ML12090A600

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Final Status Survey Report, Attachment 17, Buried and Miscellaneous Piping, for the Plum Brook Reactor Facility
ML12090A600
Person / Time
Site: Plum Brook
Issue date: 03/29/2012
From: Kolb P
US National Aeronautics & Space Admin (NASA), John H. Glenn Research Ctr at Lewis Field
To:
Document Control Desk, NRC/FSME
References
Download: ML12090A600 (82)
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Text

National Aeronautics and Space Administration John H. Glenn Research Center Lewis Field Plum Brook Station Sandusky, OH 44870 March 29, 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 17, Buried and Miscellaneous Piping, 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 17 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 Buried and Miscellaneous Piping. It supports our conclusion that radiological remediation of the buried and miscellaneous piping 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.

Aete Kolb P.

NASA Decommissioning Program Manager

Enclosure

1. Plum Brook Reactor Facility Final Status Survey Report, Attachment 17, Buried and Miscellaneous Piping, revision 0, dated March 29, 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 17 Revision 0 Buried and Miscellaneous Piping

ROUTING AND APROVAL SHEET Document

Title:

Final Status Survey Report, Attachment 17 Buried and Miscellaneous Piping Revision Number: 0 ROUTING Prepared By Independent Technical Reviewer W. Stoner Other Reviewer, QA Manager J. Thomas Other Reviewer N/A FSS/Characterization Manager W. Stoner J'i9 NASA Project Radiation Safety Officer W. Stoner ..-

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NASA PBRF DECOMMISSONING PROJECT CHANGE/CANCELLATION RECORD DOCUMENT TITLE: Final Status DOCUMENT NO: N/A REVISION NO: 0 Survey Report, Attachment 17, Buried and Miscellaneous Piping Revision 0: Initial issue of Report

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Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 LIST OF EFFECTIVE PAGES DOCUMENT NO: N/A REVISION NO: 0 Page No. Revision Level Page No. Revision Level Page No. Revision Level Cover Page 0 Routing & Approval 0 Sheet Change/Cancellation 0 Record LOEP 0 TOC 0 List of Tables 0 List of Acronyms &

Symbols, 2 pages Text, pages 1 through 0 22 Appendix A 0 8 pages Appendix B 0 41 pages

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Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 TABLE OF CONTENTS 1.0 Introduction .................................................................................................................... 1 2.0 Buried and Miscellaneous Piping Description ......................... 2 2.1 Buried and M iscellaneous Piping System s .............................................................. 2 3.0 History of Operations with Radioactive Materials ................................................. 2 3.1 W aste Handling Building ..................................................................................  :.......... 3 3.2 Fan House ............................................................................................................. 4 3.3 Hot Retention Area .................................................................................................. 4 3.4 Service Equipm ent Building .............................................................................. ........... 4 3.5 Reactor Offi ce and Laboratory Building .................................................................. 5 3.6 Hot Laboratory Building ........................................................................................... 5 3.7 Reactor Building ...................................................................................................... 5 3.8 Primary Pump House .......................................... 6 3.9 Drains and Sanitary Piping ...................................................................................... 6 4.0 BP/MP Remediation and FSS Design Approach ..................................................... 6 4.1 Rem ediation ........................................................................................................... 7 4.2 Final Status Survey M ethod ........................................................................................ 7 4.3 BP/M P DCG Ls & Radionuclide D istributions ......................................................... 8 4.4 Buried and M iscellaneous Piping Reporting Units .................................................. 9 5.0 Buried and Miscellaneous Piping Survey R esults .................................................. 10 5.1 D etector Efficiencies and MDCs ............................................................................ 10 5.2 Final Status Survey Results ................................................................................... 12 5.3 Quality Control ........................................................................................................  :..19 5.4 ALARA Evaluation ............................................................................................... 20 5.5 EPA Trigger Values ................................................................................................ 21 5.6 Conclusions ........................................................................................................... 21 6.0 References ..................................................................................................................... 22 7.0 A ppendices .................................................................................................................... 22 Appendix A - Exhibits ..................................................................................................... 22 Appendix B - Buried and Miscellaneous Piping Location Maps ................................ ........ 22 v

Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 LIST OF TABLES Table 1, DCGL Values for Buried and Miscellaneous Piping ....................... 8 Table 2, Radionuclide Activity Profiles ..................................................................................... 9 Table 3, Typical Detector Efficiencies and M DCs i .................................................................... 11 Table 4, Typical Detection Sensitivities of BP/MP Beta Detectors .............................................. 11 Table 5, Typical Detector Background Activity ........... 12 12.............................

Table 6, Buried and Miscellaneous Piping Survey Results ....................................................... 14 Table 7, BP/M P EM T Results .................................................................................................. 16 Table 8, Quality Control Replicate Measurements .................................................................. 19 Table 9, Screening Level Values for BP/MP and Radionuclide Activity Fractions ......... 21 LIST OF FIGURES Figure 1,PBRF Area Showing Reactor Building and Other Support Buildings ....................... 3 vi

Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 LIST OF ACRONYMS & SYMBOLS AF Area Factor ALARA As Low As Reasonably Achievable BP Buried Pipe BP/MP Buried and Miscellaneous Piping Co-60 Cobalt 60 CFR Code of Federal Regulations cm centimeters cpm counts per minute CPT Cold Pipe Tunnel CRB Cold Retention Basin CsI Cesium Iodide Cs-137 Cesium 137 CV Containment Vessel DCGL Derived Concentration Guideline Level DCGLw DCGL for average concentrations over a survey unit (Note: the "W" suffix denotes "Wilcoxon")

dpm disintegrations per minute EMA Elevated Measurement Area EMC. Elevated Measurement Comparison EMT Elevated Measurement Test EPA US Environmental Protection Agency Eu-154 Europium 154 FH Fan House FSS Final Status Survey FSSP Final Status Survey Plan FSSR Final Status Survey Report ft. feet g gram H-3 Tritium HEPA High Efficiency Particulate Air filter HL Hot Lab HRA Hot Retention Area 1-129 Iodine 129 in. inch kW 2 Kilo watt lb/in pounds per square inch m 2 square meters MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MW Mega watt MDC Minimum Detectable Concentration MDCR Minimum Detectable Count Rate MP Miscellaneous Pipe MUR Mock-Up Reactor N number of survey measurements vii

Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 LIST OF ACRONYMS & SYMBOLS (Continued) mrem millirem mrem/hr millirem per hour mrem/yr millirem per year NASA National Aeronautics and Space Administration N/A Not Applicable Nal Sodium Iodide NRC US Nuclear Regulatory Commission PBRF Plum Brook Reactor Facility PCW Primary Cooling Water percent PPH Primary Pump House Quad Quadrant Rm room RB Reactor Building ROLB Reactor Office and Laboratory Building SANS Sanitary Drain System SCW Secondary Cooling Water SEB Service Equipment Building Sr-90 Strontium 90 TBD Technical Basis Document WEMS Water Effluent Metering Station WHB Waste Handling Building viii

Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 1.0 Introduction This report presents the results of the final status radiological surveys of the Plum Brook Reactor Facility (PBRF) Buried and Miscellaneous Piping (BP/MP). It is Attachment 17 of the PBRF Final Status Survey Report (FSSR). 1 This attachment describes the BP/MP, its operational history, and final condition for the final status survey (FSS). It describes the methods used in decontaminating and surveying the BP/MP and presents the results.

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 will be less than 25 mrem/yr. Subpart E also requires that residual contamination be reduced to levels as low as reasonably achievable (ALARA). The Derived Concentration Guideline Levels (DCGLs) are established for residual surface contamination in the FSSP. Considering the radionuclide mixtures established for areas within the various structures and buildings, gross beta DCGLs range from 11,000 to 38,538 dpni/l00cm 2.

The survey measurement results and supporting information are presented to demonstrate that residual contamination levels in each buried or miscellaneous pipe survey unit of the PBRF are below the respective DCGLs. It is also shown that residual contamination has been reduced to levels that are consistent with the ALARA requirement. Therefore, the BP/MP total dose assessment of any given survey unit meets the criteria for unrestricted release as described in the FSSP.

Section 2.0 of this report provides a description and definition of BP/MP. Examples of BP/MP as situated in PBRF buildings are provided.

In Section 3.0, a description of the operational history with radioactive materials is presented for the various groups of BP/MP. Post shutdown decommissioning remediation and survey activities are described.

Section 4.0 presents the FSS design process for the BP/MP. This section includes applicable characterization efforts in support of FSS, DCGL (gross beta or surrogate) and nuclide distribution development. FSS Plan specifics concerning DCGLs are presented.

Survey results are presented in Section 5.0. The survey instrumentation and measurement sensitivities are presented. This section includes a summary of the survey measurements performed in the BP/MP, comparison to DCGLs, tests performed and an evaluation of residual contamination levels relative to the ALARA criterion, and a conclusion with regard to the FSS of BP/MP at PBRF.

Section 6.0 provides the references that were used to support the development of this Attachment.

