March 31, 2015 

MEMORANDUM TO: Gregory F. Suber, Chief 

Low Level Waste Branch 

Division of Decommissioning, Uranium Recovery, 

 and Waste Programs 

Office of Nuclear Material Safety 

 and Safeguards 

THRU: Christepher A. McKenney, Chief /RA by K Pinkston for/

Performance Assessment Branch 

Division of Decommissioning, Uranium Recovery, 

 and Waste Programs 

Office of Nuclear Material Safety 

 and Safeguards 

FROM: Cynthia S. Barr, Sr. Systems Performance Analyst /RA/ 

Performance Assessment Branch 

Division of Decommissioning, Uranium Recovery, 

 and Waste Programs 

Office of Nuclear Material Safety 

 and Safeguards 

SUBJECT: TECHNICAL REVIEW OF ENVIRONMENTAL MONITORING AND 

SITE-SPECIFIC DISTRIBUTION COEFFICIENT REPORTS 

The U.S. Nuclear Regulatory Commission (NRC) staff has performed technical reviews of 

environmental monitoring and site-specific distribution coefficient reports prepared by the U.S. 

Department of Energy (DOE) to support F-Area Tank Farm Facility (FTF) closure at Savannah 

River Site. This technical review report is related to Monitoring Factor 4.1, “Natural Attenuation 

of Pu,” and Monitoring Factor 4.3, “Environmental Monitoring,” listed in NRC staff’s FTF 

Monitoring Plan (Agencywide Documents Access and Management System Accession No. 

ML12212A192). The NRC staff concludes the following: 

1. DOE has performed environmental monitoring at the FTF that provides useful 

information on the hydrogeological system at FTF. This information can also be used to 

better understand contaminant flow and transport and validate DOE Performance 

Assessment models. 

CONTACT: Cynthia Barr, NMSS/DUWP 

 (301) 415-4015
G. Suber 2 

2. Uncertainty exists in the source of contaminant plumes detected via the FTF monitoring 

well network. Reducing this uncertainty will be important to better understanding 

contaminant flow and transport processes operable at the FTF. 

3. Progress has been made on development of cement leachate factors used to account 

for the impact of cement leaching on natural system sorption; however, additional 

information is needed to support factors for key radionuclides such as Neptunium(Np), 

Plutonium(Pu), and Uranium(U). 

4. Progress has been made on development of site-specific Kd s for Niobium(Nb); however, 

additional information is needed to support Kd values used in performance assessment 

calculations. 

5. Little progress has been made to address the technical issue associated with the Pu Kd

averaging approach used in tank farm performance assessment calculations. DOE 

should address this technical issue in the future. 

Many of the technical issues listed in this technical review report are listed in the FTF Monitoring 

Plan (ML12212A192) and will not be repeated here. Unique technical issues not discussed in 

the FTF Monitoring Plan that are listed as follow-up actions include the following: 

1. The NRC staff will continue to monitor the ability of the tank farm monitoring well network 

to detect releases from the tank farm facilities following closure. DOE could evaluate the 

monitoring well network by performing an analysis of the centerline of plumes emanating 

from tank sources should releases occur in the future, and provide input on optimal well 

locations to ensure that future releases from the tank farm facility would be detected. 

2. The NRC staff will continue to evaluate the source of elevated Technetium(Tc)-99 levels 

in well FTF 28. It is not clear that releases from the F-Area Inactive Process Sewer Line 

could migrate vertically to the lower zone of the Upper Three Runs Aquifer in such a 

short distance from the source. This evaluation is important to ensure that the 

hydrogeological system at FTF is well understood and that releases from the tanks could 

be detected by the monitoring well network. DOE could provide additional support for 

the source of contamination detected at well FTF 28 by performing particle tracking to 

better understand contaminant plume trajectories. DOE could also perform a more 

formal statistical analysis of FTF, and Western Groundwater Operable Unit well data to 

correlate contaminant concentrations associated with various sources. 

3. The NRC staff will continue to monitor the Kd averaging approach used to simulate Pu 

transport in the natural system at FTF. DOE could address the issue by modeling 

explicitly more mobile and less mobile forms of Pu in future performance assessment 

calculations. 

