Text

Westinghouse Hematite Decommissioning Project - Request for NRC Review of Final Status Survey Final Report Volume 3, Chapter 12, Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02
	ML17117A312
Person / Time
Site:	07000036; (SNM-0033)
Issue date:	04/03/2017
From:	Pallagi K; Westinghouse
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML17117A310	List: ML17117A312;
References
	HEM-17-25
	Download: ML17117A312 (90)
	v • d • e

i ; Westinghouse Non-Proprietary Class 3 (8 Westinghouse

ATTN: Document Control Desk Direct tel:

Director, Office of Federal and State Materials and E-mail:

Environmental Management Programs Our ref:

U'.S. Nudear Regulatory Commission Date:

Washington, DC 20555-0001 Westinghouse Electric Company LLC Hematite Decommissioning Project 3300 State RoadP Festus, MO 63028 USA 314-810-3353 pallagke@westinghouse.com HEM-17-25 April 3, 2017

Subject:

Westinghouse Hematite *Decommissioning Project - Request for NRC Review of Final Status Survey Final Report Volume 3, Chapter 12, Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 (License No.

SNM-00033, Docket No. 070-00036)

The purpose of this letter is to provide for the U.S. Nuclear Regulatory Commission (NRC) review of the Final Status Survey document Final Status Survey Final Report Volume 3, Chapter 12, Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 (LSA 08-01, and LSA 08-02). contains Final Status Survey Final Report Volume 3, Chapter 12, with a CD containing Appendices.

Please contact me at 314-8-10-3353, should you have questions or need additional information.

Sincerely,

/~

.?'#~*

Kenneth E. Pallagi Licensing Manager, Hematite Decommissioning Project

Attachment:

1) Final Status Survey Final Report Volume 3, Chapter 12, Survey Area Release Record for Land Survey Area 08, Survey Uni~s 01 and 02 (LSA 08-01 and LSA 08-02), with a CD containing Appendices (HDP-RPT-FSS-214)

HEM-17-25 April 3, 2017 Page 2 of2.

cc:

J. W. Smetanka, Westinghouse M. R. Meyer, NRC/DUWP/MDB J. A. Smith, NRC/DUWP/MDB to HEM-17-25 April 3, 2017 Final Status Survey Final Report Volume 3, Chapter 12 Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 with CD containing Appendices Westinghouse Electric Company LLC, Hematite Decommissioning Project Docket No. 070-00036

Westinghouse Non-Proprietary Class 3

8 Westinghouse Final Status Survey Report Hematite Decommissioning Project Final Status Survey Final Report Volume 3, Chapter 12 TITLE:

REVISION:

Survey A~ea Release Record for Land Survey Area 08, Survey Units 01 and 02 (LSA 08-01 and LSA 08-02) 0 EFFECTIVE DATE: APR 0 j 2017 Approvals:

~e-e.>ff~

/Kenneth E. Pallagi

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Author:

Date Owner/Manager:

W. Clark Evers Date HDP-RPT-FSS-214

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 0 I Page i of viii Table of Contents EXECUTIVE

SUMMARY

.............................................................................................. 1 1.0 REPORT BACKGROUND.............................................................................................. 2 2.0.

HDP SITE, LSA AND SURVEY UNIT DESCRIPTION............................................. 2 2.1 HDP Site Description.............................................................................................. 2 2.2 LSA Configuration.................................................................................................. 2 2.2.1 LSA 12 SU Configuration Change............................................................. 2 2.3 LSA 08-01 AND Isa 08-02 Survey Dnit Description and Configuration............... 3 3.0 HISTORY OF OPERATIONS........................................................................................ 7 3.1 Radioactive Materials in LSA 08-01 and LSA 08-02............................................. 7 3.2 Reuse Soil Disposition and Characterization.......................................................... 7 3.3 Remediation and RASS Phase ofLSA 08-01 and LSA 08-02............................... 7 3.3.1 Remedial Actions in LSA 08-01 and LSA 08-02....................................... 8 3.3.2 In Process Remedial Action Support Surveys.......................................... 11 3.3.3 Specific Investigation Areas - Former Process Buildings Investigation Area........................................................................................................... 11 3.3.4 Nuclear Criticality Safety (NCS) Borings................................................ 12 3.3.5 Groundwater Monitoring Wells................................................................ 12 3.3.6 Subterranean Piping.................................................................................. 15 3.3. 7 Characterization History........................................................................... 16 3.3.8 Remedial Action Support Survey for FSS Design.................................... 16 3.3.9 Isolation and Control.................................................................................. 17 3.3.10 Surveillance Following FSS..................................................................... 19 3.3.11 Backfill of Survey Units........................................................................... 19 3.3.12 Groundwater Monitoring.......................................................................... 19 4.0 LSA RELEASE CRITERIA.........................................................................................

111 20 5.0 FINAL STATUS SURVEY DESIGN LSA 08-01........................................................ 21 5.1 FSS Plan Design Requirements............................................................................ 21 5.1.1 Surrogate Evaluation Areas...................................................................... 21 5.1.2 DCGLw...................................................................................................... 21 5.1.3 GWS Coverage......................................................................................... 21 5.1.4 Instrumentation......................................................................................... 21 5.1.5 Scan Minimum Detectable Concentration (MDC)................................... 21 5.1.6 Investigation Action Level........................................................................ 22 5.1.7 LSA 08-01 FSS Design Summary........................................................... 22 5.1.8 LSA 08-01 Former Process Buildings Investigation Area and Hybrid Well Investigation Planning...................................................................... 24

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Revision: 0 I Pag-e ii of viii 6.0 FINAL STATUS SURVEY IMPLEMENTION LSA 08-01...................................... 24 6.1 Gamma Walkover Survey..................................................................................... 24 6.1.1 Instrumentation......................................................................................... 24 6.1.2 GWS Performance................................................................................... 25 6.2 Soil Sampling........................................................................................................ 26 6.2.1 Systematic Soil Sampling Summary......................................................... 26 6.2.2 Systematic Sampling LSA 08-01............................................................ 26 6.3 Biased Soil Sampling............................................................................................ 29 6.4 Judgmental/Sidewall Sampling for Tc-99............................................................ 29 6.5 Quality Control Soil Sampling............................................................................. 29 6.6 LSA 08-01 Former Process Buildings Investigation Area and Hybrid Well Investigation...................................................................................................................... 29 6.7 Elevated Measurement Comparison of Location Tc-99-7.................................... 31 7.0 FINAL STATUS SURVEY RESULTS LSA 08-01..................................................... 32 7.1 Gamma Walkover Survey..................................................................................... 32 7.1.1 GWS Results for LSA 08-01................................................................... 32 7.1.2 GWS Coverage Results LSA 08-01........................................................ 34 7.2 Soil Sample Results LSA 08-01.......................................................................... 35 7.2.1 Surface Soil Sample Results LSA 08-01................................................. 35 7.2.2 Subsurface Soil Sample Results LSA 08-01............................................ 35 7.2.3 WRS Test Evaluation LSA 08-01.................... ~........................................ 35 7.2.4 Graphical Data Review LSA 08-01......................................................... 35 7.2.5 Biased Soil Sample Results LSA 08-01................................................... 40 7.2.6 Judgmental/Sidewall Soil Sample for Tc-99 Results LSA 08-01............ 40 7.2.7 Quality Control Soil Sample Result LSA 08-01...................................... 40 7.3 Tc-99 Hot Spot Assessment LSA 08-01........................................ ~********************* 43 7.5 LSA 08-01 Former Process Buildings Investigation Area Results and Hybrid Well Investigation Results......................................................................................................... 43 8.0 ALARA EVALUATION LSA 08-01............................................................................. 44 1 9.0 FSS PLAN DEVIATIONS LSA 08-01.......................................................................... 44 9.1 Remedial Actions During FSS.............................................................................. 45 9.2 Adjustments to Scan MDC Calulations................................................................ 45 10.0 DATA QUALITY ASSESSMENT................................................................................ 46 10.1 Data Quality Assessment for LSA 08-01................. :....................................... ~.... 46 11.0 SURVEILLANCE FOLLOWING FSS....................................................................... 51

12.0 CONCLUSION

LSA 08-01........................................................................................... 51 13.0 FINAL STATUS SURVEY DESIGN LSA 08-02......................................................... 52 13.l FSS Plan Design Requirements............................................................................ 52 13.1.1 Surrogate Evaluation Areas...................................................................... 52

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area 13_elease Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 0 I Page iii of viii 13.1.2 DCGLw....................................................................................................... 52 13.1.3 GWS Coverage......................................................................................... 52 13.1.4 Instrumentation~........................................................................................ 52 13.1.5 Scan Minimum Detectable Concentration................................................ 52 13.1.6 Irivestigation Action Level......................................................................... 53 13.1.7 LSA 08-02 FSS Design Summary............................................................ 53 13.1.8 LSA 08-02 Former Process Buildings Investigation Area and Hybrid Well Investigation Planning...................................................................... 55 14.0 FINAL STATUS SURVEY IMPLEMENTION LSA 08-02....................................... 55

,, 14.1 Gamma Walkover Survey........................ *............................................................. 55 14.1.1 Instrumentation......................................................................................... 55 14.1.2 GWS Performance................................................................................... 56 14.2 Soil Sampling........................................................................................................ 57 14.2.1 Systematic Soil Sampling Summary......................................................... 57 14.2.2 Systematic Sampling LSA 08-02............................................................. 57 14.3 Biased Soil Sampling........................................ ~................................................... 60 14.4 Judgmental/Sidewall Sampling for Tc-99............................................................ 60 14.5 Quality Control Soil Sampling............................................................................. 60 14.6 LSA 08-02 Former Process Buildings Investigation Area and Hybrid Well Investigation.......... :.................................................... *....................................................... 60 15.0 FINAL STATUS SURVEY RESULTS LSA 08-02....................................................... 60 15.1 Gamma Walkover Survey............................................ :........................................ 60 15.1.1 GWS Results for LSA 08~02...................... :............................................. 61 15.1.2 GWS Coverage Results LSA 08-02 *......................................................... 62 15.2 Soil Sample Results LSA 08:.02............................................................................ 63 15.2.1 Surface Soil Sample Results LSA 08-02.................................................. 63 15.2.2 Subsurface Soil Sample Results LSA 08-02............................................. 63 15.2.3 WRS Test Evaluation LSA 08-02.............. :.............................................. 63 15.2.4 Graphical Data Review LSA 08-02.......................................................... 63 15.2.5 Biased Soil Sample Results LSA 08-02.................................................... 68

15.2.6 Judgmental/Sidewall Soil Sample for Tc-99 Results LSA 08-02............ 68 15.2.7 Quality Control Soil Sample Result LSA 0.8-02....................................... 68 15.3 Tc-99 Hot Spot Assessment LSA 08-02............................................................... 70 15.4 LSA 08-02 Former Process Buildings Investigation Area Results and Hybrid Well Investigation Results......................................................................................................... 70 16.0 ALARA EVALUATION LSA 08-02.............................................................................. 70 17.0 FSS PLAN DEVIATIONS LSA 08-02........................................................................... 71 17.1 Remedial Actions During FSS......................,........................................................ 71 17.2 Adjustments to Scan MDC Calulations................................................................ 71 18.0 DATA QUALITY ASSESSMENT............................. ~.................................................. 71 18.l Data Quality Assessment for LSA 08-02.............................................................. 71

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Revision: 0 I Page iv of viii 19.0 SURVEILLENCE FOLLOWING FSS......................................................... ;............... 77

20.0 CONCLUSION

LSA 08-02................. ~....................................................... ;.................. 77

21.0 REFERENCES

................................................................................................................ 78 22.0 APPENDICES............................................. ~................................. ~....................... ~........ 78

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 0 I Page v of viii LIST OF TABLES Table 3-1, Summary of Final RASS Results for LSA 08-01 and LSA 08-02............................... 17 Table 4-1, Adjusted Soil DCGLws by CSM...................................... ;........................................... 20 Table 5-1, Scan MD Cs for 2" x 2" N al° detector, 9,000 cpm background: LSA 08-01................ 22 Table 5-2, FSS Design Summary for LSA 08-01..........................................................................23 Table 6-1, Systematic Sampling Summary by Stratum for LSA 08-01....................................... 26 Table 6-2, FSS Sample Locations and Coordinates for LSA 08-01.............................................. 28 Table 7-1, GWS Gap Analysis LSA 08-01................................................................................... 35 Table 7-2, LSA 08-01 FSS Sample Data Summary and Calculated SOF Values (Systematic).... 36 Table 7-3, Final Status Survey Analytical Data: LSA 08-01........................................................ 39 Table 7-4, LSA 08-01 Sidewall Sample Data Summary and Calculated SOF Values.................40 Table 10-1, Retrospective Sample Size Verification for LSA 08-01........................................... 48 Table 12-1, LSA 08-01 SOF and Dose Summation...................................................................... 51 Table 13-1, Scan MDCs for 2" x 2" Nal detector, 13,000 cpm background: LSA 08-02............. 53 Table 13-2, FSS Design Summary for LSA 08-02........................................................................ 54 Table 14-1, Systematic Sampling Summary by Stratum for LSA 08-02...................................... 57 Table 14-2, FSS Sample Locations and Coordinates for LSA 08-02............................................ 59 Table 15-1, GWS Gap Analysis LSA 08-02........... ~...................................................................... 63

Table 15-2, LSA 08-02 FSS Sample Data Summary and Calculated SOF Values (Systematic).. 64 Table 15-3, Final Status Survey Analytical Data: LSA 08-02....................................................... 67 Table 15-4, LSA 08-02 Sidewall Sample Data Summary and Calculated SOF Values................ 68

Table 18-1, Retrospective Sample Size Verification for LSA 08-02............................................ 74 Table 20-1, LSA 08-02 SOF and Dose Summation............................................................... :...... 77

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08:..0J and LSA 08-02)

Revision: 0 I Page vi of viii LIST OF FIGURES Figure 2-1, HDP Land Survey Areas................................................................................................ 4 Figure 2-2, Final Configuration of Land Survey Area 08 and Survey Units.................................... 5 Figure 2-3, Final Configuration of Land Survey Areas and Survey Units....................................... 6 Figure 3-1, LSA 08-01 and LSA 08-02 Early Stage of Remediation May 2013.............................. 8 Figure 3-2, Final Removal of Concrete in LSA 08-01 and LSA 08-02 July 2013.......................... 9 Figure 3-3, Soil Remediation in LSA 08-01 and LSA 08-02 November 2013.............................. 10 Figure 3-4, LSA 08-01 and LSA 08-02 Depth of Excavation Map................................................ 11 Figure 3-5, LSA 08-01 and LSA 08-02 Abandoned and Post-remediation Monitoring Well Locations......................................................................................................................................... 15 Figure 3-6, Portion ofLSA 08-02 prepared for RASS FSS Design............................................... 16 Figure 3-7, Isolation and Control of Area Containing LSA 08-01 and LSA 08-02....................... 18 Figure 6-1, LSA 08-01 Systematic Soil Sample Locations.....................................................,...... 27 Figure 6-2, LSA 08-01 and LSA 08-02 Former Process Buildings Investigation Soil Sample and Hybrid Well Investigation Locations............................................................................................... 30 Figure 6-3, EMC Investigation Area within LSA 08-01................................................................ 32 Figure 7-1, Colorimetric GWS Plot for LSA 08-01...................................................................... 33 Figure 7-2, Colorimetric _GWS Plot for LSA 08-01 (Measurements> Z-score of 3)..................... 34 Figure 7-3, Graphic Statistical Summary of LSA 08-01 (SOF parameter).................................... 3 7 Figure 7-4, Posting Plot for LSA 08-01 Systematic Measurement Locations................................ 38 Figure 7-5, Form HDP-PR-FSS-703-1 Field Duplicate Sample Assessment LSA 08-01.............41 Figure 10-1, Data Evaluation Checklists prepared for LSA 08-01................................................ 49 Figure 14-1, LSA 08-02 Systematic Soil Sample Locations.......................................................... 5 8 Figure 15-1, Colorimetric GWS Plot for LSA 08-02..................................................................... 61 Figure 15-2, Colorimetric GWS Plot for LSA 08-02 (Measurements> Z-score of 3)................... 62 Figure 15-3, Graphic Statistical Summary of LSA 08-02 (SOF parameter).................................. 65 Figure 15-4, Posting Plot for LSA 08-02 Systematic Measurement Locations.............................. 66 Figure 15-5, Form HDP-PR-FSS-703-1 Field Duplicate Sample Assessment LSA 08-02............ 69 Figure 18-1, Data Evaluation Checklists prepared for LSA 08-02................................................. 75

Hematite Decommissioning Project ALARA bgs CPR cm cpm CSM DCGL DCGLw DGPS DP DQO EMC EPA ft PSS FSSFR gcpm GIS GPS GWS HDP HP I&C IAL LSA m

m2 MARS SIM MCL MDC mrem NAD NaI ncpm NCS NRC pCi/g QC Ra RASS RSO SOP SU FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Revision: 0 LIST OF ACRONYMS AND SYMBOLS As Low As Reasonably Achievable below ground surface Code of Federal Regulations centimeter( s) count(s) per minute Conceptual Site Model Derived Concentration Guideline Level

\\ Page vii of viii DCGL for average concentrations over a survey unit, used with statistical tests.

("W" suffix denotes "Wilcoxon")

Digital Global Positioning System Hematite Decommissioning Plan Data Quality Observation Elevated Measurement Comparison U.S. Environmental Protection Agency foot (feet)

Final Status Survey Final Status Survey Final Report gross count( s) per minute Graphical Information Software Global Positioning System Gamma Walkover Survey Hematite Decommissioning Project Health Physics Isolation and Control Investigation Action Level Land Survey Area meter(s) square meter( s)

Multi-Agency Radiation Survey and Site Investigation Manual Maximum Concentration Limit Minimum Detectable Concentration milliroentgen equivalent man North American Datum Sodium Iodide net count( s) per minute

Nuclear Criticality Safety U.S. Nudear Regulatory Commission picocurie( s) per gram Quality Control Radium Remedial Action Support Survey Radiation Safety Officer Sum of Fractions Survey Unit

Hematite Decommissioning Project Tc Th u

WRS yr FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 01 (LSA 08-01 and LSA 08-02)

Revision: 0 Technetium Thorium Uranium Wilcoxon Rank Sum year I Page viii of viii

Hematite

Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 0 I Page 1 of 78 EXECUTIVE

SUMMARY

This Survey Area Release Record (SARR) presents the results of the final status radiological surveys of the Hematite Decommissioning Project (HDP) Land Survey Area (LSA) 08, Survey Unit (SU) 01 (LSA 08-01) and SU 02 (LSA 08-02). As provided in Final Status Survey Final Report (FSSFR), Volume 1, Chapter 1, Section 7.0 {ML15257A307}, the final report summary, FSSFR Volume 7, Final Status Survey Final Report, will be submitted at the conclusion of the post-remediation groundwater monitoring period.

FSSFR Volume 7 will be submitted to demonstrate that the site has met the requirements for unrestricted release consistent with the requirements of the Title 10 Code of Federal Regulations (CFR) 20 Subpart E, "Criteria for License Termination."

The land area that comprises LSA 08-01 and LSA 08-02 was designated as Multi-Ag'ency Radiation'Survey and Site Investigation Manual (MARSSIM) Class 1 SUs as presented in Table 14-16 of the HDP Decommissioning Plan (DP) {ML092330123}. The Class 1 designation for the land area that comprises LSA 08-01 arid LSA 08-02 remained in effect throughout remediation of the site and Final Status Survey (FSS). For the LSA 08-01 and LSA 08-02 SUs the evaluation of analytical results against the Derived Concentration Guideline Levels (DCGL) for the Three Stratum Conceptual Site Model (CSM) was the selected approach. The objective of the FSS for all SUs was to obtain and document measurement results, analytical data, and other supporting information in order to demonstrate that after completion of remediation operations the residual radioactivity levels in the LSA 08-01 and LSA 08-02 are below the applicable Three Stratum DCGLs and therefore the land area of these SUs meet the criteria for unrestricted release.

Compliance with the "three layer" geometry requires consideration of the Surface, Root, and Deep layers independently. After the original DP submittal and approval, Westinghouse agreed with the NRC that the Deep DCGLs should not be used as they were not protective of the intruder scenario, and the Excavation DCGLs were developed as a replacement. Only the Excavation DCGLs will be used when evaluating the Deep layer as part of the "three layer" approach. Because each of the three DCGLs (Surface, Root, Excavation) represent 25 mrem/yr from each layer independently, the unity rule was used to demonstrate compliance when contamination was present in more than one soil layer.

In addition to demonstration of the SUs meeting the applicable Three Stratum DCGLs and therefore the land area of these SUs meet the criteria for unrestricted release, NRC License SNM-33 License Condition 15. C states that:

"The US. Nuclear Regulatory Commission's regulations shall govern unless the statements, representations, and procedures in the licensee's application and the following correspondence are more restrictive than the regulations........

C. Westinghouse HEM-11-56, "Evaluation of Technetium-99 Under the Process Buildings", May 5, 2011. (ADAMS Accession No. MLJ 11260624)."

As such, this report contains information relative to meeting the commitments made in HEM 56. Appendix H contains HDP-RPT-FSS-302, Summary Report of Investigation of Hybrid Wells and Former Process Buildings Investigation Area.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Revision: 0 I Page 2 of78 This SARR was prepared as described in FSSFR Volume 3, Chapter 1, Section 7.0, Survey Area Release Record Organization, as implemented by FSS procedure HDP-PR-FSS-722.

1.0 REPORT BACKGROUND As a result of the U.S. Nuclear Regulatory Commission (NRC) feedback regarding the submittal of the FSSFR, Westinghouse and the NRC agreed that Westinghouse would develop an outline presenting the format and content of FSS documents required for NRC review. Westinghouse provided the outline to the NRC for discussion during the August 19, 2015, publicly noticed teleconference and the format was agreed upon {ML15238B032}.

FSSFR Volume 3, Chapter 1, Revision 2, Land Survey Areas (LSA) Overview provides the information common to land survey areas. This report, FSSFR Volume 3, Chapter 12, builds upon the general information provided in FSSFR Volume 3, Chapter 1, Revision 3.

2.0 HDP SITE, LSA AND SURVEY UNIT DESCRIPTIONS 2.1 HDP Site Description A general description of the HDP site is given in FSSFR Volume 1, Chapter 1.

2.2 LSA Configuration The DP Chapter 14 and DP Figure 14-14 provided the conceptual approach for the configuration of LSAs and the SU s within a LSA. Figure 2-1 indicates the LSA configurations for the HDP site.

