ML063260085

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Request to Release Site Land, NRC Requested to Review and Approve Request by Year End 2006
ML063260085
Person / Time
Site: Big Rock Point  File:Consumers Energy icon.png
Issue date: 11/16/2006
From: Haas K
Consumers Energy
To:
Document Control Desk, NRC/FSME
References
Download: ML063260085 (43)
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CwisUnr Ene gy A CMS Energy Company Big Rock Point Nuclear Plant Kurt A. Haas 10269 US-31 North General Manager Charlevoix, MI 49720 November 16, 2006 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 DOCKETS 50-155 AND 72-043 - LICENSE DPR BIG ROCK POINT PLANT -

REQUEST TO RELEASE SITE LAND All physical demolition and restoration work at Big Rock Point (BRP) has been completed in accordance with the BRP License Termination Plan (LTP). The BRP site has been restored to a "Greenfield" condition, as defined in the LTP, Section 1.5. By this letter, we request that you release BRP site land from the terms of its 10 CFR Part 50 license in accordance with approved LTP sections 1.4.2 and 5.1.2. We refer to the land requested to be released from the operating license as the Release Area. The Release Area consists of all land encompassed by the licensed site boundary, with the exception of approximately 30 acres of land associated with the operation of the Independent Spent Fuel Storage Installation (ISFSI) and an additional 75 acres of land surrounding the ISFSI, including the ISFSI access road. The attached site boundary drawing shows the Release Area (noted as "Remainder") and the area to remain under the license (described as "Parcel A").

Also attached to this letter is the Final Status Survey Report (FSSR) covering the Release Area.

The FSSR demonstrates that the Release Area meets the radiological criteria for license termination.

We request the NRC review and approve this request by year end 2006 to ensure a smooth transition to ISFSI-only operation and transfer of license activities associated with the ISFSI to Entergy Nuclear Palisades, LLC, in early 2007.

If you should have any questions regarding this submittal, please contact me at (231) 547-8388.

Kurt M. Haas Site General Manager ATTACHMENTS cc: Administrator, Region III, USNRC NRC Decommissioning Inspector, Big Rock Point NRC NMSS Project Manager, James Shepherd NRC NMSS FSS Reviewer, Bruce Watson Michigan Department of Environmental Quality, Thor Strong

ATTACHMENT 1 CONSUMERS ENERGY BIG ROCK POINT DOCKET NUMBERS 50-155 AND 72-043 SKETCH OF BOUNDARY November 16, 2006 1 Page

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't ATTACHMENT 2 CONSUMERS ENERGY BIG ROCK POINT DOCKET NUMBERS 50-155 AND 72-043 FINAL STATUS SURVEY REPORT November 16, 2006 39 Pages

Big Rock Point Restoration Project Final Status Survey Report Consumers Energy Company November 16, 2006

Big Rock Point Restoration Project 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 Levels 1.3.3 Tritium in Soils 1.4 Discussion of Changes to the Final Status Survey Plan 2.0 Final Status Survey Methodology 2.1 Survey Units 2.1.1 Classification 2.1.2 Survey Unit Size 2.1.3 Survey Unit Nomenclature 2.2 Instrumentation 2.2.1 Calibration and Maintenance 2.2.2 Instrument Response 2.2.3 Minimum Detectable Concentration 2.3 Survey Methods 2.3.1 Scan Measurements 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

Big Rock Point Restoration Project Final Status Survey Report 3.0 Final Status Survey Results 3.1 Open Land Area Surface Surveys 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 Monitoring 3.4 Survey Unit Investigations 3.5 Survey Unit Anomalies 4.0 Final Status Survey Data Assessment 4.1 Data Verification and Validation 4.2 Summary of Changes from Initial Assumptions on Residual Radioactivity 4.3 Release Criteria Verification 4.4 ALARA Evaluation 4.5 Memorandum Of Understanding Between NRC and EPA 5.0 Final Status Survey Conclusions 6.0 References Appendices Appendix A - Big Rock Point Impacted and Non-Impacted Areas Appendix B - Big Rock Point Final Status Survey Units Appendix C - Big Rock Point Tritium Plume Map Appendix D - Groundwater Monitoring Well Locations Appendix E - Final Status Survey Submittal Matrix

Big Rock Point Restoration Project Final Status Survey Report List of Tables 1-1 Site-Specific Industrial Area DCGLs 2-1 FSS Instrumentation Characteristics 2-2 Procedures Applicable to Final Status Survey Activities 3-1 Class 1 Land Area Final Status Survey Results Summary 3-2 Class 2 Land Area Final Status Survey Results Summary 3-3 Class 3 Land Area Final Status Survey Results Summary 3-4 Excavated Surface Supporting Survey Results Summary 3-5 Relocated Soil Supporting Survey Results Summary 3-6a Tritium Monitoring Well Historical Data (Wells Installed in 1994) 3-6b Tritium Monitoring Well Historical Data (Wells Installed in Post-Shutdown) 3-6c Tritium Monitoring Well Historical Data (Wells Installed in 2004) 3-7 Summary of Data Investigation Results and Actions Taken 3-8 Design Parameter Comparison Survey Unit CWCq11 4-1 Comparison of BRP Maximum Single Sample Concentration to NRC/EPA MOU Table 1

Big Rock Point Restoration Project Final Status Survey Report EXECUTIVE

SUMMARY

Consumers Energy Company has decommissioned the Big Rock Point Nuclear Plant to a Greenfield condition as defined in the approved Big Rock Point License Termination Plan (LTP)

[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 or below original plant grade along with supporting surveys of excavated surfaces and relocated excavated soils.

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 impacted areas [Appendix A] were divided into 34 final status survey units and classified according to their potential for containing residual radioactivity. Sixteen open land area final status survey units are classified as Class 1, twelve open land area final status survey units as Class 2, and six open land area final status areas as Class 3. All 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 from the 10 CFR 50 license.

