E910-05-066, Experimental Corporation Response to Comments on Snec Final Status Survey Reports

Experimental Corporation Response to Comments on Snec Final Status Survey Reports

ML052590310
Person / Time
Site:	Saxton File:GPU Nuclear icon.png
Issue date:	09/08/2005
From:	Byrne J GPU Nuclear Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
E910-05-066
Download: ML052590310 (66)

Text

GPU Nuclear, Inc.

v -U G NUCLEAR Three Mile Island Nuclear Station Post Office Box 480 Middletown, PA 17057-0480 September 8, 2005 Tel717-948-8461 E910-05-066 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Gentlemen:

Subject:

Saxton Nuclear Experimental Corporation Operating License No. DPR-4 Docket 50-146 Response to Comments on SNEC Final Status Survey Reports Enclosed are the responses to the comments provided on the SNEC Final Status Survey Reports with changes to the reports provided in detail where required. These changes are administrative and for clarification purposes and do not change the final conclusions of the reports. The responses are provided in the order that the comments were issued. Each set of responses is provided with the original GPU Nuclear transmittal letter number and the date of the ORISE comment letter for cross-reference.

If there are any questions regarding this letter, please contact Mr. Art Paynter of my staff at (717) 948-8425.

Si cere~l L~

ame . Byrne Program Director, SNEC cc:

NRC Project Manager NRC Project Scientist, Region I T. Vitkus, ORISE Project Leader DO(

Survey Report MA2 Discharge Outfall (GPU Nuclear Letter E910-05-016 comments from ORISE Letter dated June 22, 2005)

1) Attachment 2-3 of appendix A is provided

2) Attachment 6-2 of appendix A is provided

3) Change Table 1 "75% Action Level" to "75% Administrative Limit"

4) Change the first paragraph of section 6.1.1 starting at the second sentence to:

"The 75% Administrative Limit was 4.89 pCi/gm and the adjusted surrogate Csl37 DCGLw for this survey unit was 6.52 pCi/gm (table 1 on page 2 of appendix A).

Although this is a Class 3 survey unit and the elevated measurement process does not specifically apply, the area factor can be used to compare the MDCscan to the 75% Administrative Limit. In this case, the MDCscan was below the 75%

Administrative Limit times the limiting area factor so no sample number adjustment was needed."

5) Change the first sentence of the third paragraph of section 6.1.2 to read:

"None of the ten fixed point soil samples collected in MA2 had results in excess of the 75% Administrative Limit."

6) Change the second sentence of section 7.2 to read:

"Ten soil samples were all less than the 75% Administrative Limit".

7) Change the second sentence in section 7.4.2 to read:

"The duplicate had good agreement as shown in the table below (Table 3) because they both support the same conclusion, that the survey unit passes."

8) Section 8 should be modified to read:

"1) The average residual radioactivity in the soils is less than the 75%

Administrative Limit in the survey unit" "2) All measurements were less than the 75% Administrative Limit in the survey unit."

Note: Some of the above changes are not based on specific comments but are consistent with comments made on other reports

TABLE 1 - Data Listina IpCI/a) ca, e 21~d T12 T12 1 T TT12 12 1 12 T12 JanFa- t20Q4 4406 27 144A ,5 1 osl 3260i 6097 0138741 5 5259 6 l925 2327611019 681592518677 61 261 '967 4 36202 __2____

Pu-23e Pu-23f Pu-241 C.14 Ih-09 Eut562 Anaiyshi Date Location Desciption 8-I 5r-.9 Coh0 Ca.131 Am-24t SIIECSampleNo 6 29 1999 2.3

t. 02 0 04 60_- 0 _i_

1 S;1tSMI"l 3 C  %-eA a S a3v-:

2a6 Juy2

%aa-ei E Ca'-eI"ac~ 100 8 30 4 16 26 60 6 2 Ec,'wS4i! _ Ilo~embef 22 199M ISIf.

s________ S c~ae c eo te FF,^re 'e ' c ____-__ 02 _ _

3 1i1 0.3 . .' llovembe 22 1999 4 S D99ieS5CS__C o e':W - It 22 1999 l1!1

" nFl'M :s:t .- -,Zs'c: -i~C 016 2 _____ __ _ilcembef 6

0732 08259 003 00181 0026 00159~ 25 0.141 0564 01 ctebei 16 2003 Si a '-~ C sc~ e.'-,,e SP-!, ce'~ sn iSz' 0207 0 0 0138 0.0 0;0876i 0 14 0 119 3 98 89 2 43 7 c- S  ; :VCi a C.0e-s ;

c-:~-e - 2,01 9 16 03 1 03 2 13 4,98 01N6 06 a,6 2001 5 a - o;II -;i~ 1-e 0047 0044 6057 396 76.0 March 2001 tO4 103 003 0.0 0044 9 775 ESCSS 1- *5- F c-¢DD 10 S e ;"GI S-SC2S 7eI 369 .o0 001 F 0 006 0003 003 549 a 22 2001 r-t70 TABLE 2 - Decayed Listina (oCMa H-3 Sr-90 Pu-238 Pu.2-9 I PU.241 C-i4 1 1-63 Eu-12 Analysis Date SEC SampleIto LoCationescription 3 86E-02 4004-02 JOl.29 1999 S ItCSZiiCCi 2sca?Se re ia: ^ ___

Sv nrl;9 7 76E-0 71 I9E*00 16460 W 14

'I4-01i600E-00 43 41 159j101 Jui, 22 199T 2 tccCcg: scrofpe r--e6 I I, --UV SSGS1:s:harge :F£ Sn 0:t e'C I - V --- 4Z ITIXemlri 3 S :5529244 Iioember 22 1999 SSGenasengeI'e 'cc 1esei -l1 __ _

_ sS5s255 Iic.ember 22 1999 i r: 5 t* _ _ l 6 SX!S_;i927 5SC-S:sc~a ge 722E-01 267E02 181E-02 2I59-02 1 59E-02 249E+00 141E-01 53 1286-01 October 16 2003 6 SI:!25 SSG C wCa ge 1e S5-3:e rc se- I S ce I 9340 13 cI- 875_-0 1.47E-01 1 19E42 386+Q00 1896-01 426402 2 OE0-01 Mav6 2003 35?t 5se sDascr ge 2 C cc .' t'e .- IcR-c C -

0_26 1.30-01 4 826+0 1 1 2 E+00 2 01 Mav 6 2001 8-ii 6 S-C 33 ZIC-SC -ce2 ? C a Coe 5-- 1 ', 191E+00 165E42 1316E01 a766+0 2,.02_ 4 38E-0 4 996-02 440E42 6 72+00 396E+00 7 73E+00 2 86E-01 Mafich 6 2001

_ Ii 35S55ne!  !,o - - 52 F CK8 3I18+00 4696E02_ 5fl7E43 2946-03 3606-2 00 437E-02 lMav 22 2001 1t 5:622 SS55 '-C 0 amte -SR-OCc

_ 35E-01 2 95E-01 392E-01 10E+01 175E+. 0 1 23Et01 2 80E+00 J99 84 157E8.1 30 081 1 t97 0 Si8 0930 18 t14 2 580 20 308 -023 017% I 0 06% 0-03 T -go, 2%19F 246%-lo ° 56%' 100 00%

14% ° KEY ergo S-a-no Back Pcorno . Pcs5t:e ;es'j:

I C-fa\ Shaned Bac.c'n = - C 0

m z

C 19f 3

Soil Sample Survey Points for Miscellaneous Survey Area MA2 l/Sf a (XT/4' GGMPAGG6provides survey points using a scale relative to the southwestern comer of the survey unit. This is cumbersome as field personnel must measure over large distances (sometimes hundreds of meters) from the single reference point To remedy this situation, this spreadsheet provides the GGMPASe survey points based on the actual location within each grid.

VXPo ;,M,. (efr/6j To use this spreadsheet, start at the grid marker. Go east the number of meters under the "E" column and then move north the number of meters in the "N" column. For simplicity, all measurements have been rounded to the nearest meter.

Location Grid E (meters) N (meters) X coordinate Y coordinate 1 BP136 6.7 0.4 6.6635 0.3754 2 BP135 5.1 0.4 15.1282 0.3754 3 BP136 2.4 7.7 2.4312 7.7061 4 BP135 0.9 7.7 10.8959 7.7061 5 BP135 9A 7.7 19.3606 7.7061 6 BQ136 6.7 5 6.6635 15.0367 7 BQ135 5.1 5 15.1282 15.0367 8 BR136 2.4 2.4 2.4312 22.3674 9 BR135 0.9 2.4 10.8959 22.3674 10 BR135 9.4 2.4 19.3606 22.3674 11 BRi36 6.7 9.7 6.6635 29.698 12 BR135 5.1 9.7 15.1282 29.698

Survey Report OL1-7 East Yard Excavation (GPU Nuclear Letter E910-05-019 comments from ORISE Letter dated June 22, 2005)

1) The LBGR listed in Table 1 should be 3.19pCi/g as also shown on attachment 7-2 of the design calculation

2) Change Table 1 "75% Action Level" to "75% Administrative Limit"

3) Change the first paragraph of section 6.1.1 starting at the second sentence to:

"The 75% Administrative Limit was 4.3 pCi/gm and the adjusted surrogate Csl37 DCGLw for this survey unit was 5.73 pCi/gm (table I on page 2 of appendix A).

The area factor can be used to compare the MDCscan to the 75% Administrative Limit. In this case, the MDCscan was below the 75% Administrative Limit times the limiting area factor so no sample number adjustment was needed."

4) Change the first sentence of the second paragraph of section 6.1.2 to read:

"None of the design fixed point soil samples in OL1 -7 had results in excess of the 75% Administrative Limit".

5) Change section 7.2 beginning with the second sentence to read:

"Both alarm points were investigated and sampled. The south alarm point had activity in excess of the 75% Administrative Limit. However, the result was less than the DCGLw adjusted down for the 4.7% contribution from the de-listed radionuclides (SNEC LTP section 6.2.2.3). Since the 75% Administrative Limit is used for conservative screening purposes, and the results were below the DCGLw adjusted down by 3.45% to account for de-listed radionuclides (SNEC LTP section 6.2.2.3), no EMC test is required. The result from the north alarm point was less than the 75% Administrative Limit. Scan MDCs were adequate. Eleven design fixed point soil samples were all less than the 75% Administrative Limit. Scan fraction, scan MDC, and number of soil samples all meet LTP and MARSSIM requirements".

6) Change the second sentence in section 7.4.2 to read:

"The duplicates had good agreement as shown in the table below (Table 5) because they both support the same conclusion, that the survey unit passes."

7) Change section 8 items I and 2 to read:

"1) The average residual radioactivity in the soils is less than the 75%

Administrative Limit in the survey unit" "2) All measurements were less than the 75% Administrative Limit in the survey unit except the south alarm point sample, which was less than the DCGLw adjusted down by 4.7% for the de-listed radionuclides."

8) Attachment 2-2 of appendix A is provided

9) Attachment 3-1 of appendix A is provided

10) Attachment 8-1 of appendix A is provided Note: Some of the above changes are not based on specific comments but are consistent with comments made on other reports.

TABLE 1 Data Litina toCgta l TABLE 2 -Decayed Lisying lpCug) II I 1;2I i T II 1! V2 IT 2 I T VI2 IT 1124 1 Hi T D a i I 1 157861.05 iM 3205.687 529.

76813BX7.75 2MAR? I I 366.25 IRM 14967. An I -- fA.

I I

I KEY I IYellow Shaded Back round

• Positive Resuli

_ lGray Shaded Background = ADA co2

2350 INSTRUMENT AND PROBE EFFICIENCY CHART 7/01/04 (Typical 2" by 2" Nal (Cs-137 W)Conversion Factors)

Inst.- l Cal Due AP Probe Cal Due cpmlmRlh 98 625 II1s/05 R 21680 Pk 1 518 I5 2'14.8S 2 98647 1 / 18,105 G &V _ 1 1667 Pk- _ _ _ _ ___l____i Yi 4'--'3 im 8/o P &Y. ___ 2 P 16__7 5 10  :

I.8 117-573 l /8/05 ()&, j211674Pk 511105 l 212..173 117566 4/9/05 (i& R ______ 185852 1'Jh 4/13/05 209.862 12 6 18 11/19/04 l 13&R 206280 Pk 12/12/04 190,907

_ _ _ _ _ __ 1 - _ __

12-9429) j 11/3/04 NY&W j____j21)6 28S3 Pk j10/31/04 177185 I _ _ _ _ _ 1 _ 1_ , I _ ,_ I 12(I 198 I1ll)3/0 4 R&W l ______ 19602 1Pk 5/25/05 209. I94 Uj 126172 6/07/05 GI&W _ 96022 6/07/05 208.302 Cr-12944() 4/09/05 I

O(&W I

• l2 10938 Pk 4/ 4 0 i 4/14/05 C) 20l;.(0 3 I'(588 6/09/051 B& W I 8.5 44 Pl; 6/09/05 2 16(.6)54 953)6Nl JI.25 P&w 1 02-568 J/28/05 2 1.7 W-) I 2350 INSTRUMENT AND PROBE EFFICIENCY CHART 7/01/04 (Typical 43-68 Beta Efficiency Factors) g9 0 6o & Ist --

Di Icerlntl iistr tlni lMrbc C3I Duc i C U;: u11121t 111:nj"Cl't'i I 1' w)\

i, 0# - O S--o / S?

