ML19338B790

Restoration Project Final Status Survey Release Record 00101H, Service Water Supply Header CO-26 and Co-29 Buried Pipe

ML19338B790
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	11/23/2019
From:	Graham J ZionSolutions
To:	Office of Nuclear Material Safety and Safeguards
References
ZS-2019-0101
Download: ML19338B790 (31)

Text

ZION STATION RESTORATION PROJECT FINAL STATUS SURVEY RELEASE RECORD Revision 0 SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H PREPARED BY / DATE: J. Graham 2019-11-23 Radiological Engineer REVIEWED BY / DATE: R. F. Yetter III 2019-11-23 Radiological Engineer APPROVED BY / DATE: D. Wojtkowiak 2019-11-23 C/LT Manager

[2]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H TABLE OF CONTENTS

1. EXECUTIVE

SUMMARY

.................................................................................................... 6

2. SURVEY UNIT DESCRIPTION ......................................................................................... 7

3. CLASSIFICATION BASIS ................................................................................................... 7

4. DATA QUALITY OBJECTIVES ........................................................................................ 7

5. SURVEY DESIGN ............................................................................................................... 10

6. SURVEY IMPLEMENTATION ........................................................................................ 12

7. SURVEY RESULTS ............................................................................................................ 13

8. QUALITY CONTROL ........................................................................................................ 16

9. INVESTIGATIONS AND RESULTS ................................................................................ 16

10. REMEDIATION AND RESULTS ..................................................................................... 16

11. CHANGES FROM THE SURVEY PLAN ........................................................................ 16

12. DATA QUALITY ASSESSMENT ..................................................................................... 16

13. ANOMALIES ....................................................................................................................... 16

14. CONCLUSION..................................................................................................................... 16

15. REFERENCES ..................................................................................................................... 17

16. ATTACHMENTS ................................................................................................................ 18 ATTACHMENT 1 - FIGURE 1 ............................................................................................... 19 ATTACHMENT 2 - MEASUREMENT DATA ........................................................................... 21 ATTACHMENT 3 - SIGN TEST ............................................................................................. 27 ATTACHMENT 4 - QC DATA .............................................................................................. 30

[3]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H LIST OF TABLES Table 1 - Dose Significant Radionuclides and Mixture ......................................................................................... 9 Table 2 - Base Case and Operational DCGLs for Buried Pipe ............................................................................ 10 Table 3 - Surrogate Ratios ................................................................................................................................... 10 Table 4 - Surrogate Base Case and Operational DCGLs ..................................................................................... 10 Table 5 - Synopsis of Survey Design ................................................................................................................... 12 Table 6 - Service Water Supply Header - Statistical Quantities - Systematic Measurement Population ............ 15 LIST OF ACRONYMS AND ABBREVIATIONS ALARA As Low As Reasonably Achievable AMCG Average Member of the Critical Group BcDCGL Base Case Derived Concentration Guideline Level BcSOF Base Case Sum of Fractions DQO Data Quality Objective DCGL Derived Concentration Guideline Level EMC Elevated Measurement Comparison FOV Field of View FSS Final Status Survey HTD Hard-to-Detect ID Internal Diameter LTP License Termination Plan MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MDC Minimum Detectable Concentration NaI Sodium Iodide OpDCGL Operational Derived Concentration Guideline Level OpSOF Operational Sum of Fractions OD Outside Diameter QAPP Quality Assurance Project Plan

[4]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H QC Quality Control ROC Radionuclides of Concern SOF Sum of Fractions TEDE Total Effective Dose Equivalent TSD Technical Support Document UCL Upper Confidence Level ZNPS Zion Nuclear Power Station ZSRP Zion Station Restoration Project

[5]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H

1. EXECUTIVE

SUMMARY

This Final Status Survey (FSS) Release Record for survey unit 00101H, Service Water Supply Header CO-26 and CO-29 Buried Pipe, has been generated for the Zion Station Restoration Project (ZSRP). The release record was developed in accordance with ZionSolutions procedure ZS-LT-300-001-005, Final Status Survey Data Reporting (Reference 1) and satisfies the requirements of Section 5.11 of the Zion Station Restoration Project License Termination Plan (LTP) (Reference 2).

FSS Sample Plan S3-00101AF was developed in accordance with ZionSolutions procedure ZS-LT-300-001-001, Final Status Survey Package Development (Reference 3) the ZSRP LTP, and guidance from NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) (Reference 4).

Following completion of this FSS, the survey unit numbers for the eight (8) buried pipe survey units listed in the Attachment 4, Survey Units for Structures from ZionSolutions procedure ZS-LT-300-001-002, Survey Unit Classification (Reference 5), were changed. The eight (8) different piping systems for survey unit 00101A were changed to 00101A through 00101H to allow for a clear distinction between these pipes in the FSS Database. The Service Water Supply Header piping was given the 00101H survey unit number.

The Service Water Supply Header piping consisted of two (2) lengths of 48-inch Internal Diameter (ID) pipe that were both approximately 208.8 feet in length and transited the soil beneath the Turbine Building basement floor. The piping terminated at the G Wall of the Auxiliary Building at the 548 foot elevation. The piping runs under the Turbine Building.

Figure 1 shows the location of this piping at the G Wall.

FSS was conducted to demonstrate that the concentrations of residual radioactivity are equal to or below site-specific Derived Concentration Guideline Levels (DCGL) corresponding to the dose criterion in 10 CFR 20.1402. The Service Water Supply Header piping (pipe nos. CO-26 and CO-29) was classified as MARSSIM Class 3 in accordance with Attachment F of Technical Support Document (TSD)14-016, Description of Embedded Piping, Penetrations, and Buried Pipe to Remain in Zion End State (Reference 6).

The Service Water Supply Header pipe was surveyed with a Ludlum Model 2350-1 Data Logger paired with a Ludlum Model 44-157 sodium/iodide (NaI) gamma detector. One-minute static measurements were taken to quantify the activity in the pipe. Each measurement had a calculated Field of View (FOV) of 4.45 ft2 (4,134 cm2). Fifty-nine (59) measurements were necessary to provide for 10% areal surface coverage for a Class 3 survey. The total linear feet of pipe in this survey unit was 417.6 feet.

For the FSS of the Service Water Supply Header pipe, one hundred thirty-two (132) measurements were obtained, sixty-six (66) measurements taken in each pipe. All of the

[6]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H readings were below an Operational Sum of Fractions (OpSOF) of 0.5 when compared against the Operational DCGL for buried pipe (OpDCGLBP) with the mean OpSOF result of 0.127.

The mean Base Case SOF (BcSOF), when compared to the Base Case DCGL for buried pipe (BcDCGLBP) was 0.033, which results in the dose calculated for this survey unit of 0.814 mrem/yr.

2. SURVEY UNIT DESCRIPTION The Service Water Supply Header piping consists of 2 sections of 48-inch outside diameter (OD) pipe that are 208.8 feet in length. The piping ends at the G Wall of the Auxiliary Building at 549 foot elevation (See Figure 1). The piping runs under the Turbine Building.

