ML16158A445
| ML16158A445 | |
| Person / Time | |
|---|---|
| Site: | 07000036 |
| Issue date: | 06/06/2016 |
| From: | Fussell G Westinghouse |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML16158A444 | List: |
| References | |
| HEM-16-31 | |
| Download: ML16158A445 (50) | |
Text
Westinghouse Non-Proprietary Class 3 Westinghouse Electric Company LLC Hematite Decommissioning Project 3300 State Road P Festus, MO 63028 USA
© 2016 Westinghouse Electric Company LLC All Rights Reserved ATTN: Document Control Desk Director, Office of Federal and State Materials and Environmental Management Programs U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Direct tel:
314-810-3355 E-mail:
fusselgm@westinghouse.com Our ref:
HEM-16-59 Date:
June 6, 2016
Subject:
Westinghouse Hematite Decommissioning Project - Request for NRC Review of Final Status Survey Final Report Volume 5, Chapter 1, Revision 1 - Final Status Survey Final Report, Piping Survey Areas (PSA) Overview (License No. SNM-00033, Docket No. 070-00036)
References:
- 1) Westinghouse letter HEM-16-31 (Fussell) to NRC (Document Control Desk) dated March 16, 2016, Request for NRC Review of Final Status Survey Final Report Volume 5, Chapter 1 - Piping Survey Areas Overview The purpose of this letter is to provide for the U.S. Nuclear Regulatory Commission (NRC) review of the FSS overview document Final Status Survey Final Report Volume 5, Chapter 1, Revision 1 - Piping Survey Areas (PSA) Overview.
In Reference 1, Westinghouse submitted for NRC review the overview document Final Status Survey Final Report Volume 5, Chapter 1. The NRC provided via email a Pre-Audit Submittal Table for Final Status Survey Final Report Volume 5, Chapter 1 on May 9, 2016, which contained comments generated by the review. During a subsequent recurring weekly publicly noticed teleconference Westinghouse and the NRC discussed the path forward and resolution of the NRC comments for Final Status Survey Final Report Volume 5, Chapter 1.
contains Final Status Survey Final Report Volume 5, Chapter 1, Revision 1. contains a track change version of Final Status Survey Final Report Volume 5, Chapter 1, Revision 1, for ease of review which identifies revisions made as a result of responses to the NRCs comments. Attachment 3 contains the Pre-Audit Submittal Table for Final Status Survey Final Report Volume 5, Chapter 1 with Westinghouses response.
Please contact Kenneth Pallagi at 314-810-3353, should you have questions or need additional information.
HEM-16-59 June 6, 2016 Page2 ofZ Sincerely,
\\--^-qo Project
Attachment:
- 1) Final Status Survey Final Report Volume 5, Chapter l, Revision l, Piping Survey Areas (PSA) Overview (HDP-RPT-FSS-400)
- 2) Track change version of Final Status Survey Final Report Volume 5, Chapter l, Revision l, Piping Survey Areas (PSA) Overview (HDP-RPT-FSS-400)
- 3) Pre-Audit Submittal Table for Final Status Survey Final Report Volume 5, Chapter 1 J. W. Smetanka, Westinghouse M. R. Meyer, NRC/DUWP/MDB J. A. Smith, NRC/DUWPtuIDB to HEM-16-59 June 6, 2016 Final Status Survey Final Report Volume 5, Chapter 1, Revision 1 Piping Survey Areas (PSA) Overview Westinghouse Electric Company LLC, Hematite Decommissioning Project Docket No. 070-00036
Westinghouse Non-Proprietary Class 3 O 2016 Westinghouse Electric Company LLC. All Rights Reserved.
Westinghouse Final Status Survey Report Hematite Decommissioning Project Final Status Survey Final Report Volume 5, Chapter 1 TITLE:
Piping Survey Areas (PSA) Overview REVISION:
1 EFFECTTVE DATE: JUN 0 6 Z0lo Approvals:
Author:
6 ?qt e Reviewed By:
Owner/Manager:
u Date bltt/76 Scott G. Zol\\er Date e/o /ru Date HDP-RPT-FSS-4OO
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page i of iii Table of Contents 1.0 PIPING SURVEY AREAS INTRODUCTION.............................................................. 1 2.0 REMEDIATION ACTIVITIES...................................................................................... 2 2.1 Remediation Planning............................................................................................. 2 2.1.1 Preliminary Piping Access, Visual Inspection and Survey......................... 3 2.1.2 Remediation Planning Summary................................................................ 4 2.2 Process Piping......................................................................................................... 4 2.3 Class 1 Piping (Storm Water, Sanitary/Gray Waste Water)................................... 4 2.3.1 Storm Water Drain System..........................................................................4 2.3.2 Sanitary and Gray Waste Water Systems....................................................5 2.4 Class 3 Piping (Raw Water System, Public Water System)................................... 6 2.5 Natural Gas Pipeline (NGP).................................................................................... 7 2.6 Piping Remediation Summary................................................................................ 7 3.0 RELEASE CRITERIA..................................................................................................... 7 4.0 DATA QUALITY OBJECTIVES................................................................................... 9 5.0 FINAL STATUS SURVEY DESIGN............................................................................ 13 6.0 FINAL STATUS SURVEY............................................................................................ 14 7.0 DATA QUALITY ASSESSMENT................................................................................ 17 8.0 SURVEY AREA RELEASE RECORD ORGANIZATION...................................... 20
9.0 REFERENCES
................................................................................................................ 21 10.0 APPENDICES................................................................................................................. 21
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page ii of iii LIST OF TABLES Table 2-1 Pre-Remediation Piping Inventory................................................................................ 22 Table 2-2 Post-Remediation Piping Inventory.............................................................................. 24 Table 3-1 Site Specific Building and Structural Surface DCGLs.................................................. 25 Table 3-2 Buried Pipe Gross Activity DCGLs.............................................................................. 26 Table 3-3 Initial Isotopic Distribution........................................................................................... 27 Table 3-4 Gross Activity DCGLSO for Small Offices.................................................................... 28 LIST OF FIGURES Figure 2-1 Hematite Class 1 Piping (Storm, Sanitary/Gray Drains)............................................. 29 Figure 2-2 Hematite Class 3 Piping (Public and Raw Water)....................................................... 30 Figure 2-3 Storm and Sanitary Piping Remaining at License Termination................................... 31 Figure 2-4 Pipe Cleaning Contractor............................................................................................. 32 Figure 2-5 Pipe Cleaning Crawler Unit......................................................................................... 32 Figure 2-6 Pipe Cleaning of Storm Water Drain Piping................................................................ 33 Figure 2-7 Example of Storm Water Drain Manhole Prior to Cleaning........................................ 33 Figure 2-8 Example of Storm Water Drain Manhole after Cleaning............................................. 34 Figure 2-9 Example of Storm Water Drain Piping Prior to Cleaning............................................ 34 Figure 2-10 Example of Storm Water Drain piping After Cleaning............................................. 35 Figure 2-11 Access to the SWTP Piping....................................................................................... 35 Figure 2-12 Natural Gas Pipe Line................................................................................................ 36 Figure 2-13 Swale that Isolated and Controls a Section of Storm Water Drain Piping................. 36 Figure 2-14 Heating/Ventilation Unit Drying a Section of Storm Water Drain Piping................ 37 Figure 2-15 Detector Unit Accessing the SWTP Piping............................................................... 37
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page iii of iii LIST OF APPENDICES Appendix A HDP Procedure Revision History............................................................................ A-1 Appendix B HDP FSSFR PSA Document Matrix........................................................................ B-1 LIST OF ACRONYMS AND SYMBOLS Am Americium CFR Code of Federal Regulations CSM Conceptual Site Model DCGL Derived Concentration Guideline Level DCGLPD DCGL (PD" suffix denotes "Pipe Diameter")
DCGLSO DCGL (SO" suffix denotes "Small Office")
DP Hematite Decommissioning Plan DQA Data Quality Assessment DQO Data Quality Objective FSS Final Status Survey FSSFR Final Status Survey Final Report HDP Hematite Decommissioning Project HP Health Physics MeV Megaelectron Volts NGP Natural Gas Pipeline NIST National Institute of Standards and Technology Np Neptunium NRC U.S. Nuclear Regulatory Commission Pu Plutonium QA Quality Assurance QC Quality Control Ra Radium RAI Request for Additional Information SWTP Sanitary Wastewater Treatment Plant Tc Technetium TEDE Total Effective Dose Equivalent Th Thorium U
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 1 of 37 1.0 PIPING SURVEY AREAS INTRODUCTION The purpose of this document, Final Status Survey Final Report (FSSFR) Volume 5, Chapter 1, Piping Survey Areas (PSA) Overview, is to provide a general description of the processes used in planning, designing, implementing, evaluating and reporting the results of final status surveys (FSS) performed of subterranean piping that will remain at the Hematite Site following license termination. Information specific to each remaining area of piping will be provided in a subsequent Volume 5 chapter.
The Hematite Decommissioning Project (HDP) FSSFR Volume 1, Chapter 1, Final Status Survey Final Report Overview, provides overview information in regards to the approval process and history of the HDP Decommissioning Plan (DP). The Hematite Decommissioning Plan (Reference 9.1) {ML092330123} and associated documents contain the requirements for surveying piping areas that remain following license termination.
