ML061030307

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Enclosure 3: Supporting Survey, Excavated Surface Release Record East TBC
ML061030307
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 04/25/2006
From:
- No Known Affiliation
To:
NRC/FSME
Shepherd J
Shared Package
ML061030302 List:
References
Download: ML061030307 (63)
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mm-Rev. 1 Supporting Survey, Excavated Surface Release Record East TBCqjI Base Elevation Survey of Turbine Building Excavation Following Removal of Foundations and Subsurface Components SURVEY PACKAGE CLOSURE Final Status Survey Documentation is authorized for closure. All required reviews are complete and the evaluation of data results have satisfied the criteria established for unrestricted release and onsite use for excavation backfill.

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Signed:

(rSSG Supervisor)

Signed:

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Date: 3 oc (ES Superintendent)

Signed:

(RP & ES Manager)

Date:

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Survey Package Revision Log Rev #

Description Date 0

Original Issue 12-06-05 Editorial changes and corrections 03-30-06

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NINNNN-Final Status Survey East TBCqII Turbine Building Base Elevation Survey Following Removal of Foundations and Subsurface Components SURVEY PACKAGE CLOSURE Final Status Survey Documentation is authorized for closure. All required reviews are complete and the evaluation of data results have satisfied the criteria established for unrestricted release and onsite use for excavation backfill.

/(/241 Signed:

Signed:

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S<G Supervisor)

Date: /2-cob-Or-Date:

Or - I ck - D Date:

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(Er SI'perintendent)

(KP & ES Manager)

Survey Requirements Release Record East TBCq11 Base Elevation Turbine Building Excavation Area Survey Description Suppcrting Survey East TBCqi1 encompasses 1776 m2 of the Turbine Building demolition area located immediately south of Containment. This area is an open excavation approximately four meters below grade that results from demolition and removal of the Turbine Building and.ll subsurface structures and components. No materials of plant origin remain in the survey area.

History During plant power operations the Turbine Building supported the components and interconnecting systems external to Containment that were necessary for electrical power generation. These systems included the following:

  • Steam turbine and generator
  • Nuclear steam supply and condensate return system piping
  • Clean-up filter and demineralizer systems
  • Condenser cooling water system Liquid waste effluent piping A detailed review of the event history and radiological characterization for the Turbine Building area is provided in Chapter 2 of the License Termination Plan (pages 2-13 and 2E-44).

Current Radiological Status Soil Characterization surveys and radiological evaluations for the release of demolition materials do not indicate the presence of significant residual radioactivity in this survey area. Based on operational history and former placement of radioactive systems and material transport pathways at this location the radiological status of this survey area is Class 1. Input for this evalua:ion includes the following survey data:

Characterization Survey Unit 8 (LTP, 2E-44),

Survey Package TB 041505, Survey Package TB 042005, Survey Package TB 051805, Survey Package TB 061005, Survey Package TB 061405, Survey Package TB 090105, and Characterization Survey East TBAq11 Survey Area Requirements Survey East TBCqf 1 Page 1 of 2

Post-Construction Expectations Survey East TBCq11 will be performed in the following activity sequence:

1. Walkdown: Site Characterization personnel will perform a walkdown assessment to insure survey area preparations are complete and confirm that the following post-construction expectations have been satisfied:

Groundwater and Surface water control is adequate All construction debris has been removed from the survey area The current survey area status meets all applicable safety requirements

2. A licensed independent survey shall verify that the excavation area is at or below the base elevation of original construction for all structures, components and foundations formerly located in the survey unit.
3. Survey Area Isolation and Control: Control measures will be established to ensure that any potential ongoing decommissioning activities in adjacent locations do not impact the current survey area status. Isolation and control measures include postings, barriers, access points, and the evaluation of ongoing work activities in adjacent areas.
4. Survey Design and Execution: Survey design and execution will follow the Data Quality Objectives for Survey East TBCq11 in accordance with the survey requirements established in RM-76, Final Status Survey Design,and RM-77, Final Status Survey Implementation. Survey size will be based on the statistical requirements of the Sign Test for Class 1 areas with soil samples collected in random start, systematic data point locations. Surface scanning will be performed with 100% survey area coverage. This survey will be conducted in accordance with approved BRP procedures and follow the guidance of NUREG 1575.
5. Data Quality Assessment: Isolation and control of the survey area will be maintained until the survey Data Quality Assessment demonstrates that the regulatory requirements for unrestricted site release have been satisfied. Once released for unrestricted use, this area will be backfilled and restored to original grade elevation.

Survey Area Requirements Survey East TBCq, 1 Page 2 of 2

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DATA QUALITY OBJECTIVES Release Record East TBCq11 Base Elevation Turbine Building Excavation Area STATE THE PROBLEM The Problem:

To demonstrate that the level of residual radioactivity in the excavated area of the former Turbine Building does not exceed the release criteria of 25 mrem/year Total Effective Dose Equivalent (TEDE) as specified in the License Termination Plan (LTP). This Class 1 survey area includes all exposed sub-surface soils in the East Turbine Building Demolition Area. It must be demonstrated that this survey area meets the criteria established for unrestricted release prior to backfill and return to original grade elevation.

Stakeholders:

The primary stakeholders interested in the answer to this problem are Consumers Energy Co., and the general public as represented by the Michigan Department of Environmental Quality (MDEQ), and the US Nuclear Regulatory Commission (USNRC).

The Planning Team:

The planning team consists of members of the BRP Environmental Services Survey Group (ESSG). The primary decision maker will be the Final Status Survey (FSS)

Supervisor. The Final Status Survey Supervisor will obtain input from the site Construction Group and Scheduling Group for issues relating to schedule and costs.

Schedule:

Approximately five (5) working days are projected to implement the Final Status Survey to collect and analyze field data.

Resources:

The primary resources needed to determine the answer to the problem are two (2) technicians to perform fieldwork, one (1) technician to prepare the samples and conduct laboratory analyses, and two (2) site characterization team members to prepare and review the design, generate maps, coordinate field activities and evaluate data.

2.

IDENTIFY THE DECISION Several decisions need to be defined to address the stated problem.

Principal Study Question (1):

Does the mean concentration of residual radioactivity in the survey unit exceed the release criteria stated above?

Decision (1):

Determine whether the mean concentration of residual radioactivity in the survey exceeds the release criteria stated in the problem.

Data Quality Objectives Survey East TBC. 11 Page 1 of 5

Actions (1):

Alternative actions include failure of the survey unit, remediation, or no action required.

Principal Study Question (2):

Do any areas of elevated activity in the survey unit exceed the release criteria?

The Decision (2):

Determine if any areas of elevated activity in the survey unit exceed the release criteria.

Actions (2):

Alternative actions include confirmation and investigation, performing the elevated measurement comparison (EMC), remediation, or no action required.

Principal Study Question (3):

Is the potential dose from residual radioactivity in the survey unit ALARA as statedt The Decision (3):

Determine if the potential dose from residual radioactivity in the survey unit is ALARA.

ALARA requirements for soil remediation are defined in Chapter 4 of the LTP.

Actions (3):

Alternative actions include remediation or no action required.

3.

IDENTIFY INPUTS TO THE DECISION Information Needed:

Characterization measurements are required to define the radionuclides present and determine the extent and variability of residual radioactivity in the survey area for design and implementation of this survey. Survey area classification, ALARA analysis, potential radionuclides of interest, and site-specific DCGL values are also required inputs to the decision process. The primary information required for evaluation is the analytical results of survey measurements.

Source of the Information:

The soil sample data to be used for survey development are the radionuclide-specifi-measurements of soil samples collected within the affected local coordinate grids during the characterization process. This data also include the results of multiple surveys performed during soil excavation and the removal of demolition debris. The ALARA analysis for potential soil remediation is provided in LTP, Section 4.4. Sitespecific DCGL values and BRP radionuclides of interest are defined in LTP Section 5, Table 5-1 and Procedure RM-76, Final Status Survey Design.

Survey East TBCql will be conducted in accordance with LTP Section 5 for Class 1 areas and associated BRP survey procedures. Soil samples will be utilized for radionuclide-specific measurements in this evaluation.

Data Quality Objectives Survey East TBCq,11 Page 2 of 5

4.

BOUNDARIES OF THE STUDY Boundaries of the Survey.

The target population for this survey is the upper 15 cm of soil in a defined survey area of 1776 M2. The physical boundary includes all exposed soils in the excavated area identified by survey design within local coordinates 6S -12S by 7E -11 E.

Temporal Boundaries:

Scanning and sampling in this survey unit will only be performed during daylight hours during acceptable weather conditions. Collection of data will take place when surface conditions are most favorable. Surface soils must be free of excessive snow cover and significant standing water prior to surface scanning. Soils must be in a non-frozen state or fragmented for collection to satisfy BRP procedural sampling requirements.

The anticipated start date for the survey is September 20, 2005.

Constraints:

Cold weather or excessive rain conditions may effect the operation of electronic equipment. Adverse weather conditions that include accumulalions of rain or snow may limit area access and delay survey efforts.

5.

DEVELOP A DECISION RULE The following decision rules have been developed to define a logical process for choosing among alternative actions for the principal study questions associated with this survey area.