The two 48-inch Service Water Supply Header pipes exit the Auxiliary Building at the 550 foot elevation. The pipes traverse east approximately 10 feet beneath the 560 foot elevation Turbine Building floor and exit the Turbine Building Oil Room wall at the 548 foot elevation. The pipes then traverse 8 feet east and then rise vertically from the 548 foot elevation to the 579 foot elevation. The pipes then continued eastward to the Crib House wall. The horizontal sections traversing from the Turbine Building to the Crib House at the 579 foot elevation were cut and the ends at the Crib House were capped.

3. CLASSIFICATION BASIS Survey unit 00101H was classified as Class 3 in accordance with Attachment F of TSD 14-016 and from information taken from the Zion Station Historical Site Assessment (Reference 7).

During the FSS of the Turbine Building and Crib House basements, radiological surveys were performed in several sections of Service Water Piping associated with the Circulating Water Intake Pipe and Circulating Water Discharge Tunnels. No plant-derived radionuclides were positively identified during the performance of these surveys. Radiological surveys were also performed to support the segmentation and removal of Condensate and Service Water pipe that was connected to the sections of end-state buried pipe. No gross radioactivity greater than background was identified during the scanning performed as part of those surveys.

Based upon completion of Survey Unit Classification Basis for final classification, which included a review of the historical information, the results of the survey data, and completion of a final Survey Unit Classification Worksheet, it was concluded that there was a low probability for the presence of residual radioactivity in these pipes in concentrations greater than 50% of the OpDCGLs, justifying a FSS unit classification of Class 3.

4. DATA QUALITY OBJECTIVES Final Status Survey planning and design hinges on coherence with the Data Quality Objective (DQO) process to ensure, through compliance with explicitly defined inputs and boundaries, that the primary objective of the survey is satisfied. The DQO process is described in the ZSRP

[7]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H LTP in accordance with MARSSIM. The appropriate design for a given survey will be developed using the DQO process as outlined in Appendix D of MARSSIM.

The DQO process incorporated hypothesis testing and probabilistic sampling distributions to control decision errors during data analysis. Hypothesis testing is a process based on the scientific method that compares a baseline condition to an alternate condition. The baseline condition is technically known as the null hypothesis. Hypothesis testing rests on the premise that the null hypothesis is true and that sufficient evidence must be provided for rejection. In designing the survey plan, the underlying assumption, or null hypothesis was that residual activity in the survey unit exceeded the release criteria. Rejection of the null hypothesis would indicate that residual activity within the survey unit does not exceed the release criteria.

Therefore, the survey unit would satisfy the primary objective of the FSS sample plan.

The primary objective of the FSS sample plan is to demonstrate that the level of residual radioactivity in survey unit 00101H did not exceed the release criteria specified in the LTP and that the potential dose from residual radioactivity is As Low As Reasonably Achievable (ALARA).

The residual radioactivity in buried piping located below the 588 foot grade that will remain and be subjected to FSS is discussed in LTP Chapter 2, section 2.3.3.7 and TSD 14-016. The dose assessment methods and resulting DCGLs for buried piping are described in detail in TSD 14-015, Buried Pipe Dose Modeling & DCGLs (Reference 8) and LTP Chapter 6, section 6.12.

ZionSolutions TSD 11-001, Technical Support Document for Potential Radionuclides of Concern During the Decommissioning of the Zion Station (Reference 9) established the basis for an initial suite of potential radionuclides of concern (ROC) for the decommissioning of the Zion Nuclear Power Station (ZNPS). LTP Chapter 2 provides detailed characterization data that described contamination levels in the Containments and Auxiliary Building, which were the primary source of radioactive contaminants. ZionSolutions TSD 14-019, Radionuclides of Concern for Soil and Basement Fill Model Source Terms (Reference 10) evaluates the results of the concrete core analysis data from the Containments and Auxiliary Building and refines the initial suite of potential ROC by evaluating the dose significance of each radionuclide.

The final ROC for the decommissioning of Zion are Co-60, Cs-134 and Cs-137 (as well as Eu-152 and Eu-154 for Containment), which are gamma emitters, and Ni-63 and Sr-90 (as well as H-3 for Containment), which are Hard-to-Detect (HTD) radionuclides. LTP section 5.1 states that HTD concentrations will be inferred using a surrogate approach and the maximum ratios from LTP Chapter 5, Table 5-15 unless area-specific ratios as determined by actual survey data are used in lieu of the maximum ratios.

LTP Chapter 6, section 6.5.2 discusses the process used to derive the ROC for the decommissioning of the ZNPS, including the elimination of insignificant dose contributors

[8]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H from the initial suite consistent with the guidance in Section 3.3 of NUREG-1757. Based upon the analysis of the Auxiliary Building radionuclide mixture in TSD 14-019, Table 19, it was determined that Co-60, Ni-63, Sr-90, Cs-134 and Cs-137 accounted for 99.5% of all dose in the contaminated concrete mixes. Table 1 presents the ROC for the decommissioning of Auxiliary Building structural surfaces and the normalized mixture fractions based on the radionuclide mixture.

Table 1 - Dose Significant Radionuclides and Mixture

% of Total Activity Radionuclide (normalized)(1)

Co-60 0.92%

Cs-134 0.01%

Cs-137 75.32%

Ni-63 23.71%

Sr-90 0.05%

(1) Based on maximum percent of total activity from Table 20 of TSD 14-019, normalized to one for the dose significant radionuclides.

At ZNPS, compliance is demonstrated through the summation of dose from four distinct source terms for the end-state (basements, soils, buried pipe and groundwater). Each radionuclide-specific BcDCGL is equivalent to the level of residual radioactivity (above background levels) that could, when considered independently, result in a Total Effective Dose Equivalent (TEDE) of 25 mrem per year to an Average Member of the Critical Group (AMCG). To ensure that the summation of dose from each source term is 25 mrem/year or less after all FSS is completed, the BcDCGLs are reduced based on an expected, or a priori, fraction of the 25 mrem/year dose limit from each source term. The reduced DCGLs, or Operational DCGLs can be related to the BcDCGLs as an expected fraction of dose based on an a priori assessment of what the expected dose should be based on the results of site characterization, process knowledge and the extent of planned remediation. The OpDCGL is then used as the DCGL for the FSS design of the survey unit (calculation of surrogate DCGLs, investigations levels, etc.). Details of the OpDCGLs derived for each dose component and the basis for the applied a priori dose fractions are provided in ZionSolutions TSD 17-004, Operational Derived Concentration Guideline Levels for Final Status Survey (Reference 11).

The Base Case and Operational DCGLs for Buried Pipe are listed in Tables 5-9 and 5-10 of the LTP, and are reproduced in the Table 2.

[9]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H Table 2 - Base Case and Operational DCGLs for Buried Pipe Base Case Operational Radionuclide Buried Pipe DCGL Buried Pipe DCGL 2

dpm/100cm dpm/100cm2 Co-60 2.64E+04 6.76E+03 Cs-134 4.54E+04 1.16E+04 Cs-137 1.01E+05 2.59E+04 Ni-63 4.89E+07 1.25E+07 Sr-90 4.50E+04 1.15E+04

5. SURVEY DESIGN The level of effort associated with planning a survey is based on the complexity of the survey and nature of the hazards. Guidance for preparing FSS plans is provided in procedure ZS-LT-300-001-001.