During the approval process for the DP the U. S. Nuclear Regulatory Commission (NRC) issued Request for Additional Information (RAI) HDPC-14-Q6 which provided the expectation that the NRC would review and approve the methodology for embedded pipe characterization. In Westinghouse letter HEM-11-96, dated July 5, 2011
{ML111880290}, in response to Request for Additional Information (RAI) HDPC-14-Q6 Westinghouse provided the following resolution The method for final status surveys of piping will be submitted for NRC review and approval, with approval received prior to implementation of final surveys of piping.
As stated in the response to RAI HDPC-14-Q6 Westinghouse submitted letter HEM 73, Request for Approval of the Hematite Final Status Survey Plan for Piping Remaining After Decommissioning, dated July 3, 2012 {ML12187A121}, which contained HDP-PO-FSS-800, Final Status Survey Plan for Piping, Revision 0, for NRC review and approval. NRC letter dated April 5, 2013, U.S. Nuclear Regulatory Commission Review of Westinghouse Hematites Final Status Survey Plan for Piping, HDP-PO-FSS-800
{ML13031A452}, provided that the proposed Plan, modified in accordance with the staffs comments, appears to provide a reasonable path forward in the final status survey of piping at the site; however, NRC staff review and comment on the Plan does not equate to an automatic approval of the overall final status survey results. The NRC will review the Final Status Survey Report once the final status survey is complete. Once the Final Status Survey Report is submitted to the NRC, dose assessments, survey results, and evaluations related to final status survey coverage (for accessible and inaccessible areas) will be evaluated by the staff. In addition, the NRC may also choose to conduct confirmatory surveys and in-process surveys, as necessary.
Subsequently, on June 15, 2015, HDP-PO-FSS-800, Revision 1 was issued that contained resolution of the NRC comments contained within the April 5, 2013, NRC letter. The guidance contained in the following regulatory documents was used in the development of HDP-PO-FSS-800 to demonstrate that the dose contribution from residual activity remaining in the piping meets the dose criterion for license termination specified in 10 CFR 20.1402 (Reference 9.2).
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 2 of 37 DO-08-004, Hematite Decommissioning Plan, NUREG-1507, Minimum Detectable Concentrations with Typical Radiation Survey Instruments for Various Contaminants and Field Conditions (Reference 9.3),
NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), (Reference 9.4),
NUREG-1757, Volume 2, Consolidated NMSS Decommissioning Guidance -
Characterization, Survey, and Determination of Radiological Criteria (Reference 9.5),
ISO Standard 7503-1 Evaluation of Surface Contamination - Part 1: Beta Emitters (Maximum Beta Energy Greater than 0.15 MeV) and Alpha Emitters, (Reference 9.6).
The conduct of FSS activities for PSAs was carried out through the implementation of the following HDP procedures:
HDP-PO-FSS-700, Final Status Survey Program HDP-PO-FSS-800, Final Status Survey Plan for Piping HDP-PR-FSS-701, Final Status Survey Plan Development HDP-PR-FSS-703, Final Status Survey Quality Control HDP-PR-FSS-720, Final Status Survey Data Integrity and Database Management HDP-PR-FSS-722, Final Status Survey Reporting A procedure revision history for the above procedures is provided in Appendix A.
2.0 REMEDIATION ACTIVITIES Site characterization data for the DP provided a preliminary assessment of the piping sections that were expected to be decontaminated and subjected to FSS or simply subjected to FSS and remain at the time of license termination. The piping sections are summarized in Table 2-1, Pre-Remediation Piping Inventory. As submitted to the NRC in HDP-PO-FSS-800 Revision 0, the piping identified as Class 1 are illustrated in Figure 2-1, Hematite Class 1 Piping (Storm Drains, Sanitary/Gray Drains), and the piping identified as Class 3 are illustrated in Figure 2-2, Hematite Class 3 Piping (Public Water). Class 1 piping had the potential to be radiologically contaminated and included all gray water piping and drains, storm sewer water piping and drains, and piping from the Sanitary Wastewater Treatment Plant (SWTP).
2.1 Remediation Planning The following is a description of the general piping remediation plan employed to support site remediation efforts.
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 3 of 37 Process piping was piping associated with Special Nuclear Material operational processes, and as such was confined to the Process Buildings area and was designated for removal and disposal.
Gray water piping was piping containing non-potable water; water that for example originated from laboratory sinks, washing machines or shower facilities. This piping was designated for removal and disposal.
Piping from the SWTP contained sanitary or gray waste water that had been treated and was being discharged to the Site Creek below the Site Dam. This piping was designated as candidate Class 1 piping for FSS.
Raw Water System piping was for the distribution of water formerly supplied by the site well, with pressure maintained by using a storage tank on the hill north of State Road P.
The Raw Water System supplied potable water to the site and supplied water to the emergency fire pump in Building 115. Subsequently, as Public Water District Number 5 ran a water main past the site the site was connected to the public water supply. The portions of the Raw Water System that remained in service along with the newly installed water supply lines were henceforth known as the Public Water system. This piping was designated as Class 3 piping.
Storm water drains and piping collected rainfall/runoff from rooftops and ground surfaces throughout the site for discharge to the Site Pond or streams. This piping was designated as candidate Class 1 piping for FSS.
2.1.1 Preliminary Piping Access, Visual Inspection and Survey As a function of piping remediation planning and FSS preplanning, portions of the piping (Class 1) that was expected to be final status surveyed was accessed, to the extent practical, for visual inspection by remote camera and radiation survey equipment. The preliminary piping access and visual inspection campaign was conducted during October 2010.
The purpose of the visual inspection was to determine if piping could be adequately accessed for FSS and to ascertain the general condition of the piping by identification of obstruction, residual deposits of sediment/scale, and breaks or cracks in the piping. None of the Class 1 piping included charged systems that required isolation and draining prior to accessing. The results of the visual inspection indicated that with the ability to access the piping with the remote camera that there would be a high degree of confidence that a significant percentage of the piping could be successfully surveyed. The visual inspection also indicated that, as expected, in storm drains there was soil, sediment and rocks that would be required to be removed to allow for an adequate FSS. It also confirmed that specific areas of piping would be difficult to access.
Radiological survey equipment was inserted and positioned in the piping by using a flexible rod or a tether (or equivalent) to push or pull the survey instrumentation through the piping. The purpose of the radiological survey was to determine the need/extent of
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 4 of 37 decontamination that may be necessary. The results of the radiological survey indicated that minimal if any decontamination would be required.
Scale or sediment samples were also collected from drain traps, manholes and piping for sample analysis. The laboratory analyses of these samples were used to confirm the isotopic distribution.
2.1.2 Remediation Planning Summary In general, during remediation, little attempt was made to decontaminate and save the majority of subterranean piping throughout the site as much of it was located in soil that was to be remediated by removal for disposal. For piping located in soil that did not need to be remediated, because of the time and difficulty to hydrolaze (decontaminate) and FSS the piping, it was more cost effective and expedient to remove the piping and send it offsite for disposal.
For the larger diameter storm water piping that had little to no contamination, cleaning and surveying would be cost effective, enabling the pipe to either be abandoned in place or placed back into use.
It is anticipated, based on radiological conditions, that no onsite subterranean piping of any kind would be required to be grouted and left in place.
2.2 Process Piping The Process Buildings were the only buildings to contain process system drains and piping. Following demolition and the disposition of the above ground portions of the Process Buildings as waste, the below ground process piping and drains remained within and under the concrete floor slabs and foundations. All of these process drains and piping were removed and disposed of as waste during the demolition of the Process Building slabs and foundation. In addition to the process piping, all other non-process related drains and piping (i.e., storm, gray, sanitary) associated with the Process Buildings were removed and disposed of as waste. No significant areas of contamination were identified in any of the drains or piping dispositioned as waste during the removal of the Process Buildings or its slabs and foundations.
2.3 Class 1 Piping (Storm Water, Sanitary/Gray Waste Water)
As described in the DP, four buildings will remain on the Hematite site at license termination: Building 110, Administration and Security (security, conference rooms, offices); Building 115, Fire Pump House (generator and fire pump); Building 230, Rod Loading (fuel rod loading plant); and Building 231, Warehouse (shipping container storage). Neither Building 115 nor Building 231 ever contained any process, storm, gray or sewer drains or piping. Buildings 110 and 230 contained only storm and sanitary/gray sewer drains and lines.
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 5 of 37 2.3.1 Storm Water Drain System All the storm water drains and piping have either been removed or final status surveyed to demonstrate meeting the release criterion. The underground storm water drain piping that had originated near Building 110 and flowed to the north end of the Site Pond has been abandoned in place. In preparation for the abandonment of this storm water piping surface soil was contoured to form a swale that directs the surface water runoff from the parking lot and area near Building 110 to bypass the storm water drains. Also, the storm water downspouts associated with Buildings 110 and the north and west sides of Building 230 that had previously drained into this same storm water drain piping were redirected to divert rainwater to this diversion swale.
On the east and south sides of Building 230 the downspouts have also been diverted to flow onto the ground surface. These areas have been graded for storm water to flow to a low area southeast of Building 230 or directly towards the Site Pond. A drain has been installed in this low area to collect storm water runoff and divert it to the Site Pond via storm water drain piping. This storm water drain piping is the only previously existing storm water drain piping that has been placed back into service following the completion of FSS.
