ML20034E501

Memo to File Mesa Assessment W_Itas_Ars

ML20034E501
Person / Time
Site:	San Onofre
Issue date:	04/10/2014
From:	Southern California Edison Co
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML20034D837	List: IR 05000206/1981002 ML20034D851 ML20034D852 ML20034D853 ML20034D858 ML20034D859 ML20034D897 ML20034D898 ML20034D899 ML20034D900 ML20034D901 ML20034D902 ML20034D903 ML20034D904 ML20034D906 ML20034D907 ML20034D908 ML20034D909 ML20034D910 ML20034D911 ML20034D912 ML20034D913 ML20034D914 ML20034D915 ML20034D916 ML20034D947 ML20034D948 ML20034D949 ML20034D950 ML20034D951 ML20034D952 ML20034D953 ML20034D954 ML20034D955 ML20034D957 ML20034D958 ML20034D959 ML20034D960 ML20034D962 ML20034D964 ML20034D965 ML20034D966 ML20034D967 ML20034D968 ML20034D969 ML20034D970 ML20034D971 ML20034D972 ML20034D973 ML20034D974 ... further results
References
Download: ML20034E501 (259)

Text

{{#Wiki_filter:MEMORANDUM FOR FILE April 10, 2014 Revised May 28. 2015 as noted by tracked changes

SUBJECT:

Assessment of Radiological Events at the Mesa EXECUTIVE

SUMMARY

During the 1980s, radioactive material that had been inappropriately transferred from the site was discovered at the Mesa. That material was primarily contamination on tools and equipment that had been inadvertently released from the site as a result of a material release program that lacked the necessary rigor and was not well enough implemented to intercept all contaminated items among the thousands of items moved to the Mesa. Since the Part 50 license did not include the Mesa, the receipt, storage, or use of radioactive material was not permitted there. Consequently, the discovery of anything with radioactive contamination required immediate and complete removal; contaminated items were immediately secured, transferred back to the site, and the area was verified to be free of residual contamination. This assessment was accomplished through a review of historical records and through interviews with current and former San Onofre employees who have knowledge of the Mesa. The intent of this assessment is to identify those locations at the Mesa that were affected by the inappropriate presence of radioactive materials. In addition, this assessment supports a foundation that will assist in determining, for each specific event and location, whether or not additional radiological surveys are appropriate to confirm the complete cleanup of radioactive materials before termination of appropriate land leases and eventual turnover to the Department of the Navy. INTRODUCTION Principle Nuclear Regulatory Commission (NRC) regulations that govern the planning for and decommissioning of a commercial nuclear power plant are 10 CFR 20.1401-1406 "Radiological Criteria for License Termination," 10 CFR 50.82 "Termination of License" and 10 CFR 50.75 (g) "Reporting and Recordkeeping for Decommissioning Planning." Implementation of the radiological assessment requirements are described in NUREG-1575, Rev 1 "Multi- Agency Radiation Survey and Site Investigation Manual (MARSSIM)". MARSSIM Chapter 3 provides guidance for performing a Historical Site Assessment (HSA.) The Mesa and its facilities were never part of the Part 50 license for the San Onofre Nuclear Generating Station (SONGS) and therefore not intended for receipt, storage, or use of any radioactively contaminated tools, materials, or equipment. As such, the discovery of anything with radioactive contamination required immediate and complete removable with an acceptance criterion of "no detectable." The only acceptable result for each event was

the immediate transfer of the radioactive material to the site and complete decontamination of the area to levels indistinguishable from background. A dose-based standard, as utilized in license termination proceedings, is not appropriate since the area was not described by a license. Derived Concentration Guideline Levels are not applicable because there is no dose-based acceptance criterion. Therefore, the MARSSIM survey process is not applicable. However, while not applicable, the MARSSIM survey process provides a well-structured approach for any confirmatory surveys that may be necessary to ensure that removal of radioactive materials was complete. OBJECTIVE The objective of the HSA is to collect existing information describing a-site's history; an early step in the graded radiation survey and site investigation process as defined in MARSSIM. For the area under consideration, the Mesa and its facilities that supported construction and operation of SONGS, the HSA methodology provides an appropriate well-structured approach. While this document is not technically an HSA, it was researched and assembled with the same level of rigor. Like an HSA, existing information was assembled to allow evaluation of the events in which radioactive materials were inappropriately transferred from SONGS to the Mesa and identification of the specific locations involved. In addition, the evaluation supports a foundation that will assist in determining, for each specific event and location, whether or not additional radiological surveys are appropriate to confirm the complete cleanup of radioactive materials. The objectives for this assessment support the standardized MARSSIM approach, that is:

1. State the problem - a history of radioactive material discoveries at the Mesa

2. Identify the decision - was the removal of radioactive materials from the area adequate for each event

3. Identify inputs to the decision - interviews and documents associated with each event

4. Define study boundaries - what areas of the Mesa were affected by each event. Are those areas sufficiently intact today such that a confirmatory survey will provide useful information

5. Develop a decision rule - is there sufficient documentation to support a decision that removal of radioactive materials from each area was complete, was any survey or decontamination performed to ensure that no residual contamination remained . The decision rule is "nc1'detectable."

6. Specify limits on decision errors - statistical-based decision errors (such as 95%

confidence for Type I errors) are not applicable. If the documentation and/or interview information cannot support a determination that removable of radioactive materials was adequate, then the area should be considered for inclusion in a confirmatory survey. METHODOLOGY This assessment was accomplished through a review of historical records and through interviews with current and former San Onofre employees who have knowledge of the Mesa. The Unit 1 HSA and the Interim Units 2 and 3 HSA were referred to extensively. Information contained there was borrowed quite liberally in the preparation of this document. Relevant documents (including the U1 HSA and the Interim U2/3 HSA) and databases were searched electronically or manually to identify items of potential interest. All documents or items judged to be of potential interest were evaluated. Information that may be of use was extracted, summarized, and evaluated. The U1 HSA and the Interim U2/3 HSA included a number of interviews of long-experienced SONGS personnel. Those interviews contain ing information related to the Mesa were evaluated and included in this report. Several additional and follow up interviews were conducted where appropriate. BRIEF HISTORY OF MESA FACILITIES San Onofre's involvement at the Mesa began in the early 1970s when it was used as a repository for the significant amount of excavated material from construction of Units 2 and

3. Early structures under the control of Bechtel Power Company were situated in the Northeast corner of the Mesa. Among those was Warehouse "B." Those buildings were eventually removed and replaced by Buildings G-48, G-49, and G-50.

By the late 1970s several facilities had been established on the Mesa. Among those facilities germane to this report were the Mesa Fabrication Shop and the Generation Retrofit Improvement Project (GRIP) Facility. Both of those facilities were established in 1979 and located on Parcel 4 known as the Lower Mesa located along El Camino Real between that road and lnterstate-5. Following completion of TMI and seismic upgrades at Unit 1, the GRIP Facility was re-designated the Special Tools and Rigging (STAR) Yard. The Mesa Fabrication Shop later served as the Unit 1 Steam Generator Sleeving Mockup Training Facility. The Ameron Laydown Area was so named because it was used by the Ameron Company for fabrication of the Units 2 and 3 circulating water system concrete pipelines. After Ameron Company's exit, that area gradually became a storage location for materials no longer needed at the units. By 1986-1987 the facilities at the Lower Mesa were closed . The STAR Yard was moved to its final location in the Southeastern portion of the Mesa and expanded to include the Ameron Laydown Area. During late 1987 the Mesa lease was renegotiated and the Lower Mesa, designated Parcel 4, consisting of 7.8 acres, left Edison's control. Soon after that, the Navy re-contoured that entire area into a series of percolation ponds. The area is no longer intact, the surface soil having experienced significant disruption. The Seaweed Drying Pad was established in the 1992-1994 timeframe near the southern boundary of the Mesa. Benthic material from the Units 2 and 3 intake was released via the pad to reduce the moisture content to required specifications. De-watered seaweed was also more cost effective to dispose of due to weight reduction. During the Units 2 and 3 Steam Generator Replacement (SGR) Outages, the drying pad was temporarily moved approximately 50 yards to the East to allow reconfiguring the area as an overflow parking lot for employee automobiles. The pad was re-established in its original location after completion of the Unit 3 SGR outage. There was significant disruption of the surface soil as a result. Throughout SONGS history, the layout of the Mesa was under constant change to better support the changing needs of the units. Buildings would come and go, replaced by new structures. Surviving buildings would see changes in their craft tenants and entire areas were re-purposed. Attached maps show the areas described above. INADVERTENT RELEASES OF RADIOACTIVE MATERIALS Most of the radiological concern for the Mesa stems from inadvertently released radioactive material. For completeness, the SONGS radioactive material control program is briefly described below. Until April of 1977, station procedures allowed items to be released from Unit 1 without evaluation for fixed contamination. The author recalls discussions with early Unit 1 Chem-Rad Techs describing how they would smear tools and equipment, and finding no activity would release the items for unconditional use, all without evaluation for fixed contamination. By 1980, the release limit was 0.25 mR/hr measured at one inch. While those release procedures were consistent with industry standards at that time, those criteria exceeded the evolving release standards. In May of 1981 IE Circular No. 81-07: Control of Radioactively Contaminated Material was issued and the SONGS release program was revised to incorporate that guidance. Evaluation for both fi xed and removable contamination was required before the unconditional release of suspected items. The initial version of the procedure allowed some discretion and applied only to suspect items. By the end of the 1980s, the program had been strengthened such that all items were monitored at the Radiologically Controlled Area (RCA) exit point. Hand-carried personal items (e.g. lunch box, thermos, and jacket) and the individual were again monitored by a portal monitor at the Protected Area/Restricted Area (PA/RA) boundary. Large items must exit through the unit hold-down points. Vehicles and their contents were inspected and monitored at the hold-down area before exiting PA/RA. In spite of those efforts, items with low level contamination occasionally escape detection and pass into the unrestricted area. Such items typically contain very low levels of contamination and have no impact on the environment or on humans. When contaminated tools or equipment were discovered outside the RCA, qualified Health Physics (HP) Technicians would confiscate the item , return it to the site, and verify that the area was free of further contaminated items and residual radioactive material. The HP Technician present at the time of the initial contaminated item discovery had two distinct advantages over any follow up surveyor. First, knowing the exact location of the contaminated item allowed the Technician to focus additional scrutiny on that spot while surveying the surrounding area for residual activity. Second, after thirty years a significant portion of the contaminant has decayed to levels well below detectability. DESCRIPTION OF RADIOLOGICAL EVENTS AT THE MESA Following is a description of 11 events or time periods summarized in the-tl:le attached Table 1 in which radiological contamination was traced from the Protected Areas at SONGS to the Mesa. The list of events was assembled from actual documentation and/or from recollections obtained from personnel interviews where no documentation could be located.

1. Mesa Intersection -- Contaminated Unit 1 Excavation Materials Summary In December of 1980, approximately 100 cubic yards of contaminated soil, asphalt, and concrete were excavated from an area close to the Unit 1 containment structure and transferred to the Mesa. The material was dumped on the North side of Mesa Road just east of the intersection with El Camino Real and North of Building E-50.

Discovery During a December 18, 1980 exit interview for IE Inspection 50-206/80-33, an NRC inspector explained that, based on survey records, trace quantities of radioactive material were likely present in material excavated at Unit 1. He warned that the aggregate sum of the material may have exceeded the levels allowed for disposal by burial in soil. Magnitude On January 7, 1981 a direct radiation survey was performed at the intersection using a Ludlum Model 19 micro-R-meter. General background was determined to range between 8 to 12 uR/hr. Twenty-five measurements were taken on and around the materials ranging from 8 to 25 uR/hr. 13 samples were collected and th e highest activity sample was sent for Geli radiometric analysis by an off-site vendor laboratory with the following results: K-40 at 16.6 +/- 0.8 pCi/g; Mn-54 at 2.2 +/- 0.1 pCi/g; Co-58 at 3.9 +/- 0.2 pCi/g; Co-60 at 29 +/- 1.0 pCi/g; Cs134 at 8.8 +/- 0.4 pCi/g; Cs-137 at 26 +/- 1.0 pCi/g; and Ce- 144 at 3.5 +/- 0 .2 pCi/g. All of the excavated material was removed from the Mesa by January 15, 1981 . Shipping records indicated that 390 fifty-five gallon drums, with a total of 7.5 mCi of licensed material in 108 cubic yards of soil , were shipped from the Mesa to a licensed burial facility in January of 1981. After the soil was removed, the area was re-surveyed at 5-10 µR/hr. Surface samples revealed the following levels of residual activity: Mn-54 at 0.04 +/- 0.02 pCi/g; Cs-137 at 0.53 +/- 0.27 pCi/g; Co-60 at 0.57 +/- 0.29 pCi/g; and Cd-109 at 0.1 +/- 0.05 pCi/g. Inspection Report 50-206/81-02, dated February 13, 1981, describes the NRC Inspector's independent direct radiation survey of 30 locations with levels ranging from 5 to 1O uR/hr. NRC analysis of a soil sample he obtained led the Inspector to conclude that the excavated material containing trace quantities of radionuclides had been effectively removed . The inspection item was closed. No item of noncompliance was identified. As a direct result of this incident, San Onofre took the precautionary measure of prohibiting future disposal of excavated material from Unit 1 at the Mesa. Evaluation Direct radiation levels at the Mesa Intersection site were indistinguishable from background following remediation in January 1981. More than 30 years have passed since then. Residual Co-60 has undergone nearly 6 half-lives diminishing its potential presence to a level below detectability. Any remaining activity due to Cs-137 will have decayed to a level consistent with background. The Unit 1 HSA concluded that there should be no residual contamination at the Mesa Intersection site. (Unit 1 HSA, Inspection Reports 5-206/80-33 and 81-02, 2012 SONGS Radiological Environmental Operating Report)

2. Old Highway 101 Landfill - Unit 1 Excavation Materials Summary A large amount of soil, asphalt, and concrete was excavated from the Unit 1 facility and disposed of at the "Old Highway 101 Land Fill," located approximately 1.5 miles south of Building E-50, the Edison Training and Education Center (TEC/EOF.) (It should be noted that the landfill was never part of the Mesa lease but is included here for completeness.) The removal and transfer of the soil to the landfill occurred during the 1976 and 1977 Unit 1 outage when the Sphere Enclosure and Diesel Generator buildings were constructed. It was discover~. four years later, that the excavated material might contain radioactive material.

Discovery In 1980 and 1981, TMI retrofit projects at Unit 1 required excavation and removal of soil from the restricted area. Analysis of that material revealed the presence of low level radioactive contamination. Consequently, disposal practices for previous excavations at Unit 1 were investigated to determine whether or not contaminated soil might have been inadvertently released. It was discovered that the only significant excavation was conducted during the construction of the Diesel Generator and Biological Shield structures, during the October 1976 through March 1977 outage. The soil had been removed and transferred to the Old Highway 101 Landfill. That discovery prompted an extensive radiological survey. Magnitude In February 1981, a three-day effort was launched to obtain direct radiation measurements obtained with a Ludlum Model 19 micro-R-meter at 60 discrete survey points at the Old Highway 101 Landfill. Those measurements revealed no evidence of radioactive contamination above the normal range for natural background radiation. Although the radiation survey map showed a localized area with slightly elevated readings (14-15 µR/hr), these readings were determined to be the result of natural radioactivity from the concrete of the road. Three samples of the transferred material were obtained and sent to an off-site vendor laboratory for Geli radiometric analysis. Natural activity was detected in all three samples. The samples showed no cobalt or cesium activity above an LLD of 0.01 pCi/g. Strontium-90 was observed in two of the samples but at environmental levels. Individual Task Assignment ( ITA) #84311 describes a 1984 confirmation of the conclusions reached in the 1981 survey effort. Evaluation The Mesa Lease never included the area of the Old Highway 101 Landfill and there was never any indication of contamination as a result of early Unit 1 soil excavation. The 1981 direct radiation survey was extensive and thorough. Off-site analysis of the three soil samples found no cobalt or cesium activity using appropriate LLDs. The Unit 1 HSA concluded that there is no residual contamination in the landfill. (Unit 1 HSA, ITA

  #84311.)

3. Contaminated Material Found at Lower Mesa -- 1981 Summary In October, 1981, workers at the Lower Mesa notified HP of some yellow bags in their work area. HP responded and found the bags to be free of radioactive contamination.

However, while there the HP Technician performed a search for other suspect items and located a 1" galvanized pipe elbow in a tool storage box contaminated with approximately 0.14 uCi of Cs-137. Expanded surveys of the work area were performed and located two additional items: a forklift battery with 400 cpm/100 cm 2 removable contamination, and several metal pre-filters with a maximum of 300 cpm/100 cm 2 of removable contamination. The contaminated items were returned to the site leaving no residual contamination. The remainder of the surveyed area was found to be free of detectable contamination by direct frisk. Evaluation The contaminated items were found at the Lower Mesa. See the Evaluation of Event Number 4 regarding materials found at the Lower Mesa facilities.

4. Contaminated Tools and Equipment Discovered at Mesa Facilities 1983 & 1984 Summary Until 1980, the release limit was 0.25 mR/hr measured at one inch. While those release procedures were consistent with industry standards at that time , those criteria exceeded the evolving release standards. Between outages at Unit 1, tools and equipment were routinely stored around the reservoir. When the reservoir was cleared for in stallation of training trailers , some of those materials found their way to the Off-Shore Pad and the Mesa.

In July, August and September of 1983, a comprehensive effort was made to survey all Mesa storage facilities and a Bechtel warehouse in La Mirada, CA for contaminated tools and equipment. The GRIP Facility, the Bechtel Fabrication Shop and part of the Ameron Laydown area were all included in the Mesa survey. In response to a Notice of Violation (NOV) issued as a result of the NRC Inspection 50-206/80-23 conducted on September 26-30, 1983, a subsequent radiological impact evaluation was also conducted. Discovery On July 14, 1983, a contaminated heliarc-welding stand was found at the Bechtel Fabrication Shop at the Mesa with 1,300 cpm/100cm 2

• On July 20, 1983, an empty gang box sent from the Mesa GRIP Facility back to Unit 1 was found to have fixed contamination on the inside of the box at 2,100 cpm/100 cm 2 . As a result of those two findings and suspecting that more radioactively contaminated material may be present at the Mesa, a comprehensive radiation and contamination survey was initiated of storage areas that could have received materials from Unit 1.

Magnitude An extensive survey of affected areas at the Mesa was initiated and included the GRIP Facility and Fabrication Shop (20 items found), the Ameron laydown areas (84 items), the Mesa Training center, E-50 (1 item), the Units 2 and 3 laydown area (67 items), Warehouse "B" (1 item), the Paint and Sandblast yard (3 items), and the Edison Warehouse (7 items.) With very few exceptions, when detected the items had fixed, but no accessible removable surface contamination. Most items were found in tool or gang boxes and thus protected from the weather. In all cases the contaminated items were confiscated, returned to the site, and the area was verified by direct frisk to be free of residual contamination . Over 90 person-months were expended during this effort to detect and recover any and all radioactively contaminated items. Major changes were made to strengthen the material release program. A letter from Mr. P.J. Knapp, HP Manager to Mr. P.A. Croy, Compliance Manager dated March 21, 1984 provided a final summary of contaminated items found at the Mesa and other locations. This information was forwarded by Mr. C.W. McCarthy, SCE Vice President, to Mr. F.A. Wenslawski , Chief Radiological Safety Branch, NRC Region Von March 29, 1984. Evaluation The GRIP Facility, Fabrication Shop, and Training Center were located on the Lower Mesa when the twenty-one items were discovered. As described above, following each discovery, the areas were verified to be free of residual contamination by direct frisk. The lower Mesa was released from Edison control during the late 1980s and was subsequently significantly re-contoured into percolation ponds. The area is no longer intact. Additional survey will not provide useful or meaningful information. Warehouse "B" was replaced by Building G-49 by the mid-1980s. Only one item with fixed contamination and no removable activity was found there. The building is no longer intact. Additional survey will not provide useful or meaningful information. Only three items with low levels of fixed contamination and no removable contamination were found at the original Paint/Sandblast Yard. The Paint Shop and the Yard are no longer intact. That area is now paved and houses Buildings G-40 and G-46. Additional survey will not provide useful or meaningful information. A total of seven contaminated items were found in the Edison Warehouse, Building W-50, during its existence at the Mesa. Two of those items contained removable activity. While areas were verified free of residual contamination by direct frisk following discovery of contaminated items there. This area is considered to have a low probability for detectable residual radioactive contamination. Sixty-seven contaminated items were discovered in the Units 2 and 3 Laydown. With few exceptions, those items contained only fixed contamination. While it is believed that most items were contained in tool and gang boxes, available data do not make that clear. Exposure to the weather was likely a factor there. Although areas were verified free of residual contamination following discovery of contaminated items, those verifications may not have been as sensitive as modern techniques. Additional survey of this area would provide definitive assurance that no residual contamination remains . Additional contaminated items were discovered in the Ameron area following the eighty-four described above. See Event Number 6 for further discussion of that area.

5. Contaminated Pipe Discovered at Lower Mesa -1986 Summary In early December of 1985, the turbine crossover pipe from Unit 1 was removed. This pipe was part of the secondary plant, outside the RCA. Because the pipe came from a system that was presumed to be clean , release surveys in the Unit 1 hold down area were limited to accessible portions of the pipe. At this point, the pipe was found to be free of contamination and was released for storage at the STAR Yard on the Lower Mesa. This area was formerly known as the GRIP Facility.

Discovery On February 6, 1986, an anonymous letter (86-RV-A-010) alleged that the crossover pipe had been shipped offsite because the craft giving the order was not qualified. As a result of this letter, SCE conducted an investigation. Surveys of other secondary piping revealed contamination inside of the pipes up to 1,000 cpm/100 cm 2 , so the crossover pipe stored at the GRIP Facility was resurveyed . Magnitude Localized fi xed contamination of up to 800 cpm/ 100 cm 2 was identified inside the pipe near the right angle weld. There was no detectable removable contamination . The pipe was returned to the site and the storage area was verifi ed to be free of residual contamination. Evaluation The Unit 1 HSA concluded that there would be no residual contamination from the presence of the pipe. Further, this was a Lower Mesa location as explained in Event Number 3. The area is no longer intact. Additional survey will not provide useful or meaningful information.

6. Contaminated Tools and Equipment Discovered at STAR Yard 1988-1989 Summary In May 1988, SONGS received a refurbished 2,000-pound pressurizer relief valve from Wyle Laboratories. The relief valve was sent back to SONGS contaminated with 93.3 uCi . A month later, a QA Inspector found that contaminated valve in the STAR Yard.

The valve was still in the shipping box. The contaminant was fixed with no removable avtivity. (By this date, the STAR Yard had been relocated from the Lower to the Upper Mesa.) In September, the same QA Inspector identified a fire hose contaminated to a level of 500 ccpm. That hose had been transferred to Building G-20 from the AWS Machine Shop. As a result of those findings, QA issued Corrective Action Report (CAR) SO-P-1171 that addresses issues specific to the HP organization . CAR SO-P-1177 was issued later that month to address problems with Station support of the release program. The response to that document described corrective actions taken by the Health Physics organization and includes a list of 14 additional contaminated items found outside the Restricted Area during September. The documentation does not specify where the items were discovered nor does it describe whether or not removable contamination was present. During a routine quarterly radiation survey in March 1989, contaminated items were discovered in several locations within the STAR Yard . It was determined that this material had been inappropriately released in February from Unit 1. Continued survey in the STAR Yard later in March resulted in a find of additional contaminated items on a wooden pallet that had come from Units 2 and 3. In April, six more items associated with stored refueling equipment were found and were noteworthy

 . in that cobalt particles were present. Because of the continuing discoveries of contaminated items, QA issued a Stop Work Order to prevent further releases from the site and the Mesa until corrective actions were implemented.

By Mid-April, 44 additional contaminated items had been found at the STAR Yard and returned to the site. Unlike Event Number 4 that resulted from legacy items released with inadequate controls and practices, the series of events described for this time period represented an on-going unresolved problem. As a result of a Root Cause Evaluation and much work to satisfy the QA concerns, the release program and implementation of the program was significantly strengthened. Inadvertent releases to the Mesa essentially stopped . Evaluation The Upper Mesa STAR Yard suffered the largest number of contaminated item discoveries. Including the earlier findings in the Ameren Laydown area detailed in Event

                                             - IO -

Number 4, more than 140 items were found there. (Recall that the Upper Mesa STAR Yard included the area formerly known as Ameron.) While the majority of those items had no removable contamination and were found in gang boxes, buildings, or cargo containers , many items were found exposed to the weather. For many of the discovered items the data are incomplete. Several of the interviewed employees recalled that as many as four HIC shields had been stored in the Yard. There was some recollection , but no documentation, that one of the shields may have contained fixed contamination and was possibly decontaminated there. Additional survey of this area would provide definitive assurance that no residual contamination remains. Boundaries of the STAR Yard at the Upper Mesa have varied over the years. The most heavily affected portion lies along the existing Construction Way cul-de-sac and then extends southeast to include what was originally the Ameron Area. That area is displayed on the attached map as a double cross-hatch area. An element to the Station's response was to initiate a comprehensive survey of the Mesa. That survey included all areas at the Mesa that contained tools and equipment. Following that survey, Health Physics personnel maintained a presence at the Mesa to survey material transfers to and from the Mesa. Key Mesa locations and facilities were added to the schedule of routine radiation surveys. Those steps were taken to ensure that no items were present at the Mesa that had not be surveyed.

7. Contaminated Items Found at Mesa Salvage Yard Summary The Salvage Yard was located in the west end of what was most recently Camp Mesa.

A large fenced area, approximately 150 yards by 25 yards, contained scrap materials. During a 1992 radiological survey effort to qualify the material for release, the following items were found to be slightly contaminated : two four-inch pipe sections, two wheels, and one Flexiatallic gasket. Discovery During May and June of 1992, the scrap material stored in the Salvage Yard was being evaluated for release. The materials were thought to be free of radioactive contamination. As a precaution the material was evaluated for residual radioactive contamination. The items identified above were found to contain low levels of contamination. Magnitude ITA 92-115 describes the two pipe sections reading 360 ccpm each with no removable contamination. Geli radiometric analysis revealed the source of the activity to be entirely Pb-214, a natural occurring radionuclide. Consequently, the pipe sections are eliminated from further consideration . Two wheels showed 1600 and 1800 ccpm by direct frisk and no removable activity. A Flexiatallic gasket measured 4500 ccpm by direct frisk and was also free from removable contamination. Those three items showed plant produced contaminants. Consistent with protocol, the items were transferred back to the site and the area was verified to be free of residual contamination by direct frisk. The fence on the East side of the area was removed when it was included as the Western end of Camp Mesa. A significant amount of large size gravel was added to the surface at that time. Evaluation Only three items were found in the Salvage Yard. The items demonstrated low level fixed contamination and no removable activity. The area was verified free of residual contamination by direct frisk following removal of the items. This area is considered to have a very low probability for detectable residual radioactive contamination.

8. Transfer of Seaweed to Mesa Drying Pad Summary Detection of low but statistically significant levels of plant produced radionuclides in Units 2 and 3 intake sludge were reported as early as 1983. Initially, radwaste discharges were suspected to be the source of that activity. Later analysis identified the source to be ocean bottom sediment. Steam generator blowdown from Unit 1 was released to the ocean. Whenever there was primary-to-secondary leakage at Unit 1 there was a strong potential for benthic material to demonstrate levels of activity that would be detectable at Units 2 and 3 just down the coast from Unit 1.

Benthic material was sampled before release. Waste found to contain radio-cesium and/or cobalt was disposed of as radwaste or in accordance with a State of California exemption obtained for specific landfill disposal. Waste showing only 1-131 was allowed to decay, be re-sampled, and then disposed of in a landfill. Following the permanent shutdown and defueling of Unit 1, the release process was modified to allow removal of benthic material without the sampling requirement. (The procedure contained a safeguard that required sampling of benthic releases if the secondary activity of either operating unit exceeded a specified threshold level .) In the early 1990s, the Seaweed Drying Pad was established in the southern portion of the Upper Mesa. Benthic material from the Units 2 and 3 intake was released via the pad to reduce the moisture content to required specifications. De-watered seaweed was also more cost effective to dispose of due to weight reduction . The SONGS Annual Radiological Environmental Operating Reports were reviewed from 1984 to the present. Before the shutdown of Unit 1 in 1992 kelp and ocean bottom sediment samples showed low levels of Cs-137 and Co-60. Since the shutdown of Unit 1, ocean bottom sediment samples are free of detectable plant produced activity and kelp samples show only 1-131 . Incidentally, the levels of 1-131 since 1988 have typically been higher in control samples than those associated with the plant. The source of the radioiodine is almost certainly due to sewerage discharges of medical administrations. (SONGS Annual Radiological Environmental Operating Reports.) Evaluation Radioiodine was likely present in benthic material deposited at the Seaweed Drying Pad. The source of that radioiodine was sewerage discharges of medical administrations. A decay time exceeding two months would reduce any 1-131 to levels below detectability. The material has been free of detectable plant produced radionuclides since the station began using the Drying Pad and is included in this assessment for completeness.

9. Damaged Exempt Cl-36 Source in HP Classroom in Building G-48 Summary Classroom 105 in Building G-48 was used for initial and continuing training of HP Technicians. Several interviewees recalled that an exempt chlorine-36 source was damaged in the classroom and decontamination was required.

The exempt quantity radioactive check source was being used to support instrument training. Once the damage was discovered, the source was secured and the classroom was decontaminated and returned to service. Reportedly, a portion of the carpet was removed before the classroom was declared free of contamination. This event was thought to have occurred in the 1993-1994 time frame. No supporting documentation was found . Personnel that identified or corroborated this information include: Paul Elliott, John Scott, Todd Adler, and Al Gray. Evaluation Those interviewed about this event described a small, button source on which the mylar covering had become partially detached. The interviewees described a thorough effort conducted by seasoned HP Technicians to recover the classroom and to ensure that no residual activity remained. While only direct frisking was performed, the Cl-36 beta would have been easily detected. This area is considered to have a very low probability for detectable residual radioactive contamination. HP Classroom 105 in Building G-48 warrants further consideration. Though not directly related to the event described above, personnel interview also revealed the existence of a floor safe used to store training's radioactive check sources in what is now known as the Joint Operation Center (JOC.) The floor safe is located in a small adjoining room in the northwest corner of the JOC. That floor safe should be verified free of residual contamination before release of Building E-50.

10. Contaminated Pliers Found in Building G-44 Summary During a late 2001 site-wide sweep for magenta marked items and associated radiological survey, four suspect tools were found in the Building G-44 Mesa Paint Shop. Of those four hand tools, only the pliers were found to be slightly contaminated:

250 ccpm fixed and no removable contamination. All four hand tools were returned to the site. Evaluation Only a single hand tool was found with low level fixed contamination and no removable activity. The worker who initially found the pliers and the surrounding area were both frisked and showed no residual activity above background. There was no spread of contamination from the event.

11. Contaminated Air Hose Found in Building G-40 Summary In November 2003 two HVAC workers were assigned to prepare equipment stored at the mesa. A sealed 55-gallon drum was retrieved from storage in a cargo container at the STAR Yard and opened in the G-40 Sheet Metal Shop. When the workers noticed a 12' long W' diameter air hose with magenta markings in the drum they stopped and contacted Health Physics.

Field surveys verified that the hose contained low level fixed contamination, <600 ccpm by direct frisk. No removable contamination was found on the hose, in the drum, in the work area, or on the HVAC Technicians. The hose and all of the other materials in the drum were returned to the plant for additional surveys. Follow-up surveys of the G-40 shop and the four other HVAC cargo containers were negative, as were surveys of the additional contents of all four drums. Investigation determined that the drum had been sealed, released from the site, and placed in the Mesa cargo container following a 1998 replacement of the charcoal in the Units 2 and 3 Fuel Handling Building Post Accident Cleanup (PACU) Units. Evaluation There was no spread of contamination from the hose to the involved personnel or the surrounding area. RESULTS OF HISTORICAL INFORMATION SEARCHES Documents and databases that were reviewed include the Annual Radiological Environmental Reports (1984 - 2013), Health Physics Division Individual Task Assignments (ITAs) (1982- 2011), PJK Log assignments (1982-1990), Integrated Health Physics System (IHPS) database of radiation surveys (1996 - present), the Action Request (AR) system in MOSAIC (1990 - 2008), Nuclear Notifications in SAP (2008 - present), and the Topic Information Server (TIS) database for mention of radioactive material at the Mesa ( 1987~present.) The most useful information came from reviewing the ITAs. ITAs were used in the Health Physics Division to document assignments and results beginning in 1982 and remained active through 2011. The first two numbers of an ITA designate the year in which the assignment was made. This system was extensively used by Health Physics to document problem s, issues, analyses and practices. Only a hardcopy index remains for the documents maintained there. The hardcopy index was manually reviewed for information about legacy radioactive material at the Mesa. Use of the ITA system declined as the AR system developed into the site-wide method for documenting problems and actions. The AR system in MOSAIC became the preferred station-wide tool for documenting problems in 1999. Use of the ITA system continued within Health Physics for documentation of items such as technical studies, new equipment evaluations, dose evaluations and some internal audits. The AR system was replaced by the SAP Nuclear Notification system in 2008. Following is a brief description of the relevant items from the ITA and AR systems: ITA 82059 This item identifies the presence of three decon showers located on the Mesa . One shower is located in the EOF and two decon showers are located in the Mesa Medical facility. The decon showers all drain to a common 2000 gallon holding tank. Provision for use of the showers is contained in S0123-Vlll-40.3, the procedure for the EOF Health Physics Leader. Periodic testing has shown the showers to be operable. The showers have never been used to decontaminate a person, hence, this item is closed . ITA 83221 This item includes a description of initial contaminated item discoveries of contaminated items at the Lower Mesa and the ensuing investigation. Finding through September 1983 are reported and initial corrective actions are described. (Event Number 4.) ITA 84311 Confirmation of the results from a radiological survey performed in 1981 of excavated material from Unit 1 that had been transferred to an area southeast of the site called the Old 101 Landfill. (Event Number 2.) ITAs 84295 and 84331 Some items with low level contamination were discovered on the Mesa and their presence gave cause for issuance of an NRC Notice of Violation in September 1983. The items were believed to have been released between March 1977 and May 1982 as a result of a material release program that lacked the necessary rigor and was not well enough implemented to intercept all contaminated items among the thousands of items moved to the Mesa. The potential impact to the public was evaluated and found to be well below any level of concern. Contained is a final list of contaminated items found through February 1984 for transmittal to the NRC. (Event Number 4.) ITA 84386 Contaminated items had been found at some previously surveyed locations at the Mesa. Material flow was investigated and traced from SONGS Unit 1 to the Off-Shore Pad, through Units 2 and 3, and eventually to the Mesa. Additional corrective actions were specified. (Event Number 4.) ITA 89045 This item documents the unintended release from U2/3 of a flatbed truck with equipment and a release of some tools to the STAR yard. The incident was quickly detected, the items were surveyed, and contaminated items were returned to U2/3. Inadequate communication and incorrect assumptions were responsible for the incidents. A formal root cause evaluation is included. The material release program was further strengthened. (Event Number 6.) ITA 89061 Documents a business analysis on the cost associated with release of salvage material under the control of the Edison Warehouse . (Event Number 6.) IT.A. 89069 Documents a skin dose evaluation of an HP Technician i.vho became contaminated with a fuel fragment while frisking material at the STAR Yard . (Event Number 6.) Due to privacy requ irements and not specific relevancy to the lease, this ITA is being strikethrough from this report. ITA 92115 This item documents the discovery of three contaminated items in the Salvage Yard. That location was later included in the establishment of Camp Mesa. (Event Number 7 .) ITAs 83181, 84319, and 84485 The items document the presence of plant produced radionuclides in seaweed and intake sludge. Disposal options and recommendations are specified. (Event Number 8.) ITAs 88020 and 90039 Document the discovery of 1-131 in benthic material collected at all three units in February 1988. Recommended decay times are calculated and specified. (Event Number-a_§.) ITA 92123 This item documents the last transfer of benthic waste to the Otay Mesa Landfill under a State of California exemption. (Event Number-a_§.) ITA 94267 This item documents an evaluation to allow the release of fish collected during operation of the plants for use as teaching aids. The evaluation References a November 1984 analysis on disposal of Benthic Material. That analysis showed that since the shutdown and defueling of Unit 1, only 1-131 was detected in Units 2 and 3 benthic material. The likely source of which is sewerage releases of medical administration of radioiodine. (Event Number-a_§.) ITA 94268 This item documented a validation that appropriate Station organizations had made necessary procedure changes to allow disposal of benthic material without further analysis. (Event Number-a_§.) ITAs for 1995-2012 No ITAs associated with the Mesa were found from 1995 to 2012. AR #010901163-6 This AR documented a Root Cause Evaluation of several failures in the material release program. Most of those involved non-contaminated but magenta marked tools found outside the RCA. Among those items was the description of four hand tools found at the Mesa Paint Shop, Building G-44. Only the pliers were found to contain low level fixed contamination. The other items were not contaminated. (Event Number 10.) AR #031100334-1 This AR describes the discovery of an air hose with low level fixed contamination and no removable activity in the Sheet Metal Shop, Building G-40. The hose was believed to have been released from Units 2 and 3 after the equipment was last used there early in 1998. Between that time and its discovery, the hose had stored in a sealed 55-gallon drum in a cargo container at the Mesa. (Event Number 11 .) INTERVIEW RESULTS AND CORROBORATION Eight interviews that were completed for the U1 HSA and the Interim U2/3 HSA contained recollections of the Mesa. Those interviews are included in this assessment. An additional six interviews and two follow up interviews were conducted specific to findings at the Mesa. The interview results are documented and organized in a separate binder. The results of the interviews are summarized below, as well as any corroboration found during the records review. Interviews from U1 HSA and the Interim U2/3 HSA: E. Bennett: Contaminated items found in Mesa laydown area W. Frick: Mesa Unit 1 Steam Generator Sleeving Mockup Training Facility S. Medling: Mesa Unit 1 Steam Generator Sleeving Mockup Training Facility M. Sullivan: Mesa storage areas R. Warnock: Contaminated construction fill at the Mesa B. McWey: Stop Work Order for contaminated items found at the STAR Yard T. Adler: Contaminated HIC shield at the STAR Yard; Damaged exempt Cl-36 source in HP Classroom P. Elliott: Contaminated tools and equipment at the STAR Yard Damaged exempt Cl-36 source in HP Classroom A. Gray Damaged exempt Cl-36 source in HP Classroom 105, Building G-48 Additional and follow up interviews: S. Folsom: Validation of survey results for Old Highway 101 Landfill E. Rinhart Bechtel Warehouse "B" Establishment of Edison Warehouse at Building W-50 location J. Scott: Presence of HIC shields at the STAR Yard Damaged exempt Cl-36 source in HP Classroom 105 of Building G-48; Presence of floor safe in E-50 used to store training check sources P. Edmonds: Presence of four HIC shields at the STAR Yard D. Webb: Experience as an HP Technician who worked to survey the Mesa in the late 1980s and early 1990s K. Coffman Experience as an HP Technician who worked to survey the Mesa in the mid to late 1990s P. Elliott: Follow up - contaminated HIC Shield may have been decontaminated at the STAR Yard A. Gray: Follow up - confirmed that the Cl-36 event occurred in HP Classroom 105 of Building G-48 CONCLUSIONS Most of the radiological concern for the Mesa stems from inadvertently released radioactive material. The items occasionally and inadvertently released from SONGS units typically displayed very low level contamination and had no impact on the environment or on humans. The items were believed to have been inappropriately released between 1977 and 1989 as a result of a material release program that initially lacked necessary rigor and later was not well enough implemented to intercept all contaminated items among the thousands of items moved to the Mesa. By 1989, the release program had been sufficiently strengthened to essentially stop inadvertent releases to the Mesa. Only a very few isolated events occurred after 1990. With few exceptions, the items contained only fixed contamination and no removable activity. A majority of items were found in tool and gang boxes or cargo containers. Those factors would mitigate concerns over the spread of contamination . However, weather exposure is a potential concern for some of the discovered items. Unfortunately, available data do not allow definitive identification of those cases. When contaminated items were found, the situation was corrected at the time of occurrence. Discovered items were confiscated and immediately transferred back to the site. The area was searched for additional contaminated items and the area was direct frisked to ensure the area was free of detectable residual activity. Based upon the records review and the interviews, the following areas summarized in the attached Table 2 were affected by the presence or potential presence of radioactive materials inappropriately transferred to the Mesa:

a. Mesa Intersection -- where contaminated excavation material from Unit 1 was dumped and subsequently removed. That event is covered as Event Number 1. This area was remediated and verified free of residual radioactive material upon its discovery. The adequacy of the 1981 survey effort should be evaluated and documented by separate memorandum.

b. Old Highway 101 Landfill - where non-contaminated excavation from Unit 1 had been transferred during the late 1970s. That event is covered as Event Number 2. The Mesa Lease never included the area of the Old Highway 101 Landfill and there was never any indication of contamination as a result of early Unit 1 soil excavation. It is included in this assessment only for completeness. The adequacy of the 1981 survey effort should be evaluated and documented by separate memorandum.

c. Lower Mesa -former site of the GRIP Facility/STAR Yard and the Fabrication Shop/Unit 1 Sleeving Mockup Training Facility. Discoveries of contaminated items there are covered in Event Numbers 1, 3, 4, and 5. That location is not a part of the current Mesa. The area has been re-contoured and re-purposed by the Navy. The area is no longer intact. Additional survey will not provide useful or meaningful information.

d. Bechtel Warehouse "B" -where only one item was discovered with low level fixed contamination and no removable activity. The location has been substantially re-purposed. Covered in Event Number 4. The building is no longer intact. Additional survey will not provide useful or meaningful information.

e. Paint/Sandblast Yard - where only three items with low levels of fixed contamination and no removable contamination were found . The original Paint Shop and the Paint/Sandblast Yard in no longer intact. Additional survey will not provide useful or meaningful information.

f. Edison Warehouse, Building W where seven contaminated items were discovered.

