.3a 1,896 4.3b 23,822 TOTAL 2s;11s 24 lm 24 E or R Samples: Sent for Anall£sis 1-0-15 cm (all sent for standard 24-0-15 cm for analysis) standard analysis 1 30 cm (4 sent for standard 4 30 cm sent analysis) for standard analysis 6 E or R Samples Total 4 -60 cm -lm sent 6 60 cm for standard Appendix A-Summary of Changes to Field Survey and Dose Assessment Plan, Rev. 0 General Description Approximate Size Total Maximum Sample Number of Samples: Elevated (E), Total Samples of Area of Area (m2) Sample Depth Random (R), or Confirmatory (C) and Collected Locations Depths (m) 6 -60 cm -lm (4 sent for standard analysis

• analysis) 6 -QC Samples for Archive Total Expanded Analysis 20 -Remaining 15 -30 cm (2 15 cm 6-30-60cm 2-15-30 cm 2-Remaining 60 cm -1 m 1-30-60 cm 1-60 cm-lm) 38 Total BOX4 4.4a 323 4.4b 245 4.4c 2,254 , . I 4.4d 1,916 TOTAL 4,738 15 lm 15 E or R Samples: Sent for Anall{sis 1 15 cm (all sent for standard 15 15 cm for analysis) standard analysis 1 30 cm (2 sent for standard 2-15-30 cm analysis) sent for standard analysis 4 E or R Samples Total 2-60 cm-lm 4 60 cm sent for standard 4 -60 cm -lm (2 sent for standard analysis analysis) 4 -QC Samples for Archive Total Expanded Analysis 13 -Remaining 15 -30 cm (2 15 cm 4-30-60cm 1-15-30 cm 2-Remaining 60 cm -1 m 1-30 cm -60 cm)

Appendix A -Summary of Changes to Field Survey and Dose Assessment Plan, Rev. 0 General Description Approximate Size Total Maximum Sample Number of Samples: Elevated (E), Total Samples of Area of Area (m2) Sample Depth Random (R), or Confirmatory (C) and Collected Locations Depths (m) 23 Total BOXS 4.5a 4,391 4.Sb 5,123 4.Sc 6,188 TOTAL 15,702 24 lm 24 E or R Samples: Sent for Anall£sis 1-0-15 cm (all sent for standard 24 15 cm for analysis) standard analysis 1-15-30 cm (4 sent for standard 4 30 cm sent analysis) for standard analysis 6 E or R Samples Total 4 -60 cm -lm sent 6 60 cm for standard 6 -60 cm -lm (4 sent for standard analysis analysis) 6 -QC Samples for Archive Total Expanded Analysis 20 -Remaining 15 -30 cm (2 15 cm 6-30-60cm 2 30 cm 2-Remaining 60 cm -1 m 1-30-60 cm 1-60 cm-lm) 38 Total AREAS BOX 1 5.la 778 5.lb 546 TOTAL 1,324 4 lm 4 E or R Samples[location: Sent for Anall£sis Appendix A-Summary of Changes to Field Survey and Dose Assessment Plan, Rev. 0 General Description Approximate Size Total Maximum Sample Number of Samples: Elevated (E), Total Samples of Area of Area (m2) Sample Depth Random (R), or Confirmatory (C) and Collected Locations Depths (m) 1-0-15 cm (all sent for standard 4-0-5 cm for analysis) standard analysis 1 30 cm 1 60 cm for standard analysis 1 E or R Sample Total 2 -QC Samples for 30 -60 cm (1 sent for standard Expanded Analysis analysis) (0-5 cm and 60 cm-1 m 60 cm-lm) 7 Total Archive: 4-15 -30 cm 1-60 cm -1 m BOX2 5.2a 3,071 5.2b 3,533 TOTAL 6,604 15 lm 15 E or R Samples: Sent for Anal)lsis 1 15 cm (all sent for standard 15 15 cm