Prior to FSS of the storm water drain piping, a contractor that specializes in storm water drain piping clean out was utilized to flush/clean all of the storm water drain piping that will remain at license termination. Figure 2-4 through Figure 2-6 are photographs of the contractor performing storm water drain piping cleaning. Figure 2-7 through Figure 2-10 are photographs that provide examples of the pre and post cleaning condition of the storm drain manholes and piping.
The Storm Water Drain System piping cleanout was very effective in that minimal to no residues or sediments remained in the piping. Therefore, radiation attenuation is not a concern for FSS of the piping. Based upon the piping FSS completed to date, the results of surveys indicate there has been no evidence of removable contamination in the piping.
The visual inspection conducted post cleaning indicated that all piping to undergo FSS was intact and that the internal condition of the piping was such that detectors would be able to pass through the entirety of the piping. No internally inaccessible areas or sections were identified.
2.3.2 Sanitary and Gray Waste Water Systems All sanitary and gray waste water lines were removed within Building 110 and Building 230 and disposed of. All of the sanitary and gray water lines from Building 110 and Building 230 to the SWTP were removed and disposed of.
The SWTP was demolished and shipped off site as waste. The SWTP discharge line carried treated water from the SWTP to the Site Creek. A section of the SWTP discharge line was removed downstream from the SWTP and a section of the SWTP discharge line was removed upstream from its discharge point below the Site Dam. The remaining
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 6 of 37 mid-section of SWTP piping (SAN-1 on Figure2-3) is 293 feet in length and has been abandoned in place. This section of piping was cleaned by the contractor performing the storm water drain piping. Figure 2-11 is a photograph showing the access point of the SWTP pipe for cleaning and FSS.
The SWTP pipe cleanout was very effective in that minimal to no residues or sediments remained in the piping. Therefore, radiation attenuation is not a concern for FSS of the pipe. Based upon the pipe FSS completed, the results of surveys indicate there has been no evidence of removable contamination in the piping.
The visual inspection of the SWTP pipe conducted post cleaning indicated that the pipe internal condition was intact and that detectors would be able to pass through the entirety of the pipe. No internally inaccessible areas or sections were identified.
2.4 Class 3 Piping (Raw Water System, Public Water System)
The Raw Water System was formerly supplied by the site well, with system pressure being maintained by using the storage tank located on Westinghouse property on the hill north of State Road P. The Raw Water System supplied potable water to the site and supplied water to the emergency fire pump in Building 115, which in turn supplied pressurized water to the fire hydrants. In order to separate the Process Building from Buildings 110 and 230, the site well was abandoned, the emergency fire pump removed and the piping isolated. The piping to the Process Building was severed. Approximately half of the Raw Water System piping was utilized by the Public Water System.
The Public Water supply remains available at the Hematite site but portions of the on-site system (e.g., restrooms and cafeteria) were abandoned at the initiation of remediation to facilitate remediation activities. The public water supply to the onsite fire hydrants have remained in service. Since the water supply system is a public water source originating offsite, it was designated as a Class 3 system indicating there should be no associated radiological contamination. As site remediation took place, several fire hydrants had to be removed and supply line piping uncovered in a number of locations.
There are no former Raw Water Systems or Public Water Systems residing in or traversing through Building 231 with the exception of a sprinkler supply line which was roughed in (capped at the floor) but never activated. The sprinkler line is part of the Public Water System.
Although remediation/decontamination of the Raw Water Systems and Public Water Systems was not necessary, radiological surveys were conducted on the exposed exterior of the supply lines to verify that no radiological contamination had collected along the lines. No contamination was identified in any of the surveys. The public supply of water will remain in place and pressurized at license termination to maintain the viability of the fire hydrants in the event of onsite fire.
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 7 of 37 2.5 Natural Gas Pipeline (NGP)
An 8 inch diameter high pressure natural gas transmission pipe line runs the length of the southeast border of the Hematite Site. The NGP was installed in 1956 and is a sole source of natural gas for local communities. Soil impacted by former Site operations was located near the NGP and was remediated. As the NGP has been active since its installation it does not present a condition in which the internals of the NGP would have become contaminated. Figure 2-12 is a photograph of the NGP during soil remediation operations.
2.6 Piping Remediation Summary Overall, the approach applied in regards to disposition of piping by the HDP resulted in a minimal amount of remaining subterranean piping. Due to the amount and types of piping removed for disposal, the piping that did remain provided the added advantage of limiting the type of survey instrumentation and complexity required to perform FSS.
A large percentage of the storm water drain piping and a portion of the SWTP discharge line will remain at license termination and will meet the release criterion. All other Class 1 piping and SWTP piping was removed and disposed of as waste. The smallest diameters of these remaining lines is 12 inches for the storm water drain piping and 6 3/4 inches for the SWTP discharge line piping. The size of these lines allowed for adequate surveys and visual inspections to be conducted without costly or unduly sophisticated equipment.
Figure 2-3, Storm and Sanitary Piping Remaining at License Termination, illustrates the piping that will undergo FSS and will remain at license termination.
3.0 RELEASE CRITERIA Section 5.1 of FSSFR Volume 1, Chapter 1 provides a discussion of the radionuclides of significance at Hematite. Radionuclide-specific derived concentration guideline levels (DCGLs) for residual surface contamination on buildings, structural surfaces and piping were developed as described in Chapter 5 of the DP using the RESRAD-BUILD computer code, Version 3.4. The exposure scenarios included building occupancy under two conceptual site models (CSM) having different room sizes (i.e., Small Offices and Large Warehouse). Piping DCGLs (DCGLPD) were also derived using RESRAD, version 6.4 for a range of pipe diameters. For simplicity and conservatism, the small office DCGL (DCGLSO) is applied to piping as the release criteria. A summary of the DCGLSO is provided as Table 3-1.
Since these values are radionuclide-specific release criterion, the values could not be applied directly to field measurements of gross activity. To account for this, gross activity limits (alpha-plus-beta, or beta only depending upon the detector) were derived based on the isotopic distribution of radionuclides that can be measured using field instrumentation, and accounting for the distribution of all other undetected radionuclides that could be present. Table 4-1 of the DP provides the initial isotopic distribution based on previously collected samples of pipe scale and debris. This distribution is reproduced
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 8 of 37 in Table 3-3. These initial isotopic distributions were used to determine a gross activity value that was equivalent to the DCGLSO using Equation 4-4 of MARSSIM (Reference 9.3). The resultant gross activity DCGLSO is provided in Table 3-4.
During the performance of FSS, additional samples of pipe scale and debris were collected for isotopic analysis. The results of the isotopic analysis uphold the initial isotopic distributions used in development of the DCGLs, and the specific isotopic results are provided in the subsequent chapters to this report.
Additionally, a gross activity DCGL (DCGLPD) was developed for piping as a function of pipe diameter, and discussed in Chapter 5 of the DP. The buried pipe DCGLs are a function of the pipe diameter since the internal surface area increases proportionally as the radius increases, while the interior volume increases as a square of the radius.
Therefore, the DCGL increases as the pipe diameter increases. The DCGLPD from DP Table 5-22 is summarized in Table 3-2. If levels of residual contamination were found to exceed the DCGLSO, the DCGLPD for the specific pipe diameter would serve as the comparator for individual measurement results to determine if the piping should have been grouted in-situ to meet the dose-based criterion rather than excavate the piping. In no situation will this be necessary.
The contamination levels in the majority of the piping to remain had been expected to be nonexistent or very low relative to the buried pipe DCGLs. Radiological surveys conducted on the piping confirmed this assessment.
The protocol established to evaluate the piping against the DCGL was as follows:
If all measurements were less than the gross activity DCGLSO and the Data Quality Objectives (DQOs) were met, then no additional investigation would be required and the piping survey unit could be recommended for unrestricted release.
If any individual measurement exceeded the gross activity DCGLSO but did not exceed the gross activity piping DCGLPD, an investigation would be performed and documented.
If the average gross activity level within a section(s) of piping containing the elevated result(s) did not exceed the DCGLSO, the piping survey unit could be recommended for unrestricted release.
In the unlikely event buried piping to remain exceeded DCGLSO and could not be practically decontaminated or removed, HDP would verify the piping met the DCGLPD and grout the piping in place. HDP would evaluate the specific dose from piping to be left and accounted for that dose in the affected piping survey unit. The specific dose from piping to be left would be determined on a case-by-
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 9 of 37 case basis using specific piping characteristics and a modeling program (e.g.,
MicroShield1).
If any individual measurement exceeded the gross activity DCGLPD, that section of piping containing the individual measurements exceeding the piping DCGLPD would be further decontaminated and re-surveyed, or excavated and removed.
For piping scan surveys, the Sign test is applied using a direct comparison to the DCGLSO. In the event that a piping survey unit could not meet the release criterion, a retrospective power analysis would be used to determine if it was due to excess residual radioactivity or if it was due to an inadequate sample size. The retrospective power analyses would be performed following the methods of MARSSIM Appendix I.9 (Reference 9.4). As of this time, no piping is expected to exceed the release criteria, however if a retrospective power analysis is required it will be noted in the respective piping survey release record Volume 5 Chapter.
FSSFR Volume 3, Chapter 1, Section 3.2, Demonstrating Compliance with the Dose Criteria, provides a discussion on how the dose attributed to a piping survey will be added to the Total Dose for a land survey area survey unit.