INST 43-68 PROBE 44-10 PROBE BETA ALPHA INST #CD PROBE C/D PROBE C/D l B AA 79037 04/05/05 122014 04/3/05 _ 1l; s.. N/A 126188 127/05 099186 1i27/05 l l-28.2% NIA 126218 01/08/05 095080 1 01/09/05 _1 1 27.9% N/A

East Yard Excavation Sample Results Location Cs137 Pit 1 0.8 Pit 1 0.1 Pit 1 0.38 Pit 1 0.46 Pit 1 0.8 Pit 1 0.09 Pit 1 1.4 Pit I 0.7 Gas Tanks 0.1 Gas Tanks 0.1 Gas Tanks 0.'08 Gas Tanks 0.17 Pit2 0.19.

Pit2 0.16 Deep pit pad 0.56 concrete Deep pit pad 0.09 concrete Gas tank pad 0.06 concrete Gas tank pad 0.06 concrete Average 0.35 Std Dev 0.37 Highlight= results <MDA Attachment 8-1 E900-05-01 2

Survey Report OL5 Open Land (GPU Nuclear Letter E910-05-017 comments from ORISE Letter dated June 22, 2005)

1) Change the third paragraph of the Executive Summary to read:

"One alarm point (AP) was found by Nal scanning in OL5-3. Subsequent investigation sampling showed the residual activity in the area to be less than the 75% Administrative Limit".

2) Change table 1 item as follows:

Change "75% action level" to "75% Administrative Limit"

3) Add footnote to Table 1 as follows:

"12 sample points were defined in OL5-2, OL5-3, and OL5-4 because the triangular random start grid automatically fit 12 points on the rectangular survey unit"

4) Change the first paragraph of sections 6.1.1, 6.2.1, 6.3.1, and 6.4.1 starting at the second sentence to:

"The 75% Administrative Limit was 4.7 pCi/gm and the adjusted surrogate Cs137 DCGLw for this survey unit was 6.28 pCi/gm (table I on page 2 of appendix A).

The area factor can be used to compare the MDCscan to the 75% Administrative Limit. In this case, the MDCscan was below the 75% Administrative Limit times the limiting area factor so no sample number adjustment was needed."

5) Change section 7.2 as follows:

Change "DCGLw" in five places to "75% Administrative Limit"

6) Change the second sentence in section 7.4.2 to read:

"The split samples had good agreement as shown in the table below (Table 7) because they support the same conclusion, that the survey units pass."

7) Change section 8 items I and 2 to read:

"1) The average residual radioactivity in the soils is less than the 75%

Administrative Limit in all four of the survey units" "2) All measurements were less than the 75% Administrative Limit in all four of the survey units" 8)Attachment 4-1 of appendix A is provided

9) Page 1 of Appendix B is provided Note: Some of the above changes are not based on specific comments but are consistent with comments made on other reports.

Nal Scan MDC Calculation MDCscan = 6.2 pCi / g

)ackground in counts per minute background counts in observation interval v = Nal Detector I meter calibrated response in cpm/uR/hr Index of sensitivity from MARSSIM Table 6.5 based on 95% detection, 60% false positive J = Elevated measurement spot diameter in centimeters Cscan = MinimumDetectable Concentration for scanning in pCi/g CRi = Minimum Detectable Count Rate in net counts per minute CRsurv = MDCRi adjusted for the human performance factor p - in net counts per minute

)ER = Minimum Detectable Exposure Rate in uR / hr output = MicroShield derived exposure rate for I pCi/g contaminant in mRlhr

= Observation interval in seconds human performance adjustment factor - unitless I = Scanning movement rate in centimeters per second

&GLeq= Net count rate equivalent to the Adjusted DCGL b= l 300 Jcpm p= 1 0.5 HSd= 56 cm SR= j 25 ]cm d=I 1.38 Conv = 205.6 cpm/uR/hr Msoutput = l .37E-04 mR/hr / pCi/g DCGL = 4.3 pCi/g HSd = 2.24 = Oi (sec) b*Oi = 11.2 = bi (counts)

SR 60 (secmin) d*sqrt(bi)*60 = 123.7 = MDCRi (net counts per minute)

Oi MDCRi = 174.9 = MDCRsurv (net counts per minute) sqrt(p)

MDCRsurveyor = 0.851 = MDER (uR/hr)

Conv MDER =6.21 1= MDCscan pCi/g MSoutput*1 000(uR/mR)

MDCsurv*DCGL = 121 =ALnetcpm MDCscan Attachment 4-1 E900-05-01 6

tI DQA Surface Soil Report Assessment Summary Site: North-East Dump Area Planner(s): W J Cooper Survey Unit Name: Open Land Areas of OL5 Survey unit OL5-1 Report Number. 2 Survey Unit Samples: 11 Reference Area Samples: 0 Test Performed: Sign Test Result: Not Performed Judgmental Samples: 0 EMC Result: Not Performed Assessment

Conclusion:

Reject Null Hypothesis (Survey Unit PASSES)

Retrospective Power Curve 09 i 0.8

. i

• I I I

, 0.6 t.

• - 0.5 a.ITT 1T .

. f I I I

I I_1

.I 1 7

,; 03 . I I IrF

° 0.1

! .1 I- I 1_1_

-I c- o 0 1 2 3 4 S Soil Concentrfion (pCig)g including backgruta

- - Prospective Power

• 1-beta - - - Actual Power

- LBGR - - Estimated Power D DCGL - - Retrospective Power Appendix B OL5 COMPASS v1.0.0 sr2sr=oo Page I

Surney Report OL9 Open Land (GPU Nuclear Letter E910-05-018 comments from ORISE Letter dated June 22, 2005)

1) Attachment 2-2 of appendix A is provided

2) Attachment 2-8 of appendix A is provided

3) Appendix C is provided in its entirety

4) Change table I line item "75% action level" to read: "75% Administrative Limit"

5) Change the first paragraph of section 6.1.1 beginning with the second sentence to:

"The adjusted surrogate Cs137 75% Administrative Limit for this survey unit was 2.82 pCi/gm and the DCGLw was 3.76 pCi/gm (table I on page 2 of appendix A).

Although this is a Class 2 survey unit and the EMC process does not specifically apply, the area factor can be used to compare the MDCscan to the 75%

Administrative Limit. In this case, although the MDCscan is above the DCGLw, the MDCscan was below the 75% Administrative Limit times the effective area factor.

Therefore, no sample number adjustment was needed."

5) Change the first paragraph of section 6.2.1 beginning with the second sentence to:

"The 75% Administrative Limit for this survey unit was 4.3 pCi/gm and the DCGLw was 5.73 pCi/gm (table 1, page 2 of appendix A). Although this is a Class 2 survey unit and the EMC process does not specifically apply, the area factor can be used to compare the MDCscan to the 75% Administrative Limit. In this case, the MDCscan was below the 75% Administrative Limit times the effective area factor.

Therefore, no sample number adjustment was needed."

6) Change the first sentence of the third paragraph of section 6.1.2 to read:

"None of the design fixed point samples in OL9-1 had results in excess of the 75%

Administrative Limit."

7) Change the first sentence of the fourth paragraph of section 6.2.2 to read:

"None of the design fixed point samples in OL9-2 had results in excess of the 75%

Administrative Limit."

8) Change section 7.2 as follows:

Change "DCGLw" in two places to "75% Administrative Limit"

9) Change the second sentence in section 7.4.2 to read:

"The split samples had good agreement as shown in the table below (Table 5) because they support the same conclusion, that the survey units pass."

10) Change section 8 items 1 and 2 to read:

"I) The average residual radioactivity in the soils is less than the 75%

Administrative Limit in both survey units as modified by item 3 below."

"2) All measurements were less than the 75% Administrative Limit in both of the survey units as modified by item 3 below."

Note: Some of the above changes are not based on specific comments but are consistent with comments made on other reports.

TABLE 1 - RAW DATA LISTING SIIEC Sample llo LAB llo. Location.Moesco Ition H-3 Si -9 Co-Go C*-1 37 Am-241 Pu-23t Pto-239 Pts-241 C-14 11i-63 Eu-I 52 Anlysis Date I SX1OSD99223 111076 Southwest Garage #4Floor Dran Rim - (< < 03g July 22, 1999 2 SX11SD990135 110660 SW Garage - South of Fence -12 'Lne, ____ < 006 0 2 September 2, 1999 3 SX11SL990085 Teledvne L20270-2 Sod1,Grid AP-1 44, SLRFA01, or 8 < 1.76 < 0.0493 < 02MM < 0.0797 < 0,0966 < 0.0966 < 5.84 < 0.497 <3.03 <0.082 October 6, 1999 4 SXSD3240 Teledyne; L20643-8 SSGS Drain Field. 0 tc 0.03

<_ j4 _< 0.175 October 22, 2002 5 SXSD3242 Teledwo; L 43-9 SSGS Drain FMid, (I _ 3 < 0.03 l_ < 0.218 October 22, 2002

• SXSD3243 Teledyne; 120643-10 SSGS Drain Field, 01r < 0.06 S _______ < 0.246 ____ October 22, 2002 7 SXSL5717 Teleneo,L2US70-1-2 Soil, SR-132, AL-143, OL9 < 0.772 < 0.0419 < 0,0378 < 0.094 < 0.0186 < 0.0228 < 3.27 0,28 <2.59 <0.114 June 16,2004 I SXIISL99230 111082 Subsurface Sample 54 (0-4') AI-153, St'l __ < 0.3 ___ __ November 18, 1999 9 SX11SL990128 1106S3 Spray Pond - Sampbe #S5,SP c 0.02

< _ _ October 14, 1999 10 SX11SL99233 111084 Subsurlace Sarple #2 (0-Y) AI1 56, , I <00_12 November 18,1999 11 SX9SL99208 111068 Substurlace Snple #1 (4-6)AO-156, SP I < 0.14 _ _______November 18, 1999 12 SX11SL99229 111080 Suburface Sa San

1. 1 pl ) AO-156, SP<

(0-3 0 12 C _ November 18, 1999 13 SX115L991124 110640 Spray Pond - Sample #1P1 cI0S O.Q2 0_02 _< October 28, 1999 14 SX11SL9902S 110650 Spra Pfond - Sasmple #2, ~Sp I < 5 f7 October 28, 1999 15 SX11SL990126 110651 Spray Pond-Saple #3, SP1 <0 October 28, 1999 16 SX11SL990127 110652 Spway Pond -Sample #4, SP I _ < 05 - _ _ ____ October 28, 1999 17 SX11SL990120 110645 Spray Pond- Sample#160, SP I < 00 < 0.02 October 28, 1999 Is SXI1SL990119 110844 Spa~rdSm IS8Pl __ ___ <,3 <.3___ _____ October 28, 1999 19 SX11SL990122 110647 Spray Pond - Sample #9, SP I <003 <003 ____ October 28, 1999 20 SX11SL990123 110648 SprayPond- Sample#8,S1 _PI <03 C< < 0.03 October28, 1999 21 SX1 SL990121 110646 Spray Pond - Sample 7, SP1 < 0.05 < 0.06 October 28, 1999 22 SX9SL99204 111064 Subsurface Swe s2 (4-6' A 156, SPI <017 < 006 November 18, 1999 23 SX9SL99205 111065 Subsurface Samp #3 (4-6) AJ-156, SP_ I <01 < 01 I _ November 18,1999 24 SX11SL99226 111137 Subsurface Sanpleb 3 (0-3) AJ-156, S_ _ < 0.3 < 0.2 November 18, 1999 25 SXSL25262 111151 Composte of Spray Pond Soil 125,126& 127, SP I 053 1t, I00.M03I < 0.0009 0.04 October 28, 1999 26 SX11SL9S0126 Teledfle;L21441-1 SprayPond- Sample#3, SP1 (SprayOl) <2.8 <0.0384 < 0.0111 156 < 0.0102 < 0.0402 0 < 2.38 025 < 1.19 < 0.02B October 28, 1999 27 SX11SL990127 Teledne; L2,1441-2 Spray Pond - Sarnpe t4, 5P I (SprayO1) < 2.04 < 0Q0338 < 0.019 < 0.0162 <0.0225 <0.0318 < 1.64 1.22 <0.0387 October 28, 1999 r KEY I Yellowv Shaded Background = Positive Resuli lI IGray Shaded Background = ADA ATTACHMENT_ 2 co-3

TABLE 1 Data Listingi pCiCgI 2)

I' rm l TABLE 2 - Dc yed Lsting pCltg KEY Yefioxv Shaded Background = Positive RestLI I lGray Shaded Background = fIDA

tl DQA Surface Soil Report Assessment Summary Site: 019-2 Planner(s): W J Cooper Survey Unit Name: OL9-2 Report Number 2 Survey Unit Samples: 17 Reference Area Samples: 0 Test Performed: Sign Test Result: Not Performed Judgmental Samples: 0 EMC Result: Not Performed Assessment

Conclusion:

Reject Null Hypothesis (Survey Unit PASSES)

Retrospective Power Curve V..

