ML092570233
| ML092570233 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project, P00M-032 |
| Issue date: | 09/03/2009 |
| From: | Dassatti E State of NY, Dept of the Environment |
| To: | Bohan C NRC/FSME/DWMEP, US Dept of Energy, West Valley Demonstration Project |
| Glenn C, FSME/DWMEP, 415-6722 | |
| References | |
| Download: ML092570233 (49) | |
Text
New York State Department of Environmental Conservation Division of Solid & Hazardous Materials Office of the Director, 9 th Floor 625 Broadway, Albany, NY 12233-7250 Phone: (518) 402-8651
- Fax: (518) 402-9024 N Website: www.dec.nv.,qov Alexander B. Grannis Commissioner SEP - 3 2009 Ms. Catherine Bohan EIS Document Manager West Valley Demonstration Project U.S. Department of Energy P.O. Box 2368 Germantown, MD 20874
Dear Ms. Bohan:
Re: Revised Draft Environmental Impact Statement for Decommissioning and/or Long-Term Stewardship at the West Valley Demonstration Project and Western New York Nuclear Service Center, ,dated December 5, 2008 This letter responds to the U.S. Department of Energy's (DOE) and the New York State Energy Research and Development Authority's (NYSERDA) request for comments on the referenced Draft Environmental Impact Statement (DEIS). The enclosed comments are the work product of the New York State Department of Environmental Conservation's (Department) West Valley assigned and non-WestValley assigned staff.; A considerable amount of Department staff time was devoted to the evaluation of this DEIS because we recognize the importance and critical nature of proper disposition of both the West Valley Demonstration Project (WVDP) and the Western New York Nuclear Service Center (WNYNSC).
In addition to -our review responsibilities as a Cooperating Agency under the National Environmental Policy Act (NEPA), and as an Involved Agency under the State Environmental :Quality Review Act (SEQR), part of the basis for Department staff's evaluation was to ascertain the DEIS's utility as a support document for the Department's permitting and corrective action activities that are associated with the disposition of the WVDP and the WNYNSC. The Department's permitting activities need to be supported by a DEIS that has been prepared ih accordance with the provisions of 6 NYCRR Part 617, SEQR.
As a result of the Department's evaluation of the 2008 DEIS, we are compelled to address a few issues which are characterized as all encompassing matters that we consider most significant.
These issues follow:
- 1. The DEIS should explain that one ideal of the Phased Decisionmaking Alternative is to work expeditiously to a final decommissioning decision, with every effort to minimize work stoppages or loss of workforce and/or funding.
- 2. The discussion ofthe ongoing assessments in Phase 1 needs to be more fully developed. At a minimum, the general anticipated focus on topics such as reducing uncertainty in erosion modeling; additional characterization of contamination levels and areas; performing regular reviews of current advancements in decommissioning procedures and processes; reviewing disposal options for currently orphaned wastes; and refining transportation dose estimates if new shipment containers, regulations, or techniques become available should be explained.
The fact that this is an iterative process taking place concurrent to the Phase -1 decommissioning work needs to be clarified. Examples include, but are not limited to, the
Ms. Catherine Bohan 2.
need to revise groundwater and erosion models to reflect actual conditions (e.g., installation of groundwater flow barriers, treatment walls, etc.) versus the use of general assumptions made during development of the DEIS; strategies for monitoring and mitigating erosion; reviewing advances in exhumation technologies (both on and offsite).
- 3. The DEIS should provide a clearer explanation of the public participation process that will be used in determining the ongoing assessment and decision making for Phase 2. DOE and NYSERDA should explore the possibility of enhanced public participation above and beyond what regulations require during Phase ,1in order to more fully inform the public and allow their opinion to be heard.
- 4. It should be stated in unequivocal language that any waste that may'have to be stored on-site due to a current lack of disposal pathway will be removed from the site once disposal options become available.
- 5. Given the decision by the DOE to nolonger consider Yucca Mountain as the likely federal V: High-Level Waste Repository, the, implications for possible long-term on-site storage of the vitrified High-Level Waste glass logs should be clearly spelled out. A similar explanation of the implications for the lack of disposal options for the Greater Than Class C and Non-Defense Transuranic (TRU) waste should be clearly detailed.
The Department expects this EIS process will result in a final approach to site remediation that is in the best interests of the public and environment of the State of New York. We anticipate that the enclosed comments will assist DOE and NYSERDA in-developing an informative and comprehensive final environmental impact statement that will satisfy the requirements of both'NEPA and SEQR.
If you have any questions regarding these comments please contact Jessie Lynch, of our Bureau of Hazardous Waste and Radiation Management, at (518) 402-8579.
Sinc y, Edin Yatti E Director Division of Solid and Hazardous Materials Enclosures Enclosure I - NYSDEC West Valley Assigned Staff DEIS Comments Enclosure 2 - NYSDEC Non West Valley Assigned Staff DEIS Comments cc: B. Bower, USDOE P.JBembia, NYSERDA.
G. Baker, NYSDOH.
J. Reidy, USEPA Region 2 A. Park, USEPA Region 2 P. Giardina, USEPA Region 2 K., McConrell,, NRC
Enclosure 1 NYSDEC West Valley Assigned Staff Comments on the Revised Draft EnvironmentalImpact Statementfor Decommissioning and/orLong-TeermStewardship at the West Valley DemonstrationProjectand Western New York.Nuclear Service-Center.
NOTE: For any Chapters/Appendices not specifically included below, the Department has no comments.
Chapter/Appendix: General comments
ý Mb-- Comet-
- 1. ,General Since the"DEIS was issued in December 2008 there have been many'changes that effect numerous portions of the DEIS.
, - *These Changes range from-political (e .g-; change: inadministration), to. economic (eg,, recession, American Recovery and
-ReinvestmentAct) totechnical (e g., recentierosion 6veiitsý,-new.'erosion studies, changes in waste disposition pathways).
It is expected that the DEIS will be updated in all applicable sections to reflect-these changes and that a discussion of these changes will be included.
2 General, Recent-events which-no lnger-make Yucca-Mountain-a disposal pathway for High-Level Waste shouldbe-addressed
.within the DEIS. The DEIS should be updated to include any changes thismay cause including butnot limited to cost of
-, - ,each alternative, dose to public,- and:changes in ongoing. monitoring. -.
-. e At A minimum,,a statement recognizing-the fact that the canisters would have to remain on the site for an indefinite period of time should be placed in theDEIS. -
3 General Recent Core Team interactions have discussed a myriad of changes that are being made to the DEIS. To the extent
' - possibile,-DOE afidfNYSERDAshIouldii*ke every effort to addfess*all as'pects of the DEIS that have changed (e.g.,
-erosion events, modeling, -Yucca Mouintain)since-the start of the Public Comment Period in December2008.
4 General " - Apparently as a i-esul* fimerous u auth6rs fop'arious ipons of the documnt, several different variati6ns of
- descriptive phrases for the different "areas" of the site are used interchangeably, which. can lead to-confusion to the
... - reader..
. "Descriptions of the various parts of the site, WNYNSC, Retained-Premises, SDA,,Project Premises, etc should be provided in Chapter land thenused con-sistently throughout'the document.--
5 - ..- General Update references' within~the text to the "Permeable Reactive Barrier-' or "PRB" as DOE has determined. that this will-not
__________..__ -,be installed. - - - -. - - * "
6 General Within "A Summaryand Guide for Stakeholders", the first paragraph-under "Abstract" on the Cover Sheet lists the site as
_________ _____-__...... 66.4-hectare (164-acre) andbullet oA;e.of the "Birief IHstory of the Site" textboxon: Page 1 lists the site as 81-hectare Page ! of,16
P.
Enclosure 1 - NYSDEC West Valley'Aissigned Staff DEIS Comments (200-acre). Additionally, DOE has recently transfiife cof0tl of certiin property back to NYSERDA for the purpose of establishing a b'uffe'r zone arud ýt-he SDA. Th&chahn gein size 0f the'WVDP and Retained Premises should be addressed.
- Please update the documenftb reflect the chang6 in acreage and teconcile the hectare (acreage) differences which are found throughout the document.
Chapter/Appendix: A Summary and Guide for Stakeholders Comment Number Page NUmber . - ...
Comment .. - -
7 A Summary The seventh bullet of the "Brief History of the Site" text box state that DOE was directed to"Dispose of low-levelol '*V and Guide for,. radioactive waste andtrdnsuranic waste that is produced in the process of solidifying high-level'rIadioacfive waste.:H-ow Stakeholders; - is this accomplished if the DOE-even remotely'considers the Sitewide Close-In-Place Alternative. ,For example, the-Page 1;. Chapter zeolite within-the columns of~the&Supematant Treatment System is low-level radioactive waste produced during the 2 and Appendix process of solidifying the HLW. To close. the columns in place'appears to be a direct violation of the West Valley Demonstration Project Act. - . -
- Please clearly define how the Sitewide Close-In-Place Alternative is compliant 'withthe directive inherent in the Act 8.,.,,:- .-A Summary The eighth bullet ofthe "Brief History of the Site" text box state that DOE was directed'to "Decontaminate. ..the and Guide for facilities...and the materials and-hardware used in conjunction with the project.". -Again, how is this accomplished if the Stakeholders, DOE even remotely considers the Sitewide-Close-In-Place Alternativei. For example, the four HLW tanks as well as the Page 1; Chapter zeolite and the columns -ofthe Supernatant Treatment System are all materials and hardware used in conjunction with the 2 and Appendix project. To close the tanks and columns in place appears to be a direct violation of the West Valley Demonstration
.C Project Act... *
- Please clearly define how the Sitewide Close-In-Place. Altemative~is compliant with'the directive inherent in the Act 9 Page 2, Under-thesecond full paragraph, this DEIS is also beingusedto0meet the DOE's obligations for a DEIS as required by
- - theNewYdfk Stde-Deep eoffEnvironmentalCrinser-ation (N.SDEC), for DOE's Part 373/RCRA Permit
~Pag ~ ~~~~~~'
10~ Unerth 46 ourhprgahi WhtDcsos 10 Page 6 Under the fourth paragraph in "What Decisions Will Be Made?", DOE fails to specifically. mention that they will
-consider all appljcableýState and Fed eral laws and regulatiqns along withmission, policy, cost, and public input. To relegate these to, other relevant factors"-wouldbe dismissiveof the!importance of State'and Federal laws and regulations.
,11 Page,9, fourth..... TheNYSDEC's intentionbehindthe use ofthe tank drying;system. at the WasteTank Farm was to drythe residuals bullet already in the tank, not to add wastes from other areas and dry those in place. According to the text of the DEIS, this was
.... ....... ...... DOE's only intent" aswell........ .. . . ,
HowevperOE m iiedt include where thesetentions h changed and its desire to add liquids anks i ae g-NSEa o ot c - oua may d fdesirertoaddliquids to the tanks for
-iný:placL' dryinig. NYSDEC has not reached -alfits conclusions on what may be transfen-e into the Waste Tank Farm.
Page1-6f46 -
4 Enclosure 1- NYSDEC West.ValleyAssigned Staff DEIS Comments
'12 Page 13, Shaded Again, there'is a failuie to include all applicable-State andFederal laws and~regulations along with mission, Text Box responsibility, environment, economi'c, and technical considerations. To relegate these to "other factors" would be, dsisv tempqrtance adFederal lawsýandd~ydgutionsi. . ,
13 , Table 4 The informatonunder "hasedDecision making Alternative (Ph-ase.1 Only)"appeaIrs to be inaccurate and/ormisleading.
+) +i/*thee
- ..*e*several since removal actio ting'place ude ,he Phas* 1 (i.e lagoostheMPPB, the source of the NPGP) the cost-effectiveness for,a Phase 2 remoVal or in-place closure decision
- time:and a Supplement to this EIS should be issued for any Phase2-decisions. should be evaluated on itsoWn
___________ _._ merits at that Chapter/Appendix: Chapter 1 men.Com 7 a-e.r "" - ." - " . " ""- .
Pa&-,NComment '
14 Page.l-1, Shaded This-box fails to mention SEQRA..The DEIS-itself states that the EIS-was scoped by NYSERDA and DOE in Box simultaneous notices on March 13, 2003., Since the notices were published in the Environmental Notice7Bulletin and the Federal Register, it.appears that the EIS was scoped under and is subject.to both NEPA and SEQRA for different aspects.
15 Page 1-1; Chapter 1 states that the:Project Premises is 164 acres while it-is listed as 200acres in the "Brief History of the Site" text" Section 1.1 box on Page 1.of the "Guide to Stakeholders"..
- Please review and clarify the acreage of the Project Premises.
16 Page 1-3, RCRA The last line of the second paragraph states that Corrective Measures Studies (CMSs) were.required for six WVDP Background. SWMUs and that NYSERDA was preparing a CMS for the SDA. The SDA SWMUs (referred to as the SDA)-are not a..
part of the WVDP. - . -
- Please reconcile the infoirmation-regarding thefiyeWVDJand one NYSERDA CMS -requiredpuriant to the Consent Order..
17 Page 1-3, RCRA .Updates.should be made to0the fifth-paragraph.- The;NYSDEC did send-a letter.to Mr.:Robert Warther, USDOE dated Background February 3, 2005. T..he letter+stated that the application was-deemed incomplete-and that an EIS, as.well as other items; was .required.- At the time, the NYSDEC intended -to commence its technical review. However, the NYSDEC's review of the, 2005 and 2008 PDEISs,,its participation in the.Core Team and the-on-going work at the site has taken precedence.
- A revised Part 373/RCRA permit application needs to be submitted-to update the facility information and changes.
DOE should.update the text-ftreflect the events followg submital of theapplidafion ii Decem er as wef as te
______________ July 2010 submittal date for the revised Part 373IRCRA application.,. ai ci in Dcme 04 a 18 Page 1-8, " Within the last sentence of first paragraph under "New York State DepartmentofEnvironmental Conservation",DOE Section 1.3 needs to address that the NYSDEC has responsibility with respect to any permits issued under Part 373/RCRA as well.
19.- 'Page 1-8, Within the second paragraph under "New York State Department'ofEnvironmentalConservation", DOEneeds to
'Section 1.3 , address that the 'WVDP is :also regulated by-NYSDEC for hazardous and mixed low-level radioactive waste pursuant to
'Page 3 of 16
Enclosure1 -oNYSDEC West*Vailey Assigned Staff DEIS Comments
..the Part ,D37dsries.
20 Page 11-8,' Wikbti "New Yrk State Depabrtenct f Enivironmenta! Conservation", DOE should "idudeinformnaiiion regarding the Section 1.3 - 3008(h) Consent Oider, as was included` inparagrdph two of"U.S. Enviro nmental Protection Agency".
- 21 a.. 1 , , *Wit*h "Regulatory Compliance Processes,,thýere- r twoconcerns . in e. fourth paragraph. One, NYSDEC has already section1.3 " required a supportiiig EIS for the W P Par 373VRCRA permit application in Februzay 2005 and is using this EIS to fulfill that rejyuiree: Seondly, .otingganalyed ýi the DEIs is ouside' "he scope.of the Part 373/RCRA permit application" since NYSERDA owns the entire site and-it is the NYSDEC's-deteriniation as to what-regulatory vehicles and how many are used to ensure compliance with the Part 373/RCRA regulations by both the WVDP and WNYNSC sites.
22 Page 1-10 Suggest that footnote be revised to read: "SEQR specifies that the assessment of environmental impacts shbuld include
.. the growth inducing aspects of a proposed action."- Saying that SEQR specifies that the assessment should be focused on
-___________ growth inducement is not correct.
..23 .. Page 1-10,_ An the. first full paragraph of Section 1.3.onthis page and in the second paragraph of Section 1.5- D"OE:should be-ad'vied Section 1.3.and, that EPA may at any time exercise their right, toperform aRCRA review.of the DEIS.: with or without NYSDEC.
- . Section :1.5. Additionally, NYSDEC may,--at any time,request their assistance with-either-the DEIS or any other reviews/needs for
- ""-.. either of the sites.i:- --- - -- - . . '
2.-. . . .- 2-/ i..
Chapter/Appendix: Chapter 2 -. - -. "_...' " . ' " "- .". <.
Number.Page Nu.mber , . - Cmment O -
- 24 General -While the docu enthas made tremendous changes to inlude nthenecessaty hazardouswastePart373/RCRAinformation
-and regulations, there are .still areas that are.lacking. These include but are not limited .to: failure to include whether. or inot-there'is hazardous wasie/constituients contamination in-all of the facilities/unitslistedunder each of thleWMA
'descriptions;. failure to include inthe description's When4a-unit is-subjectftoRCRAcbosuire or CA regulation (e.g., where
- .. .CMSs are required, NDA "decommissioning" isalso', ubject to CA-requirements); failure to include in their descriptions that each of,the alternatives:(e.g;, Clo*e-in-place; Phased Decisionmalking) are als6o subject to Part 373/RCRA when 2actions are.taken., ..
-eThibullet .ismisleading asit portrays Phase 1 as lasting only58 years.: Itshould bestated that Phase 1 will continue until "Section2.1,.....Phase,2.,isimplemented whichcantake up.to .30years . .... : , - .
26 .Page 2-1.4 -,Thelalternatives sectiondoes aigood job of-describing the reasonable alternatives included in the document and provides
.- . asufficient level'ofdetail to permit a compatative assessment by the'eader ofthealternatives under consideration.