Decision Rule (1):

If all reported concentrations for residual radioactivity are less than the sitespecific DCGL's and the unity rule has been satisfied for each sample, then the survey unit meets release criteria. No further action is required.

Decision Rule (2):

If the mean value of activity in the survey unit is greater than the DCGL, then the survey unit fails to meet the release criteria.! Remediate, resurvey, and evaluate the resul:s relative to the decision rule.

Decision Rule (3):

If the mean activity in the survey unit is less than the DCGL and any individual sample measurement exceeds this value conduct the Sign Test and the elevated measurement comparison (EMC) per LTP, Chapter 5 and Procedure RM-76, Final Status Survey Design. If the EMC and the Sign Test have been satisfied then the survey unit meuets the release criteria and no further action is required. If the EMC or the Sign Test has not been satisfied then remediate the area(s) of elevated activity, resurvey as appropriate, and evaluate the results relative to the decision rule.

1 When multiple radionuclides are present the mean activity value is determined as the average of the weighted sum. The DCGL of the weighted sum is 1.

Data Quality Objectives Survey East TBCqil Page 3 of 5

Decision Rule (4):

If the potential dose from residual radioactivity in the survey unit is ALARA, then no further action is necessary. If the potential dose from residual radioactivity in the survey unit is not ALARA, then remediate and resurvey.

6.

SPECIFY TOLERABLE LIMITS ON DECISION ERRORS The Null Hypothesis:

It is assumed that residual radioactivity in the survey unit exceeds the release criterion.

Type I Error (a):

The a error is the maximum probability of rejecting the null hypotheses when it is true.

The a error is defined in the LTP at a value of at 0.05 (5%) and cannot be changed to a less restrictive value unless prior approval is granted by the USNRC. The a error value of 0.05 will be used for survey planning and data assessment for this survey area.

Type 11 Error (,/ ):

The /J error is the probability of accepting the null hypothesis when it is false. A value of 0.05 (5%) will be used for survey planning and data assessment for this survey area.

The Lower Bound of the Gray Region (LBGR):

The LBGR is initially set at 0.5 forthis survey unit. The LBGR may be adjusted during survey design to achieve an optimum relative shift between 1.0 and 3.0.

Relative Shift (A/a):

The relative shift will be maintained within the range of 1.0 and 3.0 by adjusting the LBGR as appropriate.

7.

OPTIMIZE DESIGN FOR OBTAINING DATA Statistical Test Sign Test:

Radionuclides of potential plant origin also present in soil as background activity resulting from fallout constitute only a small fraction of the DCGL. Therefore, the Sign Test will be used where applicable in the FSS evaluation to determine if the survey area meets the requirements for unrestricted release.

Number of Samples Determined:

The number of samples required for this survey will be determined based on the relative shift as defined by the requirements of the Sign Test (LTP, Chapter 5) and Procedure RM-76, Final Status Survey Design. The LBGR is initially set at 0.5 and may be adjusted as necessary for optimizing the survey design to achieve a relative shift between 1.0 and 3.0. Sample point locations are to be determined using a random start, systematic grid spacing. For sample point locations where access is impractical or unsafe, alternate locations will be randomly selected to achieve the sample size requirement.

Data Quality Objectives Survey East TBCq1 1 Page 4 of 5

Biased Sampling:

Co-60 is the most limiting radionuclide for identification by surface scanning; biased surface and subsurface core samples will be collected in any location that exceeds the scan investigation level.

Scan Coverage:

Scanning for this survey area will provide 100% coverage.

Number of Samples for Quality Control:

A minimum of 5% of the sample population will be collected for quality evaluation.

These samples may include sample splits, sample recounts, or third party sample analysis. Quality analyses will be conducted as defined in LTP, Chapter 5 and Procedure RM-79, Final Status Survey Quality Control.

Additional Sample Analysis Requirements:

An additional quantity of soil shall be collected for Tritium Analysis in the same locations as samples selected for QAIQC. A minimum of 10% of the sample population will be sampled. Tritium analyses will be performed by an independent laboratory. Data results will be provided in the FSS package.

Investigation Levels:

Investigation levels are defined in LTP, Chapter 5 and Procedure RM-76, Final Status Survey Design, by individual survey area classification; however, prior to regulatory approval of the LTP a more conservative approach for investigation will be established for this survey as shown below.

Investigation Levels for Survey EastTBC, 11 Classification Scan Measurement Soil Sample Analysis Class 1

> DCGL

> DCGLw The investigation levels for soil sample measurements are meant to include any individual radionuclide result greater than the site-specific DCGL or where the combined radionuclide values exceed the unity rule. Co-60 is the most limiting radionuclide for identification by surface scanning; further investigation will be initiated at any location that exceeds the Co-60 Scan DCGL of 1818 CPM above background as detailed in the survey design.

Data Quality Objectives Survey East TBCq11 Page 5 of 5

SURVEY DESIGN Release Record East TBCq11 Base Elevation Turbine Building Excavation Area Survey Unit Description Final Status Survey East TBCq11 encompasses 1776 m2 of the Turbine Building demolition area immediately south of Containment. The Turbine Building and all system corn ponents, subsurface structures, and foundations have been removed. No materials of plant origin remain at this location. The survey area is an open excavation that extends approximately four meters below grade to the base elevation of original construction as detailed in Attachment 4.

Soil Sample Design Scoping Data Scoping survey measurements conducted in the Turbine Building excavation area only identified MDA or background levels of residual radioactivity. As a conservative measure, input values for survey design were estimated based on activity measurements identified in the adjacent survey unit for final status evaluation of the Screenhouse excavation (FSS 09Q 1).

Table I Input Data for Survey Design (pCi/g)

Radionuclides Cs-1 37 Co-60 0.41 0.41 DCGL 11.93 3.21 Sample Requirements The number of sample data points for this survey is based on the requirements of the Sign Test.

The Unity Rule is used for the presence of multiple radionuclides. The Standard Deviation of the weighted sum is described by the following:

Ocs3l

)2 2

CDCGLcst37)

Gc 6=0.13 Survey Design East TBCtt1 Page 1 of 8

Relative Shift The DG.GL for the weighted sum is 1.0. The relative shift is determined using an LBGR value set at,4% of the DCGLW.

Relative Shift = DCGL-LBGR 6

1-0.74 Relative Shift =

0.13 Relative Shift = 2.0 With a and f error levels set at 0.05 andthe relative shift of 2.0, the Sign Test requires 15 sample data points (Table 5.5 NUREG 1575). As a conservative measure a minimum of 18 samples will be collected in this survey unit.

Sample Locations Sample locations are selected in a random-start systematic pattern with the southwest corner of the survey unit as origin (X=0, Y=0). Two numbers between 0 and 1 have been randomly selected and then applied to the survey unit maximum X and Y dimensions to determine the random start location as shown below.

Table 2 Random Numbers Random #, X Axis l

Random #, Y Axis 0.171333 1

0.779592 l

Survey Dimensions:

X (ENW) = 40.0 meters Y (N/S) = 49.4 meters Random Start Location X = (0.171333)(40.0) = 6.9 meters With SW Corner Origin: Y = (0.779592)(49.4) = 38.5 meters The survey unit origin is located in Grid 342 of the site coordinate system at X=10.0 meters, Y= 5.0 meters. The random start location for this survey is located in Grid 269 at X= 6.9 meters Y= 38.5 meters.

Survey Design East TBC,11 Page 2 of 8

Sample Spacing Samples are located in a systematic square grid pattern with sample spacing determined by the following:

L = JI-where A= area of survey unit and n = number of samples.

L=

7_6= 9.9 meters 18 With sample spacing established at 9.9 meters, 18 data point locations are available for survey as identified in Attachment 1.

QAIQ(C Sampling A minimum of 5% of the sample population and 5% of the scan survey area are required to be selected for QA/QC verification in accordance with BRP Procedure RM-79, Final Status Survey Quality Control. As a conservative measure, three (3) soil samples and 10% of the scan survey area will be selected for QA/QC evaluation. Data point locations for soil sampling will be determined by random number selection.

The starting point and track direction for QA/QC scanning are also determined by random number selection. The first random data point selected will identify the scanning start point and the second random data point will determine the direction in which the scan will track. QA/QC location results are provided in Table 3.

Table 3 Random Numbers Generated for QAIQC QAIQC Soil Random Random S lSample Verification Scan Sample Samples Number Number Split Sample:

7 Start Point:

2 Sample Recount:

12 Scan Towards:

16 Sample Recount:

8 Minimum Scan Area Requirement:

178 m2 Surface Scanning The coverage requirement for surface scanning in this Class 1 area is 100%. The Scan MDC has been established at fractional values of the DCGLwfor typical background activity levels a, Big Rock noint. Scan MDC values for varying backgrounds are provided in Attachment 2.

Survey Design East TBCq,1 Page 3 of 8

The investigation level for identification of potential areas of elevated activity in this survey area will be the Scan DCGL as defined by the following:

SCAN IOCGL = Detector Rating CPM

  • Exposure Model uRi/hr
  • DCGL, uR/hr pCi/g Scan DGL for Co-6O = 1818 cpm Scan DZ-GL for Cs-i137 = 3518 cpm Where?