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Big Rock Point Restoration Project Final Status Survey Report OVERVIEW

1.1 Purpose and Scope

This report provides information required by 10 CFR 50.82(a)(11), which demonstrates that Big Rock Point land areas meet the radiological criteria for unrestricted use specified in 10CFR 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 Surveys were performed in accordance with the final status survey process described in the Big Rock Point License Termination Plan (LTP, Chapter 5). Final Status Surveys were conducted on open land areas at or below original plant grade elevations for the survey unit. Supporting surveys include release records for surveys of excavated surfaces upon removal of building foundation materials and surveys of relocated soil designated for backfill upon completion of demolition activities. All Final Status Survey release records have previously been submitted for review [see Appendix E].

1.2 Description of Survey Areas Final Status Survey units at Big Rock Point [Appendix B] include Class 1, 2 and 3 open land area surveys. Decommissioning activities conducted in preparation for the Final Status Survey include historical site assessment, radiological characterization, dismantlement and demolition, remediation, readiness surveys and supporting surveys.

Supporting Surveys are defined as surveys of excavated surfaces and soils relocated from excavations during removal of building foundations and below-grade components.

Supporting Surveys conducted for excavated surfaces include areas where the Turbine Building, Plant Stack, Screenhouse, Containment, Solid Radwaste Vault, Liquid Radwaste Vault, and the Condenser Circulating Water piping were formerly located.

Relocated soils consist of soil removed for building foundation and subsurface component demolition/removal activities. All supporting surveys of excavated surfaces and relocated soils were conservatively designed and executed to the requirements specified for Class 1 areas in accordance with the Big Rock Point Final Status Survey Plan (LTP Chapter 5).

Appendix B contains a map of the individual survey units.

1.3 Site Release Criteria The site release criteria applied to each final status survey unit corresponds to the radiological criteria for unrestricted use provided in 10 CFR 20.1402 and as approved in the BRP LTP. These criteria are:

i. Dose Criterion: The residual radioactivity that is distinguishable from background radiation results in a Total Effective Dose Equivalent (TEDE) to an average member of the critical group that does not exceed 25 mrem/yr, including that from groundwater sources of drinking water; and ii. ALARA Criterion: The residual radioactivity has been reduced to levels that are as low as reasonably achievable (ALARA).

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Big Rock Point Restoration Project Final Status Survey Report 1.3.1 Application of the Site Release Criteria Levels of residual radioactivity that correspond to the allowable radiation dose and ALARA levels of the site release criteria were derived by analysis of various scenarios and pathways (e.g., 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.

1.3.2 Derived Concentration Guideline Levels The residual radioactivity concentration levels for surface and subsurface soils in the Industrial Areas (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 25 mrem/yr Limit Open Land Areas **

(Surface and Subsurface Soils, pCi/g)

H-3 3.27 E+02 Mn-54 1.37 E+01 Fe-55 3.58 E+05 Co-60 3.21 E+00 Sr-90 2.48 E+00 Cs-1 37 1.32 E+01 Eu-152* 7.35 E+00 Eu-154* 6.78 E+00 Eu-155* 2.87 E+02

  • Europium is included to address potential contamination of soil from concrete demolition activities.
    • Including contribution of 0.054 mrem/y from discounted radionuclides and 0.766 mrem/y for groundwater tritium 3

Big Rock Point Restoration Project Final Status Survey Report DCGLs for Cs-1 37 and Co-60 presented above were modified to account for the presence of hard-to-detect (HTD) nuclides, Sr-90 and Fe-55, respectively, using surrogate ratios developed from characterization. The modified DCGL for Cs-1 37 is 11.93 pCi/g and for Co-60 is 3.21 pCi/g.

1.3.3 Tritium in Soils Tritium analyses on 10% of samples in survey areas impacted by the tritium plume

[Appendix C] were required (LTP Section 5.4.2.4). These areas included the Turbine Building, Liquid Radwaste Vault, Containment, and Screenhouse excavations.

Additionally, tritium analysis for 10% of the samples taken from excavated soils in the defined plume area was performed. As a conservative measure, tritium analysis was performed on 10% of samples from all excavated soils (relocated soils) to ensure acceptability of the soil as backfill 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).

1.4 Discussion of Chanqes to the Final Status Survey Plan No changes to the Final Status Survey Plan, as approved in Chapter 5 of the LTP (revision 2), were identified during conduct of supporting surveys or final status surveys at the Big Rock Point site. Changes to initial survey area units were anticipated and implemented during survey design in accordance with the LTP

[Appendix B]. Additional Class 1 survey units were designed in response to decommissioning activities.

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-1575 [Reference 2]. The Data Quality Objective (DQO) process was used to ensure that each final status survey was of sufficient quality to support future unrestricted release of the site property. Land areas were divided into survey units, which were categorized and classified according to the type and potential for residual radioactivity. Characterization and remediation data were used to design surveys and these survey designs were reviewed then translated into field instructions for data collection. Instrumentation and survey methods, appropriate to the type of radiation being measured, were used to collect measurements in accordance with site procedures and quality controls instituted to ensure accurate results.

2.1 Survey Units Impacted land areas were divided into 34 survey units based on physical characteristics and the potential for elevated residual radioactivity [Appendix B].

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Big Rock Point Restoration Project Final Status Survey Report 2.1.1 Classification Survey units were classified as Class 1, Class 2, or Class 3 based on the potential for residual radioactivity. Areas with residual radioactivity that had the potential to exceed the DCGLs prior to remediation were divided into Class 1 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.

2.1.2 Survey Unit Size Survey units were sized in accordance with NUREG-1575 guidance. They 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 1 survey areas were typically sized to a maximum of 2000 m2 unless survey conditions warranted a larger area; one supporting survey unit exceeded the recommended 2000 m2 size. A technical justification for size deviation of that Class 1 survey was provided as part of the completed survey package in accordance with Chapter 5 Section 5.2.3.1 of the LTP and in this report in Section 3.5, Survey Unit Anomalies. 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 204,676 M2 .

