ML17129A328

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ZS-LT-300-001-001, Rev. 2 - Frs Package Development
ML17129A328
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 01/19/2016
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ZionSolutions
To:
Office of Nuclear Reactor Regulation
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ML17129A311 List: ... further results
References
ZS-2016-0022
Download: ML17129A328 (46)


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ZS-LT-300-001-001 Revision2 Information Use ATTACHMENT A D&D Procedure Cover Page CHARACTERIZATION/LICENSE TERMINATION PROCEDURE FINAL RADIATION SURVEY PACKAGE DEVELOPMENT ZS-L T-300-001-001 Revision No. 2 Preparer: (Print name I sign): C 6 C::, \l "'C.Jz /c<l..;+/-.Q Date: \ftet/ "V,>l~

. Chu/k Fuller ff . JJ JJ _ ~ ~

Secondary Reviewer: (Print name I sign): JON f N/J5lTrJ ~ A 7(A,t2.C<<T Date: I,J/9/.?o/6 Joni R Naseifr Regulatory Required Reviews (per AD-11, "Regulatory Reviews")

Part 72 ISFSI Impact License: 10 CFR 72.48 DYES t8:J NO Part 50 License: 10 CFR 50.59 and 50.90 DYES ~NO Fire Protection: 10 CFR 50.48(f) DYES [8J NO Conditions of License: E-Plan: 10 CFR. 50.54(q) DYES ~NO QA Review Required? D YES [8] NO QA Reviewer: N.'A DATE:

Print Name I Signature Technical Review Required? D YES 18:1 NO Technical Reviewer: NiA DATE:

Print Name I Signature Technical Reviewer: NIA DATE:

Print Name I Signature Approval Section

~

DEPARTMENT MANAGER: ,/'""- '

2/ DATE: 1 fL2 .-lo. ....

RF Yetter Signature ~

I DECOMMISSIONING PLANT MANAGER*: NIA DATE:

Print Name I Signature

  • ReQuired for Technical Reviews only Page 1of46

ZS-LT-300-001-001 Revision 2 Information Use Summary of Changes in this Revision:

Rev. 2 - Added clarification from MARSSIM for areas that do not have sufficient characterization data Page 2 of 46

ZS-LT-300-001-001 Revision 2 Information Use

1. PURPOSE AND SCOPE .......................................................................................................4
2. RESPONSIBILITIES ............................................................................................................4
3. DEFINITIONS .......................................................................................................................5
4. PRECAUTIONS, LIMITATIONS, AND PREREREQUISITES .....................................9
5. MAIN BODY ........................................................................................................................12 5.1. FRS Package Numbering ..........................................................................................12 5.2. FRS Sample Plan Development ................................................................................13 5.3. FRS Sample Plan Cover Sheet ..................................................................................14 5.4. FRS Data Quality Objectives and Survey Design ....................................................15 5.5. Sample Plan Survey Instructions ..............................................................................23 5.6. Sample Plan Approval ..............................................................................................25 5.7. Survey Package Implementation...............................................................................25
6. REFERENCES .....................................................................................................................26
7. RECORDS ............................................................................................................................26
8. ATTACHMENTS ................................................................................................................26
9. FORMS .................................................................................................................................27 Page 3 of 46

ZS-LT-300-001-001 Revision 2 Information Use

1. PURPOSE AND SCOPE 1.1. Purpose This procedure provides instructions for the development, implementation and review of Final Radiation Survey (FRS) survey packages and sample plans generated to demonstrate compliance with the dose-based unrestricted release criteria at the Zion Station Restoration Project (ZSRP). Because of differences in the conceptual models and required source terms, the FRS includes two different approaches depending on the media; (1) Final Status Survey (FSS) is conducted on soil, buried piping and groundwater to demonstrate that residual radionuclide concentrations are equal to or below site-specific Derived Concentration Guideline Levels (DCGL), and (2) a Source Term Survey (STS) is conducted to demonstrate that the inventory of residual radioactivity in building basements, embedded piping and penetrations is below a source term inventory commensurate with the dose criterion in 10 CFR 20.1402.

The term FRS is used in this procedure to represent both the FSS and STS surveys.

When the discussion applies to only one of the survey methods, either FSS or STS is specifically referenced.

1.2. Scope This procedure implements the requirements of applicable U.S. Nuclear Regulatory Commission (NRC) regulations and guidance documents; specifically, NUREG-1757, Volume 2, Revision 1 Consolidated Decommissioning Guidance - Characterization, Survey, and Determination of Radiological Criteria (Reference 6.1), NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM, Reference 6.2) and Chapter 5 of the ZSRP License Termination Plan (LTP)

(Reference 6.3).

This procedure applies to all personnel performing FRS survey package development and/or implementation.

2. RESPONSIBILITIES 2.1. Characterization/License Termination (C/LT) Manager - is responsible for:

Providing overall guidance and support for the development and implementation of FRS sample plans and survey packages.

Reviewing and approving all FRS sample plans.

2.2. Radiological Engineer (RE) - is responsible for:

Preparing FRS sample plans and survey packages.

Ensuring FRS surveys are conducted in accordance with approved survey and sampling plans, procedures, and work instructions.

Providing technical direction and guidance to field survey and sampling activities.

Page 4 of 46

ZS-LT-300-001-001 Revision 2 Information Use 2.3. Characterization/Final Radiation Survey (C/FRS) Supervisor - is responsible for:

Controlling and implementing sample plan instructions during field activities.

Survey area/unit preparation, isolation, turnover and prerequisites (e.g., reference grid layout, identification of working constraints and accessibility needs).

Providing daily supervision and guidance to field survey and sampling crews and performing quality checks of field activities.

Overseeing the preparation of samples for transfer to on or off site laboratories.

Ensuring all necessary instrumentation and other equipment is available to support survey activities.

2.4. Graphics/GPS Specialist - is responsible for:

Preparing survey maps, layout diagrams, composite view drawings and other graphics as necessary to support survey design and reporting.

Interacting with the RE regarding the preparation of maps, diagrams and other graphics which present survey units and sample or measurement locations.

2.5. Characterization/Final Radiation Survey (C/FRS) Technicians - are responsible for:

Obtaining and documenting survey measurements in accordance with the survey package instructions.

Ensuring that all activities, actions, observations and obstructions that are encountered during the performance of characterization are documented in Attachment 14, Field Log for that survey unit.

3. DEFINITIONS 3.1. Area Factor (AF) - The factor by which an individual measurement within a specific area can exceed the DCGL, while maintaining compliance with the release criterion.

3.2. Biased Measurements - Measurements performed at locations selected using professional judgment based on unusual appearance, location relative to known contamination areas, high potential for residual radioactivity, general supplemental information, etc. Biased measurements are not included in the statistical evaluation of the survey unit data because they violate the assumption of randomly selected, independent measurements. Instead, judgment measurements are individually compared to the DCGLW.

3.3. Data Quality Assessment (DQA) - The scientific and statistical evaluation of data to determine if the data are of the right type, quantity, and quality for the intended use.

3.4. Data Quality Objectives (DQO) - Qualitative and quantitative statements derived from the DQO process that clarify study technical and quality objectives, define the appropriate type of data, and specify tolerable levels of potential decision errors that will be used as the basis for establishing the quality and quantity of data needed to support decisions.

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ZS-LT-300-001-001 Revision 2 Information Use 3.5. Derived Concentration Guideline Level (DCGL) - A derived, radionuclide-specific activity concentration within a survey unit corresponding to the release criterion. The DCGL is based on the spatial distribution of the contaminant and hence is derived differently for the nonparametric statistical test (DCGLW) and the Elevated Measurement Comparison (DCGLEMC). DCGLs are derived from activity/dose relationships through various exposure pathway scenarios.

3.6. Final Radiation Survey (FRS) - Measurements and sampling to describe the radiological conditions of a site, following completion of decontamination activities (if any) in preparation for release.

3.7. Final Status Survey (FSS) - FRS conducted on soil, buried piping and groundwater to demonstrate that residual radionuclide concentrations are equal to or below site-specific DCGLs.