Detector Rating = 1200 CPM Cs-137 and 565 CPM Co-60 uR/hr uR/hr Exposure Model = 1.229uRi/hr Cs-137 and 5.029uRi/hr Co-60 5pCi/g 5pCi/g DCGLW = 11.93 pCi/g Cs-137 and 3.21 pCi/g Co-60 The D(CGLW for Co-60 is the most limiting value for scanning measurements performed to identify areas of potentially elevated activity. Scanning conducted for this Final Status Survey will assume all residual radioactivity to originate from Co-60 and the instrument response at the Co-60 DCGLW (1818 cpm) will be used as the scanning investigation level for Survey EastTBCqi 1.

These values established in EA-BRP-SC-0201, Nal Scanning Sensitivity For Open Land Survey Survey Design East TBCj 11 Page 4 of 8 Soil Sample Locations Release Record East TBCqlI Turbine Building Excavation Area N

y=49 4 meters

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Sample Grid No.

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332

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322 6.6

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321 6.7 3.7 6 >

320

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307 6.9 3.6

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308 6.8 3.6 10 309 6.7 7

3 11 272 6.6 3.5 12 271 6.7 35 13 270 6.8 3,5 14 269 6.9 V35 15 250 6.9 3A 16 251 6.8 I3A 17 252 6.7 3d4 18 253 6.6 1 3'4

'Sample no. 14 is the random start location Sample spacing is 9.9 mters Survey Design East TBC 51l Page 5 of 8 Scan MDC In Varying Backgrounds Release Record East TBCql1 Turbine Building Excavation Area

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MDCRsurveyor Cs-137 Co-60 Cs-137 Co-60 1000 2.48 4

28.64 607.47 0.51 1.08 2.06 1.07 500.W ;:.'

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698 ;57.

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3000 2.48 4

35.07 744.00 0.62 1.32 2.52 1.31 8500 2.48 4

37.88 803.61 0.67 1.42 2.72 _

1.41 4000 2.48 4

40.50 859.10 0.72 1.52 2.91 1.51

,4500 2.48 4

42.95 911.21 0.76 1.61 3.09 1.60

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4528 960.50 0.80 1.7 6

1.69

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47.49 1,007.38 0.84 1.78 3.42 1.77 6000 2.48 4

49.60 1,052.17 0.88 1.86 3.57 1.85 6500 2.48 4

51.63 1,095.14 0.91 1.94 3.71 1.93

'000 2.48 4

53.57 1,136.48 0.95 2.01 3.85 2.00 750 28.48-4f tr'p 55 4'

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57.27 1,214.95 1.01 2.15 4.12 2.14 8500 2.48 4

59.04 1,252.34 1.04 2.22 4.25 2.20 9000 2.48 4

60.75 1,288.65 1.07 2.28 4.37 2.27 9500 2.48 4

62.41 1,323.96 1.10 2.34 4.49 2.33

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65.61 1,391.90 1.16 2.46 4.72 2.45 11000 2.48 4

67.16 1,424.65 1.19 2.52 4.83 2.51 11500 2.48 4

68.67 1,456.67 1.21 2.58 4.94 2.56 12000 2.48 4

70.14 1,488.00 1.24 2.63 5.04 2.62

,'12500.

248 4

71:59 '1,518'68 1.27

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2.67 13000 2.48 4

73.01 1,548.76 1.29 2.74 5.25 2.73 13500 2.48 4

74.40 1,578.26 1.32 2.79 5.35 2.78 14000 2.48 4

75.77 1,607.22 1.34 2.84 5.45 2.83 14500 2.48 4

77.11 1,635.67 1.36 2.89 5.55 2.88 15000 2.48*

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_ __ _ _ _ __ _ _ __ _ _ _-I Survey Design East TBCq. 1 Page 6 of 8 Area Factors for Open Land Survey Evaluation Release Record East TBCq11 Turbine Building Excavation Area ContaminatedCalculated Area Factors at Time of Peak Dose tArea (mi2 H-3 Mn-54 Fe-55l Co-60 Sr-90 Cs-137 Eu-152 Eu-Eu-1 55 Area in 2

)154 8094 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 4047 1.00 1.01 1.00 1.01 1.00 1.02 1.02 1.01 l1.02 2024 1.00 1.03 1.00 1.03 l 1.00 o 1.03 1.03 1.03 1.03 1012 1.35 1.04 1.00 1.04 1.00 1.04 1.05 1.04 1.04 516 2.91 1.09 1.98 1.08 1.98 1.13 1.07 1.07 1.06 253 6.05 1.14 3.95 1.13 3.94 1.20 1.11 1.11 1.09 126 12.4 1.20 7.93 1.20 7.87 1.29 1.17 1.16 1.14 63 24.9 1.30 15.8 1.30 15.6 1.41 1.27 1.26 1.23 32 49.2 1.49 31.2 1.49 30.5 1.62 1.44 1.45 1.39 16 98.9 1.78 62.0 1.78 59.9 1.93 1.72 1.73 1.63 8

198 2.38 123 2.38 117 2.58 2.30 2.31 2.14 4

397 3.61 243 3.62 230 3.91 3.49 3.52 3.19 2

794 5.68 473 5.75 452 6.14 5.48 5.55 4.90 1

1590 9.57 905 9.73 887 10.3 9.24 9.39 7.88 Survey Design East TBCq.1 Page 7 of 8

Survey Grade Elevations Release Record East TBCq11 Turbine Building Excavation Area SITE LOCAL COORDINATE GRID SYSTEM AND EXCAVATED GRADES SEPTEMBER 13, 2005 REACTOR SPHERE

-*249 251 4+252.

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269

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+ 300

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LURSINE CENERATOR RB 01.C ii i

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ELEVATION DENOTES MEASURED GRADE AFTER EXCAVATION.

ALL MEASURED GRADES ARE AT OR BELOW ORIGINAL DESIGN BOTTOM OF FOOTINGS ELEVATIONS AS DEPICTED ON THE TURBINE BUILDING FOUNDATION PLAN PREPARED FOR BECHTEL CORPORATION (DRAWING #0740020251 REV. B)

DATED 12-01-1967.

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I I JOHN-E. FERGUSON_ P_ e No. 24595 FELD:

COH, CS i DRAWN: DDH SCALE: I -50 JOB:

BIG ROCK POINT i DATE: 9-13-05 FERGUSON & CHAIlBERLAIN ASSOC1TSY INC.

PROFESSIONAL SURVEYORS 103 W. UPRIGHT STREET. CHARLEVOIX, MICHIGAN 49720 (231) 547-6882 -

FAX (231) 547-0021 EMAIL:

surveytfreewcy.net Survey Design East TBC.q 1 Page 8 of 8

RM-76 FINAL STATUS SURVEY DESIGN Revision 1 Page 19 of 19 RM-76-5 FINAL STATUS SURVEY APPROVAL AND AUTHORIZATION FOR IMPLEMENTATION Survey Code East TBCqj 1 Survey Area

Description:

Surveys East TBC II encompasses 1776 m2 of the Turbine Building excavation area immediately south of Containment. This area is an open excavation approximately four meters below grade located that results from demolition and removal of the Turbine Building and all subsurface structures and components.

The survey area is authorized for Final Status Survey Implementation.

Designed by Te'hnical Re\\7iew by i//4 /s0 Date 1, 0.<

Date RM-713.doc

RM-77 FINAL STATUS SURVEY IMPLEMENTATION Revision 2 Page 9 of 12 RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 1 of 3 Step (I)

Initial Date 4j4/

q/0/94-1.0 PREPARATION FORSURVEY EastTBC.1 Survey #

1.1 Survey Area Status:

a.

Final Status Survey Design has been approved for implementation (see RM-76-5, Final Status Survey Approval and Authorization for Supplementation).

1.

Survey area walkdown complete

2.

Survey area determined ready for FSS

3.

Decommissioning activities that may impact the environmental status of the survey area have been completed.

4.

Survey area environment is controlled by barriers and postings or other approved method to restrict access.

/

b. Survey area has been turned over to the Environmental Services Survey Group (ESSG) in acceptable condition for FSS.

1.2 Field Preparation:

7

a.

Survey unit boundaries delineated (Step 6.1.1) 7

b.

Statistical soil samples predetermined in the survey design are located and marked within the survey unit.

/

(Step 6.1.2) 7'

c.

Soil sample locations verified (Step 6.1.2.c) l

d.

Instruments and equipment have been collected and calibrated for data measurement and collection 7

(Step 6.1.3)

e.

Field documentation is prepared (Step 6.1.4)

ESSG ESSG X0961z ESSG RM-77.doc

RM-77 FINAL STATUS SURVEY IMPLEMENTATION Revision 2 Page 10 of 12 RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 2 of 3 Initial Date 2.0 DATA COLLECTION 2.1 Soil Survey:

-Z All soil samples collected and controlled (Step 6.2.1).

ESSG

_E6719zos-2.2 Surface Scan:

, /

Surface Scan complete. Action response requirements have been conducted on any identified areas exceeding the investigation level (Step 6.3).

2.3 Judgmental Soil Samples:

ESSG

_y2jz) C6-V

a.