Two of the items contained removable activity. Those discoveries are covered in Event Number 4. Although this area is considered to have a low probability for detectable residual radioactive contamination, it should be included in the confirmatory survey.

g. Units 2 and 3 Laydown Area - where sixty-seven contaminated items were discovered.

Those discoveries are covered in Event Number 4. Additional survey of this area would provide definitive assurance that no residual contamination remains. Hence, it should be included in the confirmatory survey.

h. STAR Yard and Ameron Laydown Area - where the majority of inadvertently released contaminated items were discovered. More than 140 contaminated items were found there. Those discoveries are covered in Events Numbers 4 and 6. Additional survey of this area would provide definitive assurance that no residual contamination remains.

Hence, it should be included in the confirmatory survey.

i. Mesa Salvage Yard - where only three items with no removable contamination were found. The area was later included as the western end of Camp Mesa. Those discoveries are covered in Event Number 7. Although this area is considered to have a very low probability for detectable residual radioactive contamination, it should be included in the confirmatory survey.

j. Seaweed Drying Pad - where benthic material collected at the site was de-watered before disposal. The material deposited there was free of detectable plant produced radionuclides. The area is included in this assessment only for completeness. Covered in Event Number 8. Further consideration of this area is not warranted.

k. Classroom 105, Building G where an exempt Cl-36 source was damaged requiring decontamination of the room . Covered as Event Number 9. Although this area is considered to have a very low probability for detectable residual radioactive contamination, it should be included in the confirmatory survey.

I. HP Lab, Building E personnel interview revealed the existence of a floor safe used to store training radioactive check sources in what is now known as the Joint Operation Center (JOG.) That floor safe should verified free of residual contamination before release of Building E-50. Hence, it should be included in the confirmatory survey.

m. Mesa Paint Shop, Building G where a pair of pliers with fixed contamination was discovered. Covered as Event Number 10. Further consideration is not warranted.

n. Sheet Metal Shop, Building G where a contaminated air hose was discovered in a sealed drum . Covered as Event Number 11. Further consideration is not warranted.

RECOMMENDATIONS

1. Evaluate and document in a separate memorandum the adequacy of the 1981 radiological surveys for locations a & b and specify any additional necessary actions.

2. Prepare a Mesa Confirmatory Survey Plan to address affected locations f,g,h,i,k, and I listed above.

DEVELOPMENTAL RESOURCES NRC Information Circular 81-07: CONTROL OF RADIOACTIVELY CONTAMINATED MATERIAL, May 14, 1981. NUREG-1575, Rev1; EPA 402-R-97-016, Rev 1; DOE/EH-0624, Rev 1; "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM); August 2000 Unit 1 Historical Site Assessment, Part I: Historical Site Assessment Report; Part II: Interview Documentation , and Part Ill: Supporting Documentation. Interim Historical Site Assessment for Units 2 and 3, Part I: Interim Historical Site Assessment Report; Part II : Interview Documentation; Part Ill: Supporting Documentation. Health Physics Procedure S0123-Vll-8, "Control of Radiological Material." Health Physics Procedure S0123-Vll-20.9, "Radiological Surveys." Health Physics Procedure S0123-Vll-20.9.2, "Material Release Surveys." Health Physics Procedure S0123-Vll-20.9.3, "Surveys for Release of Liquids Sludges, Slurries, and Sand." ATTACHMENTS

1. Table 1 - Record of Radiological Events at the Mesa

2. Table 2 - Summary of Affected Areas at the Mesa

3. Mesa Map 1

4. Mesa Map 2

                              -- ic,       ~         ~

Memorandum Prepared by: April 10, 2014 Revised on May 28, 2015 Terry Cooper, CHP ~ Reviewed by: Approved by: Chris Ahola, CHP, Radiation Protection Manager cc: T. Adler J .A. Madigan J.Janke J.B. Moore (BHI) COM

Addendum to Memorandum for File - Assessment of Radiological Events at the Mesa, dated April 11, 2014

SUBJECT:

Adequacy of 1981 Radiological Surveys for Mesa Locations a & b

REFERENCES:

1. Assessment of Radiological Events at the Mesa, T. Cooper, April 10, 2014

2. Mesa Survey Plan, E.M. Goldin, April 16, 2014

3. Radionuclide Distribution Profiles: Radiation Dose Contribution and Survey Requirements - REVISED, EM Goldin to JM Sills, February 23, 2006

4. Scanning Sensitivity - Soil/Area Scans of Remediated Areas, SONGS Unit 1 -

REVISION 1, E.M. Goldin to J.M. Sills, January 11, 2005

5. United States Nuclear Regulatory Commission (NRC) Inspection Report No. 50-206/81-02, February 13, 1981.

6. Individual Task Assignment (ITA) #84311 Reference 1 documents a retrospective assessment of events that resulted in radioactive material being inappropriately transferred from the San Onofre Nuclear Generation Station (SONGS) to the Mesa. That assessment concluded that fourteen separate locations (Locations a through n) were affected by those transfers. Six of those locations were determined to require additional survey to ensure that the removal of radioactive material was complete:

Location f - Edison Warehouse, Building W-50 Location g - Units 2 and 3 Laydown Area Location h - STAR Yard and Ameron Laydown Area Location i - Mesa Salvage Yard Location k - Cl-36 source in Rm 105, Building G-48 Location l - Source storage vault in Building E-50 Those six locations are addressed in Reference 2. One location, a, the Mesa Intersection, had been contaminated by the inappropriate transfer of soil excavated in support of TMI upgrades at Unit 1 in December 1980. Upon discovery a month later, the contaminated material was immediately removed and sent to a licensed burial facility. A second location, b, the Old Highway 101 Landfill, received soil excavated from Unit 1 during the construction of the sphere enclosure and diesel generator buildings. That discovery prompted an extensive radiological survey confirming that no contamination was present.

In both cases, radiological surveys were performed and found levels consistent with natural background. Reference 1 recommended further review of the documentation and interviews associated with each of those two locations to confirm the adequacy of those 1981 surveys. PURPOSE Determine whether or not the methods and instrumentation employed during the 1981 radiological surveys were adequately sensitive with appropriate detection efficiency to ensure that the locations were left with levels indistinguishable from background. RADIONUCLIDE DISTRIBUTION The material deposited at Mesa Locations a and b originated at SONGS Unit 1. For potential contamination derived from Unit 1, Reference 3 analyzed data from twelve dry active waste (DAW) smear samples collected between 1993 and 2002. Neglecting minor contributors, 97% of the mix is composed of: Fe-55 14%, Co-60 22%, Ni-63 11%, Cs-134 9%, and Cs-137 41%. Cs-134, Cs-137 & Co-60 combined account for more than 70% of the mix and Fe-55 & Ni-63 together about 25%. Those ratios result in a relatively easily detectable contaminant for both beta-gamma or gamma-only detectors. Those ratios also argue against the need to perform specialized analyses for hard-to-detect radionuclides - gamma radiometric analysis of any sample matter is sufficient. Reference 5 demonstrated that the scan MDC for a SPA-8 (1 x 1 sodium iodide crystal) detector was about 8 pCi/g. That level, incidentally, is well below the NRC screening value of 11 pCi/g for Cs-137 soil contamination. In conclusion, the radionuclide distribution from Unit 1 yields sufficient beta-gamma radiation emissions such that standard field instruments, e.g., 1x1 NaI based microR meters, are adequately sensitive with appropriate detection efficiency for direct radiation measurements. Gamma radiometric analysis of samples is adequate. Note that this conclusion accounts for hard-to-detect radionuclides that form a small fraction of each of the distributions. Location a - Mesa Intersection Reference 5, NRC inspection Report 50-206/81-02 contains the most useful information on the Mesa Intersection Event. In that report NRC Inspector G. P. Yuhas described the licensees radiation survey performed with a Ludlum Model 19 Micro R Meter consisting of twenty-five measurements taken on and around the dumped material. He noted general 2

background levels between 8 to 12 uR/hr, pre-remediation levels between 8 to 25 uR/hr, and that resurvey of the area after material removal showed a return to between 8 to 12 uR/hr. The licensees collection of thirteen soil samples for relative counting and an independent laboratory analysis of the highest activity sample were also described. Mr. Yuhas then described his actions: During the course of this inspection, the inspector reviewed the licensees data, performed independent radiation surveys using an Eberline PRM-7 Micro R/h Meter serial No. 453, calibrated December 15, 1980, and collected samples for analysis by the NRC laboratory facilities. On January 20, 1981 the inspector performed an independent direct radiation survey consisting of 30 locations in the general area where the material had been dumped. This survey indicated radiation levels from 5-10 uR/hr with no statistically significant increase in the localized area from where the excavated materials had been removed. On January 21, 1981 the inspector collected one square meter surface samples from the affected area and from an area considered to be background. The licensee was provided a fraction of each sample for comparative analysis. NRC analysis of the samples performed at Region V using ND6600/intrinsic germanium detector located in the mobile van indicate that virtually all the excavated material containing trace quantities of radionuclides had been effectively removed. The residual activity is noted below: Isotope Activity pCi/g Mn-54 0.04 + 0.02 Co-60 0.57 + 0.29 Cd-109 0.10 + 0.05 Cs-137 0.53 + 0.27 Mr. Yuhas concluded: Since the material was not buried, did not exceed the regulatory limits expressed in 10CFR20.105, Permissible levels of radiation in unrestricted areas, and was completely removed in an expeditious manner, no item of noncompliance was identified. Consequently, the finding was formally closed. Evaluation In December of 1980, approximately 100 cubic yards of contaminated soil, asphalt, and concrete were excavated from an area close to the Unit 1 containment structure and dumped at the Mesa Intersection. 390 55-gallon drums, nearly 130 cubic yards of material were subsequently removed and transferred for burial in a licensed facility. Based on extensive direct radiation measurements and confirmatory radiometric analysis of soil 3

samples, the licensee concluded that the excavated material had been completely removed. Based on their independent measurements, the NRC came to the same conclusion. Direct radiation measurements of the area following removal of the excavated material were indistinguishable from background. More than 30 years have passed since then. Residual Co-60 has undergone nearly 6 half-lives diminishing its potential presence to a level well below detectability. Mn-54 and Cd-109 will have decayed by greater than 30 and 25 half-lives respectively such that those radionuclides are essentially no longer present. Any remaining activity due to Cs-137 will have decayed to a level consistent with background. The SONGS Annual Radiological Environmental Operating Reports (AREOR) for years have noted low levels of Cs-137 in soil samples for both indicator and control locations due to the deposition of weapons test fallout (and Chernobyl and Fukushima.) Those levels are typically a fraction of 1 pCi/g, for example, in the 2012 AREOR, the control location exhibited 0.25 pCi/g Cs-137. The 1981 radiological surveys at the Mesa Intersection were adequate to ensure that radiological conditions are indistinguishable from background. Further action is not necessary. Location b - Old Highway 101 Landfill Much of the discussion for the Mesa Intersection Event applies to the Old Highway 101 Landfill since both involved excavation from SONGS Unit 1 and the same instrumentation and methods were applied. The notable difference is that the Mesa Intersection involved known radioactive material while there was never an indication of contamination at the Old Highway 101 Landfill. Evaluation As detailed in Reference 1, upon discovery in 1981 that Unit 1 excavated material had been transferred there, a three-day effort was launched to obtain direct radiation measurements obtained with a Ludlum Model 19 micro-R-meter at 60 discrete survey points at the Old Highway 101 Landfill. All survey data was obtained with the meter on the slow response setting. The meter was held stationary at each survey point for 15 to 30 seconds to provide stable and reproducible results. Those measurements revealed no evidence of radioactive contamination above the normal range for natural background radiation. Individual Task Assignment (ITA) #84311 describes a 1984 confirmation of the conclusions reached in the 1981 survey effort. Also in 1981, three samples of the transferred material were obtained and sent to an off-site vendor laboratory for GeLi radiometric analysis. Naturally occurring radon and thoron 4

daughter products were detected in all three samples. The samples showed no cobalt or cesium activity above an LLD of 0.01 pCi/g. Strontium-90 was observed in two of the samples but at environmental levels. One sample showed 0.02 +/- 0.01 pCi/g and the other 0.04 +/- pCi/g. Sr-90 is similar to Cs-137, in that it is commonly found in soil samples for both indicator and control locations due to the deposition of weapons test fallout (and Chernobyl and Fukushima.) SONGS AREORs show detected Sr-90 levels in soil samples from both indicator and control locations over the years 1981 to 1984 in the range of 0.02 to 0.05 pCi/g. The 1981 direct radiation survey was professionally conducted, extensive, and thorough. It was accompanied by off-site analysis of the three soil samples that found no plant produced radioactive activation or fission products using appropriate LLDs. The 1981 radiological survey effort for the Old Highway 101 Landfill was adequate to ensure that radiological conditions are indistinguishable from background. Further action is not necessary. CONCLUSION The 1981 radiological surveys performed for Locations a & b, Mesa Intersection and Old Highway 101 Landfill, respectively, were adequate to ensure that radiological conditions are indistinguishable from background. Further action is not necessary. Addendum Prepared by: April 28, 2014 Reviewed by: Approved by: Chris Ahola, CHP, Radiation Protection Manager cc: T. Adler J.A. Madigan J.Janke J.B. Moore (BHI) COM MEMORANDUM FOR FILE 10/7/2015

SUBJECT:

MESA Radiological Report Support Documentation The folder with the file name "Redacted docs" contains nineteen portable document files that included two Action Requests (AR's), seventeen Individual Task Assignments (ITA's). All portable document files have had the following information redacted:

• Personally Identifiable Information (PII)
• Health Insurance and Accountability Act of 1996 (HIPPA)
• Signatures
• Initials
• Social Security Numbers
• Names and addresses of non-Edison businesses BHI Energy and Power Services

Action Request Assignment Report Date Printed: 03/26/14 14:23:40 Root Cause Evaluation Action Request#: 010901163 ** 06 Permanently Closed

• Migrated to NDMS Assignment Type: RCE Resp Org: H3000 Category: 90 CLOSED Priority: 3A Assignee: Forecast Date:

Reference:

MATL RELEASE Due Date: 09/30/03 Owner: Health Physics Human/Programmatic Perf: l2?J Common Ca.use: l2?J Implementation Awaiting Equipment: l2.$l Event

Title:

CCE

• ROOT CAUSE INVESTIGATION OF STATION'S MATERIAL RELEASE PROGRAM General Tab Information:

Originator: H4000 86164 Added: 11/1/2001 13:34: Updated: PHAMLQ 9/23/2003 07:20: Problem

Description:

NOTIFICATION TEXT** CONDUCT A ROOT CAUSE INVESTIGATION OF THE STATION'S MATERIAL RELEASE PROGRAM WITH REGARDS TO THE RECENT EVENTS ASSOCIATED WITH THE CONTAMINATED ITEMS FOUND IN AND OUTSIDE OF THE PA. DESCRIPTION** INVESTIGATE LOW LEVEL CONTAMINATED EQUIPMENT FOUND IN THE U2,3 RESTRICTED AREA; REFERENCE AR 010900750, 010901104, 011000911, 011000755. Reference Tab Information: Description Material Release Program Text Tab Information: EVALUATION*********************--*******--*************** DESCRIPTION OF PROBLEM: In September/October 2001, SONGS personnel identified four Instances of radioactively contaminated tools (tools and equipment) outside the Radiological Controlled Areas (RCAs ). One of the Instances Involved two small hand tools (pliers/side cutters) found at the MESA and outside the Restricted Area/Protected Area (RA/PA). The other three Instances involved tools outside the RCA but Inside the RA/PA. On 11/16/2001, a vendor identified the receipt of a contaminated Unit 1 pipe cutter at their facility that had been released as free from detectable activity from the SONGS Unit 1 RA/PA. A subsequent search in November 2001, as a part of this root cause evaluation, revealed eight Instances of magenta tools (non-contaminated) outside the RCA but Inside the RA/PA. These events did not meet management expectations cited in Health Physics Procedure S0123.Vll-20.9.2 "Material Release Surveys" which calls for HP evaluations of tools released from RCAs and Radiological Material Areas (RMAs) to ensure the absence of detectable radioactivity. The inadvertent release of the two small hand tools and the Unit 1 pipe cutter outside the RA/PA had regulatory significance as violations of Site procedures, but were not reportable. The radiological significance of these events was low, In that the tools discovered had low levels of fixed activity and no detectable removable activity. Given the low levels of fixed activity, the potential for measurable radiation exposure or an uncontrolled spread of radioactivity was low. ROOT CAUSE ANALYSIS (Including background Information, the sequence of events, the evidence/facts): Background Information Restricted Area/PA: At SONGS the main Units 2/3 Protected Area is also a Restricted Area as defined in 10 CFR Part 20. At the adjacent Unit 1 property the industrial Area is a Restricted Area. An additional Restricted Area Is located at the South Services Repair Center (SSRC.) RCNHot Tool Crib: The three main RCAs at SONGS are at Units 2/3, Unit 1, and the SSRC. Hot tools Page 1 of 13

Action Request Assignment Report Date Printed: 03/26/14 14:23:40 cribs, where RCA tools are issued, are provided at Units 2/3 and Unit 1. Satellite RCA: Several Areas containing radioactive material exist outside of the main RCAs. An example Is the auxiliary feedwater buildings, in which the Refueling Water Storage Tanks (RWST) are located. Radioactive tanks, pipes, and sumps physically located outside the main RCA pose a contamination control challenge. RMA/CA Area: Radioactive Materials Areas (RMA) are posted locations containing licensed radioactivity above a certain minimum quantity. Contaminated Areas (CA) are areas containing loose, removable contamination. Magenta Tools: Hand tools, power tools, cords, hoses, and safety equipment used In areas containing radioactivity are marked magenta for contamination control purposes. They are Intended to be used only In the RCAs and satellite RMAs. Method of Analysis An Interdisciplinary team performed Process Failure Analysis (PFA) to examine the HP Material Release Process. Team membership included HP Self Assessment (Leader), HP Technical Support, HP Line Supervision, Security, Maintenance, Facilities Maintenance, NORAD, and Programs & Assessment (Coach). The team held frequent meetings to develop actions plans, status actions, clarify process requirements, and formulate new action plans. Upon completion of the actions, the teams reviewed the processes and performance, and Identified failure modes and predominant failure modes. During the course of these activities, the team:

- Generated a process map covering RCA Magenta Tool Release Controls, RCA Non-Magenta (Clean) Tool Release Controls, and PA Tool Release Controls.
- Reviewed procedures 80123-Xll-20.9.2, S023-Vl-5.3.5 and HP Standard 8-10.
- Reviewed 2001 AR ACE/TND data.
- Interviewed workers/supervisors from HP, Security, and craft groups.
- Performed plant walkdowns of Unit 1, Units 2 and 3, and the SSRC .
. Observed release process evolutions at Unit 1, Units 2 and 3, and the SSRC.

Process Failure Analysis Results RCA Magenta Tool Release Controls

• Stage 1: Workers obtains magenta tools from the RCA Hot Tool Crib
• Stage 2: Workers use magenta tools at Job site
• Stage 3: Workers return tools to RCA Hot Tool Crib Result for Stage 3: Workers return tools to RCA Hot Tool Crib Workers are required to return magenta tools to RCA Hot Tool Crib. However, contrary to this requirement, 12 of 13 identified problems involved the failure of workers to return magenta tools. The problems Include:

- Lifting Shackle: On 9/18/01, a turbine group craft worker reported to Health Physics that he had found a magenta lifting shackle In box of turbine lifting equipment just delivered from the SSRC storage yard.

HP surveyed the shackle, locating a 500 ccpm spot. It is unl<nown how long the box was stored at the SSRC, when It was last used inside the Restricted Area, or where the box was specifically used when last in the Restricted Area (Reference AR 01090075.0.)

- 02 Monitor: On 10/14/01, a magenta 02 monitor with a 200 ccpm spot was discovered In the K-20 l&C                ~             .V shop. The 02 Monitor was Incorrectly turned In to the K-10 tool room Instead of having been turned into               I\ 11J?, 1 the Hot Tool Room. No Tool Attendant recalls accepting the magenta 02 monitor at K-1 O (Reference~ AR/

011000755.)

                                                                                                                ~J#
                                                                                                 / ' ....-

• Mesa Tools: On 10/31/01 a bag containing three mage t-a-'tmi'rato6Tswas-eltirm.wered*fA4',Et'G-44 Mesa paint shop. A set of pliers read 250 ccpm, and a set f sldecutters read 2.0 nCi by SAM-9.')The other

'-;:;;----;:-- ;;-:-;:------ --------"'"-= =:::--=..;;: :;;;.,.=-~-__ ,; _ _ _ _ _ _ __ Page 2 of 13

Action Request Assignment Report Date Printed: 03/26/14 14:23:40 magenta tool contained no detectable activity (Reference AR 011000911.) - November 2001 Search Items: A search In November 2001, as a part of this root cause evaluation, located eight non-contaminated magenta tools outside the RCA but inside the RA/PA. The procedure reviews, interviews and observations revealed that RCA tools are Issued from hot tool cribs located In the Unit 1 and Un'1ts 2/3 RCAs. Magenta tools are checked out the RCA via a "conditional release" process for work performed in satellite RMAs. Returning tools to the RCAs after work Is solely the responsibility of workers. There are no process controls to ensure tool return, such as logging the tools In and out by unique serial number. Radiation workers are permitted to escort tools to and from satellite areas themselves. There Is the potential for workers to Inadvertently move magenta tools outside the RCA. The current checkout process Is patterned after programs observed at other plants during 1998 material release program benchmarking trips. While successful at other plants with very few satellite RMAs, the check out process has been less than successful at SONGS. Some magenta tools are not clearly marked, making It difficult to recognize them, especially in poor light conditions and when they are mixed with (or underneath) non-magenta tools In buckets/boxes. After multiple uses and cleanings, the paint can diminish and become difficult to see. At this time, some tools have little to no magenta paint. This increases the probably of workers not returning the tools. There is also no established protocol on how to mark tools magenta or how to maintain the markings over time. At times many common hand tools are checked out of the RCA for extended periods of time due to the number of satellite RMAs requiring tools and the length of the Jobs. Large numbers of tools are used In satellite RMAs where little potential for contamination exists. This volume of tools going In and out of the RCA Is difficult to manage and, again, Increases the probability of workers not returning tools. Predominant Failure Mode 1: Workers do not always return magenta tools to RCA Hot Tool Crib. RCA Non-Magenta (Clean) Tool Release Controls

- Stage 4: Worker requests HP Survey
- Stage 5: HP Technician (HPT) Dispositions Tools for Survey
- Stage 6: HPT Surveys Tools
- Stage 7: HPT Authorizes Tool Release One event Involved discovery of a contaminated tool Inside the Restricted Area which was not color-coded magenta, and thus may have been inadvertently released from the RCA.
- Harness: On 9/24/01, a MSG craftsperson brought a safety harness to the K-1 Otool room HP Technician for release from the Restricted Area. The harness had been Issued a week earlier from the K-10 clean toolroom, and had been used atop a manllft In painting a turbine crane boom. The SAM-9 alarmed and a 200 ccpm spot was Identified using a frisker. It Is not known when the harness may have been used In the RCA, or how or where It may have been released (Reference AR 010901104.)

The procedure reviews, assessment of event data, Interviews and observations did not any other recent problems with RCA Non-Magenta (Clean) tool release controls. There Is no Indication of a process problem and no further corrective action is warranted at this time. PA Tool Release Controls

- Stage 8: Worker request release of tools from PA
- Stage 9: HPT dispositions tools for survey
- Stage 1O: HPT surveys tools
- Stage 11: HPT authorizes tool release
- Stage 12: HPT quarantines Items awaiting transport
- Stage 13: Security confirms HP Survey Prior to Release at Hold-Downs Results of Stage 8: Worker request release of tools from PA Page 3 of 13

Action Request Assignment Report Date Printed: 03/26/14 14:23:40 Workers are required to request an HPT to release tools from the RA/PA. However, contrary to this requirement, there was a near miss identified Involving the failure of a worker to contact an HPT. On 01/01/01 a Bechtel carpenter was observed attempting to leave the Restricted Area via the south Security Processing Facility (SPF) with bags of new bolts which he assumed did need to be surveyed prior to release (Reference AR 010100381.) Failure Mode: Worker Inadvertently attempts to exit without tool survey

• This failure mode (near miss) occurred once In the search for material release problems. It was an Inappropriate action by an Individual worker. The problem was evaluated and corrected under the referenced AR. Based on procedure reviews, assessment of event data, interviews and observations, there Is no Indication of a process problem and no further corrective action is warranted at this time. This Item is discussed further In the Improvement Items section of this report.

Results for Stage 1O: HPT surveys tools Tools and equipment exiting the Restricted Area must be evaluated by qualified HP personnel to ensure the absence of detectable activity. However, contrary to this requirement, Unit 1 Health Physics Technicians surveyed and free released from the Site a Unit 1 Decommissioning Project Tri-Tool 36" clamshell pipe cutter which was subsequently discovered to be contaminated. On 10/3/01 the Unit 1 Tri-tool, following extensive decontamination, was released and shipped back to the Sacramento-area tool vendor. The vendor frisked the "clean" tool upon receipt, finding three spots of detectable contamination in his 25 cpm background. When returned to SONGS, the tool was confirmed to have four spots of fixed contamination near the limits of detectability by direct frisk, as well as a Co-60 particle. Investigation determined that the releasing HPTs had failed to thoroughly survey the tool, mlscommunlcating among themselves and supervision as to who had surveyed what, and how thoroughly, Failure Mode: HPT falls to adequately survey equipment

• This failure mode occurred once In the 14 identified material release problems. It was an inappropriate action by a pair HPTs. They did not ensure that the Tri-tool was thoroughly surveyed in a low background area before releasing It. The problem was evaluated and corrected under AR 011000911.

Based on procedure reviews, assessment of event data, interviews and observations, there Is no indication of a process problem and no further corrective action is warranted at this time, Results for Stage 12: HPT quarantines items awaiting transport HPT surveys tools and authorize release. However, based on procedure reviews, Interviews and observations, a potential process problem does exist that warrants cause/corrective action. If a worker request the release of tools and the HPT surveys and releases the tools, the tools may sit unattended in the RNPA pending transport out of the RA/PA. While unattended, the items could get mixed with other Items that have not been evaluated for release. The Mesa paint sprayer pallet tools event appears to be an example of this Issue. The releasing HPT properly surveyed all of the equipment on the subject pallet on the afternoon of 10/11 /01. Because he had no area to loci< the pallet, he wrote his name and the date on piece of masking tape, affixed the tape to the bulldog sprayer, and left the pallet unattended until It was transported out of the Restricted Area the next day. It is likely that the bag of magenta tools, improperly removed from the RCA by some unknown route, was inadvertently placed on the pallet after the HP left. Once materials are surveyed In the field, the Technician must either control or quarantine the load until It Is removed from the RA to ensure no unsurveyed material is added to the load. At Unit 1 a lockable quarantine area is provided for this purpose. No quarantine area is provided at Units 2/3, causing the Technicians to mark the load with tape, recheck loads later, or rely on word of mouth to ensure compliance. Failure Mode 1: HPT does not adequately quarantine evaluated tools/materials. Page 4 of 13

Action Request Assignment Report Date Printed: 03/26/1414:23:40 Results for Stage 13: Security request and HPT confirms survey of tools prior to transport out hold-downs Security is required to confirm HPT tool surveys prior to release. When the load Is trucked out of the RA/PA, Security Officers are directed to ensure that HP has approved the release by direct communication. However, based on procedure reviews, assessment of event data, Interviews and observations, direct communication does not always occur. HPTs survey and evaluate hand carried and vehicular loads, logging releases and communicating concurrence to the nearby Unit 3 hold down Security Officers. During interviewees, personnel Indicated some deviations occur In which loads are released on word of mouth, phone call or written note. The Mesa tools event appears an example, In which a pallet of painting equipment was surveyed, marked by the HP with tape rather than quarantined, and removed from the Restricted Area the next day without further HP concurrence. Predominant Failure Mode 2: HPT does not provide real time verification/face-to-face confirmation prior I to tool release at hold-downs. ROOT AND CONTRIBUTING CAUSES: There are two predominant failure modes/causes that result In the majority of material release problems. First, there are inadequate process controls to ensure the return of magenta tools back to the RCA after use and, secondly, there are Inadequate standards for HP to verify confirmation of tools prior to release/transport from hold-downs. Another failure mode/cause involves the lack of quarantine areas in Units 2/3 to assist HP in maintaining control of tools prior to release/transport out of holddowns (RA/PA boundary.) Predominant Failure Mode 1: Workers do not always return magenta tools to RCA Hot Tool Crib. Root Cause 1: Program Management/Other - Inadequate Process Controls: The process controls for the release/return of magenta tools are Inadequate The failure to return magenta tools to the RCA Is the result of not having adequate process controls to ensure that tools released from the RCA are returned to t11e RCA. The process relies solely on workers to remember and implement the rule to return magenta tools and, although the failure rate Is relatively low, Its is unacceptable for this activity. Management's expectations are to have no magenta tools Inadvertently get outside the RA/PA or get misplaced within the RA/PA. In addition, there is no established protocol on how to mark tools magenta or to maintain the markings over time. After multiple uses and cleanings, the paint can diminish and become difficult to see. For some tools, It is likely that the worker may have never recognized that the tool was a magenta tool for return to the RCA. To Improve performance it will be necessary to improve the controls over the release/return of tools from the RCA, and to improve the markings on tools (Reference CA 1-5.) Predominant Failure Mode 2: HP does not provide real time verification/face-to-face confirmation prior to tool release at hold-downs Root Cause 2: Inadequate Procedure/Inadequate Information: The standards and facilities for verifying confirmation of tools prior to release/transport are inadequate. The few, but more significant problems, Involving contaminated tools leaving the RA/PA is the result of a lack of standards/formality In the conduct of HPT activities when confirming surveys prior to release/transport. The final barrier to tools leaving the hold down (RA/PA boundary) Is a reliance on Security to confirm HP survey prior to release. Given the duties/training of Security Officers, It Is realistic to limit their function to simply contacting an HPT. The HPT should then conduct all activities necessary to ensure proper survey/release at the point of survey/release. To ensure consistency In Implementation, there will need to be more detail and clarity In existing procedures (Reference CA 6.) Also, the establishment of quarantine areas, as discussed below under Failure Mode 1, will Improve Implementation (Reference CA 7.) Failure Mode 1: HPT does not adequately quarantine evaluated tools/materials. Page 5 of 13

Action Request Assignment Report Date Printed: 03/26/1414:23:40 Apparent Cause 1: Program Management/Other - Inadequate Process Controls - No quarantine areas In Unit 2/3 to assist HPTs In the quarantine of tools/materials The Material Release Program relies on HP Technicians to assure that tools/materials are evaluated prior to transport out of the hold downs (RA/PA boundary), but does not provide quarantine areas to assist in them Is quarantining tools/material until transport. Also, the roving Restricted Area material release HP Technician answers requests to release tools and material from the Restricted Area. A logbook, I instrument cabinet, and SAM-9 are located in the K-10 foyer, but the Technician has no workstation in the field. He writes his name and beeper number on a nearby whiteboard and answers pages throughout the dayshlft. Establishing work areas (quarantine areas) would assist HPTs In conducting business. It would be prudent to establish quarantine/work areas (Reference CA 7.) RADIATION PROTECTION/ REGULATORY SIGNIFICANCE The radiological significance of the SONGS events was low. Magenta tools found In the Restricted Area do not meet Program expectations, but are not precluded by the Material Release procedure. Each of the contaminated tools discovered In the Units 2/3 Restricted Area contained only very low levels of fixed activity. No removable activity was detected. The potential for measurable radiation exposure or the uncontrolled spread of radioactivity was therefore low. Radioactively contaminated items discovered outside the Restricted Area are significant. The small hand tools discovered at the Mesa, and a previous event In November 2000 Involving a work boot (AR 001100473) released offslte have regulatory significance. The Inadvertent release of licensed activity outside the Restricted Area is contravenes procedural and regulatory requirements. The dose impact was calculated for each Incident in which detectable radioactive material was discovered outside the Restricted Area. In each case calculated doses were well below 0.005 Rem total effective dose equivalent. Dose calculation documentation is on file with SONGS Health Physics Technical Support. GENERIC ISSUE EVALUATION: A generic Issue involves the potential for other material release problems given the root causes Involving the adequacy of process controls for the release/return of magenta tools and the standards for verifying confirmation of tools prior to release/transport. However, the extensive efforts during this evaluation Involving searching the AR data base and site wide work areas flushed out previously not Identified problems (8 Instances of magenta tools outside the RCA but Inside the RA/PA). Regarding the potential for other radiation release process weal<nesses, none were Identified during the procedure reviews, interviews and observations conducted as a part of this evaluation. INDUSTRY/SITE EXPERIENCE EVALUATION: Site Experience Before 1999 In June 1998 Common Cause Evaluation 980603570 was documented to examine four contaminated Items found outside the RCA from 3/31/98 to 6/1/98. Two magenta tools, a ladder, and waste gas sample pump parts were Involved. Although no common cause was Identified, It was clear there were worker knowledge/accountability Issues, and the corrective actions were fashioned primarily to address those issues. Those actions Included:

  - Clarification and training on proper SAM-9 use.
  - Sltewide Intranet training module on tool control and material release rules.
  - Test a pilot magenta tool checkout program for satellite RMAs.
  - Run a material control video at control points.
  - Create an HP Material Release Standard to clarify program expectations.
  - Hold an HP Division Material Release standown.
  - HP Manager train site supervisors and managers during July 1998 Mgt. Retraining.
  - Enhance CBT by adding RCA tool control rules.
  - Contractor workforce standown 12/16/98. Hot topics training Dec. 1998.
  - QA surveillance SOS-043-98.
  - Reconfigure the SSRC RMA.

Page 6 of 13

Action Request Assignment Report Date Printed: 03/26/14 14:23:40 The corrective actions to address the worker knowledge/accountability Issues along with continuing communications appear to have been effective. In conducting employee Interviews, the 2001 PFA team found that HPs, Security Officers, and workers appeared to have a good understanding of the Material , Release Program rules. Workers know that magenta tools are for RCA/RMA use only, that all materials are

• required to be surveyed by HP for RCA removal, and that all tools and equipment removed from the Restricted Area must be approved by HP.

One 1998 pilot program in particular appears to warrant reexamination. Benchmarking of 11 material release programs in 1998 produced the trial of a "conditional release" program for magenta tools. Worl< Is performed In RMAs outside the main RCA with magenta tools. Before 1998 tools were bagged in the RCA and escorted by HP out to the satellite RMA, where the posting Indicated "HP approval required to remove any Items," At the conclusion of the Job, magenta tools were escorted back to the RCA. In 1998, use of the conditional release log was Instituted. All magenta tools were Itemized and logged out of the RCA In an attempt to maintain accountability. Escort rules were revised to allow workers to transport magenta tools without HP escort. Due to plant design, SONGS has numerous satellite RMAs. Radioactive areas outside the main RCA include Slowdown Processing Systems, the Aux. Feedwater Buildings, Tendon Galleries, and several other areas. Checking magenta tools out to those areas proved cumbersome and added little value. Tools are not serialized; thus it was impossible to determine if all of the right tools were eventually recovered. Although not conclusively determined, It Is believed that worker escorting and use of conditionally released magenta tools may be responsible for some of the observed errors since 1998. 2001 corrective actions will therefore terminate the conditional release program and the liberalized escorting rules. Magenta tools will only be used outside the RCA for contaminated area work, hopefully resulting In far fewer magenta tools used outside the RCA (Reference CA-3.) Site Experience Since 1999 On 11/1/00, a HPT released to a worker a decontaminated work boot. The boot was stored In the worker's truck for a few days before It was discovered that there was residual radioactivity (Reference AR 001100473.) Failure Mode: HPT failed to detect residual activity during survey.

  - This failure mode occurred once out of the thirteen Identified problems and was the result of an inappropriate action by an individual HPT. The HPT did not follow post decontamination survey procedures requiring that surveyed articles not be damp. The problem was evaluated and corrected under the referenced AR. There Is no Indication of a process problem, and no further action Is warranted at this time.

On 8/17 /00 a magenta utility knife was found on a picnic bench outside the Restricted Area near the AWS building. The knife did not contain reliably detectable activity, although It did alarm the SAM-9 on 2 of 5 tries. Investigation was unable to discover how the knife was removed from the RCA and Restricted Area. Most likely the knife was inadvertently carried out at lunch In a worker's pocket and left behind to avoid discovery upon reentering the Security Processing Facility. Failure Mode: Worker misjudgment in discarding knife Inadvertently carried out.

  - This failure mode occurred once In the thirteen events analyzed. The problem was addressed by publication and by unannounced Restricted Area exit Inspections (Reference AR 000800974.) There Is no Indication of a process problem, and no further action Is warranted at this time.

Recent Industry Experience At Callaway Station Inspectors in 2001 Identified that the licensee had not adequately surveyed Items released from the radiologically controlled area. This finding was a violation of 10 CFR 20.1501 (a). Page 7 of 13

Action Request Assignment Report Date Printed: 03/26/14 14:23:40 The inspectors Identified that the licensee had not evaluated personnel contamination monitors, portable frisking instruments, and tool monitors to determine their capability of detecting all radlonuclldes that could be released from the radiologically controlled area. Analysis of waste stream data confirmed that the primary isotope of interest in the waste stream was lron-55. Since lron-55 decays by electron capture and emits only a low energy x-ray, this makes It difficult to detect utilizing the licensee's Instruments. The licensee had not evaluated the ability of its personnel contamination monitors, portable frisking Instruments, and tool monitors to identify all radionuclides that might be present on items released from Its control. Without this evaluation, the licensee could not ensure that release surveys were adequately performed. The significance of this violation was determined to be more than minor, because it could be reasonably viewed as a precursor to a significant event and it involved an occurrence in the radioactive material control program. This violation was processed through the public radiation safety significance determination process and determined to be of very low safety significance (Green), because it did not result in public dose greater than 0.005 rem, and there were no more than five related events. Applicability to SONGS: The event Is applicable to SONGS In that SONGS uses similar instruments and also has electron capture Isotopes comprising a significant fraction of the waste stream. We have performed the required evaluations, however, to assure that the instruments used in performing material releases are adequate. IMPROVEMENT ITEMS The interviews, plant walk downs, observations and analysis by the RCE team reveal the following items for improvement: Item 1: Evaluate slgnage for RMA exits to prevent inadvertent removal of tools. - RMA postings prohibiting removal of items are visible upon entry to the area. It may add value to have a similar reminder visible on the bacl<slde of the sign, facing the worker who is exiting the RMA (Reference Improvement Action 8.) Item 2: Evaluate Improving Restricted Area and Industrial Area exit signage and amnesty drums. - Tools and equipment require HP evaluation for release from the Restricted Area at SONGS; a release barrier outside the RCA employed at SONGS and only a few other plants. Slgnage at the Restricted Area pedestrian exits reminds workers to contact HP if removing tools or equipment from the Restricted Area. Tool amnesty drums are provided Into which workers may deposit tools which require HP survey for removal from the Restricted Area, but which the worker need not actually remove. Most tools and equipment removed from the Restricted Area exit via the vehicle gates. Security Officers man the gates, and are directed by procedure to ensure that tools and equipment leaving the Restricted Area have been evaluated by Health Physics. Workers and Security Officers appear to have a good working knowledge of the rules. (Reference Improvement Action 9.) item 3: Evaluate the applicability of available large area probes and bag monitors to the Material Release Program.