Section 7 provides supporting information as contained in Appendices. Appendix A contains photos to supplement the text. Appendix B provides BP/MP piping location maps.

The PBRF Final Status Survey Report comprises the report main body and several attachments. This attachment presents survey results for buried and miscellaneous piping and their compliance with the release criterion as established in the PBRF FSSP. The entire final report will provide the basis for requesting termination ofNuclear Regulatory Commission (NRC) Licenses TR-3 and R-93 in accordance with 10CFR50.82 (b) (6).

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Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 2.0 Buried and Miscellaneous Piping Description Buried Piping (BP) is any pipe buried in soil and situated outside the structural foundation of a building, such as storm drains, footer drains, or sanitary lines. Miscellaneous Piping (MP) is any piping, conduit or similar system which does not meet the definition of Buried Piping or Embedded Piping as defined in the PBRF FSSP, but will remain in the structure. Examples of MP include various vents and drain lines, instrument tubing, conduits, and ventilation ducts. It also includes various penetrations in concrete walls and floors that once contained system pipes or valve operator shafts.

2.1 Buried and Miscellaneous Piping Systems The BP/MP is divided into survey units based on similar histories and characterization of residual contamination consistent with the structures associated with these survey units. The configuration of most small diameter BP/MP is such that they could not be readily surveyed with typical building surface measurement detectors. The accessible area of large diameter pipes can be surveyed with typical building surface measurement detectors.

The principal areas of similar nuclide distribution are:

  • Waste Handling Building (WHB) MP
  • Fan House (FH) MP
  • Hot Retention Area (HRA) MP
  • Service Equipment Building (SEB) MP
  • Reactor Office and Laboratory Building (ROLB) MP
  • Hot Laboratory (HL) MP
  • Reactor Building (RB) MP
  • Containment Vessel (CV) MP
  • Primary Pump House (PPH) MP
  • Water Effluent Metering Station (WEMS) Outfall Culverts BP
  • Pentolite Ditch Crossover Culverts BP
  • Sanitary Drain System (SANS) BP 3.0 History of Operations with Radioactive Materials All BP/MP was characterized to determine if they were impacted by operations. Pipes that were impacted were classified, remediated, and resurveyed for compliance with the release criteria and are included in this Attachment. Pipes that could not be, effectively remediated were removed and discarded as radioactive waste. A history of the use of radioactive materials in the various structures associated with BP/MP is provided below. BP/MP not impacted by plant operations (i.e., electrical conduits, gas lines, etc.) were abandoned in place. Figure 1 shows the relative locations of major PBRF structures.

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Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 Figure 1, PBRF Area Showing Reactor Building and Other Support Buildings 5E - 5ERVICE5 EQUIPMENT BUILDING 5 U FM - FAN H-OU5E WI-IB - WA5TE HANDUNG BUILDING PPH - PRJMARY PUMP HOU5E ROLB - REACTOR OFFICE 4 LABORATORY BUILDING HPRA - HOT RETENTION AREA 3.1 Waste Handling Building The Waste Handling Building (WHB), with a floor area of 6,750 ft. 2, was designed for handling and processing radioactive material. It was located immediately south of and directly connected to the FH. The building contained equipment for processing contaminated water, protective clothing, miscellaneous contaminated trash, or dry active waste (DAW) and equipment and experiment hardware. Waste processing activities included decontamination, waste shipment and recycling. The WHB included laundry facilities for decontaminating protective clothing. It contained operating areas for processing and packaging radioactive waste for offsite shipment. It also contained an evaporator facility for processing high-solids contaminated waste water and work areas for decontaminating reusable equipment and for packaging radioactive waste for storage and shipment. The WHB was designed for operation in close conjunction with the FH and HRA for processing PBRF radioactive wastes. Survey unit MP-I-1, WHB 0' drains is included in this Attachment.

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Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 3.2 Fan House The Fan House (FH) was a two level, 6,400 ft. 2 (floor area) structure located about 40 meters southeast of the RB and 10 meters east of the HL. The FH first floor elevation is at grade level, corresponding to the RB 0 ft. elevation.

Primary FH functions were collection and processing of exhaust air and contaminated water from the RB and other-PBRF buildings. The FH received air from the RB, the CV, reactor experiments, HL, ROLB basement, PPH, WHB, HRA and the Hot Pipe Tunnel (HPT). The incoming air was filtered, monitored, compressed and stored for decay as required, then exhausted through the monitored PBRF Stack located adjacent to the east side. of the FH.

All radioactively contaminated water from PBRF. was processed in the FH. This included the reactor primary coolant system, the HRA, Cold Retention Basins (CRBs), cooling water systems, the Quadrant and Canal systems, hot sumps and contaminated laundry. Processed waste water was either recycled or stored for decay, but was eventually disposed of as effluent waste water through the WEMS. Survey unit MP-2-1, Room 7 & 8 penetrations is included in this Attachment.

3.3 Hot Retention Area The Hot Retention Area (HRA) was designed to provide holding capacity for large volumes of radioactively contaminated water generated in PBRF operations. It functioned as a tank farm for storage, holdup and decay of water from the PBRF Hot Drain system. The tanks were housed in the HRA reinforced concrete vault-structure located south of the FH and adjacent to the west side of the WHB. It was 45 ft. wide (east-west) and 90 ft. long (north-south) with the vault floor 25 ft. below grade. The vault roof, or top surface was at grade level, corresponding to the RB 0 ft. elevation. The main HRA vault however, was covered with a four ft. thick earthen berm to provide shielding from gamma radiation emanating from contaminated water in the tanks. Survey units MP-3-1 and MP-3-2, HRA drains are included in this Attachment.

3.4 Service Equipment Building The Service Equipment Building (SEB), a three-story 25,000 ft.2 (floor area) structure, provided high-purity cooling water for the 60 MW Test Reactor and secondary cooling water for Reactor systems. It also provided service air and instrument air, emergency electric power, heating and process steam and other utilities to the PBRF complex. The SEB housed water processing equipment, air compressors, electrical control equipment, diesel generators for emergency electrical power, the health physics radiochemistry/analytical laboratory and a backup control console with capability" to safely shutdown the 60 MW Test Reactor. It also housed personnel offices, an environmental radiological counting laboratory and a chemical test laboratory for water treatment analysis. There were a number of ancillary facilities connected to the SEB. These included the main electrical substation, the water treatment precipitator, two utility air intakes, two diesel fuel oil tanks, a waste oil tank, and the Cold Pipe Tunnel (CPT). Survey unit MP-5.-1, CPT drains is included in this Attachment.

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Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 3.5 Reactor Office and Laboratory Building The Reactor Office and Laboratory Building (ROLB) was a three story, 27,000 ft.2 (floor area) structure located immediately west of the Reactor Building. It contained offices, a conference room, a classroom, a library, repair shops, health physics offices, a first aid facility, instrument calibration shop, new fuel vault, equipment calibration facility, and radiochemistry laboratories.

The east wall of the ROLB abutted the west wall of the RB. The buildings were structurally independent. The elevation of the ROLB first floor was at grade level, corresponding to RB 0 ft. elevation (631 ft. above mean sea level). Other major elevations were: basement, -15 ft.;

second floor, 12 ft. and roof, 24 ft., 3 in. The ROLB connected to the RB through doorways at the basement, first and second floor levels. Survey unit MP-6-1, ROLB Penetrations is included in this Attachment.

3.6 Hot Laboratory Building The Hot Laboratory (HL) was a 15,000 ft. 2 (floor area), three story building located adjacent to the south side of the RB. The HL was designed to handle and analyze highly radioactive materials. Chemical, radiochemical and metallurgical analyses of irradiated experiment specimens such as moon rocks, various nuclear fuel materials and nuclear rocket components were performed in the HL. Activities conducted in the HL also included -inspection, disassembly, and modification of reactor core components such as fuel elements, beryllium reflectors (sections and plates), the upper grid assembly and irradiated test materials. The HL contained extensive concrete shielding in walls, floors and ceilings, including high density concrete in the front and side walls of the seven hot cells. Through-wall mechanical manipulators, periscopes, microscopes and other remotely controlled analytical equipment were used to limit personnel exposure to radiation. Survey units MP-7-1 through MP-7-7, Hot Cell penetrations, MP-8-1, HL penetrations, and MP-9-1, Interim Storage lines are included in this Attachment.

3.7 Reactor Building The Reactor Building (RB) was a large, 41,000 ft.2 (floor area) four story structure which housed the Plum Brook 60 MW Test Reactor, the 100 kW Mockup Reactor (MUR) and associated experimental and test facilities.2 It was 162 ft. (E-W) by 149 ft. (N-S) at grade level There were two levels below grade (-15 ft. and -25 ft.), the main floor at grade level and a mezzanine floor at 12 ft. The RB was the center of a four-building complex which comprised the heart of the PBRF. It was connected to three major buildings; the HL, PPH and ROLB. The RB construction included the CV, a large cylindrical steel structure which contained the 60 MW Test Reactor. The CV was 100 ft. in diameter, 111 ft. in height at the center and extended from 56 ft. below grade to 55 ft. above grade. It surrounds the Reactor Tank (Pressure Vessel),

Bioshield and experiment-test areas. The MUR was located outside the CV in Canal H in the southeast comer of the RB. For the purposes of FSS, the CV and the RB are reported separately. Survey units MP-10-1 through MP-10-6, conduit and penetrations, and MP- 11-2, Lily Pad conduits and penetrations are included in this Attachment.