C 09 -I- -l - -V - - 11 - -f C- I. 1 I I Ir l 0.8 -aI-- - -

- 0.7 .

i-I

, 0.6 -. - - - =

O* 0 5 I- __I_ - _

= 0.4 - --- ___ _ _

.9 0.3 v 0.2 . -- - - - -

C-

, 0.

C- 0 0.0 0.5 1.0 15 20 2.5 3.0 3.5 4.0 4.5 Soil Concentrtion (pCi/g), bcluding 1ackgruund Prospective Power

• l-beta - - Actual Power

- LBGR - Estimrted Power

- DCGL --- Retrospective Power Appendix C - OL9 8/9/2005 Page 1 vl.0.0 COMPASS v1.0.0 W11200S Page 1

DQA Surface Soil Report Survey Unit Data NOTE: Type = S" Indicates survey unit sample.

Type = R' Indicates reference area sample.

Sample Number Type Cs-137 (pCUg) 1 S 0.2 2 S 0.2 3 S 0.17 4 S 0.17 5 S 0.15 6 S 0.17 7 S 0.12 9 S 0.2 10 S 0.16 11 S 0.51 12 S 0.09 13 S 0.2 14 S 0.09 15 S 0.21 16 S 0.11 19 S 0.15 21 S 0.14 Basic Statistical Quantities Summary Statistic Survey Unit . .

Background DQO Results -

Sample Number 17 N/A N=18 Mean (pCUg) 0.18 N/A 0.56 Median (pC/g) 0.17 N/A N/A Std Dev (pCi/g) 0.09 NIA 0.29 High Value (pCig) 0.51 N/A N/A Low Value (pCVg) 0.09 N/A NiA Appendix C - OL9 61912005 Paoe COMPASS vl.0.0 COMPASS v1.0.0 51912005 Paae

Survey Report SPI Spray Pond Area (GPU Nuclear Letter E910-05-020 comments from ORISE Letter dated June 22, 2005)

1) Section 7.3.1 - Add the following as a last paragraph after table 5:

"Repeat scan measurements and samples were performed and met the applicable acceptance criteria established in Section 4.6 of SNEC Procedure E900-IMP-4520.04. All QC samples/measurements are taken in accordance with the requirements of Reference 9.1 (the SNEC LTP), which requires that at least 5% of all samples and scans be re-done. No discrepancies are reported for this area, and at least 5% or more of all samples and scan measurements were repeated with acceptable results."

2) Change "DCGLw" to "75% Administrative Limit" in section 7.4 item 1

3) Change "DCGLw" to "75% Administrative Limit" in section 8.0 in three places -

items 1, 2, and 3

4) Change Table 2 line item "Surface DCGLwv" entry from "3601 *" to:

"3601 * (Administrative Limit)"

Note: Some of the above changes are not based on specific comments but are consistent with comments made on other reports

Survey Report MA9 Fences (GPU Nuclear Letter E910-05-023 comments from ORISE Letter dated July 20, 2005)

1) Change table 1 line item "action level" to read: "75% Administrative Limit"

2) Change section 6.1.1 beginning with the second sentence to:

"The 75% Administrative Limit was 19834 dpm/100cm2 (table 1 on page 2 of appendix A), and the adjusted surrogate Csl 37 DCGLw for this survey unit was 26445dpm/100cm 2 (table 1 on page 2 of appendix A). Although this is a Class 2 survey unit and the EMC process does not specifically apply, the area factor can be used to compare the MDCscan to the 75% Administrative Limit. In this case the MDCscan was below the 75% Administrative Limit so no fixed point number adjustment was needed."

3) Change the first sentence of the second paragraph of section 6.1.2 to read:

"None of the design fixed point measurements in MA9-1 had results in excess of the 75% Administrative Limit."

4) Change section 6.2.1 beginning with the second sentence to:

"The 75% Administrative Limit was 19834 dpm/100cm 2 (table 1 on page 2 of appendix A), and the adjusted surrogate Cs137 DCGLw for this survey unit was 26445dpm/100cm 2 (table I on page 2 of appendix A). Although this is a Class 3 survey unit and the EMC process does not specifically apply, the area factor can be used to compare the MDCscan to the 75% Administrative Limit. In this case the MDCscan was below the 75% Administrative Limit so no fixed point number adjustment was needed."

5) Change the first sentence of the second paragraph of section 6.2.2 to read:

"None of the design fixed point measurements in MA9-2 had results in excess of the 75% Administrative Limit."

6) Change section 7.2 as follows:

Change "DCGLw" in two places to "75% Administrative Limit"

7) Change the second sentence in section 7.4.2 to read:

"These duplicates had good agreement as shown in the table below (Table 4) because they both support the conclusion that the survey units pass and the results are within 20% or less than twice background."

8) Change section 8 items 1 and 2 to read:

"I) The average residual radioactivity on the surfaces is less than the 75%

Administrative Limit in both survey units."

"2) All measurements were less than the 75% Administrative Limit in both of the survey units."

Note: Some of the above changes are not based on specific comments but are consistent with comments made on other reports.

Survey Rcport OL4 Open Land (GPU Nuclear Letter E910-05-022 comments from ORISE Letter dated July 20, 2005)

1) Change table 1 line item "75% action level" to read: "75% Administrative Limit"

2) Change the first paragraph of sections 6.1.1, 6.2.1, 6.3.1, and 6.4.1 starting at the second sentence to read:

"The 75% Administrative Limit was 4.8 pCi/gm and the adjusted surrogate Cs1 37 DCGLw for this survey unit was 6.46 pCi/gm (table 1, page 2 of appendix A). The area factor can be used to compare the MDCscan to the 75% Administrative Limit.

In this case, the MDCscan was below the 75% Administrative Limit times the limiting area factor so no sample number adjustment was needed."

3) Change the first sentence of the second paragraph of sections 6.1.2, 6.2.2, 6.3.2, and 6.4.2 to read:

"None of the design fixed point soil samples had results in excess of the 75%

Administrative Limit"

4) Change "DCGLw" to "75% Administrative Limit" in the last sentence of the last paragraph of section 6.2.3 and 6.4.3

5) Change section 7.2 as follows: Change "DCGLw" to "75% Administrative Limit" in five places: in the next to last sentence of each paragraph and in the second sentence of the last paragraph

6) Section 7.2 change the second sentence of the second paragraph to read:

"The alarm point was extensively sampled and shown to be less than the 75%

Administrative Limit, except for a surface grab sample that was above the 75%

Administrative Limit but below the DCGLw adjusted down for the 4.7%

contribution from the de-listed radionuclides (SNEC LTP section 6.2.2.3)."

7) Change the second sentence in section 7.4.1 to read:

"The QC rescans were consistent with the primary scans because they both support the conclusion that the survey area passes."

8) Change the second sentence in section 7.4.2 to read:

"These duplicates had good agreement as shown in the table below (Table 8) because they both support the conclusion that the survey area passes."

9) Change section 8 items 1, 2, and 3 to read:

" 1) The average residual radioactivity in the soils is less than the 75%

Administrative Limit in all four survey units.

2) All fixed point measurements were less than the 75% Administrative Limit in all four of the survey units."

3) Samples collected for investigation of alarm points in two of the survey units were less than then 75% Administrative Limit except for one surface grab sample that was less than the DCGLw adjusted down by 4.7% to account for de-listed radionuclides."

Note: Some of the above changes are not based on specific comments but are consistent with comments made on other reports.

Survey Report OL8 Open Land (GPU Nuclear Letter E910-05-029 comments from ORISE Letter dated July 20, 2005)

1) Change the second sentence in section 7.4.2 to read:

"These duplicates had good agreement as shown in Table 8 below, because they support the same conclusion, that the survey units pass.

2) Reference to COMPASS was changed to VSP on the original of attachment 6

3) Change line item in Table 1 "Action Level" to "75% Administrative Limit"

4) The last sentence of the first paragraph in sections 6.1.1, 6.2.1, 6.3.1, 6.4.1, and 6.5.1 should be changed to read:

"Although this is a class 3 survey unit and the EMC process does not specifically apply, the area factor can be used to compare the MDCscan to the 75%

Administrative Limit. In this case, the MDCscan was below the 75%

Administrative Limit times the limiting area factor, so no sample number adjustment was required."

5) Change the first sentence of the second paragraph of sections 6.1.2, 6.2.2, 6.3.2, 6.4.2, and 6.5.2 to read:

"None of the design fixed point soil samples had results in excess of the 75%

Administrative Limit."

6) In section 7.2, change "DCGLw" to "75% Administrative Limit" in five places, one in each of the five paragraphs.

7) Change section 8 items I and 2 to read:

"I) The average residual radioactivity in the soils is less than the 75%

Administrative Limit in all five survey units.

2) All measurements were less than the 75% Administrative Limit in all five of the survey units."

Note: Some of the above changes are not based on specific comments but are consistent with comments made on other reports.

Survey Report OLII Open Land (GPU Nuclear Letter E910-05-025 comments from ORISE Letter dated July 20, 2005)

1) Change "DCGLw" in the last sentence of section 6.1 to "75% Administrative Limit"

2) Change "DCGLw" to "75% Administrative Limit" in section 7.2.3 third sentence

3) Change "DCGLw" to "75% Administrative Limit" in the last sentence of section 7.3.1

4) Change "DCGLw" to "75% Administrative Limit" in item 1 in section 7.4

5) Change "DCGLw" to "75% Administrative Limit" in section 8.0 in three places -

items 1, 2, and 3 Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report OL13 Open Land (GPU Nuclear Letter E910-05-024 comments from ORISE Letter dated July 20, 2005)

I) Change second sentence of section 7.4.2 to read:

"These duplicates had good agreement as shown in Table 5, below because they both support the same conclusion, that the survey unit passes."

2) Table 1 change line item "action Level" to "75% Administrative Limit"

3) The last sentence of the first paragraph in sections 6.1.1, 6.2.1, and 6.3.1 should be changed to read:

"Although this is a class 3 survey unit and the EMC process does not specifically apply, the area factor can be used to compare the MDCscan to the 75%

Administrative Limit. In this case, the MDCscan was below the 75%

Administrative Limit times the limiting area factor, so no sample number adjustment was required."

4) Change the first sentence of the second paragraph of sections 6.1.2, 6.2.2, and 6.3.2 to read:

"None of the design fixed point soil samples had results in excess of the 75%

Administrative Limit."

5) In section 7.2, change "DCGLw" to "75% Administrative Limit" in three places, one in each of the three paragraphs.

6) Change section 8 items 1 and 2 to read:

"1) The average residual radioactivity in the soils is less than the 75%

Administrative Limit in all three survey units.

2) All measurements were less than the 75% Administrative Limit in all three of the survey units."

Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report Penelec Switchyard (GPU Nuclear Letter E910-05-030 comments from ORISE Letter dated July 20, 2005)

1) Add footnote to table 4 as follows:

Change seventh line item to read "Applicable Statistical Test

• Add footnote: "*** background data for all three survey units from Williamsburg station data. See Appendix B-I SNEC calculation E900-05-002."

2) The table below should replace table 8. EMC test for PS4-1 is recalculated using an area factor of 1 for the survey unit mean.