The DQO process determined that Co-60, Ni-63, Sr-90, Cs-134 and Cs-137 would be the ROC in survey unit 00101H. During FSS, concentrations for Hard-to-Detect (HTD) ROC Ni-63 and Sr-90 are inferred using a surrogate approach. Cs-137 is the principle surrogate radionuclide for Sr-90 and Co-60 is the principle surrogate radionuclide for Ni-63. The mean, maximum and 95% Upper Confidence Level (UCL) of the surrogate ratios for concrete core samples taken in the Auxiliary Building basement were calculated in ZionSolutions TSD 14-019, and are presented in Table 3. The maximum ratios will be used in the surrogate calculations during this FSS. The results of the surrogate calculations are listed in Table 4.

Table 3 - Surrogate Ratios Auxiliary Building Ratios Mean Max 95%UCL Ni-63/Co-60 44.143 180.450 154.632 Sr-90/Cs-137 0.001 0.002 0.002 Table 4 - Surrogate Base Case and Operational DCGLs Base Case Operational Radionuclide Buried Pipe DCGL Buried Pipe DCGL dpm/100cm2 dpm/100cm2 Co-60 2.41E+04 6.16E+03 Cs-134 4.54E+04 1.16E+04 Cs-137 1.01E+05 2.58E+04

[10]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H An adjusted gross gamma OpDCGL was also calculated by applying the normalized gamma mixture from Table 1 to the surrogate OpDCGL for Co-60, the surrogate OpDCGL for Cs-137 and the OpDCGL for Cs-134 from Table 3. The adjusted gross gamma OpDCGL for buried pipe was 2.49E+04 dpm/100 cm2.

The Service Water Supply Headers are Class 3 buried pipe. Consequently, a minimum of 1%

to 10% areal surface coverage was required. For the survey of pipe internal surfaces, areal coverage is achieved by the area of detection for each static measurement taken. Scanning, in the traditional context, is not applicable to the survey of pipe internal surfaces. For the survey of these pipes, the pipe detector was calibrated for the specific geometry of the 48-inch Service Water pipes. The most likely geometry for activity in this pipe is for the activity to be collected in the bottom of the pipe. To obtain an efficiency for this geometry, a mock-up of the lower half of the inner diameter of this pipe was created. The source was positioned on the bottom of the pipe, which covered 35% of the pipe circumference. The detector was placed on the bottom of the pipe and the calibration readings obtained. This geometry covers a FOV of 4.45 ft2. The internal surface area of each of the pipes is 2,624 ft2; therefore a minimum of 59 measurements per pipe section was required to meet an areal surface coverage of 10%.

The survey design called for the use of a Ludlum Model 44-162 NaI detector. Background was initially not subtracted from the readings. The survey commenced as designed and upon insertion of the Ludlum Model 44-162 into the pipe, the gross activity readings were greater than the Action Level calculated for this pipe. In order to minimize the effect of background on the measurements taken in the pipe, a Ludlum Model 44-10, 2 inch x 2 inch NaI detector was calibrated and windowed to the Cs-137 energy. An efficiency was then derived for this detector in the geometry described above. .

Investigation levels are specified in LTP Chapter 5, section 5.6.4.6, Table 5-25. If a direct measurement for a Class 3 embedded pipe exceeded 50% of the OpDCGL, then an investigation was required. The gross gamma OpDCGL calculated in survey design was 2.49E+04 dpm/100cm2. Since the detector used for this survey was set to detect activity for a single nuclide, Cs-137, a second surrogate calculation was performed, using Cs-137 as the surrogate nuclide for the Cs-134 and Co-60. This calculation resulted in a gross gamma activity of 2.45E+04 dpm/100cm2. 50% of this value is 1.23E+04 dpm/100 cm2. Using the efficiency derived for the Ludlum Model 44-10 detector and assuming a FOV of 4.45 ft2, this equated to approximately 500 gross cpm for the instrument/detector combination described.

This was the Action Level used for the FSS of survey unit no. 00101H.

In compliance with ZS-LT-01, Quality Assurance Project Plan (for Characterization and FSS) (Reference 12), replicate measurements were to be performed on 5% of the static measurement locations. Table 5 provides a synopsis of the survey design for FSS unit no. 00101H.

[11]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H Table 5 - Synopsis of Survey Design FEATURE DESIGN CRITERIA BASIS Survey Unit Area 5,248 ft2 4 ft (ID) x 417.6 ft (length) x Number of Static 59 per pipe 10% areal coverage, Class 3 Measurements Measurement As needed to obtains sufficient 10% areal coverage, Class 3 Spacing measurements for 10% areal coverage

• Co 6.76E+03 dpm/100 cm2

• Cs-134 - 1.16E+04 dpm/100 cm2 OpDCGLs for Buried Pipe, DCGLs

• Cs-137 -2.59E+04 dpm/100 cm2 (LTP Chapter 5, Table 5-10)

• Ni-63 -1.25E+07 dpm/100 cm2

• Sr 1.15E+04 dpm/100 cm2 Gross Gamma DCGL adjusted for HTD HTD ROC Analysis LTP 5.7.1.9 based on the isotopic mixture Measurement

>0.5 Gross Gamma OpDCGL (LTP Chapter 5, Table 5-25)

Investigation Level Scan Survey Area N/A LTP 5.7.1.9 Coverage Replicate measurements will be Quality Control Quality Assurance Project Plan performed on 5% of the static (QC) (QAPP) measurement locations

6. SURVEY IMPLEMENTATION Survey instructions for this FSS were incorporated into and performed in accordance with FSS Sample Plan S3-00101AF, which was developed in accordance with ZionSolutions procedure ZS-LT-300-001-001, Final Status Survey Package Development. The FSS unit was inspected and controlled in accordance with ZionSolutions procedure ZS-LT-300-001-003, Isolation and Control for Final Status Survey (Reference 13).

Inspections of the pipe were performed with a SeeSnake pipe camera prior to the start of the survey. The SeeSnake was inserted into each of the pipes approximately 100 feet. It was decided to limit the survey to this section of the pipe to prevent the detector from being caught on an unseen obstruction further into the pipe.

A background value was determined for the detector/instrument combination to be used prior to deployment. The background value was obtained at the location where the pre-use response check of the instrument was performed. The background value was primarily used to ensure

[12]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H that the detector had not become cross-contaminated by any previous use. Background was not subtracted from any measurement.

Daily, prior to and following use, each detector was subjected to an Operational Response Check in accordance with procedure ZS-LT-300-001-006, Radiation Surveys of Pipe Interiors Using Sodium/Cesium Iodide Detectors (Reference 14). The Daily Operational Response Check compared the background response and the response to check sources ranges established for normal background and detector source response to ensure that the detector was working properly.

Surveys were started on May 4, 2018 with Ludlum Model 2350-1 #266668 coupled with Ludlum Model 44-10 #PR363489, which was calibrated for the Cs-137 window. The detector was inserted using the 3/4 fiber rod. Static measurements were taken at 1-foot intervals for the first 30 feet for each pipe. All readings were below the Action Level.

The surveys were completed on May 7, 2018 with the same instrument/detector combination.

