Text

Transmittal of Survey Packages in Support of Big Rock Point Phased License Termination
	ML070600673
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	10/24/2006
From:	Haas K; Consumers Energy
To:	; Document Control Desk, NRC/FSME
References
	Download: ML070600673 (161)
	v • d • e

ConsursEneWj A CMS Energy Company Big Rock Point Nuclear Plant Kurt A. Haas 10269 US-31 North General Manager Charlevoix, MI 49720 October 24, 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 -

TRANSMITTAL OF SURVEY PACKAGES IN SUPPORT OF BIG ROCK POINT PHASED LICENSE TERMINATION

References:

1. U.S. NRC to Big Rock Point dated March 24, 2005, Big Rock Point - Issuance of Amendment 126 to Approve the License Termination Plan (TAC No. L52096)

2. Big Rock Point to U.S. NRC dated September 27, 2005, Revision 2 of the Big Rock Point License Termination Plan

3. Big Rock Point to U.S. NRC dated April 3, 2006, Letter of Intent Concerning the Release of Part of the Big Rock Point Site Property from the 10 CFR Part 50 License.

4. U.S. NRC to Big Rock Point dated April 25, 2006, Report of April 12, 2006 Meeting to Discuss Partial Site Release and Final Status Survey Report Content

5. Big Rock Point to U.S. NRC dated August 24, 2006, Transmittal of Excavated Surface Surveys, Relocated Soil Surveys and Final Status Survey Packages in Support of Big Rock Point Phased License Termination

6. Big Rock Point to U.S. NRC dated September 19, 2006, Transmittal of Relocated Soil Survey Packages in Support of Big Rock Point Phased License Termination

7. Big Rock Point to U.S. NRC dated October 9, 2006, Transmittal of Survey Packages in Support of Big Rock Point Phased License Termination

8. Big Rock Point to U.S. NRC dated October 10, 2006, Transmittal of Survey Packages in Support of Big Rock Point Phased License Termination

9. Big Rock Point to U.S. NRC dated October 13, 2006, Transmittal of Survey Packages in Support of Big Rock Point Phased License Termination Attachment I contains a matrix of Final Status Survey (FSS) record numbers, survey area descriptions, and review status. This attachment is a revision to attachment of our letter dated October 13, 2006. It contains a list of the final status survey release records expected to be submitted in support of our FSS report. This FSS report is expected to be submitted on or around the fifteenth of November. Also attached, are the following survey release records:

CLASS 1 FINAL STATUS SURVEY RELEASE RECORDS

North West Protected Area (Attachment 2)

Central Protected Area (Attachment 3)

South Central Protected Area (Attachment 4)

CLASS 1 RELOCATED SOIL SUPPORTING SURVEY RECORD

Relocated Soils from Turbine Building/Containment Demolition (Attachment 5)

These records are being provided to facilitate U.S. Nuclear Regulatory Commission review, as discussed in our April 12, 2006 meeting. Attachments 2,Lnd 3 to this letter comprise those portions of survey packages which may be of use for final review and will be summarized in our FSS report.

The phased release approach is described in Sections 1.4.2 and 5.1.2 of the BRP License Termination Plan (LTP). BRP intends to release site land from the 10 CFR Part 50 license using this phased approach. The first phase includes the majority of the site land scheduled for release after all demolition, remediation and FSS activities associated with plant operation are complete.

BRP LTP Chapter 5 commits BRP to producing FSS package(s) for each survey area and outlines the contents of each supporting survey package.

The intended partial site release supports the process of license termination by demonstrating that an additional portion of the remaining site lands can be released from the Site license. This letter, along with completed and future on-site inspections and letters, provides documentation that demolition activities have been performed in accordance with the LTP.

Your timely review of FSS information and approval of our request to release the associated land is particularly important to the project and smooth transition to an Independent Spent Fuel Storage Installation (ISFSI)-only operation.

If you have any questions or comments on these reports, please contact Ken Pallagi, Radiation Protection and Environmental Services Manager at 231-547-8416.

Kurt M. Haas Site General Manager ATTACHMENTS 2 cc: Administrator, Region Il, USNRC (w/o Attachments)

NRC Decommissioning Inspector, Big Rock Point (w/o Attachments)

NRC NMSS Project Manager, James Shepherd (w/o Attachments)

NRC NMSS FSS Reviewer, Bruce Watson Michigan Department of Environmental Quality, Thor Strong (w/o Attachments)

ATTACHMENT I CONSUMERS ENERGY BIG ROCKPO1NT DOCKET NUMBERS 50-155 AND 72-043 TRANSMITTAL OF SURVEY PACKAGES IN SUPPORT OF BIG ROCK POINT PHASED LICENSE TERMINATION MATRIX OF FSS SUPPORTING DOCUMENTATION October 24, 2006 5 Pages

MATRIX OF BIG ROCK POINT FINAL STATUS SURVEY REPORTS SURVEY RECORD2 PACKAGE U.S. NRC PACKAGE LETTER AREA' NUMBER SURVEY AREA DESCRIPTION SIGNOFF REVIEW REVIEW DATE DATE METHOD DATE CLASS 1 AREAS - FINAL STATUS SURVEY OF SURFACES I 01Ci1 Class I Final Status Release Record, South West Protected Area 10/11/06 Letter 10/13/06 2 02C1 1 Class IFinal Status Release Record, West Central Protected Area 10/11/06 Letter 10/13/06 3 03C, I Class IFinal Status Release Record, North West Protected Area 10/16/06 Letter 10/24/06 4 04C,1 Class IFinal Status Release Record, North Central Protected Area 10/04/06 Letter 10/10/06 5 05C 1I Class IFinal Status Release Record, Central Protected Area 10/16/06 Letter 10/24/06 6 06C, 1 Class 1 Final Status Release Record, South Central Protected Area 10/23/06 Letter 10/24/06 7 07C, I Class IFinal Status Release Record, South East Protected Area 8 08C, 1 Class IFinal Status Release Record, East Central Protected Area 9 09C 1 I Class I Final Status Release Record, North East Protected Area 10/04/06 Letter 10/13/06 10 10C 1 Class I Final Status Release Record, East Protected Area III North 1IC 1 Class IFinal Status Release Record, North Radwaste Staging Area 11 South] 1C, 1 Class IFinal Status Release Record, South Radwaste Staging Area On-Site Inspection 06/13-14/06 10/9/06 15 15(2R)C 1I Class IFinal Status Release Record, Woods Road Storage Area 05/23/06 and LetterIsetn 0/ 146090 20 20C, I Class IFinal Status Release Record, East Radwaste Staging Area 23 23C,1 Class IFinal Status Release Record, North Protected Area 10/05/06 Letter 10/10/06 24 24C, I Class IFinal Status Release Record, South Protected Area Inspection DiscargeOn-Site Discharge 4 Canal C, 1 Class I Final Status Survey, Discharge Canal 01/27/05 On-Site 06/13-14/06 10/9/06 Canal _____________________________________________and Letter_______________

CLASS 1 AREAS- EXCAVATED SOIL FINAL STATUS SURVEYS' 2 02Cxj I Class I Final Status Survey, Excavated Soil from Retention Pond 10/13/2004 On-Site Inspection 06/13-14/06 10/9/06 Construction and Letter 8 08Cxl Class I Final Status Survey, Excavated Soil from Turbine Building 05/16/05 On-Site Inspection 06/13-14/06 10/9/06 Subfloor and Letter On-Site Inspection 10/9/06 Area 1 Final Status Survey, Excavated Soil from Screenhouse 9 09Cxj 1 Class 12/09/04 and Letter 06/13-14/06 9 09CX21 Area I Final Status Survey, Excavated Soil from Screenhouse Class 12/08/04 On-Site and letterInspection 06/13-14/06 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 Discharge Canal is North East of the Protected Area 5 Soils removed from Class I Area excavations Page 1 of 5

MATRIX OF BIG ROCK POINT FINAL STATUS SURVEY REPORTS SURVEY RECORD2 PACKAGE U.S. NRC PACKAGE LETTER AREA' NUMBER SURVEY AREA DESCRIPTION SIGNOFF REVIEW REVIEW DATE DATE METHOD DATE 12/09/04 On-Site Inspection 06/13-14/06 10/9/06 9 0 Area I Final Status Survey, Excavated Soil from Screenhouse Class and letter 9 09CX41 Class 1 Final Status Survey, Excavated Soil from Screenhouse 12/09/04 On-Site Inspection 06/13-14/06 10/9/06 Area and letter 9 Class I Final Status Survey, Excavated Soil from Screenhouse 12/14/04 On-Site Inspection 06/13-14/06 10/9/06 9 09CX61 Class I Final Status Survey, Excavated Soil from Screenhouse Area 01/19/05 and LetterInspection On-Site 06/13-14/06 10/9/06 9 09CX1 Class I Final Status Survey, Excavated Soil from Screenhouse 05/16/05 On-Site Inspection 06/13-14/06 10/9/06 Area and Letter II Cx Class I Final Status Survey, Excavated Soil from Radwaste 10/13/04 On-Site Inspection 06/13-14/06 10/9/06 Storage Vaults and Letter Slurry6 Wall Cxurr Slurry Wal Wall Constructiona Class I Final SttuSreyEcaaedSo__rmluryWll_2080 Status Survey, Excavated Soil from Slurry Wall 12/08/04 On-SiteInspection On-Site Inspection 06/13-14/06__

06/13-14/06 10/9/06__

10/9/06 Cxjl Construction and Letter Slurry Wall Slurry Wall Class I Final Status Survey, Excavated Soil from Slurry Wall 12/20/04 On-Site Inspection 06/13-14/06 10/9/06 Cx 2 1 Construction and Letter Turbine Class I Supporting Survey- Soil Excavated from Turbine Building On-Site Inspection Building7 TBCxj I Demolition Area, Supporting Subsurface Structure and Component 08/24/05 and Letter 06/13-14/06 10/9/06 Removal Turbine Class I Supporting Survey- Soil Excavated from Turbine Building On-Site Inspection 10/13/05 and Letter 06/13-14/06 10/9/06 Building TBCx21 Demolition Area, Supporting Subsurface Structure and Component Removal Turbine Class I Supporting Survey- Soil Excavated from Turbine Building On-Site Inspection 11/23/05 and Letter 06/13-14/06 10/9/06 Building TBCX31 Demolition Area, Supporting Subsurface Structure and Component Removal Turbine Class I Supporting Survey- Soil Excavated from Turbine Building On-Site Inspection Demolition Area, Supporting Subsurface Structure and Component 11/23/05 and Letter 06/13-14/06 10/9/06 Building TBCX41 Removal Turbine Class I Supporting Survey- Soil Excavated from Turbine Building On-Site Inspection Demolition Area, Supporting Subsurface Structure and Component 01/06/06 and Letter 06/13-14/06 10/9/06 Building TBCx5I Removal Turbine Class I Supporting Survey- Soil Excavated from Turbine Building On-Site Inspection 07/03/06 and Letter 06/13-14/06 10/9/06 Building TBCX61 Demolition Area, Supporting Subsurface Structure and Component Removal Turbine Class 1 Supporting Survey- Soil Excavated from Turbine Building On-Site Inspection 07/05/06 and Letter 06/13-14/06 10/9/06 Building TBCX71 Demolition Area, Supporting Subsurface Structure and Component Removal 6 Slurry Wall crossed several survey areas on the ease, south, and west sides of the protected area.

7 Turbine building excavation was beneath survey areas 5, 6, and 8 Page 2 of 5

MATRIX OF BIG ROCK POINT FINAL STATUS SURVEY REPORTS SURVEY RECORD' PACKAGE U.S. NRC PACKAGE LETTER AREA' NUMBER SURVEY AREA DESCRIPTION SIGNOFF REVIEW REVIEW DATE DATE METHOD DATE Turbine TBCxg1 Class I Supporting Survey- Relocated Soil from Turbine 07/03/06 On-Site Inspection 06/13-14/06 10/9/06 Building Building/Containment Demolition and Letter Turbine TBCx91 Class I Supporting Survey - Relocated Soil from Turbine 07/03/06 On-Site Inspection 06/13-14/06 10/9/06 Building Building/Containment Demolition and Letter Turbine TBCxj01 Class 1 Relocated Soil Supporting Survey Release Record - 08/03/06 Letter 8/24/06 Building Bx 1 I Relocated Soils from Turbine Building/Containment Demolition ________________

Turbine Class I Relocated Soil Supporting Survey Release Record - 08/14/06 Letter 8/24/06 Building TBCx,1 I Relocated Soils from Turbine Building/Containment Demolition Turbine TB~x121 Class I Relocated Soil Supporting Survey Release Record - 9/6/06 Letter 9/20/06 Building Relocated Soils from Turbine Building/Containment Demolition Turbine TBCx131 Class I Relocated Soil Supporting Survey Release Record - 9/6/06 Letter 9/20/06 Building Relocated Soils from Turbine Building/Containment Demolition Turbine TBCx141 Class 1 Relocated Soil Supporting Survey Release Record - 09/15/06 Letter 10/10/06 Building TBCx 41 Relocated Soils from Turbine Building/Containment Demolition Turbine Class I Relocated Soil Supporting Survey Release Record - 10/23/06 Letter 10/24/06 Building BRelocated Soils from Turbine Building/Containment Demolition CLASS 1 AREAS - FINAL STATUS SURVEY - SUBSURFACE (QUARRY) On-Site Inspection 06/13-14/06 10/9/06 09Cq1 I Class I Final Status Survey, Screenhouse Area Excavation 12/20/04 and Letter Isetn 0/ 146090 11 11 Cq I Class I Final Status Survey, Solid Radwaste Storage Area 10/13/04 On-Site Inspection 06/13-14/06 10/9/06 Excavation and Letter Containment8 CSCqj I Excavated Surface Supporting Survey Release Record - Base 08/03/06 Letter 8/24/06 Elevation Survey of Containment Structure Excavation Circulating CWCqj Excavated Surface Supporting Survey Release Record - Base 08/07/06 Letter 8/24/06 Water Piping Elevation Survey of Circulating Water Piping Excavation Turbine East TBCqj I Class 1 Final Status Release Record, Turbine Building East 03/30/06 Letter 4/03/06 Building Excavation Surface Turbine Excavated Surface Supporting Survey Release Record - Base West TBCq1 1 Elevation Survey of the Turbine Building Excavation Following 08/14/06 Letter 8/24/06 Building Removal of West-Side Foundations and Subsurface Components 8 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 Page 3 of 5

MATRIX OF BIG ROCK POINT FINAL STATUS SURVEY REPORTS SURVEY RECORD2 PACKAGE U.S. NRC PACKAGE LETTER AREA' NUMBER SURVEY AREA DESCRIPTION SIGNOFF REVIEW REVIEW DATE DATE METHOD DATE CLASS 2 AREAS - FINAL STATUS SURVEY OF SURFACE Class 2 Final Status Survey Release Record, Shoreline North of the 08/14/06 Letter 8/24/06 12 12C 1 2 Protected Area Class 2 Final Status Survey Release Record, Eastern Section 15 15(1)C 12 Woods Road Area 15 15(2)C,2 Class 2 Final Status Survey Release Record, Central Section 08/09/06 Letter 8/24/06 Woods Road Area 16 16C,2 Class 2 Final Status Survey Release Record, Shoreline East of 08/14/06 Letter 8/24/06 Breakwall Release Record, North West Transport 19 North 19C12 Route 2 Final Status Survey Class Survey Release Record, South West Transport 19 Southl19C 12 Route 2 Final Status Class Class 2 Final Status Survey Release Record, North East Transport 21 North2CC2 1 Route Class 2 Final Status Survey Release Record, South East Transport 21 South2C1C2 Route Class 2 Final Status Survey Release Record, East Powerline 22 East22C12 Corridor Class 2 Final Status Survey Release Record, West Powerline 22 West22C 12 Corridor Status Release Drainage Ditch, South and 26 26C 12 Class 2 Final West of the Industrial Area Record, Septic Drain DFC,2 Class 2 Final Status Survey Release Record, Septic Field Drain 08/14/06 Letter 8/24/06 Field9 IIIII CLASS 2 AREAS - EXCAVATED SOIL FINAL STATUS SURVEYS 12 12Cx,2 Class 2 Final Status Survey Record, Excavated Soil from Building 12/07/04 On-Site Inspection 06/13-14/06 10/9/06 Construction and Letter 1 19 19Cx,2 Class 2 Final Status Survey Record, Excavated Soil from Storm 12/02/04 On-Site Inspection 06/13-14/06 10/9/06 Drain Modification and Letter 9 Septic Field Drain survey area is contained within survey area 15(1)

Page 4 of 5

MATRIX OF BIG ROCK POINT FINAL STATUS SURVEY REPORTS SURVEY RECORD2 PACKAGE U.S. NRC PACKAGE LETTER AREA1 NUMBER SURVEY AREA DESCRIPTION SIGNOFF DATE REVIEW METHOD REVIEW DATE DATE CLASS 3 AREAS - FINAL STATUS SURVEY OF SURFACE 13 13C,3 Class 3 Final Status Survey Release Record, Shoreline East of the 08/14/06 Letter 8/24/06 13__13C_3 Industrial Site 14 14C,3 Class 3 Final Status Survey Release Record, Shoreline West of the 08/17/06 Letter 8/24/06 14___4C_3 Industrial Site 17 17C,3 Class 3 Final Status Survey Release Record, East Woods Boundary 18 18C,3 Class 3 Final Status Survey Release Record, Wooded Area West of 07/03/06"0 On-Site Inspection 06/13-14/06 10/9/06 18 _ 18C3 Industrial Site and Letter Class 3 Final Status Survey Release Record, South Woods 25 -I 25C13 Boundary 59 59C, Class 3 Final Status Survey Release Record, Soil Storage Area 07/03/06 On-Site Inspection 06/13-14/06 10/9/06 1 South of US 31 and Letter I _I 1oRevisions to packages signed after NRC review were administrative only - no changes to technical content.

Page 5 of 5

ATTACHMENT 2 CONSUMERS ENERGY BIG ROCKPOINT DOCKET NUMBERS 50-155 AND 72-043 TRANSMITTAL OF SURVEY PACKAGES IN SUPPORT OF BIG ROCK POINT PHASED LICENSE TERMINATION CLASS I FINAL STATUS SURVEY RELEASE RECORD, 03C 1 1, NORTH WEST PROTECTED AREA October 24, 2006 37 Pages

Class I Final Status Survey Release Record 03C1 l North West Protected Area SURVEY PACKAGE CLOSURE Final Status Survey Documentation is authorized for closure. All required reviews are complete and the evaluation of data results have satisfied the criteria established for unrestricted release.

Signed: Date: /e)/6'-'-,

/ (ESSG)

Y Signed: Date: /0-/(Df, (ES "Superintendent)

Signed: Date: /o-/*-06

/ (RP & ES Manager)

Survey Area Requirements Final Status Survey, Release Record 03C 1 1 North West Protected Area Survey Description Final Status Survey 03C 11 encompasses 1956 m2 at or below the grade elevation present during plant power operations in the north west section of the Protected Area. No materials of plant origin remain in the survey area.

History During power operations the Protected Area supported the components and systems necessary for electrical generation. The location of Survey Unit 03 is adjacent to the transport route used to move spent resin and filter media for radiological survey and offsite removal. Structures and enclosures formerly located in this area were once used for the storage of contaminated materials. A detailed review of the history and radiological characterization of Survey Unit 3 is provided in Appendix 2B and 2E of the LTP (License Termination Plan).

