ML061030309

Enclosure 4: Big Rock Point Restoration Project, Draft Final Status Survey Report

ML061030309
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	04/25/2006
From:	Consumers Energy
To:	NRC/FSME
Shepherd J
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Ml061030302	List: ML061030309
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Download: ML061030309 (31)

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Big Rock Point Restoi Project Final Status Su Part A - Exca' '.

Consumers Energy Company April 2006 h Tr9 C-~p (fT-D)

DRAFT Big Rock Point Restoration Prcject Final Status Survey Report Table of Contents EXECUTIVE

SUMMARY

1.0 Overview

1.1 Purpose and Scope

1.2 Description of Survey Areas 1.3 Site Release Criteria 1.3.1 Application of Site Release Criteria 1.3.2 Derived Concentration Guideline s 1.3.3 Tritium in Soils 1.4 Discussion of Changes to the Fin tus Survey Plan 2.0 Final Status Survey Methodolog 2.1 Survey Units 2.1.1 Classification 2.1.2 Surveyl _

2.1.3 Survey ome ature 2.2 Instue 2.2.2o 2.2.2 ^r nt q° S 2.2. 3 MDet re Cce ntration 2.3 Survey Metho 2.3.1 Scan Mea mnts 2.3.2 Volumetric Measurements 2.4 Survey Performance 2.4.1 Procedures 2.4.2 Training 2.4.3 Sample Handling 2.4.4 Data Investigation 2.4.5 Data Management 2.4.6 Quality Control Measurements 2.4.7 Control of Vendor Services 3.0 Final Status Survey Results 3.1 Open Land Area Surface Surveys

DRAFT Big Rock Point Restoration Project Final Status Survey Report 3.1.1 Class 1 Survey Units 3.1.2 Class 2 Survey Units 3.1.3 Class 3 Survey Units 3.2 Supporting Surveys 3.2.1 Excavated Surface Surveys 3.2.2 Relocated Soil Surveys 3.3 Groundwater Surveys 3.4 Investigations 4.0 Final Status Survey Data Assessment 4.1 Data Verification and Validation 4.2 Summary of Changes from Initial suptioron Resd dioactivity 4.3 Release Criteria Verificatio n 5.0 Final Status Survey Conclusion Re u 6.0 References Appendices Appendix A - Summa a Surve nits Appendix B - Final Surve i on Process Appendix C - Final Survey Pa ge Release Records Appendix C-1 Class I Surveys Appendix C-2 Class 2 Surveys Appendix C-3 Class 3 Surveys Appendix C4 Excavated Surface Surveys Appendix C-5 Summary of Relocated Soil Surveys List of Tables List of Figures

DRWiFT Big Rock Point Restoration Project Final Status Survey Report EXECUTIVE

SUMMARY

Consumers Energy Company has decommissioned Big Rock Point Nuclear Plant to a Greenfield condition as defined in the approved Big Rock Point License Termination Plan (LTFP) [Reference 1]. The final Greenfield condition of the site involved removal of all site buildings, foundations, buried piping, utilities and asphalt surfaces inside the Industrial Area. Office and storage buildings and underground utilities (conduit, storm drains, domestic piping, etc) outside the Industrial Area were also removed. Since no building structures supporting the former operating facility remain on site, final status surveys of the site consist of open land areas at final grade and also supporting surveys of excavated surfaces, relocated excavated soils.

Big iRock Point Final Status Survey Report - Part A the results for surveys of excavated surfaces and relocated excavated soil ducte or to 2006 at the site of the ibrmer Big Rock Point Nuclear Plant. All fi atus surve s defined in the LTP, are scheduled for completion in November 20 fter all demolit ctivities are complete. The Final Status Survey Report con of he parts atlined below to facilitate timely review of survey data prt Qto unre 6 release of si land areas encompassing impacted and non-impac d aresociated with the former nuclear plant site.

The table below provides a s Survey Report survey data.

Submittal ' Target Date PartAA April 2006 Part B Class : July 2006 Part C Class 1, 2,3 Wd Areas, Excavated December 2006 surrace and Relocated Soils es All Final Status Surveys and supporting surveys were performed in accordance with the final status survey plan described in Chapter 5 of the LTP. The site land areas were divided into 34 final surface survey units, encompassing approximately 475 acres (1.92 square kin) of land area, and classified according to their potential for containing residual radioactivity. Ninet'een final surface survey units are classified as Class 1; et final surface survey units as Class 2, and seven final surface areas as Class 3. Additionally, supporting survey data for excavated surfaces and relocated soils are also presented in this report.

Survey data were collected from each survey unit according to data collection patterns and frequencies established for each classification. The final status survey data demonstrate that each survey unit meets the radiological criteria supporting release for unrestricted use as specified in 10 CFR 20.1402. Based on the results of the final status and supporting surveys, Consumers Energy Company concludes that all land areas contained in this report meet requirements for unrestricted use and is suitable for release frorn the 10 CFR 50 license.

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DRAFT Big Rock Point Restoration Project Final Status Survey Report 1.0 OVERVIEW 1.1. Purpose and Scope This report provides information required by 10 CFR 50.82(a)(1 1), which demonstrates that Big Rock Point land areas meet the radiological criteria for unrestricted use specified in 10 CFR 20.1402. The final Greenfield condition of the site includes demolition and offsite disposal of all site buildings, foundations, subsurface piping components and utilities that supported the former operating facility.

