ML12068A261

Final Status Survey Report, Attachment 14, Transport Roadways and Parking Lots, for the Plum Brook Reactor Facility

ML12068A261
Person / Time
Site:	Plum Brook
Issue date:	03/06/2012
From:	Kolb P US National Aeronautics & Space Admin (NASA)
To:	Document Control Desk, NRC/FSME/DWMEP
References
Download: ML12068A261 (92)

Text

National Aeronautics and Space Administration John H. Glenn Research Center Lewis Field Plum Brook Station Sandusky, OH 44870 March 6, 2012 QD Reply to Attn of:

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

Subject:

Final Status Survey Report, Attachment 14, Transport Roadways and Parking Lots, for the Plum Brook Reactor Facility, Licenses Nos. TR-3, Docket No. 50-30 and R-93, Docket No, 50-185 Enclosed for your review is Attachment 14 to the Final Status Survey Report supporting eventual termination of the licenses for the Plum Brook Reactor Facility.

The complete Final Status Survey Report will consist of a series of Attachments, each addressing an individual survey area or group of survey areas or environmental areas as described in our NRC approved Final Status Survey Plan. The final submission will be the main body of the Final Status Survey Report which will consolidate and summarize the details presented in the Attachments.

This Attachment addresses the Final Status Survey of the facility's Transport Roadways and Parking Lots. It supports our conclusion that radiological remediation of the roadways and parking areas has been completed and the areas meet the criteria for unrestricted release specified in 10 CFR 20.1402.

Should you have any questions or need additional information, please contact me a NASA Plum Brook Station, 6100 Columbus Avenue, Sandusky, Ohio 44870, or by telephone at (419) 621-3242.

NASA Decommissioning Program Manager 42 0

Enclosure

1. Plum Brook Reactor Facility Final Status Survey Report, Attachment 14, Transport Roadways and Parking Lots, revision 0, dated March 6, 2012.

cc:

USNRC/C. J. Glenn (FSME)

USNRC/J. Webb (FSME)

USNRC/J. Tapp RIII/DNMS/DB ODH/M. J. Rubadue

bcc:

Q/Official File

Plum Brook Reactor Facility Final Status Survey Report Attachment 14 Revision 0 Transport Roadways and Parking Lots

Document

Title:

Final Status Survey Report, Attachment 14 Transport Roadways and Parking Lots Revision Number: 0 ROUTING ii

NASA PBRF DECOMMISSIONING PROJECT CHANGE/CANCELLATION RECORD DOCUMENT TITLE: Final Status DOCUMENT NO: NA REVISION NO: 0 Survey Report, Attachment 14, Transport Roadways and Parking Lots Revision 0: Initial issue of Report IAD-01/31 Rev 1 iii

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 LIST OF EFFECTIVE PAGES DOCUMENT NO: NA REVISION NO: 0 Page No. Revision Level Page No. Revision Level Page No. Revision Level Cover Page 0 Routing & Approval Sheet Change/Cancellation 0 Record LOEP 0 TOC 0 List of Tables & List 0 of Figures List of Acronyms & 0 Symbols, 2 pages Text, 29 pages 0 Appendix A 0 34 pages Appendix B 0 18 pages

4. .3 4 .3 4

4. .3 4 .3 4

___ I I I I 7~7 I AD-Oi/S I L.~rLJ iv

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 TABLE OF CONTENTS 1.0 Introduction ............................................................................................................. 1 2.0 PBRF Site Description and History .......................................................................... 2 2.1 PBRF Site Description ............................................................................................. 2 2.2 History of PBRF Construction and Operation ........................................................ 5 2.3 Final Configuration and Scope of FSS ..................................................................... 6 3.0 Operations with Radioactive Materials ................................................................... 7 3.1 Startup and Operations ............................................................................................. 7 3.2 Disposition of Materials in the Post-Shutdown Period ............................................ 8 3.3 Site Characterization ................................................................................................ 8 3.4 Decommissioning ................................................................................................ 12 4.0 Survey Design and Implementation ....................................................................... 12 4.1 FSS Plan Requirements ........................................................................................... 13 4.2 Area Classification and Survey Unit Breakdown .................................................. 15 4.3 Number of Measurements and Samples ................................................................ 16 4.4 Instrumentation and Measurement Sensitivity ...................................................... 19 5.0 Survey Results ......................................................................................................... 21 5.1 Scan Surveys .......................................................................................................... 22 5.2 Fixed Measurements and Tests .............................................................................. 22 5.3 Removable Surface Activity Measurements .......................... 24 5.4 QC Measurements .................................................................................................. 24 5.5 ALARA Evaluation ................................................................................................ 25 5.6 Comparison with EPA Trigger Levels .................................................................. 26 5.7 Conclusions ........................................................................................................... 27 6.0 References ..................................................................................................................... 27 7.0 Appendices ........................................................................................................... 29 Appendix A - Exhibits Appendix B - Survey Unit Maps and Tables Showing Measurement Locations and Results v

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 LIST OF TABLES Table 1, Summary of SR-18 Core Bore Sample Results .......................... 10 Table 2, Radionuclide Activity Fractions and Gross Activity DCGLs .................................... 14 Table 3, Class-Based Survey Scan Coverage and Action Level Requirements ....................... 14 Table 4, Transport Roadways and Parking Lots - Survey Units for FSS ................................ 15 Table 5, TRPL Survey Design Summary ................................................................................. 17 Table 6, Sensitivity Analysis for FSS Design .......................................................................... 18 Table 7, Typical Detection Sensitivities of Field Instruments .................................................. 20 Table 8, Scan Survey Results for Transport Roadways and Parking Lots ................ ................... 22 Table 9, Total Surface Beta Activity Measurement Summary and Test Results ..................... 23 Table 10, Replicate QC M easurements ................................................................................... 25 Table 11, Screening Level Values and Radionuclide Activity Fractions ................................. 26 LIST OF FIGURES Figure 1, PBRF Site Map Showing Roadways inside the 27 Acre Restricted Area ................... 3 Figure 2, Layout of Transport Roads and Parking Lots Showing Survey Units ........................ 4 vi

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 LIST OF ACRONYMS & SYMBOLS a alpha; denotes alpha radiation, also type I error probability in hypothesis testing AEC Atomic Energy Commission ALARA As Low As Reasonably Achievable ATS Assembly Test Storage, Building 1121 beta; denotes beta radiation, also type II error probability in hypothesis testing bi background counts in observation interval BR Background count rate BPL Byproduct License CFR Code of Federal Regulations cm 2 centimeters cm square Centimeters cpm counts per Minute A delta, DCGLw - LBGR d9 Scan surveyor sensitivity index DCGL Derived Concentration Guideline Level DCGLEMc DCGL for small areas of elevated activity, used with the Elevated Measurement Comparison test (EMC)

DCGLw DCGL for average concentrations over a survey unit, used with statistical tests.

(the "W" suffix denotes "Wilcoxon")

dpm disintegrations per minute Ei Detector, or instrument efficiency E, Surface efficiency Total efficiency EMC Elevated Measurement Comparison EPA US Environmental Protection Agency FSS Final Status Survey FSSP Final Status Survey Plan FSSR Final Status Survey Report Y gamma, denotes gamma radiation g gram gpm gallons per minute HTD Hard To Detect HSOO Health Safety Operations Office i observation counting interval during scan surveys in. inch LMI Ludlum Measurements, Inc.

LBGR Lower Bound of the Gray Region m2 square meters MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MDC Minimum Detectable Concentration; also identified as MDA, minimum detectable activity MDCscan Minimum Detectable Concentration for scanning surveys MDCstatic Minimum Detectable Concentration for static surface activity measurements MDCR Minimum Detectable Count Rate vii

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 LIST OF ACRONYMS & SYMBOLS, Continued mrem millirem MOU Memorandum of Understanding MW Megawatt MWH Montgomery Watson Harza, Inc.

NACA National Advisory Committee for Aeronautics NASA National Aeronautics and Space Administration N Number of FSS measurements or samples established in a survey design Nal Sodium Iodide N/A Not Applicable NRC US Nuclear Regulatory Commission PBOW Plum Brook Ordinance Works PBRF Plum Brook Reactor Facility PBS Plum Brook Station PNL Pacific Northwest Laboratory DStandard normal distribution function p surveyor efficiency for scan surveys pCi/g picocuries per gram

% percent, QC Quality Control RESRAD RESidual RADioactive - a pathway analysis computer code developed by Argonne National Laboratory for assessment of radiation doses. It is used to derive cleanup guideline values for soils contaminated with radioactive materials RESRAD-BUILD A companion code to RESRAD for evaluating indoor building contamination and developing site-specific DCGLs RPD Relative percent difference s seconds a generic symbol for standard deviation of a population SEB Service Equipment Building (Building 1131)

SNL Sandia National Laboratory SR Survey Request SP Sample Point, used to designate measurement or sampling locations in some characterization surveys tb background count time ts sample count time TBD Technical Basis Document TRPL Transport Roadways and Parking Lots P Mean activity concentration UCM Unusual Condition Measurement UL Upper limit of the confidence interval about the mean VSP Visual Sample Plan WEMS Water Effluent Metering Station, Building 1192, also called the Water Effluent Monitoring System Zl-a Proportion of standard normal distribution values less than 1-a ZI-0 Proportion of standard normal distribution values less than 1-I 00 Mathematical symbol for infinity viii

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 1.0 Introduction This report presents the results of the final status radiological survey of Transport Roadways and Parking Lots (TRPL) at the Plum Brook Reactor Facility (PBRF). It is Attachment 14 of the PBRF Final Status Survey Report (FSSR) 1. The areas covered by this report include paved roadways and parking lots within and in the vicinity of the PBRF over which licensed radioactive materials were transported or stored during the operating period and during decommissioning. This attachment describes the TRPL, their operational history and final condition for the final status survey (FSS). It describes the methods used'in the FSS and presents the results. 2 As stated in the PBRF Final Status Survey Plan (FSSP) [NASA 2007], the goal of the decommissioning project is to release the facility for unrestricted use in compliance with the requirements of US NRC 10CFR20 Subpart E. The principal requirement is that the dose to future site occupants is less than 25 mrem/y. Subpart E also requires that residual contamination be reduced to levels as low as reasonably achievable (ALARA). The default Derived Concentration Guideline Level (DCGL) for PBRF structures, 20,831 dpm/1 00-cm 2 has been applied to the paved areas constituting Transport Roadways and Parking Lots.3 The survey measurement results and supporting information presented herein demonstrate that residual contamination levels in each TRPL survey unit are well below the DCGL. Additionally, it is shown that residual contamination has been reduced to levels that are consistent with the ALARA requirement. Therefore, the Transport Roadways and Parking Lots meet the criteria for unrestricted release.

Section 2.0 of the report provides a description of the TRPL. This includes their location, layout, relation to PBRF buildings and areas, their use, and final configuration for the FSS.

A brief history of operations is presented in Section 3.0. A chronology of significant milestones is followed by history of operations with radioactive materials. Post shutdown and decommissioning activities are summarized. Results of radiological characterization surveys in support of decommissioning are presented.

Section 4.0 presents the FSS design for the TRPL. This section includes applicable FSS Plan requirements, breakdown into survey units and assignment of MARSSIM classifications. The survey design approach, instrumentation and measurement sensitivities are described.

Survey results are presented in Section 5.0. This section includes a summary of the FSS measurements performed in the TRPL survey units, comparison to the applicable DCGLs and an evaluation of residual contamination levels relative to the ALARA criterion.

The PBRF Final Status Survey Report comprises the report main body and several attachments. The attachments present survey results for individual buildings and open land areas. The entire final report will provide the basis for requesting termination of NRC Licenses TR-3 and R-93 in accordance with 10CFR50.82 (b) (6).

2 The FSS of other paved outdoor areasat the PBRF is reported in Attachment 15 of the Final Report, Miscellaneous Structures and Pads.

3 This is the corrected DCGLw value against which the TRPL total surface beta activity measurements are evaluated. See Section 4 for explanation and details.

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 Supporting information is contained in Appendices. Appendix A contains photos to supplement the text. Survey design maps, tables of coordinates and FSS measurement results for each survey unit are provided in Appendix B.

2.0 PBRF Site Description and History A description of the PBRF site is provided and the history of facility operations summarized to provide background for identification and descriptions of the areas which comprise the scope of this FSS report. This is followed by a description of the Transport Roadways and Parking Lots and their operational history.

2.1 PBRF Site Description The PBRF site is located near the northern edge of the 6400 acre Plum Brook Station (PBS).

The site, as described in the NRC license that controls decommissioning activities, comprises 27 acres which contain the Reactor Building and support buildings and facilities. 4 The.

controlled-access site is bounded on the south by Pentolite Rd., on the west by Line 2 Rd. and on the north and east by a boundary fence. The southwest corner of the site, the intersection of Line 2 and Pentolite Roads is used as a reference location. The coordinates are 41' 23' 03.73" North Latitude and 820 41' 05.80" West Longitude. 6 Figure 1, a map of the PBRF site, shows the main buildings and roadways inside the 27 acre restricted area and Figure 2 shows the Transport Roadways and Parking Lots in relation to the PBRF and identifies the individual survey units.