Current Radiological Status Scoping measurements and supporting surveys performed in the Protected Area following removal of subsurface components and demolition debris do not indicate the presence of elevated levels of residual radioactivity in this survey area. Based on operational history and former locations of radioactive systems and material transport pathways the radiological status of this survey unit is Class 1.

Post-Construction Expectations Final Status Survey 03C11 will be performed in the following activity sequence:

1. Walkdown: Environmental Services Survey Group (ESSG) personnel will perform a walkdown assessment to ensure survey area preparations are complete and confirm that the following post-construction expectations have been satisfied as applicable:

" Groundwater and Surface water control is adequate

All construction debris has been removed from the survey area

" The survey location status meets all applicable safety requirements

2. Survey Area Isolation and Control: Control measures will be established to ensure that any potential ongoing decommissioning activities in adjacent locations do not impact the current survey area status. Isolation and control measures include postings, barriers, access points, and the evaluation of ongoing work activities in adjacent areas.

Survey Area Requirements FSS 3C 11 Page 1 of 2

3. Survey Design and Execution: Survey design and execution will follow the Data Quality Objectives for 03Cl1 in accordance with the survey requirements established in procedures RM-76, Final Status Survey Design and RM-77, FinalStatus Survey Implementation, and LTP, Chapter 5. Survey size will be based on the statistical requirements of the Sign Test for Class 1 areas with soil samples collected in random start, systematic data point locations. Surface scanning will be performed with 100%

survey area coverage. This survey will be conducted in accordance with approved BRP procedures and follow the guidance of NUREG 1575.

4. Data Quality Assessment: Isolation and control of the survey area will be maintained until the survey Data Quality Assessment demonstrates that the regulatory requirements for unrestricted site release have been satisfied.

Survey Area Requirements FSS O3C1 Page 2 of 2

DATA QUALITY OBJECTIVES Final Status Survey, Release Record 03C11 North West Protected Area STATE THE PROBLEM The Problem:

To demonstrate that the level of residual radioactivity in Class 1 Survey Unit 03 does not exceed the release criteria of 25 mrem/year Total Effective Dose Equivalent (TEDE) as specified in the License Termination Plan (LTP).

Stakeholders:

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

The Planning Team:

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

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

Schedule:

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

Resources:

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

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

PrincipalStudy Question (1):

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

Decision (1):

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

Actions (1):

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

Data Quality Objectives FSS 03C 1 1 Page 1 of 5

PrincipalStudy Question (2):

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

The Decision (2):

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

Actions (2):

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

PrincipalStudy Question (3):

Is the potential dose from residual radioactivity in the survey unit ALARA as stated?

The Decision (3):

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

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

Actions (3):

Alternative actions include remediation or no action required.

3. IDENTIFY INPUTS TO THE DECISION Information Needed:

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

Source of the Information:

The soil sample data to be used for survey development are the radionuclide-specific measurements of representative soil samples collected for radiological characterization and excavated soil surveys conducted to determine suitability for transport of excavated soil to the SVA. The soil samples obtained were judgmentally selected as a result of multiple surveys conducted during the excavation and transport process. The ALARA analysis for potential soil remediation is provided in LTP, Section 4.4.. Site-specific DCGL values and BRP radionuclides of interest are defined in LTP Chapter 5, Table 5-1 and Procedure RM-76, Final Status Survey Design.

The survey will be conducted in accordance with applicable regulatory guidance as established in LTP Chapter 5 for Class 1 areas. Soil samples will be utilized for radionuclide-specific measurements in this evaluation.

4. BOUNDARIES OF THE STUDY Boundariesof the Survey:

The target population for this survey is the total thickness of prepared soil in the survey area of 1956 M2 .

Data Quality Objectives FSS 03Cll Page 2 of 5

Temporal Boundaries:

Scanning and sampling in this survey unit will only be performed during daylight hours under dry weather conditions. Surface soils must be free of significant snow cover and standing water prior to surface scanning. Soils must be in a non-frozen state or fragmented for collection to satisfy BRP procedural sampling requirements. The anticipated start date for the survey is September 19, 2006.

Constraints:

Cold weather or rainy conditions may effect the operation of electronic equipment.

Adverse weather conditions that include accumulations of rain or snow may limit area access and delay survey efforts.

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

Decision Rule (1):

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

Decision Rule (2):

If the mean value of activity in the survey unit is greater than the DCGL, then the survey unit fails to meet the release criteria. 1 Remediate, resurvey, and evaluate the results relative to the decision rule.

Decision Rule (3):

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

Decision Rule (4):

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

6. SPECIFY TOLERABLE LIMITS ON DECISION ERRORS The Null Hypothesis:

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

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

Data Quality Objectives FSS 03C1 1 Page 3 of 5

Type I Error(a ):

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

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

Type ilError(,8)6 The ,8 error is the probability of accepting the null hypothesis when it is false. A value of 0.05 (5%) will be used for survey planning and data assessment for this survey area.

The Lower Bound of the Gray Region (LBGR):

The LBGR is initially set at one-half the DCGLw for this survey unit. The LBGR may be adjusted during survey design to achieve an optimum relative shift between 1.0 and 3.0.

Relative Shift (A/c):

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

7. OPTIMIZE DESIGN FOR OBTAINING DATA Statistical Test Sign Test:

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

Number of Samples Determined:

The number of samples required for this survey will be determined based on the relative shift as defined by the requirements of the Sign Test (LTP, Chapter 5.) and Procedure RM-76, Final Status Survey Design. The LBGR is initially set at one-half the DCGL, and may be adjusted as necessary for optimizing the survey design to achieve a relative shift between 1.0 and 3.0. Sample point locations are to be determined using a random start, systematic square grid spacing.

Judgmental Sampling:

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

Scan Coverage:

Scanning for this survey area will provide 100% coverage.

Number of Samples for Quality Control:

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

These samples may include sample splits, sample recounts, or third party sample Data Quality Objectives FSS 03C11 Page 4 of 5

analysis. Quality analyses will be conducted as defined in LTP, Chapter 5 and Procedure RM-79, Final Status Survey Quality Control.

Additional Sample Analysis Requirements:

The area of soil excavation intersects the identified waterborne pathway for Tritium migration and shall require Tritium in soil analyses for a minimum of 10% of the sample population. Soil samples will be collected in the same random locations as those selected for QA/QC evaluation and sent to an independent laboratory for Tritium analysis. Data results will be provided in the survey package.

Investigation Levels:

Investigation levels defined in LTP, Chapter 5 and BRP Procedure RM-76, Final Status Survey Design, shall be conservatively established for this survey as shown below:

Investigation Levels for Survey 03C1 1 Scan Measurement Soil Sample Analysis

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

Data Quality Objectives FSS 03C1 1 Page 5 of 5

FINAL STATUS SURVEY DESIGN Release Record 03C 11 North West Protected Area Survey Unit Description Survey 03C,1 encompasses an area of 1956 m2 in the north west section of the Protected Area.

No materials of plant origin exist in this survey unit.

Soil Sample Design Scopina Data Scoping measurements and supporting surveys performed in the Protected Area following removal of subsurface components and demolition debris do not indicate the presence of elevated levels of residual radioactivity in this survey area. Input data for survey design were conservatively estimated based on supporting surveys of excavated soils resulting from subsurface structure and component removal within the Protected Area.

Table 1 Input Data for Survey Design (pCi/g)

Radionuclides Cs-137 Co-60 a* 0.524 0.255 DCGL 11.93 3.21

Survey data detailed in Attachment 1 Sample Requirements The number of sample data points for this survey is based on the requirements of the Sign Test.

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

2 + OYCOBO 2 Cy C'sS37 DcGLcsl37) -t DCG-co6 o)

C3

,/0.524 /2 (0.255 )2 a = 0.091 Relative Shift Relative Shift = DCGLw-LBGR Relative Shift = 1-0.818 0.091 Relative Shift = 2.0 With (xand P3 error levels set at 0.05 and the relative shift of 2.0, the Sign Test requires 15 sample data points (Table 5.5 NUREG 1575).

Survey Design FSS 03C, 1 Page 1 of 7

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

Table 2 Random Numbers Random #, X Axis Random #, Y Axis 0.353393 0.688176 Survey Unit Dimensions: X = 40.0 meters Y = 48.9meters Random Start Location X = (0.353393)(40.0) = 14.1 meters With SW Corner Origin: Y = (0.688176)(48.9) = 33.7 meters Sample Spacing As a conservative measure sample spacing will be calculated based on 18 samples for this survey. Samples are located in a systematic square grid pattern with sample spacing determined by the following:

A nA Where: A= area of survey unit, and n = number of samples.

1956 L 95-6 10.4 meters 18 With sample spacing established at 10.4 meters, 20 data points are available for this survey.

Data point locations are identified in Attachment 2.

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

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

Survey Design FSS 03C11 Page 2 of 7

Table 3 Random Numbers Generated for QA/QC QA/OC Soil Random Random Samples Sample erification Scan Sample

_____sNumber Number Split Sample: 2 Start Point: 5 Sample Recount: 10 Scan Toward: 13 Sample Recount: 13 IScan Area Requirement: 196 M2 Surface Scanning The coverage requirement for surface scanning in this Class 1 area is 100%. The Scan MDC has been established at fractional values of the DCGLwfor typical background activity levels at Big Rock Point. Scan MDC values for varying backgrounds are provided in Attachment 3. The investigation level for identification of potential areas of elevated activity in this survey area will be the Scan DCGL as defined by the following:

Scan DCGL = Detector Rating CPM

Exposure Model uR/hr

DCGLw uR/hr pCi/g Scan DCGL for Co-60 = 1818 CPM Scan DCGL for Cs-137 = 3518 CPM Where: 1 Detector Rating = 1200 CPM Cs- 137 and 565 CPM Co -60 uR/hr uR/hr Exposure Model = 1.229uR/hr Cs- 13 7 and 5.029 uR/hr Co-60 5pCi/g 5 pCi/g DCGLw = 11.93 pCi/g Cs-137 and 3.21 pCi/g Co-60 The DCGLw for Co-60 is the most limiting value for scanning measurements performed to identify areas of potentially elevated activity. Scanning conducted for this survey will assume all residual radioactivity to originate from Co-60 and the instrument response at the Co-60 DCGLw (1818 cpm) will be used as the scanning investigation level for FSS 03C1 1.

1 These values established in EA-BRP-SC-0201, Nal Scanning Sensitivity for Open Land Survey.

Survey Design FSS 03ClI Page 3 of 7

Attachment 1 Design Data - FSS 03C 11 Protected Area Supporting Surveys Cs-1 37 Co-60 Survey No. Sequence Activity Activity No. (pCilg) (pCilg)

HH060705 .165388 * .26" .66 HH660705ý 1653ý9 0.06 07W6*

HH060705" 16540 i-.05 0*66

-B062805 16755 t.16 1: - ' 0.27-

,,,,-TB062805 16756 ,0.147, _ _031_ _"

VTB062805,,- 16774 0.9.3 Mean: 0.698 0.352 Std Dev: 0.524 0.255

Measurement system MDA - Co-60 not identified in this sample Survey Design FSS 03C11 Page 4 of 7

Attachment 2 Soil Sample Locations - Survey 03C1 1 North West Protected Area

_11U I III II-. I q-ij Y= 48.9 m 57 s o1 S30 1 91 01 11 21 33 12 8 1 81 9I O5 11 52 14 7 X=40 25 10 207 208 2D9 234

- Survey Unit 03C_1 0

i 0 5

B 6 10 S

2 Mes

Sample Location tiam pie spacing 15 1U.' MeiMr Survey Design FSS 03C11 Page 5 of 7

Attachment 3 Scan MDC In Varying Backgrounds Background d' j Si MDCRsurveyor Cs-1 37 Co-60 Cs-1 37 Co-60 2000 2.48 4 28.64 607.47 0.51 1.08 2.06 1.07 i 4 2;4-8

d:Q$ A___ 32.02: -69.I8<-**' , ý260&2130 10.5 1,20-

.2 3000 2.48 4 35.07 744.00 0.62 1.32 2.52 1.31

3500 2.48 4 37.88 803.61 0.67 1.42 2.72 1.41 4000 2.48 4 40.50 859.10 0.72 1.52 2.91 1.51 4500 2.48 4 42.95 911.21 0.76 1.61 3.09 1.60 5500 2.48 4 47.49 1,007.38 0.84 1.78 3.42 1.77 6000 2.48 4 49.60 1,052.17 0.88 1.86 3.57 1.85 6500 2.48 4 51.63 1,095.14 0.91 1.94 3.71 1.93 7000 2.48 4 53.57 1,136.48 0.95 2.01 3.85 2.00 8000 2.48 4 57.27 1,214.95 1.01 2.15 4.12 2.14 8500 2.48 4 59.04 1,252.34 1.04 2.22 4.25 2.20 9000 2.48 4 60.75 1,288.65 1.07 2.28 4.37 2.27 9500 2.48 4 62.41 1,323.96 1.10 2.34 4.49 2.33 10500 2.48 4 65.61 1,391.90 1.16 2.46 4.72 2.45 11000 2.48 4 67.16 1,424.65 1.19 2.52 4.83 2.51 11500 2.48 4 68.67 1,456.67 1.21 2.58 4.94 2.56 12000 2.48 4 70.14 1,488.00 1.24 2.63. 5.04 2.62 12,'0d0 2"8 "~5 4 7.9 .8 1..2 2.659~ 516 2.6 13000 2.48 4 73.01 1,548.76 1.29 2.74 5.25 2.73 13500 2.48 4 74.40 1,578.26 1.32 2.79 5.35 2.78 14000 2.48 4 75.77 1,607.22 1.34 2.84 5.45 2.83 14500 2.48 4 77.11 1,635.67 1.36 2.89 5.55 2.88

< i 5' 740u6636 - 1 U 2.4

,Modeloo&Exposuire (uR/hr 5)-,CV-UŽ6i' Survey Design FSS 03C 1 Page 6 of 7

Attachment 4 Area Factors for Open Land Survey Evaluation Conamiae Calculated Area Factors at Time of Peak Dose Area (Mt) H-3 Mn-54 Fe-55 Co-60 Sr-90 Cs-137 Eu-152 Eu-154 Eu-155 8094 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 4047 1.00 1.01 1.00 1.01 1.00 1.02 1.02 1.01 1.02 2024 1.00 1.03 1.00 1.03 1.00 1.03 1.03 1.03 1.03 1012 1.35 1.04 1.00 1.04 1.00 1.04 1.05 1.04 1.04 506 2.91 1.09 1.98 1.08 1.98 1.13 1.07 1.07 1.06 253 6.05 1.14 3.95 1.13 3.94 1.20 1.11 1.11 1.09 126 12.4 1.20 7.93 1.20 7.87 1.29 1.17 1.16 1.14 63 24.9 1.30 15.8 1.30 15.6 1.41 1.27 1.26 1.23 32 49.2 1.49 31.2 1.49 30.5 1.62 1.44 1.45 1.39 16 98.9 1.78 62.0 1.78 59.9 1.93 1.72 1.73 1.63 8 198 2.38 123 2.38 117 2.58 2.30 2.31 2.14 4 397 3.61 243 3.62 230 3.91 3.49 3.52 3.19 2 794 5.68 473 5.75 452 6.14 5.48 5.55 4.90 1 1590 9.57 905 9.73 887 10.3 9.24 9.39 7.88 Survey Design FSS 03C 1l Page 7 of 7

RM-76 Revision 1 FINAL STATUS SURVEY DESIGN Page 19 of 19 RM-76-5 FINAL STATUS SURVEY APPROVAL AND AUTHORIZATION FOR IMPLEMENTATION Survey Code 03C, 1 Survey Area

Description:

Final Status Survey 03C,1 encompasses 1956 m 2 at or below the grade elevation present during plant power operations in the north west section of the Protected Area. No materials of plant origin remain in the survey area.

The survey area is authorized for Final Status Survey Implementation.

09 Dat by Date Technical Review by Date RM-76.doc

RM-77 Revision 2 FINAL STATUS SURVEY IMPLEMENTATION Page 8 of 12 RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 1 of 3 Step Initial Date

(+)

1.0 PREPARATION FOR SURVEY (DE_ I Survey 1.1 Survey Area Status:

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

1. Survey area walkdown complete

2. Survey area determined ready for FSS

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

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

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

1.2 Field Preparation:

a. Survey unit boundaries delineated (Step 6.1.1)

_7 b. Statistical soil samples predetermined in the survey design are located and marked within the survey unit.

(Step 6.1.2)

c. Soil sample locations verified (Step 6.1.2.c)

_.Z d. Instruments and equipment have been collected and calibrated for data measurement and collection (Step 6.1.3)

a]LO

____ e. Field documentation is prepared (Step 6.1.4) -/SSG RM-77.doc

RM-77 Revision 2 FINAL STATUS SURVEY IMPLEMENTATION Page 9 of 12 RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 2 of 3 Initial Date 2.0 DATA COLLECTION 2.1 Soil Survey:

All soil samples collected and controlled (Step 6.2.1). E*SSG 10J~

2.2 Surface Scan:

Surface Scan complete. Action response requirements have been conducted on any identified areas exceeding the investigation level (Step 6.3). LZZ- . ~4~kLo PE-S_SG 2.3' Judgmental Soil Samples:

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

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

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

a. Soil samples are homogenous Soil samples are visibly dry prior to packing

_AZ b.

c. Non-soil materials have been removed from sample

d. Soil samples have been transferred to one-liter Marinelli containers and are labeled and sealed. 449 O~q 1c93Id

"'"IE

_SS G RM-77.doc

RM-77 Revision 2 FINAL STATUS SURVEY IMPLEMENTATION Page 10 of 12 RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 3 of 3 Initial Date 3.2 Laboratory Analysis:

-< Isotopic analyses are complete. The spectroscopy report requires a signature of completion by the laboratory analyst and a signature of evaluation documenting that a second level review has been performed (Step 6.4.2). 'ý"-ESSG alad'ý 3.3 Sample Control and Documentation:

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

T'ESSG kRe~viewed by Date RM-77.doc

RM-59 Revision 11 SAMPLING AND ANALYSIS OF OPEN LAND Page 7 of 13 AREAS FOR SITE CHARACTERIZATION SURVEYS ATTACHMENT RM-59-1 SAMPLING AND ANALYSIS REPORT Date: 09-19-2006 Time: 1600 Location: 03C011 Tech: TRS/WMH/JNS SURVEY IDENTIFICATION / DESCRIPTION Survey 03C1 1 encompasses 1956 m2 at or below the grade elevation present during plant oower woerations in the north west section of the Protected Area. No materials of plant origin remain in this area.

SURVEY TYPE Survey Type: Characterization X Scan (Motive)

Remediation X Final Scan (Static)

Trenching and Digging (use RM-59-4)

SURVEY DESIGN Sample Collection: _ Judgmental _ Random X Systematic _ Large Container Assay Scan Coverage: 100%

ANALYSIS Inst.SN/Cal Due 186201/09-30-2006 DAILY CHECK: X SAT UNSAT INIT: TRS Inst.SN/Cal Due 186194/02-08-2007 DAILY CHECK: X SAT UNSAT INIT: TRS Inst.SN/Cal Due 193709/02-21-2007 DAILY CHECK: X SAT UNSAT INIT: TRS Inst.SN/CaI Due Det.# 6 DAILY CHECK: X SAT UNSAT INIT: JP Inst.SN/Cal Due DAILY CHECK: SAT UNSAT INIT:

Investigation of Unidentified Peaks: X SAT UNSAT INIT: JLR Minimum Detectable Activity (Section 5.3.2) X SAT UNSAT INIT: JLR COMMENTS Survey 03C ,1 was performed in a random start, square grid. systematic sampling pattern with samples collected at 20 data point locations. Laboratory analyses did not identify residual radioactivity above trace levels of the DCGL value. Surface scanning identified no areas of elevated residual radioactivity. The results of the QA/QC verification scan (10%) were consistent with the findings of the primary survey scan.