2.1.3 Survey Unit Nomenclature and Location A unique survey identification was utilized for each survey unit. The nomenclature for identification of final status and supporting surveys is described in general by the following:

NNTTi C Example: 09CQ11 Where:

NN - Unique alphanumeric survey unit identifier TT - Survey type CQ- Final survey of excavated (quarry) surface Cx -Final survey relocated soil C -Final Status Survey of open land area i- Survey iteration (1, 2, 3 ... )

C- Survey unit initial classification (1, 2 or 3)

Survey units were identified by reference to an established site grid plan. The site grid plan was referenced to longitude and latitude coordinate locations by a licensed survey and confirmed by Global Positioning System (GPS). The southwest corner of each area represents the identifying origin of each survey unit. The site grid plan, with reproducible field locations, facilitated survey management and design, ensured accurate location of survey measurements, and permitted the replication of survey areas for remediation and measurement verification as necessary.

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Big Rock Point Restoration Project Final Status Survey Report 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-137 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.

Table 2-1. FSS Instrumentation Characteristics Instrument and Measurement Instrument MDC Detector Type Efficiency Gamma* 1200 cpm/mR/hr Class I < DCGLEMC**

(Cs-1 37) Class 2&3 < DCGLw Canberra Genie Laboratory 44.1% < 5% of DCGLw Gamma Bulk Assay Gamma 20% < 15% of DCGLw

  • 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.

2.2.1 Calibration and Maintenance Instrumentation used for the FSSs were calibrated and maintained in accordance with site procedures. 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 instruments were conducted daily before and after each use to ensure proper instrument response and operation. Laboratory instruments were checked daily in accordance with instrument procedures. An acceptable response for field and laboratory instrumentation was an instrument reading within +/-3 sigma as documented on a control chart. Source checks use source energies consistent with the nuclides encountered at the BRP site. If an instrument failed response check, it was appropriately identified and withheld from use until the problem was corrected in accordance with applicable procedures. If a failure occurred in the post-use check, data validation was required and documented in the survey release record.

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Big Rock Point Restoration Project Final Status Survey Report 2.2.3 Minimum Detectable Concentration A minimum detectable concentration (MDC) was determined for each type of instrument and measurement method used for survey data collection. Instruments used for surface scanning were capable of detecting radioactive material at levels below the DCGL in Class 1 areas. MDC values for scanning instruments used in Class 1 and 2 areas were capable of detecting residual radioactivity below the DCGLw.

Laboratory gamma spectroscopy instruments used for soil volumetric sample analyses were capable of residual radioactivity detection at values less than 5% of the DCGLw using a one-liter marinelli geometry. The laboratory counting system had software controlled count times which were set to meet a maximum MDC of 0.13 pCi/g for Cs-60 in soil.

Where appropriate, radiological measurements were performed using the Gardian Mobile Assay System (GMAS) for large container analysis of soil-like materials (gravel, small stone, etc,) (LTP Section 5.4.2.4). This survey methodology is the same as that approved for the 10 CFR 20.2002 demolition debris disposal process. The GMAS system provided spectroscopy analyses over 100% of the survey population with software controlled count times that resulted in a detection sensitivity less than 15% of the DCGLw.

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 included field scans and gamma spectroscopy analysis of soil samples.

2.3.1 Scan Measurements Scan measurements of open land areas were performed to identify potentially elevated areas of residual radioactivity that required further investigation. Sodium Iodide detectors were used for scanning open land areas at the BRP site.

Scan measurements of Class 1 survey units were performed over 100% of the surface/land area. Scan measurements of Class 2 survey units were performed over 10 to 100% of the surface/land area. For Class 3 survey units, scan measurements were performed over 10% or less of the surface/land area. In Class 2 and Class 3 survey units, those areas with the highest potential for elevated residual radioactivity, based on historical judgment, were selected for scanning. The extent of scan coverage was determined based upon classification, historical knowledge, and physical limitations of the survey unit.

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Big Rock Point Restoration Project Final Status Survey Report 2.3.2 Soil Sample Measurements Measurement locations of soil samples were specified in the survey design process using a random-start, systematic spacing methodology for Class 1 and Class 2 survey units in accordance with site procedures and NUREG-1575. For Class 3 survey units, measurement locations were selected using a random selection process. Scale drawings or maps were prepared for each survey unit depicting all data collection locations measured from the survey unit origin (Class 1 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 was 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.

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 and 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 applicable to final survey design, data collection, review, and record keeping requirements for final status surveys.

2.4.1 Procedures Final survey activities were implemented and controlled using approved site procedures. A list of applicable procedures is provided in the following table.

Table 2-2. Procedures Applicable to Final Status Survey Activities Procedure Title Number Radiation Protection and Environmental Services Policy and Program Description D5.3 Big Rock Point Radiological Environmental Program Radiation Detection Instrumentation Calibration Facility and Source Control D5.26 Final Status Survey Program CIP-46 Operation of Canberra "Genie" CIP-50 Calibration, Functional Check and Use of Acculab V-4kg Balance 8

Big Rock Point Restoration Project Final Status Survey-Report Procedure Title Number RIP-59 Scan Measurements Calibration and Operation of the Canberra Genie 2000 (In-Situ Gamma Spectroscopy)

RM-72 Sample Chain of Custody RM-76 Final Status Survey Design RM-77 Final Status Survey Implementation RM-78 Final Status Survey Assessment RM-79 Final Status Survey Quality Control Volume 25 BRP Offsite Dose Calculation Manual Volume 34 & 34a Quality Program Description for Big Rock and Implementing Procedures 2.4.2 Training Final status survey technicians 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 procedures.

2.4.3 Sample Handling A chain-of-custody record accompanied each volumetric sample from the point of collection through obtaining the final results to ensure the validity of the sample data.

Sample tracking records were controlled and maintained in accordance with procedure RM-72, Sample Chain of Custody.

2.4.4 Data Investigation Locations, identified by scan or volumetric measurements, with residual radioactivity that exceeded the DCGL were marked and investigated. Scan measurements were performed over 100 percent of the area being investigated. Where scan measurements were performed, the gross activity value of 1818 cpm above background was used to identify areas that may have contained elevated residual radioactivity. A soil sample was collected at locations that exceeded the gross activity value and the results reviewed to determine whether the residual radioactivity exceeded the DCGL. Depending on the results of the investigation, the identified areas within the survey unit were remediated, reclassified, and/or resurveyed in accordance with LTP Section 5.3.6.2.