- Page 4 of'16
Enclosure 1 - NYSDEC West Valley Assigned Staff DEIS Comments 27 Page 2-2 -1 Waste Classifications Used in the DEIS: A comprehensive description of "Defense Waste" and ."Non-Defense Waste",
"Defense Determination", and the implcations for site waste disposal options should be included in the text box on page 2-2, and a brief description included in the Glossary', for clarification.
28- Page2-5, The~bullet-at the-bottom of the page only makes reference to Solid Waste Management Units (SWMUs) not to Interim Section 2.3.1 Status Units. Also the reference to "RCRA Closure" could be misconstrued. The NYSDEC understands that you are
- rfenring to all unit closures and. corrective actions when using thisterm but within the RCRA-regulated.community "RCRA Closure" is specific to the requirement to implement approved closure plans for any Interim Status*or permitted
-,______ ______ operating units.
29 Page 2-5, Description of WMA 11 does not include scrap metal landfill' Section 2.3 30 Page 2-7,.- Figure shows WMA 12 as-reservoirs but does-not reference "thebalance of the site" including roads and parking lots.
Figure 2-3 0 Figure should be modified to reflect extentof WMA12 . -
31 P;age 2-8, This figure nieeds to be'updated. The Inienim Waste Storage Facility :foundation in WMA-7 has been removed, it is Figure2-4 aimostimpossible to seeLagoon 1in WMA 2 (uess'you kn1:ioW whereto look), adithe DOE has recently determined
.- "" that no Permeable Reactive Barrier will be placed ih WMA4..
32 Page 2-9, These figures show the extent of Northi Plateau Groundwater;Plume but no date is given for reference.
Figure 2-5 33 Page 2-10, . The-information-for WMA-1. lists that the Contact Size-Reduction Facility.(including the Master Slave Manipulator Table 2-1 and Repair Shop) as.being demolished to grade with the foundations/slab/pads remaining with the RCRA status being Page 2-16, "RCRA Interim-Status-Unit; subject-to RCRAClosure'..'. *While the status is correct, NYSDEC understood that this IS Section 2.3.2.1, unit was not going to be clean closed until the MPPB was removed..
Paragraph two *-Please provide -clarification of DOE's intent for this unit.. ,Should this listing actually be in Table 2-2? Any changes
_______ -included herein should also be included in Chapter 4 and Appendix . as may-be necessary.
34 Page 2-10, The information forWMA-5 lists the Waste Packaging Areawith °the RCRA status being "Clean-closed under.RCRA Table 2-1 Interim Status".
. is this unitlpart of Lag Storage-Addition#4? Please clarify this in the table. -
S" Page The iformatin provided i FoOtnote "a"'s incorrect. The Old Sewage Treatment Plant was not an Interim Status unit Table 2-1 and was not "RCRA clean-closed". It is a SWMU that based on-the RIFI was determined to have "no-further action".
- ,Please correct this&iraccuracy.-
36 Page 2-11, The liquids from Tank 8D-2 would be process to remoiVe Cesium-137, uiiost.of dhe other radionuclides Woilld remain in Section 2.3.1, the-liquids. Even after evaporationthese radionuclides Wbuldbcoritinue-to pose hazard to the environment..'"
Bullet 3..*. -
37 *Page2-11, The third bullet on this page refers totreated-Tank 8D-4 liquids being 6vapoated6 in-Tank 8D-2. NYSDEC understands Section 2.3.1 that recent DOE changes to Liquid Waste:Management have theseliquids-being solidified and sentoff-site for i sposal.
Page 5 of 16O, .....
Enclosure-1 .-'NYSDEC West Valley Aisigned Staff DEIS Comments.
'Additionally, DOE has:discussed transferring other liquids into Tank 8D-2 for evaporation. While Tank 8D-2 does have
- tanktreaitment status under thePart 'A application, it doeS not currentlyhave status' as an evaporator. While the NYSDEC anticipates that eyaporation will be, used to dry tank heels, the addition: of treated liquads to, the tank for. evaporation is st ll under discussion and review by-NYSDEC and the CoreTeam. These discussions need to be completed priorto0 this action.'.
38 ; Page 2-12, ,-Thefirst bullet bnthis page refers to the&"Permdable Reactive'Barri6r" that the DOEhas recently determined will not be Section 23.1 "implemented. . ..-
. Please updatej the text to include this change and add any information consistent wit;any future plans theDOEmay..
have for this area.
39 Page 2-12,. The NYSDEC has thefollowing comments on this table Table 2-2 - - WMA-1, -PlantOffice;Building -With-what chemical(s) was the subsurface soil contaminated?
- WMA Please include information on any hazardous.chemical contamination..
W . ," 3,T*i 81-3 18D-4'-
-- Please clafy the EIS. starting point...The tanks currently have residual heels and DOE has expressed a desire to add liquid to thetanks for evaporation., How.would this be considered-"emptied" if additionally wastes are added?. Especially since the~evaporative process would not be complete by 2011. See also Page 2-20; Section 2-3.213, Paragraph two.-
... WMA-3, Supernatant'Treatnienf System - Please include iformatiion regarding the hazardous cherijical contamination............__............ ...
,:- -,WMA-4,CDDL - Please include information regarding the hazardous chemical 6ontamination.
- '-WMA-5. Please-include infornmation regarding the hazardous' chemical contamination.
....., .- . . WMA-6,-.]The:Equalization Basin and Tank and'the Sewage Treartment-Plant'are subject to correctiVe action in-addition to the CWA...........
-k,,-WMA-8, MixedoWaste Storage Facility. - Under-the Mixed: Waste. Conditional Exemption regulation'(6 NYCRR Part 374-1.9), -this unit is no longer. subject to Interim Status closure. Even so, NYSERDA has expressed their desire to
.closetis uni't .under the RCRAInterim. Status .requirements.. Pending further, determination, the unit should be listed as a SWMI-"..-
- "North Plateau Groundwater Plume - While the NYSDEC~has not required action on the NPGP, it should not be construed-that the NYSDEC'believes that the unit is not subject to regulation. W& are currently in the processof o -
reyiewing the results of the NPGP RCRA Characterization.
40 Page 2-12, Rail Spur is listed in Table. 2-2 operable and contaminated in AfWMA6.but Inactive and not contaminated in WMA 12.
Table 2-2: ... " This discrepancy'should be -addressed..-
41 Page.2-22. . Thelast line oftthe third paragraph statesthat th6.Remote-Handled Waste Facility is "permituted as a mixed low-level Section 2.3.2.5 radioactive waste treatment and storage containment, building". This unit is not permitted but has Interim Status.
- Please revise the text accordingly.
.. 42 - Page224, The third paragraph should contain. information regarding the NDA cap afidi slurry wall that were placed at the NDA as an
- Section'2.3.2.7 Interim Measure under the 3008(h) Consent Order, , : -
Page 6 of6 -6 "
Enclosure 1--.NYSDEC-West Valley' Assigned Staff DEIS Comments,,.
43 P~age 2-27, W.~: Management Area :The decision by NYSERDAeto exhume the Scrap MaterialLandfL Waste should be
.Section 2.3.2.11 incorporated.
44 Page 2-29,: The 'Decommissioning:Activities" subsections for. each alternative should include that for any regulated unit (be it-an Section-2.4 operating unit-ora SVW all:.decommissioning actions are subject to: State and Federal7RCRA regulatiolis. The
!NYSDEC-RCRA staff-understands the usage of "decommissioning' to encompass -any act of closure or corrective action as this DEIS4is also being~used in support of the WVDP's Part-373/RCRA PermitfApplication. If this is not the case the
" ?i
- 1)*. ,-.-:.
- .2-,entire DEIS8willneedtobe re tqvise di iguish betweeni-tese twoaction6 rKeerp to s d that NYSDEC ca at any.
time~request EPA assistance with any RCqRaspect of the site, theýeby possiblyrequiring a NEPA EIS for RCRA 45 Figures 2-6, 2-7, All of these fail to include "Annual Environmental-Monitoring"7 as an activity-of the alternative for its duration or in 2-8 and 2-9 perpetuity~as maybe required.,-This may or may-not be,,in addition to ",Long-TermMonitoring and Maintenance" 46 Page 2-37, .- Under thefirst bullet,-DOE fails to include that the NDA~specifically-dUe to its SWN status, and. in actuality the site'as Section 24.42.1 a whole, are subject to-the current3008(h) Consent Order andfutiirePat.373/RCRA permitting and regulation by the NYSDEC. Again, the NYSDEC RCRA-staff.understands'thezusage-o0f; "decommissioning" to encompass any act of clsure or corrective. action as ti DI isbin u;&sed inm support of ,ther.D,! Part 3/CAPriApicin.I.
this is not the case tenirDEIwilnetobresd to distinguish between these two actions. Keep. in mind that NY"SDEC can at* anytime-request EPA assistance withany RCRA4aspect of the site,:thereby possiblyTreqng a NEPA
. , ...... EIS for RCRA actions. Similar situations occur within'Sections2.4:-;, 2.4.3.14and2.4:4.l,'-
e Please review each of these sections carefully and revise the text of said sections accordingly.
47 Page 2-44 The narrative for WMA-7 and WMA -8 refer to a "30-year ongoing assessment period", while there is mention. of.
ongoing studies and analysis of data gathered during decommissioning activities there is no list of specific studies or
.assessments that Would be conducted during this time'period or how this-informationf would be used:.
48 Page 2-45, The first bullet under "Evaluations to Determine the Phase 2 Approach" should include residual hazardous Section 2 .4.3-1 .o.ttCmi*ationas we!l as the radia~ctilYYiti' , :
49 Page 2-45, Within the second paragraphunder "-Evaluations to Determine- the Phase,2 Approach", the intention of this alternative Section 2.4.3.1 is to have evaluationsat intervals no greater than-.5, years longnot at.',approximately5-year intervals". Additionally, NYSDEC reiterates its inten to include annuara§se~snmdftts for-new tecnlgeswti the Part'373' permts fot'the. sites."
50 This figure should include a line for,"DA Geomembrane -Replace
.TPage.-47, -ent;,
Additionally -theAnnual Environmental Fie2-8 Moniitorn.,hujdstarta Year Zero.
51 Page :2-51, 'i Any releasejof land should includeNYSDEC since this action would be subj ct-to our approval and release-from the Part Section 2.6.1.1 A applications orthe Part 373 Permits.
S52 Page 2-57,,-.....Under Footnote, 3it is an:understatement to say'that. the estimates are conservative.-: It is inconceivable that DOE would Section 2.6.1.5 ship only one railcar with; wasteper train. The use ofthis assumption gives theappearance ssmtingie h hi pperne of being disingenuous and an attempt to skew the transportation impacts presented in Table 2-3 to make sitewide removal appear impossible due to the
... ......__...._"_........ .... dAger s associated with transportation. For thd majorty of thewaste.*ii-site 'this sce*a6i ueasonable. NYSDEC Page7ofI6
Enclosure 1:"- NYSDEC-,West-Valley -Assigned-StaffDEIS Comments:- ::'
. .wo.ld.. oudanticipate that most waste (e.g:.,contaminated soils) wotuldhave several railcarsper train.
- Please provide a clear explanation-of DOE's intention for waste shipments.,7 -"
53 Page 2460,. " ColumnThree- entitled "Phased Decisionmaking Alternative (Phase 1 ýOnly)", is supposed to contain the discounted cost
-Table 2-5 per: avoided person-rem for.Phase41 of the alternative. -The Sitewide Alternatives aready give the b6unding cost numbers, that information doesnotz need to be reiterated. .In order to: trulyý comipare cost, the discounted cost information
..... - . .forthe1bounding.alteratives to Phate his information should be calculated and presentedherein 54* ..... :Page2-60, :Biasedýon the NYSDEC-coment above-regarding the dimingenuousness of the traportation impacts in section 2.6.1.5,
-Section 2.6.4 thefirst bullet shlioud be re-tevaluated: Additionally, if the Latent Cancer Fitality (LCF) is less than one person for each alternative it appears.that each alternative should have a maximum LCF of one person (rounding to the nearest whole.-:"
.:,,J: number)'. making them esse-ntially.the same..-...
provide aclearexplanation of why the numbers are not rounded, to reflect a;"whole" person..,
5:5, Page 2-60,: ;.Thetekt of4the~third bullet regarding the :total impacts of Phasef2,Sitewide Close-In-Place, is confusing, Since certain "Section 2.6.4;: -.-facilities and'eontamination Would' be removed Lnder Phase-, 1, wouldn't the total impacts of Phase'2 Close-Ini-Place be
-, : esst-han;,:.but hburided .by, the Sitewide Close-in-Place:Alt6erative:
"56"i: !Page2-61, The"narr~ativetesthat"PhasT I of the Phased Decsioi Md gAlternhiti've al0646f .-up to 30 years for collection and Sedcti6n2.7;- - analysis DEIS doesnot inclde aný:discu*Sion sf"datiandinformhfibni?:";-howeverthe on what specific studies will be
_________- Bullet 3 '-perfrmed nor dbesiad&es oth6w the decisiin to:proceed with Phase2 will be made.
owhen Chapter/Appendlix::Capter 3 -
-Comment --
Number :-Page Numnber -~>'Co mmen t ~. ..
57 General . There-are~several areas within.this.chapter-where thedocUmeýtation referred ob is anywhere frfin three- Afs- to 20, or-even...30years-old.
. Mostofthe-cited referfedneinformationiiappears to ýbefive to ten-3years old.
S-Piease Use-th ifmot current d~e entation for review`-f:and input-to all impacts.
58 Page3-7, .The secontdýparagrapli discuisses :theNDA heig.-: b a "initaied, grassed area'"then mentions -installation of the NDAcap
, Section.3 1:'2 in 2008 This could-be misconsfrueddthat the:ca'p'isuder a-grassy area.:Thi information should be uidaedi.
59 .. Page.3-8,. It is uncertain why the references for National Grid an Nigara Mohawk, rinthefits`tsnence, are-reversed. If DOE-was
- .Section 3.2"1: . --going to pr-ovide the most current, inf0 ationia-tiwould haVermad eoreýsense t&,tate -that National Gridvwas formerly
___________Niagara Mohawk.- -
S60- Page 3-31:'- LNarrative states that anoffsite study-has been condutedbitf is unclear hth"r thtudywas outsidetiWDP orthe Cesium
-.. , Prong;: WNY,
- SC. .:A*better descripion of the location of the studysshould be provided - - - -
. . .sPage325,- was-cedulei-.f. 2007- -Was-thi s*l*lmgcmiote 61' Page 3-5 1 Th ls ntcetaes thsmlnoa ceue o 07 a hssml ng c~peed.
p and if-so why.wasin't the-Page 8-ofl16.--.,
Enclosure 1-- NYSDEC West ValleyAssigned Staff DEIS Comments:;,:
Section 3.6.1.1,.: dataincuded?,
Paragraph 1 62 ,Page 3-53,. Tablepresents surface waterexceeding of background but not DOE DCGs for samplepoints downstream of:Franks Table 3-.10.:. Creek. The narrative however describes .severall other4surface water sampling points which exceed both which are not
_______..... _ _,. *sdisplayedinm a tabular format. 'It-wopuldbe easier tojinterpret data if it is all displayed-in a similar format.
63 page 3-92, Please provide an explanation of the tatemet "avvailable inBfont6n4is insuffic.ient -fTora.meaningful estimate of
.Section3311.3 ~.-impacts" in,paragraph two.-,: -<'S.
- 64. "Page 3-93, - Teesecond full paragraph fails to mention these azardous che'mcals areproducts'not wastes. This is confusing for
- ... Section3..3,13 anyindividual wh is-fntfamiliar with these regltio"s versiusthePart373/RCRA regulations.
65 Page 3-96, Please specify which of these releases contamed haardous waste and/or constituents-and what chemicals were involved.
Sections.3.11.5.1.
- and3:1.6L.2.- .-.--
66-. Page 3-101, Please provide infrmtion-asto Whih ines arerefrredtoin,"UndergroundLines hatCrie High-.....
"speific
-Section 3.11..5.3" ActivtyLiquiid," whO thelinies wheredtinalled by andwwhen theywere installedd.,
__67 " Page 3-102, - In"Other UndergroundLines".the results ofgroundwater momtonng or subsurface soil samples shouldnot be used to SSectioSn 31HL5;:3- "assume:the4h Iegrty of undefground lines:.,These are fiot al iniclusivehand maymiss ýcontamination. ILin~s shouldbe.
-integr-itytest'ed oar~egular basis if they are'sometdoubl waolled, 'haifre somat 6pe'oflea detectionand/6f are not in a pipe trench with or without leak detection and/or chemical resistanf coatings.
- 68. *Page3-105,. - Please provide detailed information in-regards to the statement in-the last paragraph on this -page thtai H4Hzardous and mixed low-level radioactive wastes are...disposon site." -,.
Section 3.13.1
- 69 Page 3-105, -.... The first full paragraph of this page refers to the sdheduled decontamination, demolition and removal of-the CPC-WSA
- Section.3.113, .by 2010. Accoding-to discsiiionsregarding theclosurebofiterimn stat(usuntsat-the sie, the CPC-WSAwas not
, sdheduled tobe'dosed forfiveto-seven more years.
o Please provide a current stttisfoi the cl6ure~df the unit..
