Enclosure 

TECHNICAL EVALUATION REPORT 

Background

Decommissioning of the West Valley Demonstration Project (WVDP) is conducted under the 

1980 West Valley Demonstration Project Act (WVDP Act). The WVDP Act requires the U.S. 

Department of Energy (DOE) to decontaminate and decommission, in accordance with any 

requirements prescribed by the U.S. Nuclear Regulatory Commission (NRC), the waste storage 

tanks and facilities used in the solidification of high-level radioactive waste, along with material 

and hardware used in connection with the WVDP. The NRC responsibilities under the WVDP 

Act include the prescription of decommissioning criteria, informal review and comment, and 

monitoring. 

Under the authority of the WVDP Act, NRC prescribed its License Termination Rule (LTR) as 

the decommissioning criteria for the WVDP in a Policy Statement issued on February 1, 2002, 

(67 FR 5003). NRC prescribed the LTR as the decommissioning criteria for the WVDP, 

reflecting the fact that the applicable decommissioning goal for the entire NRC-licensed site is in 

compliance with the requirements of the LTR. For purposes of this report, the NRC-licensed 

site is considered to be the West Valley Site excluding the State-licensed disposal area. DOE is 

obligated under the WVDP Act and associated DOE-NRC Memorandum of Understanding 

(MOU) to submit a Project Plan for NRC review and comment. DOE previously submitted a 

portion of the Project Plan which did not include post-operation decontamination and 

decommissioning of project facilities. The Phase 1 Decommissioning Plan (DP) for WVDP is 

considered part of the Project Plan. Specific provisions of the MOU provide that the plan “... 

contain the level of detail generally associated with conceptual design of structures, systems, 

and components” and “[a]s the project continues and more precise information is developed, 

that information will be submitted to the NRC prior to the beginning of project activities for which 

the information is relevant.” The MOU also provides that “[i]n preparing its comments, the NRC 

will specify with precision its objections to any provision of the plan.” 

The proposed action in the Phase 1 DP is based on the preferred alternative (Phased 

Decisionmaking) in the Environmental Impact Statement for Decommissioning and/or LongTerm Stewardship at the West Valley Demonstration Project and Western New York Nuclear 

Service Center (DOE, 2008b and 2010) (EIS). In general, the preferred alternative involves 

near-term decommissioning and removal actions where there is agency consensus and 

undertakes characterization work and studies that could facilitate future decisionmaking for the 

remaining facilities and areas. Under the preferred alternative, decommissioning would be 

accomplished in two phases. Phase 1 decisions would include removal of all Waste 

Management Area (WMA) 1 facilities, the source area of the North Plateau Groundwater Plume, 

and the lagoons in WMA 2 (see Figure 1). Phase 1 activities would also include additional 

characterization of site contamination and studies to provide information in support of the 

technical approach to complete site decommissioning. Phase 2 decisions involving 

decommissioning or long-term management decisions for remaining facilities including the 

Waste Tank Farm and support facilities, non-source area of the plume, and disposal areas 

would be made within 10 years of the EIS Record of Decision (ROD) if the Phased 

Decisionmaking Alternative is selected. If a different alternative is selected, the WVDP DP 

would need to be revised and re-submitted for NRC review. 
2 

This Technical Evaluation Report (TER) documents NRC staff’s comments on the Phase 1 DP 

for WVDP. The TER also includes NRC’s determination of whether the proposed action in the 

Phase 1 DP satisfies the decommissioning criteria. As such, NRC’s review of the Phase 1 DP 

focuses on information relevant to assessing whether the decommissioning criteria have been 

met (such as, planned decommissioning activities, radiological status of facilities, dose 

modeling, and final status surveys). In this review, NRC specifically evaluated how previous 

request for additional information (RAI) have been addressed in the revised Phase 1 DP 

(Revision 2). Each section of the TER describes NRC’s evaluation and conclusion. In some 

cases, comments are identified for DOE to address in the course of Phase 1 decommissioning 

activities. NRC also recognizes, based on past discussion with DOE, that certain operational 

matters related to decommissioning are appropriately addressed by DOE regulations and 

Orders and are not within the scope of NRC’s review. These operational areas include DOE 

programs related to project management and organization, health and safety, environmental 

management and control, and management of radioactive waste. 

1.0 Executive Summary and Introduction 

Executive Summary and Introduction - Evaluation

The “Executive Summary” section provides an overview of the requirements of the WVDP Act, 

and the proposed decommissioning approach for the WVDP Site (Project Premises). It includes 

general information on the decommissioning criteria, the licensee and owner of the site, WVDP 

facilities, and nature and extent of contamination of those facilities. It also provides general 

information on As Low as Reasonably Achievable (ALARA) evaluations, the time frame for the 

initiation and completion of Phase 1 decommissioning activities, and post remediation 

monitoring activities. 

An “Introduction” section provides background information pertaining to the WVDP. It 

addresses the purpose and scope of the Phase 1 DP, its relationship with the EIS and the 

general responsibilities of the organizations involved. It also introduces the content of this DP, 

site conditions at the start of Phase 1 decommissioning work, and describes the relationship 

between Phase 1 and Phase 2 decommissioning. 

Executive Summary and Introduction - Conclusion

NRC has completed a qualitative assessment of information in the “Executive Summary” and 

“Introduction” sections of the Phase 1 DP for the WVDP Site located at the Western New York 

Nuclear Service Center (West Valley Site) according to the Consolidated Decommissioning 

Guidance, Volume 1, Section 16.1 (Executive Summary). Based on this assessment, NRC 

concludes that the Executive Summary and Introduction sections provide useful background 

and overview information that serves to introduce subsequent sections that contain more 

detailed information. 

Comment: Subject to the EIS ROD, DOE expects Phase 1 decommissioning activities to 

begin in 2011 and to last approximately 8-10 years. To meet this aggressive schedule, 

Phase 1 evaluations and studies need to be identified, scoped and implemented early in 

Phase 1 to ensure that results are available in a time frame that supports making a 

technically sound Phase 2 decision. NRC expects to be able to provide 
3 

recommendations on the scope of the evaluations and studies and to be kept abreast of 

the results of the analyses as they become available. 

2.0 Facility Operating History 

Facility Operating History - Evaluation

This section provides a summary of (1) the license history including the radionuclides present 

and how they were used both under the license and under WVDP activities; (2) previous 

decontamination and remediation activities and those planned activities to be completed prior to 

the start of Phase I decommissioning; (3) previous radioactive spills or releases, and (4) prior 

onsite burials of radioactive materials within the scope of this plan. 

Facility Operating History - Conclusion

NRC has reviewed the information in the “Facility Operating History” section of the Phase 1 DP 

for the WVDP Site according to the Consolidated Decommissioning Guidance, Volume 1, 

Section 16.2 (Facility Operating History). Based on this review, NRC concludes that DOE has 

provided sufficient information on the facility operating history to serve as a basis for evaluating 

the accuracy of the descriptions of the radiological status of the WVDP Site. 

3.0 Facility Description 

Facility Description - Evaluation

This section provides site-specific information describing the facility and environs relevant to 

DOE’s estimation of impacts of: (i) the doses to onsite and offsite populations from Phase 1 

decommissioning activities; (ii) the proposed decommissioning activities on the site and 

surrounding areas; and (iii) the environment on the site (e.g., in the events of floods, tornados, 

and earthquakes). 

This section provides information on the location and description of the WVDP Site and 

environs. This information includes a description of: (i) the current population distribution; (ii) 

summary of current and potential land uses; (iii) site meteorology and climatology; surface water 

and groundwater hydrology, geology and seismology; and (iv) the natural resources in the area. 

Facility Description - Conclusion

NRC has reviewed the information in the “Facility Description” section of the Phase 1 DP for the 

WVDP facility according to the Consolidated Decommissioning Guidance, Volume 1, Section 

16.3 (Facility Description). Based on this review, NRC concludes that DOE has provided 

sufficient information on the description of WVDP Site and environs to serve as a basis for 

evaluating DOE’s estimated doses from Phase 1 decommissioning activities. 
4 

4.0 Radiological Status of Facility 

Radiological Status of Facility – Evaluation

The WVDP Phase 1 DP presents characterization data resulting from a 2004 West Valley 

Nuclear Services Company “Characterization Management Plan for the Facility Characterization 

Project.” Several inventory reports and data from routine radiological protection surveys were 

also used to identify radiologically impacted areas of the WVDP Site. 

Characterization data for environmental media were provided based upon routine reports from 

WVDP Environmental Monitoring and Groundwater Monitoring programs. Additional site status 

information has been provided in the “West Valley Demonstration Project North Plateau 

Background Soil Characterization Report (WVDP-493, Rev. 2).” To support Phase 1 

decommissioning, DOE states that additional environmental characterization will be performed 

in accordance with the “Characterization Sample and Analysis Plan (CSAP)” currently under 

development. Section 7 “Planned Decommissioning Activities” and Section 9 “Facility Radiation 

Surveys” of the Phase 1 DP define the outline for additional environmental characterization. 

NRC understands that the CSAP will provide further details on characterization of soil, stream 

beds, and banks, and will support waste management activities to be performed at the WVDP 

Site. 

Radiological Status of Facility - Conclusion

NRC has reviewed the information in the “Radiological Status of Facility” section of the Phase 1 

DP for the WVDP according to the Consolidated Decommissioning Guidance (NUREG-1757), 

Volume 1, Section 16.4 (Radiological Status of Facility). Additional supporting information in the 

“Introduction” and “Facility Operating History” sections of the DP were also reviewed. Based on 

this review, NRC concludes that DOE has described the types and activity of radioactive 

material contamination at the facility sufficiently to allow NRC staff to evaluate the potential 

safety issues associated with remediating the facility. NRC has determined that the remediation 

activities and radiation control measures proposed by DOE are appropriate for the type of 

radioactive material present at the facility. 