This report also documents that Final Status Surve re performed in accordance with the final status survey process described in ig Rock Point License Termination Plan (LTP). Final Status Surveys ducted on open land areas at final grade elevation. Supporting survey de rehie records for surveys of excavated surfaces upon removal of buil and surveys of naoundationl leriaIs relocated soil designated for backfill up ompl on of de activities.,

1.2. Description of Survey Areas The survey units associated with the al S as Survey Report are shown in Figure 1-1. Appendix A i a de t ind *ualsurvey units and a summary of changes, maidnn since site characterization; all revisions to survey uni ereade in dancwith LTP Section 5.2.2.4.

Final site surv re rts as outlined below:

ss it vated Surface and Relocated Soi urvey conducted 2003 - 2005)

Part B Cl Outlying Land Area Surveys Part C R aining Class 1,2, 3 Land Areas, Part Excavated Surfaces and Relocated Soils Survey data presented for Part A of this report include excavated surfaces where the Turbine Building, Screenhouse and Solid Radwaste Vault foundations were located, the dewatered Discharge Canal, and relocated soil designated as suitable for future onsite backfill material. All excavated surface surveys were designed and conducted to meet the requirements of a Class 1 survey unit. Part B surveys for are comprised of outlying Class 3 survey units where isolation controls were determined sufficient to allow FSS to be conducted while decommissioning activities were still in progress. Surveys for Part C include all remaining FSS and supporting surveys that could not be completed until all or the majority of decommissioning activities were complete.

Excavated surfaces where building foundations were formerly located were prepared for survey by a series of planned decommissioning activities. Planned decommissioning activities include historical site assessment, radiological characterization, dismantlement and demolition, remediation and finally readiness 2

DRAFT Big Rock Point Restoration Project Final Status Survey Report surveys prior to turnover for final status and supporting survey. Appendix B provides a general discussion of decommissioning activity progression.

Relocated soils consist of soil removed for building foundation and subsurface component demolition/removal activities. This soil was evaluated (characterized) and, if suitable, relocated to a designated area for storage and final status evaluation. All relocated soil surveys were conservatively designed and executed lo the requirements specified for Class 1 areas.

Appendix C provides completed release records for FSS and supporting surveys summarized in this report. Information included in completed release records includes FSS design, data verification and validation ta assessment, and conclusion for each survey unit.

1.3. Site Release Criteria The site release criteria applied to each status surve corresponds to the radiological criteria for unrestricted use p Noded 0 CFR and as approved in the BRP LTP. These criteria are:

1. Dose Criterion: The resid dioact, that is distinguishable from background radiation s aT ifective Dose Equivalent (TE n ave ee ber e critical group that does not exc m /yr, iudi r groundwater sources of ditwqand i

2. ALARA43fferionr ctivity has been reduced to leve aa o ea i chievable (ALARA).

1.3 1. Application of the Relea Critea Levels of residual radl iviat correspond to the allowable radiation dose arid ALARA levels of the site s criteria were derived by analysis of various scenarios and pathways (e., direct radiation, inhalation, ingestion) through which exposures could occur. These derived levels, referred to as Derived Concentration Guideline Levels (DCGLs), form the basis for the following four conditions which, when met, satisfy the site release criteria:

1. The average residual radioactivity is equal to or below the DCGL;

2. Individual measurements, representing small areas of residual radioactivity which exceed the DCGL, do not exceed the elevated measurement comparison DCGL;

3. Where one or more individual static measurements exceed the DCGL, the average residual radioactivity passes the statistical Sign Test; and

4. Remediation is performed where it is ALARA to reduce the levels of residual radioactivity below the concentrations necessary to meet the DCGLs.

The manner in which these conditions were met is described in Section 2.0.

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DRAFT Big Rock Point Restoration Project Final Status Survey Report 1.3.2. Derived Concentration Guideline Levels The residual radioactivity concentration levels for surface and subsurface soils in the Industrial Area (Class 1 and Class 2 areas) and outlying Class 3 areas were compared to the site-specific DCGLs developed specifically for volumetric residual radioactivity as provided in the LTP using the unity rule. These site-specific DCGLs are provided in the following table:

Table 1-1. Site-Specific Industrial Area DCGLs Radionuclide 25 mremlyr Limit Open Land Areas (Surface and Subsurface Soils, H-3 3 2 Mn-54 AGUE+ \

Fe-55 3.58 E+05 Co-60 I W .j*0 N6 Sr-90 '~Vff+00 Cs-I137 i, 1.31 154*-

_Eu-

• L %2.87E+02 is ntial contaminat in of soil DCGLs for Cs- and Co pr ted above were modified to account for the presence of hard etect D) n clides, Sr-90 and Fe-55, respectively, using surrogate ratios dev ied f o characterization. The modified Cs-137 DCGL of 11.93 pCi/g accounts TD nuclides.

1.3.3. Tritium in Soils Tritium analyses on 10% of the final status survey samples for survey areas impacted by the tritium plume were required (LTP Section 5.4.2.4). These areas included the Turbine Building, Liquid Radwaste Vault and Containment foundations. Investigation was required for any sample that exceeded 10% of the tritium DCGL (32.7 pCi/g) and complete resampling, with analysis of all soil samples for tritium was required if investigation showed that 50% of the tritium DCGL (164 pCi/g) was exceeded. No soil samples exceeded these investigation levels.

All soil tritium samples were protected from moisture loss in the interval between sampling and analysis and analyzed by an accredited laboratory (LTP Section 5.2.1.3).