70, - ,Page 1,090, " -.-Whiii'it isuimde6rtood thatýwaste wouldbe generated during the Interim End Staitewhich would endrin-20i11 it is unclear
_____Table 3-20' 'wat wasteswould'be &genrated after this time period that would not-be covered by-the EIS.
Chapter/Appendix: Chapter 4.......................... ....... .. .- - . . :
Numbher' PageNumbe ' ' "'p Aq. ~ ~ . Comment-71 Page 4-4, - -For the Sitewide Close-In-Place Alternative; please provide the amount of ti enecessary for the decay of the Cesium, "
. ~ *4- ~ T l 1'able4- Prong Pr n andno'ource:area and*"-,
. of the NPGP. .", . .: '" : . "*" ' " ,* . .' - "!> ,.
Page9~of.16 -.
Enclosifre1 -*NYSDEC Westaliley'-Assigned Staff DEIS' Commentsý:
Additionally provide an estimate herein of when the 1,118 hectares of land Would be available for release foe unrestricted use. -
721-- *Page54---5,. -' ,-The! 'Vistial Resources" paragraph states that the Northand-South-Plateau'd aps Woudll'e rock covered. This could-
, Section
- 4.11,2-. inhibit:replacement/rep1r.of said caps. Has'cnsideration beenigiven t6-'itheibRCRAregklatio nsforrepair/repacemenof
.' geomembrane layers in caps at-certain-intervals* and havethese co'sts been included* in the long-term monitoring and
.. maintenanceq qosts frru.te*ost benefit comparison? .
73 Page 4-11, For more accurate cost comparisons of utility use, DOE should indiudd*b t.otal 1V&ofeach utilitypyear)0ff.
. ,Table4-3 ;,decommissioningas well as the to taluse. On an annual basis the utity uses for,thethree action alternatives are similar
.... . . with Sitewide Cose-i-Place, hang the highest utility use du iits action phase. Total Utility use for. eachutility after de4omissioiing should also beý Incuded. ýThe total for each utility afterdeomis -hisest fr.th
______ _Sitewde Close-kn-Place Alternative. " iin p.. " o 74 Page 4-15, Does this DEIS include the utility usage that would be necessary for replacement of the North and South Plateau caps? If
' 41ctio
. l222, not, DOE shdiuld.update .the EIS to ths information thlude to final issuance.,
75 Page 4-88, In addiiion'to themixed low-level radioactive waste referred-to on Page 549,,
haahaous wastes would also need to be 7 -Sefctioj14.1l.-:2 -..treated to meetyassqociated RCR land disposal restriction treatment stan.dardsprior to disposal.
_76,,, . 1Vage 4-90-to;9.14:, Please provide anex*planationf-forwhy the-su numbers for Packaged .Waste fromx Site Monitoring and Table4-45 ,nd .Maintenance orLong-Term Stewardship do. not.matchthe comparisob numbers~in table 4-47.
Page 4-94,
.Table-447. ...
77 Page 4-92 to 93, Pleaseprovidethe placement for footnote 'b"' - , . . '
~Table 446---
78 Page,4-99, it is inconceivable that DOE would ever. ship only0one railcar with-w.aie per train.; The use of this assumption appears Section 4.1.12 disingenuous.and as an attempt.to skew t transportation impacts presented herein to make sitewide removal appear
- .impossible due to the dagers associated wi-thtransportation.
.. -Page
,79 .4-1 1, - Co.lumn ree eeititled 'Phased'Decisionmaking Alter*ative I(laase 1 Only)- is supposed to contain .thediscounted cost Table 4-53 per avoided person-rem for.Phase: 1.of the alternative. The Sitewide Altematiyqs already give the bounding cost numbers, that informationrdoes not need to be reiterated. In order to truly coinpare cost;,the'information forthe bounding alternative to Phase 1, this information should be calculated and presented herein.
80 Page 4-115, Please revisit the placement of footnotes "a" and "b" as they do not appear to be accurate. -Additionally, pleaserprovide.
Table 4-54 the time period for the effective annual costs for monitoring and maintenance (M&M) or long-term stewardship. As
-Tables 4-55and 4-56-(footnrotes b and e and footnote b,.respectively) refer to 1000-year periods for dose and M&Mit would seem that 1000 years of M&M or long-term stewardship costs should be included. At the least, DPOEshould:
- include-the costs until '"riss6finstitutional controls" at.100 years. - . ... - ... , ..
81 Pe'4143,' If tiePhase 2 decisin is to perform sitewide removal" a~er Ut - yeas, wuld~that alternative thenbe considered Section 4.6.3.1 the longest active phase of the alternatives?
Page 10.0o.16,
Enclosure 1- NYSDEC West Valley Ass.igned Staff DEIS-Comments Also, pleaseprovide detailed justification for how restoring the land to its original state as opposed to placing a cap, and
_______"_____"__ possibly rocks, provides a greater impact to the wetlands.
'82 Page 4-143, DOE fails to mention that monitoring and maintenance would need to be performed -perpetuity following the "ghOrt 4.6.3.2 tem.. .of significant gSection onsite decomniisioning ivi Again, NYSDEC stresses that close in place is not a viable option without -avariance6 from the State and Federal RCRArdgilations.
-83 " Page4-144, . The second section of this paragraph is misleading and possibly,ihaccurate. Will it tdke the full eight years to construt
" Section 4.6.3.3 'the building and move the logs? How is that possible f the MPPBis to be removed within those eight years? Also the intent of the two phases is to allow for the studies to be performed almost from the beginning, not eight years later. DOE should-already be try*ng to determine-the types of studies necessary and their implementation so that this can happen as
' ..juickly as§-ossible aftefrthe issuanc6'of the Record of Decision.
Chapter/Appendix: Chapter 5 Numb~er -Page Nuimber . omment.-
84 Page 5-9, The last sentence under "Administraive Order On Consent (RCRA3008#h1)" should be revised to state that CMSs were S7ection 5.2 required.
Page 5-15, Within the description of 'Resource Conservation..Parts370 to 374,:376)" iould be mentioned that NYS has all Section 5.5 the rights and authorities of the Federal regulations for.which they are authorized and that NYS' regulations may be more
. - stringent than the federal regulations. Nowhere in this text does it mention that NYS has been given the lead for all
- °..'
- " ' " ' RCRA related activit.s atsthe site.- At a mimmUm, this section should include te same level Of detailas it* counterpart
___________.__ under Section5*2 *asprovided. . .
86 Page 5-20, Be advised that the NYSDEC is working on a replacement.do~cument foprTAGM-40Q46. All corrective action work will Table 5-1. have to meet the soil cleanup levels in this new documeiat. This information should be revised accordingly.
Chapter/Appendix: Chapter 8 I*ComzmentiCmet:~ .- j--- -
.ýNxrmber -~gNumber- )c t 87 Gýen -DOE may,want to consider prefacing this chapter to statetat the' defitions usled herem are not consistent with the
"____88__ Gener__Fr__y definions within theaPart 373/rrec rhegulations due to need toshD/Eimpacts and NOT 'compliance.
88 General For any definitiIon that. references the federal RCRA regu .lations,DOE should include the reference to the State Page 11- of 16
Enclosure 1 - NYSDEC-WestfValley AssignedStiffDEIS'Comments regulations that parallels said reference.
89 Page 8-3 'The definton of -haractenst icwaste" should include a reference to the state t. regulations (6 NYCRR 31.
371.3) that parallels
.(." -
Sthe reference to the federal regulatin*a ..
90 Pag 84Thedfniin rettin toeo~ld o a. anrd di~spoa filit'i are extreme y eercand do notapartreteo hazardous waste management und'er 'either.th&state 6r'fdral RCRA-program. Again, DOE could alleviate public and
..... regulator's concerns by prefacingthe d6iapter.as mentioned in the-geneiiar comment above. . . .
.91 Page85 -n the dmfinition of "anEISthe :itaiisto Envirojnainntl Conervation Law ae n6t correct. Theyfsh*uld read "Section 92 Page 8-6 "Hazardous constituent" is more than what is referred totund OSHA.I oatw ree~edtouner isyrec ommended that the word "aste" be added and that the defmhitionfor "hazardous waste constituent" found-under 6NYCRR 370-2(b)(87) be incorporated.
93 Page 8-6 Be advised that unlike the definition of "Hazardous waste" in the federal regulations, New York State regulates certain PCBs as hazardous wastes. .
94 Page 8-8 As regards DOE's definition of "interim status facility (under RCRA)".
. First, neiiher "hazardoiis waste management facility" nor "treatment, storage or disposal facility" are defined .
elsewhere.
. -* -Second; there needs -towbereferences to NYSregulations. " -
- ';*: =:":
."" -" * *Tbrd, thePart, Aotification allows a faciliiy to continue operation in'wicc6rdarice with Interim Status stai*dards under
... . . BOTH the RCRA and-the NYS regulations,. it is NOT considered.a permit.
L "" -, the Eastly, " faoiity must eitherelope arfadiit undertintdstatus-r stiow thatthey'lprotectively;:thly cannot just
---.withdfaw their -interim status. ,... - --. . . . . ....
95 Page 8-9 The definition of mixed low-level s shouldinclud reference`to: *Sregulations as well. Unlike the federal regulatons, New York State re~ilates certain PCBs as'hazardous wastes.
- 96 Page 8-10 The definition- of,"polychlorinated biphenyls" should notetliat cer PCBs'are hazardous waste'in NYS and"sholi.d reference the definiti` tiof haEzardous waste mi- CRR 3713.
- 97. Page 8:1i3 . The-definition of "solidwaste" should include reference to NYS regulations as welL 98 Page 8-14 The defmitions relating to "storage" and "storage facility" are extremely generic as relates to hazardous waste management under either the state or federal program.. Again, DOE could alleviate public and regulator con* by prefacing the chapter as mentioned in the general comment above. At a minimum, the word "mixed" should. be used in
---place of"radioactive". "Storage" is-specifically defined and -does not distinguish between greater than and less than 90:
days in NYS regulations. This distinction determines whether or not a facility needs a permit or interim status."
--99 Page8-14 - Suggest that the definition of State Environmental Quality Review Act be revised to read: "A law pr6mulgated ... that requires that alf tatenadIocal agencies determine whether the ctdi's they directly undertake, fund or approve may have a sigmficant impacton the'environent aid, if it is deter ied that-the action may hývea significant adverse impact,,
___ _ "_"_-._____ _," prepare or.reque the preparation an en.vironmental "mpact statement.!
- Page -12 of 1.6 -
Enclosure 1.- NYSDEC West Valley Assigned Staff DEIS Comments.
Chapter/Appendix: Appendix C Comm~entý R. J-ihr -m. . 4ýk~<~w- . -
100 General. While the document has made tremendous changes to include the iecessary hazardous waste Part 373/RCRA information and regulations,- there are still areas that are lacking: These include but are not limited to: failure'to include whether or not there is hazardous waste/constituents contamination in all of the facilities/units listed under each of the WMA descriptions; failure to include in the descriptions when a unit is subject to RCRA-closure or CA regulation (e.g., where CMSs are required, NDA "decommissioning" is also subject to CA requirements); failure to include in their descriptions that each of the alternatives (e.g., Close-in-place, Phased Decisionmaking) are also subject to Part 373/RCRA when actions are-taken;..failure to -provide chemical concentrations (in ppm or mg/kg) as opposed a total -inventory (in kg).
101 Page C-l, The secondparagraph-mentions that .the Contact-SizeReduction Facility (CSRF)will-have been removed to grade at the Section C.2,1 starting point of the EIS. Is this accurate? The NYSDEC understood that the CSRF was part of the Main Plant Process
. Building (MPPB)anditsCompretiensiVe.Closure Plan. It was.undrst6od that as such the.CSRF could'not be removed until such time as a Record of Decision (ROD) was issued for the DEIS.
. Please clarify th's misu*nderstanding and assure-that the DEIS containsacurateinformation.
102 Page C-14, The fourth sentence of the introductory paragraph states that Tanks- 8D-1 and-8D-2 will be dry at the "starting point" of
- Section C.2.3 the EIS. The "startingpoint" is expected tobe accomplished by20i1.
e Please explain how this is possible? The NYSDEC's understanding of this system is that once installed it would take a several years (approximately 3 or 4) to dry the residuals that already reside in'the tanks. This does not seemrpossible, since 1) the system will not be installed until early 2010 and 2) DOE has stated within the Liquid Waste Management Plan that they would like-to transfer additional liquids from the Main Plant Process Building into these tanks. Please .
address this situation within the references of this appendix as well as the other chapters or appendices that refertece the
_________ .- Tank Drying System. ..
- 1.03 Page.C-49, Relocation f the High-LevelRadioactive Waste canisters: If there is a defin espan to the commirercial dry cask Section C.3.1,1.L.1 storage systems under considerati6n, &l~DEIS shoul acknoWledge thisandldescribe how the casks wouldbe replaced,
$161ted"for appi6vaifo#0 continued use, etc. 'At present'iheraree no obviou plans in pl c6 to address this need, which has arisen since release of the DEI§.due to the withdrawal of YuccaMou i from6consideration for permanent disposal of-HLRW.
104 Page C-55, The fifth and sixth paragraphs under "Removal of Contaminate Soil and Groundwater" and the second paragraph Section C.3.1.1.8 under Section C.3.1.4.9 make reference to reuse of the soils if they are less than the DCGLs for unrestricted release.
and Page C-57, DOE would also have to demonstrate to NYSDEC that these soils do not contain hazardous waste/constituent Section C.3.1.1.9 contamination prior to reuse.
105 Page C-57, The first paragraph states "Confirmatory sampling for constituents of concern would be performed, and remedial actions Page 13 .of 16
Enclosure 1.. - NYSDEC WestValley Assigned Staff DEIS Comments:-
Section C.3.1.1.9 would be based on the results." This sentence fails to take into account whether these confirmatory samples are for Solid Waste Management Units or for InterimStatus Operating Units. The requirements for soil cleanup objectives (i.e.,
chemical concentrations remaining) vary depending on the tinit's status. DOE has failed to make this distinction clear for both the regulator and the public or to give it due justice.
106 Page C-79, Under the Mixed Waste Conditional Exemption regulation (6 NYCRR Part 374-1.9), the Mixed Waste Storage Facility is Section C.3.1.8.1 no.longer subject to Interim Status closure. Even so, NYSERDA has expressed their desire to0clos'e this.unit underthe.
,CAn*,.Iterim Status requirements. Pending further determination. the.unit:should ibe listed as a SWMU-;
107- -Page C-89, IV:While the NYSDEC has not required action-on the NPGP, it-should not be'construed that the NYSDEC believes that the Table'C-28 and.: unit is not subject to regulation.-We areacurrently inthe process of reviewing the regults of the NPGP RCRA Section . Characterization.,
C.3.1.13.2, 108 Page C-911 While DOE does menition that certain buildings w/till be removed tolgrade fo elimnat e maintenance cost, they fail to Section C*3.;2- .'metiaotn:that m6nit"ring aid maintehancewould nedt1bepeiformed-in perpetiity under a Part .373/RCRA Post-Closure Permit. Again, NYSDEC stresses that close~in place is not aviable option Withouta variance from theState and Federal RCRA regulations.,. ~-
109 'Page C-130, Interim Siorage'Facility: An updated-description-0f the DOE plan'to use Iurrently available commercially dry cask Section C.4. 1 stora-ge technology to store the vitnified logs on-site should be icluded. Thie fact that these systems are designed to
.. withst~id highforices-froiým eismic activity andwill bedeslgncd:to'wihstahdanti ipated atmospheric or erosional
________ ___.__________. impacts should be included. ..- ..- .
Chapter/Appendix: Appendix.E N 'Jm.er Page.Number - Comment 110 Page E-77, Historical Conditions and Phased Decisionmaking Alterfiative..-! The discussion of how theNDA facility is mbdel&l,
- Sedfion E.4.2.1. witthe int&im measures in 2008, isi' elear' a limited. eMoling for e ongoing assessment-period, should it occur, mtis take mito Account the existing capandslu .Wall how this is taken into acount, especially with the
___..... __ offered-recharge estimates, is no 'F~~er'dafi collectionandupdatin~og of the model should continue:
~,J
. . . '" . 2, -. :. ., ',r .. -I.' ., *, 7 ..
Page 14 of 16
Enclosure 1 - NYSDEC West Valley Assigned Staff DEIS Comments-Chapter/Appendix: Appendix F.
'COMmentý
~*-~-
Numbher-,- -,tPagei"uNbr ~.,-~:'.~ Mm 111 General In light-of thedvery-recent occurrences of erosional events, both-largeand small scale, in the vicinity of and at the site (Route 219 erosion/slumipingi ioi cattaraugus Creek, Erdman Bro"6k knidkp6int a"Fiank's Creek knickpoint advancement, respectively, Buttermilk Creek slide reactivation), how isthie niodeling of erosion at the site to be
.updatedlexla~dedupn,du~ringthe --ngoingassessment.peridd? It wiouldai pear~ie.real-time events of interest and:
consequence must be included, and a process in place, to allow for any performance assessment to be accurate; to allow for a decision to be made that is representative.
Focus for continued erosion monitoring should not be simply data necessary for model truthing and calibration, but how real-time events are affecting the facilities in question, and whether decision-making must include a long-term.model(for anything other than decom sioning performance assessment).
112 Page.F-'6, Suismmary of Site Ejosion Measurements "Observationofotergeomorplic processes, icluding meandering and*
Section F.2,-, knickpoint advance, y prvides perspectie but no additiona4l quanlitatiyeinformation for erosion ratqeestimates."