Judgmental soil samples have been collected and controlled (Step 6.2.3).

A

b.

Deep core profiles performed in areas identified to contain elevated residual activity (Step 6.2.3).

3.0 SAMPLE PREPARATION AND LABORATORY ANALYSIS 3.1 Sample Preparation (Step 6.4.1):

7

a.

Soil samples are homogenous 7/

b.

Soil samples are visibly dry prior to packing

c.

Non-soil materials have been removed from sample 7Z

d.

Soil samples have been transferred to one-liter Marinelli containers and are labeled and sealed.

ESSG 15_,) /0!_

Qet_, -

t Tff _SG

- V, 2 16 5 -

RM-77.doc

RM-77 FINAL STATUS SURVEY IMPLEMENTATION Revision 2 Page 11 of 12 RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 3 of 3 Initial Date 3.2 Laboratory Analysis:

/

Isotopic analyses are complete. The spectroscopy report requires a signature of completion by the laboratory analyst and a signature of evaluation documenting that a second level review has been performed (Step 6.4.2).

SSG~af 3.3 Sample Control and Documentation:

/

Chain of custody documentation exhibits control of soil samples (Step 6.4.3).

?E S-SG 2_-z 7110-r-

/.D 7ate Date RM-7'7.doc

RM-59 SAMPLING AND ANALYSIS OF OPEN LAND AREA', FOR SITE CHARACTERIZATION SURVEYS Revision 10 Page 7 of 13 0-ATTACHMENT RM-59-1 SAMPLING AND ANALYSIS REPORT Date: 09-20-05 Time: 1645 Location: Turbine Building Tech:ef I l Excavation Area I

SURVEY IDENTIFICATION / DESCRIPTION Survey East TBC1 1 encompasses 1776 m2 of the Turbine Buildinq demolition area immediately south of Containment. The survey area is an open excavation approximately four meters below grade that results from demolition and removal of the Turbine Buildina and all subsurface structures and components.

SURVEY TYPE Survey Type:

Characterization Scan (Motive)

Remediation i

Final Scan (Static)

Trenching and Digging (use RM-59-4)

SURVEY DESIGN Sample Collection:

Judgmental Random V Systematic Large Container Assay Scan Coverage:

Z00 ANALYSIS Inst./Serial No. /9pj'/,///go>/§ DAILY CHECK:

v SAT UNSAT INIT: 'I Inst./Serial No.

Ztr.

DAILYCHECK:

7 SAT UNSAT INIT: i Investigation of Unidentified Peaks:

SAT UNSAT INIT:

-L Minimum Detectable Activity (Section 5.3.2)

I/

SAT UNSAT INIT: 'V,

COMMENTS Survezi East TBC,,1 was performed in a random start, square grid, systematic sampling pattern with samoles collected at 18 data point locations. Laboratorv analvses did not identify residual radioactivity above trace levels of the DCGL value. Surface scanning at 100% coverage identified no areas of elevated residual radioactivity. The results of QA/QC verification scanning (10% coverage) were consistent with the c scni v

es identfified in +he ci rve Technician Signature:

=

Date: a Second Level Review:

Signature:

Z' Date: qF/ZZ/0 RM-5;9.doc

Surface Scan Summary Release Record East TBCq1I Base Elevation Turbine Building Excavation Area N

7S 6.4 y=49.4 meters 6.0 7.8 15 a

a14 a

J5 7.7 8.9 16 i

O i

7.5 7.2

,j...

17 a

I.