4.0 DATA QUALITY OBJECTIVES The FSS process consists of the following principal elements to which the DQO are applied: Planning and Design, Implementation, and Data Assessment. DQO allow for systematic planning, address situations that require a decision to be made, and provide a framework for selecting actions that result in obtaining data of sufficient quantity and quality. The DQO process is iterative and allows for incorporation of newly gained knowledge to enhance the effectiveness of subsequent actions. The seven steps of the DQO process are as follows:
- 1. State the problem,
- 2. Identify the decision,
- 3. Identify inputs to the decision,
- 4. Define the study boundaries,
- 5. Develop a decision rule,
- 6. Specify limits on decision errors, and
- 7. Optimize the design for obtaining data.
The DQO process is described below as it applies to the HDP.
1 Copyright © 1992-2014 Grove Software l 4925 Boonsboro Rd, #257 Lynchburg, VA 24503 USA l a Division of Grove Engineering, Inc. All rights reserved.
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 10 of 37
- 1. State the Problem The problem is the potential presence of residual radioactivity associated with licensed activities within piping. The primary radionuclides of concern (ROC) and the extent of contamination were assessed in the Historical Site Assessment (HSA), (Reference 9.7) and the Hematite Radiological Characterization Report (HRCR), (Reference 9.8). The primary ROC are uranium-234 (U-234), uranium-235 (U-235+D), uranium-238 (U-238+D), technetium-99 (Tc-99), and thorium-232 (Th-232+C). Additionally, trace amounts of americium-241 (Am-241), neptunium-237 (Np-237+D) and plutonium-239/240 (Pu-239/240) may be present, however the latter are insignificant contributors to potential dose. Although Radium-226 (Ra-226+C) was identified as an ROC site-wide, it was not identified as an ROC in the buildings and associated piping.
- 2. Identify the Decision The DP, in conjunction with the associated implementing procedures, was used to demonstrate that the piping met the criteria for unrestricted release (25 millirem per year total effective dose equivalent [TEDE]) as specified in 10 CFR 20.1402. Compliance with the release criteria was satisfied using the guidance provided in MARSSIM, the DP, and associated Hematite approved procedures.
Radionuclide-specific DCGLs for piping were developed as described in Chapter 5 of the DP. The exposure scenarios included building occupancy under two CSMs having different room sizes (i.e., Small Offices and Large Warehouse). Piping DCGL (DCGLPD) was also derived using RESRAD, version 6.4 for a range of pipe diameters.
For simplicity and conservatism, the small office DCGL (DCGLSO) was initially applied to piping as the release criteria.
Since these values are radionuclide-specific release criterion, the values cannot be applied directly to field measurements of gross activity. To account for this, gross activity limits (alpha-plus-beta, or beta only depending upon the detector) were derived based on the isotopic distribution of radionuclides that could be measured using field instrumentation, and accounting for the distribution of all other undetected radionuclides that may be present. These initial isotopic distributions were used to determine a gross activity value that was equivalent to the DCGLSO. The resultant gross activity DCGLSO is provided in Table 3-3.
Additionally, a gross activity DCGL (DCGLPD) was developed for piping as a function of pipe diameter. In the event that levels of residual contamination were found to exceed the DCGLSO, the DCGLPD for the specific pipe diameter would serve as the comparator for individual measurement results to determine if the piping may be grouted in-situ and meet the dose-based criterion rather than excavate the piping.
- 3. Identify Inputs to the Decision Decision inputs determine the acceptable risk of a decision error in the release of piping systems onsite. To minimize risk, the MARSSIM process applies the graded approach
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 11 of 37 that places greater survey efforts on areas with the highest potential of contamination.
Inputs to the decision process were based on:
A comparison of scanning surveys (gross activity, alpha + beta, or beta depending on the detector) to the DCGLSO or DCGLPD, Results from statistical testing of data obtained by static measurements measuring total activity including fixed and removable contamination, and A determination of whether data are of sufficient quality and quantity.
The appropriate DCGL is used as the comparator to the data collected by these activities in the decision making process.
- 4. Define the Study Boundaries The study boundaries consisted of piping that existed prior to surveying and remediation that had the potential to remain at the time of license termination. This included sections of the piping indicated in Table 2-1.
Not all piping systems had the same potential for contamination and therefore did not require the same level of survey coverage to achieve an acceptable level of confidence that it met the release criteria. As provided in Westinghouses response to RAI HDPC-14-Q6 Westinghouse letter HEM-12-73 {ML12187A121}, the piping systems were sub-divided based on potential for contamination and identified as either Class 1 or Class 3 as indicated in Table 2-1.
The piping was further sub-divided into three survey areas based on physical arrangement. These survey areas were comprised of the Storm Drains, Sanitary/Gray Water Drain Systems and the Public Water System as indicated in Table 2-1. The Storm Drains and Sanitary/Gray Water Drain Systems were identified as Class 1 piping survey units, while the Public Water System was considered Class 3 piping survey unit. As shown in Table 2-1, each Class 1 survey area was to be further subdivided based on the amount and size of the piping, such that the total estimated surface area inside the piping within each piping survey unit was well within the suggested survey unit maximum sizes by classification as recommended by MARSSIM.
- 5. Develop a Decision Rule The decision rule is the determination of whether residual activity exceeds the DCGL.
If all measurements are less than the gross activity DCGLSO and the DQO have been met, then no additional investigation is required and the piping survey unit is recommended for unrestricted release.
If any individual measurement exceeds the gross activity DCGLSO but does not exceed gross activity piping DCGLPD, an investigation is performed and documented.
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 12 of 37 o If the average gross activity level within a section(s) of piping containing the elevated result(s) does not exceed the DCGLSO, the piping survey unit is recommended for unrestricted release.
o In the unlikely event buried piping to remain exceeded the DCGLSO and could not be practically decontaminated or removed, HDP was to verify the piping met DCGLPD and grout the piping in place. HDP would evaluate the specific dose from piping to be left and account for this dose in the affected piping survey unit. The specific dose from piping to be left would be determined on a case-by-case basis using specific piping characteristics and a modeling program (e.g., MicroShield1).
If any individual measurement exceeded the gross activity DCGLPD, the section of piping containing individual measurements exceeding the piping DCGLPD would be further decontaminated and re-surveyed, or excavated and removed. For piping surveys, the Sign test was applied using a direct comparison to the DCGLSO. In the event that a piping survey unit did not meet the release criterion, a retrospective power analysis was used to determine if this is due to excess residual radioactivity or if it is due to an inadequate sample size. Retrospective power analyses, if necessary, was performed following the methods of MARSSIM Appendix I.9, Power Calculations for the Statistical Tests.
- 6. Specify Limits on Decision Errors The probability of making decision errors is part of the DQO process in establishing performance goals for the data collection design and could be controlled by adopting a scientific approach through hypothesis testing. In this approach, the survey results were used to select between the null hypothesis or the alternate condition (the alternative hypothesis) as defined and shown below:
Null Hypothesis (Ho) - The piping survey unit does not meet the release criterion;
- and, Alternate Hypothesis (Ha) - The piping survey unit does meet the release criterion.
The Type I decision error () would result in the release of a piping survey unit containing residual radioactivity above the release criterion or a false negative. This occurs when the null hypothesis is rejected when in fact it is true.
The Type II decision error () would result in the failure to release a piping survey unit when the residual activity is below the release criterion or a false positive. This occurs when the null hypothesis is accepted when in fact it is not true.
Following the guidance in NUREG-1757 (Reference 9.4), the decision error rates for FSSs designed at the HDP are established as follows: The value will be set at 0.05 unless prior NRC approval is granted for using a less restrictive value; and, The value is nominally set at 0.10, but may be modified, as necessary, after
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 13 of 37 weighing the resulting change in the number of required sampling and measurement locations against the risk of unnecessarily investigating and/or remediating piping survey units that are truly below the release criterion.
An index of sensitivity (d) represents the distance between the means of the background and background plus signal. For surface scanning, 1.38 was used as the value for d based on a true positive proportion of 0.95 and a false positive proportion of 0.60. This value is based on data contained in Table 6.5 of MARSSIM.
- 7. Optimize the Design for Obtaining Data The first six steps of the DQO process are used to develop the performance goals of the FSS. The final step in the process leads to the development of an adequate survey design.
In order to optimize the survey and to meet the DQOs, any available information is reviewed. This may include previous characterization surveys or preliminary survey data collected near the onset of the FSS. In the absence of data, assumptions are made in accordance with the guidance as provided in MARSSIM. This allows for proper survey planning and design as well as aids in ensuring piping survey units are established properly and that adequate data are collected.
5.0 FINAL STATUS SURVEY DESIGN The output for the FSS planning and design phase is the FSS piping plan. The general approach prescribed by MARSSIM for FSS requires that a minimum number of measurements or samples be collected within a survey unit so that statistical tests can be applied with adequate confidence. Decisions regarding whether a piping survey unit meets the applicable release criterion are described in the following sections.
Sample Size Determination The level of survey effort required for a given piping survey unit is determined by the potential for contamination as indicated by its classification. The number of systematic measurement locations is dependent upon the anticipated statistical variation of the final data set such as the standard deviation, the decision errors, and a function of the gray region as well as the statistical tests to be applied. The number of measurements is determined, using the sign test sample size values, (Table I.2 of MARSSIM) to establish the relative shift using the decision errors.