3.8. Gray Region - A range of values of the parameter of interest for a survey unit where the consequences of making a decision error are relatively minor. The upper bound of the gray region in MARSSIM is set equal to the DCGLW, and the Lower Bound of the Gray Region (LBGR) is a site-specific variable.

3.9. Investigation Level - A derived media-specific, radionuclide-specific concentration or activity level of radioactivity that: 1) is based on the release criterion, and 2) triggers a response, such as further investigation or cleanup, if exceeded.

3.10. Historical Site Assessment (HSA) - A compilation of information prepared for use in planning the FRS of a survey unit. It summarizes the operational history, characterization, remedial action, or operational survey data, and other information, such as past burial or spill events, to help establish the final survey unit classification and the bases for the design of the FRS.

3.11. Measurement - For the purpose of MARSSIM, it is used interchangeably to mean: 1) the act of using a detector to determine the level or quantity of radioactivity on a surface or in a sample of material removed from a media being evaluated, or 2) the quantity obtained by the act of measuring.

3.12. Minimum Detectable Concentration (MDC) - The minimum detectable concentration is the a priori activity level that a specific instrument and technique can be expected to detect 95% of the time. When stating the detection capability of an instrument, this value should be used. The MDC is the Detection Limit, LD, multiplied by an appropriate conversion factor to give units of activity concentration.

3.13. Nonparametric Statistical Test - A test based on relatively few assumptions about the exact form of the underlying probability distributions of the measurements. As a consequence, nonparametric statistical tests are generally valid for a fairly broad class of distributions. The Wilcoxon Rank Sum test and the Sign test are examples of nonparametric statistical tests.

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ZS-LT-300-001-001 Revision 2 Information Use 3.14. Reference Area - Geographical area from which representative reference measurements are performed for comparison with measurements performed in a specific survey unit at remediation site. A site radiological reference area (background area) is defined as an area that has similar physical, chemical, radiological, and biological characteristics as the site area being remediated, but which has not been contaminated by site activities.

3.15. Sample Plan - Sample plans are prepared for each survey unit independently and contain, at a minimum, survey instructions, the number and location of survey measurements and samples, survey maps, instrumentation requirements, and safety requirement as necessary.

3.16. Sign Test - A nonparametric statistical test used to demonstrate compliance with the site release criterion when the radionuclide of interest is not present in background or constitutes a small fraction of the DCGLW.

3.17. Source Term Survey (STS) - FRS conducted to demonstrate that the inventory of residual radioactivity in building basements, embedded piping and penetrations is below a source term inventory commensurate with the dose criterion in 10 CFR 20.1402.

3.18. Survey Area - Survey areas are established based on logical physical boundaries and site landmarks for the purpose of documenting and conveying radiological information, and in order to facilitate the scheduling, management and reporting of the FRS. The survey areas may then be sub-divided into one or more survey units to meet the size requirements as specified by MARSSIM.

3.19. Survey Package - Survey packages are prepared for each survey unit. A survey package is, in essence, a file that contains all sample plans, results, records and other documents relevant to the FRS of the survey unit.

3.20. Survey Unit - The study area consisting of structures or land areas of specified size and shape for which a separate decision will be made to judge whether the remedial action has achieved the site-specific reference-based cleanup standard for the designated pollution parameter. Survey units are generally formed by grouping contiguous site areas with a similar use history and the same classification of contamination potential.

Survey units are established to facilitate the survey process and the statistical analysis of survey data. The survey unit is the fundamental unit of compliance. Each survey unit will meet, or fail to meet, the release criteria independently of all the other survey units. All the survey units must pass if the site is to be released.

3.21. Survey Unit Release Record - A document compiled for each survey unit which demonstrates that it is suitable for unrestricted use. It contains evaluated survey data and supporting information to provide a concise record of the survey results and basis for the conclusion that the release criteria are satisfied.

3.22. Type I Error () - A decision error that occurs when the null hypothesis is rejected when it is true for the scenario used. This would result in incorrectly releasing an area that does not meet the release criteria.

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ZS-LT-300-001-001 Revision 2 Information Use 3.23. Type II Error () - A decision error that occurs when the null hypothesis is not rejected when it is false for the scenario used. This would result in failing to release an area that meets the release criteria.

3.24. Unity Rule - A rule applied when more than one radionuclide is present at a concentration that is distinguishable from background and where a single concentration comparison does not apply. In this case, the combination of measurement results for each singular radionuclide present in the distribution are compared against the release criteria by applying the unity rule. This is accomplished by determining: 1) the ratio between the concentration of each radionuclide in the mixture, and 2) the concentration for that radionuclide that coincides with the release criteria (DCGL). To demonstrate compliance for the survey unit, the sum-of-fractions (SOF) for all radionuclides in the mixture should not exceed 1.

3.25. Wilcoxon Rank Sum (WRS) Test - A nonparametric statistical test used to determine compliance with the site release criterion when the radionuclide of concern is present in background 3.26. Acronyms Type I Error Probability Type II Error Probability Standard Deviation (sigma)

AF Area Factor CoC Chain-of-Custody CFR Code of Federal Regulations C/FRS Characterization/Final Radiation Survey C/LT Characterization/License Termination DCGL Derived Concentration Guideline Level DQA Data Quality Assessment DQO Data Quality Objectives EMC Elevated Measurement Comparison ETD Easy to Detect FRS Final Radiation Survey FOV Field of View FSS Final Status Survey GPS Global Positioning System HSA Historical Site Assessment HTD Hard-to-Detect Page 8 of 46

ZS-LT-300-001-001 Revision 2 Information Use ISOCS In-Situ Object Counting System L Grid Spacing LBGR Lower Bound of the Grey Region LTP License Termination Plan MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MDC Minimum Detectable Concentration NAD North American Datum NRC United States Nuclear Regulatory Commission QA Quality Assurance QC Quality Control QAPP Quality Assurance Project Plan QC Quality Control RASS Remedial Action Support Survey RE Radiological Engineer ROC Radionuclides of Concern RWP Radiation Work Permit SFP Spent Fuel Pool SOF Sum-of-Fractions STS Source Term Survey TSD Technical Support Document VSP Visual Sample Plan WRS Wilcoxon Rank Sum WWTF Waste Water Treatment Facility ZSRP Zion Station Restoration Project

4. PRECAUTIONS, LIMITATIONS, AND PREREREQUISITES 4.1. Precautions 4.1.1 Documents and databases containing FRS survey data and survey records are Quality Assurance (QA) records when complete. Positive control of these records shall be maintained until they are forwarded to Records Management in accordance with AD-20, Records Management Program (Reference 6.4).

4.1.2 When documenting survey information, ensure that all QA records are of good quality and legible. Legibility is determined to be readable and reproducible.

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ZS-LT-300-001-001 Revision 2 Information Use 4.1.3 For FSS survey design, if background is a significant fraction of the DCGLw, the WRS test shall be used. If the contaminant is not in the background or constitutes a small fraction of the DCGLw, the Sign Test shall be used. The determination of which test to use will be integral to the DQO process implemented during the FSS design.

4.1.4 In Class 1 open land survey units, a subsurface soil sample shall be taken at 10%

of the systematic surface soil sample locations in the survey unit with the location(s) selected at random.

4.1.5 For open land survey units, if during the performance of FSS, the analysis of a surface soil sample, or the results of a surface gamma scan indicates the potential presence of residual radioactivity at a concentration of 75% of the subsurface DCGLw, then additional biased subsurface soil sample(s) shall be taken to the appropriate depth within the area of concern as part of the investigation.

4.2. Limitations 4.2.1 All attachments described in this procedure may be generated electronically. If electronic attachments are used, the physical layout of the attachment may be modified provided the intent described in this procedure is not changed.

4.2.2 The output of the design process is the sample plan (instructions). A sample plan is prepared for each survey unit independently. A survey package is prepared for each survey unit and may contain one or more sample plans.

4.2.3 Radiation detection and measurement instrumentation will be selected based on the type and quantity of radiation to be measured. The target MDC for measurements obtained using field instruments will be 50 percent of the applicable DCGLw.

4.2.4 Instruments used for scan measurements in Class 1 areas are required to be capable of detecting radioactive material at the DCGLEMC.