Technician Sionature:i 5 Date: 94--

Second Level Review Signature: Date: l/"o /

RM-59.doc

Soil Sample Activity Summary Release Record 03C11 North West Protected Area 109 110 111 112 11i3 -4* -

Y =489 m 50 57

'1 9 128 130 131 132 133

@16 @15 i14 013 1)o 151 152 147 148 149

@Wo 912 166 167 168 169 170 171 04 e* Op 187 188 189 190 185 186 2 a3 4 40 0 X =40 m 204 205 206 207 208 209 0 5 10 20 Meters Survey Unit 03C1_1 I i I I1 S a i 0 Sample Location

Surface Scan Summary Release Record 03C11 North West Protected Area 4,3 ,

3.7 4.5 3 16 3.6 4.3 3.9 3.6 3.6 3.7

14 i;3 3,8 3.5 4.E 3.5 4.9 3.1 4.9 4.1 3.6 5.0 II oil04.7 012 3.5 3.9 3,7 3.3 4.9 4.1 5.1 052 5.4 O.

3.8 3.7 3.2 3.4

.1 w 3.4

,ýI,* 3.6 3.2 w~3. ý1 3.4 0 5 10 20 MOM Survey Unit 03C1_1 I M a a i i i i

Sample Location RED Values are Average Mobile Scan General Area Activity (kcpm)

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

GREY Values are Average General Background Area Activity (kcpm) du Afoa~cq N"L 4 {

-ýj, Primary Scan : .O. %

Tochnildin Signature: Dia:

_i Time:

QC Verification Scan: it %

Technician Signature: Do 9 -199 o

RM-72 Revision 0 SAMPLE CHAIN-OF-CUSI Page 4of 5 o9- 03C11 RM-72-1 CHAIN-OF-CUSTODY RECORD Sample Number Sampling Location Date Time Final Disposition of Sample 1 Grid # 186 (3.7) (2.5) f-1.. /3.--* "O vr-,,o0z'.

2 Grid # 187 (4.1) (2.5) f-'(o,4 /9Z7-2 QASplit Grid# 187 (4.1) (2.5) f-i-,. e,,I 3 Grid # 188 (4.5) (2.5) 9-R,0--o- 13Z 5 4 Grid # 189 (4.9) (2.5) /j Z-5 Grid # 170 (4.9) (2.9) -8 /

6 Grid # 169 (4.5) (2.9) 7"(/'oe -

7 Grid # 168 (4.1) (2.9) /3..

8 Grid # 167 (3.7) (2.9) f -g-T-, i3SY 9 Grid # 148 (3.7) (3.3) 7-,-o*- .

10 (R) Grid # 149 (4.1) (3.3) '.-*f- /Ii*

11 Grid # 150 (4.5) (3.3) '.../:(,k /3i'/

12 Grid # 151 (4.9) (3.3) 9-'.-. /,.',*"

13 (R) Grid # 132 (4.9) (3.7) -o /3'i 14 Grid # 131 (4.5) (3.7) /S,,ig' 15 Grid # 130 (4.1) (3.7) ?-&9-o0 &.19 16 Grid # 129 (3.7) (3.7) - /.?ZO 17 Grid# 53 (3.7) (4.1) f/9t-, .

18 Grid# 54 (4.1) (4.1) 9

'.*k. /3z-19 Grid # 55 (4.5) (4.1) - /5j*

20 Grid # 56 (4.9) (4.1) - /3z9 (Samples may be analyzed and stored, shipped for offsite evaluation or analyzed and disposed of.)

1.R linjUish Date Time Received in good condition by:

2. Relinquished by: 4 Date Time Received in good condition by:

3. Relinquished by: Date Time Received in good condition by:

4. Relinquished by: Date Time Received in good condition by:

RM-72.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 19 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 1 of 8 FINAL STATUS SURVEY: o3C2/

1.0 DATA VERIFICATION 1.1 Data Acceptance Review the Implementation Checklist (RM-77-1) to verify that survey isolation and control measures were executed prior to FSS and are being maintained.

Review RM-77, Final Status Survey Implementation, to verify that methods,

.techniques, and survey activities required for FSS have been applied in accordance with the appropriate procedures.

1.2 Field QC Records:

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

Comments:

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

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

1.3 Review Verification:

Verify that the Data Quality Objectives are complete.

Verify that the survey design has been technically reviewed.

RM-78.doc

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

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

Data Verification Completed: &) No Comments ec a0-i 3-be Date Assessor6 RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 21 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 3 of 8 2.0 DATA VALIDATION 2.1 Documentation Review:

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

§Field measurement records

.. ,* Chain-of-custody

__j Quality Control (QC) measurement records Current qualification of survey personnel Corrective Action Reports v1' Data inputs (laboratory spectroscopy)

Sample preparation techniques 2.2 Detection Limit Review:

XScan MDCs are below established site DCGLs.

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

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

2.3 Quality Control (QC) Data Review:

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

.. 1 Results of judgmental samples have been reviewed and evaluated.

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

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 22 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 4 of 8 2.4 Qualification of Data:

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

a. Total number of statistical samples planned for the survey: /J_ "

b. Total number of statistical samples determined as valid: Q b x120

c. Calculate % Completeness:

a QQualified data are :=400% completeness and are sufficient to support the Sign Test requirement for determination of unrestricted release.

Data Validation Completed: No Comments:

/De -?-0(

Assessor Date RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 23 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 5 of 8 3.0 DATA QUALITY ASSESSMENT 3.1 Review the DQOs and Survey Design:

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

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

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

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

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

3.2 Preliminary Review:

3.2.1 Preliminary Evaluation:

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

Survey is of sufficient intensity to satisfy classification requirement.

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

Comments:

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 24 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 6 of 8 3.2.2 Calculate Basic Statistical Quantities:

a. Number of qualified data points *0

b. Calculation of the Mean fL*1Jrs.#

c. Calculation of the Median /a

d. Calculation Standard Deviation ,1. 1/0 Cso)

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

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

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

7/' All survey measurements are below the DCGLW.

3.3.1 Verify Assumptions of the Survey Design

____Review the posting plot to verify that the data exhibits spatial independence. Spatial trends must be investigated and resolved prior to further assessment.

V 7

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

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 25 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 7 of 8

____ Review the dataset standard deviation and range for data variance.

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

__ Verify that the data exhibits adequate power and confirm that the sample size is sufficient to satisfy the DQOs.

3.4 Draw Conclusions from the Data:

3.4.1 Investigation Levels and Response Actions L Determine if data resul! have exceeded any investigation level.

Document findings. 1/1a !AveJt4e-,

3.4.2 Evaluation for Unrestricted Release Select applicable conclusion:

,//. Survey area acceptance criteria met and survey area satisfies the requirements for unrestricted release:

v/j All concentrations are less than the DCGLw. The Null Hypothesis is rejected.

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

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 26 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 8 of 8

, Survey area acceptance criteria not met and survey area fails to satisfy the requirements for unrestricted release:

SThe mean concentration in the survey area exceeds the DCGLw. and the null hypothesis is confirmed.

.J/ The mean concentration of the survey area is below the DCGLw but individual measurements in the Unit exceed the DCGLw..

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

Data Quality Assessment Completed: & No Comments f/

Dat1e3-0 R Assessor Date Revie vi Te K~nicaL' e v iew /Datei-ni c l ES Superintendent Date 10 -16, -o6 RP&ES Manager Date RM-78.doc

RM-78-3, Attachment I Statistical Quantities Release Record 03C1 l North West Protected Area Sample Cs-1 37 Co-60 Weighted "Weighted Sum Number (pCi/gm) (pCi/gm) Sum (SOR) <DCGLw? DCGL-W. Sum Sign 1 0.0591 0.0023 0.0057 yes 0.9943 +1 2 0.0912 0.0288 0.0166 yes 0.9834 +1 3 0.0698 0.0118 0.0095 yes 0.9905 +1 4 0.0872 0.0012 0.0077 yes 0.9923 +1 5 0.0638 0.0073 0.0076 yes 0.9924 +1 6 0.2535 -0.0063 0.0193 yes 0.9807 +1 7 0.0529 0.0243 0.0120 yes 0.9880 +1 8 0.3983 0.0343 0.0441 yes 0.9559 +1 9 0.1171 0.0110 0.0132 yes 0.9868 +1 10 0.2412 0.0077 0.0226 yes 0.9774 +1 11 0.0677 0.0010 0.0060 yes 0.9940 +1 12 -0.0001 -0.0101 -0.0032 yes 0.9968 +1 13 0.0114 0.0117 0.0046 yes 0.9954 +1 14 0.0503 0.0210 0.0108 yes 0.9892 +1 15 0.0834 0.0175 0.0124 yes 0.9876 +1 16 0.1165 0.0552 0.0270 yes 0.9730 +1 17 0.0651 -0.0035 0.0044 yes 0.9956 +1 18 0.0558 0.0250 0.0125 yes 0.9875 +1 19 0.0458 0.0254 0.0118 yes 0.9882 +1 20 0.1818 0.0046 0.0167 yes 0.9833 +1 Std. Dev 0.0955 0.0157 0.0100 Mean 0.1056 0.0135 0.0131 Median 0.0688 0.0114 0.0119 Number of Positive Differences (S+): n/a Critical Value, k, Table 1.3 of Marssim: n/a S+ >thank?: n/a Survey Unit Pass or Fail: **Pass

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

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

"I .

RM-79 Revision 1 FINAL STATUS SURVEY QUALITY CONTROL Page 11 of 13 RM-79-1 FSS QUALITY CONTROL EVALUATION RESULTS FSS Package # 0'3 C4 z QC Package # 0 .& C, / -

QC Measurement Type Acceptance Criteria Met*? Reference vi1. 1. Replicate Scan No Step 5.1.3

2. Sample Recounts Step 5.1.4.1

a. In-house "e! No

b. Third party Yes / No

3. Split Samples Step 5.1.4.2

_ c. In-house e)/No

.jL d. Third party Yes / No

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

Comments: )

(D.q X,::ý A.W-4 JA / ~.z~ '

Reviews:

Evator - Date

/

-/0 -)-6 Terch'nical Review Date RM-79.doc

QA Verification Split Sample Analysis Date: 8/25/2006 QA: 03C 1l North West Protected Area Type: Split Sample Lab: In-House Resolution C= (A)10, A

< Indicatesresults less than the MDA.

Note Results are considered in agreement for MDA and near-MDA measurement comparisons Results fthat fail agreement must be investigatedper RM-79.

QA Verification Sample Recount Analysis 6

. Table I Date: 8125/2006 Acceptance Criteria Resolution Ratio QA: 03C 1I North West Protected Area <4 N/A 4-7 0.5-2.0 Type: Sample Recounts 8-15 0.6-1.66 16-50 0.75-1.33 Lab: In- House 51-200 0.8-1.25

>200 0.85-1.18 A B C D E F G BRP Result BRP BRP BRP Results in Acceptance Recount Comparison Agreement Radionuclide Results % Error Ratio Recount Results Ratio Sample Below Resolution Result Compare MDA (pCi/g) (Sigma) (Table 1) Below MDA ______G Be____ow_____D (pCi/g) FI, Compare with D) 10 Co-60 0.0607 n/a n/a n/a < 0.0587 0.97 YES 10 Cs-137 0,2412 9.95 10.05 0M6-1.66 0.2059 0.85 YES 13 Co-60 < 00583 n/a n/a n/a < 0.0568 0.97 YES 13 Cs-137 < 0.0480 n/a n/a n/a < 0.0496 1.03 YES Resolution C= (AI( O

< Indicatesresults less than the MDA.

'Note Results are consideredin agreement forMDA and near-MDA measurementcomparisons Results fthat fail agreementmust be investigatedperRM-79.

,' i. V Tritium in Soil Data Results Final Status Survey 03C1 1 Sample Number r

j Tritium in Soil pCi/g 2 0.025 10 0.015 13 0.011 Mean: 0.0170 Median: 0.0150 St. Dev: 0.0072 Note: The DCGL for Tritium is 327 pCi/g.

Sample results are less than 0.2% of the DCGL

.. Environmental, Inc.

Midwest Laboratory an Allegheny Technologies Co.

700 Landwehr Road

Northbrook, IL 60062-2310 ph. (847) 564-0700 - fax (847) 564-4517 Mr. David W. Parish LABORATORY REPORT NO. 8022-100-239 Big Rock Point DATE: 09-27-2006 10269 US-31 North SAMPLES RECEIVED: 09-22-2006 Charlevoix, MI 49720 PURCHASE ORDER NO:

Below are the results of the analyses for tritium on three soil samples.

Excavated Soil Survey 03C 11 Sample Collection Lab Concentration MDA Description Date Code (pCi/g of soil) (pCi/g of soil)

H-3 2 09-19-06 BRSO-6484 0.025 +/- 0.008 < 0.013 10 09-19-06 BRSO-6485 0.015 +/- 0.007 < 0.011 13 09-19-06 BRSO-6486 0.011 +/- 0.005 < 0.009 The error given is the probable counting error at 95 % confidence level. The less than, (<), value is based on 4.66 sigma counting error for background sample.

APPROVED BY

/ Tony Coorlim, Quality Assurance

ATTACHMENT 3 CONSUMERS ENERGY BIG ROCKPOINT DOCKET NUMBERS 50-155 AND 72-043 TRANSMITTAL OF SURVEY PACKAGES IN SUPPORT OF BIG ROCK POINT PHASED LICENSE TERMINATION CLASS 1 FINAL STATUS SURVEY RELEASE RECORD, 05C, 1 ,

CENTRAL PROTECTED AREA October 24, 2006 37 Pages

Class I Final Status Survey Release Record 05C1 l Central Protected Area SURVEY PACKAGE CLOSURE Final Status Survey Documentation is authorized for closure. All required reviews are complete and the evaluation of data results have satisfied the criteria established for unrestricted release.

Signed: Date: lo-/la- o&

f- (ESSG)

Signed: Date: /c/*6 (ERP& perintendent)

Signed: Date: /o-/~-o*

/(RP & ES Manager)

Survey Area Requirements Final Status Survey, Release Record 05C 1 1 Central Protected Area Survey Description Final Status Survey 05C 11 encompasses 1924 m2 at or below the grade elevation present during plant power operations in the central section of the Protected Area. No materials of plant origin remain in the survey area.

History During power operations the Protected Area supported the components and systems necessary for electrical generation. The location of Survey Unit 05 is adjacent to the transport route used to move spent resin and filter media for radiological survey and offsite removal. Structures and enclosures formerly located in this area were once used for the storage of contaminated materials. A detailed review of the history and radiological characterization of Survey Unit 5 is provided in Appendix 2B and 2E of the LTP (License Termination Plan).

Current Radiological Status Scoping measurements and supporting surveys performed in the Protected Area following removal of subsurface components and demolition debris do not indicate the presence of elevated levels of residual radioactivity in this survey area. Based on operational history and former locations of radioactive systems and material transport pathways the radiological status of this survey unit is Class 1.

Post-Construction Expectations Final Status Survey 05C 1 1 will be performed in the following activity sequence:

1. Walkdown: Environmental Services Survey Group (ESSG) personnel will perform a walkdown assessment to ensure survey area preparations are complete and confirm that the following post-construction expectations have been satisfied as applicable:

Groundwater and Surface water control is adequate

All construction debris has been removed from the survey area

The survey location status meets all applicable safety requirements

2. Survey Area Isolation and Control: Control measures will be established to ensure that any potential ongoing decommissioning activities in adjacent locations do not impact the current survey area status. Isolation and control measures include postings, barriers, access points, and the evaluation of ongoing work activities in adjacent areas.

Survey Area Requirements FSS 05C1 1 Page 1 of 2

3. Survey Design and Execution: Survey design and execution will follow the Data Quality Objectives for 05C,1 in accordance with the survey requirements established in procedures RM-76, Final Status Survey Design and RM-77, Final Status Survey Implementation, and LTP, Chapter 5. Survey size will be based on the statistical requirements of the Sign Test for Class 1 areas with soil samples collected in random start, systematic data point locations. Surface scanning will be performed with 100%

survey area coverage. This survey will be conducted in accordance with approved BRP procedures and follow the guidance of NUREG 1575.

4. Data Quality Assessment: Isolation and control of the survey area will be maintained until the survey Data Quality Assessment demonstrates that the regulatory requirements for unrestricted site release have been satisfied.

Survey Area Requirements FSS 05C 11 Page 2 of 2

DATA QUALITY OBJECTIVES Final Status Survey, Release Record 05C11 Central Protected Area STATE THE PROBLEM The Problem:

To demonstrate that the level of residual radioactivity in Class 1 Survey Unit 05 does not exceed the release criteria of 25 mrem/year Total Effective Dose Equivalent (TEDE) as specified in the License Termination Plan (LTP).

Stakeholders:

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

The Planning Team:

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

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

Schedule:

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

Resources:

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

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

PrincipalStudy Question (1):

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

Decision (1):

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

Actions (1):

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

Data Quality Objectives FSS 05C 11 Page 1 of 5

PrincipalStudy Question (2):

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

The Decision (2):

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

Actions (2):

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

PrincipalStudy Question (3):

Is the potential dose from residual radioactivity in the survey unit ALARA as stated?

The Decision (3):

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

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

Actions (3):

Alternative actions include remediation or no action required.

3. IDENTIFY INPUTS TO THE DECISION Information Needed:

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

Source of the Information:

The soil sample data to be used for survey development are the radionuclide-specific measurements of representative soil samples collected for radiological characterization and excavated soil surveys conducted to determine suitability for transport of excavated soil to the SVA. The soil samples obtained were judgmentally selected as a result of multiple surveys conducted during the excavation and transport process. The ALARA analysis for potential soil remediation is provided in LTP, Section 4.4. Site-specific DCGL values and BRP radionuclides of interest are defined in LTP Chapter 5, Table 5-1 and Procedure RM-76, Final Status Survey Design.

The survey will be conducted in accordance with applicable regulatory guidance as established in LTP Chapter 5 for Class 1 areas. Soil samples will be utilized for radionuclide-specific measurements in this evaluation.

4. BOUNDARIES OF THE STUDY Boundaries of the Survey:

The target population for this survey is the total thickness of prepared soil in the survey area of 1924 M2 .

Data Quality Objectives FSS 05C 11 Page 2 of 5

Temporal Boundaries:

Scanning and sampling in this survey unit will only be performed during daylight hours under dry weather conditions. Surface soils must be free of significant snow cover and standing water prior to surface scanning. Soils must be in a non-frozen state or fragmented for collection to satisfy BRP procedural sampling requirements. The anticipated start date for the survey is September 18, 2006.

Constraints:

Cold weather or rainy conditions may effect the operation of electronic equipment.

Adverse weather conditions that include accumulations of rain or snow may limit area access and delay survey efforts.

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

Decision Rule (1):

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

Decision Rule (2):

If the mean value of activity in the survey unit is greater than the DCGL, then the survey unit fails to meet the release criteria. 1 Remediate, resurvey, and evaluate the results relative to the decision rule.

Decision Rule (3):

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

Decision Rule (4):

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

6. SPECIFY TOLERABLE LIMITS ON DECISION ERRORS The Null Hypothesis:

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

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

Data Quality Objectives FSS 05CO 1 Page 3 of 5

Type I Error(a):

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

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

Type I/ Error(,6).

The /6 error is the probability of accepting the null hypothesis when it is false. A value of 0.05 (5%) will be used for survey planning and data assessment for this survey area.