2 The combined floor area of the Reactor Building and CV was 41,324 ft 2 . The Reactor Building floor area exclusive of the CV was 30,200 ft 2 and the CV floor area was 11,100 WT.

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Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 3.8 Primary Pump House The Primary Pump House (PPH), a 4,200 ft.2 (floor area, including a mezzanine) building housed major components of the reactor primary cooling water system. These components included primary coolant pumps (three 8650 gpm pumps), two large heat exchangers, flow measuring and coolant monitoring equipment, a cleanup system and a fuel element test rig. The PPH shared a common wall with the RB east side and was of thick-walled concrete construction. The walls and roof were designed to provide shielding from gamma radiation originating in the primary coolant and contaminated process equipment. The south and east walls contained sections with removable concrete blocks to provide access for large equipment replacement (heat exchangers, pumps, etc). Survey units MP-12-3 through MP-12-11, PPH Drains and Vents are included in this Attachment.

3.9 Drains and Sanitary Piping Numerous piping systems were buried underground to convey liquids between buildings or to provide a drain path to collection points. Building footer drains collected rain water and ground water in sumps that pumped to the WEMS via various drainage pipes and catch basins. Low-level contaminated water was discharged to the WEMS where it was monitored for radioactivity, and then discharged to the Pentolite Ditch. Three 31" diameter pipes approximately 48 ft. long carried discharge water from the WEMS under Pentolite Road to the Pentolite Ditch (Appendix A, Exhibit 6). Two 31 in. corrugated pipes approximately 74 ft. long carried water in Pentolite Ditch under a section of the ditch that was filled in to allow vehicle access across the ditch. A majority of the storm drainage system has been removed.

During reactor operations, sewage from restroom facilities gravity fed to sewage sumps located in the major buildings. Sewage sumps were located in the Reactor ROLB, the RB, the SEB, the HL, the FH and the WHB. The restroom facility in the Reactor Security and Control Building (RSCB) gravity fed directly to the south sewer lateral (SANS-3). The ROLB, RB and the SEB sumps discharged into the north sewer lateral (SANS-8), located on the north side of those respective buildings. The HL, FH and WHB sumps discharged into the south lateral (SANS-3),

located on the south side of the HL and RSCB. Both of these lines tied into an 8 in. sanitary line (SANS-9) located along the west side of Line 2 Road. Sewage gravity flowed south to the south side of Pentolite Road then west to the Pentolite Road lift station. The sewage was then pumped to a 15 in. line along the north side of Maintenance Road. From there, it flowed via gravity to Taylor Road and then continued northeast in a 15 in. line on the west side of Taylor Road to the Taylor Road sewage treatment plant. The Taylor Road sewage treatment plant was removed in 2004 and the sewer system was connected to the municipal waste system. Survey units BP-l-I through BP-2-3, Storm Drains and Sewer Lines are included in this Attachment.

4.0 BPIMP Remediation and FSS Design Approach The initial efforts to reduce the radioactive materials associated with BP/MP involved the removal and disposal of system components, conduits and piping throughout the PBRF buildings. The end result was a facility where the impacted systems which remain are limited to system piping and conduits encased within walls and floors, located under the building slabs, or subsurface runs of buried piping between buildings. The remaining accesses to these conduits and piping are cut flush, or as near to flush as practicable, with the walls and floors throughout the facility buildings.

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Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 Prior to initial radiological survey activities, the piping is inspected using remote camera systems to assure the physical condition of the piping is acceptable for moving radiological detectors through the piping. Before performing any radiological survey activities using in-situ survey equipment, the piping to be surveyed is verified to be free of loose surface contamination using full piping length swabs by Radiation Protection personnel. This minimizes the potential of loose surface contamination being transported through the piping by the in-situ survey equipment, contaminating the in-situ survey equipment and biasing the piping survey results (Appendix A, Exhibits 1 & 2).

4.1 Remediation Remediation was performed on the accessible interior surfaces of all radiologically contaminated BP/MP. This involves the use of vacuuming, mechanical cleaning, grit blasting, and high-pressure water. Remediation activities commence with the simplest processes and graduate to more aggressive remediation processes based on representative survey results. This graduated approach minimizes radioactive waste generation and handling, and allows use of those remediation efforts with the lowest safety hazards to be utilized first.

The simplest remediation technique is vacuuming to remove debris deposits from the piping.

This method does not appreciably remove corrosion or scale deposits and is rarely the only remediation process required.

Corrosion and scale removal requires mechanical agitation of interior piping surfaces. These methods employ rotating snakes and abrasive or pulverizing heads to mechanically separate radioactivity bearing scale and corrosion deposits from the interior piping. These mechanical processes utilize a vacuum head in close proximity to the piping surfaces being remediated to remove scale and corrosion fragments as they are generated.

When mechanical agitation is insufficient to achieve the remediation goal, aggressive remediation such as grit blasting and/or hydro-lasing may be used. These techniques are used to remove tightly adhered corrosion layers from the piping.

4.2 Final Status Survey Method Piping interior surfaces are typically surveyed using detectors mounted in engineered sleds.

Detector sleds perform two purposes. The primary purpose is to maintain the in-situ geometry consistent with the efficiency determination during field measurements, and the secondary purpose is to facilitate ease of movement through piping and protect the detector from physical damage. The detector is manipulated by technicians through the piping to perform the survey.

(Appendix A, Exhibit 3). Sleds are not feasible for some smaller diameter piping and detectors used without a sled are manipulated cautiously to minimize any chance of damage to the detector during field surveys.

Detectors typically used to perform piping surveys are Nal or CsI gamma scintillating detectors of sizes appropriate to the piping size and the physical challenges of the piping runs. These detectors are optimized (windowed) to measure the gamma energies specific to either Co-60 or Cs-137. A static radiological survey measurement is taken for every foot of pipe traveled. The accessible interior surfaces of large diameter pipes were surveyed using plastic scintillation beta detectors or Geiger-Muller (GM) type frisker probes.

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Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 2

Field measurements in cpm are converted to equivalent beta measurements in dpm/100cm through application of surrogate calculations and piping correction factors. These calculated activity densities are assessed against the applicable DCGL from the FSSP for compliance with the 25 mrem/yr release criterion. When the post-remediation surveys demonstrate the BP/MP remediation goal has been achieved, the surveyed piping is placed in isolation and control and the survey results are documented in the survey unit release record.

4.3 BP/MP DCGLs & Raclionuclide Distributions The PBRF contains numerous pipe runs buried below the surface of site soils or encased in concrete within the site buildings. Examples include piping sleeves in the CV Quadrants and Canals, conduits and tubing in the HL, sanitary drain lines, and drain piping under the PPH floor slab. The BP/MP DCGL values are listed in Table 1. The DCGLs for BP/MP are the same as the structural values [NASA 2007].

Table 1, DCGL Values for Buried and Miscellaneous Piping DCGL Radionuclide (dpm/100cm2 )

Co-60 11,000 Sr-90 33,100 Cs-137 40,500 Eu-154 4,500 H-3 9.1E+06 1-129 14,900 Radionuclide distributions and activity ratios for the various building surfaces were developed in TBD-07-001 [PBRF 2007] and modified as described in TBD-1 1-002 [PBRF 2011]. In some instances, the mixture of radionuclides was found to be unrepresented by the associated building surface mixtures. For these pipes, the piping group activity ratios developed in TBD-06-004 [PBRF 2006] were used. The Cs-137 to Co-60 activity ratio is an important parameter of consideration for evaluation of survey measurements in PBRF BP/MP. When piping surveys are conducted using surface activity measurements, this ratio "controls" the energy window selected for measurement acquisition. This is because one or both of these radionuclides are found in all BP/MP. The Co-60 yields the most restrictive individual nuclide DCGL and the Cs-137 DCGL is the least restrictive DCGL of the gamma emitters that are consistently observed in BP/MP. A summary table of the radionuclide distributions utilized to surrogate field measurements and develop activity profiles for the BP/MP is shown below in Table 2.