4 See Technical Specifications for the License No. TR-3 (Amendment 13) and License No. R-93 (Amendment 9) [NASA 2007].

5 Prior to decommissioning, the Reactor Vessel center was typically used as a local reference location for the PBRF.

6 The coordinate grid system used for construction of the PBRF was a local coordinate system established by the Army Corps of Engineers in the 1940's for construction of the Plum Brook Ordinance Works. This local grid system has been balanced (tied in) to the Ohio regional state plane coordinate system by NASA to align Glenn Research Center and Plum Brook Station geographic references with modem high-accuracy geo-reference systems. This provides the ability to reference locations specified on historical drawings to global latitude and longitude [Hagelin 2010].

2

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 Figure 1, PBRF Site Map Showing Roadways inside the 27 Acre Restricted Area

-1;jYýT-OTE - DTCH 3

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 Figure 2, Layout of Transport Roads and Parking Lots Showing Survey Units

-TR-2-1 LEGEND

-- = CLASS 1 E = CLASS 2 TR-1-2

.,-TR-1-3 TR-1-6 TR-1-7 TR-2-4 PENTOLITE ROAD TR 1-11 0 1-10 1-9 n" 1-8 4

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 The PBRF site is generally level and graded to promote surface water drainage to the Water Effluent Metering Station (WEMS), located at the south east comer of the site [USACE 2004]. The site reference grade level at the Reactor Building is 631 ft. above mean sea level

[NACA 1956].'

The PBRF site contained several multi-story buildings and multiple support structures.

Below-grade structures and utilities extended throughout the site. These included underground pipe and utility tunnels, storm drains, catch basins, sanitary sewers, water and gas supply lines, cathodic protection wells and ground water monitoring wells. Prior to decommissioning, about 25% of the site was occupied by buildings, water processing structures (Cooling Tower Basin, WEMS, Sludge Basins, Cold Retention Basins, etc) paved roadways, parking areas, sidewalks and equipment pads. The remainder of the site surface was open land soil areas.

Areas adjacent to the PBRF on the north (north of North Rd.) contained utilities and support facilities for PBRF operations. These included the Assembly Test Storage (ATS) Building, the former Reactor Office Building (ROB), an electric substation and a deionized water storage tank. These facilities and the surrounding land area were cleared of licensed radioactive materials and released from the NRC licenses prior to decommissioning of the PBRF.8 2.2 History of PBRF Construction and Operation Plum Brook Station was formerly a World War II era explosives manufacturing facility and prior to that was occupied by family farms and orchards [Bowles 2006]. Construction of the Plum Brook Ordinance Works (PBOW) in 1941-42, involved razing of existing farms, residences and small commercial buildings and construction of explosives manufacturing facilities. After World War II, the PBOW lay dormant for 10 years. In 1955, the Department of the Army transferred 500 acres in the northern portion of the former Ordinance Works to the National Advisory Committee on Aeronautics (NACA), the NASA predecessor, for construction of the Plum Brook test reactor facility.

Planning and design for the PBRF construction was initiated in 1955. Principal milestones are listed below: 9 1956 - September, groundbreaking for PBRF.

1956 - Reactor Building construction initiated.

7 The finished floor elevation of the Reactor Building first floor is designated as the 0 ft. elevation for major PBRF buildings. This is one ft. above grade level at the Reactor Building location.

8 License Number TR-3, Amendment No. 6, approved by NRC letter dated Dec. 17, 1976.

9 Information sources for the site history include construction drawings and photos, PBRF operating cycle reports, PBRF annual reports, memoranda and other historical files maintained by PBRF Document Control.

5

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 1959 - 1960 Major building construction completed.

1961 - June, 60 MW Test Reactor critical.

1961 - 1962 - Preoperational Testing 1963 - Full power 60 MW Test Reactor operations begin.

1973 - January 5 th, Reactor shutdown (after 152 operating cycles). 10 1973 - June 30, PBRF facilities placed in standby condition.

1985 - Initial radiological characterization, Teledyne Isotopes Inc.

1989 - Follow-up radiological characterization, GTS-Duratek.

2002 - Decommissioning Plan approved.

2003 - 2004 - Equipment removal and initial building decontamination.

2006 - 2011 - Remediation of contaminated areas and preparation for FSS.

2011 - FSS measurements of Transport Roadways and Parking Lots completed.

It is noted that the Reactor Building and principal supporting facilities were completed in the construction period, 1956 - 1960, but modifications to the PBRF occurred throughout the operations period. Major modifications included installation of cathodic protection wells (1961-62), construction of the Waste Handling Building (1962-64), construction of the ATS Building and utility and personnel passage to the Reactor Building (1964-65), WEMS modifications (several times during 1961-1973) and modification of storm drains (1968).

Most of the roadways covered in this report were initially constructed in the 1940s as part of the PBOW. Aerial views of the PBOW, prior to PBRF construction, are shown in Exhibits 1 and 2 of Appendix A. They show the Line Roads, Pentolite Road and other small roadways.

Line Roads 1, 2 and 3 and Pentolite Road were repaved during the latter part of PBRF construction, circa 1959-61. The main employee parking lot located west of Line 2 Road opposite the major PBRF Buildings was installed in approximately 1959. The roadways and parking lots have undergone periodic maintenance up until the present.

2.3 Final Configuration and Scope of FSS During decommissioning, extensive remediation, excavation and building demolition occurred within the PBRF restricted area and adjacent areas. Numerous small sections were removed from roadways and parking lots. The remaining roadways and paved areas included in the scope of the TRPL FSS are listed below:

All remaining sections of roadways and paved areas within the restricted area fence, 10 The length of an operating cycle was determined by fuel bum-up in the 60 MW Test Reactor. Loss of reactivity, usually driven by xenon poisoning, dictated when the reactor was shut down and refueled. The typical cycle duration was two weeks; three days for refueling and 11 days of operating time. Some shutdown periods extended longer than three days, for example for experiment installation, reactor modifications and maintenance.

6

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0

• The PBRF paved parking lot between Line 1 Road and Line 2 Road,

• The staging/storage area west of the PBS warehouses on Pentolite Rd. west of the PBRF, commonly referred to as the "bone yard",

• Line 1, Line 2 and Line 3 Roads,

• The parking lot and connecting roadways in the vicinity of the ATS facility,

• Pentolite Road beginning at the confluence of Plum Brook and Pentolite Ditch then heading west to the western boundary of the "bone yard" identified above and

• Garage Road beginning at the intersection with Pentolite Road and extending south for 0.10 miles.

The TRPL surfaces are mostly asphalt (bitumen) or hard-packed asphalt-gravel mixtures.

Their condition ranges from good to partially degraded with a few areas which are completely degraded with exposed gravel and soil (estimated to be less than 5% of the total TRPL surface area). Prior to the FSS, the paved areas were cleared of mud and debris to the extent practical.

Exhibits 3 through 29 of Appendix A contain photos of each survey unit to illustrate conditions at the time of the FSS in late 2011.

3.0 Operations with Radioactive Materials Operations with radioactive materials at the PBRF were controlled by procedures established to comply with requirements of US Atomic Energy Commission (AEC) licenses." License No.TR-3 (Docket 50-30) authorized the 60 MW Test Reactor. The 100 KW Mock-up Reactor was licensed under License No.R-93. A broad byproduct license (BPL) No. 34-06706-03, authorized possession and use of radioactive materials (byproduct material) produced by the Plum Brook 60 MW and Mockup reactors and other radioactive materials. Radioactive materials of PBRF origin that could have contaminated roadways and parking lots originated from PBRF tests, experiments and process wastes. This section addresses handling and disposition of radioactive materials during startup and facility operations, after facility shutdown in 1973. Site characterization and decommissioning activities that affected Transport Roadways and Parking Lots are discussed.

3.1 Startup and Operations During the period from startup and testing of the 60 MW Test Reactor in 1963, until facility shutdown in 1973, large quantities of radioactive materials were routinely stored, transported and processed at the PBRF. Transfer of radioactive contamination to Transport Roadways and Parking Lots may have occurred through leaks or spills from transport vehicles or storage containers. Another possible pathway was from repairs and modifications to underground process piping and storm drains which passed beneath roadways. However, a review of the PBRF Health-Safety Operations Office (HSOO) Cycle Reports did not reveal any reports of events which resulted in contamination of Transport Roadways and Parking Lots.

Authority for the PBRF reactor and radioactive materials licenses was assumed by the US Nuclear Regulatory Commission in 1975.

7

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 3.2 Disposition of Materials in the Post-Shutdown Period Notification was received on January 5, 1973 that due to budget constraints, NASA was terminating all nuclear related research operations at PBRF. The Test Reactor, Mock-up Reactor, Hot Laboratory and all associated operations were shutdown and placed in standby condition and the reactor staff terminated by June 30, 1973.

During the period between 1973 and the start of decommissioning, activities at PBRF were controlled in accordance with the modified AEC and NRC licenses: TR-3, R-93 and BPL No.

34-06706-03. These licenses authorized possession only of the remaining radioactive materials on site, i.e., no facility operations were permitted. During this period, selected equipment, materials, and waste (both low-level radioactive and non-radioactive) were removed to other locations or discarded as the projected long-term considerations for the facility changed from possible restart to standby to decommissioning. In 1982, the NRC terminated BPL 34-06706-03 at NASA's request. A Decommissioning and Dismantling amendment to Licenses TR-3 and R-93 transferred any existing licensed radioactive materials to those licenses. For a brief history of the activities during this period see the NASA PBRF Decommissioning Plan, Section 1.2.1 Decommissioning Historical Overview [NASA 2007a].

3.3 Site Characterization Transport Roadways and Parking Lots were not addressed in the two major characterization surveys performed in the period between shutdown and initiation of decommissioning. These were the Teledyne-Isotopes survey of 1984-85 [Tele 1987] and the 1998 GTS-Duratek confirmatory survey [GTS 1998].

In 2005, the decommissioning contractor performed a characterization survey of portions of the roadway and parking lot areas covered in the present FSS. The survey covered Pentolite Road from a point about 700 ft. east of Garage Road (the Pentolite Ditch Crossover) to the entrance to Warehouse 9210 west of Line 1 Road (about 0.8 mi.). It also covered the Warehouse 9210 parking lot, an area used to store soil in "Super Sacks" that was excavated from the areas south of Pentolite Ditch identified as "areas of Concern" (AOC) where Pentolite Ditch dredge spoils had been placed over the years. These areas comprise portions of the present FSS survey units TR-2-3 and TR-2-4, described in Section 4.2. The results of this characterization survey are summarized:

• No areas of elevated gamma scans were observed in the survey of 10% of the areas described above. The range of gamma count rates was 45 to 137 gross counts per minute with the LMI 2350-1 data logging scaler rate meter and 44-10 Nal detector set up in the Cs-137 energy window.

• Beta scans were performed on 10 randomly selected areas of 100 m 2 each on the travel path and storage area using an LMI 2350-1 scaler rate meter with a 44-116 beta detector. No scan measurements were identified as "elevated" and the observed scan readings were in the range of 198 to 708 gross counts per minute.

9 Direct beta measurements were performed using the LMI 2350-1 with the 44-116 detector in each of the 10 areas that were beta-scanned. The locations selected for 8

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 these measurements were the locations where the highest beta scan counts were observed. All measurements were less than the action level of 1000 dpm/1 00-cm 2 and the highest measured value was 590 dpm/1 00-cm2.

One location was selected at random on the travel path for a direct alpha measurement.

The measured value was less than the 20 dpm/100-cm 2 action level established for alpha measurements.

Eighteen surface soil samples (0 to 6 in.) were collected from areas in the asphalt storage area where the pavement had failed and gravel or soil was exposed. The 18 samples also included samples collected from potential run-off locations along the storage area pavement periphery and from the gravel portion of the roadway to the storage area. The samples were analyzed by gamma spectroscopy at the on-site counting laboratory. The maximum measured Cs-137 activity was 1.03 pCi/g and the maximum measured Co-60 activity was 0.06 pCi/g [MWH 2005].

A characterization survey was performed in 2006 under SR- 18 in which core bore samples were collected to evaluate contamination versus depth in roadways within and in the vicinity of the PBRF. 12 The roadways were divided into 10 "survey areas" for investigation as follows:

1. North Rd. from Line 2 Rd. east to its terminus near the location of the former elevated water tank (total surface area, 17,400 ft2).

2

2. Line 2 Rd. from Pentolite Rd. north to North Rd. (total surface area, 21,400 ft ).

3. Line 3 Rd. from Pentolite Rd. north to a point 300 ft. north of North Rd. (total surface area, 27,400 ft2).

4. Pentolite Rd. from Garage Rd. east to a point 100 ft. east of the temporary Pentolite Ditch overcrossing that was constructed to facilitate soil remediation activities (total surface area, 43,700 ft2).

5. The east-west roadway from Gate 1 and the Reactor Building (total surface area, 10,150 ft2 ).

6. The east-west roadway between Line 3 Rd. and the east end of the former Service Equipment Building (total surface area, 5,130 ft2).