.-. .- " Please"clarify:this statement, esp-cially'in'light of recent (2009) erosional events'andob-servati0' (e e.g.Edan Brook "kiickptoin adancernent, Bdtte'rmir' Cr__ek slide reactivation). -
113 Page F-8, Figure North and South PlateauwGully Locations - These figures/tables need to be updatedto show reenftchangds in the.
F-5 and Page knickpoint location along Erdman Brook, relative to the V-to-U-shaped valley transition.
F-9, Table F- i 114 Page F-53, Calibration: Discussion and Interpretation - "It is also likely.that gully extension in this environint is limited by F.3.2.5 vegetation growth, which can effectively impose a large erosion threshold on-the landscape in hollows and-ephemeral channels." This statement needs further explanation/exploration, in light of rapid advancement of knickpoints in the vicinity of the SDA along Erdman Brook. These "small perturbations". are of,importance forunders t ac
. ..__________ .. -impacts to the site-inathe near-term.
Chapter/Appendix: AppendixJ ... ... , .. - V . . . ... .
Comment
-Number PaeNubrComme'nt' 115 General This appendix fails to provide any information regarding the risks of transporting non-radiological waste (i.e., hazardous waste) or a justification for their exclusion.
Page .15 of 16 "
Enclosure 1 -NYSDEC West Valley-Assignied Staff DEIS Comments 116 Page J-lO, It is inconceivable that DOE would ever ship only one railcar with waste per train. The use of this assumption appears Section J.4.2 disingenuous and as an attempt to skew the transportation impacts presented herein to make iiteWide iemo"ival apipear- -
impossible due to the,dangers.associated -withtransportation. While it is recognized that the DEIS does state that the risk.-
per train would increase proportionally based on the number of cars/train, the narrative and subsequent tables afe, . ,
misleading as they give the appearance of only one car/train being transported. It is unddrstobd-that therf will be instances Where a sgingle-car will be transported per train due to radiological considerations and shipping.regulations, but it is expected that the majority of the waste, particularly the contaminated soils, may be transported in trains containing.
dozens of railcars. * .. .. -"
- . Please provide a clear explanation of DOE's intention for waste shipments..
Chapter/Appendix: Appendix L
- eimmt I~ Jý Com, Nuber-.. Page Numbe - ,
117 PTage'L-l, .. In 19781the Staite Industrial.Hazardou Waste Managenfienit Act stblishted the NYSIzdous waste ma ngement "
FirstB t -programbyprvdigregulatoryauthority t9o htrioltheý fei storage anddisposal of hazardous waste;
":18:*Page L2, Und2er paragraph wo, in-place closure (management)"' not tpka~ly-" allowed for container and/or tank storage and/or Section L. 1 treatment units. It-is usuallyreserved- for land disposl umits.- . ..
Chapter/Appendix: Appendix M" . . . .....
119 Page M-3, Floodplains - In light of recent storm events (August .2009), perhaps reaching the 100-year flood level, and subsequent Section M.2.1 observed storm damage in the Vicinity of the site (ie.e Fox Valley Road washout), this section shoiild be updafed.
120 Page M-3, "The flood inundation area for the 100-year storm (see Figure M-4) show that no existing facilities are in the 100-year Section M.2.1. floodplain." Figure M-4 does not include the water reservoirs and dams, which were impacted by August2009.storrrs.-
Paragraph 4 This discussion and Figure should be updated to include the southern facilities.
Page 16 of 16
NYSDEC Non West Yalley Assigned Staff Comments on the
.. e Draft Environmenta. ImpSacttatementfo Decommissioning and/or Long-Term Stewardship at the,,:,.
West Valley Demonstration Project and WesternNew York Nuclear Service Center -
NOTE: For any Chapters/Appendices not specifically included below,-the Departmenthas no comments.
Book: General Comments 7 itý0, 1iat bisharg Elmnain Syte.P
- . 6NYC RRPa.rtý75, Statepollutat ischarge Elimnation System Perits, iSubpart 2.11 outlines Closure Requirements for Disposal System.. These requirements shall be complied with forsclosure of any, disposal system , , .... . -
Book: A Summary and Guidefor Stakeholders over:, "Cathern, Bohan should be Catherine.
of Front CInside .
- Cover Sheet, Location: West Valley is a mailing zip code and an umincorporated hamlet;
- * :the location is the Town ofAshford.,. .,... . , .,-
- Page 9, bullet #2: Should s6me type of handling-facility be!eftinpiace spothat emergencies can be dealt with quickly and effectively? Didn't understand this.
Page 9, bullet #5", hy is one called awall andthe otherýa barrier9 ,,Are:there functional differences that are' described later?
Page 9, bullet #5: Is there the potential for these wall/barriers to be removed inthe future as technology advances? Can there be a catastrophic failure that would require action in qthe need for handlin ,facilitiesthat have already beenremoved?
realjtime and present
- Page 9, bullet #6: What is the percentage? Why is there a differentiation between non-defense and defense waste? Are there different regulations- determining, how-they are; to be handled? Are they the same substances? Are they processed the Same wayito the same end result?
- Pagel 2, General. Comment: , Hasithere been a review, oftheqfailure to comejto;agreement
,,onclaniip responsibilityý fjthe plume, and-the resultant- expansion of the plime?:, There shouid be a discussion about what steps will be taken to avert such a circumstance in the future..... . ". ... ...
Page .13, bullet #1: What is orphn waste,.its composition and thereasonrthat-it, isicalled.
that? ' . . .. .. * , - . ,- . -
Pageq1 ofI31.
Enclosure 2 - NYSDEC Non West Valley Assigned Staff DEIS Comments Page 13, bullet #2,: There should be a ýdiscussion somewhere in the document as to the result of failure to .a*cept responsibility for the' plum and is expansion due to that failure to come to agreement. ',, . , .
Page 14, Table 1, Row: NRC-licensed DisposalfAiea (NDA) Column:. Sitewide Close-In-Place - If this is done, how hard would it be to remove if a decision is made laterto -remove it? '. '.,,.... "
- Page 14, Table 1, Footnote a: Is the restrictive. time frame given in the document?
- Page 18, Socioeconomics, paragraph 1: It depends on the number of man hours needed andthe pay gradeso6f~thoseworkers needed, not necessarily the duration of the work.
- Page 18, Socioeconomics, paragraph'2: are What happens to if it day acceptable levels of contamination discovered beistoo determnined high? that the -present Page 18, Socioeconomics, paragraph 2: Is it reasonable to say that there would be no
- - need for anyone? Is it possible that there, mightf still'be a need to do someinimal monitoring no matter what? .
- Page 18, Socioeconomics, paragraph 3: How far intothe fiuture dd*s this 1ho0d? -At some point there is going to be a change. Is the reviewer missing the point that the EIS is only looking'a certaindistance intoth'efuitre? ' ':-
- Page 20, Waste Management, paragraph 2: Where does orphan, defense and non-defense
.V7 Waste, fit: into.,the list? ':Should there.be a m&atrix: showing relatiorishipj?`,
0 Page 20, Waste Management, paragraph 5: Is this the smallest volume of the
ýl i, alternatives?, If,sbo*'just'say"t. * '"'* 'W' ,..
PPage 20,, General, Disposal Options orange graphic; last'paragraph:"'Should' it say with, regulations existing at the time of disposal or most restrictive?
S" ,Page 27, Long-term Impacts, last word: '("later") - Later than wchat?'Ar~finrtthere'
',impacts beyond peak'annual, dose? When' is 'the predict e peal annual dose? ."
Page 28, The Sitewide Close-In-Place Alternative: With the failure of institutional controls;' are there'jir6blemsý with:small doses'tovery large populations. through'
- 'c6ntamination of Erie co utm public waterdsuppfies which get wat&r from Lake Erie?
- Page 30, bullet #1: Orphan waste?
- ' ,Page 30, bullet #2 :' But mighttultimately have theiimost risk df contaminating and; affecting the most land/water and people.
Page 31,.bullet #1, end of line 3: What does "source terms" mean?
Page 2 Uf31
Enclosure2 -.NYSDEC ,Non,West alley Assigned Staff DEIS Comnments,
- ,age 3l, bullet#1, srng on!line,* 9: at istrg to be said here?,
- Page 33, Human health: Our understanding and research in the future may alter how specificlevels of exposure are yiewed.. Is this uncertainty considered?7 -Is not considering decay rates enougih? Typically, scientific study has indicated that acceptable levels yesterdayrare too high today. .. ..
- Page-34, Lon-6r h an -h'ealth.: Should cha'nge6s to figks de oii ledged of the effects of exposures or the discovered increased risk from "combinations of contaminants' be included" Ild e p34 ose te piesthe photo adescnrption.
rageP&4,photo:' Inc!ueWhatpos ofethe ppe Page 40, Appendix E: What does "near-field flow" mean?,
- Page 40, Appendix H: Change "assessment results" to "assessment model results".
- Page 47, cesium: Is it still the,most electropositive element known? Ifso, say it..
.Page 47, collective dose: o ffyou w expose to things. from different source, the
-infrmationwouldn't secify 'the sfii total'or exposures and the total dosewouldn't be detscribea figywhere? . . ." , " J, " .
- -**Page 47 'Should there be a description for defense waste (anorn
- ei b0ty es ofw'ste tw WtValley?, *YAýie-theyý.reated diffeietle y 4procedure, processing or degree of processing based upon their origin:althoughthey are the same man:7' .contamL : . ,4
'Page 448, hy~drofracture: in weýstern NewYlorkh dr a i~ isa~sociated with development of oil and naturalgas wells:- ,'
Pa I 48: Shou, there be'a Page adescription for,non-defense waste(and/or defense waste)?
- (Seecommentt** above) ., ' . i-.N : ..
S -Page 48, permeability: Add "or gasses" after "The rate at which liquids' ." Also, should this include contaminantsthat do not dissolve n,,,water?,..,.
Book: Chapter]:IntroductionandPurpose,andNeed forgencyAction
- Page. 1-tol-2,ast lne,onpg., 1-j: '..TheSDA,received waste from offsite locations...
Was it the same type of Waste? Commecial.? Primary asteor waste generated by cleanup operations or both?
.;'- . rAY K.
Page3 oqf, 31
Enclosure 2" NYSDEC Non West VAlley"A'"signed StaffDEIS; conments Page 1-10, footnote 1, 1St sentence: "SEQR specifies that the assessment of environmental ini~od~t-iiuses 'o'n`the6"groxi)Vffh-inducitigý dksp&t of a rPioPs'e Action."
SEQR does not focus on growth-inducing aspects of a proposal. ,,
- Pagel 15; Section 1.6.11; ast sentence:: Wat. oes QuahtyServices mean?*
- Page 1-16, Section 1.7.2, 4 th sentence: "A formal public`& eariiig was :con'ducted in three meetings on August 6, 1996, in West Valley,'New York, to receive oral comments."
West Valley is an un-incorporated hamlet which is shown.on some maps. The project is intte towni of ýshfor~ ~ " ~w
Page 1-18, 5th bullet: Relationship between DOE and NYSERDA. Why can't disagreements and responsibility be a topic for discussion, especially if disagreement.
causes delay and results in such'things as the rfgratin of tle plume because tliere was a disagreement about responsibility? ;
Book: C'hapter2 Page'2-1, Sectiohn .1 Introdcton stated that The Phased Decisionmaking Alternative (The Preferred Alternative), under which there would be an initial (Phase 1):8-year period of remdval actions fdrallfaclitiesexcept......and Construc"ti'n"and 'Demolition Debris iandfilL." It should be pointed out tlat stormwater discharges from construction activity should follow requirements outlined in the most recent version of the "General Permit for Stormwater Discharges from Construction Activity." Current version of this General ermitNo. is' GP4-008-OO 1. Tlhis ,is also apphlelt0Pag 2-46, Sectin 2.4.3.2 Ne~w Constrictin and any., otier sectioni related to this issue.
Under this Section, it is further stated that "During a period of up to 30 years, DOE and NYSERDA would conduct a variety of activitiesintended to expand the information available't6 support-lateraddii*inai daeconmiss'iiihng decision making (Phase 2)'for those facilities and areas not address in Phase 1."'ItJ nb cr w eiwv ih3 years, the decommissioning.for those facilities and area not addressed Phase 1 would be
'compl'eted bor'not" 'If not, wihatisthe pr,oposed"'chdule for fI pltm[of o
decommissioning. Page 2-47, Figure 2-8 extends to a penod of 70 ye-asbut no'activities shown beyond 30 years.
Page 2-2, Section 2.1: HLW'or HLRW What about
- ves'ofthe s'? What is the relationship to transuranic wastes?
1st paragraph: "Such term'-Shouldni"'t"'tbe
" "sucht n nclud6"" '
LLRW-; Are the criteria' f6o classification given somewhere'ie'terms tlife, of 1/2 concentration or some 6theriquahlfier? .... >
Greater than class C - Is it possible to give concentration limits in this document?
Page 4 6f,3' 3
Enclosure 2 - NySDEC Non WestV#alley Assigned Staff DEIS Comments C &~D debris - etanitrhveg atrthan,background levels 0fradioactivit?,
,Page 2-3, Section,2.2, 1st paragraph: Doesnot tell where the W'aste Classifications" text
'box can ~b~e 'od. Wha tpa`ge si on? A:;,j 2 "dparagraph: Is the same type of radioactive materialhandled' the sa1e94wayjveqn if part is from the Defense Department and the other part is non-defense material? Or are the
..twoldifferent types',hemically" mutually exclusive? 1, 4
- Page 2-3,Section 2.3: Direction & Distance from Buffalo - Straight line distanýe, between the two is about 24.5 miles at their nearest points. Direction is south southwest.
Cattaraugus Creek mouth is*23.3 miles "Southwestof Buffalo at its nearest pbint.
.Page 2-5, setion2.3, bullet: A 11-add ScrapMaterial Landfill to~bullet.*'
- Pg2-;,..yofatre*etwllarea part of, WMA1 Sam frpmtel laidfill and bulk storage warehouse. See title of fig 2-31 Add WMA 11 to labeling on figure for Hydro frac and warehouse as did for the landfill.
S ' d st . ..gra fie " l, . ..
Page 2-11, 2' bullet,4 1"sentece:. ,Al ipgade sl9Tybamer wall will beqinstalled and a geomembrane cover will be placed over the NDA as part of the NDA groundwater infiltration mitigationmeasures'I.qphet*m'nmitigatjon!' is again usedina' way that is not very descriptive. Much more meaning wOuld be imparted ifpreyentorreduce were used.
, 3r bullet- ý,cesium- 137 invento ry!,-he imventory contaminates the absorbent media.
-Hojymuch liquid will, be leaa,ap ercentage? yhywon't5 theimeda absorb all-the.
Page 2-12, 1"bullet: What is the difference between a treatment wall and'a reactive
- Page 2-21, Section 2.3.2.3, 2 ,dparagraph:, t'Most of the residuaLcontaminafion in this building is in the two HEPA filters, which could contain as much as 7.5 curies of cesium-
.137 andmuchsmaller activities.,of otherr lionuchdes,* ,Actiitles). ..
If defense waste was part of the reason for contamination of equipment does that mean the equipment is handled as defense waste,?;,.. ... ,
Page 2-2,1, 7 _ paragraph: ,IstheConEd Building, itself contaminated,, or is the,,:,
equipment contaminated or both?
- Page 2-26, Se6tion 2.3.2.9` Drum cell - contaminatedornot?,,Wy wouldanything be assumed?
Page,5* of 31:
Enclosure 2 - NYSDEC'Non West Valley "ssignledStaff DEIS Comments Page 2-27, Section 2.3.2.11: If the environmental assessment done previously is not included; i nthis 'document theni it ýshouid be, stated' where it *can be found/obtaified.
2V paragraph: "This waste'materia' was radiologically surveyred, deortaminadtd as necessary, and released for unrestricted use beforeitiwas buri in theteh'cd" R~leased for unrestricted use? Please explain. Is there a reason that recycling of scrap metals such as -alumhinum'tcahn~iot c'cur?'"' "
Page 2-27, Section 2.3.2.12, 1st paragraph:; "..contaminiatedsedimentsresuling from regulated releases." So thesereleases were scheduled and planned? There needs to be a bette explanation- ~
2 nd paragraph: The North Reservoir has a pump house to regulate the water level?
1'41 Page 2,-28, Section 2.3.2.13: North Plateau Groundwater Plume - The inability of the two agenicies,. t*rachagreefitent is!the&rason foi the&,`s'i~e of!the plunide This shlildbl& stated' explicitly. Somewhere in the document there should be a discussion of future contdmination possibilities due to'ttheinaabilityWof ageiicies to agree on someihing in the Page 2-29, Section 2.3.2.14: "The cesium prong is the result of uncontrolled releases...";
S'ýWhat do&s tha~tmean? ýWa,giteeq uipmentfailre, umidiin' error orwhat?..
Page 2-29 Section 24- ,st .bullet:*"'enwronmentalmedia"? ,Notinthe gloessary. How do
,you d6c'ntamfinate 'soils?9T ' " " '
"This,' alternative doeuld g erWatet 'wds'te for which thei6e is 'curreni, no, offsit&:disposal 16'location.Y::*.'" 'Generaing Wast 'einplies',ifi&orWae§te4han bef&6r. 'Ihlthe do*iinent trying to say, "Under the sitewide removal option some waste could not be shippedsince there is no place to ship it. "?