18 0

6.7 7.8 a13 8S 6.6 Ji

~~~~..

6.8 6.5 8

9 0

a 7.2 7.0 12 a

10 a

5 0

11 JP J2 I

I 6.7 i

_~

9S 7.3 7

0 6.2 7.2 6

7.4.

7.3 7.2 4

0 0S 7.6 J4 2

6.9 ID7*

1T f6.1 3

O 6.5 t1S 75 12S

_3 6.7 6.6!

bE 6.31 hOE 6.5 X=40.0 meters 7E 18E h1 E I..

Legend O

Soil Sample Locations

=

SurveyArea

=

Numbered Local Coordinate Grid, IOXIO meters j7 Sump 1251 I I10 Meters

'-i Values are Average Mobile Scan General Area Activity (kcpm)

BLUE Values are Average Verification Scan General Area Activity (kcpm)

GREY Values are Average General Background Area Activity (kcpm)

Primary Scan:

/00 %

Technician Signature:

QC Verification Scan:

/0 Technician Signature:

K.

Date: ' o05 Time: I-L qO&

Dale: Z

- C)v-Time: -/6 L.

Soil Sample Activity Summary Release Record East TBCq1 I Base Elevation Turbine Building Excavation Area y=49.4 meters N

X=40.0 meters Legend Sol$a." ILociorw M~ S.W.m Sample,,

Grid X

y Cs137(pC

)

Co-60 (pC No No.-

Coord.

Coord.

AcUv1ty M-I Ac'VIXY I

DA" 1

331 8.9 3.8

.-O0003 0.0344 0O0033

-0.0562 2

332

.8 3.8 00022 0.0525

  • 0.033 0.0725 3

- 333 7

38

'0.0239 0.0550

'0.0411 0.0750 4

-- 322 6.6 3.7

'*0.0144 0.0471

'-0.0407 0.0550 5

32 7-37 i 0.0307

  • .0008 0.0524 6

320 3'8 3.7 0.0331

'-0.005

-0.0544 7

139 69 3

'-0.0322 0.0393

  • -0.0362 0.0509 8

07

,:69 36

'-0.0144 0.0386

'0.0279 0.0704

-9 308 -

i3.8 3.6

, 0.0221 0.0518

  • 0.0126 0.0684 10 309

'37 3.6

-- 0.0006 0.0470

'-0.006 0.0579

.86

3.5

'-0.0161 0.0399

  • -0.0225 0.0594 12 271 8

i

&7 3.5

-0.0195 0.0526

'0.0085 0.0659 13 -270

-0!6.8 3.5 0.0453

  • 0.0301

-0.06t4

-14 26

-29

.3.5

  • 0.031 0.0586

'0.0339 0.0728

.15 4250 L.9 34 0.0071 0.0470

  • 0.0022 0.0606

-16

251 68 3.4

'-0.0002 0.0560

'0.0316 0.0822 17 252

6.7
3.4 0.2399 0.0069 0.0605 18 253 6.6
3.4 0.0803 0.0615 0.0615 J1 -
270 4.5 2.3

'-0.0002 0.0459

'0.0365 0.0653 J2

.272 6.4 3.4

  • 0.0142 0.0466
  • 0.0179 0.0561 J3 344 8.3 8.6

'-0.0146 0.0445

'0.0060 0.0694 J4.

i319 2.4 4.4

'0.0002 0.0487

'0.0015 0.0659 J5

- I 251 2.7

'3.4

'-0.0093 0.0359

'-0.0177 0.0605

'Forced-count values

  • Coordinate locabon relative to SW corner of survey unit where X=O m. and Y'0 m.

RM-72 SAMPLE CHAIN-OF-CUSTODY Revision 0 Page 4cf 5 F55 EGS]-&C' iA RM-72-1 CHAIN-OF-CUSTODY RECORD Sample Number Sampling Location Date Time Final Disposition of Sample

. /

4e:A *3 0*\\38 Q~tID DS 5

  • a3z (io-i) (3.¶)

ca/20fes o85 lJ. atk 33 (La.)(3.7) 041o b

___090 lef

  • 31

~nq rICY 3.7')

9912Do Oqi V-Go-d *?2Z (10.t)(31) r2jJ5 O. A I 4.r.--u3DA7

{I@1Y3 -

0912010S ncP93 JL-21O 0X o-k

5) o2zo/ov 09q I 7

/a j-Aq2g h6eYIl q2o/o5 fJ.2.

I G:lIz3I b4Y(3.

5)

_____sO~q J6 o',

(bA o A 8ofS 4ojq

_q_

I r

i

A2S

(&.

)34)

P4 2/o2 06 tq

^J*#253~ (iY34Ad Ae/0 r

  • r :

§*z' a a!15 ov3s u (Samples may be analyzed and stored, shipped for offsite evaluation or analyzed and disposed of.)

1. Relinquished by:

Date Time Received in good condition by:

zJ3g H/2;z'o I/o5a

~%L.e

^Az ArjSi~z~

(c4(3A oqkol<

as~

LffLo Uished by: s Date s Time eed ain good condit.i) l y:

A(Z21

/,

/S/ 0 F o r a$

ef+

SAI 14.Relinquished by:

Date Time Received in good condition by:

RM-72.doc

I RM-72 SAMPLE CHAIN-OF-CUSTODY Revision 0 Page 4of 5 tUj F3 W

O-6C 4 I RM-72-1 CHAIN-OF-CUSTODY RECORD Sample Number Sampling Location Date Time Final Disposition of Sample 2 I (to d

1zeA*

0 13 ceAS 9!4~ 4 CB 60@qY3

--)

12O_ =

5

C

~~.91!5X~

C2.3g.z ljoo 1___5 Gc:-kalZI Z2.7 L3.4)

IO

/ J (Samples may be analyzed and stored, shipped for offsite evaluation or analyzed and disposed of.)

11 8&ciiv~din.good cniticg by:

10&

ZOC

=

. -97 RM-72.doc

RM-78 FINAL STATUS SURVEY ASSESSMENT Revision 1 Page 19 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 1 of 8 FINAL. STATUS SURVEY:

1.0 DATA VERIFICATION 1.1 Data Acceptance

,/_ Review the Implementation Checklist (RM-77-1) to verify that survey isolation and control measures were executed prior to FSS and are being maintained.

a</

Review RM-77, Final Status Survey Implementation, to verify that methods, techniques, and survey activities required for FSS have been applied in accordance with the appropriate procedures.

1.2 Field QC Records:

Review all assessments, Condition Reports and audits to ensure that identified issues have been resolved.

Comments:

L/

V/

1.3

/ /_

I-_

Verify scan instrumentation was in calibration and the QC source checks were performed prior to and after surveys.

Verify daily QC source checks for Canberra gamma spectroscopy detector properly logged prior to soil sample analysis.

Review Verification:

Verify that the Data Quality Objectives are complete.

Verify that the survey design has been technically reviewed.

RM-78.doc

RM-78 FINAL STATUS SURVEY ASSESSMENT Revision 1 Page 20 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 2 of 8 Verify that gamma spectroscopy results have received a technical review.

Verify the Sample and Analysis Report (RM-59-1) is completed and reviewed.

I/A,

,/,,

Data Verification Completed:

Comments (P

No G7 Assessor c? r2Z -05' Date RM-78.doc

RM-78 Revision 1 FINAL STATUS SURVEY ASSESSMENT Page 21 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 3 of 8 2.0 DATA VALIDATION 2.1 Documentation Review:

Perform documentation review for quality control purposes and validate the data collected is complete and appropriate for use as defined by the survey design. Documentation includes:

V' Field measurement records

/7 Chain-of-custody 77 Quality Control (QC) measurement records

,/~

Current qualification of survey personnel

./

Corrective Action Reports

/

Data inputs (laboratory spectroscopy)

V Sample preparation techniques 2.2 Detection Limit Review:

,/

Scan MDCs are below established site DCGLs.

/..z Forced-count values are assigned as necessary when activity is not detected in a sample.

/

Minimum Detectable Concentration (MDC) values of gamma spectroscopy are below established DCGLs.

2.3 Quality Control (QC) Data Review:

/

Quality Control (QC) data results have received required reviews and are complete and consistent.

Results of judgmental samples have been reviewed and evaluated.

7/

Review to ensure that the analytical results of judgmental samples do not impact the evaluation for unrestricted release of the survey area.

RM-78.doc

RM-78 FINAL STATUS SURVEY ASSESSMENT Revision 1 Page 22 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 4 of 8 2.4 Qualification of Data:

Statistical radionuclide-specific measurements for completeness. Evaluae the survey for determination of data usability and confirm that sufficient qualified data are present for the decision process.

a.

Total number of statistical samples planned for the survey:

if

b.

Total number of statistical samples determined as valid:

/L

c.

Calculate % Completeness:

b x120 =

a

,/

Qualified data are 2100% completeness and are sufficient to support the Sign Test requirement for determination of unrestricted release.

Data 'Validation Completed:

e No Comments:

eAssessor Date RM-7'8.doc

RM-78 Revision 1 FINAL STATUS SURVEY ASSESSMENT Page 23 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 5 of 8 3.0 DATA QUALITY ASSESSMENT 3.1 Review the DQOs and Survey Design:

7' Confirm that all inputs to the decision have been reviewed and are complete.

,/

Verify that boundaries or constraints identified in the survey area have not affected the quality of the data.

Review the Statement of Hypothesis and confirm that it remains relevant.

,/

Confirm that Type I and Type II error limits are consistent with DQOs.

/

Confirm that the survey design is consistent with DQOs and that the appropriate number of data points were obtained.

3.2 Preliminary Review:

3.2.1 Preliminary Evaluation:

A/

Quality Assessment (QA) reports consistent with procedure RM-79, Final Status Survey Quality Control.

,/

Survey is of sufficient intensity to satisfy classification requirement.

,/

Potential trends of radioactivity levels in the survey area do not impact a decision for unrestricted release.

Comments:

RM-78.doc

RM-78 Revision 1 FINAL STATUS SURVEY ASSESSMENT Page 24 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 6 of 8 3.2.2 Calculate Basic Statistical Quantities:

a.

Number of qualified data points

b.

Calculation of the Mean

a.

oc) XS

c.

Calculation of the Median

. o)G

d.

Calculation Standard Deviation C.

t 0

)

IA Attach graphic representation of the data if any radionuclide-specific measurements exceed 50% of the DCGL.

Sample QA/QC measurements consistent with FSS data 3.3 Statistical Evaluation:

NOTE:

If all measurement data are less than the DCGLw, statistical testing in not required and the survey unit meets the regulatory requirement for unrestricted release.

X'AII survey measurements are below the DCGLw.

3.3.1 Verify Assumptions of the Statistical Test JJAA Review the posting plot to verify that the if data exhibits spatial independence. Spatial trends must be investigated and resolved prior to further assessment.

.. L Review to verify dispersion symmetry. The appearance of skewed data must be investigated for cause and documented prior to further assessment.

RM-7,8.doc

NOENERMEE RM-78 Revision 1 FINAL STATUS SURVEY ASSESSMENT Page 25 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 7of8 K) A~ Review the dataset standard deviation and range for data variance.

Questionable data must be investigated for cause and documented prior to further assessment.

Compare the prospective power curve with the retrospective power curve. Verify that the data exhibits adequate power and confirm that the sample size is sufficient to satisfy the DQOs.

3.4 Draw Conclusions from the Data:

3.4.1 Investigation Levels and Response Actions 7' Determine if data results have exceeded any investigation level.

Document findings.

A<

JfJ, aj 3.4.2 Evaluation for Unrestricted Release Select applicable conclusion:

t-/Survey area acceptance criteria met and survey area satisfies the requirements for unrestricted release:

I/

All concentrations are less than the DCGLW The Null Hypothesis is rejected.

/IA The mean concentration of the survey area is below the DCGLW but individual measurements in the survey unit exceed the DCGLw. The Sign Test and EMC evaluation are successful and the Null Hypothesis is rejected.

RM-78.doc