LSA 08 encompasses the entire former "Process Building" footprint and adjacent land areas within the Central Tract. LSA 08 consists of SUs LSA 08-01 through LSA 08-17 (See Figure 2-2).

The DP stated that it was expected that the conceptual boundaries of the SUs would be altered based on the actual configuration and condition of the SU at the time of survey design. As expected, it was necessary to modify the boundary of SU s within LSA 08.to facilitate the remediation process. A portion of the land area in the northeast section of the conceptual configuration of LSA 08 was transitioned into LSA 10 (portions of LSA 10-01, LSA 10-03, LSA 10-13 and LSA 10-14). This was a result of expanded remediation in the Burial Pit Area.

Also, as a consequence of specific remediation efforts required in LSA 08 and the need to maintain a "Haul Road" to the Waste Holding Area near the Rail Spur as long as possible to support remediation activities all SU boundaries with LSA-08 were reconfigured (See Figure 2-3).

It is important to note that all of the LSA 08 conceptual land areas (DP Chapter 14 and DP Figure 14-14 were designated as MARSSIM Class 1 and as such remained as MARSSIM Class 1 as either part of LSA 08 or LSA 10, thus ensuring compliance with the DP.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 0 I Page 3 of78 2.3 LSA 08-01 and LSA 08-02 Survey Unit Descriptfon and Configuration After the removal of. the Process Building concrete slab and footings, the removal of all subterranean piping, the removal of spent limestone fill material and the completion of radiological remediation of the soil, in the final configuration, LSA 08-01 and LSA 08-02 consisted of the excavated area in each SU which consisted of native soil. There were no structures, piping, groundwater monitoring wells, or spent limestone remaining within the SUs at the time ofFSS.

Upon completion of remediation, in its final excavated configuration as prepared for FSS, LSA 08-01 presents 1,502 square meters (m2) in planar (2-dimensional) extent, within an interior surface area of 2,050 m2 (3-dimensional).

Upon completion of remediation, in its final excavated configuration as prepared for FSS, LSA 08-02 presents 1,440 square meters (m2) in planar (2-dimensional) extent, within an interior surface area of 2,064 m2 (3-dimensional).

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 0

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Revision: 0 Figure 2-2 Final Configuration of Land Survey Area 08 and Survey Units Page 5 of 78 LEGEND:

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Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 7 of78 3.0 IDSTORY OF OPERATIONS A discussion of site historical operations prior to the decommissioning phase of the HDP is presented in the FSSFR Volume 1, Chapter 1, Section 3.0, Site Historical Operations.

A detailed discussion of the historical background information related to the* general remediation process is presented in the FSSFR Volume 3, Chapter 1, Section 2.1.1, Remediation and Excavation.

3.1 Radioactive Materials in LSA 08-01 and LSA 08-02 Radioactive materials within LSA 08-01 and LSA 08-02 resulted from leakage and migration of contamination within the Process Building along the floor and footing interface as well as at locations of piping and drain penetrations through the concrete floor.

In addition, as described in FSSFR Volume 3, Chapter 1, Section 2.3 Process Building, during the construction of Building 253 then owner, Combustion Engineering, requested that NRC allow spent limestone that was stored on-site to be used as backfill material within the excavation area under Building 253 because of concerns about undermining the structural support of Building 240. The spent limestone was available backfill material. The NRC allowed spent limestone from two piles meeting a 30 pCi/g limit (alpha) to be used as fill below Building 253 with the understanding that the fill would have to be removed upon facility decommissioning.

Radioactive material in the SUs consists of those Radionuclides of Concern indicated in FSSFR Volume 1, Chapter 1.

3.2 Reuse Soil Disposition and Characterization Prior to removal of the Process Building concrete slab and subsequent remediation of the underlying contaminated soil it was determined that generation of reuse soil in the land area of LSA 08-01 and LSA 08-02 would not be pursued. As, such no reuse soil was generated from LSA08-01 and LSA 08-02.

3.3 Remediation and Remedial Action Support Surveys (RASS) Phase of LSA 08-01 and LSA 08-02 The sections below provide a discussion of the various elements of the remediation and RASS phase of LSA 08-01 and LSA 08-02 necessary to prepare the SUs for FSS.

Important to the planning and execution of remediation of the soils under the former Process Buildings was the information provided in Westinghouse letter HEM-11-56 to the NRC which contained the "Evaluation of Technetium-99 Under the Process Building" report. This section is written such that the statements in the "Evaluation of Technetium-99 Under the -Process Building" are written in italics and quotation marks followed by a discussion of compliance with the statement.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01and02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 8of 78 3.3.1 Remedial Actions in LSA 08-01 and LSA 08-02 "Excavation under the former Processing Buildings is expected to begin with the removal of the building slabs and the building footers. Soil will then be excavated to make underground piping available for removal, and then the piping will be removed. "

Remedial actions began in LSA 08-01 and LSA 08-02 in April, 2013, and -continued through November, 2015 after the removal of the former Process Building concrete slabs. Remediation consisted of excavation by large and small excavating equipment to remove building footings and foundations and subterranean process piping. Figure 3-1 is a photograph of the early stages of remediation in LSA 08-01 and LSA 08-02 shortly after the former Process Building concrete slab and subterranean process piping were removed.

Figure 3-1 LSA 08-01 and LSA 08-02 Early Stage of Remediation May 2013

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01and02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 9 of78 Figure 3-2 is a photograph of the removal of the final footings and foundations in LSA 08-01 and LSA 08-02.

Figure 3-2 Final Removal of Concrete in LSA 08-01 and LSA 08-02 July 2013 "Soil and spent limestone baclifill will then be removed. It should be recognized that one area may progress through soil and spent limestone baclifill removal before the slab is removed in another area. "

"As appropriate, the excavation contours will be updated following the analysis for Tc-99 in the archived samples discussed in Section 4.3. The depth of excavation to remove spent limestone baclifill could be 8 to 15 feet. The Figure 1 conceptual contours are based on soil sample results exceeding the DCGLs or exceeding the chemical Remediation Goals (RGs), and includes a projected average excavation depth of 2 feet within the footprint of the former Process Buildings. "

After completion of the removal of the foundations, footings and subterranean p1pmg the remaining remediation of LSA 08-01 and LSA 08-02 was the removal of spent limestone and continued soil remediation.

Figure 3-3 demonstrates the remediation in locations where contamination was expected to be present was the locations identified during the remediation effort.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 10 of78 Figure 3-3 Soil Remediation in LSA 08-01 and LSA 08-02 November 2013 The maximum depth of remedial excavation necessary in portions of LSA 08-01 to ensure all areas identified during site characterization, the historical site assesemnt and remedial action survey efforts were adequately remediated relative to the original grade was 18 to 20 feet. The estimated volume of excavated waste materials from LSA 08-01 was 4,604 cubic yards.

The maximum depth of remedial excavation necessary in portions of LSA 08-02 to ensure all areas identified during site characterization, the historical site assesemnt and remedial action survey efforts were adequately remediated relative to the original grade was 18 to 20 feet. The estimated volume of excavated waste materials from LSA 08-02 was 4,322 cubic yards.

Figure 3-4 provides the depth of excavations for LSA 08-01 and LSA 08-02.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 11 of 78 Figure 3-4 LSA 08-01 and LSA 08-02 Depth of Excavation Map (Depths in Feet)*

08--06 LEGEND:

D LSA Boundaries D Buildings

~ Fence

-18

-16

-14 LSA Oll-01 & L S A 08 ~2 Depth of Et.ca\\1!.tion

.... -.ted Sy Do:.rmat '-- <11 C.?.um RS S.U J.

Hemati ~ DeoommiS!"ioning Project Jefferson County Hematite, ~.f()

Pbpa-.d Sy 1--

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Depth of Excavation Map presented in colored bands of feet. Maximum depth is 18 to 20 feet.

3.3.2 In Process Remedial Action Support Surveys During excavation and remediation of the Process Building Area, remedial action support surveys were conducted in accordance with procedure HDP-PR-HP-601, Remedial Action Support Surveys. The radiological information obtained from the surveys served the purpose of categorizing the soil/material into one of two categories; 1) Soil/material potentially exceeding the Nuclear Criticality Safety Exempt Material Limit, 2) Soil/materials potentially containing radioactivity concentrations above the DCGL.

3.3.3 Specific Investigation Areas - Former Process Buildings Investigation Area "Figure 14-21 shows the investigation area beneath the former Process Buildings in which soil will be sampled and analyzed for Tc-99 and uranium from the surface of the excavation to the top of the sand/gravel layer. Final status survey sampling stations that fall within this Process Building investigation area will be sampled as follows:

A composite soil sample will be taken from each 5 foot interval of excavated soil down to within 6 inches of the sand/gravel layer; and

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 12of78 A soil sample will be taken of the remaining 6 inches of soil immediately above the sand gravel layer. Figure 14-21 shows a conceptual layout of the conceptual final status survey units across the former Process Buildings. "

"Should a sample result from the investigation sampling described in this subsection exceed the applicable DCGL, then remediation of the subsurface soil represented by the sample is required. "

The implementation of the investigation is discussed in Section 7.4.

3.3.4 Nuclear Criticality Safety (NCS) Borings NCS Borings were not required within LSA 08-01 and LSA 08-02 as the land area of the SUs was never subject to NCS controls.

3.3.5 Groundwater Monitoring Wells A detailed discussion of history, purpose, use, issues, and results of the groundwater monitoring wells at HDP is presented in the FSSFR Volume 6, Chapter 1.

3.3.5.1 Abandoned Wells "The following actions shall be taken to investigate the potential for a preferential pathway ofTc-99 and uranium along a monitoring well screen that crosses both the Silty Clay Aquitard HSU and the Sand/Gravel HSU (hybrid well), and to determine whether contaminated soil exists in proximity to a hybrid monitoring well:

When hybrid wells are abandoned they will be over drilled using hollow stem augers of sufficient outside diameter to remove approximately two inches of surrounding soil, the well riser, well screen, and screened jilter pack. The auger will continue until reaching refusal, which indicates bedrock. The soil cuttings that are removed during the boring process will be surveyed for indications of elevated radioactivity as a qualitative measure and sampled for laboratory analysis.

Within each 5 foot interval, sample(s) of soil indicating elevated concentrations will be collected for laboratory analysis. In the event that an elevated count is not observed, one composite sample of the cuttings collected within each 5 foot interval will be collected for laboratory analysis.

When completing remediation actions in the area of a hybrid well screen that extends beyond the depth of soil excavation, any water sample taken over the history of that well will be assessed for results that exceed the MDC+ Error for Tc-99 or exceed the Background Threshold Value for total uranium. For such an exceedance, four borings will be made in close proximity (e.g., approximately equidistant within a 2-4 foot radius) to each monitoring well that is not excavated to the bottom of the well. The borings shall extend down to refusal, which indicates bedrock. Composite samples will be collected as follows:

From each 5 foot increment of depth to the top of the screened/filtered interval,*

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 13 of 78 From the increment that is equivalent to the top half of the screened/filtered interval; and From the increment that is equivalent to the bottom half of the screened/filtered interval.

Should a sample result from the investigation sampling described in this subsection exceed the applicable DCGL, then remediation of the subsurface soil represented by the sample* is required If remediation was by overboring, then sampling borings as described in the preceding paragraph may be used to demonstrate compliance. If remediation was by excavation, a final status survey (FSS) per Chapter 14 will be completed "

The following groundwater monitoring wells were located in the land area of LSA 08-01 and LSA 08-02 were subsequently abandoned in accordance with State of Missouri Department of Natural Resource (MDNR) requirements (10 CSR 23-4.080):

BD-01 Hybrid well BD-01 (total depth 34.5 ft) was abandoned on August 24, 2006 by Westinghouse contractor Geotechnology. A variance for abandonment of this well was approved by MDNR (Variance No. 3268) that allowed for the removal of the upper 3 feet of casing and tremie filling the well with grout from the bottom to top. Abandonment of monitoring well BD-01 included tremie grouting the well from the bottom to top and the removal of the upper 5 feet of PVC riser pipe.

The Hybrid Well Investigation results for BD-01 indicated that the radiological survey of the soil cuttings that were removed during the boring process did not demonstrate indications of elevated radioactivity. The laboratory analysis, of the soil sample intervals for BD-01 indicate that the highest interval Uniform DCGL SOF was 0.21 and the highest interval Excavation DCGL was 0.07.

The top 6 feet of soil from original grade of abandoned BD-01 was removed during the SU soil remediation. Therefore the highest interval (BDOl-E depth interval of 4 to 8 ft) soil Uniform DCGL SOF remaining in the area of BD-01 is 0.19. All sample results for BD-01 are provided in Attachment 6 of Appendix H.

BD-02 Hybrid monitoring well BD-02 (total depth 34 ft) was abandoned in January 2012 by Westinghouse contractor Geotechnology. The well was overdrilled to the top of bedrock with an 8 inch OD Hollow Stem Augers to remove existing well materials included PVC screen, PVC riser, sand filter pack and grout. Following the removal of the well materials, the boreholes were tremie grouted from the bottom to top in accordance with MDNR regulations.

The Hybrid Well Investigation results for BD-02 indicated that the radiological survey of the soil cuttings that were removed during the boring process did not demonstrate indications of elevated radioactivity. The laboratory analysis, of the soil sample intervals for BD-02 indicates that one location (BD-02) had an SOF > 1.0 in the 0-5 foot interval using the Uniform DCGLs. The 0-5 foot was excavated and removed during the remediation of soils within the SU. The next highest interval Uniform DCGL SOF was 0.76 and the highest interval Excavation DCGL was 0.21.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 14of78 The top 12 feet of soil from original grade of abandoned BD-02 was removed during the SU soil remediation.

Therefore the highest interval (BD02-N depth interval of 17.5 to 22 ft) soil Uniform DCGL SOF remaining in the area of BD-02 is 0.58. All sample results for BD-02 are provided in Attachment 6 of Appendix H.

BD-03 Hybrid monitoring well BD-03 (total depth 33 ft) was abandoned in January 2012 by Westinghouse contractor Geotechnology. The well was overdrilled to the top of bedrock with an 8 inch OD Hollow Stem Augers to remove existing well.materials included PVC screen, PVC riser, sand filter pack and grout. Following the removal of the well materials, the boreholes were tremie grouted from the bottom to top in accordance with MDNR regulations.

The Hybrid Well Investigation results for BD-03 indicated that the radiological survey of the soil cuttings that were removed during the boring process did not demonstrate indications of elevated radioactivity. The laboratory analysis, of the soil sample intervals for BD-03 indicate that the highest interval Uniform DCGL SOF was 0.38 and the highest interval Excavation DCGL was 0.14.

The top 4 feet of soil from original grade of abandoned BD-03 was removed during the SU soil remediation. Therefore the highest interval (BD03-N depth interval of 20 to 24 ft) soil Uniform DCGL SOF remaining in the area of BD-03 is 0.38. All sample results for BD-03 are provided in Attachment 6 of Appendix H.

BD-04 Hybrid monitoring well BD-04 (total depth 34.5 ft) was abandoned in January 2012 by Westinghouse contractor Geotechnology. The well was overdrilled to the top of bedrock with an 8 inch OD Hollow Stem Augers to remove existing well materials included PVC screen, PVC riser, sand filter pack and grout. Following the removal of the well materials, the boreholes were tremie grouted from the bottom to top in accordance with MDNR regulations.

The Hybrid Well Investigation results for BD-04 indicated that the radiological survey of the soil cuttings that were removed during the boring process did not demonstrate indications of elevated radioactivity. The laboratory analysis, of the soil sample intervals for BD-04 indicate that the highest interval Uniform DCGL SOF was 0.48 and the highest interval Excavation DCGL was 0.17.

The top 10 feet of soil from original grade of abandoned BD-03 was removed during the SU soil remediation. Therefore the highest interval (BD04-S depth interval of 28 to 30 ft) soil Uniform DCGL SOF remaining in the area of BD-03 is 0.48. All sample results for BD-04 are provided in Attachment 6 of Appendix H.

WS-10 WS-10 was a water supply well and not a groundwater monitoring well, as such, WS-10 was not a hybrid well and was therefore not subject to the Hybrid Well Investigation requirements. Plant production water supply well WS-10 (total depth 600 ft) was abandoned on December 20, 2005 by Westinghouse contractor Roberts Drilling Company. A variance. for abandonment of this

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 15of78 well was approved by MDNR (Variance No. 3112) that allowed for the filling of the core hole in the bedrock aquifer with permeable material and grouting of the remaining well hole.

Abandonment of well WS-10 included backfilling the core hole with clean gravel from 300 ft to 600 ft below ground surface. The remainder of the core hole and well was tremie grouted from 300 ft below ground surface to the top of the steel casing with bentonite grout.

3.3.5.2 Post-remediation Groundwater Monitoring Wells Two monitoring wells were installed in LSA-08-02 in May and June of 2016 for the purpose of collecting groundwater samples following the completion of remedial activities. Post-remediation groundwater monitoring well G W-II is installed to a depth of 3 5 ft and is screened in the sand/gravel hydrostratigraphic unit. Post-remediation monitoring well BR-16-JC is installed to a depth of 89.5 ft and is screened in the Jefferson City-Cotter hydrostratigraphic unit.

Figure 3-5 LSA 08-01 and LSA 08-02 Abandoned and Post-remediation Monitoring Well Locations 08-17 08-06 3.3.6 Subterranean Piping LEGEND:

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Abandoned 08-08 D LS..\\. Boundaries

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Preliminary remediation planning activities indicated that subterranean process piping would be encountered in LSA 08-01 and LSA 08-02. As stated in Section 3.3.1 excavation remediation

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 16of78 activities were conducted to remove subterranean process piping from LSA 08-01 and LSA 08-02.

As no buried piping remains under the footprint of LSA 08-01 and LSA 08-02 there is no dose contribution from this pathway.

3.3. 7 Characterization History Appendix G, Westinghouse letter HEM-11-56 and Appendix H, HDP-RPT-FSS-302, Summary Report of Investigation of Hybrid Wells and Former Process Buildings Investigation Area provides a summary of the characterization data of LSA 08-01 and LSA 08-02 land area as a portion of the former Process Building area.

3.3.8 Remedial Action Support Survey for FSS Design The RASS was conducted within LSA 08-01 and LSA 08-02, 1) to determine when a SU had been adequately prepared for FSS, and 2) to provide updated estimates of the parameters to be used for planning the FSS.

Upon the completion of remediation of the SU and prior to implementation of FSS activities, a final RASS was performed to validate the status of the SU prior to implementing Isolation and Control (I & C) postings. The I & C posting for LSA 08-01 and LSA 08-02 was completed in November of 2015. Figure 3-6 is a photograph which shows a portion of LSA 08-02 ready for the final RASS and is an example of both LSA 08-01 and LSA 08-02 prepared for FSS.

Figure 3-6 Portion of LSA 08-02 Prepared for RASS FSS Design

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 17of78 The RASS included a GWS, sy~tematic surface sample collection based on a sixteen (16) point triangular grid, and biased surface sampling. The Final RASS results were used to develop the FSS Plan for each SU. The Final RASS systematic sample results used to develop the FSS sampling grid are summarized in Table 3-1 below:

Table 3-1 Summary of Final RASS Results for LSA 08-01 AND LSA 08-02 LSA Ra-226 (net)

Tc-99 Th-232 (net)

U-234 U-235 U-238 Mean Max Mean Max Mean Max Mean Max Mean Max Mean Max 08-01 0.133 1 o.320 0.523 1.340 0.139 0.300 2.967 7.133 0.160 I o.394 1.127 1.390 08-02 0.034 1 0.140 0.708 1.580.

0.081 0.190 7.657 29.79 0.418 1 1.640 2.155 7.960 DCGL° 5.4 74.0 5.2 872.4 208.1 551.1 Notes:

I.

All units are in picocuries per gram (pCi/g)

2.

Results reflect net concentrations after subtraction of background (Ra-226 bkg = 0.9 pCi/g; Th-232 bkg = 1.0 pCi/g).

3.

Excavation Stratum DCGLs (From Table 4-1)

All Final RASS systematic sample and biased sample results were less than the appropriate DCGLw (Three Stratum) and the Final RASS data set was considered sufficient to support FSS design.

3.3.9 Isolation and Control As directed by HDP-PR-HP-602, Data Package, Development and Isolation and,.Control Measures to Support Final Status Survey, in November of 2016, the SUs in LSA 08 were isolated and controlled in accordance with Work Package HDP-WP-ENG-803, Isolation and Control Measures, (See Figure 3-7) Isolation and control measures included silt fence, straw wattle, and soil berms between these SUs and the adjacent remediation area to ensure that cross-contamination of these LSAs undergoing FSS did not occur.