5.0 Dose Analysis 

5.1 Unrestricted Release using Site-Specific Information 

Overall Conclusions

NRC has reviewed dose modeling analyses for Phase 1 of the Phased Decisionmaking 

Alternative as part of its review of revision 2 of the DP, using the Consolidated 

Decommissioning Guidance, Volume 2, Section 5.2 (Unrestricted Use Using Site-Specific 

Information). Based on this review, NRC concludes that dose modeling performed to calculate 

derived concentration guideline levels (DCGLs) or clean-up levels for various contaminated 

media present at the WVDP Site is generally acceptable and provides reasonable assurance 

that the dose to the average member of the critical group is not likely to exceed the 0.25 mSv 

(25 mrem) annual dose criterion in 10 CFR 20.1402 for source areas that are the subject of 

Phase 1 remediation. This conclusion is based on review of dose modeling analyses performed 

by DOE, as well as independent analysis performed by NRC. 
5 

Constraints on Partial Decommissioning 

As stated above, DOE’s DP as supplemented and revised through responses to RAI (DOE 

2008a, 2009a, 2009b, 2009c, 2009d, 2009e) issued by NRC (NRC, 2009), used defensible 

assumptions and models to calculate the potential dose to the average member of the critical 

group. Sufficient information was provided to allow an independent evaluation of the potential 

dose resulting from the residual radioactivity after remediation and reasonable assurance that 

the decommissioning activities will comply with radiological criteria specified in the LTR found in 

10 CFR 20, Subpart E, for unrestricted use. However, because WVDP decommissioning 

activities will result in partial clean-up of the site only, at the end of the phased 

decommissioning, DOE must ultimately demonstrate that decommissioning criteria are met for 

the entire West Valley Site, including previously remediated areas. Because DOE is aware that 

it must address the cumulative impacts of all source areas on entire West Valley Site to 

demonstrate compliance with LTR criteria and has considered this in its development of DCGLs 

for Phase 1 (see discussion in DP Section 5.3 [DOE, 2009e] and DOE response to NRC RAI 

5C1 [DOE 2009c]), the risk of having to perform additional cleanup due to the phased 

decommissioning approach taken is reduced. Nonetheless, if previously cleaned areas become 

re-contaminated, the collection of additional information during the ongoing assessment period 

reveals that risks are significantly underestimated, or modeling assumptions otherwise become 

invalid, NRC expects that the impact of these events on the ability of the site to meet LTR 

criteria will need to be re-evaluated. As such, NRC will be particularly interested in the types of 

monitoring activities and studies that will occur during the ongoing assessment to ensure that 

risks are appropriately managed and studied. 

 

Comment: If previously cleaned areas become re-contaminated, the collection of 

additional information during the ongoing assessment period reveals that risks are 

significantly underestimated, or modeling assumptions otherwise become invalid, NRC 

expects that the impact of these events on the ability of the site to meet LTR criteria will 

need to be re-evaluated at the time of final decommissioning. 
6 

Figure 1 Site Map Showing Areas to Be Remediated in Phase 1 
7 

5.1.1 Dose Analysis Overview 

DOE developed three sets of DCGLs to guide remediation of the site during Phase 1 of the 

Phased Decisionmaking Alternative including: (i) subsurface soil DCGLs to guide cleanup of 

WMA 1 and WMA 2 soils; (ii) surface soil DCGLs to guide cleanup of areas of the Project 

Premises with surficial contamination less than 1 m (3 ft) in thickness; and (iii) streambed 

sediment DCGLs to guide cleanup of portions of site streams located on the Project Premises 

(e.g., portions of Erdmann Brook and Franks Creek). Subsurface soil DCGLs would apply to 

residual soil contamination located at the bottom of planned soil excavations in WMAs 1 and 2 

only. The soil excavations will extend to at least one foot (0.3 m) into a relatively impermeable 

lavery till located around 10-15 m below grade in WMA 1 and this area will be backfilled with 

clean soil following remedial (excavation) activities1

. Figure 1 shows the locations on site where 

Phase 1 clean-up activities are expected to occur. 

Figures 2 through 4 illustrate the basecase conceptual models for DCGL development. These 

conceptual models are implemented in the RESRAD computer code. Therefore, the site 

conceptual models are parameterized consistent with the pre-defined conceptual model in the 

RESRAD computer code. In some cases (e.g., for some alternative conceptual models), 

additional mathematical tools are needed to evaluate potential transport mechanisms or 

processes that are not evaluated by the RESRAD computer code (e.g., diffusive transport of 

residual contamination from the lavery till at the bottom of the WMA 1 and 2 excavations into the 

overlying initially clean backfilled excavations on the North Plateau where a domestic well could 

be used)2

. 

Figure 2 shows the geometrical configuration of surface soil contamination expected to be less 

than 1 m (3 foot) thick. The resident farmer scenario is selected as the critical group for surface 

soil DCGL calculations. The resident farmer engages in various activities that lead to 

radiological exposures including residing and working in contaminated soils, growing and 

consuming produce grown in contaminated soils, and consuming contaminated 

animals/products. The resident farmer is also assumed to use a well for drinking water and 

irrigation purposes that may lead to secondary (water dependent) sources of soil contamination, 

as well as exposure to the receptor through the drinking water pathway. General pathways of 

exposure include external gamma exposure, inhalation, and ingestion (e.g., drinking water, soil 

[incidental ingestion], produce and animal/products). For a complete list of exposure routes and 

pathways see Table 5-2 in Revision 2 to the DP (DOE 2009e). 

 

1

 The depth of the excavation and expected amount of residual radioactivity is more accurate for WMA 1. 

The lavery till is shallower in WMA 2, such that the excavations may only be around 4-8 m (12-26 ft). Due 

to the assumed dilution factor of 10 due to mixing of clean backfill material with contaminated material 

during an intrusion event, residual contamination located at the bottom of the excavation may only be one 

tenth of the excavation depth or around 0.4-0.8 m (1 to 3 ft) or less in thickness in WMA 2 to be 

consistent with dose modeling assumptions. 

2

 RESRAD includes a leaching code that considers the transport of contamination from the unsaturated to 

the saturated zone rather then the transport of contamination already located within the saturated zone. 

Diffusional processes that are expected to occur due to the concentration gradient between the residual 

contamination located in the relatively low permeability lavery till remaining at the bottom of the soil 

excavations and the initially clean backfill cannot be modeled using the RESRAD code. 
8 

The site hydrology is depicted as having an unsaturated zone 2 m (6 ft) thick below the 

contaminated zone. Because RESRAD treats erosion as a removal mechanism (because the 

RESRAD code estimates dose for onsite receptors and eroded material is expected to be 

removed from the source area and deposited in downgradient or offsite locations), DOE 

conservatively3

 assumed no erosion. Separate analyses were conducted to study the potential 

impacts of erosion on on-site and off-site receptors (e.g., receptors located in the vicinity of 

gullies or utilizing surface water impacted by eroded material). Contamination is also assumed 

to leach out of the contamination zone into the underlying saturated sediments on the North 

Plateau such that the resident farmer could extract contaminated groundwater for the purposes 

of drinking water and irrigation. 

Figure 2 Conceptual Model for Development of Surface Soil DCGLs 

 

3 The term conservative is used here to imply that the assumption is expected to lead to a higher, rather 

than lower, estimation of the potential dose with all other factors being equal. 
9 

In the case of subsurface soil DCGLs, DOE considered the types of initiating events that might 

occur that could lead to the redistribution of buried subsurface soil contamination4

 to the ground 

surface such that a resident farmer scenario similar to the scenario evaluated for the surface 

soil DCGLs would apply. Because excavation of soils for the purpose of building a basement 

would not be expected to uncover contamination located at least 4 m (12 ft) below grade, this 

scenario was eliminated from consideration. Instead, construction of a cistern or large well is 

assumed exposing a receptor to contamination originally at depth then relocated when 

contaminated drill cuttings are brought to the surface and deposited over some nominal area 

(e.g., basecase scenario assumes a 100 m2

 area with a contaminated zone thickness of 0.3 m) 

and subsequently used to construct a residence and garden. Figure 3 depicts the primary 

conceptual model developed for subsurface soil DCGL development. Exposure pathways for 

the basecase scenario are listed in Table 5-4 in Revision 2 to the DP (DOE 2009e). 

Figure 3 Conceptual Model for Development of Subsurface Soil DCGLs 

 

4

 Subsurface soil DCGLs apply only to WMA 1 and 2, as deep soil excavations are planned for these two 

source areas. The subsurface soil DCGLs will apply to the bottom and sides of the excavated areas. 

Clean material will be used to backfill the soil excavations, such that the subsurface contamination will 

initially be located at significant depths 4-15 m (12-45 ft) below grade following remedial activities. 
10 

Finally, DOE developed DCGLs to guide remediation of Project Premises streambed sediments. 

Because it was not deemed practical to build a residence on streambed sediments given the 

current topography of steeply sloped stream channels, a residential scenario was not evaluated 

when developing streambed sediment DCGLs. Instead, the use of site streams for recreational 

purposes was considered a reasonably foreseeable land use in deriving streambed sediment 

DCGLs. Recreational activities include hiking over contaminated sediments, fishing from 

contaminated streams, hunting deer for venison contaminated from foraging (grass 

consumption) and water consumption near site streams, and incidental ingestion of 

contaminated sediments and surface water. For a complete list of exposure routes and 

pathways see Table 5-6 in Revision 2 to the DP (DOE 2009e). 

Figure 4 depicts the conceptual model for streambed sediment DCGLs. As shown in Figure 4, 

the contaminated zone is assumed to be 1 m (3 ft) thick. The contaminated area is assumed to 

be 1000 m2

 and consistent with the default (circular) geometry in RESRAD. Sediment 

contamination is assumed to be in equilibrium with surface water using distribution coefficients 

consistent with lavery till sediments (simulated as leaching with an infinitely small vadose zone 

in RESRAD). 

Figure 4 Conceptual Model for Streambed Sediment DCGL Development 
11 

5.1.2 Source Term 

Source Term—Evaluation

DOE provided information pertinent to developing the source term including nuclides of interest, 

expected depth of residual contamination in existing source areas, and justification for assumed 

subsurface soil source configurations (geometry of contaminated zone and garden) following 

various intrusion events5

. Based on an NRC RAI (5C2), DOE also provided additional 

information on the screening approach used to identify 18 key radionuclides targeted for DCGL 

development. In some cases, radionuclides were eliminated from detailed study due to their 

relative activity levels compared to other “similar” radionuclides. The basis for elimination of 

some of these “similar” radionuclides is not clear. 

