ML102250089

Response to Request for Additional Information Concerning Hematite Decommissioning Plan: Chapter 11, Environmental Monitoring Program

ML102250089
Person / Time
Site:	07000036
Issue date:	08/10/2010
From:	Hackmann E Westinghouse
To:	Document Control Desk, NRC/FSME
References
HEM-10-84
Download: ML102250089 (29)

Text

Westinghouse Non-Proprietary Class 3

8) Westinghouse ATTN: Document Control Desk Director, Office of Federal and State Materials and Environmental Management Programs U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Direct tel:

Direct fax:

E-mail:

Our ref:

Date:

Westinghouse Electric Company LLC Hematite Decommissioning Project 3300 State Road P Festus, MO 63028 USA 314-810-3368 636-937-6380 hackmaek@westinghouse.com HEM-I0-84 August 10, 2010

Subject:

Response to Request for Additional Information Concerning Hematite Decommissioning Plan: Chapter 11, Environmental Monitoring Program (License No. SNM-00033, Docket No. 070-00036)

References:

1) NRC (1. J. Hayes) letter to Westinghouse (E. K. Hackmann), dated July 2, 2010, "Westinghouse Hematite Decommission Plan Review Requests for Additional Information"

2) Westinghouse (E. K. Hackmann) letter to Document Control Desk (NRC),

HEM-09-94, dated August 12, 2009, "Decommissioning Plan and Revision to License Application" This letter provides the Westinghouse Electric Company LLC response to the NRC's Reference 1 request for additional information concerning Chapter 11, Environmental Monitoring, of the Decommissioning Plan of Reference 2. provides responses to the request for additional information, and provides an explanation of associated changes to the Decommissioning Plan resulting from those responses.

The actual changes to the Decommissioning Plan will be provided under separate cover.

Please contact Gerard Couture, Licensing Manager of my staff at 803-647-2045 should you have questions or need any additional information.