Last sentence: "bounding alternative" ?? Please rephrase.
- ' Page ,2,' 0,TextBox-,,Is~there defense waste'at West Valley? '
General question;' what is low"level, radioative' wast ecomprised of? Arid fdr other types?
Or is there no good answer?
Text Boxes should be labeled in a formatrlike figures"- ' ."w" ' ,'
Page 2-32; Section 21.4A 1: .. environmental media"; different words please.
Page 2-33,. Section 2.4.i.1. 1st bullet: What is the waste that will be generated during the
ý'work? Eq'u-ipn-menf, soil, water-,' chefiai'cs? '* , '.,; '*>A,, ,':; -
Page'6 of31
Enclosure 2, - SDEC No~ WestValley Assigned Staff DEIS, Comments 0 Page 2-33, Section,2.4.11,44th bullet: What will beAqone to "remediate"!surface soil and sediment. Will the radioactivitybeq'ieremoved"from the soil, orwill thecontaminated soil/sediment be separated and removed for disposal at a different location?
S ;,Page 2-33, Sectiofin24.,l, WMA. 1, 1t pjaragraph::hat part of~the building is contaminated.?. Knowing tat might then explain how, .iis decontaminated.
,:,2*paragraph: , 9 2 paagrah Wat d.oes,1 coqmp ety rempyed"*mean?., Everything taken from the site?,
3 ; paragraph, last sentence: .,What about contaminated subsoil?dIf subsoil 4s.,
contaminated does that mean they areleaving it? Wy isn'ýt'environmentalmedia" ntin g thatnisnt wh ichiseemns~t o r~" _ anyth i man-made Ch,n ch'
- i. used?~,-, C:,
WMA 2: 1 St paragraph, Lagoons completely removed from the site? The contaminated materials can be.removed and theexcavations filled...
WMA 4: What about contaminated subsoil?
WM
- A,5: No mention of,soif or subsoil. ,Why not say*all contaminated environmental
- ~Page,2-35, Section 2.4.1.2, New Construction: "ALeachate AtIncludes TreatmentFacility,,
to.piocess contaminated leachate from the NDA andSDA.". The SPDES modification
-applicafionfor the poEppsedqdischarge from the proposed leachate, treatmnent facility should be submittedtoithe Region 9:r;pEBPoffice forprgcessgin;:CAfter thi* pernit modification issued, the design engineering report and plans and specifications for the Cleachate treatment facility should,be -submitted.toBBurea.upoffWaterPermits and ,Region 9, office`for review and approval prior to construction. Also see Page 2-64,ý Section 2.8.2.2 and Appendix C, Page C-138 Leachate treatment facility. The applicant should be familiar with 6NYCRR Part 750, SPDES Permit and Technical and GuidanceSeries .C C (TOGS) 1.2.1. Industrial Permit Writing in dealing with point source discharges to the Cwater. of the state.. C'CCCj; ,'C ~ CCC C
- Page 2-3 8, Section 2.4.2.1, WMA 1: Large boulders may serve as an intrusion barrier, Cu t.butwon',t do much for, stopp ing,,rosion.;,.The boulders may also .helplto concentrate C C' Csurface Water runoff*:t0o, spe(cifc points,(between,the boulders),and actuallyvincrease the erosion potential. C -.
- , *Page 2-39,Section 2.4.2.,WA,3las. sentence L.g9 boulders may1serve, asian intrusion barrier, but won't do -much for: sopi*ingerosiotpSee comment. abtve.C,,
- Page 2-39, Section 2.4.2.1, WMA 12: There will have to be a downstream end of the excavating and riprapping.4It,is this,.nick point-where erosion wilstart almost C C immediately. Do the plans identify maintenance of artificialstreamrCchannels as: a cost?
Pagel7 of 31
Enclosure 2'- NYSDEC Non West Valley Assigned Staff DEIS Comients o Page 2-40, Section 2.4.2.2, Last bullet: How do you construct an erosion control structute around a creek? Poor wording; needs to be explained better.
- Page 2-43, Section 2.4.3.1, last bullet: Removal is determined by depth rather than radioactivity? Once you have opened ahole why not' remove ihe contamination in the bottom of it? What happens if the material below 2 feet isreally "hot"?
o, -Page 2-45, Last Paragraph - States, "The final decision on'the Phase 2decommissioning and long-term management approach. would be made within 30 years of the date of issue of the Phase 1'ROD. As new information bebcmes'available during.Phase 1, DOE would conduct appropriate NEPA review.," Fromthis statem'ent, it seems there is n6 ending date set for the completion of Phase 2 decommissioning. What would be the reasonable schedule for completion of decommissioning?
o Page 2-46, Section 2.4.3.3, Last paragraph: Is there space to store'this "unanticipated" waste?
,Page 2-51, Section 2.6.1, Last sentence: "This approach was performed in such a way that did not bias the comparison of alternatives." Suggested change: This approach was performed in order to attempt to remove bias from the comparison of alternatives,.
o * , Page 2-59, Section 2.6.2, last paragraph: What would be the exposure to everyone drinking publid water taken from Lake Erie? If nothing else at leaist there should be a statement that dilution 'xwIould be Such that there would be nothing measurable above background levels:, Tlhis may have been addressed later in'th6 document.'.
Page 2-62, Section 2.8.1'.4, 1st paragraph: "Atlantic Compact" should be explained.
Book: -Chapter3; ' "- . ,'
o Page 3-6, Section 3.1.1, 2 nd full paragraph: What is an "acreage lot"? Dothey mean a small parcel separated from a large parcel to construct a single family residence?
- Page 3-12, Section 3.3.1.1i First paragraph: Elevations 'are discussed without reference to a datum which is'a standard notation. Ex. International Great Lakes Datum (IGLD) 985 o Figure 3-7: The figure shows orientation of the cross section as west.to east. The orientation should be the samie'as Figuire 3-6.The' cross section 'is shonwr 'as extenfding beyond Buttermilk'Creek on Figure 3-8,while the cross section-itself Stdps'at the 'creek.
This discrepancy should be resolved.
o Figure 3-9:" It'Would be better if thelhoriziontal Scales of thecrobss sections'were the same, "making it easier to compare. ' ,"' ' :
Page8 of 31
nlo~sgre;2 :NyS*EC Non estYafleIyAssigined *Staff DEIS Comments Page, 3-21, Sction 3,.3.1.1: KntRecessionailSequence.- "The basal lacustreine sediments
',.were deposited:in glacialjlakes that forrmed asglaciersheA blocked*.henorthward,
-4qri a gefptreams.'!
Sand and gravel was later deposited 6fro where streams entered the glacial
.lakesforming deltas and along the floodplains of streams that formed during ice-free episodes,, ... ..
- Page 3-28, Section 3.3.1.3: There are three types of mineral resources; sand and gravel come from the glaciers, oil mostlyfom the upper Devonian and4gas mostly.from the lower Silurian period.
Mineral district has: no, meaigin New rpk State.4 ItJsa westerntem. If the document is trying to identiy the locatiqniofihe resource,;,it *wuldbeemiore appropriate to use county names.
- Page 3,-29, Section 3.3.1,:i Soil contaminatiqnA, ivye an explanation*,of an operational incident.; jsJt limitedto humanqerrors?. i , .
2 nd paragraph: The primary constituents areas of radiologically contaminated soilare cesium- 13.7 :tafassociated with the Cesium Prong area; soils affected by the NorthjiPlateau strontium,90 grounidwater plume; and .radiolgicallycontanminate&d soil Sassociated with Lagponsj1through 5 and the Solvent Qike(MA2).,,This needs work.
The primary areas (whichare.1cafiýns) can'tbeia chemical.- -
- Page 3730, 1VI paragraph-: 'The1.olw1level chenical detections~are,,cornsistent~withi ..
g .human activity and ,ýeimdustrial natureofthe*spit.,* e Page 3-30, last paragraph: "Metals concentrations in RCRA facility investigation soil samplesfirtm these facility areas slightly_ exceed backgrooundor Techhical an Administrative Guidance Memorandum 4046 criteria." Slightly? By what amount?
-Page 3-31 :: ,Cesiuim Prohg *-,'.Uncontrolled airborne releases from~theMain, PIlant. Process Building venitilation sy stemfilters in 1,968 released contamiiated material through, a 60-meter (200-f6ot) high~planf~tack ~ - Hown ~yr~~e ere t1r? hydid the, releases
. .4 .
happen?
ld Mechanical
- failure?
Human:
failure?
.. * * . S'"
... age,3-36, 2 nd paragraph-.theslupmpblcks.are shown, in figure 3,16 not 3-15 (two places injparagraph),p)). " , ,
S Page 348, Fi0e3-18,8 The delimeation of a~state wetland isypicallyiyvalid fqr*three
,yeas Part of!*thprcess of issuing; apnyNS W Wetand Permits would be verification of "the wetland boundary ,-Thedocumentirefers to the w etland as a Class IV DEC never
,o;;6fficially determined the~classilficatiponopf thewetland.:*, ,
.. ,A ..i. ,.,,,..".,* .'**,i
- t.*};U
- LV ,**, .. :i'** *,* U)i'..'**.....V i,*,* ',:,.. ': ;, ....... .*(
Page 9;of-ý3,
Enclosure NYSDEC Noni WestlValley Assigned Staff DEMIS .Comnts
.Page 349, Section 3*. 1, .2paragaph; 2nd 2ndtoliastsentehce ' e " - In addition to the two water supply rese'rvoirs"and wastewater treatment, lag6ons in W-MA '2, several small ponds are located across the WNYNSC including former borrow pits"-(Northern Borrow Pits) located in'the northeast corner of the Project Premises (WVNS 2004a, WVNS and TRS:2005.)"' _1 o",' '.-.
- .7* - , . - , . . -4 7 , .
- Page 3-54; 2 nd full paragraph: What are the implications for the general publidcaft the first point accessible given the radiation levels?
Page 3-54' 3 rd full paragraph: No mention is made of testing for radioactiity?'
- Page 3-54, Section 3.6.1.2, 1st paragraph: Several of the discharged radionuclides,
,',:, ,::.-parti6ularly cobalt-'60, strontiumm90, cesium-134, and cesiuim-:137:, have fan- affmiity, to
,become chemically seebd attached to silt* anid'accumulate in* thestrambedS.
The writer should acknowledge that over time all of the contaminated sediments will
'le'aVe' the site a'nd, end;up in Cattarau~gusCreekan*d*LakefErie. There have been' discussions regarding the removal of the Springville "D'am wh Ich i o6uld thefn allow¢ a more continuous movement of sediment down the creek. At issue *isthe sediment behind the
-1dam.- 7.*:;
'1
- ... ... ..{;:*!,*.. . , . ..... . .;* .' . . ;2. *,. ....
Wh at does thecontamination level-of the sediment
!,1',sediment haveto"be removed to a disposal locatinf behind the dam mean,? Ddes' the or does current 'regulation allow it to stay in place? Is DOE fesporisibld for ieihbVming .thesedimenit?'.......' -'
How often 'is'the groundwater pumped to' maintain the elevation? If the.French drain'dischaige was plugged What is happenli ng to groundwater
- elevation and flow?
- Page 3-60*, l:* paragraph* 7 'Pleas6"eeplain the different typeSf "biointrusionS" .
Pag '1 'pargrph . e7 fttpe r
- Page 3-60, 2 nd paragraph: "Models for the South Plateau developed by Prudic (Prudic
' 1986) and by Bergeron (Bergeron'aid Buigliosi l988) support only moder ate lateiral
- m fovdenent through the weathered, till 'untlflow become directed dowward iito,.he unwedtheied-Lavery till." .'flowx ,beco-mes" or 'flowSbecme", *'ý
- Page 3-60, 2nd paragraph: "Using these models as a. starting point, Kool and Wu (Kool
,and Wu 1991l)'examined] ho cha i ..... yrwii "h cond ....ty vcr' "a " ....
and herizontal anaset-epy in the hydraulic conductivity can impaict flow through,,tie weathered Lavery till." Anisotropy, different values along different axes; in this case the.
'xevertical ixe*:A ,an'*horizitai hard word to use.d ' Sugg'sted cliaing'g, "U'itnig, these
' models as a starting pointiKool and Wu (Koolfand Wu 199,1) examined how aisotropic
,char'actenstxs hydraulc conductivi.t impacted flow-ttirough theweatlered, avery till." Are they also trying tosay that, 'Iydrau"conductivity was,not constt on any Tparticular axis? The, use of the word anisotropism tends to indicate there is one value on a specific axis. If this is not the case the word should be removed and others used.
P~age,410o 1i
Enclosure.2 - NYSDECNon WestfValley Assigned Staff DEIS Comments Page 3-6,1,jBedrockufit: "Wells completing in his zone, yield 40 to.60jliters perminute (10.6: to 15.9 gallons per minute),and. orrespon4s tohe.regionaLbbro&k aquife."
What does "completing" mean? Do they mean wells drawing water from the weathered
.bedrock?. ,y; ,
Page 3-63, Norh Plateau Groundwater Contamination, Figure 3-22: There should be a dateon the figire. "..
Have they gone, back and ichecked to see if the fgtre was, aqcurate based upon later investigations? ' . - ... . :.:*.*,
- , ",,Page 364, :figur. 3-23, the separate.,panels shouldhaye, theelejyations reversed., It would be .easier. o read , -,.,,,. . F,',:2-. ' ,.
- Page 3-65: What justification was there6 fr,reducing :the frequency,of monitQri1ng?
- ae3 6 sentence: "IJn November 199 5, grqundwateKr ecjo~yer systemw ws; insalld t mtigte h~ipoe~n~tof strontiumn-qQOqcontaina~tion in groundwater in the sweri lob~e of the'pluine.and reduc'e gronwesepg.ohastf the'Mi Plant Process Buildimg." * .... ... "
As previously noted, the reader believes the use of the word mitigate in this context should be changedto: more, eplicit,-Reduce, theexpansion, or stop the expansion: is the way to describe ifthati s what is being done. ,-,-.
- , ,,Page 3.-68, last pa~ragraplh:'.,trench system wasipreyiouslypnsptruted along the northeast and northwest ides 0f'theýNDXto, cpllecptgroundwater thatewas potentially contaminated with a mixture of n-dodecane and tributyl phosphate."
- U,'I , .k
ý - ' I, ,
- Page 3,69, 1s.paragraph: Gross
. betaand tritium concentrations in samples from, locatin W NAT.R, a .sump.,at the Io !est,point ofrechhad6ro downgradient well 909 screened in the Lavery fill continued to be~elevated-withrespect to background monitoring locations on the South Plateau." Is the well "screened" to the entire till unit ýor; does it only-proide.access toa, small, portiponof the till:ti?ý.,
o n e l, c .tc sp4v~ a ,,
nd p'"
Page 3-70, Section 3.7.1, 2 -paragraph: The difference, in elevation between Lake Erie andSWNYNC,,is not 1,3 10 feet. ýLake Erie'* Me an High'Water Level is 573.4*!GLD
.1985 datum. WNYNSC is at 1,400 feet (the docýment does not use a,-datum reference which is a flaw) according to the document. Even allowing for the use of different datums the elevation differenice stated i.s wy4on.gby apprgxjmate!y 483 feeti The correct difference is 827feett/-. .
o ,Page 3-.74, 2 d p~agraph:. "'*1e following emissions sourcesare monitored on a-.
continuous basis for radionuclides- the'Maim Plant: Process Building*entiiation~stack. the former vitrification heating; ventilation and air conditioning system; the 0 1-14 building Pagej.i ofj31
Enclosure 2'- NYSDEC Non West Valley Assigned Staff DEIS Conniments ventilation stack; the supernatant treatment system ventilation stack; and the Remote-Handled Waste Facility (WVNS and URS 2007)." "the former vitrification heating;"
What is that 'upposed to mean? Should the semi-colon at the erid be.takeh out?'
Page 3-76, Section 3.8.2, 3rd full paragraph: "The state also regulates work within a 30.5-meter (100-foot) boff-ffene adjacent area around designated freshwater wetlands."
o Page 3-91, Maximum Dose: What criteria were used for the max dose to an offsite individual? Is the person presumed to be at their location 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day or did going to Work get included in the calculatidoni? If so what about a "stay 'at home'.'? Is'there a potential for bio-accumulation? If so was it taken into account?
'Page 3-91,'Wat~rborne-Releages: Where would the'person be who'teceived the max dose? Was bio-accumulation taken into account? Why are these water releases allowed?
Is there a way to treat the'water and reduce the rates? Seems like a lot of radiation to release 6ver another 30 years. And what about all that has-lbeen released already.
Page 3 "Figures 3-30 and 3-31 show the calkulated annual dose tothe'i hypothetical
'maximally exposed "individual -and the collective' d6s to the populatioia respectively over.
the last 10 'years. The over'all radioactivity represented by these data conff-iris the continued inconsequential addition to the natural background radiation-dose thatithe individuals and population around the WNYNSC receive from site activities."
6"inconsequential" is a very subj'ective Word. Find btlihe wordsthat say at the' present time we don't think there is any impact.
oPage 3-94, 40 paragraph:', "This is-the only undeiground petroleum storage tank'currently in use at the site." Are there' any tanks'niot cufrently in use?