4.2.5 The target MDC for measurements obtained using laboratory instruments will be 10 percent of the applicable DCGLw.

4.2.6 Measurement results with associated MDC that exceed the target MDC values may be accepted as valid data after evaluation by C/LT supervision.

4.2.7 The Canberra In-Situ Object Counting System (ISOCS) has been selected as the primary instrument that will be used to perform STS. ZionSolutions Technical Support Document (TSD)14-022, Use of In-Situ Gamma Spectroscopy for Source Term Survey of End State Structures (Reference 6.5) provides the initial justification for selecting a reasonably conservative geometry for efficiency calibrations for the ISOCS based on the physical conditions of the remediated surface and the depth and distribution of activity in the concrete surface. Review post remediation conditions and surveys to determine if the geometry of remaining residual radioactivity has significantly changed from that assumed in TSD 14-022. If the geometry appears to be significantly different from that which was assumed in TSD 14-022, then inform the C/LT Manager.

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ZS-LT-300-001-001 Revision 2 Information Use 4.2.8 After completion of the FRS in a specific survey unit, the sample plan is reviewed for completeness and the data validated in accordance with ZS-LT-300-001-004, Final Radiation Survey Data Assessment (Reference 6.6) before sample plan closure and the reporting of results.

4.2.9 Upon closure of the sample plan, a survey unit release record will be prepared for each survey unit within the survey area in accordance with ZS-LT-300-001-005, Final Radiation Survey Reporting (Reference 6.7).

4.2.10 For the FRS of Class 3 survey units, if a randomly selected location is found to be either inaccessible or unsuitable, then the location will be adjusted to the closest adjacent suitable location. In these cases, a notation will be made in Attachment 14, Field Log and the coordinates of the new location documented.

4.3. Prerequisites 4.3.1 A FRS package will be prepared for each applicable survey unit. A folder designated as the FRS package should be utilized to keep original documents.

The folder shall be controlled in accordance with the record quality requirements of ZS-LT-01 Quality Assurance Project Plan (QAPP) for Characterization and Final Radiation Survey (Reference 6.8).

4.3.2 The impacted structural and open land survey areas at ZSRP have been subdivided into Class 1, Class 2, or Class 3 survey units. The initial classifications and survey unit boundaries are specified in the Commonwealth Edison Zion Station Historical Site Assessment, (HSA, Reference 6.9). Actual open land survey unit boundaries may vary from the conceptual survey unit boundaries presented in the HSA based on actual conditions at the time of survey design as long as the classification does not change. The survey units designated for structures below 588 foot elevation from the HSA were based on screening values and source term assumptions that are not applicable.

4.3.3 With the exception of the Auxiliary Building, where the walls and floor will be separate survey units, the STS survey units will be comprised of the combined wall and floor surfaces of each remaining building basement (i.e. Unit 1 Containment, Unit 2 Containment, Turbine Building, Crib House/Forebay, Waste Water Treatment Facility (WWTF), remnants of the Spent Fuel Pool (SFP)/Fuel Transfer Canal and the Circulating Water Intake and Circulating Water Discharge Tunnels). The total embedded pipe located within a STS survey area will be treated as a separate STS survey unit. As such, the STS penetration and/or embedded pipe survey unit will be part of the summation of the fraction of the inventory source term calculated for each building basement in which they are located.

4.3.4 Characterization data, radiological surveys performed to support commodity removal, and surveys performed to support structural remediation for open air demolition will be used to verify that the contamination potential within each STS survey unit is reasonably uniform throughout all walls and floor surfaces.

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ZS-LT-300-001-001 Revision 2 Information Use 4.3.5 The size of a Class 1 open land survey unit will not exceed 2,200 m2 and the size of a Class 2 open land survey unit will not exceed 11,000 m2 without approval of the C/LT Manager.

4.3.6 Final classification of an open land survey unit should be assigned and/or validated in accordance with ZS-LT-300-001-002, Survey Unit Classification (Reference 6.10).

4.3.7 Prior to issuance of a specific sample plan for performance of the FRS, isolation and control measures shall be established in accordance with ZS-LT-300-001-003, Isolation and Control for Final Radiation Survey (Reference 6.11).

4.3.8 Survey units should be cleared of all loose equipment and materials to the maximum extent possible.

NOTES The vegetation in open land survey units should be cut as close to the ground surface as possible.

With the exception of accessibility, the use of an ISOCS for FSS does not require vegetation to be removed.

4.3.9 To eliminate physical obstructions, open land survey units should be cleared of debris and/or vegetation to the extent possible.

4.3.10 All identified physical hazards in the survey unit shall be either removed or marked as appropriate.

4.3.11 Prior to performing FRS, a reference coordinate system or grid will be established. For the FSS of open land survey units, reference coordinates will be acquired using a Global Positioning System (GPS) coupled with the North American Datum (NAD) standard topographical grid coordinate system.

4.3.12 The systematic sampling and measurement locations within each survey unit will be clearly identified and documented for the purposes of reproducibility. Actual measurement locations will be marked and identified by tags, labels, flags, stakes, paint marks, GPS location, photographic record, or equivalent.

4.3.13 Prior to using any survey instrument, the current calibration will be verified.

Response checks will be performed daily before instrument use and again at the end of use.

5. MAIN BODY 5.1. FRS Package Numbering NOTES The Survey Area Number, Survey Unit Number and current classification are taken from the updated master copy of Survey Units for Open Land Areas and Survey Units for Structures that are maintained by the C/LT Manager in accordance with procedure ZS-LT-300-001-002, Survey Unit Classification.

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ZS-LT-300-001-001 Revision 2 Information Use 5.1.1 Prepare a FRS Package. FRS Packages will be designated as follows:

1.) The 1st digit indicates the type of Survey Area A. L = Open Land B. B = Structural C. S = System 2.) The 2nd digit indicates the Current Classification A. 1 = Class 1 B. 2 = Class 2 C. 3 = Class 3 D. 4 = Non-Impacted E. 5 = Unassigned 3.) The 3rd, 4th and 5th digits indicates Survey Area Number 4.) The 6th and 7th digits indicates Survey Unit Number 5.) The 8th digit is the alphanumeric sequence where: Sequence A-J allows the survey unit to be divided into 10 smaller survey units. Sequence K-Z allows for up to 16 different survey instructions for a single survey unit.

6.) The 9th digit is the letter F to designate FSS or the letter S to designate STS.

5.2. FRS Sample Plan Development 5.2.1 Prepare a FRS Sample Plan for each survey unit independently. A FRS Package may contain one or more FRS Sample Plans.

NOTE The RE tasked with the development and implementation of multiple FRS Sample Plans for a single survey unit must be aware that it is possible that duplicate sample/measurement numbers may be generated when using the guidance for designating a unique sample identification number in accordance with the Sample & Measurement Unique Identification Designation presented in Attachment 7. Consequently, the responsible RE must be vigilant to ensure that this does not occur.

5.2.2 Designate each FRS Sample Plan in the FRS Package specific to a survey unit numerically by sequence (e.g., Plan #1, Plan #2, etc).

5.2.3 A FRS sample plan will usually contain the items listed below.

1.) Attachment 11, FRS Sample Plan Cover Sheet.

2.) Area Turnover and Control Checklist from ZS-LT-300-001-003, Isolation and Control for Final Radiation Survey.

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ZS-LT-300-001-001 Revision 2 Information Use 3.) Pre-Turnover Walk-Down from ZS-LT-300-001-003, Isolation and Control for Final Radiation Survey.

4.) Survey Unit Classification Basis Summary from ZS-LT-300-001-002, Survey Unit Classification.

5.) Survey Unit Classification Worksheet from ZS-LT-300-001-002, Survey Unit Classification.

6.) Attachment 12, FRS Data Quality Objectives and Survey Design.

7.) Attachment 13, Survey Instructions.

8.) Attachment 14, Field Log.

9.) Attachment 15, Sample/Measurement Identification and Coordinates.

10.) Attachment 16, Scan Area Identification and Coordinates.

11.) Photographs, maps, and/or drawings of the survey unit.

12.) FRS field measurement and analytical results.