Sincerely,

~~~~a~vvUv E. Kurt Hackmann Director, Hematite Decommissioning Project

©2010 Westinghouse Electric Company LLC All Rights Reserved

HEM-10-84 August 10, 2010 Page 2 of 2 Attachments: 1) Response to Request for Additional Information Hematite Decommissioning Plan: Chapter 11, Environmental Monitoring

2) Replacement Table 11-1, response to RAI HDP-C11-Q3

3) Replacement Figure 11-1, response to RAI HDP-C11-Q3

4) Replacement Table 11-5, response to RAI HDP-C11-Q8

5) Replacement Table 11-4, response to RAI HDP-C11-Q13 cc:

J. J. Hayes, NRC/FSME/DWMEP/DURLD J. W. Smetanka, Westinghouse, w/o attachments J. E. Tapp, NRC Region III/DNMS/DB, w/o attachments to HEM-10-84 August 10, 2010 Page 1 of 19 ATTACHMENT 1 Response to Request for Additional Information Hematite Decommissioning Plan:

Chapter 11, Environmental Monitoring Westinghouse Electric Company LLC, Hematite Decommissioning Project Docket No. 070-00036 to HEM-10-84 August 10, 2010 Page 2 of 19 Decommissioning Plan Chapter 11, Environmental Monitoring The following reiterates the NRC requests for additional information (RAI) of letter dated July 2, 2010, followed by the Westinghouse response for each RAI. Some of the responses will result in changes, as noted, to the Decommissioning Plan (DP; Hematite Decommissioning Plan, DO-08-004, Revision 0.0). The changes to the DP will be provided under separate cover, denoted by vertical lines in the right margin of the document.

These RAI responses are organized in the same manner as the RAIs concerning DP Chapter 11.

For each RAI, the NRC's Comment, Basis and Path Forward is reiterated, and followed by the Westinghouse Response.

1.

(HDP -C11-Q1) Comment: In several sections of Chapter 11, reference is made to the Effluent and Environmental Monitoring Plan (EEMP) and the Water Management Plan.

However, details as to what the Plans consist of are not described in the Hematite Decommissioning Plan (DP). [The Hematite Decommissioning Project uses the acronym HDP. To avoid confusion, the use of HDP by the commenter to refer to the Hematite Decommissioning Plan has been changed to Hematite DP.]

Basis: Details of the EEMP and the Water Management plans are necessary to complete the NRC staff's evaluation of the Hematite DP.

Path Forward: Provide a copy of the Effluent and Environmental Monitoring Plan (EEMP) or incorporate into the Hematite DP details from the EEMP which describe the effluent and environmental monitoring plan.

Westinghouse Response:

A copy of HDP-PO-EM-001, Effluent and Environmental Monitoring Plan, Revision 0, will be provided under separate correspondence.

2.

(HDP-C11-Q2) Comment: Footnote B of Table 11-1 indicates that the As Low as Reasonably Achievable (ALARA) goal will be based upon annual average concentrations and for liquids this is applied at the site boundary. It seems inappropriate to define the process as being ALARA when the ALARA actions are limited to basing the consequences on an annual average concentration and there is so much time when no activities are occurring.

Basis: An ALARA is a program whereby licensees implement actions to limit the exposure of on-site and off-site personnel. Determination of the dose based upon an annual average concentration cannot be considered as an implementation of an ALARA program. Appendix D of NUREG-1757 provides guidance on the information that the licensee should provide regarding the Environmental ALARA Evaluation Program. This to HEM-10-84 August 10, 2010 Page 3 of 19 includes a description of the ALARA goals and the procedures, engineering controls, and process controls to maintain doses ALARA.

Path Forward: Provide a description of the ALARA program which will be implemented during the decommissioning.

Westinghouse Response:

HDPs ALARA goal is established at 20 percent of the effluent limits for air and water in 10 CFR 20, Appendix B, Table 2, Column 1 and Column 2, respectively. In addition to the ALARA goal, HDP commits in Section 11.1.1.2 to taking investigatory and corrective actions when an individual air or water sample exceeds 50 percent of the effluent limits in 10 CFR 20, Appendix B, Table 2, Column 1 or Column 2, respectively.

This Investigation Level in response to a single sample result prompts near real-time action to identify potential trends that may jeopardize the ALARA goal if not corrected in a timely manner. HDP believes this is more responsive approach than increasing the frequency of assessment.

Section 11.1 contained a description of the environmental ALARA program, including a description of ALARA goals for effluent control, a description of the procedures, engineering controls and process controls to maintain doses ALARA, and a description of the ALARA reviews and reports to management. These descriptions have been upgraded based on other comments on this section. These descriptions are based on Appendix D to NUREG 1757.

HDP has invested heavily in technologies to reduce liquid effluent concentrations to levels that are ALARA. To date, HDP has expended approximately $250,000 on the water treatment system in order to remove radioactivity and volatile organics from liquid effluents. As another ALARA action, HDP has placed impervious liners in the two evaporation ponds that formerly were used in handling process water. One pond has been temporarily backfilled to preclude the collection of water. The liner serves to isolate the backfill from the contaminated pond bed, and the absence of water head pressure reduces the potential for downward migration of contamination. The remaining pond is used as part of the sites water collection system for remediation activities. This liner isolates the collected water from the contaminated pond bed. With these liners now installed, the concentration of radioactivity in the pond water discharge is now much lower than before. These actions are indicative of HDPs commitment to ALARA.

Section 11.1 has been revised to state the following:

11.1 ENVIRONMENTAL ALARA EVALUATION PROGRAM This section describes the requirements for establishing and maintaining releases of radioactive materials to levels which are ALARA.

to HEM-10-84 August 10, 2010 Page 4 of 19 11.1.1 ALARA COMMITMENT Hematite Site activities will be conducted in a manner that minimizes adverse impact to the health and safety of the public, site employees and the environment. This goal will be achieved through the implementation of programs that maintain the release of radioactive material and exposure to ionizing radiation at levels that are ALARA.

In accordance with Regulatory Guide 8.37, ALARA Levels for Effluents from Materials Facilities (Reference 11-4), every reasonable effort will be made to ensure that decommissioning activities are conducted in accordance with ALARA principles, and that concentrations of radioactive materials in air and liquid effluents are minimized in a manner consistent with the ALARA philosophy.

11.1.1.1 ALARA Goals The Hematite Site ALARA goal for airborne effluents is based on controlling the generation of dust containing airborne radioactivity during contaminated soil movement and excavation. The Hematite goal for liquid effluents is based on collecting liquids that become contaminated from soil and material being remediated, and then processing those liquids through a Water Treatment System to remove the radioactivity to the maximum extent practical. Section 11.2.4 describes the effluent control program.