4. The NRC staff will continue to monitor support for cement leachate factors developed for 

Pu (and other constituents). DOE could provide support for cement leachate factors by 

performing site specific analyses. 
G. Suber 3 

5. The NRC staff will continue to monitor the basis for selection of the Nb distribution 

coefficient or Kd value of 160 L/kg used in the Tanks 5 and 6 Special Analysis. DOE 

could address the technical issues by verifying the batch experiments did not exceed 

solubility limits and are representative of conditions at FTF (e.g., plot solid phase versus 

aqueous phase concentration or Kd versus concentration; evaluate Kd for FTF aquifer 

soils); or perform additional experiments to verify the Nb Kd. 

Docket No.: PROJ0734 

Enclosure: 

Technical Review of DOE Environmental 

 Monitoring Reports for Tank Farms 
G. Suber 3 

5. The NRC staff will continue to monitor the basis for selection of the Nb distribution 

coefficient or Kd value of 160 L/kg used in the Tanks 5 and 6 Special Analysis. DOE 

could address the technical issues by verifying the batch experiments did not exceed 

solubility limits and are representative of conditions at FTF (e.g., plot solid phase versus 

aqueous phase concentration or Kd versus concentration; evaluate Kd for FTF aquifer 

soils); or perform additional experiments to verify the Nb Kd. 

Docket No.: PROJ0734 

Enclosure: 

Technical Review of DOE Environmental 

 Monitoring Reports for Tank Farms 

DISTRIBUTION: CGrossman GAlexander LParks MFuhrmann 

ML12272A124 

OFC DWMEP DWMEP DWMEP DWMEP: DWMEP 

NAME CBarr TMoon CMcKenney JShaffner CBarr 

DATE 3/ 03 /15 3/5 /15 3/ 17 /15 3/23/15 3/31/15 

OFFICIAL RECORD COPY
Enclosure 

TECHNICAL REVIEW OF ENVIRONMENTAL MONITORING REPORTS PREPARED BY DOE 

FOR TANK FARMS 

Date: March 2015 

Reviewers: Cynthia S Barr, U.S. Nuclear Regulatory Commission 

Mark Fuhrmann, U.S. Nuclear Regulatory Commission 

George Alexander, U.S. Nuclear Regulatory Commission 

David Pickett, Center for Nuclear Waste Regulatory Analyses 

Summary of Review Documents

Review of Tank Farm Environmental Monitoring Reports (Monitoring Factor 4.3 “Environmental 

Monitoring” (ML12212A192)) 

The Environmental Protection Agency (EPA) and the South Carolina Department of Health and 

Environmental Control (SCDHEC) approved a new Sampling and Analysis Plan (SAP) for 

F-Area Tank Farm (FTF) in December 2012 (SRNS-RP-2012-00287, Rev. 1). In 2013, 

Savannah River Site (SRS) performed sampling according to the Sampling and Analysis Plans 

for the FTF (SRNS-RP-2014-00226, Rev. 0). SRS collected samples during the first and third 

quarters from 131

 wells at the FTF. Also of note, DOE measured a rainfall value of 71.4 inches 

in 2013, which is significantly higher than the 30-year average value of 47.2 inches/yr. In fact, 

the 2013 precipitation rate was the greatest amount of annual rainfall recorded at SRS over the 

past 30 years. At the time of preparation of the 2013 tank farm groundwater monitoring report, 

although the water levels had risen due to the higher than average 2013 rainfall amounts, the 

water levels were still stated to be lower than the long-term average. 

In addition to the monitoring well network at the FTF, DOE also monitors groundwater quality in 

the Western Groundwater Operable Unit (ERD-EN-2005-0127). Elevated concentrations of 

non-volatile beta, Iodine-129, Strontium-90, and Tritium have been measured in what is referred 

to as the “South Plume” in the Western Groundwater Operable Unit down-gradient of the FTF 

(ERD-EN-2005-0127 [2014]). 

Review of Distribution Coefficient Reports (Monitoring Factor 4.1 “Natural Attenuation of 

Plutonium” (ML12212A192)) 

A data set of 64 Kd values for Pu was assembled from literature values from batch 

determinations of samples of Savannah River site sediment (Almond et al., 2012). These data 

were taken under varying conditions of pH, oxidation state of the tracer and contact times (1, 6, 

or 33 days). Kd values ranged from 107 to 50,000 mL/g. A number of statistical distribution 

models were evaluated with three goodness-of-fit metrics for the entire data set. The data were 

also segregated into several groups; pH > 7, pH ≤ 7, and a combination of pH and sediment 

texture. 