The Lower Bound of the Gray Region (LBGR):

The LBGR is initially set at one-half the DCGLW for this survey unit. The LBGR may be adjusted during survey design to achieve an optimum relative shift between 1.0 and 3.0.

Relative Shift (A/cy):

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

7. OPTIMIZE DESIGN FOR OBTAINING DATA Statistical Test Sign Test:

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

Number of Samples Determined:

The number of samples required for this survey will be determined based on the relative shift as defined by the requirements of the Sign Test (LTP, Chapter 5.) and Procedure RM-76, Final Status Survey Design. The LBGR is initially set at one-half the DCGL, and may be adjusted as necessary for optimizing the survey design to achieve a relative shift between 1.0 and 3.0. Sample point locations are to be determined using a random start, systematic square grid spacing.

Judgmental Sampling:

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

Scan Coverage:

Scanning for this survey area will provide 100% coverage.

Number of Samples for Quality Control:

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

These samples may include sample splits, sample recounts, or third party sample Data Quality Objectives FSS 05C11 Page 4 of 5

analysis. Quality analyses will be conducted as defined in LTP, Chapter 5 and Procedure RM-79, Final Status Survey Quality Control.

Additional Sample Analysis Requirements:

The area of soil excavation intersects the identified waterborne pathway for Tritium migration and shall require Tritium in soil analyses for a minimum of 10% of the sample population. Soil samples will be collected in the same random locations as those selected for QA/QC evaluation and sent to an independent laboratory for Tritium analysis. Data results will be provided in the survey package.

Investigation Levels:

Investigation levels defined in LTP, Chapter 5 and BRP Procedure RM-76, Final Status Survey Design, shall be conservatively established for this survey as shown below:

Investigation Levels for Survey 05C 11 Scan Measurement Soil Sample Analysis

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

Data Quality Objectives FSS 05C, 1 Page 5 of 5

FINAL STATUS SURVEY DESIGN Release Record 05C11 Central Protected Area Survey Unit Description Survey 05C, 1 encompasses an area of 1924 m 2 in the central section of the Protected Area. No materials of plant origin exist in this survey unit.

Soil Sample Design Scoping Data Scoping measurements and supporting surveys performed in the Protected Area following removal of subsurface components and demolition debris do not indicate the presence of elevated levels of residual radioactivity in this survey area. Input data for survey design were conservatively estimated based on supporting surveys of excavated soils resulting from subsurface structure and component removal within the Protected Area.

Table 1 Input Data for Survey Design (pCi/g)

Radionuclides Cs-137 Co-60 O-

0.524 0.255 DCGL 11.93 3.21

Survey data detailed in Attachment 1 Sample Requirements The number of sample data points for this survey is based on the requirements of the Sign Test.

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

0= V( CS1372 +,YO02 DCGLcs137 WDC-oGo)

(= 0.091 Relative Shift Relative Shift = DCGLw- LBGR (Y

Relative Shift = 1-0.818 0.091 Relative Shift = 2.0 With ( and P3 error levels set at 0.05 and the relative shift of 2.0, the Sign Test requires 15 sample data points (Table 5.5 NUREG 1575).

Survey Design FSS 05C1 l Page 1 of 7

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

Table 2 Random Numbers I Random #, X Axis Random #, Y Axis 0.091956 0.994458 Survey Unit Dimensions: X = 30.3 meters Y = 70.0 meters Random Start Location X = (0.091956)(30.3) = 2.8 meters With SW Corner Origin: Y = (0.994458)(70.0) = 69.6 meters Sample Spacing As a conservative measure sample spacing will be calculated based on 18 samples for this survey. Samples are located in a systematic square grid pattern with sample spacing determined by the following:

L=A n

Where: A= area of survey unit, and n = number of samples.

1924 L= 91-2 10.3 meters 18 With sample spacing established at 10.3 meters, 19 data points are available for this survey.

Data point locations are identified in Attachment 2.

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

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

Survey Design FSS 05C 11 Page 2 of 7

Table 3 Random Numbers Generated for QA/QC SRandom Random Samples Sample Verification Scan Sample Samples Number Number Split Sample: 3 Start Point: 12 Sample Recount: 5 Scan Toward: 3 Sample Recount: 11 Scan Area Requirement: 193 M 2 Surface Scanning The coverage requirement for surface scanning in this Class 1 area is 100%. The Scan MDC has been established at fractional values of the DCGLw for typical background activity levels at Big Rock Point. Scan MDC values for varying backgrounds are provided in Attachment 3. The investigation level for identification of potential areas of elevated activity in this survey area will be the Scan DCGL as defined by the following:

Scan DCGL = Detector Rating CPM . Exposure Model uR/hr . DCGLw uR/hr pCi/g Scan DCGL for Co-60 = 1818 CPM Scan DCGL for Cs-137 = 3518 CPM Where:'

Detector Rating = 1200 CPM Cs- 137 and 565 CPM Co - 60 uR/hr uR/hr Exposure Model = 1.229 uR/hr Cs-137 and 5.029 uR/hr Co -60 5pCi/g 5 pCi/g DCGLw = 11.93 pCi/g Cs-137 and 3.21 pCi/g Co-60 The DCGLw for Co-60 is the most limiting value for scanning measurements performed to identify areas of potentially elevated activity. Scanning conducted for this survey will assume all residual radioactivity to originate from Co-60 and the instrument response at the Co-60 DCGLw (1818 cpm) will be used as the scanning investigation level for FSS 05C11.

'These values established in EA-BRP-SC-0201, Nal Scanning Sensitivity for Open Land Survey.

Survey Design FSS 05C, 1 Page 3 of 7

Attachment I Design Data - FSS 05C 1 1 Protected Area Supporting Surveys Cs-1 37 Co-60 Survey No. Sequence Activity Activity No. (pCi/g) (pCi/g)

.HH060705 16538,! , :.ý1.26 . 0.66 16539' ý0.06 0.06*

HH060705 "HHO60705- _ 16540- 1.050.66 TB062805 '16755 1.16 "G27,

.TB062805 16756", 0-47 . 0.1*

TB062805ý] 16774 0.19 0.31 Mean: 0.698 0.352 Std Dev: 0.524 0.255

Measurement system MDA - Co-60 not identified in this sample Survey Design FSS 05C11 Page 4 of 7

Attachment 2 Soil Sample Locations - Survey 05C11 Central Protected Area 89 17190 20821 191 19213 211212 21" 4

227 229231 246 250 2369 35 31639 37 328 1 X=30.3 m 340 "343

- Survey Unit 05C _1 0 i i 1 5 10 I

20 Meters I

Sample Location Sample spacing Is 10.3 metors Survey Design FSS 05C11 Page 5 of 7

Attachment 3 Scan MDC In Varying Backgrounds Background d' Si MDCasurveyor Cs-137 Co-60 Cs-137 Co-60 2000 2.48 4 28.64 607.47 0.51 1.08 2.06 1.07 3000 2.48 4 35.07 744.00 0.62 1.32 2.52 1.31 3500 2.48 4 37.88 803.61 0.67 1.42 2.72 1.41 4000 2.48 4 40.50 859.10 0.72 1.52 2.91 1.51 4500 2.48 4 42.95 911.21 0.76 1.61 3.09 1.60 5500 2.48 4 47.49 1,007.38 0.84 1.78 3.42 1.77 6000 2.48 4 49.60 1,052.17 0.88 1.86 3.57 1.85 6500 2.48 4 51.63 1,095.14 0.91 1.94 3.71 1.93 7000 2.48 4 53.57 1,136.48 0.95 2.01 3.85 2.00 8000 2.48 4 57.27 1,214.95 1.01 2.15 4.12 2.14 8500 2.48 4 59.04 1,252.34 1.04 2.22 4.25 2.20 9000 2.48 4 60.75 1,288.65 1.07 2.28 4.37 2.27 9500 2.48 4 62.41 1,323.96 1.10 2.34 4.49 2.33 10500 2.48 4 65.61 1,391.90 1.16 2.46 4.72 2.45 11000 2.48 4 67.16 1,424.65 1.19 2.52 4.83 2.51 11500 2.48 4 68.67 1,456.67 1.21 2.58 4.94 2.56 12000 2.48 4 70.14 1,488.00 1.24 2.63 5.04 2.62

-4 71.5 -15i68 127 26 515~* 2T 13000 2.48 4 73.01 1,548.76 1.29 2.74 5.25 2.73 13500 2.48 4 74.40 1,578.26 1.32 2.79 5.35 2.78 14000 2.48 4 75.77 1,607.22 1.34 2.84 5.45 2.83 14500 2.48 4 77.11 1,635.67 1.36 2.89 5.55 2.88 4i§7&21 re'--&4K248 ~~ 3 4 i64 64,Xi2

_______ ~~o~0' 5,Q3E+to Survey Design FSS 05C 11 Page 6 of 7

Attachment 4 Area Factors for Open Land Survey Evaluation Contaminated_ Calculated Area Factors at Time of Peak Dose Contaminated H-3 Mn-54 Fe-55 Co-60 Sr-90 Cs-137 Eu-152 Eu-154 Eu-155 Area (in 2) 8094 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 4047 1.00 1.01 1.00 1.01 1.00 1.02 1.02 1.01 1.02 2024 1.00 1.03 1.00 1.03 1.00 1.03 1.03 1.03 1.03 1012 1.35 1.04 1.00 1.04 1.00 1.04 1.05 1.04 1.04 506 2.91 1.09 1.98 1.08 1.98 1.13 1.07 1.07 1.06 253 6.05 1.14 3.95 1.13 3.94 1.20 1.11 1.11 1.09 126 12.4 1.20 7.93 1.20 7.87 1.29 1.17 1.16 1.14 63 24.9 1.30 15.8 1.30 15.6 1.41 1.27 1.26 1.23 32 49.2 1.49 31.2 1.49 30.5 1.62 1.44 1.45 1.39 16 98.9 1.78 62.0 1.78 59.9 1.93 1.72 1.73 1.63 8 198 2.38 123 2.38 117 2.58 2.30 2.31 2.14 4 397 3.61 243 3.62 230 3.91 3.49 3.52 3.19 2 794 5.68 473 5.75 452 6.14 5.48 5.55 4.90 1 1590 9.57 905 9.73 887 10.3 9.24 9.39 7.88 Survey Design FSS 05C 11 Page 7 of 7

RM-76 Revision 1 FINAL STATUS SURVEY DESIGN Page 19 of 19 RM-76-5 FINAL STATUS SURVEY APPROVAL AND AUTHORIZATION FOR IMPLEMENTATION Survey Code 05C* 1 Survey Area

Description:

Final Status Survey 05C,1 encompasses 1924 m 2 at or below the grade elevation present during plant power operations in the central section of the Protected Area. No materials of plant origin remain in the survey area.

The survey area is authorized for Final Status Survey Implementation.

629/y 9oDat 7 - [esigned by Date Tech al Review by Date RM-76.doc

RM-77 Revision 2 FINAL STATUS SURVEY IMPLEMENTATION Page 8 of 12 RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 1 of 3 Step Initial Date (1) 1.0 PREPARATION FOR SURVEY survey#W 1.1 Survey Area Status:

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

1. Survey area walkdown complete

2. Survey area determined ready for FSS

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

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

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

1.2 Field Preparation:

a. Survey unit boundaries delineated (Step 6.1.1)

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

(Step 6.1.2)

c. Soil sample locations verified (Step 6.1 .2.c)

d. Instruments and equipment have been collected and calibrated for data measurement and collection e.

(Step 6.1.3)

Field documentation is prepared (Step 6.1.4) r).,(Iz - 01 Llrzoto 67ESS-G RM-77.doc

RM-77 Revision 2 Page 9 of 12 FINAL STATUS SURVEY IMPLEMENTATION RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 2 of 3 Initial Date 2.0 DATA COLLECTION 2.1 Soil Survey:

v/ All soil samples collected and controlled (Step 6.2.1).

SESSG 0-9kio&

2.2 Surface Scan:

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

uESSG 2.3 Judgmental Soil Samples:

A44 a. Judgmental soil samples have been collected and controlled (Step 6.2.3).

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

fE_SG S

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

a. Soil samples are homogenous

b. Soil samples are visibly dry prior to packing C. Non-soil materials have been removed from sample

iz~ d. Soil samples have been transferred to one-liter Marinelli containers and are labeled and sealed. rlý 01j'pa2b4

ýtSSG RM-77.doc

RM-77 Revision 2 FINAL STATUS SURVEY IMPLEMENTATION Page 10 of 12 RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 3 of 3 Initial Date 3.2 Laboratory Analysis:

7 Isotopic analyses are complete. The spectroscopy report requires a signature of completion by the laboratory analyst and a signature of evaluation documenting that a second V J, 9JO6 (0 level review has been performed (Step 6.4.2). /E! YS-'SG 3.3 Sample Control and Documentation:

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

c9 /Zyo 2c

?E S-SG Reviewed by Date RM-77.doc

RM-59 Revision 11 SAMPLING AND ANALYSIS OF OPEN LAND Page 7 of 13 AREAS FOR SITE CHARACTERIZATION SURVEYS ATTACHMENT RM-59-1 SAMPLING AND ANALYSIS REPORT Date: 09-18-2006 Time: 1600 Location: 05C1 1 Tech: TRS/WMH/JNS SURVEY IDENTIFICATION / DESCRIPTION Survey 05C01 encompasses 1924 m2 at or below the grade elevation present during plant Power operations in the central section of the Protected Area. No materials of plant origin remain in this area.

SURVEY TYPE Survey Type: Characterization X Scan (Motive)

Remediation X Final Scan (Static)

Trenching and Digging (use RM-59-4)

SURVEY DESIGN Sample Collection: _ Judgmental _ Random X Systematic _ Large Container Assay Scan Coverage: 100%

ANALYSIS Inst.SN/Cal Due 186201/09-30-2006 DAILY CHECK: X SAT UNSAT INIT: TRS Inst.SN/Cal Due 186194/02-08-2007 DAILY CHECK: X SAT UNSAT INIT: TRS Inst.SN/Cal Due 193709/02-21-2007 DAILY CHECK: X SAT UNSAT INIT: TRS Inst.SN/Cal Due Det. #6 DAILY CHECK: X SAT UNSAT INIT: Jp Inst.SN/Cal Due DAILY CHECK: SAT UNSAT INIT:

Investigation of Unidentified Peaks: X SAT UNSAT INIT: JLR Minimum Detectable Activity (Section 5.3.2) X SAT UNSAT INIT: JLR COMMENTS Survey 05C01 was performed in a random start, square arid, systematic samplina pattern with samples collected at 20 data point locations. Laboratory analyses did not identify residual radioactivity above trace levels of the DCGL value. Surface scanning identified no areas of elevated residual radioactivity. The results of the QA/QC verification scan (10%) were consistent with the scan values identified in the survey.

Technician Signature: ,,Jt , ,LL -e:

Second Level Review Signature: */(t//$f*-4/,/. Date: /01// /(

RM-59.doc

Soil Sample Activity Summary Release Record 05Cll Central Protected Area Survey Unit 05C1_1 0 4.5 9 18 Meters 1i 1 1 :1 A S Sample Location

Surface Scan Summary Release Record 05C11 Central Protected Area 3.81 17 3.2 14.0

3. 7 3- 1 4.1 5.0~ 4,1 4.3 4.14.

3.5 3. 9. 4.1 o 14A 36 1I4.4. 0 4.4 4.04f 4.5

~ ____

__ ____ ___ 4.4 I~ 4I 2

-Survey Unit 05CI_1 0 4.5 9 18 Meten S Sample Location Ili ii i ii ii RED Values are Average Mobile Scan General Area Activity (kcpm)

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

GREY Values are Average General Background Area Activity (kcpm)

Primary Scan : 'A"920;91WýW Technician Signature: Dats:

Time:

QC Verification Scan: ,/0 %

Technician Signature: Date: £ Time:

RM-72 Revision 0 SAMPLE CHAIN-OF-CUSTODY Page 4of 5 05C1l RM-72-1 CHAIN-OF-CUSTODY RECORD Sample Number Sampling Location Date Time Final Disposition of Sample 1 Grid#329 (2.8) (7.2) o-0g- IAqo 2 Grid#330 (3.1) (7.2) _ -__-0_ _____

3 Grid#318 (3.1) (7.6) 0 )2fo 3 QA Split Grid # 318 (3.1) (7.6) *j76 (.L*t *L 4 Grid#317 (2.8) (7.6) 5 (R) Grid # 304 (2.5) (8.0) OISCD' 6 Grid #305 (2.8) (8.0) 2SQ 7 Grid#306 (3.1) (8.0) - I)S 8 Grid#268 (3.1) (8.4) ?4-V ( O' 9 Grid#267 (2.8) (8.4) 1(/3-0(p 120 10 Grid # 266 (2.5) (8.4) c4oI 3 03 11 (R) Grid#247 (2.5) (8.8) qJ(g*fo (1300*5 12 Grid # 248 (2.8) (8.8) - -) ' ,,? O&'

13 Grid # 249 (3.1) (8.8) Nj-0 61 13to 14 Grid#230 (3.1) (9.2) 1213 15 Grid #229 (2.8) (9.2) - I 31S\

16 Grid #228 (2.5) (9.2) (

17 Grid#209 (2.5) (9.6) qit"-o-0 13P, 18 Grid #210 (2.8) (9.6) ' _

19 Grid#211 (3.1) (9.6) 7-[*gý-(, 13;3-T (Samples may be analyzed and stored, shipped for offsite evaluation or analyzed and disposed of.)

"/ C* t'v) Tim RReeDate e odn~c, *ito n

1. Reli quished/ :y:, I,, *, Dt Tie, y

2. Relinquishedb y: Date Time Received in good condition by:

f1LT- ra, e____ __________6__-3

3. Relinquished by: Date Time Received in good condition by:

4. Relinquished by: Date Time Received in good condition by:

RM-72.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 19 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 1 of 8 FINAL STATUS SURVEY: o5c, I 1.0 DATA VERIFICATION 1.1 Data Acceptance Review the Implementation Checklist (RM-77-1) to verify that survey isolation and control measures were executed prior to FSS and are being maintained.

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

1.2 Field QC Records:

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

Comments:

.i*1 Verify scan instrumentation was in calibration and the QC source checks were performed prior to and after surveys.

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

1.3 Review Verification:

__ Verify that the Data Quality Objectives are complete.

____Verify that the survey design has been technically reviewed.

RM-78.doc

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

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

Data Verification Completed:

&No Comments Do O at/3-e Assesso'r Date

//

6/

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 21 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 3 of 8 2.0 DATA VALIDATION 2.1 Documentation Review:

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

Field measurement records Chain-of-custody Quality Control (QC) measurement records Current qualification of survey personnel Corrective Action Reports Data inputs (laboratory spectroscopy)

Sample preparation techniques 2.2 Detection Limit Review:

,__ Scan MDCs are below established site DCGLs.

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

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

2.3 Quality Control (QC) Data Review:

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

,_ Results of judgmental samples have been reviewed and evaluated.

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

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 22 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 4 of 8 2.4 Qualification of Data:

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

a. Total number of statistical samples planned for the survey:

b. Total number of statistical samples determined as valid: /

b x 120 lo=

c. Calculate % Completeness: f7______

Qualified data are A 00% completeness and are sufficient to support the Sign Test requirement for determination of unrestricted release.

Data Validation Completed: O*-sNo Comments:

/0 o(?

Assessor Date RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 23 of 26 RM-78-3 DATA ASSESSMENT REPORT

.Page 5 of 8 3.0 DATA QUALITY ASSESSMENT 3.1 Review the DQOs and Survey Design:

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

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

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

_ Confirm that Type I and Type IIerror limits are consistent with DQOs.