7. The east-west roadway between Line 3 Rd. and the east side of the Hot Laboratory (total surface area, 14,860 ft).

8. The asphalt "storage pad" that was located south of the Waste Handling Building and the connecting roadway to Line 3 Rd. (total surface area, 12,500 ft2 ).

9. The east-west roadway that begins at Line 3 Rd. and terminates near the WEMS (total surface area, 7,650 ft2).

10. Garage Rd. from Pentolite Rd. extending south for 300 ft. (total surface area, 6,000 12 Survey Request SR-18, Asphalt Surfaces and Roads, (Collect core bore samples of the asphalt-paved areas of the PBRF site that were previously used for the transport of Radioactive Shipments), 3/13/2006.

9

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 Core bores were collected at 85 locations, selected using a systematic sampling plan. The bores were taken through the depth of the pavement (typically one ft. or less in depth). The 3 in. cores were sliced into V2 in. slices, or pucks for analysis by gamma spectroscopy at the PBRF on-site counting laboratory. The pucks were counted with top and bottom sides facing the detector. For pucks that showed positive activity (for Cs-137 or Co-60), the average activity was calculated for the puck. The analysis results for each of the 10 survey areas are summarized in Table 1. In total, 810 analyses were performed (this count includes 5% QC replicate puck sample counts). All Co-60 results were < the Co-60 MDA except one. The measured concentration was 0.22 pCi/g (in Area 3 Line 3 Rd. Location SP-9, surface sample slice). Of the 810 puck analyses performed, only 130 exceeded the Cs-137 MDA and 90 exceeded 10% of the DCGL. The DCGL used for this evaluation was 2.2 pCi/g, the subsurface structure volumetric DCGL for Cs-137 reported in Table B-14 of the FSS Plan, Appendix B. It is seen from Table 1 that most of the positive results were obtained from asphalt material that was covered over by repaving that had occurred over the years.

Table 1, Summary of SR-18 Core Bore Sample Results No.

a No.of of ANo. of Positive Maximum Cs-Area No. of Analyses Cs- 137(2)Results 137 Activity (pCig) Location of Highest Activity Cores Performed (3)

(1) 1 8T'7- 90 13 0.41 Slice No 7 from SP No. 5 (5) 2 8 82 21 0.74 Slice No. 8 from SP No. 8 (5) 3 20 (4) 202 26 0.48 Slice No. 6 from SP No. 8 (5) 4 15(4) 140 26 0.40 Slice No. 11 from SP No. 13 5 6 48 12 0.36 Slice No. 1 from SP No. 5 6 6 22 6 0.23 Slice No. 1 from SP No. 2 7 10 84 12 0.85 Slice No. 1 from SP No. 7 8 7 4 112 18 0.67 Slice No.6 from SP No. 3 5 9 7(4) 16 4 0.30 Slice No. 1 from SP No. 1 10 3 14 6 0.49 Slice No 5 from SP No.2 (5)

Table 1 Notes:

1. The number of analyses performed is usually greater than the number of pucks or slices obtained from the cores. This is because the individual pucks were analyzed twice; with the top facing the detector and with the bottom side facing the detector.

2. Positive results are described as greater than 10% of the FSS Plan subsurface volumetric DCGL for Cs-137, 2.2 pCi/g, i.e., greater than 0.22 pCi/g.

3. Reported as the average of the top and bottom core slice analysis results.

4. Includes a replicate QC core.

5. These pucks, or slices were identified as from the top layer of a layer of subsurface asphalt that had been paved over.

In 2010, a characterization survey was performed of the Plum Brook Station roadways outside of the PBRF restricted area over which most of the PBRF decommissioning radwaste shipments traveled. The shipment routes included the roadway between the PBRF and the Main PBS gate on Columbus Avenue and the two routes traveled from the PBRF to the Scheid Road PBS exit gate. Specific roadways covered were:

e Ransom Rd. between Pentolite Rd. and West Scheid Rd. (1.7 miles).

10

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0

• West Scheid Rd. from Ransom Rd. east to Center Magazine Rd., continuing on Center Magazine Rd. to Columbus Ave. (2.2 miles).

• Columbus Ave, from the intersection with Columbus Ave. continuing on Columbus Rd. to the East Scheid Rd. PBS exit Gate (0.4 miles).

" Pentolite Rd. from Ransom Rd. to the main PBS gate at Columbus Ave. (1.5 miles).

• Columbus Ave. from the main PBS gate to Center Magazine Rd. (1.7 miles).

A standard protocol was applied to each roadway leg listed above. Survey/sample locations were established at one-tenth mile intervals. At each survey/sample location, a two square meter area was established on the outward bound pavement-shoulder. One square meter was designated for survey on the pavement and one square meter on the shoulder, usually an area of soil or soil and gravel. At each survey/sample location the following was performed:

" Surface gamma scan of the shoulder area with the LMI 2350-1 and 2 x 2 in Nal detector (operated in the Cs-137 window mode),

0 Surface beta scan of the pavement area with the LMI 2350-1 and 44-116 or 43-37 (large area detector),

• Acquire a minimum of one surface soil sample in the center of the shoulder square meter (additional samples may be required as determined by soil scanning results),

• Perform a minimum of one static beta measurement and removable surface activity measurement (smear sample) at the center of the paved roadway square meter (additional measurements may be required as determined by scanning results) and

" QC surveys/samples of a minimum of 5% of the scanned areas, static measurements and samples collected were required.

The scan investigation levels established for the principal detectors were:

• 250 ncpm for the LMI 44-10 gamma detector. This was set to be well below, 50 to 75%, (depending on the background count rate) of the Cs-137 surrogate DCGL, 13.3 pCi/g, established in TBD-09-001 [PBRF 2009].

• 2700 gcpm for the LMI 44-116 beta detector. This was set to be below the default gross activity DCGL, 27,166 dpm/100-cm 2, established in TBD-07-001 [PBRF 2007].

The survey results are summarized:

• All gamma scan results were below the investigation level.

" All surface beta scan results were below 50% of the 2700 gcpm investigation level.

" The removable surface activity smear counts were all < MDA for alpha and beta activity.

• The highest static beta measurement was 1470 dpm/100-cm 2 (at Ransom Rd. SM-I location, at the intersection of Pentolite and Ransom Roads).

• Ninety surface soil samples were collected and analyzed by gamma spectroscopy at the PBRF on-site counting laboratory. This number includes 8 QC samples. All Co-60 11

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 results were below MDA (the average MDA was 0.16 pCi/g). Of the 92 original sample Cs-137 results, 49 were > MDA (avg. Cs-137 MDA was 0.10 pCi/g). The average measured Cs-137 concentration in the positive samples was 0.41 pCi/g and the maximum was 1.14 pCi/g (at location SP-15, on the Ransom Rd. west shoulder about 800 ft. below the intersection with Taylor Rd.)

The results of the SR-18 and SR-248 characterization surveys are included here to support two objectives: 1) They are to demonstrate that the survey of Roadways and Parking Lots included evaluation of volumetric and subsurface contamination. 2) All the roadway travel paths that were known to have been used to transport PBRF radioactive materials and radioactive waste from the PBRF to the PBS gates were evaluated.

3.4 Decommissioning Beginning in 2002, decommissioning activities occurred throughout the 27 acre restricted area and surrounding areas. These activities caused physical disturbance of and created potential pathways for contamin*ation of roadway and parking lots. Activities that impacted Transport Roadways and Parking Lots included:

e Removal of portions of roadways to gain access to storm drains and underground utilities,

• Excavation of soil beneath and adjacent to roadways and parking lots,

• Transport of excavated-contaminated material in open vehicles over roadways,

• Construction of staging areas for excavated material,

• Construction of temporary haul roads that transected roadways,

• Construction of temporary pads for setup and operation of the Mactec Orion ScanSort soil scanning conveyor system,13

• Storage of radioactive waste containers,

• Transport of radioactive waste shipments and

• Use of parking lot for FSS of soil in lifts.

Material removed from roadway sections during decommissioning was surveyed by FSS technicians and screened using scan surveys with Nal detectors set up to count in the appropriate energy window (usually Cs- 137). Any material above the most conservative site soil DCGL (10.3 pCi/g) was staged for disposal as radwaste. Material below the DCGL, but above the remedial action level (RAL, 2 of the3 DCGL), was staged for FSS. Material below the RAL was staged for future use as backfill.1 4.0 Survey Design and Implementation This section describes the method for determination of the number of fixed measurements and samples for the FSS of the TRPL Applicable requirements of the FSS Plan are summarized. These 13 See Attachment 18 of the FSS Report, Excavated andBackfill Material,for a detailed description of the Orion ScanSort soil conveyor-sorter system and the method for screening excavated soil in the field by FSS technicians.

12

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 include the gross activity DCGL, the DCGLw 14, scan survey coverage and action-investigation levels, classification of areas and breakdown of the survey units. The radiological instrumentation and their detection sensitivities are discussed.

4.1 FSS Plan Requirements In the FSS Plan, Section 7.6, the approach to FSS of outdoor paved areas including roads and parking lots is described [NASA 2007]. It states:

"The survey design of parking lots, roads and other paved areas will be based on soil survey unit sizes since they are outdoor areas where the exposure scenario is most similar to direct radiation from surface soil. The (single radionuclide) structure values presented in Table 3-2 are applicable to paved areas because the dose pathways and source geometry (i.e., area source) are essentially the same as those assumed in the Building Reuse scenario. In addition, the agricultural pathways are not applicable. The structure DCGL values are conservative since the direct dose from a 2000 m 2 outdoor area is less than the dose from the Building Reuse scenario.....Scan and static beta surveys are made as determined by the survey unit design. If subsurface contamination is possible under paved or other covered areas, subsurface volumetric samples should be collected."

The DCGLs for individual radionuclides were obtained for PBRF structures considering exposure to future site occupants from two potential pathways. Single radionuclide DCGLs were calculated using RESRAD-BUILD Version 3.22 for a building reuse scenario. Single radionuclide volumetric DCGLs were calculated for subsurface structures using RESRAD Version 6.21 for a resident farmer scenario. 15 The volumetric DCGLs (in pCi/g) were converted to "effective surface" DCGLs (in dpm/100-cm2) using surface-to-volume ratios for the assumed volume of contaminated subsurface concrete. The DCGL calculations are described in the FSSP, Attachment B. To obtain the DCGLs for PBRF structures, the smaller of the two DCGLs calculated for each of the radionuclides of concern were selected.

A gross activity DCGL is used for structural surfaces in the PBRF, where multiple radionuclides are potentially present in residual contamination. The gross activity DCGL accounts for the presence of multiple radionuclides, including beta-gamma and alpha emitters.

The gross activity DCGL can also account for so-called hard-to-detect (HTD) radionuclides.

The latter are not detected, or detected with very low efficiency, by the beta detectors selected for the FSS of structures and paved surfaces such as the TRPL.

The gross activity DCGL for the TRPL survey units is calculated using equations in the FSSP for surrogate DCGLs and gross activity DCGLs, based on the radionuclide mixture in residual contamination. Activity fractions and the gross activity DCGL for the "default" radionuclide 14 The convention used in the MARSSIM is to identify the DCGL used as the benchmark for evaluating survey unit measurement results, as the DCGLw. The "W" subscript denotes "Wilcoxon", regardless of the particular test used (Wilcoxon Rank Sum Test, or Sign Test).

15Potential exposure to future occupants from subsurface structures could occur from contaminated concrete rubble placed as fill and from contaminated intact structures such as the below-grade portion of the Reactor Bioshield.

13

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 mixture for structures were used in Survey Design 73 to develop the survey design for the TRPL. These were taken from the PBRF Technical Basis Document, PBRF-TBD-07-001

[PBRF 2007]. However in late 2011, errors were identified in several of the TBD-07-001 gross activity DCGLs.

Subsequent to preparation of Design 73, the gross activity DCGLs used for the various PBRF structural areas were corrected, including the default DCGL. The radionuclide mixtures and their activity fractions for the various areas were also re-evaluated and new mixtures were established. These results are published in the Technical Basis Document PBRF-TBD- 11-002

[PBRF 2012]. Table 2 shows the original radionuclide activity fractions and gross activity DCGL from TBD-07-007. It also shows the revised default activity fractions and gross activity DCGL developed in TBD- 11-002. In Section 4.3, the survey design calculation of the number of measurements is discussed, including the effect of the revised DCGL.

Table 2, Radionuclide Activity Fractions and Gross Activity DCGLs ile 2 Notes:

1. Activity fractions and gross activity DCGL from TBD-07-001 [PBRF 2007].

2. Activity fractions and gross activity DCGL from TBD- 11-002 [PBRF 2012].

3. It was determined in TBD- 11-002 that U-234 and U-235 should be removed from the radionuclide mixtures in all structure areas (and the default mixture) except the Reactor Office and Laboratory Building New Fuel Vault. Their presence was based on core sample analysis results, which upon re-evaluation were shown to be indistinguishable from background concentrations in PBS concrete structures.

Survey designs incorporate requirements for scan coverage and investigation levels derived from the MARSSIM classification of survey units. The values applicable to the TRPL are shown in Table 3.

