ML100670102

New York State Energy Research and Development Authority (NYSERDA) Comments on the Phase 1 Final Status Survey Plan (Fssp) for the West Valley Demonstration Project (Wvdp)

ML100670102
Person / Time
Site:	West Valley Demonstration Project, P00M-032
Issue date:	02/01/2010
From:	Bembia P State of NY, Energy Research & Development Authority
To:	Bower B NRC/FSME, US Dept of Energy, West Valley Demonstration Project
References
Download: ML100670102 (6)

Text

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

• info@nyserda.org February 1, 2010 Mr. Bryan C. Bower, Director U.S. Department of Energy West Valley Demonstration Project 10282 Rock Springs Road West Valley, NY 14171-9799

SUBJECT:

New York State Energy Research and Development Authority (NYSERDA)

Comments on the Phase 1 Final Status Survey Plan (FSSP) for the West Valley Demonstration Project (WVDP)NYSERDA is providing the enclosed comments on the Department of Energy's (DOE) Phase 1 Final Status Survey Plan for the West Valley Demonstration Project, dated December 16, 2009.NYSERDA respectfully requests that DOE provide a written response to the enclosed comments.Any questions regarding the enclosed comment package should be directed to Paul L. Piciulo, Ph.D., at (716) 942-9960 extension 4378.Sincerely, W VALLEY SITE MANAGEMENT PROGRAM Paul J. Bembia, Director JCK/amd

Enclosure:

1. NYSERDA Comments on the Phase 1 Final Status Survey Plan (FSSP) for the West Valley Demonstration Project (WVDP)PJB/10amd008.jck Main Office West Valley Site New York City Buffalo Albany Management Program 485 Seventh Ave., Suite 1006 Larkin at Exchange Building 17 Columbia Circle 10282 Rock Springs Road New York, NY 10018 726 Exchange Street, Suite 821 Albany, NY 12203-6399 West Valley, NY 14171-9799 Phone: (212) 971-5342 Buffalo, New York 14210 Toll Free: 1 (866) NYSERDA Phone: (716) 942-9960 Fax: (212) 971-5349 Phone: (716) 842-1522 Phone: (518) 862-1090 Fax: (716) 942-9961 Fax: (716) 842-0156 Fax: (518) 862-1091 Messr. Bryan C. Bower Page 2 February 1, 2010 cc: K. I. McConnell, NRC, w/enc.M. N. Maloney USDOE-WVDP, w/enc.D. A. Munro, NYSERDA-Alb, w/enc.J. C. Kelly, NYSERDA-WV, w/enc.P. L. Piciulo, Ph.D., NYSERDA-WV, w/enc.M. J. Willett, NYSERDA-WV, w/enc.A. L. Mellon, NYSERDA-WV, w/enc.PJB/lOamdOO8.jck NYSERDA Comments on-the Phase 1 Final Status Survey Plan for the West Valley Demonstration Project, Dated December 16, 2009 February 1, 2010 Cmt~~ ~,~. ~ RevýiewersýProposedýWes~outio-'n (If~ ýýrc6 6ti~ onfcaiiaini probably doesnit needa PogoeSection No.oe~ eo~iin~;1. General Based on the Characterization Sampling and Analysis Plan Prepare and submit the CSAP work plan and results to (CSAP) data collection, this Final Status Survey Plan (FSSP) NYSERDA for our review prior to the resubmitting the final may need to be revised. NYSERDA requests an opportunity to FSSP to us for comments.review the CSAP when it is finalized in February 2010, and subsequently comment on the revised FSSP.2. Page viii, Line 12 The Executive Summary states that "The plan uses gamma Clarify lhow the gamma scans performed in the field will scans combined with biased soil samples to address DCGLermc provide the necessary accuracy in determining biased sample concerns." Given the 18 Radionuclides of Interest (ROIs) for locations as well as ensuring compliance with the DCGLemc for this FSSP, is the use of gamma scans adequate for field all 18 ROIs.measurements in deciding biased soil sample locations or in determining DCGLemc for all 18 ROIs? Further, if all 18 ROIs cannot be detected using Gamma Walkover Surveys (GWS), explain how those radionuclides (e.g., C-14, Sr-90, Tc-99 and Pu-241) will be analyzed or accounted for during the field measurementprocess.