The administrative control of multiple postings labeled "Contact Health Physics Prior to Entry" were installed around the entire perimeter of the SUs prior to FSS field activities to prevent inadvertent entry by site personnel. The LSA 08 SUs are located within the fenced security perimeter of the HDP which therefore prevents access by the general public.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 18of 78 Figure 3-7 Isolation and Control of Area Containing LSA 08-01 and LSA 08-02

~~~~~~~~~~~~~~~

1 0 NOTE: CONTROLS MAY BE REVISED TO BETTER SUIT FIELD CONDITIONS IF DIRECTED BY ENGINEERING OR OPERATIONS. THIS DRAWING SHOULD BE REDLINED TO REFLECT _1 ANY CHANGES.

LEGEND STRAW WATTLES SILT FENCE

-a--

BERM LSA 08-01, 08--02, 08--06, 08-07, 08-11, 08-16 & 08-17 ISOLATION

& CONTROL MEASURES Hematite Decommissioning Project Jeffmon County Hematite, MO

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 19of78 3.3.10 Surveillance Following FSS Following the completion of a FSS, the DP requires continued surveillance to minimize the potential to re-contaminate a SU (e.g., surface water transport of potentially contaminated sediment or a soil pile that was not present during FSS). The surveillance included the routine visual inspection of the integrity of the I & C measures implemented for LSA 08-01 and LSA 08-02. If a SU is suspected of having been re-contaminated then an investigation survey will be performed to reconfirm the FSS survey validity.

During the timeframe since the completion of FSS field activities to the date of completion of all physical work at HDP and project demobilization, LSA 08-01 and LSA 08-02 did not evidence an event that would cause them to be suspect and thus require investigation. Nevertheless, both LSA 08-01 and LSA 08-02 were subjected to a confirmatory GWS in the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to placing backfill soil in the LSA. The results of the confirmatory GWS were compared to the results of the FSS in order to confirm that there had been not impacts to the LSA prior to backfill.

3.3.11 Backfill of Survey Units In accordance with work package HDP-WP-ENG-802, Baclefill & Site Restoration, the determination was made to utilize Combined Reuse Soil Stockpile 4-7 (3,651 cubic yards total) soil in the Deep Stratum of LSA 08-01 and LSA 08-02. Backfill placement of Combined Reuse Soil Stockpile 4-7 consisted of 2, 173 cubic yards of soil placed in the Deep Stratum of LSA 08-02 and 1,4 78 cubic yards of Reuse Soil Stockpile 4-7 soil placed in the Deep Stratum of LSA 08-01. As Combined Reuse Stockpile 4-7 {ML16285A372} was used for backfill in LSA 08-01 and LSA 08-02, as such, 6.3 mrem/yr will be added to the total dose calculation for LSA 08-01 and LSA 08-02 to account for the placement of the reuse soil.

To bring LSA 08-01 and LSA 08-02 excavation to final grade the backfill of the SUs was completed with off-site "borrow" soil from the Horine Road site in Festus, MO.

3.3.12 Groundwater Monitoring In response to NRC RAI Chapter 3-4, during the review and approval process for the DP, Westinghouse documented in letter HEM-11-96 {ML111880290} the revised text of DP Section 14.5.l to be as follows:

"Post-remediation monitoring wells will be sampled quarterly after the completion of remediation until license termination. The data collected will be used to confirm that the sum of the annual dose from groundwater for all the radionuclides does not exceed the EPA Maximum Contaminant Level (MCL) of 4 millirem/year. Separately, the sum of the dose from all residual sources remaining after remediation, including soil and groundwater pathways, will be confirmed to result in an annual dose that does not exceed 25 millirem/year."

As stated in the Executive Summary section, the exposure results of this report will be combined with the dose attributed to groundwater to demonstrate that the site has met the requirements for unrestricted release consistent with the requirements of the Title 10 CFR 20 Subpart E, "Criteria for License Termination." As such, for the purpose of this report, groundwater will be assigned

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 20 of 78 a conservative SOF of 0.16 which equates to 4 mrem/yr until such time that the p~st-remediation groundwater sampling has been completed and reported as part of FSSFR Volume 6, Chapter 7, Post-remediation Groundwater Monitoring Summary. The final dose for LSA 08-01 and LSA 08-02 will be reported in FSSFR Volume 7, reflecting the updated results of the post-remediation groundwater monitoring.

4.0 LSA RELEASE CRITERIA As the release criteria for all LSA SUs is common, FSSFR Volume 3, Chapter 1, Section 3.0, Release Criteria, provides a detailed discussion on the release criteria that is _applicable to LSA 08-01 and LSA 08-02. Table 4-1 provides the.applicable DCGLs.

Table 4-1 Adjusted Soil DCGLw's by CSMa Three Layer A 1proach DCGLw Values (pCil!!:)b Uniform Radionuclide Surface Root Stratum Excavation Stratum Stratum Scenario (pCi/g)

Radium-226+C 0

5.0 2.1 5.4 1.9 Technetium-99 151.0 30.1 74.0 25;1 Thorium-232+C 0

4.7 2.0 5.2 2.0 Uranium-234

508.5 235.6 872.4 195.4 Uranium-235+Dc 102.3 64.1 208.1 51.6 Uranium-23 8+Dc 297.6 183.3 551.1 168.8

Table as presented in FSSFR Volume 3, Chapter I.

b The reported DCGLw's are the activities for the parent radionuclide and were calculated to account for the dose contribution from insignificant radionuclides.

0 +D indicates the DCGLw includes short-lived (half-life :S 6 mo.) decay products.

d+c indicates the DCGLw includes all radionuclides in the associated decay chain.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 21 of 78 5.0 FINAL STATUS SURVEY DESIGN LSA 08-01 This section of the report describes the method for determining the number of samples required for the FSS of LSA 08-01 as well as summarizing the applicable requirements of the FSS Plan.

These include the DCGLw, scan survey coverage, and Investigation Action Levels (IAL). The radiological instrumentation used in the FSS of LSA 08-01 and the detection sensitivities are also discussed.

5.1 FSS Plan Design Requirements FSS Plan requirements for LSA 08-01 were driven by the type (Open Land) and Class (Class 1) of the SU and developed in accordance with HDP procedure, HDP-PR-FSS-701, Revision 10, Final Status Survey Plan Development, November 2015.

5.1.1 Surrogate Evaluation Areas A discussion of Surrogate Evaluation Areas is given in the FSSFR Volume 3, Chapter 1, Section 5.0, Final Status Survey Design.

5.1.2 DCGLw During the FSS design process a review was performed of the RASS data for LSA 08-01. The RASS data was used to identify that areas of residual radioactivity potentially remained within the SU that exceeded the Uniform Stratum DCGLw (locations Tc-99-7 and Tc-997 A from the Process Building Investigation Area at depths from 20 to 28 feet bgs ). While only 3 out of the 124 Process Building Investigation Area samples exceeded a Uniform SOF of 1.0, this was an indication that residual levels of Tc-99 may remain within the area that exceed the Uniform DCGLw. Since the minimum excavation depth in LSA 08-01 exceeded 8 feet bgs in all areas, and all available RASS survey and sampling data indicated that no residual Tc-99 radioactivity remained above the Excavation Stratum DCGLw, the conclusion was drawn that the Excavation Stratum DCGLw would be the most appropriate to be used to demonstrate compliance with the release criteria.

Therefore the Three-Stratum DCGLw was selected for use in demonstrating compliance with the release criteria.

5.1.3 GWS Coverage As a Class 1 SU, LSA 08-01 was required to undergo a 100% GWS.

5.1.4 Instrumentation Radiological instrumentation selected for performance of GWS within LSA 08-01 was the Ludlum 44-10 2" x 2" sodium iodide (NaI) detectors, coupled to a Ludlum 2221 scaler-ratemeter.

5.1.5 Scan Minimum Detectable Concentration (MDC)

Scan MDCs for LSA 08-01 were calculated in accordance with HDP-PR-FSS-701, Revision 10, Final Status Survey Plan Development and HDP-TBD-FSS-002, Revision 3, Evaluation and

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 22 of 78 Documentation of the Scanning Minimum Detectable Concentrations (MDC) for Final Status Surveys (FSS). *As background levels were approximately 13,000 counts per minute (cpm) within LSA 08-01, the scan minimal detection concentration (MDC) calculation for total uranium given in HDP-PR-FSS-701, Final Status Survey Plan Development, Step 8.2.6.d, was applied:

1 Scan MDC (total uranium) = (

)

f u-234 + f u-235 + f u-23s (4172pCi/g) (2.65pCi/g) (34.9pCi/g)

Equation 5-1 To determine isotopic Uranium fractions HDP-PR-FSS-701, Revision 10, Final Status Survey Plan Development assumes that the average LSA emichment is 4% or less.

Based on the systematically collected RASS samples in LSA 08-01, the average enrichment for the SU was 2.3%. All other Scan MDC parameters agreed upon between Westinghouse and the NRC were applied (e.g. use of a 2 in air gap, scan rate of 1 ft/sec, 0.75 surveyor efficiency), therefore no subsequent changes to the calculated Scan MDCs need to be made.

Prospectively calculated Scan MDCs for 2" x 2" Nal detectors that were used in LSA 08-01 are shown below:

Table 5-1 Scan MDCs for 2" x 2" Nal detector, 13,000 cpm background: LSA 08-01 Scan MDC DCGLw Scan DCGLw*

Scan DCGLw*

(Total U)

MDC (Ra-226)

MDC (Th-232)

(Ra-226)

(Th-232)

LSA 08-01 46.7 31.7 1.37 6.3 0.99 6.2

DCGLw includes background concentrations of 0.9 pCi/g for Ra-226 (no ingrowth) and 1.0 pCi/g for Th-232. DCGLw values are based on the Excavation Stratum release criteria.

The values in Table 5-1 reflect those presented in the FSS Plans prepared for the SU prior to FSS.

5.1.6 Investigation Action Level FSSFR Volume 3, Chapter 1, Section 6.1.3, Investigation Action Level (JAL), provides a discussion in regards to the IAL. The basis of the-IAL is detailed in HDP memorandum, HEM-l 5-MEM0-021 "Evaluation of the Scan JAL for Class 1 areas at the Westinghouse Hematite Site". The IAL used during the GWS of LSA 08-01 was established at 4,000 net counts per minute (ncpm).

5.1.7 LSA 08-01 FSS Design Summary The FSS Plans for LSA 08-01 can be found in Appendix C. Table 5-2 presents an overall FSS design and implementation summary for LSA 08-01.

Hematite FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Decommissioning Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Project Revision: 1 I Page 23 of 78 Table 5-2 FSS Design Summary for LSA 08-01 Gamma Walkover Survey (GWS):

Scan Coverage 100% exposed excavation floors and walls 46.7 pCi/g total Uranium (based on a Scan MDC 13,000 cpm background); 0.99 pCi/g Th-232; 1.37 pCi/g Ra-226*

Investigation Action Level (IAL) 4,000 net cpm **

Systematic Sampline Locations:

Depth Number of Comments Sample 0 - 15 cm (Surface) 0 These samples will be taken on 15 cm - 1.5 m (Root) 0 a random-start systematic grid.

> I.Sm (Excavation) 19 Biased Survey/Sampline; Locations:

Biased samples may be collected during GWS at the discretion of the HP Technician, after statistical analysis of the survey data, or at the direction of the FSS Supervisor.

Sidewall Sampline; Locations:

A minimum of one (1) discretionary sidewall sample(s) will be collected based on the following definition of "sidewall: sidewall candidates for sampling must be vertical or near vertical (> 45° angle) and at least 12" in height.

Process Buildine; Investie;ation Area Locations:

As required in Section 7:1 of Attachment 1 to Westinghouse letter HEM-11-56, those systematic sample locations (TBD) in LSA 08-01 which fall inside the Process Building Investigation Area will require deep sampling to within six inches of the sand/gravel layer just above the aquifer.

1. A composite soil sample taken from each 5 foot interval between the excavation surface to within 6 inches of the sand/gravel layer; and

2. A soil sample taken from the remaining 6 inches just above the sand/gravel layer Soil data collected during the 2013 Process Building investigation will be used to augment the FSS data evaluation and satisfy the commitment as described above.

Instrumentation:

Ludlum 2221 with 44-10 (2x2 Nal) I Used for GWS and to obtain static count detector; with collimation for investigations rates at biased measurement locations.

Values based on information provided in HDP-TBD-FSS-002, "Evaluation and Documentation of the Scanning Minimum Detectable Concentrations (MDC) for Final Status Surveys (FSS). The Scan MDC for total Uranium reflects a conservative assumption of 4% enrichment. The actual RASS enrichment (2.3%) would result in Scan MDC values slightly less than those calculated for FSS planning purposes.

- IAL is the net count per minute (ncpm) equivalent of an activity concentration less than the Uniform Stratum DCGLw derived from the technical bases presented in HEM-MEM0-15-021 and HDP-TBD-FSS-003 "Modeling and Calculation of Investigative Action Levels for Final Status Soil Survey Units", Westinghouse, March 2015.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01and02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 24 of 78 5.1.8 LSA 08-01 Former Process Buildings Investigation Area and Hybrid Well Investigation Planning LSA 08-01 land area included portions of the land area designated for the Former Process Buildings Investigation Area and Hybrid Well Investigation. A sampling campaign separate from FSS was performed to meet the requirements of the investigations as stated in Westinghouse letter HEM-11-56 to the NRC which contained the "Evaluation ofTechnetium-99 Under the Process Building" report (Appendix G).

Figure 4, Conceptual Investigation Sample Stations Associated with the Process Buildings, of "Evaluation of Technetium-99 Under the Process Building" report provides the conceptual soil sampling and well locations for the Former Process Buildings Investigation Area and Hybrid Well Investigation (see Figure 6-2).

During development of the work package for the Former Process Buildings Area and Hybrid Well Investigation it was determined that the available sampling equipment of the drilling company contracted to perform the sampling utilized a 4 foot core sampler rather than a 5 foot core sampler. A licensing evaluation was completed and documented using HDP-PR-LI-005-1, Change Evaluation Form. The evaluation determined that this was an adequate approach and potentially increased the sample density and therefore, there was no change in intent in regards to accomplishing the investigation as described in HEM-11-56.

Section 7.0 of HEM-11-56 specifies that sampling would be post excavation for the Former Process Buildings Investigation Area and Hybrid Well Investigation sampling. This statement was a preliminary statement based upon the expected logistics related to performing the sampling. Due to VOC contamination in the area at depth, it was recognized by the site staff that post excavation sampling presented the difficulties of having a drill rig or direct push rig enter the area after significant excavatiol} depths had taken place as the surfac.es would be extremely uneven (see Figure 3-3). In consideration of the need to have a relatively flat surface for the drill rig to operate on and the inherent safety concerns of using a drill rig on uneven surfaces, a decision was made to perform the sampling in the Tc-99 investigation area and at some of the hybrid wells prior to performing soil excavation. The sampling of the 15 systematic locations therefore occurred after removal of the former Process Building's concrete slab and sub-floor gravel, but prior to excavation of contaminated soil.

6.0 FINAL STATUS SURVEY IMPLEMENTATION LSA 08-01 FSS was performed in accordance with procedure HDP-PR-FSS-711, Final Status Surveys and Sampling of Soil and Sediment.

6.1 Gamma Walkover Survey 6.1.1 Instrumentation The selected instrumentation to perform the GWS in LSA 08-01 was a 2" x 2" NaI detector in combination with a Ludlum 2221 rate meter. Each NaI instrumentation set was interfaced with a Trimble DGPS (Digital Global Positioning System) and handheld data logger.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 25of78 Prior to the first field use of the GWS instrumentation, initial set-ups were performed. Also, daily pre-and post-use source checks were performed for each day that GWS was performed within the SU.

Initial set-ups, daily source checks, and control charting were performed according to the requirements of HDP-PR-HP-416, Operation of the Ludlum 2221 for Final Status Survey.

6.1.2 GWS Performance All GWS measurements on the excavation floor and sidewalls collected with the Nal detector(s) were connected to a Trimble DGPS and with a hand-held data logger. The logging frequency in the survey unit was 1 GWS measurement per second. Each gross gamma measurement is correlated to a set of coordinates based on the Missouri East State Plane, NAD '1983.

The GWS requirements involved moving the Nal detector in a side-to-side fashion no faster than 1 foot per second while holding the probe as close as possible to the excavation surface (nominally 1", but not to exceed 3"). At the same time, the technician was required to slowly advance, causing the detector to trace out a serpentine path over the excavation surface.

HP Technicians performing GWS in LSA 08-01 used the 4,000 ncpm JAL as a field guide to know when to slow or pause the GWS for more deliberate investigation. If during the GWS, audible count rates noticeably increase above the general area average (i.e., > minimum detectable count rate), HP Technicians were required to pause momentarily and observe count rates. If sustained count rates approached the JAL, further focused investigation was conducted within the locally elevated area.

To use the JAL effectively, HP Technicians first determined the local background count rate before starting the GWS. Although the ambient gamma level may vary across the SU due to the geometry and relative distance from contaminated materials in nearby remedial excavations, the average background rate (measured at waist level) within the LSA ranged between 13,000 and 14,000 gross counts per minute (gcpm). Therefore, at locations where the 2" x 2" Nal detector measurements exceeded 17,000 to 18,000 gcpm, HP Technicians slowed or paused the GWS for more careful investigation of the small areas of elevated activity before deciding if "flagging" a point for potential biased sampling was warranted.

Sidewalls, hard to reach areas, atid non-typical areas were surveyed manually as necessary in order to assess the potential for an area of elevated residual activity over 100% of the exposed ground surface.

After the GWS survey was complete, the GPS/GWS data was reviewed by Radiological Engineering and the Health Physics (HP) Technician performing the survey to determine if possible areas of elevated residual activity remained within the SU that required biased sample investigation. Areas that were flagged by the HP Technician were considered, as well as a statistical evaluation of the GWS data set. The statistical evaluation determined the mean count rate and standard deviation associated with the GWS and then could be used to identify any areas that exceeded 3 standard deviations above the mean. The number of biased samples* to be collected and the locations are based on flagged locations exceeding the JAL, the statistical evaluation of the G WS data set, and the professional judgment of Radiological Engineering.

FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Hematite Decommissioning Project Revision: 1 I Page 26 of 78 6.2 Soil Sampling 6.2.1 Systematic Soil Sampling Summary Table 6-1 provides a summary of systematic sampling by stratum for LSA 08-01.

Table 6-1 Systematic Sampling Summary by Stratum for LSA 08-01 LSA 08-01 SU Area, planar (m2) 1,502 Surface 0

Systematic Root 0

Deep (Excavation) 19

Excavation samples were collected and archived, analysis only required if an overlying Root sample exceeds a 0.5 SOF 6.2.2 Systematic Sampling LSA 08-01 QC 2

Within LSA 08-01, there were 19 systematic locations prescribed by the FSS plans.

This increased number of systematic sample points is based on the expectation of elevated residual Tc-99 soil concentrations. The systematic grid concentration was increased in order to provide sufficient minimum spacing in between each point to identify the potential Tc-99 elevated areas, and address them through the application of Area Factors should they be identified. Given a planar area of 1,502 m2 for LSA 08-01 and a 19 - point systematic triangular grid, the point-to-point distance within each row was 9.3 m.

While there were nineteen (19) systematic locations on the LSA 08-01 sampling grid, a total of twenty-one (21) samples were collected and analyzed at these locations, including:

Zero (0) samples collected within the surface stratum Zero (0) samples collected within the root stratum Nineteen (19) samples analyzed within the excavation, or "deep" stratum Two (2) Quality Control (QC) field replicate Figure 6-1 presents the map of the eight systematic sample locations which were sampled within LSA 08-01. The inset table notes the location coordinates (Missouri East, North American Datum (NAD) 1983) and collection intervals for each systematic location.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 9: Survey Area Release Record for Land Survey Area 12, Survey Units 03, 04, 05, 06, 07, 08, and 09 (LSA 08-01 through 12-09)

Revision: 1 Page 27 of78 Figure 6-1 LSA 08-01 Systematic Soil Sample Locations Sample Locations Stort End Northing Sample ID O.pth Dept h Easting