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Big Rock Point Restoration Project Final Status Survey Report 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 survey 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. 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 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 criteria were based on NRC Inspection Procedure 84750.

Procedures provide that unacceptable QC comparisons receive a documented investigation and reanalysis, resurvey, or resample, as necessary.

2.4.7 Control of Vendor Services Vendor laboratory services were utilized for analysis of QC measurement and tritium analyses. These services were secured in accordance with purchasing requirements for quality related services, to ensure the same level of quality.

3.0 Survey Results The survey unit package release record contains the number of measurements taken, a survey map, sample concentrations, statistical evaluations, including power curves, where applicable, and judgmental and miscellaneous data sets for each final status or supporting survey conducted. Each survey package also contains a summary of anomalous data if applicable. Tables 3-1 to 3-5 in this section also present a summary of these parameters.

3.1 Open Land Area Surface Surveys 3.1.1 Class 1 Survey Units Class 1 Final Status Survey results for open land areas are presented in each survey package and are summarized in Table 3-1, Class 1 Open Land Area Final Status Survey Results Summary.

All final status survey release records for Class 1 survey units have previously been submitted for review [Appendix E].

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Big Rock Point Restoration Project Final Status Survey Report 3.1.2 Class 2 Survey Units Class 2 Final Status Survey results for open land areas are presented in each survey package and are summarized in Table 3-2, Class 2 Open Land Area Final Status Survey Results Summary.

All final status survey release records for Class 2 survey units have previously been submitted for review [Appendix E].

3.1.3 Class 3 Survey Units Class 3 Final Status Survey results for open land areas are presented in each survey package and are summarized in Table 3-3, Class 3 Open Land Area Final Status Survey Results Summary.

All final status survey release records for Class 3 survey units have previously been submitted for review [Appendix E].

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 requirement of Class 1 area surveys as specified in NUREG-1575 and were also performed following the guidance in NUREG-1727 Appendix E Section 11.1.

Excavated surface areas include former locations of the Screenhouse, Turbine Building, Containment, Liquid Radwaste Vault, and Gaseous Effluent Stack foundations, and the Solid Radwaste Vault and Circulating Water excavation.

Excavated surface survey units were established based on physical location, i.e.,

excavation footprint of removed foundations/structures, and Class 1 survey size limitations.

Excavated Surface Survey results are presented in each survey package and are summarized in Table 3-4, Excavated Surface Supporting Survey Results Summary.

All Excavated Surface Survey release records have previously been submitted for review [Appendix E].

3.2.2 Relocated Soil Excavated soil supporting removal of building foundations and subsurface components was relocated to a designated area for final evaluation prior to use as onsite backfill material. Prior to relocation, soils were evaluated (characterized) to determine suitability for transport to the area dedicated for excavated soils. Controls were instituted to prevent mixing of soils from different survey areas prior to evaluation.

Once relocated, these soils were graded to a maximum depth of one meter.

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Big Rock Point Restoration Project Final Status Survey Report 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 1 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).

Relocated Soil Survey results are presented in each survey package and are summarized in Table 3-5, Relocated Soil Supporting Survey Results Summary.

All Relocated Soil Survey release records have previously been submitted for review

[Appendix E].

3.2.3 Tritium in Soils In accordance with the LTP section 5.2.1.3 tritium in soils is addressed by tritium analyses on 10% of the FSS samples for all survey areas impacted by the tritium plume (Appendix C). There were no samples in any survey unit that exceeded 10% of the tritium DCGL.

Tritium in soil analyses results are presented in each survey package and are summarized in Tables 3-1 through 3-5.

3.3 Groundwater Monitorinq Groundwater monitoring wells were sampled periodically, dependent on availability based on demolition and decommissioning activities, throughout the decommissioning project. Groundwater monitoring well data through 2004 was provided in the LTP (see Section 2.4.5.3). Monitoring wells within the tritium plume (wells MW-5 and MW-6 and piezometric wells PZ-3MA, PZ-3MB, PZ-3D and PZ-5S) were maintained until the FSSs were completed in the Industrial Area. All groundwater monitoring well sample data at the conclusion of Final Status Survey were below the drinking water Maximum Contaminant Level (MCL) for tritium of 20,000 pCi/L. No upward trends in this data were indicated ensuring that the hydrogeologic evaluation and stated conclusions in the LTP are valid. No groundwater contamination exists above the tritium MCL and monitoring wells have been abandoned in accordance with the LTP and State of Michigan criteria (LTP Sections 5.4.2.5). Tables 3-6a, 3-6b and 3-6c contain tritium data for the site groundwater monitoring wells. Appendix D, Groundwater Monitoring Well Locations provides location and depths of the wells.

3.4 Survey Unit Investigations The results of the data investigations are summarized in Table 3-7. The details of the investigations are included in survey unit package release records. Depending on the results of the investigation, the identified areas within the survey unit was determined to have met the criteria for unrestricted release or remediated, and resurveyed in accordance with LTP Section 5.3.6.2.

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Big Rock Point Restoration Project Final Status Survey Report 3.5 Survey Unit Anomalies Survey Unit CWC qI1, Base Elevation of Circulating Water Piping Excavation.was designed at 2935 M2 . This excavation surface area exceeded the maximum size requirement of 2000 M2 for a Class 1 survey area. However, with potentially unstable embankments, considerations for worker safety, weather, and groundwater management/removal led to the conclusion that the excavation should be surveyed as one unit. As this was a supporting survey it was determined that Class 1 survey design requirements would be satisfied by maintaining sample size spacing and density consistent with values established for a standard Class 1 area of 2000 M2 . A comparison of the design parameters for development of Survey Unit CWC q1 1 with regulatory guidance, as shown in the table below, demonstrates verification that the design values in the survey unit met or exceeded Class 1 survey requirements.

