ML18124A056
| ML18124A056 | |
| Person / Time | |
|---|---|
| Site: | 07000036 |
| Issue date: | 05/02/2018 |
| From: | Pallagi K Westinghouse |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| HEM-18-14 | |
| Download: ML18124A056 (8) | |
Text
Westinghouse Non-Proprietary Class 3 (8 Westinghouse ATTN: Document Control Desk Director, Office of Federal and State Materials and Environmental Management Programs U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Direct tel:
E-mail:
Our ref:
Date:
Westinghouse Electric Company LLC Hematite Decommissioning Project 3300 State Road P Festus, MO 63028 USA 314-810-3353 pallagke@westinghouse.com HEM-18-14 May 2, 2018
Subject:
Westinghouse Hematite Decommissioning Project - Submittal of Errata Pages for 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)
Reference 1) Westinghouse (Pallagi) Letter to NRC (Document Control Desk), HEM-17-25, dated April 3, 2017, "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" The purpose of this letter is to provide to the U.S. Nuclear Regulatory Commission (NRC) Errata pages for Final Status Survey Final Report (FSSFR) Volume 3, Chapter 12, Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02, Revision O (LSA 08-01 and LSA 08-02).
Via email on April 30, 2018, the NRC indicated that during the review of FSSFR Volume 3, Chapter 12, as submitted to the NRC (Reference 1), it appeared that Figure 6-3 for LSA 08-01 may have been drawn incorrectly. Westinghouse reviewed the figure and agrees that the figure was drawn incorrectly. Westinghouse has corrected Figure 6-3 and the associated text. contains the errata pages (page 31 of 78 and page 32 of 78) for Final Status Survey Final Report (FSSFR) Volume 3, Chapter 12, Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02, Revision 0. contains the errata pages (page 31 of 78 and page 32 of 78) for Final Status Survey Final Report (FSSFR) Volume 3, Chapter 12, Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02, Revision 0, in track change for ease of review.
Please contact me at 314-810-3353, should you have questions or need additional information.
© 2018 Westinghouse Electric Company LLC All Rights Reserved
HEM-18-14 May 2, 2018 Page 2 of2 Sincerely, Kenneth E. Pallagi Licensing Manager, Hematite Decommissioning Project
Attachment:
- 1) Errata Pages (page 31 of 78 and page 32 of 78) for Final Status Survey Final Report (FSSFR) Volume 3, Chapter 12, Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02, Revision 0
- 2) Errata Pages (page 31 of 78 and page 32 of 78) for Final Status Survey Final Report (FSSFR) Volume 3, Chapter 12, Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02, Revision 0, Track Change Version cc:
V. J. Kelmeckis, Westinghouse S. S. Koenick, NRC/DUWP/MDB J. A. Smith, NRC/DUWP/MDB
Attachment l to HEM-18-14 May 2, 2018 Final Status Survey Final Report Volume 3, Chapter 12 Errata Pages (page 31 of 78 and page 32 of 78) for Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02, Revision 0 Westinghouse Electric Company LLC, Hematite Decommissioning Project Docket No. 070-00036
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 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 estimated by using the nearest "clean" 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 rnrem/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 was placed in order to completely encompass the location of the surrounding "clean" biased 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 FSSFR Volume 3, Chapter 12: Survey Area Release Record for Land Survey Area 08, Surve Units OJ and 02 (LSA 08-01 and LSA 08-02)
Revision: 0 Page 32 of 78 Figure 6-3 EMC Investigation Area within LSA 08-01 LSA 08-01 EMC Area and Tc-99 Sample Locations LOS-01-03-T-E-S-OO u,,,,,_,,_,_,_,,.,y LOS-01-06-T-E-S-00
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LOS-01-06-T-E-Q-OO LOS-01-05-T-E-S-OO ~
LOS-01-10-T-E-S-OO~
LOS-01-09-T-E-S-OO/-L
(
08-01 LOS-01 T-E-S-OO /
LOB-01 T-E-S-OO ~
t; LDB-01-15-T-E-S-OO V N
LDB-01-17-T-E-S-OO
+
LDB-01-18-T-E-S-OO 0 5 10 20 30 40 Feet LOS-01-19-T-E-S-OO 7.0 FINAL STATUS SURVEY RESULTS LSA 08-01 7.1 Gamma Walkover Survey LOB-01-01-T-E-S-OO LDB-01-04-T-E-S-00
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CO>-O>OHHOC
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coo-0,-00-,.,_
LOS-01-12-T-E-S-OO LOS-01 T-E-S-OO 08-02 Sample Above the DCGL Sample Below the DCGL LSA 08-01 Sys. Sample Locations Post-processed OPS coordinate data is accurate to within +/- 0.1 m for the handheld OPS models used during the OWS. The OWS maps are plotted and presented in a 2-D format.
When multiple data points are collected at the same OPS 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).
OWS 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, OWS 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 O WS data set.
to HEM-18-14 May 2, 2018 Final Status Survey Final Report Volume 3, Chapter 12 Errata Pages (page 31 of 78 and page 32 of 78) for Survey Area Release Record for Land Survey Area 08, Survey Units 01 and 02, Revision 0, Track Change Version Westinghouse Electric Company LLC, Hematite Decommissioning Project Docket No. 070-00036
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 j Page 31 of 78 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 estimated by using the nearest "clean" I 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 rnrern/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 onwas placed in order to completely encompass I the location of the surrounding systematic "clean" biased 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 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 Page 32 of 78 Figure 6-3 EMC Investigation Area within LSA 08-01
'~~.7 ~ LSA ~8-01 EMC Area and Tc-99 Sample f
Locations Loe-01-01-r-E-s-oo
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LOS-01-06-T-E-S-OO
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LOB-01-06-T -E 00 L08-01-05-T-E-S-OO ~
LOB-01-10-T-E-S-OO
/
co~,.o,.,.,a~~
08-01 LOB-01-14-T-E-S-OO /
LOS-01-13-T-E-S-OO "J::------__
z LOS-01 T-E-S-OO V N
LOS-01-17-T-E-S-OO
~
LOS-01 T-E-S-OO T O 5 10 20 30 40 Feet 7.0 FINAL STATUS SURVEY RESULTS LSA 08-01 7.1 Gamma Walkover Survey LOS-01 T-E-S-00
~
co,.o,.o,.,,.s.oo
~
=,,.oo.,.s,.oo LOS-01-12-T-E-S-OO LOS-01 T-E-S-OO 08-02 Sample Above the DCGL Sample Below the DCGL LSA 08-01 Sys. Sample Locations 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 2-0 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.