3. Page 3/ Section 2.1 identifies the excavation depth planned for the Reconsider the depth of the excavation necessary for WMA 2.Section remediation activities in Waste Management Areas (WMAs) 1 2.1/Paragraph 2 and 2. Given that the depth of Lagoon 2 exceeds the proposed 14-ft excavation, reconsider the excavation depth for WMA 2.4. Page 4/Section 2.2 As stated in Section 2.2, the Derived Concentration Guideline Clarify how the proposed DCGLs for WMAs 1 and 2 are Levels (DCGLs) for each ROI are based on a 25 millirem adequate (i.e., less than 25 mrem/yr) for contributions from all (mrem)/year (yr) dose requirement.

If the goal is the 18 ROIs as well as each of the sample media (e.g., soils, stream unrestricted release of WMA 1 and 2 (i.e., the sum total dose sediments and subsurface soils).from all 18 ROIs is less than 25 mrem/yr for WMA 1 and 2), are the DCGLs calculated low enough to achieve less than 25 mrem/yr in these areas? Specifically, as defined in the Phase 1 DP, the cleanup goals for soil and stream sediment are 22.5 for soil and 2.5 for stream sediment, for a total contribution of 25 mrem/yr (see Tables 9-1 and 9-3 of Rev. 2 of the Phase 1 DP).Clarify the contribution to the dose from the subsurface soils and how these DCGLs are included in the less than 25 mrem/yr for WMAs 1 and 2.5. Page 4/Section The paragraph is truncated after the word "stream." The Relocate the fragmented paragraph on Page 7 to Page 4.I of 4 Reviewers7Proposed Resolution

1. Pag-e/Secti on ~No.j t.ome t,~ 7. ý (f yorcmn sa point of c1a~rfication-ftpjroliably doesn't ne EPi~posdiiresolution:)

2.2/Last sentence remainder of this section, currently on Page 7, should be moved to Page 4.6. Page 7/Section 2.2 The final set of DCGL values listed in Table 5-14 of the Phase Incorporate the DCGL values for Sr-90 and Cs-137 at the time 1 DP is projected for year 2041 (after one additional half-life of remediation, and for year 2041.decay of Cs-137 and Sr-90). The FSSP does not mention that the DCGL values are for year 2041. As the Final Status Surveys for WMAs 1 and 2 will likely occutribefore year 2041, the cleanup goals for Cs-137 and Sr-90 should reflect the time of remediation, and if these units are not below 25 mrem/yr unrestricted release, this should be clearly stated, along with the tentative date that these units will be below 25 mrem/yr unrestricted release.7. Page 9/Second Although the paragraph acknowledges the potential need for Identify the need for RCRA samples, and plan accordingly for bullet/Chemical chemical analyses of soil samples collected as part of the Phase sampling and analyses in the FSSP. If RCRA sampling will be Contamination 1 FSSP, it states that it is "not directly within the scope of the covered by a separate SAP, identify when that SAP will be Phase 1 FSSP." If RCRA sampling will be required and it is available for review. Also, provide a crosswalk between the anticipated that FSSP samples will be used, either the CSAP or CSAP and FSSP with a separate RCRA SAP. There should be the FSSP should incorporate sampling plans so that holding little separation in time between completion of the CSAP and times and/or other RCRA-parameter specific reqiuirements will preparation of a RCRA SAP as the field work should be done be met. concurrently according to approved plans by the requisite regulatory agencies.8. Page 10/First The sentence states: "If the CSAP data results indicate only a Identify all of the decision criteria in the FSSP for assessing bullet/Last sentence subset of the ROI are pertinent for specific areas, then the CSAP sample results used to determine the appropriate ROI FSSP sample analyses for those individual areas may be list.limited to the smaller set of relevant ROI." The criteria for reducing the ntimber of radionuclides should also include location historical knowledge and-inventory records.9. Page 14/Section 3.4 The defined boundaries of this study indicate that the soil Add language in this section regarding future sampling of the laydown areas will undergo Phase 1 FSS data collection to soil laydown areas during the Phase 2 decommissioning document their contamination status regardless of whether activities.

subsurface soil contamination is known to be present. This data collection will only focus on the upper one meter of soil for the area. How will this data be incorporated into future biased sampling efforts that will be completed during Phase 2 decommissioning activities?