The detector was inserted into each pipe using 10-foot sections of solid steel rod with threaded connectors. Ten (10) sections were used to insert the detector from 30 feet to 100 feet into each pipe. One-minute static measurements were taken at 2-foot intervals as the detector was pulled out of the pipe. A total of 66 measurements were taken in each of the pipes (132 measurements overall). With a FOV of 4.45 ft2, this represents an areal coverage of 587.4 ft2 of area, which equates to 11.2% of the total internal surface area of the pipe of 5,248 ft2.

Daily prior to use (Pre-Test) and daily upon completion of surveys (Post-Test), response checks were performed in accordance with procedure ZS-LT-300-001-006 for each detector and data logger pairing. In addition, the instrument and detector was physically inspected for mechanical damage as part of the response check process. During the FSS, no instances were encountered where the instrument and/or detector failed a pre- or post-response check or were found to be physically damaged during the inspection.

7. SURVEY RESULTS The SOF or unity rule is applied to the data used for the survey planning, data evaluation and statistical tests for basement surfaces since multiple radionuclide-specific measurements will be performed or the concentrations inferred based on known relationships. The application of the unity rule serves to normalize the data to allow for an accurate comparison of the various data measurements to the release criteria. When the unity rule is applied, the DCGLW (used for the nonparametric statistical test) becomes one (1). The BcDCGLB are directly analogous to the DCGLW as defined in MARSSIM. The use and application of the unity rule was performed in accordance with section 4.3.3 of MARSSIM.

As described in LTP Chapter 5, section 5.10.3.2, the Sign Test was used to evaluate the measured residual radioactivity against the dose criterion. The OpSOF for each measurement

[13]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H was used as the sum value for the Sign Test. The Sign Test then demonstrated that the mean activity for each ROC was less than the OpDCGLB at a Type I decision error of 0.05.

For buried pipe, areas of elevated activity were defined as any area identified by measurement (systematic or judgmental) that exceeded the OpDCGL but was less than the BcDCGL. Any area that exceeded the BcDCGL would have required remediation. The OpSOF for a systematic or a judgmental measurement/sample(s) could exceed one without remediation as long as the survey unit passed the Sign Test and the mean OpSOF for the survey unit did not exceed one. Once the survey data set passed the Sign Test (using OpDCGLs), then the mean radionuclide activity (dpm/100cm2) for each ROC from systematic measurements along with any identified elevated areas from systematic and judgmental samples was used with the BcDCGLs to perform a mean BcSOF calculation. The dose from residual radioactivity assigned to the FSS unit is the mean BcSOF multiplied by 25 mrem/yr.

After completion of the FSS measurements in the pipe, the sample plan was reviewed to confirm the completeness of the survey and the survey data was validated in accordance with procedure ZS-LT-300-001-004, Final Status Survey Data Assessment (Reference 15). Data processing includes converting measurement data into reporting units, validating instrument applicability and sensitivity, calculating relevant statistical quantities, and verification that all DQO have been met. In accordance with the procedure, a preliminary Data Assessment was prepared.

Since the survey was performed with a Ludlum Model 44-10 set to the Cs-137 window, the calculated gross gamma value was applied to Cs-137, and the Co-60 and Cs-134 values were inferred based on the isotopic mix from Table 1 normalized to the gamma-emitting ROC. The normalized mix was Cs-137 - 98.78%, Co 1.21%, and Cs-134 - 0.01%. The surrogate ratios for the HTD nuclides listed in Table 5-15 of the LTP (Ni-63/Co-60 of 180.45; Sr-90/Cs-137 of 0.002) were then used to infer representative concentrations for HTD ROC.

The results of the data assessment for the Service Water Supply Header buried pipe are provided in Attachment 2. A statistical summary of the data is presented in Table 6. No observed individual measurement exceeded an OpSOF of 0.5.

The data collected passed the Sign Test. The result of the Sign Test is provided in Attachment 3.

[14]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H Table 6 - Service Water Supply Header - Statistical Quantities - Systematic Measurement Population Individual Measurement Metrics Total Number of Systematic Measurements = 132 Number of Quality Control Measurements = 7 Number of Judgmental/Investigational Measurements = 0 Total Number of Measurements = 139 Mean Systematic Measurement OpSOF = 0.127 Max Individual Systematic Measurement OpSOF = 0.288 Number of Systematic Measurements with OpSOF >0.5 = 0 Statistical Quantities - Systematic Measurement Population MEAN MEDIAN MAX MIN STD. DEV. BcDCGL Avg Dose ROC BcSOF (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) per ROC Gross Gamma 3.11E+03 2.89E+03 7.07E+03 1.15E+03 1.57E+03 N/A N/A N/A Co-60 3.80E+01 3.53E+01 8.64E+01 1.40E+01 1.92E+01 2.64E+04 0.001 0.036 Ni-63 (1) 6.86E+03 6.37E+03 1.56E+04 2.53E+03 3.46E+03 4.89E+07 0.000 0.004 Sr-90 (1) 6.23E+00 5.78E+00 1.41E+01 2.29E+00 3.14E+00 4.50E+04 0.000 0.003 Cs-134 4.13E-01 3.84E-01 9.39E-01 1.52E-01 2.09E-01 4.54E+04 0.000 0.000 Cs-137 3.11E+03 2.89E+03 7.07E+03 1.15E+03 1.57E+03 1.01E+05 0.031 0.771 (1) Concentrations for Ni-63 and Sr-90 are inferred MEAN BcSOF ASSIGNED TO SURVEY UNIT (SYSTEMATIC AVG.) = 0.033 DOSE ASSIGNED TO SURVEY UNIT (SYSTEMATIC AVG.) = 0.814

[15]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H

8. QUALITY CONTROL In compliance with ZS-LT-01, replicate measurements were performed on 5% of the survey locations chosen at random. Seven (7) replicate measurements were taken. Using the acceptance criteria specified in section 4.1.2 of ZS-LT-01, there was acceptable agreement between the replicate readings and the original readings. Refer to Attachment 4 for quality control analysis results.

9. INVESTIGATIONS AND RESULTS As all measurements in the accessible pipe interior surface area were below an OpSOF of 0.5, no investigations were required or performed.

10. REMEDIATION AND RESULTS No remediation was performed in this piping survey unit.

11. CHANGES FROM THE SURVEY PLAN The detector selected for the survey during the survey design (Ludlum Model 44-162) was unable to obtain satisfactory results due to high background readings. A Ludlum Model 44-10 detector was subsequently calibrated for the Cs-137 energy window operating mode and was used to successfully collect the measurements required.

12. DATA QUALITY ASSESSMENT In accordance with procedure ZS-LT-300-001-004, the DQOs, sample design, and data were reviewed for completeness, accuracy, and consistency. Documentation was complete and legible. The FSS unit was properly classified as Class 3. All measurement results were individually reviewed and validated. The number of measurements was sufficient to meet 10%

areal surface coverage of accessible surfaces. The instrumentation used to perform the FSS was in calibration, capable of detecting the activity with an adequate MDC and successfully response checked prior to and following use. An adequate number of replicate measurements were taken and the results meet the acceptance criteria as specified in the QAPP.