!inches) (inche5}

!feet I (feet) l08-01-01-T-E-S-00 0

6 864934 B27160 LW-01-02-T-E-S-00 0

6 S64~07 S27ll3 LOS-01-03-T-E-S-00 0

864907 827144 LDS-01-04-T-f-S-00 0

864907 B27175 LD8-0l-OS-T-E-S-OO 0

364880 827007 LOS-01-06-T-E-S-00 0

864880 B27128 l08-01-07-T-E-S-00 0

864880 827160 LOS-01-0S-i-E-S-00 0

S648SO 827191 LOS-01-09-T-E-S-OO 0

864853 B27082 l08-0l-10-T-E-S-00 0

864853 827113 LOS-01-11-T-E-S-OO 0

864853 827144 LOS-01-12-T-E-S-00 0

864853 827175 LOB-01-13-T-E-S-OO 0

864826 827066 LOS-01-1'-T-E-S-00 0

864826 827097 N

L08-0l-1 5-T-E-S-00 0

864826 827128 L08-0l T-E-S-OO 0

864826 827160 LOS-01-17-T-E-S-00 0

864799 B27082 LOS-01-18-T-E-S-00 0

864799 827113 0

10 20 40 60 80 L0&-01-19-T-E-S-OO 0

864799

&27144 Feet LOS-01 T-E -Q-00 0

864880 B27128 u

Hematite FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Decommissioning Survey Units 01and02 (LSA 08-01 and LSA 08-02)

Project Revision: 1 I Page 28 of 78 Table 6-2 below presents a tabular listing of all FSS samples collected within LSA 08-01 with associated IDs, sample types, collection intervals, coordinates, and notes.

Table 6-2 FSS Sample Locations and Coordinates for LSA 08-01 Hematite Procedure: HDP-PR-FSS-70 I, Final Status Survey Plan Development Decommissioning Appendix Project Revision: 10 P-4 Page I of !

APPENDIX P-4 FSS SAMPLE & MEASUREM ENT LOCATIONS & COORDINATES Survey Area:

LSA 08

==

Description:==

OQen Land Area, Tc-99 SEA Survey Unit:

I

==

Description:==

Central OQen Land Area S urve~ Unit in "Area 17" Survey Type:

FSS Classification:

Class I Measurement or Sample Surface or Start End Northing Easting Type (Y Axis)

Remarks I Notes ID CSM Elevation Elevation (X Axis)*

L08-0 1-0 I -T-E-S-00 Deep s

425.1 424.6 864934 827160 Excavation 6-inch grab L08-0 l-02-T-E-S-OO Deep s

425.6 425.1 864907 827113 Excavation 6-inch grab L08-01-03-T-E-S-OO Deep s

42 1.6 421.1 864907 827144 Excavation 6-inch grab L08-0l-04-T-E-S-OO Deep s

428.5 428.0 864907 827175 Excavation 6-inch grab L08-01-05-T-E-S-OO Deep s

423.3 422.8 864880 827097 Excavation 6-inch grab L08-0 1-06-T-E-S-OO Deep s

426.2 425.7 864880 827128 Excavation 6-inch grab L08-0 1-07-T-E-S-OO Deep s

425.2 424.7 864880 827 160 Excavation 6-inch grab L08-0 l-08-T-E-S-OO Deep s

428.5 428.0 864880 827191 Excavation 6-inch grab L08-0 1-09-T -E-S-00 Deep s

427.7 427.2 864853 827082 Excavation 6-inch grab L08-0 1-IO-T-E-S-OO Deep s

423.1 422.6 864853 8271 13 Excavation 6-inch grab L08-0 l-l l-T-E-S-OO Deep s

429.0 428.5 864853 827144 Excavation 6-inch grab L08-0 l-1 2-T-E-S-OO Deep s

424.4 423.9 864853 827175 Excavation 6-inch grab L08-0 l-13-T-E-S-OO Deep s

429. 1 428.6 864826 827066 Excavation 6-inch grab L08-0 1-14-T-E-S-OO Deep s

428.5 428.0 864826 827097 Excavation 6-inch grab L08-01-1 5-T-E-S-OO Deep s

429.4 428.9 864826 827128 Excavation 6-inch grab L08-0 1-16-T-E-S-OO Deep s

422.1 421.6 864826 827160 Excavation 6-inch grab L08-0 1-1 7-T-E-S-OO Deep s

429.4 428.9 864799 827082 Excavation 6-inch grab L08-0 l-1 8-T-E-S-OO Deep s

428.4 427.9 864799 827113 Excavation 6-inch grab L08-0 l-1 9-T-E-S-OO Deep s

424.2 423.7 864799 8271 44 Excavation 6-inch grab L08-01-06-T-E-Q-OO Deep Q

426.2 425.7 864880 827128 Lab QA Duplicate L08-0 1-23-T-E-Q-OO Deep Q

429.1 428.6 864846 827136 Lab QA Duplicate L08-0 1-20-T-E-B-OO Deep B

427.8 427.3 864950 827 160 6-inch Sidewall sample L08-01-2 1-T-E-B-OO Deep B

42 1.9 42 1.4 864908 827 126 Biased 6-inch grab L08-01-22-T-E-B-OO Deep B

428.2 427.7 864874 827 157 Biased 6-inch grab L08-01-23-T-E-B-OO Deep B

429.1 428.6 864846 827 136 Biased 6-inch grab L08-01-24-T-E-B-OO Deep B

426.0 425.5 864795 827 14 1 Biased 6-inch grab L08-0 l-25-T-E-B-OO Deep B

424.2 423.7 864939 827147 Biased 6-inch grab Green shaded samples are the samples at each sample

Elevations are in feet above mean sea level.

location, for use in WRS test.

- Missouri - East State Plane Coordinates [North American Datum (NAD) 1983] (Open Land Area)

CSM :

Three-Layer (Surface-Root-Deep) or Uniform Type:

Systematic = S, Biased = B; QC =Q; Investigation = I Quality Record

Hematite Decommissioning Project FSSFR Vohim~ 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 29 of 78 6.3 Biased Soil Sampling As discussed in FSSFR Volume 3, Chapter 1, Section 6.1.3, there are three key methods for identifying areas for biased soil sampling, the JAL, the Z-score of the FSS GWS, and the professional judgment of the HP Staff. For LSA 08-01 five (5) biased sample locations were selected within the SU based on the evaluation of the GWS survey data and HP Technician professional judgment. Biased samples are collected at the prescribed location to a depth of 6 inches below the exposed ground surface.

6.4 Judgmental/Sidewall Sampling for Tc-99 Sidewall sampling was prescribed in the FSS Plan developed for LSA 08-01 in accordance with the guidance provided in HDP-PR-FSS-70i, Final Status Survey Plan Development. See FSSFR Volume 3, Chapter 1, Section 5.2, Tc-99 Side Wall Sampling for further discussion.

During FSS of LSA 08-01, one (1) sidewall sample was collected.

See section 7.2.5, Judgmental/Sidewall Soil Sample for Tc-99 Results LSA 08-01 for further discussion.

6.5 Quality Control Soil Sampling Two QC field duplicate sample point were randomly selected and collected at systematic locations L08-01-06 and L08-01-23 for LSA 08-01.

6.6 LSA 08-01 Former Process Buildings Investigation Area and Hybrid Well Investigation The sampling of the investigation area began in July of 2013 and work was performed in accordance with Work Package HDP-ENG13-WP-009, Direct Push Technology Sampling at Hybrid Wells.

As provided in HEM-11-56 the soil sampling in the former Process Buildings Investigation Area consisted of 15 systematic sample stations located in the center of each grid square with approximately 40 feet spacing between locations. The investigation area was approximately 2230 m2 with each sample location representing approximately 149 m2.

For LSA 08-01 the systematic soil sample locations were locations 1 through 9 (see Figure 6-2 below).

For LSA 08-01 the Hybrid Well Investigation soil samples were located at abandoned groundwater monitoring locations BD-01, BD-02 and BD-03 (see Figure 6-2 below).

Hematite Decommissioning Project

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08-1 7 FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 30of 78 Figure 6-2 LSA 08-01 and LSA 08-02 Former Process Buildings Investigation Soil Sample and Hybrid Well Investigation Locations LE GE~D :

08-16

:-<*w Tc-99 Boring Hybrid \\\\'ells

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Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Lan£Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 31 of78 6.7 Elevated Measurement Comparison of Location Tc-99-7 A sampling campaign separate from FSS was performed to meet the requirements of the investigations as stated in Westinghouse letter HEM-11-56 to the NRC which contained the "Evaluation of Technetium-99 Under the Process Building" report (Appendix H). This sampling campaign identified one location with residual Tc-99 activity that exceeded the Tc-99 activity of any surrounding location. This location was identified as location Tc-99-7 in the report (See Figure 6-3).

Location Tc-99-7 at a depth interval of 20- to 24 feet was identified to contain 190 pCi/g of Tc-

99. Excavation at this location proceeded to 12 feet below the original ground surface. This was taken into account when the FSS Plan for LSA 08-01 was prepared, and the sample station density was significantly increased to account for the presence of elevated Tc-99 activity and to determine if any other areas of elevated Tc-99 activity could be identified. No other areas of elevated Tc-99 activity were identified, and no other Tc-99 sample result exceeded the Tc-99 DCGLw.

Therefore, an EMC investigation was performed for LSA 08-01 as required by Procedure HDP-PR-FSS-721 Final Status Survey Data Evaluation. The size of the associated elevated area surrounding this biased location was determined by using the nearest "clean" systematic and biased locations and the boundary edges of the SU itself to define a polygonal area of 40 m2 as calculated by GIS software. Following the steps presented in Section 8.6.7 of HDP-PR-FSS-721, the DCGLEMcs for all nuclides were calculated based on the nuclide-specific area factors corresponding to 40 m2* Then the difference between the activity of each nuclide in the elevated area and the average activity of the corresponding nuclide in the general SU area was divided by the nuclide-specific DCGLEMc to determine an activity fraction for each nuclide in the elevated area. These six activity fractions were added together for a total SOF of 0.22 for the EMC area.

This SOF is equivalent to a dose of 5.5 mrem/yr.

Additional information on the EMC calculation can be found in Appendix A.

It should be noted that all of the Tc-99 investigation samples surrounding location Tc-99-7 were considered acceptable as they did not exceed the Tc-99 DCGLw, indicating that the size of the elevated area is much smaller than the 40 m2 that was used as an estimate for the EMC investigation. This 40 m2 elevated area is based on the location of the surrounding systematic samples, and is being used as a conservative measure.

It should also be noted that the elevated area of Tc-99 is at a depth of 20 to 24 feet below the original ground surface (and approximately 8 to 12 feet below the lowest excavated surface),

therefore for the purposes of the EMC investigation, only the samples from the 20 to 24 foot depth interval were used. This is to ascertain the level of residual Tc-99 activity within the "layer" of sub-surface soil in the same manner that an EMC investigation is performed on a location that exists within the exposed excavation surface layer, only in this case, the "layer" is not exposed, and is covered by at least 8 feet of "clean" soil.

Hematite Decommissioning Project N

FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 32 of78 Figure 6-3 EMC Investigation Area within LSA 08-01

-01 EMC Area and Tc-99 Sample ations LOB-01-03-T-E-S-OO LOB-01-02-T-E-S-O O LOB-01-01-T-E-S-00 LOB-01-04-T-E-S-OO LOB-0 1-07-T-E-S-OO LOB-01-05-T-E-S-OO LOB 1 O-T-E-S-00 LOB-01 T-E-S-OO LOB-01-13-T-E-S-OO LOB-01-15-T-E-S-OO 08-01 ~LOB 12-T-E-S-OO 08-01 EMC Area

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LOB-01-11-T-E-S-OO 40 m 2

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--I' le 7d 08-02 Sample Above the DCGL 0 5 10 20 30 40 Feet Sample Below the DCGL LSA 08-01 Sys. Sample Locations 7.0 FINAL STATUS SURVEY RESULTS LSA 08-01 7.1 Gamma Walkover Survey Post-processed GPS coordinate data is accurate to within +/- 0.1 m for the handheld GPS models used during the GWS. The GWS maps are plotted and presented in a 2-D format.

When multiple data points are collected at the same GPS location during the walkover, the most elevated radiological measurements are plotted "on top" (e.g. if any sidewalls featured more elevated readings than the floor directly below, the sidewall radiological measurements would overlie the lower floor readings).

GWS measurements were collected in LSA 08-01 between December 10, 2015, and February 15, 2016.

7.1.1 GWS Results for LSA 08-01 For LSA 08-01, GWS count rates ranged between 5,586 gcpm and 15,406 gcpm, with a mean count rate of 10,562 gcpm. The median count rate was 10,536 gcpm and the standard deviation was 964 cpm. Figure 7-1 below presents a map of the complete GWS data set.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record/or Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Legend CPM Revision: 1 5586 - 12084 12085-13268 13269 -14453 14454 - 15637 Page 33of78 Figure 7-1 Colorimetric GWS Plot for LSA 08-01

-01 Garn Its LSA 08-01 1502 m2 Planar Area Survey Instruments -2x2 Nal detectors 44-10 290809 '13" - Cal Due 09/29/16 44-10 242821 'U " - Cal Due 04/15!16 44-10 242862 'P " - Cal Due 08/31/16 44-10 240325 "Q " - Cal Due 08/31/16 Normaized to Z Score cpm for Instrument B 01020 40 60 80

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An evaluation of the entire GWS data set was performed to evaluate those small areas of elevated activity which exceeded three (3) standard deviations above the GWS mean measurement, (i.e., "+ 3 Z-score"). Five locations were selected for biased sample collection based on evaluation of the GWS readings and HP Staff professional judgment. These biased locations represented the maximum GWS measurements encountered within the SU.

Figure 7-2 below presents a map of the +3 Z-score GWS measurements within LSA 08-01,

including the selected biased sampling locations.

FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Hematite Decommissioning Project Revision: 1 Page 34of78 Figure 7-2 Colorimetric GWS Plot for LSA 08-01 (Measurements > Z-score of 3)

Gamma alkover Survey 3+ Results L08-01-20-T-E-B-OO L08-01 T-E-B-OO L08-01-22-T-E-B-OO LSA 08-01 1502 m2 Planar Area LOB-01-24-T-E-B-OO Legend Z Score 3 ( 13269 - 14453 cpm) 4 ( 14454 - 15637 cpm)

I..

L08-01-23-T-E-B-OO Survey In struments - 2x2 Nal detectors 44-10 290809 "B" - Cal Due 09/29/16 44-10 242821 'D" - Cal Due 04/15n6 44-10 242862 '?" - Cal Due 08/31/16 44-10 240325 Q " - Cal Due 08/31/16 Normaized to Z Score cpm for Instrument B 0

10 20 --

40 60 N

All GWS data collected m LSA 08-01 was datalogged and post-processed m Graphical Information Software (GIS).

7.1.2 GWS Coverage Results LSA 08-01 FSSFR Volume 3, Chapter 1, Section 6.1.4, Exposed Surfaces versus Accessible Surfaces, provides a discussion and the criteria for evaluating the GWS coverage of a SU during FSS.

The post survey processing of the GPS data indicated that although 100% of accessible areas underwent GWS the GWS covered 99.96% of the SU (see Table 7-1).

As the evaluation indicates that the GPS coverage exceeded 95% with no readings approaching or exceeding the IAL of 4,000 net cpm in the vicinity of any apparent GPS coverage gaps, the GWS coverage for the SU has been evaluated to meet the intent of the " 100% GWS coverage" requirement.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Table 7-1 GWS Gap Analysis LSA 08-01 Total SU GWS Gap Gap Pixels Pixels Percentage LSA 08-01 246,293 101 0.04 7.2 Soil Sample Results LSA 08-01 GWS Coverage 99.96 I Page 35of78 MARS SIM Class 1

Appendix A presents the analytical results and associated statistics for all FSS surface samples collected within LSA 08-01.

7.2.1 Surface Soil Sample Results LSA 08-01 Within LSA 08-01 the surface and root stratums were completely removed. All remaining soil was evaluated under the Excavation Stratum DCGLws, however for the purposes of this report, all of the samples collected were collected from the exposed excavation surface to a depth of 6 inches.

The maximum Excavation SOF result for the samples collected from the exposed excavation surface was 0.32 (collected from sample L08-01-23-T-E-Q-OO).

7.2.2 Subsurface Soil Sample Results LSA 08-01 No subsurface sampling was performed in LSA 08-01. All samples were collected from the excavation stratum, and as such, were collected from the exposed excavation surface to a depth of 6 inches.

7.2.3 WRS Test Evaluation LSA 08-01 Per Step 7.8.3 of HDP-PR-FSS-721 Final Status Survey Data Evaluation, the Wilcoxon Rank Sum (WRS) statistical test was not required for LSA 08-01 since the difference between the maximum SU data set gross SOF and the minimum background area SOF was less than one using the Excavation Stratum criteria. However, for illustrative purposes, the WRS Test was still performed for LSA 08-01. All systematically collected samples regardless of depth are used to perform the WRS Test, however biased and QC sample results are not utilized in the WRS Test.

The 19 systematically collected samples in LSA 08-01 were ranked against the adjusted activity concentrations of the 32 samples collected within the Background Reference Area. The SU passed the WRS Test since the ranked sum of the reference area ranks, or test statistic WR, (1136) was greater than the critical value (917) for the test. As such, the null hypothesis that the SU average concentration.is greater than the DCGLw was rejected. The WRS evaluation is also included in Appendix A.

7.2.4 Graphical Data Review LSA 08-01 Table 7-2 below presents summary results for the all systematically collected samples (includes surface, and root, but not biased or QC samples) collected within LSA 08-01, and the associated SOF when compared to the Excavation Stratum DCGLws. The arithmetic average concentration resulted in a SOF of 0.05.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ 'and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 36of78 Table 7-2 LSA 08-01 FSS Sample Data Summary and Calculated SOF Values (Systematic)

Ra-226 Th-232 U-234 U-235 U-238 Sample Statistic DCGL= 1.9 Tc-99 DCGL DCGL=2.0 DCGL=195.4 DCGL=51.6 DCGL=168.8 SOF BKG = 1.07

= 25.1 (pCi/g)

BKG =1.0 (pCi/g)

(pCi/g)

(Excavation (pCi/g)

(pCi/g)

DCGL)

Average 0.116 0.335 0.112 3.603 0.195 1.247 0.05 Minimum 0.030 0.012 0.00 1.056 0.053 0.755 0.03

(<BKG)

Maximum 0.240 1.820 0.250 16.498 0.908 2.270 0.10 Notes:

I.

Ra-226 and Th-232 background activities subtracted prior to calculating SOF value. Ra-226 background without ingrowth = 0.9 pCi/g; Ra-226 background with ingrowth= 1.07 pCi/g. Negative SOF components are set to zero in SOF calculation.

2.

Average SOF for data set calculated using average radionuclide concentrations.

3.

U-234 values are inferred from the U-235/U-238 ratio.

Section 8.2.2.2 of MARS SIM recommends a graphical review of FSS analytical data, to include at a minimum, a posting plot and a histogram. A frequency plot, or histogram, is a useful tool for examining the general shape of a data distribution. This plot is a bar chart of the number of data points within a certain range of values. The frequency plot will reveal any obvious departures from symmetry, such as skewness or bimodality (two peaks), in the data distribution for the SU. The presence of two peaks in the SU frequency plot may indicate the existence of isolated areas of residual radioactivity.

Figure 7-3 presents the overall statistical metrics for the SOF parameter for the 16 systematically collected samples from LSA 08-01. The top graph is a histogram and line plot of the SOF for the systematic data population for LSA 08-01. The middle graph presents the mean SOF (0.05 as indicated by the blue vertical line) of the sample population and the 95% confidence interval of the mean SOF represented by the blue diamond which is 0.04 to 0.07. The 98.08% confidence interval based on the median (0.05) of the sample results is 0.04 to 0.08. The bottom two charts present the various statistical metrics of the LSA 08-01 SOF data set, including the mean, median, standard deviation, minimum, maximum, confidence intervals, etc.

Figure 7-3 exhibits no unusual symmetry or bimodality concerns for the LSA 08-01 data associated with the systematically collected measurement locations.

Hematite FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Decommissioning Survey Units 01and02 (LSA 08-01 and LSA 08-02)

Project Revision: 1 I Page 37of78 Figure 7-3 Graphic Statistical Summary for LSA 08-01 (SOF parameter) 10 9

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0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1

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0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1

LSA 08-01 Sys SOF N

19 Mean 95% Cl Mean SE SD Variance Skewness Kurtosis LSA 08-01 Sys 0.05 0.04 to 0.07 0.005 0.02 0.00 0.4

-1.15 SOF 1st 3rd Minimum quartile Median 98.08% Cl quartile Maximum IQR LSA 08-01 Sys 0.03 0.04 0.05 0.04 to 0.08 0.08 0.1 0.04 SOF

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Surve Units 01and02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 38of78 A posting plot is simply a map of the SU with the data values (in this case the SOF values for each systematically collected sample) entered at the measurement locations. This potentially reveals heterogeneities in the data - especially possible patches of elevated residual radioactivity.

The posting plot for LSA 08-01 is presented below in Figure 7-4. Figure 7-4 shows no unusual patterns in the data.

Figure 7-4 Posting Plot for LSA 08-01 Systematic Measurement Locations l08 1.01-T-E-S-OO Q0.05 L08-01.03-T-E-S-OO L08-01 T-E-S-Q 0.03 Q

0.03Q LO 04-T-E-S-OO LSA08-01 1502 m2 Planar Area 0.05 l08-01.06-T-E-S-OO l08-01-06-T-E-Q.OO 0.07 L08-01 T. -S.00 Q 0.05 Q

Q 0.05Q L08-01-08-T-S 0 0.10 L08-01.07-T-E-S.OO 0.03 l08-01 T-E-S.OO 0.09 O~

LOB-Ol j l -T-E-S.OO 0.04Q L08-01 T. -S-00 L08-01 T-E-S.OO 0.04 Q

l08-01-16-T-E-S.O 0~6 l08-01 T-E-S-OO o]a L08-01 T-E-S-OO LOB-01 T-E-,OO Q0.08 80

-==-c:::::J---====---Feet 40 60 Q

0.03Q L 19-T-E-S-OO 0.03 N

Appendix A to this report presents the complete analytical data set (in Microsoft Excel format) used to derive the summary statistics presented in Table 7-2, Figure 7-3, and Figure 7-4 above.

A summary of the analytical data is presented in Table 7-3 below.

Appendix E to this report presents the TestAmerica Analytical Laboratory soil sample reports.

Hematite Decommissioning Project Q

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E 111 en L08-01-01-T-E-S-OO L08-01-02-T-E-S-OO L08-01 T-E-S-OO L08-01-04-T-E-S-OO L08-01-05-T-E-S-OO L08-01-06-T-E-S-OO L08-01 T-E-S-OO L08-01-08-T-E-S-OO L08-01-09-T-E-S-OO L08-01-1 O-T-E-S-00 L08-01-11-T-E-S-OO L08-01-12-T-E-S-OO Cl> c.

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L08-01-14-T-E-S-OO 18.00 S