Information on surface soil, subsurface soil, and streambed sediment contamination is limited. 

Therefore, several NRC RAIs (NRC, 2009) were also directed at DOE’s efforts to verify 

underlying source assumptions used to derive DCGLs (e.g., RAIs 4C1 and 5C9 regarding 

confirmation of vertical and lateral extent of contamination). DOE agreed to verify dose 

modeling assumptions in the field and committed to providing a characterization plan for NRC 

review. DOE noted that the surface soil DCGLs would only apply to areas of the WVDP Site 

determined to have no subsurface soil contamination (i.e., subsurface contamination extends to 

depths greater than 1 meter), because DOE does not plan to modify its surface soil DCGLs as it 

may impact the design of the Phase 1 Final Status Survey (FSS) and considers the 1 m 

assumption to be conservative. DOE also committed to performing in-process surveys at the 

bottom of WMA 1 and 2 excavations and along H-piles (that provide support for the Main Plant 

Process Building) that may serve as a preferential pathway for contaminant transport in the 

lavery till. While DOE does not intend to remediate streambed sediments at this time (which 

would require a revision to the DP), DOE also noted its intent to verify dose modeling source 

assumptions in the field and revise DCGLs as necessary (see response to 5C13 [DOE 2009b]). 

NRC also requested additional information regarding the use of surrogate radionuclides as DOE 

provided insufficient characterization to determine the homogeneity of radionuclide 

concentrations in the field. Because variable radionuclide ratios are expected over space given 

the length of time that has passed since releases have occurred (e.g., faster transport rates of 

more mobile species compared to easy to detect surrogate radionuclides such as Cs-137 would 

lead to variable ratios along the flow path), additional data collection would be necessary to 

support use of surrogate radionuclides to demonstrate compliance with LTR criteria for 

subsurface soils. In response to RAI 5C9 (NRC, 2009), DOE indicated that based on available 

data it was doubtful that radionuclide ratios would be consistent enough to permit use of an 

easy-to-measure surrogate radionuclide to identify the concentrations of Sr-90 which available 

data suggest will be the dominant radionuclide at the bottom of the excavations. 

DOE also provided sufficient information regarding the chemical characteristics of the waste 

including background information on chemical processes that might influence radionuclide 

transport in the environment. DOE provided a comprehensive summary of available sitespecific data on distribution coefficients for key risk drivers at the site that are expected to 

 

5 Because DOE assumed buried subsurface soils were brought to the surface in its basecase DCGL 

calculations, certain assumptions regarding the distribution of the subsurface material on the surface 

were necessarily made to estimate potential dose consequences. 
12 

significantly reduce the uncertainty associated with DCGL development. DOE performed a 

comprehensive sensitivity and uncertainty analysis to ensure that DCGLs adequately accounted 

for uncertainties in chemical characteristics of the waste, as well as assumptions regarding 

source geometry (e.g., area and thickness). 

Source Term—Conclusions

DOE provided sufficient information regarding the physical and chemical characteristics of 

residual radioactivity including information regarding chemical processes used in the 

reprocessing and stabilization of spent nuclear fuel that is the major source of contamination at 

the site. A fair amount of site-specific information is available regarding the expected 

attenuation properties of radionuclides in the natural environment. As the uncertainty 

associated with transport of contaminants in the environment can drive the risk for any given 

site, the reduction and management of this uncertainty with site-specific information and 

probabilistic analysis (discussed below) is considered by NRC to be of significant benefit in 

constraining the dose predictions for key risk drivers at the West Valley Site. 

Regarding subsurface soil clean-up in WMA 1 and 2, if in-process survey results reveal 

significant subsurface contamination not considered in DCGL development, the risk significance 

of this contamination should be evaluated and appropriately managed. Therefore, NRC has the 

following comments. 

Comment: Dose modeling assumptions regarding the lateral and vertical extent of 

contamination needs to be verified in the field. If significant deviations exist, DOE needs 

to: (i) evaluate the risk significance of these deviations; and if necessary; (ii) revise the 

DCGLs; or (iii) apply the DCGLs to just those areas of the site where the dose modeling 

assumptions are valid. This comment applies to surface, subsurface, and streambed 

sediment soils. 

Comment: If DOE chooses to use surrogate radionuclides for the FSS, sufficient 

information (characterization data) needs to be provided to ensure that use of surrogate 

radionuclides will not lead to a significant underestimation of the potential dose 

associated with residual contamination at the site. 

5.1.3 Critical Groups, Scenarios, Pathways: Identification and Selection 

Critical Groups, Scenarios, Pathways: Identification and Selection—Evaluation 

In deriving DCGLs, DOE considered reasonably foreseeable land use scenarios including 

various rural, residential scenarios (i.e., resident farmer and gardener) for development of soil 

DCGLs. DOE also considered other processes that may lead to exposure to a potential 

receptor including erosion. In some cases land use was assumed to be limited given certain 

characteristics of the site (e.g., topography). For example, a recreational receptor was assumed 

to be located in the vicinity of actively eroding gullies for soil and streambed sediment DCGLs 

because steep stream banks were assumed to preclude certain activities such as construction 

of a residence, farming or gardening. 
13 

With respect to surface soil DCGLs, DOE considered both the resident farmer and a resident 

gardener residing on a large (10,000 m2

) area of contamination that was assumed to be 1 m 

thick. DOE also evaluated two alternative conceptual models involving erosion in response to 

NRC RAI 5C4. One erosion scenario involved sheet or rill erosion of surface soils to 

downstream locations. The assumption is that a resident receptor will be exposed to eroded 

material that is transported downstream via surface water through various water dependent 

pathways (e.g., drinking water, irrigation, and fish consumption). The second erosion scenario 

involves contaminated surface soils being deposited in an onsite gully. DOE presented a 

qualitative evaluation of the impact of this second erosion scenario--due to the reduced number 

of pathways and lower occupancy factors for a recreationalist, the scenario was not expected to 

be more limiting then the resident farmer scenario. Results of DOE’s analysis show that the 

residential farmer scenario in the absence of erosion is most limiting. 

Because residual contamination underlying WMA 1 and 2 following remediation is located at 

significant depths (around 4 to 15 m below grade), various initiating events or processes that 

could lead to the redistribution of contamination to the surface thereby making it more 

accessible to a potential receptor were considered (e.g., drilling of a cistern or natural gas well 

that could lead to the relocation of well cuttings to the surface or erosional processes that could 

expose contamination located at depth). DOE presented a range of potential initiating events 

and alternative conceptual models in response to NRC RAIs (e.g., see RAIs 5C5, 5C6, 5C7, 

5C8, 5C9, 5C10, and 5C18 in [NRC, 2009]) which is considered sufficiently comprehensive to 

provide confidence that the subsurface DCGLs calculated to guide cleanup of WMA 1 and 2 will 

be protective of human health. The list of scenarios which is also presented in Table 1 below 

includes the following: 

• Intrusion--Cistern Construction 

o Resident farmer 

o Resident gardener6

o Acute dose to worker 

• Intrusion--Natural Gas Driller 

• Erosional Processes 

o Recreationalist in the vicinity of an actively eroding, onsite gully 

o Offsite resident exposed to eroded sediments transported via surface water to 

downstream locations 

• Groundwater transport from the relatively impermeable lavery till to the more permeable 

backfill materials where groundwater could be extracted for residential purposes 

(drinking water and irrigation). An intrusion event is also assumed to occur leading to 

surface soil contamination from both deposition of contaminants in irrigation water, as 

well as from deposition of contaminated drill cuttings from cistern or well construction on 

the surface. 

 

6

 A resident gardener is a modification of the resident farmer scenario. While due to the increased 

consumption rates, a resident farmer is oftentimes viewed as a more bounding scenario, in some cases 

the increased water usage requirements for a resident farmer leads to greater well bore dilution and lower 

potential doses for radionuclides dominated by groundwater dependent pathways. 
14 

Similar to the approach taken to develop surface soil DCGLs, DOE considered two erosion 

scenarios: an on-site and off-site receptor when deriving subsurface soil DCGLs. The on-site 

receptor is exposed to contamination that will be at significant depths (4-8 m) following remedial 

activities in WMA 27

 due to erosional processes (i.e., gully advancement) that is assumed to 

uncover buried contamination over time. Due to the steep and uneven landscape expected 

near a gully, the receptor is assumed to participate in recreational activities such as hiking, 

hunting, and fishing rather then residing in the area of contamination. With respect to the offsite 

receptor, erosion is expected to lead to transport of contaminated sediments in surface water to 

a downstream receptor, who is subsequently exposed by using the surface water pathway for 

drinking and irrigation purposes and through fish consumption. As indicated in the last bullet 

above, DOE also considered various processes that could lead to the transport of contamination 

at depth to ground or surface water that could be used by a potential receptor for drinking water 

or irrigation purposes (e.g., transport of contamination from the lavery till into the more 

permeable backfill sediments where contamination could be extracted from a domestic well 

used for drinking water or irrigation). 

For streambed sediment DCGLs and given the topography expected near certain streambed 

channels, DOE selected a recreational scenario to derive DCGLs with similar pathways as 

described for the onsite gully erosion scenarios discussed above. Based on an NRC RAI 

(5C12) DOE included an additional inhalation pathway not originally considered in the DCGL 

calculations. This pathway did not significantly impact the results. 

Critical Groups, Scenarios, Pathways: Identification and Selection—Conclusions

With respect to the surface soil DCGLs, DOE evaluated reasonable land use scenarios and 

appropriately considered potential pathways of exposure. DOE provided a technically sound 

qualitative argument to support its conclusion that the onsite gully (recreational) scenario would 

be bounded by the onsite resident farmer scenario due to the limited number of recreational 

pathways and lower occupancy factors. The onsite gully scenario could only be more limiting if: 

(i) the land was modified to allow construction of a residence and/or; (ii) upgradient 

contamination somehow concentrated or accumulated in the downstream gully. Modification of 

the land in the vicinity of a large gully to support construction of a residence would likely lead to 

the dilution or burial of eroded (contaminated) material making this scenario less limiting. 