- Conventional GM frlsl<ers and scintillation tool monitors are used in the material release program.

Large area probes and bag monitors may offer improved performance In some situations. (Reference Improvement Action 10.) Item 4: Evaluate and eliminate, if practical, candidate satellite RMAs.

- The existence of satellite RMAs challenges contamination control efforts. While most satellite RMAs exist by plant design, it Is possible that concerted effort may eliminate one or two existing satellite RMAs (Reference Improvement Action 11.)

Item 5: Prohibit free release of clean common hand tools from the RCA .. Page 8 of 13

Action Request Assignment Report Date Printed: 03/26/14.14:23:40 - Workers exiting the RCAs self-survey hand carried personal effects using the SAM-9 tool monitor. Tools and equipment are presented to HP for release at the RCA control points and at the Units 2/3 truckbay. Materials are surveyed using the SAM-9 and friskers, and are released If no detectable activity is found. Common hand tools are presently free released from the RCA with supervisory concurrence. If no common hand tools were released from the RCA, challenges to the release program would be fewer (Reference Improvement Action 12.) COMPLETED CORRECTIVE ACTIONS (Reference the tracking document): On 11 /2/01 the following Interim corrective actions were Implemented by sltewide communication: - Hand tools will not be released from Radiologically Controlled Areas. Exceptions require HP Manager approval. (Tracking Document: No exceptions approved through 12/07/01.) - Other materials, tools, and equipment submitted for release from the Restricted Areas or the Units 2/3 truckbay will be subject to second checks by qualified HP Technicians. (Tracking Document: Material Release Logbooks.)

- Division Managers will coordinate searches of all SONGS' shops, tool boxes, laydown areas and offices for magenta tools adrift outside approved Radioactive Materials Areas. (Objective Evidence of Completion: AR 010901163, assignments 7-28.)

Reference:

E-Mail, from HP Manage,. I [I o Site Personnel, dated 11/2/01,

Subject:

Material Release Restrictions (See Notes tab for copy): PLANNED REQUIRED CORRECTIVE ACTIONS [must be linked on CA Tab]:

1) Develop and implement standardized RCA tool marking protocol to conspicuously Identify RCA tools (CA for Root Cause 1).

2) Revise 80123-XV-30 to incorporate magenta tool program responsibilities presently carried in HP procedures (CA for Root Cause 1).

3) Revise appropriate HP program documents and training materials to specify magenta tools use in remote contaminated areas only (CA for Root Cause 1).

4) Revise appropriate program documents and training materials to require HP escort of magenta tools used outside the main RCAs (CA for Root Cause 1).

5) Prohibit the release of common hand tools from the RCA (CA for Root Cause 1).

6) Revise appropriate HP and Security procedures to require face-to-face HP concurrence for release of tools and equipment, subject to reasonable exceptions, from the Restricted Area (CA for Root Cause 2).

7) Provide Material Release quarantine areas and workstations near the U3 vehicle exits (CA of Apparent Cause 1).

OTHER ACTIONS NOT REQUIRED AS DEFINED PER S0123-XV-50: Improvement Items:

8) Improve slgnage for RMA exits to prevent inadvertent removal of tools.

9) Improve Restricted Area and Industrial Area exit slgnage and amnesty drums.

10) Make available large area probes and bag monitors to the Material Release Program where practical.

11) Evaluate and eliminate, If practical, candidate satellit~ RMAs.

Approval Tab Information: Code To Status From By Timestamp Pax CHG,RESTR 9/23/2003 14: 11 :43 AR Restraint has changed for assignment: 6 Type: RCE old value was "O.O" A 90 80 9/23/2003 14: 11 :36 86164 A 80 50 SYSTEM 9/23/2003 07:20:31 Child assignments closed DASSOC .. I 8/13/200311:47:22 Disassociated assignment AR#: 010901163 Seq: 56 Page 9 of 13

Action Request Assignment Report Date Printed: 03/26/14 14:23:40 Code To Status From By Tlmestamp Pax CHG*RQD Ii J *

• 8/13/200311:47:08 Basis for Assignment Required status change: this CWO (MO assignment #66) has been superceded by the OWO of assignment #60 (per K, Weiss) #60 Is now linked, will unlink #56 CATAB 811111:..._ 8/13/200311:46:02 REQUIREDJLAG was changed by: llaitild value: Y new value: N Assoc a IFII It 8/13/2003 *11:46:37 Associated assignment AR#: 010901'163 Seq: 60 CHG-DD Ill II 1111 6/26/200312:10:36 Due date not valid, clue d~1te reassessed by assignee/supervisor (describe In COMMENTS)

CHG*OD 01 6/25/200312:10:36 Due Date has changed for assignment: 6 Type: ROE Old value was "4/15/2003 00:00:00" CHG*DD IIP (1111 6/26/200312:10:36 Due date established to match sub-assignments 55 & 66 of this AR, ASSOC 3/26/200310:33:67 Associated assignment AR#: 010901163 Seq: 58 DASSOC 3/26/2003 10:33:23 Disassociated assignment AR#: 010901163 Seq: 58 CHG-RQD d Jb 3/26/2003 10:33:10 sasls for Assignment Required status change: need to temporally disassociate assignment to fix ar assignment screen display to eliminate secondary linkage to oaf 1;1nd associate properly to RCE CA TAB [ ** 3/26/2003 10:33:03 REQUJRED_FLAG was ch1;1nged by: S z  ? ,Id value: Y new value: N ASSOC all I'. IZI 3/26/200310:31:47 Associated assignment AR#: 010901163 Seq: 66 DAS SOC $ fl J 1111& 3/26/2003 10:31 :05 Disassociated assignment AR#: 010901163 Seq: 56 CHG*RQD ., JI.: 3/26/2003 10:29:19 \ Basis for Assignment Required status change: need to temporally disassociate assignment to fix ar assignment sc1*een display to eliminate secondary llnk1;1gt1 to oaf and associate properly to RCE CA TAB

• H 3/26/200310:27:18 REQUIRED_FLAG w1;1s changed by: 713 7
• a old value: Y new value: N ASSOC I 11 I 7 3/26/2003 09:57:18 Associated assignment AR#: 010901163 Seq: 58 ASSOC l 11 Fil 3/26/2003 09:56:32 Associated assignment AR#: 010901163 Seq: 57 ASSOC di 111 b 3/26/2003 09:66:21 Associated assignment AR#: 010901163 Seq: 56 ASSOC
• IIJ5Ja 3/26/2003 09:56:06 Associated assignment AR#: 010901163 Seq: 55 cHo-cE *u, 1 3;*181200314:46:58 Implementation Awaiting EqL1lpment has changed for assignment: 6 Type: RCE old value was "N" CHG,DD 2/24/2003 07:23:25 due date extended lo meet Layclown sub-assignment closure date, CHG-DD er I 2/24/2003 07:23:25 Due Date has changed for assignment: 6 Type: RCE Old value was "2/24/2003 oo:00:00" CHG-DD ... *
• 2/24/2003 07:23:25 Page10of13

Action Request Assignment Report Date Printed: 03/26/14 14:23:40 Code To Status From By Timestamp Pax CHG-DD 12/19/2002 08: 13: 16 CHG-DD UIIII II 12/19/200208:13:16 due changed to reflect assignment time frame to complete laydown ar assignment; temporary quarantine area at U2,3 constructed to receive materials l11'~if'i"';,'ll1i,r1or to release from the site CHG*DD ...... 12/19/2002 08:13:16 Due Date has changed for a s s l ~ : ROE Old value was "12/30/2001 00:00:00" EST-DD 12/2/2002 15: 17:46 Due Date has changed for asslgn~J:;.(l;,if~: ROE Old value was "4/30/2002 00:00:00" EST*DD * $ 12/2/2002 15:17:46 Interim U2,3 quarantine area estabJJs,hed Jor..m.aterlal release program. Remaining ROE action will close pending management review of ROE corrective actions; ROE extened pending this review. EST-DD 11111n IL 12,21200215:17:46 CHG-RESTR ...... 10/30/2002 09:27:22 AR Restraint has changed for a s ~ y p e : ROE old value was"" A1 50 45 11 1*11 Re-Opened ROE and associated as"ste'rinien ii"'#47 and #49 1013012002 09:26:54 89485 Assoc 11n a* Associated assignment AR#: 01090'1~3 Seq:4a'g 10,30,2002 09:25:57 Assoc as: r Associated assignment AR#: 010901J,).J,S.W]o147 1013012002 09:25:24 CHG-RESTR 10/30/2002 09:24:52 AR Restraint has changed for assign'1',Js.Rt:,&..;r;..y.pei ROE old value was "" D2 45 90 ffl Ill p 10/30/2002 09:24:14 89485 Re-Opened to Incorporated commep.t.c,.fr0tl'\-OA¥, (Asmgt 45). A 90 50 Child assignments closed, CHG-RESTR 12/18/200114:16:42 A 50 40 12/18/200114:16:29 87780 CHG-RES TR 12/14/2001 13:09: 19 AR Restraint has changed for assignment: 6 Type: RCE old value was ""

                                                .... ,;*** ;~:.,,.:<

A 40 30 [ p 12/14/200113:09:12 86661

                                                ,..,,,_           . .',i\Ml\\*

CHG-RESTR 5Lf 12/14/2001 09:43:41 AR Restraint has changed for assignment: 6 Type: ROE old value was ""

                                                ;,, ** ,.       I   i.ftiil,~*,,

A 30 20

• b 12/'14/2001 09:43:33 86164 CHG-RESTR  :* [ I 12/14/2001 09:43:29 AR Restraint has changed for assignment: 6 Type: RCE old value was ""

as 1

                                                    ~ 1 .. 1<;,.;,>;;,,1 __!;,'.~

A 20 10 s 12,1412001 09:43:14 86164 Page 11 of 13

Action Request Asslgnmor1t Report

• De1le Prlr1ted: 0(~/26/1414:23:40 Gode lo Status rrom By 'flm~swm~ Peix CHG-RE!STR 11awa:1 r *\*l/1/200113:34:37 AR Restraint he.a ohang0<1 fol' asa\gnrnenll 6 Type: RCE old value was "null" Notes Tub Information:

Reference:

Copy of ic:"ME\11 from HP Mam1ge1 Site Personnel as Interim Correotlve Aotlon: l~f PJr~l~fJIR~~~'.g~a~ii*Y*SONGS

*11/02/01 05:33 PM 81',S PSR80NNBL Oontarnlne\ted rnc1gc1nta toola heve been dlsooverecl adrift outsld@ Recllolloally Controlled Areas (ROAs) on thre0 separn\a oooaslons In the last six woel<S. The third lnoldent oomirred this weak, with the discovery of a bag containing several oontemlnated magent1:1 hand tools at a Mesa craft shop, Interim oorreotlva actions Implemented Immediately prevent further errors lnolL1de:                                                                                                       to Hanel tools will not be released from Racllologlo~lly Controlled Areas, Exceptions require HP Manager approval.

Other m~1terlmls 1 tools, 1:mcl equipment submitted for release from the Restricted Areas or the Units 2/3 truol~bay will subject to second oheoks by qualified HP Teohnlolans, b,1 Division Managers will coordinate searches of all SONGS shops, tool boxes, Jaydown areas and ()frloes for magentti tools adrift outside approved Radioactive Materials Areas. Control of radioactive rnaterl.1ls In general, f.tnd magenta color ooded "hot tools" In speolflo, Is essential. Your ooopera\lon In tightening existing and Interim controls Is appreciated, Questions regarding the release of tools or material from the RCA or the Restricted Area/Protected Area should be directed to the HP Control Point a t -

-~*i,~*~l tl~y_slo _s_

CA Tab Information: AR/SEQ/TYPE l'{osp Org AssJgnaa Due Date Status QA REQ ~rlor\ty MO 'JYpe 0 010901163 48 OAF 0 N240o ....... Iii .11/15/2002 90 N 3A PElRFORM INT8RIM OAF TO vgR\PIY Eil~FeOT\VSNSSS OF OOMPLE:TED INTERIM ACTIONS TO PREM:lNT REOURR8NOI::, (ROOT OAUSS INVSSTIGATION OP S'TATION'S MAT13RIAL RELEASE PROGRAM) 010901163 30 0TH H3000 . . ,l!i.l 04/12/2002 90 DEV8LOP AND IMPLF.!MEN'r STANDARDIZSD ROA TOOL. MARl<ING PROTOCOL. TO Y 3A CONSPICUOUSLY IDF.!NTIFY ROA TOOLS (OA ,~oR Roo*r GAUSS 'I). 010901163 31 PRO H3000 811 Jftllll 04/12/2002 90 Y 3A RSVISEl 80123-XV*30 TO INCORPORATE: MAG8Nl'A TOOL. PROGRAM RE8PON8\BII.ITl8S PR\38SNTLY OARRll:!D IN HP PROCEDURGS (CA flOR ROOT OAUS8 1). 01090*1163 32 TRN H3000 lliiillt 111111 04/'12/2002 90 Y 3A REVISE APPROPRIATE HP PROGRAM D00UMSNT8 AND TRAINING MATERIALS TO SPE!O\PY MAGSNTA TOOLS use IN REMOTE CONTAMINATED ARE:AS ONI.Y (CA FOR ROOT CAUSE 1), 01090*1163 33 TRN 1-\3000 )][ IIIJII\ 04/'12/2002 90 Y 3A R8Vl8S APPROPRIATG PROGRAM DOOUMSNTS AND TRAINING MATERIALS TO REQUIRS HP l:!SOORT 01~ MAGBNTA TOOLS USISD OUTSIDE THE MAIN l'{OA8 (CA FOR ROOT OAU881), 010901163 34 0TH J-13000 (.f* . 04/'12/2002 90 Y SA PROJ-IISIT THl5 RELSA88 OF COMMON HAND TOOLS FROM THE RCA (CA FOR ROOT CAUSE 1), 01090*1163 36 PRO \-13000 * * *, 04/12/2002 90 Y 3A

6) REVISS APPROPl'{\A1E HP AND SECURITY PROOEDUR8S TO REQUIRE! FA0f.HO*FA06 HP OONCURRE:NOS FOR REL8ASS OF TOOLS AND 8QUIPMSNT, BU8d80T TO REA80NAB1.E EXCEPTIONS, FROM THE: RESTRIOTJW AREA (CA POR ROOT CAUSE 2),

01090116s 36 o*n-1 HGooo *IUIK 041*1212002 eo Y 3A

7) PROVIDE MAT8RIAL RELSASE QUARANTINE AR8AS AND WOR!<STATIONS Nl:!Ar{ 1HE U3 V8\-IICLI?. EXITS (CA Or APPARENT CAUSE 1),

Page 12 of 13

Action Request Assignment Report Date Printed: 03/26/14 14:23:40 CA Tab Information: AR/SEQ/TYPE Resp Org Assignee Due Date Status QA REQ Priority MO Type 010901153 47 LAY H3ooo s: 1 a 04,1512003 90 v 3C Notification text -- Non-outage laydown area requested per the referenced AR. Request approx. 10' x 20' fenced, gated HP Material Release quarantine area sited near the U3 LCS. Critical corrective action per the referenced RCE. DESCRIPTION-* INVESTIGATE LOW LEVEL CONTAMINATED EQUIPMENT FOUND IN THE U2,3 RESTRICTED AREA; REFERENCE AR 010900750 & 010901104. 010901163 49 EEB c21 oo a z )2/24/2003 90 v 3C Notification text-* Engineering modification request for Gatekeeper review and processing. Need Engineering approval to erect 12' x 20' chain link fence HP Lockdown area Just south of the Unit 3 HUT. Laydown request has been approved by all affected parties. DESCRIPTION** INVESTIGATE LOW LEVEL CONTAMINATED EQUIPMENT FOUND IN THE U2,3 RESTRICTED AREA; REFERENCE AR 010900750 & 010901104, 010901163 55 ECP C2100 111 J E 09/30/2003 90 Y 3A NOTIFICATION TEXT** PROCESS ENGINEERING CHANGE IAW THE GUIDANCE OF S0123-XXIV-10.1 ERECT 12' X 20' CHAIN LINK FENCE HP LOCKDOWN AREA JUST SOUTH OF THE UNIT 3 HUT. REFER TO EEB ASIGNMENT 49. SEE NOTE TAB OF THIS ASSIGNMENT FOR ADDITIONAL INFO. DESCRIPTION** INVESTIGATE LOW LEVEL CONTAMINATED EQUIPMENT FOUND IN THE U2,3 RESTRICTED AREA; REFERENCE AR 010900750 & 010901104. 010901163 57 SCN 02100 II ]$01/06/2003 99 Y 3C Notification text -- Document 50,59 screening for the proposed change/activity DESCRIPTION -- INVESTIGATE LOW LEVEL CONTAMINATED EQUIPMENT FOUND IN THE U2,3 RESTRICTED AREA; REFERENCE AR 010900750 & 010901104, 010901163 58 SCN C2100 31[ J09/01/2003 90 Y 3A Notification text -- Document 50.59 screening for the proposed change/activity DESCRIPTION -- INVESTIGATE LOW LEVEL CONTAMINATED EQUIPMENT FOUND IN THE U2,3 RESTRICTED AREA; REFERENCE AR 010900750 & 010901104, 010901163 60 MO W0010 111818 09/19/2003 90 Y 4 CW Notification text -- Write CWO to supersede CWO 02120032000 for Implementation of ECP 010901163-55, Install HP Quarantine Fence DESCRIPTION*- INVESTIGATE LOW LEVEL CONTAMINATED EQUIPMENT FOUND IN THE U2,3 RESTRICTED AREA; REFERENCE AR 010900750 & 010901104.

                                                         ----- END OF REPORT *****

Page 13 of 13

_rC.= SONGS RADIOLOGICAL SURVEY j&'E DATE~l/01 ~ _ o f_ _ UNIT SURVEY REASON D l'o$t-Oecon D Pre-Job SURVEYNO. NO. -y a NO. -y a Massllm 0Routm._ _ D ShlpmenfJReceJpt MONO. D Job Coverage D SourcaJLeakTest REP NO. 0 Pwr En!IY.__% ~ Olher EQUIP.ID.

                                                                                                          "D1A.E:cr J-1.M'D 1<56LS.                 ~ D j,..,       rncsA.                            z.        fUK.           .:s-Ni'-.

11 ,..J

             *-10                                                                 -<.. K..             ..;}So i-.lef>h-     H. i n~i
                                                                                   -<-\K                 <100 8
              ~ 1)\w::;-ot-l N- Cu.rr.£~5'                                         <It..

9 llN S"tJ1PS <tK. -< il)O 10

            "*- -     100L$.           PP.,~T~h          fhP..GcNTA.                                                                                 11 f 12
        *. "*- -      ~I\C.11...G.Lo~ Rl;~~l ,-1 G- &:_I1,.)£",t r-J                     8 O - I 00        c. p fr.-

13 14 15 Utb'!J A~>.Jf\L A.-r G-4t..t fJp..iNf" Sl-1.oP P.., mE"Sf:\. .} w~ n1~ c.r~ ~ f's. B~ ci:: ht-.t.i~ -rcc.L S c.at-l'Th1J 1"1G- --rA.£" Move Ll'S.'TE:t:. lT£1r.S - AP-re.It.. c.+i.f:CJL.t.l& -rl--:\.1:'.: "TooLS r::dJ..... S:h..E.N2.P.Jh£ + i;::\~t:,. ~-r.P{'r,.1tJ~--r,Cr-.\,

      ~~          blU..4::.C::CE:b. 10             -n~£        Pl>...LLtT       Wn~OC lft£ Tet::.LS:- L-::.12.£ F'olNJb *
     ..St"oT CJ.,.£U ..DIILtCX F!aSI<:.. af'.                               Pf\. LL£T(woet:£tJ) ~ t::"Ol.1..1Pl'N::t-r1-Lo0-."Tt:D 1.J "'"G. GGJEeN_ "'-Q...fJ,,,. ~                                         o~ \ ~ R>,.u£,--f W~"S f£v...FoLl'f'.£!). N...t_ 1)'i..£cr ~USiL ~ . ~ s W£L£ -<fct:>tJq'r-.

Sr<--e~ ~ 1...l ~f'...rv-£ Loa....11-c:x.J l..::£12£ ~u_ -< IK Df',...__J IOD6"'......

     \JiofU.£..L         WI>.O !..l l 7? ALL~ l="Cv-J ~                 Tk.£        6. i,.G oi'.'.   -r&:. LS J:'.(. \ s:f...Eb HIS                 Model
    +i~D5 ...S v,:le{.L - No n"!£crl'-.Si.£ c...:,v.....1-r..s: t,.S6J(,. B"-CKGLOUA.l-o L.J£R..6                                                  SerialNo tJci--rc:1::, _ StAPt'R.'JIS-DR..                             - RcQu.t:".:s~ Po.. W~tG.A.T ON -r'J-1.C CJ\f'NhlE:"L LDOlS r:-oJ?...       c..1.,J2...11:: Cor-rreNT CJ>..Lo.;J_c,.,.-r\DtJ. ~ 1 GRT o&-r""~ 'FRPl"t".. TR..FtE                                      Print 8.£~ Sc.Al£ -                 4.;tS-GM/t-..S _         S\,..pc.R.Vt.50<.~ A.u.*n~0/2.12£.D ~ F £ ! i !                      or: c&WPrncrJr      Sign FRP~ ff,.£.Sr\. 10 ..S.S R.c.. ~p.._ . PE'2.f00..n--£I> S"i'.M..<l                                   .s~~ . . .--r SSP-L.

Form Number SCE HP {2J3} 1258-1000 REV. 1 11/f/94 Originator File Copy Archived on 05/28/2002

Action Request Assignment Report Date Printed: 03/26/14 13:59:24 Apparent Cause Evaluation Action Request#: 031100334 ** 01 Permanently Closed - Migrated to NDMS Assignment Type: ACE Resp Org: H3000 Category: 90 CLOSED Priority: 3A Assignee:. IJI Forecast Date:

Reference:

Due Date: 01/10/04 Owner: Health Physics Human/Programmatic Perf: ['8J Common Cause: D Implementation Awaiting Equipment: D Event TIiie: INVESTIGATE DISCOVERY OF FIXED CONTAMINATED MAGENTA AIR HOSE IN MESA G40 SHOP General Tab Information: Originator:. lb H3000 89117 A d d e d - - 11/6/200313:10: 1/22/200411:16: Problem

Description:

Notification text** PERFORM AN APPARENT CAUSE EVALUATION OF THE EVENT(S) ON THE REFERENCED AR DESCRIPTION -- INVESTIGATE FIXED-CONTAMINATED MAGENTA AIR HOSE DISCOVERED IN MESA G-40 METAL SHOP OUTSIDE THE RESTRICTED AREA. Reference Tab Information: Text Tab Information: EVALUATION--------------------------------*---******-**** Document the ACE in accordance with S0123-XV-50.39, Attachment 2. Do Not Delete the Default Template. TITLE: Contaminated Magenta Hose Discovered on Mesa ACE EVALUATOR: - H e a l t h Physics Technical Specialist PROBLEM STATEMENT: A magenta radioactively contaminated 1/2" diameter air hose was discovered in a 55-gallon drum normally stored at the Mesa storage yard (Staryard) on Thursday, November 6 2003. Health Physics personnel evaluate materials removed from Radiologically Controlled Areas (RCAs) to ensure that no detectable activity Is ultimately released from the Restricted Area. This event Is being evaluated to determine why the RCA evaluation barrier failed to contain this source as intended. Because the radioactive source was discovered inside a sealed drum which had been unopened since removal from the Restricted Area, radiological significance is low. No measurable exposure or spread of contamination to areas accessible by Site staff or members of the public resulted. There are no related source documents, LERs, NCVs, or NOVs that pertain to this event. AS-FOUND EVIDENCE AND FACTS: Maintenance Division HVAC staff store excess supplies and infrequently used equipment In four locked cargotalners In the staryard or temporarily moved to the G-40 sheet metal shop on the Mesa. In November 2003 the Maintenance HVAC crew was assigned to perform infrequent maintenance on a Units 2/3 CREACUS HVAC unit. Special equipment was to be used to evacuate and replace the HVAC unit charcoal bed. Hoses, cords, tubing, and other materials associated with the special charcoal replacement rig were stored in four 55-gallon drums located Inside one of the Mesa cargo containers. Each drum was bolted Page 1 of 9

Action Request Assignment Report Date Printed: 03/26/14 13:59:24 shut and marked with tape indicating that the drum(s) had been released from the RCA 1/15/98. January, 1998 was the last time HVAC charcoal replacement had been performed in the plant. When opened on November 6 In the G-40 shop by two HVAC Technicians preparing equipment for the CREACUS Job, one of the drums was discovered to contain a single 12' magenta air hose located at the bottom of the drum. The magenta hose was not discovered during a late 2001 sitewide magenta tool sweep that followed the discovery of two contaminated magenta tools on the Mesa. HVAC did not open or inspect any of the MESA cargo containers or any of their contents in the directed Inspection of late 2001. SEQUENCE OF EVENTS: In January, 1998 SCE HVAC Technicians replaced the charcoal In the Units 2/3 Fuel Handling Building Post Accident Cleanup (PACU) Units. The charcoal is normally recharged on a 10 year cycle. Anticipating no need for the specialized charcoal moving equipment for several years, the Technicians and HP prepared the equipment Inside the RCA for storage at the Mesa at the conclusion of the Job, Health Physics surveyed and released the equipment from the RCA, as Indicated by tape affixed to the top of the equipment drums. The tape read "Released to the Mesa 1/15/98" and was Initialed by an SCE HP Technician. The drums were transported to the Mesa for storage In locked HVAC cargotalners. On October 31, 2001 two contaminated magenta hand tools were discovered In a Maintenance shop on the Mesa. Root Cause Evaluation 010901163 was performed. Site Division Managers were assigned In December, 2001 to make detailed searches of all shops, tools boxes, laydown and storage areas, and offices for additional magenta tools and equipment outside the RCA. Communications between the HP Manager and the Maintenance Manager at that time sought to clarify the extent of the Intended searches. The searches then performed by Maintenance, documented on AR 010901163-8, discovered no further magenta tools outside the Restricted Area. On Wednesday November 5 2003 two SCE Maintenance HVAC Technicians were assigned to prepare equipment stored at the Mesa . Using a forklift, they removed four 55-gallon drums of materials from one of four locked HVAC cargotalners and moved them to the nearby G-40 Sheet Metal Shop. They also removed a sl<id-mounted charcoal replacement rig, and began assembling the rig In the metal shop as assigned. The materials were scheduled to be used In the plant the following week to replace charcoal in a CREACUS HVAC unit. On Thursday morning, November 6 the two HVAC Technicians began opening the drums and removing the hoses, cords, tubing, and other materials needed to assemble and test the charcoal replacement rig. Each drum was secured with a ring and bolt, and was marked on top with white tape Indicating that the drums had last been released from the plant by Health Physics on 1/15/98. The HVAC Supervisor recalled that charcoal maintenance was last performed In the plant In January, 1998 when the FHB PACU units were serviced. One of the drums was opened and materials were removed and stacked next to the drum. As they emptied the drum the Technicians saw that the last Item in the drums was a 12' long 1/2" diameter air hose with Chicago fittings. The hose was clearly marked with magenta spray paint. They immediately stopped working and contacted both Health Physics and their Supervisor. HP responded Immediately with a Technician who was working at the nearby G-48 Training building. That Technician secured the area and personnel until an on-shift Technician and HP Technical Specialist responded shortly tl1ereafter. Field surveys verified that hose contained low level fixed contamination. No removable contamination was found on the hose, in the drum, in the work area, or on the HVAC Technicians. The hose and all of the other materials in the drum were returned to the plant for additional surveys. Follow-up surveys of the G-40 shop and the four HVAC cargotalners were negative, as were surveys of the additional contents of all four drums. ANALYSIS AND CAUSES: Method of Analysis: [mark with X to identify the method(s) of analysis]: Page 2 of 9

Action Request Assignment Report Date Printed: 03/26/1413:59:24 _X_ Event and Causal Factors Analysis - operating events, equipment, human performance Process Analysis - common cause/repetitive problems within a process Supplemental Analysis: _Barrier, _Change, _Failure Modes,_ Task, _Technical Other Method - describe methods and Identify approving manager Analysis Summary for Inappropriate Action: Personnel involved In the 1998 removal of the HVAC charcoal replacement equipment do not remember the specifics of how or where the charcoal replacement equipment was released from the RCA. Since the PACU work was performed inside the main RCA, It would have been appropriate for HVAC to have used magenta air hoses from the hot tool Inventory. It Is therefore likely that, when drumming the materials for transport to the Mesa at the end of the Job, workers and HP failed to notice the clearly magenta markings an air hose used during the PACU Job. INAPPROPRIATE ACTION 1: Workers and HP preparing materials for transport to the Mesa following completion of PACU maintenance In 1998 failed to notice the magenta markings on the RCA air hose and presumably placed the hose in a drum Intended to contain only clean, releasable equipment.

SUMMARY

OF ANALYSIS: Numerous corrective actions recently taken to Improve the material release program were not yet In place when the HVAC equipment was processed and released to the Mesa in January 1998. Since 1998 the entire site population has been retrained on magenta tool control. A material release standard has been published to clarify process elements and expectations. An HP second check of all releases from the Restricted Area has been implemented, new videos and signage has been used to promote awareness of magenta control, and the temporary use of magenta tools outside RCAs has been severely limited. Sufficient barriers therefore exist to preclude a similar event In 2003. The 1998 air hose was conspicuously marked in several places with bright magenta paint. Radiation Worker training and annual refresher training thoroughly cover the topic of hot tool marking and handling. Since the event occurred almost 6 years earlier, however, no direct evidence Is avallable as to precisely how or why the magenta hose was not recognized and segregated for retention in the RCA. Inattention to detail is therefore assumed. APPARENT CAUSE: Inattention to detail. Health Physics Procedure S0123-20.9.2 "Material Release Surveys" controlled the release of the drummed HVAC equipment, requiring evaluation by a Health Physics Technician to ensure that no licensed activity was released from the Restricted Area. The Involved HP Technician Initialed the tape on top of the drums on 1/15/98. The Technician was unable recall any of the events of that time period. Under the requirements of the procedure the Technician likely performed massllnn and direct frisk surveys of the HVAC equipment at the FHB jobsite as the material was being drummed for transport to the Mesa. No additional surveys or oversight was required by the procedure at that time. INAPPROPRIATE ACTION 2: The SCE Health Physics Technician failed to properly evaluate the HVAC equipment for contamination as required by HPP S0123-Vll-20.9.2 "Material Release Surveys."

SUMMARY

OF ANALYSIS: Whlle It Is not known how or whether the HPT visually examined and surveyed the HVAC equipment, that evaluation was deficient In that It failed to detect the presence of the contaminated magenta hose In the bottom of one of the four drums. APPARENT CAUSE: Inattention to detail. INAPPROPRIATE ACTION 3: 2001 Communications between Maintenance and HP regarding the scope of Intended RCE follow-up magenta searches resulted In searches Inadequate to discover the Mesa HVAC hose stored there since January 1998.

SUMMARY

OF ANALYSIS: Upon accepting the 2001 assignment to search facilities for magenta tools, Maintenance sought logistical information and clarification from Health Physics regarding the scope of the Intended sweep. HP approved an exception for cargo containers and large storage containers of secondary plant outage equipment and materials which could be best searched when next opened for outage Page 3 of 9

Action Request Assignment Report Date Printed: 03/26/14 13:59:24 use. Communications regarding such issues appear to have resulted In a misinterpretation of intent, resulting in the HVAC section of Maintenance Inspecting only those materials stored inside the Protected Area. Since 2001 the Site has developed and disseminated Human Performance Tools which emphasize formal communication standards In extensive detail. Maintenance and HP management have been personally Involved in crafting and teaching formal communication standards. It Is therefore unlikely such a miscommunication would occur today.

• APPARENT CAUSE: Inadequate communication. Communications between Maintenance and HP, and subsequent direction from Maintenance management Implementing magenta searches, were inadequate In failing to cause the discovery of the Mesa HVAC hose.

GENERIC ISSUES: As detailed In IA-3, a communication weakness apparently caused the Maintenance HVAC Group to confine Its magenta tool search to the Protected Area in 2001. Other groups with facilities on the Mesa which store materials used in the PA may also have failed to search their Mesa locations. It will be necessary to evaluate that condition and search the remaining facilities, If any, which were not properly searched In 2001. RADIOLOGICAL SIGNIFICANCE: Radiological significance was very low. The hose was contained in a sealed drum from the time It left the RCA in 1998 until discovery, virtually eliminating the likelihood of exposure. No removable activity was detected. Fixed activity consisted of a few spots less than 15 cm2 in area reading less than 600 ncpm. Total activity was estimated at 40 nCi by SAM-9. No spread of contamination occurred when the hose was discovered. OPERATING EXPERIENCE: Although related events have occurred, since the errors which precipitated this event occurred in 1998, the event Is not properly characterized as a "repeat event." Numerous corrective actions taken to remedy other program deficiencies have been Implemented since the HVAC equipment was processed and released to the Mesa in January 1998. Since 1998 the entire site population has been retrained on magenta tool control. An HP quarantine area has been constructed. A material release standard has been published to clarify process elements and expectations. An HP second check of all releases from the Restricted Area has been Implemented, new videos and signage has been used to promote awareness of magenta control, and the temporary use of magenta tools outside RCAs has been severely limited. Sufficient barriers therefore exist to preclude a similar event In 2003. Several Industry and SONGS were noted Involving discoveries of contaminated material in the clean Restricted Area trash. Three events were germane to the subject event, and are reviewed below. The Operating Experience Search system was searched for the terms "trash," "material release, and" radioactive scrap." Site Operating Experience Document Number: CCE 980603570

Title:

SONGS Material Release Program Common Cause Evaluation. Date: June, 1998 Appllcablllty to Event: Four contaminated items found outside the RCA from 3/31 /98 to 6/1 /98. Two magenta tools, a ladder, and waste gas sample pump parts were involved, Although no common cause was Identified, It was clear there were worker l<nowledge/accountabillty issues, and the corrective actions were fashioned primarily to address those issues. Those actions included: - Clarification and training on proper SAM-9 use. - Sitewide Intranet training module on tool control and material release rules. Page 4 of 9

Action Request Assignment Report Date Printed: 03/26/14 13:59:24

- Test a pilot magenta tool checkout program for satellite RMAs.
- Run a material control video at control points.
- Create an HP Material Release Standard to clarify program expectations .

• Hold an HP Division Material Release standown .
• HP Manager train site supervisors and managers during July 1998 Mgt. Retraining .
• Enhance CBT by adding RCA tool control rules .
• Contractor workforce standown 12/16/98. Hot topics training Dec. 1998.
• QA surveillance 808-043-98.

i - Reconfigure the SSRC RMA. Document Number: 010901163

Title:

SONGS Material Release Program RCE Date: 10/31/01 Applicability to Event: Two contaminated magenta hand tools were discovered at the Mesa on a pallet of painting equipment recently removed from the RCA. Several other material release events were analyzed by an Interdisciplinary team. Corrective actions completed Included the following:

 - One satellite RMA was evaluated and eliminated.
 - Free release of clean common hand tools from the RCA was prohibited by procedure.
 - A second check of materials, tools, and equipment submitted for release from the Restricted Areas was Implemented .

• Division Managers coordinated searches of all SONGS' shops, tool boxes, laydown areas and offices for magenta tools adrift outside approved Radioactive Materials Areas. Eight magenta tools were found.

 - A standardized RCA tool marking protocol to conspicuously identify RCA tools was developed.
 - 80123-XV-30 was revised to Incorporate magenta tool program responsibilities.
 - HP program documents and training materials were revised to specify magenta tools use In remote contaminated areas only.

• Program documents and training materials were revised to require HP escort of magenta tools used outside the main RCAs .
• HP and Security procedures were revised to require face-to-face HP concurrence for release of tools and equipment from the Restricted Area.

 - A Material Release quarantine area was established at Units 2/3.

Repeat Site Problem: _X_Yes _No Industry Operating Experience Document Number: OE9873

Title:

Contaminated Chem Sample in Clinton Clean Trash Date: 1/08/02 Applicability to Event: A contaminated chemistry sample was disposed of in 'green Is clean' trash, which was released from the RCA In error. The cause was Indeterminate, but an error-likely situation was recognized in keeping clean trash and contaminated trash In close proximity to each other. Document Number: S-2002-3478

Title:

Surry Worl<er Exits PA with Particle In Jacket Date: 11/02 Applicability to Event: Worker's Jacket and tools discovered contaminated offslte. Relaxed HP controls at the Surry ISFSI facility failed to detect contamination after maintenance was performed on a spent fuel shipping cask. Repeat Site Problem:_Yes _X_No COMPLETED CORRECTIVE ACTIONS

1. Root Cause Analysis 010901163 and Its numerous corrective actions and followup verifications was Page 5 of 9

Action Request Assignment Report Date Printed: 03/26/1413:59:24 completed to preclude recurrence of similar events since the October 2001 Initiating event.

2. The contaminated magenta hose was confiscated, analyzed, and returned to the RCA for disposal on 11/6/03.

3. Follow-up surveys of G-30, the four drums of HVAC equipment, the materials In the hose drum, and all four HVAC cargotainers were performed with negative results.

4. Apparent Cause 2: The involved Health Physics Technician received appropriate counseling.

5. Generic Issue 1: Evaluate Mesa facilities which may contain material used In the PA and identify where searches may not have been completed in 2001. Resp PLANNED CORRECTIVE ACTIONS [must be linked on CA Tab]:

1. Apparent Cause 1: HVAC Maintenance Supervision will review this Incident with applicable staff and

~II reinforce the Importance of identifying and controlling potentially contaminated materials. Resp:

2. Apparent Cause 1: Site Workers will be reminded of the Importance of Identifying and controlling potentially contaminated materials via U2RFO Hot Topics communication. Resp: Jll f II

3. Generic Issue 1: Maintenance and HP Inspect identified areas outside the PA for potential radioactive material Items In drums, cargo containers, shops and storage areas. Resp:

4. Apparent Cause 3: Remind appropriate Maintenance and HP personnel of the Importance of employing formal communication tools to avoid miscommunlcatlons of this type. Resp*

OTHER ACTIONS: None. SUPPORTING EVALUATIONS NA

*-****---***********************************EVALUATION-CONT.---*-*******************************--*-****

Approval Tab Information: Code To Status From By Tlmestamp Pax CHG-RESTR *

• 1/22/2004 11 :18:00 AR Restraint has changed for assignment: 1 Type: ACE old value was "0.0" A 90 80 11 111 a 1/22/2004 11: 17:56 86164 CHG-RESTR arn , 1 112212004 11 :16:40 AR Restraint has changed for assignment: 1 Type: ACE old value was""

A 80 50 SYSTEM 1/22/2004 11 :16:40 Child assignments closed A 50 20 II IPl 1/22/2004 11: 16:34 89439 CHG-RESTR I JI I 1/22/2004 11 :16:21 AR Restraint has changed for assignment: 1 Type: ACE old value was"" Page 6 of 9

Action Request Assignment Report Date Printed: 03/26/14 13:59:24 Code To Status From B Timestam Pax D1 20 90 2 on t 112212004 11 :14:26 89439 Assignment approval logic Is Incorrect. Assignment should have gone to cat. 80 after advancing out of 45 but did not. WIii move to cat. 50 to allow auto advance to cat 80 so line can approve. CHG-RESTR 2 11,

• 11221200410:48:03 AR Restraint has changed for assignment: 1 Type: ACE old value was 11 0.0" A 90 45 RI ] Ill 1/22/2004 10:47:25 89439 GARB comments Incorporated Into existing ACE Text.

ASSOC J3 [81 Q 12/18/2003 13:18:28 Associated assignment AR#: 031100334 Seq: 11 ASSOC ., Pl 12/18/200313:18:23 Associated assignment AR#: 03110 334 Seq: 12 ASSOC ~ J £ 12/18/200313:14:10 Associated assignment AR#: 031 00334 Seq: 10 CHG-DD ]BIOi* 12/17/2003 09:56:21 Due date updated to allow 30 days to incorporate GARB comments on 12/10/2003 CHG-DD I II IP . 12/17/2003 09:56:21 Due date not valld, due date reassessed by assignee/supervisor (describe In COMMENTS) CHG-DD 12/17/2003 09:56:21 Due Date has changed for assignment: 1 Type: ACE Old value was "2/15/2004 00:00:00" CHG-DD j JI d 12/17/2003 09:52:21 Alignment of parent assignment to daughter assignments (RCE, ACE, SAF, OE, etc.) EST-DD 181 A 1211112003 09:52:12 Prior to plant need EST-DD 7 II C 12/17/2003 09:52:12 Due Date has changed for assignment: 1 Type: ACE Old value was 11 5/4/2004 00:00:00 11 cHG-RESTR

• 1 a 1211112003 09:45:05 AR Restraint has changed for assignment: 1 Type: ACE old value was 1111 D1 45 50 a 11 1 1211112003 09:44:02 86661 Reopened evaluation to lncorp CARB comments on 12/10/03: See Notes tab for GARB comments.