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DRAFT Big Rock Point Restoration Project Final Status Survey Report 1.4. Discussion of Changes to the Final Status Survey Plan No changes to the Final Status Survey Plan as approved in Chapter 5 of the LTP were identified during conduct of supporting surveys or final status surveys at the Big Rock Point site. Changes to initial survey area classification were anticipated and are summarized in Appendix A.

2.0 FINAL STATUS SURVEY METHODOLOGY Final Status Surveys were designed and performed as described in the LTP, Chapter 5 and in accordance with NUREG-1 575. The Data Quality Objective (DQC) process was used to ensure that each final status s e was of sufficient quality tco support future unrestricted release of the site pro Land areas were divided into survey units of proper size, which were catego, classified according to the type and potential for residual radioactivity. aacter ton and remediation data were used to design surveys and these s designs reviewed then translated into field instructions for data ection. Instrum ion and survey methods, appropriate to the type of radiati ei easured e used to collect scan, volumetric and supplementa1g easure The measur ments were collected in accordance with site pr res an uality controls instituted to ensure accurate results.

2.1. Survey Units 4 Land areas were., i in34, re uni ased on the physical characteristics, the potential fesi a ond the size of the area with similar potential for reuaadi r i 2.1.1. Classification Survey units were cat s Class 1, Class 2, or Class 3 based on the potential for residual radi ity in accordance wit the methodology in NUREG-1575 and as described in Chapter 5 of the BRP LTP. Areas with residual radioactivity that had the potential to exceed the DCGLs prior to remediation wern divided into Class I survey units. Areas with residual radioactivity that were not expected to exceed the DCGL prior to remediation were divided into Class 2 survey units. Areas with a low probability of containing residual radioactivity detectable above background levels were divided into Class 3 survey units.

Several survey areas were reclassified from their initial classification in the LTP to a more restrictive (more conservative) classification due to decommissioning activities that affected these areas after initial classification.

2.1.2. Survey Unit Size Survey units were sized in accordance with NUREG-1575 guidance and were designed to have relatively simple shapes unless an unusual shape was appropriate for the operational history of the area or as a result of decommissioning activities, i.e., excavation footprints. Class I surface areas and excavation surfaces were sized to maximum 2000 M2. The majority of relocated soil surveys were a maximum of 2000 M2; however, a small number of these surveys exceeded recommended 2000 m2 size. A technical justification for size 5

DRIFT Big Rock Point Restoration Project Final Status Survey Report deviations of Class 1 surveys was provided as part of the completed survey package (see Appendix C). Class 2 survey areas were all less than 10,000 m2 in size. While a maximum size guideline for Class 3 survey units does not exist, the largest Class 3 survey unit at BRP was 256,000 M2.

2.1.3. Survey Unit Nomenclature and Location The nomenclature for identification of final status and supporting surveys is described by the following:

NNTTC Example: 09C0 11 Where:

NN - Unique alphanumeric su entifier TT - Survey type Co - Final surve xcavated (qua surface CQ -Final survey r ted C -Final Stu Surv en land are

- Survey iteration ...

C - Surv lnitial ssi o (or 3)

Survey units a e ifi a ce n established site grid plan. The southwest c rof &are pre identifying B origin of each survey unit.

The site grid coor it eprod cible field locations facilitates survey management a sign, sure curate location of survey measurements, and permits the replica of sure arers for remediation and measurement verification as neces Cl survey unit origin and sample points were also referenced to longitude de.

2.2. Instrumentation Radiation detection and measurement instrumentation for the FSS was selected to provide both reliable operation and adequate sensitivity to detect the radionuclides identified at the site at levels sufficiently below the DCGLs. Site history and characterization efforts identified Cs-1 37 and Co-60 as the predominant radionuclides present in BRP site soils. Soil sampling and analysis have demonstrated that direct measurements of Cs-1 37 and Co-60 can be used as surrogates for estimating levels of other contaminants that may be present in BRP soils. Detector selection was based on detection sensitivity, operating characteristics and expected performance in the field. Portable instruments, laboratory instruments and bulk assay equipment were used to perform FSS measurements. Final Status Survey instrumentation characteristics are provided in Table 2-1.

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DRAFT Big Rock Point Restoration Prcject Final Status Survey Report 2.2.1. Calibration and Maintenance Instrumentation used for the FSSs is calibrated and maintained in accordance with site procedures. Instruments and detectors were calibrated for the radiation types and energies of radionuclides known to be present at the site. Radioactive sources used for calibration are traceable to the National Institute of Standards and Technology (NIST) and have been obtained in standard geometries to match the type of samples being counted.

2.2.2. Instrument Response Instrumentation response checks for field instrumen are conducted daily before and after each use to ensure proper instrument rise and operation.

Laboratory instruments are checked daily in ac §ance with instrument procedures. Source checks use source ene, istent with the nuclides encountered at the BRP site. If an instru ailed onse check, it is appropriately identified and withheld fr se until the lem was corrected in accordance with applicable procedure 2.2.3. Minimum Detectable Concentrati A minimum detectable concentrati ~C wa etermined for each type of instrument and measur etho se su data collection. Instruments used for surface sca Ded g dioactive material at levels below the DCGL.

Laboratory g a8% ctro e used for soil volumetric sample analyses ar able o sid adioa i detection at values less than 5%of the DCGLw us d one-li geometry. The laboratory counting system IaFb has software con I ed cou me ich are set to meet a maximum MDC of 0.13 pCi/g for Co-6 0.1 i/g for Cs-1 37 in soils.

ammasp eiro'wasc using the-uk asa uil nre ppropriate for analyzing soil-likeaterials (gravel, small large rcontainerprior to use-as potential backfill mateial.: The methodology 0or this equipment is described in' LTP.1&ectionJ5.4.3.