5.2.4 Include any available relevant information for the survey unit, (i.e. as-built floor plans, blue prints, photographs, computer generated or hand drawn survey maps) in the FRS sample plan.

5.2.5 Provide a unique sample identification number for all FRS direct measurements and/or samples in accordance with Attachment 7, Sample & Measurement Unique Identification Designation.

5.3. FRS Sample Plan Cover Sheet 5.3.1 Initiate Attachment 11, FRS Sample Plan Cover Sheet for the survey unit.

5.3.2 Complete the General Section of Attachment 11, by entering the requested information.

5.3.3 Assess the readiness of the survey unit by completing the Preparation for Final Radiation Survey section of Attachment 11 using the following guidance:

1.) Ensure that a pre-FRS walk-down of the survey unit has been performed in accordance with ZS-LT-300-001-003, Isolation and Control for Final Radiation Survey and that all items identified for hazard mitigation and area preparation have been satisfactorily completed.

2.) Ensure that all turnover items that were identified on the Area Turnover and Control Checklist from ZS-LT-300-001-003, Isolation and Control for Final Radiation Survey, have been completed or resolved prior to signifying readiness.

5.3.4 The responsible RE shall signify by signature on Attachment 11 that the survey unit is ready for FRS implementation.

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ZS-LT-300-001-001 Revision 2 Information Use 5.4. FRS Data Quality Objectives and Survey Design 5.4.1 Initiate Attachment 12, FRS Data Quality Objectives and Survey Design for the survey unit.

NOTE The problem associated with FRS is to determine whether the survey unit meets a specified radiological release criterion (e.g., 10 CFR 20.1402).

5.4.2 State the Problem - commence survey design through the DQO process by providing a clear description of the problem and a conceptual model of the hazard to be investigated.

1.) Clearly state the problem.

2.) Identify the stakeholders.

3.) Identify the planning team and decision maker(s).

4.) Specify the anticipated schedule for the activity.

5.) Identify the resources and support that will be required to successfully complete the activity.

NOTE The principal study question for FSS might be, Does the residual radioactive contamination present in the survey unit exceed the release criteria?. The principal study question for STS might be, Is the inventory of residual radioactivity in the building basement, including all relevant embedded piping and penetrations, when multiplied by the Basement Dose Factors, below the 25 mrem/yr dose criterion?. Alternative actions may include no action, investigation, re-survey, remediation and/or reclassification. The stated decision may be, IF any of the measurement data results exceed the release criteria, THEN use the DQA process to evaluate the alternative action or combination of actions.

5.4.3 Identify the Decision - develop objectives for the FRS, or if applicable, several objectives, based on the stated problem.

1.) State the principal study question.

2.) List any alternative actions.

3.) Clearly state the decision.

5.4.4 Identify Inputs to the Decision - Identify the types and quantity of radiological data that will be necessary to address the objectives identified in the previous step.

1.) State the information needed.

A. Identify the sample media (e.g., surface soil, concrete).

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ZS-LT-300-001-001 Revision 2 Information Use B. Identify the types of measurement (e.g., scan, static measurement, surface soil sampling, etc.).

C. Identify sources of information that will be used (e.g., HSA, previous survey data, etc).

2.) Summarize any relevant historical information for the survey unit using the following guidance:

A. Summarize the function of the survey unit during facility operation.

B. Summarize any process events, spills or radiological incidents that have been documented in the HSA and are pertinent to the survey unit.

C. Summarize the current radiological condition of the survey unit using all available past and present radiological surveys [e.g. routine surveys, Radiation Work Permit (RWP) coverage surveys] that are pertinent to the survey unit.

3.) List the Radionuclides-of-Concern (ROC) and the basis for being included in the sampling plan.

NOTE Attachment 1 presents the Basement Dose Factors from LTP Chapter 5, Table 5-3. Attachment 2 presents the site-specific DCGLs for surface and subsurface soils reproduced from Table 5-4 and Table 5-5 of LTP Chapter 5.

Attachment 3 presents the site-specific DCGLs for buried pipe reproduced from Table 5-6 of LTP Chapter 5.

For multiple radionuclides, the unity rule applies.

4.) State the release criteria (DCGL or Basement Dose Factors) for each ROC applicable to the survey.

5.) Summarize the radiological survey data that will be used for FSS design for open land and buried pipe survey units. For STS survey units, summarize the historical radiological conditions applicable to the survey unit and proceed to step 5.4.5.

A. Review the characterization and/or RASS sample data to determine if adequate data is available to perform FSS design. When preliminary data are not obtained, it may be reasonable to assume a coefficient of variation on the order of 30%, based on experience.

B. Derive and list the basic statistical data for each analyzed radionuclide or direct measurement in the survey data that will be used for the FSS design for the survey unit. At a minimum, the statistics will include the minimum, maximum, mean and median value of the data set and the standard deviation.

C. Calculate a mean SOF for the survey data that will be used for the FSS design using the following equation.

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ZS-LT-300-001-001 Revision 2 Information Use 1 2

= + +

1 2 Where Concn = mean concentration of radionuclide n and DCGLn = DCGL of radionuclide n D. Calculate a weighted Standard Deviation (SOF) for the survey data that will be used for the FSS design for the survey unit.

1 2 2 2 2

= [( ) +( ) + ( ) ]

1 2 Where n = standard deviation of radionuclide n and DCGLn = DCGL of radionuclide n NOTE Characterization or RASS data with excessive variability is typically not representative of the radiological condition of the survey unit at the time of the FSS.

E. Assess the variability of the survey data that will be used for survey design.

F. Document on the sample plan that the characterization and/or RASS data that will be used for survey design is satisfactory. If the data is not satisfactory, then provide a technical justification to continue the planning process that includes an assessment of process knowledge and historical information. Document the basis in the sample plan or, stop and perform additional characterization surveys and repeat the planning process.

G. Determine the need to sample and analyze for HTD radionuclides or, if a surrogate relationship will be established between the presence of the HTD radionuclide and a gamma-emitting radionuclide.

i. If a surrogate relationship is to be established, then describe the survey populations used to establish the relationship, the fraction that will be used to mathematically describe the relationship between the HTD radionuclide and gamma-emitting or easy-to-detect (ETD) radionuclide and the basis for its use.

ii. Derive the surrogate DCGL using the following equation; 1

=

1 2 3

[( ) + ( ) + ( ) + ( )]

1 2 3 Where DCGLsur = Surrogate DCGL for ETD radionuclide Page 17 of 46

ZS-LT-300-001-001 Revision 2 Information Use Rn = Established ratio of radionuclide n with radionuclide to be used as surrogate DCGLn = DCGL of radionuclide n 6.) Describe the action levels as well as the actions that will be taken if they are reached. The action level provides the criterion used during the decision process for choosing among alternative actions.

7.) Establish the requisite scan coverage area for the sample plan and the basis for the selection.

A. Survey units will be scanned in accordance with their classification. Scan coverage recommendations for characterization for each class of survey unit is presented in Attachment 4.

B. If less than 100% scan coverage is required, then designate areas to be scanned using the reference coordinate system that equates to the required total area that is to be scanned and document the basis of why that area was selected.

C. Designate scan locations, and location coordinates on Attachment 16, Scan Area Identification and Coordinates and on the survey map.

D. If less than 100% scan coverage is required, then a 1-meter radius should be scanned around each probability-based and biased sample location in addition to the area designated for scanning.

8.) Determine and document the type and frequency of Quality Control (QC) measurements using the QAPP as guidance.

9.) Determine the investigation levels using Attachment 5 as guidance and document in the sampling plan.

NOTE Static and Scan MDC for scanning structures and soil will be determined in accordance with the guidance provided in Attachment 8.

10.) Determine the type of analyses that will be performed on material sample(s).

A. Establish the analytical MDCs and reporting errors necessary to meet objectives of the sampling plan.

B. Designate the radiological instrumentation that will be used to acquire field measurements and document that the static and scan MDC is sufficient for the action levels specified.

C. Establish criteria for sample moisture content, considering the impact on detection sensitivity to low energy photons or particles (requires drying or maximum moisture content).