Page 3-95, Section 3.11.4, 2 nd paragraph: Average doses are just numbers. When you start 'averaging in'zeros it-quickly starts to hide the high doies. What wvere'the highest doses? Report the top'"l0% of doses. Is there a"graph' somewhere showing tihe doses, a hist ogr am' or somet hin g ? "' ' ! ', ':*' - ' ; ' .," -' : - . ',.....*
What does"'conriactor's daily limit of 100 millirem" mean? Is that for one person or everyone that works for a contractor?
o 'Page 3-96, Section13.11.5.1:' Over what period of time 'is-itbelievedtha the rel*ease of radioactive nitric acid spill occurred?'
Page .3-103, Section3:12, Enrui-6rnmeni~al Justice: Why is Canada discussed in this section? Is there a federal requirement?. Or NY State requirement? '
Page 3-110, Remote' Handled Waste Facility: It is to be dismantled in 2011. So in two to three years'therie will no longer be a'need for it? . ' ; '
Page 12 of 31
SEnclosure X-2,1YSDEC Non West Valley Assigned&Staff DEIS Comments.
Page 3-i111 Section 3.13.2: 'The emphasis on good business practices; source reduction,.
,,an.d :recycling nizes :the generation of lo&Jeyel radioacti*e waste,, mixed,!ow-level radioactive waste, haiardouswaste,-industrial 5wastes, and sanitary wastes, such as paper, w aod,scrap metal.7., *, .
Sanitary'waste is not paper., wood or scrap metal. Sanita'y waste would be more accurately describedas municipal solid wyasteor pgitrescible waste._,
Book: Chapter 4 ,
4 1, "Impacts of less significance":, Geology and oilshould-,be listed in the section of grVeat sigmificance.,,~~~~~~~~.* ~ ' ~ ";.,..,..
- .,+' . ..
- Page 44, Table,4:-1, Land Dpi*trbance: -Eyen if the.,Closerin-Place alternative were choseii, the CdSiimprongand the groundwater plume should notbe Wallowed to expand, or leave the site through surface runoff; erosion andor groundwater movement..
, * , * ~
fl'. ' " ' .. ++ +
1'4 W % 'P " ... K .'.. ' Fa- .> a.'
- - Page 4-15, 4.1.2.,. 5paragraph,' "Almostfall of the waste, hpmentsandiconstruction material deliveries for this alternative would occur'over the first 7 years of the implementation period most decommissioning would wwhen take place; and reflect the efriargequantitties.of soil, sand,,gravel,aiftd other materials forNDA and SDA
,stbilizatiqn.' "The context of thOfpr of-the sentenicb tlat ,o'ther materials'",is use~d in, would leadoneto think that other mateiasIS natural product fther materials could mean a lot o6fthings. It could.beryanyhimgrormnhea boulders to straw, to silt fencing, to tire chipsto slag!fom.a steel plant Please Page 4-19, 4.1.3.1: "The greatest requirements are foi 'soil, concrete, clay, and sand and
/,?;gravel." - :. > + .. 7.. +.,+= +.
- Page 4-22, 3 rd paragraph: "The impacts of tiel,' oil, or lubricant spills could be fi~el ol, r,,~ spl, could be.++
, . ti++, te.
minimized.by keeping.te, equipment -i good-repair and conducting *maintenace,
,ope~rations in areas designedfor such operations, , . . ,. ,
Page 4-23;,+2j+,paragraph":;jhis paragraph-says +Area excavatlons.-would be backfilled
-with +r,+
clean +iwth;c.ea*+>s!l soils, ++~dm*.de; andparedtoe Qres~t0+re i*e+area to +gnatural+appearance+that ta approximates a~oiae natural condifionidfor the i ,, theý eog'teri, iplementation of-theSitewide Close-In-Place Alternative would have a positive impact on groundwater quality." ,. It isl however in 4.1.4.1 Sitewide Removal Alternative 4-*23,.4,ul*, .paragaPh"Surface 4ph:, aPage Water Flow,,andiQuaty *31The impacts of
,".fulel :oil,; iibncant; spills would be p+igate aminimized by keeping 'the equipment in good repair and conducting maintenance operations in- areas designoed for+such,-,I..
operations."
.-. *..+
Page J3-of3,1
Enclosure 2- NYYSDEtCNonWest.Valey A'ssigned Staff DEIS ComIments Page 4-24,, 2n- 'paragraph:- "The Hazard;Irid for rýleases from" thei fuclities was at leasttwo 'orders. of magnitude lowvr;(§eeý Appenidix H,"-thble 2;32,'ofthi.EIS): This
- analysis suggests that there"w6Ildbe noseriousq ng-terim imp'act to CattaraiigusCreek water quality under the Sitewide Close-In-Place Alternative':'Buf the liases would be two orders of maguitude greater. Doesn't that mean that something is wrong.here?
- Page 4-24, 4.1.4.3, 2 nd paragraph: "Surface Water Flow and'Quality -The impacts of fuel, oil, or lubricant spills would be it"'igate" minimized by keeping the equipment in good repair and conducting maintenance operations in areas designed for such operations."
- Page 432,'4.1.5:3; 2 d paragraph "EAguidelines~ideiitify aý 24Lhbuiexkposu're level of 70 decibels or lower as the level of environmental noise that will prevenf 'ahi' irieasurable hearing loss over a lifetime. Likewise, levels of 55 decibels outdoors and 45 decibels indoors (or .lower) arre identfifedas preVenting activity, mterfrendce and 'anyance."
Page4-32 paragraph:' Durng Phase 2;simila havy'diesel'construiction 'equipment operation would be expected. The duration of these activities would be expected to be
':,,,une the same duration as 4 the Site/wide Remo~val'Alternative."
- 'Page 4-33;` 3 !, p hragrapli:
".ThisnoIsewould be barely 'audible'ibove background sound levels in the area. Noise from this activity and othier constrjuction-type activities wbuld
.occurduringdaytime hbursand would not bedasourceofannance to'nearby reidents."
,, :: It c6ann6t be stated "whiat "will be an, arnnoiýyance;. It could be'saidi thaiithe"imiractw ill be minimail,'but the writers have no way of k_.nowing-whlat will be -ann'oyance. Someone could be working nights, sleeping drglgthe day havetheir windows open"'and find even minimal noise very annoying. .
- Page 4-34, Table.4-9: The table states that there will be, "No impacts to Federalior State-cies. ... -
.listed endangered, threatened, or candidate spe..
This, statement'ignadew ithtdt"dif site-d -R'emvaPlAlfteiriative, Site'-Wide Close-in-Place Alternative or Phased-D'ecisionm-imiakinfg Alternative Phase 1"and Phase 2.
A categorical statement such as this cannot be made., It implies something of which no one can be certain becaiuse it cannot bepr'en-..For examplth Northern Harrier,
'.Circus cyaneus is 'a;NYS-threatefied, speies'tsha beef recofded in,,the 6'a. All that can be Saidis ;that "e'eiry effort wilt be made to avoivd
- significant :impcts 0tdthdse species. L,.- * '
The 2008 NYS Breeding Bird Atlas has surveyed this area. The project site falls within
,,, .Block..1970A anda lihst of species .for'the site is provided&(see attachment). Of a total of S:.,87 species,thereare 29 whIch cspecies are recorded-'asgPossible.Breeding; 16Probable Breeding, andý 42 ConfirmedBre i:'; ' " .... ,g.
There will be inevitable disturbance to bird species that will occur through complete removal of the forest trees, and shrub layer. The primary way to minimize this damage, Page144 of3l
Enclosure 2,- NY Non WestValley Assigned Staff DEIS Comments
,especially td nesting and breeding resident birds, is t, conduct the removal, activities b i n erlio r than August. 1. -Most birds bree throughout Mý44y and June,: and late-
.nesters and fledglings require undisted habita"throughout July.'bIt is prolable that
,Augst clearing activities willcauselte ist impact t- resident species..
However, migration begins. in August,,and fromAugust troughOctber, birds wi be using t'he foestasa irato*stopoverssites There ill be o er habitath .uiiused fiest§byfwidie Thr,,wl no ,one seaslon where the haittisiusdywldie,;pecially birds.-H evr, inm~~ oiniimize the damage caused by clearing'activities Aworkshoild begin~no~s00ner than August l, and should be completed, orhfialtedby Mi ch 15, when spring.igrantsreturtobreed.,, .
. Page 4734, , paragraph, Terrestrial *Rsouces:j*-w*ildlife inwadjacent habitat -could be disturbed, by nioise.-and increased: human presence,,which could cause some animals to
- teipporarily move from the ar*a, While*i others -ei,1d-adept-more ae toleranttof human actities. Proper maintenance of equipment and restrictingworkers Jto, the work, zone would help mitiga*e minimize this impact."
.3 st " ep A p..
45,1 lt .pýaraph:.,Whathis te depthkof topsoil currently in the Cesium Prong?
9Pge Howrmuch contaminated soil will be removedStillbeen h,
-allow yegetationto grow? , Will the s Page,4,35,;.st full paragraph:.,,Pnor to land-cleanng. operations, ,thelareas ,to.be,di*Sturbed woUld, be: surveyed for,nests :of migratory birds~in.accordance with the Migratory Bird.
Treaty Act. It might,be necessary to uderake clearingoperations, prioto Or after, the breeding season to mitigate impacts to migratory birds." "
(Thi.s jiessentially.what ,wehaye.just.explained mthe above~conimentary)
Specific dates are necessar, which we,have providedinj previous comments, but this
.-period 9f".ofnnt6-i -bance should be Marpch! 5:A-ugtA1. tis :incumbent.that, specific-breeding bird surveys be done by a qualified consultant in order that all known"listed species are detected, and a list of all breeding birds is produced. Additionally, bird speciesusing this.area asstop0ver habitat0during Migration should be iisted? Due.to the BreedingBird Atlas,, we are aware of whatspecies of birds canibe. expected, but a current survey should be lrovided by t tle apPli ant.Q . "',,oV, .
- *'.Page 4-35, 2',paragraph:, 'Impacts of clearing operations associated withlthei
- ,.remediation:ofthe undisturbed portionoftieWCesium Prongwould include th.loss of less mobile species (e.g., mice, rabbits, snakes, and squirrels), aswe!.,ll as displacement- pf other more mobile species (e.g., birds and large mammals)." The statement identifies the loss of lessmobile species., Thiss.a very conservative statemen t-Someof -those, poulations-may be reduced, but it is unlikely that they will' be eliminated.,
pu ,, .... .. ,
- 'ý <
- .,'Pge 4-,3.5,, 2 d jparagraph: ,,!'tmight be necess.ary tounderke cleaing operatio-isprior to oriafter hp,breedingseason: to minnimize , ig4eimpactsjtoimi.gr tor;birds.,indirect impacts to wildlife from increased presence.of humans and inoise couIld,alsodisturb animals in adjacent habitat. Upon restoration of the site, it would once again be available page. 15* o~f-31.
Encosujre 2 z NYSDEC 'Non West Valley Assigned Staff DEIS Comments to wildlife." The habitat wouldbbe changed by the clearing 6peratiois so that there would
, likely-be different syeeies,withi' differi*eit`puplat:ion .size*s. Open fields Would frotbe suitable habitat f6roi§quirrels ordinestingfg h tbitt for m0st non-grounid nesting smiall birds.
Birds such as the Hefislow SPaf6rW andthe Shoiit Eared Owl may find. itto be suitable nesting habitat where it was not before.
.Pag4-36, 2.2,paragraph*: "Mifigation,; aludig Aeppidiridte "roio cont ols,' would be insialled"and best mana'gement practic ld.beb implemiented ,to-&iifiirniIze .s6il
. '..erosionand sedimnentation.As With, the da`mslý andieservoiir",specifi fequireimeiits for fish management would be develkped as part of the a'ppr'ovalprocess -priorto any actions taking place*."'-`
Page 4-36, 4.1.6.1, Threatened andEndangered Species" No:Federal or State thieatened,
,enidangered, orcandidate species havelbeefnfound to reside onfthe WNYNSC'Sit&'(see hakter, 3,'Section:3: 8:4) thus,th~re would,be no' imipact "to any listed species from the Sitewide Removal Alternativ*." ', ' . . "
How often has the site been surveyed and when was the last time the site was surveyed?
This, survey shlouldhbeprovided so. that:-DEC biologists can' examine it.' Once again, it is.-
somewhat*false to state that becauseno, iste d species were .seen d uing stiveys that they are not present. Cooper's Hawk and Sharp-shinned Hawks are fairly 'regular denizens of wooded areas, and are both listed as state species of special concern. Northern Harriers
,have ýbeen recorded by thed'Breeding Bird Atlas as occurring in this block of habitat, and
'they areý thrreatened. The: best that can be said is that.,impact'to all species willbe:
'minimizedby judicious choice of theperi6d when clearing will, occur..
- Page 4-39, 1" paragraph: "On the basis of this screening analysis, it is concluded that long-term releases from theý Sitewide t16ose4n-Place Alternative (assuming no-untmitigated e'rosion) would not result in ldng'tehfirecological 'consequences. "!",",
, Prepositional" ases.don't belon*,at the st6r of sentences'., ; Samine'domment about'the use
- 'ýof the termmitigktioa:.' r
'It-has been 'concluded;,on 'the'basis of this.screening analysis, that long-'term releases from-th'e Sitewide Close-In-PlaceeAlternative'(assfiihingactive'ero'ion coh" bl continues to take place) would not result in long-termn 'ecbogicalb'don.equences. ' -
- Page 4-39, .411.63-3Atsparagraph: rew tempoiary facilities have tobe'built?
riWhydo
,Shouila explain somewhere 'in theodocument why.:Didnot, notice ianything in'document
- explams the reasorn s)'.-"'n ... f &that
- Page&4-40;,dasttwo paragraphs: , This is the correct Way to talk' abbut' impacts' rather than use the word.. " imtitgate"'
",;Theese factors; plus the,'implementation, ofasite soil erosion, and sediment control: plan,
',wold~hiimlmlze~potentlehia ' direct lmpacts tothe Appalachianftiger beetle' and
'cobblestone tiger b~e6tl&""ý-_' C.'~
Page 16 of 31
Enclosure 2.- SDECNon West etNl Valley No ýs ssigned e Staff-DEIS CommentsrDC "If Phase 2 activities are similar to those undertaken under the Sitewide Close-In-Place Alternative, potential impacts to these,twospecies would be inimized through the 1implementation of the site. erosion and the sedirent contol plan (see Secfion 4.1*62)."
Page 4-41, Historic Resources: "The possibility te-imeaý4 of unearthing previously undetectedsites is~greater nearthebanks of streams and rivers, where previous.
inhabitants tended.to establish selements. . . .
S. Page 4-52, Table 4-15: "Doses are peak annual doses coincident with one-time,,,:
replacement of the permeable treatment wall, if necessary, and include doses conservatively projected. from releases from MAs,,that are notaremoved orclosed-in-place during Phase 1 actions." Add"It's, , . /. ..
a Page 4-52,Maximum ExposedIndividual' Have any, studies been done in the-Cattaraugus Reservation with the Seneca Nation of Indians to determine cancefrates?
Page 4ý-63, Top of page: ,.f or1the No Action Altemative., The peak annual. dose t.
reason ibieseeable offsite forest reasonably.ie~e individuals dule to ,a;.gateda uncontro oled fa eros~ion would be in. rangeof about W t I millirem for both alternatives." ;.
- Page 4-96, 3r paragraph: The volume of high level radioactive waste (500 cubic meters) waste ad if diyided into twosubcategories to'210CubichAneters) does not(2equal an,d transuranicwaste*. 80 qcubictheirmeters) y. , radioactive volume; lowlevel *
- Page 4-97: "Ani additional 3.2 cubic meters (1,10.,eb ).,qLClas s..Aowdlevel, radioactive waste would be generated annually duringmaintenance and surveillance of this orphan waste.',., What is this additional waste?, Contaminated containers, handling
,equipment, leachate, soil,, orwhat . . a
- *Page 4-98, Sitewide Close-In-Place Alternative: Less than 3.2 cubic meters (110 cubic a feet) of CasAowevl radioacive ,we generatedannually during-a
, a maintenance and surveillace ofhli orphan'wast6. )Whatisthenatre of this additional
- Page 4-98, "Phased Decisionmaking Alternative: Less than.orequal; to3 .-2;2cubic meters (110 cubic feet) of Class A low-level radioactive waste would be generated
-annually during maintenance and surveillance of-this:orphan waste"?.Whatis -thenature
- of thiSadd tio'lase ,. .. .4.*,. .. ,a *. ... .. ..
- ,.Page 4A-101, 14.1.12.1!Methodologyand Assumptions:, Shi ppg packa es contaig
'radioactive materials ,emitow,*eelsof radiation; theý,amount of radiation, depends on the kindand amount of transported materials. DOT regulations require that shipping
. packages containing radioactiyve materials have sufficient, radiation shieldingtoqlimit the radiation to 10 millKem per hour at a distance of 2. meters (6.6: feet). from the transporter."
Is "low level" defined and used in the context of what'amount of radiation can get out of a package? Otherwise the first sentence should be removed; just state the regulation.
Page 17 of31
En'l0sure'2T- N:YSDEC Non West Valiey MAsigihed staff DEIs Comimients S Paige 4-107,.4.1.12.4, Sitewlde Close-In-Place Alternative: "If train transport was used,
'th' totalhuinuberdfb shipmens woul be aboUtone-hal of those, m adde undor tiruck-ýonly transport (about 615 shipments)." Which is which? 1230 vs 615 or 615 vs 307.