Table 3, Class-Based Survey Scan Coverage and Action Level Requirements Static Measurement Classification Scan Survey Scan Investigation or Sample Result Coverage Levels Investigation Levels Class 1 i00% >DCGLEMc >DCGLEMc Class 2 Cl to210 100% >DCGLw if MDCsa oris >MDCS, >DCGLw

>DCGLw Class 3 Minimum of 10% >DCGLw or >MDC 5 , > 50% of the DCGLw if MDCscan is >DCGLw _

14

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 4.2 Area Classification and Survey Unit Breakdown At the time the FSS Plan was prepared, not all the TRPL were identified and assigned MARSSIM classifications. Several were included in the environmental areas listed in Table 2-2 of the Plan. Table 4 identifies the survey units established for FSS of the TRPL. It is seen that there are 15 survey units; 11 Class 1 and 4 Class 2. Refer to the Figure 2 map for a view of the survey units and their location relative to the PBRF site.

The total surface area of the TRPL survey units is 50,365 M 2 . The total area of the Class 1 survey units is 15,917 M 2 and the total area of the Class 2 survey units is 34,448 M 2 .

Table 4, Transport Roadways and Parking Lots - Survey Units for FSS SurveySClass Survey Class SR Description Unit (m2) Design West Access Driveway to Reactor Building TR-I-1 1 559 73 358/359 (6,012 ft2)

TR-1-2 1 931 73 358/359 Line 3 Road north of North Road (10,024 ft 2)

Line 3 Road from BJ Gridline to North Road TR-1-3 1 1657 73 358/359 (20,214 ft 2) (1)

Line 3 Road from South Crossover to BJ TR-1-4 1 1602 73 358/359 Gridline (17,246 ft2) (1)

Line 3 Road from Gate 6 to South Crossover TR-1-5 1 840 73 358/359 and WEMS Road (9,042 ft 2)

TR-1-6 (2) 1 1593 73 358/359 Parking Lot - West Soil Lift Area (17,142 ft2)

TR-1-7 (2) 1 1593 73 358/359 Parking Lot - East Soil Lift Area (17,148 ft2 )

Pentolite Road Rad Waste Storage - Section #1 TR-1-8 1 1804 73 358/359 (19,413 ft 2)

Pentolite Road Rad Waste Storage - Section #2 TR-1-9 1 1811 73 358/359 (19,492 It 2 )

Pentolite Road Rad Waste Storage - Section #3 TR-I-0 1 1813 73 358/359 (19,510 ft 2 )

Pentolite Road Rad Waste Storage - Section #4 TR-1-11 1 1714 73 358/359 (18,446 ft 2)

Northern Sections of Line 1, 2, & 3 Roads TR-2-1 2 9948 73 362 (107,084 ft 2)

Parking Lot, Line 2 Road TR-2-2 (2) 2 7907 173 362 Class 2 Section from Parking Lotofto North Road (85,107 ft 2)

Line 2 Road from Parking Lot to Pentolite TR-2-3 2 8844 73 362 Road, Pentolite Road from Line 2 Road to Plum Brook (95,198 ft 2)

Pentolite Road from Line 2 Road to West TR-2-4 2 7749 73 362 Warehouse, Line 1 Road from Pentolite Road to Parking Lot, North 0.1 mile of Garage Road (83,406 ft 2)

Table 4 Notes:

15

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0

1. The BJ Gridline is the gridline that runs east-west through the restricted area site just south of the Reactor Building. Survey Unit TR-1-3 includes the connecting roadway that joins Line 3 Rd. just north of the BJ Gridline and extends east (and then north).

2. The main parking lot is divided into two Class 1 survey units and one Class 2 survey unit. The portion of the lot where soil lifts were established for excavated soil surveys is Class 1 and the remainder of the lot is one Class 2 survey unit.

4.3 Number of Measurements and Samples The number of measurements and samples for each survey unit was determined using the MARSSIM statistical hypothesis testing framework as outlined in the FSS Plan. The Sign Test is selected because background count rates of instruments to be used are equivalent to a small fraction of the applicable DCGLw.16 Decision error probabilities for the Sign Test are set at a = 0.05 (Type I error) and 13 = 0.10 (Type II error) in accordance with the FSSP.

The Visual Sample Plan (VSP) software was used to determine the number of FSS measurements in the TRPL. 17 When the Sign Test is selected, the VSP software uses MARSSIM Equation 5-2 to calculate the number of measurements. Equation 5-2 is shown below:

N=l1.2 (Zl-a* + Zl-,6 )2 (Equation 1) 1 A+0.52 4[1.D(z where:

1.2 = adjustment factor to add 20% to the calculated number of samples, per a MARSSIM requirement to provide a margin for measurement sufficiency, N = Number of measurements or samples, a = the type I error probability, P3= the type Il error probability, ZI- = proportion of standard normal distribution < 1 - a (1.6449 for a =

0.05),

Z -p= proportion of standard normal distribution < 1 - 13 (1.2816 for f3 0.1),

4) (A/a) = value of cumulative standard normal distribution over the interval -

oo, A/a, A = the "relative shift", defined as the DCGL - the Lower Bound of the Gray Region (LBGR), and a = the standard deviation of residual contamination in the area to be surveyed (or a similar area). This may include the variation in measured ambient background plus the material background (for total surface beta measurements).

16 Background count rates for the LMI 44-116 detector, the instrument of choice for FSS surface beta activity measurements on structures, are in the range of 300 cpm or less for most materials. This is equivalent to about 2500 dpm/100-cm 2; about 12% of PBRF structure DCGLs (this assumes a detection efficiency of - 12%).

17 The FSS Plan (Section 5.2.4) states that a qualified software product, such as Visual Sample Plan0 [PNL 2010], may be used in the survey design process.

16

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 The MARSSIM module of VSP requires user inputs for the following parameters: a, J3, LBGR, the DCGLw and a. The numbers of measurements were calculated for the TRPL survey units using the parameters established in Design 73. Table 5 summarizes the survey design parameters, including values of key VSP input parameters used to calculate N, the number of measurements.

Table 5, TRPL Survey Design Summary Gross DCGLw LBGR Basis Activity (1)(2) (1) A a A/a N DCGL (1)

Original (3) 27,166 24,449 12,225 12224 4890 2.5 11 Revised (4) 23,146 20,831 10,415 10,416 4166 2.5 11 Table 5 Notes:

1. Units are dpm/100-cm 2.

2. The DCGLw is obtained by adjusting the gross activity DCGL to account for the 10% dose contribution (2.5 mren/y) from deselected radionuclides.

3. From Design 73 using the default gross activity DCGL in TBD-07-001 [PBRF 2007].

4. The gross activity DCGL is from TBD- 11-002. The DCGLw is obtained by adjusting the gross activity DCGL to account for the 10% dose contribution (2.5 mrem/y) from deselected radionuclides.

5. The revised sigma value is 20% of the DCGLw as assumed in the original design calculation.

As discussed in Section 4.1, the DCGLw has been revised subsequent to the development of Design 73. Table 5 shows the original and revised design parameters for calculating the number of measurements. The effect of the revised DCGL has been evaluated in the TRPL survey unit release records, revised in January 2012. The revised release records show that the TRPL design calculation of the number of measurements, N, is unchanged, as seen in Table 5.

Selection of design input parameters followed guidance in the FSS Plan. The Plan states that "the LBGR is initially set at 0.5 times the DCGLw, but may be adjusted to obtain a value for the relative shift (A/a) between 1 and 3". It is seen in Table 5 that a relative shift value of 2.5 was used in the final calculations for determining N.

The VSP software automatically performs an analysis to examine the sensitivity of N, the number of samples, to critical input parameter values. The following is an example developed using the same method and equations used by VSP with the design parameters used in Design 73 (with the revised DCGLw). The sensitivity of N was explored by varying the following parameters: standard deviation, lower bound of gray region (as % of DCGL), beta, probability of mistakenly concluding that the survey unit mean concentration, p, is greater than the DCGL and alpha, probability of mistakenly concluding that the survey unit mean concentration, p, is less than the DCGL. Table 6 summarizes this analysis. The region of interest is for a = 0.05 (required to be fixed), 03= 0.10 (may be adjusted) and the LBGR at 50% to 70% of the DCGL. In this region, it is seen that N is sensitive to a. Holding 03= 0.10 and doubling a causes N to increase from 14 to 35 when the LBGR is set at 70% of the DCGL; 12 to 23 when the LBGR is 60% of the DCGL and 11 to 17 when the LBGR is 50%

of the DCGL. However, the sensitivity of N to an incorrect conclusion that the survey unit 17

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 will pass (regulator's risk) is quite low. With the LBGR at 50% of the DCGL (as used in Design 73) and P3 = 0.10, increasing a from 0.05 to 0.10 and 0.15 and holding a constant at 4166 dpm/1 00-cm 2, shows that the number of measurements is 11 or fewer in all cases. These results show that N = 11 represents a conservative design.18 Table 6, Sensitivity Analysis for FSS Design Number Of Samnles1 2

DCGLw = 20,831 "' a = 0.05 a= 0.10 a = 0.15

= 8332 (1 ý1 = 4166 a = 8332 (= 4166 a = 8332 a = 4166 LBGR = 70% ()(4) j3=0.05 *s 44 18 35 14 29 12

_3=0.10 35 14 27 11 22 9 13=0.15 29 12 22 9 18 7 LBGR = 60% 13=0.05 28 15 23 12 19 10

_3=0.10 23 12 17 9 14 8 13=0.15 19 10 14 8 12 6 LBGR = 50% J3=0.05 21 14 17 11 14 9 13=0.10 17 11 13 9 11 7 13=0.15 14 9 11 7 9 6 Table 6 Notes:

1. Units of DCGL, a and LBGR are dpm/1 00-cm 2.

2. a = alpha, probability of mistakenly concluding that p < DCGL.

3. a = Standard Deviation.

4. LBGR = Lower Bound of Gray Region (as % of DCGL)

5. 13 = beta, probability of mistakenly concluding that p > DCGL Visual Sample Plan was also used to determine the grid size, the random starting location coordinates (for both the Class 1 and Class 2 survey units) and to display the measurement locations on survey unit maps drawn to scale. Refer to Appendix B for tables of location coordinates, measurement results and scale VSP maps showing measurement locations for each TRPL survey unit.

The survey designs also specify scan survey coverage and action levels based on the MARSSIM classification listed in Table 3. If the scan sensitivity of the detectors used in Class 1 survey units is below the DCGLw, the number of measurements in each survey unit is determined solely by the Sign Test. If the scan sensitivity is not below the DCGLw, the number of measurements is increased as determined by the Elevated Measurement Comparison (EMC). As discussed in the next section, the scan sensitivities of instruments used in the FSS of the TRPL are below the DCGLw, and no increase in the number of measurements above the value calculated using the Sign Test was required.

18 This conclusion is supported by the survey results. The standard deviation of the 176 systematic total surface beta 2 2 measurements in the TRPL survey units is 1050 dpM/100-cm , significantly lower than the value of 4166 dpm/100-cm assumed in the design calculations. This indicates that the actual, or retrospective statistical power is greater than the prospective power of the design.

18

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 4.4 Instrumentation and Measurement Sensitivity Instruments to be used in the FSS of each survey unit are selected in each survey design.

Their detection sensitivities must be sufficient to meet the required action levels for the MARSSIM class of each survey unit. Minimum detection sensitivities for static alpha and beta measurements are calculated using the following equation:

3 + 3.29 BRtS(1 + -b)

MDCstatic A ' (Equation 2) t,E1o, 1-0 100 where:

MDCStaic = Minimum Detectable Concentration (dpm/100-cm 2),

BR = Background Count Rate (cpm),

tb = Background Count Time (min),

t= Sample Count Time (min),

A - Detector Open Area (cm 2) and Et,, = Total Detection Efficiency (counts per disintegration). The total efficiency equals the product of Detector Efficiency, Ei and Surface Efficiency, E,.

Scan sensitivities for detectors which measure alpha and beta surface activity are determined using the following equation:

d', Fb-60 MDCscan iA , (Equation 3) 100 Where:

MDCSca,, = Minimum Detectable Concentration (dpm/100-cm2),

d' = Index of sensitivity related to the detection decision error rate of the surveyor, from Table 6.5 of MARSSIM [USNRC 2000],

i = observation counting interval, detector width (cm) / scan speed (s),

bi = background counts per observation interval, Ei = Detector Efficiency (counts per disintegration),

Es = Surface Efficiency, typically 25% for alpha and 50% for beta per ISO 7503-1, Table 2 [ISO 1988],

p = Surveyor efficiency (typically 50%) and A = Detector Open Area (cm 2).

19

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 A summary of representative a priori detection sensitivities of instruments used in the FSS of Transport Roadways and Parking Lots is provided in Table 7.

Table 7, Typical Detection Sensitivities of Field Instruments MDCscan Net cpm Detector (dpm/100-cm 2) Equivalent to (p/0cm2)

Detector Model Efficiency (2) DCGLW(') (dpm/1( 2 )

(c/d) () (2)

LMI 44-116 0.140 2,834 (4) 2,608 589 (5)

LMI 43-37 0.1475 953 (6) 3,606 N/A LMI 44-9 0.125 11,268 (6) 367 3,668 (8)

Table 7 Notes:

1. The detector efficiencies listed are total efficiency, i. e., E, = Ei + E,.

2. A' priori scan sensitivities are calculated using Equation 3 and static sensitivities are calculated using Equation 2.