ALWR RM-78 FINAL STATUS SURVEY ASSESSMENT Revision 1 Page 26 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 8 of 8

\\J/q Survey area acceptance criteria not met and survey area fails to satisfy the requirements for unrestricted release:

AJ-The mean concentration in the survey area exceeds the DCGLw. and the null hypothesis is confirmed.

ALA The mean concentration of the survey area is below the DCGLW but individual measurements in the Unit exceed the DCGLW..

The Sign Test and EMC evaluation are unsuccessful and the null hypothesis is confirmed.

Data Ouality Assessment Completed:

Yes No Comments 1

-m 1 A i / ( ~ ~ 7 f ~

I4~

/

Assessor Reviews:

/

Technical Bv w ES Su"perintendent RP&ES Manager 02_Date Date Date I 13 /D 2

Date

/- Salmon Date RM-78.doc

RM 78-3, Attachment I Statistical Quantities Release Record East TBCq 1I Base Elevation Turbine Building Excavation Area Results*

Statitical Calculations Sample Cs-137 Co-60 Weighted Sum Wt Sum <

DCGLw -

Number (pCi/g)

(pCi/g)

(SOR)

DCGLw? **

Wt Sum Sign 1

-0.0003 0.0033 0.0010 yes 0.9990

+1 2

0.0022 0.0330 0.0105 yes 0.9895

+1 3

0.0239 0.0411 0.0148 yes 0.9852

+1 4

0.0144

-0.0407

-0.0115 yes 0.9885

+1 5

0.0307 0.0080 0.0051 yes 0.9949

+ 1 6

0.0331

-0.0050 0.0012 yes 0.9988

+1 7

-0.0322

-0.0362

-0.0140 yes 0.9860

+1 8

-0.0144 0.0279 0.0075 yes 0.9925

+1 9

0.0221 0.0126 0.0058 yes 0.9942

+1 10

-0.0006

-0.0060

-0.0019 yes 0.9981

+I 11

-0.0161

-0.0225

-0.0084 yes 0.9916

+1 12 0.0195 0.0085 0.0043 yes 0.9957

+1 13 0.0453 0.0301 0.0132 yes 0.9868

+1

=14 0.0310 0.0339 0.0132 yes 0.9868 15 0.0071 0.0022 0.0013 yes 0.9987

+1 16

-0.0002 0.0316 0.0098 yes 0.9902

+1

=17 0.2399 0.0069 0.0223 yes 0.9777

+1 1 8 0.0803 0.0615 0.0259 yes 0.9741

+1 _

iK)

Mean:

Std. Dev.:

Median:

Maximum:

0.0270 0.0590 0.0170 0.2399 0.0106 0.0269 0.0083 0.0615 0.0056 0.0106 0.0054 0.0259 Number of Positive Differences (S+):

n/a Critical Value, k, Table 1.3 of Marssim:

n/a S+ > than k?:

n/a Survey Unit Pass or Fail:

PASS

'Note. Forced-Count values are used for samples with activity levels below the MDA.

-*Note: If all measurement data are less than the DCGL W, the Sign Test is not required.

RM-79 FINAL STATUS SURVEY QUALITY CONTROL Revision 1 Page 12 of 13 RM-79-1 FSS QUALITY CONTROL EVALUATION RESULTS FSS Package #

-#4TBCi, I I

QC Package # A'l _T61 QC Measurement Type Acceptance Criteria Met*?

Reference v_

1.

Replicate Scan Ge)/ No Step 5.1.3

2. Sample Recounts Step 5.1.4.1
a. In-house (s

No

/I

b. Third party Yes / No
3. Split Samples Step 5.1.4.2
c. In-house e

No

d. Third party Yes / No
  • NOTE:

If Acceptance Criteria is not met, completion of Attachment RM-79-2, FSS Quality Control Investigation Results, is required.

Comments:

OPIL

-41OL4 i I. I-L 5.

.2'a aa-ztc'

-a 5 I-,ot&

Reviews:

AX i

// I 7-C/.7-Cd¶ Ftvaluator 1

.i Date I 7 nical keview--

Date RM-79.doc

IC QA Verification Worksheet In-House Sample Recounts Release Record East TBC. 41 Base Elevation Turbine Building Excavation Area C

Date:

9120/05 QA Package:

East TBC, 11 Turbine Building Excavation Area f§918 ii NRC 84750 Criteria Resolution Ratio

<4 NMA 4-7 0.5-2.0 8-15 0.6-1.66 16-50 0.75-1.33 51-200 0.8-1.25

>200 0.85-1.18 QA Type:

Sample Recounts Lab:

In-House A

B C

D E

F G

BRP BRP BRP BRP Recount Recount Ratio Resolution Rato Resuets in SapePat Rsl1eut

-sigma Resolution Results Results Ratio (Compare C Ratio 1)(Cmpreemn No.

Nuclide Below l (pCig)

(pCg)A/B Below AID 1

(Table 1)

(Compare 8

Co-60 0.0704 n/a n/a 0.0619 1.1373

<4 n/a YES 8

Cs-1 37 0.0386 n/a n/a 0.0440 0.8773

<4 n/a YES 12 Co-60 0.0658 n/a n/a 0.0668 0.9850

<4 n/a YES 12 Cs-137 0.0526 n/a n/a 0.0368 1.4293

<4 n/a YES Indicates results less than the MDA; recorded resutts are MDA values.

'Note: Alt analyses comparisons not in agreement must be investigated per RM-79.

r QA Verification Worksheet In-House Split Sample Comparison Release Record East TBCq11 Base Elevation Turbine Building Excavation Area r

Date:

9120105 QA Package:

East TBC,41 Turbine Building Excavation Area QA Type:

Split Sample Lab:

In-House TObl I1 NRC 84750 Criteria Resolution Ratio

<4 N/A 4-7 0.5-2.0 8-15 0.6-1.66 16-50 0.75-1.33 51-200 0.8-1.25

>200 0.85-1.18 A

B C

D E

F G

< indicates results less than the MDA; recorded results are MDA values

'Note: Al/ analyses comparisons not in agreement must be investigated per RM-79.

Tritium in Soil Release Record East TBCQ1I Base Elevation Turbine Building Excavation Area Sample Tritium in Soil Number pCi/g 7

0.366 8

0.839 12 0.373 Mean:

Median:

St. Dev:

0.526 0.373 0.271 Note: The DCGL for Tritium is 327 pCi/g.

Sample results are less than 0.3% of the DCGL

GENERAL ENGINEERING LABORATORIES, LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com Certificate of Analysis Report for for ROCK001 Big Rock Nuclear Facility Client SDG: 146545 GEL Work Order: 146545 Lab Sample ID 146545001 146545002 146545003 146545004 146545005 146545006 Sample(s) Contained within this report:

Client Sample ID Sample Description East TBC Ql 1 #7 N/A EastTBC Q1 #8 N/A East TBC Q11 #12 N/A East TBC Q11 #7 N/A East TBC Q1I #8 N/A East TBC Q1 I #12 N/A Collected 09t20t2005 12:00 09/20/2005 12:00 09/20/2005 1!2:00 09/20/2005 1!2:00 09/20/2005 1'2:00 09/20/2005 12:00 Where the analytical method has been performed under NELAP certification, the analysis has met all of the requirements of the NELAC standard unless qualified on the Certificate of Analysis.

This data report has been prepared and reviewed in accordance with General Engineering Laboratories, LLC standard operating procedures. Please direct any questions to your Project Manager, Cheryl Jones.

Y Reviewed by Page 1 of 9

GENERAL ENGINEERING LABORATORIES, LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com 10 CFR Part 50/61 Certificate of Analysis GEL Sample ID:

146545001 Client Sample ID:

East TBC QI #7 Matrix:

Soil Amount of Sample Received:

Client: Big Rock Nuclear Facility Collect Date: September 20, 2005 Receive Date: September 27, 2005 Report Date: October 11,2005 Aliouot 2

l Analyte (g)

Run Date Activity Uncertainty MDA RL Units Qualifier

-........................................................................................................................................ I............ I.............................................

H-3 8.27E+02 10/07/05 5.78E+03 3.02E+02 2.74E+02 5.00E+02 pCi/L 3

Note(s):1i Calculated MDAs are a-posteriori values.

2. Activity concentration net +/- 2 sigma overall on reference date.
3. Results ate statistically positive at the 99.9% confidence level (activity is greater than three times the one sigma uncertainty)

H Analytical holding time exceeded.

Page 2 of 9

GENERAL ENGINEERING LABORATORIES, LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com 10 CFR Part 50/61 Certificate of Analysis GEL Sample ID:

Client Sample ID:

Matrix:

Amount of Sample Received:

146545002 East TBC Q1l #8 Soil Client: Big Rock Nuclear Facility Collect Date: September 20, 2005 Receive Date: September 27, 2005 Report Date: October 11,2005 Aliquot 2

1 Analyte (g)

Run Date Activity Uncertainty MDA RL Units Qualifier H-3 8.06E+02 10/07/05 1.21E+04 4.OOE+02 2.68E+02 5.OOE+02 pCi/L 3

Note(s):1. Calculated MDAs are a-posteriori values.

2. Activity concentration net +1-2 sigma overall on reference date.
3. Results a re statistically positive at the 99.9% confidence level (activity is greater than three times the one sigma uncertainty)

H Analytical holding time exceeded.

Page 3 of 9

GENERAL ENGINEERING LABORATORIES, LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com 10 CFR Part 50/61 Certificate of Analysis z

GEL Sample ID:

Client Sample ID:

Matrix:

Amount of Sample Received:

146545003 East TBC Q11 #12 Soil Client: Big Rock Nuclear Facility Collect Date: September 20,2005 Receive Date: September 27,2005 Report Date: October 11, 2005 Aliquot 2

1 Analyte

(. )

Run Date Activity Uncertainty MDA RL Units Qualifier

.......... I.....................................

........ I........... -....

....... I... I.... -....................................

H-3 8.47E+02 10/07/05 5.76E+03 3.03E+02 2.76E+02 5.OOE+02 pCi/L 3

..............I.........I.....

-...... I...........................

Note(s):1. Calculated MDAs are a-posteriori values.

2. Activity concentration net +/- 2 sigma overall on reference date.
3. Results are statistically positive at the 99.9% confidence level (activity is greater than three times the one sigma uncertainty)

H Analytical holding time exceeded.

Page 4 of 9

GENERAL ENGINEERING LABORATORIES, LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com 10 CFR Part 50/61 Certificate of Analysis 4k.

J GEL Sample ID:

Client Sample ID:

Matrix:

Amount of Sample Received:

146545004 East TBC Q1l #7 Soil Client: Big Rock Nuclear Facility Collect Date: September 20,2005 Receive Date: September 27,2005 Report Date: October 11,2005 Aliquot (L) 2 Run Date Activity Uncertainty MDA Analyte

.............. I....................

RL Units Qualifier

......................................................................................... A.................................................................. I............................................ -......................... _ I..

H-3 Moisture I.OOE-02 10/07/05 09/28/05 3.66E-01 1.91E-02 1.73E-02 6.OOE+00 pCi/g 6.30E+00 percent 3

H Note(s):1. Calculated MDAs are a-posteriori values.

2. Activity concentration net +/- 2 sigma overall on reference date.
3. Results.are statistically positive at the 99.9% confidence level (activity is greater than three times the one sigma uncertainty)

H Analytical holding time exceeded.

Page 5 of 9

GENERAL ENGINEERING LABORATORIES, LLC 2040 Savage Road Charleston SC 29407- (843) 556-8171 - www.gel.com 10 CFR Part 50/61 Certificate of Analysis Uk GEL Sample ID:

Client Sample ID:

Matrix:

Amount of Sample Received:

146545005 East TBC Q11 #8 Soil Client: Big Rock Nuclear Facility Collect Date: September 20,2005 Receive Date: September 27,2005 Report Date: October 11, 2005 Aliquot 2

l Anallyte (L)

Run Date Activity Uncertainty MDA RL Units Qualifier H-3 Moisture I.OOE-02 10/07/05 09/28/05 8.39E-01 2.76E-02 1.85E-02 6.00E+00 pCi/g 7.25E+00 percent 3

H Note(s):1. Calculated MDAs are a-posteriori values.