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

3.2 Preliminary Review:.

3.2.1 Preliminary Evaluation:

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

Survey is of sufficient intensity to satisfy classification requirement.

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

Comments:

RM-78.doc

I-RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 24 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 6 of 8 3.2.2 Calculate Basic Statistical Quantities:

a. Number of qualified data points /

b. Calculation of the Mean 0. 0OSI, (SOP-)

c. Calculation of the Median t9.ocLog-)

d. Calculation Standard Deviation k Attach graphic representation of the data if any radionuclide-specific measurements exceed 50% of the DCGL.

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

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

All survey measurements are below the DCGLw.

3.3.1 Verify Assumptions of the Survey Design

_ _ Review the posting plot to verify that the data exhibits spatial independence. Spatial trends must be investigated and resolved prior to further assessment.

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

RM-78.doc

I, RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 25 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 7 of 8

,..I* Review the dataset standard deviation and range for data variance.

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

jVerify that the data exhibits adequate power and confirm that the sample size is sufficient to satisfy the DQOs.

3.4 Draw Conclusions from the Data:

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

Document find ings~~~k7X/A20~ ~4e~~

3.4.2 Evaluation for Unrestricted Release Select applicable conclusion:

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

/' All concentrations are less than the DCGLw. The Null Hypothesis is rejected.

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

RM-78.doc

I, RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 26 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 8 of 8 4,_ Survey area acceptance criteria not met and survey area fails to satisfy the requirements for unrestricted release:

,4_ The mean concentration in the survey area exceeds the DCGLw. and the null hypothesis is confirmed.

4_.The mean concentration of the survey area is below the DCGLw but individual measurements in the Unit exceed the DCGLw..

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

Data Quality Assessment Completed: Ye No Comments

/o-/3- O V Date Reviews:,

Date Tech i'ca fReview ES Superintendent Date RPES Manager Date RM-78.doc

RM-78-3, Attachment I Statistical Quantities Release Record 05C 11 Central Protected Area Sample Cs-137 Co-60 Weighted **Weighted Sum Number (pCi/gm) (pCilgm) Sum (SOR) <DCGLw? DCGL-W. Sum Sign.

1 0.0218 0.0120 0.0056 yes 0.9944 +1 2 0.0279 0.0173 0.0077 yes 0.9923 +1 3 0.0559 0.0106 0.0080 yes 0.9920 +1 4 0.0501 0.0002 0.0043 yes 0.9957 +1 5 0.0710 0.0404 0.0185 yes 0.9815 +1 6 0.0745 0.0144 0.0107 yes 0.9893 +1 7 0.1045 0.0059 0.0106 yes 0.9894 +1 8 0.1357 -0.0099 0.0083 yes 0.9917 +1 9 0.0861 0.0101 0.0104 yes 0.9896 +1 10 0.0462 0.0048 0.0054 yes 0.9946 +1 11 0.0124 -0.0006 0.0009 yes 0.9991 +1 12 0.0018 0.0119 0.0039 yes 0.9961 +1 13 0.0386 0.0082 0.0058 yes 0.9942 +1 14 -0.0002 -0.0108 -0.0034 yes 0.9966 +1 15 0.0390 0.0047 0.0047 yes 0.9953 +1 16 0.0208 -0.0117 -0.0019 yes 0.9981 +1 17 0.0531 -0.0152 -0.0003 yes 0.9997 +1 18 0.0384 -0.0027 0.0024 yes 0.9976 +1 19 0.0110 0.0126 0.0048 yes 0.9952 +1 Std. Dev 0.0356 0.0129 0.0051 Mean 0.0468 0.0054 0.0056 Median 0.0390 0.0059 0.0054 Number of Positive Differences (S+): n/a Critical Value, k, Table 1.3 of Marssim: n/a S+ >than k?: n/a Survey Unit Pass or Fail: **Pass

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

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

RM-79 Revision 1 FINAL STATUS SURVEY QUALITY CONTROL Page 11 of 13 RM-79-1 FSS QUALITY CONTROL EVALUATION RESULTS FSS Package # 5~5X2, / QC Package #

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

Comments:

14U '

/ tj Reviews:

!-/ ip060 valuato Date Technical Review Date RM-79.doc

QA Verification Split Sample Analysis Table I Date: 9/20/2006 Acceptance Criteria Resolution Ratio QA: 05C,1 Central Protected Area <4 N/A 4-7 0.5-2.0 Type: Split Sample 8-15 0.6-1.66 16-50 0.75-1.33 Lab: In-House 51-200 0.8-1.25

>200 0.85-1.18 A B C D E F BRP Results in Result BRP BRP BRP Acceptance Split Comparison Agreement Sample Radionuclide Below Results % Error BRP Ratio Results Split Results Ratio Resolution(pi) opr Beo (pCi/g) (Sigma) (Table 1) Below MDA (pC/g) FIA Compare MDA G with D) 3 Co-60 0.0633 n/a n/a n/a < 0.0594 0.94 YES 3 Cs-137 0.0559 38.89 2.57 n/a 0.0414 0.74 YES I .4 -I- I 1 1 4 I 4 4. 4. 4- I 4 I 4 4 I 4 4- 4. 4 4-4 .4 4. 4 4 4 .4 4 4- 4 I .4 .4 4 4 4. 4 4 4

£ .4 .4 I I 4. I 4 4-L .4 _____ .4 _______ 1 ________ 1 ______ .4 _______ 1 _________

Resoltuionc (A)(B7A 0 I

< Indicatesresults less than the MDA.

Note Results are consideredin agreement for MDA and near-MDA measurementcomparisons Results fthat fail agreement must be investigatedper RM-79.

QA Verification I Sample Recount Analysis Table I Date: 9/20/2006 Acceptance Criteria Resolution Ratio QA: 05C,1 Central Protected Area <4 N/A 4-7 0.5-2.0 Type: Sample Recounts 8-15 0.6-1.66 16-50 0.75-1.33 Lab: In- House 51-200 0.8-1.25

>200 0.85-1.18 A B C D E F G BRP Results in BRP BRP Acceptance Recount Comparison Sample SapeRadionuclide Rdould Result eut BRe t Results %

% EBRP Error Reouin atio Ratio Recount Reut Results RatioCopr Agreement Below Resolution Result MDA (pCi/g) (Sigma) (Table 1) Below MDA (pCi/g)sCompare F/A G with D)

___Below MDAth__D) ___D__G 5 Co-60 < 0.0731 n/a n/a n/a 0.0822 1.12 YES 5 Cs-137 0.0710 24.90 4.02 0.5-2.0 0.0426 0.60 YES 11 Co-60 < 0.0494 n/a n/a n/a 0.0607 1.23 YES 11 Cs-137 < 0.0523 n/a n/a n/a 0.0564 1.08 YES Resolution C = (A)(B 0

< Indicates results less than the MDA.

Note Results are consideredin agreement for MDA and near-MDA measurementcomparisons Results fthat fail agreementmust be investigatedperRM-79.

Tritium in Soil Data Results Final Status Survey 05C 1 1 Sample Tritium in Soil Number pCi/g 3 1.227 5 0.009 11 0.013 Mean: 0.4163 Median: 0.0130 St. Dev: 0.7021 Note: The DCGL for Tritium is 327 pCi/g.

Sample results are less than 0.4% of the DCGL

09/2')/200 18:09 8475644517 ý'Aor- I U / I '.ý Environmental, Inc.

Midwest Laboratory

-* 131Allegheny Teconologles Co, 700 LUnmwehr Rozd

Nortnbrook, IL 6006&!2310 ph. (847) 564-0700 - fax (847) 564.4517 Mr. David W. Parish LABORATORY REPORT NO. 8022-100-234 Big RocK Point DATE: 09-22-2006 10269 US-31 North SAMPLES RECEIVED: 09-20-2006 Charlevoix, MI 49720 PURCHASE ORDER NO:

Below are the results of the analyses for tritium on three soil samples.

Excavated Soil Survey 05C11 Sample Collection Lab Concentration MDA Description Date Code (pCi/g of soil) (pCi/g of soil)

H-3 3 09-18-06 BRSO-6400 1.227 +/- 0.031 < 0.018 3 09-18-06 BRSO-6401 0.980 +/-0.028 < 0.018 5 09-18-06 BRSO-6402 0.009 t 0.007 < 0.013 11 09-18-06 SRSO-6403 0.013 +/- 0.007 < 0.012 Denotes a duplicate, The error given is the probable counting error at 95 % confidence level. The less than, (<), value is based on 4.66 sigma counting error for background sample.

APPROVED BY Tony Coorlim.

Quality Assurance SEP 22 2006 18:51 8475644517 PFGE. 10

/,

ATTACHMENT 4 CONSUMERS ENERGY BIG ROCKPOINT DOCKET NUMBERS 50-155 AND 72-043 TRANSMITTAL OF SURVEY PACKAGES IN SUPPORT OF BIG ROCK POINT PHASED LICENSE TERMINATION CLASS 1 FINAL STATUS SURVEY RELEASE RECORD, 06C 1 1, SOUTH CENTRAL PROTECTED AREA October 24, 2006 37 Pages

Class 1 Final Status Survey Release Record 06C1 1 South Central Protected Area SURVEY PACKAGE CLOSURE Final Status Survey Documentation is authorized for closure. All required reviews are complete and the evaluation of data results have satisfied the criteria established for unrestricted release.

Signed: ýF -liný ý Date: to ---5o6 (ESSG)

Signed: Date: /d-,:9 -- o.6 TES Superintendent)

Signed: , -&E-'- e Date: /o--2-5-6o 6

,(F'Pý & ES kan-ager)

Survey Area Requirements Final Status Survey, Release Record 06C11 South Central Protected Area Survey Description Final Status Survey 06C 1 1 encompasses 1977 m 2 at or below the grade elevation present during plant power operations in the south central section of the Protected Area. No materials of plant origin remain in the survey area.

History During power operations the Protected Area supported the components and systems necessary for electrical generation. The location of Survey Unit 06 is adjacent to the transport route used to move spent resin and filter media for radiological survey and offsite removal. Structures and enclosures formerly located in this area were once used for the storage of contaminated materials. A detailed review of the history and radiological characterization of Survey Unit 06 is provided in Appendix 2B and 2E of the LTP (License Termination Plan).

Current Radiological Status Scoping measurements and supporting surveys performed in the Protected Area following removal of subsurface components and demolition debris do not indicate the presence of elevated levels of residual radioactivity in this survey area. Based on operational history and former locations of radioactive systems and material transport pathways the radiological status of this survey unit is Class 1.

Post-Construction Expectations Final Status Survey 06C, 1 will be performed in the following activity sequence:

1. Walkdown: Environmental Services Survey Group (ESSG) personnel will perform a walkdown assessment to ensure survey area preparations are complete and confirm that the following post-construction expectations have been satisfied as applicable:

Groundwater and Surface water control is adequate 0 All construction debris has been removed from the survey area 0 The survey location status meets all applicable safety requirements

2. Survey Area Isolation and Control: Control measures will be established to ensure that any potential ongoing decommissioning activities in adjacent locations do not impact the current survey area status. Isolation and control measures include postings, barriers, access points, and the evaluation of ongoing work activities in adjacent areas.

Survey Area Requirements FSS O6C 1 Page 1 of 2

3. Survey Design and Execution: Survey design and execution will follow the Data Quality Objectives for 06C1 1 in accordance with the survey requirements established in procedures RM-76, Final Status Survey Design and RM-77, Final Status Survey Implementation, and LTP, Chapter 5. Survey size will be based on the statistical requirements of the Sign Test for Class 1 areas with soil samples collected in random start, systematic data point locations. Surface scanning will be performed with 100%

survey area coverage. This survey will be conducted in accordance with approved BRP procedures and follow the guidance of NUREG 1575.

4. Data Quality Assessment: Isolation and control of the survey area will be maintained until the survey Data Quality Assessment demonstrates that the regulatory requirements for unrestricted site release have been satisfied.

Survey Area Requirements FSS O6C 1 Page 2 of 2

J DATA QUALITY OBJECTIVES Final Status Survey, Release Record 06C11 South Central Protected Area STATE THE PROBLEM The Problem:

To demonstrate that the level of residual radioactivity in Class 1 Survey Unit 06 does not exceed the release criteria of 25 mrem/year Total Effective Dose Equivalent (TEDE) as specified in the License Termination Plan (LTP).

Stakeholders:

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

The Planning Team:

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

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

Schedule:

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

Resources:

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

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

PrincipalStudy Question (1):

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

Decision (1):

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

Actions (1):

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

Data Quality Objectives FSS 06C 1I Page 1 of 5

PrincipalStudy Question (2):

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

The Decision (2):

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

Actions (2):

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

PrincipalStudy Question (3):

Is the potential dose from residual radioactivity in the survey unit ALARA as stated?

The Decision (3):

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

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

Actions (3):

Alternative actions include remediation or no action required.

3. IDENTIFY INPUTS TO THE DECISION Information Needed:

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

Source of the Information:

The soil sample data to be used for survey development are the radionuclide-specific measurements of representative soil samples collected for radiological characterization and excavated soil surveys conducted to determine suitability for transport of excavated soil to the SVA. The soil samples obtained were judgmentally selected as a result of multiple surveys conducted during the excavation and transport process. The ALARA analysis for potential soil remediation is provided in LTP, Section 4.4. Site-specific DCGL values and BRP radionuclides of interest are defined in LTP Chapter 5, Table 5-1 and Procedure RM-76, Final Status Survey Design.

The survey will be conducted in accordance with applicable regulatory guidance as established in LTP Chapter 5 for Class 1 areas. Soil samples will be utilized for radionuclide-specific measurements in this evaluation.

4. BOUNDARIES OF THE STUDY Boundariesof the Survey:

The target population for this survey is the total thickness of prepared soil in the survey area of 1977 M2 .

Data Quality Objectives FSS 06C,1 Page 2 of 5

Temporal Boundaries:

Scanning and sampling in this survey unit will only be performed during daylight hours under dry weather conditions. Surface soils must be free of significant snow cover and standing water prior to surface scanning. Soils must be in a non-frozen state or fragmented for collection to satisfy BRP procedural sampling requirements. The anticipated start date for the survey is September 14, 2006.

Constraints:

Cold weather or rainy conditions may effect the operation of electronic equipment.

Adverse weather conditions that include accumulations of rain or snow may limit area access and delay survey efforts.

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

Decision Rule (1):

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

Decision Rule (2):

If the mean value of activity in the survey unit is greater than the DCGL, then the survey unit fails to meet the release criteria. 1 Remediate, resurvey, and evaluate the results relative to the decision rule.

Decision Rule (3):

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

Decision Rule (4):

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

6. SPECIFY TOLERABLE LIMITS ON DECISION ERRORS The Null Hypothesis:

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

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

Data Quality Objectives FSS 06C 11 Page 3 of 5

Type I Error(a):

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

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

Type II Error(,B):

The f8 error is the probability of accepting the null hypothesis when it is false. A value of 0.05 (5%) will be used for survey planning and data assessment for this survey area.

The Lower Bound of the Gray Region (LBGR):

The LBGR is initially set at one-half the DCGLW for this survey unit. The LBGR may be adjusted during survey design to achieve an optimum relative shift between 1.0 and 3.0.

Relative Shift (A/a):

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

7. OPTIMIZE DESIGN FOR OBTAINING DATA Statistical Test Sign Test:

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

Number of Samples Determined:

The number of samples required for this survey will be determined based on the relative shift as defined by the requirements of the Sign Test (LTP, Chapter 5.) and Procedure RM-76, Final Status Survey Design. The LBGR is initially set at one-half the DCGL and may be adjusted as necessary for optimizing the survey design to achieve a relative shift between 1.0 and 3.0. Sample point locations are to be determined using a random start, systematic square grid spacing.

Judgmental Sampling:

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

Scan Coverage:

Scanning for this survey area will provide 100% coverage.

Number of Samples for Quality Control:

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

These samples may include sample splits, sample recounts, or third party sample Data Quality Objectives FSS 06C1 1 Page 4 of 5

analysis. Quality analyses will be conducted as defined in LTP, Chapter 5 and Procedure RM-79, Final Status Survey Quality Control.

Additional Sample Analysis Requirements:

The area of soil excavation intersects the identified waterborne pathway for Tritium migration and shall require Tritium in soil analyses for a minimum of 10% of the sample population. Soil samples will be collected in the same random locations as those selected for QA/QC evaluation and sent to an independent laboratory for Tritium analysis. Data results will be provided in the survey package.

Investigation Levels:

Investigation levels defined in LTP, Chapter 5 and BRP Procedure RM-76, Final Status Survey Design, shall be conservatively established for this survey as shown below:

Investigation Levels for Survey 06C1 1 Classification Scan Measurement Soil Sample Analysis Class 1 > DCGL > DCGLw The investigation levels for soil sample measurements are meant to include any individual radionuclide result greater than the site-specific DCGL or where the combined radionuclide values exceed the unity rule. Co-60 is the most limiting radionuclide for identification by surface scanning; further investigation will be initiated at any location that exceeds the Co-60 Scan DCGL of 1818 CPM above background as detailed in the survey design.

Data Quality Objectives FSS 06C11 Page 5 of 5

FINAL STATUS SURVEY DESIGN Release Record 06C11 South Central Protected Area Survey Unit Description Survey 06C11 encompasses an area of 1977 m2 in the south central section of the Protected Area. No materials of plant origin exist in this survey unit.

Soil Sample Design Scoping Data Scoping measurements and supporting surveys performed in the Protected Area following removal of subsurface components and demolition debris do not indicate the presence of elevated levels of residual radioactivity in this survey area. Input data for survey design were conservatively estimated based on supporting surveys of excavated soils resulting from subsurface structure and component removal within the Protected Area.

Table 1 Input Data for Survey Design (pCi/g)

Radionuclides I Cs-137 I Co-60 O"*

DCGL

Survey data detailed in Attachment 1 0.524 11.93 0.255 3.21 I Sample Requirements The number of sample data points for this survey is based on the requirements of the Sign Test.

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

JG CCS137 DCGLcsl37 )

2 GCOSO

+DCGLcoeo) 2 Cy 0.ý524 +2(0.2515ý y= 0.091 Relative Shift Relative Shift = DCGLw-LBGR Relative Shift = 1-0.818 0.091 Relative Shift = 2.0 With ca and [3 error levels set at 0.05 and the relative shift of 2.0, the Sign Test requires 15 sample data points (Table 5.5 NUREG 1575).

Survey Design FSS 06C,1 Page 1 of 7

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

Table 2 Random Numbers Random #, X Axis Random #, Y Axis 0.803882 0.025830 Survey Unit Dimensions: X = 60.0 meters Y = 39.3 meters Random Start Location X = (0.803882)(60.0) = 48.2 meters With SW Corner Origin: Y = (0.025830)(39.3) = 1.0 meters Sample Spacing As a conservative measure sample spacing will be calculated based on 18 samples for this survey. Samples are located in a systematic square grid pattern with sample spacing determined by the following:

L=A n

Where: A= area of survey unit, and n = number of samples.

L 1977 1- 10.4 meters 18 With sample spacing established at 10.4 meters, 20 data points are available for this survey.

Data point locations are identified in Attachment 2.