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Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 Table 2, Radionuclide Activity Profiles DCGLw (1) Activity Fractions Bldg / Location (dpm/100cm2 ) H-3 Co-60 Sr-90 1-129 Cs-137 Eu-154 RB Area 2 & Lily Pad 11,544 0.9757 0.021 0.0013 0 0.002 0 RB Quad A 13,450 0 0.7499 0 0 0.2501 0 RB Quads B, C, & D 21,470 0 0.3305 0 0 0.6695 0 RB Canals E, F, G & H 30,734 0.012 0.117 0 0 0.871 0 RB-25 ft. el. 14,382 0.075 0.555 0.229 0 0.124 0.018 Hot Lab All Other Areas 38,538 0.000 0.006 0.158 0 0.836 0.000 Hot Lab Hot Cells 34,583 0.105 0.026 0.330 0.0003 0.538 0.001 FH Rooms 7 & 8 10,560 0 1.0 0 0 0 0 WHB SANS 40,500 0.0003 0.043 0.088 0 0.868 0 HRA Drains 11,000 0 1.0 0 0 0 0 CPT Drains 16,240 0 .557 0 0 .443 0 ROLB SANS 23,146 0.265 0.178 0.078 0.013 0.465 0.0013 PPH Rooms 1-3,5-8 23,914 0.595 0.095 0.103 0.000 0.207 0 PPH Vent, Fill, & Drain Lines 11,000 0 1.0 0 0 0 0 WEMS All Areas 33,67.3 0 0.0756 0 0 0.9244 0 Sanitary Lines 28,748 0.0004 0.463 0.0034 0 0.489 0.0034 Table 2 Notes:

1. Gross beta DCGL calculated as described in Section 4.4.

4.4 Buried and Miscellaneous Piping Reporting Units BP/MP surveys were performed in accordance with the Babcock Services Incorporated (BSI)/LVS-002, Work Execution Package (WEP)05-006 [PBRF 2005] or a PBRF generated Survey Request. The survey instructions described in these documents constitute "Special Methods" as defined in the FSSP for the survey design used in the acquisition of survey measurements. Survey units were developed based on grouping pipes according to function (e.g., conduit, drains, etc.) and associated building area. The data was evaluated using the surface beta DCGLs and activity ratios given in Table 2. The appropriate radionuclide surrogate (Cs-137 or Co-60) was calculated using the following equation:

1 Surrogate. =

[I J+( R 2 )+ -). ,]

RDCGL,4 'ýDCGLJ \DCGL) IDCGI.,J Where: DCGLsuT = Surrogate radionuclide DCGL DCGL2, 3.. .n = DCGL for radionuclides to be represented by the surrogate Rn = Ratio of concentration (or nuclide mixture fraction) of radionuclide "n" to surrogate radionuclide 9

Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 The results of the BP/MP radiological surveys are assessed for compliance with the 25 mrem/yr release criterion in units of unity where 1.0 is 25 mrem/year in accordance with the FSSP. The unity calculation is as follows:

C___ C2 C,,

C) + + <1 DCGLI DCGL2 DCGL.

Where: C1 .*= concentration of radionuclide 1- n and DCGLI., = DCGL of radionuclide 1-n.

5.0 Buried and Miscellaneous Piping Survey Results Post remediation surveys are performed to establish the final status of BP/MP systems after all cleaning and remediation is complete. In small diameter pipe, a one-minute static measurement is obtained inside the pipe at 1 foot increments along its entire length. In large diameter pipe, direct beta measurements are taken where accessible. If any individual measurement exceeds the unity value (>1.0), an area factor (AF) is calculated based on the actual size of the elevated measurement area (EMA) and an elevated measurement comparison (EMC) is performed as described in the FSSP, Section 8.3. The DCGLEmc is calculated as the product of the Area Factor (AF) and the DCGLw. If any EMA is greater than the DCGLEmc, additional remediation is performed. If the EMA is less than the DCGLEmc, an elevated measurement test (EMT) is performed using the following equation:

__ +(averageconcentration in elevated area)- 8 < 1.0 DCGLw (AF) (DCGLw)

Where: 5 is the average residual activity concentration in the survey unit.

If more than one EMA is found in a survey unit, the second term in the EMT equation is calculated for each and summed with the first term to perform the unity rule calculation for the EMT. Results of the DCGLEmc and EMT calculations are presented in Table 7.

5.1 Detector Efficiencies and MDCs The detectors utilized for a majority of BP/MP surveys were gamma scintillating detectors constructed of NaI or CsI crystals with photo-multiplier tubes in a single housing purchased from various vendors. These detectors were optimized during calibration to measure gamma energies representative of Co-60 or Cs-137 gamma energies with the use of discriminator settings (windowing). The accessible interior surfaces of large diameter pipes were surveyed using plastic scintillation beta detectors or GM type frisker probes.

For gamma detectors, the calibrated detectors are assigned specific efficiencies for each unique combination of detector, sled, and nuclide of concern, co-axial cable length and pipe diameter.

An example of how these unique efficiencies are determined for a 4 in. pipe with a predominately Cs-137 nuclide mixture follows:

10

Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0

  • A sled suitable for the physical layout of the 4 inch pipe(s) to be surveyed is selected to be used with detector.
  • A 4 ft. section of 4 in. clean piping (mockup) is loaded with a large, flexible, conformal single nuclide source which has a vendor certified (NIST traceable), homogenous activity deposition of Cs- 137 activity across its surface area. The source is loaded inside the 4 in. clean pipe section, in continuous contact with the pipe's inside diameter.

0 The detector is fitted into the sled and inserted into the 4 inch pipe containing the conformal Cs-137 source. The detector is centered on the middle of the Cs-137 source (Photographs of a detector-sled-pipe and cable setup are located in Appendix A, Exhibit 4 of this attachment).

" A series of counts are collected and a unique efficiency is calculated for the detector-sled-pipe combination.

After the efficiency determination is completed, it is used to calculate MDCs and MDCRs for that detector-pipe combination. All calibrations, efficiencies and MDC/MDCR calculations are entered into the detector history files and referenced for converting field measurements in counts per minute to activity measurements in disintegrations per minute per 100 centimeters squared. Detector sensitivity is verified to be acceptable for use in accordance with the FSSP, Section 6.5. Table 3 lists typical efficiencies and MDCs for several common pipe sizes utilized during surveys of the BP/MP presented in this Attachment.

Table 3, Typical Detector Efficiencies and MDCsttk Pipe Diameter Co-60 MDC Co-60 Cs-137 MDC Cs-137 2

(Inches) (dpm/l00cm2) Efficiencies (dpm/lOOcm ) Efficiencies 1.0 6,687 0.0006 12,247 0.00048 2.0 5,234 0.00024 10,190 0.00026 4.0 4,973 0.00032 4,280 0.00043 6.0 3,406 0.00018 1,206 0.00051 For beta measurement detectors, the detection sensitivities must be sufficient to meet the required action levels for the MARSSIM class of each survey unit. The minimum detection sensitivities for scan and static beta measurements were developed in Survey Request (SR) 361 and are shown in Table 4 below.

Table 4, Typical Detection Sensitivities of BP/MP Beta Detectors Detector MDC. Net cpm MDC,.,k Detector Model Efficiency (dpm/100cm 2) Equivalent to (dpm/100cm2)

(c/d) DCGLw LMI 44-116 0.280 3,176 2000 723 LM144-9 0.146 3,140 200 3,808 Table 4 Notes:

1. Static count time of 1 minute
2.44-116 background count rate of 200 cpm
3. 44-9 background count rate of 125 11

Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 5.2 Final Status Survey Results The BP/MP remediation and survey campaign began in 2005 and continued through the decommissioning effort at PBRF. As a result of this remediation and survey campaign, 35 survey units of BP/MP were remediated and surveyed. Table 6 provides a summary of the BP/MP survey results. Each survey unit is identified with a Survey Unit ID, a short description of the survey unit, the survey unit's size, MARSSIM Class, and the number of survey measurements acquired in the survey unit. For each survey unit, the appropriate DCGL, maximum activity, EMC Test result, mean activity and standard deviation of the survey measurements for that survey unit is listed and an affirmation that the average activity in each survey unit is less than the DCGLw. The last column references the appropriate Appendix B Map number for the survey unit.

The PBRF FSSP [NASA 2007] requires BP to be assessed for compliance using the building structure DCGL. This is a very conservative approach since the assumptions for this model are greatly exaggerated when applied to any BP/MP survey unit. All of the dose pathways in this model assume an individual is present in the survey unit. Since it is not physically possible for a dose receptor to occupy a BP/MP survey unit, the calculated activity is extremely overestimated and only serves as an upper bound to indicate that the survey unit meets the release criteria. Most BP/MP survey units are also very small when compared to the modeled building surface area. Area factors (AF), when used, are underestimated in most cases since the average size of the elevated areas (0.13m 2) is much smaller than the area used in the FSSP (0.25m2) to calculate the largest AF (40.2). Eighty seven percent of the elevated areas identified during surveying are less than 0.25m2.

A static measurement is obtained for each foot of BP/MP for all survey units, except the sanitary (SANS) system. The number of measurements (N) far exceeds the sample density of a typical building surface survey unit. In addition, background activity is not subtracted from BP/MP surface activity measurements since no background study was performed for the numerous pipe size geometries and configurations. However, most of the survey measurements fall within typical background ranges for the various detector and pipe geometry combinations observed during detector efficiency determinations, or would be significantly reduced if typical background values were applied. Table 5 shows the range and average typical gamma background count rates obtained inside the various pipe mockups and associated average gamma background activity.