Higher concentrations of contamination in downgradient locations are not expected, and it is 

reasonable to assume that material would not accumulate in a gully in a geometrical 

configuration that would be more limiting than a large, surficial source 10,000 m3

 in volume that 

is currently assumed in deriving surface soil DCGLs. DOE found the onsite resident farmer 

scenario to be more limiting than either the onsite resident gardener or the offsite resident 

farmer (offsite erosion scenario). DOE’s analysis and arguments appear reasonable for 

demonstrating compliance with LTR criteria. 

Similar to surface soil DCGLs, DOE evaluated residential scenarios that due to the number of 

pathways considered and high occupancy factors assumed were expected to be most limiting 

for subsurface soil cleanup levels. In response to RAIs 5C10 and 5C18 (NRC 2009, DOE 

2009b, DOE 2009c), DOE revised its DCGLs to account for more conservative source geometry 

 

7

 While erosion was considered for WMA 1, the results of DOE’s EIS (2008b and 2010) suggest that a 

gully would not advance into the area of the Main Plant Process Building within the 1000 year compliance 

period. 
15 

assumptions, as well as assumptions regarding pumping rates necessary to support a smaller 

garden compared to the larger pumping rates needed to support a 10,000 m2

 garden assumed 

in the surface soil DCGL calculations. In one case, DOE constrained land use to be consistent 

with the expected characteristics of the site (steep topography) that precluded certain activities 

such as construction of a residence, farming or gardening. For this onsite gully scenario, DOE 

evaluated the potential dose to a recreationalist spending time in the actively eroding onsite 

gully hiking, fishing, and hunting. Although it is possible that the gullies could be filled with clean 

material and that home construction could occur leading to potential residential scenarios, it is 

reasonable to assume that other residential scenarios evaluated by DOE for development of 

subsurface soil DCGLs would bound the impacts associated with this potential scenario8

. 

For streambed sediment DCGLs, DOE also presented a reasonable argument for use of a 

recreational scenario given the topography expected near certain streambed channels that 

would make construction of residences difficult (see Figure 5-12 in revision 2 to the DP 

[DOE 2009e] for map of locations). In other streambed areas where the topography might be 

more conducive to construction of a residence, DOE will use surface soil DCGLs to guide 

remediation. 

In conclusion, DOE developed reasonable exposure scenarios based on reasonable 

foreseeable land use. DOE appropriately selected the residential farmer or gardener as the 

critical group for exposure to site soils and recreational receptor for exposure to streambed 

sediments. In response to RAIs (NRC, 2009), DOE evaluated a number of alternative 

conceptual models and scenarios including those that might be deemed less likely but plausible. 

In all cases9

, DOE selected the most restrictive scenario on a radionuclide-specific basis when 

deriving DCGLs. DOE adequately evaluated a range of potential exposure scenarios and 

appropriately selected the critical group or group of people reasonably expected to receive the 

greater dose from residual contamination at the West Valley Site. 

Notwithstanding the conclusion above and although the basis was briefly discussed in a public 

meeting on DOE’s RAI responses, NRC noted that DOE did not provide a robust discussion 

regarding its lack of consideration of advective flow from the lavery till to the backfill sediments 

due to the effects of a pumping well that would be expected to cause a head reversal near the 

well. 

Comment: DOE did not demonstrate that diffusive transport is the dominant transport 

mechanism of contamination from the lavery till into the overlying aquifer. DOE needs to 

more formally document its conclusion that advective flow from the lavery till to the 

backfill sediments is not the dominant transport mechanism for the groundwater 

transport (or multi-source) scenario. 

 

8

 Gully erosion would be expected to deplete the subsurface soil sources, such that the residential farmer 

scenario in the absence of gully formation would be expected to bound the risks associated with a 

potential gully re-fill scenario. 

9

 In one case (surface soil DCGLs) and for one radionuclide (Np-237), DOE selected the probabilistic 

peak of the mean to calculate a DCGL when the deterministic DCGL was slightly lower (factor of 3). 

However, the critical group was the same—the residential farmer scenario. 
16 

Initiating Event or Process

Receptor Location

Mode Landuse Scenario Mathematical 

Model

Notes

Surface Soil DCGLsResidence Construction 

Various10 Deterministic 

Probabilistic 

Resident Farmer Resident Gardener 

RESRAD Basecase scenario 

Resident gardener 

Erosion Cattaraugus 

Creek 

Deterministic Resident Farmer WEPP11

Custom 

Not limiting 

Erosion Onsite gully Deterministic Recreational Qualitative Not limiting Subsurface Soil DCGLsGully Erosion Gully near 

Erdmann Brook/WMA 2 

Deterministic Recreational DEIS erosion 

modeling12

RESRAD 

Not limiting 

Gully Erosion Cattaraugus 

Creek 

Deterministic Resident Farmer 

Recreational (fishing) 

CHILD13

Custom 

Not limiting 

Cistern and Residence Construction 

WMA 1 and WMA 2 

Deterministic Probabilistic14

Resident Farmer Resident Gardener15

Worker (acute) 

RESRAD Basecase scenario 

Resident gardener cases. 

Natural Gas Drilling 

WMA 1 and WMA 2 

Deterministic Worker (acute) RESRAD Not limiting 

Groundwater Transport16

WMA 1 and WMA 2 

Deterministic Resident Farmer 

Resident Gardener17 

STOMP Custom18 Diffusion-limited co

from lavery till to ov

Streambed Sediment DCGLsRecreational Activity 

Onsite Creeks19

Deterministic Probabilistic 

Recreational RESRAD Basecase Scenario 

Table 1 List of Basecase and Alternative Exposure Scenarios 

10 Receptors are located in contaminated areas outside of WMA 1 and 2, or within the first 1 m (3 ft) of WMA 1 and 2. 11 The Water Erosion Prediction Project (WEPP) model results presented in the FEIS (DOE, 2010) were used to estimate erosion rates. 12 Information provided in Appendix F to the DEIS (DOE, 2008b) forms the basis for many of the assumptions regarding the erosion scen13Assumptions regarding gully erosion rates were drawn from CHILD landscape evolution modeling presented in the FEIS (DOE, 2010). 

used to calibrate the CHILD modeling results to a simple gully model and calculate the resulting dose associated with exposure to erode

14 Only the resident scenarios were run in probabilistic mode. The acute worker was run in deterministic mode. 15 Different contaminated zone (CZ) geometry assumptions (RAI 5C10) were also simulated with larger area, smaller thickness CZs limit16 Also called the multi-source model, the combined risk from residual groundwater contamination and the basecase intrusion event were 17 Various contaminated zone geometry configurations were considered.18 Information from the 3D STOMP model was used to set parameters for custom models including FEIS finite difference groundwater tra19 See Figure 5-12 in revision 2 to the DP (DOE, 2009e) for exact locations on the Project Premises. The locations do not include certai

tributaries to Erdmann Brook and Franks Creek. 
17 

5.1.4 Conceptual and Mathematical Models 

Conceptual and Mathematical Models—Evaluation 

DOE provided information regarding its conceptual models for exposure including information 

on the initiating events, transport of contaminants in the environment, and potential pathways of 

exposure. For most scenarios, DOE selected the RESRAD computer code to calculate surface, 

subsurface and streambed sediment DCGLs. While the conceptual and mathematical models 

implemented in the RESRAD computer code are well known and documented, not all 

contaminant fate and transport processes that may be operable at the West Valley Site are 

evaluated in the RESRAD models and code (e.g., erosion and diffusion). In these cases, DOE 

relied on the EIS analysis and models, as well as other custom programs to estimate the risks 

associated with residual contamination at the site. 

For example, DOE used custom models to estimate the dose from eroded surficial soil 

contamination transported to downgradient locations. Results from the EIS (DOE, 2008b) 

Watershed Erosion Prediction Project (WEPP) erosion analysis were used to estimate sheet 

and rill erosion rates. Custom models were used to estimate the dose to potential offsite 

receptors from use of contaminated surface water for drinking, irrigation, and fish consumption. 

As another example, the conceptual model implemented in the RESRAD computer code does 

not consider the risk associated with residual contamination located within saturated sediments, 

nor does it consider transport processes that might occur in relatively less permeable sediments 

such as lavery till materials located at the West Valley Site. Figure 5 illustrates the alternative 

conceptual model DOE evaluated in response to NRC RAI 5C9 (2009) to assess the impact of 

diffusion-limited transport from the lavery till vertically upwards into the more permeable backfill 

sediments where a domestic well could be installed and used to provide groundwater for 

drinking water and irrigation. This scenario was found to be most limiting for many 

radionuclides in deriving subsurface soil DCGLs. DOE used flow information from near-field 

Subsurface Transport Over Multiple Phases (STOMP) modeling to set parameters for a Final 

Environmental Impact Statement (FEIS) (DOE, 2010) model (e.g., finite difference rectangular 

source) along with dose to source ratios from RESRAD to evaluate the potential risk associated 

with this scenario. Verification packages for this custom modeling were provided by DOE for 

NRC review. 

DOE also used custom models to estimate the dose from an actively eroding erosion front, an 

alternative conceptual model for subsurface soil exposure in response to NRC RAI 5C6 (2009). 