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

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

Survey Design FSS 06C1 l Page 2 of 7

Table 3 Random Numbers Generated for QA/QC Random Random QA/QC Soil Sample Verification Scan Sample Samples Number ,Number Split Sample: 12 Start Point: 11 Sample Recount: 14 Scan Toward: 17 Sample Recount: 16 IMinimum Scan Area Requirement: 198 m 2 Surface Scanning The coverage requirement for surface scanning in this Class 1 area is 100%. The Scan MDC has been established at fractional values of the DCGLwfor typical background activity levels at Big Rock Point. Scan MDC values for varying backgrounds are provided in Attachment 3. The investigation level for identification of potential areas of elevated activity in this survey area will be the Scan DCGL as defined by the following:

Scan DCGL = Detector Rating CPM . Exposure Model uR/hr . DCGLw uR/hr pCi/g Scan DCGL for Co-60 = 1818 CPM Scan DCGL for Cs-137 = 3518 CPM Where:1 Detector Rating = 1200 CPMCs -137 and 565 CPM Co -60 uR/hr uR/hr Exposure Model = 1.229uR/hr Cs- 137 and 5.029uR/hr Co-60 5pCi/g 5 pCi/g DCGLw = 11.93 pCi/g Cs-137 and 3.21 pCi/g Co-60 The DCGLw for Co-60 is the most limiting value for scanning measurements performed to identify areas of potentially elevated activity. Scanning conducted for this survey will assume all residual radioactivity to originate from Co-60 and the instrument response at the Co-60 DCGLw (1818 cpm) will be used as the scanning investigation level for FSS 06C, 1.

'These values established in EA-BRP-SC-0201, Nal Scanning Sensitivity for Open Land Survey.

Survey Design FSS 06C 11 Page 3 of 7

Attachment I Design Data - FSS 06C1 l Protected Area Supporting Surveys Cs-1 37 Co-60 Survey No. Sequence Activity Activity No. (pCi/g) (pcilg) 1111060705 *16588 :-.:26t, 0.m66'

,HH0607051ý 16539., 0i.'062 06

ý,HH06075 '16540, ~1.05 j0.6&11 TB062AQ5 '16755 1 16 0.27

~TB062405 16756 0,47 '0.15*

TB062805 16774 0.1903 Mean: 0.698 0.352 Std Dev: 0.524 0.255

Measurement system MDA - Co-60 not identified in this sample Survey Design FSS 06C1 I Page 4 of 7

Attachment 2 Soil Sample Locations - Survey 06C11 South central Protected Area 31 U al 2 19 (17 2I 1 0 5 10 2 Meters SurveyUnit06C1

. Sample Location Survey Design FSS 06C11 Page 5 of 7

Attachment 3 Scan MDC In Varying Backgrounds Background d' i Si MDCRsurvevor Cs-137 Co-60 Cs-137 Co-60 2000 2.48 4 28.64 607.47 0.51 1.08 2.06 1.07 25,00~ 2.48 ~4 2.27 b >67ý,~ > 57,, >!,-1,U2O 2__30_ 1.20 3000 2.48 4 35.07 744.00 0.62 1.32 2.52 1.31 3500 2.48 4 37.88 803.61 0.67 1.42 2.72 1.41 4000 2.48 4 40.50 859.10 0.72 1.52 2.91 1.51 4500 2.48 4 42.95 911.21 0.76 1.61 3.09 1.60 5500 2.48 4 47.49 1,007.38 0.84 1.78 3.42 1.77 6000 2.48 4 49.60 1,052.17 0.88 1.86 3.57 1.85 6500 2.48 4 51.63 1,095.14 0.91 1.94 3.71 1.93 7000 2.48 4 53.57 1,136.48 0.95 2.01 3.85 2.00 8000 2.48 4 57.27 1,214.95 1.01 2.15 4.12 2.14 8500 2.48 4 59.04 1,252.34 1.04 2.22 4.25 2.20 9000 2.48 4 60.75 1,288.65 1.07 2.28 4.37 2.27 9500 2.48 4 62.41 1,323.96 1.10 2.34 4.49 2.33

-1ii 2A-4 "1 11" `4403 4.5&5 2.".4:____

10500 2.48 4 65.61 1,391.90 1.16 2.46 4.72 2.45 11000 2.48 4 67.16 1,424.65 1.19 2.52 4.83 2.51 11500 2.48 4 68.67 1,456.67 1.21 2.58 4.94 2.56 12000 2.48 4 70.14 1,488.00 1.24 2.63 5.04 2.62 2$ ~2.4ýZ ~> 7.9" 8 j15:8~6~~"1.7 .9 62 13000 2.48 4 73.01 1,548.76 1.29 2.74 5.25 2.73 13500 2.48 4 74.40 1,578.26 1.32 2.79 5.35 2.78 14000 2.48 4 75.77 1,607.22 1.34 2.84 5.45 2.83 14500 2.48 4 77.11 1,635.67 1.36 2.89 5.55 2.88

~ 24 Ai4 Z84~K 5Yi663.63 19 5.4 2 M~de ______ _ _____ _______

I

_______________ i~~~~~1~23'~0 _______ ______

Survey Design FSS 06C 11 Page 6 of 7

Attachment 4 Area Factors for Open Land Survey Evaluation Contaminated

_Calculated Area Factors at Time of Peak Dose Area (M2) H-3 Mn-54 Fe-55 Co-60 Sr-90 Cs-137 Eu-152 Eu-154 Eu-155 8094 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 4047 1.00 1.01 1.00 1.01 1.00 1.02 1.02 1.01 1.02 2024 1.00 1.03 1.00 1.03 1.00 1.03 1.03 1.03 1.03 1012 1.35 1.04 1.00 1.04 1.00 1.04 1.05 1.04 1.04 506 2.91 1.09 1.98 1.08 1.98 1.13 1.07 1.07 1.06 253 6.05 1.14 3.95 1.13 3.94 1.20 1.11 1.11 1.09 126 12.4 1.20 7.93 1.20 7.87 1.29 1.17 1.16 1.14 63 24.9 1.30 15.8 1.30 15.6 1.41 1.27 1.26 1.23

.32 49.2 1.49 31.2 1.49 30.5 1.62 1.44 1.45 1.39 16 98.9 1.78 62.0 1.78 59.9 1.93 1.72 1.73 1.63 8 198 2.38 123 2.38 117 2.58 2.30 2.31 2.14 4 397 3.61 243 3.62 230 3.91 3.49 3.52 3.19 2 794 5.68 473 5.75 452 6.14 5.48 5.55 4.90 1 1590 9.57 905 9.73 887 10.3 9.24 9.39 7.88 Survey Design FSS 06Cl Page 7 of 7

RM-76 Revision 1 FINAL STATUS SURVEY DESIGN Page 19 of 19 RM-76-5 FINAL STATUS SURVEY APPROVAL AND AUTHORIZATION FOR IMPLEMENTATION Survey Code 06Cl1 Survey Area

Description:

Final Status Survey 06C, 1 encompasses 1977 m 2 at or below the grade elevation present during plant power operations in the south central section of the Protected Area. No materials of plant oriain remain in the survey area.

The survey area is authorized for Final Status Survey Implementation.

T esigned by Date

Technical Review by Date RM-76.doc

RM-77 Revision 2 FINAL STATUS SURVEY IMPLEMENTATION Page 8 of 12 RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 1 of 3

(+) Initial Date 1.0 PREPARATION FOR SURVEY Survey #

1.1 Survey Area Status:

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

1. Survey area walkdown complete

2. Survey area determined ready for FSS

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

4. Survey area environment is controlled by barriers ILIJA 0 and postings or other approved method to restrict eE5SG access.

_-,Z b. Survey area has been turned over to the Environmental Services Survey Group (ESSG) in acceptable condition for FSS. ,2L4O 4 (

1.2 Field Preparation:

/ a. Survey unit boundaries delineated (Step 6.1.1)

b. Statistical soil samples predetermined in the survey

/-7 design are located and marked within the survey unit.

(Step 6.1.2)

c. Soil sample locations verified (Step 6.1.2.c)

d. Instruments and equipment have been collected and calibrated for data measurement and collection e.

(Step 6.1.3)

Field documentation is prepared (Step 6.1.4) azzz

(/LSSG RM-77.doc

RM-77 Revision 2 Page FINAL STATUS SURVEY IMPLEMENTATION 9 of 12 RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 2 of 3 Initial Date 2.0 DATA COLLECTION 2.1 Soil Survey:

.Z All soil samples collected and controlled (Step 6.2.1). 01,40 2.2 Surface Scan:

,/ Surface Scan complete. Action response requirements have been conducted on any identified areas exceeding the investigation level (Step 6.3). 2ý_44/ma tSýSG 2.3 Judgmental Soil Samples:

P/A a. Judgmental soil samples have been collected and controlled (Step 6.2.3).

b. Deep core profiles performed in areas identified to contain elevated residual activity (Step 6.2.3). 6j11{4 3.0 SAMPLE PREPARATION AND LABORATORY ANALYSIS 3.1 Sample Preparation (Step 6.4.1):

7 a. Soil samples are homogenous

-7" b. Soil samples are visibly dry prior to packing C. Non-soil materials have been removed from sample

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

"ESSG RM-77.doc

RM-59 Revision 11 SAMPLING AND ANALYSIS OF OPEN LAND Page 7 of 13 AREAS FOR SITE CHARACTERIZATION SURVEYS ATTACHMENT RM-59-1 SAMPLING AND ANALYSIS REPORT Date: 09-14-2006 T Time: 1600 Location: 06C, 1 Tech:

TSSO/JHW/LED/JNS SURVEY IDENTIFICATION / DESCRIPTION Survey 06CI1 encompasses 1977 m 2 at or below the grade elevation present during plant power operations in the south central section of the Protected Area. No materials of plant ori-gin remain in this area.

SURVEY TYPE Survey Type: Characterization X Scan (Motive)

___ Remediation X Final Scan (Static)

Trenching and Digging (use RM-59-4)

SURVEY DESIGN Sample Collection: _ Judgmental _ Random X Systematic Large Container Assay Scan Coverage: 100%

ANALYSIS Inst.SN/Cal Due 201195/02-10-2007 DAILY CHECK: X SAT UNSAT INIT: sso Inst.SN/Cal Due 186185/09-23-2006 DAILY CHECK: X SAT UNSAT INIT: LED Inst.SN/Cal Due 193709/02-21-2007 DAILY CHECK: X SAT UNSAT INIT: TRS Inst.SN/Cal Due 189086/01-26-2007 DAILY CHECK: X SAT UNSAT INIT: JHW Inst.SN/Cal Due Det. # 6 DAILY CHECK: X SAT UNSAT INIT: Jp Investigation of Unidentified Peaks: X SAT _ UNSAT INIT: JLR Minimum Detectable Activity (Section 5.3.2) X SAT UNSAT INIT: JLR COMMENTS Survey 06C,1 was performed in a random start, square grid, systematic sampling pattern with samples collected at 20 data point locations. Laboratory analyses did not identify residual radioactivity above trace levels of the DCGL value. Surface scanninq identified no areas of elevated residual radioactivity. The results of the QA/QC verification scan (10%) were consistent with the findings of the primary survey scan.

-I m

Date: /p -ZZ-II OC( I RM-59.doc

RM-77 Revision 2 FINAL STATUS SURVEY IMPLEMENTATION Page 10 of 12 RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 3 of 3 Initial Date 3.2 Laboratory Analysis:

L/ Isotopic analyses are complete. The spectroscopy report requires a signature of completion by the laboratory analyst and a signature of evaluation documenting that a second level review has been performed (Step 6.4.2). ý, týS-G-192 AI/W 3.3 Sample Control and Documentation:

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

(/ESSG 0-ýZoea

( -I ý,ý/ /i2(1 9 ý-Zj Date RM-77.doc

Soil Sample Activity Summary Release Record 06011 South Central Protected Area 304 305 30/ 309 310 290 316 291 328 ý34 292 340 293 352 3,M8 294 X=I 60.0 m 364 365 366 369 370 295

= Survey Unit 06C1_1 0I .

5I .

10 I

20 Meters 0 Sample Location

Surface Scan Summary Release Record 06C 11 South Central Protected Area

= Survey Unit 06C1_1 0 5 10 20 Motors

! l ; , I = i r I

Sample Location RED Values are Average Mobile Scan General Area Activity (kcpm)

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

GREY Values are Average General Background Area Activity (kcpm)

V, Primary Scan:

Technician Signature: Date: '1-A. 0 Time: '400 QC Verification Scan: /0 %

Technician Signature: ' JA Date: 9*.14-o(o Time: 1l400

RM-72 Revision 0 SAMPLE CHAIN-OF-CUSTODY Page 4of 5 06C1 1 RM-72-1 CHAIN-OF-CUSTODY RECORD Sample Number Sampling Location Date Time Final Disposition of Sample 1 Grid #353 (6.6) (1.0) u HT'o* "-

2 Grid # 354 (7.0) (1.0) - - .O 17-4-D 3 Grid#355 (7.4) (1.0) 0('-i.( 13, 4 Grid#356 (7.8) (1.0) 5I.I*-(do \2ifi 5 Grid #357 (8.2) (1.0) *,l -.o0 IS' 6 Grid # 358 (8.6) (1.0) .Iq'ot*

7 Grid#346 (8.6) (1.4) . I.5" 8 Grid #345 (8.2) (1.4) 9.- ,IUS0 12 1L 9 Grid #344 (7.8) (1.4) 9.1Llr

10 Grid # 343 (7.4) (1.4) -i"(z-0I9 3m 11 Grid # 342 (7.0) (1.4) 5L. +/--D ý,-

12 Grid #341 (6.6) (1.4) jlH.(O .ZLA1e 12 QASplit Grid#341 (6.6) (1.4) Iq.t-o( \I-LI(p 13 Grid # 331 (7.4) (1.8) q,, V- M.Q 14 (R) Grid # 332 (7.8) (1.8) ".ILb 0 4 , I.,%,L 15 Grid #333 (8.2) (1.8) .9. jLLf.(I \7CQS 16 (R) Grid #334 (8.6) (1.8) q.IL*o.o( I SOt /

17 Grid # 322 (8.6) (2.2) 9. 1&I.oeC ID,(4 18 Grid#321 (8.2) (2.2) ,I-O(* \ )

19 Grid#320 (7.8) (2.2) --

20 Grid#319 (7.4) (2.2) _0.O(_ _ _ __'_

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

',1 ¢-WeI, I. l,

2. elnqishd y:Date . Time Received in good condition by:

2. Relinquished by: e Date Time Received in good condition by:

3. Relinquished by: Date Time Received in good condition by:

4. Relinquished by: Date Time Received in good condition by:

RM-72.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 19 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 1 of 8 FINAL STATUS SURVEY: O& (,//

1.0 DATA VERIFICATION 1.1 Data Acceptance

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

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

1.2 Field QC Records:

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

Comments:

,/1 Verify scan instrumentation was in calibration and the QC source checks were performed prior to and after surveys.

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

1.3 Review Verification:

v/" Verify that the Data Quality Objectives are complete.

" Verify that the survey design has been technically reviewed.

RM-78.doc

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

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

Data Verification Completed: YosN o Comments Assessor Date RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 21 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 3 of 8 2.0 DATA VALIDATION 2.1 Documentation Review:

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

IField measurement records SChain-of-custody Quality Control (QC) measurement records Current qualification of survey personnel Corrective Action Reports

.* Data inputs (laboratory spectroscopy)

Sample preparation techniques 2.2: Detection Limit Review:

X Scan MDCs are below established site DCGLs.

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

7Minimum Detectable Concentration (MDC) values of gamma spectroscopy are below established DCGLs.

2.3 Quality Control (QC) Data Review:

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

4* Results of judgmental samples have been reviewed and evaluated.

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

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 22 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 4 of 8 2.4 Qualification of Data:

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

a. Total number of statistical samples planned for the survey: j*"j

b. Total number of statistical samples determined as valid: c,2 D b x120_

c. Calculate % Completeness:

a

_ Qualified data are J00% completeness and are sufficient to support the Sign Test requirement for determination of unrestricted release.

Data Validation Completed: 2 No Comments:

Assessor Date RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 23 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 5 of 8 3.0 DATA QUALITY ASSESSMENT 3.1 Review the DQOs and Survey Design:

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

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

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

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

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

3.2 Preliminary Review:

3.2.1 Preliminary Evaluation:

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

SSurvey is of sufficient intensity to satisfy classification requirement.

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

Comments:

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 24 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 6 of 8 3.2.2 Calculate Basic Statistical Quantities:

a. Number of qualified data points 0-9

b. Calculation of the Mean P,,1a-.00.1

c. Calculation of the Median .

d. Calculation Standard Deviation Co iP. o'7"2 COW il& Attach graphic representation of the data if any radionuclide-specific measurements exceed 50% of the DCGL.

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

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

____All survey measurements are below the DCGLw.

3.3.1 Verify Assumptions of the Survey Design

____ Review the posting plot to verify that the data exhibits spatial independence. Spatial trends must be investigated and resolved prior to further assessment.

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

RM-78.doc

I RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 25 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 7 of 8

___ Review the dataset standard deviation and range for data variance.

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

Verify that the data exhibits adequate power and confirm that the sample size is sufficient to satisfy the DQOs.

3.4 Draw Conclusions from the Data:

3.4.1 Investigation Levels and Response Actions

_*. Determine if data results have exceeded any investigation level.

Document findings. > . '&-'-J-y/

3.4.2 Evaluation for Unrestricted Release Select applicable conclusion:

j Survey area acceptance criteria met and survey area satisfies the requirements for unrestricted release:

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

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

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 26 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 8 of 8

.4 Survey area acceptance criteria not met and survey area fails to satisfy the requirements for unrestricted release:

,d The mean concentration in the survey area exceeds the DCGLw. and the null hypothesis is confirmed.

A2ý, The mean concentration of the survey area is below the DCGLw but individual measurements in the Unit exceed the DCGLw..

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

Data Quality Assessment Completed: No Comments 7 Assessor Date Reviews:

Ot Da(Z-3 Technical R iew Date ES Superintendent 'Date RPr&-ES Manager Date RM-78.doc

RM-78-3, Attachment 1 Statistical Quantities Release Record 06C11 South Central Protected Area Sample Cs-1 37 Co-60 Weighted **Weighted Sum Number (pCi/gm) (pCi/gm) Sum (SOR) <DCGLw? DCGL-W. Sum Sign 1 0.0547 0.0319 0.0145 yes 0.9855 +1 2 0.0490 -0.0036 0.0030 yes 0.9970 +1 3 0.0472 -0.0083 0.0014 yes 0.9986 +1 4 0.0853 0.0471 0.0218 yes 0.9782 +1 5 0.0331 0.0291 0.0118 yes 0.9882 +1 6 0.0902 -0.0150 0.0029 yes 0.9971 +1 7 0.0581 0.0132 0.0090 yes 0.9910 +1 8 0.0044 0.0023 0.0011 yes 0.9989 +1 9 0.0667 0.0566 0.0232 yes 0.9768 +1 10 0.0918 0.0369 0.0192 yes 0.9808 +1 11 0.0468 0.0323 0.0140 yes 0.9860 +1 12 0.0324 -0.0009 0.0024 yes 0.9976 +1 13 0.0624 0.0013 0.0056 yes 0.9944 +1 14 0.0417 0.0030 0.0044 yes 0.9956 +1 15 0.0364 0.0474 0.0178 yes 0.9822 +1 16 0.0213 0.0110 0.0052 yes 0.9948 +1 17 0.0613 0.0049 0.0067 yes 0.9933 +1 18 0.0422 0.0084 0.0062 yes 0.9938 +1 19 0.0287 0.0119 0.0061 yes 0.9939 +1 20 0.0524 0.0422 0.0175 yes 0.9825 +1 Std. Dev 0.0224 0.0210 0.0072 Mean 0.0503 0.0176 0.0097 Median 0.0481 0.0115 0.0064 Number of Positive Differences (S+): n/a Critical Value, k, Table 1.3 of Marssim: n/a S+ >thank?: n/a Survey Unit Pass or Fail: **Pass

Note: Forced-Countvalues are used for samples with activity levels below the MDA.