- Pageb4-109, 4.1.12.5,Phased Decisionmaking Alternative: "If train transport was used, the total number of shipments would be about 6n~-half of those made undertruck-only transport (about 6,300 shipments)." Is 6,300 the bigger number or the smaller number?
- Page 4-113, 4.1.13.2, Long-term Impacts: Have any Siitdies bee6i doneon cari~er rates on the Seneca Nation of Indians reservation? ' .
Page4-114; last paragraph: "boundimi'", USea di"fferent .. word;: maxiniumlargest,' etc?
- Page 4-119, 4.3.4: "The downstream population estimates are also conservative because no credit: is takenfor radiomiclidl remonvalaas pit 'of water tretmenit systems ad it was assumedthat in addition to'direct water'consumption, the water would be used to Irrigate a local garden." Please-explainhowand why'a water freatment srystem takes out-radionuclides. What percentage is taken out?
- 'Page 4-123' 1-~paragrapt:- "Cur~ulatlve impacts can also result from spatial (geographic) and/or temporal (time) crowding of e'nir'o'inmehntal p'ertijibatiis (i.,' conciurrentiuman
- activities and the resulting impacts on the environment are additive iffthere is insufficient timefr thie en.irornment'to-r~cor5.
to b . ' ... ..
- :"Pe6turbations"!, 'Just say'disurbance: The vord is iOret*pcally. Iised to describe a change in the typical/normal movement of a celestial-body. -See previ'ousc6mmients about the readability of the document.
- Page 4-1 23,' 3,- bullet: "...The construction andI operation' of theso faclities would'result in.
a noticeable addition tolocal employment."' Disagree 7thattheoperatlon ofwidpowered electrical generation towers would be a noticeable addition to local employmeint.
Construction is short term and specialized so employment of local citizens at-a noticeable
- l'evel'is also uestiond , ,,.
- Page&4-123 4.5.-1: One impact iot isted from past actios (or inadtion) is the scope of additional contamination that resulted from the failure to clavuptlthe groundwater plume when it was first discovered. The inability of the agencies to agree on cleanup should be discussed' in" this.d'cumnt. How much smaller6woulddthe' .lumebe if r.emediatifi had
', been'ed6ne ina'tim"ely ianner What is the addedL cos ogfthis'filur&e?,
.* .Page41-4-125;,5- bullet: 'Elli'ttville has not issued approvals'foir the conversion to burning wood chips. The proposal appears to be problematic for Ellic-'tivilfe "'
Page,18 of3t
Enclosure 2I NYSDEC Non West Valey Assigned Staff DEIS Comments Page 4-129, 4.5.8, Water Resources: "Decommissioning activities at WNYNSC would not substantially contribute to adverse cumulative impacts to surface water resources, and would generally produce long-term beneficial results afterdecommissioning." How would long term beneficial results occur? Why is there so much discussion about the
, construction* fRo~ute 2 19?. hat peacty does this have to do-with West Valley? Where is the relevance?, ,. -, . - .
- .Page 4-130,. 1..paragaph: "These. actions will result in temporary impacts.to water resources which will. subside once construction activities are complete (USDOT. and NYSDOT 2003b)." There will be permanent impacts resulting from the streams being piped (culverted). Culverts are not the. natural stateý of astream so there will be.
,permanent imp.acts.however minimal. .. ..
Page 47130, 3d paragraph: "'Forexample, redirecting. the runoff into streams having
.higher ratesof flow will result in the contaminants being more diluted and less,likely to impact the, overall water quality:of the stream." ,This sounds good but has the review of the 219 plans indicated this will happen? Moving surface water into different '"sub-basins" can have long term implications-to bothhe watercourse receiving more water
-and the one,receiying. less. The stream.dynamics will change for-both. So.while diluting may have a positive "chemical". aspect there are potentially greater ,negative impacts such as increased erosion, gradient changes, water temperature changes and habitat changes
.rdiated to fish migration, spawning, :makeup of populationsg atd density."
"Page
- 4-132, 4.5.10;,5 th paragraph: Re search has idicated bats do not necessarily have to be 'struk by iotating blades to be killed. A bat's lung is very deicate and can suffer
- .enough-tra'uafrom the change in air pressure aroundda rotating blade to cause the lung
'to henorrAge, killingithe bat. The case`ddesindt aipear to Ibethe same for' ereiitie smallest.of bird which have' more robust lungs. -_ , .. . ,
SPge 4-137, last paragraph "Institutional controls are considaredran im1poriaait pa-t of any alternative, and act to wmitig"e* (reduce or minimize) potential impacts. However, the unlikely6§ss -0f instittitionaltcohnfols woiild potentially- lead-to " uncohtrolled
. erosion, id/lor intruders 'within site boundaresI ana would result in iadi01ogical dose iimpacts to humains: The 'ii" ...
ga"id uncontrolled erosion casd' would lead to doses
, approaching or exceeding 500 millirem pei year for somne individual receptor scenarios.
There is no mention offiuivaslv6 species on-site ncr adis'cussion of preventing tlheir occurrence /spread.
Book: Chap .....
Page 5-1 1"oalitionoWest Valley Nuclea W tes a tive Waste Campaign
-and'DOEStipulaiionof Compromise settlement":. Statds thitaif aaction wkas filed in ey red a stipulatin in987:..Isthat correct?
- Page 5-14: footnote 2 is not shown at the bottom of the page Page 19 of,31
Eiiclosure 2 - NYSDEkC ýN6n,,West:Valley AssignedStaff DEIS Commenits Book:- Chapter6, '
. Page `6-6, 6.4- 3 rd bUllet: "Limit u'nnecessaiyridliig times on diesel-powered ehgines."
New York State ConservationLaw limits the operation of certain on-road heavy duty diesel powered vehicles. Off road vehicles such as earth movers are exempt from the regulation. --Over the road truksg th t t -wouldvisitthe site would, besubject to the 6 NYCRR Part' 217: Motor Vehicle Emissions ',
No person who owns, operates or leases a heavy,duty vehicle ,including a bus or truck, the
,motive power for'whichtisprovitded'by a diesel or non-diesel fueled engine or who owns,
.lases or.occupies'land andhas thelactual or apparent dominiion or -cbntrolnover the operation~ofa-heavy, diitywehice including abusor.truck present on such land-,the motive power for which, sai& heavy *duty'vehicle is provided by a.diesel 6r, non-diesel fueled engine;, shall' allow' or permitthe engine of such heaVy duty. vehlicleito idle for
- ,>i mor*ethan fiVe consecutive-minutes when the heavy.iduty vehicle is notin, motion, except
. . as otherwise ýpermitted by ,sectioni 2,17-3.3 'of this Subpart.,
- ' Pae-7 64, coogca"Rsoces:., 'ýFor,,examnple, ,prior to', land-disturbing activities,
- Page 6-7, 6.5,,E~colo gical,,Resoure>
i Frea
.the proposed site would be surveyed for nests of migratory birds in accordance with the Migratory Bird Treaty Act. Although threatened and endangered species-have not been recorded on the site, any mitigation actions deemed necessary through the consultation processregarding state and federally listed threatened. and endangered:species would be' implemented if such species, were recorded onsite in the future. (Forvapplicable.regulatory requirements, see Chapter 5, Section 5.6.1, Ecological Resources Consultations.)" It is against the law to interfere directly or indirectly with the nesting of any birds covered by the Migratory Bird Treaty Act whetherthey e threatened or endangered or.not...
Page, 6-77 Chapter 6.5,. l1st paragraph:, "For example, prior toq and-disturbing activities, the proposed site would be, surveyed for-nests of migratory birds in, accordance with the Migratory Bird Treaty Act. Although tl1reatened.and endangered sPecies have not ;been
.,recordedon the site, any mitigation actions deemed necessary.through.the'consultation process regarding state and federally listed threatened and endangeredspecies would'be implemented if such spe6ies were recorded onsiteintheTuture., ,.. ,
See comments for Page 4-34, Table 4-9.. It is imperative that the client must insure that all bird species are protected through the Migratory Bird Treaty Act. Throughout this proposal, it is apparent that the only species given serious consideration are .state, listed, species. However, the MBTA prohibits the destruction, harassment, or overall"taking' of "any-bird species. That includes disruption of the nest,.the eggs,, the nestlings, or. the bird itself.,' In other wordsj eve.ry-effort must be madetto minimize harassment of th-e numerous species of birds whichi occupylthe forests im whichwork is proposed,- and all
.bird species must be considered.' '. .
Page 20 of 31
Enclosure.2w- NYSDEC Non WestValley Assigned Staff DEIS Comments
- .,; , Page 6-7,,6.5, 2 d,,paragrqph:: ,Options t9 mitigatedirect impactsto,* etlands.qoquld raiige fomti!e rees~al!ishment of fffect* ad s to t icreai intion ,of* *ewtlands either oi- or off site." Remove the" "after the word 'on..
Book:* Chapter] 1.,...............'4 :,, . .
- Senator Clinton and Representative Reyniolds no longer hold elective office.
Book: Glossary Comments: . "
1,. kpri4 e or ohe.4 ld4 bri Page 8.2, "Bedload"- definition should read as:Soil,rockpartidesOrlothersolidebris moving along the bottom of a stream in traction by rolling, shiding or saltation Oumping),
and in general not supported by the water. .
- ...silt load, carried by suspension." Both clay andsilt ar~ecarred by suspensin.
- Page 8.2, "Besti"Magement Practces,,, first",intence: S Icrlostructuri, 'and inmanagerial techniques, other than effluent limitations, to prevent or reduce pollution of surface water. .,
- Page 3added 3 clay should be tothe dCntttns. Isaciay used in contaimme other specifc ways that should be described? Bentonite, ' to" the Page 8.5, Environmental Impact aement(EIS)", first sentence.: significantly Pag 8.5,Eiiomn a 't a .. ,,n *Ey ,.y.. * ..
affecting the quality of the human environment..,, Shouldn't,it read .... si. szncqntly affectn the 'uality oflhe environment".1 -, , .. " ,,
Page 8.5, "Erosion": should read as: Natureprocesses which include weathering, dissolution, abrasion,corrosion andtransportation,by which materialis wor~n aqr y.n from the earth'ssurface.
- Page 8.8, "Ion Exchange"* Defitition notwell,wttteh; ij .. >; >*.....
- Page 8.9, "Mitigative Measures: Those actions that avoid impacts altogether, minimize impacts, rectity impacts, reduce-or eliminate impacts,or compens ac
'AWilt his ,, . ~ , p c s r o p n at~4 f r, th~e i mip ac .
wiiltisfinition may come out of the dctiona.y an law/regulation is does4 little to S succincly descib.* what is occurringfin ach instance that t USed. S ific ordshould be used: aoid,'reduce, replace, etc. + . .,
,,, d enthssDm Page 8.10, "Modified Mercalli Intensiy Scale"?, , 2, ..sentence, 2 "dparentesis: age9D, total. Shouldis read as- tota[.ddlnmg? .. ,ta- ., 4
' "4 *'?-- ' 4;` ':"!{7; 44¢* 444>4*'ffk.!.
Pg21of 3,1
Enclosure 2 -,NYSDE;C Nn -West Vall'ey Assigned staff DEis Coinfieiint
- Page 8.1 "'oiphan Waste":. Waste *tiat c'anno ciii-rentl* b'edis~psedof in an established
- or planned peimnanefitdispbosal facility'.. Why can 't iitbe dispbsed of. It s hoidnibugh to just say it can't be disposedof,". '.. .
that contains source,
- Page 8.11, "Radioactive Waste", 2 nd sentence: "Waste material special nuclear, or by-product material is subject to regulation as radioa'ctive waste under the Atomic Energy Act." What does "specialnuclear" mean?
Page 8.13, "Silt Load": Clay andsilt are carriedin the suspended load. The defined word should be "SuspendedLoad".
Page 8.13, "Sole Source Aquifers": Poorly written. Should be rewritten.
Page 8.13., "Solid Waste", 2 d definition: ... sludge from a waste treatment plant...
Should readas'..'sludefrom a waste water treatmentVlant.
- Page 8.13, "Solvents": Should include that wateir isthe,un'itve'sa1 solvent.
- Page 8.13: "Special Nuclear" should be added to the list of definitions.
Page 8.14, "Stream Terrace": Originally occurring at or below the level of*the stream, the stream terrace is exposed as stream downcutting occurs. How can it.occur below the level Of thestream. Glaciers areproba. 'bl the most cominmon cause of streamns aggrading.Once the stream bedload returns to non-glacierconditions the stream will cut through the alluvial deposits, degrading. Terraces can then be created.
- Page 8.15: Shouldthere be a definiton for Visitor ?--Individias-on sitef'rreasons such as regulatory oversight, as representativeOf agencies with permit authorttpfor activities on-site.
- There were fourteen references to "clean fill", seventeen to 'clean material" twelve to "other clean material" and tweiity two to "appropriat'ebackfiil 'imateriil"' found ilný' =
Appendix C. Please describe exactly what thesedifferent items are.
, ., ,N" .. . ' . *. ' .
There are twenty eight refeirnces to .contour to'grade". In every case will seeding,
. n. y ce q.
. con . ..... g mulching and erosion control take place. How much time will elapse between the placing of'these various items and seeding and,miilching. Immediately after, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />? .
Page C-63, C3:1.3.1, 3r'paragraph:-"The ýt~ee'shield w*alls ad~'roof of the STS Valve Aisle would be removed remotely using a telescbp'ing'mast equipped 'w'iticutting, grappling, and lifting end-effectors."
Padge22 of23dfi
Enc1osure,2 PYSDEC Non WestXA'11ey Assigned SaffDEIS Comments-effec tori-f-k't~t) n.*
- 1. A niuscle, gland, or Organ capable of responding to a stimulus, especi~ily a nerve 6rg-,
- 2. A nerve ending that carries impulses to a muscle, gland, or organ and activates muscle contrationorglandular secretion,
- 3. Biochemistry A small molecule, thattwhen bound t0an allosteric site of an enzyme causes either a decrease or an increase in the activity of the enzyme. .
Computer Science A device used toproduce a desired change.in an object in
-response to input. ' 'K*.' ., . - .
I,: q~
Used.5 times inthis hendi ile the reieweruýdkerst hatsaid, hiainsdi the word doae's'not's eetdr1i tti-e'use that is int.ended. , : f Page C-,77,, C.3.1.7,6: It is.ntcAear from the description,if all the excavated areas would remain open and then all be filled at one time. Are they all under covei untilithe holes are
- .,
- .:filled?;. .
Page C.3.1.12.3, Railroad Spurs: "The removed rails and tracks would be disposed of as
,construction and. demolition debris."., Ties. typically contain creosote to extend their life.
"Th~ere is noxiention o~f ballastwhicli is' us'e-d to suppoirtite tirack and. ,royidedrainage. Is thereballast, and if so, how, will itbe-diispo's'd'oif, ifa'tall'?.
Page C-134, C.4.4, 1st paragraph: "It would also be capable of receiving wastes in packaged form, decontaminating the packages, if necessary, classifyingthem,,
temporarily storing them, and loading them onto trucks or railcars for-offsite trisport."
Could any; ofthese received wastes come from off-site?
S Page-C434 ,3t paragraph:,` Wstaace? sNo se'f&oor becreated fWrhyce.
piping for potable water? or sewers. d' b- N
- Pag 43i7SC.4' paragraph:.' "AreceivingJock, ,separat~efroffi.the shippindc would also be provided for reception -of prqpqsý, mateffals, such as. emt fboxes aind' drums, and prepackaged wastes." Where would the prepackaged wastes be'c'oming
'from? Anfrom An,' offsite . , ,. ,, ... ", , '
- Pa e 138, C .4.4 2 nd paragraph: "Oneqnponent-ofthewaste retrievalprocess that*
involves a high level of uncertainty is the retrieval of Wastes from the Nuclear Fuel Services deep holes, using primarily a telescoping boom with various end effectors-"
Suggest changing end of sentence to read "...telescoping boom with various attachments/tools at the end."
Page,23, of 31,
Enclosure`2:- NYSDEC dNonWeStValIey Assigned Staff DEIS CoMments Page C-139, C.4.5, 7th paragraph: "In general, sCqblin waste and deni6ciished,,'
equipmefit..." Please use a word that the general public can understand.
- Page C-145, C.4.6.8, 2nd paragraph: This paragraph is also found in C.44 on page C-138. Does not seem to belong here.
- . Page C-150, C.4.8.3: Plants are tia~ious.How will'4 allrfmanner of planitsbe dealt with when they start on top of the cap?
- 4Page C-155," C4.13,'ErosionCiC6htrol Structures: All 6fthe man ihade stcmtures will change the dynamics of the area. What is the projected design life of these structures?
NovVithstanding design life thing's can happen at any time that require4 attention. How will these structures be maintained as everything around them erodes? If not maintained, diversion ditches will immediately begin to be populated by trees and shrubs., Plant litter "wllstrtto fill' the diftctesWhich will get wetter. Eventually, the ditches will be" overtopped during.a storm event, with the bermsultimately breaching."
Straightenig astream entails isieasing the and therefore erosional f6rces.
- Page C-457, Diversion Ditches: What is the "maximum probable flood"? Water Control Structures What is the "maximum probable flood"? . . . "
Page C-i59, last sentence: Finally, the' stiream flow would'be rediverted back to the armored strdambed. There is in discussion'aboutdiverting the stream before'the channel is excavated.. " 4 "" .
Book: AppendixV ':- .4..