Table 5, Typical Detector Background Activity Average Activity 2

Radionucide Range (cpm) Average (cpm) (dpAe100ct )i Co-60 2-6 4.1 5,840 Cs-137 9-13 10.7 7,345 3The sanitary (SANS) system was an active system at the time of the survey. The flow of water was temporarily halted using an inflatable bladder. The first two feet of pipe in each direction at each manhole was the only accessible portion of the system.

12

Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 The average background count rate for beta survey measurements 2 4 was 196.4 cpm. This is equivalent to a background beta activity of 1,708 dpm/IOOcm .

The cumulative effect of the multiple layers of conservative measures applied in the survey design and data assessment of the BP/MP results in a significant overestimate of the survey results presented in Tables 6 and 7.

4 This value was calculated using detector data from the FSS/Characterization Survey Form, CHS-3681, October 26, 2011.

E, 0.34, Ei = 0.338, Et = 0.115 13

Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 Table 6, Buried and Miscellaneous Piping Survey Results Survey Test Mean Appendix B Suniy CNo. of DCGLw Maximum Result: Mean Standard Activity Map Unit Description Cla2) Measurements o)(2) Activity ) Maximum Activity Deviation Number UniDscr n(i) <DCGLw () <DCGLw Nub BP-1-1 Sanitary System Drain 2.24 1 23 28,748 24,148 Yes 14,086 4,312 Yes 36 SANS-11I BP-2-1 Pentolite Ditch 109.3 1 145 33,673 16,837 Yes 12,459 1,684 Yes 37 Crossover __________________

BP-2-2 WEMS Outfhll 110.0 1 146 33,673 11,112 Yes 7,071 1,347 Yes 38 BP-2-3 Sanitary System Drain 3.16 3 40 28,748 2,452 Yes 1,328 780 Yes 39 SANS-9 MP-1-I WHB SANS 4.3 1 44 40,500 21,384 Yes 12,555 4,172 Yes I MP-2-1 Fa House Rooms 7 & 7.6 1 52 10,560 9,050 Yes 2,323 1,341 Yes 2 8 Penetrations ____ ___________________

MP-3-1 HRA 0' Floor Drains 9.82 1 101 11,000 27,280 No (3) 5,555 3,465 Yes 3 MP-3-2 HRA Vault Perimeter 21.1 1 225 11,000 3,707 Yes 2,574 473 Yes 4 Drains ____________________

MP-5-! CPT Floor Drains 2.043 1 21 16,240 11,043 Yes 7,795 1,949 Yes 5 MP-6-1 ROLB SANS 0.85 1 10 23,146 27,312 No (3) 15,739 7,175 Yes 6 Penetrations MP-7-1 Hot Cell #1 34.9 1 683 34,583 157,698 No (3) 17,292 14,179 Yes 7 MP-7-2 Hot Cell #2 32.8 1 733 34,583 206,461 No () 13,487 10,720 Yes 8 MP-7-3 Hot Cell #3 25.8 1 669 34,583 995,990 No (3) 15,217 13,142 Yes 9 MP-7-4 Hot Cell #4 34.8 1 881 34,583 116,545 No (3) 11,758 6,225 Yes 10 3

MP-7-5 Hot Cell #5 38.6 1 960 34,583 41,500 No ) 11,412 5,187 Yes II MP-7-6 Hot Cell #6 35.1 1 905 34,583 217,527 No (3) 12,796 9,337 Yes 12 MP-7-7 Hot Cell #7 38.2 1 1103 34,583 112,049 No (3) 12,450 8,646 Yes 13 MP-8-1 Hot Laboratory 14.45 1 233 38,538 25,435 Yes 5,781 3,468 Yes 14 MP-9-! Interim Storage Lines 15.13 1 .311 38,538 146,830 No (3) 33,143 8,864 Yes 15 MP-10-1 RB -25' 2" Conduits 0.36 1 8 14,382 8,960 Yes 1,470 326 Yes 16 14

Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 Table 6, Buried and Miscellaneous Piping Survey Results Survey Test Mean Appendix B Survey Survey Unit No. of DCGLw Maximum Result: Mean Standard Activit Map Unit Description Unit 2size Class Measurements (1)(2) Activity (1) Maximum Activity Deviation AcGvw Number MP-10-2 RB -25' 1.5" Conduits 2.995 1 81 14,382 15,676 No(3) 7,191 2,876 Yes 17 MP-10-3 Quad A Penetrations 5.17 1 52 13,450 27,438 No (3) 10,626 6,053 Yes 18 MP-10-4 Quad.D Penetrations 64.2 1 77 21,470 28,985 No (3) 12,882 5,797 Yes 19 MP-10-5 Quads B&C 7.21 1 75 21,470 31,132 No () 12,453 6,656 Yes 20-21 Penetrations MP-10-6 Canal E Penetrations 1.167 1 8 30,734 3,073 Yes 2,151 615 Yes 22 MP- 11-2 Lily Pad Valve 16.6 143 11,544 4,271 Yes 1,270 924 Yes 23 Operator Sleeves MP-12-3 PPH Rooms 1-3,5-8 29.4 1 569 23,914 71,742 No ) 16,022 7,892 Yes 24- 30 MP- 12-4 PPH Room 4 2.1 1 11 11,000 21,340 No (3) 9,119 5,340 Yes 31 Emergency Fill Line MP-12-5 PPH Room 4 Water 4.7 1 24 11,000 12,089 No (3) 5,962 1,661 Yes 31 Fill Line MP-12-6 PPH Room 4 Exhaust 33.9 1 174 11,000 12,331 No (3) 5,676 2,585 Yes 32 PPH Room 5 Off-Gas MP-12-7 Line 1.6 1 33 11,000 7,403 Yes 4,015 1,331 Yes 33 MP-12-8 PPH Room Vents 21.95 1 171 11,000 8,701 Yes 5,060 1,463 Yes 34 MP-12-9 PPH Rooms 1,2,3,4,8 24.6 1 209 11,000 15,807 No (3) 5,522 2,299 Yes 34 Drains MP-12-10 PPHRooms5&6 1.27 1 13 11,000 8,701 Yes 4,301 1,727 Yes 34 Drains _________________

MP-12-11 PPH Room 5 Degas 0.21 1 2 11,000 6,864 Yes 6,006 1,210 Yes 35 Sump Line Table 6 Notes:

1. Activity is dpmn/100cm 2 .
2. Gross beta DCGL calculated as described in Section 4.4.
3. EMT performed. Refer to Table 7.

15

Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 Table 7, BP/MP EMT Results Measured Size of Average Activity EMT Survey EMA Activity Elevated Area (d Cm 2 ) in Survey Unit Unity Unit ID Umt(Unity Value) Area (m2 Factor (dpm/100em) (Unity Value) Value (UnUnityValue))Aeaa(in 37 1.002 .0973 40.2 MP-3-1 50 1.876 .0973 40.2 11,000 0.505 0.571 100/101 1.76 .1946 40.2 MP-6-1 EMA1 1.15 0.12 40.2 23,146 0.68 0.57 EMA2 1.60 0.274 36.85 EMA3 1.29 0.12 40.2 EMA4 2.08 0.304 33.38 EMA5 1.93 0.304 33.38 MP-7-1 EA1.8(12 EMA6 1.28 0.152 402 40.2 34,583 '0.50 0.709 EMA7 1.95 0.195 40.2 EMA8 1.10 0.195 40.2 EMA9 3.18 0.146 40.2 EMAI 1.52 0.07 40.2 EMA2 4.04 0.07 40.2 EMA3 2.58 0.11 40.2 MP-7-2 34,583 0.39 0.597 EMA4 1.02 0.024 40.2 EMA5 1.05 0.024 40.2 EMA6 1.15 0.036 40.2 EMA1 1.02 0.036 40.2 EMA2 1.01 0.036 40.2 EMA4 2.42 0.146 40.2 MP-7-3 EMA5 1.96 0.292 34.68 34,583 0.44 0.564 EMA6 1.61 0.365 28.05 EMA7 1.03 0.073 40.2 EMA8 1.20 0.049 40.2 EMAI 1.24 0.024 40.2 MP-7-14 EMA2 3.37 0.049 40.2 34,583 0.34 0.472 EMA3 2.07 0.097 40.2 EMA1 1.02 0.049 40.2 EMA2 1.20 0.097 40.2 MP-7-5 EMA3 1.07 0.036 40.2 34,583 0.33 0.418 EMA4 1.03 0.018 40.2 EMA5 1.20 0.018 40.2 16

Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 Table 7, BP/MP EMT Results (Continued)