Table 2-1. FSS Instrumentation Characteristics Instrument and Measurement Instrument Detector Type Efficiency 2" x 2" Nal Gamma* 1 Cs-137) Class I, 2 &3 < DCGL*`

Canberra Genie Laboratory 44.1% < 5% of < DCGL Gamma Bulk Assay Gamma 20.0 % < 15% of < DCGL

• Scan for gamma emitting nuclides using the Ludlum 2350-1 rate meter or equivalent.

• • MDC values for varying background values are provided in LTP - Appendix 2-D.

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DRAFT Big Rock Point Restoration Project Final Status Survey Report 2.3. Survey Methods Survey methods, as described in the following sections, were applied to collect scan and volumetric measurements of residual radioactivity of land areas. The techniques for performing survey measurements and collecting samples are specified in approved site procedures. Final status survey measurements include field scans and gamma spectroscopy analysis of soil samples.

2.3.1. Scan Measurements Scan measurements of open land areas were p ed to identify potentially elevated areas of residual radioactivity that re further investigation. Sodium iodide detectors were used for scanning oe s at the BRP site.

Scan measurements of Class I surve s were perfor4over 100% of the surface/land area. Scan measurement' Cla survey i_ were performed over 10 to 100% of the surface/I d area ss 3 survey its, scan measurements were performed f to 10 the surface/land area. In Class 2 and Class 3 survey units, those ar e st potential for elevated residual radioactivity, b n histo a en ere selected for scanning.

The extent of scan co g ach rve t etermined based class requirement for the sto uni, o le and physical limitations of the survey unit.A 2.3.2. Soil Sample surem n Measurement oc s of s rnams were specified in the survey design process using a ran ta spacing teratic methodology for Class 1 and Class 2 survey units in o ance with site procedures and NUREG-1575. For Class 3 survey units, me #ment locations were selected using a random section process. Scale drawings or maps are prepared for each survey unit depicting all data collection locations measured from the survey unit origin (Class I and 2 areas) or located by GPS (Class 3 areas).

Soil sample size was sufficient to fill a one-liter marinelli container, nominally 1600 grams. Surface samples were collected from the top 15 cm of soil. Sample preparation included removing extraneous material, homogenizing, and drying the soil for gamma isotopic analysis. Separate containers were used for each sample and each container is tracked through the analysis process using a chain-of-custody record. Laboratory gamma spectroscopy was used to analyze collected soil samples. Samples were split when required by the applicable QC procedures.

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DRAFT Big Rock Point Restoration Project Final Status Survey Report Tritium analyses on 10% of the final status survey samples for all survey areas impacted by the tritium plume were required (LTP Section 5.4.2.4). Off-site laboratory facilities were utilized for tritium or QC measurements as specified in applicable survey design and associated site procedures. Analytical methods for offsite laboratory facilities were established to ensure minimum detection levels of 10% to 50% of the DCGL value (LTP Section 5.4.1).

2.4. Survey Performance This section describes procedures and processes a i able to final survey design, data collection, review, and record keeping requi s for final status surveys.

2.4.1. Procedures Final survey activities were implement d controlled u approved site procedures. A list of applicable proced is ided in th owing table.

Table 2-2. Procedures Applicab tl S sSurvey Activities Vh Procedure D5.1 Radiation tecti nd En mental Services Policy and Program

. pMhoon I _ If*.

D5.3 ig RocV t olog*1cM vlonmental Program D5.19 'Rlation D tiVon rumentation Calibration Facility and Source D5.26 Final?%t s Su Program RM-76 Final Sta ty Design RM-77 Final Status rvey Implementation RM-78 Final Status Survey Assessment RM-79 Final Status Survey Quality Control RM-72 Sample Chain of Custody RIP-59 Scan Measurements Calibration and Operation of the Canberra Genie 2000 (In-Situ RIP-60Gamma Spectroscopy)

RM-72 Sample Chain of Custody CIP-46 Operation of Canberra "Genie" CIP-50 Calibration, Functional Check and Use of Acculab V-4kg Balance Volume 25 BRP Offsite Dose Calculation Manual Quality Program Description for Nuclear Power Plants (Part 1)- Big Volume 34 Rock Point (and associated procedures) 2.4.2. Training 9

DR/iFT Big Rock Point Restoration Project Final Status Survey Report Final survey data collection and technical support staff were trained and qualified in the procedures performed under each respective job responsibility. Additional training was provided if any of the above procedures changed significantly.

Personnel performing final status survey measurements were trained and qualified in procedures governing the conduct of the FSS, operation of field and laboratory instrumentation used in the FSS, and collection of final status survey measurements and samples. Qualification was obtained upon satisfactory demonstration of proficiency in implementation of procedural requirements. The extent of training and qualification was commensurate with the education, experience and proficiency of the individual and the scope, complexity and nature of the activity performed by that individual. Records of training and qualification are maintained in accordance with approved site p dures.

2.4.3. Sample Handling A chain-of-custody record accompanied volum ample from the point of collection through obtaining the final re o re th lidity of the sample data. Sample tracking records were compelied d maintaIU in accordance with procedure RM-72, Sample Chai of Cust 2.4.4. Data Investigation Scan measurements to ideify h ay have contained elevated volumetric residual r.a ctivi ocatite fi~d by scan measurements as exceeding the action le fIE cpm marked for investigation. Scan measurement erf 00 cent of the area being investigated to identify the Ioeaf tia d ctivity. Soil samples were then collecte these I tSon furthe define the vertical extent of activity.