L08-01-15-T-E-S-OO 19.00 S

L08-01-16-T-E-S-OO 20.00 S

L08-01 -1 7-T-E-S-OO 21.00 S

L08-01-18-T-E-S-OO 22.00 S

L08-01-19-T-E-S-OO 23.00 S

L08-01-06-T-E-Q-OO 24.00 Q

L08-01-23-T-E-Q-OO 25.00 Q

L08-01-20-T-E-B-OO 26.00 B

L08-01 T-E-B-OO 27.00 B

L08-01-22-T-E-B-OO 28.00 B

L08-01-23-T-E-B-OO 29.00 B

L08-01 T-E-B-OO 30.00 B

L08-01 T-E-B-OO 31.00 B

FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 1.210 0.161 0.055 NIA 0.140 1.170 0.158 0.061 NIA 0.100 1.100 0.166 0.080 NIA 0.030 1.120 0.1 53 0.060 NIA 0.050 1.170 0.179 0.088 NIA 0.100 1310 0.174 0.070 NIA 0.240 1.180 0.171 0.078 NIA 0.110 1.190 0.158 0.062 NIA 0.120 1.270 0.185 0.073 NIA 0.200 1.210 0.171 0.074 NIA 0.140 1.210 0.165 0.076 NIA 0.140 1.180 0.169 0.075 NIA 0.110 1.1 70 0.160 0.067 NIA 0.100 1.170 0.177 0.082 NIA 0.100 1.200 0.1 58 0.055 NIA 0.1 30 1.170 0.1 56 0.064 NIA 0.100 1.210 0.170 0.071 NIA 0.140 1.110 0.154 0.068 NIA 0.040 1.180 0.177 0.079 NIA 0.110 1.070 0.146 0.058 NIA 0.000 1.290 0.189 0.080 NIA 0.220 1.020 0.141 0.050 NIA

-0.050 1.110 0.152 0.063 NIA 0.040 1.180 0.176 0.084 NIA 0.110 1.130 0.155 0.066 NIA 0.060 1.010 0.149 0.077 NIA

-0.060 0.962 0.150 0.077 NIA

-0.108 Table 7-3 Final Status Surve Anal tical Data: LSA 08-01

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w 0.140 0.063 0.063 0.024 0.206 U

1.070 0.160 0.104 NIA 0.070 0.070 3.225 NA NA NA 0.174 0.129 0.213 U

1.350 0.484 0.720 NIA 2.0 0.100 0.112 0.112 0.049 0.212 U

1.030 0.158 0.121 NIA 0.030 0.030 2.175 NA NA NA 0.118 0.139 0.222 U

0.841 0.280 0.797 NIA 2.2 0.030 0.044 0.044 0.077 0.210 U

1200 0.191 0.084 NIA 0.200 0.200 2.240 NA NA NA 0.120 0.148 0.257 U

1 070 0.386 0.965 NIA 1.8 0.050 0.263 0.263 0.070 0.207 NIA 1040 0.158 0.105 NIA 0.040 0.040 1.788 NA NA NA 0.092 0.145 0.241 U

1.200 0.532 0.819 NIA 1.2 0.100 0.013 0.013 0.044 0.219 U

1.090 0.212 0.108 NIA 0.090 0.090 5.580 NA NA NA 0.307 0.192 0.226 NIA 0.755 0.332 0.947 U

6.0 0.240 0.127 0.127 0.022 0.204 U

1.230 0.171 0.116 NIA 0.230 0.230 2.740 NA NA NA 0.149 0.129 0.189 U

1.000 0.284

0. 747 NIA 2.3 0.110 0.713 0.713 0.111 0.199 NIA 1.150 0.177 0.124 NIA 0.150 0.150 4.058 NA NA NA 0.223 0.154 0.213 NIA 1.140 0.337 0.899 NIA 3.0 0.120 0.604 0.604 0.093 0.203 NIA 1.090 0.159 0.079 NIA 0.090 0.090 2.160 NA NA NA 0.114 0.154 0.227 U

1.180 0.539

0. 710 NIA 1.5 0.200 0.012 0.012 0.032 0.208 U

1.210 0.210 0.141 NIA 0.210 0.210 1.056 NA NA NA 0.053 0.174 0.292 U

0.854 0.349 1.010 U

1.0 0.140 0.070 0.070 0.016 0.202 U

1.020 0.175 0.096 NIA 0.020 0.020 1.527 NA NA NA 0.076 0.120 0.225 U

1.420 0.649 0.818 NIA 0.9 0.140 0.224 0.224 0.051 0.201 NIA 1.180 0.188 0.115 NIA 0.1 80 0.1 80 16.498 NA NA NA 0.908 0.205 0.214 N/A 2.270 0.646 0.922 NIA 5.9 0.110 0.774 0.774 0.1 00 0.206 NIA 1.010 0.165 0.111 NIA 0.010 0.010 1.374 NA NA NA 0.069 0.124 0.236 U

1.070 0.301 0.794 NIA 1.0 0.100 0.024 0.024 0.032 0.204 U

1.220 0.175 0.075 NIA 0.220 0.220 3.252 NA NA NA 0.179 0.159 0.201 U

0.846 0.331 0.857 U

3.2 0.100 0.304 0.304 0.040 0.199 NIA 1.170 0.194 0.1 35 NIA 0.170 0.170 2.882 NA NA NA 0.153 0.181 0.279 U

1.490 0.711 0.91 7 NIA 1.6 0.130 0.115 0.115 0.061 0.203 U

1.020 0.143 0.094 NIA 0.020 0.020 2.411 NA NA NA 0.128 0.1 26 0.219 U

1.240 0.510 0.781 NIA 1.6 0.100 1.820 1.820 0.241 0.221 NIA 1.150 0.163 0.128 NIA 0.1 50 0.150 2.549 NA NA NA 0.1 36 0.118 0.191 U

1.240 0.492 0.748 NIA 1.7 0.140 0.104 0.104 0.052 0.223 U

1.250 0.198 0.138 NIA 0.250 0.250 2.381 NA NA NA 0.127 0.11 3 0.188 U

1.160 0.659 0.886 NIA 1.7 0.040 0.614 0.614 0.078 0.214 NIA 0.973 0.170 0.091 NIA

-0.027 0.000 8.964 NA NA NA 0.495 0.137 0.187 NIA 1.890 0.572 0.819 NIA 4.0 0.110 0.372 0.372 0.034 0.222 NIA 0.923 0.168 0.197 NIA

-0.077 0.000 1.591 NA NA NA 0.076 0.1 70 0.280 U

1.670 0.413 0.901 NIA 0.7 0000 0.121 0.1 21 0.026 0.208 U

1.130 0.162 0.097 NIA 0.130 0.130 2.084 NA NA NA 0.1 10 0.121 0.221 U

1.180 0.485 0.741 NIA 1.5 0.220 0.428 0.428 0.077 0.222 NIA 0.989 0.175 0.128 NIA

-0.011 0.000 194.640 NA NA NA 8.680 0.970 0.392 NIA 2.440 0.658 1.370 NIA 35.6 0.000 0.038 0.038 0.020 0.231 U

1.040 0.156 0.073 NIA 0.040 0.040 2.347 NA NA NA 0.127 0.137 0.218 U

0.943 0.301 0.707 NIA 2.1 0040 0.200 0.200 0.056 0.230 U

1.220 0.1 85 0.098 NIA 0.220 0.220 2.399 NA NA NA 0.128 0.129 0.174 U

1.180 0.527 0.814 NIA 1.7 0.11 0 0.743 0.743 0.101 0.223 NIA 1.040 0.182 0.082 NIA 0.040 0.040 8.489 NA NA NA 0.463 0.166 0.1 98 NIA 0.873 0.316 0.868 NIA 7.7 0.060 0.554 0.554 0.095 0.238 NIA 1.110 0.164 0.118 NIA 0.110 0.110 137.028 NA NA NA 6.320 0.725 0.308 NIA 2.210 0.511 1.100 NIA 30.8 0.000 0.309 0.309 0.079 0.230 NIA 1.160 0.1 67 0.083 NIA 0.1 60 0.1 60 4.176 NA NA NA 0.228 0.1 61 0.1 93 NIA 1.390 0.479 0.702 NIA 2.5 0.000 0.087 0.087 0.041 0.223 U

1.220 0.222 0.111 NIA 0.220 0.220 3.903 NA NA NA 0.215 0.132 0.202 NIA 1.000 0.393 1.020 U

3.3 0.030 0.012 0.000 1.056 0.053

0. 755

3. 7 With in rowth, use Ra226 bk 1.07 Th232 bk

1.0 NOTES

Gross results in units of pCilg

Background with ingrowth (1.07 pCilg) subtracted from gross result

- Background (1.0 pCilg) subtracted from gross result U qualifier: A normal, non-detected result (result less than MDC).

All uncertainty values are reported at the 2-sigma confidence level.

u..

0 en

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 j Page 40 of 78 7.2.5 Biased Soil Sample Result LSA 08-01 Five (5) biased samples were collected from 1SA 08-01. The sample collected at location 108-01-23 represented the maximum GWS measurement (15,637 gcpm) within the SU, and had a result of 0.32 Excavation SOF.

7.2.6 Judgmental/Sidewall Soil Sample for Tc-99 Results LSA 08-01 One sample was collected from the sidewalls of LSA 08-01.

Table 7-4 provides the data summary for the sample.

Table 7-4 LSA 08-01 Sidewall Sample Data Summary and Calculated SOF Values Ra-226 Tc-99 Th-232 U-234 U-235 U-238 SampleSOF DCGL=S.41 DCGL=

DCGL=S.2 Sample ID BKG=0.9

. 74.0 BKG=l.O DCGL=872.4 DCGL=208.l DCGL=SSI.l (Uniform (oCi/2)

(oCi/g)

(pCi/g)

DCGL)

L08-01-20-T~E-B-OO 1.02 0.038 1.04 2.347 0.127 0.943 0.01 7.2.7 Quality Control Soil Sample Result LSA 08-01 Two QC field duplicate sample points were randomly selected for 1SA 08-01 which were collected at systematic locations 108-01-06and108-01-23.

For the 25 samples (i.e., 19 systematic+ 5 biased+ 1 sidewall) collected within LSA 08-01, two field duplicate samples were collected.

This frequency equates to 8%, (i.e. 2/25).

Form HDP-PR-FSS-703-1 documents that the duplicate sample result comparison with the partner's sample results that all comparison criteria were less than the calculated warning limits (see Figure 7-5 below).

Hematite FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA Decommissioning 08-01 and LSA 08-02)

Project Revision: 1 Page 41 of78 Figure 7-5 Form HDP-PR-FSS-703-1 Field Duplicate Sample Assessment LSA 08-01 (1of2)

Procedure: HDP-PR-FSS-703, Final Status Survey Quality Control Hematite Decommissioning Project Revision: 2 Page I of 1 FORM HDP-PR-FSS-703-1 FIELD DUPLICATE SAMPLE ASSESSMENT Survey Unit No.:

LSA 08-01 Survey Unit

Description:

Open Land Area. Tc-99 SEA Field Duplicate Sample Average Nuclide Statistic Field Duplicate Sample (pCi/g)

(pCi/g)

Activity (j( )

DCGL Warning Control Exceeds Limit?

Sample ID Sample ID Radionuclide Activity (xi)

MDC Activity (xi)

MDC (pCi/g)

(pCi/g)

Statistic2 Limit Limit (YIN)

L08-01-23-T-E-B-OO L08-01-23-T-E-Q-OO Ra-226 1.130 0.066 1.290 0.080 1.210 5.4 0.160 0.764 1.145 N

L08-01-23-T-E-B-OO L08-01-23-T-E-Q-OO Tc-99 0.554 0.238 0.428 0.222 0.491 74 0.126 10.471 15.688 N

L08-01-23-T-E-B-OO L08-01-23-T-E-Q-OO Th-232 I. I I 0 0.118 0.989 0.128 1.050 5.2 0.121 0.736 1.102 N

L08-01-23-T-E-B-OO L08-01-23-T-E-Q-OO U-234 1 137.028 NIA 194.640 NIA 165.834 872.4 57.612 123.445 184.949 N

L08-01-23-T-E-B-OO L08-01-23-T-E-Q-OO U-235 6.320 0.308 8.680 0.392 7.500 208.1 2.360 29.446 44.117 N

L08-01-23-T-E-B-OO L08-01-23-T-E-Q-OO lJ-238 2.210 I.JOO 2.440 1.370 2.325 551.1 0.230 77.981 116.833 N

Comments:

I. lJ-234 is inferred. no MDC available.

2. Duplicate assessment is not necessary irthc result of either sample is< MDC.

Pt:rformed by: Thomas Yardy

/J:~ ~

~LL Reviewed by: Clark Evers / /JJ. / ',t r

Date:

T - 2 7-/ 7 Date: :zl1S/17 Quality Record

Hematite FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA Decommissioning 08-01 and LSA 08-02)

Project Revision: 1 J Page 42of78 Figure 7-5 Form HDP-PR-FSS-703-1 Field Duplicate Sample Assessment LSA 08-01 (2of2)

Procedure: HDP-PR-FSS-703, Final Status Survey Quality Control Hematite Decommissioning Project Revision: 2 Page 1 of I FORM HDP-PR-FSS-703-1 FIELD DUPLICATE SAMPLE ASSESSMENT Survey Unit No.:

LSA 08-01 Survey Unit

Description:

Open Land Area, Tc-99 SEA Field Duplicate Sample Average Nuclide Statistic Field Duplicate Sample (pCi/g)

(pCi/g)

Activity <x)

DCGL Warning Control Exceeds Limit?

Sample ID Sample ID

.Radionuclide Activity (x;)

MDC Activity (x;)

MDC (pCi/g)

(pCi/g)

Statistic2 Limit Limit (YIN)

L08-0 l-06-T-E-S-OO L08-01-06-T-E-Q-OO Ra-226 1.310 0.070 1.070 0.058 1.190 5.4 0.240 0.764 1.145 N

L08-0 l T-E-S-OO L08-01-06-T-E-Q-OO Tc-99 0.127 0.204

. 0.121 0.208 0.124 74 NA 10.471 15.688 NA L08-01-06-T-E-S-OO L08-01-06-T-E-Q-OO Th-232 1.230 0.116 1.130 0.097 1.180 5.2 0.100 0.736 1.102 N

L08-01-06-T-E-S-OO L08-01-06-T-E-Q-OO U-234 1

2.740 NIA 2.084 NIA 2.412 872.4 0.656 123.445 184.949 N

L08-01-06-T-E-S-OO L08-0 l-06-T-E-Q-OO U-235 0.149 0.189 0.110 0.221 0.130 208.1 NA 29.446 44.117 NA L08-01-06-T-E-S-OO L08-01-06-T-E-Q-OO U-238 1.000 0.747 1.180 0.741 1.090 551.1 0.180 77.981 116.833 N

Comments:

1. U-234 is inbred. no MDC available.

2. Duplicate assessment is nol necessary if the result of either sample is< MDC.

Performed by: Thomas Yardy

~ ~~

Reviewed by: Clark Evers I/) r~*

A,A- ----*

Dale:

2 7 - / 7 Date: ]/;_i/1?

Quality Record

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 43 of78 7.3 Tc-99 Hot Spot Assessment LSA 08-01 For LSA 08-01, the Tc-99 hotspot assessment was actually performed as part of the FSS planning stage.

The highest observed Tc-99 sample result collected from LSA 08-01 was 190 pCi/g a Tc-99 investigation area sample. As this sample result exceeds the Uniform DCGLw (and an EMC investigation was performed in the SU), it was identified that additional systematic samples must be collected to account for the presence of areas of elevated Tc-99 contamination.

Using 190 pCi/g as the maximum reasonable level ofTc-99 that could potentially be encountered within the SU, and the Tc-99 DCGLw of 74 pCi/g, an AF of 2.57 would be needed (assuming that the average Tc-99 activity was 190 pCi/g across a very large portion of the SU). In order to support an AF of 2.57, at least 1 systematic sample must be collected for every 79 m2 within the SU (using the table provided in Appendix E of HDP-PR-FSS-721 (Table 14-12 in Chapter 14 of the DP), and interpolating the area of 79 m2 provides an Excavation Area Factor (AF) of 2.57 for Tc-99). The surface area covered by the SU is 1,502 m2, meaning that 19 systematic locations must be collected within the SU to result in 1 sample per 79 m2. The hypothetical DCGLEMC is then determined by multiplying the DCGLw by the AF, which results in a maximum DCGLEMC value of 190 pCi/g for Tc-99.

While the number of systematic samples was increased in LSA 08-01 to account for the potential presence of Tc-99 hotspots, it should be noted that the actual area that was identified to be elevated was much smaller (40m2 as detailed in the EMC investigation), and no other areas of elevated Tc-99 activity were identified within the SU. Given that the number of systematic samples was increased significantly to account for any potential additional Tc-99 contamination, that no additional elevated Tc-99 contamination was identified, and that the hypothetical maximum calculated DCGLEMC for Tc-99 was not exceeded, the Tc-99 hotspot assessment is considered successful.

7.4 LSA 08-01 Former Process Buildings Investigation Area Results and Hybrid Well Investigation Results The collected samples were sent to Test America for analysis and the results were compared against the Uniform and Excavation DCGLs.

All 15 locations had results that were below a sum-of-fraction of 1.0 using the Uniform and Excavation Scenario DCGLs with the exception of location Tc-99-7.

Location Tc-99-7 exceeded a SOF of 1.0 in the samples collected from 20 to 24 feet bgs interval had a SOF of 2.58

using the Excavation Scenario DCGL. The results including actual depths are provided in of Appendix H.

In August of 2013, three additional sample locations (locations Tc-99-16 through 18) were collected down to the sand gravel layer to bound location Tc-99-7 to the west. All of the samples from these three locations had a SOF less than 1.0 for both Uniform and the Excavation Scenario DCGLs.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 44 of78 In October of 2013, five additional investigation locations (locations Tc-99-7 A through 7E) were

. collected to the sand gravel layer around location Tc-99-7. Excavation to approximately 7.0 to 7.5 feet had been performed in the area around location Tc-99-7 prior to collecting these additional locations. None of these 5 sample locations exceeded the Excavation DCGL. The results for the samples associated with the Tc-99 investigation are presented in Attachment 2 of Appendix H.

The EMC investigation of location Tc-99-7 is discussed above in Section 6.6 and concludes that the area is suitable for release. Furthermore, the Former Process Building Area and Hybrid Well investigation concludes that there are no other areas of concern in LSA 08-01.

8.0 ALARA EVALUATION LSA 08-01 All samples collected within LSA 08-01 were evaluated against the Excavation Stratum DCGLw.

For LSA 08-01 no PSS sample result exceeded a SOP of 1.0, however one historical elevated Tc-99 result remains within the unexcavated portions of the LSA and is factored into the SU final dose via the EMC investigation process. The average SOP result, based on all systematically collected samples, was 0.05 for LSA 08-01. The average SOP equates to residual activity contributions from the survey unit area of 1.25 mrem/yr for LSA 08-01.

The EMC area associated with location Tc-99-7 was determined to result in a residual radioactivity contribution of 0.22 SOP, which equates to an additional 5.5 mrem/yr dose contribution.

Groundwater Monitoring Well data provided in FSSFR Volume 6, Chapters 2 and 3 {ML16287A528}, and Chapter 4 {ML16342B552}, indicate that the groundwater dose contribution will be a fraction of the MCLs. Nevertheless, a maximum groundwater contribution assumption of 4.0 mrem/yr based upon the U.S. Environmental Protection Agency (EPA) MCLs will be added to the total estimated dose for LSA 08-01. And finally, portions of Combined Reuse Stockpile 4-7 were placed into LSA 08-01, therefore an additional 6.25 mrem/yr will be added to account for the additional dose contribution form reuse soil. Adding these dose contributions together, the total estimated dose for LSA 08-01 is 17.0 mrem/yr.

Since the estimated Total Effective Dose Equivalent is below the regulatory release criterion of 25 mrem/yr, the conclusion of the ALARA evaluation is that the PSS of LSA 08-01 was successful and that there would be no discernable benefit to the health and safety of the public in attempting to further reduce the results of PSS by performing additional remediation of LSA 08-01.

9.0 FSS PLAN DEVIATIONS LSA 08-01 During a NRC Inspection on December 15, 2015, the NRC Inspector observed that during PSS of LSA 08-01, the contracted PSS Technician performing a GWS was traversing an area with a survey meter and the height of the probe did not appear to be 3 inches or less from the soil. The NRC Inspector took a photograph of the survey technique and immediately notified HDP Management who agreed that the photograph indicated that the survey probe distance did not appear to be 3 inches or less from the soil. This event resulted in a Severity Level IV Violation

{ML16172A285}.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 45 of78 The RSO recognized that this was the second instance in which the distance at which the FSS Technicians were surveying came into question.

The first instance is described in NRC Inspection report {ML15334A404}.

As this was a repeat event, the RSO issued a Stop Work order to the FSS Contractor on all FSS field work and terminated FSS of LSA 08-01. The GWS in question was discarded. The event was entered into the Westinghouse Corrective Action System (CAPAL Issue #100349993).

~

Westinghouse provided a response to the violation in Westinghouse letter HEM-15-131

{ML15357A074}. In the response Westinghouse provided that HDP Management and the FSS Contract Supervisor performed a preliminary causal assessment which indicated the reason for the event was the oversensitivity to observation of the GPS Handset to ensure adequacy of GWS coverage. HDP Management was able to review additional photographs the NRC Inspector took of the performance of the GWS and noted that the FSS Technician's oversensitivity to observation of the GPS Handset.

Based upon the preliminary causal assessment, the FSS Contractor developed and presented formal training to the two former Health Physics Technicians and the new Health Physics Technicians (employed after September 30, 2015).

The focal point of the training was to maintain the primary focus on the gamma walk over technique and to pause the GWS when observing the GPS.

The FSS Contractor conducted an individual counseling session on adherence to procedural requirements with the Health Physics Technician that performed the survey on December 15, 2015, in LSA 08-11.

Upon the completion of all corrective actions a new FSS was successfully completed.

9.1 Remedial Actions during FSS There was no remedial action after FSS in LSA 08-01.

9.2 Adjustments to Scan MDC Calculations Scan MDCs for LSA 08-01 were calculated in accordance with HDP-PR-FSS-701, Revision 10, Final Status Survey Plan Development and HDP-TBD-FSS-002, Revision 3, Evaluation and Documentation of the Scanning Minimum Detectable Concentrations (MDC) for Final Status Surveys (FSS).

The assumed LSA background count rate of 13,000 cpm was applied to determine the prospective Scan MDCs, and the actual mean count rate from the FSS survey was 10;562 cpm. Therefore the calculated Scan MpCs are conservative, and no adjustments fleed to be made.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01and02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 46 of78 10.0 DATA QUALITY ASSESSMENT The Data Quality Objective (DQO) process is thoroughly integrated within the DP and Hematite FSS procedures. The steps of the DQO process are presented in Volume 3, Chapter 1, Section 4.0 of the FSSFR and correspond to the DQO steps described in Chapter 14, Section 4.2.1 of the DP. The HDP DQO process reflects the recommendations given in MARSSIM, Chapter 2, Figure 2-2.

10.1 Data Quality Assessment for LSA 08-01 The Data Quality Assessment of the survey methodology, sampling and sample analysis results, and the Quality Control sampling and analysis results to ascertain the validity of the conclusion for LSA 08-01 (see Figure 10-1) provides the following:

The field and laboratory instruments utilized were capable of detecting activity at an MDC less than the appropriate investigation level, and were verified to be operable prior to and after use in accordance with HDP-PR-HP-416 (Operation of the Ludlum 2221 for Final Status Survey).

The calibration of all instruments that were used to measure or analyze data was current at the time of use and the calibrations of the instruments were performed using a NIST traceable source. The instruments used were successfully source checked prior to and after use.

The systematic samples that were collected (on a random-start triangular grid) and the gamma scan surveys that were conducted were performed in accordance with procedure HDP-PR-FSS-711, Final Status Surveys and Sampling of Soil and Sediment.

All samples sent for analysis at the approved offsite laboratory (TestAmerica) were tracked on a chain of custody form in accordance with HDP-PR-QA-006, Chain of Custody.

Quality Control sample results were verified to meet the acceptance criteria as specified in HDP-PR-FSS-703, Final Status Survey Quality Control.

LSA 08-01 survey and sample results were independently reviewed and validated in accordance with HDP-PR-FSS-721 Final Status Survey Data Validation.

The WRS Test is not necessary when the difference between the maximum SU data set measurement SOF and the minimum background area measurement SOF is less than or equal to one. For LSA 08-01, no individual gross SOF result in the FSS data set exceeded the SOF of the minimum background reference area measurement by more than one using the Uniform Stratum criteria. Therefore, the WRS Test was not required for LSA 08-01. However, the WRS Test was still performed for illustrative purposes. Since the test statistic, WR (1136) exceeded the critical value (917), the FSS data set passed the WRS Test and the null hypothesis was rejected. The WRS Test worksheet is presented in Appendix A.

A biased soil samples was collected from the location of the highest gamma count rate within the SU, with a maximum result of 0.23 Excavation SOF.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA OB-OJ and LSA 08-02)

Revision: 1 Page 47 of78 The maximum SOF result for all surface samples within LSA 08-01 was 0.23.

The maximum SOF result for all subsurface samples within LSA 08-01 was 2.58 (location Tc-99-7). An EMC investigation was performed and concluded that the area is suitable for release.