CHG-DUE nm 1 11 121101200311:14:23 Due Date has changed for assignment: Old value:5/4/2004New value: 5/4/2004 CHG-RESTR IFII 111 12/10/200311:14:23 AR Restraint has changed for assignment: 1 Type: ACE old value was 1111 A1 50 45 I UP

• 121101200311:14:12 86164 CHG-RES TR II Di I 12/10/2003 08:33:50 AR Restraint has changed for assignment: 1 Type: ACE old value was 1111 D1 45 50 111 f 12/10/2003 08:33:35 89439 Return to cat. 45 to Incorporate VP comments CHG-RESTR 12/5/2003 15:18:43 CHG-DUE 9 1 n 12151200315:18:42 Due Date has changed for assignment: Old value:12/6/2003New value: 5/4/2004 GEN-TND zP 12151200315:18:42 Created Assignment Type: TND from RCE/ACE/RCT process A 50 20 7 di
• 12/5/200315:18:36 89115 Page 7 of 9

Action Request Assignment Report Date Printed: 03/26/14 13:59:24 Gode To Status From By Tlmestamp Pax ASSOC I j II 12/3/2003 10:09:44 Associated assignment AR#: 031100334 Seq: 7 ASSOC ]Ill[ 11111 12/3/200310:09:41 Associated assignment AR#: 031100334 Seq: 6 ASSOC II I . 11 12/3/200310:09:38 Associated assignment AR#: 031100334 Seq: 6 ASSOC .,, f 12/3/200310:?9:36 Associated assignment AR#: 03110 34 Seq: 4 ASSOC Associated assignment AR#: o31~~]'11Dt 3 1213120031 o:o 9 33 ASSOC II I (

• 12/3/2003 10:09:20 Associated assignment AR#: 031100334 Seq: 2 CHG-RES TR 12/3/2003 09:39:06 AR Restraint has changed for assignment: 1 Type: ACE old value was ""

A 20 10 11111* 12/3/2003 09:38:51 89117 Notes Tab Information: User ID: Pl [ j fP lme: 12/17/2003 09:50:00 Text: CARB comment from Meeting on 12/10/03

1) Under IA-1 compare the past process controls for surveying/releasing drums to the current controls leading to the conclusion that the problem could not occur today. Update the CAs to reflect the completion of the CAs from RCE 010901163.

2) Update the OE section to meet the procedural requirement "If a repeat problem, identify the ... corrective action that will ensure sustained Incorporation of the operating experience." - I.e., why the CAs will prevent the problem In the future. [Ref. At!. 2 of the 50.39 procedure]

3) Generic Issue section should Identify the potential for other containers not searched during the RCE CA and capture your planned action to search the staryard.

4) Rework/clarify the facts/analysis leading to AC-3 (Inadequate communication) and define the CA for the Inadequate communication.

5) Delete the CA to Maintenance conduct a cause evaluation given the Inadequate search was the result of inadequate communication between HP an ai ten ,~ce.

6) HP to provide Maintenance 11 1 he revised ACE for review/concurrence.

CA Tab Information: AR/SEQ/TYPE Resp Org Assignee Due Date Status QA REQ Priority MO Type 031100334 9 TND H4000 -2/26/2003 99 N 3C Trending Assignment created from RCE/ACE/RCT process 031100334 2 TND H4000 a 1* 12,12,2003 90 y NOTIFICATION TEXT-- EVALUATE THE ISSUE IDENTIFIED ON THE AR AND SUMMARIZE THE 3C FOLLOWING INFORMATION ON THE DESCRIPTION TAB: WHAT HAPPENED, WHY IT HAPPENED, AND WHAT IS THE SIGNIFICANCE OF THE ISSUE, CODE ON THE TRENDING TAB. DESCRIPTION-- INVESTIGATE FIXED-CONTAMINATED MAGENTA AIR HOSE DISCOVERED IN MESA G-40 METAL SHOP OUTSIDE THE RESTRICTED AREA. SEE TEXT FROM ACE ASSIGNMENT 1 OF THIS AR FOR A DETAILED ACCOUNT OF THE EVENT'S CIRCUMSTANCES/CAUSE ANALYSIS. Page 8 of 9

Action Request Assignment Report Date Printed: 03/26/14 13:59:24 CA Tab Information: AR/SEQ/TYPE Resp Org Assignee Due Date Status QA REQ Priority MO Type 3-11-00-3-3 4--3--0-TH--M '50-0--'-- 12/17/2003 90 ' Y 3C Notification text-* HVAC Maintenance Supervision will review this Incident with applicable staff ~d will reinforce the Importance of Identifying and controlling potentially contaminated materials. ResP9

• a DESCRIPTION** INVESTIGATE FIXED-CONTAMINATED MAGENTA AIR HOSE DISCOVERED IN MESA G-40 METAL SHOP OUTSIDE THE RESTRICTED AREA.

031100334 4 0TH H4000 Ill :mc210112004 90 Y 3C Notification text-* Site Workers will be reminded of the importance of Id an controlling potentially contaminated materials via U2RFO Hot Topics communication. Resp: DESCRIPTION** INVESTIGATE FIXED-CONTAMINATED MAGENTA AR HOSE DISCOVERED IN MESA G-40 METAL SHOP OUTSIDE THE RESTRICTED AREA. 031100334 5 0TH H2000 -2/17/20 03 90 Y 3C Notification text-* The Health Physics Technician will be coached regarding Material Release performance expectations. Resp: di P DESCRIPTION -- INVESTIGATE FIXED-CONTAMINATED MAGENTA AIR HOSE DISCOVERED IN MESA G-40 METAL SHOP OUTSIDE THE RESTRICTED AREA. 031100334 6 0TH Mssoo 11 a I 12,1112003 99 y 3c Notification text** Investigate and determine the cause of incomplete 2001 Mesa Maintenance storage area magenta tool searches. Resp: Ill I DESCRIPTION -- INVESTIGATE FIXED-CONTAMINATED MAGENTA AIR HOSE DISCOVERED IN MESA G-40 METAL SHOP OUTSIDE THE RESTRICTED AREA. 031100334 7 0TH M7400 -1/23/20 04 90 Y 3C NOTIFICATION TEXT-* MAINTENANCE AND HP INSPECT AREAS OUTSIDE THE PA FOR POTENTIAL RADIOACTIVE MATERIAL IT SIN DRUMS, CARGO CONTAINERS, SHOPS AND STORAGE AREAS. RESP: DESCRIPTION -- INVESTI ED-C NTAMINATED MAGENTA AIR HOSE DISCOVERED IN MESA G-40 METAL SHOP OUTSIDE THE RESTRICTED AREA. 031100334 10 0TH M7400 QI I

• 01/01/2004 90 Y 3C Notification text** Evaluate Mesa facllltles which may contain material used In the PA and Identify where searches may not have been completed In 2001.

DESCRIPTION** INVESTIGATE FIXED-CONTAMINATED MAGENTA AIR HOSE DISCOVERED IN MESA G-40 METAL SHOP OUTSIDE THE RESTRICTED AREA. 031100334 11 0TH HOOOO *

• 11/01/2004 90 Y 3C Notification text** Remind approplrate HP personnel of the Importance of employing formal communication tools to avoid mlscommunlcatlons of this type.

DESCRIPTION** INVESTIGATE FIXED-CONTAMINATED MAGENTA AIR HOSE DISCOVERED IN MESA G-40 METAL SHOP OUTSIDE THE RESTRICTED AREA. 031100334 12 0TH MOOOO a , 11 0110112004 90 y 3C Notification text** Remind appropriate Maintenance personnel of the importance of employing formal

   , communication tools to avoid mlscommunlcatlons of this type.

DESCRIPTION** INVESTIGATE FIXED-CONTAMINATED MAGENTA AIR HOSE DISCOVERED IN MESA G-40 METAL SHOP OUTSIDE THE RESTRICTED AREA.

                                                           ***** END OF REPORT **..*

Page 9 of 9

      ~ ~ ~ u ::

' 'l=, k.,~ A. DESCRIPTION OF TASK

k= sb~ ~z AIRS #___ ___ ___ ___ ___

  / ~f~*~41l                                 :f ~e         L       .        .                   OTHER#

OTHER#

         ='i5, ASSfGNE                                                                           AS IGN                                 initial s

• DATE ACTION MUST BE COMPLETED.~- ... b' d- 1) Was Assignment Discussed With Assignee?

                                                                                                     ~Yes                             Date Done 7~2(!)

2) Are all documents necessary to understand and complete this task (which are not easil~

available to the assignee) Attached? Yes/VA

3) Has a copy of this form with attachments been deliv~r.ed to assignee?

Assignmenti'is not effecti ve until thubo ve -- - yYes Date Done *7-2D

                                                                                                *are p:~_mpl et~e; DATE ASSIGNMENT EFFECTIVE            ?- ,_--

Jhi s date must coincide with or be later ge,

                                                                                                                                                  ~--- -
                                  .                                                                                                                  than

J'=::;.;.z .. ~  ::;::::: == t: the latest date above.

F. REQUE~ TO RESCHEDULE COMPLETION DATE (NOTE: this section is ~ =- _..

                                                ~...,....";."'~'"tt       i.....:t.::::!::Z! :£       ;1t._   l     t                                :.::r.::::n.:.z-~
         * *-* unsatfs factory outcom eo"ftfi e Assignment discussion in E.1) which must be dealt                       not    to be used  because  of     an informally before the original assignment date is specified.)                                                            with

1) Date of request for reschedule 2) initial s of requestor

3) Reason why assigned completion date cannot be met:

                                                           '*    I
                                                       .

• I 4)*Requested New Completion Date

5) Requested New C9mp1etion Date Appro ved?~ yes

                                                                      --- --- -                             Date of Appr oval- -~~~ ~-~~ -

6) Request Approved by

                                                                                                                                                  -~~-

G. 1) Statem~nt-of-Complet~d A c - t i o i i : ~ : i ; ; . ; : ~ ' = ~ ~

                             ]> S~e_.. s. C:i~~~tktJ. tl-E~ t2 6]&.~ ~~~                                                          ~---~

_~ t4w h ,(M1+it1JMJ . . ... *. . -:-- --** -

2) Date Compl et~/ti:i-: .. .

3) Is a copy of completion ~ ~ ~ y e s (ACTION IS NOT COMPLETE WITHOUT THIS)

4) Signature of. Assignee_. - .

7 1NSTRUCTIONS: 1) Form ,s to have at least three copies.

2) Original with Attachments goes to Assignee.

3) One copy is kept by the Assignor.

4) One Copy goes to the HP Manager *.

5} Whenever Section F. or Section G. is filled out it is to be done on the original and copies are immediately sent to the Assignee and the HP Manager.

6) When Action ,is complete copies of completion documents supplie d.to Assignor. :

( August 4, 1982 SUBJECT; TAC Item E82-059 Decon Showers in the Medical Facility It has been determined that there are two decon showers in the Mesa Medical Facility, both of which are of the cold water deluge type. Additionally, a decon shower having only cold water piping is planned for the EOF - Train-ing Facility. The waste water from all three of these showers is routed to a 2000 gal hold up tank. The~e findings were verified with construction personnel f r o ~ The following drawings were examined to make this determination:

1. San Onofre Mesa Medical Facility 5166379-1 P-2 "Floor Plan, Plumbing & Details 0

2. San Onofre Mesa EOF - Training Facility 715827 P2 .1 "Plumbing Site Plan"

3. San Onofre Mesa EOF ~ Training Facility 715828 P3. l Hot, Cold & Dion:i.zed Water Plan"

4. San Onofre Mesa EOF .... Training Facili.ty 715684 .A3.l "Floor Planll

C: "'J O , -**C; [ 6£..- ........ ( ( August 6, 1982

SUBJECT:

Personnel Decontamination Showers at the San Onofre Mesa Medical Facility and EOF - Training Facility A review of the subject fac.:tlities by station health physics engineering personnel indicates that the personnel decontamination showers are of the cold water deluge type. Such showers are not generally desirable for the intended purpose because (1) cold water causes the pores in the skin to close and entrap contamination* (2) a deluge type shower may cause the sp'tead of localized contamination and* (3) an injured-contami nated person may not be able to withstand the physical shock of being deluged with cold water. lt is reconunended that the subject showers be supplied with both hot and cold water and that the deluge shower heads be replaced with shower heads on short hoses so that they can be used either as stall showers or as a hand held shower. Please communicate these concerns to the responsible Project personnel and keep me informed of corrective actions which are planned.

  /
                                                                                         * , * ' ~ " ' 01                                                                                         , ,* ,,, ,. '                     ** j * * ****

• • ** ,***, >-" ,.,,*,*' ~**"" ,,.,,.,., * . , , , I ' *<'*',**~"1*' "1'*','~{...,\'"1' ",.-:*\* ;,,',, *,**.,:** ***,*: *:~;*'.-'"'*'~ ':'*"'*~V,1,U,~**.-,!.'**" ""IV

                                          ~ONGS HP INDIVIDUAL TASK ASSIGNMENT (ITA)

I* *-.j;,*

5) List appropriate references ("'{; r:1 ..(;' ~-- '

                                                                                                                                                                ..._,!,'.:*_).**.*.1'<!.~::,~'._*_.:,*
                                                                                                  ,c           ,. - .          \j ::( .1 ... 1..i{'t .~.      .         _ ~ ::r.. ..

6) Sign and Date C I...) **. d ... {r***,

1-* ..;.,.

8. ASSIGNOR(S}: Compliance with this Section is indicated by your signature or initials below.

1) All necessary documents are to be referenced and/or readily available and/or attached.

2) Prime assignor a~d assign~; discuss ts h ITA a_nd~ a,gree on iPrime D.~e Date, assignor _enter\: ...

PRIME DUE DATE* ofe;, **ft;~ f;iAssigned . . y ~ O n l':_,**/?~ ~, ',

3) Subsequent assignor and assignee discuss an a~ ee on ub Due Date, assignor enters:

SUB DUE DATE* of Assigned to By On _ _ _ _ __

4) Assignor(s) gives original ITA to assignee an~ forwards a copy to TAC Coordinator.

   *Prime Due Dates should be at least 5 caleridar days beyond the date when task first assigned and Sub Due Dates must not be later than Prime Due Dates.

C. DUE DATE EXTENTION REQUEST: This Section is not a substitute for the Prime Due Date in Section B which must be agreed to between assignor/assignee prior to establishment. Required exten-sions, initiated by assignee, are to be requested as far in advance of the pending due date(s) as possible whenever completion date problems are identified.

1) New SUB DUE DATE of _ _ _ _ _ _ _ _ _ _ _ _ _ Requested By On _ _ _ __

2) New PRIME DUE DATE of C>/z.3 /tt.3 Requested B y - - - - O n C::,

1 fS/<t3

3) Reason why due date cannot be met ____W'---=-~'-*_i'_,+'-*'""";":J-.-+---'-'-~-=-11~v-_ _"""'"w,..-~_,,.._e- _ _ _s._/,\-_w---t1"-\e_.s_*_ _ __

_c,-v~+--'--e-_,*li~-'----k,=/-

   -----------"+-'----"-,;}__1,,_~..c__ _~(.~Q_.......                                 \t..J1..d w a..d*e f

4) New SUB DUE DATE of _ _ _ _ _ _ _ _ _ _ _ _ _Approved By On - - - - - -

5) New PRIME DUTE DATE of (s, ** 23 ...-'8' 3 Approved By On~_

6) Copy of !TA forwarded to TAC Coordinator By ________ ________ ______~

D. TASK COMPLETION: To be completed by assignee and forwarded to originator.

1) Statement of completed action _ ____,E:""""k..c.,-..__,c,"'----'--(~0~5~~--=-..c_--=Vl1'-f-->:e,"""-'-1,n...=-c.~-------------~

2) Date comp 1ete d_ _ _ _7.L..../-/----'G--1/_._B:_~_______ _______ _______ ____

r I

3) Is a copy of completion IS NOT COMPLETE WITHOUT THIS)

4) Signature of Assignee

5) Originator is to forward original !TA and supporting documentation to TAC Coordinator.

To TACC on _________ ______ date, By ________ ________ ____ Distribution: White" Originator Canary & Pink - Assignee Goldenrod "TAC Coordinator .see so(1u) 111 Rll:V, o 11/24/e2

1. ww~~~~J~~d

       ~ ~ - \ 6~ 1:i ; c ~ C:560._,,.Co -13?

l, ~ ~ A& ~ CD,"'; ~~

__ ~-

        ~?            .

~' B&Ul- -+/-Rw_ ~ 75> ~ ~ I~ r~~ 4, w~~~ ~r :r- ~~

      ~(~~AA,~~/~
      ~~1.Qc-W~-*)                                        ~
      ~~~~/~~
        ~~~~f                                                    .

5 . '.?, ~~ u..,.e... ar~ I D c. 1- te. :;;J.O , 3 c:, ~- -.+ 1.. £ AJ~ 8 a-o~ ~:;& c ~ 1-=Jj},_<4- ~ ?

May 23, 1983

SUBJECT:

Preliminary Report on Contaminated Unit 3 Intake Sludge

REFERENCE:

Individual Task Assignment E83-181 The following information has been acquired regarding the detection of 6

                                                                              °Co and 137 Cs in sludge from the Unit 3 intake:

A) Source of the Contamination It is conceivable that liquid radwaste discharged into the seal weir vent could cross over to the intake side through the* recjrculation gate. One attempt to demonstrate this cross-over was unsuccessful. A diver is scheduled to be onstte Monday, May 23, to obtain additional samples from various locations of the intake structure. B) 58 Co Anomaly Radwaste discharges have typically had at least ten times more 58 Co than 6

     °Co. For example, during the months of February, March and April 1983, the rat1os of 58 Co to 6 °Co were 14, 13 and 9 respectively. Since the half-life of 58 Co is 71 days, the amount of 68 Co should be at least the same order of magnitude as 6 °Co, yet 6 °Co is present in all samples, and 58 Co is not detected in any of the samples.

C) Counting Statistics Although the levels of 6 °Co and 137 Cs which were detected are very low, the results are, nevertheless, statistically significant. The 6

                                                                                °Co photo peaks typically had errors of 10%, while the 137 Cs photopeak usually had an error of about 15%. Both of these two isotopes were detected in all twelve of the samples counted.

D) Detectability The two isotopes of interest ( 6 °Co and 137 Cs) were reported in all samples. It is possible that sample inhomogeneity could account for detection of these activation and fission products. This is possible if the detector 11 saw 11 6 °Co and 137 Cs at very low levels in portions of the sample which settled to the bottom of the flask, close to the detector. The analysis program would assume that this quantity is uniformly dispersed throughout the sampls, thereby artificially increasing the value for the amount detected, and declaring the isotope to be statistically significant above background. (Note that inhomogeneity could also artificially reduce the quantity if the contaminated materials were far from the detector).

h - - - l *- - * -*'-1*. -* May 23, 1983 Continuation of the investig ation can be pursued in at least four directio ns.

1) Dispose of the sludge as low-level radwaste. This would be expensive, but may be necessary.

2) Dilute the sludge with additional sludge (not-contaminated) and dispose of the entirety as simple waste. This technique is apparently not a viable solution .

3) Continue the investig ation into the source of the contamination, to resolve 11 A11 above. The samples taken by the diver may help to identify the source.

4) Perform addition al, carefull y controll ed Geli counts to determine if the sludge is truly cpntaminated. This would cover 11 C11 and 11 011 above, and perhaps 11 811

• Carefully controll ed sampling and counting might also render the 6 °Co and 137 Cs isotopes as being below detectab le limits, resolving 11 811 above, and allowing disposal of the sludge as clean waste. The additional samples to be obtained by the diver should be useful in this regard.

Note that this report is preliminary, and answers to the E83-181 questions requira substant ial additonal information. ALARA is continuing the investig ation. cc:- _.,02 72K :.

        ~

July 6, 1983 MESSRS.-..

SUBJECT:

SONGS Unit 3 Intake Sludge

REFERENCES:

1) ae ~~~j:c,_..y ontaminated Unit 3 Intake Sludge

2) Annual Operating Report of SONGS Unit 1 for 1982, Radiological Environmental Monitoring Evaluation

3) Individual Task Assignme~~ E83-181

                                                \..,......... .

During early May, 1983, a quantity of sludge was removed from the SONGS Unit 3 intake structure. Gamma spectral analysis of this sludge revealed very low levels of 6 °Co and 137 Cs in all samples. The levels of contamination were reported to average 2.95 x 10- 7 µCi/gm of 6 °Co and 1.01 x 10- 7 µCi-/gm of 137 Cs. Some of the biowaste was drummed *and shipped to the burial site as ra.dwaste. The remaining 60 drums contain primarily sand. A number of questions arose concerning how the intake sludge became contaminated; what was the source of contamination, and how should the sludge be disposed? The following discussion is the Station ALARA Engineering evaluation of the situation. Source: The contamination is probably due to intake of ocean bottom sediment. This conclusion was reached by elimination of the possibility of Unit 3 radwaste discharge being recirculated through Gate 4 into the intake structure. The major releases of radwaste from Unit 2 were d,schargad during Feoruary, March and April 1983, through the Unit 3 radwaste discharge line (Unit 2 line was inoperable due to construction in the seal weir vent). These discharges had, respectively, 14, 13, and 9 times more 68 Co than 6 °Co. Even with the relatively short half-life of 58 Co (71 days), any detection of this discharge would certainly show " 8 Co activity along with 6

                   °Co. This was not evident in the intake sludge samples.

MESSRS. July 6, 1983 The only other source of activity identifi ed was ocean bottom sediment. The Annual Operating Report of SONGS Unit 1 for 1982, Radiological Environmental Monitoring Evaluation, reported that ocean bottom.sediment contained small quantiti es of 6 °Co and 137 Cs. Three of eight samples showed 6 °Co in a range of 1.3 to 5.8 x 10- 7 µCi/gm, with a mean of 2.8 x 10- 7 µCi/gm, very comparable to the values reported for the intake sludge samples (2.95 x 10- 7 µCi/gm). In the three of eight o~ean bottom sediment samples, 137 Cs was reported at 0.5 to 1.3 x 10- 7 µCi/gm, with a mean of 0.833 x 10- 7 µCi/gm, also comparable to the values reported for the intake sludge samples (1.01 x 10- 7 µCi/gm). (Note that page F-2 of the Annual Report states that no accumulation of 6 °Co or 137 Cs could be related to effluent s from Unit 1.) 58 Co was not detected . The attached graphs show the activity levels in ocean bottom sediment. Attachment 3 tabulate s the counting data. Unfortunately, the samples taken offshore at the intake structur e did not demonstrate any detectab le 6 °Co or 137 Cs. This does not support the reported activity in the Environmental Report for ocean bottom sediment. However, with the recent heavy storms, turnover of the ocean bottom material could easily explain the lack of activity in our recently collecte d samples. During recent work on the Unit 2 Circulat ing Water System (6/24 - 6/30), samples of sludge from the forebay were collecte d and counted. These two samples showed 6 °Co and 137 Cs in barely dBtectable, but not statisti cally signific ant, levels.

Conclusions:

1) The source of the contamination is ocean bottom sediment.

2) Depending on storms and ocean activity , it is quite conceivable that in the future, contaminated sediments could again be deposited in either Unit 2 or 3 intake structur es.

3) The remaining sludge (as well as any future sludge with similar levels of radioact ive contaminants) should be disposed of as 11 very-low-level 11 waste. The recommendation below identifi es the suggested process for disposal .

4) Radwaste discharges appear to be ruled out as a source of contamination, suggesting no serious design problem.

MESSRS. July 1, 1983 Recommendation: Dispose the remaining sludge as 11 very-low-level 11 contaminated waste in accordance with the recommendation in IE Information Notice No. 83-05: Obtaining Approval for Disposing of Very-Low-Level Radioactive Waste. This Notice calls out the use of 10 CFR 20.302(a), which permits burial of licensed material contaminated at very low levels, on either Federal or State-owned land. Please direct any questions to Station ALARA Engineering at PAX 56178. -0371K/. ~chment cc:

~~-_,,,..,,.....,,._GI"""'**:.;:=-;.....,.-~--~*" ........ :.,.

                                                                                                                                                                         . ,_,_ '\*e,,
                                                                                                                                                                                  ' ..J CESIUM--137 Aclivity 1n
                                                                                                                                                                                \

Ocean Bollom Sediment 0.25-.---------------------------, 0..20 0.15 et: 0 O> 0.10

                              ~

uC 0.05 Legend D. 0.5m. N. of SONGS 1 0.00 W - - - ~ ' " " - - - C - - - - - _ . ; i , . . a , c __ _ _ ____,_ _ _ _ _ _ _~ - - - t l l ( I X O.Sm. S. of SONGS 1 0 0.5m. N. of SONGS 2A:3

                                                                                                                                                   ~    0.5m. S. of SONGS Z-&:3
                                                                                                                                                   ;::K NORTH CONTROL --*---
                                          -0.05 ......      --~---------.------,-----r---"'f'!------------f Ju~1"B Q"'c 1~           J.)~ 1~ 'Q\.-c 1q "':JD~ '?>o 'Qt,..c ?>o                °:JD\\ -o1,: 'Q\.-c <o~

MONTH/YEAR Figure 16

CO BA LT -60 ACTIVITY IN OCEAN BOTTOM SEDIMENT 12 .- -- -- -- -- -- -- -- -- -- -- -- -- -- -- , 10 8 0:: 6 0 0)

    ~

0 C 2 Leg end 6 0.5m . N. of SONG S l [l 0.5m . S. of SONG S 1 0.5m. N. of SONG S 2&.3 N 0.5m. S. of SOHG S 2&3

                                                                                                                             'Q. Nod h Confr nl
                                                    ,._\ ~o            'oo      ,._\ 'o....:. r <o"   .._\ ~'1-    e, <o'r
               ,,_,-1~ ---e,1~    ~, 1q    e,1q                                               Q~v     jU\'        u'0
                       \)\..'. )\J\   'Q0     :\\j\"'       \)\--G         )'0\"
          )\J,.....

MONTH/YEAR F!qur r. 12

ATTACHMENT 3 Sample 6

                           °Co(µCi/gm  X  10~ 7 )    13 7 cs (µCi/gm X 10- 7 )

Sludge - white 1.88 + .33 I 0.91 + ,22 S1udge ~ white 2 .16 + .28 1.03 + .21 I Sludge - green 3.43 + ,32 0.85 + .20 Sea-growth-white 0.99 + .19 I 0.67+ .13 Green .. sludge 3.07 + .19 0.77+, 11 I

1. 3 3. 74 + .20 I 1.08 + .12
2. 1 3.32 + .21 I 1.05 + .14
3. 2 Sludge 3.08 + .30 1.01 + .19 113 Sludge 3.26 + .33 1*

1.22 + .19 Sludge (sand) 2.92 + .33 1.47 + .23

1. 2 Sump ~sand~ 4 .11 + .37 1.05 + .22
2. 1 Sump sand 3.49 + .35 1.01 + .31 Average 2.95 1.01 In order to authenticate SONGS counting data, two composite samples were taken from iiiiii remaini H.he n drums (primarily sand). These two samples wre counted by and reported below. The results are comparable to data fr e , . counting facilit y and, therefore, confirm the detection of the two radioisotope*s* in the intake sludge.

l~GM-620 3.5 + .37 2.8 + .27 2-GM-620 4.4 I .46 1.1 ~ .10

SONGS KP INDIVIDUAL TASK ASSIGNMENT (ITA) I ,t_i-.

                                                                                                 , 1J..*; . .,.,.,,.,..!.. r,, ..I... . . ,,*"ti',,

6) Sign and Date_

B, ASSIGNOR(S): Compliance with this Section is indicated by your signature or in1tia1s below.

1) All necessary documents are to be referenced and/or readi]y available and/or attached,

2) Prime assignor {i) assignee discuss th;,,~ ItA and agree on Prim~ ,-~ss1g no~

                                                                                                              *. en:,,e:,.~: i:,. "/Ji.

PRIME DUE DATE* of Assigned t o ~ ~ B y - - - O n ,/J'.... 1;;,;;1 . *(,) ,. . )

3) ~ubsequent assignor and ass1g~ee discuss and agree on Sub D~e Date, assignor enters:

SUB DUE DATij* of Assigned to By On~~~~~-

4) Assignor( s) gives original ITA'to assignee and forwards a c0py to TAC Coordinat or.

    *Prime Dua Dates should be at least 5 caleridar days beyond the date when task first assigned and Sub Due Dates must not be later than Prime Due Oates.

DUE DATE EKTENTION REgUEST: Thi~ Section 1s not a substitut e for the Prime Due Date in Section B which must be agreed to between assignor/ assignee prior to establishm ent, Required exten-sions, initiated by assignee, are to be requested as far In advance of the pending due date(s) as possible whenever completion date proble n~tifi ed. ,,-* ,,.;:,**.)'""

1) New SUB DUE DATE of___ ~'e.s. tetJ. ~ * ¥ ~ , . . On ______ ___

2) New PRIME DUE DATE of Requested By On

3) Reason why due date cannot be met ____ _ _

4) New SUB DUE DATE of ____ ____ ____ _~Approved By ____ ____

__On _ _ _ __

5) New PRIME DUTE DATE of Approved By _ _ _ _ _ _ _ _ _ On

6) Copy of ITA forwarded to TAC Coordinator D y _ ~ ~ - ~ * - - - - - ~ - - -

D. TASK COMPLETION: To be completed by assignee and forwarded to originato r,

1) Statement of completed a c t i o n ~ l . . - ~ ~ Q L J ~ ' "

T E ; l ) ._ _ J w 5e-C :no~ ~'oo \J E. *

2) Date completed ~7-~ ~=3~ ----= ----- ---

3) Is a copy of completion (ACTION IS NOT COMPLETE WITHOUT THIS)

4) Signature of Assignee~~-----=~

5) Originato r is to forward documentation to TAC Coordinat or.

To TACC on date, By Distribut ion: White~ Originato r Canary & Pink. Assignee Goldenrod - TAC Coordinat or ,see ao(1?.3) 197 R};;V, 0 II/Z~/02

September 21, 1983 MR.

SUBJECT:

Contaminated Material Released from SONGS, Unit 1 Attached for your information and use is the September 20, 1983 Memorandum For File addressing radioactively contaminated material released from SONGS, Un 1t 1. For your convenience, I have prepared and attached a summar of all contaminated items found during the investigation. A detai1yed*des the items and the activi ties detected is included in the memorandumcript1 and on of the attached surveys. Per y o u r ~ i e s ~ h a v e been forwarded to Messrs. 111111111111111and ~ r*'* Should you have any questions or comments, please contact me. llo66 9K/a Attachrnenr-' cc: CDM files

MEMORANDUM FOR FILE September 20, 1983

                                 -- o -

SUBJECT:

Contaminated Material Released from SONGS Unit 1

REFERENCES:

(1) Memorandumt dated July 2 ~ a t ~ (2) Memorandurnt - t o - dated A u g u s t ~ t t a ~ On July 14, 1983, personnel from the~F abrica tion Shop at the Mesa contacted SONGS Unit 1 Health Physics expressing concern about the possible radiation hazard of some 11 old 11 material which had been stored in the Fabrication Shop yard for several years. A survey performed of the area revealed the presence of a heliarc welding stand with 13,200 dpm/100 cm 2 fixed contamination. No other contaminated items were identifie d. The welding stand was removed to the Unit 1 Restricted Area for decontam1nation. On July 20, 1983, an empty gang box was delivered to the Unit l Restricted Area from the Mesa GRIP Facility for loading of small hand tools and subsequent transport back to the Mesa Facility . Before the tools were loadedt a contamination survey revealed fixed contamination on the inside of the box of 21,000 dpm/100 cm 2 and a meter deflection on an Eberline E~520 with an HP-270 Probe to 4 on the 0-20 mR/hr scale with the instrument probe located 1/2 inch from the surface of the contamination were observed. No dose rate above background was detected at 1 foot from the surface of the isolated 11 Hot Spot". Since this instrument is designed and calibrated to measure only uniform gamma radiation fields and certain narrowly defined beta fields, was not possible to measure the actual radiation field present. Further, it1t was not necessary to make a more precise measurement because there was no personnel exposure and the contaminated spot was removed. A sample smear obtained from the inside of the box revealed approximately 43 dpm/100cm 2 cobalt~so, and 6 dpm/100 cm 2 cesium-137. No direct radiation or contamination could be detected on the exterior of the gang box. The gang box was retained by Health Physics for additional evaluation and decontamination. (A detailed account of the initial findings is contained in Reference 1.) Mr . . . . . . . . a-Tea mste r who h a ~ t t IP F for s e v e ~ a s questioned by Messrs. 4lllllllll lland Unit 1 Radwaste Personnel, regarding the history of the contamina e gang ox. It was determined that the box had been stored at the Mesa for 11 over two years," and that other material present in the yard may have been received from the jobsite during the same time period.

• MEMORANDUM FOR FILE September 20, 1983 IMMEDIATE ACTION Following the realiz ation that additional radioactively contaminated might be present at the Mesa, Health Physics established material included: a program which

1. Initia tion of comprehensive radiation and contamination Mesa Facil ities which could have received materials from survey the s of all Unit 1 Restricted Area.

2. Imposition of material accountability controls at the affected Mesa Facil ities such that no materials could be removed without a Health Physics release.

3. Initia tion of an investigation to determine the source of the contaminated material at the Mesa and whether or not simila contaminated items had been released from these facil ities rin poten tially the past, Description of Involved Mesa Facil ities and Survey Findings The map included as Attachment 1 to this memorandum shows the locati of the involved Mesa Facil ities. on of each The Mesa Fabrication Shop has been controlled b y ~ since its establishment in 1979. The shop was used dur ing~ O sleeving Unit 1 outages to fabricate components in support of the and present TMI and seism upgrade proje cts. Most recently, the shop was used for 11 sma11 tool 11 ic segregation. The inventory 9f Unit 1 small hand tools and equipment during the past extended Unit 1 outages was divided betwee used n and Edison.

Thorough radiation and contaminatipn surveys of the entire Mesa Fabri Shop area, which included opening boxes and evaluating items indiv cation contamination, revealed: an impact hammer with a maximum of idually for 70,000 dpm/100 cm fixed 0r contamination; a cable 2

• of 13,000 dpm/100 cm 2 fixed 0r; a core drill with achoke r with a maximum*

maximu 2,000 dpm fixed Br on one small spot; an 8 inch tap and a m10 ofinch wrenc both with 6,700 dpm/100cm 2 fixed 0r; and a dynameter with a maximum h, 26,700 dpm/100 cm fixed 0r. In each case, removable contamination 2 of <1000 dpm/100 cm 2

• Each contaminated item was prope was rly labele radioactive material and transported to the Unit 1 Restricted Area* d as decontamination or disposal. for The Generation Retrofit Im rovement Project (GRIP) Facil ity, also in 1979, was under estab lished direc tion until Edison assumed control in June, 1983. The GRIP Faci ity functioned as a receiving and distri butio n support of the TMI and seismic upgrade projects at SONGS Unit 1. area in Const materials were assembled into packages and delivered to the Mesa Fabri ruction Shop or the Unit 1 Restricted Area as needed. Surplus materials and cation equipment no longer required at Unit 1 were removed to the GRIP FacilProject storage and salvage. An intensive radiation and contamination survey ity for Mesa GRIP Facil ity was performed, No contaminated items were found. of the substantial amount of material contained in large storage containers A be surveyed: In the interim, controls have been instit uted to preve is yet to removal of any material from the facili ty until the materials are nt the evaluated

MEMORANDUM FOR FILE ~3- September 20, 1983 for contamination and are cleared by Health Physics for release. C / material control program will remain in effec t until facil ity is verified to be free of contamination, all mate rial This at the The~cope of the search for contaminated materials was expan

         --    Laydown Area, so named since it was used by the AmerendedCompa   to include the abr ~ation of the Units 2 and 3 circu latin g water system concr              ny for The area has been essen tially devoid of activ ity since the comp        ete   p1pl1  ne.

struc ture, and it gradually became a storage location for mate letion of that needed at the units. rials no longe r ',[

                                        '7/\                                                       ~:::..--**

A comprehensive radiation and,**'6'ontamination survey o*f the-Area was initia ted on July,,29, 1983. Because of the large area Lay dow n of items involved, approximately 40 man-days have been expen and the number 1 and retrie val effor t, Though all ident ified contaminated items ded on the survey returned to Unit 1, an estimated 6 man-days of radiation surve have been ~ / - the area is declared free of radioactive material. Thirty-thr y remai n until ~ been ident ified with fixed ~r contamination rangin ee items have g from appro ximately 6,000 dpm/100 cm to 670,000 dpm /,*m 2

• Three a1umi num 2

pipes with 1,100 dpm/100 cm removable~ ,on their internal surfaces. were found 2 removable contamination was detec ~ on the remainder of the No of these items is described in At chment 2. mate rial. Each Appropriate soil samples were obta*ined and analyzed. No activ natural products) was detected. ity (othe r than [' *- On July 29, 1983, a guard was stationed at the entrance to the Area to ensure that no material would be de'l ivered Laydown or remov authorization. The area was, and will be, locked when the guard ed witho ut prope r present, These controls will remain in place until all conta is not is removed. minated material The involved area was roped-off to restr ict personnel access. contaminated item was discovered, a label was attach~d which As each radioactive material, On August 19, 1983, the radioactively ident ified it as material uncovered in the initi al survey effor t was prepared contaminated back to the Unit 1 Restricted Area, and transported The surveys were obtained using an Eberl ine E-520 with a Model HP"270 external G-M hand probe, and an Eberline RM-14 with a Model HP-260 external G-M pancake probe . Readings obtained from items with uniformly deposited fixed corrected by the following method: contamination were Assume an item is found with uniformly deposited contamination. reading of 5,000 cpm above background is obtained with an HP-26 A pancake probe whose window area is 15cm 2

• The corrected surfa 0 G~M contamination expressed per 100 cm 2 is: ce 5000 (cpm/probe area) x 6.7 ( probe area s) x 1Qi-9Q!!L) 100 cm 2

                                                                          ~   330,000     L~ )

cpm 100 cm 2

MEMORANDUM FOR FILE -4~ September 20 1 1983 Source of the Contaminated Mate..d!J. Since the Mesa Fabrication Shop and GRIP Faci1itie materials, and based on information supplied s handle only Unit 1 by the that the contaminated items were released from*unit workers there, it appears 1 several years ago, Personnel from the Station Maintenance Organization, and other employees with D1~1 s1on, the Project Management several years experience at SONGS were assembled at the Laydown Area and contaminated items, Al1 of the contaminawere ted asked to identify the items were recognized as having been used at Unit 1 seve that could be iden tifie d established that many of the items had previous1y ral years ago. It was also four years at the Reservoir, north of Unit 1. Thatbeen stored for at leas t the Sill IS Laydown Area when tra 11 ers were 1ocated material was removed to second calendar quarter of 1982. An area survey perfo at the Raservoi r during the showed no residual contamination. rmed at the Reservoir SUBSEQUENT INVESTIGATION The Health Physics Division recognized that present byproduct material other than radioactive calib ratio licensing does not permit init ial action taken by Hea1th Physics was to requ n sources at the Mesa. An Safety and Licensing to obtain a license permittingest Nuclear Engineering material ~t the Mesa while the contaminated items the presence of the for decontamination or disposal. However, by Septewere iden tifie d and prepared determined that all contaminated items had been loca mber 16, 1983, it was covered by licen se. It was also concluded that the ted and returned to areas not cons titut e a quantity large enough to require tota l activ ity found did Accordingly, that line of action was terminated. licensing action. The question of whether or not materials had been Mesa Fac iliti es to locations other than SONGS, Unitshipped from the involved 1 was evaluated. Material Sent to Alhambra Mr. lli! J $1 Project Construction Engineer, was material movement into.and out of the GRIP and Fabr interviewed regarding While actual supervision and control of the Mesa Fac ication Shop Fac iliti es. resp onsi bilit y of iliti es was the Mr. Utll$..vas the Edison employee who represented Edison's inte rest s there. It was known that material leaving Unit Shop or the. GRIP Area. However, Mr. Ill 1 Lcould state d go eith er to the Fabrication offs ite release of material only through the GRIP that procedures al lowed and salvagable material present at the Fabrication Faci lity, Therefore, scrap GRIP yard before removal from the Mesa. Shop was transferred to the All salvage acti vity at the GRIP Faci lity was hand and Equipment Sales Department. Scrap and salvagabled by the Edison Material in a designated area within the GRIP Jard ahd subs le material was segregated Edison Salvage Facility in Alhambra. A few of those equently.removed t6 the Edison took control of the GRIP Faci lity in June, shipments occurred before 1983.