Page 18 of 46

ZS-LT-300-001-001 Revision 2 Information Use 5.4.5 Define the Study Boundaries 1.) Generate a computerized survey map for the survey unit and include the boundaries of the entire survey unit and major geographic or physical features.

(If necessary, drawings may be substituted for computer generated maps).

Ensure the graphic representation of the dimensions and boundaries correspond to the established reference coordinate system.

2.) Describe the boundaries, physical conditions, orientation and landmarks of the survey unit using the following guidance:

A. Describe the spatial boundaries of the survey unit, including length and width in meters.

B. Describe the different surfaces and media present in the survey unit (e.g.

surface soil, sediment bed, sand beach).

C. Describe any physical landmarks or prominent features present.

D. Describe the orientation of the survey unit in relation to other survey units, prominent or established geographic landmarks and compass direction.

3.) Describe the temporal boundaries, including the anticipated schedule for performing the survey, the expected weather conditions and any time constraints.

4.) Describe any applicable and practical constraints or conditions when survey performance may not be possible, including but not limited to, physical obstacles to access the area of interest and inclement weather.

5.) Identify contingencies when possible to define acceptable solutions or alternatives to these constraints.

5.4.6 Develop a Decision Rule - Using the If, Then format, and create a condition or set of condition(s) where a conclusion or set of conclusions can be made in regard to the objectives of the survey based on comparison of the survey results with the action level(s) and/or an assessment of the data statistics.

5.4.7 Specify Limits on Decision Errors 1.) State the null hypothesis (e.g., The survey unit exceeds the release criteria.)

Page 19 of 46

ZS-LT-300-001-001 Revision 2 Information Use NOTE Section 5.5.2.2 of LTP Chapter 5 presents the logic and reasoning employed to determine adequate areal coverage based upon contamination potential for each STS survey unit. The required number of ISOCS measurements required in each STS survey unit was then calculated as the quotient of the ISOCS Field-of-View (FOV) divided into the surface area required for areal coverage. To ensure that the number of ISOCS measurements based on the necessary areal coverage in a STS survey unit was sufficient to satisfy a statistically based sample design, a simplified calculation was performed to determine sample size using the guidance in MARSSIM. This calculation is summarized in section 5.5.2.2 of LTP Chapter 5 and was applied to the Class 2 and Class 3 STS survey units. Attachment 6 presents the STS survey units and the minimum number of ISOCS measurements that shall be taken in each for STS.

2.) If performing survey design for STS, then proceed to 5.4.8, step 5.

3.) Define both the Type I, or ( value) error and the Type II, or ( value) error as 0.05. The Type I error will always be set at 0.05 unless prior NRC approval is granted for using a less restrictive value. The Type II error may be adjusted with the concurrence of the C/LT Manager, after weighing the resulting change in the number of required sample or measurement locations against the risk of unnecessarily investigating and/or remediating survey units that are truly below the release criterion.

NOTE If no other information is available regarding the survey unit, the LBGR may be initially set equal to 0.5 times the applicable DCGLW and may be set as low as the MDC for the specific analytical technique.

4.) Establish the LBGR. The LBGR should be initially set at the mean concentration of residual radioactivity that is estimated to be present in the survey unit or the mean Sum-of-Fractions (SOFMean) if multiple radionuclides are present.

5.4.8 Optimize the Design.

NOTE The Sign Test is expected to be the most appropriate test for ZSRP FRS results because background is expected to constitute a small fraction of the DCGL. If a situation is encountered where background is a significant fraction of the DCGL, the WRS Test may be used.

1.) Determine the appropriate statistical test, Sign Test or WRS that will be used to meet the objectives of the sampling plan.

Page 20 of 46

ZS-LT-300-001-001 Revision 2 Information Use 2.) Calculate the relative shift (/) using the following equation:

Action Level LBGR SOF where; / = Relative Shift LBGR = Lower Bound of the Gray Region A. If the resulting Relative Shift is between (and including) one (1) and three (3), then go to step 3.). Otherwise, proceed to the next step.

B. If the Relative Shift is greater than three (3), then use a value of three (3) as the adjusted Relative Shift. Adjust the LBGR by subtracting the estimated concentration variability from the DCGL.

C. If the Relative Shift is less than one (1), then stop and return to the DQO process to determine the cause and/or make adjustments to the DQOs.

3.) Determine the number of samples (N) needed in the survey unit for the selected values of Type I error (), Type II error () and Relative or adjusted Relative Shift (/) from the appropriate table of the number of samples and record in the space provided.

A. If the Sign Test has been chosen as the statistical test, then use Attachment 9 to determine N.

B. If the WRS Test has been chosen as the statistical test, then use Attachment 10 to determine N/2.

4.) Ensure that the scan MDC of the instrument and detector that will be used for scanning is less than the DCGLw of the most limiting ROC or surrogate radionuclide. If the scan MDC is greater than the DCGLw of the most limiting ROC or surrogate radionuclide, then the N value must be adjusted in accordance with MARSSIM, section 5.5.2.4.

NOTE Software such as Visual Sample Plan (VSP) may be used to determine the location of samples or direct measurements in lieu of the following steps.

5.) Calculate the Grid Spacing A. If the survey unit is classified as Class 3, then proceed to step 6.

B. If the survey unit is STS and classified as Class 1 (Auxiliary Building 542 foot Floor or the SFP/Transfer Canal), then sufficient ISOCS measurements shall be taken in the survey units to provide 100% areal coverage.

C. If the survey unit is STS and classified as Class 2 or, if the survey units is FSS and classified as Class 1 or Class 2, then calculate the Grid Spacing (L) as follows; Page 21 of 46

ZS-LT-300-001-001 Revision 2 Information Use Area Area D. L L

.866 N or N 2

for a triangular grid, or N or N 2

for a square grid 6.) Generate a Survey Map A. Assign a unique identification number to each sample in the Statistical Sample Population using the guidance and direction provided in Attachment 7.

NOTE A computer generated survey map shall be generated for each sample plan and should show the boundaries of the entire survey unit, major geographic or physical features and the coordinates of all survey locations.

Software such as VSP may be used to determine the location of samples or direct measurements in lieu of the following steps.

B. Generate a graphic representation of the Survey Unit with dimensions and boundaries corresponding to the established reference coordinate system.

C. If the survey unit is classified as STS Class 1, then establish a sufficient number of measurement locations with an overlapping FOV to provide 100% areal coverage and continue to step H.

D. If the survey unit is classified as STS or FSS Class 3, then establish sample locations on the survey map using a random-number generator and continue to step H.

NOTE The grid spacing may be rounded down for ease of locating sampling and measurement locations on the reference grid. Depending on the configuration and layout of the survey unit and the starting grid location, the minimum number of sampling and measurement locations may not be identified (as they fall out of the survey unit footprint). In this event, either a new random starting location will be specified or the grid spacing adjusted downward until the appropriate number of locations is reached.

E. If the survey unit is STS and classified as Class 2 or, if the survey units is FSS and classified as Class 1 or Class 2, then establish a Random Starting Point within the Survey Unit.

F. Starting from the randomly-selected location, establish a row of points parallel to one of the survey units axes at intervals of L.

G. Establish additional rows parallel to the first row.

Page 22 of 46

ZS-LT-300-001-001 Revision 2 Information Use

i. For a triangular grid, additional rows will be added at a spacing of 0.866L from the first row, with points on alternate rows spaced mid-way between the points from the previous row.

ii. For a square grid, points and rows will be spaced at intervals of L.

H. Using the reference coordinate system, ascertain coordinates for each sample location.

I. Designate sample locations, and location coordinates on Attachment 15, Sample/Measurement Identification and Coordinates.

7.) Designate 5% of the systematic measurement and/or sample locations, chosen at random, for replicate measurement and/or split sample analyses in accordance with the QAPP. Designate QC sample locations, and location coordinates on Attachment 15, Sample/Measurement Identification and Coordinates and the survey map.

NOTE Biased samples are not included as part of the Statistical Sample Population.

Rather, they are treated as pre-emptive investigation samples.

8.) Designate if any biased samples will be taken at the discretion of the survey designer and the basis for taking them.