 

1

 One FTF well was dry--background well FBG001D. 
2 

Conclusions of this statistical analysis are: 

 

1. pH 4.6 to 10.47 sediment Pu Kd values ranged from 100 to 50,000 mL/g (mean Kd = 

8,559 ± 10,823 mL/g; to simulate a plume moving through all pH conditions), 

2. pH 4.6 to 7.0 sediment Pu Kd values ranged from 100 to 33,000 mL/g (mean = 6,047 ± 

6,971 mL/g ; to simulate a plume moving through far-field conditions), 

3. pH 7.01 to 10.47 sediment Pu Kd values ranged from 210 to 50,000 mL/g (mean = 

12,851± 14,525 mL/g; to simulate a plume moving through a basic cementitious plume 

conditions), and 

4. the Weibull distribution was recommended for each of the Pu sediment distributions. 

Batch sorption tests were also performed to calculate Kd values for Niobium(Nb) and 

Selenium(Se) to SRS soils underlying the Saltstone Disposal Facility, and to study the sorption 

behavior of Radium(Ra) to reducing and non-reducing cementitious materials (SREL Doc. R-13-

0005, Rev. 1). All batch sorption tests considered both oxic and anoxic conditions to evaluate 

the sensitivity of experimentally derived Kd to redox state. Four different groundwater 

chemistries were considered: portlandite, saltstone leachate solution, calcite, artificial 

groundwater reflecting different stages of cement degradation and associated changes to key 

parameters most notably pH. The focus of this technical review is on the Nb distribution 

coefficient that is important to Tanks 5 and 6 closure (ML13273A299). The results of this study 

calculate Kds for Nb >1200 L/kg for all chemical conditions. 

NRC Evaluation

Review of FTF Environmental Monitoring Reports (Monitoring Factor 4.3 “Environmental 

Monitoring” (ML12212A192)) 

During 2013, SRS collected samples during the first and third quarters from 132

 wells at the FTF 

(see Figure 1a). Constituents analyzed include gross alpha, nonvolatile beta, tritium, nitratenitrite, cadmium, chromium, manganese, sodium, and Technetium(Tc)-99. These constituents 

were selected based on historical monitoring and an evaluation of the most prevalent 

radionuclides expected during operations, waste removal, and tank closure activities. 

Radionuclide-specific analyses are performed if sample analysis results exceed trigger levels of 

15 pCi/L gross alpha, or 50 pCi/L nonvolatile beta. In 2013, the nonvolatile beta trigger level 

was exceeded at a well screened in the lower aquifer zone of the Upper Three Runs Aquifer 

(UTRA), well FTF 28. Because well FTF 28 exceeded the screening trigger level, several other 

constituents were analyzed. Radium-226, Iodine-129, and Tc-99 were detected in the 

radionuclide-specific analyses. Consistent with measurements in previous years, Tc-99 was 

measured at values above 1000 pCi/L in well FTF 28 (see Figure 9 in SRNS-RP-2014-00226). 

Previously, Tank 83

 was implicated as a possible source of the non-volatile beta/Tc-99 

measurements at well FTF-28 (SRNS-RP-2012-00022, Rev. 1). However, currently SRS 

scientists attribute the radioactivity measured at well FTF 28 to releases from the F-Area 

Inactive Process Sewer Line (FIPSL). The FIPSL is a vitrified clay pipe used to transfer acidic, 

low-level radioactive wastewater from the separations facilities to the F-Area seepage basins to 

the southwest of the FTF. A section of the FIPSL collapsed just south of well FTF 28 as shown 

 

2

 One FTF well was dry—background well FBG 1D. 

3

 In 1961, Tank 8 waste was released to the environment due to a tank over-fill event and suspected 

leakage through the fill line encasement (DPSU 75-11-8, DPSU 76-11-8, DPST-86-00511). 
3 

in Figure 2a. The FIPSL is associated with a non-volatile beta plume that extends from FTF 28 

to monitoring wells located to the southwest of FTF-28 in the Western Groundwater Operable 

Unit (Figure 2b). 