Reference Grid A one-dimensional reference grid will be used within the piping (e.g. a straight line down the bottom center of the pipe). The measurement spacing within each Class 1 piping survey unit is established by dividing the overall length of the pipe to be surveyed as part of the piping survey unit by the number of measurements required by the FSS plan. This results in a systematic (static) measurement frequency per unit length of piping.
As described above, the number of systematic measurements for all Class 1 piping has been calculated to be a minimum of 11 systematic locations. This value is based on the sign test with a predicted relative shift of 3. As part of the FSS planning process the
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 14 of 37 predicted relative shift is calculated for each survey unit. If the relative shift does not fall between 1 and 3, an adjusted LBGR is calculated to achieve a relative shift between 1 and 3. The adjusted LBGR may be set as low as the MDC for the specific analytical technique to achieve this, if necessary. The actual relative shift, and adjusted LBGR for each survey unit will be reported for each survey unit in subsequent chapters to this report, however as a matter of conservatism, the RSO has directed that 15 systematic locations be specified by the FSS plan for each piping survey unit. A reference grid was not established for the Class 3 piping survey units.
Scan Coverage The purpose of scan measurements is to confirm that an area was properly classified, and that any areas of elevated activity are identified. Depending upon the calculated sensitivity of the scanning method used, the number of static total surface contamination measurements is increased if the scanning sensitivity is greater than the DCGLSO. The scan coverage also depends upon the piping survey unit classification; Class 1 piping requires a higher degree of scan coverage than Class 3 piping.
Class 1 Piping Scan Coverage For Class 1 piping survey units, surface scans are performed on the interior bottom within the accessible piping to the maximum extent practical. The interior bottom of the piping was selected as the scan location as it is the most probable location that residual contamination would reside. Due to the remote nature of the piping surveys, 100 percent scan coverage is difficult, particularly at greater distances from the access locations. The goal for FSS is to ensure that all accessible piping is subjected to scan coverage and also an evaluation of sections of piping between access locations where full scan coverage is not achieved. The evaluation considers the results of the scanned areas and the static measurements performed within the accessible portions of the piping, and also the information obtained from the visual inspections, to determine if the type and number of measurements are adequate. The evaluation described in this section is consistent with the direction provided in Section 6.4.5 of NUREG/CR-5849.
Class 3 Piping Scan Coverage Class 3 piping survey units are subjected to judgmental or biased surface scan coverage at access locations identified by the Health Physics (HP) Staff. Given the very low probability of the public water supply containing licensed radioactivity, a minimum of 11 locations of all of the Class 3 piping will be selected for survey.
6.0 FINAL STATUS SURVEY Final status surveys are conducted to compile data of adequate quantity and quality to demonstrate the annual dose associated with residual activity in piping and the Land Survey Area in which it resides meets the dose criterion for license termination specified in the Code of Federal Regulations (CFR) Title 10, Part 20.1402, Radiological Criteria for Unrestricted Use.
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 15 of 37 Instrument Selection The radiation detection instrumentation selected is based upon the pipe diameter to be surveyed, with the intent to position the face of the detector as close to the piping surface to be surveyed as possible. Due to the size of piping left in place, the only detector selected to perform FSS was a Ludlum Model 43-68 (126 cm2 flat gas flow proportional detector). This detector was either pushed or pulled through the pipe using the instrument mounted on a sled in areas that could not be reached by hand holding the instrument. In addition, a small remotely operated cart was used with a camera to conduct visual inspections inside the piping.
Instrument Calibration and Efficiency Calculation Each Ludlum Model 43-68 used to perform FSS was calibrated with sources traceable to the National Institute of Standards and Technology (NIST), and representative of the type and energy of the radiations emitted by the ROC for an 8 inch diameter pipe. The detectors are calibrated in a similar geometry, with a similar cable length, and with the source presented at a distance that approximates the distance to the surface of the piping that was used during the survey. This calibration is applicable to all piping that will remain at the time of license termination with the exception of the SWTP piping. As the SWTP piping is 6.75 inches in diameter, as required by HDP-PO-FSS-800 a weighted detection efficiency was calculated for this piping.
Instrument Detection Sensitivity Instrument detection sensitivities depend upon the measurement geometry, instrument efficiencies, count times and scan speeds. Both scan and static measurement sensitivities for the various piping detectors were determined using the guidance in Chapter 14 of the DP, and as specified below:
The scan MDC was estimated for a 126 cm2 gas proportional detector with a thin Mylar window (0.8 mg/cm2). The surveyor efficiency (p) will be 0.5, as recommended by MARSSIM and NUREG-1507. The probe area is 126 cm2 with a nominal background count rate of 300 cpm for poured concrete. The total weighted efficiency was estimated to be 0.16 based on nominal instrument efficiencies for 4.5 percent U-235 enrichment.
The estimated scan MDC for building and structural surfaces (piping is considered a structural surface) is calculated to be 1,299 dpm/100 cm2 and is illustrated below.
2 cm dpm/100 299
,1 100 126 16
.0 5.0 1
60 60 1
300 38
.1
=
x x
x x
x
=
MDC Scan Equation 6.1 The static MDC was estimated for a 126 cm2 gas proportional detector with a thin Mylar window (0.8 mg/cm2) and a nominal background count rate of 300 cpm. The total weighted efficiency was calculated to be 0.16 based on nominal instrument efficiencies
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 16 of 37 for 4.5 percent U-235 enrichment. The estimated static MDC for building surfaces is calculated to be 415 dpm/100 cm2.
2 cm dpm/100 415 100 126 1
16
.0 1
1 1
1 300 29
.3 3
=
x x
+
x x
x
+
=
MDC Equation 6.2 Piping Isolation and Control As previously described, based upon the visual inspection results, piping was required to be cleaned in order to remove the buildup of sediment and materials. Prior to commencing FSS on a section of piping it was verified by remote camera inspection to be clean and absent of obstructions that would prevent FSS. To maintain isolation and control of piping, as previously described, in preparation for the abandonment and FSS of storm water drain piping, surface soil was contoured and a swale that directs the surface water runoff from the site parking lot and area near Building 110 to bypass the storm water drains was installed. Figure 2-13 is a photograph of the installed swale that isolates and controls the storm water drain piping designated to undergo FSS. Also, the storm water downspouts associated with Buildings 110 and the north and west sides of Building 230 that had previously drained into this same storm water drain piping were redirected to divert rainwater to this diversion swale. On the east and south sides of Building 230 the downspouts have also been diverted to flow onto the ground surface not requiring remediation. These areas have been graded for storm water to flow to a low area southeast of Building 230 or directly towards the Site Pond.
Additionally some of the piping sections were also ventilated and heated in order to dry surfaces prior to survey. Figure 2-14 is a photograph of a portable ventilation and heating unit in operation drying a section of storm water drain piping.
Survey Methods The survey methods employed by the FSS for piping consisted of a combination of interior surface scans of the bottom accessible portions of the piping, static measurements at judgmental and biased locations and an interior visual inspection. Smear samples and/or sediment and scale samples were collected to confirm, or update the isotopic distribution.
Scan Surveys For Class 1 piping, scan surveys are performed to the maximum extent practical over the length of the bottom portions of the piping. Surface scans were performed either by pushing the detector into the piping or by pulling the detector through the piping from the opposite end. Figure 2-15 is a photograph of a detector unit at the access point of the SWTP piping. Scan speeds were controlled to ensure detection sensitivities below the DCGLSO.
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 17 of 37 For Class 3 piping, scan surveys were performed only within the immediate vicinity of the access locations.
Static Measurements For the purposes of FSS, piping surveys units are treated as Structures and piping static measurement locations are determined in a manner similar to that of building structures.
For Class 1 piping, static measurements were performed at systematic locations along the length of the piping. The measurement frequency was determined by the overall length of the piping within the piping survey unit and the number of measurements required.
Additional static measurements were performed at locations of elevated count rate (biased) that are observed during the scan survey, or at locations where visual inspection identified cracks or breaks in the piping. Biased measurement results were not included in the statistical evaluation, but are directly compared to the DCGLSO.
For Class 3 piping, static measurements were collected at the accessible openings of piping.
Smears and Sediment Samples Each FSS piping plan indicated that smear samples will be collected from the accessible openings of the piping whenever a scan survey is performed. Additional smear surveys were performed on the interior portions of manholes or culverts that provided access to piping. Due to the difficulty in accessing interiors of the piping due to length it was not possible to collect smear surveys beyond the accessible openings of any Class 1 or Class 3 piping.
In regards to sediment samples, due to the effectiveness of the pipe cleaning there was and is not expected to be any sediment available in the piping to take a sediment sample at the time FSS was or is going to be performed. Data from previously collected sediment samples are presented in the piping survey area release record, along with the final survey data, for informational purposes, however sediment sample results were not included in the statistical evaluation.
7.0 DATA QUALITY ASSESSMENT The Data Quality Assessment (DQA) process is used during the evaluation phase of the FSS of piping to ensure the validity of results and to demonstrate the survey plan objectives have been achieved. The DQA process includes a review of the DQOs, the adequacy of the survey plan, assumptions regarding the isotopic distribution and associated gross activity limit, assumptions regarding the required number of measurements, and the appropriateness of the statistical testing. A summary of the DQA process is provided in the following sections.