3. The DCGLw value used in the Survey Design 73 instrument specification is 24,449 dpm/100-cm2.

4. The scan MDC for the LMI 44-116 is reported in Design No. 73 for background count rate

= 200 cpm; scan speed =15.2 cm/s and E, = 0.5. An efficiency correction factor = 0.7619 is applied to compensate for concrete roughness (the detector-to-surface distance is 0.75 in.).

5. The static MDC for the LMI 44-116 detector is reported in Design No. 73 for background count rate = 200 cpm, E, = 0.5 and the detector-to-surface distance = 0.75 in. (one minute count times are assumed for both the background and sample counts).

6. The scan MDC for the LMI 43-37 is from Survey Design No. 73. The background count rate is 400 cpm; the scan speed is 53 cm/s, Es = 0.5 and the detector-to-surface distance is 0.5 in.

7. The scan MDC for the LMI 44-9 is obtained from Survey Design No. 73. The background count rate is 125 cpm with a scan speed of 4.4 cm/s and the detector in contact with the surface.

8. The static MDC for the LMI 44-9 is obtained from Survey Design No. 73. The background count rate is 125 cpm and the detector in contact with the surface (one minute count times are assumed for both the background and sample counts).

Modifications to survey instructions are adjusted to account for measurements under unusual surface conditions, called unusual condition measurements (UCM). Modified detection sensitivities may be applied taking into account adjustments in detector efficiency. Scan speeds may be reduced to ensure that required scan sensitivities are achieved. The bases for adjustments due to non-standard conditions are provided in PBRF Technical Basis Documents. 19 Examples of areas or locations in TRPL survey units where special measurement conditions apply are shown in Exhibits 30 through 32 of Appendix A.

Measurement results reported for all FSS scan and direct measurements include the serial 19 The PBRF-TBD-07-004 [PBRF 2007a] presents efficiency correction factors developed for the LMI 44-116 detector.

The correction factors are presented as a function of detector-to-surface distance. Application of the factors requires empirical measurements of the effective detector-to-surface distance for areas with non-standard surface conditions as part of the survey unit inspection process.

20

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 numbers of the instruments used in the survey, their efficiencies and any adjusted efficiencies used because of unusual measurement conditions.

As a result of the revised DCGLw published in TBD- 11-002 for the default mixture used in the TRPL FSS design, evaluations were performed. They were performed to determine if instrument scan-detection sensitivities were sufficient to meet the Class-based investigation level requirements summarized in Table 3.20 For Class 1 survey units, the requirement is that the detector be capable of measuring surface contamination levels below the DCGLEMC in scan surveys. However in practice, the investigation level in Class 1 survey units has been set at a scan count rate equivalent to the DCGLw. From the evaluation, it was concluded that for the detectors used in the FSS, the investigation levels were insufficient to detect activity at the revised DCGLw (20,831 dpmr/100-cm 2). However, it was not necessary to show that the investigation level was sufficient to detect levels at the DCGLEMc, because in FSS of the TRPL Class 1 survey units, the survey instructions directed that any detectable activity above background be recorded (and investigated). As reported in Section 5, no investigations were required as a result of scan surveys in Class 1 (or Class 2) survey units.2' An evaluation was performed to show that the sensitivities of the instruments actually used in the FSS of TRPL Class 2 survey units were sufficient to detect surface contamination levels equivalent to the revised DCGLw. The efficiencies of the actual instruments used (or available to be used) in the scans of Class 2 survey units were determined from the survey reports. Then they were used to calculate the activity that would be measured at the scan investigation level count rates in the Design 73 survey instructions. In the retrospective evaluation described here, the actual activity that could be measured in all cases is found to be less than the revised DCGLw (20,831 dpm/100-cm 2). The worst case isthe calculated value of 20,454 dpm/100-cm 2 for the large area (43-37) detector. In this case, the investigation level was set at 3600 gcpm and the background count rate at 583 cpm (this condition was not actually encountered in the survey, however).

5.0 Survey Results Results of the FSS of the TRPL are presented in this section. This includes scan survey frequencies

(% of areas covered) for each survey unit and replicate QC scan frequencies. Results of systematic-fixed measurements for each survey unit and the results of comparison tests of survey unit maximum and average values with the DCGLw are reported. As discussed below, no statistical tests were required. It is shown that levels of residual contamination have been reduced to levels that are ALARA. This section closes with a summary which concludes that applicable criteria for release of the Transport Roadways and Parking Lots for unrestricted use are satisfied and all FSS Plan requirements are met.

20 The evaluation of the effect of the revised DCGLw on investigation levels and the instrument sensitivity requirements are documented in revised Release Records for the TRPL survey units. These are maintained in the PBRF Document Control System.

2' The scan investigation level was reduced in the Class 1 survey units so the survey would meet the requirements of the PBRF procedure for release of materials (Radiological Release of Equipment, Material and Vehicles, RP-008, Revision 1). This is under the expectation that the PBRF is to become a "wetland" area after license termination. This will involve removal and disposal of all man-made materials that can be removed from the site ground surface.

21

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 5.1 Scan Surveys Scan survey results were reviewed to confirm that the scan coverage requirement (as % of survey unit area) was satisfied for all survey units. The results of QC replicate scan surveys were also reviewed to confirm that the minimum coverage requirement of 5% was satisfied.

Results of the scan surveys are compiled in Table 8. The table shows that scan coverage requirements were satisfied for all survey units. The table also shows that no investigations were performed in the 15 TRPL survey units. No scan investigation-action levels were exceeded in the original scan surveys or the QC scan surveys.

Table 8, Scan Survey Results for Transport Roadways and Parking Lots Scan Survey Survey Investigation QC Replicate Scan Survey Unit ClassReus Coverage (%) (1) Req2u Performed, Coverage (%) (3)

TR-1-1 1 100 358 No 8.5 (4)

TR-1-2 1 100 358 No 8.5 TR-1-3 1 100 358 No 8.5 TR-1-4 1 100 358 No 8.5 TR-1-5 1 100 358 No 8.5 TR-1-6 1 100 358 No 8.5 TR-1-7 1 100 358 No 8.5 TR-1-8 1 100 358 No 8.5 TR-1-9 1 100 358 No 8.5 TR-1-10 1 100 358 No 8.5 TR-1-11 1 100 358 No 8.5 TR-2-1 2 32.4 362 No 11.2 TR-2-2 2 47.6 362 No 11.2 TR-2-3 2 32.2 362 No 11.2 TR-2-4 2 33.0 362 No 11.2 Table 8 Notes:

1. One hundred percent of the accessible surface area of Class 1 survey units was scanned.

Altogether, 2,560 ft2 of the total Class 1 survey unit area (171,309 ft2), was inaccessible for scanning. The scanned area is 168,748 ft2 . The un-scanned inaccessible area is less than 1.5%

(1.49%) of the total surface area.

2. The SR under which the scan surveys were performed.

3. The % QC scan coverage is given as the % of the area scanned in the initial survey.

4. Replicate QC scan coverage is reported in the aggregate for all 11 Class 1 survey units. The QC scans covered a total area of 14,369 ft2. This is 8.5% of the 168,748 ft2 scanned in the original scan survey of the Class 1 survey units.

5. Replicate QC scan coverage is reported in the aggregate for the four Class 2 survey units. The QC scans covered a total area of 14,900 ft2. This is 11.2 % of the 133,405 ft2 scanned in the original scan survey of the Class 2 survey units.

5.2 Fixed Measurements and Tests Results of the assessment of FSS total surface beta measurements are presented in Table 9.

(individual measurements in each survey unit are reported in Appendix B). The table presents the number of measurements, maximum, average and standard deviation for each survey unit.

22

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 Table 9 compares the maximum activity measured in each survey unit to the DCGLw. It is demonstrated that all measured activity values are less than the DCGLw, thus all survey units meet the 25 mrem/y release criterion. The mean activity of each survey unit is also compared to the DCGLw, and as expected, are all less than the DCGLw. The average of 176 total 2 surface beta measurements reported in the TRPL release records is: 483 +/- 1050 dpm/100-cm (one standard deviation). 22 Removable surface activity measurements were also performed at each fixed activity measurement location and counted for gross alpha and gross beta activity. A review of the release records was conducted to ensure that all smear counting results were less than 10% of the gross activity DCGL. The requirement for PBRF laboratory smear counting instruments is that the MDAs be < 10% of the applicable gross activity DCGL 23. Gross beta and gross alpha counts for all FSS smears collected in the TRPL were less than MDA.

Table 9, Total Surface Beta Activity Measurement Summary and Test Results Survey No. of Maximum Test Result: Average Standard Deito Test Avrg< Result:

Unit ID Measurements () Maximum < (1) Deviation Average <

DCGLw (2) (1)(3) DCGLW (2)

TR-1-1 11 414 Yes 291 112 Yes TR- 1-2 14(4) 812 Yes 513 164 Yes TR-1-3 13(4) 880 Yes 513 187 Yes TR-1-4 11 824 Yes 487 183 Yes TR- 1-5 11 613 Yes 352 161 Yes TR- 1-6 11 723 Yes 465 163 Yes TR-1-7 12(4) 691 Yes 457 159 Yes TR- 1-8 11 582 Yes 432 105 Yes TR- 1-9 11 754 Yes 412 236 Yes TR-1-10 11 858 Yes 419 263 Yes TR-1-11 1 676 Yes 346 200 Yes TR-2-1 14(4) 14,10815) Yes 1275 3697 Yes TR-2-2 10 713 Yes 372 209 Yes TR-2-3 13) 631 Yes 313 154 Yes TR-2-4 11 580 Yes 397 130 Yes Table 9 Notes:

1. The units for: maximum, average and standard deviation are dpm/1 00-cm 2 .

2. The survey unit maximum and average activities were compared to the revised DCGLw value for the TRPL, 20,831 dpm/100 cm2 .

3. Standard deviations of the measurements in each survey unit are reported for comparison to the values used in the survey design. As shown in the table, values of o obtained from the FSS measurements in each TRPL survey unit are less than values used in the survey design (4166 dpm/100-cm 2). This confirms that the survey design for the TRPL was conservative.

22 mesrmnsi2otedtco It is noted that in converting total surface activity measurements in cpm to dpm/100-cm , the detector background response from surface materials is not subtracted. As a result, the total surface activity measurement results are biased high.

23 Typical MDAs for PBRF low background smear counting instruments are 14 dpm for alpha and 18 dpm for beta.

Smears cover 100 cm 2 , so these MDA values are equivalent to dpm/100-cm2.

23

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0

4. In the FSS design calculation for survey units developed using VSP, "extra" fixed measurement locations are sometimes added when fitting the calculated grid size onto the survey unit layout.

5. In survey unit TR-2-1, the value of 14,108 dpm/100-cm 2 was noted at location SM-3, located on Line 3 Rd. about 150 ft. north of North Rd. (see the TR-2-1 survey unit map in Appendix B). As a result, the SM-3 area was evaluated and the area of elevated activity was found to be 4 x 4 cm. A beta scan survey was performed that covered the full width of Line 2 Rd. extending 30 ft. north and 30 ft. south of the SM-3 location. No other areas of "elevated" activity were observed (all the scan count rates were less than the scan investigation level). No further action was taken.

5.3 Removable Surface Activity Measurements The FSS Plan requires that removable surface activity in each survey unit be less than 10% of the DCGLw. In accordance with the FSS Plan, removable surface activity measurements were taken at each systematic measurement location in TRPL survey units. Removable surface activity is measured by counting 100 cm 2 smear samples for beta and alpha activity. 24 Results were below counting instrument MDA values in all survey units. Hence, removable surface activity measurement results are less than 10% of the applicable survey unit DCGLw for all TRPL survey units.

5.4 QC Measurements Per FSS Plan requirements, QC replicate measurements were taken of at least 5% of the TRPL FSS measurements. This included scan surveys and total surface activity measurements. Scan QC survey results are shown in Table 8 wherein the 5% scan QC coverage is confirmed. No QC scan surveys identified areas of elevated activity - these surveys confirmed the results of the original scan surveys of the areas covered, that is, both the original and QC scan measurements were below the investigation level.

Replicate total surface activity measurements were performed at selected systematic measurement locations. The 5 % requirement is satisfied in that 10 replicate QC measurements were reported; this represents 5.7 % of the 176 systematic measurements taken in the FSS of the TRPL. The measurement results for the 10 total surface activity original and QC replicate measurement pairs are shown in Table 10. The data are sorted by increasing original activity.

The FSS Plan (Section 12.7) identifies a target criterion of 20% for the relative percent difference (RPD) between original and replicate measurements [NASA 2007]. Seven of the 10 measurement pairs exceed the 20% criterion. Each measurement pair failing to meet the 20% criterion was individually investigated in accordance with FSS Plan requirements and implementing procedures, resolved and determined to be acceptable.25 24 Smears are counted in the PBRF Counting Laboratory on automated sample changer proportional counters. Two such counters are available for this purpose: Tennelec Model LB-5 100 and Tennelec Model 5X-LB. Typical MDAs for these counters are 10 to 16 dpm beta and 8 to 12 dpm alpha.