2. Activity concentration net +/- 2 sigma overall on reference date.
3. Results are statistically positive at the 99.9 % confidence level (activity is greater than three times the one sigma uncertainty)

H Analytical holding time exceeded.

Page 6 of 9

GENERAL ENGINEERING LABORATORIES, LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com 10 CFR Part 50/61 Certificate of Analysis 2j GEL Sample ID:

Client Sample ID:

Matrix:

Amount of Sample Received:

146545006 East TBC Q11 #12 Soil Client: Big Rock Nuclear Facility Collect Date: September 20, 2005 Receive Date: September 27, 2005 Report Date: October 11, 2005 Aliquot 2

Analyte (L)

Run Date Activity Uncertainty MDA

.......................................................I................. -................. I.............

I RL Units Qualifier

.1............................................. I..........................

H-3 Moisture I.OOE-02 10/07/05 09/28/05 3.73E-01 1.96E-02 1.79E-02 6.OOE+00 pCi/g 6.26E+O0 percent 3

H

........................................................................ I............................................... :........................................................................

Note(s):1. Calculated MDAs are a-posteriori values.

2. Activity concentration net +/- 2 sigma overall on reference date.
3. Results are statistically positive at the 99.9% confidence level (activity is greater than three times the one sigma uncertainty)

H Analytical holding time exceeded.

Page 7 of 9

GENERAL ENGINEERING LABORATORIES, LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com QC Summary Big Rock Nuclear Facility 10269 US 31 North Charlevoix, Michigan

Contact:

Mr. Chuck Barsy Workorder:

146-15 Rerort Date: October 11, 200!

Page 1 of 2 Parmname Rad Liquid Scintillation Batch 467482 QC1200947468 146545001 DUP Tritium NOM Sample Oual QC Units RPD%

REC%

Range Anlst Date Time 5780

+/-302 5800

+1-302 pCinL 0

(0%-20%) VIXPI 10/07/05 20:57 QC1200947470 LCS Tritium 7560 6690

+/-312 pCi/L 89 (75%-125%)

10/07/05 23:03 QC1200947467 MB Tritium U

76.4

+1-160 pCi/L.

10/07/05 19:55 QC1200947469 146545001 MS Tritium Batch 467484 QC1200947480 146545004 DUP Tritium QC1200947482 L.CS Tritium 15200 5780

+/-302 22000

+1-522 0.367

+/-0.0191 pCi/L 107 (75%-125%)

10/07105 22:00 10/07/05 20:57 10107/05 23:03 0.366

+1-0.0191 0

(0%-20%) MXP I 89 (75%-125%)

7.56 6.69

+1-0.312 pCilg QC1200947479 MB Tritium U

0.0764

+1-0.160 pci/p 10/07/05 19:55 QC1200947481 14t545004 MS Tritium pCi/p 107 (75%-125%)

0.959 0.366

+/-0.0191 1.39

+/-0.033 10/07/05 22:00 Notes:

The Qualifiers in this report are defined as follows:

Indicates the analyte is a surrogate compound.

B Target analyt: was detected in the sample as well as the associated blank.

BD Results belovw the MDC or low tracer recovery.

E Concentration of the target analyte exceeds the instrument calibration range.

H Analytical hclding time exceeded.

J Indicates an estimated value.

U Target analyte was analyzed for but not detected above the MDL or LOD.

Ul Uncertain identification for gamma spectroscopy.

X Lab-specific qualifier-please see case narrative. data summary package or contact your project manager for details.

d The 2:1 depIction requirement was not met for this sample h

Sample preparation or preservation holding time exceeded.

Page 8 of 9

GENERAL ENGINEERING LABORATORIES, LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 -www.gel.com QC Summary WVorkorder:

146545 Page 2of 2 Parmname NOM_ __ SampleQual

_QC Units RPD%

REC%

Range Anlst Date Time N/A indicates that spike recovery limits do not apply when sample concentration exceeds spike conc. by a factor of 4 or more.

A The Relative Percent Difference (RPD) obtained from the sample duplicate (DUP) is evaluated against the acceptance criteria when the sample is greater than five times (5X) the contract required detection limit (RL). In cases where either the sample or duplicate value is less than 5X the RL, a control limit of +1-the RL is used to e valuate the DUP result.

For PS, PSD, and SDII.T results, the values listed are the measured amounts, not final concentrations.

Where the analytical method has been performed under NELAP certification, the analysis has met all of the requirements of the NELAC standard unless qualified on the QC Summary.

Page 9 of 9

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RM-72-2 CHAIN-OF-CUSTODY RECORD FOR SAMPLES SHIPPED OFF-SITE Sample Number Sampling Location Date Time Final Disposition of Sanmple

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Date Time Received in good conditi~n by:

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RETURN THIS FORM WITH ANA'LYSIS RESULTS TO:

CHARACTERIZATION SUPERVISOR CONSUMERS ENERGY BIG ROCK POINT 10269 U.S. 31 NORTH CHARLEVOIX, MICHIGAN 49720 RM-72.doc

Page: _

of General Engineering Laboratories, LLC Project #:

2040 Savage Road GEL Quote :

GEL Chain of Custody and Analytical Request Charleston, SC 29407 COCNumber '

Phone: (843) 556-8171 P0 Number:

Fax: (843) 766-1178 Tnlame:

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Phone#: Z 31,

Sample Analysis Requested (Fill in the number of containers for each test)

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  • N -for samnple was not field filtered.

4.) Marrix Codes: DW - Drinking Water, GW - Groundwater, SW

  • Surface Water, WW = Waste Water, W = Water, SO
  • Soil, SD - Seditrtnt, SL
  • Sludge, SS Solid Waste. 0-Oil. F - Filter, P. Wipe, U - Urine, F.

Fecal, N

  • Nasal 5.) Samnple Analysis Requested: Analytical mnthod requested (i.e. 8260B. 601OBJ7470A) and nuniber of containers provided for each (i.e. 8260B -13. 6l10/7470CA 1).

6.) Preservative7 } IA - Hydrochloric Acid, NI-Niric Acid,SH *SodiurnHydroxide.

SA - Sulfuric Acid, AA

  • Ascorbic Acid, HX - -kxane, ST. SodiuinThiosulfase. If iopreservaiive is added-Ilave fieldblank WHITE = LABORATORY YELLOW = F.

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LUNITED STATES L

tOCH-haLed NUCLEAR REGULATORY COMMISSION (hD REGION III 2443 WARRENVILLE ROAD, SUITE 210 0 LISLE, ILLINOIS 60532-4352 Novarber 219' 2005 Mr. Ku; I M. Haas General Manager Big Rock Point Nuclear Plant Consumers Energy Company 10269 U.S. 31 North Charlevoix, MI 49720

SUBJECT:

BIG ROCK POINT INSPECTION REPORT 050-00155/05-004(DNMS)

Dear Vr. Haas:

On November 10, 2005, the NRC completed inspection activities at the Big Rock Point Nuclear Plant. The purpose of the inspection was to determine whether decommissioning activities were conducted safely and in accordance with NRC requirements. Specifically, during on-site inspections on August 22 through 25, and September 19 through 21, 2005, the inspector evaluated decommissioning and demolition activities, management oversight of decommissioning activities, radioactive waste management, final status surveys, and radiological safety. At the conclusion of on-site inspections on August 25 and September 21, 2005, the inspector discussed the inspection findings with you and members of your staff. On Ad November 10, 2005, the inspector completed an in-office review of laboratory analysis results for soil samples collected during the September 19 through 21 inspection. The inspector conducted a telephone exit interview with members of your staff on November 10, 2005, to discuss the results of the in-office review of the laboratory results.

This inspection consisted of an examination of decommissioning activities at the Big Rock Point Nuclear Plant as they relate to safety and compliance with the Commission's rules and regulations. Areas examined during the inspection are identified in the enclosed report. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations of activities in progress, and interviews with personnel.

Based on the results of this inspection, the NRC did not identify any violations.

In acco dance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). The NRC's document system is accessible from the NRC Web site at http: lwww.nrc.gov/readinp-rm/adams.html.

K. Haas We will gladly discuss any questions you may have regarding this inspection.

Sincerely, Jamnes L. Cameron, Chief Decommissioning Branch Docket No.:

License No.:

Enclosure:

050-00155 DPR-6 Inspection Report 050-00155/05-004(DNMS) cc w/encl:

R. A. Fenech, Senior Vice President, Nuclear, Fossil, and Hydro Operations John King, Michigan Public Service Commission L. Shekter Smith, Michigan Department of Environmental Quality Chief, Nuclear Facilities Unit, Michigan Department of Environmental Quality Department of Attorney General (Ml)

Emergency Management Division, Michigan Department of State Police

U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket No.:

License No.:

Report No.:

Licensee:

Facility:

Location:

Dates:

Inspector:

Approved by:

050-00155 DPR-6 050-001 55/05-004(DNMS)

Consumers Energy Company Big Rock Point Restoration Project 10269 U.S. 31 North Charlevoix, Ml 49720 August 22 through 25, 2005 (on-site),

September 19 through 21, 2005 (on-site), and November 10, 2005 (in-office)

William G. Snell, Senior Health Physicist Jamnes L. Cameron, Chief Decommissioning Branch, Division of Nuclear Materials Safety

EXECUTIVE

SUMMARY

Consumers Energy Company Big Rock Point Restoration Project NRC Inspection Report 050-001 55105-004(DNMS)

This routine decommissioning inspection involved a review of the Consumers Energy Company's and its contractors' performance related to decommissioning and demolition activities;, management oversight of decommissioning activities, radioactive waste management, inspection of final status surveys, and radiological safety. During this inspection period, major activities included demolition, decontamination, and scabbling of concrete surfaces inside containment and at the radwaste vaults, and final status surveys of the location of the fcrmer turbine, service and administration buildings.

Organiz:ation, Management and Cost Controls The inspector determined that the licensee was actively pursuing ways to maintain the restoration project on schedule while minimizing costs. (Section 1.0)

Decommissioning Performance and Status Review The inspector determined that the licensee was effective in ensuring that management's expectations for work performance were being communicated to the workforce.