for analysis) standard analysis 1 30 cm (2 sent for standard 2 30 cm analysis) sent for standard analysis 4 E or R Samples Total 2-60 cm -lm 4 60 cm sent for standard 4 -60 cm -lm (2 sent for standard analysis analysis) 4 -QC Samples for Archive Total Expanded Analysis 13 -Remaining 15 -30 cm (2 15 cm 4-30-60cm 1-15-30 cm 2-Remaining 60 cm -1 m 1 -30 cm -60 cm) J Appendix A-Summary of Changes to Field Survey and Dose Assessment Plan, Rev. 0 General Description Approximate Size Total Maximum Sample Number of Samples: Elevated (E), Total Samples of Area of Area (m2) Sample Depth Random (R), or Confirmatory (C) and Collected Locations Depths (m) 23 Total Box 5.3 (5.3a) 573 4 lm 4 E or R Sent for Anal)lsis 1-0-15 cm (all sent for standard 4-0-5 cm for analysis) standard analysis 1-15 -30 cm 1 60 cm for standard analysis 1 E or R Total 30 -60 cm (1 sent for standard 2 -QC Samples for analysis) Expanded Analysis 60 cm -1 m (0-5 cm and 60 cm-lm) Archive: 4-15-30 cm 1-60 cm -1 m 7 Total Box 5.4 (5.4a) 1791 4 lm 4 E or R Sent for Anal)lsis 1 15 cm (all sent for standard 4-0-5 cm for analysis) standard analysis 1-15 -30 cm 1-30-60 cm for standard analysis 1 E or R Total 60 cm (1 sent for standard 2 -QC Samples fo analysis) Expanded Analysis 60 cm-1 m (0-5 cm and 60 cm -lm) Archive: 7 Total 4-15-30 cm 1-60 cm -1 m Box 5.5 (5.5a) 312 4 lm 4 E or R Sent for Anal)lsis 1 15 cm (all sent for standard 4-0-5 cm for Appendix A-Summary of Changes to Field Survey and Dose Assessment Plan, Rev. 0 General Description Approximate Size Total Maximum Sample Number of Samples: Elevated (E), Total Samples of Area of Area (m2) Sample Depth Random (R), or Confirmatory (C} and Collected Locations Depths (m) analysis) standard analysis 1-15 -30 cm 1 60 cm for standard analysis 1 E or R Sam[!le Total 30 -60 cm (1 sent for standard 2 -QC Samples for analysis) Expanded Analysis 60 cm -1 m (0-5 cm and 60 cm-lm) Archive: 4-15-30 cm 1-60 cm -1 m 7 Total Box 5.6 (5.Ga) 888 4 lm 4 E or R Sam[!les[location: Sent for Analysis 1-0-15 cm (all sent for standard 4-0-5 cm for analysis) standard analysis 1-15 -30 cm 1 60 cm for standard analysis 1 E or R Sam[!le Total 30 -60 cm (1 sent for standard 2 -QC Samples for analysis) Expanded Analysis 60 cm-1 m (0-5 cm and 60 cm -lm) Archive: 7 Total 4-15-30 cm 1-60 cm -1 m Appendix A-Summary of Changes to Field Survey and Dose Assessment Plan, Rev. 0 ff --=::::i ... --Feel 0 250 590 1.000 Area 4 Proposed Survey and/or Sampling Locations -2014Areas Meeting Criteria for Further Evaluation survey and sampling Sub-Areas 4.4e 4.4d 4.4a 4.Sa 4.Sb 4.5c Appendix A-Summary of Changes to Field Survey and Dose Assessment Plan, Rev. 0 5.6a 5.5a 5.4a ' /"JM ---==:=11----*Feet 0 250 500 1,000 Area 5 Proposed Survey andlor Sampling Locations -2014Areas Meeting Criteria for Further Evaluation Survey and Sampling Sub-Areas 5.6 0 5.5 5.1 \ <>* 5.1a 5.1b 5.4 0 5.2 5.3 5.3a