MEMORANDUM FOR FILE September 20, 1983 Mr, Supervisor of the Edison Material and Equipment Salas Department was contacted regarding hand ling of mater1a1 which was salvaged from the SONGS GRIP Facility. Mr. i*U:lllilll from a11 Edison Divisions at the faci lity expl is ained that mater1a1 received 1mm type and is distributed to existing storage areas adiate 1y sorted by material within the salvage yard. On August 11, 1983 I was accompanied by Mr, 411:U Technician, to the Edison salvage yard in UL i 1111111! Radwaste the yard by Mr.ilfUH~illi*l[Q Matel"ial Expediter, *who We ware escorted thl"ough SONGS material may ave been stored, Each of those area ind'lcated areas whey,e present in them was evaluated w'lth Ebar11ne PRM~7 Micr s, and any material readings in excess of natural background (on the orde o 11 11 R meters. No observed. r of 15µR /hr) were Mr. 111111 b.stated that salvaged mater1 al was l"outine'Jy as possi61e due to space limitations at the yard. Withheld for as short a t*lme Fl explained salvaged material was sold to salvage vend few exceptions, Mr, same day on ships destined for Taiwan. ors and loaded the Both Mr. and I were aware of the potential for creating undue concern to workers at the salvage yard . We spent considerable time explaining the types of l"ad1at1on, the b~sic interact ions with matter, the operation of our detection instruments, and SONGS material release procedures. The comments we received indicated that we were succ essful in assuaging thei r fears. The movement of tools and equipment from the Fabricati tigh tly controlled as was the movement of material. on Shop was not as possibility existed that tools and equipment could have Therafora, the Fabrication Shop, bypassing the GRIP been released from the with the level of work experienced at Faci lity, However, tllllll Unit 1 during the past several yearthat

                                                                                       !ife lt few, if any tools or pieces of equipment                                                        s, from the* Fabrication Shop. Following the, woul           d have been permanently removed Unit l Sleeving/TM! Outage, tools and equipment were moved to the GRIP 1980       Faci  lity for storage, Those same items ware transferred back to Unit 1 for use durin             g the present Outage, Messrs,                             Materials Controller at the Mesa Fabr Shop, an                          Foreman at the GRIP Facility, were also ication

• 1ntervi ewe account of material handling at the Mesa Fac iliti es, Items Sent t2-ltllllllll Because a Teamster who had worked at the Mesa Fabrication Shop that potentially radioactively contamin alleged transported to ated tools and equipment may have been 1nvestigated, that possibility was also The I Facility 'Is hous~s! .in a s*lngle stru ctur e, deignated 1ocated at . . bl1ilding 841,

                                              .             . The  1 aNJe   st  port ion of the building is use as a ware Lsa, un                      su     visio (Mr. 11111 l!Jl had previous'ly workid,iis a materials insp         n   of   Mr.         .

Because of his past exper*lence 1 l Qiwas able to view ecto r for the AEC, real istic perspective and thus avoid Je lmdu e conc ern this matter from a personnel.) Until recently, Mr. Jill I explained, his of his warehol~se faci lity had had limited contact with SONGS, In past years1 various tools requiring

MEMORANDUM FOR FILE September 20, 1983 calib ration or repai r were channeled through his facili where they direc ted to an 0L1tside calibration lab or a repair shop.ty Mr. f[i would be tPass me that in all cases, after caibration or repair, the *Items were return ured SONGS. ed to has now been tasked with preparing a detailed inventory o too sand equipment salvaged from SONGS. The f1rst shipm SONGS material contained on pallet s and in gang boxes was received ent of August 2, 1983 from the Mesa Fabrication Shop. The contents of eight on subsequent shipments from SONGS were also present at the warehouse. recent shipments of SONGS material were temporarily being The most stored traile rs at a local freight company due to space limitations at the on two truck warehouse. Arrangements were made by Mr. -.... to have the material transf erred from the freight company to his""racility. He informed these were the last expected shipments of SONGS equipment. me that On September l, 1 9 8 3 , ~ Radwaste Technician, and I ......W areh ouse in ~ a t e items they had went to the ~ o f the large number of items involved, additional help was received from SONGS. and another Radwaste Technician 1 Mr. requir ed

• effor t, was assign ed to the survey The first phase of the survey consisted of unloading the palle ts and boxes received from SONGS.during August 1983 and evaluating each item gang individually for contamination. Of the thousands that were inspected, a drill stand and three hoses ofwere recently received items fournd with detectable contamination. A detailed description of the contaminated in Attachment 3 to this Memorandum (Item Nos. 19 through 22,items is contained and Item 23).

The survey was then expanded to include all tools warehouse. Nineteen additional contaminated items and were equipment present in the ident ified during the second phase of the survey. Fixed contamination levels on those items ranged from SiOOO dpm/100 cm 2 on a rubber hose to greater than 500,00 area on an impact wrench. Removable contamination above SONGS0 releas dpm/probe was detected on three items: 1,120 dpm/100 cm 2 ~r on a rubber hose; e limits 1,500 dpm/100 cm 2 ~r on a welding connector; and 35,100 dpm/100 cm 2 and 40 dpm/100 cm 2

• inside the previously mentioned impact wrench, ~r contaminated items were being stored on shelves in a low occupancy The the Warehouse. Even in the most extreme case, the impact wrench, the area within rate in the adjacent walkway was elevated by only a few µR/hr. A detail dose description of the contaminated items found during this phase of the ed also contained in Attachment 3 (Item Nos. 1 through 18 and Item 24.) survey is The contaminated items were segregated and subsequently removed to Unit 1 Restr*lcted. Area. Al 1 areas within the warehouse which had contai the SONGS the contaminated ~terns were checked and found to be free of residual ned contamination.

J ~ was surprised that we found contam part o the recent shipments from SONGS; Sinceinatioall n on items that were not items received previously at the warehouse from SONGS were always returned after the necessary calibr ation s or repairs were performed, was initia lly skeptical that any of those contaminated items hag_ever been to SONGS . However, since isotopic analy~es performed onismears olttained from those *Items revealed typical power plant contaminants, it was assumed that the items came from

MEMORANDUM FOR FILE September 20, 1983 SONGS. The most probable, explanation is that item repair ware occasionally replaced by idantica1 piecs sent to the warehouse for tool was placed in stock at the warehouse. es and the actual repaired The contaminated mater'la 1 found at the - f a categories: l ' l s into three The firs t category includes the four.contaminated the August 1983 shipments from SONGS which should items identified as part of surveys performed before the material was released have bean found during the at the Mesa, from the Fabrication Shop The second category includes the two impact wren and the two hosas 1 Item Nos. 3, 16, 17, 18, and ches, the air-powered grinder, interview of the 24 of Attachment 3, Through Warehouse crew, 1t was estab1shed that those items had been present at the warehouse explained earl ier, it is suspected for that at least two to three years, As sent to the warehouse for repair and retaitem ined s in this second category were as stock at the warehouse while replacement items were sent to SONGS. Many tool as those in this second category had been used for s stored in the same location construction project earl ier this year. However, another Bechtel the return of the tools from that project was revie the invoice which accompanied any items of the type we found to be contaminated wed and it d1ci not include The third category includes the twelve welding valves, Item.Nos. 1, 2, and 4 through 15, Thoseconnectors and the two gate existing stock which was moved five to s1x years items were part of the Southgate location the present warehouse location ago from the previous in LaM1rada. Because of the isolated locations occupied by the the dose rates involved, tha warehous contaminated material and radiation exposure, e pers onne l were subjected to neg11g1b1e To ensure a complete assessment of contaminated mata thei r repair and calibration methr1a1 ods associated with the ware further investigated. - h a s a coJJ.kact wit h*

• to repair damaged tool and equipment, Ull llll bt act a an n*e up damaged items from the rne ary: thei r representative picks s received from SONGS), delivers a 1 ems* o any (which includes equipment repair shops, and returns the repaired items to of several outside independent is then returned to SONGS) even if repairs the warehouse. The equipment could ware presently out for repa ir, that area of conc not ba made. Since no items ern is closed.

Three independent vendors are used by

• caibrat*lon on tools . t:

both in a s far ca a* *on. An ammeter had bean sent to torque meter and several ~1ectfica1 cibl ~ drimpirs Corporation for calibration. The amm 'had b~en sent o eter and the t

• warehouse on September 12, 1983. r made an torq add' ue mater were returned

               * * - to check the two items before they were          ltiona1 trip to the

• 1 m .ers were free of radioact shipped back to ive contamination.

MEMORANDUM FOR FILE September 20, 1983 All of the crimpers were determined to be damaged calibration lab to the manufacturer for repa ir: ]nand were sent by the crimpers are used, they are not expected to be cont view of the way the effo rts to evaluate the crimpers would be diff icul aminated, Additional concern by outside vendors. For these reasons, I recom t, and could cause undue area closed, mend considering this Another concern raised during the investigation was contamination on tools and eqipment used by Edison the poss ibili ty of Maintenance. Steam Generation Division Division Maintenance is a support orga workers, tool s, and equipment to assi stniza tion which dispatches maintenance Edison Stations during unit outages and other large proj ects . of Division Maintenance was contacted by telephone the avai labi lity of thei r tools and equipment regarding contamination survey~ He informed me that more than for the purp oses of a inventory was curreritly at the half of thei r tool Generatihg Station and that we were we 1come to perform our survey. (The rema.1 nder of used on Jobs at three diff eren t Edison Stat ions .) t - u ient was being me that even though his crews bring a complete set further informed made at SONGS to use only Station tools in Red Badg o o s, every effo rt is e Areas. On August 18, 1983, I was again accompanied by Mr. ~S tat io n, A comprehensive surve - t o . the y of al 1 a ~ g an enti re trai ler of equipment which had v ~ w a s performed SONGS, Unit 1. No readings above natural backgroundrecently returned from were observed. We were again aware that our presence could cause Division Maintenance personnel. However, all of the the undue concern of had previously performed maintenance at SONGS and workers we encountered ther Radiation Training, Instead of concern, the workers efore had received Basic for our evaluating thei r equipment for residual cont expressed appreciation amination. Since more than half of thei r tool inventory was found radioactive contamination, and because additional to be free of concern, I recommend that this area also be considere effo rts could cause undue d closed. ~ are in order as a resu lt of our experience at t h e ~ Firs t, the Micro "R" meters which were used during the warehous invaluable 1n locating contaminated materials. Use of those e survey proved reduced to at leas t one-half the time required to perform the instruments allowed us to find contaminated items that otherwise could havesurvey and been missed. Second, it should a1so be mentioned that - crew at t h e _ _ _ _ . could not ~ o r and his e~t ire warehouse co op er ati ve ~r ve y effo rt was made e helpful and effo rts, possible only through thei r

MEMORANDUM FOR FILE September 20, *1933 CORRECTIVE ACTIONS As directed by the Health Physics Manager:

1. The Health Physics per~onnel involved with the inadvertent release of the four ras_l_i_9._acti vely contarni nated items from the Mesa Fabricated Shop to the have been counselled,

2. Two Eberline PRM"7 Micro 11 R11 meters have been made available for use in the hold-down areas.

3, The Radwaste Group has initiat ed random surveys of material released through the hold~down areas, A minimum of two releasable (green~tagged) items per day are subjected to a thorough evaluation for the presence of residual contamination. This measure provides an additional means to identify any weakness in release methods. CONCLUSIONS The extensive investigation described above has verified that there are no avenues remaining for the release of radioactive material to the public. The evidence indicates that the contaminated items were released from Unit several years ago, Before 1980, SONGS Health Physics' staffin g and methods l were such that low level contaminated items must have been inadvertently occasionally released. Since that time, Station procedures regarding the proper release of material from the Restricted Area were more strict ly followed. Control was substa ntially increased in April 1983, by full release control respon sibilit y to a single Supervisor and by assign ing provid ing a substantial number of additional personnel. With the Health Physics controls presently in place and with the correc tive measures taken concerning the four items released in the August 1983 shipme to.. 11, the release of radioactively contaminated material from nts Restricted Areas at SONGS is adequately prevented. RECOMMENDATIONS The one disconcerting finding of the inv~ st*l. atio was then discovery of the four contaminated items released to the from the Mesa Fabrication Shop. Even though those ite represente a neglig ible percentage of the total amount of released material, it is the policy of SONGS Physics Division that no radioactive material be inadvertently releasHealth ed. The following recommendations are intended as aids to guarantying that this policy is achieved:

1. The Micro 11 R11 meters proved to be invaluable tools in locating contaminated items in large groups of material. Suffic ient instruments of this type should be made available for use in SONGS hold-do wn areas.

ACTION ITEM The Manager of Health Physics has directed that a total of three Micro 11 R11 meters will be made available for use in SONGS hold-do wn areas by October 14, 1983 and two a ~ e t e r s for backup by December 1, 1983, (Responsibility: ..... ....

MEMORANDUM FOR FILE . September 20, 1983 2.. Additional training should be administered to a11 Radwaste Senior Handlers regarding proper survey methods including use of Micro 11 R11 meter for releasing material from the Restricted the training should include discussions of instrument response Areas. time The 1 the care that must be exercised to detect low level contamination and stress the importance of this compliance function. 1 ACTION ITEM Per the request of the Health Physics Manager, a brief training course to satisf y recommendation number 2, above, will be develo ped and presented to a11 - a aste d Se or Hand'I ers by November 15, 1983, (Resp ons1b 1Hty~ . [%?)-d'4/S llo652K:II cc:

; \'                                                                              RE FERENCE 1 Page 1 of 2

( July 28, 1983 MESSRS:

SUBJECT:

Contaminated Material at Mesa GRIP Facility On July 20, 1983, while tools were being surveyed at t.he....,t ool crib for release from the Restricted Area at Unit 1, a gang box was bro-ught to the area to transport tools to the Mesa. The Radwaste technician surveying the tools chose to survey the box prior to use and found it contaminated to 4 mrad/hr Beta and 0.1 mR/hr gamma in one small spot (see attached survey form.) The box was then removed to the Red Building Area for storage and sampling* (results of sample attached). Upon investig.atio n, it was detenn~ned that the box had just been brought over from the Mesa GRIP Facility for use. Since we confiscated the box, it was inniediately obvious there was some radiologica1 prob1em. A $hort while later 1 a call was received f r o m - a t the ~sa Facility. Concern was expressed over the uncont ~ence of radioactive material at the Mesa. nd .ryself arrived on the Mes*a at noon and questioned the history of the box. The following information was

1) it had been on the Mesa for "over two yea rs 11 ,

2) it had last contained pipe caps,

3) it.had been stored in at least three different locations,

4) other items in the area may have come over from the jobsite at the same time.

No radioactive material was found on this day (July 20, 1983); however, in the following two days, Mesa personnel continued to identify material that they suspected had arrived a year or more ago and may not have been surveyed since. As a resu1t of their calls and surveys by Radwaste technicians two additional items were retrieved. The contamination levels found were 1 13,000 dpm/100 cm~ fixed on a cab1e choker and 200 cpm above background in a

     . sma 11 area of a core dri 11. ( See survey.)

These incidents, in conjunction with a heliarc welding stand found on July 14, would seem to indicate the possibility of the presence of contaminated items at the Mesa Fac1lity which were released from the site prior to instituting the present release controls, In the quantities found to date, *the radiation hazard is believed to be minimal, however, additional controls are needed to prevent release of any like items from the Mesa facilities.

REFERENCE 1 MESSRS: D. DURAN Page 2 of 2 R. *posrK - 2 *. July 28, 1983 ( On Monday July 25, 1983, a tour of all Mesa laydown faciliti es (GRIP Area, Fab Shop, 111111 was made. It was determined that there is no account ability of material at the facility that may have been in the protected area over the past 5-7 years. In addition, only minimal records are available for surveys of items remo ed from the protected areas. Based on this, contact was made with (GRIP Yard Supervisor) and an agre~ment made that Radwaste Healt ysics would be notified in advance of any material leaving the GRIP Yard or Fab Shop areas. A material laydown area at~w as observed on the tour and was determined not to have had material controls in place or have been surveyed by Health Physics. A survey of this area was performed on July 27, 1983 and found no radiation levels above 'background. A comprehensive survey of all items in this area is being performed and should be completed by August 5, 1983, ( cc: CDM files

SONGS: HP *rno'r.v(ouAL~ TASK

                                                                       '  ** . . _: :_ r;. * * .~** '  *.

ASsi'GNMENT-(ITA) : i,.; .OR!GtNATOR:. :a .. :

                       ])Nallie '(Print) t)   Si~~ Bnd*D~t~ *
        .: .          ~;s;:~o:i:;;, ,:;m::::~:~.:' ::.':: *~~ :::: ;,::;:"! ::;:;' ,::                                                   ;::fl'~t;1~!1:!~!i~t:~~*r :'

i;l : d~::.' ,:: :

2) Prime ass i gno"r ah d ass i g ne*e disc us s th is:

PRIME o*utoAU~ of* *." ', Assigned'.to . Prime_. Die oh*~, -~s i*i_9_._._n_*_ onr** :e~te,r.s{_. , By 0 )j

                     . 3). Sub s;quel't t as s*i *g n_or ~n d 'as Sign ee discuss : an.

SUB DUE DATE* 6'-i: '-. . - Assigned_: 'fci..,;_*.*.*- *----'------*8

                                                                                                                            ..Dyu._e. *Date, a~:-j1gn._:fr.>~:~_-.*.o~en__r_: f: '. .\ ':              n:

4) As,slgrior;{'~). g/ye*s original !TA to assigne~ _-1,1nd forward~ a *c'.opy t.o:t~'C.;:c/9f~\?*1!tqr';i _ _

                      *Prim~ Due Dates. shoul ct' be            at  1e~~t 5.     'calen*a;r             d~ys, b:~yond the. date when 'ta~k {ir.s_t::a:ss\ ghed' ..

_ *and ~.ub *D.ue Dates mu:St not b,e la_te_r th:ap P.rime D1,te Oat.es*.:

                    -DUE :oA}E EXTENTION REQUEST:                  This Secti~n: i*s not a ;ubst1tutd for. the 'Prime :bue >D_ate tn: $.ecti!>.n
                   '::If wh' fcii

• lirus t °be a greed to betw(len ass i g'n or/assignee prior. to. e. s tabl-is h:~eit >-'. R~:*g Ui'.reci' ~ltl:'e.ri'-'.

O:s foni:;  ; ntt \ate d - b\1 ass; 9nee, are *to be -reci*u*e st*e d as fa-r ; 11 aiyil nee --6 r th~-: penl1{gd ut:a~t1:X:t5

                 .. a's possi'ble when*e*v~r* completion da.te probiems*a re'.identifi ed..                                                    ' . '                    . .         . . , *. . .
                       * '

• L*

l)

• Ne:w SUB. DUE DATE of _ _ _ _ _ _ _ _ _ _ _ _--'Requested By_.-'-- ---~~--~

2) New PRlME DUt'D,ATE of Requested]3 y - - - - - ' - , , - - - , - - ~ ~

3) Re as on why due '.date cannot be me t _ _ _ _ _ _ _--'--,--,---'----'-- ---c'-~~'---'-,-~, ,__--'---,-c...,_.. .:c__....:....:.,.:,. .-,---"

4) New SUB DUE DATE of.-.-------- -"------ Approv ed By_*------, --+--,----*-_ .-Oii __**-------,--,-,c-~,

5) New .PRIME DUTE .DATE .b,f App-rciv.e<l [ly *.>: .. - *>:**o*n*_'____..'-----~-~

6) Copy .of ITA *forwarded to TAC Coordinato_r .-By_ * .. :..,,,

D.-TASK COMPLET!ON:

• To be.ccimplete d by as~igne*e a~d forwarde.d,t.o originatot. .:**

             . J})J-&~-,~~ri~~fcfo.mplJ~;g~c~- 1,i Th<il?fllileh M&iii\00                                                                      ~~fciJ,16/1<.)&'J]-h;{_,;*

Al:E.,L;i:z~F)&Frae:1~), ti1A:ni62.:iAL~, 14..:":n*~te;;. . 'g.)~:~~,~~~L Ct:flC:.;;;f.)C.v. -t~i1:;~ic~r~--. b _

                      ,T"::~~~;~~\ Ak Y"' ~, , g                                                               .. ** . : .*.* ..... ,.>                                   _               *>**_;/

3) Is .a copy of COMfLETE W_I oat,* ~.ts.) . /

4) Signat~re*o f Asslgnee-

5) Ori.ginator .is to d6~umentati on t~ JAG Codrd1nato r, To TACC on _ _ _ _ _ _ _ __;___ _ _ _ _ date, By..:_**_*_ _.,__:__ ___:__~---'---~--~-...:....,...--....;___:______,

Distributio n: White - Orig{nator Canftry & Pink - Aisidnee. Gold~~rod ~TAC-Coor dinator.:

             ,s<:E sb(12a)       101   RE:V, o 11/7.4/a~

MEMORANDUM FOR FILE December 21, 1983

SUBJECT:

Evaluation of "Most *Significant 11 Potential Radiological Conditions from Inadvertently Released Contaminated Material This memorandum, written in response to the Notice of Violation wh' from* the NRC inspection conducted September 26-30, 1983, by Mr. contains a summary of the requested radiological impact evaluation. included are: *

1. The detailed calculations on which the summary is based;

2. A tabulation of all contaminated items found by December 31, 1983 outside of the Restricted Area;

3. Estimated release dates and radioactive decay corrections;

4. A description of follow-up efforts to locate and control potentially contaminated items; and

5. The status and est~mated completion date of the radiological surveys.

INTRODUCTION Since 1976, San Onofre Nuclear Generating Station, Unit 1 has undergone several major construction and repair projects. Those activities necessarily involved moving tools and materials in and out of Restricted Areas. Although Station procedures regarding the proper release of materials were in effect at that time, controls and methods were not as rigorous as those now in place. In October 1981, some items contaminated with licensed material were discovered outside the Unit 1 Restricted Area. That situation indicated the need for strengthening the contamination control program. As a result, the Health Physics Division began taking steps to increase both procedural and administrative controls over such releases.

• Corrective steps which.were taken included the following:

1. Routine weekly radiation surveys were expanded in October 1981 to include a portion of the Mesa.

2. Health Physics procedures regarding the release of potentially contaminated material were revised in November 1981, to incorporate NRC recommendations contained in NRC IE Circular 81-07.

3. Health Physics Technician coverage at potential release points was increased to 24-hours-a-day in November 1981. The points were locked when no-technician was present.

4. The Health Physics Division began providing continuous, 24-hours-a-day coverage in the holddown area, the final release point from Unit 1 in September 1982.

Memorandum for File December 21, 1983 5, Micro-R meters have been made available to Radwaste personnel permitting more sensitive release surveys.

6. Vehicle monitors were installed and are currently undergoing final testing in the two most heavily used Unit holddown areas as a supplemental measure to help prevent the release of radioactive material.

Con~rol was substantially increased in May 1983, by assigning responsibility to the Radwaste Supervisor for releasing material from SONGS Restricted Areas for unrestricted use~ Control of release is considered a primary function of the Radwaste Group and additional personnel have been committed to meet this goal. The group is currently expending approximately 1000 person-hours per month to perform radiological surveys of material released from Unit 1. As a result of the increased surveillance by the Health Physics Division and cooperation by other groups at SONGS, several items with detectable fixed contamination were discovered at the Mesa in July 1983. Following the realization that additional radioactively contaminated material might be present at the Mesa, the Health Physics Division established a program which included:

1. Initiation of comprehensive radiation and contamination surveys of all Mesa Facilities which could have received materials from the Unit 1 Restricted Area.

2. Imposition of material accountability controls at the affected Mesa Facilities such that no materials could be removed without a Health Physics release.

3. Initiation of an investigation to determine the source of the contaminated material at the Mesa and whether or not similar potentially contaminated items could have been released from the facilities in the past.

STATUS OF FOLLOW-UP EFFORT Approximately 90 person-months have been expended through December 31, 1983, to locate potentially contaminated material ouside the SONGS Restricted Area. Radiological survey efforts are presently concentrated at the Mesa. There are approximately 90 person-months of survey work remaining with an estimated completion date of February 12, 1984.

• Appendix 1 to this memorandum is a lis~ing of all contaminated material which has been found through December 31, 1983. The tabulation includes a description of each item, the location of its discovery, the measured fixed and removable activities, the approximate release date, and the radioactive decay corrected activities estimated to have been present at the time of release.

Memorandum for File December 21, 1983 Appendix 2 describes the rationale for establishing the release dates and characterizes the method for determining the activities present when the items were released. Also included is a discussion of a technique for dating several of the items by Cs-137/Cs-134 ratios. It is important to note that all of the items described in Appendix 1 were released from SONGS Unit 1 before the rigorous controls, enumerated above, were established to prevent such releases. Since their institution, those corrective iteps have prevented the inadvertent release of radioactively contaminated materials from SONGS Restricted Areas. RADIOLOGICAL IMPACT EVALUATION The remainder of this memorandum is a summary of an evaluation of the maximum possible radiological impact to members of the general public resulting from the possible use or possession of any item described in Appendix 1. The evaluation was performed by carefully reviewing the data and then selecting those items from Appendix 1 which were deemed able to present the greatest potential for direct whole body and extremity exposure, for skin contamination, for inhalation, and for ingestion, and then establishing and analyzing a 11 most significant 11 scenario for maximum possible exposure in each of the categories. It is intended that these scenarios represent the most significant possible radiological conditions posed by any contaminated item found. The following sections provide a brief description of the analysis performed for each exposure category mentioned above and cite the appendix which contains the detailed dose calculations. Table 1 summarizes the calculated potential exposures to members of the general public and compares these to the applicable regulatory limits.

Memorandum For File December 21, 1983 TABLE 1

SUMMARY

OF UPPER LIMITS ON MOST SIGNIFICANT POTENTIAL EXPOSURE TO MEMBERS OF THE GENERAL PUBLIC I MOST SIGNIFICANT 10 CFR 20.105 !VALUE ASSUMED EQUIVALENT\ CONDITION I SCENARIO DOSE LIMIT I TO REGULATORY LIMIT I I I I I I. Direct Radiation I I I I Whole Body I I I I I 0.3 mrem/hour I 2.0 mrem/hour I I I 7.8 mrem (Lifetime) I 100 mrern/week I I I I 500 mrem/year I I I I I I Extremity I I I 1 I I 20 mrem/hour I NONE I 30 mrem/hour I I 120 mrem (Lifetime) I I 1500 mrem/week I I I I 7500 mrem/year I I I I I I I. Skin Contamination I I I I I 8.5 mRem/hour 100 mRem (Lifetime) I I NONE I I 2 12 mrem/hour 600 mrem/week I I I I I 3000 mrem/year I I I I I 1I. Inhalation I 69 mrem (Lifetime) I 500 mrem/year I I I I I I IV. Ingestion I 21 mrem (Lifetime) I NONE I 3 1500 mrem/year I I I I I 1 Obtained by multiplying the limits specified in 10 CFR 20.105 by the ratio of maximum permissible whole body and extremity doses contained 10 CFR 20.lOl(a). (See Appendix 3.) 2 Obtained by multiplying the limits specified in 10 CFR 20.105 by the ratio of maximum permissible whole body and skin of whole body doses contained in 10 CFR 20.lOl(a). (See Appendix 4.) 3 Health Physics: Vol 3; "Report of ICRP Committee II on Permissible Dose for Internal Radiation (1959), With Bibliography for Biological, Mathematical and Physical Data 11 , Section II, Paragraph 4(a); 1960. I. DIRECT RADIATION The 1 inch dr~wered impact wrench, retrievetj from the Bechtel warehouse in ~ ( i t e m numbei VI, 9 of Appendix 1), was judged to be the item which presented the greatest potential for whole body and extremity exposure to a member of the general public. Appendix 3 describes the scenario used to evaluate the most significant potential exposure and details the dose calculations.

Memorandum For File M 5 - December 21, 1983 I. DIRECT RADIATION (Continued) Very briefly, the most significant scenario selected for evaluating potential whole body and extremity exposure to a member of the general public involved an individual repairing the 1mpact*wrench, As shown in Table 1, the resultant maximum potential doses are far below those allowed. II. SKIN CONTAMINATION The most significant scenario selected for evaluating potential skin contamination involved the deposition of contaminated grease, on the thigh of the* supposed individual repairing the wrench described in the preceding section. The scenario and the dose calculations are detailed in Appendix 4. As shown in Table 1, the maximum pot~ntial dose to the skin is far below the assumed limit to members of the general public. III. INHALATION Since few of the recovered items had removable surface contamination, there was an insignificant potential for the dispersal or inhalation of radioactive materials. However, for the purposes of evaluation, Appendix 5 describes a scenario in which the non~removabl~ contaminants in a vacuum hose, retrieved from the Bechtel warehouse in.......,(item number VI, 3), are exhausted into a $mall room continu~pied by a member of the general public. As shown in Table 1, and detailed in Apendix 5, the resultant whole body dose is a small fraction of the limit established for members of the general public. The potential whole body dose was more significant than the potential organ dose.

• IV. INGESTION Again, because of the absence of removable contamination, few of the inadventently released items presented a potential for ingestion of radioactive material.

Appendix 6 describes a scenario and contains dose calculations for an individual' who consumes contaminated grease from the impact wrench described in Section I. As shown in Table 1, the resultant dose is again an insignificant fraction of the ICRP II recommendation.

Memorandum For File December 21, 1983 CONCLUSION The evaluation described in this memorandum consisted of establishing and analyzing the most extreme credible scenarios involving the potential for exposure to members of the general public from contaminated items inadvertently released from SONGS. In each case, the maximum potential dose was far below regulatory and related limits. Health Physics Engineer ~0929K/~ cc:

APPENDIX 1 PAGE 1 OF 6 APPENDIX 1

SUMMARY

OF CONTAMINATED ITEMS I l l ACTIVITY DETECTED I ACTIVITY WHEN RELEASED l I I ESTIMATED I FIXED PLUS I REMOVABLE I FIXED PLUS I REMOVABLE I COMMENTS I LOCATION/ITEM DESCRIPTION l RELEASE I REMOVABLE I  ! REMOVABLE I I I I DATE I (c12m) I (CQm)  ! (CQm) I (c12m)  !

!                               l            l               l           !              I           I
! l. AWS WAREHOUSE              I            !              !             I             I          I  These tools and materials were I                               I            l               I            I            I           I  discovered in the AWS Warehouse I    PERSONNEL LOCKERS:         I            I              I             I            I           I  during October 1981. Since

.I I I l I  ! I documentation of radiological I 1. Strapping Tool.  ! 5-1-81 l 300 I I 390 I I surveys at that time was less I 2. Wrench (7/16"} I 5-1-81 I 400 l l 520 I l rigorous than now, the information I 3. Wrench (1-15/16n) I 5-1-81 I 500 I I 650 I I is incomplete in most cases. A I 4. Snap Ring PI iers  ! 5-1-81 l 200 I l 260 I I dash indicates i ncomp I ete data. I 5. Channel Locks I 5:..1-81 I 1,400 I I 1,820  ! I I 6. Channel Locks  ! 5-1-81 I 300 I I 390 I I I 7. Wrench (7/8"} I 5-1-81 I 600 I I 780 I I I 8. Wrench ( 3/4} I 5-1-81 I 300 I I 390 I  ! I 9. Screwdriver I 5-1-81 I 200 I l 260 I I I 10. Screwdriver I 5-1-81 I 400 I I 520 I  ! I 11. Crescent Wrench ( 10 11 ) I 5-1-81 I I 1,500 l I 1,950 I Removable contamination was 11 I 12. Crescent Wrench (12 )1 5-1-81 I I 10,000 I I 13,000 I evaluated by obtaining a gross I 13. Crescent Wrench ( 6") I 5-1-81 I l 3,000 I I 3,900 I smear on masslin and determining I 14. Nylon Slings I 5-1-81 I 200 I I 260 I  ! the count rate with a frisker. I 15. Scaffo Id Wrench I 5-1-81  ! I 600 I I 780 l I 16. Steel Wedge I 5-1-81 I 200 I I 260 I I I 17. Pipe Wrench (14") I 5-1-81 I 700 I I 910 I I I 18. Magnetic Base I 5-1-81 I 300 l I 390 I I

!   19. Crescent Wrench         I 5-1-81     I 1,500        I             I    1,950   I           I I                               I            I              I            I             I           I I    Tool Crib:                 I            I              I            I             l           I I                               I           I               I            I             I           I
! 20. Special Tool              I 5-1-81    I     200       I            I       260   I           I I     800       I            I     1,040   l           I I   21. Air Driven Grinder      I 5-1-81 I 5,000         l            I     6,500   I           I l   22. Crescent Wrench         ! 5-1-81 I   23. Wrench                  I 5-1-81    r     500       r            I       650   I           I I   24. Wrench                  l 5-1-81    I     500       I I

800 l l 650 I I 1,040 I Items 32 through 36 were placed in l the Maintenance Shop crypt in I 25. Slug Wrench I 5-1-81 I I 26. I Bolt I 5-1-81 I 1,000 I l 1,300  ! I January 1981. The materia I I 27. Mi SC. Parts I 5-1-81  ! 500 I I 650 I l remained isolated unti I the crypt I 5-1-81 500 I I 650 I  ! was opened for radiological survey I 28. Grinder Parts  ! I in October 1981. The items were I 11

29. crescent Wrench ( 10 ) I 5-1-81  ! 1,500 l  ! 1,950 I

30. Chicago Fitting l 5-1-81 I 2,000 I I 2,600  ! I returned to the Restricted Area

31. Tin Snips I 5-1-81 I l 1,200 I I 1,560 I after survey and were never I I I I I I accessible to a member of the Machine ShoQ C!:'i:Qt: l I  !  ! l I genera I pub I ic.

                                !           I               !            !             I           I I 1-1-81                    I            I     3,900   I           I Beta corrected measurements      or

32. Stud Tension Tester I I 20 mrad/hr at 1/2 and o. 1 mRad/hr 11 RCS Seal Dummy I 1-1-81 I I 1 1,300 I 33.

I 1-1-81 l l l 650,000 I I at 12" were reported on item No. 35.

34. I Beam I Dose rates when released are Steel 0-Ring I 1-1-81 I I I See Comment I

35. I 650 I I calculated to have been 25% higher.

36. RCS Seal Dummy I 1-1-81 I I

APPENDIX 1 PAGE 2 OF 6 APPENDIX 1

SUMMARY

OF CONTAMINATED ITEMS J I ACTIVITY DETECTED ACTIVITY WHEN RELEASED I l I ESTIMATED FIXED PLUS I REMOVABLE FIXED PLUS I REMOVABLE I COMMENTS I LOCATION/ ITEM DESCRIPTION l RELEASE REMOVABLE I 21 REMOVABLE I 21 l l DATE (CQID) I ( dQml'.'.100cm l ! (CQID) I { d2mL100cm J l  ! I I I I I l I. MESA GRIP FACI UTY I I I I I I I I I j I I l. Pipe Elbov (1") I 5-1-81 >50,000 (on! LLD I 66,000 I LLD l Item No. 1 was found in October l I one sma l 1 I  ! l I 1981. The reported maximum ! I spot) l I I I reading was 10 mRad/hr (Beta l I l l l I co r rected )

• I I I I I I I 2. Wood Plank I 5-1-81 600 I LLD I 1,000 l LLD l Item No. 2 was discovered in I I I I l I March 1982.

l I l I I l I I 3. Gang Box I 5-1-81  ! 300 (genera!) I I 400 l I I I 1>50,000 (on I I I I l l lone sma 11 I <1,000 I >50,000 I <1,000 I Item No. 3 was found in July, 1983. I I !spot inside I I l I No radiation above background on I I I box) I l I l exterior of box. I I I I I I I I I I I I l I I l I I I I I I I I I I I I I 1. Fork! ift Battery I 5-1-81 I See I 4,000 I See I 5,200 I These items were found in October I I Comment I l Comment I I and December, 1981. Reported dose I I 2. Pre-Filters I 5-1-81 I I 3,000 I I 3,900 I rates, in excess of natural back-I I I I I I I ground were: !tern No. 1, 25 uR/hr; I 5-1-81 I I I I I Item No. 2, 40 uR/hr; and I 3. Lead Blankets I Item No. 3, 2 UR/hr. Dose rates I (6 Pa I lets) I I I I I l I I l I I I when- released are estimated to I I I I I I have been 25% higher. I I I I I I I I I I I I I I I LLD These items, released a m1n1rnum I 1. He I i a re we I d i ng Stand I 5-1-81 I 200 I LLD I 340 I I I 2. Rota Hammer I 5-1-81 I 1,000 I <1,000 I 1,700 I 1,100 l of 2 to 3 yea rs ago, we re surveyed Cable Choker I 5-1-81 I 200 I LLD I 340 I LLD I in July 1983. I 3. 340 I LLD I I 4. Core Ori I! I 5-1-81 I 200 I LLD  ! I 5. Tap I 5-1-81 I 100 I LLD I 170 I LLD I Wrench I 5-1-81 I 100 I LLD  ! 170 I LLD I I 6. 680 I LLD I l 7. Dyna meter I 5-1-81 l 400 I LLD I I l I I I I l I I l I I I I I  ! I I 111. AMERON LAYDOWN AREA I  ! I I I I I  ! I I 3-1-77 800 I LLD I 9,100 l LLD I These items, released from Unit 1 I 1. 1

• 5 Meter Di a
• Metal j l I I before 1980, were surveyed in l (max.)  ! I I Rings I

                                                                                                    !       LLD     I August and September 1983.

! 2. Metal Sup po rt Rack l 3-1-77  ! 3,000 I LLD I 34,000 I Steel Shaft (4"x50") I 3-1-77 l 10,000 I LLD I 114,000 I LLD l

3. 3,400 I LLD I I 4. Sp! it Pressure flask I 3-1-77 I 300 I LLD (

Cy! indrica I Meta! I 3-1-77 I 3,000 I LLD I 34,000 l LLD I I 5. I  ! l I Puck I I I LLD - Belov Lower Limit of Detection

APPENDIX 1 PAGE 3 OF 6 APPENDIX 1

SUMMARY

OF CONTAMINATED ITEMS l I I ACTIVITY DETECTED l ACTIVITY WHEN RELEASED I I I ESTIMATED 1 FIXED PLUS ! REMOVABLE l FIXED PLUS ! REMOVABLE l COMMENTS l LOCATJON/ITEM DESCRIPTION J RELEASE l REMOVABLE l 21 REMOVABLE I 21 l J DATE I {cpm} I t dpm/100cm } I (cpm} I ( dom/100cm J I l l l I l I I 6.-11. Pressure I 3-1-77 I 600 {max.) l LLD I 6,800 I LLD I I Desurgers (9} I I  ! I l I 12. Pump Case I 3-1-77 I 75 l LLD I 850 J LLD I 13. 10 cm Shackle I 3-1-77 I 300 l LLD I 3,.400 l LLD l 14. 7.5 cm Shackle I 3-1-77 I 75 l LLD*  ! 850 l LLD I 15. Clamp I 3-1-77 l 75 l LLD I 850 l LLD I 16. Drain Cap l 3-1-77 I 2,000 l LLD I 23,.000 I LLD l 17. Hand Lift l 3-1-77 I 150 l LLD I 1,700  ! LLD I 18.&19. Clamps {2) i 3-1-77 l 350 (max.) l LLD l 4,.000  ! LLD I 20. Cruciform Pipe I 3-1-77 I 5,.000 l LLD I 57,.000 l LLD I 21. 30 cm. Dia. Handwheel [ 3-1-77 I 1,000 I LLD I 11,.400 I LLD I 22. Valve Stem I 3-1-77 I 2,000 I LLD I 23,000 l LLD I 23. 3-Inch Gate Valve I 3-1-77 [ 600 [ LLD I 6,800  ! LLD [ 24.&25. Shackles (2} I 3-1-77 I 100 I LLD I 1,100 I LLD I 26. Aluminium Pipes l 3-1-77 I 2.,.000 I <1.,.000 I 23.,.000 I 5,700  ! I (3} I I (Externa t) I I (Externa l) I I I I l 1,100 I l 12,.500 I I l I I ( lnterna l} l I ( lnterna l) I l 29. Lead Blanket I 3-1-77 I 1,000 I LLD t 11,.400 l LLD l I 30. Metal Brace I 3-1-77 I 700 I LLD l 8,000 I LLD I [ 31. 3tt Thick Meta I Plate I 3-1-77 I 2,600 I LLD I 30,000 I LLD I [ 3-1-77 I 500 l LLD l 5,.700 l LLD I [ 32. 22-inch Pipe I 33. Tube [ 3-1-77 I 1,200 I LLD I 14.,.000 l LLD I [ I I I l I I I l I I I I I I I l l I

1. IV. EDISON SALVAGE YARD - I I  !

                             !            I                 I                 I I                                                                                           I                I I.           I                 I                I I                                                                                           [                l FOUND       l             I                I                 I l     NO ITEMS                                                                I             I                [

I I  ! I J I 1 [ I I I [ [ I I l V. DIVISION MAINTENANCE I I I I l I [ I I FACILli ~T I l NO ITEMS FOUND I J l I I I I [ [ l [ l [ I I I I I I l I I I I I [ I  ! I These items were surveyed in I I I l l I [ I Septembe r 1983 l V!. BECHTEL WAREHOUSE IN l [ I I l [ I I [ l I I Items l through 4 were re I eased I l l l 2,000 [ LLD I 5,600 [ LLD I from Mesa fabricati on Shop during I 1. Ori! l Press I 5-1-81  ! August 1983 I 5-1-81  ! 75 I <1,000 I 210 I I 2. 50', 1/2-inch Dia. l I I I ! Hose l l Removable contamin ation on item 3 I LLD I 4,200  ! LLD I I 3. 24', 2-inch Dia. I 5-1-81 I 1,500 was confined to a 3 Inch long Vacuum Hose j  ! (Externa I) [ (External } I (Externa I) I ( Externa ! } I I

                                          !    10.,.000     I      1,120     I    28,000    I      3,100 J     metal fitting on one end of the l                             l I  ( lnterna I) I      ( Intema I) I ( Interna I) I ( I nterna I ) I hose.