Table 3-8 Design Parameter Comparison Survey Unit CWCqi1 Survey* Sample Size Spacing Sample Density Standard Requirements I Class 1 Area 2000 m 2 15 0.75 samples/i00 m2 Survey1CWC 2935 M2 Area qClass 32 8 1.09 samples/100 m 2

  • Survey Unit Relative Shift = 2.0 3.6 Survey Quality Control Measurement Results All Quality Control Measurement comparisons were acceptable, no investigations were required.

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Big Rock Point Restoration Project Final Status Survey Report Table 3-6a. Tritium Monitoring Well Historical Data (in pCi/I) - (Wells Installed in 1994)

Sampled MW #1 MW #2 MW #3 MW #4 MW #5 MW #6 MW #7 MW #8 MW #9 08/1994 <1250 <1250 <1250 <1250 11,300 40,600 <1250 <1250 <1250 09/1994 <504 <504 <503 <503 10,500 27,000 <502 <503 <522 04/1996 23,800 46,900 07/1996 <721 23,200 16,000 <721 <721 536 10/1996 <804 <804 <804 22,600 22,300 <804 <804 <804 04/1997 <149 <149 <149 22,700 36,800 <149 <149 <149 10/1997 <706 <706 14,400 24,700 <706 <706 <706 04/1998 <602 <602 <602 13,900 9,100 <602 <602 10/1998 <524 <524 <524 15,800 23,100 <524 628 03/1999 <523 <523 <523 10,500 13,900 <523 <523 07/1999 184 <150 <150 10,100 2,730 <150 598 10/1999 <183 <183 <183 <183 16,500 1,900 <183 510 04/2000 <175 <157 <157 <157 17,392 5,276 <157 430 10/2000 <156 <156 <156 <156 10/2000 191 26,000 5,057 03/2001 9,600 5,160 04/2001 170 <186 <186 8,820 5,280 <186 10/2001 <168 <168 <168 <168 9,160 2,420 <168 422 03/2002 3,860 1,747 04/2002 <141 <141 <164 <164 2,860 5,150 <164 357 10/2002 <150 <150 <146 <146 4,910 4,320 <146 <150 04/2003 188 <133 <133 <133 3,490 2,960 <133 269 10/2003 <169 <169 <169 4,870 5,080 <169 349 12/2003 2,326 341 05/2004 <157 <154 4,081 1,362 <154 324 07/2004 280 5215 2730 <157 367 09/2004 3923 2090 11/2004 2828 04/2005 4918 05/2005 4436 10/2005 5254 4987 05/2006 <1000 <1000 <1000 3023 2037 <1000 07/2006 <733 <733 09/2006 2719 <763 20

Big Rock Point Restoration Project Final Status Survey Report Table 3-6b. Tritium Monitoring Well Historical Data (Wells Installed in Post-Shutdown)

Sampled PZ-1D PZ-1M PZ-1S PZ-2D PZ-2M PZ-2S PZ-3D PZ-3Ma PZ-3Mb PZ-3S PZ-4S PZ-5S PZ-6S 01/2002 <126 290 02/2002 <96 03/2002 <96 <96 <96 <96 1,423 <96 <96 957 <96 05/2002 <97 <97 2,105 595 06/2002 1,560 10/2002 <177 <177 <177 <177 <177 <177 768 2,060 808 <177 <177 2,650 <177 04/2003 <163 <163 <163 <163 <163 798 3,165 383 <163 <163 1,069 <163 11/2003 <174 <174 <174 <174 919 3,342 380 737 <174 12/2003 942 3,183 361 315 05/2004 <154 373 2,667 279 <159 <154 892 07/2004 <157 <157 172 <157 403 2671 724 203 2656 09/2004 <993 <993 1888 11/2004 <1000 2107 <1000 1957 04/2005 <1000 <1000 1405 2141 1745 4842 10/2005 2813 2961 4248 2222 03/2006 <157 <157 05/2006 <1000 <1000 <1000 <1000 <1000 1095 1845 1592 1793 07/2006 <733 <733 <733 <733 09/2006 1334 1355 <763 1227 21

Big Rock Point Restoration Project Final Status Survey Report Table 3-6c. Tritium Monitoring Well Historical Data (Wells Installed in 2004)

Sampled PZ-7M PZ-7Ma PZ-8M PZ-8Ma PZ-9M PZ-9Ma 06/2004 <162 <162 <182 <162 523 <162 07/2004 <157 <157 <157 <157 408 199 09/2004 <993 <993 <993 <993 408 <993 11/2004 <1000 <1000 <1000 <1000 04/2005 <1000 <1000 <1000 <1000 10/2005 <1000 1477 <1000 03/2006 <157 <157 <157 <157 <157 05/2006 <1000 <1000 <1000 <1000 <1000 <1000 22

Big Rock Point Restoration Project Final Status Survey Report Table 3-7. Summary of Data Investigation Results and Actions Taken Survey Class Identified Locations Description Actions Taken Unit Scan Soil Sample

1. Isolated and initiated survey investigation.

Investigation Solid Radwaste Vault Excavated 2. DCGL concentrations were NOT exceeded.

1x1evel Surface 3. Survey unit satisfied the criteria for unrestricted Exceeded use.

1. Isolated and initiated survey investigation.

West Investigation 2. Residual radioactivity exceeded the scan DCGL.

t 1 Level N/A Turbine Building Excavated Surface 3. Remediated and resurveyed.

TBCq 1 Exceeded 4. Survey unit satisfied the criteria for unrestricted use.

1. Isolated and initiated survey investigation.

Investigation 2. Residual radioactivity exceeded the scan DCGL.

CanalC 11 1 Level N/A Discharge Canal Surface 3. Remediated and resurveyed.

Exceeded 4. Survey unit satisfied the criteria for unrestricted use.

1. Isolated and initiated survey investigation.

Investigation Relocated Soil From Slurry Wall 2. Residual radioactivity exceeded the scan DCGL.

SWCx 21 1 Level N/A Excavation 3. Remediated and resurveyed.

Exceeded 4. Survey unit satisfied the criteria for unrestricted use.