The average SOF result for all systematically collected samples within LSA 08-01 was 0.05, with an upper 95% confidence level (UCLmean 0.95) of 0.07.

No FSS sample result in LSA 08-01 exceeded a SOF of 1.0 as compared to the Excavation Stratum criteria, however an elevated measurement comparison (EMC) was required due to the presence of elevated residual Tc-99 activity at location Tc-99-7.

The results of the EMC investigation were successful and concluded that despite the elevated residual soil activity, the area is still suitable for release as the SU final residual radioactivity considering all contributing factors does not exceed 25 mrem/yr.

A retrospective sampling frequency evaluation was performed to determine if sufficient statistical power exists to reject the null hypothesis based on the total number (19) of systematic samples actually collected within LSA 08-01. The successful result of the retrospective power evaluation presented in Table 10-1 for LSA 08-01 indicates that the minimum number of samples required (8) for the WRS Test were less than the number of sampling locations actually collected within LSA 08-01.

The methodology used for the retrospective sampling frequency evaluation is similar to the prospective sample size determination performed during FSS Plan Development except that actual FSS sample results and statistics are used in the sample size verification. Specifically, the mean and standard deviation of the eight LSA surface samples (i.e., the WRS Test sample data set) are used to derive the relative shift for each LSA. Given the HDP Type I and Type II errors of 0.05 and 0.10, respectively, the calculated relative shift is then correlated to a minimum sample size number as provided in Table 5-1 of MARS SIM.

HDP staff ensured that a visual inspection of the SU configuration, the Isolation

& Control measures and the Pre-backfill G\\VS was completed for LSA 08-01 prior to the commencement of backfill operations. Additionally a confirmatory GWS was performed of the SU within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to the commencement of backfill operations. The results of the confirmatory GWS were compared to the results of the FSS GWS and the comparison determined that there were no changes within the LSA since FSS was performed.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Table 10-1 Retrospective Sample Size Verification for LSA 08-01 N/2 Value Verification lsoto es SOF (Ra/Tc/Th/lso U St. Dev.

0.02 DCGLsoF LBGR Mean 0.05 Shift 0.95 Relative Shift (t:i/o) 42.05 MARSSIM Table 5.1 Pr 1.000000 N

12 N + 20%

14.4 N/2 8

FSS N/2 19 Verification Check "N/2" Corresponds to the number of survey unit measurement locations re uired for the WRS Test MARSSIM Table 5.1 fl/a Pr 0.1 0.528182 0.2 0.556223 0.3 0.583985 0.4 0.611335 0.5 0.638143 0.6 0.664290 0.7 0.689665 0.8 0.714167 0.9 0.737710 1.0 0.760217 1.1 0.781627 1.2 0.801892 1.3 0.820978 1.4 0.838864 1.5 0.855541 1.6 0.871014 1.7 0.885299 1.8 0.898420 1.9 0.910413 2.0 0.921319 2.25 0.944167 2.5 0.961428 2.75 0.974067 3.0 0.983039 3.5 0.993329 4.0 0.997658 4.01 1.000000 Page 48 of78 MARSSIM Table 5.2, a= 0.05, 13 = 0.10 a (or 13)

Z1-a (or Z1.a) 0.005 2.576 0.01 2.326 0.015 2.241 0.025 1.960 0.05 1.645 0.10 1.282 0.15 1.036 0.2 0.842 0.25 0.674 0.30 0.524

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 49 of 78 Figure 10-1 Data Evaluation Checklists prepared for LSA 08-01 (page 1 of 2)

Procedure: HDP-PR-FSS-721, Final Status Survey Data Evaluation Hematite Decommissioning Project APPENDIX G-1 Revision: 10 Appendix G-I.

Page 1 of2 FINAL STATUS SURVEY DATA QUALITY OBJECTIVES REVIEW CHECKLIST Survey Area:

Sun*ey Unit:

LSA08 01

==

Description:==

Open Land Area, Tc-99 SEA

==

Description:==

Central Open Land Area Survey Un it in "Area 17'"

1.

Have all measurements and/or analysis results that will be subjected to data analysis for FSS been individually reviewed and validated in Yes~ NoO accordance \\yith Section 8.1 of this procedure?.

2.

Have all systematic measurements and/or samples been taken or acquired at the locations specified in the FSSP and the FSS Sample Yes~ NoO Instructions?

3.

Have all scans surveys been performed of the areas specified as Yes~ NoO required in the FSSP and the FSS Sample Instructions?

4.

Have all biased measurements and/or samples been taken or acquired Yes~ NoO NAO at the locations specified in the FSSP & the FSS Sample Instructions?

5.

Have duplicate and/or split samples or measurements been taken or Yes~ NoO NAO acquired at each location designated as a QC sample?

6.

Were the instruments used to measure or analyze the survey data capable of detecting the ROCs or gross activity at a MDC less than Yes~ NoD the appropriate investigation level?

7.

Was the calibration of all instruments that were used to measure or analyze data, current at the time of use and were those calibrations Yes~ NoD perfom1ed using a NIST traceable source'?

8.

Were the instruments successfully response-checked before use and, Yes~ NoD where required. after use on the day the data was measured?

9.

Do the samples match those identified on the chain of custody?

Yes~ NoO NAO IO.

Do the QC Sample Results meet the acceptance criteria as specified in Yes~ No0NA0 HDP-PR-FSS-703, Final Status Survey Quality Control?

lL Are all Laboratory QC parameters within acceptable limits?

Yes~ No0NA0 If "No" was the response to any of the questions above. then document the discrepancy as well as any corrective actions that were taken to resolve the discrepancy.

Comments: N/ A Quality Record

Hematite FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Decommissioning Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Project Revision: 1 I Page 50of78 Figure 10-1 Data Evaluation Checklists prepared for LSA 08-01 (page 2 of 2)

Procedure: HDP-PR-FSS-721. Final Status Survey Data Evaluation Hematite Decommissioning Appendix G-1.

Project Revision: 10 Page 2 of2 APPENDIX G-1 FINAL STATUS SURVEY DATA QUALITY OBJECTIVES REVIEW CHECKLIST Survey Area:

No.

LSAOS

==

Description:==

Open Land Area, Tc-99 SEA Survey Unit:

No.

01

==

Description:==

Central Open Land Area Survey Unit in *'Area 17" Discrepancy:

None Corrective Actions Taken:

None

11.

Have the corrective actions resolved the discrepancy with the data?

YesD No DNA [2J

a. If.. No**. then forward this form to the RSO.

12.

The following questions will be answered by the RSO.

a. lfthe answer to question 11 was '"No"'. then is the aftected data YesD No0 NAjX(

sti 11 val id'?

b. lf"No". then are the existing valid measurements or samples YesD No0 NAJ2g sufficient to demonstrate compliance for the survey unit?

c. If"No'", then direct the acquisition of additional measurements or samples as necessary to demonstrate compliance for the survey unit.

Prepared by (I-IP Staff):

Thomas Yardy

~~ ~/

]-27*/7 (Print Na1111.:J Jt~A

(!late)

Approved by (RSO):

Clark Evers 3/a/;?

/;.

(Sig, urc)

~

tPrint Nam..:)

(flatc)

Quality Record

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 51 of 78 11.0 SURVEILLANCE FOLLOWING FSS FSS activities in LSA 08-01 were completed in March 2016. Between the completion of FSS and the commencement of backfill operations there were no events that had a potential to re-contaminate LSA 08-01. The assessment that there were no events that had a potential to re-contaminate LSA 08-01 was confirmed by the Pre-backfill GWS that was completed for LSA 08-01 prior to the commencement of backfill operations.

12.0 CONCLUSION

LSA 08-01 An adequate quantity and quality of radiological surveys and samples, as well as the corresponding laboratory analysis has been performed, evaluated and documented to demonstrate that the dose associated with all sources within SU LSA 08-01 does not to exceed the dose criterion for unrestricted release in accordance with 10 CFR 20.1402.

It should be noted that in accordance with Volume 3, Chapter 1; Revision 3, Section 3.1.2 Three Stratum DCGLs, compliance with the "three layer" geometry requires consideration of the Surface, Root, and Deep layers independently, because each of the three DCGLs (Surface, Root, Excavation) represent 25 mrem/yr from each layer independently. Therefore the Unity Rule must be applied when there is more than one layer present, however in the case of LSA 08-01, only the deep stratum remained, therefore the arithmetic average of the systematically collected samples is representative of the residual radioactivity remaining within the SU (e.g. 0.0 remaining Surface SOF + 0.0 remaining Root SOF + 0.05 remaining Deep SOF = 0.05 remaining SU SOF).

Table 12-1 LSA 08-01 SOF and Dose Summation AVE. SU SOIL ELEVATED GROUND BURIED REUSE AREA TOTAL RADIOACTIVITY CONTRIBUTION WATER PIPING SOIL SOF 0.05 0.22 0.16 NIA 0.25 0.68 1.25 5.5 4.0 NIA 6.25 17.0 DOSE mrem/year mrem/year mrem/year mrem/year mrem/year

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 52 of 78 13.0 FINAL STATUS SURVEY DESIGN LSA 08-02 This section of the report describes the method for determining the number of samples required for the FSS of LSA 08-02 as well as summarizing the applicable requirements of the FSS Plan.

These include the DCGLw, scan survey coverage, and IAL. The radiological instrumentation used in the FSS of LSA 08-02 and their detection sensitivities are also discussed.

13.1 FSS Plan Design Requirements FSS Plan requirements for LSA 08-02 were driven by the type (Open Land) and Class (Class 1) of the SU and developed in accordance with HDP procedure, HDP-PR-FSS-701, Revision 10, Final Status Survey Plan Development, November 2015.

13.1.1 Surrogate Evaluation Areas A discussion of Surrogate Evaluation Areas is given in the FSSFR Volume 3, Chapter 1, Section 5.0, Final Status Survey Design.

13.1.2 DCGLw During the FSS design process a review was performed of the RASS data for LSA 08-02. The RASS data was used to identify that areas of residual radioactivity potentially remained within the SU that exceeded the Uniform Stratum DCGLw (locations Tc-99-7 and Tc-997 A from the Process Building Investigation Area at depths from 20 to 28 feet bgs in the neighboring LSA 08-01 ). While only 3 out of the 124 Process Building Investigation Area samples exceeded a Uniform SOF of 1.0, this was an indication that residual levels of Tc-99 may remain within the area that exceed the Uniform DCGLw. Since the minimum excavation depth in LSA 08-02 exceeded 6 feet bgs in all areas, and all available RASS survey and sampling data indicated that no residual Tc-99 radioactivity remained above the Excavation Stratum DCGLw, the conclusion was drawn that the Excavation Stratum DCGLw would be the most appropriate to be used to demonstrate compliance with the release criteria.

Therefore the Three-Stratum DCGLw was selected for use in demonstrating compliance with the release criteria.

13.1.3 GWS Coverage As a Class 1 SU, LSA 08-02 was required to undergo a 100% GWS.

13.1.4 Instrumentation Radiological instrumentation selected for performance of GWS within LSA 08-02 was the Ludlum 44-10 2" x 2" NaI detectors, coupled to a Ludlum 2221 scaler-ratemeter.

13.1.5 Scan Minimum Detectable Concentration Scan MDCs for LSA 08-02 were calculated in accordance with HDP-PR-FSS-701, Revision 10, Final Status Survey Plan Development and HDP-TBD-FSS-002, Revision 3, Evaluation and Documentation of the Scanning Minimum Detectable Concentrations (MDC) for Final Status Surveys (FSS). As background levels were approximately 13,000 cpm within LSA 08-02, the

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 53 of 78 scan MDC calculation for total uranium given in HDP-PR-FSS-701, Final Status Survey Plan Development, Step 8.2.6.d, was applied:

1 Scan MDC (total uranium) = (

)

f U-234 f U-235 fu-238

( 4~ 72 pCi/ g )+(2.6SpCi/ g)+(34.9pCi/ g)

Equation 13-1 To determine isotopic Uranium fractions HDP-PR-FSS-701, Revision 10, Final Status Survey Plan Development assumes that the average LSA enrichment is 4% or less. Based on the systematically collected RASS samples in LSA 08-02, the average enrichment for the SU was 2.96%. All other Scan MDC parameters agreed upon between Westinghouse and the NRC were applied (e.g. use of a 2 in air gap, scan rate of 1 ft/sec, 0.75 surveyor efficiency), therefore no subsequent changes to the calculated Scan MDCs need to be made.

Prospectively calculated Scan MDCs for 2" x 2" NaI detectors that were used in LSA 08-02 are shown below:

Table 13-1 Scan MDCs for 2" x 2" Nal detector, 13,000 cpm background: LSA 08-02 Scan MDC DCGLw Scan DCGLw*

Scan DCGLw*

(Total U)

MDC (Ra-226)

MDC (Th-232)

(Ra-226)

(Th-232)

LSA 08-02 46.7 29.8 0.99 6.3 1.37 6.2

DCGLw includes background concentrations of0.9 pCi/g for Ra-226 (no ingrowth) and 1.0 pCi/g for Th-232. DCGLw values are based on the Excavation Stratum release criteria.

The values in Table 13-1 reflect those presented in the FSS Plan prepared for the SU prior to FSS.

13.1.6 Investigation Action Level FSSFR Volume 3, Chapter 1, Section 6.1.3, Investigation Action Level (JAL), provides a discussion in regards to the IAL. The basis of the IAL is detailed in HDP memorandum, HEM-l 5-MEM0-021 "Evaluation of the Scan JAL for Class 1 areas at the Westinghouse Hematite Site". The IAL used during the GWS of LSA 08-02 was established at 4,000 ncpm.

13.1.7 LSA 08-02 FSS Design Summary The FSS Plan for LSA 08-02 can be found in Appendix D. Table 13-2 presents an overall FSS design and implementation summary for LSA 08-02.

Hematite FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Decommissioning Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Project Revision: 1 J Page 54 of 78 Table 13-2 FSS Design Summary for LSA 08-02 Gamma Walkover Survey (GWS):

Scan Coverage 100% exposed excavation floors and walls 40.9 pCi/g total Uranium (based on a Scan MDC 10,000 cpm background); 0.87 pCi/g Th-232; 1.21 pCi/g Ra-226*

Investigation Action Level (IAL).

4,000 net cpm **

Systematic Sampline Locations:

Depth Number of Comments Sample 0- 15 cm (Surface) 0 These samples will be taken on 15 cm - 1.5 m (Root) 0 a random-start systematic grid.

> 1.5m (Excavation) 11 Biased Survey/Samp!ine Locations:

Biased samples may be collected during GWS at the discretion of the HP Technician, after statistical analysis of the survey data, or at the direction of the FSS Supervisor.

Sidewall Sampline Locations:

A minimum of one (1) discretionary sidewall sample(s) will be collected based on the following definition of "sidewall": sidewall candidates for sampling must be vertical or near vertical (> 45° angle) and at least 12" in height.

Process Buildine Investieation Area Locations:

As required in Section 7.1 of Attachment 1 to Westinghouse letter HEM-11-56, those systematic sample locations (TBD) in LSA 08-02 which fall inside the Process Building Investigation Area will require deep sampling to within six inches of the sand/gravel layer just above the aquifer.

1. A composite soil sample taken from each 5 foot interval between the excavation surface to within 6 inches of the sand/gravel layer; and

2. A soil sample taken from the remaining 6 inches just above the sand/gravel layer Soil data collected during the 2013 Process Building investigation will be used to augment the FSS data evaluation and satisfy the commitment as described above.

Instrumentation:

Ludlum 2221 with 44-10 (2x2 N al) I Used for GWS and to obtain static count detector; with collimation for investigations rates at biased measurement locations.

Values based on information provided in HDP-TBD-FSS-002, "Evaluation and Documentation of the Scanning Minimum Detectable Concentrations (MDC) for Final Status Surveys (FSS). The Scan MDC for total Uranium reflects a conservative assumption of 4% enrichment. The actual RASS enrichment (2.3%) would result in Scan MDC values slightly less than those calculated for FSS planning purposes.

- IAL is the net count per minute (ncpm) equivalent of an activity concentration less than the Uniform Stratum DCGLw.derived from the technical bases presented in HEM-MEM0-15-021 and HDP-TBD-FSS-003 "Modeling and Calculation of Investigative Action Levels for Final Status Soil Survey Units", Westinghouse, March 2015.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01and02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 55of78 13.1.8 LSA 08-02 Former Process Buildings Investigation Area and Hybrid Well Investigation Planning LSA 08-02 land area included portions of the land area designated for the Former Process Buildings Investigation Area and Hybrid Well Investigation. A sampling campaign separate from FS S was performed to meet the requirements of the investigations as stated in Westinghouse letter HEM-11-56 to the NRC which contained the "Evaluation of Technetium-99 Under the Process Building" report (Appendix H).

Figure 4, Conceptual Investigation Sample Stations Associated with the Process Buildings, of "Evaluation of Technetium-99 Under the Process Building" report provides the conceptual soil sampling and well locations for the Former Process Buildings Investigation Area and Hybrid Well Investigation (see Figure 6-3).

During development of the work package for the Former Process Buildings Area and Hybrid Well Investigation it was determined that the available sampling equipment of the drilling company contracted to perform the sampling utilized a 4 foot core sampler rather than 5 foot. A licensing evaluation was completed and documented usmg HDP-PR-LI-005-1, Change Evaluation Form. The evaluation determined that this was an adequate approach and potentially increased the sample density and therefore, there was no change in intent in regards to accomplishing the investigation as described in HEM-11-56.

Section 7.0 of HEM-11-56 specifies that sampling would be post excavation for the Former*

Process Buildings Investigation Area and Hybrid Well Investigation sampling. This statement was a preliminary statement based upon the expected logistics related to performing the sampling. Due to VOC contamination in the area at depth, it was recognized by the site staff that post excavation sampling presented the difficulties of having a drill rig or direct push rig enter the area after significant excavation depths had taken place as the surfaces would be extremely uneven (see Figure 3-3). In consideration of the need to have a relatively flat surface for the drill rig to operate on and the inherent safety concerns of using a drill rig on uneven surfaces, a decision was made to perform the sampling in the Tc-99 investigation area and at some of the hybrid wells prior to performing soil excavation. The sampling of the 15 systematic locations therefore occurred after removal of the former Process Building's concrete slab and sub-floor gravel, but prior to excavation of contaminated soil.

14.0 FINAL STATUS SURVEY IMPLEMENTATION LSA 08-02 FSS was performed in accordance with procedure HDP-PR-FSS-711, Final Status Surveys and Sampling of Soil and Sediment.

14.1 Gamma Walkover Survey 14.1.1 Instrumentation The selected instrumentation to perform the GWS in LSA 08-02 was a 2" x 2" NaI detector in combination with a Ludlum 2221 rate meter. Each NaI instrumentation set was interfaced with a Trimble DGPS and handheld data logger.

Prior to the first field use of the GWS instrumentation, initial set-ups were performed. Also, daily pre-and post-use source checks were performed for each day that GWS was performed

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 56 of 78 within the SU.

Initial set-ups, daily source checks, and control charting were performed according to the requirements of HDP-PR-HP-416, Operation of the Ludlum 2221 for Final Status Survey.

14.1.2 GWS Performance All GWS measurements on the excavation floor and sidewalls collected with the Nal detector(s) were connected to a Trimble DGPS and with a hand-held data logger. The logging frequency in the SU was one (1) GWS measurement per second.

Each gross gamma measurement is correlated to a set of coordinates based on the Missouri East State Plane, NAD 1983.

The GWS requirements involved moving the Nal detector in a side-to-side fashion no faster than 1 foot per second while holding the probe as close as possible to the excavation surface.

(nominally 1 ", but not to exceed 3"). At the same time, the technician was required to slowly advance, causing the detector to trace out a serpentine path over the excavation surface.

HP Technicians performing GWS in LSA 08-02 used the 4,000 ncpm IAL as a field guide to know when to slow or pause the. GWS for more deliberate investigation. If during the GWS, audible count rates noticeably increase above the general area average (i.e., > minimum detectable count rate), HP Technicians were required to pause momentarily and observe count rates. If sustained count rates approached the IAL, further focused investigation was conducted within the locally elevated area.

To use the IAL effectively, HP Technicians first determined the local background count rate before starting the GWS. Although the ambient gamma level may vary across the SU due to excavation geometry and relative distance from contaminated materials in nearby remedial excavations, the average background rate (measured at waist level) within the LSA ranged between 13,000 and 14,000 gcpm. Therefore, at locations where the 2" x 2" Nal detector measurements exceeded 17,000 to 18,000 gcpm, HP Technicians slowed or paused the GWS for more careful investigation of the small areas of elevated activity before deciding if "flagging" a point for potential biased.sampling was warranted.