A. Using the reference coordinate system, ascertain coordinates for each biased sample location.

B. Designate biased sample locations and location coordinates on Attachment 15, Sample/Measurement Identification and Coordinates and the survey map.

5.5. Sample Plan Survey Instructions NOTE Survey instructions may be provided without using Attachment 13 provided all the applicable items of the Survey Instruction attachment are included.

5.5.1 Complete the General Instructions section of Attachment 13, Survey Instructions. The type of instructions that may be specified in the General Instructions include but are not limited to the following:

1.) Area description and dimensions, physical features, water bodies and natural boundaries.

2.) Any temporal boundaries such as:

A. Expected weather conditions B. Time constraints C. Schedule for survey (e.g., round-the-clock, daylight hours).

Page 23 of 46

ZS-LT-300-001-001 Revision 2 Information Use 3.) Safety considerations including any required Personal Protective Equipment, safety sampling and/or safety surveillances.

4.) References to relevant procedures for survey performance, sample collection and sample analysis.

5.) A list of all equipment and instrumentation required to perform the survey, as well as applicable procedural references.

6.) Quality control measures such as instrument calibration requirements, instrument control requirements and instrument response check requirements as necessary.

7.) Additional requirements such as GPS use, marking of sample locations, documentation, photographs, etc.

5.5.2 Complete the Specific Instructions section of Attachment 13. The type of instructions that may be specified in the Specific Instructions include, but are not limited, to the following:

1.) Description of potential safety hazards that may be encountered during performance of the survey.

2.) Identified areas, conditions or constraints where sampling or surveying may not be possible and alternative solutions to support survey requirements if these obstacles are encountered.

3.) Specific instructions for performing sampling, scans, static measurements, loose surface contamination measurements or special measurements that may include, but is not limited to:

A. Area (in square meters) and location for surface scans.

B. Specific scanning instructions including scan speed, pattern (e.g.,

serpentine), alarm set-points, action levels, background check, etc.

C. Scan MDC requirements.

D. Contingency for relocating sample location due to obstacle, obstruction, or for safety reasons.

E. Instructions for background correction if applicable.

F. Count times for static measurements.

G. Desired depth and volume requirements for surface and subsurface soil samples.

H. Directions for collecting and analyzing samples of other media types.

I. Directions for collecting water, sediment or vegetation samples as necessary.

4.) Instructions for performing other radiological surveys.

Page 24 of 46

ZS-LT-300-001-001 Revision 2 Information Use 5.) Instructions for quality control (e.g., techniques to prevent cross-contamination, proper sampling, and labeling techniques).

6.) Investigation actions to be performed in the survey specific instructions if action levels for scanning are exceeded.

7.) Documentation requirements (e.g., survey map, documentation of anomalies, clarity and good legibility).

8.) Chain-of-Custody (CoC) instructions in accordance with procedure ZS-WM-131, Chain-Of-Custody (Reference 6.12).

9.) Any areas of interface where the progress of the survey will be contingent on interaction or support from another department or group (e.g., security notification, man-lift support, scaffold erection support, excavation or soil loading support, etc.)

5.6. Sample Plan Approval 5.6.1 Once a sample plan is complete, forward it to a separate qualified individual to perform an independent peer review to check for plan completeness, accuracy of calculations and viability of assumptions.

5.6.2 Complete the independent peer review and sign as the reviewer on Attachment 11, FRS Sample Plan Cover Sheet. (Peer Reviewer) 5.6.3 Upon completion of the peer review, forward the sample plan to the C/LT Manager for approval.

NOTE FRS may not proceed in a survey unit until Attachment 11 has been signed by the C/LT Manager.

5.6.4 Signify approval of the FRS Sample Plan by signing Attachment 11, FRS Sample Plan Cover Sheet. (C/LT Manager) 5.7. Survey Package Implementation 5.7.1 Perform a pre-survey briefing with the C/FRS Technicians to review instructions and safety issues. (RE) 5.7.2 Initiate a Field Log (Attachment 14) for the sample plan. (C/FRS Supervisor) 5.7.3 Perform surveys in accordance with the survey unit specific survey instructions contained in each FRS Sample Plan. (C/FRS Technicians) 1.) If a situation is encountered in which survey instructions cannot be followed as written, then contact the responsible RE for resolution.

A. Make minor changes that do not affect the technical content of the survey package (typographical errors, instrument ID, etc.) using a pen and ink change.

Page 25 of 46

ZS-LT-300-001-001 Revision 2 Information Use B. Make major changes to survey instructions that would affect the technical content (i.e. number of measurements, instrument MDC, etc.) by revising the sample plan instructions and include a revision number. Document sample plan revisions and reasons and forward the revised sample plan to the C/LT Manager for approval.

6. REFERENCES 6.1. NUREG-1757, Consolidated NMSS Decommissioning Guidance - Characterization, Survey, and Determination of Radiological Criteria Volume 2, Revision 1 -

September 2002 6.2. NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) - August 2000 6.3. Zion Station Restoration Project License Termination Plan - December 2014 6.4. AD-20, Records Management Program 6.5. ZionSolutions Technical Support Document 14-022, Use of In-Situ Gamma Spectroscopy for Source Term Survey of End State Structures - May 2015 6.6. ZS-LT-300-001-004, Final Radiation Survey Data Assessment 6.7. ZS-LT-300-001-005, Final Radiation Survey Reporting 6.8. ZS-LT-01 Quality Assurance Project Plan (QAPP) for Characterization and FRS 6.9. Commonwealth Edison Zion Station Historical Site Assessment 6.10. ZS-LT-300-001-002, Survey Unit Classification 6.11. ZS-LT-300-001-003, Isolation and Control for Final Radiation Survey 6.12. ZS-WM-131, Chain-Of-Custody 6.13. ISO 7503-1, Evaluation of surface contamination - Part 1: Beta-emitters (maximum beta energy greater than 0.15 MeV) and alpha-emitters 6.14. ZionSolutions Technical Support Document 11-004, Ludlum Model 44-10 Detector Sensitivity - February 2012

7. RECORDS 7.1. Final Radiation Survey Package
8. ATTACHMENTS 8.1. Attachment 1, Basement Dose Factors 8.2. Attachment 2, Site-Specific DCGLs for Surface and Subsurface Soils 8.3. Attachment 3, Site-Specific DCGLs for Buried Piping 8.4. Attachment 4, Recommended Scan Coverage 8.5. Attachment 5, Investigation Levels Page 26 of 46

ZS-LT-300-001-001 Revision 2 Information Use 8.6. Attachment 6, Number of ISOCS Measurements per STS Survey Unit based on Areal Coverage 8.7. Attachment 7, Sample & Measurement Unique Identification Designation 8.8. Attachment 8, Calculation of Static and Scan MDC 8.9. Attachment 9, Number of Samples Required for the Sign Test 8.10. Attachment 10, Number of Samples Required for the WRS Test 8.11. Attachment 11, FRS Sample Plan Cover Sheet 8.12. Attachment 12, FRS Data Quality Objectives and Survey Design 8.13. Attachment 13, Survey Instructions 8.14. Attachment 14, Field Log 8.15. Attachment 15, Samples/Measurement Identification & Coordinates 8.16. Attachment 16, Scan Area Identification & Coordinates

9. FORMS None Page 27 of 46

ZS-LT-300-001-001 Attachment 1 Revision 2 Basement Dose Factors Information Use Nuclide Auxiliary Containment Turbine SFP Crib WWTF House/Forebay Co-60 1.10E-02 4.13E-02 1.26E-02 1.20E+00 2.05E-02 7.57E-01 Cs-134 1.57E-02 2.16E-01 5.56E-02 7.15E-01 5.31E-02 9.27E+00 Cs-137 3.00E-02 1.65E-01 4.21E-02 3.67E-01 3.83E-02 7.31E+00 Eu-152 5.14E-03 1.77E-02 5.48E-03 5.66E-01 9.18E-03 2.83E-01 Eu-154 5.70E-03 2.04E-02 6.21E-03 6.26E-01 1.01E-02 3.73E-01 H-3 6.28E-03 2.73E-02 6.88E-03 1.10E-08 5.87E-03 1.25E+00 Ni-63 2.89E-04 1.61E-03 4.06E-04 2.85E-06 3.48E-04 7.40E-02 Sr-90 3.33E-01 4.54E+00 1.15E+00 5.83E-04 9.78E-01 2.09E+02 Note In units of mrem/yr per mCi Page 28 of 46