DOE used information from the FEIS (DOE, 2010) to calculate potential dose to an offsite 

receptor. The Channel Hillside Integrated Landscape Development model (CHILD) was used to 

estimate the potential erosion rates associated with gully intrusion into WMA 2. The highest 

erosion rates from sensitivity runs (e.g., runs with higher precipitation rates) were used to 

estimate the characteristics of gully propagation over time. A single gully model conceptualized 

in Figure 6 was used to estimate the volumes of eroded material assumed to be transported in 

surface water to downstream locations to a potential receptor. Using a stable slope angle of 

21 degrees and time variant downcutting and advance rates, the simple analytical model 

presented in Figure 6 was fit to the most pessimistic CHILD landscape evolution simulation 

result discussed above (see FEIS [DOE, 2010]). The erosion rate estimates from the analytical 

model were then used to calculate surface water concentrations used to estimate the potential 

offsite impacts to a resident farmer from drinking water, irrigation, and fish consumption. 
18 

Additionally, potential risk to an onsite recreationalist/hiker in contact with the exposed 

contaminated zone was implemented in RESRAD as conceptualized in Figure 7. A one meter 

thick contaminated zone is exposed with an area of 200 m2

 (2 m wide by 100 m long). A 

recreationalist/hiker is assumed to be exposed from external gamma exposure, incidental soil 

ingestion and inhalation for 28 hours/yr while traversing the contaminated area. 

Figure 5 Alternative Conceptual Model for Development of Subsurface Soil DCGLs—

Groundwater Transport (Diffusion) From Lavery Till to Backfill Sediments with 

Subsequent Well Withdrawal 
19 

Figure 6 Schematic Representation of Single Gully for the Purposes of Estimating Doses 

to an Offsite Receptor Due to Erosion 

Figure 7 Alternative Conceptual Model for Development of Subsurface Soil DCGLs—

Exposure to Onsite Receptor Due to Gully Formation 

Although the underlying conceptual model implemented in RESRAD differs fundamentally from 

the conceptual model developed specifically for streambed contamination, DOE provided 

additional information and clarification on the adaptation of the streambed sediment DCGL 

conceptual model to RESRAD in response to NRC RAI 5C11, DOE expects the risks from 

streambed sediments to be overestimated by the RESRAD modeling due to several dose 

modeling assumptions (e.g., inclusion of the fish pathway on site streams that are not expected 

to support this pathway). However, because there is a potential for recontamination of 

streambed sediments that may be remediated during Phase 1, DOE elected to defer cleanup of 
20 

streambed sediments at this time. A revision to the decommissioning plan would be necessary 

to remediate streambed sediments. Nonetheless, NRC has offered a few comments below that 

should be considered if the DP is revised to support remediation of streambed sediments. 

In response to NRC RAIs (5C3, 5C9 and 5C20), DOE also evaluated the impact of engineered 

barriers on the flow field and the potential impact of flow field changes on dilution factors 

calculated in the RESRAD code. This evaluation was performed using the three-dimensional 

STOMP code. DOE interpreted the results of these analyses and showed that the engineered 

barriers will have little impact on the dilution factors. Additionally, DOE provided comparisons of 

the dilution factors calculated by RESRAD and STOMP and hard-wired the RESRAD nondispersion sub-model used in the surface soil DCGL calculations to produce results similar to 

what would be expected using the more sophisticated code. DOE showed that dilution using 

the mass balance model in RESRAD for the subsurface soil DCGLs was underestimated 

compared to the STOMP modeling. 

It is important to note that DOE plans to remove the Phase 1 hydraulic barriers in the event 

sitewide removal is sought at the end of phased decision-making, making the technical issue 

moot. However, because a final decision on Phase 2 has yet to be made, it would be difficult for 

DOE to evaluate the impact of final engineered barrier designs on site performance for all 

potential engineered barrier configurations that might be employed if the site-wide close-in-place 

(or similar) alternative is considered as the final decommissioning decision for the site. While 

engineered barriers are typically used to limit radionuclide releases and resultant doses, in 

some cases due to underperformance, degradation, or indirect impacts (e.g., changes in flow 

paths or decreased dilution in the saturated zone due to the presence of a cap) adverse impacts 

may occur and would need to be considered to ensure that when evaluating potential 

cumulative impacts of all remaining source areas, including remediated Phase 1 sources, that 

the dose remains below LTR criteria for the 1000 year compliance period. Because the dose 

standard would be four to twenty times higher20 then the unrestricted use standard being used 

to guide Phase 1 remediation, engineered barriers that may be constructed to support restricted 

use in Phase 2 are not expected to have a significant detrimental impact on DOE’s ability to 

comply with LTR criteria due to the level of clean-up of Phase 1 source areas. 

DOE provided elevated measurement concentration DCGLs (or DCGLemc) to guide clean-up of 

smaller, elevated areas of contamination. However, insufficient information was provided to 

allow independent assessment of these calculations. Namely, revision of the values to account 

for more limiting exposure scenarios such as the resident gardener or multi-source model were 

referenced in the report; however, details of these calculations were incomplete. Evaluation of 

the actual application of these DCGLs during the FSS is the subject of Section 9 (radiological 

survey) evaluations. 

 

20 In the case of restricted use and loss of institutional controls, 10 CFR 20.1403 provides a restricted use 

limit of 1 mSv/yr (100 mrem/yr) or in certain cases 5 mSv/yr (500 mrem/yr) compared to the unrestricted 

use limit of 0.25 mSv/yr (25 mrem/yr) found in 10 CFR 20.1402. 
21 

Conceptual and Mathematical Models—Conclusions

Most of the DCGL scenarios were modeled with the RESRAD code. RESRAD developers have 

subjected the code to extensive benchmarking, verification, and some limited validation. No 

independent verification of this NRC approved code is necessary (NRC, 2006). RESRAD input 

and output files were provided, as were spreadsheets presenting results of the analysis. 

Given its expected risk significance, DOE provided sufficient information for NRC to perform a 

high-level review of the landscape evolution and custom programs used to calculate erosion 

rates and dose consequences as a result of gully propagation. Additionally, the mathematical 

representation is adequate for the purposes of DCGL development. While limited information is 

available on CHILD verification and validation (CNWRA, 2008), independent calculations 

conducted by NRC using site-specific information on gully downcutting and advance rates 

generally supports the adequacy of the final DCGLs developed for subsurface soils. Any 

potential issues NRC identified with the erosion analysis (e.g., use of a Cattaraugus versus 

Buttermilk Creek receptor with a factor of eight greater dilution factor and assumptions 

regarding the timing or magnitude of peak erosion rates) were either offset by: (i) the safety 

margin between the basecase and erosion scenarios; and/or (ii) due to the use of a more 

limiting scenario such as the multi-source model (e.g., NRC results showed that the erosion 

scenario might be more limiting than the cistern scenario for C-14 but the multi-source model 

was even more limiting). With a few exceptions, which will be resolved separately and at a later 

time, DOE provided adequate descriptions and documentation (e.g., calculation packages) of 

alternative conceptual models evaluated with custom models and programs. These models 

generally appear to be adequate for the purposes of DCGL development. 

NRC has confidence that the mathematical models employed by DOE are sufficient to 

implement the conceptual models for exposure from surface and subsurface soils and that 

DCGLs were appropriately derived. 

Although the underlying conceptual model implemented in RESRAD differs fundamentally from 

the conceptual model developed specifically for streambed contamination, implementing the 

conceptual model associated with risks from streambed sediments in RESRAD should be 

adequate for the purposes of guiding clean-up of contaminated streambed sediments. DOE 

responded adequately to NRC comments (RAIs 5C1 and 5C11) regarding potential cumulative 

impacts to surface water to ensure that DCGLs for specific source areas are sufficiently 

bounding, as future surface water impacts were not specifically considered in developing 

streambed sediment DCGLs. For example, NRC cautioned DOE that if the risk associated with 

seepage, discharge, or erosion of multiple sources in downgradient receptor locations is 

potentially greater than the onsite risk for individual sources, then the DCGLs for individual 

source areas may need to be adjusted to ensure that LTR criteria are met at these 

downgradient locations. DOE thinks that this risk is low and has provided compelling arguments 

to support its assumption that the “onsite” or on-source receptor DCGLs derived will bound the 

impacts associated with any “offsite” or down-source receptors. In any event, DOE has elected 

to postpone remediation of contaminated streambed sediments in Phase 1. A revision to the 

DP would be needed to support remediation of streambed sediments. 
22 

Notwithstanding the conclusions above, NRC offers the following comments: 

Comment: Potential adverse impacts of final engineered barrier designs have not been 

evaluated at this time. DOE needs to evaluate any potential adverse impacts of final 

engineered barrier designs that may affect risk calculations to support Phase 2 decisionmaking. 

Comment: It is not clear that alternative conceptual models (e.g., multi-source and 

gardener) were appropriately considered when deriving area factors provided in Chapter 

9. NRC expects DOE to provide a basis for the number and size of the areas evaluated 

and the model selected to derive a particular set of area factors prior to remediation. 

5.1.5 Parameter Support and Analysis 

Parameter Support and Analysis—Evaluation 

DOE provided information for NRC to evaluate the parameters used in RESRAD and custom 

models to estimate the potential risk from the site including information on its deterministic 

parameter selection and probabilistic parameter selection. DOE initially performed a 

deterministic analysis with a comprehensive sensitivity analysis to identify significant risk factors 

and to indicate the level of uncertainty due to incomplete information regarding parameter 

values. In response to several NRC RAIs regarding justification for parameter selection (see for 

example RAIs 5C15 through 5C19 in [NRC, 2009]) and other stakeholder comments regarding 

use of a probabilistic analysis to evaluate uncertainty, DOE revised its DCGL calculations to 

consider results of a probabilistic assessment. Additionally, based on the results of the updated 

(DOE 2009e) parameter sensitivity and uncertainty analysis and in response to NRC comments, 

DOE revised its deterministic model parameters to help ensure that the modeling did not 

underestimate the potential risk. With one exception, the most limiting DCGL from either the 

deterministic or the probabilistic modeling was selected21 (DCGLs derived using the peak of the 

mean from the probabilistic analysis were more limiting for surface soil and streambed 

sediments). DOE also evaluated scenario uncertainty and managed this uncertainty by using 

the most limiting DCGL considering a range of alternative conceptual models and scenarios 

evaluated, as discussed above. 