13. ANOMALIES No anomalies were observed during the performance or analyses of the survey.

14. CONCLUSION One hundred thirty-two (132) static measurements were taken in the Service Water Supply Header (Pipe nos. CO-26 and CO-29) buried piping. The accessible length of pipe, based on the SeeSnake inspection, was 200 feet. The 132 readings covered 11.5% of the total area of the

[16]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H two (2) pipes; therefore the 10% areal surface coverage requirement for a Class 3 buried pipe was achieved.

All of the measurements taken inside the buried pipe were below an OpSOF of 0.5 when compared to the OpDCGLBP. The average OpSOF for the survey unit was 0.127. The Sign Test was passed, and the Null Hypothesis was rejected. The requirements for a Class 3 survey unit have been met.

The mean BcSOF for this survey unit is 0.033. The dose contribution from survey unit no. 00101H, Service Water Supply Header CO-26 and CO-29 Buried Pipe is 0.814 mrem/yr TEDE, based on the average concentration of the ROC in samples used for non-parametric statistical sampling.

Survey unit no. 00101H, Service Water Supply Header CO-26 and CO-29 Buried Pipe is acceptable for unrestricted release.

15. REFERENCES

1. ZionSolutions procedure ZS-LT-300-001-005, Final Status Survey Data Reporting

2. Zion Station Restoration Project License Termination Plan

3. ZionSolutions procedure ZS-LT-300-001-001, Final Status Survey Package Development

4. NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual

5. ZionSolutions procedure ZS-LT-300-001-002, Survey Unit Classification

6. ZionSolutions TSD 14-016, Description of Embedded Piping, Penetrations, and Buried Pipe to Remain in Zion End State

7. Zion Station Historical Site Assessment

8. ZionSolutions TSD 14-015, Buried Pipe Dose Modeling and DCGLs

9. TSD 11-001, Technical Support Document for Potential Radionuclides of Concern During the Decommissioning of the Zion Station

10. ZionSolutions TSD 14-019, Radionuclides of Concern for Soil and Basement Fill Model Source Terms

11. TSD 17-004 Operational Derived Concentration Guideline Levels for Final Status Survey

12. ZionSolutions procedure ZS-LT-01, Quality Assurance Project Plan (for Characterization and FSS)

[17]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H

13. ZionSolutions procedure ZS-LT-300-001-003, Isolation and Control for Final Status Survey

14. ZionSolutions procedure ZS-LT-300-001-006, Radiation Surveys of Pipe Interiors Using Sodium/Cesium Iodide Detectors

15. ZionSolutions procedure ZS-LT-300-001-004, Final Status Survey Data Assessment

16. ATTACHMENTS

1. Attachment 1 - Figure 1

2. Attachment 2 - Measurement Data

3. Attachment 3 - Sign Test

4. Attachment 4 - QC Data

[18]

ATTACHMENT 1 FIGURE 1

[19]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H FIGURE 1

[20]

ATTACHMENT 2 MEASUREMENT DATA

[21]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H Measurement Results CO-26 and CO-29 Service Water Supply Header Pipe Survey FEET INTO GROSS PIPE Co-60 Ni-63 Sr-90 Cs-134 Cs-137 OpSOF PIPE GAMMA 2 2 2 2 2 (dpm/100cm ) (dpm/100cm ) (dpm/100cm ) (dpm/100cm ) (dpm/100cm ) (dpm/100cm2)

CO-26 102 2.58E+03 3.16E+01 5.70E+03 5.17E+00 3.43E-01 2.58E+03 0.105 CO-26 100 2.44E+03 2.98E+01 5.37E+03 4.88E+00 3.24E-01 2.44E+03 0.099 CO-26 98 2.54E+03 3.10E+01 5.59E+03 5.07E+00 3.37E-01 2.54E+03 0.103 CO-26 96 3.49E+03 4.26E+01 7.68E+03 6.97E+00 4.63E-01 3.49E+03 0.142 CO-26 94 2.58E+03 3.16E+01 5.70E+03 5.17E+00 3.43E-01 2.58E+03 0.105 CO-26 92 3.17E+03 3.87E+01 6.99E+03 6.34E+00 4.21E-01 3.17E+03 0.129 CO-26 90 2.93E+03 3.57E+01 6.45E+03 5.85E+00 3.88E-01 2.93E+03 0.119 CO-26 88 3.24E+03 3.96E+01 7.15E+03 6.49E+00 4.31E-01 3.24E+03 0.132 CO-26 86 3.17E+03 3.87E+01 6.99E+03 6.34E+00 4.21E-01 3.17E+03 0.129 CO-26 84 3.71E+03 4.53E+01 8.17E+03 7.41E+00 4.92E-01 3.71E+03 0.151 CO-26 82 3.41E+03 4.17E+01 7.52E+03 6.83E+00 4.53E-01 3.41E+03 0.139 CO-26 80 3.61E+03 4.41E+01 7.95E+03 7.22E+00 4.79E-01 3.61E+03 0.147 CO-26 78 4.36E+03 5.33E+01 9.62E+03 8.73E+00 5.79E-01 4.36E+03 0.178 CO-26 76 3.54E+03 4.32E+01 7.79E+03 7.07E+00 4.69E-01 3.54E+03 0.144 CO-26 74 3.80E+03 4.65E+01 8.38E+03 7.61E+00 5.05E-01 3.80E+03 0.155 CO-26 72 4.39E+03 5.36E+01 9.67E+03 8.78E+00 5.83E-01 4.39E+03 0.179 CO-26 70 3.83E+03 4.68E+01 8.44E+03 7.66E+00 5.08E-01 3.83E+03 0.156 CO-26 68 5.12E+03 6.25E+01 1.13E+04 1.02E+01 6.80E-01 5.12E+03 0.209 CO-26 66 4.24E+03 5.18E+01 9.35E+03 8.48E+00 5.63E-01 4.24E+03 0.173 CO-26 64 3.78E+03 4.62E+01 8.33E+03 7.56E+00 5.02E-01 3.78E+03 0.154 CO-26 62 4.58E+03 5.60E+01 1.01E+04 9.17E+00 6.09E-01 4.58E+03 0.187 CO-26 60 4.75E+03 5.81E+01 1.05E+04 9.51E+00 6.31E-01 4.75E+03 0.194 CO-26 58 4.85E+03 5.93E+01 1.07E+04 9.70E+00 6.44E-01 4.85E+03 0.198 CO-26 56 5.78E+03 7.06E+01 1.27E+04 1.16E+01 7.67E-01 5.78E+03 0.236 CO-26 54 5.27E+03 6.43E+01 1.16E+04 1.05E+01 6.99E-01 5.27E+03 0.215 CO-26 52 4.71E+03 5.75E+01 1.04E+04 9.41E+00 6.25E-01 4.71E+03 0.192

[22]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H Measurement Results CO-26 and CO-29 Service Water Supply Header Pipe Survey (continued)

FEET INTO GROSS PIPE Co-60 Ni-63 Sr-90 Cs-134 Cs-137 OpSOF PIPE GAMMA (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2)