Attachment 2 ZS-LT-300-001-001 Site Specific DCGLs for Surface and Revision 2 Subsurface Soils Information Use DCGLs for Surface Soils Surface Soil DCGL Radionuclide (pCi/g)

Co-60 4.7 Cs-134 7.5 Cs-137 15.7 Ni-63 3998 Sr-90 14.3 DCGLs for Subsurface Soils Subsurface Soil DCGL Radionuclide (pCi/g)

Co-60 3.8 Cs-134 4.9 Cs-137 8.5 Ni-63 847 Sr-90 1.8 Page 29 of 46

ZS-LT-300-001-001 Attachment 3 Revision 2 Site Specific DCGLs for Buried Piping Information Use DCGLs for Buried Piping Buried Piping DCGL Radionuclide (dpm/100 cm2)

Co-60 3.60E+04 Cs-134 6.33E+04 Cs-137 1.50E+05 Ni-63 1.31E+08 Sr-90 3.49E+05 Page 30 of 46

ZS-LT-300-001-001 Attachment 4 Revision 2 Recommended Scan Coverage Information Use Area Surface Activity Measurements Scan Coverage Classification Or Soil Samples As determined by statistical tests; additional Class 1 100 percent measurements/samples to account for small areas of elevated activity as necessary Class 2 10 to 100 percent As determined by statistical tests 1 to 10 percent Class 3 (Judgmental)

Page 31 of 46

ZS-LT-300-001-001 Attachment 5 Revision 2 Investigation Levels Information Use Survey Unit Direct Measurement Scan Investigation Levels:

Classification Investigation Levels:

Class 1 > DCGLEMC > DCGLEMC

> DCGLW or > MDCscan if Class 2 > DCGLw MDCscan is greater than DCGLW

> DCGLW or > MDCscan if Class 3 > 50 percent of DCGLw MDCscan is greater than DCGLW Page 32 of 46

Attachment 6 ZS-LT-300-001-001 Number of ISOCS Measurements per STS Survey Revision 2 Unit based on Areal Coverage Information Use Required Minimum # of Adjusted Adjusted Areal ISOCS Areal Areal STS Survey Unit Classification Coverage Measurements Coverage Coverage (m2) (m2) (% of Area)

Auxiliary Building Class 1 2,591 93 2,591 100%

542 foot Floor Auxiliary Building Class 2 392 14 392 10%

Basement Walls Unit 1 Containment Class 2 276 14 392 14%

Basement Unit 2 Containment Class 2 276 14 392 14%

Basement SFP/Transfer Canal Class 1 780 28 780 100%

Turbine Building Class 3 147 14 392 3%

Basement Crib House/Forebay Class 3 69 14 392 6%

Circulating Water Class 3 49 14 392 8%

Discharge Tunnels WWTF Class 3 11 14 392 35%

Note: 1) The minimum number of ISOCS measurements is based on a measurement FOV of 28 m2.

Page 33 of 46

ZS-LT-300-001-001 Attachment 7 Revision 2 Sample & Measurement Unique Identification Designation Information Use (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17)

Classification & Survey Area Survey Unit Number & Survey and Surface Type Sample or Measurement No. Media Type Sequence Indicator Measurement Type 1st digit indicates type of Survey Area 6 and 7th digits indicates th The 9th digit indicate The 11th digit indicates The 13th, 14th and 15th digits The 16th and 17th Survey Unit Number the type of survey. the type of surface indicate the alphanumeric digits indicate the L = Open Land Area where the type of media that B = Structural Survey Area (from Tables 6-1 and 6-2) A = Assessment measurement number B = Background measurement was was sampled.

S = System taken. Sequentially, 001 through 999 The 8th digit indicate S = Scoping SS = Surface Soil 2nd digit indicates Classification C = Characterization F = Floor SB = Subsurface alphanumeric sequence 1 = Class 1 R = Remedial Action W = Wall Soil 2 = Class 2 (Sequence A-J) allows the F = FRS C = Ceiling SM = Sediment 3 = Class 3 survey unit to be divided into I = Investigation S = System WT = Water 4 = Non-impacted 10 smaller survey units. V = Verification R = Roof LQ = Other liquids 5 = Unassigned (Sequence K-Z) allows for up Q = QA/QC P = Paved Road besides water 3rd, 4th and 5th digits indicates Survey Area Number to 16 different survey A G = Ground OL = Oil

[The Survey Area Number, Survey Unit Number and current classification are instructions for a single survey The 10th digit L = Water CV = Volumetric taken from the updated master copy of Survey Units for Open Land Areas unit. indicates the type of The 12th digit indicates Concrete and Survey Units for Structures that are maintained by the Characterization/License Termination Manager in accordance with procedure measurement. the material AV = Volumetric ZS-LT-300-001-002, Survey Unit Classification (Reference 6.9)]

composition of the Asphalt B = Background MT = Metal R = Random surface where the measurement was PT = Paint S = Systematic SW = Smear Sample J = Biased taken.

BD = Beta Direct I = Investigation C = Concrete AD = Alpha Direct V = Verification M = Metal GD = Static Gamma Q = QA/QC W = Wood measurement B = Cinder Block BS = Beta Scan K = Brick GS = Gamma Scan A = Asphalt JS = Juncture Scan S = Soil JD = Juncture T = Tar Direct L = Liquid PS = Penetration Scan PD = Penetration Direct Page 34 of 46

Attachment 8 ZS-LT-300-001-001 Calculation of Static and Scan MDC Revision 2 Page 1 of 2 Information Use MDC is the minimum activity concentration on a surface or within a material volume, that an instrument is expected to detect (e.g., activity expected to be detected with 95% confidence).

The MDC is dependent upon the counting time, geometry, sample size, detector efficiency and background count rate. For a portable instrument, MDC is calculated using two different methods depending on the mode of operation, static (MDCstatic) or scanning (MDCscan).

Total Efficiency Instrument efficiencies (i) are derived from the surface emission rate of the radioactive source(s) used during the instrument calibration. Total Efficiency (t) is calculated by multiplying the instrument efficiency (i) by the surface efficiency (s) commensurate with the radionuclides alpha or beta energy using the guidance provided in ISO 7503-1, Evaluation of surface contamination - Part 1: Beta-emitters (maximum beta energy greater than 0.15 MeV) and alpha-emitters (Reference 6.13).

Beta-Gamma Scan Measurement MDC The formula used to determine the scanning MDC at the 95% confidence level is:

( 60

)

=

( )(100)

Where, MDCscan = Minimum Detectable Concentration in dpm/100 cm2 d = index of sensitivity (1.38)

I = observation interval (seconds) bi = background counts per observation interval t = total efficiency p = surveyor efficiency (0.5)

A = detector area in cm2 (not to exceed 126 cm2)

The observation interval (i) is considered to be the amount of time required for the detector field of view to pass over the area of concern. This time depends upon the scan speed, the size of the source, and the fraction of the detectors sensitive area that passes over the source. The scan speed is based on one detector window width per second however; other scan speeds may be used. For the Ludlum Model 43-68 gas flow proportional detector, the window width is 8.8 cm resulting in a scan speed of ~3.5 inches per second. The floor monitor detector is the Ludlum Model 43-37 with a window width of 13.35 cm which results in a scan speed of 5.25 inches per second.