Sidewalls, hard to reach areas, and non-typical areas were surveyed manually as necessary in order to assess the potential for an area of elevated residual activity over 100% of the exposed excavation surface.

~fter the GWS survey was complete, the GPS/GWS data was reviewed by Radiological Engineering and the HP Technician performing the survey to determine if possible areas of elevated residual activity remained within the SU that required biased sample investigation.

Areas that were flagged by the HP Technician were considered, as well as a statistical evaluation of the GWS data set. The statistical evaluation determined the mean count rate and standard deviation associated with the GWS and then could be used to identify any areas that exceeded 3 standard deviations above the mean. The number of biased samples to be collected and the locations are based on flagged locations exceeding the IAL, the statistical evaluation of the GWS data set, and the professional judgment of Radiological Engineering.

FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Hematite Decommissioning Project Revision: 1 I Page 57 of 78 14.2 Soil Sampling 14.2.1 Systematic Soil Sampling Summary Table 14-1 provides a summary of systematic sampling by stratum for LSA 08-02.

Table 14-1 Systematic Sampling Summary by Stratum for LSA 08-02 LSA 08-02 SU Area, planar (m2) 1,440 Surface 0

14.2.2 Systematic Sampling LSA 08-02 Systematic Root 0

Deep (Excavation) 11 QC 1

Within LSA 08-02, there were no systematic locations in which portions of the surface stratum (0 - 15 cm), or the root stratum (15cm - I.Sm) remained within the SU.

Excavation stratum samples were collected at all 11 systematic sample locations.

Given a planar area of 1,440 m2 for LSA 08-02 and an eleven - point systematic triangular grid, the point-to-point distance within each row was 16.8 m with spacing of 12.2 m between each of the parallel grid rows within the SU.

While there were eleven (11) systematic locations on the LSA 08-02 sampling grid, a total of twelve (12) samples were collected and analyzed at these locations, including:

Eleven (0) samples collected and analyzed within the surface stratum Eleven (0) samples collected and analyzed within the root stratum Eleven (11) samples analyzed within the excavation, or "deep" stratum One (1) QC field replicate Figure 14-1 presents the map of the eleven systematic sample locations which were sampled within LSA 08-02. The inset table notes the location coordinates (Missouri East, NAD 1983) and collection intervals for each systematic location.

Hematite Decommissioning Project S*mµI~ ID LOB-02-01-T-[-':.-00 IOR-m-07-T-F-">-OO l08-Cl-U3-l-t->-UU LOS-02-04-T-E-S-OO l08-Cl-05-T-E->OO LOB-02-06-T-E-S-00 l08-C2-07-T-E-S-OO l08-C2-08-T-E-S-DO L08-02-09-T-E-S-OO l08-C2-10-T-E-S-OO LOS Cl 11 T E S DO I OR-07-06---F-r.-no FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Start End Northirg Deµ lh D~µlh (in~hes) (inches)

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Hematite FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Decommissioning Survey Units 01 and02 (LSA 08-01 and LSA 08-02)

Project Revision: 1 I Page 59 of 78 Table 14-2 below presents a tabular listing of all FSS samples collected within LSA 08-02 with associated IDs, sample types, collection intervals, coordinates, and notes.

Table 14-2 FSS Sample Locations and Coordinates for LSA 08-02 Hematite Procedure: HDP-PR-FSS-70 I, Final Status Survey Plan Development Decommissioning Appendix Project Revision: IO P-4 Page I of l APPENDIX P-4 FSS SAMPLE & MEASUREMENT LOCATIONS & COORDJNATES Survey Area:

LSA 08

==

Description:==

OQen Land Area, Tc-99 SEA Survey Unit:

02

==

Description:==

Central OQen Land Area S u rve~ Unit in "Area 17" Survey Type:

FSS Classification:

Class I Measurement or Sample Surface or Start End Northing Easting Type (Y Axis)

Remarks I Notes ID CSM Elevation Elevation (X Axis)*

L08-02-0 l -T-E-S-00 Deep s

4 15.7 4 15.2 864826 827 184 Excavation 6-inch grab L08-02-02-T-E-S-OO Deep s

422.3 42 1.8 864826 827224 Excavation 6-inch grab L08-02-03-T-E-S-OO Deep s

429.6 429.2 864826 827264 Excavation 6-inch grab L08-02-04-T-E-S-OO Deep s

422.1 42 1.6 864791 827 164 Excavation 6-inch grab L08-02-05-T-E-S-00 Deep s

427.8 427.3 86479 1 827204 Excavation 6-inch grab L08-02-06-T-E-S-OO Deep s

429.8 429.3 86479 1 827244 Excavation 6-inch grab L08-02-07-T-E-S-OO Deep s

430.1 429.6 864756 827 144 Excavation 6-inch grab L08-02-08-T-E-S-OO Deep s

429.1 428.6 864756 827 184 Excavation 6-inch grab L08-02-09-T-E-S-OO Deep s

429.2 428.7 864756 827224 Excavation 6-inch grab L08-02-I O-T-E-S-OO Deep s

429.1 428.6 86472 1 827 164 Excavation 6-inch grab L08-02-11-T-E-S-00 Deep s

423.8 423.3 864721 827204 Excavation 6-inch grab L08-02-06-T-E-Q-OO Deep Q

429.8 429.3 86479 1 827244 Excavation 6-inch grab L08-02-1 2-T-E-B-OO Deep B

425.4 424.9 864830 827234 Biased 6-inch grab L08-02-13-T-E-B-OO Deep B

429.6 429. 1 864758 827 133 Biased 6-inch grab L08 l 4-T-E-B-OO Deep B

429.2 428.7 864748 827174 Biased 6-inch grab L08 l 5-T-E-B-OO Deep B

429.4 428.9 864768 827250 Biased 6-inch grab L08-02-1 6-T-E-B-OO Deep B

429.0 428.5 864726 827 188 Biased 6-inch grab L08 I 7-T-E-B-OO Deep B

424.5 424.0 86478 1 827 165 Sidewall Sample L08 18-T-E-B-OO Deep B

429.5 429.0 864766 827 139 Sidewall Sample Gre e n shaded samples are the samples at each sample location, for use in WRS test.

Elevations are in feet above mean sea level.

- Missouri - East State Plane Coordinates [North American Datum (NAD) 1983 1 (Open Land Area) OR Distance in feet from lower left corner of the surface (Structures); each surface has it's own (X,Y) = (0,0); OR For piping the distance from the beginning of the survey uni t.

Surface: Floor = F; Wall = W; Ceiling =

Roof = R CSM

Three-Layer (Surface-Root-Deep) or Uniform Type:

Systematic = S, Biased = B; QC =Q; Investigation = I Quality Record

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 90 of 78 14.3 Biased Soil Sampling As discussed in FSSFR Volume 3, Chapter 1, Section 6.1.3, there are three key methods for identifying areas for biased soil sampling, the IAL, the Z-score of the FSS GWS, and the professional judgment of the HP Staff. For LSA 08-02 five (5) biased sample locations were selected within the SU based on the evaluation of the GWS survey data and HP Technician professional judgment. Biased samples are collected at the prescribed location to a depth of 6 inches below the exposed ground surface.

14.4 Judgmental/Sidewall Sampling for Tc-99 Sidewall sampling was prescribed in the FSS Plan developed for LSA 08-02 in accordance with the guidance provided in HDP-PR-FSS-701, Final Status Survey Plan Development. See FSSFR Volume 3, Chapter 1, Section 5.2, Tc-99 Side Wall Sampling for further discussion.

During FSS of LSA 08-02, two (2) sidewall samples were collected.

See section 15.2.6, Judgmental/Sidewall Soil Sample for Tc-99 Results LSA 08-01 for further discussion.

14.5 Quality Control Soil Sampling One QC field duplicate sample point was randomly selected and collected at systematic location L08-02-06 for LSA 08-02.

14.6 LSA 08-02 Former Process Buildings Investigation Area and Hybrid Well Investigation The sampling of the investigation area began in July of 2013 and work was performed in

accordance with Work Package HDP-ENG13-WP-009, Direct Push Technology Sampling at Hybrid Wells.

As provided in HEM-11-56 the soil sampling in the former Process Buildings Investigation Area consisted of 15 systematic sample stations located in the center of each grid square with approximately 40 feet spacing between locations. The investigation area was approximately 2230 m2 with each sample location representing approximately 149 m2.

For LSA 08-02 the systematic soil sample locations were locations 10 through 15 (see Figure 6-2 above).

For LSA 08-02 the Hybrid Well Investigation soil samples were located at abandoned groundwater monitoring location BD-04 (see Figure 6-2 above).

15.0 FINAL STATUS SURVEY RESULTS LSA 08-02 15.1 Gamma Walkover Survey Post-processed GPS coordinate data is accurate to within +/- 0.1 m for the handheld GPS models used during the GWS. The GWS maps are plotted and presented in a 2-D format. When multiple data points are collected at the same GPS location during the walkover, the most elevated radiological measurements are plotted "on top"( e.g. if any sidewalls featured more elevated readings than the floor directly below, the sidewall radiological measurements would overlie the lower floor readings).

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01and02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 61of78 GWS measurements were collected in LSA 08-02 between December 10, 2015, and January 14, 2016.

15.1.1 GWS Results for LSA 08-02 For LSA 08-02, GWS count rates ranged between 5,665 gcpm and 19, 122 gcpm, with a mean count rate of 10,318 gcpm. The median count rate was 10,455 gcpm with a standard deviation of 1,150 cpm. Figure 15-1 below presents a map of the complete GWS data set.

Legend CPM 5665 - 11178 11179-12198 12199 - 13216 1321 7 - 14329 14330 - 15260 15261 - 16280 16281 - 17301 17302 - 18322 18323 - 19122 Figure 15-1 Colorimetric GWS Plot for LSA 08-02 LSA 08-02 Garn Results LSA08-02 1440 m2 Planar Area Survey Instruments

2X2 Nal detectors 44-10 242840 "A" - Cal Due 10/30/ 16 44-10 2428 19 "C" - Cal Due 10/30/16 44-10 242821 [) " - Cal Due 04/15/16 44-10 242862 'F ' - Cal Due 08/31/16 44-10 240 325 "Q" - Cal Due 08/3 1/16 No rmaized to Z Score CPM for instrument D over Survey 1

40 60 80

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-c:::i--==---====--- Feet rr An evaluation of the entire GWS data set was performed to evaluate those small areas of elevated activity which exceeded both the IAL (> 4000 ncpm) and three (3) standard deviations above the GWS mean measurement, (i.e., "+ 3 Z-score"). Several locations were selected for biased sample collection. The sample collected at location L08-02-14represented the maximum GWS measurement (19,122 gcpm) within the SU.

Figure 15-2 presents a map of the +3 Z-score GWS measurements within LSA 08-02, including the selected biased sampling location.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01and02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 62of78 Figure 15-2 Colorimetric GWS Plot for LSA 08-02 (Measurements > Z-score of 3) alkover Survey Z Score Results Biased Sam pie L08-02-1 2-T-E-B-OO Legend Z Score Sidewall Sample L08-02-17-T-E-B-OO Biased Sam pie l08-02-14-T-E-B-OO Sidewall Sample L08-02-18-T-E-B-OO

~

3 (12199 -13216 cpm) 4 (13217 - 14329 cpm) e 5 (14330 - 15620 cpm)

Biased Sam pie L08-02-1 3-T-E-B-OO 6 (15621 -16280 cpm) 7 (16281 -17301 cpm) 8 (17302 - 1 8322 c pm}

9 (18323 -19122 cpm)

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10 20 40 60 80 Feet N +

All GWS data collected in LSA 08-02 was datalogged and post-processed in GIS software.

15.1.2 GWS Coverage Results LSA 08-02 FSSFR Volume 3, Chapter 1, Section 6.1.4, Exposed Surfaces versus Accessible Surfaces, provides a discussion and the criteria for evaluating the GWS coverage of a SU during FSS.

The post survey processing of the GPS data indicated that although 100% of accessible areas underwent GWS the GWS covered 99.95% of the SU (see Table 15-1). As the evaluation indicates that the GPS coverage exceeded 95% with no readings approaching or exceeding the IAL of 4,000 net cpm in the vicinity of any apparent GPS coverage gaps, the GWS coverage for the SU has been evaluated to meet the intent of the "100% GWS coverage" requirement.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Table 15-1 GWS Gap Analysis LSA 08-02 Total SU GWS Gap Gap Pixels Pixels Percentage LSA 08-02 416,058 228 0.05 15.2 Soil Sample Results LSA 08-02 GWS Coverage 99.95 I Page 63 of 78 MARSSIM Class 1

Appendix B presents the analytical results and associated statistics for all FSS samples collected within LSA 08-02.

15.2.1 Surface Soil Sample Results LSA 08-02 There were eleven (11) systematic samples, one (1) QC sample, five (5) biased samples, and two (2) sidewall samples collected from the exposed excavation surface of LSA 08-01.

The maximum Excavation SOF result for the surface samples was 0.27.

15.2.2 Subsurface Soil Sample Results LSA 08-02 As LSA 08-02 contains no soil from either the surface or root stratums, all samples were collected from the excavation stratum to a depth of 6 inches. Therefore, no subsurface sampling was performed in LSA 08-02.

15.2.3 WRS Test Evaluation LSA 08-02 Per Step 7.8.3 of HDP-PR-FSS-721 Final Status Survey Data Evaluation, the WRS statistical test was not required for LSA 08-02 since the difference between the maximum SU data set gross SOF and the minimum background area SOF was less than one using the Excavation Stratum criteria. However, for illustrative purposes, the WRS evaluation was still performed for LSA 08-02. All systematically collected samples regardless of depth are used to perform the WRS Test, however biased and QC sample results are not utilized in the WRS Test. The 11 systematically collected samples in LSA 08-02 were ranked against the adjusted activity concentrations of the 32 samples collected within the Background Reference Area. The SU passed the WRS Test since the ranked sum of the reference area ranks, or test statistic WR, (880) was greater than the critical value (764) for the test. As such, the null hypothesis that the SU average concentration is greater than the DCGLw was rejected. The WRS evaluation is also included in Appendix B.

15.2.4 Graphical Data Review LSA 08-02 Table 15-2 below presents summary results for the all systematically collected samples (includes surface, and root, but not biased or QC samples) collected within LSA 08-02, and the associated SOF when compared to the Excavation Stratum DCGLws. The arithmetic average concentration resulted in a SOF of 0.06.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 64of78 Table 15-2 LSA 08-02 FSS Sample Data Summary and Calculated SOF Values (Systematic)

Ra-226DCGL Th-232 U-234 U-235 U-238 Sample Statistic

= 1.9 Tc-99 DCGL DCGL=2.0 DCGL=195.4 DCGL=51.6 DCGL=168.8 SOF BKG = l.07

= 25.1 (pCi/g)

BKG = l.O (pCi/g)

(pCi/g)

(Excavation (pCi/g)

(pCi/g)

DCGL)

Average 0.090 0.631 0.113 7.612 0.417 2.006 0.06 Minimum 0.00 0.072 0.00 0.03

(<BKG).

(<BKG) 1.359 0.070 0.915 Maximum 0.260 1.360 0.230 20.321 1.120 4.970 0.12 1

Notes:

I.

Ra-226 and Th-232 background activities subtracted prior to calculating SOF value. Ra-226 background without ingrowth = 0.9 pCi/g; Ra-226 background with ingrowth= 1.07 pCi/g. Negative SOF components are set to zero in SOF calculation.

2.

Average SOF for data set calculated using average radionuclide concentrations.

3.

U-234 values are inferred from the U-235/U-238 ratio.

Section 8.2.2.2 of MARS SIM recommends a graphical review of FSS analytical data, to include at a minimum, a posting plot and a histogram. A frequency plot, or histogram, is a useful tool for examining the general shape of a data distribution. This plot is a bar chart of the number of data points within a certain range of values. The frequency plot will reveal any obvious departures from symmetry, such as skewness or bimodality (two peaks), in the data distribution for the SU. The presence of two peaks in the SU frequency plot may indicate the existence of isolated areas of residual radioactivity.

Figure 15-3 presents the overall statistical metrics for the SOF parameter for the -11 systematically collected samples from LSA 08-02. The top graph is a histogram and line plot of the SOF for the systematic data population for LSA 08-02. The middle graph presents the mean SOF (0.06) as indicated by the blue vertical line of the sample population and the 95%

confidence interval of the mean SOF represented by the blue diamond which is 0.04 to 0.08. The 98.33% confidence interval based on the median (0.08) of the sample results is 0.03 to 0.09. The bottom two charts present the various statistical metrics of the LSA 08-02 SOF data set, including the mean, median, standard deviation, minimum, maximum, confidence intervals, etc.

Figure 15-3 exhibits no unusual symmetry or bimodality concerns for the LSA 08-02 data associated with the systematically collected measurement locations.

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Revision: 1 I Page 65 of 78 Figure 15-3 Graphic Statistical Summary for LSA 08-02 (SOF parameter)

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N 0.1 0.2 0.1 0.2 11 Mean 0.3 0.4 0.5 0.6 0.7 0.8 0.9 LSA 08-02 Sys SOF 0.3 0.4 0.5 0.6 0.7 0.8 0.9 LSA 08-02 Sys SOF 95% Cl Mean SE SD Variance Skewness Kurtosis LSA 08-02 Sys 0.06 0.04 to 0.08 0.008 0.03 0.00 1.2 0.88 SOF 1st 3rd Minimum quartile Median 98.83% Cl quartile Maximum IQR LSA 08-02 Sys 0.03 0.04 0.05 0.03 to 0.09 0.08 0.1 0.04 SOF 1

1

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record/or Land Survey Area 08, Survey Units 01and02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 66 of78 A posting plot is simply a map of the SU with the data values (in this case the SOF values for each systematically collected sample) entered at the measurement locations. This potentially reveals heterogeneities in the data - especially possible patches of elevated residual radioactivity.

The posting plot for LSA 08-02 is presented below in Figure 15-4. Figure 15-4 shows no unusual patterns in the data.

Sa"'4Jle 10 LOS-02-01-T-E-S-OO LOB-02-02-T-E-S-OO LOS-02-03-T-E-S-OO LOB-02-04-T-E-S-00 LOS-02-05-T-E-S-OO LOS-02-06-T-E-S-OO LOS-02-06-T-E-Q-OO LOS-02-07-T-E-S-OO LOS-02-tm-T-E-S-OO LOS-02-09-T-E-S-OO LOS-02-W-T-E-S-OO LOB-02-11-T-E-S-OO Figure 15-4 Posting Plot for LSA 08-02 Systematic Measurement Locations SOF 0.05 0.06 0.08 0.04 0.12 0.03 0.07 0.09 0.06 0.03 0.05 0.05 LSA 08-02 Posting P LSAOB-02 1440 m2 Planar Area L08-02-0 -T-E-S-00 0.05 L08-02-03-T-E-S 0.08 Q

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Appendix B to this report presents the complete analytical data set (in Microsoft Excel format) used to derive the summary statistics presented in Table 15-2, Figure 15-3, and Figure 15-4 above. A summary of the analytical data is presented in Table 15-3 below. Appendix F to this report presents the Test America Analytical Laboratory soil sample reports.

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1.22 0.177 0.0906 NIA

0. 150 0.150 0.0723 0.072 0.129 0.222 u

1.16 0.202 0 115 NIA 0.160 0.160 1.359 NA NA NA 0.0701 0.154 0.284 u

0.915 0.322 0.86 NA 1.2 L08-02-03-T-E-S-OO 5.00 s

118 0.164 0.0743 NIA 0.110 0.110 0.646 0.646 0.169 0.211 NA 1.21 0.174 0.131 NIA 0.210 0.210 8.709 NA NA NA 0.481 0.173 0.225 NA 1.56 0.341 0.805 NA 4.6 L08-02-04-T-E-S-OO 5.00 s

1.1 0.153 0.0639 NIA 0.030 0.030 0.442 0.442 0.151 0.239 NA 1 09 0.179 0.0811 NIA 0.090 0.090 3.907 NA NA NA 0.212 0.11 0.167 NA 1.48 0.495 0.722 NA 2.2 L08-02-05-T-E-S-OO 5.00 s

1.33 0.2 0.0897 NIA 0.260 0.260 0.735 0.735 0.21 0.227 NA 1.23 0.216 0.139 NIA 0.230 0.230 11.634 NA NA NA 0.642 0.253 0.256 NA 1.87 0.679 NA 5.1 L08-02-06-T-E-S-OO 5.00 s

1.1 0.16 0.0753 NIA 0.030 0.030 1.16 1.160 0.21 0.219 NA 0.989 0.158 0.137 N/A

-0.011 0.000 5.829 NA NA NA 0.32 0.15 0.197 NA 1.68 0.591 0.872 NA 2.9 L08-02-07-T-E-S-OO 5.00 s

1.27 0.17 0.0671 NIA 0.200 0.200 0.144 0.144 0.167 0.221 u

1.21 0.169 0.112 NIA 0.210 0.210 6.164 NA NA NA 0.338 0.143 0.266 NA 1.88 0.6 0.877 NA 2.8 L08-02-08-T-E-S-OO 5.00 s

1.17 0.159 0.064 NIA 0.100 0.100 0.282 0.282 0.068 0.221 NA 0.553 0.119 0.315 NIA

-0.447 0.000 20.321 NA NA NA 1.12 0.245 0.266 NA 4.97 0.902 0.877 NA 3.4 L08-02-09-T-E-S-OO 5.00 s

0.973 0.1 58 0.0808 NIA

-0.097 0.000 1.36 1.360 0.235 0.209 NA 0.875 0.156 0.118 NIA

-0.125 0.000 9.320 NA NA NA 0.514 0.192 0.211 NA 1.45 0.585 0.884 NA 5.3 L08-02-1 O-T-E-S-00 5.00 s

1.1 0.161 0.0672 NIA 0.030 0.030 0.66 0.660 0.085 0.249 NA 1.07 0.161 0.109 NIA 0.070 0.070 13.226 NA NA NA 0.728 0.196 0.217 NA 3.44 0.88 0.932 NA 3.2 L08-02-1 1-T-E-S-OO 5.00 s

1.15 0.164 0.0803 NIA 0.080 0.080 0.102 0.102 0.044 0.224 u

1.14 0.174 0.111 N/A 0.140 0.140 1.598 NA NA NA 0.0805 0.14 0.25 u

1.35 0.533 0.812 NA 1.0 L08-02-06-T-E-Q-OO 5.00 Q

1.2 0.164 0.0667 NIA 0.130 0.130 0.741 0.741 0.079 0.211 NA 1.13 0.158 0.124 NIA 0.130 0.130 6.054 NA NA NA 0.333 0.145 0.231 NA 1.65 0.561 0.828 NA 3.1 L08-02-12-T-E-B-OO 5.00 B

1.15 0.157 0.0605 NIA 0.080 0.080 2.82 2.820 0.277 0.21 NA 1.12 0.166 0.101 N/A 0.120 0.120 11.478 NA NA NA 0.634 0.195 0.223 NA 2.11 0.594 0.837 NA 4.5 L08-02-13-T-E-B-OO 5.00 B

1.2 0.157 0.0598 NIA 0.130 0.130 0.0152 0.015 0.043 0.22 u

1.14 0.167 0.0979 NIA 0.140 0.140 29.910 NA NA NA 1.65 0.272 0.244 NA 6.88 1.01 0.948 NA 3.6 L08-02-14-T-E-B-OO 5.00 B

1.14 0.154 0.0628 NIA 0.070 0.070 0.298 0.298 0.091 0.208 NA 1.12 0.161 0.11 NIA 0.120 0.120 51.783 NA NA NA 2.86 0.389 0.274 NA 10.6 1.64 1.29 NA 4.1 L08-02-15-T-E-B-OO 5.00 B

1.1 3 0.157 0.0621 N/A 0.060 0.060 0.583 0.583 0.079 0.195 NA 1.18 0.179 0.0935 NIA 0.180 0.180 21.926 NA NA NA 1.21 0.232 0.228 NA 5.01 0.875 0.969 NA 3.7 L08-02-1 6-T-E-B-OO 5.00 B

1.28 0.171 0.0741 NIA 0.210 0.210 0.0467 0.047 0.042 0.207 u

1.14 0.165 0.127 NIA 0.140 0.140 134.544 NA NA NA 7.19 0.805 0.387 NA 9.28 1.32 1.24 NA L08-02-17-T-E-B-OO 5.00 B

1.2 0.175 0.0805 N/A 0.130 0.130 0.176 0.176 0.08 0.217 u

1.03 0.168 0.129 NIA 0.030 0.030 2.097 NA NA NA 0.107 0.0954 0.164 u

1.51 0.704 0.879 NA 1.1 L08-02-18-T-E-B-OO 5.00 B

1.25 0.166 0.0662 NIA 0.180 0.180 0.0974 0.097 0.069 0.197 u

1.21 0.176 0.11 NIA 0.210 0.210 31.168 NA NA NA 1.72 0.281 0.293 NA 7.12 1 04 0.943 NA 3.7 Systematic Minimum 0.000 0.072 0.000 1.359 0.070 0.915 3.5 r-~~S_y_s_te_m_a_tic~M_ax_i_m_um~~~-r-~~~~~~~