Review of the DQOs and Survey Design Prior to subjecting the data to statistical tests and comparing it to the release criterion, the data was confirmed to have been collected in accordance with applicable procedures,
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 18 of 37 survey plan and QA/QC requirements. This evaluation included a confirmation, by review of the daily instrument response checks that the instrumentation was operating properly. The survey documentation was reviewed to ensure the prescribed number of measurements were collected, and that the detection sensitivity met the DQO. Any discrepancies between data quality or the data collection process and applicable survey requirements were resolved and documented during data analysis.
Data Review The net results were then converted to standard units of reporting for comparison to the DCGL by applying the weighted detection efficiency and any correction for the surface area of the detector. Basic statistical quantities were calculated for the sample data set from systematic static measurements including the maximum, mean, median and standard deviation. An initial assessment of the measurement results and any sample data was used to determine whether the survey unit met the release criteria. Interpreting the results for the piping surveys was straightforward with an initial comparison to the DCGLSO or the DCGLPD.
Any individual measurement exceeding the DCGLSO was further evaluated against the piping DCGLPD.
Sections of piping containing individual measurements that exceed the DCGLSO, but are less than the DCGLPD were evaluated to determine the need for further decontamination and re-survey, or grouting the portion of the piping containing elevated activity in preparation for leaving in place.
Sections of piping containing individual measurements exceeding the piping DCGLPD were further decontaminated and re-surveyed, or excavated and removed.
Sign Test Section 14.4.2.5 of the DP states that the sign test will be used to evaluate surface contamination measurements on building surfaces. The sign test was applied to the piping survey units since the interior of the piping was considered a structural surface and the structural surface DCGLso values was used to evaluate the survey measurements. The Sign Test was applied using the systematic measurements obtained from within piping.
The Sign test was based on net FSS results; the net results were obtained by subtracting the instrument response to ambient conditions from the gross results, but did not include a correction for the response due to naturally-occurring radioactivity in construction materials.
The Sign Test was conducted as described below:
- 1. Each piping survey unit measurement was listed. This consisted of the net radioactivity measurement by subtracting the instrument response to ambient conditions from the gross results. This consisted only of the systematic sampling and measurement locations to avoid bias in the statistical evaluation.
- 2. Each measurement was subtracted from the DCGLSO (or DCGLPD).
- 3. Differences where the value was exactly zero were discarded and the number of measurements reduced by the number of such zero measurements.
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 19 of 37
- 4. The number of positive differences was then totaled. Measurements that were less than the release criteria provided evidence that the piping survey unit met the site release criterion. The resulting total was the test statistic (S+), or critical value.
- 5. The critical value (S+) was then compared to the critical value as provided in Appendix I, Table I.3 of MARSSIM, for the total number of measurements taken and the corresponding decision error (), which was set at 0.05. Provided the critical value, S+, was greater than the value as given in the reference table, the null hypothesis was rejected and the piping survey unit met the release criterion. If the critical value, S+, was less than or equal to the value, the piping survey unit failed to meet the release criterion. In the event that the Sign Test failed, the piping survey unit was re-evaluated to determine whether additional remediation was required or the FSS re-designed to collect more data (i.e., a higher frequency of measurements and samples).
Piping Survey Unit Dose Contribution Assessment Any piping that was to be grouted in place would be further evaluated using MicroShield1 modeling as described in Attachment 4 to HEM-10-85, Response to Request for Additional Information Concerning Hematite Decommissioning Plan:
Chapter 5, Dose Modeling {ML102290015} to assess any potential exposure to the public in the event that piping is removed following license termination. This dose contribution would have then been summed with the contribution to dose from the soil within the applicable piping survey unit. The assessment of potential exposure to the public was not necessary as no piping was expected to be grouted.
Elevated Measurement Comparison The Elevated Measurement Comparison (EMC) will not be applied to the results of piping surveys. Any piping that does not meet the DCGLso is further evaluated as described in the following section. Currently all remaining piping is believed to meet the DCGLso.
Data Conclusions The data evaluation results in one of two conclusions consistent with the decision rules discussed previously.
If all measurements were less than the gross activity DCGLSO and the DQO were met, then no additional investigation was required and the piping survey unit was recommended for unrestricted release.
In the event buried piping to remain exceeded DCGLSO and could not be practically decontaminated or removed, HP verified the piping met the DCGLPD and grouted the piping in place. HP evaluates the specific dose from piping to be left and accounts for the dose in the affected piping survey unit. If any individual measurement exceeded the gross activity DCGLPD, the section of piping containing individual measurements exceeding the piping DCGLPD was further decontaminated and re-surveyed, or excavated and removed.
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 20 of 37 The Sign test was applied to the static measurements obtained at systematic locations and compared to the DCGLSO. In the event that a piping survey unit did not meet the release criterion, a retrospective power analysis would be used to determine if it was due to excess residual radioactivity or if it was due to an inadequate sample size. Retrospective power analyses, if necessary, were performed following the methods of MARSSIM Appendix I.9, Power Calculations for the Statistical Tests.
8.0 SURVEY AREA RELEASE RECORD ORGANIZATION In accordance with HDP-PO-FSS-700, Final Status Survey Program, documentation of the FSS will result in two types of reports, FSS Survey Area Release Records and an FSS Final Report, and will be consistent with Section 8.6 of NUREG-1757, Volume 2, Consolidated Decommissioning Guidance - Characterization, Survey, and Determination of Radiological Criteria.
The FSS Final Report will incorporate multiple Volumes. The first Chapter of Volumes 1 through 6 will include general information and an overview of the FSS Program for that subject area (Volume 2 Reuse Soil, Volume 3 Land Survey Areas, Volume 4 Building Survey Areas, Volume 5 Piping Survey Areas, Volume 6, and Groundwater).
Subsequent Chapters (beginning with Chapter 2) within these Volumes will contain FSS Survey Area Release Records.
Survey Area Release Records are prepared to provide a record of the composition and location of the survey area; the measurements obtained during the FSS; the number and location of any small areas of elevated concentration; and a summary of the data that represents the final radiological condition, including a determination that an individual survey area/unit meets the release criteria.
The Piping Survey Area Release Records will be formatted to contain the following information:
- An Introduction section which will include Piping Survey Area specific information (e.g., geographical location/description, summary of historical radiological data).
- A description of the specifics of FSS Protocol and DQOs, including but not limited to:
Piping Survey Unit designation and classification.
Background determination.
Instrumentation (detector efficiencies, detector sensitivities, instrument maintenance and control and instrument calibration).
Survey methodology and protocols.
QC surveys.
- A Conclusion section which provides an overall assessment of the FSS of the piping survey unit.
- Supporting documents (e.g., spreadsheets, statistical analyses, figures, tables).