Analysis of the oils sa es eviewed to determine whether the residual radioactivity exce the D L. epending on the results of the investigation, the identified area(s) tin t urvey unit were remediated and resurveyed in accordance with LTP .3.6.2. Documentation of all investigation activities and corresponding results evaluations are included in the appropriate survey package release record.

2.4.5. Data Management Final survey measurements were performed only after verification that isolation measures to prevent recontamination were effective and that the survey unit was in its final configuration. Measurement results of statistical samples and scan data for final status and supporting surveys were included in the data set for each survey unit to determine compliance with the criteria for unrestricted release.

Volumetric measurements were recorded and compared with the DCGLs.

Measurement records include, at a minimum, the surveyor's name, the location of the measurement, the instrument used, measurement results, the date and time of the measurement, any surveyor comments, and records of applicable reviews. All data records are maintained in accordance with site procedures and are stored as a quality record in the final survey package release record.

2.4.6. Quality Control Measurements 10

DRAFT Big Rock Point Restoration Project Final Status Survey Report Procedures governing final survey design and implementation have built-in QC checks for the survey process, instrumentation, field, and laboratory measurements. A minimum of 5%of final survey soil, water, and sediment samples were evaluated through the QC program. Quality Control measurements consisted of one or more of the following: in-house recounts, split samples, third party analysis, and/or statistical comparisons. Acceptance criterion was based on NRC Inspection Procedure 84750. Unacceptable QC comparisons received a documented investigation and reanalysis, resurvey, or resampling, as necessary.

2.4.7. Control of Vendor Services Vendor laboratory services were utilized for analys, QC measurement and tritium analyses. These services were secured ordance with purchasing requirements for quality related services, to e e same level of quality as onsite analyses.

3.0 Survey Results The survey unit package release cord con numbe f measurements taken, a survey map, sample concet tions, s isical evaluations, including power curves, where applicable, and judgme nd mi Ineous data sets for each firial status or supporting surv akage aucted. also contains a summary of anomalous a a iMicab Ta>5 3-5 in this section also present a summary of tMprtes 3.1. Open Land A u 3.1.1. Class 1 Survey s Class 1 Final Statu r suIts for open land areas will be presented in Part C Irvey of the Final Status Su R rt. Table 3-1 provides a summary of Class 1 surface survey units.

Appendix C-1 contains all final status survey release records for Class I survey units.

3.1.:2. Class 2 Survey Units Class 2 Final Status Survey results for open land areas will be presented in Part C of the Final Status Survey Report. Table 3-2 provides a summary of Class 2 surface survey units.

Appendix C-2 contains all final status survey release records for Class 2 survey units.

3.1.:3. Class 3 Survey Units Class 3 Final Status Survey results will be presented in Parts B and C of the Final Status Survey Report. Table 3-3 provides a summary of Class 3 surface survey units.

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DRAFT Big Rock Point Restoration Project Final Status Survey Report Appendix C-3 contains all final status survey release records for Class 3 survey units.

3.2. Surveys Supporting Final Evaluation 3.2.1. Excavated Surface Surveys Surveys of excavated surface areas were completed to demonstrate that all structural materials of plant origin were removed and that the exposed surface area met the criteria for unrestricted release prior to backfill. All excavated surface survey designs met the requirements of Class 1 area survey as specified in NUREG-1575 and was also performed following th fuidance in Appendix E, Section 11.1 of NUREG-1727.

Surface excavated areas include former lo d creenhouse foundation Turbine Building foundation, Containme ndation aseous Effluent Stack foundation, Liquid Radwaste Vault an I d Radwaste s, and Discharge Canal. Excavated surface survey units e established b on physical location, i.e., excavation footprint of remo ed ations/st r res, and Class 1 survey size limitations.

Table 3-4 provides a su ry of e v urf ~urveys. Appendix C4 contains completed su ge rease, e d r excavated surface surveys. H 3.2.2. Relocated S i Soil remove upport ov a buiinfoundations or subsurface components waocate debated area for final evaluation prior to use as onsite backfill mat. Prio relo tion, soils were evaluated (characterized) to determine suitability rans to the area dedicated for excavated soils.

Controls were institute ent mixing of soils from different survey areas prior to evaluation. Once reloca l these soils were graded to a maximum depth of one meter.

The primary method for evaluation of relocated soils originating from Class 1 and Class 2 areas followed the guidance provided in NUREG-1 575 for final status survey of Class 1 areas. Relocated soil surveys met the design criteria for Class I area. Volumetric samples for laboratory analysis were homogenized over the total 1 meter depth of soil. Soils satisfying the criterion for unrestricted release were stockpiled for use as onsite backfill material.

Alternatively gamma spectroscopy using the large container assay system was also utilized for evaluation of small amounts of relocated soils (LTP Section 5.4.2.4).

Table 3-5 provides compilation of relocated, excavated soil surveys and Appendix C-5 contains a summary of completed survey data for relocated soils.

3.2.3. Tritium in Soils There4w;ere no samples in any survneyi~rt thatexceeded-10% of the ttitim DCGL.

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DRIFT Big Rock Point Restoration Project Final Status Survey Report 3.3. Groundwater Surveys Groundwater sampling and monitoring was performed during excavation of building foundations and subsurface structures and during final site survey of corresponding survey areas, as necessary. Groundwater sampling consisted of gamma spectroscopy analysis and tritium analysis; tritium was the only radionuclide identified in site groundwater. Groundwater and surface water control measures were instituted during demolition activities to minimize or eliminate the impact of water movement.