Page 35 of 46

Attachment 8 ZS-LT-300-001-001 Calculation of Static and Scan MDC Revision 2 Page 2 of 2 Information Use Direct Beta-Gamma Measurement MDC Direct (static) measurements utilize the following formula:

2.71

+3.29 +

=

100 2 Where, MDCstatic = Minimum Detectable Concentration in dpm/100 cm2 ts = sample count time tb = background count time Rb = background count rate (cpm) t = total efficiency A = detector window area (cm2)

Gamma Scan MDC The gamma scan MDC is discussed in detail in TSD 11-004, Ludlum Model 44-10 Detector Sensitivity (Reference 6.14). This Technical Support Document (TSD) examines the gamma sensitivity for 5.08 by 5.08 cm (2 x 2) NaI detectors to several radionuclide mixtures of Co-60 and Cs-137 using sand (SiO2) as the soil base. The TSD derives the MDC for the radionuclide mixtures at various detector distances and scan speeds. The TSD model uses essentially the same geometry configuration as the model used in MARSSIM. TSD 11-004 provides MDC values for the expected ZSRP soil mixture based on detector background condition, scan speed, soil depth (15 cm), soil density (1.6 g/cm3) and detector distance to the suspect surface.

Page 36 of 46

Attachment 9 ZS-LT-300-001-001 Number of Samples Required for the Sign Test Revision 2 Information Use 0.05 0.01 0.025 0.05 0.10 0.25 0.1 2984 2459 2048 1620 1018 0.2 754 622 518 410 258 0.3 341 281 234 185 117 0.4 197 162 136 107 68 0.5 130 107 89 71 45 0.6 94 77 65 52 33 0.7 72 59 50 40 26 0.8 58 48 40 32 21 0.9 48 40 34 27 17 1.0 41 34 29 23 15 1.1 36 30 26 21 14 1.2 33 27 23 18 12 1.3 30 24 21 17 11 1.4 28 23 20 16 10 1.5 27 22 18 15 10 1.6 24 21 17 14 9 1.7 24 20 17 14 9 1.8 23 20 16 12 9 1.9 22 18 16 12 9 2.0 22 18 15 12 8 2.5 21 17 15 11 8 3.0 20 17 14 11 8 Page 37 of 46

Attachment 10 ZS-LT-300-001-001 Number of Samples Required for the WRS Test Revision 2 Information Use Page 38 of 46

ZS-LT-300-001-001 Attachment 11 Revision 2 FRS Sample Plan Cover Sheet Information Use GENERAL SECTION Survey Area No.: Survey Unit No.:

Survey Unit Name:

Survey Unit Type:

- Open Land - Structural Interior - Structural Exterior - System Classification: - Class 3 - Class 2 - Class 1 PREPARATION FOR FINAL STATUS SURVEY ACTIVITIES (a checked box signifies an affirmative response)

Reference Grid and/or Reference Coordinates have been established (if appropriate).

A walk-down has been performed of the survey unit and a completed Pre-Turnover Walk-Down form completed in accordance with ZS-LT-300-001-003, Isolation and Control for Final Radiation Survey is included with this Sample Plan.

Area Turnover and Control Checklist completed in accordance with ZS-LT-300-001-003, Isolation and Control for Final Radiation Survey is included with this Sample Plan and all items and issues that were identified have been resolved.

All preparation activities (clear vegetation, erect scaffolding, etc.) necessary to perform Final Radiation Surveys have been completed.

Area has been cleared of all non-essential materials and equipment.

Area has been posted and access control measures have been implemented.

ALL ABOVE ACTIONS ARE COMPLETE AND SURVEY UNIT IS PREPARED AND READY FOR FRS ACTIVITIES (signature signifies affirmative response)

Radiological Engineer (Print Name/Signature) Date SURVEY PACKAGE APPROVAL THIS SAMPLE PLAN HAS BEEN COMPLETED, INDEPENDENTLY REVIEWED AND APPROVED FOR IMPLEMENTATION.

Prepared: Date:

(Print Name) (signature)

Peer Review: Date:

(Print Name) (signature)

Approved: Date:

Characterization/License Termination Manager (signature)

(Print Name)

Page 39 of 46

Attachment 12 ZS-LT-300-001-001 FRS Data Quality Objectives and Survey Design Revision 2 Page __ of __ Information Use Survey Unit No: ________________________

DATA QUALITY OBJECTIVES 1.0 STATE THE PROBLEM The problem:

Stakeholders:

The Planning Team:

Schedule:

Resources:

2.0 IDENTIFY THE DECISION Principal Study Question:

Alternate Actions:

The Decision:

3.0 IDENTIFY INPUTS TO THE DECISION Information Needed:

Historical Information:

Radionuclides of Concern:

Release Criteria:

Radiological Survey Data:

Basis for the Action Level:

Basis for Scan Measurements:

Basis for Quality Control (QC) Measurements:

Investigation Levels:

Sampling and Analysis Methods to Meet the Data Requirements:

4.0 DEFINE THE BOUNDARIES OF THE SURVEY Boundaries of the Survey:

Temporal boundaries:

Constraints:

5.0 DEVELOP A DECISION RULE Decision Rule:

6.0 SPECIFY TOLERABLE LIMITS ON DECISION ERRORS The Null Hypothesis:

Page 40 of 46

Attachment 12 ZS-LT-300-001-001 FRS Data Quality Objectives and Survey Design Revision 2 Page __ of __ Information Use Type I Error:

Type II Error:

Lower Bound of the Grey Region 7.0 OPTIMIZE DESIGN Type of statistical test:

Wilcoxon Rank Sum Test (WRS) Sign Test Basis including background reference location if WRS test is specified:

Number of Systematic samples:

Number of Biased samples and locations:

Number of samples for Quality Control:

Page 41 of 46

Attachment 13 ZS-LT-300-001-001 FRS Survey Instructions Revision 2 Page ___ of ___ Information Use Survey Area No.:

Description:

Survey Unit No.:

Description:

Survey Unit Type:

- Open Land - Structure Interior - Structure Exterior - System Survey Unit Classification:

Classification: - Class 3 - Class 2 - Class 1 General Instructions:

1. Personnel will follow all relevant safety directives and procedures while performing this work.
2. Survey and sampling will be performed by qualified technicians under the direction of Characterization/FSS Supervision.
3. Instrumentation used in the field will be used in accordance with applicable procedures.
4. Detailed field notes and observations will be documented during survey and sampling.
5. Photographs should be taken as necessary to clarify survey and sampling activities or survey constraints.
6. Samples will be controlled under Chain-of-Custody in accordance with procedure ZS-WM-131, Chain-Of-Custody.
7. Documents generated during the performance of survey and sampling will be complete and legible.

Corrections will be made using a single line-out followed by an initial and date.

8. Sample & measurement locations will be identified using coordinates consistent with the established reference coordinate system. Sample and measurement locations will be identified by marks or flags prior to and during survey implementation.

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Attachment 13 ZS-LT-300-001-001 FRS Survey Instructions Revision 2 Page ___ of ___ Information Use Survey Area No..:

Description:

Survey Unit No.:

Description:

Specific Instructions:

1. Proceed to the survey unit.
2. Initialize and utilize a Field Log document.

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Attachment 14 ZS-LT-300-001-001 FRS Field Log Revision 2 Page ___ of ___ Information Use Survey Area No.:

Description:

Survey Unit No.:

Description:

Field Log: Date:_________

Time: Observation or Comment: Technician Page 44 of 46

Attachment 15 ZS-LT-300-001-001 FRS Samples/Measurement Identification & Coordinates Revision 2 Page ___ of ___ Information Use Survey Area No.:

Description:

Survey Unit No.:

Description:

No. Type Media Sample/Measurement ID Number Northing Easting Type: B = Background, R = Random, S = Systematic, J = Biased, I = Investigation, V = Verification, Q = QA/QC Media: SS = Surface Soil, SB = Subsurface Soil, SM = Sediment, WT = Water, CV = Volumetric Concrete, AV = Volumetric Asphalt, MT = Metal, PT = Paint, SW = Smear, TB = Direct Beta-gamma Measurement, TA = Direct Alpha Measurement, GM = Static Gamma Measurement Page 45 of 46

Attachment 16 ZS-LT-300-001-001 FRS Scan Area Identification & Coordinates Revision 2 Page ___ of ___ Information Use Survey Area No.:

Description:

Survey Unit No.:

Description:

Coordinates Surface % of Total Scan Area Area Survey Corner 1 Corner 2 Corner 3 Corner 4 No.:

(m2) Unit Area Northing Easting Northing Easting Northing Easting Northing Easting Page 46 of 46