Near the collapsed section of the FIPSL, elevated non-volatile beta has been measured at wells 

FSL 5D (see Figure 2b), as well as FTF 28. However, FSL 5D is located in the upper aquifer 

zone of the Upper Three Runs Aquifer (UTRA) and is screened at an elevation of 204-224 ft, 

while FTF 28 is screened in the lower aquifer zone of the UTRA at an elevation of 151-161 ft (43 

ft lower in the UTRA). Additionally, FTF 28 is also located slightly up-gradient and north of the 

collapsed FIPSL section. Although wastewater released from the FIPSL could have migrated 

towards FTF 28 in the vadose zone, it is more difficult to explain the vertical migration of the 

radioactivity to the lower aquifer zone of the UTRA where FTF 28 is screened in such a short 

lateral distance from the source. Elevated non-volatile beta has also been measured at FGW 

12C, a well also screened in the lower zone of the UTRA at and elevation 154-164; however, 

this well is located approximately 700 m down-gradient of the FIPSL, a significant distance away 

from the source. 

During the March 27-28, 2013, onsite observation NRC staff inquired about the source of 

elevated non-volatile beta and Tc-99 at FTF 28 (ML13113A322). DOE contractors indicated 

that the source of the FTF 28 non-volatile beta and Tc-99 was now thought to be the FIPSL, 

rather than Tank 8 as originally suspected. NRC staff inquired about the vertical extent of the 

plume that lies directly underneath the process sewer lines. DOE contractors explained that a 

residual hydrogen ion plume was also present that is similarly, vertically extensive in the UTRA 

further supporting the hypothesis that elevated non-volatile beta and Tc-99 at FTF was sourced 

by the FIPSL. SRNS-RP-2014-00226 also indicates that pH is depressed in FTF 28 (pH values 

between 4.5 and 5 in 2013) compared to other wells screened in the lower zone of the UTRA 

(see text on page 9 and Figure 10). However, SRNS-RP-2014-00226 also indicates that FTF 

9R is likely impacted by the FIPSL with low pH increasing the solubility of manganese, while the 

pH measurements in FTF 9R were actually not low at all compared to background levels (5.9 

and 6.3 in 2013). Given the small data set, and what appears to be a weak correlation between 

pH and constituent concentrations that have been attributed to the FIPSL, the arguments 

presented are not conclusive. Explanations for the vertical extent of the plume include the 

following: (1) the lower zone of the UTRA was contaminated during FTF 28 well construction, or 

(2) Tc-99 present in FTF 28 is impacted by another F-Area source (other than the FIPSL). 

In an effort to evaluate the efficacy of the FTF monitoring well network for detecting future 

releases of radioactivity from the tank farm, NRC staff analyzed DOE’s FTF Performance 

Assessment (SRS-REG-2007-00002, Rev. 1) calculations (e.g., Figure 3) and ran DOE’s 

saturated zone PORFLOW models. NRC staff matched features with known coordinates on (1) 

a map that utilized the Universal Transverse Mercator (UTM) coordinate system to (2) the maps 

illustrated on Figures 5.2-2 and 5.2-5 in SRS-REG-2007-00002, Rev. 1, that depict the FTF 

local model grid, which is not in the UTM coordinate system. This was necessary because only 

UTM coordinates were available for FTF wells (see SRNS-RP-2014-00226, Table 1), and the 

UTM coordinates had to be translated to FTF grid cells. Next, FTF PORFLOW model 

simulations of Tc-99 releases from various FTF sources were executed, and concentrations 

were extracted from the model from the water table surface, vertically downward to the bottom 

of the model domain at each FTF well location. Tc-99 was chosen for the simulations because 

it is fairly mobile and long-lived (i.e., acts like a conservative tracer that would produce a fully 

developed plume in shorter simulation periods). The statistical analysis of concentrations in the 
4 

UTRA at the FTF well locations was reviewed to determine the optimal well screen depth and 

elevation. 

Based on NRC staff’s evaluation, NRC staff thinks that the monitoring well network could be 

enhanced to help ensure releases from the FTF facility are detected. Table 1 lists each FTF 

well and provides an assessment of the tank or set of tanks that each FTF well is best aligned 

with based on Figure 3 stream traces, and also evaluates, based on the PORFLOW model 

simulations described above, whether the well is screened at an appropriate depth in the aquifer 

to best detect releases from those tanks. While the PORFLOW calculations reflect modeling 

results and may not reflect reality, it is not clear to NRC staff how DOE contractors selected the 

monitoring well locations at FTF, as they do not always appear to be screened at the most 

appropriate depth based on FTF Performance Assessment (PORFLOW) modeling results. 