23

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. When 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 data were reviewed to ensure that they were complete, fully documented, and technically acceptable. The review criteria for data acceptability included the following items:

" The instrumentation MDC for fixed or volumetric measurements was below the DCGLEMc for Class 1, below the DCGLwfor Class 2, and below 0.5 DCGLwfor Class 3 survey units;

" The instrument calibration was current and traceable to NIST standards;

" The field instruments were source checked with satisfactory results each day data was collected or data was evaluated if instruments did not pass a response check;

" The MDCs and assumptions used to develop them were appropriate for the instruments and techniques used to perform the survey;

" The survey methods used to collect data were proper for the types of radiation involved and for the media being surveyed;

" "Special methods" for data collection were properly applied for the survey unit under review, if applicable;

" The chain-of-custody was 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

" 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 documented in accordance with approved site procedures.

4.1.2 Graphical Data Review Survey data were graphed to identify patterns, 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 and is included in each survey package.

24

Big Rock Point Restoration Project Final Status Survey Report 4.1.3 Statistical Analysis License Termination Plan Chapter 5, Section 5.6 provides guidance for the use of statistical analysis to determine whether the survey unit meets the release criteria. As all survey units met the release criteria, statistical analysis as provided in the LTP was not required.

4.2 Summary of Changes from Initial Assumptions on Residual Radioactivity 4.3 There were no changes from the initial assumptions on residual radioactivity as described in the LTP.

4.4 Release Criteria Verification An assessment was performed on all final status or supporting survey data to ensure that they were adequate to support the determination that the survey unit met the criteria for unrestricted release. For each survey unit three tests or evaluations were performed to ensure that the release criteria were met. These tests are summarized below in Table 4-1.

4.3.1 Condition #1 - Mean Test This condition requires that the mean residual radioactivity was less than the 1.0 x DCGLw. To determine if this condition was met, the mean of the final survey unit data set for each survey unit was compared to the DCGLw (applying the unity rule). In all cases the mean residual radioactivity was less than 0.0549 x DCGLw. Therefore, each survey unit satisfied Condition #1.

4.3.2 Condition #2 - Elevated Measurement Comparison The Elevated Measurement Comparison (EMC) test requires that individual measurement representing small areas of residual radioactivity exceeding the DCGLw did not exceed the DCGLEMc. Since all measurements were less than the DCGLw, an EMC was not required for any survey unit and Condition #2 was automatically satisfied for all survey units.

4.3.3 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.

25

Big Rock Point Restoration Project Final Status Survey Report 4.4 ALARA Evaluation In accordance with the release criteria (Section 1.3) an evaluation was 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.

4.5 Memorandum Of Understanding Between NRC and EPA On Cleanup Of Radioactively Contaminated Sites 4.5.1 Soil Final Status Survey data was compared to the NRC and EPA MOU Table 1 Consultation Triggers for Residential and Commercial/Industrial Soil Contamination Concentrations. The more restrictive "Residential Soil Concentration" data was utilized. Final Status Survey sample data provides that the trigger concentrations for contamination were not exceeded.

Table 4-1 Comparison of BRP Maximum Single Sample Concentration to NRC/EPA MOU Table 1 BRP Maximum MOU Table 1 Nuclide Concentration Residential Soil Fraction in a Sample Concentration (pCi/g) (pCi/g)

H3 19.0800 228 0.0837 Co-60 1.6100 4 0.4025 Cs-137+D 2.6970 6 0.4495 Sum of the fractions. If less than 0.9357 one, consultation not required.

4.5.2 Groundwater All groundwater monitoring well sample data post remediation were below the EPA drinking water MCL for tritium of 20,000 pCi/L. No upward trends in the data provided in this report were indicated, demonstrating that the hydrogeologic evaluation and stated conclusions in the LTP are valid.

26

Big Rock Point Restoration Project Final Status Survey Report 5.0 Final 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 release and that that all remaining surface and associated subsurface land areas were evaluated against the criteria for unrestricted release. The final survey data presented in this summary report demonstrate compliance with 10 CFR 20.1402 and the site impacted and non-impacted land areas meet the criteria for unrestricted release.

The information contained in this submittal, together with the information provided in prior submittals is sufficient for the NRC to make a determination equivalent to 10 CFR 50.82(a)(1 1) regarding the lands to be released from the license. Once these lands are so released, it is understood that the NRC will not require any additional surveys or decontamination of these areas unless the NRC determines that the criteria of 10 CFR Part 20, Subpart E were not met and that residual activity remaining on the land could result in a significant threat to public health and safety.

6.0 References

1. Big Rock Point License Termination Plan
2. U.S. Nuclear Regulatory Commission NUREG-1 575, Multi-Agency Radiation Survey And Site Investigation Manual (MARSSIM)
3. U.S. Nuclear Regulatory Commission NUREG-1727, NMSS Decommissioning Standard Review Plan 27

Big Rock Point Restoration Project Final Status Survey Report Appendix A - Big Rock Point Impacted and Non-Impacted Areas N

LAKE MICHIGAN UJS31 Legend Impacted Areas Non-hnpacted Areas 0 250 500 Scale: I I I I I I I I 'Meters 28

Big Rock Point Restoration Project Final Status Survey Report Appendix B - Big Rock Point Final Status Survey Units 1 of 2 14 582R)15(2) 13 12

- -23... 16

_3 4/ 9 110 North 21 7T 8 7 17

___ 24 North 19 East 22 29

Big Rock Point Restoration Project Final Status Survey Report Appendix B - Big Rock Point Final Status Survey Units 2 of 2

/

//

//

Non-Impacted Aiea 59C1 3

/

I 30

Big Rock Point Restoration Project Final Status Survey Report Appendix C - Big Rock Point Tritium Plume Map 14-12 15(2) 16 13 3 ~ 4I A,

  • 1o 2 8 North 21 17 7

18 North 19 1 6 242 O Legend

-- Tritium Plume in Shallow GroundwaterZone

-_ Tritium Plume inIntermediate GroundwaterZone

-- Tritium Plume in Bedrock Groundwater Zone 31

Big Rock Point Restoration Project Final Status Survey Report Appendix D - Groundwater Monitoring Well Locations hmL6cPZ. 3 SS NW-5