W Site Report An1 ase ,on MARSIM Eu .. on 2 I 0.621PC4/9 ,

Referenc Bkand NOTE:

Rol PCUr Remove Bkgnd ? l No mes collecte man etha c AFI ean 1b 16137 EMp1u 11.31n CsUg AFto1 28.2w s f s EM2sin a i u AF2 1 I EMI-31l *u9 AF-3 1 1-teTem loau w.nAvaluesInl RED l

3) The number of samples used to build a surrogate ratio depends on the number of samples collected from an area that contains measurable Cs-133 7 concentrations (the surrogate). Samples collected in the OU I area during characterization activities produced few substantive Cs-137 concentrations worth sending for costly off-site analysis. In addition, the added level of conservatism employed for OL12-1 by using the extremely low 75% Administrative Limit value of 2.41 pCi/g Cs-1 37 developed for this area, is considered adequate. These and similar low contamination areas typically contain so little surrogate radionuclide that useful ratios are difficult to establish. Because the OLI I survey area contains Cs-I 37 concentrations at essentially background levels, additional sampling for this purpose is considered unwarranted. No changes to the report are required.

4) Section 7.4 change "DCGLw" to "75% Administrative Limit" in two places, one each in items 2 and 3

5) Section 8.0 change "DCGLw" to "75% Administrative Limit" in two places, one each in items I and 3

6) Page 4 last paragraph. Delete the period after "(more or less)"

CO*

Survey Report Penclec Switchyard (Continued)

7) Change "...Figure 3..." to "...Figure 2..." first sentence section 2.3 Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report OL3 Open Land (GPU Nuclear Letter E910-05-056 comments from ORISE Letter dated August 10, 2005)

1) Change table I line item "Action level" to read: "75% Administrative Limit"

2) The following should be appended to the first paragraph in sections 6.1.1, 6.2.1, 6.3.1, 6.4.1, 6.5.1, and 6.6.1:

"The area factor can be used to compare the MDCscan to the 75% Administrative Limit. In this case, the MDCscan was below the 75% Administrative Limit times the limiting area factor, so no sample number adjustment was required."

2) The report should be amended so the last sentence in the first paragraph in sections 6.1.2 and 6.5.2 reads:

"No biased samples were required by the initial survey design"

3) The OL3-5 discussion in section 7.2 should be amended to read:

"A soil sample taken at the alarm point revealed activity much less than the 75%

Administrative Limit, so the EMC test was not required."

4) Change section 7.2 as follows: Change "DCGLw" to "75% Administrative Limit" in six places

5) Change the first sentence of the last paragraph of section 7.3.1 to read:

"The sample taken from the re-excavated location was 1.12 pCi/g Cs-137 which is less than the 75% Administrative Limit."

6) Section 7.4.2 should be amended to read:

"These duplicates had good agreement as shown in Table 9 below because both sets of data support the conclusion that the survey units pass"

7) Section 8 should be modified to read:

"1)The average residual radioactivity in the soils is less than the 75%

Administrative Limit in all of the survey units" "2) All measurements in the survey units were less than the 75% Administrative Limit except for a single area in OL3-1 identified by scanning.

3) OL3-1 had elevated results that pass the EMC test. Measurements of this area after sampling were all less than the 75% Administrative Limit."

8) Instruments with efficiencies less than the minimum specified in the survey design are not used. The minimum efficiency is carried fonvard into the "Survey Request" as a prerequisite and is one of the supervisory survey completion review parameters. No changes to the report are required Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report OL3 Paved Surfaces and Concrete (GPU Nuclear Letter E910-05-048 comments from ORISE Letter dated August 10, 2005)

1) The survey was designed using the sign test based on the simplifying assumption that background would be insignificant and the 75% Administrative Limit in use for the DCGL is based solely on a surrogate Cs137. MARSSIM allows use of the sign test if the licensee is willing to accept the contribution of background. The SNEC LTP section 5.6.4.2 allows the use of the sign test for gross measurements if background is considered to be insignificant. The survey design is consistent with MARSSIM and the SNEC LTP. No changes to the report are required.

2) Change line item in table I from "Action Level" to "75% Administrative Limit"

3) In section 7.2 change "DCGLw" to "75% Administrative Limit" in three places

4) Section 7.4.2 change the second sentence to read:

"These duplicates had good agreement as shown in Table 5 below, because they support the same conclusion, that the survey units pass, and they are within 20% of the initial result."

5) Change section 8.0 to read:

"1) The average residual radioactivity on the asphalt and concrete surfaces is less than the 75% Administrative Limit in the survey units

2) All measurements in the survey units were less than the 75% Administrative Limit"

6) The sheet in the design showing an efficiency of 21.7% is for a 43-37 detector SN92501. The minimum efficiency required for 43-37 detectors was 20%. No changes in the report are required.

7) Change the second sentence in the last paragraph of section 6.1.1, 6.2.1, and 6.3.1 from "The Administrative Limit was >1190 ncpm." To:

"The Administrative Limit was > 1190 ncpm (Table 2, page 3 of Appendix A)."

Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report OL7 Paved Surfaces and Concrete (GPU Nuclear Letter E910-05-042 comments from ORISE Letter dated August 10, 2005)

1) The survey was designed using the sign test based on the simplifying assumption that background would be insignificant and the 75% Administrative Limit in use for the DCGL is based solely on a surrogate Cs 137. MARSSIM allows use of the sign test if the licensee is willing to accept the contribution of background. The SNEC LTP section 5.6.4.2 allows the use of the sign test for gross measurements if background is considered to be insignificant. The survey design is consistent with MARSSIM and the SNEC LTP. No changes to the report are required.

2) Section 2.1.2 of appendix A discusses the use of the Nal for scanning. Since the surrogate is CsI37, any instrument can be used that is capable of detecting Cs137.

Appendix A demonstrates that the detection efficiency and MDCscan is adequate for FSS. Common industry practice and historical practice at SNEC is to use gamma sensitive instruments when surface conditions warrant. In this case, the macadam was old (-40 years old) porous, broken, etc. and was more appropriately scanned using gamma sensitive equipment. No changes to the report are required.

3) Change section 7.4.2 to read:

"These duplicates had good agreement, as shown in Table 5 below, because they support the same conclusion, that the survey units pass, and they are within 20% of the original results"

4) Change section 8.0 to read:

"I) The average residual radioactivity on the asphalt and concrete surfaces is less than the 75% Administrative Limit in the survey units

2) All measurements in the survey units were less than the 75% Administrative Limit"

5) Instruments with efficiencies less than the minimum specified in the survey design are not used. The minimum efficiency is carried forward into the "Survey Request" as a prerequisite and is one of the supervisory survey completion review parameters. No changes to the report are required

6) Change section 7.2 as follows: change "DCGLw" to "75% Administrative Limit" in three places Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Rcport OL7 Open Land Soils (GPU Nuclear Letter E910-05-035 comments from ORISE Letter dated August 10, 2005)

1) Section 7.4.2 can be changed to read:

"These duplicates had good agreement, as shown in Table 5 below, because they support the same conclusion that the survey units pass."

2) Section 8.0 change both line items to read:

"I) The average residual radioactivity in the soils is less than the 75%

Administrative Limit in all three of the survey units.

2) All measurements in all three of the survey units were less than the 75%

Administrative Limit"

3) Instruments with efficiencies less than the minimum specified in the survey design are not used. The minimum efficiency is carried fonvard into the "Survey Request" as a prerequisite and is one of the supervisory survey completion review parameters. No changes to the report are required.

4) Change the Table I line item "Action Level" to "75% Administrative Limit"

5) Change the last sentence of the first paragraph of sections 6.1.1, 6.2.1 and 6.3.1:

"Although this is a Class 2 survey unit and the area factor does not specifically apply, the area factor can be used to compare the MDCscan to the 75%

Administrative Limit. In this case, the MDCscan was below the 75%

Administrative Limit times the limiting area factor so no sample number adjustment was needed."

6) Change section 7.2 as follows: change "DCGLw" to "75% Administrative Limit" in three places Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report Switch Yard Control Building (GPU Nuclear Letter E910-05-032 comments from ORISE Letter dated August 10, 2005)

1) In section 8.0, change "DCGLw" to "75% Administrative Limit" in two places - one each in items I and 2

2) In section 7.4, change "DCGLw" to "75% Administrative Limit" in item 1

3) Change "DCGLw" to "75% Administrative Limit" in the next-to-last paragraph of the executive summary (page 3)

Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report Remediated Soils (GPU Nuclear Letter E910-05-031 comments from ORISE Letter dated August 10, 2005)

1) The SR sheets are signed. Copies are attached.

2) Change last sentence in section 6.1.2 under heading "Results Conclusion" to read:

".... The applicable 75% Administrative Limit and therefore..."

3) Section 8.0 change all three line items to read:

"1) The average residual radioactivity in the soils is less than the 75%

Administrative Limit.

2) Since all measurements were either less than the 75% Administrative Limit, or were discarded from the batch, no EMC test is required.

3) Remediation of soils prior to FSS reduced levels of residual radioactivity to below the concentrations necessary to meet the 75% Administrative Limit."

Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

SURVEY REQUEST CONTINUATION SHEET SR NUMBER SR-0186 AREAJLOCATION SNEC Site SPECIFIC SAMPUNG I SURVEY INSTRUCTIONS OR COMMENTS C. Soil Samples One hundred thirty-one samples were obtained covering 56 batches.

Results: The highest activity was indicated on sample SX-SL-9469 with 0.84 +/- 0.14 pCilg, Cs-137, <0.1 pCilg, Co-6O. Positive Cs-137 results ranged from 0.13 to 0.84 pCilg. No Co-6S was identified (typical achieved MDA was 0.1 pCi/g).

Two additional samples (unprocessed) were obtained of material on the conveyor belt during the alarm of batch SRA-05-044-2). These samples indicated 0.6 +/- 0.17 and 0.19 +/- 0.08 pCilg, Cs-137. No Co-60 activity was indicated (MDA was 0.09 and 0.18 pCilg).

2. Quality Control (QC) Measurements and Comparisons Repeat Scan measurements and Soil samples were performed and met the applicable acceptance criteria established in Section 4.6 of E900-IMP-4520.04. A repeat static measurement was not performed in response to the alarm in batch SRA-05-044-2. This was due to an oversight of the technician. The QAO was notified.

3. Special Notes:

R. Shepherd performed two quality checking inspections. Inspection performed on 12/04104 primarily checked SRA technician's qualifications and observed pre-op checking of detectors. One discrepancy was identified. The technician did not have a copy of the SRA-SXTN-106 Rev. 0 procedure, Operation of the SMCM /Conveyor System'. A copy was obtained. An inspection performed on 1/18105 observed a point source alarm/response by SRA technician and site Rad Con technician to ensure compliance with SR requirements. No discrepancies were identified.

4. Exceptions and Discrepancies: none t David Sarge (GRC Si &f I,- Date I. /°(

._ C. .

Page 2 of 2

SURVEY REQUEST CONTINUATION SHEET SR NUMBER I SR-0190 I AREAILOCATION I SNEC Site SPECIFIC SAMPUING I SURVEY INSTRUCTIONS OR COMMENTS C. SoIl Samples Five samples were obtained covering batch SRA.05-054.

Results: The highest activity indicated was 1.0 +/- 0.18 pCilg, Cs-137. <0.15 pCilg, Co-60. All samples indicted positive Cs-137 ranging from 0.7 to 1.0 pCi/g. No Co-60 was identified (typical achieved MDA was 0.13 pCilg).

Four additional samples (unprocessed) were obtained of material on the conveyor belt during the alarms of batch SRA-05-054). These samples indicated positive Cs-137 ranging from 0.52 to 0.62 pCilg. No Co-60 activity was indicated (typical achieved MDA was 0.12 pCi~g).

2. Quality Control (QC) Measurements and Comparisons Repeat Scan and soil samples were performed and met the applicable acceptance criteria established in Section 4.6 of E900-IMP-4520.04. A repeat static measurement was not obtained during the response of the point source alarm. This was due to an oversight of the technician. The QAO was notified.

3. Special Notes: none

4. Exceptions and Discrepancies: see section 2.

David Sarge (GRCS) d & Date CS Page 2 of 2

Survey Report OL1-6 Trench (GPU Nuclear Letter E910-05-052 comments from ORISE Letter dated August 11, 2005)

1) Section 7.2.1 mentions that the soil samples were not I meter thick samples. The samples were 6-inch thick samples. Because the trench was about 1 meter deep, shallower samples are appropriate. No change to the report is needed.

2) Change section 8.0 "DCGLw" to "75% Administrative Limit" in three places one each in items 1, 2, and 3.

3) In Appendix A-1 the Microshield model is slightly different than those of other reports. Different cases may involve calculations of gamma flux in different models.