NRC staff suggests that when the monitoring well network is evaluated in the future, DOE 

contractors perform an evaluation using the FTF Performance Assessment (PORFLOW) model 

and provide input on the horizontal and vertical distribution of wells in the FTF monitoring 

network to DOE subcontractors responsible for well construction, maintenance, and monitoring. 

This effort should be focused on identifying well locations that would maximize the ability to 

detect FTF releases and minimize false negative monitoring well results. Adequate 

groundwater monitoring data could help validate Performance Assessment Models, as well as 

provide direct evidence that the tank farm facilities are operating as intended. NRC staff will 

continue to monitor the basis for and adequacy of the FTF monitoring well network and field and 

chemical data collected, as tank farm closure progresses. 

Figure 1: FTF Monitoring Well Network. Adapted from Figure 4 in SRNS-RP-2014-00226.
5 

(a) 

(b) 

Figure 2: Western Groundwater Operable Unit Monitoring Well Network and Collapsed 

Section of F-Area Inactive Process Sewer Line (a) and Non-Volatile Beta Plume (b). 

Adapted from Figure A-2 and A-5 in ERD-EN-2005-0127 (2014).
6 

FTF 

Well 

Screen 

Interval 

Western 

Sources 

Eastern 

Sources 

Assessment of Well Location and 

Screen Depth 

FTF 9R 203-212 -- Tanks 1 and 2 Screen depth high for eastern sources. 

FTF 12R 195-205 Tanks 19 

and 20 Tanks 3 and 4 Screen depth okay for western sources. 

Screen depth high for eastern sources. 

FTF 19 198-228 Tank 44 Tanks 5 and 6 

Not aligned well, but screen depth okay for 

western sources. 

Screen depth high for eastern sources. 

FTF 20 198-228 Tanks 25 

and 44 Tanks 7 and 8 

Screen depth little high but okay for western 

sources. 

Screen depth high for eastern sources. 

FTF 22 212-242 Tanks 27 

and 46 -- Screen depth high for western sources. 

FTF 23 201-231 Tank 47 Tanks 33 and 

34 

Screen depth okay but a little high for western 

sources. 

Screen depth okay but a little high for eastern 

sources. 

FTF 28 151-161 -- Tanks 5 and 6 Screen depth high for eastern sources. 

FTF 29 157-177 -- Tank 1 and 2 Screen depth high for eastern sources. 

FTF 30 183-193 Tanks 26 

and 45 -- Screen depth little low for western sources. 

FTF 30D 213-223 Tanks 26 

and 45 -- Screen depth high for western sources. 

FTF 31 186-1964 -- Tanks 33 and 

34 

Screen depth okay for eastern sources.

Table 1: Assessment of FTF Monitoring Well Network Based on Figure 3 and PORFLOW 

Model Simulations. 

 

4

 Note that SRNS-RP-2014-00226 indicates that the screen depth for FTF 31 is 76-106 ft. This is 

different than the screen depth reported in a data report with FTF well construction details provided as a 

follow-up action item from the September 26-27, 2012, Onsite Observation (ML12299A188) of 96-106 ft. 
7 

Figure 3: Stream Traces from FTF Tanks, FTF Local Model Grid, and FTF Well Locations 

Assigned to Model Cells. Adapted from Figure 5.2-5, SRS-REG-2007-00002, Rev. 1. 

Review of Distribution Coefficient Reports (Monitoring Factor 4.1 “Natural Attenuation of 

Plutonium” (ML12212A192)) 

DOE performed a statistical analysis of 64 Kd values (SRNL-STI-2011-00672) taken from many 

areas and materials around the Savannah River Site, in an attempt to re-examine Kd from a sitewide perspective. In this report, chemistry is considered only in a very simple manner (i.e. pH 

binned as greater or less than 7) and Plutonium(Pu) redox state was not considered. As a 

result NRC staff considers this statistical analysis inappropriate. 