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 21 of 37
9.0 REFERENCES
9.1 DO-08-004, Hematite Decommissioning Plan (DP) {ML092330123}
9.2 Code of Federal Regulations, Title 10, Part 20.1402, Radiological Criteria for Unrestricted Use 9.3 U.S.
Nuclear Regulatory Commission, NUREG-1507, Minimum Detectable Concentrations with Typical Radiation Survey Instruments for Various Contaminants and Field Conditions 9.4 NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) 9.5 NUREG-1757, Volume 2, Consolidated NMSS Decommissioning Guidance -
Characterization, Survey, and Determination of Radiological Criteria 9.6 ISO Standard 7503-1 Evaluation of Surface Contamination - Part 1: Beta Emitters (Maximum Beta Energy Greater than 0.15 MeV) and Alpha Emitters 9.7 DO-08-005, Historical Site Assessment (HSA), July 2009 {ML092870417}
9.8 DO-08-003, Radiological Characterization Report, July 2009 {ML092870496}
9.9 Westinghouse Letter HEM-10-85, Response to Request for Additional Information Concerning Hematite Decommissioning Plan:
Chapter 5,
Dose Modeling
{ML102290015}
10.0 APPENDICES Appendix A HDP Procedure Revision History Appendix B HDP FSSFR PSA Document Matrix
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 22 of 37 Table 2-1 Pre-Remediation Piping Inventory System Figure 2-1 Reference ID#
Survey Unit #
Depth BGS (inches)
Cover Length (feet)
Diameter (inches)
Surface Area (m2)
Storm Drain(s) - Class 1 Survey Area #1 Bldg. 110 SE STM-1 1
60 asphalt 172 12 50.2 Bldg. 110 NW and West STM-2 2
60 soil/asphalt 209 15 76.2 Bldg. 230 SE STM-3 3
60 concrete 237 18 103.8 Bldg. 230 South STM-4 4
60 asphalt/soil 235 18 102.9 Bldg. 230 North Corner STM-5 5
60 asphalt 26 30 19 Bldg. 230 NW **
STM-6 6
60 asphalt 249 36 218 Bldg. 230 - 101 Leg STM-7 7
60 soil/asphalt 71 15 25.9 Bldg. 240 North Corner STM-8 8
60 asphalt 22 18 9.6 Bldg. 240 NW STM-9 9
60 asphalt 140 24 81.7 Bldg. 230 South Interior Drains STM-10 10 36 concrete 155 4
15.1 Bldg. 230 NE STM-11 11 60 soil 58 24 33.9 Bldg. 230 NE STM-12 12 60 soil 15 18 6.6 Discharge Leg STM-13 13 60 soil 59 36 51.7 Discharge Leg Outlet STM-14 14 60 soil 59 42 60.3 Survey Area #1 Totals:
1,707 n/a 854.9 Sanitary / Gray Water Drains - Class 1 Survey Area #2 Bldg. 110 Sanitary SAN-1 1
48 concrete/asphalt 124 4
12.1 Bldg. 230 north Sanitary SAN-2 2
36 concrete/soil 130 4
12.6 Bldg. 230 north Gray SAN-3 3
36 concrete/soil 155 4
15.1 Bldg. 230 south Sanitary SAN-4 4
60 concrete/soil 80 4
7.8 Bldg. 240 NW - Gray SAN-5 5
48 asphalt 297 8
57.8 Bldg. 240 NW - Sanitary SAN-6 6
60 asphalt 291 8
56.6 Bldg. 240 South - Gray to Sanitary Connection SAN-7 7
48 asphalt 207 8
40.3 Bldg. 240 south - Sanitary to Treatment Plant SAN-8 8
60 asphalt 301 8
58.6 Survey Area #2 Totals:
1,585 n/a 260.9
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 23 of 37 Table 2-1 (Continued)
Pre-Remediation Piping Inventory System Figure 2-1 Reference ID#
Survey Unit #
Depth BGS (inches)
Cover Length (feet)
Diameter (inches)
Surface Area (m2)
Public Water System (County Water District) and Raw Water System - Class 3 Survey Area #3 to Building 110 WAT-1 1
36 soil 266 2
12.9 to Building 230 WAT-2 1
48 asphalt 252 2
12.2 to Building 231 WAT-3 1
60 concrete/soil 355 8
69.0 to Building 115 WAT-4 1
48 soil 94 10 23.0 to Hydrants WAT-5 1
60 soil/asphalt 1,761 8
342.6 Main along Hwy. P, within right of way WAT-6 1
60 soil 2,733 6
398.9 Old Main along Hwy. P, north parking lot WAT-7 1
60 soil 1,034 10 251.6 Raw Water WAT-8 1
60 soil 639 10 155.4 Survey Area #3 Totals:
7,134 n/a 1,265
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 24 of 37 Table 2-2 Post-Remediation Piping Inventory System Figure 2-3 Reference ID#
Survey Unit #
Depth BGS (inches)
Cover Length (feet)
Diameter (inches)
Surface Area (m2)
Storm Drain(s) - Class 1 Survey Area #1 Bldg. 110 N, W (CO to MH-19 to MH-07 to MH-25)
STM-1 01 60 Soil/asphalt 137/76 12/15 68 Bldg. 110 S (MH-18 to East STM-2 02 60 soil/asphalt 170/101 12/18 94 Parking Lot S (West breach to 50 past MH-24)
STM-3 03 60 Concrete/
asphalt 44/25/50 24/30/36 89 Parking Lot S (50 past MH-24 to C124B)
STM-4 04 60 asphalt 105 36 92 Parking Lot S (C124B to MH-02)
STM-5 05 60 asphalt 95 36 84 MH-02 to Outfall STM-6 06 60 Asphalt/soil 55/50 36/42 100 MH-31 South to MH-02 STM-7 07 60 asphalt 73 15 27 Bldg. 230 W (MH-02 to MH-01)
STM-8 08 60 asphalt 230 18 101 Bldg. 230 S (MH-01 to MH-22)
STM-9 09 60 concrete 206 18 90 Survey Area #1 Totals:
1,417 N/A 745 System Figure Reference ID#
Survey Unit #
Depth BGS (inches)
Cover Length (feet)
Diameter (inches)
Surface Area (m2)
Sanitary / Gray Water Drains - Class 1 Survey Area #2 Former SWTP Discharge Line SAN-1 01 60 Concrete/soil 293 6.75 46.5 Survey Area #2 Totals:
293 n/a 46.5 System Figure Reference ID#
Survey Unit #
Depth BGS (inches)
Cover Length (feet)
Diameter (inches)
Surface Area (m2)
Public Water System (County Water District) and Raw Water System - Class 3 Survey Area #3 to Building 110 WAT-1 1
36 soil 266 2
12.9 to Building 230 WAT-2 1
48 asphalt 252 2
12.2 to Building 231 WAT-3 1
60 concrete/soil 355 8
69.0 to Building 115 WAT-4 1
48 soil 94 10 23.0 to Hydrants WAT-5 1
60 soil/asphalt 1,761 8
342.6 Main along Hwy. P, within right of way WAT-6 1
60 soil 2,733 6
398.9 Old Main along Hwy. P, north parking lot WAT-7 1
60 soil 1,034 10 251.6 Raw Water WAT-8 1
60 soil 639 10 155.4 Bldg. 110 / 230 Downspouts DRN-X 02 Varies Soil/varies Varies Varies Varies Survey Area #3 Totals:
7,134 n/a 1,265
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 25 of 37 Table 3-1 Site Specific Building and Structural Surface DCGLs Radionuclide Occupancy DCGLw (dpm/100 cm2)a By Conceptual Site Model Small Office Large Warehouse U-234 20,000 49,000 U-235 + D b 19,000 37,000 U-238 + D b 21,000 49,000 Tc-99 13,000,000 13,000,000 Th-232 + C c 1,200 2,200 Np-237 + D b 2,700 4,000 Pu-239/240 3,500 5,300 Am-241 3,400 5,100 a
The reported building DCGLs are in gross radioactivity limits rounded down (truncated) to two significant figures.
b
+ D = plus short-lived decay products.
c
+ C = plus the entire decay chain (progeny) in secular equilibrium.
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 26 of 37 Table 3-2 Buried Pipe Gross Activity DCGLs a The Gross Activity DCGL is based on the Root DCGLs for soil and the Activity Fractions from building drain samples.
Note: To ensure conservatism, HDP will utilize the Building DCGLs (Small Office) as release criteria for buried piping to remain in place. In the unlikely event buried piping to remain exceeds Building DCGLs and cannot be decontaminated or removed, HDP will verify the piping meets Buried Pipe DCGLs (above) and grout the piping in place.
Buried Pipe Diameter (inches)
Gross Activity DCGL (dpm/100cm2)a 2
81,086 4
162,172 6
243,258 8
324,344 10 405,430 12 486,516 14 567,602 16 648,689 18 729,775 20 810,861 22 891,947 24 973,033 26 1,054,119 28 1,135,205 30 1,216,291 32 1,297,377 34 1,378,463 36 1,459,549 38 1,540,635 40 1,621,721 48 1,946,066
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 27 of 37 Table 3-3 Initial Isotopic Distribution a Values are as reported in Table 4-1 of the DP, Reference 9.1.
Radionuclide Radioactivity Fraction a U-234 8.27E-01 U-235 + D b 3.72E-02 U-238 + D b 1.27E-01 Tc-99 2.83E-03 Th-232 + C c 3.21E-03 Np-237 + D b 5.57E-05 Pu-239/240 2.03E-06 Am-241 2.68E-03 Sum of fractions for Uranium Only 9.91E-01 Sum of fractions for all Radionuclides 1.00E+00
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page 28 of 37 Table 3-4 Gross Activity DCGLSO for Small Offices a Values are calculated using Equation 4-4 of MARSSIM, Reference 9.4.
Radionuclide DCGLSO (dpm/100 cm2) fi fi / DCGLSO a
U-234 20,000 8.27E-01 4.14E-05 U-235 + D 19,000 3.72E-02 1.96E-06 U-238 + D 21,000 1.27E-01 6.05E-06 Tc-99 13,000,000 2.83E-03 2.18E-10 Th-232 + C 1,200 3.21E-03 2.68E-06 Np-237 + D 2,700 5.57E-05 2.06E-08 Pu-239/240 3,500 2.03E-06 5.80E-10 Am-241 3,400 2.68E-03 7.88E-07
( fi / DCGLSO) a 5.28E-05 Gross DCGL = (1 / ( (fi / DCGLSO,i)) a (dpm/100 cm2) 18,925
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: I Page29 of37 Figure 2-l Hematite Class I Piping (Storm, Sanitary/Gray)
- -orr-!-t" fH" ad sToft$ sEX'ER 0
50 Eo r20 SCAlE 1'-
GO' LEGEND RETllO\\IE RAIOT'E PIPIilG HIHTN FIfi)TPIUNT OF PROCESS BIXLOING 9.AAS PO1ENNAL DE@I{TAMNANO{,/9JNVEY SURVF, qilLY Hludits Dcosmmiseioning hoj oct JeffersonC,ouff)r Eerratite, MO
Hematite Decommissioning Project FSSFR Volume 5, Chapter l: Piping Survey Areas (PSA) Overview Revision: 1 Page 30 of37 Figure 2-2 Hematite Class 3 Piping (Public Water)
LECE\\D Public \\vflcr LirE
-.- Abntrdoncd Public warcr LirN Rr\\'\\\\iter l-inc Stof,lgc Trnli L-- l Eunal Pir Arcn Surfflcc \\\\'alcr I
NE Sile Creck DiveEion
.] Divcncd Crcck E!aporalioD Ponds
[_-l Propent Boundarl E
Buildirgs E Fonncr Blde Foorprinl Roud
...._ Railrord Fcrcc lir t..r
.r4.