Survey EMA Measured Size of Area DCGLW ( Average Activity EMT Activity Elevated2 F in Survey Unit Unity (Unity Value) Area (m ) Factor (dp2/100cm) (Unity Value) Value EMA1 1.06 0.018 40.2 EMA2 1.06 0.018 40.2 EMA3 1.07 (0.049 40.2 MP-7-6 E EMA4 1.09 (1.024 40.2 34,583 0.37 0.545 EMA5 1.15 0.024 40.2 EMA6 4.49 0.097 40.2 EMA1 1.17 0.097 40.2 EMA2 1.05 0.019 40.2 EMA3 2.22 0.036 40.2 EMA4 1.15 0.15 40.2 EMA5 1.05 0.12 40.2 EMA6 1.06 0.037 40.2 EMA7 1.05 0.12 40.2 MP-7-7 34,583 0.36 0.669 EMA8 1.02 0.024 40.2 EMA9 0.97 0.097 40.2 EMAI0 1.38 0.049 40.2 EMAI1 1.06 0.12 40.2 EMA12 1.06 0.15' 40.2 EMA13 1.02 0.024 40.2 EMA14 3.24 0.049 40.2 EMA1 1.23 0.924 11.97 EMA2 1.06 0.632 16.87 MP-9-1I EA .0 .4 00 38,538 0.86 0.884 EMA3 1.10 0.341 30.01l EMA4 1.11 0.486 21.20 MP-10-2 EMA1 1.09 0.04 40.2 14,382 0.50 0.505 EMA1 1.49 0.073 40.2 EMA2 1.95 0.073 40.2 EMA3 1.80 0.12 40.2 EMA4 1.43 0.097 40.2 MP-10-3 EMA 1.48 0.097 40.2 13,450 0.79 0.774 EMA6 1.26 0.584 18.07 EMA7 1.30 0.061 40.2 EMA8 1.13 0.438 23.6 17

Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 Table 7, BP/MP EMT Results (Continued),

EMA Measured Size of Area DCGLw o) Average Activity EMT Survey ID Activity Elevated2 Factor (dp2/100m) in Survey Unit Unity Unit (Unity Value) Area (m ) Fo,,cm) (Unity Value) Value EMAl 1.35 0.015 40.2 EMA2 1.35 0.015 40.2 MP-10-4 21,470 0.60 0.634 EMA3 1.26 0.015 40.2 EMA4 1.26 0.015 40.2 EMAI 1.30 0.048 40.2 EMA2 1.23 01.048 40.2 EMA3 1.03 0.024 40.2 MP-10-5 . 21,470 0.58 0.622 EMA4 1.45 0.015 40.2 EMA5 1.16 0.015 40.2 EMA6 1.06 (.015 40.2 EMAI 1.61 0.19 40.2 EMA2 1.10 0.049 40.2 EMA3 2.40 0.19 40.2 EMA4 1.10 0.049 40.2 EMA5 1.61 0.19 40.2 EMA6 1.79 0.13 40.2 EMA7 1.03 0.12 40.2 EMA8 1.03 0.049 40.2 EMA9 1.20 0.12 40.2 EMAIO 1.17 0.44 23.59 EMAI1 1.05 0.15 40.2 MP-12-3 EMA 12 1.17 0.049 40.2 23,914 0.67 0.98 EMA13 1.14 0.073 40.2 EMA14 1.26 0.15 40.2 EMA15 1.10 0.049 40.2 EMA16 1.03 0.15 40.2 EMA17 1.03 0.049 40.2 EMA18 1.45 0.097 40.2 EMA19 1.20 0.030 40.2 EMA20 1.43 0.097 40.2 EMA21 1.30 0.19 40.2 EMA22 1.03 0.15 40.2 EMA-1 MP-12-41100080.2 1.94 0.19 20.8 EMA-2 1.634 0.19 20.8 MP-12-5 EMA-1 1.1 0.19 40.2 11,000 0.54 0.575 18

Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 Table 7, BP/MP EMT Results (Continued)

Survey EMA Measured Size of Area DCGLw ( Average Activity EMT Unit ID Acvity Va E) revate Factor (dpm/100cm) in Survey Unit Unity (Unity Value) Area (in) (Unity Value) Value EMA-I 1.03 0.19 40.2 EMA-2 1.03 0.19 40.2 MP-12-6 EMA-3 1.12 0.19 40.2 11,000 0.52 0.559 EMA-4 1.06 0.19 40.2 EMA-1 1.39 0.097 40.2 MP-12-9 EMA-2 1.44 0.097 40.2 11,000 0.50 0.55 EMA-3 1.2 0.19 40.2 Table 7 Notes:

1. Gross beta DCGL calculated as described in Section 4.4.

5.3 Quality Control Replicate field measurements were not consistently performed by the BP/MP contractor as required by the FSSP, Section 12.7.1. However, replicate scans and static measurements were performed on the survey units shown in Table 8 below. A total of 45 replicate measurements were taken of 518 static measurements in 8 of the 35 BP/MP survey units. At least 5% of each of the survey units was rescanned. The results of these QC measurements met the acceptance criteria given in the FSSP, Section 12.7.1.

Table 8, Quality Control Replicate Measurements Survey Request Number of Replicate Total Number of Measurements Survey Unit Number Measurements Represented by Replicate BP-1-1 SR-292 2 23 BP-2-1 SR-181/182 15 145 BP-2-2 SR-190 9 146 BP-2-3 SR-361 2 40 MP-8-1 SR-149/150 2 20 MP-10-1 SR-333 2 8 MP-10-2 SR-334 9 81 MP-11-2 SR-341 4 55 The quality of BP/MP radiological survey measurements was assured by the application of quality control protocols delineated in the implementing procedures and review criteria for BP/MP field activities, detector quality control documents, and survey assessment. All activities are directed by PBRF approved procedures.

All instrument and detector calibrations are performed by a qualified off-site vendor(s) using NIST traceable standards. After calibration and prior to use, background and source quality control charts are developed for each detector with an acceptable range of h20% for the 19

Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 established source and background count rates. A.performance check is done prior to and after any efficiency determination or field survey measurements. If a detector fails the pre-use source check it is removed from service. If a detector fails a post use source check, the cause is investigated and the data is reviewed for acceptability. If the cause of the failure cannot be determined, the survey is re-performed.

Efficiency determinations are performed using NIST traceable sources. Drawings accompany all efficiency determinations which depict the in-situ geometry, detectors, radioactive sources and other specifics allowing accurate reproduction of efficiency determinations at future dates.

5.4 ALARA Evaluation It is shown that residual contamination in the BP/MP 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, those 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 is presumed that it had been reduced to levels that are ALARA. Therefore, the licensee does not need to conduct an explicit analysis to meet the ALARA requirement." 5 Screening level values published by the NRC for the mix of radionuclides in structural surface residual contamination potentially present in the BP/MP are shown in Table 9. Since individual radionuclide activity concentrations are not measured in the FSS of BP/MP, 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 beta activity DCGL. Since the BP/MP nuclide mixture varies with its associated structure, area weighted average nuclide fractions were calculated to develop a screening level value that is equivalent to a gross activity DCGL using the equations in Section 3.6 of the FSS Plan.6 The activity fractions listed in Table 9 were used in the calculation. The screening level equivalent DCGL for the BP/MP is calculated to be 13,497 dpm/100cm2 .

The best estimate of average residual total surface beta activity in the BP/MP is the mean of the 8,914 measurements. This is 9,225 +/-6,379 dpm/10Ocm2 (one standard deviation). The upper limit of the confidence interval about the mean at the 95% probability level is 9,358 dpm/100 cm 2.7 This value is well below the screening level gross beta activity DCGL of 13,497 dpm/ 100 cm2.2 5 This guidance was initially published in Draft Regulatory Guide DG-4006, but has been reissued in NUREG-1757 Volume 2, Appendix N [USNRC 2006].

6 The equivalent screening level gross activity DCGL is calculated using the equations in section 3.6 of the FSS Plan

[NASA 2007].

The upper limit of the confidence interval, 95% probability level value, is calculated as: UL = mean + 1.96 a/hln, where n

= 8,914 systematic measurements.

20

Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 Table 9, Screening Level Values for BP/MP and Radionuclide Activity Fractions Radionuclide Screening Level Value (dpm/lO0cm 2 ) Activity Fraction (%) (1)

H-3 1.2 E+08 (2) 0.0784 Co-60 7. 1E+03 (2) 0.249 Sr-90 8.7E+03 (2) 0.116 1-129 3.5E+04 (2) 0.0001 Cs-137 2.8E+04 (2) 0.556 Eu-154 1.2E+04 (3) 0.0004 Table 9 Notes:

1. Activity fractions are calculated as the area weighted average of all survey units.
2. Values from NUREG-1757 Vol. 2, Table H.A [USNRC 2006].
3. Values from NUREG/CR-5512, Vol. 3, Table 5.19 [SNL 1999]. These are 9 0 tb percentile values of residual surface activity corresponding to 25 mrem/yr to a future building occupant.

5.5 EPA Trigger Values 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). Concentrations of individual radionuclides, identified as "trigger levels" for further review and consultation between the agencies, are published in the MOU [USEPA 2002].