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

I t RM-79 Revision 1 FINAL STATUS SURVEY QUALITY CONTROL Page 11 of 13 RM-79-1 FSS QUALITY CONTROL EVALUATION RESULTS FSS Package # 0(a C' I QC Package # o (c2Co /

QC Measurement Type Acceptance Criteria Met*? Reference

1. Replicate Scan (2 No Step 5.1.3.

2. Sample Recounts Step 5.1.4.1

_ _ a. In-house No 2/yL b. Third party Yes / No

3. Split Samples Step 5.1.4.2

c. In-house No

d. Third party Yes I No

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

Comments:~

-wý 4 AA F t -

Reviews:

TEvaluator Date Technical Review Die RM-79.doc

QA Verification Split Sample Analysis Table I Date: 9/14/2006 Acceptance Criteria Resolution Ratio QA: 06C,1 South Central Protected Area <4 N/A 4-7 0.5-2.0 Type: Split Sample 8-15 0.6-1.66 16-50 0.75-1.33 Lab: In-House 51-200 0.8-1.25

>200 0.85-1.18 A B C D E F (3 BRP BRP BRP Results in Sample Radionuclide Result Results % Error BRP Ratio Results ResltsRatioSplit Results Rati Comparison Agreement Below Resolution (pCi/g) Compare MDA (pCi/g) (Sigma) (Table 1) Below MDA F/A G with D) 12 Co-60 < 0.0624 n/a n/a n/a < 0.0638 1.02 YES 12 Cs-137 < 0.0612 n/a n/a n/a < 0.0622 1.02 YES A"

Resolution C = -

(A)( IB I

< Indicates results less than the MDA.

Note Results are considered in agreement for MDA and near-MDA measurementcomparisons Results fthat fail agreement must be investigated per RM-79.

QA Verification Sample Recount Analysis Table 1 Date: 9/14/2006 Acceptance Criteria Resolution Ratio QA: 06C,1 South Central Protected Area <4 N/A 4-7 0.5-2.0 Type: Sample Recounts 8-15 0.6-1.66 16-50 0.75-1.33 Lab: In- House 51-200 0.8-1.25

>200 0.85-1.18 A B C DE F G BRP BRP BRP Acceptance Recount Recount Comparison Agreement Sample Radionuclide Result Below Results % Error RReonAgemt Ratio Resolution Result Results Ratio Compare S (pCi/g) (Sigma) ( Table 1) el (pCi/g) F/A Compare MDA pg, Iga(Tbe Below MDA G with D) 14 Co-60 < 0.0639 n/a n/a n/a < 0.0749 1.17 YES 14 Cs-137 0.0417 38.44 2.60 n/a 0.0671 1.61 YES 16 Co-60 < 0.0612 n/a n/a n/a < 0.0479 0.78 YES 16 Cs-137 < 0.0598 n/a n/a n/a 0.0506 0.85 YES Resolution C= (Al OO

< Indicates results less than the MDA.

Note Results are considered in agreement for MDA and near-MDA measurement comparisons Results flhat fail agreement must be investigatedper RM-79.

.4 if Tritium in Soil Data Results Final Status Survey 06C 1 1 Sample Tritium in Soil Number pCi/g 12 0.007 14 0.015 16 0.024 Mean: 0.0153 Median: 0.0150 St. Dev: 0.0085 Note: The DCGL for Tritium is 327 pCi/g.

Sample results are less than 0.02% of the DCGL

-

Environmental, Inc.

Midwest Laboratory an Allegheny Technologies Co.

700 Landwehr Road - Northbrook, IL 60062-2310 ph. (847) 564-0700

fax (847) 564-4517 Mr. David W. Parish LABORATORY REPORT NO. 8022-100-230 Big Rock Point DATE: 09-22-2006 10269 US-31 North SAMPLES RECEIVED: 09-19-2006 Charlevoix, MI 49720 PURCHASE ORDER NO:

Below are the results of the analyses for tritium on three soil samples.

Excavated Soil Survey 06C1 l Sample Collection Lab Concentration MDA Description Date Code (pCi/g of soil) (pCi/g of soil)

H-3 12 09-14-06 BRSO-6372 0.007 +/- 0.006 <0.011 14 09-14-06 BRSO-6373 0.015 +/- 0.008 < 0.014 16 09-14-06 BRSO-6374 0.024 +/- 0.007 < 0.013 The error given is the probable counting error at 95 % confidence level. The less than, (<), value is based on 4.66 sigma counting error for background sample.

APPROVED BY- J-0ý4//& A Tony Coorlim, Quality Assurance

t~

ATTACHMENT 5 CONSUMERS ENERGY BIG ROCKPOINT DOCKET NUMBERS 50-155 AND 72-043 TRANSMITTAL OF SURVEY PACKAGES IN SUPPORT OF BIG ROCK POINT PHASED LICENSE TERMINATION CLASS I RELOCATED SOIL RELEASE RECORD, TBCx1 51, RELOCATED SOILS FROM TURBINE BUILDING/CONTAINMENT DEMOLITION October 24, 2006 38 Pages

Supporting Survey, Relocated Soil Release Record TBCx151 Relocated Soils From Turbine Building/Containment Demolition SURVEY PACKAGE CLOSURE Final Status Survey Documentation is authorized for closure. All required reviews are complete and the evaluation of data results have satisfied the criteria established for unrestricted release and onsite use for excavation backfill.

Sianedýý' -ý5 -5sy-ýý Date: io(Z.5 (ESSG Supervisor) '

z/ /

Signed: Date:

'S Superintendent)

Signed: Date:

(RP & ES Manager)

I-,

Survey Requirements Release Record TBCx51 l Relocated Soils From Turbine Building/Containment Demolition Area Survey Description Supporting survey TBCX15 1 consists of soils excavated during Turbine/Containment demolition and the removal of subsurface piping components. The excavated soil was transported to the soil verification area (SVA) and graded to maximum depth of 1.0 meter. The physical size of the survey area is 1800 square meters.

The evaluation of excavated soil will be performed in accordance with procedure RM-76, Final Status Survey Design. Sample locations will be established by random start, systematic square grid pattern over the graded area. Each soil sample will be a full core homogenized composite that is representative of total soil thickness. Surface scanning will be conducted over 100% of the survey area.

History The soil for survey evaluation originated from a Class 1 area that was excavated to remove concrete and piping components in the Turbine Building/Containment demolition area. Soil remediation efforts were required for some areas associated with subsurface component removal.

Current Radiological Status Based on post remediation analyses and supporting surveys the residual radioactivity in this excavated soil is not expected to exceed DCGL concentration values. Survey documentation is maintained in the 10 CFR 50.75(g) files. Input for this evaluation includes the following survey data:

Turbine Building Demolition Supporting Surveys for Soil Transport and Evaluation TB051005 SB040405 SB042905 TB062805 HH060705 TB052405 SB040605 SB050205 HH050505 TB060905 TB052505 SB040705 SB051705 HH051705 TB080805 TB052605 SB041205 SB051805 HH051905 TB080905 TB060105 SB041905 HH042705 HH041905 Survey Requirements TBC.isI Page 1 of 2

40ý i Post-Construction Expectations Survey TBCx151 will be performed in the following activity sequence:

1. Walkdown: Environmental Services Survey Group (ESSG) personnel will perform a walkdown assessment to ensure survey area preparations are complete and confirm that the following post-construction expectations have been satisfied as applicable:

0 Groundwater and Surface water control is adequate 0 All construction debris has been removed from the survey area 0 The survey location status meets all applicable safety requirements

2. Survey Area Isolation and Control: Control measures will be established to ensure that any potential ongoing decommissioning activities in adjacent locations do not impact the current survey area status. Isolation and control measures include postings, barriers, access points, and the evaluation of ongoing work activities in adjacent areas.

3. Survey Design and Execution: Survey design and execution will follow the Data Quality Objectives for TBCxl 51 in accordance with the survey requirements established in procedures RM-76, Final Status Survey Design and RM-77, Final Status Survey Implementation, and LTP, Chapter 5. Survey size will be based on the statistical requirements of the Sign Test for Class 1 areas with soil samples collected in random start, systematic data point locations. Surface scanning will be performed with 100%

survey area coverage. This survey will be conducted in accordance with approved BRP procedures and follow the guidance of NUREG 1575.

4. Data Quality Assessment: Isolation and control of the survey area will be maintained until the survey Data Quality Assessment demonstrates that the regulatory requirements for unrestricted site release have been satisfied.

Survey Requirements TBCX1 51 Page 2 of 2

DATA QUALITY OBJECTIVES Survey TBCx15 1 Relocated Soils From Turbine Building/Containment Demolition Area STATE THE PROBLEM The Problem:

To demonstrate that the level of residual radioactivity in soils excavated from the Turbine Building/Containment demolition area does not exceed the release criteria of 25 mrem/year Total Effective Dose Equivalent (TEDE) as specified in the License Termination Plan (LTP). This soil has been relocated to the soil verification area (SVA) and is to be prepared for survey by grading out to a depth of one (1) meter or less. The excavated soil for evaluation is to be designated as a Class 1 survey area. It must be demonstrated that soils in this survey area satisfy the criteria established for unrestricted release prior to disposition as fill material for onsite usage.

Stakeholders:

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

The Planning Team:

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

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

Schedule:

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

Resources:

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

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

PrincipalStudy Question (1):

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

Data Quality Objectives TBC,15 1 Page 1 of 5

Decision (1):

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

Actions (1):

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

PrincipalStudy Question (2):

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

The Decision (2):

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

Actions (2):

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

PrincipalStudy Question (3):

Is the potential dose from residual radioactivity in the survey unit ALARA as stated?

The Decision (3):

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

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

Actions (3):

Alternative actions include remediation or no action required.

3. IDENTIFY INPUTS TO THE DECISION Information Needed:

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

Source of the Information:

The soil sample data to be used for survey development are the radionuclide-specific measurements of representative soil samples collected for characterization to determine suitability for transport to the SVA. The soil samples obtained were judgmentally selected as a result of multiple surveys conducted during the excavation and transport process. The ALARA analysis for potential soil remediation is provided in LTP, Section 4.4. Site-specific DCGL values and BRP radionuclides of interest are defined in LTP Chapter 5, Table 5-1 and Procedure RM-76, Final Status Survey Design.

The survey will be conducted in accordance with applicable regulatory guidance as established in LTP Chapter 5 for Class 1 areas. Soil samples will be utilized for radionuclide-specific measurements in this evaluation.

Data Quality Objectives TBC, 15 1 Page 2 of 5

4. BOUNDARIES OF THE STUDY Boundaries of the Survey:

The target population for this survey is the total thickness of prepared soil in the survey area of 1800 M2 .

Temporal Boundaries:

Scanning and sampling in this survey unit will only be performed during daylight hours under dry weather conditions. Surface soils must be free of significant snow cover and standing water prior to surface scanning. Soils must be in a non-frozen state or fragmented for collection to satisfy BRP procedural sampling requirements. The anticipated start date for the survey is September 22, 2006.

Constraints:

Cold weather or rainy conditions may effect the operation of electronic equipment.

Adverse weather conditions that include accumulations of rain or snow may limit area access and delay survey efforts.

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

Decision Rule (1):

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

Decision Rule (2):

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

Decision Rule (3):

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

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

Data Quality Objectives TBCx151 Page 3 of 5

Decision Rule (4):

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

6. SPECIFY TOLERABLE LIMITS ON DECISION ERRORS The Null Hypothesis:

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

Type I Error(a ):

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

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

Type II Error(/3):

The ,8 error is the probability of accepting the null hypothesis when it is false. A value of 0.05 (5%) will be used for survey planning and data assessment for this survey area.

The Lower Bound of the Gray Region (LBGR):

The LBGR is initially set at one-half the DCGLw for this survey unit. The LBGR may be adjusted during survey design to achieve an optimum relative shift between 1.0 and 3.0.

Relative Shift (A/a):

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

7. OPTIMIZE DESIGN FOR OBTAINING DATA Statistical Test Sign Test:

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

Number of Samples Determined:

The number of samples required for this survey will be determined based on the relative shift as defined by the requirements of the Sign Test (LTP, Chapter 5.) and Procedure RM-76, FinalStatus Survey Design. The LBGR is initially set at one-half the DCGLw and may be adjusted as necessary for optimizing the survey design to achieve a relative shift between 1.0 and 3.0. Sample point locations are to be determined using a random start, systematic square grid spacing.

Data Quality Objectives TBC 1 51 Page 4 of 5

Judgmental Sampling:

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

Scan Coverage:

Scanning for this survey area will provide 100% coverage.

Number of Samples for Quality Control:

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

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

Additional Sample Analysis Requirements:

The area of soil excavation intersects the identified waterborne pathway for Tritium migration and shall require Tritium in soil analyses for a minimum of 10% of the sample population. Soil samples will be collected in the same random locations as those selected for QA/QC evaluation and sent to an independent laboratory for Tritium analysis. Data results will be provided in the survey package.

Investigation Levels:

Investigation levels defined in LTP, Chapter 5 and BRP Procedure RM-76, Final Status Survey Design, shall be conservatively established for this survey as shown below:

Investigation Levels for Survey TBCx1 51 Scan Measurement Soil Sample Analysis

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

Data Quality Objectives TBC, 15 1 Page 5 of 5

SURVEY DESIGN Survey TBCx 5sl Survey Design Relocated Soils from Turbine Building/Containment Demolition Area Survey Unit Description Survey TBCx15 1 consists of excavated soils that have been removed from the Turbine Building/Containment demolition area for subsurface structure and component removal. Areas of excavation include the Containment foundation and the following subsurface piping and components:

Underground diesel storage tank (heating boiler),

Condenser cooling water piping,

Service water and firewater piping

East side storm drain, and

Radwaste effluent piping in Survey Units 8, 9, and 10.

The soil has been graded out to a maximum thickness of one (1) meter over a total area of 1800 M2. Soil sample locations for this survey will be determined using a random start, systematic, square-grid pattern over the graded area. Each soil sample will be a homogenized composite representative of the total thickness of soil. Surface scanning will be conducted over 100% of the graded area.

Soil Sample Design Scoping Data Sample measurements obtained to determine suitability for soil transport to the designated survey area have not identified residual radioactivity above fractional concentrations of the DCGL value. Input data for survey design were conservatively estimated based on supporting surveys for transport suitability obtained in the Turbine Building demolition area.

Table 1 Input Data for Survey Design (pCi/g)

Radionuclides Cs-137 Co-60 a

0.524 0.255 DCGL 11.93 3.21

Survey data detailed in Attachment 1 Sample Requirements The number of sample data points for this survey is based on the requirements of the Sign Test.

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

= ICDCG~cs1

37) +C~o Survey Design TBCx151 Page 1 of 8

,/0.524 '2 (f0.255'2

(= 0.091 Relative Shift Relative Shift = DCGLw-LBGR G

Relative Shift = 1-0.818 0.091 Relative Shift = 2.0 With cc and P3 error levels set at 0.05 and the relative shift of 2.0, the Sign Test requires 15 sample data points (Table 5.5 NUREG 1575).

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

Table 2 Random Numbers Random #, X Axis 0.341663 +/- Random #, Y Axis 0.184214 Survey Unit Dimensions: X = 150 meters Y = 12 meters Random Start Location X = (0.341663)(150) = 51.2 meters With SW Corner Origin: Y = (0.184214)(12) = 2.2 meters Sample Spacing As a conservative measure sample spacing will be calculated based on 18 samples for this survey. Samples are located in a systematic square grid pattern with sample spacing determined by the following:

L=A!n where A= area of survey unit, and n = number of samples.

L, 18 = 10 meters

= 180 Survey Design TBCý15 1 Page 2 of 8

With sample spacing established at 10 meters, 15 data points are available for this survey.

Data point locations are identified in Attachment 2.

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

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

Table 3 Random Numbers Generated for QA/QC Random Random QA/QC Soil Sample Verification Scan Sample Samples Number Number Split Sample: 2 Start Point: 8 Sample Recount: 4 Scan Toward: 2 Sample Recount: 7 Minimum Scan Area Requirement: 180 M 2 Surface Scanning The coverage requirement for surface scanning in this Class 1 area is 100%. The Scan MDc has been established at fractional values of the DCGLwfor typical background activity levels at Big Rock Point. Scan MDc values for varying backgrounds are provided in Attachment 3. The investigation level for identification of potential areas of elevated activity in this survey area will be the Scan DCGL as defined by the following:

Scan DCGL = Detector Rating CPM

Exposure Model uR/hr , DCGLw uR/hr pCi/g Scan DCGL for Co-60 = 1818 CPM Scan DCGL for Cs-137 = 3518 CPM Where:1 Detector Rating = 1200 CPM Cs-137 and 565 CPM Co- 60 uR/hr uR/hr Exposure Model = 1.229uR/hr Cs-1 37 and 5.029 uR/hr Co_-60 5pCi/g 5 pCi/g DCGLw = 11.93 pCi/g Cs-137 and 3.21 pCi/g Co-60 These values established in EA-BRP-SC-0201, Nal Scanning Sensitivity for Open Land Survey.

Survey Design TBC 15 1 Page 3 of 8

The DCGLw for Co-60 is the most limiting value for scanning measurements performed to identify areas of potentially elevated activity. Scanning conducted for this survey will assume all residual radioactivity to originate from Co-60 and the instrument response at the Co-60 DCGLw (1818 cpm) will be used as the scanning investigation level for Survey TBCx15 1.

Survey Design TBC,151 Page 4 of 8

Attachment 1 Design Data - Survey TBCx,1 5 Relocated Soils From Turbine Building Demolition Area Cs-I 37 Co-60 Survey No. Sequence Activity Activity No. (pCi/g) (pCi/g)

H H060705, 1'6538 :126 0,66'

-HH06070'5r 1653;9 0.06 0.06*

HH675 16540 1.05 0ý66 TB062805t -16755& 11 0.27 TB062805, C11617665 ý4ý7*, 5ý*

oTB062805 1"6774 019 03 Mean: 0.698 0.352 Std Dev: 0.524 0.255

Measurement system MDA - Co-60 not identified in this sample Survey Design TBCx15 1 Page 5 of 8

Attachment 2 Soil Sample Locations - Survey TBC, 151 Relocated Soils From Containment/Turbine Building Demolition Area V=IV)

=

X= 150 M

- Sol Pise 0 5 10 20 Motors 0 8an~e Location 1L+/-.- LL.-

Sample no. 6 Is the random start location Sample spacing Is 10.0 meters Survey Design TBCxist Page 6 of 8

Attachment 3 Scan MDC In Varying Backgrounds Background d' _ Si MDCRsurveyor Cs-137 Co-60 Cs-137 Co-60 2000 2.48 4 28.64 607.47 0.51 1.08 2.06 1.07 3000 2.48 4 35.07 744.00 0.62 1.32 2.52 1.31 3500 2.48 4 37.88 803.61. 0.67 1.42 2.72 1.41 4000 2.48 4 40.50 859.10 0.72 1.52 2.91 1.51 4500 2.48 4 42.95 911.21 0.76 1.61 3.09 1.60

______2.480 - 4 4.8 -, 960.5,0 >0ý18O< ~1A7d 32~~ 1 5500 2.48 4 47.49 1,007.38 0.84 1.78 3.42 1.77 6000 2.48 4 49.60 1,052.17 0.88 1.86 3.57 1.85 6500 2.48 4 51.63 1,095.14 0.91 1.94 3.71 1.93 7000 2.48 4 53.57 1,136.48 0.95 2.01 3.85 2.00 8000 2.48 4 57.27 1,214.95 1.01 2.15 4.12 2.14 8500 2.48 4 59.04 1,252.34 1.04 2.22 4.25 2.20 9000 2.48 4 60.75 1,288.65 1.07 2.28 4.37 2.27 9500 2.48 4 62.41 1,323.96 1.10 2.34 4.49 2.33 10500 2.48 4 65.61 1,391.90 1.16 2.46 4.72 2.45 11000 2.48 4 67.16 1,424.65 1.19 2.52 4.83 2.51 11500 2.48 4 68.67 1,456.67 1.21 2.58 4.94 2.56 12000 2.48 4 70.14 1,488.00 1.24 2.63 5.04 2.62 1240,0 U4 7.859

71. -i586 1.27 12:9 5. 1;5 i2.67 13000 2.48 4 73.01 1,548.76 1.29 2.74 5.25 2.73 13500 2.48 4 74.40 1,578.26 1.32 2.79 5.35 2.78 14000 2.48 4 75.77 1,607.22 1.34 2.84 5.45 2.83 14500 2.48 4 77.11 1,635.67 1.36 2.89 5.55 2.88 Sxpsr

5" ý:(iR/hrfl5p)i~j.