- Page D-13, D.3.1.3, Receptor's Ifisid'e ihe: Current Wesern Nel* e*oikNucleair Service .Center Boundary, 2 .dparagraph: "In particular, direct intrusion into buried
- wste*is ass'uimdd' to-not ,dciii the' e because'eroioii-driven exposure of the waste involves development of steep slopes and conc~itratedflow as tfie:ea lnoves within the rim of a creek." Exposure would occur as the creek rim advanced (due to
.ros§ioin)into/t6ward'the Dispo'saflArea. The disposal area would not'move toward the
&.creek ririiTh e creek 'rim moves i t0"the DisposalArea.
Children/teenagers who lived in the house where the excavatiorntok place would'likely be more exposed than their residential farmer farther. Aren't children more susceptible to tte, effects. 'f . rdiatioin/chemicals
.. than 4.- adults? -:- , .444 .
4 '..:-, ',' , .. . 44..
,4 44 4 .44< , -* , , . .
Book: Appendix E P a"., ." .., 4'.
Palsge'e,24.of 31
Enclosureg. 2:-NYSDEC NonWest yalley Assigned StaffDEISComments Page E-33, E.3.4!.,Thick-beddeddUnit,ý, 2 ,ý,paragraph:-, 'These estimates employed .
,artifi'iali neuralnetwork methods. Dgifrom-locations'with both~hydrauhii&conductivity
ýmeasuir&ents and so*i teus Were us&dto train aIRadial"Basis N tvork or RBN,
- networlk Soil texture datfrom locationsl (ythout conduictivi determinations were run then through the trained network to p 'eest'mates f~rose locations. "
Should there be a period to end a sentence after "RBN network" ?
S Page'-33, E.3.4:1, 2 paragraph, lst §sitence: "ITe soil textures for training the network and subsequently predict addition hydraulic conductivities consisted of both
- boratory otermnes textues exten edy estimates f'romite'golog6sts 'using bormg
'log'descripti6ns (Cohen 2006).' Sientence notwe written. -The use 6f thle word'"both" does not seem correct. Should "determines" be determined?
thS.hgeE P h' "aragrap
'We 1locations are scattered 'b6Ut the ste; mostly on
-x:'
he'South' Plateau andt average-distanc' betweenlocations is hundreds of 'feet-likely ofeat sc ture injheiii.9 7' Spataptl.any med sce 'Should it .be exeeing the'scaleofany atial str~ctum structiie? rnte 'the
-patny unit?
- Page E-37, E.3.4.1, 1s paragraph: "Although not completely optimal, sensitivity of model results to changes in the parameter value appears low and the initial i'iputtvalue has not been changed." Should it say, '...even though the initial input value has not been changed."? t.onlusmg.:..) , , * .. .. *.'* : " * : "' ..
Page E-37, E.3.4.1, Slack-water Sequence, 2 nd sentence: Do they mean that only, 12 locations were used after 1999 or were some of the wells plugged?
Page E-37, E.3.4, 1, Slack-water Sequence,, 2 d paragraph, 1' sentence:,. Are they talking
- *abiut data from 12,ells? or 12 piees oMdata7 , r t talkin
' Page E-46, E.3.5, AutomatedCalibration, 3paragraph, 2 sentence: 'The automated-calibrated model yielded the a head RMSE of 4.2 meters and aseeps RMSE of 1.04 kilogram per second, but weighted RMSEs were 5.2 meters and, 1.11 kilograms ppr second, respectively Sh6uld 't be removed 6be in, "yliededjthe a head RMSE"? ..
- Page E-51, E3.7. 1, last paragraph, 2 nd last word on page: "V'Unperturbed" poor word usage given generaiy ceepted'mneaingis. A muuch better-choice wouild be
'Undisturbedl.. ...
- Page E-53, E.31.71, 3r paragraph, 4th sentence: "unperturbed" see immediately above
-or conmment on wordenition. IS hausthor i this case t'ryng to say, am, rodlbased upon nttira I condition's where there ate no human constructed facilities or disturbances on the site?
Page.25 of,3i1
Enclosure 2 - NYSDEC' Non West Valley Assign-d Stgff DEISCbomments
'St Page E-74;E.A.l.2-ls :paragraph: "To representtthese featuies the hydradlic`
conductivities of the tanks and Seidimentsof Lagoonis:2 and 3 are assigned values of hydraulic conductiviy of I x10: centimetersper Second while the combined.,ffee*
effectsý f barriers at Lagoon Al is arerepresented by assigentof a Value of /1< 10 centimeters per secbndtLotemate..ria tLag6on1"'
The phrase "Waste Tank Farm Tanks,"was used 9 times in Appendix. E. the second use of "tanks" didn't seein o fit`Weell in several cases. It'would,be better to leave it out.
Page E-76, E.4.1.3, I paragraph: "The cross-sectional structure of ihe aquife~r is hm represented in Figures -33 through E-36 with the samie vertical discretizationas the listorlcal'conditions case. .. . . .
Page E-76, E.4.1.3: "Flow balances predict flow from the pfie are .fthe . location of the removed Main Plant Process Buildingithrough the slurry wall to the west,,
thatis, toWards theWaste Tank F and fom theearea of the lagoons b6th to the east towards Erdmann Brook and to the west through the slurry wall towards the northern extension of the North Plateau Plume.". This sentence is too long. It should be turned into at least two
'sentences.
Book: Ap e'ndixF F.......
Pg 53, F 25 paragraph' Oe element that would likely bp improved by a more thfeugh thorough calibration approach is the degree of landscape dissection." ng word.
Book: Appendix G A .....
Page "Cumulative imp'acts of a mixture of radionuclides are estimated as the sum of dose or risk..." Has any thought been given to the lIkehohoodthat, when'several contaminants" are mixed together the impact is greater than the sum or has this been disproved in studies. A A . , .
o Page G20,G.3.2.2, Wy seintnce:, o.include
.. ao tumlus coverinang . Iabtisbecgaust Tuimeulusi an artificial hillock or amound ais over 'agrave) esp:pan ancient g tgranve.
- PgeG2, G322~"Te prinay features of the tiunul are soil , aingand,c ay layers designed to minimiz oilw rate of Water reacin g Atew~~om' dle~signed to minimize the amount ofwater penetrating the cover or .. reaching the. Wast. .
- PageA G-23, G.3.213: Why will groundwater flowt6 !hthe tanks? Is tibeaush tim Aei A so long that the tanks have failed or that hole's for ipi ngini the tanks have
- Page G-39, G.4 Intruder Scenario Models: Is an intruder by definition a human? Did not' find "intruder" in glossary. Why use the hiker who comes' once or twice? That seems like Page64 -f3f
Enclosure*2* NYSDECNon,West,Valey Assigned;Staff DEIS Comments a minimal exposure. Why not children playing in the "neighborhood" who are the children ofithe resident farmer, riding-dirt bikes, atvs, and othertypesof play? Are children more inimpacted-by radatio'ananc ical exposures? Children arealso drawn to water, to pay 1 in, buldamsc.-,.'
build etc. i:, v: ,*<
Shouldn't largest accident dose be from a terrorist attack? Or is that not considered in accident catego y Isthere a listing .for,intentional vandalism/terrorism? .-.,,
What about "dumrpster divers' looking for resources? . ",
Book: Appendix H * : .
Page H -25, H.2.2.1, 1st paragraph, last sentence: "While decrease i retention of elements on cement with degradation has been reported (Bradbury and Sarott 1995), high retention of actinide elements is reported for even for degraded cements." This sentence ned obe re'VvMýifttei.`
Page H-25, H.2.2.1, 22ud paragraph,, 2 sentence: "Characterization of grouted materials
'.n
hns estasnibliahed tceium and stronnum nprimarily.
are retameo Ion the .
aggregates diiueithe concrete (add '," or,ený sentence eih) *hwle other elements are retained bo. bte ont aggregate and on the caIcumm sihet hydiogelmatnix o-fthie concrete (Stinton et al. 1984)" ,. .,:
- Page 11-2S, 11.2.2.1, 3-u ara Ai~ Prepositionalph
, pagrp: Pep pases at the begming of sentences make them awkward and harder to understand.
- Page H-26, H.2.2.2. 1, Total Effective Dose Equivalent, 2 nd paragraph, 2 d sentence: ,
'"There is an earlier, subsidiary SDA peak occurring at about 1,000 years, and a few minor peaks associated with the." The sentence, needs ve,,sass~me,**,se nnenetobe ce finished., i. .',: .
- ~~ ~ I ~ ~"q, ~ ~ ~ ' I it
.2.2'.iH-iad idx ootnote .73-,etne ge1433ý fthazardquotientfo an individual chemical Or6the hazardquotientforagrouP of chemicals,exceeds unity, the chemticals,) may produce andgadverse effect, but,normally this will require,a hazard index or quotient ofseveral times uni." The word "and" should be changedto, "an".
Pag5, H--
11212; , 1tnc:,,
. - 2s ,.satdoesa Seneca Nation of.Indian receptor mean?
IsthereceptoramemberOf the Seneca Nation?, There are CayugaNation members that live on Seneca Nation land. Please see all other "Seneca Nation of Indians receptor".
- '", Page H-35, H.2.2.2.2,.,S. paragraph, 2 sentence: Theiuseof theword. 'raised';imeans that someone/somethighas taken an active role inat least part ofthe-life cycle of the fish that are being consumed. Fish are not normally, raisedjin Cattaraugus,.Creek:,.Fish found in Cattaraugus Creek typically are raised in a hatchery and then stocked or are native to the creek. The word should bechangedto."hving aandior stocked" .,,The word "raisd"is used seven times in this appendix. . ' " "
Page: 2'7 of 31
Enlosure 2-*,NYSDEC Non*West'Valley Asiglied Staff DEIS Comme'nts Page H.:51,* H.2.2.3.3, Total EffrctiVe Dose Equivalen't, 3r paagraph 1st sentence: "The
. results presented in Table H147 show that the totalpeak armual 'dose to the Cattaraugus Creek receptor due to'groundwater releases would 4b* below'25 mili.iem per ye6ar for both alternatives." Remove single letter "s".
- Page H-53,;.2.2.3.3, 16 sentencf Noperiod afthe end 6fthe sentence.
Page ControalngNhelid~san'dPathways, d-54, P.2.2.3.3, 1st paragaiph, 1 sentence:
The sentence starts "It is of interest...." It is of importance or necessary to understand.
- Page 11-57, 11.2.2.3.3, Hazard Index, Table H-52, footnote a: Why does the, "*imiimted information ... suggest. ... ,'? What is this base on? Lack of information means you should Plahnor worst case'.
Page H-58, H12.2.3.3,Table iI-53, footnote b: Same comment as immediately above about "limited information".
- ...... Page H-61', H.2.2.3, last sentence: "'For the No Action Altefatlve,.the prcipal difference from Cattaraugis Creks that the dominant nuclides and pathways for the principal contribu~tor (the Wdase TfiFarkFi)m is now strohtiuni-9O, via~ fish rather than via drning wa
"Difference from Cattaraugus Creek"?? Is it supposed to mean the dominant pathway for strontiumi-90 in Cttaraugus'Creel is now fish rather than dinkig water?
Book.-: Apendix T Page 1-13, 1.4.3 2,1i'st seatence: "Sourceterni(s) (thati is,,the'quantities of radioactive material released to the environment over a given period) for the No Action Alternative normal, operational releases were based on .release quantities identified in Ahniial Site Envronme'intaaR+epors, which can be" fo6ud on' the Ik6ternet at Www.wv.de.gov and are suminarieddin a technical reporti'(WSMs'2008e)." This is ones nce. Itn*
stafes that Aual ,Site Environment Reportscaii'be fobuind on the internet: and that they are summarized in WSMS 2008e. The single sentence is misleading since one would expect
`6" evei'thuigiiithe sentence to th'lie inrtcet. Since the summaary 1snbt on the net it
. sh6uld'tell'the'reader wher get it."",
Page 1-18, 1.43.5: The paragraph states that an MEI is a member of the Seneca Nation of
.I'n'IdiL dans.' The statement should alsoidentify th&p ssibility that it could be,a member of
'teCyuga~Nto ri oa enh ie~'a i~ Notal oad Ntiiv Americ is~ living
.. on--Seneca Natlon~landare enecas.+ .... .... . , ..
Page 1-20,.I4.3-6, 1 -fullt ar'gph: -.same comment asilmmediately above regarding Cayuga Nation members "'
6f 31 Page6`. 8 o
Enclosure,2-. NYSDEC Non Westalley, Assigned Staff DEIS C6mments,
- Page 1-22, 1.5.3: Why does the list only identify structural failures from seismic activity?
,Were other weather relatedpevents such ashpeayyý snow load or high~wifds or possibly tornadoes considered?
- ... Page I23, I.5.3: "Chemicals ,at the WYDPR inended for'decommissioning activities are notcapable ofr.eaction with chemicals already at theW*DPL or with each other-in such a way that could initiate, any accident releasing radionuclides.,. , .
- Page 1-23, 1.5.3,ý3ad paragraph: .,"'The seismic eventfis als6 assumedjto fail any isolating or confinement covers around the high-level radioactive !waste tanks.". ,:.. .K SRewrite to,read: The seismic!eyent is, also, assumed toi cause anny isolatingh or confinement; covers around the,high4-level radioactive waste tanks to fail.,,.:.,:,
The,,seismiceventis also assumed to compromiseanylisolating or dconfmement covers around the highlev el radioactive waste tanks.. , ; . . . :... ... '
- Page 1-41, 1.5.8, last paragraph, 5t line: "For the chemIc" listedin Table "
Should be Table 1-28 Book"AppendixJ.:*. :
PPage J-33, J. 11.4, last paragraph, st sentence: What does "State-of-the-art computer codes" mean? :Codes-for-what 7 ,' ' A".
.Book: AppendixK.)#i,ý,,,,ý
- Page K-1, K. 1, ISt paragraph, 2 nd sentence: "Air quality impacts were assessed by
- ..?estimatingonsite' and'offsite conc'efitrati6nso'f criteriaahd tokic aii lli1itantS of.-.-"'
- environmintal concemnaiidicomparig themto Federal.and State health-base'd ýambient air quality, standards.,ý
- What doesthie tunderlinied, mean? A: 3/4 ,1 Q' Ar r, t Y ,
Page,;P qf.4,1
Enclosure '2- NYSDECNbn MWest Valley Assigned Staff DEIS Comments Book: Appendix M
ý*
Page M47 , M.4.2ý 2nd to 4lastpargraph:,The Word'mitigate' is uisd in'th6broad'sense.
A much better choice would be "minimize.
- Pge M-'12, M.3112:. Thed word "buffer",.whfile iti fay~bedescriptive;. is not usedin the regulations. The proper is "adj dterm aent area", which i's usediiff the regulation, 6, NYCRR Part 663.2(b).,5 The&adjacent area is atleast. 100 feet Wide buVmay be broader where necessary to protect and preserve a wetland. The word "buffer" was used six
. Atimes in this appendix.,, Five of those usages were with regard t6 NYS freshwater .
wetlands and should'be corrected. . ' .. .
- *, .*Page'M-1,1M.5;3*:2.1:, *Last sentenace:*. ,"Additionally, the&loss of inf*titution'al* *controls leading to unmitigated erosion of theNDA and"SDA(ie.;no credit i'"..takenf.o.
monitoring and mainitenance of erosion control structures) is analyzed.in Appendix H."
Is the sentence. intended to say "uncontrolled" erosion?
- - It is not clear, if the ýsectibn!states .thatCorps Permitsi would be -required.for federal wetland disturbances (when they are not state wetlands).:Additiohally; the Corps'may require. Water Quality Certification be issued by New York State if the activity has not beelapre-certified by the DEC.,. .
- Page M- 6, M.4.1, 4 th paragraph, 2 nd sentence: "These measures include adherence to the State Pollutant Discharge Elimination System (SPDES) General Permit for
- construction activities occurring in an area of five acres or greater." The area subjectito
- regulation under this program is now one acre or greater..
- Page M- 17, M.4.2, 1 St paragraph:, "A Sitewide Stormwater Pollution PreventionTPlan for controlling runoff and pollutants from the site during and after construction activities would be required to obtain permit coverage under NYSDEC's General Permit *(GP 0+) for Stormwater Discharges from Construction Activities." Replace withGP0-08,-
001
- Page M-7, M.4.2, 2. paragraph"*Prior to the disturbance of anyywetland, a Section 404
.permit would' be acquired fromi -the US. Army Corps of Engineersalong with a Section 401 Water Quality Certificate from the State of New York,"! This statement is" misleading. In cases where a Corps Nationwide Permit has been pre-certified by New York State an individual Water Quality Certification is not required, Book: Appendix N Page N-1, N.2: Explosive devices are discussed but it is not clear if a scenario with a fire is part of any of the on-site scenarios. (Fires are discussed in transportation situations)
Would a fire that could not be controlled by water (phosphorous?) with a resulting smoke plume disperse more material over a greater area?
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Enclosure 2 - NYSDEC Non West Valley Assigned Staff DEIS Comments Book: Appendix P Page.P-2, P.3, recreational hiker: Why was this class of individual chosen? Was it for the type of activity or for the location that the activity takes place? If it was for the activity one would think the exposure was minimal and why bother except to show the small amount of exposure. If the attempt was to find some type of individual that would be in a specific location then there is a better choice. Children/youths would likely be in the same area and could have potentially more exposure by operating off road vehicles or playing in the stream.
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