! l LLD-Belov Lo\ler Limit of Detection

APPEND IX l PAGE 4 OF 6 APPENDIX 1

SUMMARY

OF CONTAMINATED ITEMS I l ACTIVITY DETECTED ACTIVITY WHEN RELEASED l I l ESTIMATED FIXED PLUS t REMOVABLE FIXED PLUS I REMOVABLE I COMMENTS I LOCATION/ITEM DESCRIPTION I RELEASE REMOVABLE I 21 REMOVABLE I 21 I I DATE (cpm) l(dpm/lOOcm) (cpm} l(dpm/100cm I I I I I I I I 4. 100 1 , 1 inch Di a. I 5-1-81 I 100 I <1,000 280 I 1,300 1 I Hose I I I I I I 5. Air Po~ered Grinder I 5-1-81 I 4,000 I LLD 11,200 I LLD I Items 5 through 9 were released I 6. 6', 1 inch Dia. Hose I 5-1-81 I 4,000 I LLD 11,200 I LLD 1 from Unit 1 a minimum of 2-3 years l I I { Exte rna l ) l (External) ( Externa 1) l ( Exte rna I ) I ago. I I I 16,000 I <1,000 44,800 I 1, 100 I I I I ( I nte rna I) l ( lnterna I) ( I nterna I) ! (Internal)! I 7. 6', 1 inch Di a. Hose 1 5-1-81 I 1,000 l LLD 2,800 I LLD I I 8. Impact Wrench I 5-1-81 I 1,200 I <1,000 3,400  ! <1,000 l I 9. Impact Wrench I 5-1-81 145,000 (one I 2,200 61,200 I 3,000 I An isotopic analysis of !tern No. 9 l I lhot spot) I ( Externa I ) l  ! I revealed essentially only Cobalt-60. I I I 15mR/hr by 135, 100 $y, 40Cll 20mR/hr I 47,800 $y I ! I ITLD l ( 1nte rna I ) I l I I 10. Welding Connector- I 3-1-77 l 75 I LLD I 880 I LLD I Items 10 through 24 released from I 11.-16. Welding Connectors! 3-1-77 I 100 I LLD  ! 1,170 I LLD I Unit 1-a minimum of 5-6 years ago. I (5) I I I I I I l 17. Welding Connector I 3-1-77 I 100 l <1,000 I 1,170 I 2,800 I I 18. Welding Connector I 3-1-77 I 800 I LLD l 9,400 I LLD I I 19. Welding Connector I 3-1-77 I 800 I <1, 000 I 9,400 I 3,500 l l 20. Welding connector I 3-1-77 I 800 I 1,500 I 9,400 I 17:,500  ! I 21. Welding connector I 3-1-77 1 2,000 I <1,000 I 23,400 I 3,300 I I 22. Welding Connector I 3-1-77 I 2,200 I <1,000 l 25,800 l 10,700 I I 23. Gate Valve I 3-1-77 I 700 I <1, 000 I 8,200 I LLD I l I I ( Externa I) I ( I nte rna I I ( Externa I) I ( Exte rna I) I I I I 800 I and I 9,400 I 7,500 1 I I ( lnterna I) I Externa I) I ( lnterna I) l ( I nte rna I) I I I 24. Gate Va !Ve I 3-1-77 I 1,000 I LLD I 11,700 I LLD I l I ( Externa I) I ( Exte rna I ) l ( Externa I) I { Exte rna l )I I I I l 6,000  ! <1,000  ! 70,000 I 7,400 I I ( lnterna I) I ( I nte rna I ) I ( lnterna l) I ( I nte rna I) I I I I I I I I I I I I I I !. I I I l I I VI I. MESA FENCED AREA  ! I I I WEST OF AMERON l l I l I I I l I The material found, November '83, I l .&2. Head Set I 5-1-81 1,800 l <1, 000 I 5,400 I <3,000 I l <1,000 I 270 I <3,000 I in this area had been received from I 3. Ratchet Wrench I 5-1-81 90 the GRIP Facility before the 100 I <1,000 l 300 I <3,000 I l 4. Staple Gun I 5-1-81 I <3,000 Radwaste Group established control 100 I <1,000 I 300 I I 5. Ratchet Head I 5-1-81 I <3,000 I over the movement of materials I 6. Slug Wrench l 5-1-81 90 I <1,000 l 270 75 I <1,000 I 225 I <3,000 I between areas at the Mesa. l 7. Air Powered Nail Gun 1 5-i"-81 I <3,000 I I 8. C Clamp I 5-1-81 240 I <1,000 l 720 270 l <1,000 I 800 1 <3,000 I I 9. Pipe Stand I 5-1-81 l <3,000 1 ! 10. Pipe Stand  ! 5-1-81 390 l <1,000 1 1,170 LLD - Below Lower Limit of Detection

APPENDIX 1 PAGE 5 OF 6 APPENDIX l

SUMMARY

OF CONTAMINATED ITEMS I I I ACTIVITY DETECTED ACTIVITY WHEN RELEASED l I I ESTIMATED I FIXED PLUS I REMOVABLE FIXED PLUS I REMOVABLE I COMMENTS I LOCATION/ITEM DESCR I PT! ON I RELEASE I REMOVABLE I 21 REMOVABLE I 21 I I DATE I (cpm) I ( dpm/100cm) I (cpm) I { dpm/100cm I I I I I I I I I 11. C Clamp I 5-1-81 l 300 l <1,000 I 900 I <3,000 I I 12. Pipe Stand I 5-1-81 I 125 I <1,000 I 375 I <3,000 I I 13. Strap I 5-1-81 I 200 I <1,000 I 600 I <3,000 I I 14. Vise Grips I 5-1-81 I 3,000 I 1,650 I 9,000 I 5,000 I I 15. Vise Grips I 5-1-81 I 90 I <1,000 I 270 I <3,000 I I 16. Vise Grips I 5-1-81 I 6,500 I 5,800 I 19,500 I 17,400 I I 17; Vise Grips I 5-1-81 I 3,200 I 3,880 I 9,600 I 11,600 I I 18. Vise Grips I 5-1-81 I 75 I <1,000 I 225 I <3,000 I I 19. and 20. Fitting I 5-1-81 I 125 I <1,000 I 375 I <3,000 I I 21. Fitting l 5-1-81 I 150 I <1,000 I 450 I <3,000 I The vi ceg rips, item 16, were I 22. and 23. fitting I 5-1-81 I 100 I <1,000 I 300 I <3,000 I modified for remote operation. I 24. fitting I 5-1-81 I 1,590 I <1,000 l 4,800 I <3,000 I use as a standard hand too! was l 25. Fitting I 5-1-81 I 1,000 I 1,190 I 3,000 I 3,600 I not possible. I 26. Valve I 5-1-81 I 1,000 I <1,000 I 3,000 I <3,000 I I 27. Box l 5-1-81 I 200 I 1,070 I 600 I 3,200 I I 28. Vacuum Tool l 5-1-81 I 250 I <1,000 I 750 I <3,000 l I 29. Regu I a tor I 5-1-81 I 100 *1 <1,000 I 300 I <3,000 I I 30. Socket Drive I 5-1-81 I 250 I <1,000 I 750 I <3,000 I I 31. Winch I 5-1-81 I 200 I <1,000 I 600 I <3,000 l I 32. Bucket I 5-1-81 I 75 I <1,000 I 225 I <3,000 I I 33. T. V. Camera I 5-1-81 I 300 I <1,000 I 900 I <3,000 I I 34. Head Set I 5-1-81 I 200 I <1,000 I 600 I <3,000 I I 35 .. Head Set I 5-1-81 I 250 I <1,000 I 750 l <3,000 I I 36. Metal Disk I 5-1-81 I 400 I <1,000 I 1,200 I <3,000 l I 37. Al !en wrench I 5-1-81 l 250 I <1,000 I 750 I <3,000 I I 38. Pipe Bender I 5-1-81 I 500 l <1,000 I 1,500 I <3,000 l j 39. Pump and Valves I 5-1-81 I 100 I <1, 000 I 300 I <3,000 I

40. Socket Breaker Bar I 5-1-81 l 100 I <1,000 I 300 I <3,000 I I 41. Pipe I 5-1-81 l 300 I <1,000 I 900 I <3,000 l l 42. Gas Bottle I 5-1-81 I 400 l <1,000 I 1,200 I <3,000 !

I 43. Scaffolding Knuckle I 5-1-81 I 2,500 I <1,000 I 7,500 I <3,000 I I 44. Scaffolding Knuckle I 5-1-81 I 18,000 l 4,200 I 54,000 I 12,600 I I 45. Casters I 5-1-81 I 1,000 I <l,000 I 3,000 I <3,000 l I 46. Barrel I 5-1-81 I 200 l <l,000 I 600 I <3,000 l I 47. Glove I 5-1-81 I 200 I LLD I 600 I LLD I l I I I I I I l I I I I I I I I I I [ I These items were surveyed in I VI 11. MESA 2/3 LAYDOWN I November and December 1983. AREA I [ I I I I l I I  ! I I I I 3-1-77 I 1,000 l <1,000 I 12,000 I <12,000 I Item 1 was removed from Unit 1 I 1. Tube Lock <3,000 I before 1980. 2.-7. Knuckle I 5-1-81 I 100 I <1,000 I 300 I I I 5-1-81 I 200 l <1,000 I 600 I <3,000  ! I 8.-9. Knuckle <3.000 I I 10.-11. Knuckle I 5-1-81 I 400 I <1,000 l 1,200 I I 5-1-81  ! 150 l <l.000 I 450 l <3,000 l I 12.-15. Knuckle <3,000 I I 16.-26. Knuckle l 5-1-81 I

• 75 I <1.000 I 225 I

APPENDIX 1 PAGE 6 Of 6 APPENDIX 1

SUMMARY

OF CONTAMINATED ITEMS l 1 ACTlV!TY DETECTED ACTIVITY WHEN RELEASED l l l ESTIMATED FIXED PLUS I REMOVABLE I FIXED PLUS I REMOVABLE l COMMENTS I LOCATION/ITEM DESCRIPTION I RELEASE i REMOVABLE I 21 REMOVABLE I 2l [ I DATE  ! (cpm) I (dpm/100cm) I fcpm)  !{dpm/100cml! j I i I I I

27. Knuckle j 5-1-81 I 350 I [1,000 I 1,050 I [3,000 I

28. Knuckle I 5-1-81 I 80 I [1,000 I 240 I [3,000 I

29. Knuckle I 5-1-81 I 500 l [1,000 I 1.,.500 I [3,000 I

30. Knuckle l 5-1-81 l 250 I [ 1,.000 I 750 I [3,000 I

31. Knuckle I 5-1-81  ! 160 I [ 1.,.000 I 480 I [3,000 I

32. Knuckle l 5-1-81 l 10,000 I [1,000 I 30.,.000 I {3,000 I

33. Knuckle I 5-1-81 I 350 I [1,000 I 10.,.500  ! f3.,.000 l

34. Engineers Box I 5-1-81 I 200 I [1,000 l 600 I [3.,.000 I

35. Tape I 5-1-81 I 300 J [1.,.000 I 900 I {3,000 I

36. fl le I 5-1-81 I 600  ! [1,000 l 1,800 I [3,000 I

37. Box Wrench I 5-1-81 I 80 l {1,000 l 240 I [3,000 I

38. Brass Fittings I 5-1-81 I 800 l fl,000 I 2,400 l {3.,.000 I

39. Hydrolazer I 5-1-81 I 2,000 I 3,700 1 6,000 l 11,100 l l I I I I I I I i I I J

  !  IX_ Mesa   1 rain ino Center                                   I                   I               I                l I                                                                 I                   !               I                I This item.,. round in December 1983.,.

I 1. Survey Instrument 5-27-82 20,000 I LLD l 25,000 I LLD I was released from the Unit 1 I I l I I Restricted Area in May, 1982. lt I I I I I 'tt'aS then transferred f"rom the

 !                                                                  I                   I               l                I Protected Area in May, 19837 to I                                                                  l                  l                I               I the Training Center- f"or use as a l                                                                 l                   [                I               I training aid.

l I l l l [ l I I I X. San Diego State I I University I I I I No items found  ! l l  ! I  ! J I I I I l I I I I  ! These items vere inadvertently I - l I shipped to the manufacturer for I  ! I I I I [ I I l I I  ! repair. The combined fixed plus 5-2-82 l 300 I 1150 (max.)! 350 I 1,300 l removable activity (primarily [ 1.-3. Three level [ l Co-60 and Cs-137) was estimated j detectors. I I J l I [ I I l I  ! at 0.1 uCI_ The items were [ I I I I I surveyed and decontaminated by l I [ l a I Icensed contractor berore I l I I I l I I J I repa I rs were made. I l 1 l I J I I I I I I I I I I I I I l I I l I I I I I I I I l I  ! j I l I [ I I I I I LLD - Below Jover limit of detection 0929K

APPENDIX 2 PAGE 1 OF 3 APPENDIX 2 RELEASE DATE ANALYSIS AND DECAY CORRECTIONS A review of outages and the types of work performed during those outages suggested that October 1976 - March 1977 and March 1980 - June 1981 were the most likely times during which radioactive materials may have inadvertently been released. Major work during the 1976-1977 period included structural steel additions in containment, and construction of the diesel generator and biological shield structures. The 1980 - 1981 outage included the steam generator repair by sleeving and extensive TMI related backfit work. Much material was repeatedly transferred between SONGS 1 and the Mesa facilities during that outage. Large quantities of equipment and materials were removed from containment in March 1977 and May 1981 as the unit was being prepared for return to service. Some of those items were ultimately transferred to various Mesa facilities for storage or salvage. The decay of gross fission products may be described by following equation which was taken from, Introduction to Health Physics, by H. Cember (p. 368): A= 1.46 P[(t-t)-O.Z_t-0' 2J Ci (EQN. 2.1) where A= fission product activity, curies P= power, watts t = reactor operating time, days t = t + time after shutdown, days Figure 2.1 provides a graph of A versus time after shutdown for a reactor which has operated for 500 days. That operating time is a reasonable approximation of one fuel cycle for SONGS 1. Some indication of the age of contaminated material may be obtained by performing an analysis for radionuclides present. The presence of only the longer-lived fission and corrosion products (Co-60, Cs-134, Cs-137) is good evidence that the radionuclides exited the primary system months to years ago. A knowledge of typical Cs-137/Cs-134 ratios during operation, as they applied to primary system and liquid waste streams, combined with a measurement of those radionuclides on recently found contaminated items, permits an estimate of the number of years since the contamination *was released from the reactor coolant system. Before 1981, the Cs-137/Cs-134 ratio was about 1.8 for SONGS Unit 1 reactor coolant. The ratio had increased to 2.5-3.0 by late 1983 as a result of differential decay rates combined with only a few mont~s of operation since early 1980. Items analyzed for radionuclides.are shown in Table 2-1 together with the estimated age" based on Ci-137/Cs-134 ratios. The estimated ages are considered supportive of the estimated release dates shown in Appendix 1.

APPENDIX 2 PAGE 2 of 3 >- 5__ I-1-1 1-1 4_ - - I-u <C 3- - LLJ !;j: 2.. -l l.l.J Cl:'. I 0 1 2 2, 4 5 6 7 TIME AFTER SHUTDOWN (YEARS)

APPENDIX 2 PAGE 3 OF 3 TABLE 2-1

                                  £ESIUM DATING MAJOR RADIONUCLIDES  I                    ~STIMATED 1

ITEM IDENTIFIED Cs~137/Cs-134 AGE ~~EASE DATE Scaffolding l<nuckle (VII, 44) Co-60, Cs-134, Cs-137 8 years I 5-1-81 Vice Grips) Fitting Headset I (VII, 1, 16,21) !Co-60, Cs-134, Cs-137 7 years 5-1-81 Tube Lock I!Co-60, I (VIII, 1) Cs-137 2 3 years 3-1-77 Vacuum Hose I I (VI, 3) ICo-60, Cs-134, Cs-137 2 years 5-1-81 Impact Hammer (VI, 9) ico-60, Cs-134, Cs-1371 10 years 5-1-81 1 The notation in parenthesis refers to the item's location in Appendix 1. 2 Since Cs-134 was not identifed, the m*lnimum detectable activity was used to calculate the ratio. The actual ratio, and thus the age, could be much greater than the listed value. For purposes of the radiological impact assessment, the amount of radioactive material detected on an item was decay corrected, using Figure 2.1, from the time of measurement back to either March 1977 or May 1981, whichever date was more consistent with the probable release date, Because of the special circumstances associated with the material found in the Maintenance Shop crypt, those items were corrected back to January 1, 1981. It should be noted that the reactor was shut down for 6 months before March 1977, and for 15 months before May 1981. The only exception to this method was a nor~a1 decay correction.for items ~hich showed essentially only cobalt to be present. Release dates were estimated from (1) a knowledge of the history of an area (1 .e., GRIP established in 1979; material moved t o ~ 5 years ago ... ), (2) personnel recollections, (3) release tag records, anci (4) dating by Cs-137/Cs-134 ratios. 0929K

APPENDIX 3 ,* PAGE 1 OF 3 APPENDIX 3 EVALUATION OF THE MOST SIGNIFICANT DIRECT RADIATION CONDITION The steel 0-ring which was found in the AWS Maintenance Shop crypt presented the highest exposure rate of all the items listed 1n Appendix 1. However, because the 0-ring was never released from the site and was totally isolated from personnel in its storage location, the exposure potential was insignificant. Instead, the l~inch drive air-powered impact wrench, retrieved from the Bechtel Warehouse i n ~ i t e m number VI, 9 in Appendix 1), was judged to be the item which p ~ e greatest potential for whole body and extremity exposure to a member of the general public. Initial radiological surveys of the wrench revealed only a minimal amount of removable contamination on the external surface, that the direct radiation due to cobalt-60, was emanating from a localized spot inside the handle, and that exposure rates were essentially the same on either side of the handle, No beta radiation was detected. A piece of X-ray film was exposed to the wrench to determine the location and the effective size of the radiation source inside the handle. The image on the film indicated that the source was on the air inlet side toward the lower end of the handle and that the source measured approximately 3/4 inch in diameter. A number of thermoluminescent dosimeters (TLDs) were then *exposed along the length of the handle to further characterize the radiation field. The radiation survey and TLD evaluation results* are summarized in Table 3-1. TABLE 3-1 IMPACT WRENCH SURVEY RESULTS Measurement ~-*Exposure Rate (mR/hr) Method I 1 Contact I 12 11 Eberline R0-2 \ 5.0 0.2 Eberline E620 I with HP270 Probej 13.0 0.2 Panasonic TLD I 15.0 1 .The surface to center-of-detector was* 1 1/2 11 and 1/2 11 for the Eberline R0~2 and HP270 probe, respectively, The center of the TLD phosphor was 1/8 11 from the wrench surf ace.

APPENDIX 3 PAGE 2 OF 3 The 11 contact 11 exposure rates measured w1th the two survey instruments were not corrected for source size or distance effects which resu1t in an under response at short distances. The TLD results are representative of the actual dose rate at the exterior surface of the wrench handle and are used in the dose calculations below. No correction to the TLD measured surface exposure rate (actually 1/8 inch from the surface) was warranted since the actual radioactive source was about 1/4 inch below the surface of the wrench handle and is shielded by greater than 1/8 inch of steel.

• The TLD measurements ranged from 5.5 mR/hr to a high of 19.0 mR/hr. Because the 19 mR/hr was measured near the bottom of the handle, even a 'large hand positioned on the handle woul'd not have extended that low and would have been exposed to a maximum of only about 15 mR/hr.

The exposure rate measured by survey instrument at 12 inches from the wrench surface requires no corrections for geometry or energy, This conclusion is based on a study perf b 11 Externa1 Dose Evaluation Manua 1, BNWL-MA~62, 11 August 5, 1969, which concluded that source size and distance corrections are not required when using an instrument similar to the Eberline R0-2 at source to window distances greater than 6 inches. The contaminated wrench was originally sent to the - f o r repairs. According t9 warehouse personnel, after b ~ w r e n c h was stored at the warehouse until it was found during a radiation survey and subsequently returned to SO~GS. When found, the repair tag was still loosly attached to the wrench which 1s further evidence that the wrench was never operated after being repaired. In its storage location at the warehouse, the wrench presented an insignificant potential for personnel exposure as verified by radiation measurements made at the*storage location. A private firm which performs maintenance and repairs on air powered tools was contacted regarding typical repairs on impact wrenches. It was learned that a* complete rebuild of a wrench of that type would involve no more than 1 to 2 hours of work. However, if weld repairs were naeded, the total repair time could increase to 6 hours. It was further mentioned that if required replacement parts were not locally available; delivery would extend the repair time to 2 weeks. The 11 most s1gnificant 11 scenario selected 'for evaluating potential whole body and extremity exposure involved an individual repairing the impact wrench. The following assumptions were made:

1. Total repair time was 6 hours.

2. The repairman held .the wrench by the. handle at a distance of 12 inches from h1s body during the entire 6 hours.

3, The wrench remained at the work station at a distance of 2 feet from the repairman during a 2 week wait for replacement parts,

4. The exposure rate at a distance of 2 feet was 0.075 mR/hr.

APPENDIX 3 PAGE 3 OF 3

5. 20 mR/hr extremity exposure rate (TLD results decay corrected using cobalt-60 half-life sfnce essentially only cobal\-60 was Identified in the isotopic analysis).

6. 0.3 mR/hr whole body exposure (12 11 detector-to-surface measurement, Eberline R0-2 also decay corrected).

POTENTIAL WHOLE BODY EXPOSURE 6 hours x 0.3mR + 40 hours x 2 weeks x 0.075 mR = 7.8 mR hour week hour POTENTIAL EXTREMITY EXPOSURE 6 hours x 20 mR = 120 mR hour The whole body exposures calculated above are well below the 2mR/hour, lOOmR/week, and 500mR/year allowed in section 20.105 of 10 CFR. The code does not include limits for extremity exposure for members of the general public, however, the code does limit general public annual whole body exposure to 10% of the occupational exposure limits. If the limits specified in section 20.105 are multiplied by the ratio computed of maximum permissible whole body and extremity doses contained in section. 20.lOl(a) [occupational] of 10 CFR as follows: Occupational General Public Extremity Dose Allowed Extremity Whole Body Dose x Limit (10 CFR 20.lOl(a)) = Dcise to a Member Limit (10 CFR 20.105) Occupational of the General Whole Body Dose Public Limit (10 CFR 20.lOl(a)) The results are: 2 mrem (whole body)/hr x 18.75 rem (extremity dose)= 30 mrem/hr (extremity) 1.25 rem (whole body dose) 100 mrem (whole body )/7 days x 18.75 rem (~xtremity dose)= 1500 mrem/7days 1.25 rem (whole body dose) (extremity) 500 mrem (whole body)/year x 18.75 rem (extremity dose)= 7500 mrem/year

• 1.25 rem (whole body dose) (extremity)

The ~alculated potential extremity dose to a member of the general public* is far below values obtained by the above ratioing of occupational and general public whole body exposure limits.

APPENDIX 4 PAGE 1 OF 3 APPENDIX 4 EVALUATION OF MOST SIGNIFICANT SKIN CONTAMINATION CONDITION Initially, it was thought that operation of the air-driven impact wrench, described i'n Appendix 3 would generate an airborne radioactive material condition. To evaluate this possibility, the wrench was secured in a vice and operated continuously for 20 minutes in an 8 1 x 10 1 x 8 1 room with no ventilation. Several air samples were obtained at various distances from the wrench both before and during the 20-minute run time. No difference was observed in the two sets of air sample results. However, a total of approximately 0.5 cm 3 of grease was discharged downward from the wrench exhaust port. It should be mentioned that this was not typical operation for this type of wrench. Under normal loaded operation, the wrench turns much slower and, therefore, the rate of contaminated grease discharge would also be much less than observed in the test. The wrench was subsequently disassembled and a sample of grease was obtained from the exhaust port. The sample was analyzed on a gamma ray spectrometer (Geli detector) and revealed 3.88 E-4 µCi/mg cobalt-60, and 4.44 E-6 µCi/mg cesium-137. The total volume of contaminated grease in the wrench was estimated at 5 cm 3

• The 11 most significant 11 scenario selected for evaluating maximum potential skin contamination involved the deposition of the contaminated grease on the thigh of the repairman while testing the wrench. The following assumptions were made:

1) The total volume of contaminated grease, estimated at 5 cm 3 , was discharged from the wrench.

2) The contaminated grease was deposited on the repairman's pants covering a 10 cm x 10 cm area, 100 cm 2 *

3) The pants were worn for 12 hours before being removed.

4) The epidermis of the thigh is 7 mg/cm 2

• The pants provided an additional 25 mg/cm 2 for a conservative total density thickness (x) of 30 mg/cm 2 between the contaminant and the basal layer of the skin.

5) The grease provided no additional beta particle absorption through self-absorption.

6) All activity in the grease was due to cobalt-60 (99% actually).

7) The.total activity in the grease. (A) was 5.34 E-4 µCi/mg, decay corrected to the time the wrench was relea~ed using the half-life for coba 1t-60.

8) The density of the grease (pg) was conservatively estimated to be 1 g/cm 3

• APPENDIX 4 PAGE 2 OF 3

9) The maximum beta energy (E~max) for cobalt-60 is 0.318 (99+%),

(from Radiological Health Handbook).

10) The average beta energy (E~) is 0.095 MeV, (from Radiological Health Handbook).

11) The density of soft tissue (pt) is 1 g/cm 3

• The *beta dose rate to the basal layer of the skin is calculated by the following semi-emperical equation described by Brownell and Hine in Radiation Dosimetry, pg. 720:

R = 8.0 E-9 pt 2 E~ ~a ~c [l+ln(c/vx) - exp (1-vx/c)J + exp (1-vx~ Rad/hr ( EQN. 4 .1) [ ]=0 for: x c/v where c and~ are empirical constants (2 and 0.260, respectively); the 8.0 E-9 value is a dose conversion factor; vis the apparent beta absorption coefficient of soft tissue; a is the source strength in disintegrations/ hour per cm 2 ; and Pt, E~, and x are used as defined above. The absorption coefficient, v, was calculated by: v = ___1_8_.6_ _ _ _ _ ( 2 - Ea ) cm 2

                                                     /g                          (EQN 4.2)

(Eamax - 0.036) 1.37 E*

                                            ~

where Ea* is a hypothetical average beta ray energy per disintegration for a hypothetical allowed spectrum with the same value of Eamax* For allowed spectra, the ratio Ea/E~* is unity, and the parentheses containing this term is unity. Substituting the value for Eamax' yields:

     \) ::: - -18.6 (0. 318 - 0.036) 1

• 37 v = 105.4 cm 2 /g The source strength, a, is calculated by:

0

        = AfVpg     disintegrations/ hour per cm 2                                 (EQN 4.3) a where A is the activity present in the grease in µCi/mg, .f is a conversion factor with units of distintegrations /hour per µCi, Vis the volume of the grease in cm 3 , Pg is the density of th~ grease in mg/cm 3 , and a is the area of skin exposed in cm 2

• APPENDIX 4 PAGE 3 OF 3 Substituting the values into EQN 4.3, yields:

0

       = {2.34 E-4)(1.33E8)(5)(1000) 100
       = 3.55 E6 disintegrati ons/hour per cm 2 Since:

X > c/v 0.030 g/cm 2 > 2/105.4 cm 2 /g

                  ~ 0.019 g/cm 2 The term within the brackets [ J of EQN 4.1 is identically zero and equation 4.1 reduces to:

R = 8.0 E-9 p2v E~~cr exp (1-vx) Rad/hr (EQN 4.2) Substituting the values into equation 4.2 yields: R = 8.0 E-9(1) 2 (105.4)(0.095)(0.260)(3.55E6)exp[l-(105.4)(0.030)]

        = 8.51 E-3 Rad/hr Assuming a 12 hour exposure period, the total dose to the basal layer of the repairman's skin (D) is given by:

D = (8.51 E-3 Rad/hr)(12 hr)

        = 1.02 E-1 Rad or 100 mRad The Code of Federal Regulations does not include limits for skin exposure for members of the general public, however, the Code does limit general public annual whole body exposure to 10% of the occupational exposure limits. If the limits specified in Section 20.105 are multiplied by the ratio computed of maximum permissible whole body and skin of whole body doses c6ntained in Section 20.lOl(a) [occupational] of 10 CFR as follows:

Occupational General Public Skin Dose A11 owed Ski n Whole Body Dose x Limit (10 CFR 20.lOl(Q)) = Dose to a Member Limit (10 CFR 20.105) Occupational of the General Whole Body Dose Public Limit (10 CFR 20.lOl(a)) The resLllts are:

• 2 mrem (whol~ body)/hr x 7.5 rem (skin dose) = 12 mrem/hr (skin) 1.25 rem (whole body dose) 100 mrem (whole body)/7 days x 7.5 rem (skin dose) = 600 mrem/7 days 1.25 rem (whole body dose) (skin) 500 mrem (whole body)/ye_ar x 7.5 rem (skin dose) = 3000 mrem/year 1.25 rem (whole body dose) (skin)

The calculated maximum potential skin dose to a member of the general public is far below values obtained by the above ratioing of occupational and general public whole body exposure limits.

APPENDIX 5 PAGE 1 OF 5 APPENDIX 5 EVALUATION OF THE MOST SIGNIFICANT INHALATION CONDITION Very few of the items uncovered during the investigation had removable surface contamination in excess of the SONGS release limits. Several of the items with fixed contamination could have presented an inhalation condition had cutting or grinding been attempted on them. However, the potential uptake was so slight for those items, that analyses were not performed. Instead, a 24-foot section of vacuum hose, retrieved from the * (item number VI, 3 in Appendix 1), was selected as the most significant item for this scenario. It Was assumed that, though the contaminants were fixed and not removable, the entire amount of radioactivity in the hose would be exhausted if air were blown through it. The scenario assumes that the entire contents of the hose exhausted into a small room (10' x 10 1 x 8 1 ) occupied by an individual. Those dimensions equate to a room volume of 2.3 E7 cm 3

• The observed deposition of activity was nonuniform along the length of the hose. A detailed radiation survey demonstrated a substantial decrease in activity after the first 8 feet of the hose. Isotopic analyses of several segments of the hose revealed the following nuclides and decay corrected activities:

TABLE 5-1 VACUUM HOSE ISOTOPIC ANALYSIS RESULTS AND INITIAL ROOM CONCENTRATION DECAY CORRECTED ACTIVITY (µCi) I I FIRST 8 1 REMAINING 16 1 I TOTAL I ROOM CONCENTRATION (C) I 0 NUCLIDE SECTION SECTION I @ t = 0 (µCi/cm 3

                                                                                  )

I Mn-54 0. 77 0. 77 I 3.3 E-08 I Co-60 2.99 2.08 E-2 3.01 I 1. 3 E-07

   '                                                      I Cs-134        19.2           1.76 E-3           19.20  I     8.3 E-07 I

Cs-137 31.1 1. 99 E-2 31.12 I 1. 4 E-06 I TOTAL: 54 .10 I 2.39 E-06 In a study performed by et al, published in the July-August 1972 issue of 11 Nuclear Safety, 11 the number of complete a*ir changes per hour were measured for several single family dwellings in New England. Air exchange rate~ of 2 to 3 per hour were observed on the first floor of these dwellings.

APPENDIX 5 PAGE 2 OF 5 Considering the effect of ventilation on activity removal, the effective half-life for removal of the radioactive material from the room is calculated by the equation: r112 (physical)

• r112 (vent) r 112 (effective) = (EQN 5.1) r 112 (physical)+ r 112 (vent) where r (vent)= 0.693
• T (air change), and T (air change) is the 112 room volume divided by the air volume exhausted per unit time.

However, since r 112 (vent)<< r 112 (physical), Equation 5.1 reduces to: r112 (effective)= T112 (vent) (EQN 5.2) If a conservative 2 air volume changes per hour is substituted into equation 5.2: r 112 (effective) - r 112 (vent)= 0.693

• T (air change)

                    - 0.693 Room Volume 2-Room volumes exhausted/hour
                     = *0

• 693 hours 2

Assuming a feed and bleed situation, the concentration of radioactivity present after any time interval is given by the following equation: C =Ce ->.,efft (EQN 5.3) 0 where C0 is the initial concentration, C is the concentration present after time t, >.,eff is the effective activity removal constant, and e is the base of the system of natural logarithms. The effective activity removal constant is the fraction of activity removed per unit time, and is related to the effective half-life r 112 (effective), by:

              \eff=0.693 r 112 (effective)                             (EQN 5.4)

Substituting the value obtained for r 112 (effective) into equation 5.4, yields:

              \ef f = 0, 693 0

• 693 hours 2

                     = 2 hours A plot (Figure 5.1) of airborne radioactive material present in the room vs time shows that the airborne concentration decreases very rapidly.

APPENDIX 5 PN:m: 3 OF 5 4 ____ _ \' *::'. FIGURE 5.1 AIRIDRNE CONCENI'RATION l.OE-6 1.0E-11 a9 ____ - - _- 7 *- - - - E~E=~-~ = 6 -* - - - s__ -- 4_ -* -* 3 ... *- - -

1. OE-7 l.OE-12 9 _ -- -

8 0 1.0E-8 1. OE-13

1. OE-9 1.0E-14 6

                 ,I.

1. OE-10 1. OE-15 0 2 4 6 8 10 12 TIME (HJURS)

APPENDIX 5 PAGE 4 OF 5 The total activity inhaled (AI) by the individual in the room is the product of: Concentration (C), Breathing Rate (B), and Time (t) of exposure. A resting breathing rate of 2.5E5 cm 3 /hour was obtained from ICRP 23 for the most significant individual engaged in light activity. Since the concentration is constantly decreasing, the time integral must be obtained: A1 = ) CBdt (EQN 5.5) Substituting the expression for concentration (from equation 5.3), the value of Aeff, and then solving, yields:

                               - -    µCi 2

Since virtually all of the radioactive material was removed from the air in the room after the first 8 hours, Equation 5.5 yields the same inhaled activity for all values oft> 8 hours. The following dose evaluation was performed using ICRP II methods. The evaluation assumes a single uptake of the contaminants present in the room and calculates the resultant whole body dose using the equation: DOSE= 2.13 ~~- Rem ( EQN 5. 6) Where e is the energy absorption term expressed in MeV (ICRP II), A1 is the inhaled activity, fr is the fraction of inhaled activity retained (ICRP II), fa is the fraction reaching the "critical organ" (ICRP II), mis the body mass in grams (ICRP 23), and Ab is the biological decay constant with units of inverse hours (ICRP II). The 2.13 value is a factor for convefting from energy deposited to dose. An A1 value was ~alcµlated for each nuclide from Table 5-1 information and equation 5.5. Values used in the dose calculation are contained in Table 5-2. Notice that the values used for the energy absorption term (e) relate to 11 total body 11 dose. Those values were conservatively used since the calculated reiultant whole body dose was greater than that to just the lungs.

APPENDIX 5 PAGE 5 OF 5 TABLE 5-2 INHALATION DOSE CALCULATION VARIABLES AI e

                                                                         \ _L NUCLIDE         (µCi)            (MeV)       fr       fa           (hr    )

Mn-54 4.13 E-3 0.51(TB) 0.75 0.3 5.2 E-3 Co-60 1.63 E-2 1. 5 (TB) 0.75 1.0 3.0 E-3 Cs-134 1. 04 E-1 1.1 (TB) 0.75 0.75 4.1 E-4 Cs-137 1. 75 E-1 0.59(TB) 0.75 0.75 4. 1 E-4 The dose contribution from each nuclide was calculated separately using Equation 5.6: Mn-54 = 2.13 (0.51) (0.75) (4.13 E-3) (0.3) = 2.0 E-5 Rem (9,500)(5.2 E-3) Co-60 = 2.13 (1.5) (0.75) (l.63 E-2) (1.0) = 1.4 E-3 Rem (9,500)(3.0 E-3) Cs-134 = 2.13 (1.1) (0.75) (1.04 E-1) (0.75)

                                                               = 3.5 E-2 Rem (9,500)(4.1 E-4)
          . Cs-137 = 2.13    (0.59) (0.75) (1.75 E-1) (0.75)   = 3 . 2 E- 2 Rem (9,500)(4.1 E-4)

Total whole body dose due to inhalation of the contaminants is the sum of the dose from each nuclide: Total dose= E (DMn-54, 0co-60, 0cs-134, 0cs-134)

                         = 6.9 E-2 Rem or 69 mrem The whole body dose calculated above is less than 14% of the 500 mR/year allowed in Section 20.105 of 10 CFR.

0929K

APPENDIX 6 PAGE 1 OF 5 APPENDIX 6 EVALUATION OF THE MOST SIGNIFICANT INGESTION CONDITION Again, because of the lack of significant removable radioactive contamination on most of the inadvertently released items, the potential for ingestion of radioactivity was present for very few of the discovered items. The scenario for the most significant ingestion of radioactivity involves the possible consumption of contaminated grease by an individual operating or repairing the impact wrench described in Appendices 3 and 4. It's difficult to imagine anyone ingesting more than trace amounts of the grease, however, for the purposes of calculation, it was assumed that the subject of the internal dose evaluation ingested 1 cm 3 of the contaminated grease. It was assumed that all activity in the grease was due to cobalt-60 and that the activity was consumed in a single uptake. The total activity ingested (A) is given by: (EQN 6.1) where Vis the volume of grease ingested in cm 3 , A is the activity present 1 in the grease in µCi/mg, and Pg is the conservatively assumed density of the grease in mg/cm 3

• Substituting the values into EQN 6.1, yields:

A= (1)(5.34 E-4)(1000)

      = 0.53 µCi Cobalt-60 encountered at nuclear generating stati~ns is found primarily in the oxide form. ANSI N343-1978, 11 Internal Dosimetry for Mixed Fission and Activation Products," classifies oxides of cobalt as being highly insoluble.

Following the guidance of the Standard, the cobalt was assumed to be nontransportable. The following dose evaluation was performed using ICRP II methods. The dose from both beta and gamma exposure to the contents of the digestive segments are calculated and the dose to the wall of the digestive tract is assumed to be one-half the sum of these values.