2 of 4 U on..Cmttent (If. Yordmeti~kpqf, e.1 ~~men~1s,,aont cf clrfcainjrbb doesn'tne Pagde/SectioniNo.>

!K.10. Page 22/Section 4.3 Targeted areas for biased sampling should also include areas Include contamination areas identified during the CSAP data with elevated contamination identified during the CSAP data collection as targeted areas in which biased sampling will be collection activities.

performed.

11. Pages 27-28/Section As stated in the last paragraph on Page 27, "As a point of Perform additional subsurface soil sampling in WMAs 1 and 2 4.7/Line 1 comparison, there are limited data available for subsurface soil during the CSAP to increase the relative shift for these areas.samples collected from the Lavery till interface." Given the limited data available for WMAs 1 and 2, additional data should be collected to increase the relative shift for these areas.12. Page 43/Section This section describes daily quality checks for detectors Identify GWS instrumentation limitations associated with 5.4/Gamma capable of detecting low energy gamma-emitting radionuclides contamination at discrete depth intervals.

Surveying Protocols such as Am-241. The Quality Control (QC) protocol will be used for CSAP and FSSP GWSs. While the protocol described are appropriate, an additional measurement from the"calibration" location should be taken to determine the detector's efficiency for detecting ROI source term at depth (i.e., if contamination is 2 or 5 cm below grade, will the detector identify the ROi?), to fully understand the limitations of the GWS data.13. Page 43/Section As defined in the DP, CSAP and FSSP, surface soils are soils Identify the limitations associated with using GWS data for 5.4/Gamma to a depth of orie meter. As such, it is unclear how the decisions concerning what ROI to sample for or for identifying Surveying Protocols proposed field screening methods (e.g., gamma survey using localized hot spots within a unit.FIDLER and/or Nal detectors) could identify most of the 18 ROI if they are, covered with even a few cm of soil.Consequently, unless surrogate isotopes are present in the upper 5 cm of soil that have gamma or x-ray energies well above the Compton edge (e.g., Cs-137), as documented during the off-site Cesium prong investigation (Dames -and Moore, 1995), most of the ROI would not be identifiable-at depths exceeding a few centimeters.

How will this factor be incorporated into the CSAP or FSSP planning for interpreting GWS data results? __,_ _14. Page 44/Section 5.4/ The QC Check for each detector consists of stationary readings Amend this section to include language regarding detector bias.Gamma Surveying at the start and end of each day the detector is in use. The Protocols detector is determined to be "out of control" if. the detector result exceeds plus or minus two standard deviations.

If an"out of control" measurement is obtained, the measurement is 3 of4

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-0 .(f your comment is,.a poihtofc1arificaini rbal os' need a ptdpqse,&ýso~iutiori:Y)K repeated.

If the results are still outside plus or minus two standard deviations, additional investigation is required.

How is detector bias tracked? Specifically, if a detector consistently reports low values for a historical location, how is. this bias addressed?

15. Page 46/Section This section identifies the radiological quality control (RQC) Identify other data sources and incorporate the requirement that 5.6.1/Contractor program requirements for the FSSP. However, since the CSAP these sources will meet equivalent QA/QC requirements as Quality Assurance data will be an intrinsic part of the information used and detailed in the FSSP.Program, assessed during the FSSP, this section should describe how the CSAP data will comply with equivalent QA/QC requirements.

16. Page 58/Table It is assumed that the table identifies what might be expected Note the geometry configuration used to determine detector 5/Estimated MDCs for the detectors if contamination, is in a specified geometry MDCs for various ROI and the limitations of the GWS data for of ROI in Soil (lm x lm, depth thickness 0.5 to 2 cm) as noted in unit decisions.

MARSSIMS Appendix H. MARSSIMS also notes that contaminated soil depths greater than a few centimeters result in an increased scan MDC because the increase in contamination depth does little to increase detectability of these low energy photons. To better evaluate detector results, it will be necessary to determine how much of an ROI in a specific geometry (i.e., depth and areal extent) is needed to produce a specific count rate. Since the FSSP defines surface soils as soils to a depth of one meter, in the absence of near surface contamination, it is highly unlikely that GWS data can*be used to identify Cleanup Goal exceedances or even elevated subsurface

(> 2 cm in depth) locations.

References

1) Dames and Moore, Western New York Nuclear Service Center Off-Site Radiation Investigation, December 1, 1995.4 of 4