The Hematite Site numerical ALARA goals for air and liquid effluent concentrations have been established at 20 percent of the applicable values in 10 CFR 20, Appendix B, and are summarized in Table 11-1. These goals are based on the annual average values contained in Table 2 of 10 CFR 20, Appendix B. These goals are not intended to be applied as a limit, but rather as a standard for comparison during decommissioning work planning and execution.

These goals may be adjusted based on decommissioning experience or based on detailed information related to specific work activities.

11.1.1.2 ALARA Investigation Levels The investigation levels for air and liquid effluent concentrations have been established at 50 percent of the applicable values in 10 CFR 20, Appendix B. If an individual effluent sample result exceeds an investigation level, a review of the decommissioning activities will be performed to identify appropriate changes to work to HEM-10-84 August 10, 2010 Page 5 of 19 methods and/or engineering controls to reduce the concentrations as low as reasonably achievable.

11.1.2 PROCEDURES, PROCESS CONTROLS AND ENGINEERING CONTROLS The outcome of the efforts to achieve the ALARA goals will be realized through implementation of HDP programs and procedures that maintain the release of radioactive material and exposure to ionizing radiation at levels that are ALARA. A summary description of the procedures, process controls and engineering controls to maintain worker exposure and effluent concentrations of radioactive material ALARA, is summarized in Section 11.2.4. In addition to procedures implementing EEMP requirements, specific work plans will be developed for all major decommissioning activities to ensure effective implementation of engineering controls.

11.1.3 ALARA REVIEWS Environmental ALARA is continually reviewed as analytical data for air and liquid effluent is received and evaluated. In addition, the effectiveness of this continual review is evaluated through the use of periodic reviews, surveillances and/or audits. Table 10-14 lists three such documented reviews: an ALARA report is submitted semi-annually by the Radiation Safety Officer (RSO) to the Project Director, an annual ALARA review by the Project Oversight Committee, and an annual audit of the ALARA program by Quality Assurance. Periodic audits of the effluent and environmental monitoring programs and associated procedures will be performed as provided by the site quality assurance plan. Additionally, the RSO may elect to perform periodic surveillances of the environmental effluent control and monitoring program, to ensure ALARA considerations are being effectively applied to specific decommissioning work activities.

3.

(HDP-C11-Q3) Comment: With respect to airborne effluents it would seem that the sampling point also needs to be at a downwind location at the maximum off-site location based upon the process being performed.

Basis: Depending upon the process and the environmental conditions, the maximum location for effluent monitoring may not be located at the perimeter.

to HEM-10-84 August 10, 2010 Page 6 of 19 Path Forward: Westinghouse Electric Company (WEC) should include in its airborne effluent monitoring an assessment for the maximum offsite location.

Westinghouse Response:

The processes to be used by HDP during decommissioning involve the demolition of buildings, soil excavation and waste handing. These activities occur outdoors, and typically do not create discrete release points for air effluents. Nor do they involve stacks or heat sources that would elevate potential releases over the perimeter. Rather, air releases occur at ground level within the vicinity of the work and tend to be more widespread. Thus, downwind airborne sampling at the perimeter of decommissioning work activities is the best method to assess the maximum concentration in air effluent.

The first two sentences of Section 11.2.1 are revised to reflect the above explanation. In addition, wording was added at the end of Section 11.2.1 and to row 1 of Table 11-1 to identify the use of fixed air samplers for effluent monitoring as well as environmental monitoring (Section 11-3).

Section 11.2.1 has been revised to state, the following:

Since decommissioning activities involve outdoor soil movement and excavation, these activities do not typically create discrete release points for airborne effluents. Nor do they involve stacks or heat sources that would elevate potential releases over the perimeter. Rather, air releases occur at ground level within the vicinity of the work and tend to be more widespread. Thus, downwind airborne sampling at the perimeter of decommissioning work activities is the best method to assess the concentration in air effluent. Perimeter air sampling will be performed when work activities are likely to generate at the perimeter of the work activities, airborne radioactivity concentrations in excess of 20 percent of the values listed in 10 CFR 20, Appendix B, Table 2, Column 1 (Reference 11-3).

The number and location of perimeter air samplers will be established based on consideration of the location and nature of current work activities, and environmental conditions such as wind direction. When performed, perimeter air sampling will be done on a continuous basis and samples will be analyzed daily, as summarized in Table 11-1.

Note that the occupational air concentrations within the work area will be measured using personal air sampling pumps or additional low-volume portable sampling pumps independently of the perimeter sampling.

In addition, the data obtained from air samplers positioned at fixed locations near the perimeter of the Central Tract Area as a part of the Environmental Monitoring Program will provide supplemental data for effluent monitoring. These fixed air monitoring locations are identified Table 11-1 and on Figure 11-1. (Table 11-1 and Figure 11-1 are enclosed.)

to HEM-10-84 August 10, 2010 Page 7 of 19

4.

(HDP-C11-Q4) Comment: The collection mode for the sanitary wastewater treatment liquid effluent is not specified in Table 11-1. It appears that only the analytical frequency "weekly" is specified.

Basis: The collection mode for the Sanitary Wastewater Treatment effluent stream should be specified.

Path Forward: Specify the collection mode for the Sanitary Wastewater Treatment effluent stream.

Westinghouse Response:

The current mode of collection is one grab sample per week. An auto-sampler will be installed prior to commencement of work activities under the approved DP and the EEMP will be updated to reflect continuous sample collection. Composite sampling has been added to Table 11-1. (Table 11-1 is enclosed.)

5.

(HDP-C11-Q5) Comment: It is stated in Section 11.2.1 of the Hematite DP that air effluent sampling will consist of perimeter sampling. It is also stated that perimeter sampling will only occur when work activities are likely to generate, at the perimeter of the work activities, airborne radioactivity concentrations in excess of 20 percent of the values listed in Appendix B, Table 2 of 10 CFR Part 20. The number and the location of the perimeter air samplers will be established based upon consideration of the location and nature of the current work activities and environmental conditions such as wind direction.

Basis: Effluent monitoring is typically required when a particular process has the potential for releasing a given amount of material which could contribute a given fraction of the allowable dose. It is usually not based upon a given application of the process but rather based upon the potential. In addition, when such processes do not include a defined discharge point, fixed monitoring locations are typically selected to provide some stability to such a program.