Existing monitoring wells within the tritium plume (webW-5 and MW-6 and piezometricwells PZ-3MA, PZ-3MB, PZ-3D and P were sampled periodically throughout the decommissioning project.

Eoa~er~vey. results~will. e presed int:Part Cof the tuSurvey eeport.-.Table~.36 contains all grbundwater monitonng data for the site monitoring s fr,,om' ,1999'- 2006. :,All groundwater monitoring well sample'datawiere elow th'edrinking water..MCL-.for tritiumn of 20,000 pCi/L. No upw~ard trends int{hissdata were: indicated eniu'ringthat the hydrogeologicevaluation and siid ,conc u'sionih7 the LTP'are.:valid (LTP,'Section 4.2.2.2).Figure 3-,1;provides'a'graphical representation of groundwater monitoring tritium data for.well locationsiiii detectable tritiu'm no groundwater:contamiination exists 'abovejtie ivalues.ce'Siri'e tri!tiuriMCL, monitoring els have:.been abaidoned inaccordance withS.tate.of Michigqan crieria (LW Section"8.6.

3.4. Survev Unit Inve pations Tof the data investigations are summanzed iTle 3-7.e details of the inv'stigation's,'arre included insurvey unit package,release records (se'e Appendix C).- ' Depending'on the results of the investigation, the identified areas ithin'.the survey unit were,,remediate nd resurveyed in accordance with LTP iSectnf'5.3.56.2.

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DRAFT Big Rock Point Restoration Project Final Status Survey Report Table 3-1. Class I Land Area Final Status Survey Results Summary - to be completed in Part C I 1lSoil Sample Measurements Survey Scan Survey ID Description Area Coverage Number Co-60 Cs-137 Weighted (MIn)  % fSum Samples Max Mean Std Dev Max Mean Std Dev Mean 01 Ci1 Southwest restricted area 02CO1 West side of restricted area _ w 03CO1 Northwest restricted area 04CO1 North restricted area ._ _w _.

05C 11 West central restricted area 06C1 1 South restricted area x_ _ _ _

07Ci 1 Southeast restricted area 08C11 East central restricted area -- _ _Ail 09C 1 1 Northeast restricted area _

10C,1 East restricted area A_ ___W_

11C1i Solid radwaste storage area __E_.__

West beach remediated during .1i1 15(2R)Ci 1 paint chip cleanup . __-___ __

20C11 New solid radwaste staging area K 22ACO 1 Soil verification area A _ _ __

22BC11 Soil verification area B _ . __K 22CC 11 Soil verification area C .

22DCO 1 Soil verification area D _

22ECO1 Soil verification area E I DCC1 Discharge Canal final surface .

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DRAFT Big Rock Point Restoration Project Final Status Survey Report Table 3-2. Class 2 Land Area Final Status Survey Results Summary - to be completed in Part C Soil Sample Measurements Survey Scan (pCVg)

Survey ID Description Area Coverage Number Co-60 Cs-137 Weighted (in) of Max Mean Std ev Max Mean Std Dev Sum

. . Samples .__ _

12C 12 Beach north of restricted area ._._.___,

15 1)C 2 Northern wooded area west of (1)C 1 restricted area AN_ .

Southern wooded area west of A (2)C1 restricted area ._____.

16Ci2 Beach area west of restricted area ____

Area around new radwaste NoAl I9Ci2 staging/shipping location l_ i _

Area around new radwaste 19Ci2 staging/shipping location ll______

23 C i2 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ __ _ _ _ _

DDC 12 Drainage Ditch ________

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DRAFT Big Rock Point Restoration Project Final Status Survey Report Table 3-3. Class 3 Land Area Final Status Survey Results Summary - to be completed in Part B Surve lSoilS l SampleMeasurements

.. Survey Scan 1.

tpii~

Survey ID Description Area Coverage Number Co-60 Cs-137 Weighted

) of Max Mean Std Dev Max Mean Std Dev Sum

_ __ _ _ _ _ _ S a m p le s _ _ _ _ _ _ _ _ _ _ _ _

13Ci3 I3CtWooded area land east of industrial 14Ci3 Beach west of industrial area _ ___

_5(3)CI3 Northern portion of land adjacent to west beach remediation area 15(4 Ci3 Northern portion of land adjacent (4)C1 to west beach remediation area A,___

Wooded area east if industrial 17Ci3 area (adjacent to Soil Verification A rea) _ _ _ _ _ __ _ _ _

Wooded area west of industrial 18C3 area V 59C1 3 Land area south of US 31

_ xNEW _ _ _ _

sa 96C

. s v .

xM V Vik

.4 'law.