Microshield calculations are then repeated in order to provide appropriate conversion factors. Engineering judgment is used in all of these cases to develop appropriate model conditions. In this case, the difference between 1I -inch radius and 11. 1 -inch radius produces less than a 2% difference in the surface area of the assumed source.

This difference is trivial compared to the variance associated with the judgment involved in developing the models and changes in assumptions that are case -to case and then comparing that to the actual surfaces scanned. No changes to the report are needed

4) Background values used in Appendix A-1 are different than those used in other reports. Background values are obtained during the design process, typically from the survey unit itself, where activity is not expected or known to not be present. Different instruments may vary in backgrounds to the extent noted in the comment. In addition, different surface materials will vary significantly, particularly at SNEC where fly ash and 'clinkers' as well as natural rocks and soils are present. Further, the MDCscan calculation is an a-priori estimate of the MDC. Since this is an estimate, primarily for demonstrating that the survey design meets detection capability requirements, different engineering choices may be made under different circumstances in designing different surveys. Since background directly affects the MDC, it may in one circumstance be desirable to estimate the probable MDC using the typical background, and in another to provide a conservative maximum MDC based on the highest expected background in order to demonstrate that the MDC will be adequate in any circumstance. Therefore, the observed backgrounds and choices made in evaluating the a-priori MDCscan do not materially affect the FSS results and no change to the report is required.

5) Change "DCGLW' to "75% Administrative Limit" in section 7.4 item I Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report OL2 Open Land (GPU Nuclear Letter E910-05-052 comments from ORISE Letter dated August 11, 2005)

1) The survey of the residual concrete pads in OL2 was design6d using the sign test based on the simplifying assumption that background would be insignificant and the 75%

Administrative Limit in use for the DCGL is based solely on a surrogate Cs 137.

MARSSIM allows use of the sign test if the licensee is willing to accept the contribution of background. The SNEC LTP section 5.6.4.2 allows the use of the sign test for gross measurements if background is considered to be insignificant. The survey design is consistent with MARSSIM and the SNEC LTP. No changes to the report are required.

2) Section 8.0 change the four line items to read:

"I) The average residual radioactivity in the soils is less than the 75%

Administrative Limit in both of the survey units.

2) The average residual radioactivity on the concrete is less than the 75%

Administrative Limit.

3) All measurements in all three of the survey units were less than the 75%

Administrative Limit

4) Samples collected for investigation of the alarm point in the OL2-2 survey unit were all less than the 75% Administrative Limit"

3) Instruments with efficiencies less than the minimum specified in the survey design are not used. The minimum efficiency is carried forward into the "Survey Request" as a prerequisite and is one of the supervisory survey completion review parameters. No changes to the report are required.

4) Change first sentence of second paragraph of section 6.3.2 to read:

"None of the fixed point measurements in MA8-5 had results in excess of the 75%

Administrative Limit."

5) In section 7.2, change "DCGLw" to "75% Administrative Limit" in four places.

6) Change "...discusse .. ." to "...discussed..." in first line of section 2.0 Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report Obi Macadam (GPU Nuclear Letter E910-05-051 comments from ORISE Letter dated August 11, 2005)

1) Change table 1 line about "action level" to "75% Administrative Limit"

2) Change line item I in the executive summary to read:

"...scans of 100% of the macadam surfaces in 18 grids covering about 42% of the 1800 square meters of the total area in the grids".

3) The survey was designed using the sign test based on the simplifying assumption that background would be insignificant and the 75% Administrative Limit in use for the DCGL is based solely on a surrogate Cs137. MARSSIM allows use of the sign test if the licensee is willing to accept the contribution of background. The SNEC LTP section 5.6.4.2 allows the use of the sign test for gross measurements if background is considered to be insignificant. No changes to the report are required.

4) Change the last sentence of the first paragraph of sections 6.1.1, 6.2.1, 6.3.1, 6.4.1, 6.5.1, 6.6.1, 6.7.1, 6.8.1, 6.9.1, and 6.10.1 to read:

"In this case the MDCscan was below the 75% Administrative Limit so no fixed point number adjustment was needed"

5) Change the second sentence of the first paragraph of sections 6.1.2, 6.2.2, 6.3.2, 6.4.2, 6.5.2, 6.6.2, 6.7.2, 6.8.2, 6.9.2, and 6.10.2 to read:

"None of the design fixed point measurements in [survey unit name e.g. MA8-6]

had results in excess of the 75% Administrative Limit."

6) Table 12 is incorrect due to a personnel error in transferring the data into the report.

Other FSS reports were reviewed to confirm that this was an isolated error. The table should read as follows:

Fixed Point Result QC result FePn (m (cpm)

MA8-6 3 387 428 MA8-7 1 364 383 MA8-8 2 357 394 MA8-9 1 384 401 MA8-10 6 331 322 MA8-11 7 341 343 MA8-12 5 369 376 MA8-13 2 343 349 MA8-16 1 327 381 MA8-17 1 344 428 The text of section 7.4.2 should be changed to read:

"These duplicate had good agreement as shown in the table below (Table 12) because they support the same conclusion, that the survey units pass and because the results are within 20% or are less than twice the background"

Suryc} Report OLI Macadam (continued)

7) Section 8 should be changed to read:

" 1) The average residual radioactivity on the surfaces is less than the 75%

Administrative Limit in all of the survey units.

2) All measurements were less than the 75% Administrative Limit in all of the survey units"

8) The sheet in the design showing an efficiency of 21.7% is for a 43-37 detector SN92501. The minimum efficiency required for 43-37 detectors was 20%. No changes in the report are required.

Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report GAl Small Penclec Garage (GPU Nuclear Letter E910-05-054 comments from ORISE Letter dated August 11, 2005)

1) The cumulative frequency distribution of the data collected is used to select a background from a group of backgrounds that are collected on various surfaces at the site. No changes to the report are required.

2) Change section 5.0 to read:

"The maximum MDC observed for a 100 square centimeter area in the SCM scanning was about 28% of the 75% Administrative Limit"

3) Change section 6.1 last paragraph to read:

"All SCM surveys indicated activity less than the 75% Administrative Limit. No follow-up 43-68 GFPC scans were required."

4) Change section 7.2 first sentence to read:

"GAl-I had no activity in excess of the 75% Administrative Limit during scan surveys of approximately 85% of the surface"

5) Add the following paragraph at the end of section 5.0:

"Portions of this survey were conducted with an automated positionally sensitive proportional counter Surface Contamination Monitor (SCM) system. The SCM is typically used in a scanning (rolling) mode. In rolling mode, the SCM logs information in 25 square centimeter 'bins' by logging data for each 5 cm width of the detector and for each 5 cm of travel. A precision wheel encoder measures the distance traveled. Data are recorded in 25 square centimeter pixels over the entire surface surveyed, meaning the SCM records 400 measurements for every square meter it covers. When SCM data is analyzed, the software considers each 25 square centimeter measurement as 1/4 of four separate 100 square centimeter areas. This technique ensures that the highest activity in any single 100 square centimeter area is identified. The collection of large amounts of data in discrete values allows the data to be evaluated via statistical methods that consider the distribution of activity on the surface in addition to its average concentration."

6) Section 8 should be changed to read:

"1) The average residual radioactivity on the surfaces is less than the 75%

Administrative Limit in the survey unit.

2) All measurements were less than the 75% Administrative Limit in the survey unit."

7) Since the garage pad did not contain specific contaminated systems and was of interest for residual radioactivity only because of the long-term presence of the garage at the site, the surfaces are expected to be uniformly contaminated with no locations of unusual concentrations such as would occur if systems or equipment were present.

Therefore, the surfaces surveyed with the SCM were fully representative of the possible residual radioactivity. No changes to the report are required.

8)Add the following after the last paragraph of section 6.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100cm2 Area 100 cm 2 Areas MDC 2 (dpm/1 00cm 2 ) (dpm/1 00cm2 ) (dpm/I00cm2 )

SRR7001Z 10520 431 5958

Survcy Report GAl Small Penelec Garage (continued)

9) Change section 7.4.2 to read:

"Since no fixed point measurements were required due to the unique nature of the SCM scanning, no specific fixed point QC measurements were taken. However, since the SCM collects data in a positionally sensitive pixel process similar to full coverage fixed point measurements, comparisons of the SCM data can be made.

Although exact pixel to pixel comparisons are impractical due to the limitations on the positional accuracy, the overall results agree as shown in the table below, since both sets reach the same conclusion that the survey unit passes."

Initial SCM results QC SCM results (cpm/l 00 cm 2 ) (cpm/ OOcm 2 )

628 580 Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report Weir Discharge Area (GPU Nuclear Letter E910-05-053 comments from ORISE Letter dated August 11, 2005)

Ia) Insert the following as a new paragraph in section 6.3 after the first paragraph:

"Samples were collected to a depth of about 6 inches because the sample point was in a trench already more than a meter below grade. Since the intent of I meter sampling is to represent the soil thickness used in the site dose model, 6-inch samples may be used when the sample point is more than I meter below grade. This would actually be conservative when the activity is not expected to be distributed through an additional meter of soil."

Ib) Add the following to the end of the new second paragraph (as mentioned above) of section 6.3:

"The SNEC LTP (section 5.4.3.1) allows use of alternative sampling designs - e.g. to collect 30 samples if there is no statistical design. This data set meets these requirements."

Ic) Add the following to section 2.0 after the sentence ending "... by September 2001."

" The soil under the pipe was originally unclassified, but was treated as Class 3 for the purposes of the Final Status Survey Report."

2) This result was inside the pipe and does not represent activity found in the soils. The pipe was completely removed. No changes to the report are required.

3) Appendix A-I is SR-0020 closeout results for one phase of the remediation support survey work. Since the content of the removed pipe is actually irrelevant to the Final Status Survey, delete the last sentence in section 6.3.

4) This is a reference to a conservative remediation and sampling assumption. During the remediation of the pipe, there was no evidence of leakage from the piping into the ground below, and the elevated measurements reported for inside the pipe do not correspond to any activity found outside the pipe. No changes to the report are required

5) The highest concrete sample result (in pCi/g of Cs-137) was compared to the Cs-137 volumetric DCGLw as a point of reference, and not as a measure of compliance since these were simply remediation support surveys. Note however, that if one were to treat the concrete volume as volumetric material (typical for concrete when it is broken up),

the mean concentration of the headwall would be well within the required 75%

Administrative Limit for this area. With regard to why static measurements were not performed with the GM detector used for scanning the surface, this survey work was in support of the remediation of the Weir line and was not originally planned as an FSS type survey. The actual surface area of the Weir line headwall is about 7.3 square meters with an estimated volume of about 1.2 cubic meters. It is simply a slab of concrete through which the Weir pipe was retained at the rivers edge. Most of the structure is below grade or below the river water line. Because of the small size of the monolith and the expected deterioration in the riverbank zone, a volumetric DCGL consistent with section 5.5.3.4.4 of the SNEC LTP is dosimetrically appropriate. No changes to the report are required 6a) Section 8.0 change "DCGLw" to 75% Administrative Limit" in three paces - one each in items 1, 2, and 3

Survey Report Weir Discharge Area (Continued) 6b). The Weir pipe soil bed should have the following conclusion (No. 4) added to Section 8.0:

"4. The Weir pipe soil bed did not contain concentrations of residual contamination above the site Administrative Limit for Cs-1 37 concentration, as evidenced by samples taken during remediation support survey work. Results support the conclusion that additional survey and/or sampling efforts in this area are not warranted consistent with the SNEC LTP section 5.4.3.1."

7) Portions of the pipe were scanned. However, since the pipe was removed, the extent of the survey of the pipe is not relevant to the FSS. No changes to the report are required.

8)Different cases may involve calculations of gamma flux in different models.

Microshield calculations are then repeated in order to provide appropriate conversion factors. Engineering judgment is used in all of these cases to develop appropriate model conditions. In this case, the difference between 11-inch radius and 11.1-inch radius produces less than a 2% difference in the surface area of the assumed source.

This difference is trivial compared to the variance associated with the judgment involved in developing the models and changes in assumptions that are case -to case and then comparing that to the actual surfaces scanned. No changes to the report are needed.

9) Because the total efficiency is arbitrarily set to 10% (procedure E900-OPS-4524.42 SNEC Radiological Controls Instrument Operations Manual) when using a pancake GM probe (actual efficiencies are typically higher) the 10% value is entered in the instrument efficiency directly (Ei =0.1). In this case, the Es must be set to equal 1 in order for the total efficiency to remain 10%. No changes to the report are needed.