Path Forward: The effluent monitoring program should be a function of the processes being performed. Where a defined release point exists for the process, that discharge point should be monitored for its release. To ensure adequate monitoring for those instances where a fixed release point cannot be identified, perimeter monitoring is acceptable but the monitors should be fixed in location and should provide a decommissioning project history. The fixed perimeter monitors should be supplemented by mobile sampling locations which account for environmental factors and the process.

to HEM-10-84 August 10, 2010 Page 8 of 19 Westinghouse Response:

The nature of the decommissioning work activities drives the specific requirements for perimeter monitoring based on the potential to generate airborne radioactivity.

Downwind air sampling with mobile samplers appropriately positioned at the perimeter of the work area is believed to be the most appropriate method to assess the potential off-site impact. The number and location of perimeter samplers is based on the nature of the work activity (process) since not every soil movement process will have the same potential impact for generating airborne effluents. For example, excavation of water-laden soil would likely not have the potential to generate the same amount of airborne effluent that excavation of dry silty soil may generate.

Westinghouse had included both mobile and fixed air sampling locations in its effluent monitoring program, as identified in the first row of Tables 11-1 (Perimeter - which is mobile) and of Table 11-5 (Fixed Locations). As discussed in the response to Comment HDP-C11-Q3, Table 11-1 has been revised to include the fixed air sampling locations. Figure 11-1 has been added and it shows the locations of the fixed air samplers. (Table 11-1 and Figure 11-1 are enclosed.) These fixed air samplers provide supplemental data to that obtained from mobile perimeter monitoring, in addition to their basic function in the Environmental Monitoring Program.

In the event that Westinghouse chooses to treat materials onsite using a soil vapor extraction system to remove volatile organic compounds, a fixed discrete sample point will be established to sample the effluent. Prior to the operation of such a system, a work package and associated procedures will be established and the sampling will be included in the Effluent and Environmental Monitoring Program. Continuous sampling will be performed when the system is in operation.

6.

(HDP-C11-Q6) Comment: Section 11.2.3.1 of the Hematite DP states that "liquid effluent will be controlled by an evaluation of laboratory results to determine suitability for release, or by process knowledge and retrospective confirmation of the concentrations based on subsequent laboratory analysis." It is also indicated that methods for water treatment will be implemented when appropriate to further reduce concentrations released to the environment. However, no description is provided of the laboratory analysis, process knowledge or methods for water treatment which will be utilized to minimize the release. Table 11-1 specifies Gross Alpha and Gross Beta as the types of analyses for liquid effluent and in a footnote states, "Analytical procedures that provide equivalent data quality (e.g., liquid scintillation, kinetic phosphorescence analysis or alpha spectroscopy) may be selected based upon the sample medium." However, clarification is needed on how and when these other methods will be employed. A threshold where specific isotopic analysis will be performed should also be identified.

to HEM-10-84 August 10, 2010 Page 9 of 19 Basis: Appendix D of NUREG-1757 indicates that a description should be provided of the controls that will be used to minimize releases of radioactive material to the environment.

Path Forward: The types of detection methods and laboratory analysis should be specified, including ability to detect Tc-99. The methods for reducing the concentrations from the water treatment facility to the environment should be provided.

Westinghouse Response:

Section 11.2.3.1 has been revised to add after the penultimate sentence, which is quoted in the comment, Sample collection and analysis is discussed in Section 11.2.3.4.

Process knowledge will be based on the liquid being consistent in terms of source (e.g.,

same location) and method of generation (e.g., precipitation) as a liquid where previous sample results are known. A discussion of the minimum detectable concentration by the analysis has been added to Section 11.2.3.4. A discussion of when isotopic analysis is required has been added to Section 11.2.3.4. The added text is:

The MDC target for laboratory analysis of gross beta and gross alpha analysis of liquid effluents is established at 5 percent of the applicable 10 CFR 20 Appendix B, Table 2, Column 2 limits. For on-site analysis using a proportional counting system, the MDC target is 25 percent of the applicable 10 CFR 20 Appendix B, Table 2, Column 2 limits.

The MDC targets for laboratory analysis of isotopic uranium and Tc-99 in liquids are 1.0 pCi/L and 3.0 pCi/L, respectively. These targets are less than the guidance in Regulatory Guide 4.16 (Reference 11-6) of 5 percent the applicable limits.

Consistent with Reference 11-6, isotopic analysis of effluent water samples shall be performed when radioactivity concentrations are in excess of 10 percent of the annual limits specified in 10 CFR 20, Appendix B, Table 2, Column 2. The methods of isotopic analysis for uranium and Tc-99 in liquids are ASTM 3972-90M and USEPA 906.0M, respectively, or equivalent.

Section 11.2.4.1 is revised to describe the WTS controls that reduce the concentration of radioactivity in liquid effluents. The added text is:

Collected water will be directed to the WTS for analysis and treatment as required. Surface water that pools on-site will be tested. Based upon the concentration of contaminants (by comparison to the ALARA goals) it may either be filtered to remove solids using the bag filters and released to a permitted outfall or processed through the WTS. The treatment will reduce contaminates in the water through the following mechanisms:

to HEM-10-84 August 10, 2010 Page 10 of 19 Settling of solids entrained in the liquid. This mechanism is enhanced by the addition of polymer flocculent via a mixer as water enters a series of quiescent settling tanks.

10-25 micron bag filters to remove remaining entrained material.

Granulated activated carbon filters (virgin anthracite media) to remove volatile organics and Technetium 99.

5-10 micron bag filters to remove remaining entrained material.

Ion exchange units (zeolite media) to remove metals, including uranium and the Technetium-99 that may be in solution as uranyl or technetium carbonate complexes and are not removed by the granulated activated carbon filters.

The text of Section 11.2.4.1 discussing the Sanitary Wastewater Treatment Plant has been revised to state While the Sanitary Wastewater Treatment Plant is not designated to receive contaminated liquids, liquid effluent from this system is monitored in accordance with the EEMP. The Sanitary Wastewater Treatment Plant is primarily a below-grade system that is checked on a weekly basis for proper operation. The Sanitary Wastewater Treatment Plant was installed in 1977-78. Consistent with systems of that era, it does not have a leak detection system.

7.