16

DRAFT Big Rock Point Restoration Project Final Status Survey Report Table 3-4. Excavated Surface Supporting Survey Results Summary - partial, to be completed in Part C I I I I Soil Sample Measurements Survey Scan (p igj)

Survey ID Description Area Coverage Number Co-60 Cs-1 37 Weighted (i )of Sum Samples Max Mean Std Dev Max Mean Std Dev Mean 11 Solid Radwaste Vault excavation 228 100 20 0.1330 0.0248 0. 0.4320 0.0840 0.1142 0.0148 09CO11 Screenhouse excavation surface 1820 100 20 0.0912 0.0162 6 1.0740 0.1317 0.2925 0.0161 TBCQo1 Turbine Bldg East excavation 1776 100 18 0.0615 0 0.02 0.0270 0.0590 0.0056 surface DCCQ11 Discharge Canal excavated 1300 100 19 1.6100 88 o.6543 . 0.3028 0.4606 0.1516 Turbine Bldg West excavation TBC0 21 surface including Solid Radwaste 100 Vault excavation surface CcQI1 Containment excavation surface 100 17

DRAFT Big Rock Point Restoration Project Final Status Survey Report Table 3-5. Relocated Soil Supporting Survey Results Summary - partial, to be completed in Part C

[ Sn Soil Sample Measurements Survey Scan Survey ID Description Area Coverage Weighted (M)i% Number ofSum Co60Cs-137 Samples Max Mean Std Dev Max Mean Std Dev Mean SWCx11 Soil from slurry wall construction 1800 100 24 0.0250 0.0035 0.Q 0.4550 0.0468 0.0951 0.0050 SWCX21 Soil from slurry wall construction 1800 100 24 0.0297 0.0091 58 0.4100 0.0990 0.1111 0.0111 TBCx11 Soil from Turbine Bldg foundation 3100 100 22 0.0900 0.034 . 0.1300 0.0768 0.0368 0.0171 TBCx 21 Soil from Turbine Bldg foundation 1080 100 18 0.1800 0 0.04 0.1100 0.0635 0.0247 0.0160 TBCx 31 Soil from Turbine Bldg foundation 1440 100 26 0.0022 0 02 0.0016 086 0.0024 0.0022 0.0003 TBCx 41 Soil from Turbine Bldg foundation 1935 100 21 0.0431 Ik08 W.0141 0.0300 0.0169 0.0059 TBCxs1 Soil from Turbine Bldg foundation 1800 100 20 01 32 0.0 0.0387 0.1205 0.0659 0.0256 0.0082 2

0 CxOl Soil from retention pond construction 150 100 19 0.0 0.0056N .0098 0.1040 0.0542 0.0189 0.0063 8Cx1 Soil from Turbine Bldg subfloor 368 100 096 0.2618 0.1357 0.0561 0.0549 demolition __-_._____A O9Cx11 Soil from Screenhouse demolition 1610 100 .0732 2 IZ.0245 0.2501 0.0687 0.0802 0.0117 09Cx 21 Soil from Screenhouse demolition 1120 100 I% AN79 193 0.0184 0.4309 0.1672 0.1386 0.0200 09CX31 Soil from Screenhouse demolition 825 100 18 . 0. 1 0.0156 0.0870 0.0279 0.0226 0.0028 9

O CX41 Soil from Screenhouse demolition 1200 id 0247 0048 0.0157 0.0617 0.0163 0.0180 0.0029 09Cx 51 Soil from Screenhouse demolition 840 1 1 2 0.0100 0.0187 0.1146 0.0157 0.0283 0.0044 09CX 61 Soil from Screenhouse demolition 1200 100 18 0.0248 0.0029 0.0093 0.0580 0.0139 0.0216 0.0021 09CX 71 Soil from Screenhouse demolition 106 100 8 0.0607 0.0169 0.0190 0.1596 0.0270 0.0426 0.0075 11CX1I Soil from Solid Radwaste Vault 100 0.0590 0.0114 0.0174 0.0920 0.0344 0.0256 0.0064 dem olition _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _

12Cxil Soil from temporary bldg 100 18 0.0500 0.0099 0.0151 0.5800 0.2867 0.1171 0.0271 construction drain modifcatio 100 1.03 0.0 0.60 l9CXiI Soil from storm drain modification 100 18 0.0337 0.0131 0.0105 0.2000 0.0919 0.0361 0.0118 18

DRAFT Big Rock Point Restoration Project Final Status Survey Report Table 3-6. Groundwater Monitoring Data - partial, to be completed in Part C l Depth Tritium Mean Well ID Location Depth)

(ft) 1999 2000 2001 2002 2003 2004 2005 2006 MW-5 MW-6 Pz-PZ- . '..'Aivl

. der

. wE'law SC ag&&

H IAa %h.

. A =

19

DRAFT Big Rock Point Restoration Project Final Status Survey Report Table 3-7. Summary of Data Investigation Results and Actions Taken 20

DRAFr Big Rock Point Restoration Project Final Status Survey Report 4.0 Final Status Survey Data Assessment 4.1. Data Verification and Validation Data were reviewed to verify that Data Quality Objectives (DQOs) established in each of the survey designs were met. Where appropriate, graphical representations and statistical comparisons of the data were made to provide both qualitative and quantitative information about the survey data. An assessment was performed to verify the data supported the underlying assumptions necessary for statistical tests if applicable.

4.1.1. Data Quality Review Final status survey and supporting survey dz to ensure that they were complete, fully documented, and tech The review criteria for data acceptability included the followed

• The minimum detectable concentr used for radiological measureme t was be all radionuclides of interest;

• The instrument calibration wasrk to NIST standards;

• The field ir and after each survey to verify satis

• The MDCs pthem were appropriate for the instrumg the survey;

• Thesy data were proper for the types of radiatin being surveyed;

• uSpecial m collection were properly applied for the survey unit under ible;

• The chain-of-custoaVas tracked from the point of sample collection to the point of obtaining results;

• The data set is comprised of qualified measurement results collected in accordance with the survey design which accurately reflect the radiological status of the facility; and 0 The data were properly recorded.