NRC noted that DOE did not consistently consider uncertainty in the distribution coefficients for 

subsurface media. The response to RAI 5C15 indicated that DOE would consider the 

uncertainty in distribution coefficients for all zones (contaminated, unsaturated, and saturated) in 

the probabilistic DCGL calculations for all media (see Table 5C15-1). However, it is not clear 

from Appendix E, or the RESRAD input files that uncertainty in distribution coefficients for all 

subsurface media were considered and appropriately correlated. For example, the surface soil 

DCGLs included distribution coefficients for all radionuclides and zones; however, correlation 

coefficients for progeny were not considered. Subsurface soil DCGLs only considered 

uncertainty in the distribution coefficients for the contaminated zone. It is not clear why 

uncertainty in distribution coefficients for the unsaturated and saturated zones were not 

considered. 

 

21 In one case (surface soil DCGLs) and for one radionuclide (Np-237), DOE selected the probabilistic 

peak of the mean to calculate a DCGL when the deterministic DCGL was slightly lower (factor of 3). 
23 

DOE did not appear to consider uncertainty in important parameters such as effective diffusion 

coefficients used to estimate the potential risk of contaminating the overlying aquifer due to 

residual contamination in the lavery till. 

DOE used the Buttermilk Creek watershed area to determine surface water dilution factors that 

impact potential doses from fish and deer consumption. Because the sediment DCGLs are 

based on exposure to Franks Creek and Erdmann Brook sediments, this assumption, while 

potentially justified should be further explained. For example, onsite Creeks may not support 

fish populations and consumptions rates assumed in the analysis and thus, use of the larger 

Buttermilk Creek watershed area may be appropriate. These assumptions should be clearly 

documented if the DP is revised to support clean-up of streambed sediments. 

Parameter Support and Analysis—Conclusions

Based on DOE’s comprehensive evaluation of parameter and scenario uncertainty, NRC 

concludes (with the exceptions noted below) that DOE has provided adequate justification for its 

selection of model parameters and has appropriately considered uncertainty in its dose 

predictions. 

Comment: DOE did not provide adequate justification for its treatment of uncertainty of 

distribution coefficients for subsurface soil DCGL calculations. NRC recommends that 

DOE consider or provide justification for lack of consideration of uncertainty in 

distribution coefficients for subsurface materials in the subsurface soil DCGL 

calculations. DOE needs to properly consider parameter correlations consistent with the 

approach laid out in Appendix E, Table E-7 of Revision 2 to the DP. 

Comment: DOE did not consider the uncertainty in potentially risk-significant 

parameters when deriving subsurface soil DCGLs based on the multi-source scenario. 

NRC recommends that DOE perform a sensitivity analysis to evaluate the risk 

significance of important parameters (e.g., distribution coefficients) on the results of the 

multi-source scenario, which drives many of the subsurface soil DCGLs, and adjust 

parameters as necessary to ensure DCGLs are sufficiently protective at the unrestricted 

use level. 

Comment: DOE did not provide a rationale for using the Buttermilk Creek watershed 

area when deriving streambed sediment DCGLs. NRC recommends that DOE justify use 

of the Buttermilk Creek watershed area to calculate surface water concentrations in the 

streambed sediment DCGLs prior to their use in a future DP revision. 

5.1.6 Compliance with Regulatory Criteria 

Compliance with Regulatory Criteria—Conclusions

Based on review of DOE’s Phase 1 DP as revised by NRC review and comment (DOE 2009e), 

NRC has reasonable assurance of the following: 

• DOE has provided adequate information on surface and subsurface soil source terms for the 

purposes of DCGL development and has agreed to verify dose modeling assumptions in the 

field. If in-process or other characterization surveys of subsurface soils at the bottom of 
24 

excavations or along H-piles reveal significant levels of contamination not previously 

identified, the risk significance of this contamination should be evaluated and appropriately 

managed. DOE has agreed to apply surface soil DCGLs in only those areas of the WVDP 

site where surface contamination exists (defined by DOE to be less than 1 m thick) 

consistent with dose modeling assumptions. Streambed sediment geometries will be 

verified in the field and DCGLs modified, if necessary, if DOE elects to remediate streambed 

sediments in a future DP revision. 

• DOE has analyzed a range of reasonably foreseeable land use scenario(s), and has 

demonstrated that the exposure group(s) adequately represents a critical group(s). 

• The mathematical method and parameters used are appropriate for the scenarios evaluated 

and parameter uncertainty has been adequately addressed (with comments noted above). 

• For deterministic analyses, the peak annual dose to the average member of the critical 

group is expected to be less than (or equal to) 0.25 mSv (25 mrem) or for probabilistic 

analyses, the “peak of the mean” dose distribution to the average member of the critical 

group is expected to be less than (or equal to) 0.25 mSv (25 mrem). 

• DOE has committed to using radionuclide-specific DCGLs to guide remediation of the 

WVDP Site to ensure that the total dose from all radionuclides will meet the requirements of 

Subpart E by using the sum of fractions rule. NRC encourages DOE to follow through on its 

intent to evaluate the final dose using data collected from the final survey results to provide 

additional assurance that LTR criteria are met and to provide a more accurate estimate of 

risk from residual contamination. NRC also encourages DOE to calculate potential dose at 

downgradient locations to provide an indication of the available safety margin remaining for 

Phase 2 decommissioning activities (or additional support that the on-source DCGLs will be 

more limiting when cumulative dose from all sources is considered). 

Notwithstanding the conclusions above, due to the relatively large amount of information that 

has been provided for NRC review since the Revision 1 DP submittal, NRC has performed a 

comprehensive review all recent submittals (with more risk-significant comments noted in this 

TER). NRC would like to discuss these and other less risk-significant comments and questions 

further with DOE. 

Comment: Clarity of Phase 1 DP modeling assumptions and parameters could be 

enhanced. NRC seeks clarification on a few modeling assumptions and parameter 

values to help improve clarity of the Phase 1 DP and/or ensure all remaining risksignificant technical issues are adequately addressed. 

5.2. Engineered Barriers 

Engineered Barriers - Evaluation

In the Phase 1 DP, DOE proposed to use a variety of different engineered barriers to facilitate 

remediation. These barriers include: sheet pilings, hydraulic barrier walls, a Permeable 

Treatment Wall, and French drains. Many of these barriers have been used previously at the 

WVDP during site operations. Phase 1 decommissioning activities will involve the excavation of 
25 

contaminated soil for offsite disposal. The engineered barriers will be used to prevent the 

intrusion of groundwater into excavations during their excavation, FSSs, and backfilling with 

clean soil. The engineered barriers are not being relied upon as long-term barriers to meet the 

unrestricted use decommissioning criteria. The sheet pilings are temporary barriers used during 

excavation. The hydraulic barrier walls are permanent barriers used to facilitate excavation of 

contaminated soil and to prevent recontamination of remediated areas prior to completion of 

Phase 2 activities. Monitoring will be performed to verify recontamination has not occurred, and 

if necessary additional remediation will be completed. Figure 8 is a plan view of the site 

showing the location of the permanent barrier walls to facilitate decommissioning and 

associated monitoring locations. 
26 

Figure 8 - DOE’s Proposed Use of Permanent Engineered Barriers for Phase 1 

Decommissioning Activities and Associated Monitoring Locations 
27 

DOE described the design information provided in the Phase 1 DP as conceptual in nature, 

because a ROD for the EIS has not yet been made. DOE stated if the Phased Decisionmaking 

Alternative for decommissioning is selected, then a final design for the engineered barriers will 

be provided to NRC for technical review. 

Temporary sheet piling will be driven into uncontaminated soils on the upgradient and crossgradient sides of the excavations. Interlocking sheet piling was used during construction of a 

variety of facilities at WVDP in the 1960’s and during construction of the Permeable Treatment 

Wall in 1999. The sheet piling was used to support excavations ranging from 9 to 15 meters 

(30 to 50 feet). In response to an NRC RAI, DOE provided photographs and a discussion of 

previous experience with sheet piling. The photographs support the reasonable likelihood that 

DOE will be able to limit water flow into the excavations with sheet piling. 

The permanent hydraulic barrier wall constructed on the downgradient side of the excavation 

would be a soil-cement-bentonite slurry wall installed using slurry wall trenching technology. 

The wall would be installed under a quality control – quality assurance program. The soilcement-bentonite mixture would be in the proportion 85-5-10, with an initial maximum design 

hydraulic conductivity of 6.0E-06 cm/s. The wall would be approximately 230 meters (750 ft) 

long, up to 15 m (50 ft) deep, and 1 to 4 meters (2 to 13 feet) wide. In RAI DC3, NRC requested 

additional information with respect to a number of aspects of the permanent barrier wall design 

and implementation. The Phase 1 DP provided insufficient information that the performance 

goals of the slurry wall are likely to be achieved. DOE responded that it is premature to present 

final performance goals prior to a EIS ROD, and that the final design details, performance goals, 

and supporting technical basis for the hydraulic barriers and French drains will be provided to 

NRC for technical review prior to their installation. When DOE provides the information to NRC, 

it needs to address the specific elements stated in RAI DC3. 

NRC requested additional information on the Phase 1 engineered barrier corrective action 

program. Identifying that engineered barriers have been implemented properly and are 

functioning as designed is essential. NRC expressed concern that without an effective 

monitoring and maintenance program or robust designs, the engineered barriers may not be 

able to meet their performance requirements. DOE responded that both a groundwater 

monitoring network and a French drain would be installed adjacent to the barrier wall to monitor 

its performance and identify necessary corrective actions. The monitoring could involve the use 

of nested piezometers at different depth intervals installed at regular intervals upgradient and 

downgradient. Groundwater samples would be routinely collected and analyzed for radiological 

indicator parameters. Changes in those parameters may identify defects. However, the 

monitoring network can not be fully-designed until site-specific hydrological and geotechnical 

information is collected. Section 2.1.1 of the DP was modified to reflect the types of monitoring 

that would be performed. NRC staff reviewed the information and found the content to present 

a reasonable path forward. NRC will review the specific details of the engineered barrier 

monitoring system design when it becomes available during implementation of Phase 1, as 

applicable. 
28 

NRC requested additional information on the effect of the engineered barriers on groundwater 

flow (e.g., to WMA 3 [waste release, Tank Farm groundwater dewatering system] or the 

Permeable Treatment Wall), which could impact Phase 2 activities. In response, DOE outlined 

a number of actions that will be taken to ensure the use of the permanent hydraulic barrier walls 

will not have adverse impacts on Phase 2 decision making. 