Survcy Report CV Yard Excavation (GPU Nuclear Letter E910-05-013 comments from ORISE Letter dated August 15, 2005) la) Change Table I as follows:

Delete the "Administrative Cs-137 DCGLw" and "Scan MDC" lines Add the following lines:

75% Administrative Limit (Cs137 pCilg) 4.3 75% Administrative Limit (dpmIO00cm 2) 33325 MDCscan pCig 3.2 MDCscan dpm/1OOcm 2 4407 Ib) Change table 4 as follows:

Delete the "Administrative Cs-137 DCGLw" and "Scan MDC(dpm/100cm 2 )" lines Add the following lines:

75% Administrative Limit (Cs137 pCilg) 4.3 75% Administrative Limit (dpm/1OOcm 2) 33325 33325 33325 MDCscan pCVg 4.1 MDCscan dpm/1OOcm 2 2204 784 784 lc) Change table 7 as follows:

Delete the "Administrative Cs-137 DCGLw" and "Scan MDC" lines Add the following lines:

75% Administrative Limit (Csl 37 pCi/g) 4.3 3 75% Administrative Limit (dpm/100cm) I 1 33325 I ~ MDCscan pCi/g 13.2 MDCscan dpm/1OOcm2 929 ld) Change table 11 as follows:

Delete the "Administrative Cs-137 DCGLw" and "Scan MDC" lines Add the following lines: _

75% Administrative Limit (Cs137 pCilg) 4.3 l _l 75% Administrative Limit (dpm/1OOcm 2) 33325 MDCscan pClg 3.3 MDCscan dpm/1OOcm 2 2204

2) Section 6.2, Table 4 - A higher sample density was desired in the subsurface region of the CV yard. The WRS testing approach provided as many or more samples than the Sign Test would have for this area, and so the WRS testing approach was used to increase the sample population. Use of the WRS statistical testing approach is permitted by the SNEC LTP (as an example, see SNEC LTP Table 5-17). While this may have been inconsistent with other areas around the site where the Sign Test was applied exclusively, the area adjacent to the CV was considered a special subsurface volume with a much higher potential for contamination than at other SNEC site locations. No changes to the report are needed.

3) Table 4 Comment addressed in item lb above

Survey Report CV Yard Excavation (Continued)

4) Since the surrogate isotope is Cs137, any instrument can be used that is capable of detecting Cs137. Appendix A demonstrates that the detection efficiency and MDCscan for a Nal detector is adequate for FSS. Common industry practice and historical practice at SNEC is to use gamma sensitive instruments when surface conditions warrant. In this case, the surfaces were old (-40 years old) porous, broken, etc. and were more appropriately scanned using gamma sensitive equipment. No changes to the report are required

5) Change section 8.0 references to "DCGLw" to "75% Administrative Limit" in 3 places

- one each in each line item 1,2, and 3

6) Section 7.2 change references to "DCGLw" to 75% Administrative Limit" in 20 places

- two in each of the ten paragraphs.

7) Section 6.1.1 change "...MDCscan of 3.2 pCi/g (page 3 of Appendix A)." to:

"...MDCscan of 3.2 pCi/g (page 2 of Appendix A)."

8) Section 6.2.2 change ".... DCGLw for the concrete wall was 2519 ncpm." To:

". ..DCGLw for the concrete wall was 2519 ncpm (page 4 of Appendix B)."

Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report OLl Open Land Soil (GPU Nuclear Letter E910-05-041 comments from ORISE Letter dated August 11, 2005)

1) Change section 8.0 items 1, 2 and 3 to read:

"1) The average residual radioactivity in the soils is less than the 75%

Administrative Limit in all six survey units.

2) All measurements were less than the 75% Administrative Limit in all six of the survey units

3) Samples collected for investigation of alarm points in OLI-1 1, OLI-12, and OLI-13 survey units were all less than the 75% Administrative Limit"

2) Instruments with efficiencies less than the minimum specified in the survey design are not used. The minimum efficiency is carried forward into the "Survey Request" as a prerequisite and is one of the supervisory survey completion review parameters. No changes to the report are required.

3) In section 7.2 throughout the six paragraphs, change "DCGLw" to "75%

Administrative Limit" in nine places.

Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Surey} Report OLl Residual Concrete (GPU Nuclear Letter E910-05-050 comments from ORISE Letter dated August 11, 2005)

1) The survey was designed using the sign test based on the simplifying assumption that background would be insignificant and the 75% Administrative Limit in use for the DCGL is based solely on a surrogate Csl37. MARSSIM allows use of the sign test if the licensee is willing to accept the contribution of background. The SNEC LTP section 5.6.4.2 allows the use of the sign test for gross measurements if background is considered to be insignificant. The survey design is consistent with MARSSIM and the SNEC LTP. No changes to the report are required.

2) Change second sentence of section 7.4.2 to read:

"These duplicates had good agreement as shown in the table below (Table 12) because they support the same conclusion, that the survey units pass, and the results are within 20% or are less than twice background"

3) Change section 8 items I and 2 to read:

" I) The average residual radioactivity on the surfaces is less than the 75%

Administrative Limit in all of the survey units

2) All measurements were less than the 75% Administrative Limit in all of the survey units"

4) Change table I - in two places the text "action level" should read "75% Administrative Limit"

5) In sections 6.1.1, 6.2.1, 6.3.1, 6.4.1, 6.5.1, 6.6.1, 6.7.1, 6.8.1, and 6.9.1 change the last sentence of the first paragraph to read:

"In this case the MDCscan was below the 75% Administrative Limit so no fixed point adjustment was needed" Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report OL6 and OLIO Open Land (GPU Nuclear Letter E910-05-033 comments from ORISE Letter dated August I1, 2005)

Ia) Change "DCGLw" to "75% Administrative Limit" in section 7.4 Ib) Change "DCGLw" to "75% Administrative Limit" in three places, one in each line item, in section 8.0 Ic) Change "DCGLw" to "75% Administrative Limit" in two places in the next-to-last paragraph in the executive summary.

ld) Change "DCGLwv" to "75% Administrative Limit" in two places in the second paragraph of section 6.1 I e) Change "DCGLw" to "75% Administrative Limit" in the last sentence of section 6.3 1f) Change "DCGLwv" to "75% Administrative Limit" in the last sentence of section 6.4

2) Instruments with efficiencies less than the minimum specified in the survey design are not used. The minimum efficiency is carried forward into the "Survey Request" as a prerequisite and is one of the supervisory survey completion review parameters. No changes to the report are required

Survey Report SSGS Spray Pump Area (GPU Nuclear Letter E910-05-046 comments from ORISE Letter dated August 11, 2005)

1) Change section 1 first sentence second paragraph to read:

".... data collected in four survey units consisting..."

2) Change section 8 items 1 and 2 to read:

"1) The average residual radioactivity on the surfaces is less than the 75%

Administrative Limit in all of the survey units

2) All measurements were less than the 75% Administrative Limit in all of the survey units"

3) Instruments with efficiencies less than the minimum specified in the survey design are not used. The minimum efficiency is carried forward into the "Survey Request" as a prerequisite and is one of the supervisory survey completion review parameters. No changes to the report are required.

4) Section 7.2 change "DCGLw" to "75% Administrative Limit" in four places (one in each paragraph).

5) Page 3, second line from top, change "...lowewT..." to "...lower..."

Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report SSGS Intake Tunncl (GPU Nuclear Letter E910-05-043 comments from ORISE Letter dated August 17, 2005)

1) The cumulative frequency distribution of the data collected is used to select a background from a group of backgrounds that are collected on various surfaces at the site. No changes to the report are required.

2) Add the following paragraph at the end of section 5.0:

"Portions of this survey were conducted with an automated positionally sensitive proportional counter Surface Contamination Monitor (SCM) system. The SCM is typically used in a scanning (rolling) mode. In rolling mode, the SCM logs information in 25 square centimeter 'bins' by logging data for each 5 cm width of the detector and for each 5 cm of travel. A precision wheel encoder measures the distance traveled. Data are recorded in 25 square centimeter pixels over the entire surface surveyed, meaning the SCM records 400 measurements for every square meter it covers. When SCM data is analyzed, the software considers each 25 square centimeter measurement as 1/4 of four separate 100 square centimeter areas. This technique ensures that the highest activity 100 square centimeter area is identified.

The collection of large amounts of data in discrete values allows the data to be evaluated via statistical methods that consider the distribution of activity on the surface in addition to its average concentration."

3) SNEC agrees not to use I square meter generic default averaging therefore the third paragraph of sections 6.1.1, 6.2.1, 6.3.1, 6.4.1, 6.5.1, 6.6.1, 6.7.1, 6.8.1, and 6.9.1 should be changed to read:

"All SCM surveys indicated activity less than the 75% Administrative Limit. No follow-up 43-68B scans were required."

4) Since the intake tunnel did not contain specific contaminated systems and was of interest for residual radioactivity only because of the recirculation of SSGS discharge water, the surfaces are expected to be uniformly contaminated with no locations of unusual concentrations such as would occur if systems or equipment were present.

Therefore, the surfaces surveyed were fully representative of the possible residual radioactivity. No changes to the report are required.

Survey Report SSGS Intake Tunnel (continued)

5) Change section 7.4.2 to read:

"Since no fixed point measurements were required due to the unique nature of the SCM scanning, no specific fixed point QC measurements were taken. However, since the SCM collects data in a positionally sensitive pixel process similar to full coverage fixed point measurements, comparisons of the SCM data can be made.

Although exact pixel to pixel comparisons are impractical due to the limitations on the positional accuracy, the overall results agree as shown in the table below, since both sets reach the same conclusion that the survey unit passes."

Initial SCM results QC SCM results Survey area (cpm/I 00 cm ) (Cpm/OOcm 2 )

SS19-1 -18 -94 SS19-2 -150 -116 SS19-3 -45 31 SS20-1 154 -48 SS20-2 -91 51 SS20-3 30 -22 SS21-1 57 -248 SS21-2 19 45 SS21-3 100 137

6) Change section 8 items 1 and 2 to read:

"1) The average residual radioactivity on the surfaces is less than the 75%

Administrative Limit in all of the survey units

2) All measurements were less than the 75% Administrative Limit in all of the survey units"

7) Add the following after the last paragraph of section 6.1.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100cm2 Area 100 cm 2 Areas MDC (dpm/1OOcm ) (dpm/lOOcm ) (dpm/1OOcm 2) 2 2 SRS7032Z 4094 -50 2487 Add the following after the last paragraph of section 6.2.1:

"The following table provides the summary of the SCM data."

Maximum Mean of 2

Survey Name 100 cm Area 100 cm2 Areas MDCp 2 2 2 (dpm/lOOcm ) (dpm/1 OOcm ) (dpm/100_cm )

SRS7018Z 3223 -180 2075 SRS7021Z 3569 -20 2345 SRS7024Z 3324 5 2497

Survey Report SSGS Intake Tunnel (continued)

Add the following after the last paragraph of section 6.3.1:

"The lowing table provides the summary of the SCM data."

Maximum Mean of Survey Name 100 cm2 Area 100 cm 2 Areas MDC 2 (dpm/lOOcm 2 ) __pm/1 OOCM2) (dpm/100cm)

SRS7027S 3927 26 2581 SRS7027Z 1 3315 -75 2371 Add the following after the last paragraph of section 6.4.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100cm2 Area 100 cm 2 Areas MDC (dpm/l OOcm 2) (dpm/l 00cm 2) (dpm/l 00cm2)

SRS7030S 3508 -14 2149 SRS7030Z 4194 85 2414 SRS7033R 4296 460 3099 SRS7033S 3945 653 3445 SRS7033Z 3513 175 2748 Add the following after the last paragraph of section 6.5.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100 cm Area 100 cm 2 Areas 2 MDC (dpm/lOOcm 2 ) (dpm/l OOcm 2 ) (dpm/lOOcm 2 )

SRS7019R 2455 -193 1759 SRS7019S 2944 -185 1864 SRS7019T 2318 -189 1846 SRS7019Z 2821 -179 1820 SRS7022S 3205 -18 2187 SRS7022Z 3223 18 2231 SRS7025S 3475 -36 2109 SRS7025Z 2424 -155 1821 Add the following after the last paragraph of section 6.6.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100 cm2 Area 100 cm 2 Areas MDC (dpmll100cm 2 ) (dpm/1 00CM2 ) (dpmll100cm 2 SRS7028R 3493 -65 2076 SRS7028S 3868 -32 2170 SRS7028T 2216 -160 1897 SRS7028U 3148 -98 2063 SRS7028Z 2965 -34 2110

Surey} Report SSGS Intake Tunnel (continued)

Add the following after the last paragraph of section 6.7.1:

"The following table provides the summary of the SCM data."