If the data review criteria were not met, the discrepancy was evaluated and the decision to accept or reject the data was documented in accordance with approved site procedures. The BRP Corrective Action Program was used to document and resolve discrepancies as applicable.

4.1.2. Graphical Data Review Survey data was graphed to identify pattems, relationships or possible anomalies that would not be evident using other methods of review. As a minimum a posting plot was used for each survey unit.

21

DRAFT Big Rock Point Restoration Project Final Status Survey Report 4.1.3. Statistical Comparisons Values of the median, mean, standard deviation and maximum radioactivity levels for both Cs-137 and Co-60 were determined from gamma isotopic results for each survey unit. The weighted sum using the unity rule was also calculated for each survey unit to allow comparison to the DCGLw. These values are summarized in Tables 3-1 through 3-5 for each survey unit and are detailed in the assessment section of each final status survey package (Appendix C).

4.2. Release Criteria Verification An assessment was performed for each final sta or supporting survey data set to ensure adequate basis to that the surve met riteria for unrestricted release. This process is described below mmariz each survey unit in Table 4-1.

4.2.1. Condition #1 - Mean Test This condition requires that the r vity was less than the 1.0 x DCGLw. To determine if this coi .an of the final survey unit data set for each survey I> .Nw (applying the unity rule).

In all cases the mean rgj3ial an 0.05 x the DCGLW for each survey unit There ea Condition #1.

4.2.2. Condition #2 The Elevated Msureme ~m (EMC) test requires that individual measurement relenting sbl ar of residual radioactivity exceeding the DCGLW did not exche D a4EMC. Since all measurements were less than the DCGLw, an EMC wasl geq ud for any survey unit and Condition #2 was automatically satisfied fo1E" vey units.

4.2.3. Condition #3 - Sign Test This condition requires that where-one or more soil sample measurements in a survey unit exceed the DCGLw, the average residual radioactivity passes the Sign statistical test. Since all soil sample measurements were less than DCGLW, the Sign statistical test was not applied to any survey unit data set and all survey units satisfied Condition #3.

4.3. Summarv of Changes from Initial Assumptions on Residual Radioactivity supporting survfeys did not identify radioactivity levels that altered any of the inital assumptions contained in the1BRP LTP regarding residual radioactivityhat the site.

22

DRAFT Big Rock Point Restoration Project Final Status Survey Report 4.4. ALARA Evaluation In accordance with the release criteria (Section 1.3 an evaluation is required to determine if it is ALARA to reduce the levels of residual radioactivity to below concentrations necessary to meet the DCGLW. The License Termination Plan, Section 4.4 contains the ALARA evaluation for Big Rock Point. This evaluation previously determined that both the site specific DCGLs for Class 1 and Class 2 areas and the screening DCGLs for Class 3 areas are considered ALARA for the land areas to be release for unrestricted use.

23

DRAFT

• Big Rock Point Restoration Project Final Status Survey Report Table 4-1. Summary of Survey Unit Release Criterion Evaluation' I I . I ¢as% CILtejVIrI Survey Survey Unit Class Description Condition #1 Condition #2 Condition #3 Unit

. Mean Test EMC Test Sign Test Passed?

Aw

=I, A OLx Nk. X ,11 XIncludes Final Status Surveys of open land areas.

21

DRAFT Big Rock Point Restoration Project Final Status Survey Report 22

DRAF1 Big Rock Point Restoration Project Final Status Survey Report 5.0 Fiinal Status Survey Conclusions Scan and volumetric measurement data collected during final status surveys confirmed that the classification for each of the survey units was accurate. Final Status Surveys and supporting surveys demonstrate licensed radioactive materials were removed from BRP property to the extent that any remaining residual radioactivity is below the radiological criteria for unrestricted use and that that all remainingsurface and associated subsurface land areas were evaluated against the criteria for rfktricted use. The final survey data presented in this report plan demonstrate compJwith 10 CFR 20.1402 and the site impacted and non-impacted land areas meet a for unrestricted use.

The information contained in this submi getherw Te information provided in prior submittals and subsequent suppleme atpnases is sufficirt or the NRC to make a determination equivalent to 10 CFR 5 1 garding ands to be released from the license. Once these lands ae so reles s understoo at the NRC will not require any additional surveys or ~tamin of these areas unless the NRC determines that the criteria of 0C1 20, art E were not met and that residual activity remaining on theJad could sig nt threat to public health and safety.

21

DRAFT Big Rock Point Restoration Project Final Status Survey Report 6.0 References 22

t i

I Consam e COWnt on Us I

I BigRock Point RestorationProject Tel:231 547 8416 i

10269 US31 North Fax: 231 675 7548 i Charlevoix, Ml 49720 Pager: 231 317 0567 E-Mail: kepaffagigcmsenergy.com Kenneth E. Pallagi Manager Radiation Protection & Environmental Services A CMlS Energy Company Consumersj __i. Count on Us Big Rock Point Restoration Project Tel: 231 5478171 10269 US31 North Fax:231 237 2594 Chartevoix, Ml 49720 E-Mail: dwparish~cmsenergy.com David Parish Analyst Radiation Protection & Environmental Services A CMS Energy Company Consumers Enejrgy . Count on Us 10269 US 31 N. Tel:231 547 8389 Charlevoix, MI 49720 Fax: 231 237 2595 Pager: 231 317 0569 E-Mail: tmgobleecmsenergycom Tracy A. Goble, PE.

Environmental Services Superinlendent Big Rock Point Restoration Project A CAIS Enegmy Con7pa;m