Although a considerable amount of work was being performed, the workforce was working safely and in accordance with license requirements. (Section 2.0)

Maintenance and Surveillance The licensee was doing an adequate job of preparing the containment building for the sphere dismantlement effort. (Section 3.0)

Occupational Radiation Exposure The inspector concluded that the radiological work practices of the licensee and contractor staff were adequate. (Section 4.0)

Inspection of Final Surveys Residual radioactive contamination in the turbine building excavation area was less than the licensee's unrestricted release limit of 5 picocuries per gram (pCi/g) as described in the approved License Termination Plan. The licensee's radioanalytical capability to determine residual radioactivity in soil samples was adequate. (Section 5.0)

Solid Radioactive Waste Management and Transportation The inspector determined that the licensee adequately controlled and stored radioactive waste in the radwaste building and radwaste yard. (Section 6.0) 2

Report Details' 1.0 Organization, Management and Cost Controls (36801) 1.1 Inspection Scope The inspector evaluated the licensee's decommissioning planning, scheduling, and cost expenditure.

1.2 Observations and Findings The licensee determined that the decline in background radiation levels in the containment building had slowed appreciably even though scabbing and other remediation activities were continuing. This was because most of the high dose areas

-'had already been remediated or shielded, and the ongoing removal of surface material containing low levels of contamination was having a minimal impact on lowering the overall background radiation level. Because the background was remaining higher than expected, the licensee was unable to conduct adequate scanning to verify that building surfaces were remediated to less than 5000 disintegrations per minute (dpm) per 1 00 square centimeters (cm2) that was required by the License Termination Plan (LTP).

Since material verified as less than 5000 dpm/1 00 cm2 could potentially be disposed of in a local landfill, the inability to conduct the verification meant concrete and debris would have to be disposed of as radioactive waste at a considerably higher cost. This has left the licensee with the option either to continuing to work to reduce the background, or disposing of the containment building concrete and other debris as radioactive waste. To continue to remediate to lower the background levels could delay the dismantlement of the containment structure and extend the site restoration effort by several months or longer, which would add to the cost of the project. However, disposing of the concrete and debris as radioactive waste would also increase the cost of the project. While both options will add millions of dollars in costs to the restoration project, at the time of the on-site inspections the licensee was moving toward the oDtion of shipping the concrete and debris as radioactive waste. This would maintain the current schedule for completing the restoration project by late 2006. The licensee also indicated to the inspector that the LTP would have to be revised to reflect any change in the decommissioning planning and scheduling.

1.3 Conclusion The inspector determined that the licensee was actively pursuing ways to maintain the restoration project on schedule while minimizing costs.

2.0 Decommissioning Performance and Status Review (71801) 2.1 Inspection Scone The inspector attended and observed the conduct of licensee meetings regarding decommissioning activities, including daily management team meetings. The inspector 1A list of acronyms used in the report is included at the end of the Report Details.

3

performed plant tours to assess field conditions and decommissioning activities, and to verify that the licensee and its contracted workforce conducted work safely and in accordance with license requirements, and that radioactively contaminated material was controlled.

2.2 Observations and Findings

  • rhe inspector observed that licensee management representatives routinely toured the site to observe work and evaluate progress. Observations from these tours were discussed during the daily morning management meetings to ensure that expectations were being communicated to the work force and that managers and workers were focused on the same issues and concerns.

'During site tours, the inspector observed licensee staff conducting decontamination of structural surfaces, demolition activities, and radiological surveys. The inspector noted that even though there was a significant amount of work being conducted by numerous work crews, the workers were attentive to other work being performed nearby.

2.3 Conclusion The inspector determined that the licensee was effective in ensuring that managerrient's expectations for work performance were being communicated to the workforce.

Although a considerable amount of work was being performed, the workforce was working safely and in accordance with license requirements.

3.0 Maintenance and Surveillance (62801) 3.1 Inspection Scope The inspector walked down areas of the containment building to assess the material condition of the facility and equipment.

3.2 Observations and Findings The licensee's work force was focused on scabbling, jack-hammering, and completing the remediation of surface contamination in preparation for the sphere dismantlement.

Additional efforts were under way to remove scaffolding, equipment and other materials.

The licensee's goal was to complete all remediation activities in the containment building by late September so that the containment could be readied to start removing the sphere in mid-October. During the sphere removal no workers will be allowed inside the containment building. The inspector observed that a significant amount of material had

  • been and was being removed from the containment building.

3.3 Conclusion The licensee was doing an adequate job of preparing the containment building for the sphere dismantlement effort.

4

NIMMEMOMMMEN 4.0. Occupational Radiation Exposure (83750)

O 4.1 Inspection Scope The inspector evaluated the radiological work practices of licensee and contractor staff who conducted decommissioning activities.

4.2 Observations and Findings During tours of the site, the inspector observed that workers adhered to proper radiological work practices while conducting decommissioning activities. Personnel were observed adhering to radiological boundaries, properly exiting contamination areas, wearing appropriate personal protective clothing for the work being conducted, and wearing dosimetry as required.

4.3 Conclusion The inspector concluded that the radiological work practices of the licensee and contractor staff were adequate.

5.0 Final Status Survey (83801) 5.1 Inspection ScoDe Independent radiological confirmatory surveys were conducted of the turbine building excavation area. Analyses were performed on radiologically contaminated soil samples provided by the licensee to assess the adequacy of the licensee's radioanalytical capability.

5.2 Observations and Findings The Oak Ridge Institute for Science and Education (ORISE) conducted independent in-process confirmatory surveys for the NRC of the turbine building excavation area.

The surveys included a 90 percent surface scan of the area using sodium iodide (Nal) scintillation detectors and the collection of five surface soil samples. Following the on-site inspection the licensee provided ORISE with three additional soil samples for an inter-laboratory comparison. These three samples contained detectable levels of radiological contamination. The eight soil samples were analyzed by ORISE for tritium (hydrogen-3), cobalt-60, cesium-1 37, europium-1 52, europium-1 54, europium-1 55 and manganese-54.

The soil surface scanning identified no areas of radiological contamination in excess of background levels. The ORISE analysis of the five soil samples collected during the inspection identified no contamination in excess of the licensee's unrestricted release limit of 5 picocuries per gram (pCi/g) as described in the licensee's License Termination Plan.

5

a The analytical results of the three surface soil samples that were provided by the license to verify the adequacy of the licensee's radiological counting capability compared acceptably with ORISE's analysis of the samples. The results of the ORISE analyses are publicly available through NRC's Agencywide Documents Access and Management System (ADAMS) under Accession No. ML053220613.

5.3 Conclusion Residual radioactive contamination in the turbine building excavation area was less than the licensee's unrestricted release limit of 5 picocuries per gram (pCi/g) as described in the approved License Termination Plan. The licensee's radioanalytical capability to determine residual radioactivity in soil samples was adequate.

6.0 Solid Radioactive Waste Management and Transportation (86750) 6.1 Inspection Scope

  • The inspector toured the radwaste yard and radwaste building to verify that radioactive waste stored in those areas was adequately labeled and controlled.

6.2 Observations and Findings Both the radwaste yard and radwaste building contained numerous containers of varying types and sizes. Most of the containers were full or partially full or radioactive waste and were being temporarily stored until they could be shipped off-site for disposal. All the containers examined had legible radiological labeling that was indicative of what was in the container.

6.3 Conclusion The inspector determined that the licensee adequately controlled and stored radioactive waste in the radwaste building and radwaste yard.

7.0 Exit Meeting Summary The inspector presented preliminary inspection findings to members of the licensee management team at the conclusion of on-site inspection activities on August 25 and September 21, 2005. An additional telephone exit meeting was conducted on November 10, 2005, to provide the licensee with the results of the radiological analysis of soil samples collected during the on-site inspection conducted on September 19 through 21, 2005. The licensee acknowledged the findings presented. The licensee did not identify any documents or processes reviewed by the inspector as proprietary.

6

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