Maximum SurveyName 100em Area 100 Mean of em Area s 100cm 2) (dpm/ 2OOC 2) (dpm/1cm )

(dpm/

M0Cm 2)

SRS7031Z 3981 25 2682 Add the following after the last paragraph of section 6.8.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100cm 2 Area 100 cm 2 Areas MDC02 2 2 (dpm/l 00cm ) (dpm/l OOcm ) (dpm/10 cm )

SRS7020Z 2989 -98 2184 SRS7023Z 2796 150 2579 SRS7026Z 3220 -11 2513 Add the following after the last paragraph of section 6.9.1:

"The following table provides the summary of the SCM data."

Maximum Mean of DC Survey Name 100 cm Area 100 cm2 Areas dpmlOOcm 2 )

__(dpm/0cm

2) (dpm/0OOCM 2) ___70__2682 _

SRS7029Z 4014 j 70 J 2682 Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report SSGS Discharge Tunnel (GPU Nuclear Letter E910-05-044 comments from ORISE Letter dated August 17, 2005) la) Change the fourth paragraph of section 6.1.1 to read:

"All SCM surveys indicated activity less than the 75% Administrative Limit. All 43-68 scans were less than the 300 net cpm action level" Change the last sentence of section 6.2.1 to read:

"All SCM surveys indicated activity less than the 75% Administrative Limit."

Change the last sentence of section 6.3.1 to read:

"All SCM surveys indicated activity less than the 75% Administrative Limit."

Change the fourth paragraph of section 6.4.1 to read:

"All SCM surveys indicated activity less than the 75% Administrative Limit except for a three square meter area that had a maximum value of 11553 dpm/l 00cm 2 . This area was resurveyed using hand-held instrumentation. An elevated measurement comparison on this area is provided in section 6.4.3."

Change the last sentence of section 6.5.1 to read:

"All SCM surveys indicated activity less than the 75% Administrative Limit."

Change the fourth paragraph of section 6.6.1 to read:

"All SCM surveys indicated activity less than the 75% Administrative Limit."

Change the first two sentences of the fourth paragraph of section 6.7.1 to read:

"All SCM surveys indicated activity less than the 75% Administrative Limit except for two one square meter areas that had a maximum value of 7147 dpm/1 00cm 2 . An elevated measurement comparison test is shown in section 6.7.3."

Change the last sentence of section 6.8.1 to read:

"All SCM surveys indicated activity less than the 75% Administrative Limit."

Change the last sentence of section 6.9.1 to read:

"All SCM surveys indicated activity less than the 75% Administrative Limit."

Add section 6.7.3 as follows:

"6.7.3 Elevated Measurement Comparison Two areas were identified with the SCM scan, each less than one square meter in size. The maximum observed 100cm 2 value was 7147dpm/100 cm2 . This result can be used in an elevated measurement comparison using MARSSIM equation 8.2 as follows.

Assuming two areas of 1 square meter each one at 7147 and the other at 6742 dpm/1 00cm 22a survey unit average of 21 dpm/I 00cm 2 , and using the 75% Administrative Limit then Equation 8.2 becomes:

(7147-21)/(6605*1 1.2) + (6742-21)/(6605*1 1.2) + 21/6605 =

0.094 + 0.088 + 0.003 = 0.19 Therefore, the elevated measurement comparison using highly conservative assumptions (e.g. that each entire square meter is at the maximum observed for any single 100cm area in that square meter instead of the average for the square meter, using two separate I square meter areas instead of one 2 square meter area reduces the effective area factor, using the 75% Administrative Limit instead of the DCGLw adjusted down by the 4.7% for the de-listed radionuclides per the SNEC LTP section 6.2.2.3, etc.), is 19% of the EMC test limit. Therefore the survey unit passes."

Survey Report SSGS Discharge Tunnel (continued) lb) Since the class 2 and class 3 areas of the discharge tunnel did not contain specific contaminated systems and those areas of the discharge tunnel that were of higher potential for residual contamination were designated class 1, the class 2 and class 3 surfaces are expected to be uniformly contaminated with no locations of unusual concentrations such as would occur if systems or equipment were present. Therefore, the class 2 and class 3 surfaces surveyed with the SCM were fully representative of the possible residual radioactivity while class I areas did receive separate fixed-point measurements. No changes to the report are required.

lc)&ld) Change section 7.4.2 to add after table 7.4-1 read:

"Since the SCM collects data in a positionally sensitive pixel process similar to full coverage fixed point measurements, comparisons of the SCM data can be made.

Although exact pixel to pixel comparisons are impractical due to the limitations on the positional accuracy, the overall results agree as shown in the table below, since both sets reach the same conclusion that the survey unit passes."

Initial SCM results QC SCM results Survey area (cpm/100 cm2 ) (cpm/lOOcm 2 )

SS1 -1 -240 SS2 -18 -91 SS3 81 55 SS4 427 -147 SS5 168 928 SS6-1 126 334 SS6-2 53 610 SS7-1 -152 580 SS7-2 377 1396

2) Change the last sentence of the third paragraph of section 6.4.3 to read:

".... the SCM data was used as documented in Appendix E to directly determine..."

3) Change the second sentence in the second paragraph of section 7.4.2 to read:

"... supported by both the initial and QC results (reference 9.8) and they are within 20% or two times the background".

4) A special dose assessment was performed to demonstrate compliance because of the unique condition of the survey unit (many feet below ground, narrow tunnel) and because of the multiple types of measurements collected. Section 2.5.1.1 of MARSSIM provides for the option of performing specific dose assessments: "as an alternative to the unity rule, the dose or risk due to the actual residual radioactivity distribution can be calculated...". No changes to the report are required.

5) The elements of the data listed as NA in the table were not available from the SCM vendor. Since this is a completed design. The design calculation will not be revised for this clarification. No changes to the report are required.

Surey} Report SSGS Dischargc Tunnel (continued)

6) Add the following paragraph at the end of section 5.0:

"Portions of this survey were conducted with an automated positionally sensitive proportional counter Surface Contamination Monitor (SCM) system. The SCM is typically used in a scanning (rolling) mode. In rolling mode, the SCM logs information in 25 square centimeter 'bins' by logging data for each 5 cm width of the detector and for each 5 cm of travel. A precision wheel encoder measures the distance traveled. Data are recorded in 25 square centimeter pixels over the entire surface surveyed, meaning the SCM records 400 measurements for every square meter it covers. When SCM data is analyzed, the software considers each 25 square centimeter measurement as 1/4 of four separate 100 square centimeter areas. This technique ensures that the highest activity 100 square centimeter area is identified.

The collection of large amounts of data in discrete values allows the data to be evaluated via statistical methods that consider the distribution of activity on the surface in addition to its average concentration."

7) Add the following after the last paragraph of section 6.1.1:

"The lowing table provides the summary of the SCM data."

Maximum Mean of Survey Name 100 cm2 Area 100 cm 2 Areas MDC 2

(dpm/l OOcm ) (dpm/l 00cm ) (dpm/l 00cm2 )

2 SCS7055S 1410 -100 1233 SCS7055Z 1621 50 1518 SRS7037Z 4469 -33 2436 Add the following after the last paragraph of section 6.2.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100 cm Area 100 cm2 Areas 2 MDC (dpm/1 OOcm 2 ) (dpm/l 00cm 2 ) (dpm/l OOcm )

SRS7051Z 4885 -49 2666 Add the following after the last paragraph of section 6.3.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100 cm2 Area 100 cm 2 Areas MDCm2 (dpm/l OOcm 2 ) (dpm/l 00cm 2 ) (dpm/IOOCM )

SRS7050Z 5412 49 2831

Survcy Report SSGS Dischargc Tunncl (continued)

Add the following after the last paragraph of section 6.4.1:

"The lowing table provides the summary of the SCM data."

Maximum Mean of Survey Name 100 cm Area 100 cm Areas MDC

___________(dpm/1 2

00cm ) (dpm/1 00cm 2 (dpm/100____

SCS7074Z 1727 61 1350 SCS7075Z 3286 176 1652 SCS7076Z 3309 1069 3080 SRS7036Z 11553 395 4478 Add the following after the last paragraph of section 6.5.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100cm Area 100 cm 2 Areas MDC 5 RS7049Z

____________ (d1 4424 00cm2) 114 (dpm421438 3389 Add the following after the last paragraph of section 6.6.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100 cm2 Area 100 cm2 Areas MDC

___________(dpmll 00CM 2 ) (dpm/ 100cm2 ) (dpmll 00CM2 SCS7053S 2149 129 1630 SCS7053Z 1516 -91 1219 SRS7046Z 5164 95 3042 Add the following after the last paragraph of section 6.7.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100 cm2 Area 100 cm2 Areas MDC (dpm/l 00cm 2 ) (dpm/1 00cm 2 ) (dpm/100_cm )

SCS7054S 1832 136 1594 SCS7054Z 1199 -163 1085 SRS7047Z 7147 21 3350 Add the following after the last paragraph of section 6.8.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100 cm Area 100 cm 2 Areas 2 MDC (dpm/l 00cm 2 ) (dpm/1 OOCm 2 ) (dpm/I OOCm )

SRS7048L 4929 24 3199 SRS7048Z 5365 -184 2426

Survey Report SSGS Discharge Tunnel (continued)

Add the following after the last paragraph of section 6.9.1:

"The lowing table provides the summary of the SCM data."

Maximum Mean of Survey Name 100 cm2 Area 100 cm 2 Areas MDC (dpm/100cm 2 ) (dpm/1 OOCM2) (dpm/lOOcm )

SRS7052L 5069 -184 3089 SRS7052Z 3878 350 2926

8) Change section 8 items I and 2 to read:

"1) The average residual radioactivity on the surfaces is less than the 75%

Administrative Limit in all of the survey units

2) All measurements were less than the 75% Administrative Limit in survey units SSI, SS2, SS3, SS5, SS7-1, and SS7-2. Units SS4, SS6-1, and SS6-2 were shown to meet the elevated measurement criteria."

Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report SSGS Discharge Tunnel Transition Area (GPU Nuclear Letter E910-05-039 comments from ORISE Letter dated August 17, 2005)

1) Section 2.2.1 of appendix A discusses the use of the Nal for scanning for difficult to reach areas or highly corroded surfaces (where beta efficiencies would be limited).

Since the surrogate is Cs137, any instrument can be used that is capable of detecting Cs137. Appendix A demonstrates that the detection efficiency and MDCscan is adequate for FSS. Common industry practice and historical practice at SNEC is to use gamma sensitive instruments when surface conditions warrant. In this case, the surfaces were old (up to 70 years) porous, broken, etc. and were more appropriately scanned using gamma sensitive equipment. No changes to the report are required.

2) Change table 7.4-1 last two fixed-point location identifiers to:

Nal SS25-2 5 Nal SS25-2 20 Add the following to the first paragraph of section 7.4.2:

"GFPC data and Nal data for SS25-2 5 was within 20% or a factor of two of the background. Nal data for SS25-2 20 cannot be specifically compared for the within two times background criteria because the data recorded was in gross cpm with no specific background acquired. However, the data show that the results of both the initial and QC scan were less than the scan action level."

3) Change section 8.0 items 1 and 2 to read:

"1) The average residual radioactivity on the surfaces is less than the 75%

Administrative Limit in all of the survey units.

2) All measurements were less than the 75% Administrative Limit in three of the survey units and an elevated...."

4&5) Instruments with efficiencies less than the minimum specified in the survey design are not used. The minimum efficiency is carried forward into the "Survey Request" as a prerequisite and is one of the supervisory survey completion review parameters. No changes to the report are required.

6) In section 7.2, change "DCGLv" or "DCGL" to "75% Administrative Limit" in four places in through the first three paragraphs.

Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report SSGS CV Steam Tunnel (GPU Nuclear Letter E910-05-045 comments from ORISE Letter dated August 17, 2005)

1) Change items I and 2 in section 8.0 to read:

"I) The average residual radioactivity on the surfaces is less than the 75%

Administrative Limit in all of the survey units.

2) All measurements were less than the 75% Administrative Limit in all of the survey units."

2) Instruments with efficiencies less than the minimum specified in the survey design are not used. The minimum efficiency is carried forward into the "Survey Request" as a prerequisite and is one of the supervisory survey completion review parameters. No changes to the report are required.