17 18 

20 19 

1 2 

3 

4 

5 6 

7 8 

25 

44 

26 

27 

28 

45 

46 

47 

33 

34 

FTF 19

FTF 20

FTF 22

FTF 23

FTF 30/30D 

FTF 29 

FTF 9R 

FTF 12R 

FTF 28 

FTF 31
8 

This same report suggests that a Pu Kd value of 650 mL/g be used for sandy sediment because 

1) information from a modeling analysis (Demirkanli, 2007) of long-term lysimeter studies 

(Kaplan et al., 2006) indicate that the Kd should be 1800 mL/g and that 2) the statistical analysis 

showed that the 290 ml/g value is in the lower quantiles. The sediment in the lysimeter appears 

to have had more clay in it than typically found at the FTF location and so the 1800 value was 

lowered to 650 ml/g. This value in turn was increased for the “near field” of the tanks using a 

factor of two recommended in SRNL–STI–2009–00473, Rev. 0, to account for greater 

adsorption due to elevated pH resulting from grout leaching. The use of a factor to adjust Kd for 

effects of higher pH due to grout is an arbitrary adjustment that will vary with pH, time, and 

aqueous speciation. It also depends on the scenario by which water intrudes into the tanks, 

with some conceptual models not involving water that has been conditioned by grout. While 

leachate that is influenced by cement chemistry will have an impact in the near-field, NRC staff 

finds the approach of arbitrarily assigning a factor to increase adsorption to be inappropriate. 

As expressed further in the HTF Technical Evaluation Report (ML14094A496), NRC staff has 

technical issues associated with the same cement leachate factors applied in the HTF 

Performance Assessment (Table 4.2-25; SRR-CWDA-2010-00128, Rev. 1). The cement 

leachate factors are used to account for the effect of high pH leachate on the ability of natural 

soils to sorb key radionuclides also present in the leachate. The cement leachate factors used 

in the HTF Performance Assessment are based on information provided in SRNL-STI-2009-

00473, Rev. 0, and Hanford site data. As stated in the HTF Technical Evaluation Report, 

because the Hanford site geological and geochemical environment contrasts sharply with SRS, 

using Hanford site data to calculate the factors for SRS is not justified without an element-byelement analysis of the chemical processes affecting sorption. Element-specific considerations 

were applied to some but not all key radionuclides when deriving cement leachate factors. With 

respect to uranium(U) and neptunium, DOE uses cement leachate factors for sand greater than 

1, and DOE selected a value of 0.9 for Pu, which is higher than the value of 0.25 used in the 

Hanford study. Selection of the Pu and U cement leachate factors are based on solubility 

arguments. However, sorption describes a different mechanism limiting aqueous phase 

concentrations and if limited by solubility, experiments used to study sorption may over-estimate 

calculated Kd values. As stated in the HTF Technical Evaluation Report, the sorption behavior 

of actinides at high pH in the unsaturated zone may be strongly dependent on the presence of 

carbonate species. Sorption may decrease in the presence of elevated pH, if high carbonate 

concentrations exist in the natural environment. Therefore, additional information is needed to 

support the cement leachate factors applied for key radionuclides such as Pu. 

With regard to Pu Kd averaging approach applied by DOE in its performance assessment 

models for the SRS tank farms, NRC staff continues to find the approach inadequate as it 

potentially overestimates travel time for the more mobile fraction of Pu and thus early dose from 

Pu. Long-term lysimeter experiments conducted at SRS and other work referenced in Kaplan 

(2006) show that although most Pu is in the (IV) state, there is a small component that at times 

is in a much more mobile form. In fact, most Pu that is in solution (albeit a very small 

concentration) is in the Pu (V) form. Even PuO2 (s) which had been considered a stable form of 

Pu(IV) has been shown to oxidize in the presence of water forming a substantial fraction (27%) 

of Pu(VI) (Haschke et al., 2000). In SRS sediment it is thought that Pu cycles repeatedly 

through the Pu(IV) and Pu(V) oxidation states in response to wet/dry cycles (WSRC–MS–2003–

00889). SRNL–STI–2009–00473 lists the ‘best” Kd value for sandy soil for Pu (V/VI) as 16 

mL/g, while for Pu (III/IV) the “best” value is 300 mL/g. The use of an average Kd value for 

different oxidation states is not appropriate, even if the values are weighted for proportions of 
9 

different redox states. The more mobile fraction of Pu should be modeled explicitly in the 

performance assessment models that will result in the more mobile fraction arriving at the 

compliance point earlier in time, possibly during the compliance period, and the concentration 

and dose from the more mobile fraction and less mobile fraction used to assess compliance with 

the 10 CFR Part 61, Subpart C, performance objectives. 