5,03Ej00

ýC4$151;23E+OO,_____

Survey Design TBC, 151 Page 7 of 8

Attachment 4 Area Factors for Open Land Survey Evaluation Calculated Area Factors at Time of Peak Dose Area (Mt) H-3 Mn-54 Fe-55 Co-60 Sr-90 Cs-137 Eu-152 Eu-154 Eu-155 8094 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 4047 1.00 1.01 1.00 1.01 1.00 1.02 1.02 1.01 1.02 2024 1.00 1.03 1.00 1.03 1.00 1.03 1.03 1.03 1.03 1012 1.35 1.04 1.00 1.04 1.00 1.04 1.05 1.04 1.04 506 2.91 1.09 1.98 1.08 1.98 1.13 1.07 1.07 1.06 253 6.05 1.14 3.95 1.13 3.94 1.20 1.11 1.11 1.09 126 12.4 1.20 7.93 1.20 7.87 1.29 1.17 1.16 1.14 63 24.9 1.30 15.8 1.30 15.6 1.41 1.27 1.26 1.23 32 49.2 1.49 31.2 1.49 30.5 1.62 1.44 1.45 1.39 16 98.9 1.78 62.0 1.78 59.9 1.93 1.72 1.73 1.63 8 198 2.38 123 2.38 117 2.58 2.30 2.31 2.14 4 397 3.61 243 3.62 230 3.91 3.49 3.52 3.19 2 794 5.68 473 5.75 452 6.14 5.48 5.55 4.90 1 1590 9.57 905 9.73 887 10.3 9.24 9.39 7.88 Survey Design TBC. 151 Page 8 of 8

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

Description:

Survey TBCx15 1 is the final status evaluation of soil that was excavated from the Turbine Buildingq/Containment demolition area. The soil has been relocated to the SVA and prepared for survey by -gradingq to a maximum depth of 1 meter over an area of 1800 square meters.

The survey area is authorized for Final Status Survey Implementation.

...2-/D-ate o Designed by Date on- I*-'*Im~o Technical Review by Date RM-76.doc

RM-77 Revision 2 FINAL STATUS SURVEY IMPLEMENTATION Page 8 of 12 RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 1 of 3 Step Initial Date

(+)

1.0 PREPARATION FOR SURVEY Survey #

1.1 Survey Area Status:

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

1. Survey area walkdown complete

2. Survey area determined ready for FSS

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

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

/ b. Survey area has been turned over to the Environmental Services Survey Group (ESSG) in acceptable condition for FSS. 4ý-Iw(a 1.2 Field Preparation:

+ a.

b.

Survey unit boundaries delineated (Step 6.1.1)

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

(Step 6.1.2)

c. Soil sample locations verified (Step 6.1.2.c)

d. Instruments and equipment have been collected and calibrated for data measurement and collection (Step 6.1.3)

/ e. Field documentation is prepared (Step 6.1.4) (/ESSG RM-77.doc

RM-77 Revision 2 FINAL STATUS SURVEY IMPLEMENTATION Page 9 of 12 RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 2 of 3 Initial Date 2.0 DATA COLLECTION 2.1 Soil Survey:

All soil samples collected and controlled (Step 6.2.1).

EdSSG_

OIL4,ýrlo &

2.2 Surface Scan:

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

62;ý 2.3 Judgmental Soil Samples:

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

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

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

/ a. Soil samples are homogenous

b. Soil samples are visibly dry prior to packing

c. Non-soil materials have been removed from sample

d. Soil samples have been transferred to one-liter Marinelli containers and are labeled and sealed. d4z ,22Zzs1-(;(0 JESSG RM-77.doc

RM-77 Revision 2 FINAL STATUS SURVEY IMPLEMENTATION Page 10 of 12 RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 3 of 3 Initial Date 3.2 Laboratory Analysis:

Isotopic analyses are complete. The spectroscopy report requires a signature of completion by the laboratory analyst and a signature of evaluation documenting that a second level review has been performed (Step 6.4.2). SSG 3.3 Sample Control and Documentation:

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

eME8SG bý Date Reviewed 7

RM-77.doc

RM-59 Revision 11 SAMPLING AND ANALYSIS OF OPEN LAND Page 7 of 13 AREAS FOR SITE CHARACTERIZATION SURVEYS ATTACHMENT RM-59-1 SAMPLING AND ANALYSIS REPORT Date: 09-22-06 Time: 1600 I Location: TBC. 15 1 Tech:WMHILED/JHW/JNS SURVEY IDENTIFICATION I DESCRIPTION 1

Survey TBC x15 consists of excavated soils removed from the Turbine/ Containment Building demolition area and the removal of subsurface Dinino and components. The phvsical size of the survey prep is ISMlfl SURVEY TYPE Survey Type: Characterization X Scan (Motive)

Remediation Scan (Static)

X Final Trenching and Digging (use RM-59-4)

SURVEY DESIGN Sample Collection: _ Judgmental _ Random X Systematic Large Container Assay Scan Coverage: 100 %

ANALYSIS Inst.SN/Cal Due 186194/02-08-2007 DAILY CHECK: X SAT UNSAT INIT: WMH Inst.SN/Cal Due 186192/03-14-2007 DAILY CHECK: X SAT UNSAT INIT: WMH Inst.SN/Cal Due 201195/02-10-2007 DAILY CHECK: X SAT UNSAT INIT: WMH Inst.SN/Cal Due 189086/01-26-2007 DAILY CHECK: X SAT UNSAT INIT: WMH Inst.SN/Cal Due Det #6 DAILY CHECK: X SAT UNSAT INIT: JP Investigation of Unidentified Peaks: X SAT UNSAT INIT: JLR Minimum Detectable Activity (Section 5.3.2) X SAT UNSAT INIT: JLR COMMENTS Survey TBC 15 1 was performed in a random start, square grid, systematic sampling pattern with samples Collected at 15 data point locations. Laboratory analyses did not identify residual radioactivity above trace Levels of the DCGL value. Surface scannina at 100% coveraae identified no areas of elevated residual Radioactivity. The results of QA/QC verification scanning (10% coverage) were consistent with the scan values identified in the survey.

A PJ Technician Signature: Date: ______i_____

Second Level Review Signature: _6 4 Date: /Z2-O0 RM-59.doc

Soil Sample Activity Summary Release Record TBCx1 51 Relocated Soil from Containment/Turbine Building Demolition Area Y= 12m X = 150 m

- Soil Pile 0 5 10 20 I I i I I I I I Meters S Sample Location Prorcea-count values Coordinate location relative to SW comer of survey unit where X=O m. and Y=O m.

Surface Scan Summary Release Record TBCx1 51 Relocated Soil from Containment/Turbine Building Demolition Area 4.2 4.5 4.3 4.4 4.2 4,2 4.0 4.4 4.0 3.8 4.3 4.0 4,2 4.1 4 .2 0Soil Pile 0 5 10 20

Sample Location I 1 i i I 1 , 1 IMeters RED Values are Average Mobile Scan General Area Activity (kcpm)

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

GREY Values are Average General Background Area Activity (kcpm)

Primary Scan: / * %_xwo TechnIcian Signature: Date: 2-:t-O; Time: Mlop QC Verification Scan: 10 %

Technician Signature: Date: * *?.-

Time: IS'"

RM-72 Revision 0 SAMPLE CHAIN-OF-CUSTODY Page 4of 5 TBCx151 RM-72-1 CHAIN-OF-CUSTODY RECORD Sample Number Sampling Location Date Time Final Disposition of Sample 1 (1.2)(2.2) q-*-o6 / 3a* e_* *.y,'-v ro.

2 (11.2)(2.2) " -

23 QASplit (11.2)(2.2) 7-7 gsj0j/L(130 25"o-9~cl, 3 (21.2)(2.2) I L- 1-15'o4 4 .. (R) (31.2)(2.2) ýS-c6/3 /

5 (41.2)(2.2) -'061 £ t 3 2" 6 (51.2)(2.2) 7- d'-e6 1/ 3 11" 7 (1) (61.2)(2.2) -,-*5-od; ! 3 d/

8 (71.2)(2.2) 7-.-5,01 132j 3 9 (81.2)(2.2) cI-,5"o6 1 39*-S 10 (91.2)(2.2) 7- 0 OK 3d7o 11 (101.2)(2.2) I 3"c""° d,

12 (111.2)(2.2) 7"o5'O6 /3 A 13 (121.2)(2.2) 9"O 1330 14 (131.2)(2.2) -"A.S'o6 13 3A 15 (141.2)(2.2) ', ;5-06 1 33_ _ _ _ _ _ _ _

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

1. Relinquis, d by: *-4/*o1*. Date Time Received in go condition by:

3. Relinquished by Date Time Received in good condition by:

3. Relinquished by: Date Time Received in good condition by:

4. Relinquished by: Date Time Received in good condition by:

RM-72.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 19 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 1 of 8 FINAL STATUS SURVEY: "1' w/

1.0 DATA VERIFICATION 1.1 Data Acceptance X Review the Implementation Checklist (RM-77-1) to verify that survey isolation and control measures were executed prior to FSS and are being maintained.

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

1.2 Field QC Records:

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

Comments:

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

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

1.3 Review Verification:

7' Verify that the Data Quality Objectives are complete.

.. Verify that the survey design has been technically reviewed.

RM-78.doc

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

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

Data Verilfication Completed: No Comments Assessor Dafe RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 21 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 3 of 8 2.0 DATA VALIDATION 2.1 Documentation Review:

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

Field measurement records Chain-of-custody Quality Control (QC) measurement records Current qualification of survey personnel Corrective Action Reports Data inputs (laboratory spectroscopy)

Sample preparation techniques 2.2 Detection Limit Review:

___ Scan MDCs are below established site DCGLs.

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

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

2.3 Quality Control (QC) Data Review:

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

4 Results of judgmental samples have been reviewed and evaluated.

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

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 22 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 4 of 8 2.4 Qualification of Data:

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

a. Total number of statistical samples planned for the survey:

b. Total number of statistical samples determined as valid: /

b x120

c. Calculate % Completeness: -/,-" ()ý0 --

a

_zQualified data are A 00% completeness and are sufficient to support the Sign Test requirement for determination of unrestricted release.

Data Validation Completed: No Comments:

A~s'ses'so r Date RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 23 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 5 of 8 3.0 DATA QUALITY ASSESSMENT 3.1 Review the DQOs and Survey Design:

X1 Confirm that all inputs to the decision have been reviewed and are complete.

Z1* Verify that boundaries or constraints identified in the survey area have not affected the quality of the data.

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

__ Confirm that Type I and Type IIerror limits are consistent with DQOs.

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

3.2 Preliminary Review:

3.2.1 Preliminary Evaluation:

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

v/ Survey is of sufficient intensity to satisfy classification requirement.

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

Comments:

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 24 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 6 of 8 3.2.2 Calculate Basic Statistical Quantities:

a. Number of qualified data points

b. Calculation of the Mean O2ocOV

c. Calculation of the Median

d. Calculation Standard Deviation Attach graphic representation of the data if any radionuclide-specific measurements exceed 50% of the DCGL.

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

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

.wj" All survey measurements are below the DCGLw.

3.3.1 Verify Assumptions of the Survey Design

-__ Review the posting plot to verify that the data exhibits spatial independence. Spatial trends must be investigated and resolved prior to further assessment.

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

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 25 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 7 of 8 X/ Review the dataset standard deviation and range for data variance.

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

_ Verify that the data exhibits adequate power and confirm that the sample size is sufficient to satisfy the DQOs.

3.4 Draw Conclusions from the Data:

3.4.1 Investigation Levels and Response Actions Determine if data results have exceeded any inyestiation level.

Document findings.

3.4.2 Evaluation for Unrestricted Release Select applicable conclusion:

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

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

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

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 26 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 8 of 8

_A4L Survey area acceptance criteria not met and survey area fails to satisfy the requirements for unrestricted release:

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

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

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

Data Quality Assessment Completed: O*No W)

Comments Assessor Date Reviews:

Technical Oview bate ES Superintendent Date RlM&ES Manager Date RM-78.doc

RM-78-3, Attachment I Statistical Quantities Release Record TBCx1 51 Relocated Soil from Containment/Turbine Building Demolition Area Sample Cs-I 37 Co-60 Weighted **Weighted Sum Number (pCi/gm) (pCi/gm) Sum (SOR) <DCGLw? DCGL-W. Sum Sign 1 0.0694 0.0121 0.0096 yes 0.9904 +1 2 0.0431 0.0065 0.0056 yes 0.9944 +1 3 0.0391 0.0283 0.0121 yes 0.9879 +1 4 0.0299 -0.0181 -0.0031 yes 0.9969 +1 5 0.0190 -0.0144 -0.0029 yes 0.9971 +1 6 0.0256 0.0002 0.0022 yes 0.9978 +1 7 0.0332 0.0000 0.0028 yes 0.9972 +1 8 0.0442 -0.0209 -0.0028 yes 0.9972 +1 9 0.0183 0.0151 0.0062 yes 0.9938 +1 10 -0.0020 -0.0016 -0.0007 yes 0.9993 +1 11 0.0212 0.0003 0.0019 yes 0.9981 +1 12 0.0312 0.0206 0.0090 yes 0.9910 +1 13 0.0706 0.0144 0.0104 yes 0.9896 +1 14 0.0427 0.0319 0.0135 yes 0.9865 +1 15 0.0458 -0.0087 0.0011 yes 0.9989 +1 Std. Dev 0.0189 0.0161 0.0056 Mean 0.0354 0.0044 0.0043 Median 0.0332 0.0003 0.0028 Number of Positive Differences (S+): n/a Critical Value, k, Table 1.3 of Marssim: n/a S+ >thank?: n/a Survey Unit Pass or Fail:

- Pass

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

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

I. .

RM-79 Revision I FINAL STATUS SURVEY QUALITY CONTROL Page 11 of 13 RM-79-1 FSS QUALITY CONTROL EVALUATION RESULTS FSS Package # - QC Package #

QC Measurement Type Acceptance Criteria Met*? Reference

1. Replicate Scan --;/ No Step 5.1.3

2. Sample Recounts Step 5.1.4.1

a. In-house

No

, b. Third party Yes / No

3. Split Samples Step 5.1.4.2

c. In-house No 4,.,L/A d. Third party Yes / No

NOTE: IfAcceptance Criteria is not met, completion of Attachment RM-79-2, FSS Quality Control Investigation Results, is required.

Comments: Q A 44q - 4,4 1

_-i

/

Reviews:

Date

,Evaluator Technical Review Date RM-79.doc

QA Verification Split Sample Analysis Table 1 Date: 9/25/2006 Acceptance Criteria Resolution Ratio QA: TBC.,gl Excavated Soil from Contain. Bldg. Area <4 N/A 4-7 0.5-2.0 Type: Split Sample 8-15 0.6-1.66 16-50 0.75-1.33 Lab: In- House 51-200 0.8-1.25

>200 0.85-1.18 A B C D E F G RP BResults in Sample Radionuclide Result Below Results % Error BRP Resolution Acceptancetio Recount Recount Comparison Agreement Result Compare MDA (pCi/g) (Sigma) (Table 1) Belo (pCi/g) F/A CowphrD MABelow MDA G with D) 2 Co-60 < 0.0754 n/a n/a n/a < 0.0588 0.78 YES 2 Cs-137 0.0431 46.17 2.17 n/a < 0.0605 1.40 YES Resolution C=()t Indicates results less than the MDA.

Note Results are consideredin agreement for MDA and near-MDA measurementcomparisons Results fihat fail agreement must be investigatedper RM-79.

QA Verification Sample Recount Analysis Table I Date: 9/25/2006 Acceptance Criteria Resolution Ratio QA: TBC,,.l Excavated Soil from Contain. Bldg. Area <4 N/A 4-7 0.5-2.0 Type: Sample Recounts 8-15 0.6-1.66 16-50 0.75-1.33 Lab: In- House 51-200 0.8-1.25

>200 0.85-1.18

~t A B C D E F G RP BResults in Sample Radionuclide Result Results % Error BRP Ratio Recount Results Ratio Agreement Below (Sigma) Resolution 1' Result (pCi/g) F/A Compare MDA Below MDA G with D) 4 Co-60 < 0.0387 n/a n/a n/a < 0.0641 1.66 YES 4 Cs-137 < 0.0568 n/a n/a n/a < 0.0568 1.00 YES 7 Co-60 < 0.0541 n/a n/a n/a < 0.0442 0.82 YES 7 Cs-137 0.0332 44.44 2.25 n/a < 0.0547 1.65 YES Resolution C A)(aZ O

<Indicates results less than the MDA.

Note Results are consideredin agreement for MDA and near-MDA measurementcomparisons Results Ithat fail agreementmust be investigatedper RM-79.

n S -, 5'-

Tritium in Soil Data Results Final Status SurveyTBC, 15 1 Sample Tritium in Soil Number pCi/g 2 0.007 4 0.006 7 0.004 Mean: 0.0060 Median: 0.0060 St. Dev: 0.0010 Note: The DCGL for Tritium is 327 pCi/g.

Sample results are less than 0.2% of the DCGL

-Environmental, Inc.

Midwest Laboratory an Aliegheny Technologies Co.

700 Landwehr Road

Northbrook, IL60062-2310 ph. (847) 564-0700 . fax (847) 564-4517 Mr. David W. Parish LABORATORY REPORT NO. 8022-100-243 Big Rock Point DATE: 10-02-2006 10269 US-31 North SAMPLES RECEIVED: 09-27-2006 Charlevoix, MI 49720 PURCHASE ORDER NO:

Below are the results of the analyses for tritium on three soil samples.

Excavated Soil Survey TBCx1 5-1 Sample Collection Lab Concentration MDA Description Date Code (pCi/g of soil) (pCi/g of soil)

H-3 2 09-25-06 BRSO-6591 0.007 +/- 0.006 < 0.011 4 09-25-06 BRSO-6592 0.006 +/- 0.006 < 0.010 7 09-25-06 BRSO-6593 0.004 +/- 0.005 < 0.010 The error given is the probable counting error at 95 % confidence level. The less than, (<), value is based on 4.66 sigma counting error for background sample.

Sincerely, Bronia Grob, Laboratory Manager

-x APPROVED BY Tony Coorlim, Quality Assurance

ML070600673

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