25 When the acceptance criterion is not met, an investigation is performed to determine the cause and corrective actions.

The investigation may include repetition of the replicate QC measurement or other actions determined by the FSS/Characterization Supervisor. If upon repetition, the RPD criterion is still not satisfied, the result may be accepted if the original and QC replicate measurement are in agreement that both are below the DCGLw for the survey unit, the 24

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 It is found that all of the TRPL FSS measurements (except one) subjected to QC replicate measurements were low activity measurements (below 1000 dpm/1 00-cm 2). Experience and the theory of measurement errors have shown that low activity measurements such as these are subject to variation which is high relative to the measured activity.

Table 10, Replicate QC Measurements Survey Unit Measurement Net Activity QC Replicate Location No. (dpm/100 cm2) (dpm/100 cm2) RPD (%)

TR-2-2 9 197 446 77.4 TR-1-7 7 237 594 85.9 TR-2-2 6 363 149 83.6 TR-1-2 1 376 453 18.6 TR- 1-3 1 466 245 62.2 TR- 1-7 1 475 469 1.3 TR-1-4 4 528 548 3.7 TR-1-5 3 549 433 23.6 TR- 1-7 3 626 1084 53.6 TR-2-1 3 14108 14959 5.9 5.5 ALARA Evaluation It is shown that residual contamination in the TRPL survey units has been reduced to levels that are ALARA, using a method acceptable to the NRC. The NRC guidance on determining that residual contamination levels are ALARA includes the following:

"In'light of the conservatism in the building surface and surface soil generic screening levels developed by the NRC, NRC staff presumes, absent information to the contrary, that licensees who remediate building surfaces or soil to the generic screening levels do not need to provide analyses to demonstrate that these screening levels are ALARA. In addition, if residual radioactivity cannot be detected, it may be presumed that it had been reduced to levels that are ALARA. Therefore the licensee 26 may not need to conduct an explicit analysis to meet the ALARA requirement.

Screening level values published by the NRC for the mix of radionuclides in structural surface residual contamination potentially present in the TRPL are shown in Table 11. Since FSS/Characterization Supervisor reviews the investigation and concurs that the measurement is acceptable and the results of the investigation are documented in the Survey Request Summary and Close-out (Procedure CS-01, Survey Methodology to Support PBRF License Termination).

26 This guidance was initially published in Draft Regulatory Guide DG-4006, but has been reissued in NUREG-1757 Volume 2, Appendix N.

25

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 individual radionuclide activity concentrations are not measured in the FSS of structures and the TRPL, a direct comparison of residual contamination levels to individual radionuclide screening level values is not possible. A comparison can be made to an appropriate gross activity DCGL. A screening level value that is equivalent to the gross activity DCGL was calculated using the equations in Section 3.6 of the FSS Plan. 27 The activity fractions listed in Table 3 (also shown in Table 11) were used in the calculation. The activity fractions used for this ALARA evaluation are the default mixture developed for the PBRF in TBD-1 1-002. The screening level equivalent DCGL for the TRPL using this mixture is calculated to be 14,124 dpm/100-cm 2 .

The average total surface beta activity measured in the FSS of the TRPL surfaces is 483 +/-

1050 dpm1 00-cm2 (one standard deviation). The upper limit of the 9 5th oconfidence interval of this mean value is 638 dpm/100-cm2.8 22 This value is below the screening level gross activity DCGL of 14,124 dpm/1 00-cm2 .

Table 11, Screening Level Values and Radionuclide Activity Fractions Screening Level Value 2 Activity Fraction Radionuclide (dpm/100-cm (%) (1)

H-3 1.2 E+08 ý") 26.5 Co-60 7.1E+03 (2) 17.8 Sr-90 8.7E+03 (2) 7.8 1-129 3.5E+0412) 0.13 Cs-137 2.8E+0412) 46.5 Eu-154 1.2E+0413 ) 0.13 U-234 9.1E+01 (3) 0.0 U-235 9.8E+0 13) 0.0 Table 11 Notes.

1. Activity fractions used to develop the DCGLw for TRPL are from TBD- 11-002; the revised default radionuclide mixture.

2. Values from NUREG- 1757 Vol. 2, Table H. 1 [USNRC 2006].

3. Values from NUREG/CR-55 12, Vol. 3, Table 5.19 [SNL 1999]. These are 90th percentile values of residual surface activity corresponding to 25 mrem/y to a future building occupant.

5.6 Comparison with EPA Trigger Levels The PBRF license termination process includes a review of residual contamination levels in groundwater and soil, as applicable, in accordance with the October 2002 Memorandum of Understanding (MOU) between the US NRC and the US Environmental Protection Agency (EPA) [USEPA 2002]. Concentrations of individual radionuclides, identified as "trigger levels" for further review and consultation between the agencies, are published in the MOU.

27 The equivalent screening level gross activity DCGL is calculated using an EXCEL template. This template incorporates the equations in section 5.3 of the FSS Plan [NASA 2007].

28 The upper limit of the confidence interval, 95th percentile value, is calculated as: UL = mean + 1.96 aI/*n, where n 176 measurements.

26

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 As the FSS of the TRPL comprises no soil or groundwater measurements, the comparison with EPA trigger levels is not applicable.

5.7 Conclusions The results presented above demonstrate that the TRPL satisfy all FSS Plan commitments and meet the release criteria in 10CFR20 Subpart E. The principal conclusions are:

• Scan surveys were performed in 100 % of the accessible surfaces of all eleven Class 1 survey units and at least 30% of the four Class 2 survey units.

" The scan action-investigation level was not exceeded during the FSS.

• All systematic (with random start) total surface activity measurements are less than the applicable DCGLw.

" All survey unit mean fixed measurement results (total surface beta activity) are below the DCGLw, hence no statistical tests were required.

• All removable surface activity measurements are less than 10% of the DCGLw.

• Residual surface activity concentration measurement results are shown to be less than NRC screening level values - demonstrating that the ALARA criterion is satisfied.

" Volumetric and subsurface contamination levels in the Transport Roadways and Parking Lots were evaluated. All measured results were well below the applicable DCGLs.

• The only change from what was proposed in the FSS Plan was that the TRPL was divided into 15 survey units, whereas the FSS Plan did not provide a breakdown of the Transport Roadways and Parking Lots.

• There were no changes from initial assumptions (in the FSS Plan) regarding the extent of residual activity in the TRPL. No reclassification of survey units was required as a result of FSS measurements.

6.0 References Bowles 2006 Mark D. Bowles, Science in Flux, NASA's Nuclear Programat Plum Brook Station 1955 - 2000, NASA History Division, Washington DC, June 2006.

GTS 1998 GTS-Duratek, Inc., NASA/Lewis Plum Brook Facility 1998 Confirmation Survey, Volume I - Survey Packages andSurvey Results, November 1998.

Hagelin 2010 Karl W. Hagelin, Bremba K. Jones and Associates, NASA Plum Brook Reactor Facility Coordinates,PersonalCommunication,December 20, 2010.

ISO 1988 International Organization for Standardization, Evaluation of Surface Contamination,Part 1: Beta Emitters andAlpha Emitters, ISO-7503-1, 1988.

27

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 NACA 1956 National Advisory Committee on Aeronautics, NACA NuclearReactor Plot Plan and Soil BoringData, Drawing No. PFOO101, Plot Plan and Soil Boring Data, Dec.

4, 1956.

NASA 2007 NASA Safety and Mission Assurance Directorate, FinalStatus Survey Planfor the Plum Brook ReactorFacility, Revision 1, February 2007.

NASA 2007a NASA Safety and Mission Assurance Directorate, DecommissioningPlanfor the Plum Brook Reactor Facility,Revision 6, July 2007.

MWH 2005 Montgomery Watson Harza, Inc. NASA Plum Brook Reactor Facility Decommissioning,Survey Package A2500 201C1, PentoliteRoad (West)

Radioactive MaterialStorageArea, April 19, 2005.

PBRF 2007 Plum Brook Reactor Facility Technical Basis Document, Adjusted Gross DCGLsfor StructuralSurfaces, PBRF-TBD-07-001, June 2007.

PBRF 2007a Plum Brook Reactor Facility Technical Basis Document, Efficiency Correction Factor,PBRF-TBD-07-004, November 2007.

PBRF 2009 Plum Brook Reactor Facility Technical Basis Document, RadionuclideDistributions and Adjusted DCGLsfor Site Soils, PBRF-TBD-09-001, June 2009.

PBRF 2012 Plum Brook Reactor Facility Technical Basis Document, Re-evaluation of Radionuclide Mixtures and Structure DCGLs, PBRF-TBD- 11-002, January 2012.

PNL 2010 Battelle Pacific Northwest Laboratories (PNL), Visual sample Plan,Version 5.9, 2010.

SNL 1999 Sandia National Laboratories (SNL), for US Nuclear Regulatory Commission, Residual Radioactive ContaminationFrom Decommissioning,ParameterAnalysis, NUREG/CR-5512, Vol.3, Oct. 1999.

Tele 1987. Teledyne Isotopes, An Evaluation of the Plum Brook Reactor Facilityand Documentationof Existing Conditions,Prepared for NASA Lewis Research Center, December 1987.

USACE 2004 US Army Corps of Engineers Louisville District, HydrologicalReport Plum Brook Reactor FacilitySandusky, Ohio, November 17, 2004.

USEPA 2002 Memorandum of Understanding, US Environmental Protection Agency and US Nuclear Regulatory Commission, Consultationand Finalityon Decommissioning andDecontaminationof ContaminatedSites, October 9, 2002.

USNRC 2000 US Nuclear Regulatory Commission, Multi-Agency RadiationSurvey and Site Investigation Manual (MARSSIM), NUREG- 1575, Rev. 1, August 2000.

28

Plum Brook Reactor Facility FSSR Attachment 14, Rev. 0 USNRC 2006 US Nuclear Regulatory Commission, ConsolidatedDecommissioning Guidance, Characterization,Survey and Determinationof RadiologicalCriteria,NUREG 1757, Vol. 2, Rev.1, September 2006.

7.0 Appendices Appendix A - Exhibits Appendix B - Survey Unit Maps and Tables Showing Measurement Locations and Results 29

Plum Brook Reactor Facility Final Status Survey Report Attachment 14 Transport Roadways and Parking Lots Revision 0 Appendix A Exhibits

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 2 of 34 List of Exhibits Exhibit 1, Aerial View of PBOW circa 1950 Looking North ........................................................... 3 Exhibit 2, Aerial View of PBOW circa 1950 Looking West ........................................................... 4 Exhibit 3, Survey Unit TR-I-1, (October 2011) .............................................................................. 5 Exhibit 4, Survey Unit TR-1 Looking North from North Rd. (November 2011) ....................... 6 Exhibit 5, Survey Unit TR-1-3 (November 2011) ............................................................................ 7 Exhibit 6, Survey Unit TR-1-3, West Leg of North Road Looking West through Gate 2 ................ 8 Exhibit 7, Survey Unit TR-1-3, East Leg of North Road - looking East ........................................... 9 Exhibit 8, Survey Unit TR-1-3, Road South of former SEB, looking East ..................................... 10 Exhibit 9, Survey Unit TR-1-4, Line 3 Road Looking South from BJ Grid line (November 2011) ... 11 Exhibit 10, Survey Unit TR-1-4, Roadway from.Line 3 Road to the Hot Lab ................................ 12 Exhibit 11, Survey Unit TR-1-5 Looking East (November 2011) .................................................. 13 Exhibit 12, Survey Unit TR-1-6, Parking Lot West Soil Lift Area Looking South (December 2011) 14 Exhibit 13, Survey Unit TR-1-7, East Soil Lift Area Looking South (December 2011) ................. 15 Exhibit 14, Survey Unit TR-1-8, Pentolite Road Radwaste Storage Yard Looking North (December 2 0 11)..................................................................................................................................................... 16 Exhibit 15, Survey Unit TR-1-9, Pentolite Road Radwaste Storage Yard Looking North (December 20 11)..................................................................................................................................................... 17 Exhibit 16, Survey Units TR-I-10 and 1-11, Pentolite Road Radwaste Storage Yard Looking North (D ecember 2011) .................................................................................................................................. 18 Exhibit 17, Survey Unit 2-1, Line 1 Road Looking North from Parking Lot (November 2011) ........ 19 Exhibit 18, Survey Unit TR-2-1 Northern E-W Leg, Looking East ............................................... 20 Exhibit 19, Survey Unit TR-2-1, North Road Looking East from Line 3 Road ............................. 21 Exhibit 20, Survey Unit TR-2-2, Line 3 Rd. Looking North from Parking Lot (November 2011) ..... 22 Exhibit 21, Survey Unit TR-2-2, North Side of Parking Lot Looking West .................................. 23 Exhibit 22, Survey Unit TR-2-2, South Side of Parking Lot Looking West .................................. 24 Exhibit 23, Survey Unit TR-2-3, Pentolite Road Looking West from Plum Brook (November 2011)