  • 0z-5 PZ.4S mVV-I PZ-7M4 Z17M
  • W49 P 2D P2 4PZ2M kI9N8 PZ-9N
  • VZ-Sha PZ-6S

.PZ.3s PZ-ID

  • pz.Is 0,z-1m Well Feet (BGL) Well Feet (BGL) Well Feet (BGL)

MW 1 19.0 PZ-1S 12.0 PZ-1D 86.0 MW 2 24.0 PZ-2S 8.0 PZ-2D 50.0 MW 3 20.0 PZ-3S 9.0 PZ-3D 51.5 MW 4 24.0 PZ-4S 11.5 PZ-7M 23.0 MW 5 24.0 PZ-5S 13.0 PZ-7Ma 33.5 MW 6 19.0 PZ-6S 13.0 PZ-8M 35.0 MW 7 29.0 PZ-1M 30.5 PZ-8Ma 44.0 MW 8 45.0 PZ-2M 25.0 PZ-9M 28.0 MW 9 16.0 PZ-3Ma 32.1 PZ-9Ma 41.0 PZ-3Mb* 20.0

  • PZ-3Mb also identified as PZ-3M 32

Big Rock Point Restoration Project Final Status Survey Report Appendix E - Final Status Survey Submittal Matrix Page 1 of 3 SURVEY RECORD2 LETTER SURVEY NMECORD 2SURVEY AREA DESCRIPTION DATE AREA' NUMBER IDATE CLASS 1 AREAS - FINAL STATUS SURVEY OF SURFACES 1 01C 11 Class 1 Final Status Release Record, South West Protected Area 10/13/06 2 02C 11 Class 1 Final Status Release Record, West Central Protected Area 10/13/06 3 03C11 Class 1 Final Status Release Record, North West Protected Area 10/24/06 4 04C 1 1 Class 1 Final Status Release Record, North Central Protected Area 10/10/06 5 05C, 1 Class 1 Final Status Release Record, Central Protected Area 10/24/06 6 06C, 1 Class 1 Final Status Release Record, South Central Protected Area 10/24/06 7 07C, 1 Class 1 Final Status Release Record, South East Protected Area 10/27/06 10/27/06 8 08C 1 1 Class 1 Final Status Release Record, East Central Protected Area Errata 11/2/06 9 09C 1 1 Class 1 Final Status Release Record, North East Protected Area 10/13/06 10 10C 1 1 Class 1 Final Status Release Record, East Protected Area 10/27/06 ill North11C, 1 Class 1 Final Status Release Record, North Radwaste Staging Area 10/27/06 11 SouthC11C 1 Class 1 Final Status Release Record, South Radwaste Staging Area 10/31/06 15 15(2R)C 1 1 Class 1 Final Status Release Record, Woods Road Storage Area 10/9/06 20 20C,1 Class 1 Final Status Release Record, East Radwaste Staging Area 10/31/06 10/10/06 23 23C1 l Class 1 Final Status Release Record, North Protected Area Errata 11/2/06 24 24C1 1 Class 1 Final Status Release Record, South Protected Area 4 11/08/06 CLASS 1 AREAS- EXCAVATED SOIL FINAL STATUS SURVEYS 2 02Cxi 1 Class 1 Final Status Survey, Excavated Soil from Retention Pond Construction 10/9/06 8 08Cx 1 Class 1 Final Status Survey, Excavated Soil from Turbine Building 10/9/06 08Cx__1_ Subfloor 9 09Cx 1l Class 1 Final Status Survey, Excavated Soil from Screenhouse Area 10/9/06 9 09Cx2 1 Class 1 Final Status Survey, Excavated Soil from Screenhouse Area 10/9/06 9 09Cx3 1 Class 1 Final Status Survey, Excavated Soil from Screenhouse Area 10/9/06 9 09Cx4 1 Class 1 Final Status Survey, Excavated Soil from Screenhouse Area 10/9/06 9 09Cx 51 Class 1 Final Status Survey, Excavated Soil from Screenhouse Area 10/9/06 9 09Cx6 1 Class 1 Final Status Survey, Excavated Soil from Screenhouse Area 10/9/06 9 09Cx 71 Class 1 Final Status Survey, Excavated Soil from Screenhouse Area 10/9/06 11 1lCx 1l Class 1 Final Status Survey, Excavated Soil from Radwaste Storage 10/9/06 11__11Cx__ 1 Vaults Slurry5 Wall Slurry Wall Class 1 Final Status Survey, Excavated Soil from Slurry Wall 10/9/06 Wall Cxii1 Construction1096 Slurry Wall Slurry Cx 1 Wall Class 1 Final Status Survey, Excavated Soil from Slurry Wall Construction 10/9/06 2

Turbine Class 1 Supporting Survey- Soil Excavated from Turbine Building Building6 TBCx1 1 Removal Area, Supporting Subsurface Structure and Component Demolition 10/9/06 1 Survey Area Map - Big Rock Point License Termination Plan, Chapter 5, figure 5-3, Initial Land Area Survey Units 2 Record Number nomenclature is defined in Procedure RM-76, Final Status Survey Design, step 6.2, Survey Unit Nomenclature 3 Surface of survey unit 11 was divided into North and South areas due to intermediate use of land between the quarry survey and the final surface survey (served as solid Radwaste storage yard in interim.)

4 Soils removed from Class 1 Area excavations 5 Slurry Wall crossed several survey areas on the ease, south, and west sides of the protected area.