CO-26 50 3.80E+03 4.65E+01 8.38E+03 7.61E+00 5.05E-01 3.80E+03 0.155 CO-26 48 4.58E+03 5.60E+01 1.01E+04 9.17E+00 6.09E-01 4.58E+03 0.187 CO-26 46 5.02E+03 6.13E+01 1.11E+04 1.00E+01 6.67E-01 5.02E+03 0.205 CO-26 44 6.36E+03 7.77E+01 1.40E+04 1.27E+01 8.45E-01 6.36E+03 0.259 CO-26 42 4.41E+03 5.39E+01 9.73E+03 8.83E+00 5.86E-01 4.41E+03 0.180 CO-26 40 5.53E+03 6.76E+01 1.22E+04 1.11E+01 7.35E-01 5.53E+03 0.226 CO-26 38 5.53E+03 6.76E+01 1.22E+04 1.11E+01 7.35E-01 5.53E+03 0.226 CO-26 36 5.39E+03 6.58E+01 1.19E+04 1.08E+01 7.15E-01 5.39E+03 0.220 CO-26 34 6.19E+03 7.56E+01 1.36E+04 1.24E+01 8.22E-01 6.19E+03 0.253 CO-26 32 5.80E+03 7.09E+01 1.28E+04 1.16E+01 7.70E-01 5.80E+03 0.237 CO-26 30 5.95E+03 7.27E+01 1.31E+04 1.19E+01 7.90E-01 5.95E+03 0.243 CO-26 29 5.51E+03 6.73E+01 1.21E+04 1.10E+01 7.32E-01 5.51E+03 0.225 CO-26 28 3.75E+03 4.59E+01 8.28E+03 7.51E+00 4.98E-01 3.75E+03 0.153 CO-26 27 2.73E+03 3.34E+01 6.02E+03 5.46E+00 3.63E-01 2.73E+03 0.111 CO-26 26 1.80E+03 2.20E+01 3.98E+03 3.61E+00 2.40E-01 1.80E+03 0.074 CO-26 25 1.37E+03 1.67E+01 3.01E+03 2.73E+00 1.81E-01 1.37E+03 0.056 CO-26 24 1.51E+03 1.85E+01 3.33E+03 3.02E+00 2.01E-01 1.51E+03 0.062 CO-26 23 1.39E+03 1.70E+01 3.06E+03 2.78E+00 1.85E-01 1.39E+03 0.057 CO-26 22 1.73E+03 2.11E+01 3.82E+03 3.46E+00 2.30E-01 1.73E+03 0.071 CO-26 21 1.51E+03 1.85E+01 3.33E+03 3.02E+00 2.01E-01 1.51E+03 0.062 CO-26 20 1.32E+03 1.61E+01 2.90E+03 2.63E+00 1.75E-01 1.32E+03 0.054 CO-26 19 1.90E+03 2.32E+01 4.19E+03 3.80E+00 2.52E-01 1.90E+03 0.078 CO-26 18 1.56E+03 1.91E+01 3.44E+03 3.12E+00 2.07E-01 1.56E+03 0.064 CO-26 17 1.71E+03 2.08E+01 3.76E+03 3.41E+00 2.27E-01 1.71E+03 0.070 CO-26 16 1.54E+03 1.88E+01 3.39E+03 3.07E+00 2.04E-01 1.54E+03 0.063 CO-26 15 1.76E+03 2.14E+01 3.87E+03 3.51E+00 2.33E-01 1.76E+03 0.072

[23]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H Measurement Results CO-26 and CO-29 Service Water Supply Header Pipe Survey (continued)

FEET INTO GROSS PIPE Co-60 Ni-63 Sr-90 Cs-134 Cs-137 OpSOF PIPE GAMMA (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2)

CO-26 14 1.37E+03 1.67E+01 3.01E+03 2.73E+00 1.81E-01 1.37E+03 0.056 CO-26 13 1.71E+03 2.08E+01 3.76E+03 3.41E+00 2.27E-01 1.71E+03 0.070 CO-26 12 1.34E+03 1.64E+01 2.96E+03 2.68E+00 1.78E-01 1.34E+03 0.055 CO-26 11 1.73E+03 2.11E+01 3.82E+03 3.46E+00 2.30E-01 1.73E+03 0.071 CO-26 10 1.54E+03 1.88E+01 3.39E+03 3.07E+00 2.04E-01 1.54E+03 0.063 CO-26 9 1.71E+03 2.08E+01 3.76E+03 3.41E+00 2.27E-01 1.71E+03 0.070 CO-26 8 1.76E+03 2.14E+01 3.87E+03 3.51E+00 2.33E-01 1.76E+03 0.072 CO-26 7 1.63E+03 2.00E+01 3.60E+03 3.27E+00 2.17E-01 1.63E+03 0.067 CO-26 6 1.90E+03 2.32E+01 4.19E+03 3.80E+00 2.52E-01 1.90E+03 0.078 CO-26 5 1.88E+03 2.29E+01 4.14E+03 3.75E+00 2.49E-01 1.88E+03 0.077 CO-26 4 2.17E+03 2.65E+01 4.78E+03 4.34E+00 2.88E-01 2.17E+03 0.088 CO-26 3 2.51E+03 3.07E+01 5.53E+03 5.02E+00 3.33E-01 2.51E+03 0.102 CO-26 2 2.66E+03 3.25E+01 5.86E+03 5.31E+00 3.53E-01 2.66E+03 0.108 CO-26 1 3.90E+03 4.76E+01 8.60E+03 7.80E+00 5.18E-01 3.90E+03 0.159 CO-29 100 2.78E+03 3.39E+01 6.13E+03 5.56E+00 3.69E-01 2.78E+03 0.113 CO-29 98 2.85E+03 3.48E+01 6.29E+03 5.70E+00 3.79E-01 2.85E+03 0.116 CO-29 96 3.22E+03 3.93E+01 7.09E+03 6.44E+00 4.27E-01 3.22E+03 0.131 CO-29 94 2.73E+03 3.34E+01 6.02E+03 5.46E+00 3.63E-01 2.73E+03 0.111 CO-29 92 3.68E+03 4.50E+01 8.11E+03 7.36E+00 4.89E-01 3.68E+03 0.150 CO-29 90 3.29E+03 4.02E+01 7.25E+03 6.58E+00 4.37E-01 3.29E+03 0.134 CO-29 88 3.75E+03 4.59E+01 8.28E+03 7.51E+00 4.98E-01 3.75E+03 0.153 CO-29 86 3.56E+03 4.35E+01 7.85E+03 7.12E+00 4.73E-01 3.56E+03 0.145 CO-29 84 3.54E+03 4.32E+01 7.79E+03 7.07E+00 4.69E-01 3.54E+03 0.144 CO-29 82 3.85E+03 4.71E+01 8.49E+03 7.70E+00 5.11E-01 3.85E+03 0.157 CO-29 80 4.07E+03 4.97E+01 8.97E+03 8.14E+00 5.41E-01 4.07E+03 0.166 CO-29 78 5.17E+03 6.31E+01 1.14E+04 1.03E+01 6.86E-01 5.17E+03 0.211 CO-29 76 3.41E+03 4.17E+01 7.52E+03 6.83E+00 4.53E-01 3.41E+03 0.139

[24]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H Measurement Results CO-26 and CO-29 Service Water Supply Header Pipe Survey (continued)

FEET INTO GROSS PIPE Co-60 Ni-63 Sr-90 Cs-134 Cs-137 OpSOF PIPE GAMMA (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2)