However, no soil survey units are included in the survey of the BP/MP. It is also noted that groundwater is not within the scope of the BP/MP survey effort. Therefore, comparison with EPA Trigger Levels is not applicable to BP/MP survey measurement results.8 5.6 Conclusions The results presented above demonstrate that the BPiMP satisfies all FSS Plan commitments and meets the release criteria in I10CFR20 Subpart E. The principal conclusions are:

" Static radiation measurements were performed at 1 foot intervals on 100% of all remaining BP/MP Class 1 survey units. Direct surface measurements were made on accessible portions of active sanitary system (SANS) pipes.

" All survey unit mean fixed measurement results are below the DCGLw.

  • Investigations were performed following observation of elevated activity in 19 survey units. As a result of these investigations, elevated measurement comparisons and elevated measurement tests were performed and all were satisfactory.

8 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 Environmenfal 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. Since these trigger levels are only applicable to the PBRF for residual soil and water concentrations, they do not apply to the Buried and Miscellaneous Piping results provided in this attachment.

21

Plum Brook Reactor Facility FSSR Attachment 17, Rev. 0 The classification of Miscellaneous Pipe (MP) is not defined in the FSS Plan. MP was surveyed using the same criteria as BP.

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

A significant portion of MP was removed from the associated structures during the decontamination phase of the project. At the time of development of this report attachment, building demolition was in progress. The MP remaining in the above grade structures is being segregated and surveyed for free release or disposal as radioactive waste (See Appendix A, Exhibit 5).

6.0 References NASA 2007 NASA Safety and Mission Assurance Directorate, FinalStatus Survey Planfor the Plum Brook Reactor Facility,Revision 1, February 2007.

PBRF 2005 Plum Brook Reactor Facility Work Execution Package, Decontamination&

RadiologicalSurvey of Embedded andBuried Piping Systems, PBRF-WEP-05-006, November 2005.

PBRF 2006 Plum Brook Reactor Facility Technical Basis Document, Activity Ratios of Radionuclides in Embedded andBuried Piping,PBRF-TBD-06-004, October 2006.

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

PBRF 2011 Plum Brook Reactor Facility Technical Basis Document, Re-Evaluation of Structure DCGLs and Uranium Activity Fractions,PBRF-TBD- 11-002, January 2012.

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

USEPA 2002 Memorandum of Understanding, US Environmental Protection Agency and US Nuclear Regulatory Commission, ConsultationandFinalityon Decommissioning and Decontaminationof ContaminatedSites, October 9, 2002.

USNRC 2006 US Nuclear Regulatory Commission, ConsolidatedDecommissioning Guidance, NUREG-1757, Vol. 1, Rev.2, September 2006.

7.0 Appendices Appendix A Exhibits Appendix B - Buried and Miscellaneous Piping Location Maps 22

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix A Rev.0, Page 1 of 8 Plum Brook Reactor Facility Final Status Survey Report Attachment 17 Buried and Miscellaneous Piping Revision 0 Appendix A Exhibits

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix A Rev.O,:Page 2 of 8 List of Exhibits Exhibit 1, Video Inspection and Cleaning of Buried and Miscellaneous Piping ............................... 3 Exhibit 2, Typical Pipe Survey Sled .................................................................................................. 4 Exhibit 3, Buried and Miscellaneous Piping Survey ......................................................................... 5 Exhibit 4, Detector-Sled-Pipe and Cable Mock-up ......................................................................... .6 Exhibit 5, Release Survey of MP Removed During Demolition ........................................... ............... 7 Exhibit 6, WEMS Outfall Culverts .................................................................................................... 8

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix A Rev.0, Page 3 of 8 Exhibit 1, Exhibit 1, Video Inspection and Cleaning of Buried and Miscellaneous Piping

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix A Rev.0, Page 4 of 8 Exhibit 2, Typical Pipe Survey Sled

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix A Rev.0, Page 5 of 8 Exhibit 3, Buried and Miscellaneous Piping Survey

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix A Rev.0, Page 6 of 8 Exhibit 4, Detector-Sled-Pipe and Cable Mock-up

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix A Rev.0, Page 7 of 8 Exhibit 5, Release Survey of MLP Removed During Demolition

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix A Rev.0, Page 8 of 8 Exhibit 6, WEMS Outfall Culverts

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 1 of 41 Plum Brook Reactor Facility Final Status Survey Report Attachment 17 Buried and Miscellaneous Piping Revision 0 Appendix B Buried and Miscellaneous Piping Location Maps

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 2 Of41 Table of Contents Map Survey Unit Location 'Page Number Map 1 MP-1-1 WHHB 0'Drains to -13 SANS Sump 3 Map 2 MP-2-1 Fan House- FH- 112 & FH- 113 4 Map 3 MP-3-1 HRA Pipe Chase Floor Drain 5 Map 4 MP-3-2 HRA Perimeter Drains 6 Map 5 MP-5-1 CPT Floor Drains 7 Map 6 MP-6-1 ROLB SANS Drains 8 Map 7 MP-7-1 Hot Cell #1 Misc Piping & Conduits 9 Map 8 MP-7-2 Hot Cell #2 Misc Piping & Conduits 10 Map 9 MP-7-3 Hot Cell #3 Misc Piping & Conduits 1 Map 10 MP-7-4 Hot Cell #4 Misc Piping & Conduits 12 Map 11 MP-7-5 Hot Cell #5 Misc Piping & Conduits 13 Map 12 MP-7-6 Hot Cell #6 Misc Piping & Conduits i 14 Map 13 MP-7-7 Hot Cell #7 Misc Piping & Conduits 15 Map 14 MP-8-1 Hot Laboratory Conduit/Piping 16 Map 15 MP-9-1 Interim Storage Pit Conduit/Piping 17 Map 16 MP-10-1 RB -25' Conduits 18 Map 17 MP-10-2 RB -25' Conduits 19 Map 18 MP-10-3 Quad A Conduit/Piping ' 20 Map 19 MP-10-4 Quad D Conduit/Piping 21 Map 20 MP-10-5 Quad B Conduit/Piping 22 Map 21 MP-10-5 Quad C Conduit/Piping 23 Map 22 MP-10-6 Canal E Conduit/Piping 24 Map 23 MP-1 1-2 Reactor Vessel & Lily Misc Pad Pipes & Conduits 25 Map 24 MP-12-3 Primary Pump House, Room 1 26 Map 25 MP-12-3 Primary Pump House, Room 2 27 Map 26 MP-12-3 Primary Pump House, Room 3 28 Map 27 MP-12-3 Primary Pump House, Room 5 29 Map 28 MP-12-3 Primary Pump House, Room 6 30 Map 29 MP-12-3 PPH, Rooms 7 & 8 Floor , 31 Map 30 MP-12-3 PPH Room 7 & 8 West & South Walls 32 Map 31, MP-12-4, MP-12-5 PPH - Rooms 2 & 4 - PPH-103/104 33 Map 32 MP-12-6 PPH - Room 4 - PPH-105 34 Map 33 MP-12-7 PPH - Room 5 - PPH-106 35 Map 34 MP-12-8, MP-12-9, PPH - Rooms 1 PPH-108, PPH-109, PPH- 115 36 MP-12-10 Map 35 MP-12-11 PPH Room 5 - R5V1 37 Map 36. BP-I-I Sanitary Drain Piping, San 11 38 Map 37 BP-2-1 Pentolite Ditch Crossover Culverts 39 Map 38 BP-2-2 WEMS Crossover Culverts 40 Map 39 BP-2-3 Sanitary Drain Piping,'San 9 41

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 3 of 41 Map 1, WHB - 0' Drains to -13 SANS Sump - Survey Unit MP-1-1 TO "INSLIF4 1 ý-Iju Kaý CC

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Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 4 of 41 Map 2, Fan House - FH-112 & FH-113 - Survey Unit MP-2-1 i ***. -o Pxe. T I'Na *1 *

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Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 5 of 41 Map 3, HRA Pipe Chase Floor Drain - Survey Unit MP-3-1 HRAFDI

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910 ael N

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 6 of 41 Map 4, HRA Perimeter Drains - Survey Unit MP-3-2 LMAIi-

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 7 of 41 Map 5, CPT Floor Drains - Survey Unit MP-5-1

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 8 of 41 Map 6, ROLB SANS Drains - Survey Unit MP-6-1

'I'Nk I:-ý/ cc~ M9OMA N. "r^_

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev 0, Page 9 of 41 Map #7, Hot Coll #1 Misc Piping & Conduits, Survey Unit MP-7-1 0*

i A 0~

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev 0, Page10 of 41 Map #8, Hot Coll #2, Misc Piping & Conduits, Survey Unit MP-7-2 314' P5525 3/4' P 1631 1 PI 1501 314'P5 t 3 1,2' P41 314' P 4654ý 1324P P*)457 12' P561 10' MP [(2-3) 3 14' P41 412' 4 P 15 I-CC 3/4' P8463 P (604 1VC (7, 314' PPtM I" C M4-,

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PIPESIZES WHERETAKENFROM ENLARGEMENT "A- EXISTINGCONSTRUCTIONORAWINGS PIPINGUSEDFOR SCWS,SCWR,SA DIW,AXD KI

+0,- 142' PASSTHROUGHTOCELL.I I 144'C I1YP.4 ENLARGEIINT '8 I 1/4'C 42971 FLOOR

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev 0, Pagel I of 41 Map #9, Hot Cell /3, Misc Piping & Conduits, Survey Unit MP-7-3 3 14 'P 154) 34 P (52) 10, MP (3-1I 314' P M P16l2'P~l

  • 314" C 091 112' P (571- t I17,PI.,

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,0'-1 112' (321 THRU 1431, CONDUIT BANKS SEE ENLARGEMENT B" ENLARGEMENT B" SEE ENLARGEMENT"C ELECTRICAL CABINET f2 CH (3-71 RABBIT TRANSFER STATION 1YE FOUR I 114'C -

I 1 Al C (TYPI FO-CH ENLARGEMENT C" FLOOR

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev 0, Pagel2 of 41 Map #10, Hot Coil #4, Mlsc Piping & Conduits, Survey Unit MP-7-4 34' P165) P R154?