(HDP-C11-Q7) Comment: Section 11.3 of the Hematite DP states that a revision to a monitoring location contained in the EEMP may be replaced with an alternate location without prior NRC approval provided that the alternative is representative of the original location and that no other changes are necessary. However, justification for the change is not included as a stipulation. Section 11.3 also states that corrections will be taken to investigate the cause of a "significant" continuous upward trend and that remedial actions will be taken as appropriate.

Basis: Appendix D of NUREG-1757 provides guidance which indicates that the licensee should provide a summary or a diagram of the location of all effluent discharge points.

Path Forward: WEC should clarify Section 11.2.3.3 and Table 11-1 to ensure that the information is consistent with the guidance of NUREG-1757. Replacement of monitoring locations should be a last resort. The documented evaluation should also include justification for replacing a monitoring location. Clarify the term significant and provide more detail for the investigation process.

Westinghouse Response:

Figure 11-1, which contains planned liquid effluent discharge points for decommissioning, has been added. (Figure 11-1 is enclosed.)

In Section 11.3, the conditions for replacing a monitoring location are revised to state; to HEM-10-84 August 10, 2010 Page 11 of 19 Revisions to the Environmental Control and Monitoring Program contained in this document may be made without prior NRC approval for the following conditions, provided POC approval is obtained:

Adequate justification is provided to discontinue sampling an effluent discharge location, or Adequate justification is provided to relocate an effluent monitoring location (e.g., remediation must occur at the original location and effluent flow path altered),.and Adequate justification is provided that the change does not otherwise necessitate a change to the license application.

The criterion of replacing a monitoring location as a last resort has not been included since the dynamic nature of decommissioning operations occurring in the environment itself may mean that replacement of a location improves monitoring. A condition requiring replacement only as a last resort may result in remaining in a less than ideal location.

The sentence in Section 11.3 addressing a significant upward trend was revised to state, The quarterly environmental monitoring results shall be reviewed for trends using the non-parametric Mann-Kendall test, or equivalent. If an adverse trend is identified in the sampling data, the EH&S Manager and RSO will be notified and a review of the associated decommissioning activity(s) will be conducted identify changes to work methods and/or engineering controls should be implemented, as appropriate, to reduce effluent concentrations to ALARA levels.

8.

(HDP-C11-Q8) Comment: It appears from discussion in Section 11.2.1 of the Hematite DP that mobile air samplers will be utilized and will be moved based upon the work activities, wind direction and other environmental conditions. It would appear appropriate for some air samplers to be mobile and some to be permanent.

Basis: Material may be discharged from the site as a result of specific decommissioning processes or as a result of the entrainment of site soil and other material which may become airborne as a result of climatic conditions. The methods for determining the impact of site decommissioning should account for potential continuous release mechanisms and those associated with a process.

Path Forward: WEC should include in the Hematite DP air sampling program both mobile and permanent air sampling locations, describe the manner in which each will be employed, and provided the location of each permanent air sampler.

to HEM-10-84 August 10, 2010 Page 12 of 19 Westinghouse Response:

Westinghouse has included both mobile and fixed location air sampling locations in the monitoring programs, as identified in the first row of Tables 11-1 (Perimeter - which is mobile) and 11-5 (Fixed Locations). (Tables 11-1 and 11-5 are enclosed.) The responses to Comments HDP-C-11-Q3, HDP-C11-Q5, and HDP-C11-Q7 resulted in additional text being added to Chapter 11 to further explain monitoring for airborne radioactivity in the environment. In the event that Westinghouse chooses to treat soil and soil like materials onsite using a soil vapor extraction system to remove volatile organic compounds, a fixed discrete sample point will be established to sample the effluent. Prior to the operation of such a system, a work package and associated procedures will be established and the sampling will be included in the Effluent and Environmental Monitoring Program. Continuous sampling will be performed when the system is in operation.

9.

(HDP-C11-Q9) Comment: An annual review of the ALARA program seems too infrequent considering the decommissioning will only last about 3 years (Section 11.1.3).

Basis: Appendix D of NUREG-1757 provides guidance on the information that the licensee should provide regarding the Environmental ALARA Evaluation Program. This includes a description of the ALARA reviews and reports to management. Having an annual review for a program which is anticipated to be three years in duration appears to be insufficient for ensuring that programmatic changes may be made in a timely fashion.

Path Forward: Provide an explanation as to why an annual assessment of the ALARA program is sufficient in timeliness and why an assessment should not be more frequent than annually.

Westinghouse Response:

HDP agrees that the wording of Section 11.1.3 did not reflect HDPs position on conducting continual reviews of environmental ALARA, with multiple documented assessments in the course of a year. The first two sentence of DP Chapter 11, Section 11.1.3 have been revised to state, Environmental ALARA is continually reviewed as analytical data for air and liquid effluent is received and evaluated. In addition, the effectiveness of this continual review is evaluated through the use of periodic reviews, surveillances and/or audits. As listed in Table 10-14, an ALARA report is submitted semi-annually by the Radiation Safety Officer (RSO) to the Project Director, the Project Oversight Committee performs an annual ALARA review, and Quality Assurance performs an annual audit of the ALARA program.

In addition to the ALARA goal, HDP commits in Section 11.1.1.2 to taking investigatory and corrective actions when an individual air or water sample exceeds 50 percent of the effluent limits in 10 CFR 20, Appendix B, Table 2, Column 1 or Column 2, respectively.

to HEM-10-84 August 10, 2010 Page 13 of 19 This Investigation Level in response to a single sample results prompts near real-time action to identify potential trends that may jeopardize the ALARA goal if not corrected in a timely manner. HDP believes this is more responsive approach than increasing the frequency of assessment.

10.

(HDP-C11-Q10) Comment: The Hematite DP contains no information on the location of the airborne and liquid effluent sampling points. Also, there are no specified locations for soil, sediment, and vegetation samples, nor are there particular on-site wells specified which will be part of the monitoring program.

Basis: Appendix D of NUREG-1757 provides guidance on the information that the licensee should provide regarding the Effluent Monitoring Program. One of the items is a summary or a diagram of all effluent discharge points.