CO-29 74 4.22E+03 5.15E+01 9.30E+03 8.44E+00 5.60E-01 4.22E+03 0.172 CO-29 72 4.24E+03 5.18E+01 9.35E+03 8.48E+00 5.63E-01 4.24E+03 0.173 CO-29 70 4.10E+03 5.00E+01 9.03E+03 8.19E+00 5.44E-01 4.10E+03 0.167 CO-29 68 3.85E+03 4.71E+01 8.49E+03 7.70E+00 5.11E-01 3.85E+03 0.157 CO-29 66 3.66E+03 4.47E+01 8.06E+03 7.31E+00 4.86E-01 3.66E+03 0.149 CO-29 64 4.02E+03 4.91E+01 8.87E+03 8.05E+00 5.34E-01 4.02E+03 0.164 CO-29 62 4.05E+03 4.94E+01 8.92E+03 8.09E+00 5.37E-01 4.05E+03 0.165 CO-29 60 4.17E+03 5.09E+01 9.19E+03 8.34E+00 5.54E-01 4.17E+03 0.170 CO-29 58 4.83E+03 5.90E+01 1.06E+04 9.65E+00 6.41E-01 4.83E+03 0.197 CO-29 56 4.12E+03 5.03E+01 9.08E+03 8.24E+00 5.47E-01 4.12E+03 0.168 CO-29 54 4.71E+03 5.75E+01 1.04E+04 9.41E+00 6.25E-01 4.71E+03 0.192 CO-29 52 5.19E+03 6.34E+01 1.14E+04 1.04E+01 6.89E-01 5.19E+03 0.212 CO-29 50 4.36E+03 5.33E+01 9.62E+03 8.73E+00 5.79E-01 4.36E+03 0.178 CO-29 48 4.73E+03 5.78E+01 1.04E+04 9.46E+00 6.28E-01 4.73E+03 0.193 CO-29 46 6.36E+03 7.77E+01 1.40E+04 1.27E+01 8.45E-01 6.36E+03 0.259 CO-29 44 5.17E+03 6.31E+01 1.14E+04 1.03E+01 6.86E-01 5.17E+03 0.211 CO-29 42 6.09E+03 7.44E+01 1.34E+04 1.22E+01 8.09E-01 6.09E+03 0.249 CO-29 40 6.27E+03 7.65E+01 1.38E+04 1.25E+01 8.32E-01 6.27E+03 0.256 CO-29 38 7.07E+03 8.64E+01 1.56E+04 1.41E+01 9.39E-01 7.07E+03 0.288 CO-29 36 5.63E+03 6.88E+01 1.24E+04 1.13E+01 7.48E-01 5.63E+03 0.230 CO-29 34 2.80E+03 3.42E+01 6.18E+03 5.61E+00 3.72E-01 2.80E+03 0.114 CO-29 32 1.68E+03 2.05E+01 3.71E+03 3.36E+00 2.23E-01 1.68E+03 0.069 CO-29 30 1.49E+03 1.82E+01 3.28E+03 2.97E+00 1.97E-01 1.49E+03 0.061 CO-29 29 1.49E+03 1.82E+01 3.28E+03 2.97E+00 1.97E-01 1.49E+03 0.061 CO-29 28 1.54E+03 1.88E+01 3.39E+03 3.07E+00 2.04E-01 1.54E+03 0.063 CO-29 27 1.61E+03 1.97E+01 3.55E+03 3.22E+00 2.14E-01 1.61E+03 0.066 CO-29 26 1.66E+03 2.02E+01 3.65E+03 3.32E+00 2.20E-01 1.66E+03 0.068

[25]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H Measurement Results CO-26 and CO-29 Service Water Supply Header Pipe Survey (continued)

FEET INTO GROSS PIPE Co-60 Ni-63 Sr-90 Cs-134 Cs-137 OpSOF PIPE GAMMA (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2)

CO-29 25 1.37E+03 1.67E+01 3.01E+03 2.73E+00 1.81E-01 1.37E+03 0.056 CO-29 24 1.46E+03 1.79E+01 3.22E+03 2.93E+00 1.94E-01 1.46E+03 0.060 CO-29 23 1.19E+03 1.46E+01 2.63E+03 2.39E+00 1.59E-01 1.19E+03 0.049 CO-29 22 1.32E+03 1.61E+01 2.90E+03 2.63E+00 1.75E-01 1.32E+03 0.054 CO-29 21 1.22E+03 1.49E+01 2.69E+03 2.44E+00 1.62E-01 1.22E+03 0.050 CO-29 20 1.34E+03 1.64E+01 2.96E+03 2.68E+00 1.78E-01 1.34E+03 0.055 CO-29 19 1.41E+03 1.73E+01 3.12E+03 2.83E+00 1.88E-01 1.41E+03 0.058 CO-29 18 1.19E+03 1.46E+01 2.63E+03 2.39E+00 1.59E-01 1.19E+03 0.049 CO-29 17 1.15E+03 1.40E+01 2.53E+03 2.29E+00 1.52E-01 1.15E+03 0.047 CO-29 16 1.29E+03 1.58E+01 2.85E+03 2.58E+00 1.72E-01 1.29E+03 0.053 CO-29 15 1.56E+03 1.91E+01 3.44E+03 3.12E+00 2.07E-01 1.56E+03 0.064 CO-29 14 1.68E+03 2.05E+01 3.71E+03 3.36E+00 2.23E-01 1.68E+03 0.069 CO-29 13 1.24E+03 1.52E+01 2.74E+03 2.49E+00 1.65E-01 1.24E+03 0.051 CO-29 12 1.24E+03 1.52E+01 2.74E+03 2.49E+00 1.65E-01 1.24E+03 0.051 CO-29 11 1.51E+03 1.85E+01 3.33E+03 3.02E+00 2.01E-01 1.51E+03 0.062 CO-29 10 1.32E+03 1.61E+01 2.90E+03 2.63E+00 1.75E-01 1.32E+03 0.054 CO-29 9 1.44E+03 1.76E+01 3.17E+03 2.88E+00 1.91E-01 1.44E+03 0.059 CO-29 8 1.39E+03 1.70E+01 3.06E+03 2.78E+00 1.85E-01 1.39E+03 0.057 CO-29 7 1.61E+03 1.97E+01 3.55E+03 3.22E+00 2.14E-01 1.61E+03 0.066 CO-29 6 1.56E+03 1.91E+01 3.44E+03 3.12E+00 2.07E-01 1.56E+03 0.064 CO-29 5 2.00E+03 2.44E+01 4.41E+03 4.00E+00 2.65E-01 2.00E+03 0.082 CO-29 4 1.46E+03 1.79E+01 3.22E+03 2.93E+00 1.94E-01 1.46E+03 0.060 CO-29 3 1.46E+03 1.79E+01 3.22E+03 2.93E+00 1.94E-01 1.46E+03 0.060 CO-29 2 1.83E+03 2.23E+01 4.03E+03 3.66E+00 2.43E-01 1.83E+03 0.075 CO-29 1 1.71E+03 2.08E+01 3.76E+03 3.41E+00 2.27E-01 1.71E+03 0.070 CO-29 0 2.73E+03 3.34E+01 6.02E+03 5.46E+00 3.63E-01 2.73E+03 0.111

