Corrective Action Decision Document/Corrective Action Plan for Corrective Action Unit 98: Frenchman Flat, Nevada National Security Site, Nevada, Revision 1

Abstract

This CADD/CAP follows the Corrective Action Investigation (CAI) stage, which results in development of a set of contaminant boundary forecasts produced from groundwater flow and contaminant transport modeling of the Frenchman Flat CAU. The Frenchman Flat CAU is located in the southeastern portion of the NNSS and comprises 10 underground nuclear tests. The tests were conducted between 1965 and 1971 and resulted in the release of radionuclides in the subsurface in the vicinity of the test cavities. Two important aspects of the corrective action process are presented within this CADD/CAP. The CADD portion describes the results of the Frenchman Flat CAU data-collection and modeling activities completed during the CAI stage. The corrective action objectives and the actions recommended to meet the objectives are also described. The CAP portion describes the corrective action implementation plan. The CAP begins with the presentation of CAU regulatory boundary objectives and initial use restriction boundaries that are identified and negotiated by NNSA/NSO and the Nevada Division of Environmental Protection (NDEP). The CAP also presents the model evaluation process designed to build confidence that the flow and contaminant transport modeling results can be used for the regulatory decisions required for CAU closure. The first two stages of the strategy have been completed for the Frenchman Flat CAU. A value of information analysis and a CAIP were developed during the CAIP stage. During the CAI stage, a CAIP addendum was developed, and the activities proposed in the CAIP and addendum were completed. These activities included hydrogeologic investigation of the underground testing areas, aquifer testing, isotopic and geochemistry-based investigations, and integrated geophysical investigations. After these investigations, a groundwater flow and contaminant transport model was developed to forecast contaminant boundaries that enclose areas potentially exceeding the Safe Drinking Water Act radiological standards at any time within 1,000 years. An external peer review of the groundwater flow and contaminant transport model was completed, and the model was accepted by NDEP to allow advancement to the CADD/CAP stage. The CADD/CAP stage focuses on model evaluation to ensure that existing models provide adequate guidance for the regulatory decisions regarding monitoring and institutional controls. Data-collection activities are identified and implemented to address key uncertainties in the flow and contaminant transport models. During the CR stage, final use restriction boundaries and CAU regulatory boundaries are negotiated and established; a long-term closure monitoring program is developed and implemented; and the approaches and policies for institutional controls are initiated. The model evaluation process described in this plan consists of an iterative series of five steps designed to build confidence in the site conceptual model and model forecasts. These steps are designed to identify data-collection activities (Step 1), document the data-collection activities in the 0CADD/CAP (Step 2), and perform the activities (Step 3). The new data are then assessed; the model is refined, if necessary; the modeling results are evaluated; and a model evaluation report is prepared (Step 4). The assessments are made by the modeling team and presented to the pre-emptive review committee. The decision is made by the modeling team with the assistance of the pre-emptive review committee and concurrence of NNSA/NSO to continue data and model assessment/refinement, recommend additional data collection, or recommend advancing to the CR stage. A recommendation to advance to the CR stage is based on whether the model is considered to be sufficiently reliable for designing a monitoring system and developing effective institutional controls. The decision to advance to the CR stage or to return to step 1 of the process is then made by NDEP (Step 5).