Survey Report SSGS Scal Chamber Roofs (GPU Nuclear Letter E910-05-047 comments from ORISE Letter dated August 19, 2005)

1) Change third sentence of section 7.4.2 to read:

"...And therefore are in agreement with the primary result because they support the same conclusion, that the survey units pass, and the results are within 20% or are less than twice background"

2) Change items 1 and 2 in section 8.0 to read:

"1) The average residual radioactivity on the surfaces is less than the 75%

Administrative Limit in all of the survey units.

2) All measurements were less than the 75% Administrative Limit in all of the survey units."

3&4) Instruments with efficiencies less than the minimum specified in the survey design are not used. The minimum efficiency is carried forward into the "Survey Request" as a prerequisite and is one of the supervisory survey completion review parameters. No changes to the report are required.

5) In section 7.2 change "action level" to "75% Administrative Limit" in four paces, one in each paragraph

6) Change second line of second paragraph of section 6.1.2 from "... the of 75%..." to:

"... the 75%..."

Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Rcport SSGS Basement (GPU Nuclear Letter E910-05-037 comments from ORISE Letter dated August 19, 2005)

1) The cumulative frequency distribution of the data collected is used to select a background from a group of backgrounds that are collected on various surfaces at the site. No changes to the report are required

2) Replace the fist two sentences of the fourth paragraph of sections 6.1.1, 6.2.1, 6.3.1, 6.4.1, 6.5.1, 6.6.1, 6.7.1, 6.8.1, and 6.9.1 with:

"All SCM surveys indicated less than the 75% Administrative Limit."

3) Since the class 2 and class 3 areas of the basement were wall surfaces and did not contain specific contaminated systems and those areas of the basement that were of higher potential for residual contamination were designated class 1, the class 2 and class 3 surfaces are expected to be uniformly contaminated with no locations of unusual concentrations such as would occur if systems or equipment were present.

Therefore, the class 2 and class 3 surfaces surveyed with the SCM were fully representative of the possible residual radioactivity. No changes to the report are required.

4a) Add to section 6.2.2 prior to table 6.2-2:

" A concrete surface sample was collected at fixed point 7 and analyzed by laboratory gamma spectroscopy. Results were less than the 75% Administrative Limit as shown in Table 6.2-2 below."

4b) Add to section 6.3.2 prior to table 6.3-2:

" A concrete surface sample was collected at fixed point 5 and analyzed by laboratory gamma spectroscopy. Results were less than the 75% Administrative Limit as shown in Table 6.3-2 below."

4c) Add to section 6.4.2 prior to table 6.4-2:

" A concrete surface sample was collected at fixed point 7 and analyzed by laboratory gamma spectroscopy. Results were less than the 75% Administrative Limit as shown in Table 6.4-2 below."

4d) Add to section 6.5.2 prior to table 6.5-2:

" A concrete surface sample was collected at fixed point 3 and analyzed by laboratory gamma spectroscopy. Results were less than the 75% Administrative Limit as shown in Table 6.5-2 below."

5) Change the second sentence in section 7.4.2 to read:

"These duplicates had good agreement as shown in the table below (Table 7.4-2) because they both support the same conclusion, that the survey units pass, and because they are within 20% or a factor of two times the background except for SS 14-2 point 10. SS 14-2 point ten results in both cases of the initial and QC measurement, had unshielded results more than twice the backgrounds. This sample pair does not meet the criteria in reference 9.8. However, the remaining results (10 measurement) meet replicate requirements.

6) Change items I and 2 in section 8.0 to read:

" I) The average residual radioactivity on the surfaces is less than the 75%

Administrative Limit in all of the survey units.

2) All measurements were less than the 75% Administrative Limit in all of the survey units except SS14-1. Unit SS14-1 was shown by calculation to meet elevated measurement criteria"

Survey Report SSGS Basement (continued)

7) As a result of the comments from the inspection, the DCGLs wvere recalculated. The survey results were evaluated against these more recent mix calculations as discussed in section 5 and footnotes to table 1. No changes are required.

8)Add the following paragraph at the end of section 5.0:

"Portions of this survey were conducted with an automated positionally sensitive proportional counter Surface Contamination Monitor (SCM) system. The SCM is typically used in a scanning (rolling) mode. In rolling mode, the SCM logs information in 25 square centimeter 'bins' by logging data for each 5 cm width of the detector and for each 5 cm of travel. A precision wheel encoder measures the distance traveled. Data are recorded in 25 square centimeter pixels over the entire surface surveyed, meaning the SCM records 400 measurements for every square meter it covers. When SCM data is analyzed, the software considers each 25 square centimeter measurement as 1/4 of four separate 100 square centimeter areas. This technique ensures that the highest activity 100 square centimeter area is identified.

The collection of large amounts of data in discrete values allows the data to be evaluated via statistical methods that consider the distribution of activity on the surface in addition to its average concentration."

9) Add the following after the last paragraph of section 6.1.1:

"The following table provides the summary of the SCM data."

J Maximum Survey Name 100 cm Area 2 Mean of 100 cm 2 Areas MDlDC j(dpm/l OOcm 2

) (dpm/l 00cm2 ) (dpm/ 00cm)

SCS7066Z 3442 18 2078 Add the following after the last paragraph of section 6.2.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100cm2 Area 100 cm 2 Areas MDC 2 (dpm/1 00cm 2 ) (dpm/l OOcm 2 ) (dpm/l OOcm)

SCS7067Z 2176 -117 1781 Add the following after the last paragraph of section 6.3.1:

"The following table provides the summary of the SCM data."

Maximum Mean of

________j(dpm/1 Survey Name SCS7068Z 100 cm 2 Area 00CM 2) 1955 100 cm 2 Areas (dpml 100cm

-347 2)

MDC (dpmllI00CM2 1424 Add the following after the last paragraph of section 6.4.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100 cm 2 Area 100 cm 2 Areas MDC (dpm/l OOcm 2) (dpm/1 OOCm2) (dpm/lOOcm 2 )

SCS7069Z 2387 5 2018

Survey Report SSGS Basement (continued)

Add the following after the last paragraph of section 6.5.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100 cm2 Area 100 cm 2 Areas MDClDC 2

(dpnm/l OOcm ) (dpm/l 00cm 2 ) dp 00C)

SCS7070Z 1754 -381 1339 Add the following after the last paragraph of section 6.6.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100 cm2 Area 100 CM2 Areas MDC 2 2

(dpm/lOOcm ) (dpm/1 OOCM2) (dpm/lOOcm )

SCS7072S 1859 -377 1668 SCS7072Z 2645 -221 1894 Add the following after the last paragraph of section 6.7.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name I 100 cm 2 Area 100 cm 2 Areas MDC 2 (dpm/l OOcm 2

) (dpm/l 00cm 2 ) (dpm/1 00cm )

SCS7061Z 2219 -185 1298 Add the following after the last paragraph of section 6.8.1:

"The following table provides the summary of the SCM data."

Maximum Mean of c 2 Are 100cm 2 Ara MDC 2 Survey Name 100 cm Area AreasmAres (dpm/1 OOcm 2) (dpm/l 00cm 2) (dpm/l 00cm2 )

SCS7062R 1827 -33 1350 SCS7062S 1510 -82 1243 SCS7062T 1405 25 1493 SCS7062Z 1616 -243 1207 SCS7063Z 1932 163 1590 SCS7064R 1616 -30 1312 SCS7064S 2038 -8 1462 SCS7064T 1721 -30 1335 SCS7064Z 2038 23 1421

Survey Report SSGS Basement (continued)

Add the following after the last paragraph of section 6.9.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100 cm 2 Area 100 cm 2 Areas MDC (dpm/I OOcm ) (dpm/l OOcm ) (dpm/l 00cm2 )

2 2 SCS7065R 1367 -152 1102 SCS7065S 1721 -96 1214 SCS7065T 1405 -133 1197 SCS7065U 1932 -44 1241 SCS7065V 1616 -43 1309 SCS7065Z 1616 -59 1285 SCS7071X 1965 96 1926

10) Change section 7.4.2 to add after table 7.4-3 to read:

"Since the SCM collects data in a positionally sensitive pixel process similar to full coverage fixed point measurements, comparisons of the SCM data can be made.

Although exact pixel to pixel comparisons are impractical due to the limitations on the positional accuracy, the overall results agree as shown in the table below, since both sets reach the same conclusion that the survey unit passes."

Table 7.4-4 Basement SCM QC comparison Initial SCM results QC SCM results Survey area (cpm/100 cm2 ) (cpm/lOOcm )

SS14-1 143 144 SS14-2 7 -170 SS14-3 -223 -488 SS14-4 129 517 SS14-5 -257 -417 SS15 -142 -212 SS16 196 68 SS17 -26 -37 SS17 220 -119 Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report SSGS Firing Aisle (GPU Nuclear Letter E910-05-036 comments from ORISE Letter dated August 19, 2005) la) The cumulative frequency distribution of the data collected is used to select a background from a group of backgrounds that are collected on various surfaces at the site. No changes to the report are required Ib) Replace the fist two sentences of the third paragraph of sections 6.1.1 and 6.2.1 with:

"All SCM surveys indicated less than the 75% Administrative Limit."

I c) Since the class 3 areas of the firing aisle were floor and wall surfaces and did not contain specific contaminated systems the class 3 surfaces are expected to be uniformly contaminated with no locations of unusual concentrations such as would occur if systems or equipment were present. Therefore, the class 3 surfaces surveyed with the SCM were fully representative of the possible residual radioactivity. No changes to the report are required.

Id) Change items 1 and 2 in section 8.0 to read:

"1) The average residual radioactivity on the surfaces is less than the 75%

Administrative Limit in both of the survey units.

2) All measurements were less than the 75% Administrative Limit in both of the survey units."

2&3) Change section 7.4.2 to read:

"Since no fixed point measurements were required due to the unique nature of the SCM scanning, no specific fixed point QC measurements were taken. However, since the SCM collects data in a positionally sensitive pixel process similar to full coverage fixed point measurements, comparisons of the SCM data can be made.

Although exact pixel to pixel comparisons are impractical due to the limitations on the positional accuracy, the overall results agree as shown in the table below, since both sets reach the same conclusion that the survey unit passes."

Table 2 Firing Aisle SCM QC comparison Initial SCM results QC SCM results Survey area (cpm/100 cm 2 ) (cpm/lOOcm )

SS13-1 -24 -388 SS13-2 -108 -301

4) Add the following paragraph at the end of section 5.0:

"Portions of this survey were conducted with an automated positionally sensitive proportional counter Surface Contamination Monitor (SCM) system. The SCM is typically used in a scanning (rolling) mode. In rolling mode, the SCM logs information in 25 square centimeter 'bins' by logging data for each 5 cm width of the detector and for each 5 cm of travel. A precision wheel encoder measures the distance traveled. Data are recorded in 25 square centimeter pixels over the entire surface surveyed, meaning the SCM records 400 measurements for every square meter it covers. When SCM data is analyzed, the software considers each 25 square centimeter measurement as 1/4 of four separate 100 square centimeter areas. This technique ensures that the highest activity 100 square centimeter area is identified.

The collection of large amounts of data in discrete values allows the data to be evaluated via statistical methods that consider the distribution of activity on the surface in addition to its average concentration."

Survey Report SSGS Firing Aisle (continued),

5) Add the following after the last paragraph of section 6.1.1:

"The following table provides the summary of the SCM data."

l Maximum Mean of Survey Name 100 cm 2 Area 100 cm Area MDC l (dpm/ll OOcm 2 ) (d (dpm/l cm)

SRS7056Z 5869 -234 3622 Add the following after the last paragraph of section 6.2.1:

"The following table provides the summary of the SCM data."

Maximum Mean of Survey Name 100 cm2 Area 100 cm 2 Areas MDC (dpm/1 OOcm 2 ) (dpm/l OOcm 2 ) (dpm/l OOcm2 )

SRS7057L 4949 561 4304 SRS7057X 1 3844 -163 2936 Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Report SSGS Seal Chambers (GPU Nuclear Letter E910-05-038 comnmenis from ORISE Letter dated August 19, 2005)

1) Change items I and 2 in section 8.0 to read:

"1) The average residual radioactivity on the surfaces is less than the 75%

Administrative Limit in all of the survey units.

2) All measurements were less than the 75% Administrative Limit in all of the survey units except for one concrete sample in SS8-2."

2) Change center and right column headings in table 5.0.1 from "SS8-1, SS8-1, SS8-3" to: "SS8-1, SS8-2, SS8-3" Note: Some of the above changes may not be based on specific comments for this report but are consistent with comments made on other reports

Survey Rcport Embedded Buried Piping (GPU Nuclear Letter E910-05-055 comments frobm ORISE Letter dated August 23, 2005)

There were no comments requiring resolution on this report