[26]

ATTACHMENT 3 SIGN TEST

[27]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H Sign Test - Service Water Supply Header Buried Piping Survey Area 00101 Survey Area Service Water Supply Header Survey Unit 00101H Survey Unit Buried Pipe CO-26 and CO-29 Classification 3 Type I Error 0.05 Number of Measurements 132 SOF SOF

1. 1-Ws Sign # 1-Ws Sign (Ws) (Ws) 1 0.105 0.89 +1 67 0.113 0.89 +1 2 0.099 0.90 +1 68 0.116 0.88 +1 3 0.103 0.90 +1 69 0.131 0.87 +1 4 0.142 0.86 +1 70 0.111 0.89 +1 5 0.105 0.89 +1 71 0.150 0.85 +1 6 0.129 0.87 +1 72 0.134 0.87 +1 7 0.119 0.88 +1 73 0.153 0.85 +1 8 0.132 0.87 +1 74 0.145 0.85 +1 9 0.129 0.87 +1 75 0.144 0.86 +1 10 0.151 0.85 +1 76 0.157 0.84 +1 11 0.139 0.86 +1 77 0.166 0.83 +1 12 0.147 0.85 +1 78 0.211 0.79 +1 13 0.178 0.82 +1 79 0.139 0.86 +1 14 0.144 0.86 +1 80 0.172 0.83 +1 15 0.155 0.84 +1 81 0.173 0.83 +1 16 0.179 0.82 +1 82 0.167 0.83 +1 17 0.156 0.84 +1 83 0.157 0.84 +1 18 0.209 0.79 +1 84 0.149 0.85 +1 19 0.173 0.83 +1 85 0.164 0.84 +1 20 0.154 0.85 +1 86 0.165 0.83 +1 21 0.187 0.81 +1 87 0.170 0.83 +1 22 0.194 0.81 +1 88 0.197 0.80 +1 23 0.198 0.80 +1 89 0.168 0.83 +1 24 0.236 0.76 +1 90 0.192 0.81 +1 25 0.215 0.79 +1 91 0.212 0.79 +1 26 0.192 0.81 +1 92 0.178 0.82 +1 27 0.155 0.84 +1 93 0.193 0.81 +1 28 0.187 0.81 +1 94 0.259 0.74 +1 29 0.205 0.80 +1 95 0.211 0.79 +1 30 0.259 0.74 +1 96 0.249 0.75 +1 31 0.180 0.82 +1 97 0.256 0.74 +1 32 0.226 0.77 +1 98 0.288 0.71 +1 33 0.226 0.77 +1 99 0.230 0.77 +1

[28]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H Sign Test - Service Water Supply Header Buried Piping (continued)

SOF SOF

1. 1-Ws Sign # 1-Ws Sign (Ws) (Ws) 34 0.220 0.78 +1 100 0.114 0.89 +1 35 0.253 0.75 +1 101 0.069 0.93 +1 36 0.237 0.76 +1 102 0.061 0.94 +1 37 0.243 0.76 +1 103 0.061 0.94 +1 38 0.225 0.78 +1 104 0.063 0.94 +1 39 0.153 0.85 +1 105 0.066 0.93 +1 40 0.111 0.89 +1 106 0.068 0.93 +1 41 0.074 0.93 +1 107 0.056 0.94 +1 42 0.056 0.94 +1 108 0.060 0.94 +1 43 0.062 0.94 +1 109 0.049 0.95 +1 44 0.057 0.94 +1 110 0.054 0.95 +1 45 0.071 0.93 +1 111 0.050 0.95 +1 46 0.062 0.94 +1 112 0.055 0.95 +1 47 0.054 0.95 +1 113 0.058 0.94 +1 48 0.078 0.92 +1 114 0.049 0.95 +1 49 0.064 0.94 +1 115 0.047 0.95 +1 50 0.070 0.93 +1 116 0.053 0.95 +1 51 0.063 0.94 +1 117 0.064 0.94 +1 52 0.072 0.93 +1 118 0.069 0.93 +1 53 0.056 0.94 +1 119 0.051 0.95 +1 54 0.070 0.93 +1 120 0.051 0.95 +1 55 0.055 0.95 +1 121 0.062 0.94 +1 56 0.071 0.93 +1 122 0.054 0.95 +1 57 0.063 0.94 +1 123 0.059 0.94 +1 58 0.070 0.93 +1 124 0.057 0.94 +1 59 0.072 0.93 +1 125 0.066 0.93 +1 60 0.067 0.93 +1 126 0.064 0.94 +1 61 0.078 0.92 +1 127 0.082 0.92 +1 62 0.077 0.92 +1 128 0.060 0.94 +1 63 0.088 0.91 +1 129 0.060 0.94 +1 64 0.102 0.90 +1 130 0.075 0.93 +1 65 0.108 0.89 +1 131 0.070 0.93 +1 66 0.159 0.84 +1 132 0.111 0.89 +1 Number of positive differences (S+) 132 Critical Value 75 The Survey Unit MEETS the Acceptance Criteria

[29]

ATTACHMENT 4 QC DATA

[30]

FSS RELEASE RECORD SERVICE WATER SUPPLY HEADER CO-26 AND CO-29 BURIED PIPE SURVEY UNIT 00101H SERVICE WATER SUPPLY HEADER BURIED PIPE - QC AGREEMENT Survey Unit # 00101H Survey Unit Name Service Water Supply Header Buried Pipe Sample Plan # S3-00101A Sample

Description:

Comparison of replicate gross-gamma measurements for QC from Pipe CO-26

- positions 80, 50 and 20 and from Pipe CO positions 78, 54, 20 and 7.

STANDARD DUPLICATE ID ACTIVITY +20% -20% ID ACTIVITY ACCEPTABLE (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (Y/N)

Pipe CO-26, 80 ft. 3.61E+03 4.33E+03 2.89E+03 Pipe CO-26, 80 ft. QC 3.22E+03 Y Pipe CO-26, 50 ft. 3.80E+03 4.56E+03 3.04E+03 Pipe CO-26, 50 ft. QC 4.44E+03 Y Pipe CO-26, 20 ft. 1.32E+03 1.58E+03 1.05E+03 Pipe CO-26, 20 ft. QC 1.41E+03 Y Pipe CO-29, 78 ft. 5.17E+03 6.20E+03 4.13E+03 Pipe CO-29, 78 ft. QC 4.97E+03 Y Pipe CO-29, 54 ft. 4.71E+03 5.65E+03 3.76E+03 Pipe CO-29, 54 ft. QC 4.51E+03 Y Pipe CO-29, 20 ft. 1.34E+03 1.61E+03 1.07E+03 Pipe CO-29, 20 ft. QC 1.32E+03 Y Pipe CO-29, 7 ft. 1.61E+03 1.93E+03 1.29E+03 Pipe CO-29, 7 ft. QC 1.37E+03 Y Comments/Corrective Actions: There was The acceptance criteria for replicate static acceptable agreement between the standard measurements and scan surveys are that the measurement and the replicate measurement. No same conclusion is reached for each further action is necessary. measurement. That is defined as + 20% of the standard.

[31]