'.'{.Y':c,
'r - )'r Ptrblic Waler Lir)cs Ctnrrl Sitc Tract Hcrutile DEotrurissioilirg l'mjccl JcllLrson Cotrnll Hcnrarirc. MC)
Hematite Decommissioning Project FSSFR Volume 5, Chapter 7: Piping Survey Areas (PSA) Overview Revision: I Page 31 of37 Figure 2-3 Storm and Sanitary Piping Remaining at License Termination
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: I Page 32 of 37 Figure 2-4 Pipe Cleaning Contractor
-*il-..
.-,. fr i..--v I
!+
Figure 2-5 Pipe Cleaning Crawler Unit L.. '
..Af'a*
ai
\\
-2
Hematite Decommissioning Project FSSFR Volume 5, Chapter l: Piping Survey Areas (PSA) Overview Revision: I Page 33 of37 Figure 2-6 Pipe Cleaning of Storm Water Drain Piping Figure 2-7 Example of Storm Drain Manhole Prior to Cleaning 09 iliil{
,09.09 ri9.l! !:iL-tc
- d. U r' I'
- IlF':
G?iT
!'-rF : n{-tr
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: I Page 34 of 37 Figure 2-8 Example of Storm Water Drain Manhole After Cleaning (Remaining sediment removed manually)
I'rt\\Il 1-4 I
Example of Storm Figure 2-9 Water Drain Piping Prior to Cleaning
Hematite Decommissioning Project FSSFR Volume 5, Chapter l: Piping Survey Areas (PSA) Overview Revision: I Page 35 of37 Figure 2-10 Example of Storm Water Drain Piping After Cleaning I{I Figure 2-11 Access to the SWTP Piping
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: I Page 36 of37 Figure 2-12 Natural Gas Pipe Line (during soil remediation) rl i_
-r**$-*-r
-b
'\\
',b-, t Figure 2-13 Swale that Isolates and Controls a Section of Storm Water Drain Piping
Hematite Decommissioning Project FSSFR Volume 5, Chapter l: Piping Survey Areas (PSA) Overview Revision: I Page37 of37 Figure 2-14 Heating/Ventilation Unit Drying a Section of Storm Water Drain Piping Figure 2-15 Detector Unit Accessing the SWTP Piping 1.
I I
I t
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page A-1 of 5 Volume 5 Chapter 1-Appendix A HDP Procedure Revision History HDP-PO-FSS-700 Final Status Survey Program Revision Number Effective Date Summary of the Revision 0
01/16/2012 Initial issuance of the policy. Implements the requirements of the Final Status Survey plan contained within the DP.
1 12/04/2012 Updated policy to include soil sampling requirements during the abandonment of hybrid wells, per Section 14.4.3.4.2 of the DP.
2 01/31/2013 Updated Section 13, Final Status Survey Reporting to reflect the changes of Section 14.6 in the DP.
3 11/26/2014 Revision included clarifications and enhancements.
4 02/19/2015 Added information regarding scan MDCs and revised wording to be consistent with Westinghouse letter HEM-11-56.
5 10/28/2015 Changed policy to Westinghouse Proprietary Class 2. No technical changes.
6 04/07/2016 The revision incorporates a
new section 15 SURVEILLANCE FOLLOWING FSS as a component of a corrective action to a Notice of Violation. Clarifications have been made to section 9.7 regarding isolation and control.
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page A-2 of 5 Volume 5 Chapter 1-Appendix A HDP Procedure Revision History HDP-PO-FSS-800 Final Status Survey Plan for Piping Revision Number Effective Date Summary of the Revision 0
- N/A
- HDP-PO-FSS-800 Revision 0 was approved but never Implemented. Rev. 0 received HDP managerial approval (HDP-PO-FSS-800 R0 Record Note) in order to be transmitted to the NRC in request of comments on this document (HEM-12-73). Comments were received from the NRC (HEM-13-NRC-0405-282), and will be incorporated into Revision 1 (below). HDP-PO-FSS-800 Revision 0 will be posthumously approved in EDMS on the Effective date of Revision 1 in order to complete Form 36 archive requirements resulting from interconnecting the Form 36 to Rev. 0 of the Policy instead of the transmitting correspondence.
1 06/15/2015 Revision incorporates changes in response to NRC comments received on April 5, 2013; specifically:
Section 9.4.2 and accompanying Table A-1 revised to divide survey units into appropriate sized areas based on MARSSIM guidance for structural survey units. Section 12.3 revised to provide additional clarification on the basis for use of the sign test for evaluation of systematic measurements. Administrative and formatting corrections.
2 10/28/2015 Changed policy to Westinghouse Proprietary Class 2. No technical changes.
3 03/11/2016 Updated the table containing the piping that will undergo FSS.
Updated text in section 14.5.1 to be compliant with HDP-PR-FSS-3
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page A-3 of 5 Volume 5 Chapter 1-Appendix A HDP Procedure Revision History HDP-PR-FSS-701 Final Status Survey Plan Development Revision Number Effective Date Summary of the Revision 0
01/16/2012 Initial issuance of the procedure.
1 02/04/2013 Provided clarification on soil sampling by stratum as indicated in Decommissioning Plan Table 14-24.
2 02/12/2013 Provided additional instructions for creating FSS Plans for Reuse Soil.
3 11/26/2014 Significant revision for clarification and minor corrections.
4 01/07/2015 Subsequent to comments received by NRC Region III regarding content of this procedure a technical readiness review was performed and the procedure revised accordingly.
5 02/11/2015 Updated the scan MDCs for U, Th-232 and Ra-226.
6 03/25/2015 Clarification of guidance for background ranges including acceptable ranges for use of a 10,000 cpm background for calculations and direction when background values are outside that range or survey parameters differ from those in HDP-TBD-FSS-002.
7 06/15/2015 Added information regarding piping survey plans, updated Ra-226 in-growth background value, clarified mean of SO equation, added direction on adjusting grid spacing to account for potential Tc-99 hotspots.
8 08/21/2015 The revision is initiated upon an agreement between the NRC and Westinghouse HDP in regards to Tc-99 sidewall sampling.
The agreement was reached during a
NRC Public Teleconference Meetings held on August 12, 2015, and August 19, 2015 9
10/28/2015 Changed procedure to Westinghouse Proprietary Class 2. No technical changes.
10 11/19/2015 Resolution and clarification of 100% GWS based on discussions with NRC Headquarters.
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page A-4 of 5 Volume 5 Chapter 1-Appendix A HDP Procedure Revision History HDP-PR-FSS-703 Final Status Survey Quality Control Revision Number Effective Date Summary of the Revision 0
01/16/2012 Initial issuance of the procedure.
1 11/26/2014 Clarification for SSC Survey units.
2 10/28/2015 Changed procedure to Westinghouse Proprietary Class 2. No technical changes.
HDP-PR-FSS-720 Final Status Survey Data Integrity and Database Management Revision Number Effective Date Summary of the Revision 0
09/13/2011 Initial issuance of the procedure.
1 01/13/2015 Revised section for Data Download to update the process for downloading data to a FSS computer that is password protected. Inclusion of a section to review and store GWS data.
Addition of new Data Download Report Form. Changed back up of FSS data from being backed up as part of the routine site media backup process to being backed up on a password protected external hard drive and included a minimum frequency of weekly for hard drive backup.
2 10/28/2015 Changed procedure to Westinghouse Proprietary Class 2. No technical changes.
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page A-5 of 5 Volume 5 Chapter 1-Appendix A HDP Procedure Revision History HDP-PR-FSS-722 Final Status Survey Reporting Revision Number Effective Date Summary of the Revision 0
09/13/2011 Initial issuance of the procedure.
1 02/05/2015 Updated to reflect changes to HDP-PO-FFS -700 regarding FSS reporting.
2 01/31/2014 Removed the formatting guidelines which were contained in Appendix A and B.
3 01/13/2015 Editorial corrections.
4 11/06/2015 Changed procedure to Westinghouse Proprietary Class 2.
No technical changes.
Hematite Decommissioning Project FSSFR Volume 5, Chapter 1: Piping Survey Areas (PSA) Overview Revision: 1 Page B-1 of 1 Appendix B HDP FSSFR PSA Document Matrix Survey Unit Description FSS Class FSS Complete Date Assigned FSSFR Volume 5 Chapter Number Date Submitted to NRC PSA-01 Storm Drains PSA-01-01 Building 110 Storm Drain (STM-1) 1 11/24/15 3
PSA-01-02 Building 110 to Building 230 Storm Drain (STM-2) 1 02/11/16 3
PSA-01-03 Building 230 North Storm Drain (STM-3) 1 01/29/16 3
PSA-01-04 Building 230 North Storm Drain (STM-4) 1 3
PSA-01-05 Building 230 North Storm Drain (STM-5) 1 3
PSA-01-06 Building 230 North Storm Drain (STM-6) 1 3
PSA-01-07 Building 230 North Storm Drain (STM-7) 1 3
PSA-01-08 Building 230 West Storm Drain (STM-8) 1 02/17/16 3
PSA-01-09 Building 230 South Storm Drain (STM-9) 1 12/3/15 3
PSA-02 Sanitary Treatment Piping PSA-02-01 Former SWTP Discharge Line (SAN-1) 1 11/15/15 2
PSA-03 Utility Piping / Public Water System PSA-03-01 Water Supply Lines (WAT 1-8) 3 03/23/16 4
PSA-03-02 Building 110/230 Downspouts (DRN-X) 3 01/25/16 4