APPENDIX 6 PAGE 2 OF 5 TABLE 6-1 INGESTION DOSE CALCULATION VARIABLES I Effective I Energy Terms M, Mass of I ,:, Residence SEGMENT Contents (g) I Time (hrs) .:B(MeV) .:/MeV) Stomach, (S) 250 1 0.1 0.62 Sma 11 Intestine (SI) 1100 4 0.1 1.4 Upper Large Intestine (UL!) 135 8 0.1 0.34 Lower Large Intestine (LU) 150 18 0.1 0.34 The radioactive decay constant (\r) for cobalt-60 is 1.5 E-5 hr- 1 ; the biological removal rate constant (\b) is 3.0 E-3 hr- 1 ; and the fraction of activity transported from the small intestine to the blood (f 1 ) is 0.3. The dose in rem to the stomach due to the beta component (D0SE B) 1s calculated 5 from the equation:

                               -\r,:S 2.13.:BA(l-e           )

OOSESB = Rem (EQN 6.2) 2Ms\r where the 2.13 value is used to convert from energy deposited *to dose and the factor of 2 is used as explained above. Substituting the values into EQN 6.2, yields: 2.13 (0.1)(0.39)(1-e-(l.S E-S)(l)) DOSESB = 2(250)(1.5 E-5)

             = 2.26 E-4 Rem The dose to the stomach from the gamma radiation (DOSE ) is equal to 50 DOSE.SB multiplied by the ratio of the gamma and beta effective energy terms:

D0SE 5Be 0 00SE 50 = (EQN 6.3) eB (2.26 E-4)(0.62)

             =--------

0 .1

             = 1. 40 E-3 Rem

APPENDIX 6 PAGE 3 OF 5 Total dose to the stomach (DOSES) is the sum of the gamma and beta components: DOSES= DOSESB + OOSE 50 (EQN 6.4)

           = 2.26 E-4 + 1.40 E-3 DOSES= 1.63 E-3 rem After one hour, the material is passed to the small intestine (SI).             The average beta dose to the small intestine is calculated by:
                               -\ t      -(\ + \r)tsI r S        b 2.13 eBAe        (1-e               )                          (EQN 6.5)

DOSESIB = Rem 2MsI (\ + Ar) 2.1 3 (O.l)(0. 53 )e-(l.5 E-5)(1)(l-e -(3.0 E-3 + 1.5 E-5)(4)) 2 (1100)(3.0 E-3 + 1.5 E-5) DOSESIB = 2.04 E-4 Rem The gamma dose to the small inteitine is obtained by multiplying OOSESIB by the ratio of the gamma and beta effective energy terms: D0SESIBo DOSESio = - - - - (EQN 6.6) EB

              = (2.04 E-4)(1.4) 0.1 OOSESio = 2.85 E-3 Rem Total dose to the small intestine (D0SE 51 ) is the sum of the beta and gamma components:

DOSEsr = DOSESIB + OOSESio (EQN 6.7)

             = 2.04 E-4 + 2.85 E-3 DOSES!= 3.06 E-3 Rem After five hburs,* the radioactive ~aterial enters the upper large intestine (UL!).

The beta dose to the upper large intestine is calculated by:

                                       -\ T      -\ tULI r        r 2.13 eBA(l-f 1 )e      (1-e         )                            (EQN 6.8)

DOS EU LIB = - - - - - - - - - - - - - Rem where Tis the total time the mat~rial is present in the digestive tract and all other factors are used as described above.

APPENDIX 6 PAGE 4 OF 5 Substituting the values into EQN 6.8, yields:

            = 2.13(0.l)(0.53)(1-0,3)e -(1.5 E-4)(31)(1-e-(1.5 E-5)(8)).

2 (135)(1.5 E-5) OOSEULIS = 2.34 E-3 Rem The gamma dose to the upper large intestine is obtained by multiplying DOSEULIS by the ratio of the gamma and beta effective energy terms: OOSEuur = (EQN 6.9) es

            = (2.34 E-3)(0.34) 0.1
            =  7.95 E-3 Rem Total dose to the upper large intestine (DOSEULI) is the sum of the gamma and beta components:

OOSEULI = DOSEULIS + DOSEULio (EQN 6.10)

           =  2.34 E-3  + 7.95 E-3 DOSEULI =  1.03 E-2 Rem After thirteen hours from ingestion, the radioactive material enters the lower large intestine (LLI). The average beta dose to the wall of the lower large intestine is calculated by:
                                  -ArT      -Art LU 2.13 e:SA(l-f 1 )e      (1-e         )                 ( EQN 6 .11)

OOSELLIS = 2 MLLI Ar

             = 2.13 (O.l)(0.53)(1-0.3)e-(1. 5 E-5)(31) (1-e-(1.5 E-5)(18))

2 (150)(1.5 E-5)

             = 4,74 E-3 Rem

APPENDIX 6 PAGE 5 OF 5 The gamma dose to the lower large intestine is obtained by multiplying DOSELLI~ by the ratio of the gamma and beta effective energy terms: (EQN 6.12) e~

              = (4.74 E-3)(0.34)

(0.1)

              = 1. 62 E-2 Rem Again, total dose to the lower large intestine (DOSELLI) is the sum of the gamma and beta components:

DOSELLI = DOSELLI~ + DOSELLir (EQN 6.13)

             = 4.74 E-3    + 1.62 E-2 DOS ELLI = 2-. 09 E-2 Rem Since the potential dose to the lower large intestine was calculated to be greater than that to any of the other segments of the digestine tract, the lower large intestine was the 11 critical organ."

A calculation performed using methods outlined in MIRO Phamphlet No. 11 demonstrated an insignificant dose contribution (1 mrem) to the lower large intestine from the radioactive material while it was in the other segments of the digestive tract. The maximum potential dose to an internal organ, then, is: DOSELLI = 2.09 E-2 Rem or 21 mrem ICRP II recommends that the internal dose to members of the general pub'lic be limited to 1.5 Rem/year. The 21 mrem received by the subject of the scenario represents less than 2% of this annual limit. 0929K

SONGS Hr INDIVIDUAL TASK ASSIGNMENT (!TA) . : ........ A. assigning ITA is to complete Section B.

                                                                                                                                                              *L~4---;;J!

3) . De~/ r i be Ta s k--'""'-"'Ti-'-"'r"-- '-=-"'--....>.....&4' -'~~===4.c.==--.- -,.-¥,'-"".:..e:;.=.c .....::,;,~,--=*,r.'.l.. !.'.1,~--,,,_._ _ _ _ '_

               ,i
                  . *1 ,.:

I

                               /;;?.,,~
                            ):

j'

1) All necessary documents are to be referenced and/or readily available and/or attached.

2) Prime assignor and ass gnee discuss this Pr~*m .... Date, e , * *assignor

                                                                                                                                                            *D                         en~~rs.: ~*-

PRIME DUE DATE* of ~Assigned to By On /_, ......: <-:; ,... ',~ _.,

                                                                                                                                                                                 ,

• I

3) Subsequent assi~nor and as Due Date, assignor enters:

SUB DUE DATE* of_~~-~ ~ _______ __By On ______

4) Assignor(s) gives original !TA to assignee and forwards a copy td TAC Coordinator.

                  *Prime Due Dates should be at least 5 caleridar days beyond the date when task first assigned and Sub Due Dates must not be later than Prime Due Dates.
      -~. C. DUE DATE EXTENTJON REQUEST: This Section is not a substitute for the Prime Due Date in Sectio~

B which must be agreed to between *assignor/assi gnee prior to establishment . Required exten-sions, initiated by assignee, are to be requested as far in advance of the pending due date(s) as possible whenever completion date prob1e~f are identified.

1) .New SUB DUE DATE of ______ ______ _ Requested By _ _ _ _ _ _ _ _ _On_.-- - - - -

• 1.,

                                                                                                                                                                 ~J\, ',J,~:'.~',1.' e t

2) New PRIME DUE DATE of --~------ --Reque sted By _ _ _ _ _ _ _:_.. *_on***. :.~*.: ,.: ..

3) Reason why due date cannot be met ______ ______ ______ ______ ' :.(Jc

___ . :;.fji.//.'_.

                                        ')'    :*:
                                          ~ ,'I

4) New SUB DUE DATE of _ _ _ _ _ _ _ _ _ _ _ __.Approved By _ _ _ _ _ _ _ _ _on _ _ _ __

5) New PRIME DUTE DATE of Approved By On _ _ _~ -

6) Copy of ITA forwarded to TAC Coordinator By _ _ _ _ _ _ _~ - - - - - - - - - - - - - - -

D, TASK COMPLETION: To be completed by assignee and forwarded to originator.

1) Statement of completed action C::-.6,u?L<S,Tc;D 7HG K.,ffiL')6S t ~

                   .**UE)AO 2 ) Da t e comp 1et ed 2., f .:....           '6 +: *.
                                                                    ...~; ::*'.~),f'.~*:.:'.'*   :,.* *.

3) Is a copy of completio,n ,doc (ACTION IS NOT COMPLETE WITHOUT THIS)

4) Signature of Assignee 5.) Originator is to forward documentation to TAC Coordinator, To TACC on ______ ______ __ date, By ______ ______ ______ __

Distribution: White - Originator Canary & Pink - Assignee Goldenrod - TAC Coordinatof

..!j . " MEMORANDUM FOR FILE

     )
        "                                     February 17, 1984

SUBJECT:

11 01d Highway 101 Land Fi 11 11

REFERENCES:

1) Radiation Survey Report, lllllllllto dated April 17 1 1981

2) Letter ,

(SONGS Chem1s ry,

Subject:

--- "Soil Sample to 981; On January 12 1 1984, a telephone c o n ~ u r r e d between SONGS Environmental Monitoring, a n d ~ USNRC-Region

• inquired about the result s of a Station invest igatio n regard presence of plant-generated radioa ctivity in the "Old Highwaing y the poss, e 101 Land Fill. 11 He recommended that Station review the result s of radiat ion surveys and isotop ic analyses of soil samples obtained at the land fill to determine need for a 10 CFR 20.302 submittal. the

       )

• The purpose of this Memorandum is to document Statio n's evaluation of all availa ble radiological data relatin g to the land fill site and to close the issue.

BACKGROUND: During the March 1980 - June 1981 Unit 1 outage, TMI retrof it projects required the removal of soil from radiol ogical ly controlled areas. Isotop analyses of samples of the excavated material revealed the presen ic level radioa ctive contamination. ce of low As a result of those findings, Station invest igated disposal methods for previous excavations at SONGS Unit 1 to determine whether or not contaminated soil had been inadvertently released. It was determined that the only signif icant excavation which had previously been experienced at Unit 1 was performed during the October 1976 - March 1977 outage when a signif icant amount of substr ate was removed to allow. construction of the Diesel Generator and BiologicaJ Shield structu res. Through interviews with individuals who worked on thos~ projec of the disposal site for the excavated material was also determts, the locati on ined ..

.>~ MEMORANDUM FOR FILE February 17, 1984 SURVEYS AND ANALYSES: Reference 1 describes an extensive radiation survey cond 11 1and fill" area in March 1981. Exposure rates between ucted of the 15 µR/hr were measured by Ludlum Model 19 Micro-R-Meters.5 µR/hr and were well within the normal range for natural background Those readings surveyor concluded that there was no evidence of radio radia tion. The active contamination. That conclusion is subs tanti ated by the resu lts of isoto by EAL Corporation, a cont ract laboratory, on three soil pic analyses performed the land fill. Reference 2 reports those resu lts, and samples obtained from natu rally occurring radon and thoron daughter products. indic ates only activ ation or fissi on products were iden tifie d. No radioactive DISCUSSION:

   **Though all exposure rate measurements were within the background radia tion, the radia tion survey map, conta range of natural ined in Reference l, seemed to indic ate a loca lized area with sligh tly eleva (14-15 µR/hr). To evaluate that anomaly, the land fill ted readings site was visit ed.

The "old land fill 11 is located approximately 1 1/2 miles Edison Training and Education Center. The land fill south of the new frontage road that para llels Inter state 5 on its east is acce ssible by the of two ravines which run from the frontage road> join side. The site cons ists term'inate in a culv ert which continues under the Inte near Inter state 5, and heavily overgrown with foila ge, although dirt mounds rstat e. The area is visib le. and broke n conc rete are Exposure rates of 5 µR/hr to 10 µR/hr were observed in ravine using an Eberline PRM-7 Micro-R-Meter. The readiand around the by placing the meter in contact with the material that ngs were not increased off-loaded there . Special atten tion was paid to the had obviously been highest readings during the referenced survey. The poin area* which showed the elevated readings during the 1981*survey were located ts which showed measurements were made. The exposure rate observed on and exposure rate road was 8 µR/hr to 10 µR/hr. The exposure rate meas the shoulder of the of the concrete road was 14 µR/hr to 16 µR/hr. Similar ured on the surface obtained along the road in the vicin ity of the ravine meas urem ents were An analogous set of measurements made at a location appro with iden tical resu lts. north of the land fill demonstrated comparable resu lts. xima tely 1/4 mile It is obvious that th~ elevated exposure rates are the radio activ ity in the concrete of the road. resu lt of natural

MEMORANDUM FOR FILE February 17, 1984 CONCLUSION: ) Based on the result s of GeLi analyses performed by the contract enviro laboratory, the extensive radiation survey performed in 1981, and the nmental verif icatio n of the resul ts of that survey, the soil disposed of in recen t Highway 101 Land Fill 11 did not contain 1i censed materi a1. A 10 CFR the 11 01d submittal is not required. 20. 302 Engineer COM fi1 es ")

) January 12, 1984

SUBJECT:

Radiolo gical Environ mental Survey of Old Hwy 101 Landfi ll Attache d for your informa tion and review are:

2) results of laborat ory analyse s of soil samples collect ed from the subject landfi ll.

3) Report f r o m - t o oncerni ng Environ mental Survey of subject landfi ll.

Please let me know if you need additio nal help or informa tion. ) Attachm ents cc: )

TE LEP!-KJNE NOTES DISTRIBUTION ACTION REQUIRED I II ), 1-\......, ,. \ 0 l t D C,..J2-lZ- 2-tD. ~ o ~ DISCUSSION HIGHLIGHTS AND AGREEMENTS REACHED

  --~--1..W-f>r'---'S"----'-,...-4-..,_*                             _~ ,_IE_s,___

__ _ _ _K.

                                                                                          ~_"P         __   ~_o_\J.-!'c;...;;._ _~   __ l-\-;...:;.S--

o? '<>@,._Jc!' ~..,... J' 0 '7-kO I O P.,..l.,..~ I \J I "'>'j L -..\ ~ J D.-..,c...:-..:;.?_ _ \-t_vJ_7,,___I_O_l'---l_-~-....r_o_r-_,_...._1..-_..;..* _1111111"1111111111111 "'::>T .,.._..,- c:f" o ( P- pos 1 -r 1 ..J!F" 1:-,;-v-~ ~ A-'?Jov, ;- afl.,,1 tp, >>), 'IJ4-'6"r-!

  ..,-p                  tt:2 () ll.6',S."::,                                                                                                         O.F ID     CJ::-fl                                  ~   u 1=;;, I'\.'\ , -r,A* '- .

g3 ltO 141 NltW 11/10 (cw)

• • \ 1~*~<\.

'41',. I/ 1 I AL CORPORATION 2030 Wright Avenue Richmond, California 94804 (415) 235-2633 (TWX) 910*382-8132 3 April 1981 Ref: EAL 2301

         -*~r Gene rating Stati on P.O. Box 128 San Clem ente, CA 92672 Dear The resul ts of the soil samp les we recei ved on March been comp leted and are shown on Attac hmen t 1.              2, 1981, have We appre ciate this oppo rtuni ty to be of servi ce, Very truly yours ,
                                                      ~ n t a l Chemist
           - A ttachm ent 1 cc:,...

' t, ,,,,,:_ I  : *' f ./ I r, ATTACHMENT l SOIL RESULTS

       )

G*e (Li) Scan Radioch emical Collect i~n Site nCi/kg +/- 2 0- nCi/kg +/- 2 u nnd Date (dry wt. basis) Isotope (dry wt. bnsis) Jap Mesa Dumpsite 0.51 +/- 0.03 soco 1/21/81 0.63 +/- 0,03 137cs

0. 70 +/- o. 04 22eRa decay chain (1) 0.36 +/- 0.07 232Th decay chain (2) 90Sr 0.09 +/- 0.02 SONGS I 0.07 +/- 0.01 eoco Securit y Bldg. 0.04 +/- 0.01 137Cs 1/21/81 _ . 0

• 47 +/- 0
• 0 2. -* 2 21:;iRa decay . .chain .(1) 0.28 +/- 0.04 232Th decay chain (2) sosr 0.02 +/- 0.01.

E. side of 0.05 +/- 0.02 eoco Sphere Near 0.12 +/- 0.02 137Cs Door 16 1.05 +/- 0.05 22°Ra decay chain (1) 2/19/81 0.33  :!: 0.06 232Tb decay chain (2) 90Sr 0 +/- 0.01 Locatio n 0 +/- 0.01 eoco No, 33 Old 0 +/- 0.01 137Cs Hwy. 101 0.33 +/- 0.03 ~26Ra decay chain (1) 2/19/81 0.29 +/- 0.05 232Th decay chain (2) sosr O +/- 0.01 Locatio n 0 +/- 0.01 eoco No .. 28 Old 0 +/- 0.01 137Cs Hwy. 101 0.29. +/- 0.03 22eRa decay chain (1) 2/19/81 0.26 +/- 0.05 232Tb decay chain (2) 90Sr 0.04 +/- 0.01 Locatio n 0 +/- 0.01 soco No. 24 Old 0 +/- 0.01 137Cs Hwy 101 0.42 +/- 0.03 226Ra decay chain (1) 2/19/81 0.35 +/- 0.06 232Tb decay chain (2) gosr 0.02 +/- 0.01 (1) The notural ly occurri ng 2 .:i 0 Ra decny chnin r~por.te d is cnlculn 1 t~d 011 the 21 iBi photope ak at 0.609 MeV. Other photope aks detecte d in this chain are 226Ra, 214pb, 210Bi and 210T1. , (2) The natural ly occurri ng 23 2Th decay chain reporte d is calcula ted on tlie

        \                     :i2eAc pho topeak at O. 910 MeV. Other pho top ea ks detecte d *in this chain are 22srh, 212pb, 212Bi and 2osr1.

SAN ONOFRE NUCLEAR GENERATING STATION MEMORANDA FOR FILE APRIL 17, 1981 TO: FROM: -

SUBJECT:

Environme ntal Survey of 1976~1977 Land Fill Site approxima tely 2.5 miles South East East of Jap Mesa PURPOSE: During the. con~tructi on of Unit One Sphere Containme nt in 1'976 and 1977 a large amount of soil'**was*re moved and disposed of at a site approxima tely 2.5 miles South East East of Jap Mesa. During the disposal operation there was evidential ly no reason to be concerned with the possibilit y of this resultant land fill being contaminat ed with radioactiv e materials resultant from the past operation of Unit One. With in the recent past a careful study has been made of the events surroundin g the exavation and subsequen t disposal of soil associated with Unit One Sphere. The results of this study pointed for a need to survey the land fill site to asertain once and for all the degree of radioactiv e contamina tion, if any, present at the site. On February 4, 1981-hro uh~Febru ary 7 1981 a r a d i a ~ survey io was conducted by..... . . . . . and Although this represe~ n ve e a r ~ e r o questions were raised during the analysis of the survey results. These questions were roostly based on two criteria. First, there was extreme difficulty in matching the data gleened from the two different Ludlum Model 19 Micro-Roentegen Meters used for the survey and the low range calibration of these instruments were also in question. Secondly, data showed a wide variance in reading obtained in adjacent locations. For example data from a survey of the drainage tunnel under Interstate 5 showed a variance from 10 to 150 micro-roentegen/hour. It was also noted that the survey ,did not include information from areas of the ravines were the angle of incline approached and many times exceeded 30 degrees. Because of the foregoing reasons on March 12, 1981 the decision was made to conduct an exhaustive and hopefully reproduceable survey again to asertain once and for all whether or not the activities associated-with the 1976-1977 Unit One Sphere construction had led to any radioactive contamination of the -land fill. DISCUSSION: During initial planning for the survey every attempt was made to devise procedures that would standardize each survey measurement and make it possible to locate at a later date each survey point for later resurvey or soil sampling. After careful research it was decided that all survey measure-ments would be taken at a distance of one meter from the surface of the soil. This hopefully would allow a comparison of results with other environmental surveys performed recently throughout the Health Physics profession.

        , 11 r  ..*

f SAN ONOFRE NUCLEAR GENERATING STATION

   )

MEMORANDA FOR FILE 17. APRIL })I, 1981 PAGE 2 DISCUSSION (Continued): To eliminate techniques were devised to both enhanceanyrepr unexplainable data varience two other and/or any inte rfere nce caused by buildup of oducnatu ability and detect source position rally occuring airborne radio-acti vity . resu ltan t from atmospheric inversion at the Firs t, careful study of the manufacturers liter atur survey points. u~derstanding of the Ludlum Model 19 Micro-Roenteg e yielded a deta iled

• has a one inch by one inch Sodium Iodine (Thallium en Mete r. This instrument at the front and bottom of the instrument. Hence all activ ated ) crys tal located

                   . taken with the face of the instrument dial' and thus         surve   y  measurements were crys tal parr elle l to the soil surface being measured. ly-th   e  cent  erlin e of the . .

ativ ely easy to perform on gent1e inclines and some This tech nique was rel-dealing with incl ines which in some cases exceed 30 what more diff icul t when the manufacturers 1ite ratu re gave helpful informati degr ees. Furt her study of acti stic s of the Ludlum Model 19 Micro-Roentegen Mete on abou t the resp onse char-were theorized to be readable on the. lowest scal e, r. As all meas urem ents all data was taken with the instrument in the Slow 0 to 25 Micro-Roentegen/Hour, mode. This technique resulted in a period of respo Response or Slow Reaction manufacturers liter atur e of approximately 11 *seconds nse as per above mentioned Actual field experience indicated reproduceable respo for each measurement. 5 seconds to as long as 30 seconds. For this reaso nse time of approximately instrument was held in the above discussed geometryn, at each survey point the seconds to insure that the instrument had indeed given for a period of 15 to 30 able measurement. a stable and reproduc-Second, extensive past field experienc radi atio n leve ls had indicated as much as ae 30with the measurement of low level perc observed when the individual holding the instrument ent'variation in readings so as his body was between the source of radiation positioned the instrument to having an unobstructed field of measurement in and the detector as opposed Detailed study of professional papers submitted relation to the known source. Physics profession indicated that the potential for throughout the Health tant from the accumulation of naturally occuring airbo interference in data resul-atmospheric inversions. In worst cases measurements rne radi oact ivity during much as 85%. Jt was noted that these accumulations could be caused to vary as when encount~red during atmospheric inversion almo of airborne radi oact ivity cloud-like concentrations in which a given reading st exclusively represented at leas t 15% with a change in air movement, survey with in the cloud varied time. This char acte risti c of natural airborne radi instrument posi tion , and uceab1e in all instances except those dealing with oactivity appeared r.eprod-such as the drainage tunnel under Inte rsta te Highw a part ially enclosed areas much more uniform due to lack of air movement wi,thay 5 where measurements were tunnel. in center portions of the Due to the foregoing considerations at each surve  ;* measurements were taken. Using a rela tive y point four sepe rate ly netic corrections applied measurements were taken inexpens ive compass with no mag-instrument and the individual holding the instrume at each point with the East, South, and West compass directions nt facing in the North, then in that order.

• ~ *
• I ~ ,*

SAN,ONOFRE NUCLEAR GENERATING STATION MEMORANDA FOR FILE ..... APRIL 17, 1981

                                  '

• P.AGE 3 DISCUSSION (Continued): Comparis made it possible to distingui,sh ason toofwhe the four measurements at each point point was indeed valid and reproduceable. ther Mea the data for each par ticu lar with other measurenents at the same point wou sure ments when late r compared another by less than 15% unless some other infl ld be ex pee ted to vary one from,:

to a point source or bui1d up of natura11y occu uen ce such as close proximety

• during atmospheric invers,ons. Actual fiel d ring airb orne rad ioac tivi ty survey locations out of the over 130 location exp erie nce show ed that only 10 of greater than 15%. Variance was ca1cu1ated s surv eyed show ed a*~ariance lowest of the four readings take at a given by sele ctin g the highest and these two va1ues was then diviaedn by point. The difference* between th~ lowest reading giving a decimal that could be converted to percent variance. Later resurvey of these 10 locations showed tha t ear lier reading were def init ely of naturally occuring airborne radioactivity being effected by the build up For example one survey location when firs t mea during atmospheric inversion.

11.5 and 15 micro-Roentegen per hour. Init ital sured showed readings between showed a variance of ov~r 30% between the four examination of this data After comparison with other ,surrounding surv readings taken at tha t location. this varience was not being caused by a poiney points it appeared evident that

   *,                   it became'readilly clea r when the survey point source. As fiel d experience grew atmospheric inversion. For example on one Sundt was under the influence of an of 19 micro-Roentegen ~er hour was observed ay morning a general background of 8 to 10 micro-Roentegen per hour and when where ear ler dat~ showed ,readings of greater than 15% were observed were resurvey       the locations in which variances was greater than 15% 1ower than that init iall ed the highest reading observed points was well within .:t. 15%.                     y observed and agreement between As the desired goal was to obtain enough info 1andfi11 areas and the nearby area                              rmation from survey of both s  to between the two several techniques were deve  dist ingu   ish     any possible differences area to be surveyed in was deemed that the init      lope   d   to   this end. Due to the large imately 10 meters apart. Later examination of             ial    surv   ey points would be approx-more detailed area survey was required~ but             the     data    would show whether a proved this degree of detail was both expedia       hop    eful   ly,   and as fiel d experience the desired goal. It should be noted that out         te    and    sub   stit ive enough to reach meters surveyed only approximately 900 square            of    the    app  roximately 3000 square as being of landfill orig in.                            met   ers    show  ed dist inc t evidence In order that the data presented would be an                                          * .

trends in radiation ieve1s observed in one area accu rate repr odu ction of the techniques used in taking the measurements beca vers us ano ther the sequ ence and ruggedness of the terr atn line of site approxim me mos t imp orta nt. Due to the angles became impossible. To solv ations of perpendicual or pa~11e1 e although not corrected for magnetic this erro problem a compasss was purchased which, points to be 1ayed out in a NORTH-SOUTH, r,EAST made it possible for adjacent survey on a road map where the upper 1ef t corner is -rlEST GRID somewhat 1ike tha t observed A*l. North-West and has the designation

", ) .. SAN ONOFRE NUCLEAR GENERATING STATION

 ~

j MEMORANDA FOR FILE APRIL 17, 1981 PAGE 4 DISCUSSION (Continued): The sequence desi gne d to most effe ctiv ely :place survin which the survey data was take n was apa rt with out the time consum:1ing~* use ofey loca tion s approximately 10 met ers North-West Corner of the survey area a surv eyo rs equipment, Sta rtin g in the an arc star ting at 90 deg rees and proc eedi sequence of survey poin ts was take n in retu rn to 90 deg rees was affe cted , 'l'his ng to 180 degrees at which time a inte rest was su;rveyed at the pres crib ed proc ess was repe ated unt il the area of 10 meter inte rva ls,

           . ,-**-**lt sho uld be noted tha t at each surv for purposes of both surv ey map.making.a ey poin t* topo grap hica l data* was gath ered The map obta ined can only be con side red nd late r ana lysi s of survey res ults .

it is real ized the measured 10 meter incran accu rate dep ictio n of the area if the. area as if all the dep ress ions eg, ements cause the illu st:r atio n to refl ect same leve l as the upper most elev atio ns ravi nes and gul lies , were rais ed to the of the area , Figu re 1A and 1B show the measurement data As stat ed. all read ings are in micro-Roent reco rded for each surv ey poin t, hou r Sca le of Ludlum Model 19 Micro-Roent egen /Ho ur read ing the 0-25 mic ro-R oen tege n/ reoo:rd.ed. are the high est observed at tha egen Met er Ser ial Number 12906. Readings prev ious disc ussi on it should be noted t poin t from the four read ings take n, From lea st t 15% agreement between measuremen agai n fina l surv ey resu lts refl ecte d at ts, Figu re 2 shows the soi l clas sifi cati reas earc hing rece nt stud ies made in the on given to each survey poi nt, From it was lear ned that rete ntio n of radi oacfiel d of Environmental Health Pny sics por tion al to soi l par ticl e size , This tive mat eria ls in soi l was inv ersl ~ *~ro-area s which showed evidence of bein g actu data was also help ful in def inin ing the to be almost ent irel y beach sand with a al land fill , lan dfil l soi l was known thus ly in most case s a cha rac teri stic allyrela tive ly low soil par ticl e size and pot ent ial, high er natu ral background read ing Fin ally , Figu re 3 dep icts the a:rea incl ine encountered at each survey poi nt,as to the incl ine of the soi l surf ace yie ld a pos sibl e und erst and ing of the pot Init iall y this dat was coll ecte d to acti ve mat eria l found at the survey site enti al tran spo rt mechanism afan y radi o-ful in making the con tour s sho,m as acc , This info rma tion was also most help - rude dire ctio n and measurement tech niqu urat e as pos sibl e in ligh t of* the obviously es used to sele ct the survey poi nts, It should be noted in the sum ific atio n or elev atio n data is showmati on of this disc ussi on tha t no soi l clas n for the survey data coll ecte d in the s-age tunn el und er Inte rsta te Highway drai n-of less than 15%,

                                                    .5 as this was a con cret e tunn el with a slop e

SAN ONOFRE NUCLEAR GEl*;ERATING STATION "ti M.SMORAFDA FOR FILE APR IL 17 , 1981

                 '\.                                                                PAGE  5 CONCLUSION Af!D RECOHJ1IDJIDATIONS: Afte r caref ully exam on the attac hed Figu res 1 through J i t ~ evide              ining the resu lts prese nted evidence what so ever was obtai ned tht would show              nt that no conc lusiv e contaminated by radio activ e mate rials origi natin g    any   of the land fill area was Unit One Containment Sphe re.                             from   the cons truct ion of the As expected the surve y data indic ated the colle cted at widely varin g soil class ifica tiondesir    ed varie nce between data area s, confirming earl ier stud ies that showed the high est background readi ngs in area smal l part icle size -e*g, less than ,2 Il\In, ... -      s were the so~l has a relat ely The read ings obtai ned in the drain age tunn can be expla ined as the read ing are sign ifica ntlyel unde r Inte rstat e Highway 5 at eith er end. This lead s one to belie ve the readi high er in the cent er than of the tunn el are influ ence d by the the buildup ofngs obtai ned in the oent er radi oact ivity due to lack of vene latio n in the centnatu rally occu rring airbo:z:ne sista nt sourc e repre sente d by the conc rete,           er of the tunn el and a con-In summation it shou ld be state d that the was to compare two adja cent area s for radia tion purpo

• • • ,, se of this surve y simply

  )                                                           leve susp ect and the othe r was not, 'Ihe instr umen tatio n ls knowing one area was cons idere d adequate to accomplish this effo rt, It and techn iques used are Ludlum Model 19 Micro-Roentegen meter is calib ratedshould be noted that the Scale by pulse sign al only because of presumed backgon the 0-25 Micro-Roentegen nega ting the poss ibili ty of sourc e calib ratio n, The round radia tion inter feren ce brati on on the subje ct scale was unav ailab le from reco nls of the curr ent cali-department but line arity checks to !mown ranges confi    the 'Instrument and calib ratio n calib ratio n. Each* survey poin t was marked with a white    rmed a roughly accu rate grid loca tion and sequence number for late r refer ence tape marked with the if attem pted, would hope fully use an instr umen t with or res\ll'.'Vey, Resurvey, and be shiel ded from atmo sphe ric inter feren ce using much larg er crys tal si~e aqui sitio n time s at each survey poin t,.Fro m the resusign ifica ntly long er data survey there appe ars very littl e need to attem pt suchlts of this init ial exten sive a resur vey,

                                                        ~                           \J.
                                                        ......              ~       ~
                                                                      ....._..,  Q.,
                                                                            ~
                                                                            ~
                                                                                  ~
                                                      ' "'                  \        ..
                                                    ~ -~                          ~'s;:

-1)* .. ' ~ .; '\\

                                                    ~ ~                            "-~,'
                                           \
                                                                             ~
                       ~                  ....       "t
                                                    ~
                                                                                 ~
                                        *~.
                                         'I l.1,i'

i \;-,<*~

                                            ~
                    . "~
                   \        '           ~
                                        ~
                    ~                       "....
~",': *- ,_;* ~:*. N..                         ,  ,M*          .'-/'

I*'* I

                                                                            -- ~- --- -~ --- -.. ... -.. ..,.o- ~ '"'"*-

I,.(')

• I.O .. I"-. ....... CO . . O"\

                                                                                                                            '     o '"   - '01    '   0   I   +    I<*    I
                                                                                                                                                                    .,N ...
                                                                                                                                                                             \

M

                                                                                                                                                                                                    *----*1
\* *-* .

I *" * " .. ~ ~

                       .                                                                                                              i-1               M                .-i r:i- ---- .                  -.
                                                                                                                                                                                                                     ~::
                                                                                                                                                                                                          .. I
                                                                                                                                                                                        ,.._ "

• I 1..... .. ',..

                                                                                                                          '   ' I      *       '*   I I ' * <f ' ' " '  I  o o ,, '  ,..,~ _..,      I*   I
},....... .__.,                 . r--          '

I j:.:: .~ .,,_.. ""

                                                                                                              -- -- -- -- ~ -- -- --
                                                                                                                                                                                          ... **      ~     ' I
                                                                                         "* *-- *--                                                                                                       . I
                                                                                                                                                                                                                     'j
                                                                                                                                                                                                                  ;o 0

                                                                                                                                                                           ~   .~ ... **- -..................._              _._'
                                                                                                                                                                           -,*      ....... ..._................. .......... , ... 4
                                                                                                                                                                             ,-1-- ........ ... ' ... _*
                                                                                                                                                                          ,,_( ____ -               ****-* ........1

(

                                                                                                                                                                                                            - ..---*'-j
                                 .._,**~*
                                                         . __ ... --------**** **- -........ ... ..............---- -*-- ---- ---- ---- --~ --
                                                                       * ,_., " , , _ .. _ ' " '"' I *
                                                                                                       ,  ~
                                                                                                       .,.,  ' " '"

• I

                                                                                                                                                                                                     ................... ... ~-.1              ,t 1t*i\
                                                                                                                                                   ~ *~*   '&i                                    **~

( ............... _**-~-'-:>- - ~ - " - - - *

                                                                                                                                                               ."' ........   '. .."' - '." :~*:.'.==J.~

(.

                                                                                                            .,                                           -..--*- *-** ---- -.                                                         ~
                      ';I(

x_ . ___ _ ,,I

                 'f'\         "'r..                                                                                                                      ......- - - - - - - ~ * .....--- /I
                 '\            **,                                                                                                                                                                                                     t

A - 3e.,,.,.,1 -..C,...,J' C..(.,.,,,,o/-t':p J .

                                                                                                                                 ~ ......JJ.
                                                                                     ~~: ( fAtd-, *c[-,.:     s;:~ r....

6 uHLU ~v * '-- - -" ..... ~.:.. .~:J- !J I  ;._i 'l.. -l*~ ....

.'         :.. ,:1. -** , *,      .... * * *. , )1.,1  :J, i  l  ~1 ... ,,1 ;

                                            * .... :*I             *-

l

                                                                                / I /Ii;.:

• 0

                                                                                       /     3D 7

8 11 1~ UBLU Sit * * ! - - .... : ,a ... i-J l'.I ~-:..::3

            ;. u, .** ~ .... :, - - n-'<.it 31~.l U.l. Jf :;
                                                                 ** 1..:i ,_J

l*

                                            *-*             * *- . *-** i
                                                                            ~ 0 11'?1'!1
                                .. ~               ...
             . i* ~.::. : .                         :!

1 ,

• I

';:J.i- ~.~~~.--~~--.::i---~~-.~~~ __-__-__ ..-----.-,~r~-

• I

                                ~  4   .* '  .* *, -      *

: : : :.'~J =~*:

  ~~-~~--~~--.~~~.---.--~~-.--~~~-
                                .   '/ ~, * . -       .i
                                * -+:-- *-* * - I
                                                                          .i:,.

0) 0

                                                                          "-J co 0

                                                                                                                                                      )
                                                                                                                                                        "I I
                                                                                                                     -4,/" L *
                                                                                                                   ,,. .L .~ ..:..
                                                                                                               /I             O *,J.O *

($ ~-,o

• C '30° A

11-t" :th' c) tJ _. I ~~~ ~ 3 B -J.. I IL/ . IL( IV Ii I {r) (.4.fJ ,,,

                                                                                                                           "!k: .

f .. \

          ~    'I             It .. ,,.z     9.r; 9        ~.s ~.5'                                     [

• A ,.-.

s Ii .. 3 ;o*,; Jo /D /b 8 ~**_t

                ~               B-3          /0      q*    9     '1                                    B                  ~*
                                                                                                                        *.~               *---
                                                                                                                                              *i 7             C. -3          .9     9 *, 1      g.{                                 E                       A g*          C-J.              C,' 9       q,')  ~.5'                               [                       A
               *er . . - --- .

C-I

                                         ...       --*-   . .          .. . *-*~---~                         ' -~*

IO D~ I  ; l II 'D

• l 7,S ~ 7,S "J.S' E A

                                                                .4'                               L-.-                              .....

I J. D - 3. I '-I /J I<< /;)  ;  ! I' ~ t Vl

  . -~\
            . /3               D-'-/          7     7 ;.! ~()                                     t                    A                            I I'/              c-t./          *7 7 7            7, 5',                               -

J.:::.:_ (1

                                                                                                                       \,..._                     I IS                 B~f            7 7 7               7 e                   ~

                                                                                                                                                .:i.
                                                                                                                                                      ,\

A!.,/,1 L r(..t .. ~ ~ I'/ o -~o*

                                                                                                                       ~       ..,1ia .. ,o*

I) - ('/ 11-Y L. ' ;t.t' ..r;; ( '/ C ,.38':)

       £ ... J/o.,JJ I' I..ALf< ~;, 1~1,;/.,.        r,/.lfl""-*' Ru,./,:,...(}/,...,\...               1 s;.;./ ~ . :1 ' 1 ~

S~/)'1 ?~ ;r., . r;,10 d /V w s * ;::- I ?: 71 I/.~ - -

           /'7                    A-i            7.~ 7.s 7,5 7,o 6            8 17                        A *S'         g         ~       2 fl                                            E            (!_,

If' B*S' 1 1 7 7.J . I t ~-

           /9                    c .. 5           I o.S /D JD I o
                                                                            .J:)                                   13          8
   ., :, rto
      )
                                 ?>-S-           ~.{ f? ?!               /tr                                      (3          A "11                      E"-5'          7,5        7,i>... 7S   7,;;                                     C            fl
         ~J                       E. '/          f}~ Id_ , I/            //                                       T            A c.13                   E.*3             ~*       ~       8     9                                       £             A cJ'i                    E-:2.         @;        * ~ ~1                            *-*~- ... '
                                                                                                                 ~)        *-~

JJ E., I - '

     . cl?.                        r--1
          ;. ?                     F-:l
                                                                                       .                    ~
          ~!                        F-3           1 9 y t.s~                                ; .
                                                                                                                 *c              4            I t""~"

ol'j F-7' (j*,, J.5 13 VJ.~ 7 ~ . Jc:.,  ;::- ..5' ~.*s y,5 ~.;; ?( (! A

                                                                                                                                               \

1l

                                                                                                                                                  ~\
                                                                                                                            .4,.,t/, L "I *,! * .L....;,,

A o *-o

• o- Jl.j'.L., ,.- ~, d .Ja *Jo 0

    £' .. /(O<J...; ,; ~~ ~,*,          f~1. ;/; r,j ,Ifk

• 1 , ~*

                                                                                                                        ,*    >JOO Rt,,,_t,:..,. G /,...\...       ~~

-~"1 ?I/';., .t:7 G~/~ i1I' IV w s IE"' l J:. 7), ti.. -- - - a~ I 31 F' -~ /3S~ )).' { ,2.5 Ji ; c- A J,l *Is, er< ~.f /0 .In *- A A 33 D

• it:, /0*':> 16,~

                                                                     ./

JOl* ~- B A 3'-1 C. - ' q.t5 ~ ?*5 .

                                                                               ~ ')

B A -is' 8-(p g ~ ~-~ JO t- . (2, J~ A*~ C(5 )CJ ;c,.S 9,5 {3 C- _3 _7 11*7 g.5 ~.~ ~..~ 10 ( (! 31* 8 -7 g,5 '1,o i,o '?:S A ff. 3'1"* ... c* . 7* *----- {0,5 II II r/. i; ---- - .(1 ... ~-*---* C*

  'lo                    0.- 7 *               ,~.;            I J_     I~ \~                                    A A        I ii                    E--7                    //.;;         Il        11 It ;                                   A        A
  'I).                  P*    t                J f .f)        13 S 13> I'/, o                                  \~          11
 '13                                           \0 ~

e

                                                                                                     )

G*7 /0 10.;

 /~<

10 4 I - ~-~ Io f

                                                              /0 .')-  /(\   q.;                                 e         A ti ~                  G*                    I~ . /3                r- /3      II E        A                .

                                                                                                                                              .41/'- L
                                                                                                                                            '( ,,1. .. L    ;,,

t'I o .._u,* d ~-,o* {) ... ~ ./. ,:J.~ Ji,, .

                                                                                                                             ,           *C      .,. ;;oo F ... ,(}:µiv/' LA~ .s;,,*1 f'~ :tr,~~~A.4, * /?t~~ (; /,...,'-.. 1 s-.:.t ~       a.-µ S~r.17 ?~ s:t                                                  IV w _c; IF 1 f. 7). t'I. .... - -

G~/1:, d

                       '/(p               G .. '-/         )5 I~                      j /.5"       /J.~                               I        ~
                                                                                                                                               ~

17 G -3 11 ,~.£" *l II. I{ ('_ A.

                       '/?                 G -J.                ~

i-&-....