Path Forward: WEC should provide a map showing the airborne and liquid effluent monitoring locations as well as the environmental monitoring program sampling locations. Also provide a description of on-site wells that will be used with the monitoring program.

Westinghouse Response:

Figure 11-1 has been added showing the fixed effluent and environmental monitoring locations. (Figure 11-1 is enclosed.) The mobile air monitoring locations are dependent on wind direction and the perimeter of the work area, so they cannot be shown on a figure. The basis for their positioning is described in Section 11.2.1.

11.

(HDP-C11-Q11) Comment: Table 11-5 of the Hematite DP contains no ALARA goals, Investigative Level or Regulatory Level for groundwater, soil, sediment, or vegetation.

Also the precise basis for these levels for air and surface water should be provided.

Basis: Appendix D of NUREG-1757 indicates that a decommissioning plan should contain a summary of action levels and a description of the actions to be taken if a limit is exceeded.

Path Forward: Provide the ALARA goals, Investigative Level or Regulatory Level values for groundwater, soil, sediment, or vegetation in Table 11-5. Clarify from where in Part 20, Appendix B, Table 2, the regulatory level in Table 11-5 is taken. If uranium and thorium are used as surrogates for gross alpha and beta, this should be explained, possibly as a footnote to the tables.

to HEM-10-84 August 10, 2010 Page 14 of 19 Westinghouse Response:

NUREG-1757 does not provide action levels or regulatory limits that apply specifically to samples of environmental media. Rather, that guidance is related to limitations and considerations prior to creating effluent releases.

Environmental monitoring does not ensure that a specific effluent release is acceptable.

Environmental monitoring consists of an assessment of environmental conditions over time to identify changes, including the potential buildup radioactivity in the environment by permitted releases.

To identify changes in the environmental conditions, the data are trended and significant changes are investigated. The text in Section 11.3 about trending environmental data is revised to read: The quarterly environmental monitoring results shall be reviewed for trends using the non-parametric Mann-Kendall test, or equivalent. If an adverse trend is identified in the sampling data, the EH&S Manager and RSO will be notified and a review of the associated decommissioning activity(s) will be conducted identify changes to work methods and/or engineering controls should be implemented, as appropriate, to reduce effluent concentrations to ALARA levels.

A footnote has been added to table 11-5 stating: aAnalytical procedures that provide equivalent data quality (e.g., gamma spectroscopy, liquid scintillation, kinetic phosphorescence analysis, or alpha spectroscopy) also may be selected based upon the sample medium. For gross alpha radioactivity, uranium (Class Y) may be used as a comparator and for gross beta radioactivity; Thorium-234 may be used.

12.

(HDP-C11-Q12) Comment: The discussion in Section 11.2.3.4 of the Hematite DP indicates that there will be a weekly grab sample from the Sanitary Wastewater Treatment Plant Outfall. It would appear that a weekly composite would be appropriate.

Basis: Guidance in NUREG-1757 Appendix D indicates that licensees are to submit a decommissioning plan which includes an environmental monitoring program which demonstrates that samples will be representative of actual radiological conditions at the time samples are collected. It is unclear that a weekly grab sample would be representative of the actual radiological conditions.

Path Forward: Modify the sampling program for the Sanitary Wastewater Treatment Plant Outfall to be a continuous composite sample or else provide a justification as to why the weekly grab sample is representative of the actual radiological conditions.

to HEM-10-84 August 10, 2010 Page 15 of 19 Westinghouse Response:

HDP will establish composite sampling using an auto-sampler prior to commencement of work activities under the approved DP and the EEMP will be updated to reflect continuous sample collection. Composite sampling will better satisfy the objective of the sample being representative of the effluent.

13.

(HDP-C11-Q13) Comment: The discussion in Section 11.2.3.5 indicates that the quality assurance requirements for the effluent monitoring program are contained in the EEMP.

The EEMP has not been provided for review and no details were provided in the Hematite DP about the requirements. While an "example" list of typical procedures was provided in Table 11-4, such a listing provides no commitment nor does it establish what the actual requirements will be.

Basis: Guidance in NUREG-1757 Appendix D indicates that licensees are to provide a description of the quality assurance program to be established and implemented for the effluent monitoring program.

Path Forward: Provide the EEMP or a description of the quality assurance program to be established and implemented for the effluent monitoring program.

Westinghouse Response:

A copy of HDP-PO-EM-001, Effluent and Environmental Monitoring Plan, Revision 0, will be provided under separate correspondence.

The description of the Quality Assurance program in Section 11.2.3.5 of DP Chapter 11 has been revised to state:

Chapter 13 of the DP addresses general quality assurance requirements for activities conducted at the Hematite site. Surveillances and audits of effluent and environmental monitoring programs are conducted to verify compliance with 10 CFR 20 requirements as they relate to effluent monitoring and control. As a minimum, an annual audit of the EEMP is conducted at the Hematite site.

Effluent and environmental samples will be collected and analyzed in accordance with site procedures and the requirements of quality assurance sample collection, chain of custody, handling, storage, instrument maintenance and control, including sample analysis requirements, and vendor laboratory analysis requirements. These procedures contain the appropriate level of detail to ensure that handling, storage, and analysis requirements are conducted in accordance with the HDP Project Quality Plan (PQP) (Reference 11-7). A list of site procedures implementing the requirements of the EEMP is provided in Table 11-4.

to HEM-10-84 August 10, 2010 Page 16 of 19 Environmental samples that are shipped to vendor laboratories for analysis are handled in accordance with the quality assurance and quality control (QA/QC) programs for the individual laboratory. QA/QC programs for vendor laboratories are reviewed and validated by the HDP quality assurance organization.

Table 11-4 has been expanded to describe the effluent and environmental monitoring procedures. (Table 11-4 is enclosed.)

14.

(HDP-C11-Q14) Comment: It is stated that contaminated water will be collected and treated in accordance with the Water Management Plan. The Water Management Plan was not provided nor was the collection and treatment plans described in Section 11.2.4.1 of the Hematite DP.

Basis: Guidance in NUREG-1757 Appendix D indicates that licensees are to provide a description of the controls that will be utilized to minimize the releases of radioactive material to the environment.

Path Forward: Provide the Water Management Plan or a description of the methods which will be incorporated to collect and treat contaminated water.

Westinghouse Response:

The reference to the Water Management Plan has been replaced with a description of the water collection and treatment system, and is included within Section 11.2.4.1as follows:

Potentially contaminated water could result from decommissioning operations, from precipitation that enters work areas, or from excavations that encounter ground water. HDP will use Best Management Practices to divert surface water away from work areas, collect water from work areas (such as open excavations),

and to prevent sedimentation run-off. Examples include:

Earthen berms to keep surface water from entering impacted areas.

Coverings/tarps to keep precipitation from soil stockpiles.

Sumps within excavation areas during remediation.

A French drain from the railroad loading area to a collection pond.4 Temporary Storage Tanks (Baker Tanks) within/near excavation areas.

Collected water will be directed to the WTS for analysis, and treatment as required. The treatment will reduce contaminates in the water through the following mechanisms:

Settling of solids entrained in the liquid. This mechanism is enhanced by the addition of polymer flocculent via a mixer as water enters a series of quiescent settling tanks.

to HEM-10-84 August 10, 2010 Page 17 of 19 10-25 micron bag filters to remove remaining entrained material.

Granulated activated carbon filters (virgin anthracite media) to remove volatile organics and Technetium 99.

5-10 micron bag filters to remove remaining entrained material.

Ion exchange units (zeolite media) to remove metals, including uranium and the Technetium-99 that may be in solution as uranyl or technetium carbonate complexes and are not removed by the granulated activated carbon filters.

The Temporary Storage Tanks within/near excavation areas will be within a secondary containment and located within/near the excavation(s). The secondary containment will be installed and operated to prevent the migration of wastes or accumulated liquid outside the secondary containment area. The WTS is located inside Building 230 within a lined secondary containment designed to hold the contents of the two largest tanks in the WTS. The Temporary Storage Tanks, WTS, and connecting piping are above-ground systems with the exception of underground crossings at on-site travel paths. The underground crossings will be configured so the system piping passes through larger conduit that has above ground openings on both ends to allow visual inspection. Temporary Storage Tanks, WTS, and connecting piping, including underground crossings will be visually inspected on a daily basis during operation of this equipment. Controls and practices such as spill prevention and overfill controls will be employed.

Components will be removed from service, repaired or replaced following equipment failure or malfunction resulting in a leak.

15.

(HDP-C11-Q15) Comment: Section 11.2.4.1 of the Hematite DP discusses that holding tanks not requiring secondary containment will have their above ground components, piping, and ancillary components inspected for system integrity and potential leakage.

Leak detection and integrity assessments will be performed on tanks, piping, and components which are located below ground is not discussed.

Basis: Guidance in NUREG-1757 Appendix D indicates that licensees are to provide a description of the leak detection systems for tanks.

Path Forward: Provide a description of the leak detection systems that will be implemented for those liquid systems that have components which are located below ground and the basis for determining whether a system or component requires secondary containment.

Westinghouse Response:

Section 11.2.4.1 has been revised to address leak detection and integrity assessments for the Water Treatment System. See the response to Comment HDP-C11-Q14 for text on to HEM-10-84 August 10, 2010 Page 18 of 19 the leak detection and integrity assessments. The Sanitary Wastewater Treatment Plant was installed in 1977-78. Consistent with systems of that era, it does not have a leak detection system. No leaks have been identified during operation, however the components and surrounding soil will be thoroughly evaluated as a part of the Final Status Survey.

16.

(HDP-C11-Q16) Comment: It is indicated in Section 11.2.4.2 of the Hematite DP that the comparison of effluent concentration values with the applicable regulatory limits in Appendix B, 10 CFR Part 20 will be performed semi-annually and reported to the Hematite Project Director. This information also needs to be reported to the U. S. Nuclear Regulatory Commission in accordance with 10 CFR 70.59.

Basis: 10 CFR 70.59 requires semi-annual reporting of the quantity of each of the principle radionuclides released to unrestricted areas in liquid and gaseous effluents during the previous 6 months and such information as the Commission my require to estimate the maximum potential annual radiation doses to the public resulting from effluent releases.

Path Forward: Modify Section 11.2.4.2 to include a commitment to provide the effluent release data required by 10 CFR 70.59.

Westinghouse Response:

HDP is aware of this regulatory requirement and has been compliant by submitting the report as directed by the current HDP effluent program. Section 11.2.3.4 has been revised to include As required by 10 CFR 70.59, HDP will submit to NRC, on a semi-annual basis, the results of effluent sample analyses.

17.

(HDP-C11-Q17) Comment: It is stated in Section 11.3 of the Hematite DP that the environmental monitoring locations and sampling parameters are presented in Table 11-

5. In most cases, the specific monitoring locations are not specified in the table. In addition, for the groundwater, soil, sediment, and vegetation samples, no ALARA goal, Investigative Level or Regulatory Level values are provided.

Basis: Guidance in NUREG-1757 Appendix D indicates that licensees are to provide a summary of the action levels. Environmental monitoring locations are to be representative of actual radiological conditions. Unless the monitoring locations are known, a determination cannot be made as to whether the monitoring locations will be representative of actual radiological conditions.

Path Forward: Provide the action levels for the ground water, soil, sediment, and vegetation samples; ALARA goal; and Investigative Level or Regulatory Level; and provide all monitoring locations.

to HEM-10-84 August 10, 2010 Page 19 of 19 Westinghouse Response:

Please see the response to Comment HDP-C11-Q11 regarding the action level that will be established for use in evaluating the data associated with samples of environmental media.

Figure 11-1 has been added to illustrate the fixed air sampling locations; the liquid effluent sampling locations; the soil, sediment and water sampling locations; and the locations where thermo-luminescent devices will be placed during decommissioning operations.

18.

(HDP-C11-Q18) Comment: It is stated in Section 11.3 of the Hematite DP that the environmental samples will be collected and analyzed in accordance with the approved site procedures (see Table 11-4) and governing programs. However, Table 11-4 is only entitled "Example List of EEMP Implementing Procedures". There is no indication that WEC has or will have those procedures.

Basis: Guidance in NUREG-1757 Appendix D indicates that licensees are to provide a summary of the collection and analysis procedures.

Path Forward: Provide a summary of the collection and analysis procedures.

Westinghouse Response:

Table 11-4 has been expanded to describe the effluent and environmental monitoring procedures that are approved for implementation. (Table 11-4 is enclosed) to HEM-10-84 August 10, 2010 Page 1 of 2 ATTACHMENT 2 REPLACEMENT TABLE 11-1 Effluent Monitoring Program Sampling (Referred to in response to RAI HDP-C11-Q3) to HEM-10-84 August 10, 2010 Page 2 of 2 Table 11-1 Effluent Monitoring Program Sampling a Analytical procedures that provide equivalent data quality (e.g., liquid scintillation, kinetic phosphorescence analysis or alpha spectroscopy) may be selected based upon the sample medium. Per Section 11.2.3.4, isotopic analysis shall be considered based on gross alpha and gross beta radioactivity results.

b Values reflect the annual average concentration.

c Values reflect the results obtained from individual samples.

d Quarterly averages of effluents (weighted by the amount of air/liquid each sample represents) are compared against the ALARA goal. For liquid effluents, these values are applied at the site boundary.

e The sampling location is within Building 230, even though the discharge is at Outfall #003.

f These fixed location samplers are also a part of the Environmental Monitoring Program.

Sample Medium Sampling Points Collection Mode /

Analytical Frequency Type Of Analysis a ALARA Goal d (Ci/ml)

Investigation Level c (Ci/ml)

Regulatory Limit b (Ci/ml)

Air Effluent Perimeter (Multiple - mobilized to downwind locations)

Continuous /

Daily during Work Activities Gross Alpha 1.0E-14 2.5E-14 5.0E-14 Gross Beta 4.0E-11 1.0E-10 2.0E-10 Four (4) Fixed Locations around the HDP f (AS-A, AS-B, AS-C, AS-D)

Continuous and Analyze Weekly Gross Alpha 1.0E-14 2.5E-14 5.0E-14 Gross Beta 4.0E-11 1.0E-10 2.0E-10 Liquid Effluent Sanitary Wastewater Treatment Plant (SFW-A)

Composite / Weekly*

• May use Batch Grab Prior to Each Release for the Water Treatment System Gross Alpha 6.0E-8 1.5E-7 3.0E-7 Site Dam (SFW-B)

Gross Beta 1.0E-6 2.5E-6 5.0E-6 Water Treatment System (SFW-A2e) to HEM-10-84 August 10, 2010 Page 1 of 2 ATTACHMENT 3 REPLACEMENT FIGURE 11-1 Effluent and Environmental Sampling Locations during Decommissioning Operations (Referred to in response to RAI HDP-C11-Q3) to HEM-IO-84 August 10, 2010 Page 1 of2 Figure 11-1 Effluent and Environmental Sampling Locations during Decommissioning Operations SL-B VG-B ~

TLD-K GW-Y GW-G

--(NB-33)

TLD-J Planned Laydown Area

• TLD-Q MB-F

/ B-71 )*

• TLD-R

• TLD-P SL-E

• VG-E LEGEND:

Air Sample I! Liquid Emuent Sample Water Sample

• Sediment Sample o Soil Sample TLD Location

{)-

Vegetation Sample

• Monitoring Well

[ ] Propeny Boundary o Buildings

[~J Burial Pit Area Evaporation Ponds Surface Water

)(-- Fence

c:z Gate Locations

-+- Railroad RR Spur Hematite Decommissioning Project Jefferson County Hematite. MO Westinghouse Prepared By.

JAl. Om to HEM-10-84 August 10, 2010 Page 1 of 2 ATTACHMENT 4 REPLACEMENT TABLE 11-5 Environmental Monitoring Program Sampling (Referred to in response to RAI HDP-C11-Q8) to HEM-10-84 August 10, 2010 Page 1 of 2 Table 11-5 Environmental Monitoring Program Sampling Sample Medium Sampling Points Collection Frequency Sample Type Type of Analysisa Air Four (4) Fixed Locations around the HDP (AS-A, AS-B, AS-C, AS-D)

Continuous and Analyze Weekly Particulate Gross Alpha Gross Beta Surface Water Joachim Creek Upstream of Site Creek Outfall (SFW-J)

Monthly Grab Joachim Creek Downstream of Site Creek Outfall (SFW-M)

Monthly Grab Joachim Creek and Site Creek Confluence (SFW-H)

Quarterly Grab Outfall #003 (SFW-C)

Quarterly Grab Outfall #004 (SFW-D)

Quarterly Grab Outfall #005 (SFW-E)

Quarterly Grab Outfall #006 (SFW-F)

Quarterly Grab Planned Ditch North of Burial Pits (SFW-K)

Quarterly Grab Planned Ditch from Laydown Area (SFW-L)

Quarterly Grab Ground Water On-Site Well (GW-A)

Monthly Grab Off-Site Well (GW-R)

Quarterly Grab Three (3) Evaporation Pond Downgradient Monitoring Wells (GW-U, GW-G, GW-Y)

Quarterly Grab Three (3) Process Buildings Downgradient Monitoring Wells (GW-T, GW-Z, GW-S)

Quarterly Grab Three (3) Burial Pits Downgradient Monitoring Wells (HB-F, GW-BB, GW-W)

Quarterly Grab Soil Six (6) Site Area Locations (SL-B, SL-E, SL-F, SL-G, SL-H, SL-J)

Quarterly Grab Gross Alpha Gross Beta Alpha Spect.

Liq. Scint.

Vegetation Six (6) Site Area Locations (VG-B, VG-E, VG-F, VG-G, VG-H, VGJ)

Quarterly Grab Gross Alpha Gross Beta Alpha Spect.

Liq. Scint.

Gamma Spect.

Sediment Joachim Creek and Site Creek Confluence Below Site Dam (SD-H)

Annually Grab TLD Perimeter of Central Tract (TLD-A to TLD-F, TLD-H, TLD-J to TLD-N, TLD-P to TLD-T)

Quarterly Read N/A N/A aAnalytical procedures that provide equivalent data quality (e.g., gamma spectroscopy, liquid scintillation, kinetic phosphorescence analysis, or alpha spectroscopy) also may be selected based upon the sample medium. For gross alpha radioactivity, uranium (Class Y) may be used as a comparator and for gross beta radioactivity, Thorium-234 may be used.

to HEM-10-84 August 10, 2010 Page 1 of 2 ATTACHMENT 5 REPLACEMENT TABLE 11-4 Effluent and Environmental Monitoring Procedures (Referred to in response to RAI HDP-C11-Q13) to HEM-10-84 August 10, 2010 Page 2 of 2 Table 11-4 Effluent and Environmental Monitoring Procedures Following the prescribed requirements and steps in procedures for the following topics is a key element of obtaining consistent and accurate analysis results.

Subject*

Description Groundwater Sampling HDP-PR-EM-0 11 HDP-PR-EM-010 Requirements for the proper collection, handling, and documentation of surface water samples and evaluation of sample results. Samples shipped off-site for analysis.

Surface Water Sampling HDP-PR-EM-003 Requirements for the proper collection, handling, and documentation of surface water samples and evaluation of sample results. Samples analyzed on-site for gross alpha and gross beta radioactivity and shipped off-site for analysis.

Soil Sampling HDP-PR-EM-004 Requirements for the proper collection, handling, and documentation of soil samples and evaluation of sample results. Samples shipped off-site for analysis.

Sediment Sampling HDP-PR-EM-005 Requirements for the proper collection, handling, and documentation of sediment samples and evaluation of sample results. Samples shipped off-site for analysis.

Vegetation Sampling HDP-PR-EM-007 Requirements for the proper collection, handling, and documentation of vegetation samples and evaluation of sample results. Samples shipped off-site for analysis.

Airborne Sampling HDP-PR-HP-033 This procedure ensures the proper collection, handling, analysis, documentation, and evaluation of airborne particulate samples of air effluent and of the ambient environmental air. Samples analyzed on-site for gross alpha and gross beta radioactivity and shipped off-site for analysis.

Environmental Exposure Monitoring PR-EM-006 Requirements for the proper handling, documentation, and evaluation of environmental TLDs, which are placed around the Westinghouse Hematite site boundary to verify external dose to public is below Federal Regulations.

Chain Of Custody HDP-PR-QA-006 Requirements for documenting a continuous chain of custody of samples sent for off-site analysis. This procedure is invoked by sampling procedures.

Tennelec Operation HDP-PR-HP-414 Required steps for measuring the amount of gross alpha and gross beta radioactivity in a sample using the Tennelec LB-5100 proportional counting instrument.

Liquid Sample Analysis HDP-PR-HP-313 Required steps for preparing liquid samples for analysis using the Tennelec LB-5100 instrument.

QA/QC Supplier Evaluation HDP-PR-QA-010 Requirements for Quality Assurance to evaluate a vendors quality program -

applies to off-site laboratories.

• The procedure numbers may change in the course of an update