...................................... ooo°° o°,*°. ,*o°....................................... o°°°**° ........ ....................................... 2 5 Exhibit 24, Survey Unit TR-2-3 Line 2 Road Looking North from Pentolite Road ....................... 26 Exhibit 25, Survey Unit TR-2-4, Pentolite Road Looking West from Garage Road (November 2011)

.......................................................................................................................................................... . 27 Exhibit 26, Survey Unit TR-2-4, Garage Road Looking South from Pentolite Road ..................... 28 Exhibit 27, Survey Unit TR-2-4, Line 1 Road Looking North from Pentolite Road ...................... 29 Exhibit 28, Survey Unit TR-2-4, East Warehouse Storage Lot Looking North ............................. 30 Exhibit 29, Survey Unit TR-2-4, West Warehouse Storage Lot Looking North ............................ 31 Exhibit 30, Unusual Condition Measurement Areas ........................................................................ 32 Exhibit 31, Unusual Condition Measurement Areas, Continued ........................ 33 Exhibit 32, Unusual Condition Measurement Areas, Continued .................................................... 34

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 3 of 34 Exhibit 1, Aerial View of PBOW circa 1950 Looking North 2 Road is in the Center N-S and Nnrth Rnad ii F,.W in ths ,.ntr\

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 4 of 34 Exhibit 2, Aerial View of PBOW circa 1950 Looking West (Line 3 Road is in the Foreground; Line 1 Road is at the Top; the E-9 Warehouses and Parking Lots are at Top Left)

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 5 of 34 Exhibit 3, Survey Unit TR-1-1, (October 2011)

(View of E-W Leg from inside Gate 1 Looking Northwest - pre-FSS cleaning is in progress)

(View of N-S Leg looking north - pre-FSS cleaning is in progress)

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 6 of 34 Exhibit 4, Survey Unit TR-1 Looking North from North Rd. (November 2011)

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 7 of 34 Exhibit 5, Survey Unit TR-1-3 (November 2011)

(The section of North Road that extends East of Line 3 Rd. - lookh

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 8 of 34 Exhibit 6, Survey Unit TR-1-3, West Leg of North Road Looking West through Gate 2 t

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 9 of 34 Exhibit 7, Survey Unit TR-1-3, East Leg of North Road - looking East

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 10 of 34 Exhibit 8, Survey Unit TR-1-3, Road South of former SEB, looking East

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 11 of 34 Exhibit 9, Survey Unit TR-1-4, Line 3 Road Looking South from BJ Grid line (November 2011)

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 12 of 34 Exhibit 10, Survey Unit TR-1-4, Roadway from Line 3 Road to the Hot Lab I I

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 13 of 34 Exhibit 11, Survey Unit TR-1-5 Looking East (November 2011)

(Crossover Road looking east from Line 3 Road toward the WEMS)

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 14 of 34 Exhibit 12, Survey Unit TR-1-6, Parking Lot West Soil Lift Area Looking South (December 2011)

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 15 of 34 Exhibit 13, Survey Unit TR-1-7, East Soil Lift Area Looking South (December 2011) 40

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 16 of 34 Exhibit 14, Survey Unit TR-1-8, Pentolite Road Radwaste Storage Yard Looking North (December 2011) 4 1'/

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 17 of 34 Exhibit 15, Survey Unit TR-1-9, Pentolite Road Radwaste Storage Yard Looking North (December 2011)

,V i

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 18 of 34 Exhibit 16, Survey Units TR-1-10 and 1-11, Pentolite Road Radwaste Storage Yard Looking North (December 2011)

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 19 of 34 Exhibit 17, Survey Unit 2-1, Line 1 Road Looking North from Parking Lot (November 2011)

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 20 of 34 Exhibit 18, Survey Unit TR-2-1 Northern E-W Leg, Looking East

.\

A,.

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 21 of 34 Exhibit 19, Survey Unit TR-2-1, North Road Looking East from Line 3 Road

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 22 of 34 Exhibit 20, Survey Unit TR-2-2, Line 3 Rd. Looking North from Parking Lot (November 2011)

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 23 of 34 Exhibit 21, Survey Unit TR-2-2, North Side of Parking Lot Looking West

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 24 of 34 Exhibit 22, Survey Unit TR-2-2, South Side of Parking Lot Looking West

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 25 of 34 Exhibit 23, Survey Unit TR-2-3, Pentolite Road Looking West from Plum Brook (November 2011)

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 26 of 34 Exhibit 24, Survey Unit TR-2-3 Line 2 Road Looking North from Pentolite Road

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 27 of 34 Exhibit 25, Survey Unit TR-2-4, Pentolite Road Looking West from Garage Road (November 2011)

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 28 of 34 Exhibit 26, Survey Unit TR-2-4, Garage Road Looking South from Pentolite Road

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 29 of 34 Exhibit 27, Survey Unit TR-2-4, Line 1 Road Looking North from Pentolite Road

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 30 of 34 Exhibit 28, Survey Unit TR-2-4, East Warehouse Storage Lot Looking North

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 31 of 34 Exhibit 29, Survey Unit TR-2-4, West Warehouse Storage Lot Looking North

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 32 of 34 Exhibit 30, Unusual Condition Measurement Areas npmpnt in Qilrvpv I hit Xl )

(Rot TrD _I

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 33 of 34 Exhibit 31, Unusual Condition Measurement Areas, Continued ti-ýrnv1~ihiPU hri-n& ;n nnui-mint in 5qiirvpev I Tnit TR- 1 -11 (Rough pavement surface in Survey Unit TR-1-6)

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix A, Rev. 0, Page 34 of 34 Exhibit 32, Unusual Condition Measurement Areas, Continued

Plum Brook Reactor Facility Final Status Survey Report Attachment 14 Transport Roadways and Parking Lots Revision 0 Appendix B Survey Unit Maps and Tables Showing Measurement Locations and Results

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix B Rev. 0, Page 2 of 18 Index of Transport Roadways Survey Unit Maps and Tables of Coordinates Survey Unit Description Page Number Number of Pages TR-1-1 West Access Driveway to Reactor Building 4 1 (6,012 ft2 )

TR-1-2 Line 3 Road north of North Road (10,024 ft2) 5 1 TR- 1-3 Line 3 Road 2 from BJ Gridline to North Road 6 (20,214 ft ) 6_1 TR-1-4 Line 3 Road from South Crossover to BJ Gridline 7 1 1 (17,246 ft)

Line 3 Road from Gate 6 to South Crossover and WEMS Road (9,042 ft2 )

TR-1-6 Parking Lot - West Soil Lift Area (17,142 ft2 ) 9 1 TR- 1-7 Parking Lot - East Soil Lift Area (17,148 1f) 10 1 TR-1-8 Pentolite Road Rad Waste Storage - Section #1 11 1 (19,413 ft2)

TR-1-9 Pentolite Road 2 Rad Waste Storage - Section #2 12 1 (19,492 ft )

TR-1-10 Pentolite Road Rad Waste Storage - Section #3 13 1 (19,510 ft2)

TR-I-11 Pentolite Road Rad Waste Storage - Section #4 14 1 TR-1-11__ (18,446 ft) 14_1 Northern Sections of Line 1, 2, & 3 Roads (107,084 TR-2-1 ft2) 15 1 TR-2-2 Class 2 Section of Parking Lot, Line 2 Road from 16 1 Parking Lot to North Road (85,107 ft2 )

Line 2 Road from Parking Lot to Pentolite Road, TR-2-3 Pentolite Road from Line 2 Road to Plumbrook 17 1 (95,198 ft2)

Pentolite Road from Line 2 Road to West TR-2-4 Warehouse, Line 1 Road from Pentolite Road to 18 1 Parking Lot, North 0.1 mile of Garage Road (83,406 ft2)

Appendix B Notes:

1. Occasionally negative values of individual measurements appear in the tables in this appendix. In 2 accordance with PBRF FSS/Characterization procedures, each measurement result in dpm/100-cm is obtained by taking a shielded measurement and an unshielded measurement at each location established in the survey design. The shield is of sufficient thickness to completely attenuate (absorb) the most energetic beta from PBRF residual surface contamination (Sr/Y-90). The net activity is then determined as:

Net activity in dpm/lOO-cm 2 = (Unshielded cpm - Shielded cpm): Where:

Et (A/100)

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix B Rev. 0, Page 3 of 18 Unshielded cpm is the detector response including contributions from radiation entering the detector sensitive face (open area) and from ambient radiation (mostly gammas) entering the detector from all directions.

Shielded cpm is the detector response with the shield in place between the detector sensitive face and the surface being investigated. The shield eliminates beta particles from the surface under investigation and the detector response is due only to ambient radiation that enters the detector (from all directions).

(Unshielded cpm - Shielded cpm) is the net cpm due to activity, mostly beta particles entering the detector from the surface under investigation. Note that the net cpm includes contributions from residual contamination that may be present and from naturally occurring beta emitters in the material. This natural background component is considered to be small and is neglected, i. e., this background contribution is not subtracted in determining net cpm.

Detector efficiency, E,, dpmlcpm for the detector, is the product of the detector efficiency and the surface efficiency. A typical value of E, for the Ludlum 44-116 detector, the detector of choice for FSS systematic measurements in structures, is approximately 15% (0.15).

A/100 is the factor to convert dpm per detector area to dpm/l 00-cm 2, where A is the detector open area in cm 2. The open area of the Ludlum 44-116 is 100 cm 2, so the (A/l100) factor is unity in this case.

Negative values of net activity occur when the measured shielded cpm is greater than the measured unshielded cpm at a location. This most often occurs in survey units where residual contamination levels are low, near background, and the ambient background is also low. Thus, the random variability of low level count rates will result in occasional measurement pairs where the recorded shielded count rate exceeds the unshielded count rate.

2. The survey unit maps on the following pages show the survey units in color. The Class 1 survey units are colored yellow and the Class 2 are colored blue. The Class 1 roadway survey units are overlaid onto the FSS grid system (grid lines are not labeled). Survey units TR-1-3 and TR-1-4 are identified with reference to the BJ grid line. That is the E-W grid line which passes just south of the Reactor Building. Areas within the Class 1 roadway survey units that are gray colored or not colored (TR-1-1) are not paved. These areas were not surveyed in the FSS of the TRPL. They were covered in the FSS of Open Land Areas, Attachment 16 of the FSS Report.

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix B Rev. 0, Page 4 of 18 Survey Unit TR-1-1 TR-1-1 AREA: West Access Driveway to Reactor Building Measurement Locations and results Location /

2 X Co-ord (ft) Y Co-ord (ft) dpm/1 00-cm Type Notes 15' east of SW comer 6' north of SW comer SM-1 344 Systematic N/A 40' east of SW comer 6' north of SW comer SM-2 376 Systematic N/A 65' east of SW comer 6' north of SW comer SM-3 64 Systematic N/A 115' east of SW comer 6' north of SW comer SM-4 414 Systematic N/A 130' east of SW comer 29' north of SW comer SM-5 255 Systematic N/A 130' east of SW corner 73' north of SW comer SM-6 395 Systematic N/A 140' east of SW comer 95' north of SW corner SM-7 127 Systematic N/A 165' east of SW comer 95' north of SW corner SM-8 306 Systematic N/A 130' east of SW comer 117' north of SW comer SM-9 363 Systematic N/A 155' east of SW corner 117' north of SW comer SM-10 325 Systematic N/A 140' east of SW corner 139' north of SW comer SM-1 1 229 Systematic N/A The X, Y coordinates for survey locations SM-1 thru SM-1 1 are measured from the SW comer of the survey unit.

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix B Rev. 0, Page 5 of 18 Survey Unit TR 2 -- - - -

Line 3 Road North of North Road Measure from this point TR-1-2 AREA: Line 3 Road North of North Road Measurement Locations and results X Co-ord Y Co-ord Location / 2 Type Notes Lft) Lft) dpm/1 00-cm 0 -175 SM-1 376 Systematic N/A 20 -141 SM-2 767 Systematic N/A 0 -107 SM-3 812 Systematic N/A 20 -73 SM-4 594 Systematic N/A 0 -40 SM-5 571 Systematic N/A 20 -6 SM-6 293 Systematic N/A 0 28 SM-7 534 Systematic N/A 20 62 SM-8 534 Systematic N/A 0 96 SM-9 662 Systematic N/A 20 129 SM-10 429 Systematic N/A 0 163 SM-I1 286 Systematic N/A 20 197 SM-12 519 Systematic N/A 0 231 SM-13 481 Systematic N/A 20 265 SM-14 323 Systematic N/A The X, Y coordinates for survey locations SM-1 thru SM-14 are measured from the intersection of the BO arid line with the west edae of the road.