6 Turbine building excavation was beneath survey areas 5, 6, and 8 33

Big Rock Point Restoration Project Final Status Survey Report Appendix E - Final Status Survey Submittal Matrix Page 2 of 3 ORD 2Y SURVEY AREA DESCRIPTION LETTER AREA1 NUMBER DATE Turbine Class 1 Supporting Survey- Soil Excavated from Turbine Building Building TBCx2 1 Demolition Area, Supporting Subsurface Structure and Component 10/9/06 Removal Turbine Class 1 Supporting Survey- Soil Excavated from Turbine Building Building TBCx 31 Demolition Area, Supporting Subsurface Structure and Component 10/9/06 Removal Turbine Class 1 Supporting Survey- Soil Excavated from Turbine Building Building TBCx4 1 Demolition Area, Supporting Subsurface Structure and Component 10/9/06 Removal Turbine Class 1 Supporting Survey- Soil Excavated from Turbine Building Building TBCx 51 Demolition Area, Supporting Subsurface Structure and Component 10/9/06 Removal Turbine Class 1 Supporting Survey- Soil Excavated from Turbine Building Building TBCx61 Demolition Area, Supporting Subsurface Structure and Component 10/9/06 Removal Turbine Class 1 Supporting Survey- Soil Excavated from Turbine Building Building TBCx 71 Demolition Area, Supporting Subsurface Structure and Component 10/9/06 Removal Turbine TBCxal Class 1 Supporting Survey - Relocated Soil from Turbine 10/9/06 Building Building/Containment Demolition Turbine TBCxg1 Class 1 Supporting Survey - Relocated Soil from Turbine 10/9/06 Building Building/Containment Demolition Turbine TBCx 1 1 Class 1 Relocated Soil Supporting Survey Release Record - 8/24/06 Buildin T Relocated Soils from Turbine Building/Containment Demolition Turbine TBCxI Class 1 Relocated Soil Supporting Survey Release Record - 8/24/06 Building Relocated Soils from Turbine Building/Containment Demolition Turbine Class 1 Relocated Soil Supporting Survey Release Record - 9/20/06 Building Bxq Relocated Soils from Turbine Building/Containment Demolition Building TRelocated Soils from Turbine Building/Containment Demolition Turbine Class 1 Relocated Soil Supporting Survey Release Record - 10/10/06 Building BRelocated Soils from Turbine Building/Containment Demolition Turbine TBCX1 Class 1 Relocated Soil Supporting Survey Release Record - 10/24/06 Building _Relocated Soils from Turbine Building/Containment Demolition CLASS 1 AREAS - FINAL STATUS SURVEY - SUBSURFACE (QUARRY) 9 09Cql 1 Class 1 Final Status Survey, Screenhouse Area Excavation 10/9/06 11 11Cq 1 Class 1 Final Status Survey, Solid Radwaste Storage Area 10/9/06

___________Excavation Containment 7 CSCq,1 Excavated Surface Supporting Survey Release Record - Base 8/24/06 Elevation Survey of Containment Structure Excavation Circulating Excavated Surface Supporting Survey Release Record - Base 8/24/06 Water Piping CWCqi 1 Elevation Survey of Circulating Water Piping Excavation Turbine East TBCq 11 Class 1 Final Status Release Record, Turbine Building East 4/03/06 Buildin _______ Excavation Surface Turbine West Excavated Surface Supporting Survey Release Record - Base Building TBCq1 1 Elevation Survey of the Turbine Building Excavation Following 8/24/06 Removal of West-Side Foundations and Subsurface Components DischarPe Canal Cq11 Class 1 Final Status Survey, Discharge Canal 10/9/06 Canal I 7 Containment quarry was beneath survey areas 4, 5, 8, and 9. Circulation Water quarry was beneath survey areas 7, 8, 9, and 10. Turbine Building quarry was beneath survey areas 5, 6, and 8 8 Discharge Canal is North East of the Protected Area 34

Big Rock Point Restoration Project Final Status Survey Report Appendix E - Final Status Survey Submittal Matrix Page 3 of 3 SURVEY RECORD 2 LETTER AREA1 NUMBER SURVEY AREA DESCRIPTION DATE CLASS 2 AREAS - FINAL STATUS SURVEY OF SURFACE 12 12C 12 Class 2 Final Status Survey Release Record, Shoreline North of the 8/24/06 12 _ 12C_2 Protected Area 15 15(1)C 12 Class 2 Final Status Survey Release Record, Eastern Section Woods 10/30/06 Road Area 15 15(2)C 12 2 Final Status Survey Release Record, Central Section Woods Class Area 8/24/06 Road 16 16C 12 Class 2 Final Status Survey Release Record, Shoreline East of 8/24/06 Breakwall 19 Northl9C 2 1 Class Route 2 Final Status Survey Release Record, North West Transport 10/30/06 19_North19C_2 19 Southl9C,2 Class Route 2 Final Status Survey Release Record, South West Transport 11/08/06 19_South19C_2 21 North2lC,2 Class Route 2 Final Status Survey Release Record, North East Transport 11/08/06 21_No__h21C_2 21 South2lC,2 Class Route 2 Final Status Survey Release Record, South East Transport 11/08/06 21_South21C_2 22 East22C12 Class 2 Final Status Survey Release Record, East Powerline 11/08/06 Corridor 22 West22C,2 Class 2 Final Status Survey Release Record, West Powerline 11/08/06 Corridor 26 26C,2 Class 2 Final Status Release Record, Drainage Ditch, South and 1108/06 West of the Industrial Area Septic Drain DFC12 Class 2 Final Status Survey Release Record, Septic Field Drain 8/24/06 Field9 CLASS 2 AREAS - EXCAVATED SOIL FINAL STATUS SURVEYS 12 12Cx,2 Class 2 Final Status Survey Record, Excavated Soil from Building 10/9/06 12__12Cx_2 Construction 19 19Cx,2 Final Status Survey Record, Excavated Soil from Storm Class 2Modification 10/9/06 Drain CLASS 3 AREAS - FINAL STATUS SURVEY OF SURFACE 13 13C 13 Class Site Status Survey Release Record, Shoreline East of the 3 Final Industrial 8/24/06 14 14C 13 Class 3 Final Status Survey Release Record, Shoreline West of the Industrial Site 8/24/06 17 17C 13 Class 3 Final Status Survey Release Record, East Woods Boundary 10/30/06 18 18C 13 Class 3 Final Status Survey Release Record, Wooded Area West of 10/9/06 18___18C___3 Industrial Site 25 25 _

25Ci3 25C3_

Class 3 Final Status Survey Release Record, South Woods Boundary 11/08/06 59 Class 3 Final Status Survey Release Record, Soil Storage Area 10/9/06 959C3 South of US 31 Septic Field Drain survey area is contained within survey area 15(1) 35

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