0._2_60~~~~~~~-r-~~~~~-1_

. 3_6_0~~~~~-r-~~~~~~~0_

. 2_3_0~~~~~~~-r-~~~-20_._32_1~~~--1r-~~~~1_

.1_

20~~~~-f'~~~~4-*_97_0~~~~~a> 1:

Cl Q)

Systematic Mean 0.090 0.631 0.113 7.612 0.417 2.006 ns E 1--~~~~~~~~~~~-t--~~~~~~~~~~~~~~~-+-~~~~~~~~~~~~-+-~~~~~~~~_.,:_~~~~~~-+~~~~~~~~~-+-~~~~~~~~~~-t--~~~~~~~~~4~~~

1--~~-s_y_st_e_m_at_ic_M_e_d_ia_n~~~-t-~~~~~~~

o._0_80~~~~~~~-+-~~~~~-o_.6_4_

6 ~~~~~-+-~~~~~~~o_

. 1_3_0~~~~~~~-+-~~~-6_

. 1_6_4~~~--<>--~~~~o_

. 3_38~~~~-+~~~~-1._56_0~~~~~ ~

~

Systematic Standard Deviation 0.085 0.481 0.087 5.856 0.325 1.169 w

With ingrowth, use Ra226 bkg =

1.07 Th232 bkg =

1.0 NOTES

Gross results in units of pCilg

Background with ingrowth (1.07 pCilg) subtracted from gross result

- Background (1.0 pCilg) subtracted from gross result U qualifier: A normal, non-detected result (result less than MDC).

All uncertainty values are reported at the 2-sigma confidence level.

u..

0 CJ)

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 I Page 68 of 78 15.2.5 Biased Soil Sample Result LSA 08-02 Five (5) biased sample were collected from LSA 08-02. The sample collected at location L08-02-14 represented the maximum GWS measurement (19,122 gcpm) within the SU, and had a result of 0.14 Uniform SOF.

15.2.6 Judgmental/Sidewall Soil Sample for Tc-99 Results LSA 08-02 Two samples were co~lected from the sidewalls of LSA 08-02. Table 15-4 provides the data summary for the samples.

Table 15-4 LSA 08-02 Sidewall Sample Data Summary and Calculated SOF Values Ra-226 Tc-99 Th-232 U-234 U-235 U-238 Sample SOF DCGL=S.4 DCGL=

DCGL=S.2 Sample ID BKG=0.9 74.0 BKG=l.O DCGL=872.4 DCGL=208.1 DCGL=551.1 (Uniform (pCi/g)

(pCi/g)

DCGL)

L08-02-17-T-E-B-OO 1.2 0.176 1.03 2.097 0.107 1.51 0.04 L08-02-18-T-E-B-OO 1.25 0.0974 1.21 31.168 1.72 7.12 0.13 15.2. 7 Quality Control Soil Sample Result LSA 08-02 One QC field duplicate sample point was randomly selected for LSA 08-02 which was collected at systematic location L08-02-06.

For the 18 samples (i.e., 11 systematic+ 5 biased+ 2 sidewalls) collected within LSA 08-02, one field duplicate sample was collected.

This frequency equates to 5.6%, (i.e. 1118).

Form HDP-PR-FSS-703-1 documents that the duplicate sample result comparison with the partner's sample results that all comparison criteria were less than the calculated warning limits (see Figure 15-5 below).

Hematite FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01and02 (LSA 08-01 and LSA 08-02)

Decommissioning I Page 69 of 78 Project Revision: 1 Figure 15-5 Form HDP-PR-FSS-703-1 Field Duplicate Sample Assessment LSA 08-02 Procedure: HDP-PR-FSS-703, Final Status Survey Quality Control Hematite Decommissioning Project Revision: 2 Page 1 of 1 FORM HDP-PR-FSS-703-1 FIELD DUPLICATE SAMPLE ASSESSMENT Survey Unit No.:

LSA 08-02 Survey Unit

Description:

Central Open Land Area SU in "Area 17

Field Duplicate Sample Average Nuclide Statistic Field Duplicate Sample (pCilg)

(pCi/g)

Activity (j()

DCGL Warning Control Exceeds Limit?

Sample ID Sample ID Radionuclide Activity (x;)

MDC Activity (x;)

MDC (pCilg)

(pCilg)

Statistic2 Limit Limit (YIN)

L08-02-06-T-E-S-OO L08-02-06-T-E-Q-OO Ra-226 I.JOO 0.0753 1.200 0.0667 1.150 5.4 0.100 0.764 1.145 N

L08-02-06-T-E-S-00 L08-02-06-T-E-Q-OO Tc-99 1.16 0.219 0.741 0.211 0.951 74 0.419 10.471 15.688 N

L08-02-06-T-E-S-OO LOS-02-06-T-E-Q-OO Th-232 0.989 0.137 1.130 0.124 1.060 5.2 0.141 0.736 1.102 N

LOS-02-06-T-E-S-OO L08-02-06-T-E-Q-OO U-234 1 5.829 NIA 6.054 NIA 5.942 872.4 0.225 123.445 184.949 N

L08-02-06-T-E-S-OO L08-02-06-T-E-Q-OO U-235 0.32 0.197 0.333 0.231 0.327 208.I 0.013 29.446 44.117 N

L08-02-06-T-E-S-OO L08-02-06-T-E-Q-OO U-238 1.68 0.872 1.68 0.828 1.680 551.1 0.000 77.981 116.833 N

Comments:

I. U-234 is inferred. no MDC available.

2. Duplicate assessmelll is not necessary if the result of either sample is< MDC.

Performed by: Thomas Yardy

/"£*

t~*

Reviewed by: Clark Evers //A J. IM

~ -

v I

Date:

.3 17 Date: 3/~'l/I?

Quality Record

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 70 of78 15.3 Tc-99 Hot Spot Assessment LSA. 08-02 As noted previously, due to the presence of elevated Tc-99 residual activity in the neighboring LSA 08-01, the minimum number of systematic sample locations within LSA 08-02 was increased in order to account for this, and to potentially identify any other possible areas of residual activity. However no sample result within LSA 08-02 was ever identified to exceed the Tc-99 DCGL.w, therefore no Tc-99 hotspot assessment is required.

15.4 LSA 08-02 Former Process Buildings Investigation Area Results and Hybrid Well Investigation Results The collected samples were sent to Test America for analysis and the results were compared against the Uniform and the Excavation DCGLs.

All 15 locations had results that were below a sum-of-fraction of 1.0 using the Excavation Scenario DCGLs with the exception of location Tc-99-7 (which is located in the neighboring LSA 08-01 ). Location Tc-99-7 exceeded a SOF of 1.0 in the sample collected from 20 to 24 feet bgs interval which had a SOF of 2.58 using the Excavation Scenario DCGL, for which an EMC was performed at this location (only applicable to LSA 08-01 ). The sample results including actual depths are provided in Attachment 2 of Appendix H.

In August of 2013, three additional sample locations (locations Tc-99-16 through18) were collected down to the sand gravel layer to bound location Tc-99-7 to the west. All of the samples from these three locations had a SOF less than 1.0 for both Uniform and the Excavation Scenario DCGLs.

In October of2013, five additional investigation locations (locations Tc-99-7A through 7E) were collected to the sand gravel layer around location Tc-99-7. Excavation to approximately 7.0 to 7.5 feet had been performed in the area around location Tc-99-7 prior to collecting these additional locations. None of these 5 sample locations exceeded the Excavation DCGL. The results for the samples associated with the Tc-99 investigation are presented in Attachment 2 of Appendix H.

Within LSA 08-02 no Process Building Investigation Area sample, Hybrid Well Investigation sample, or FSS sample exceeded an Excavation DCGLw.

Furthermore, the clean bounding sample Tc-99-7d which is located in LSA 08-02 shows that any elevated residual Tc-99 activity associated with location Tc-99-7 is contained in a very small area and does not present a potential impact to LSA 08-02.

16.0 ALARA EVALUATION LSA 08-02 All samples collected within LSA 08-02 were evaluated against the Excavation Stratum DCGLw.

For LSA 08-02 no sample result exceeded a SOF of 1.0. The average SOF result, based on all systematically collected samples, was 0.06 for LSA 08-02. The average SOF equates to residual activity contributions from the SU area of 1.5 mrem/yr for LSA 08-02. Groundwater Monitoring Well' data provided in FSSFR Volume 6, Chapters 2 and 3 {ML16287A528}, and Chapter 4

{ML16342B552}, indicate that the groundwater dose contribution will be a fraction of the

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 71of78 MCLs. Nevertheless, a maximum groundwater contribution assumption of 4.0 mrem/yr based upon the EPA MCLs will be added to the total estimated dose for LSA 08-02. And finally, portions of Combined Reuse Stockpile 4-7 were placed into LSA 08-01, therefore an additional 6.25 mrem/yr will be added to account for the additional dose contribution form reuse soil.

Adding these dose contributions together, the total estimated dose for LSA 08-02 is 11.75 mrem/yr.

Since the estimated Total Effective Dose Equivalent is below the regulatory release criterion of 25 mrem/yr, the conclusion of the ALARA evaluation is that the FSS of LSA 08-02 was successful and that there would be no discernable benefit to the health and safety of the public in attempting to further reduce the results of FSS by performing additional remediation of LSA 08-

02.

17.0 FSS PLAN DEVIATIONS LSA 08-02 17.1 Remedial Actions during FSS There were no remedial actions after FSS in LSA 08-02.

17.2 Adjustments to Scan MDC Calculations Scan MDCs for LSA 08-02 were calculated in accordance with HDP-PR-FSS-701, Revision 10, Final Status Survey Plan Development and HDP-TBD-FSS-002, Revision 3, Evaluation and Documentation of the Scanning Minimum Detectable Concentrations (MDC) for Final Status

Surveys (FSS).

The assumed LSA background count rate of 13,000 cpm was applied to determine the prospective Scan MDCs, and the actual mean count rate from the FSS survey was 10,318 cpm. Therefore the calculated Scan MDCs are conservative, and no adjustments need to be made.

18.0 DATA QUALITY ASSESSMENT The DQO process is thoroughly integrated within the DP and Hematite FSS procedures. The steps of the DQO process are presented in Volume 3, Chapter 1, Section 4.0 of the FSSFR and correspond to the DQO steps described in Chapter 14, Section 4.2.1 of the DP. The HDP DQO process reflects the recommendations given in MARS SIM, Chapter 2, Figure 2-2.

18.1 Data Quality Assessment for LSA 08-02 The Data Quality Assessment of the survey methodology, sampling and sample analysis results, and the Quality Control sampling and analysis results to ascertain the validity of the conclusion for LSA 08-02 (see Figure 18-1) provides the following:

The field and laboratory instruments utilized were capable of detecting activity at an MDC less than the appropriate investigation level, and were verified to be operable prior to and after use in accordance with HDP-PR-HP-416 (Operation of the Ludlum 2221 for Final Status Survey).

The calibration of all instruments that were used to measure or analyze data was current at the time of use and the calibrations of the instruments were performed

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 72 of78 using a NIST traceable source. The instruments used were successfully source checked prior to and after use.

The systematic samples that were collected (on a random-start triangular grid) and the gamma scan surveys that were conducted were performed in accordance with procedure HDP-PR-FSS-711, Final Status Surveys and Sampling of Soil and Sediment.

All samples sent for analysis at the approved offsite laboratory (TestAmerica) were tracked on a chain of custody form in accordance with HDP-PR-QA-006, Chain of Custody.

Quality Control sample results were verified to meet the acceptance criteria as specified in HDP-PR-FSS-703, Final Status Survey Quality Control.

LSA 08-02 survey and sample results were independently reviewed and validated in accordance with HDP-PR-FSS-721 Final Status Survey Data Validation.

The WRS Test is not necessary when the difference between the maximum SU data set measurement SOF and the minimum background area measurement SOF is less than or equal to one. For LSA 08-02, no individual gross SOF result in the FSS data set exceeded the SOF of the minimum background reference area measurement by more than one using the Excavation Stratum criteria. Therefore, the WRS Test was not required for LSA 08-02. However the WRS Test was still performed for illustrative purposes. Since the test statistic, WR (880) exceeded the critical value (764), the FSS data set passed the WRS Test and the null hypothesis was rejected. The WRS Test worksheet is presented in Appendix B.

A biased soil sample was collected from the location of the highest gamma count rate within the SU, with a maximum result of 0.14 Excavation SOF.

The maximum SOF result for all surface samples within LSA 08-02 was 0.27.

The average SOF result for all systematically collected samples within LSA 08-02 was 0.06, with an upper 95% confidence level (UCLmean 0.95) of 0.08.

No FSS sample result in LSA 08-02 exceeded a SOF of 1.0 as compared to the Excavation Stratum criteria, therefore an EMC or supplemental investigations was not required.

A retrospective sampling frequency evaluation was performed to determine if sufficient statistical power exists to reject the null hypothesis based on the total number of systematic samples actually collected (11) within LSA 08-02. The successful result of the retrospective power evaluation presented in Table 18-1 for LSA 08-02 indicates that the minimum number of samples required (8) for the WRS Test was less than the number of sampling locations actually collected within LSA 08-02.

The methodology used for the retrospective sampling frequency evaluation is similar to the prospective sample size determination performed during FSS Plan Development except that actual FSS sample results and statistics are used in the sample size verification. Specifically, the mean and standard deviation of the eight LSA surface samples (i.e., the WRS Test sample data set) are used to derive the relative shift for each LSA. Given the HDP Type I

Hematite Decommissioning Project PSSPR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 73 of78 and Type II errors of 0.05 and 0.10, respectively, the calculated relative shift is then correlated to a minimum sample size number as provided in Table 5-1 of MARS SIM.

HDP staff ensured that a visual inspection of the SU configuration, the Isolation

& Control measures and the Pre-backfill GWS was completed for LSA 08-02 prior to the commencement of backfill operations. Additionally a confirmatory GWS was performed of the SU within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to the commencement of backfill operations. The results of the confirmatory GWS were compared to the results of the PSS GWS and the comparison determined that there were no changes within the LSA since PSS was performed.

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Table 18-1 Retrospective Sample Size Verification for LSA 08-02 N/2 Value Verification lsoto es SOF (Ra/Tc/Th/lso U St. Dev.

0.03 DCGLsoF 1

LBGR Mean 0.06 Shift 0.94 Relative Shift (Ma) 33.74 MARSSIM Table 5.1 Pr 1.000000 N

. 12 N + 20%

14.4 N/2 8

FSS N/2 11 Verification Check "N/2" Corresponds to the number of survey unit measurement locations re uired for the WRS Test MARSSIM Table 5.1 6/a Pr 0.1 0.528182 0.2 0.556223 0.3 0.583985 0.4 0.611335 0.5 0.638143 0.6 0.664290 0.7 0.689665 0.8 0.714167 0.9 0.737710 1.0 0.760217 1.1 0.781627 1.2 0.801892 1.3 0.820978 1.4 0.838864 1.5 0.855541 1.6 0.871014 1.7 0.885299 1.8 0.898420 1.9 0.910413 2.0 0.921319 2.25 0.944167 2.5 0.961428 2.75 0.974067 3.0 0.983039 3.5 0.993329 4.0 0.997658 4.01 1.000000 Page 74 of 78 MARSSIM Table 5.2, a= 0.05, 13 = 0.10 a (or 13)

Z1.... (or Z1.6) 0.005 2.576 0.01 2.326 0.015 2.241 0.025 1.960 0.05 1.645 0.10 1.282 0.15 1.036 0.2 0.842 0.25 0.674 0.30 0.524

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 75 of78 Figure 18-1 Data Evaluation Checklists prepared for LSA 08-02 (page 1 of 2)

Procedure: HDP-PR-FSS-721, Final Status Survey Data Evaluation Hematite Decommissioning Project APPENDIX G-1 Revision: 10 Appendix U-l, Page l of2 FlNAL STATUS SURVEY DATA QUALITY OBJECTIVES REVIEW CHECKLIST Survey Area:

Survey Unit:

LSA 08 02

==

Description:==

Open Land Area, Tc-99 SEA

==

Description:==

Central Open Land Area Survey Unit in "Area IT'

1.

Have all measurements and/or analysis results that will be subjected lo data analysis for FSS been individually reviewed and validated in Yes~ NoD accordance with Section 8.1 of this procedure?

2.

Have all systematic measurements and/or samples been taken or acquired at the locations specified in the FSSP and the FSS Sample

Yes~ NoD Instructions?

3.

I-lave all scans surveys been performed of the areas specified as Yes~ NoD required in the FSSP and the FSS Sample Instructions?

4.

Have all biased measurements and/or samples been taken or acquired Yes rg)

NoD NAO at the locations specified in the FSSP & the FSS Sample Instructions?

5.

Have duplicate and/or split samples or measurements been taken or Yes rg]

NoD NAO acquired at each location designated as a QC sample?

6.

Were the instruments used to measure or analyze the survey data capable of detecting the ROCs or gross activit~ at a MDC less than Yes rgj NoD the appropriate investigation level?

7.

Was the calibration of all instruments that were used to measure or analyze data, current at the time of use and were those calibrations Yes rg)

NoD performed using a NIST traceable source?

8.

Were the instruments successfully response-checked before use and, Yes lZJ NoD where required, alter use on the day the data was measured?

9.

Do the samples match those identified on the chain of custody?

Yes lZl NoD NAO IO.

Do the QC Sample Results meet the acceptance criteria as specified in Yes rg]

No0NA0 I-IDP-PR-fSS-703. Final Status Survey Quality Control?

11.

Are all Laboratory QC parameters within acceptable limits?

Yes rg)

No0NA0 lf **No \\Vas the response to any of the questions above, then document the discrepancy as well as any corrective actions that were taken to resolve the discrepancy.

Comments: N/ A Quality Record

Hematite FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Decommissioning Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Project Revision: 1 Page 76 of78 Figure 18-1 Data Evaluation Checklists prepared for LSA 08-02 (page 2 of 2)

Procedure: HOP-PR-FSS-721. Final Status Survey Data Evaluation Hematite Decommissioning Appendix 0-1, Project Revision: I 0 Page 2 of2 APPENDIX G-1 FINAL STATUS SURVEY DATA QUALITY OBJECTIVES REVIEW CHECKLIST Survey Arca:

No.

LSA 08

==

Description:==

Open Land Area, Tc-99 SEA I

Survey Unit:

No.

02

==

Description:==

Central Open Land Area Survey Unit in "Area I 7

Discrepancy:

None Corrective Actions Taken:

None

11.

Have the corrective actions resolved the discrepancy with the data?

YesO No D NA [gl

a. If"No". then forward this form to the RSO.

12. The following questions will be answered by the RSO.

a. If the answer to question I I was "No'*. then is the affected data YesO No D NA J'.Z1 still valid?

b. If **No. then are the existing valid measurements or samples YesD No D NA l'ZJ sufficient to demonstrate compliance for the survey unit?

c. lf"No", then direct the acquisition of additional measurements or samples as necessary to demonstrate compliance for the survey unit.

Prepared by (I-IP Staft):

Thomas Vardy

~- y~

]*zz*!l (Prinl Nam~) ~

(llatcl Approved by (RSO):

Clark Evers

~3fad'!/l (Print Name)

( g (Date)

Quality R~cord

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 77 of78 19.0 SURVEILLANCE FOLLOWING FSS FSS activities.in LSA 08-02 were completed in February 2016. Between the completion ofFSS and the commencement of backfill operations there were no events that had a potential to re-contaminate LSA 08-02. The assessment that there were no events that had a potential to re-contaminate LSA 08-02 was confirmed by the Pre-backfill GWS that was completed for LSA 08-02 prior to the commencement of backfill operations.

20.0 CONCLUSION

LSA 08-02 An adequate quantity and quality of radiological surveys and samples, as well as the corresponding laboratory analysis has been performed, evaluated and documented to demonstrate that the dose associated with all sources within SU LSA 08-02 does not to exceed the dose criterion for unrestricted release in accordance with 10 CFR 20.1402.

It should be noted that in accordance with Volume 3, Chapter 1, Revision 3, Section 3.1.2 Three Stratum DCGLs, compliance with the "three layer" geometry requires consideration of the Surface, Root, and Deep layers independently, because each of the three DCGLs (Surface, Root, Excavation) represent 25 mrem/yr from each layer independently. Therefore the Unity Rule must be applied when there is more than one layer present, however in the case of LSA 08-02, only the deep stratum remained, therefore the arithmetic average of the systematically collected samples is representative of the residual radioactivity reinaining within the SU (e.g. 0.0 remaining Surface SOF + 0.0 remaining Root SOF + 0.06 remaining Deep SOF = 0.06 remaining SU SOF).

Table 20-1 LSA 08-02 SOF and Dose Summation

A VE. SU SOIL ELEVATED GROUND BURIED REUSE AREA TOTAL RADIOACTIVITY CONTRIBUTION WATER PIPING SOIL SOF 0.06 NIA 0.16 NIA 0.25 0.47 1.5 NIA 4.0 NIA 6.25 11.75 DOSE mrem/year mrem/year mrem/year mremlyear

Hematite Decommissioning Project FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Survey Units OJ and 02 (LSA 08-01 and LSA 08-02)

Revision: 1 Page 78 of78

21.0 REFERENCES

21.1 D0-08-004, Hematite Decommissioning Plan {ML092330123}.

21.2 D0-08-003, Radiological Characterization Report, July 2009 {ML092870496}

21.3 Westinghouse letter HEM-11-56, "Evaluation of Technetium-99 Under the Process Buildings", dated May 5, 201 L 21.4 HDP-TBD-FSS-002, Evaluation and Documentation of the Scanning Minimum Detectable Concentrations (MDC) for Final Status Surveys (FSS) 22.0 APPENDICES {To Be Provided On Separate Data Disc)

APPENDIX A:

APPENDIXB:

APPENDIXC:

APPENDIXD:

APPENDIXE:

APPENDIXF:

APPENDIXG:

APPENDIXH:

Analytical Data Evaluation Spreadsheets for LSA 08-01 Analytical Data Evaluation Spreadsheets for LSA 08-02 FSS Plan Development for LSA 08-01 FSS Plan Development for LSA 08-02 TestAmerica Laboratory Analytical Data Reports for LSA 08-01 TestAmerica Laboratory Analytical Data Reports for LSA 08-02 Westinghouse letter HEM-11-56, "Evaluation ofTechnetium-99 Under the Process Buildings", dated May 5, 2011 HDP-RPT-FSS-302, Summary Report oflnvestigation of Hybrid Wells and Former Process Buildings Investigation Area

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ML17117A312
Site:	07000036 (SNM-0033)
Issue date:	04/03/2017
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