• The WMA 1 barrier wall and French drain will be designed to result in minimal changes 

to groundwater flow patterns and levels in WMA 3. 

• Additional monitoring locations will be added to better identify potential changes to the 

water flow to WMA 3. 

• The contractor responsible for the Permeable Treatment Wall design is modeling the 

effects of the WMA 1 and 2 barriers on groundwater flow directions and gradients. 

• If a Phase 2 close-in-place option were selected for the HLW tanks, the design would 

likely include engineered barriers such as a circumferential hydraulic barrier wall and 

upgradient barrier wall to divert groundwater flow away from the tanks and a multi-layer 

closure cap to reduce infiltration. 

• The Phase 2 barrier walls could be tied into the proposed Phase 1 barriers, if necessary. 

Collectively, the proposed actions provide adequate basis that the impacts of Phase 1 barriers 

on Phase 2 activities will be addressed. However, NRC will verify this conclusion upon review 

of the detailed information as it becomes available. 

Engineered Barriers - Conclusions

NRC has reviewed the engineered barriers analyses and information as part of the review of 

DOE’s decommissioning plan, using the Consolidated Decommissioning Guidance, Volume 2, 

Section 3.5 (Use of Engineered Barriers). Based on this review, NRC concludes that the use of 

engineered barriers for unrestricted use of areas of the WVDP identified in the Phase 1 DP is 

reasonable and appropriate for the stated objectives of the barriers. The stated objective of the 

engineered barrier is to control the spread of contamination from unremediated areas to 

remediated areas, as well as to limit the flow of groundwater to areas that are being remediated. 

This conclusion is based on NRC evaluation in the Phase 1 DP and responses to requests for 

additional information. NRC conclusions for specific issues related to engineered barriers are 

found in the staff evaluation section above in order to provide the reader with the appropriate 

context. 

In the DP for Phase 2, DOE will need to demonstrate that the entire West Valley Site meets the 

LTR. If the engineered barriers employed to limit recontamination of areas that have been 

remediated prove not be effective resulting in recontamination of Phase 1 areas that were 

previously remediated, further remediation of those areas could be required to meet LTR 

criteria. Additionally, design of the Waste Tank Farm groundwater dewatering system or other 

systems may be confounded by increased water flow resulting from the presence of Phase 1 

engineered barriers. The basis for selecting a two phase approach to decommissioning is in 

part that Phase 1 actions will not impact the selection of Phase 2 options. Decisions based on 
29 

conceptual designs are subject to greater uncertainty than if the designs of the engineered 

barriers were more robust. However, because the engineered barriers are not being relied upon 

for long-term performance (i.e. they are designed to eliminate the need to perform additional 

remediation at some future date), conceptual designs are suitable at this time. Detailed 

information will be reviewed as it becomes available during Phase 1 activities. 

6.0 ALARA 

ALARA Evaluation 

DOE provided its ALARA evaluation in Section 6.0 of the Phase 1 DP, Rev. 0 (DOE 2008a). 

NRC reviewed Section 6 of the DP, Rev. 0 and raised concerns about three ALARA issues in 

the May 15, 2009, RAI (NRC 2009). DOE provided responses to the RAI (DOE 2009b) and a 

revision 2 of the DP (DOE 2009e). The ALARA evaluation addresses: (i) methods by which 

DOE plans to achieve a decommissioning goal below the dose limits (Section 6.2 of the DP); 

(ii) cost-benefit ALARA analyses for surface soil cleanup (and DCGL), subsurface soil cleanup, 

and streambed sediment cleanup (Section 6.3 of the DP); and (iii) additional ALARA analyses 

that DOE plans to perform (Section 6.4 of the DP). 

NRC guidance provides that ALARA evaluations for unrestricted use decommissioning should 

address two aspects: (i) typical good practices or good housekeeping efforts and (ii) costbenefit ALARA analyses. Regarding the good practices, DOE had partially addressed 

qualitative aspects of ALARA, in Section 6.2 of the DP, Rev. 0 (DOE 2008a). However, NRC 

staff had a concern, included in the RAI (NRC 2009), that DOE had only provided a brief 

mention of broad concepts related to good practices and should provide more details on actual 

practices that might be employed. In its response to the RAI (DOE 2009b) and in Rev. 2 of the 

DP (DOE 2009e), DOE provides references to DOE documents that include good practice 

provisions that promote ALARA, and mentions specific good practices that will be used. The 

staff considers the DOE revision acceptable. 

DOE also describes its cost-benefit analyses, in Section 6.3 of the DP. In Rev 0 of the DP 

(DOE 2008a), DOE used a simplified analysis, which assumed the only benefit would be the 

collective dose averted by the action and evaluated only the cost of disposal of Low-Level 

Radioactive Waste (LLW). Based on that comparison, DOE concluded that soil remediation 

below the proposed DCGL is not warranted. This is consistent with NRC’s conclusion that 

shipping soil to a LLW facility is unlikely to be cost-effective for unrestricted use (NUREG-1757, 

Vol. 2, Appendix N, Section N.1.5). However, in its analysis, DOE applied a monetary discount 

rate of 0.03/yr (3%/yr). NRC expressed its concern in the RAI (NRC 2009) that the use of a 

discount rate is inappropriate when the benefits and costs span across population generations 

(as may be the case here, with some long-lived radionuclides). In its response to the RAI 

(DOE 2009b) and in Rev. 2 of the DP (DOE 2009e), DOE provided additional analyses using 

lower discount rates (to zero), and showed that with zero discount rate, the disposal component 

of costs exceeds the value of dose averted and further remediation would not be necessary. 

NRC considers the DOE revision acceptable. 

NRC also had a concern (NRC 2009) on Rev. 0 of the DP (DOE 2008a) about why DOE 

presented a preliminary ALARA evaluation (i.e., in the present DP) and plans an additional, 

more detailed ALARA evaluation during the Phase 1 remediation work. In its response to the 

RAI (DOE 2009b) and in Rev. 2 of the DP (DOE 2009e), DOE indicated that this approach is 
30 

appropriate because information used in the analyses may change by the time remediation 

takes place. DOE mentioned an example of waste disposal costs potentially changing, which 

could affect the analyses. NRC also notes that characterization activities are not complete at 

this time, and additional information obtained through characterization might also change the 

analyses. Given the overall approach to the Phase 1 decommissioning, the NRC considers it 

acceptable for DOE to perform the more complete, detailed ALARA analyses during the 

remediation work. 

NRC also notes that DOE commits in Section 6.4 of Rev. 2 of the DP (DOE 2009e) to meeting 

soil cleanup goals that are concentrations lower than the calculated DCGLs (calculated based 

on 25 mrem/yr). This is another aspect of the application of ALARA to the Phase 1 

decommissioning. 

ALARA – Conclusions

NRC has reviewed DOE’s ALARA evaluation as part of the review of the Phase 1 DP, using the 

Consolidated Decommissioning Guidance, Volume 2, Section 6 and Appendix N (ALARA 

Analyses). Based on the NRC staff’s review of DOE’s DP as supplemented and revised 

through responses to the RAI (DOE 2008a, DOE 2009b, DOE 2009e), NRC concludes that 

DOE’s ALARA evaluations completed for the proposed Phase 1 decommissioning provide 

reasonable assurance that the ALARA criterion in NRC regulations at 10 CFR 20.1402 will be 

met. As discussed above, DOE plans to perform additional ALARA analyses during 

implementation of the Phase 1 decommissioning work; and NRC will review the additional 

ALARA analyses when available during implementation of Phase 1, as applicable. 

Based on the Statement of Considerations for the LTR (NRC 1997), the radon pathway does 

not need to be included in dose assessments for compliance with the dose criteria of the LTR. 

However, the ALARA evaluation for compliance with §20.1403(a) (restricted use) should 

consider the practicality of radon mitigation techniques in structures as part of the institutional 

controls proposed for the site. Thus, if restricted use is proposed for Phase 2 and if radongenerating radionuclides are present (e.g., Th-230 or Ra-226), DOE should address this for 

Phase 2 and should consider whether any changes to Phase 1 decommissioning are 

appropriate. 

Comment: Although final decommissioning decisions have not been made, DOE needs 

to be aware that if it selects sitewide close-in-place for Phase 2 decommissioning with 

institutional controls to meet criteria for restricted use, DOE may need to consider radon 

impacts as part of the demonstration of compliance with §20.1403(a) even for Phase 1 

source areas. 

7.0 Planned Decommissioning Activities 

Planned Decommissioning Activities - Evaluation 

DOE provided a description of the West Valley Site and area conditions anticipated at the 

beginning of Phase 1 decommissioning and a general overview of proposed Phase 1 

decommissioning activities. DOE stated that detailed procedures or “Decommissioning Work 

Plans” will be completed to ensure work is performed safely prior to the commencement of 

Phase 1 decommissioning activities. 
31 

A summary of remediation and demolition technologies was provided in Section 7 of the 

Phase 1 DP. DOE provided a general schedule with the basic sequence and order-ofmagnitude of the proposed activities. Prior to DOE developing the Phase 1 DP, NRC agreed 

that certain DOE regulations, orders, and technical standards are adequate to define, control, 

and establish safe work activities at the site. NRC determined that DOE did not need to provide 

these details in the Phase 1 DP. In this respect, NRC considered areas such as project 

management and organization, the health and safety program, the environmental monitoring 

and control program, and the radioactive waste management program adequate under DOE’s 

responsibility and authority. 

Planned Decommissioning Activities - Conclusion

NRC has reviewed the planned decommissioning activities described in the Phase 1 DP for the 

WVDP according to the Consolidated Decommissioning Guidance (NUREG-1757), Volume 1, 

Section 17.1 (Planned Decommissioning Activities). Based on this review, NRC concludes that 

DOE provided sufficient information to allow an evaluation of planned decommissioning 

activities and to ensure that the decommissioning can be conducted safely and in accordance 

with NRC decommissioning criteria. 