Batch sorption tests were performed to study the sorption behavior of Nb and Se to SRS soils 

underlying the saltstone disposal facility as well as to study the sorption behavior of Ra to 

reducing and non-reducing cementitious materials (SREL Doc. R-13-0005, Rev. 1). All of the 

sorption tests considered oxic and anoxic conditions, as well as four different groundwater 

chemistries reflecting different stages of cementitious material degradation (and associated pH 

changes). Although soils underlying the saltstone disposal facility may not be representative of 

water table aquifer sediments underlying the tank farm facilities, the results of this study are 

being leveraged to help provide support for the Nb distribution coefficient selected for use in the 

Tanks 5 and 6 Special Analysis (SRR-CWDA-2012-00106, Rev. 1). As indicated in the 

Technical Review Report for the Tanks 5 and 6 Special Analysis (ML13273A299), additional 

support for the Nb distribution coefficient of 160 L/kg was needed given the risk-significance of 

the parameter and recommendation of SRNL–STI–2009–00473 for the distribution coefficient of 

0 L/kg based on the expectation that Nb would exist as an anion in the natural environment at 

SRS. In fact, SREL Doc. R-13-0005, Rev. 1 also indicates that Nb exists as various ionic 

species at pH values above neutrality based on a literature review. While the study provides 

support for Nb Kd s greater than 1200 L/kg for all chemical conditions, several technical issues 

should be addressed to support the distribution coefficient values including the following: 

1. The soils used in the study are representative of soils underlying the SDF and may not 

be representative of aquifer sediments underlying the tank farms. In general, the soils 

used in the study have a higher clay content and greater sorption capacity compared to 

aquifer sediments underlying FTF. 

2. Solubility limits may have been exceeded in the experiments. If solubility limits were 

exceeded, then the results of the experiments may over-estimate Kd. 

3. The report indicates that cement leachate factors should be greater than 1 based on the 

results of the study; however, the study provides insufficient information to conclude that 

high pH, cement leachate emanating from the tanks would lead to higher sorption 

coefficients for SRS soils compared to non-cement-impacted leachate (i.e., all Kd s were 

stated to be >1200 L/kg so there is no basis to conclude which Kds would be higher). In 

fact, the text of SREL Doc. R-13-0005, Rev. 1 (page 12) indicates that Nb would exist as 

an anionic species for higher pH values suggesting that the Kd might decrease with 

increasing pH characteristic of cement leachate impacted ground waters. 

As stated above, the focus of this review is on the Nb distribution coefficient. Other technical 

issues such as the use of H2 gas in the experiments that may provide additional reducing 

capacity beyond what might be achieved in the field, and the targeted Eh and pH for the various 

pore waters (e.g., relatively low pH achieved for calcite representative pore water) should also 

be addressed if the results of the study will be relied on in the performance assessment 

calculations. 
10 

Teleconference or Meeting

None. 

Follow-up Actions

Most of the technical issues listed in this technical review report are listed in the FTF Monitoring 

Plan (ML12212A192) and will not be repeated. Unique technical issues not discussed in the 

FTF Monitoring Plan include the following: 

1. The NRC staff will continue to monitor the ability of the tank farm monitoring well network 

to detect releases from the tank farm facilities following closure. DOE could evaluate the 

monitoring well network by performing an analysis of the centerline of plumes emanating 

from tank sources should releases occur in the future, and provide input on optimal well 

locations to ensure that future releases from the tank farm facility would be detected. 

2. The NRC staff will continue to evaluate the source of elevated Tc-99 levels in well FTF 

28. It is not clear that releases from the F-Area Inactive Process Sewer Line could 

migrate vertically to the lower zone of the Upper Three Runs Aquifer in such a short 

distance from the source. This evaluation is important to ensure that the 

hydrogeological system at FTF is well understood and that releases from the tanks could 

be detected by the monitoring well network. DOE could provide additional support for 

the source of contamination detected at well FTF 28 by performing particle tracking to 

better understand contaminant plume trajectories. DOE could also perform a more 

formal statistical analysis of FTF, and Western Groundwater Operable Unit well data to 

correlate contaminant concentrations associated with various sources. 

3. The NRC staff will continue to monitor the Kd averaging approach used to simulate Pu 

transport in the natural system at FTF. DOE could address the issue by modeling 

explicitly more mobile and less mobile forms of Pu in future performance assessment 

calculations. 