3,4' P 100) 1 112' P f63)

I.*' P 1881 112' P 1691 j XO

  • oa PIPESIZES FROM 4111RETAKEN PC0 0 PIPINGOS. OR SW111Ws~LA 112. P R L 01Df.AND HINOR 1/2- P 18 3/4'6191jj112-P1.

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-I" C KIf ENLARGEMENT 'A'

- OP 14-31 PASSTHRNOUGH4 TOCELL

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- SEEFULAR1MUNGIT 'C' 2"CH-C/IDS14-41, POUR1 114' C-LE I 1/14 C (TYP/

FLOOR 4l ENLARGEMENT "C"

Plum Brook Reactor Facility FSSk.Attachment 17 Appendix B Rev 0, Pagel3 of 41 Map #11, Hot Coll #5, Misc Piping & Conduits, Survey Unit MP-7-5 3 4" P4 1791 - 1' P 781 P P77 314" PtIjawo 3A4 1111) 1 12 P 176*

112' P 824 NOM:

O O0 0 PIP0 W ES W...E TA.EN FXISTING CONSTRUCTION DRAWNGS 0"00 3/4' C .4, 8 10, MP 1-)

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1/2' P (754 DW. AND.IM N 3 1 w 4C 788 314' C 74 3W4 P 473 1 112'P481 314- C 8814 SEEENLA(1GEMENI C478 34' -- P

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.0'.1 7/2' ENLARGEMENT "8*

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EM.ARGEMSNT "C" 4' C74.41CO 78-44 F4IDOR

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev 0, Pagel4 of 41 Map #12, Hot Cell #6, Mlsc Piping & Conduits, Survey Unit MP-7-6 3/4" P (87) P r1 IES) 314"P (89)1 1 )/2P455f 134" P 1W01 112- P 71 NOTES, 0 0 o 0 PIPESIZES WHERETAKENFROM 0 PIPINGUSEDFOR SCWs SCWR,SA. ' P(61-2) 1)2'P. DIWANHW N E 10 MPWI) 112" P1 3/4'P)7 17 1 - 112M C (80)- 3,4" C (8)1 314-P 71 P73/4" 314' P(75) V P (741 314" C I80) C1 3)4" C .. C81 ENLARGEMENT "A" + 01'-" T1 I_____.

- ___________ ... .C[..82 1" PASS THROUGHTO CELL5

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ENLARGEMENT "B' RABBITTRANSFER ELECTRICAL - SEE STATION CABINET ENLARGEMENT 'C' SII 1II"C 1 14" C (TYP ENLARGEMENT "C" FLOR -3" VL -5)

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev O, Pagel Sof 41 Map #13, Hot Cell #7, Misc Piping & Conduits, Survey Unit MP-7-7 Yl4' P 76) IP(IN V

34' P1771 1P (74) 314.P(781 1 12* P (73) 12" (amNO ES, 0 00 EXESIZEESWHERE TAKERNFRO ICONSTR1UCT1O1 DUAWOEG BED FORsCUS. SCWKTA.

PIPI F NGU 3MW

112PR, 314' P t2 Pja 3,.Pis. F,(I821 W.-O ENLARGEMENT'A' II) P R CR).

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Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 16 of 41 Map 14, Hot Laboratory Conduit/Piping - Survey Unit MP-8-1 I

I I

I I

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 17 of 41 Map 15, Interim Storage Pit Conduit/Piping - Survey Unit MP-9-1

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 18 of 41 Map 16, RB -25' Conduits - Survey Unit MP-10-1

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 19 of 41 Map 17, RB -25' Conduits - Survey Unit MP-10-2

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 20 of 41 Map 18, Quad A Conduit/Piping - Survey Unit MP-10-3 Quad A N

0 0

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 21 of 41 Map 19, Quad D Conduit/Piping - Survey Unit MP-10-4 Quad D N-N

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 22 of 41 Map 20, Quad B Conduit/Piping - Survey Unit MP-10-5 Quad B

Plum Brook Reactor Facility FSSIR Attachment 17 Appendix B Rev.0, Page 23 of 41 Map 21, Quad C Conduit/Piping - Survey Unit MP-10-5 Quad C N 0

CO 000

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.O, Page 24 of 41 Map 22, Canal E ConduitlPiping, Survey Unit MP-10-6 Canal E 1

N 0

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 25 of 41 Map 23, Reactor Vessel and Lily Pad Misc Pipes & Conduits, Survey Unit MP-11-2

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 26 of 41 Map 24, Primary Pump House, Room 1, MP-12-3 2' C w N __

2' OW WPH4901 /- 314' SA IPPH493) 2" PW IppI44.)

VOEH 3M4R=CW /> 1/4.-

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Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 27 of 41 Map 25, Primary Pump House, Room 2, MP-12-3 3/4* SCW (PPH47 1) 2 E S

, 2" C 1P 70) 11 473). 3/4' SA

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1/2' CGR -VSE HOLE EX 16" PCWS D STILL IN PLAC Q

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Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 28 of 41 Map 26, Primary Pump House, Room 3, MP-12-3 2* C W a/4'SCWV N E S IPPHS931 (IPPHU 3/4 SA (PPH564)

S1/4 21 PW IPt5S 2 W PP4W2* DW IPPH58I - 4 TO G*PRIMARY MOTOR VOEN WPH~S82, SHF (PPH83) 2" C (PPHS741  :/4IP 17' PCW (SRQ3 VOEH 'Ile(PPH5Sl)

VN 2* C J 0IIIZ (PPHS5)S VOEH KY 1/2'CGR I?* PCW (SR9W VOeN FLOOR REMOVED/

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Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 29 of 41 Map 27, Primary Pump House, Room 5, MP-12-3 16" P (PUMP LEAKAGE CONITAINMENT PIT)

"--314* SIJMP DRAIN FLOOR

un Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 30 of 41 Map 28, Primary Pump House, Room 6, MP-12-3

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Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 31 of 41 Map 29, Primary Pump House, Rooms 7 & 8 Floor, MP-12-3 2' DAWiFP8 5, 1 U - DW IFPB6) 4' VENTIN I N2'A 1 6FP8-4) 6' SLEEVE 3- PW 1"PR3)

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Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 32 of 41 Map 30, Primary Pump House, Rooms 7 & 8 West and South Walls, MP-12-3 SCUMWALL 3 l SCW1P*'6931 . I- CON0UIT 1- 12, C-11 1-ft 11-w ROOM $

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Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 33 of 41 Map 31, Primary Pump House, Rooms 2 & 4 PPH-103/104, Survey Units MP-12-4 and MP-12-5 pI.Ao~VVmft M ,C a $M~tA

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Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 34 of 41 Map 32, Primary Pump House, Room 4 PPH-105, Survey Unit MP-12-6

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 35 of 41 Map 33, Primary Pump House, Room 5 PPH-106, Survey Unit MP-12-7 I

EbuTimc, CA- 21. m, 440 Apoa )""AT

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 36 of 41 Map 34, Primary Pump House, Rooms 1 - 8, PPH-108, PPH-109, & PPH-115, Survey Units MP-12-8, MP-12-9, MP-12-10

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 37 of 41 Map 35, Primary Pump House, Room 5, R5V1, Survey Unit MP-12-11 1.F.

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 38 of 41 Map 36, Sanitary Drain Piping San 9, Survey Unit BP-1-1

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 39 of 41 Map 37, Pentolite Ditch Crossover Cudverts, Survey Unit BP-2-1 BA BA BA BA BA

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 40 of 41 Map 38, WEMS Crossover Culverts, Survey Unit BP-2-2

Plum Brook Reactor Facility FSSR, Attachment 17 Appendix B Rev.0, Page 41 of 41 Map 39, Sanitary Drain Piping San 11, Survey Unit BP-2-3 4,,

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I 311 di I41M ii~4i I

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