8. Quality Assurance 

Quality Assurance - Evaluation

NRC has completed a qualitative assessment of the information in the “Quality Assurance 

Program” section of the Phased 1 DP for the WVDP which focuses on the Quality Assurance 

(QA) related to characterization surveys, engineering data, calculations, dose modeling, and 

FSS supporting the proposed decommissioning activities. In this section, DOE provides an 

overview of the QA program but states that the information is generic because contractual 

arrangements for the proposed decommissioning have not yet been made. This overview 

includes information on QA: (i) organization; (ii) duties and responsibilities of each unit within 

the organization; (iii) controls for documents, measuring and test equipment, purchased 

material, contractor services, corrective action, audits and surveillances, and for control of QA 

records; and (iv) refers to existing quality control assurance programs for the preliminary dose 

modeling and engineered barrier design that will be completed prior to the initiation of Phase 1 

decommissioning activities. 

 

Quality Assurance - Conclusion

NRC has completed a qualitative assessment of the Quality Assurance Program for the WVDP 

Phase 1 DP according to the Consolidated Decommissioning Guidance, Volume 1, Section 17.6 

(QA Program). Based on this assessment, NRC concludes that DOE’s QA program is sufficient 

to provide reasonable assurance that accurate, high-quality information will be developed to 

support Phase 1 decommissioning activities. 

Comment: The Phase 1 DP provides an overview of the QA program noting that the 

information is generic because contractual arrangements for the proposed 

decommissioning have not yet been made. Section 1.6 of the Phase 1 DP states that a 

QA Project Plan will be developed and forwarded in the future. NRC will review the 

elements of the QA Project Plan applicable to data and information collected in 
32 

conjunction with planned characterization and surveys supporting decommissioning 

activities (e.g., scientific and engineering data, calculations, measurement and test 

equipment, and dose modeling) when this information becomes available. The QA 

Project Plan needs to be developed prior to the start of decommissioning activities to 

ensure the collection of high-quality and defensible information. 

9.0 Facility Radiation Surveys 

9.1 Decommissioning Criteria 

Decommissioning Criteria – Evaluation

DOE’s derivation of DCGLs and area factors are described in Chapter 5 and Appendix C of the 

Phase 1 DP (DOE 2009e). NRC’s evaluation of the DCGL modeling and calculations is 

discussed in Section 5.1. Please refer to Section 5.1 for detailed information and conclusions 

regarding DCGL and area factor development. 

Decommissioning Criteria – Conclusion

NRC has reviewed the information in the Phase 1 DP for the WVDP according to the 

Consolidated Decommissioning Guidance (NUREG-1757), Volume 2, Section 4.1 (Release 

Criteria). Based on this review, NRC concludes that DOE has sufficiently summarized the 

DCGL(s) and area factors used for survey design and for demonstrating compliance with the 

radiological criteria for unrestricted use. 

9.2 Characterization Surveys and Remedial Action Support Surveys 

Characterization Surveys and Remedial Action Support Surveys - Evaluation

DOE stated in Section 7 of the West Valley Phase 1 DP that “the WVDP facilities and areas had 

not been completely characterized for radioactivity as of 2009. Additional characterization will 

be performed as necessary in accordance with the [CSAP], as explained in Section 9.” 

Additionally, DOE states in Section 9 of the DP that, “while this section addresses all applicable 

requirements for facility radiation surveys, it does so in general terms because two 

supplemental documents will provide additional details: a [CSAP] and a Phase 1 Final Status 

Survey Plan.” In Section 9.4.1, DOE also stated that, “[a] key objective of [the CSAP] will be to 

produce data for the Phase 1 FSS of sufficient quality and quantity to serve FSS purposes when 

practicable.” In response to the above statements and the integral importance to the survey 

requirements to demonstrate consistency with NRC guidance, NRC requested (RAI 9C1) that 

the CSAP be provided to NRC to supplement the technical review of the WVDP Phase 1 DP. In 

response to this request, DOE revised Section 9.4 (Characterization Surveys) incorporating an 

annotated outline of the content of CSAP summarizing: its scope and content, characterization 

methodologies, data quality objectives for characterization surveys, quality control of 

measurements and samples, and use of characterization data for FSSs. 
33 

In accordance with NRC review guidance, NRC staff requested detailed information on sitespecific facility surveys, “Remedial Action Support Surveys,” also known as in-process surveys. 

NRC staff requested (RAI 9C2) that DOE provide a Remedial Action Support Survey Plan 

based upon current site characterization data, and suggested that the Remedial Action Support 

Survey Plan would also provide DOE with a basis for developing the Final Status Survey Plan 

(FSSP). NRC specifically requested that the Remedial Action Support Survey Plan include the 

survey methodologies to be performed to ensure that the detection of residual radioactivity is 

well below the DCGL, to demonstrate that soil has been sufficiently remediated and that the 

residual radioactivity at depth meets release requirements. In response to this request, DOE 

revised Section 9.5 incorporating additional information on survey methodologies and field 

instrumentation to be used in these surveys to detect contamination below DCGLs. 

Additionally, DOE has committed to provide further details in the CSAP on how background 

data will be applied to characterization and remedial action support surveys (as a response to 

RAI 9C3 on the application of background data). 

The CSAP and additional details of Remedial Action Support Surveys were both requested by 

NRC as part of the RAI process. In DOE’s response to NRC’s request, DOE stated that “the 

[CSAP] will cover both pre-remediation and remedial support collection needs.” NRC agrees 

with DOE that the WVDP DP radiological program is highly dependent on the forthcoming 

CSAP. Accordingly, NRC has determined that a detailed technical evaluation of the Facility 

Radiation Surveys cannot be completed until the CSAP, a critical technical basis document, is 

confirmed to adequately address issues identified by NRC. 

Characterization Surveys and Remedial Action Support Surveys – Conclusion

In the absence of the CSAP, the information supplied in Revision 2 of the Phase 1 DP was 

reviewed according to the NUREG 1757 Consolidated Decommissioning Guidance, Volume 2, 

Section 4.2 (Characterization Surveys) and Section 4.3 (Remedial Action Support Surveys). 

Since additional information on characterization and remedial action support surveys is 

anticipated, NRC conclusion is dependent on the CSAP and development of the radiation 

survey plans. 

Comment: NRC will review and comment on the CSAP when it becomes available. The 

CSAP implementation will enable the development of the radiation survey plans as 

defined in NRC guidance. 

9.3 Final Status Survey Design 

Final Status Survey Design - Evaluation

In response to NRC’s request for clarification on the Final Status Survey Design (FSSD) (RAI 

9C4), DOE revised the DP by adding Appendix G incorporating Phase 1 Final Status Survey 

Conceptual Framework to serve as a basis for the development of a FSSP. DOE also provided 

the WVDP FSSP (DOE 2009f) as a stand alone document to supplement the Phase 1 DP, 

which includes the FSSD. In the FSSP, DOE states that, “This [FSSP] is consistent with the 

Multi-Agency Radiation Survey and Site Investigation Manual [MARSSIM NUREG 1575].” 
34 

In the DP and FSSP, DOE identifies 18 radionuclides of concern. Many of the 18 radionuclides 

are hard-to-detect nuclides which have extremely low DCGLs proposed to demonstrate 

compliance with radiological criteria for unrestricted use. The hard-to-detect radionuclides may 

require complex radiochemical and measurement protocols in order to validate their existence 

and to quantify the specific activity in the environment. Consistent with the other radiological 

facility surveys, the FSSP is highly dependent on the forthcoming CSAP. The CSAP will 

provide radiological results that DOE will use as the technical basis for demonstrating 

consistency with MARSSIM and NRC guidance. NRC staff has determined that the FSSP will 

require clarification and should apply results from the CSAP. In addition, the FSSP proposes 

the use of composite sampling. However, DOE should clarify its technical justification for using 

composite sampling to demonstrate compliance and consistency with MARSSIM and NRC 

guidance. In the DP Section 9.4.1, DOE states that the radiological surveys and samples 

obtained from the CSAP may be used to satisfy FSSP requirements. The CSAP has not been 

provided for NRC review; and therefore, the relationship between the CSAP and FSSP can not 

be determined. 

Final Status Survey Design - Conclusion

NRC has reviewed the information in the Phase 1 DP for the WVDP and the Phase 1 FSSD 

according to NUREG-1757 Consolidated Decommissioning Guidance, Volume 2, Section 4.4 

{Final Status Survey Design (FSSD}. Based on this review, NRC concludes that DOE’s FSSD 

may be adequate, but may require clarification upon completion of the site characterization 

work. In addition, the technical approaches proposed by DOE in the survey plans will require 

clarification. NRC concurs with DOE that the CSAP results are critical to the finalization of the 

Facility Radiological Surveys, including the FSSP. 

 

Comment: The CSAP and the survey plans are necessary to clarify the approach to the 

Facility Radiation Surveys and the technical bases. As stated above, NRC expects DOE 

to revise the survey plans following implementation of the CSAP. NRC will review these 

documents when they become available. 

10.0 Summary 

NRC has completed its review of the Phase 1 DP for the WVDP. The major conclusions based 

on the staff’ evaluations of the Phased 1 DP are summarized below: 

• No objections identified. 

• Phase 1 DP provides sufficient information and acceptable analyses for NRC to 

determine if the applicable LTR decommissioning criteria have been met. 

• Based on the information provided and independent staff analyses, NRC has determined 

that there is reasonable assurance that the proposed action will meet the 

decommissioning criteria. 

• Phase 1 DP provides an acceptable approach for guiding decommissioning activities 

using the DCGLs presented. 
35 

• Comments have been identified for DOE to address during Phase 1 activities. 

• Some comments request that DOE provide NRC with new information as it is collected 

or analyzed during phase 1 activities, such as monitoring data for potential recontamination, or in-process survey data showing significant deviations from modeling 

assumptions, or changes to DCGLs. 

• Other comments relate to information that needs to be developed and provided to NRC 

for review, such as detailed engineer barrier designs, CSAP, and FSSP. 

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