4. The NRC staff will continue to monitor support for cement leachate factors developed for 

Pu (and other constituents). DOE could provide support for cement leachate factors by 

performing site specific analyses. 

5. NRC staff will continue to monitor the basis for selection of the Nb distribution coefficient 

or Kd value of 160 L/kg used in the Tanks 5 and 6 Special Analysis. DOE could address 

the technical issues by verifying the batch experiments did not exceed solubility limits 

and are representative of conditions at FTF (e.g., plot solid phase versus aqueous phase 

concentration or Kd versus concentration; evaluate Kd for FTF aquifer soils); or perform 

additional experiments to verify the Nb Kd. 

Open Issues

None. 
11 

Conclusions

The NRC staff has performed technical reviews of environmental monitoring and site-specific 

distribution coefficient reports prepared by the DOE to support FTF closure at Savannah River 

Site. This technical review memorandum is related to Monitoring Factor 4.1, “Natural 

Attenuation of Pu”, and Monitoring Factor 4.3, “Environmental Monitoring” listed in NRC staff’s 

FTF Monitoring Plan (ML12212A192). The NRC staff concludes the following: 

1. DOE has performed environmental monitoring at the FTF that provides useful 

information on the hydrogeological system at FTF. This information can also be used to 

better understand contaminant flow and transport and validate DOE Performance 

Assessment models. 

2. Uncertainty exists in the source of contaminant plumes detected via the FTF monitoring 

well network. Reducing this uncertainty will be important to better understanding 

contaminant flow and transport processes operable at the FTF. 

3. Progress has been made on development of cement leachate factors used to account 

for the impact of cement leaching on natural system sorption; however, additional 

information is needed to support factors for key radionuclides such as Np, Pu, and U. 

4. Progress has been made on development of site-specific Kd s for Nb; however, 

additional information is needed to support Kd values used in performance assessment 

calculations. 

5. Little progress has been made to address the technical issue associated with the Pu Kd

averaging approach used in tank farm performance assessment calculations. DOE 

should address this technical issue in the future. 

Many of the technical issues listed in this technical review report are listed in the FTF Monitoring 

Plan (ML12212A192) and will not be repeated here. Unique technical issues not discussed in 

the FTF Monitoring Plan that are listed as follow-up actions include the following: 

1. The NRC staff will continue to monitor the ability of the tank farm monitoring well network 

to detect releases from the tank farm facilities following closure. DOE could evaluate the 

monitoring well network by performing an analysis of the centerline of plumes emanating 

from tank sources should releases occur in the future, and provide input on optimal well 

locations to ensure that future releases from the tank farm facility would be detected. 

2. The NRC staff will continue to evaluate the source of elevated Tc-99 levels in well FTF 

28. It is not clear that releases from the F-Area Inactive Process Sewer Line could 

migrate vertically to the lower zone of the Upper Three Runs Aquifer in such a short 

distance from the source. This evaluation is important to ensure that the 

hydrogeological system at FTF is well understood and that releases from the tanks could 

be detected by the monitoring well network. DOE could provide additional support for 

the source of contamination detected at well FTF 28 by performing particle tracking to 

better understand contaminant plume trajectories. DOE could also perform a more 

formal statistical analysis of FTF, and Western Groundwater Operable Unit well data to 

correlate contaminant concentrations associated with various sources. 
12 

3. The NRC staff will continue to monitor the Kd averaging approach used to simulate Pu 

transport in the natural system at FTF. DOE could address the issue by modeling 

explicitly more mobile and less mobile forms of Pu in future performance assessment 

calculations. 

4. The NRC staff will continue to monitor support for cement leachate factors developed for 

Pu (and other constituents). DOE could provide support for cement leachate factors by 

performing site specific analyses. 

5. NRC staff will continue to monitor the basis for selection of the Nb distribution coefficient 

or Kd value of 160 L/kg used in the Tanks 5 and 6 Special Analysis. DOE could address 

the technical issues by verifying the batch experiments did not exceed solubility limits 

and are representative of conditions at FTF (e.g., plot solid phase versus aqueous phase 

concentration or Kd versus concentration; evaluate Kd for FTF aquifer soils); or perform 

additional experiments to verify the Nb Kd. 
13 

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