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix B Rev. 0, Page 6 of 18 Survey Unit TR-1-3 Line 3 Road from BJ Gridline to North Road TR-1-3 AREA: Line 3 Road from BJ Gridline to North Road Measurement Locations and results X Co-ord (ft) Y Co-ord (ft) Location I Type Notes dpm/1 00-cm 2 17 4.5 SM-1 466 Systematic N/A 30.5 4.5 SM-2 504 Systematic N/A 91.5 4.5 SM-3 714 Systematic N/A 14.5 4.5 SM-4 789 Systematic N/A 5.5 4.5 SM-5 496 Systematic N/A 5.5 26 SM-6 331 Systematic N/A 16.5 14.5 SM-7 338 Systematic N/A 31 9 SM-8 361 Systematic N/A 92 9 SM-9 549 Systematic N/A 37 9 SM-10 361 Systematic N/A 97 9 SM-1 1 293 Systematic N/A 158 9 SM-12 880 Systematic N/A 199 9 SM-13 586 Systematic N/A The X,Y coordinates for survey locations SM-1 thru SM-1 3 are measured from the southwest comer of the road section in which they lie.

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix B Rev. 0, Page 7 of 18 Survey Unit TR-1-4 Line 3 Road from South Crossover to BJ Gridline TR-1-4 AREA: Line 3 Road from South Crossover to BJ Gridline Measurement Locations and results X Co-ord Y Co-ord Location / Type Notes (ft) (ft) dpm/IOO-cm2 _

17 71 SM-1 218 Systematic N/A 17 145 SM-2 585 Systematic N/A 17 219 SM-3 465 Systematic N/A 17 292 SM-4 528 Systematic N/A 17 366 SM-5 444 Systematic N/A 17 440 SM-6 732 Systematic N/A 17 513 SM-7 451 Systematic N/A 17 587 SM-8 218 Systematic N/A

-68 661 SM-9 444 Systematic N/A

-26 661 SM-1 451 Systematic N/A 17 661 SM-Il 824 Systematic N/A I

Tne X, Y coorainates tor survey locations SM-1 tnru SM-1 1 are measurea from the southwest corner of the survey unit.

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix B Rev. 0, Page 8 of 18 Survey Unit TR-1-5 Line 3 Road from Gate 6 to South Crossover and WEMS Road TR-1-5 AREA: Line 3 Road from Gate 6 to South Crossover and WEMS Road Measurement Locations and results X Co-ord (ft) Y Co-ord (ft) Location I 2 Type Notes dpm/1 00-cm 12 5.5 SM-1 127 Systematic N/A 60 5.5 SM-2 134 Systematic N/A 107 4.8 SM-3 549 Systematic N/A 155 3.7 SM-4 380 Systematic N/A 203 3.9 SM-5 549 Systematic N/A 251 4.7 SM-6 345 Systematic N/A 299 6.0 SM-7 317 Systematic N/A 347 7.1 SM-8 303 Systematic N/A 395 7.1 SM-9 268 Systematic N/A 443 7.1 SM-10 289 Systematic N/A 491 26 SM-11 613 Systematic N/A The X coordinate for survey locations SM-1 thru SM-11 is measured from the west edge of L3 road, the Y-coordinate from the south edge of WEMS Rd.

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix B Rev. 0, Page 9 of 18 Survey Unit TR-1-6 Parking Lot, West Soil Lift Area SM- SFM-I S3M- SM- SM SM SM SM-I SM-Ares Lift Soilresults Westand Lot, ParkingLocations TR-I-6 AREA: TR-1 -6 AREA: Parking Measurement Lot, West Soil Lift Area Measurement Locations and results X Co-ord (ft) Y Co-ord (ft) Location / 2 Type Notes dpm/1 00-cm 42 21 SM-1 277 Systematic N/A 85 21 SM-2 209 Systematic N/A 21 58 SM-3 365 Systematic N/A 64 58 SM-4 311 Systematic N/A 106 58 SM-5 676 Systematic N/A

-0 94 SM-6 439 Systematic N/A 42 94 SM-7 541 Systematic N/A 85 94 SM-8 723 Systematic N/A 21 131 SM-9 574 Systematic N/A 64 131 SM-10 500 Systematic N/A 106 131 SM-11 500 Systematic N/A Samples are measured from the southwest corner of the survey unit.

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix B Rev. 0, Page 10 of 18 Survey Unit TR-1-7 Parking Lot, East Soil Lift Area SM-Il SM-12 SM-S 5M4 SM4 SM-3 SM IM-L ism-.1 TR-1-7 AREA: Parking Lot, East Soil Lift Area Measurement Locations and results X Co-ord (ft) Y Co-ord (ft) Location I Type Notes dpm/1 00-cm 2 34 1 SM-1 475 Systematic N/A 76 1 SM-2 489 Systematic N/A 13 38 SM-3 626 Systematic N/A 55 38 SM-4 525 Systematic N/A 98 38 SM-5 331 Systematic N/A 34 75 SM-6 223 Systematic N/A 76 75 SM-7 237 Systematic N/A 13 111 SM-8 691 Systematic N/A 55 111 SM-9 662 Systematic N/A 98 111 SM-10 525 Systematic N/A 34 148 SM-11 360 Systematic N/A 76 148 SM-12 345 Systematic N/A Samples are measured from the southwest corner of the survey unit.

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix B Rev. 0, Page 11 of 18 Survey Unit TR-1-8 Pentolite Road Rad Waste Storage Yard - Section #1 TR-1-8 AREA: Pentolite Road Rad Waste Storage Yard - Section #1 Measurement Locations and results X Co-ord (ft) Y Co-ord (ft) Location / 2 Type Notes dpm/1 00-cm 26 4 SM-1 455 Systematic N/A 75 4 SM-2 328 Systematic N/A 1 47 SM-3 493 Systematic N/A 51 47 SM-4 239 Systematic N/A 26 90 SM-5 396 Systematic N/A 75 90 SM-6 321 Systematic N/A 51 132 SM-7 530 Systematic N/A 26 175 SM-8 537 Systematic N/A 75 175 SM-9 403 Systematic N/A 1 218 SM-10 582 Systematic N/A 51 218 SM-11 463 Systematic N/A Samples are measured from the southwest corner of the survey unit.

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix B Rev. 0, Page 12 of 18 Survey Unit TR-1-9 Pentolite Road Rad Waste Storage Yard - Section #2 TR-1-9 AREA: Pentolite Road Rad Waste Storage Yard - Section #2 Measurement Locations and results X Co-ord (ft) Y Co-ord (ft) Location / 2 Type Notes dpm/1 00-cm 76 0 SM-I 179 Systematic N/A 8 40 SM-2 231 Systematic N/A 53 40 SM-3 119 Systematic N/A 30 79 SM-4 478 Systematic N/A 76 79 SM-5 358 Systematic N/A 8 118 SM-6 754 Systematic N/A 53 118 SM-7 172 Systematic N/A 30 157 SM-8 552 Systematic N/A 76 157 SM-9 291 Systematic N/A 8 196 SM-10 739 Systematic N/A 53 196 SM-1 1 657 Systematic N/A Samples are measured from the southwest corner of the survey unit.

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix B Rev. 0, Page 13 of 18 Survey Unit TR-1 -10 Pentolite Road Rad Waste Storage Yard - Section #3 TR-1-10 AREA: Pentolite Road Rad Waste Storage Yard - Section #3 Measurement Locations and results X Co-ord (ft) Y Co-ord (ft) Location / Type Notes dpm/1 00-cm2 50 -0 SM-1 635 Systematic N/A 28 39 SM-2 47 Systematic N/A 73 39 SM-3 277 Systematic N/A 5 78 SM-4 514 Systematic N/A 50 78 SM-5 270 Systematic N/A 28 117 SM-6 122 Systematic N/A 73 117 SM-7 858 Systematic N/A 5 157 SM-8 466 Systematic N/A 50 157 SM-9 223 Systematic N/A 28 196 SM-10 412 Systematic N/A 73 196 SM-11 784 Systematic N/A Samples are measured from the southwest corner of the survey unit.

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix B Rev. 0, Page 14 of 18 Survey Unit TR-1-1 1 Pentolite Road Rad Waste Storage Yard - Section #4 TR-1-11 AREA: Pentolite Road Rad Waste Storage Yard - Section #4 Measurement Locations and results X Co-ord (ft) Y Co-ord (ft) Location / Type Notes dpm/1O0-cm _

27 18 SM-1 520 Systematic N/A 75 18 SM-2 216 Systematic N/A 3 60 SM-3 399 Systematic N/A 51 60 SM-4 0 Systematic N/A 27 102 SM-5 203 Systematic N/A 75 102 SM-6 182 Systematic N/A 3 143 SM-7 101 Systematic N/A 51 143 SM-8 473 Systematic N/A 27 185 SM-9 439 Systematic N/A 75 185 SM-10 480 Systematic N/A 3 226 SM-11 459 Systematic N/A 51 226 SM-12 676 Systematic N/A Samples are measured from the southwest comer of the survey unit.

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix B Rev. 0, Page 15 of 18 Survey Unit TR-2-1 TR-2-1 AREA: Northern Sections of Line 1, 2, & 3 Roads Measurement Locations and results X Co-ord (ft) Y Co-ord (ft) Location 2 Type Notes dpm/1 00-cm2 11 271 SM-1 236 Systematic N/A 11 588 SM-2 535 Systematic N/A 6 229 SM-3 14108 Systematic N/A 11 905 SM-4 229 Systematic N/A 6 545 SM-5 408 Systematic N/A 7 8 SM-6 89 Systematic N/A 11 1222 SM-7 197 Systematic N/A 2 856 SM-8 382 Systematic N/A 4 328 SM-9 236 Systematic N/A 11 1540 SM-10 293 Systematic N/A Edge 1176 SM-I1 516 Systematic N/A 9 644 SM-12 299 Systematic N/A 11 1857 SM-13 427 Systematic N/A 15 962 SM-14 -108 Systematic N/A The X, Y coordinates for survey locations SM-1 thru SM-14 are measured from the southwest comer of the road section surface on which they lie.

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix B Rev. 0, Page 16 of 18 Survey Unit TR-2-2 Class 2 Section of Parking Lot, Line 2 Road from Parking Lot to North Road 4 SMeaur fots sm M4 Measure from this pi E

TR-2-2 AREA: Class 2 Section of Parking Lot, Line 2 Road from Parking Lot to North"Road Measurement Locations and results X Co-ord (ft) Y Co-ord (ft) Location / Type Notes dpm/100-cm2

-166 6 SM-1 401 Systematic N/A

-55 6 SM-2 713 Systematic N/A 57 6 SM-3 389 Systematic N/A

-222 103 SM-4 0 Systematic N/A

-111 103 SM-5 Not taken Systematic N/A 1 103 SM-6 363 Systematic N/A

-278 200 SM-7 268 Systematic N/A

-166 200 SM-8 662 Systematic N/A

-55 200 SM-9 197 Systematic N/A 57 200 SM-10 293 Systematic N/A 57 393 SM-11 433 Systematic N/A Samples are measured from the point shown on the map.

SP-5 was inaccessible as it was under Trailer #5, and was not taken.

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix B Rev. 0, Page 17 of 18 Survey Unit TR-2-3 Line 2 Road from Parking Lot to Pentolite Road, Pentolite Road from Line 2 Road to Plumbrook 4

Ii TR-2-3 AREA: Line 2 Road from Parking Lot to Pentolite Road, Pentolite Road from Line 2 Road to Plumbrook Measurement Locations and results X Co-ord (ft) Y Co-ord (ft) Location / Type Notes dpm/100-cm 2 127 8 SM-1 363 Systematic N/A 438 8 SM-2 102 Systematic N/A 748 8 SM-3 338 Systematic N/A 1059 8 SM-4 64 Systematic N/A 1370 8 SM-5 306 Systematic N/A 1681 8 SM-6 631 Systematic N/A 1992 8 SM-7 312 Systematic N/A 2303 8 SM-8 210 Systematic N/A 2614 8 SM-9 178 Systematic N/A 2925 8 SM-10 312 Systematic N/A 3236 8 SM-11 439 Systematic N/A 3546 8 SM-12 484 Systematic N/A

-29 277 SM-1 3 331 Systematic N/A Samples are measured from the south edge of Pentolite Road at a point directly south of the west fence line.

Plum Brook Reactor Facility FSSR, Attachment 14 Appendix B Rev. 0, Page 18 of 18 Survey Unit TR-2-4 Pentolite Road from Line 2 Road to West Warehouse, Line 1 Road from Pentolite Road to Parking Lot, North 0.1 mile of Garage Road I"

441 --- -

l I Measure from this point I

\1 TR-2-4 AREA: Pentollte Road from Line 2 Road to West Warehouse, Line I Road from Pentolite Road to Parking Lot, North 0.1 mile of Garage Road Measurement Locations and results X Co-ord (ft) Y Co-ord (ft) Location I Type Notes dpm/100-cm2 1252 -305 SM-1 580 Systematic N/A 136 17 SM-2 510 Systematic N/A 322 17 SM-3 446 Systematic N/A 508 17 SM-4 541 Systematic N/A 694 17 SM-5 484 Systematic N/A 880 17 SM-6 255 Systematic N/A 1066 17 SM-7 248 Systematic N/A 1252 17 SM-8 299 Systematic N/A 229 178 SM-9 229 Systematic N/A 787 178 SM-10 306 Systematic N/A 787 500 SM-11 465 Systematic N/A Samples are measured from the southwest corner of the survey unit (on Pentolite Road).