                                                                     ~ -;
                                                                     -..l
                                                                      -~
                                                                           . .) -

• ~

1, ~s

                                                                                                               - ..J
                                                                                                                                   ~  .        \l' \   '

t/1 c" -I

        .. 5c,                              1-1 ., I
                .I
                       ~I                   I-I . ;i 5,Z                I-/ ., 3       '
                                                            / A,'5' I/
                                                              ~
                                                                            .r;*       /1
                                                                                                  3 .)                              F.         A
                        .._1-J              H .. t./
                                                                  ,/
                                                             /3~) 1i . /3                          14.{                              r;         A             ,

sv** 1-I -S"

                                                          'iJ,5 /l5                   J'H 'JJ:t       .
                                                                                                                                  *E*--          A            ~

_ss-- .. H-, J L( JV /t 15 . G C I

                                                                           ?,(. r.;
                       ~l

• H-7 ~ 9 £ (!

57 H*i ~ i . 1*,J.'~"' . . . 5"! G*8 I S9 F*~ ,,

                                                          ..                                                                                                I
        ... .~O    ,*                       ~-?                                                              I

SONGS HP INDIVIDUAL TASK ASSIGNMENT (ITA) A. ORIGINATOR: assigning ITA is to complete Section B. 1,t****C'*

                                                                                                                                                                                                                                                                                  .~:* ,::<;*//" *'"
                                                                                                                                                                                                                                                                                                                      ; 'w .. J l) Name (Print                                                                                                                                                        2) Enter yo.ur next ITA number                                                                                              .1          ;

3) Descri b.e '>".':: ,,......,-,.,,<,,,..,'I.

                                                                                                                                                                                   ' ' *(' I, 1** ,-.

I

                                                                                                                                                                                                                 ,,,***-::.,...-\.
                                                                                                                                                                                                                                          .-**,           ("
                                                                                                                                                                                                                                        *1.* . (* - ~,-_- I I     I-v'/1-*1
                                                                                                                                                                                                                                                                         ,- * ,.,:.**.*,1) 1 C                              (.
               . . )(~';.~t .f'        ,*';      ...t ..*
                   .)
                  ~) Des c ri ~e .wha ;.- cons tit uty, comp 1et ion /.
                   /;~ .*... , J~A.v* . ti*J,*,.                                       /1.FPf"i.'./..{'"'.'*:-r*uu ;: \... L,:,,.,,(..,~,'.f.*

f.:'.' **:*'\*:'t~*~<<- .

                                                                                                                                                                                         ),0/1 1
                                                                                                                                                                                                      .~i~i.~ l':: "1~L.:' ,(~; r*f',. *~.,-*~*V\. '.: ~'.;:J,* :;_ _ ' *
                                                                                                                                                                                                       *,LtVt

{1 (),~) L ,jJ J,,.(,.j -*~ ,.***,. ~::*, 1 * *

                      . ,*{ ).. '                            ,,. ::;. 1.,                              '. I '                       .,,.,..,.):.;;,,                           I ' '                I                         -l                       'I;;:,            '         ,,        (                                   *  < .

1 , ( ),,. ' .,.,. 1f*~*,-,.y,,l,.,~: I ,{ ,,-i.

• C. ;

J. £1'.J.'2. * ':'.I.. ._

                                                                 *   ,o                  *   *,,.,t,,,_1, ,
                                                                                                              .'\ ~ ~).,{..P.  ~**      ,     C'"  1*             P ..i:'.k,..,)
                                                                                                                                                                            ~
                                                                                                                                                                                               '-'I,/*        1..,_.,c:C./;_~.:_.:.~             ,*:~,-2, . l"(,,£.*,' (.r;::~t*'.      *::~:~::: "*     (;~.*.*.*,* *_*.*.*,**'   "i

\., l*1:**)t' 5 1

                     ')>12l~ i*\p~rg p+--n*t~**1'~-r~'\;~e1r~\; r                                                                                                            *',. e1 *. ,;;,. '              ;'          "J / ' r              .-*: .-1 i (* . / '

1

                                                                                                                                                                                                                                                                              ) **

• 1

                                                                                                                                                                                                                                                                                            .-*:,,,.., .,.*-./,/
                              '1 i' .. ~~* ./***

I 1*.

                                            '   I,..,                   {
                                                                          .*'\.* i't.,,*                      ..                    -,-              ,._....J
                                                                                                                                                              .                             /,-,.,.~.;,.,
                                                                                                                                                                                               /J / ' '
                                    '*~*'<

L* * * / *(_s,/."  ; -,:,,.1._.,(.A (

                                                                                                                             ' L,: ,...*. *1
                                                                                                                                  -, ..,, J
                                                                                                                                                        .-' 1     1,;-* <1 i I .. ,;; k.c*:;<
                                                                                                                                                                             ,,,___.~b-'- '=--~-------- -----------
                                                                             -----.....                                                                                                                   *'"*)                   I.....        f',.lf

6) Sign and D a t e - '*:*. w **** / ,,;>---(\ t--

B. ASSIGNOR(S): Compliance with this Section is indicated by your signature or initials below. l) All necessary documents are to be referenced and/or readily available and/or attached.

2) Prime assignor and assignee, discuss this P r ~ assignor., __ent~~-s: ,*., /i PRIME DUE DATE* of..::) *. ,:-~~:t.&crAssigned t y---------Onc _;_,)r*J :: **,. t*

3) Subsequent assignor and assignee discus Due Date, assignor enters:

SUB DUE DATE* of Assigned to By On _ _ _ _ __

4) Assignor(s) gives original ITA to assignee and forwards a copy to TAC Coordinator.

                  *Prime Due Dates should be at least 5 caleridar~days beyond the date when task first assigned and Sub Due Dates must not be later than Prime Du~ Dates.

C. DUE DATE EXTENTIO~ REQUEST: This Section is not a substitute for the Prime Due Date 1n Section B which must be agreed to between assignor/assignee prior to establishment. Required exten-sions, initiated by assignee, are to be requested as far in advance of the pending due date(s) as possible whenever completion date problems are identified.

1) New SUB DUE DATE of _________ _____ Requested By _________ _ on_ _ _ _ __

2) New PRIME DUE DATE of _______ Requested By On _ _ _ _ __

3) Reason why due date cannot be met _________ ____

4) New SUB DUE DATE of________ ___ Approved By _________ _On

5) New PRIME DUTE DA TE of _________ ____ App roved By. _________ _On _ _ _ _ __

6) Copy of ITA forwarded to TAC Coordinator B y - - - - - - - - - - - - - - - - ~ ~ - - - ~ - -

D, TASK COMP LET I ON : To be co mp 1et e d b_,Y y s i gnee l) Statement of completed action_~~~~~~~ ~-~--~

2) Date compl eted_.~"--+ -A-"--~--"' ~--/--f-<'~- </---------- ----------

3) Is a copy of L/'ves (ACTION IS NOT COMPLETE WITHOUT THIS)

4) Signature of Assignee_

5) Originator is to supporting documentation to TAC Coordinator.

To TACC on -~~~-~~- date, By __~~~~~---~~----~~--~ Distribution: White - Originator Canary & Pink - Assignee Goldenrod - TAC Coordinator

         ,SCI: so(123) 101 RllV, o 11/24/02

February 22, 1984

SUBJECT:

Contaminated Material Discovered on Circulat ing Water Stop Gate #4, San Onofre Nuclear Generating Station Unit 3

REFERENCE:

* *   *-!TA E84-319 On February 12, 1984, the Number 4 stop gate on Unit 3 wa.s removed from service and lifted from its support ~tructur e for inspection. The purpose of the inspection was to determine if the concrete gate was damaged. Because of the close proximity of Gate 4, when in service, to the liquid radwaste discharge point into the circulat ing water system, a radiological survey was performed. A small amount of sludge on the discharge side of the gate was found to be contaminated. The activity was detected when a Frisker Survey of the surface of the gate measured 200 to 400 counts above background. A sample of sludge (approximately 100 grams) was analyzed on the Geli System which identifie d Cr-51, Mn-54, Co-58, Zr-95 and Nb-95. The gate was decontaminated and released for repairs. Approximately five gallons of waste sludge was removed from the gate.

On February 16th, with repairs complete, the Number 4 gate was lifted in preparation for reinstal lation into the support structur e. A survey of the intake side of the gate was performed at that time. No activity was detected. Origin of Contamination The source of the contaminated material found on the stop gate was determined to be liquid radwaste discharging to the circulat ing water system. Radioisotopes identifi ed in the sludge were compared to those in reactor coolant from Unit 2 and Unit 3. Results indicate that the primary source of the contamination was probably Unit 2 and was released*from the miscellaneous radwaste system. Radiological Significance While in service, no radiolog ical hazard exists by the deposition of radioact ive sludge on the stop gate. The only precaution required is to survey the Number 4 stop gate on either unit when lifted out of its normal position for inspection or service. Addition ally, should contaminated sludge be recovered in the future, special radwaste packaging may be required, particul arly if the sludge contains bio-mass.

February 22, 1984 Recommendation -~ Post the Number 4 stop gates on both units to require Health Physics notific ation when those gates are removed from their normal positio n. The Project should be requested to expedite, and the Station to support, the completion of DCP 768.5N. This DCP provides for the relocation of the radwaste discharge line to a more desirable location. Additionally, though there is no evidence that liquid radwaste discharged into the even is passing under or around Gate #4 into the intake, sludge and debris outfall from the intake should be surveyed until DCP 768.5N is completed. cc:

SONGS HP INDIVIDUAL TASK ASSIGNMENT (ITA) A. ORIGINATOR: Corn p1_ E; t e, th i .s Sect i on , 1ndi vi du a 1 assigning ITA is to complete Section B. 1

1) Name (Print ~ - - - - -

• 2) Enter your next ITA number,' ,*:* :i: ,_.-r

                                                                                                                                                                                                                                                              .. *. r                  ,* . *.:*:

...\ 3) Describe Task

                                                   ; fi . *. l.' *: ;

1 ,.. * "

                                                                                                                   /,
                                                                                                                 -,:.' *1* *,. ** r'* , , ..:-*,.',i.~.-f/ /-
                                           / - - ' * - *Tf°"""'"-'-",_."-'""*c,_.,~-*....,,-~'."-""'-'_.,_,._*3-'-1-,*"-.*~:t"",:=:**c...***c..*-'-""---'-:-'"-'-If*-+----'-*

I/ . *** I

                                                                                                                                                                                                * ., ..../,

Ii' l .... *" /i 11.,--11:** '-. f'"I* * / ,_*; ,_-*:;( 1 -+---""'--"-'-'--"------,.c'-'*'--'-clc'--"-;.....,_,-'-1--........,.~..C....:

                                                                                                                                                                                                                                                                                         /:

r:>*, (:";_:,.,.::\ t .,

• I .~-!.!:!L:...::._;,.._:;.,.L,.*

                     ....;:.._ ;. "*' ,::.y     .. ( c :v~)-(,>*, tf***                                   . _, ., ..,,./                                            .;',;'("; -~:o("{** i')                  . f>f~(').                 -1 *,,.*_:;i-<~:,,.    ..,,,.... _ , n , .:f(( *
                                                                                                                                                   ...,                               /

4) Des c r i be what constitutes comp 1 et i on__-jf=:*...'t"i,,..,.'.\._ _ _ **~f_<..=.r,,:~*.::~ -*-------------- -

_. .._*i:~}~*~-1..~,'=':.,_,

6) Sign and Date B. ASSIGNOR(S): Compliance with this Section is indicated by your signature or initials below.

1) All necessary documents are to be referenced and/or readily available and/or attached.

2) Prime assignor ~~d ass.\_ g ee discuss t h- i and~ a ree_ on P r ~ e , assignor_ . ,en~~r~;./,'

PRIME DUE DATE* of;.'.-;,"/ *":1** d - Assigned to By......._______ _On ..,)--* -,; .... 1-,***{-*

3) Subsequent assignor and assignee discuss and agree on sub Due Date, assignor ente;;: 1 SUB DUE DATE* of Assigned to By On ______

4) Assignor(s) gives original !TA to assignee and forwards a copy to TAC Coordinator.

          *Prime Due Dates should be at least 5 caleridar days beyond the date when task first assigned and Sub Due Dates must not be later than Prime Due Dates.

C. DUE DATE EXTENTION REQUEST: This Section is not a substitute for the*Prime Due Date in Section B which must be agreed to between assignor/assignee prior to establishment. Required exten-sions, initiated by assignee, are to be requested as far in advance of the pending due date(s) as possible whenever completion date problems are identified.

1) *New SUB DUE DATE of ________ ____~Requested By ________~On ______

2) New PRIME DUE DATE of Requested By On _ _ _ __

3) Reason why due date *cannot be met __________

4) New SUB DUE DATE of _________ _____Approved By _________ _On_*_ _ _ __

5) New PRIME crUTE DATE of Approved By On _ _ _ __

6) Copy of ITA forwarded to TAC Coordinator By ________ ________ _______

D. TASK COMPLETION: To be completed by assignee ind forwarded to originator.

1) Statement of completed a Ct i On..Ul?.'t::>

P-l=.Q.LJ.r:::;~~ M~OS Pr:rEb Al:': \?6)..)D I K 1 d ?li!.E'PAQ.e.b

2) Date com pl eted.....,3_,__-_...(b_,__j}._,*-%-1--- -------- -------- --------

3) Is a"*copy of completion document attached ~ACTION IS NOT COMPLETE WITHOUT THIS)

4) signature of Ass 1g n e ~ - - - - - - - - - - - - - - - - - - - - - - - -

5) Originator is to forward original ITA *and supporting documentation to TAC Coordinator.

To TAC C on ________ ______ date, By _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Distribution: White - Originator Canary & Pink - Assignee Goldenrod - TAC Coordinator _s<:E so(123) 197 RIZV, 0 11/24/02

UNITED STATES NUCLEAR REGULATORY COMMISSION ., '~* REGION V . '*. 1450 MARI A LANE , SUITE 210

                                                                                                                              *ct..:*f If: CE!':*~ f:

WALNUT CREEK, CALIF ORNI A 94596 FEB 71 ~~4HG io _ ~'.*l !~ 38 f Docket Nos. 50~206, 50*361 and 50-362 Js:111 I 1TB t r Sou ther n Cal ifor nia Edison Company P. 0. J.\.ox 8C>O 2244 Wal nut Grove Avenue

         ~ose s.ea d, C&lifot1l.ia. '91770 Atte Dtio n:

Gentleae.n:

                        =g
                        -                                                 Vice Pre side nt ThAnk yo~ for you r repo rt date d Janu ary you r effo rts to loca te it.el ls contl.11.in.at 16, 1984 des crib ing the stat us -0f aate rla. l. ~ on e>u.r l"e'View of you
                                                                                                  ~d with low leve ls of rad io.c tive r rad iolo sicd eva luat ion and the rep la~ t p.aJt! (Appendix l, page 1) 27 1 19!.4 ~ fi.ad you r conclu.sioz:u; to beprov ided to our insp ecto r on Janu ary reas ona ble.

>:tNe mader*'tMi! tha t you rill s'lill ait *

      ~~ ..J\~ ;dh rts; ~*& n.-, tlie y..) *u let..tt!x info*P,g:,,<11$>.of the 1*.t'e$ult.fi,      .ot:
                                                                                *~l ete .                                                       ** '*'

• t tou r c:oo pen tion With us is app reci ated .

Sin cere ly, Rad iolo gica l

                                                ,\   .*:::

': ; .. .. ... .,.:.~.~

                                                      ' *~ , .,. _**;: ,.'l,*. *1,*.:2,~::.

March 21, 1984

SUBJECT:

Final Results of Survey Efforts at the Mesa Attached for your use is the final summary of contaminated items found at the MESA and a draft letter for transmission of this information to of the US NRC Region V. Should you have any questions or require further assistanc~, please contact me. Health Physics Manager

ATTACHMENT U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596-5368 Attention:

Subject:

Notification of Completion and Final Results of Survey Efforts to Locate Contaminated Material at the Mesa

Reference:

Letter, (SCE) t o - (NRC), dated January 16, 1 ~ to request for follow-up information letter of February 7, 1984, acknowledged receipt of the e er w 1ch transmitted information re ardi r ollow-up efforts contaminated material at the Mesa. letter also requested that SCE forward the final results o s when they were completed. Radiological survey of the Mesa was completed on February 8, 1984. Forty-three (43) additional items with measurable radioactive contamination were found and transferred to the Unit 1 restricted area after December 31, 1983. The enclosure is an updated Appendix 1 to the referenced letter. We have compared the radiological conditions presented by each of the forty-three items to those presented by the "most significant" items evaluated in the referenced report. It was determined that none of the recently recovered items posed a condi-tion that was not already bounded by our radiological impact evaluation. If you require any additional information, please so advise.

APPENDIX 1 PAGE 1 Of 7 APPENDIX 1

SUMMARY

OF CONTAMINATED ITEMS I I ACTIVITY DETECTED I ACTIVITY WHEN RELEASED I [ ESTIMATED J FIXED PLUS J REMOVABLE I FIXED PLUS I REMOVABLE l COMMENTS I LOCATION/ITEM DESCRIPTION RELEASE l REMOVABLE I l REMOVABLE I I I DATE I ( cpm) I (cpm) I ( cpm) I ( cpm) I [ l  ! I l I l I I. AWS WAREHOUSE I I I I 1 I These tools and materials were

  !                                 I                I                 I               I               l              I discovered in the AWS Warehouse I     PERSONNEL LOCKERS:           I               I                 I               I                I             I  during October 1981. Since

[ I I 1 l l I documentation of radiological

  !     1. Strapping Too I          I  5-1-81        I     300         I               I        390    l              I surveys at that time was less
  !    2. Wrench (7/16u)            I  5-1-81       I      400         I               I        520    I              I  rigorous than now, the information
  !     3. Wrench (1-15/16")        I  5-1"'."81    I      500         I               I        650    l              I is incomplete in most cases. A I    4. Snap Ring Pliers          I  5-:-1-81      I     200         I              I         260    I              I dash indicates incomplete data.

I 5. Channel Locks I 5-1-81 I 1,400 I I 1,820 I I

6. Channel Locks I 5-'1-81 I 300 I I 390 I I I 7. Wrench (7/8"} I 5-1-81 I 600 I I 780 l I I 8. Wrench (3/4"} I 5-1-81 I 300 I I 390 I l I 9. Sc re'w'd r i ve r I 5-1-81  ! 200 I I 260 I I I 10. Screwdriver I 5-1-81 l 400 l l 520 l I I 11. Crescent Wrench (10")1 5-1-81 I I 1,500 l l 1,950 I Removable contamination was I 12. Crescent Wrench ( 12") I 5-1-81 I I 10,000 I I 13,000 I evaluated by obtaining a gross l 13. Crescent Wrench (6 11 ) I 5-1-81 I l 3,000 I I 3,900 l smear on mass! in and determining I 14. Nylon Slings I 5-1-81 I 200 I I 260 I J the count rate with a frisker.

I 15. Scarfold Wrench l 5-1-81 I I 600 I I 780 I l 16. Steel Wedge I 5-1-81 I 200 I I 260 I I l 17 .. Pipe Wrench (14") I 5-1-81 I 700 l J 910 I I I 18. Magnetic Base I 5-1-81 I 300 l I 390 J I I 19. Crescent Wrench I 5-1-81 l 1,500 I l 1,950 I I I I I I I I l

!      Tool Crib:                  I               I                 I               l                I             I I                                  !               l                 l               I                I             l I     20. Special Tool             I   5-1-81      l      200        I               I          260   I             I I     21. Air Driven Grinder       l   5-1-81      I      800        I               I      1,040    I              I I     22. Crescent Wrench         I    5-1-81      I   5,000         I               I      6,500    I              I I     23. Wrench                  I    5-1-81     I       500        l               I          650  I              I I     24. Wrench                  l    5-1-81      l      500        I               I          650  !              l    Items 32 through 36 were placed in I     25. Slug Wrench             I    5-1-81     I                  !       800     I               I     1,040    I the Maintenance Shop crypt in I     26. I Bolt                  !    5-1-81      I   1,000         I              I       1,300    I              I January 1981.      The materia I I     27. Misc. Parts             I    5-1-81      I      500        I               I          650  l              I remained isolated until the crypt I     28. Grinder Parts            I   5-1-81      l      500        I               I          650  I              I was opened ror radiological survey 11 I     29. Crescent Wrench (10 )1       5-1-81     I    1,500        I                I      1,950    I              I in October 1981.      The items were I     30. Chicago Fitting         I    5-1-81     I    2,000        l                I      2,600    I              ! returned to the Restricted Area I     31. Tin Snips               I    5-1-81     I                 I     1,200     I                l     1,560    I arter survey and \-/ere never I                                 I               I                 I               I                I              I accessible to a member or the I      Machine Shop Crypt:        l               l                 I               I                I             I genera I pub! ic.

I I I I I I  ! J 32. Stud Tension Tester l 1-1-81 I I I 3,900 I I Beta corrected measurements of I 33. RCS Sea! Dummy I 1-1-81 I I I 1,300 I I 20 mrad/hr at 1/2" and 0. 1 mRad/hr l 34. I Beam I 1-1-81 I I I 650,000 I I at 12n \-/ere reported on item No. 35. I 35. Steel 0-Ring l 1-1-81 I I I See Comment! l Dose rates when released a re I 36. RCS seal Dummy I 1-1-81 I I I 650 I l calculated to have been 25% higher.

• The "Fixed Plus Removable" activities contained in Appendix 1 \-/ere recorded in units o-f counts per minute {cpm}. The typical instrument used to make those measurements was the Eberline RM-14 count rate meter with an HP-260 GM Probe. Nominal efficiency for these instruments is 10%.

APPENDIX 1 PAGE 2 OF 7 APPENDIX 1

SUMMARY

OF CO!'jTAM I !'jATED ITEMS I I ACTIVITY DETECTED ACTIVITY WHEN RELEASED I I J ESTIMATED FIXED PLUS I REMOVABLE FIXED PLUS I REMOVABLE I COMMENTS I LOCATION/ITEM DESCRIPTION I RELEASE REMOVABLE I 21 REMOVABLE I 21 I I DATE {c12m) I {d12mLlQOcm) I (c12mJ l fd12mL1QOcm I I I I I l I I 11. MESA GRIP FACILITY I I I J I l I J I t I I l. Pipe EI bow ( 1 n) I 5-1-81 >50,000 (onl LLD I 66,000 I LLD I Item No. 1 was found in October I I one sma 11 I I I  ! 1981. The reported maxi mum I I spot) I I I I reading was 10 mRad/hr ( Beta I J I I I I corrected ) . I [ [ I I I I 2. Wood Plank J 5-1-81 600 I LLD l 1,000 I LLD l Item No. 2 was discovered in I J I I I I March 1982. I l I I I I I l 3. Gang Box l 5-1-81 I 300 (genera I ) l I 400 I I I I 1>50,000 (on I I I I I I lone small J <1,000 I >50,000 l <1,000 I Item No. 3 was found in July, 1983. I I I spot inside I J I l No radiation above background on I I !box} I I I I exterior of box. J I l l l l I I I I I I I I l I I l I I J I I I I I I I J l. Fork I ift Battery l 5-1-81 I See I 4,000 I See I 5,200 J These items "were round in October J J I Comment I J Comment I J and December, 1981. Reported dose l 2. Pre-Filters I 5-1-81 I J 3,000 I I 3,900 I rates, in excess of natural back-I I l l I I I ground were: Item No. 1, 25 uR/hr; I 3. Lead Blankets I 5-1-81 J I I I I Item No. 2, 40 uR/hr; and J (6 Pa J lets) I J I I I J Item No. 3, 2 uR/hr. Dose rates I I I I I I l when released are estimated to I l I I I I I have been 25% higher. I I l I I I I I I I I l I I I 1. He I i a re We I d i ng Stand! 5-1-81 l 200 l LLD I 340 I LLD I These items, released a m1n1mum l 2. Rota Hammer I 5-1-81 I 1,000 I <1,000 I 1,700 J 1,100 I of 2 to 3 years ago, we re surveyed I 3. Cab I e Choker I 5-1-81 I 200 l LLD I 340 I LLD I in July 1983. I 4. Core Ori 11 I 5-1-81 l 200 I LLD I 340 I LLD I I 5. Tap I 5-1-81 I 100 l LLD I 170 I LLD J I 6. Wrench I 5-1-81 I 100 I LLD I 170 I LLD I I 7. Dynameter I 5-1-81 I 400 I LLD I 680 I LLD I I J I I I J I I I I I I I l I I I I* AMERON LAYDOWN AREA I I I I I I I I I I I I 1

• 1
• 5 Meter Di a
• Metal 3-1-77 I 800 I LLD I 9,100 I LLD I These items, released from Unit 1 I Rings l { max. ) I l I I before 1980, we re surveyed in I 2. Metal Support 11Rack 3-1-77 I 3,000 J LLD I 34,000 J LLD I August and September 1983.

I 3. Steel Shaft (4 x50") 3-1-77 I 10,000 l LLD J 114,000 I LLD I I 4. Split Pressure Flask 3-1-77 I 300 I LLD J 3,400 I LLD I I 5. Cy! indrica I Metal 3-1-77 I 3,000 I LLD I 34,000 I LLD I I Puck I I I I I l I l I I J. I I I I I I I I I I I I I I I I I LLD - Below Lower Limit of Detection

APPENDIX l PAGE 3 OF 7 APPENDIX 1

SUMMARY

OF CONTAMINATED ITEMS I ACTIVITY DETECTED ACTIVITY WHEN RELEASED l ESTIMATED FIXED PLUS I REMOVABLE FIXED PLUS J REMOVABLE I COMMENTS LOCATION/ITEM DESCRIPTION I RELEASE REMOVABLE I 21 REMOVABLE I 21 I DATE (cpm) I { dpm/100cm l (cpm) I ( dpm/100cm I I I I I 6.-11. Pressure  ! 3-1-77 600 ( max. ) I LLD 6,800 I LLD I Desurgers (6) I I I I

12. Pump Case I 3-1-77 75 I LLD 850 l LLD I

13. 10 cm Shackle I 3-1-77 300 I LLD 3,400 l LLD I

14. 7.5 cm Shackle I 3-1-77 75 I LLD 850 I LLD I

15. Clamp I 3-1-77 75  ! LLD 850 I LLD  !

16. Drain Cap I 3-1-77 2,000 I LLD 23,000 I LLD I I 17. Hand Lif't I 3-1-77 I 150 [ LLD I 1,700 I LLD I I 18.&19. Clamps (2} I 3-1-77 I 350 (max.) I LLD I 4,000 I LLD I I 20. Crucironn Pipe I 3-1-77 I 5,000 I LLD  ! 57,000 I LLD I l 21. 30 cm. Dia. Handwheel I 3-1-77 I 1,000 l LLD I 11,400 J LLD  !

I 22. Valve Stem I 3-1-77 I 2,000 I LLD I 23,000 I LLD J I 23. 3-inch Gate Valve I 3-1-77 I 600 I LLD I 6,800 I LLD I I 24.&25. Shackles (2) I 3-1-77  ! 100 I LLD I 1,100 I LLD I I 26.-28. Aluminium Pipes I 3-1-77 I 2,000 I <1,000 I 23,000 I 5,700  ! . I ( 3)  ! I I ( Externa I) I I ( Externa I) I I I I I 1,100 I I 12,500 I I I I I ( I nterna I) I I ( I nte rna I ) I I 29. Lead Blanket I 3-1-77 I 1,000 I LLD I 11,400 I LLD I I 30. Metal Brace I 3-1-77 I 700 I LLD  ! 8,000 I LLD I I 31. 3" Thick Meta I Plate I 3-1-77  ! 2,600 I LLD l 30,000 I LLD I I 32. 22-inch Pipe I 3-1-77 I 500 I LLD I 5,700 I LLD I l 33. Tube I 3-1-77  ! 1,200 I LLD I 14,000 I LLD I I I I I  ! I I I I  ! I l I l I IV. EDISON SALVAGE YARD - I l l l l I I ALHAMBRA I I I l l I l I l I  ! I [ I NO ITEMS FOUND I I I I I I I I I [ I I I I I I l I l I I V. DIVISION MAINTENANCE l I I I I I l FACILITY AT ALAMITOS  ! I I I I I I STATION I I I I I I I I l I l I l l NO ITEMS FOUND I I l I l I I I I l I l I l  !  ! I l l I These items were surveyed in I VI. BECHTEL WAREHOUSE IN  !  ! I I l I September 1983 I LA MIRADA I I I l I l I I I  ! I I I Items 1 through 4 were released I 1. Dri 11 Press I 5-1-81 I 2,000 I LLD I 5,600 I LLD I f'rom Mesa Fabrication Shop during I 2. 50', 1/2-inch Dia. I 5-1-81 I 75 I <1,000 I 210 I I August 1983 l Hose I l I I I I I 3. 24', 2-inch Dia. I 5-1-81 l 1,500 I LLD I 4,200 I LLD I Removable contamination on item 3 I Vacuum Hose I I ( Externa I) I ( Externa I} I ( Externa I) I ( Externa I) I was confined to a 3 inch long I I I 10,000 I 1, 120 I 28,000 I 3,100 I metal fitting on one end or the I l I ( I nterna I) I (Internal)  ! ( lnterna I) I { I nte rna I ) I hose. I I I J. I I I I I l t I I I I I I I I I I I I l I I LLD-Below Lower Limit of Detection

APPENDIX 1 PAGE 4 Of 7 APPENDIX 1

SUMMARY

OF CO!':jTAM!!jATED !TEMS I I I ACTIVITY DETECTED ACTIVITY WHEN RELEASED I I I ESTIMATED I FIXED PLUS I REMOVABLE FIXED PLUS I REMOVABLE I COMMENTS I LOCATION/ITEM DESCRIPTION I RELEASE I REMOVABLE I 21 REMOVABLE I 21 I I DATE I t c12ml I { dQmL10Qcm l I {CQffil I ( dQmll 00cm I I I I I I I I I 4. 100 1 , 1 inch Dia. I 5-1-81 I 100 I <1,000 I 280 I 1,300 I I Hose [ I I I I I I 5. Air Powered Grinder I 5-1-81 I 4,000 I LLD I 11,200 I LLD I Items 5 through 9 were released I 6. 6', l inch Dia. Hose I 5-1-81 I 4,000 I LLD I 11,200 I LLD I from Unit 1 a minimum of 2-3 years I I I ( Externa I) I ( Externa I) I ( Externa I) I ( Externa I) I ago. I I I 16,000 I <1,000 I 44,800 I 1, 100 I I I I ( lnterna I) I ( lnterna I) I (Internal) I (Internal)! I 7. 6' , 1 inch Dia. Hose I 5-1-81 I 1,000 I LLD I 2,800 I LLD I I 8. Impact wrench I 5-1-81 I 1,200 I <1,000 I 3,400 I <1,000 I I 9. Impact wrench I 5-1-81 145,000 (one l 2,200 l 61,200 I 3,000 I An isotopic analysis of Item No. 9 I l !hot spot) I ( Externa I) I I I revea I ed es sent i a I Iy only Cobalt-60. I I I 15mR/hr by !35,100 ,40 l 20rnR/h r I 47,800 I I I JTLD I ( lnterna I) I I I I 10. Welding Connector I 3-1-77 I 75 I LLD I 880 I LLD I Items 10 through 24 re I eased from I 11.-16. Welding Connectors! 3-1-77 I 100 I LLD I 1,170 I LLD I Unit 1 a minimum of 5-6 :yea rs <190. I ( 5) 1 l I I I I l 17. Welding Connector l 3-1-77 I 100 I <l,000 I 1,170 I 2,800 I l 18. Welding Connector l 3-1-77 I 800  ! LLD I 9,400 I LLD I I 19. Welding Connector J 3-1-77 I 800 I <1,000 I 9,400 I 3,500 J I 20. Welding Connector I 3-1-77 I 800 I 1,500 I 9,400 l 17,500 I I 21. Welding Connector I 3-1-77 I 2,000 l <1,000 I 23,400 I 3,300 I I 22. Welding Connector I 3-1-77 I 2,200 I <1,000 I 25,800 I 10,700 I l 23. Gate Valve I 3-1-77 I 700 I <1,000 I 8,200 I LLD l I I I ( Externa I) I ( I nterna I I ( Externa I) I ( Exte rna I ) I l I I 800 I and I 9,400 I 7,500  ! I I I ( I nterna I) l Externa I) I ( lnterna I) I ( Jnterna I) I I 24. Gate Valve I 3-1-77 I 1,000 I LLD I 11, 700 I LLD I

!                               l             l   ( Externa I}     I (External J     I  ( Externa I}  I    (External} I I                               I             I       6,000        I <1,000          I  70,000        I        7,400        I l                               I             I   { Jnterna I)     l ( lnterna I)    I  (Internal)    I    ( l nte rna I ) 1
!                               I             I                    1                 I                I                     l I                               I             I                    J                 I                I                     I I   VI I. MESA FENCED AREA      I             I                    I                 I                I                     !

I WEST OF AMERON l I l I l I I I I I 1 I l I 1.-2. Head Set I 5-1-81 I 1,800 I <1,000 l 5,400 l <3,000 l The materia I round, November '83, I 3. Ratchet Wrench I 5-1-81 l 90 l <1,000  ! 270 I <3,000  ! In this area had been rece lved from I 4. Staple Gun I 5-1-81 I 100 I <1,000 I 300 I <3,000 I the GRIP Facility before the I 5. Ratchet Head I 5-1-81 I 100 I <1,000 I 300 I <3,000 I Radwaste Group established control I 6. Slug wrench I 5-1-81 I 90 I <1,000 I 270 I <3,000 1. over the movement of materials I 7. Air Powered Nai I Gun I 5-1-81 I 75 l <1,000 I 225 I <3,000 l between areas at the Mesa. I 8.* c Clamp I 5-1-81 I 240 I <1,000 I 720 I <3,000 I I 9. Pipe Stand I 5-1-81 I 270 I <l,000 I 800 I <3,000 I I 10. Pipe Stand I 5-1-81 I 390 J <1,000 I 1,170 I <3,000 1 I I I I I I I ! I I J I I I I I I J I J l l I I I I I I I I I I I I l I I 1 I I l l I I J J I l I I I I I I LLD - Below Lower Limit of" Detection

APPENDIX 1 PAGE 5 OF 7 APPENDIX 1

SUMMARY

OF CONTAMINATED ITEMS I I ACTIVITY DETECTED ACTIVITY WHEN RELEASED I I I ESTIMATED l f !XED PLUS I REMOVABLE  ! FIXED PLUS l REMOVABLE I COMMENTS I LOCATION/ITEM DESCRIPTION I RELEASE 1 REMOVABLE  ! 21 REMOVABLE I 21 f I DATE f (cpm} I ( dpm/100cm l I {cpml l(dpm/1QOcm I I l I l l l I f 11. C Clamp l 5-1-81 l 300 l <1,000 I 900 l <3,000 l l 12. Pipe Stand J 5-1-81 I 125 I <1,000 I 375 J <3,000 I l 13. Strap l 5-1-81 I 200 I <1,000 I 600 I <3,000 I I 14. Vise Grips f 5-1-81 I 3,000 l 1,650 I 9,000 I 5,000 I I 15. Vise Grips f 5-1-81 J 90 l <1,000 I 270 I <3,000 I I 16. Vise Grips I 5-1-81 l 6,500 I 5,800 I 19,500 I 17,400 I I 17. Vise Grips I 5-1-81 I 3,200 I 3,880 I 9,600 I 11,600 I I 18. Vise Grips t 5-1-81 I 75 I <1,000 I 225 I <3,000 I I 19. and 20. Fitting t 5-1-81 l 125 I <1,000 I 375 I <3,000 I t 21. Fitting I 5-1-81 f 150 I <1,000 I 450 I <3,000 I The vicegrips, item 16, were I 22. and 23. Fitting l 5-h81 l 100 J <1,000 I 300 I <3,000 I modified for remote operation. I 24. Fitting J 5-1-81 I 1,590 I <1,000 I 4,800 I <3,000 I Use as a standard hand tool was I 25. fitting I 5-1-81 I 1,000 I 1,190 I 3,000 I 3,600 I not possible. I 26. Valve f 5-1-81 I 1,000 I <1,000 f 3,000 I <3,000 l t 27. Box I 5-1-81 l 200  ! 1,070 I 600 I 3,200 I f 28. Vacuum Toof I 5-1-81 I 250 I <l ,000 I 750 I <3,000 I f 29. Regu fa tor I 5-1-81 l 100 l <1,000 I 300 1 <3,000 I I 30. Socket Drive I 5-1-81 I 250 I <1,000 l 750 I <3,000 I t 31. Winch I 5-1-81 f 200 I <1,000 I 600 I <3,000 l 1 32. Bucket 1 5-1-81 I 75 l <1,000 I 225 I <3,000 J I 33. T. V. Camera I 5-1-81 l 300 I <l,000 l 900 I <3,000 l I 34. Head Set l 5-1-81 I 200 I <1,000 I 600 I <3,000 I

 ! 35. Head Set                  I 5-1-81        I       250       I       <1,000     I        750     I     <3,000      I f 36. Metal Disk                I 5-1-81       I        400       f       <1,000     I     1,200      I     <3,000      I I 37. Allen Wrench              I 5-1-81       I        250       I       <1,000     I        750     I     <3,000     I f 38. Pipe Bender               I 5-1-81       I        500       I       <1,000     I     1,500      f     <3,000     l I 39. Pump and Valves           l 5-1-81       l        100       I       <1,000     l        300     I     <3,000     I I 40. Socket Breaker Bar        I 5-1-81       l        100       I       <1,000     I        300     I     <3,000     I I 41. Pl pe                     I 5-1-81       l        300       l       <1,000     I        900     I     <3,000     l I 42. Gas Bottle                I 5-1-81       I        400       I       <1,000     I     1,200     I      <3,000     I l 43. Scaffolding Knuckle        I 5-1-81       1     2,500       I        <1,000     I     7,500     l      <3,000     I l 44. Scaffolding Knuckle       I 5-1-81        I    18,000       I         4,200    I     54,000     I      12,600     I I 45. Casters                    I 5-1-81       I     1,000        I       <1,000     I     3,000      I     <3,000     I I 46. Bar re I                  f 5-1-81        J        200      I-      <1,000     I         600    I      <3,000     I I 47. Glove                     I 5-1-81        l        200      I            LLD   I         600    l          LLD    I I                               I               l                 I                  l                I                 I I                               I                                 I                  l                I                 I

!VIII. Mesa Training Center l l I J I I I I I J J This item, found in December 1983, I 1. Survey Instrument I 5-27-82 20,000 l LLD l 25,000 I LLD J was released from the Unit 1 l I I I I I Restricted Area in May, 1982. It I I I I I I was then transferred from the I I I I I I Protected Area in May, 1983, to I l I I I the Training Center for use as a I I I I I t ra in i ng a i d.

                                !                                I                   I               I                 I
                                !                                I                  I                I                 I IX. San Diego State                                         I                  I                I                I University                                               I                  I                I                l l                  I                I                !

No items found I l I J I I I l I l I I I I I l LLD - Below lower limit or detection

APPENDIX 1 PAGE 6 OF 7 APPENDIX 1

SUMMARY

OF CONTAMINATED ITEMS l l ACTIVITY DETECTED ACTIVITY WHEN RELEASED I I I ESTIMATED l FIXED PLUS I REMOVABLE FIXED PLUS I REMOVABLE I COMMENTS I LOCATION/ITEM DESCRIPTION I RELEASE l REMOVABLE [ 21 REMOVABLE I 21 I I DATE I {CQffi}  ! {dQmL100cmJ I {CQm} l {dQm[l 00cm} I [ [ I l I l [ I X. Trans America/ l l I l l [ l Deleval Corporation - I l [ l I I These items were inadvertently I Connec:i;icut I I r I I I shipped to the. manufacturer for I I l I I I I repair. The combined fixed plus I 1.-3. Three level I 5-2-82 I 300 I 1150 (max.) I 350 I 1,300 [ removable activity (primarily I detectors. I l I I I I Co-60 and Cs-137) was estimated I I I I I I l at 0. 1 uCi. The items were I I I I I  !  ! surveyed and decontaminated by I l I I I l l a I icensed contractor before I I I I I I I repairs were made. l I I I I I I I I I I I I I l XI. MESA 2/3 LAYDOWN  ! I I I I l Items 1-39 were surveyed in I AREA I I  ! I [ l November and December 1983. I I I I I I I l 1. Tube Lock l 3-1-77 I 1,000 I <1,000 I 12,000 I <12,000 I Item 1 was removed from Unit I, 2.-7. Scaffo Id Knuckle I 5-1-81 I 100 [ <1,000 [ 300 [ <3,000 I before 1980. I 8.-9. Scaffold Knuckle I 5-1-81 I 200 I <1,000 l 600 I <3,000 I l 10.-11. Scaffold Knuckle I 5-1-81 I 400 l <1,000 l 1,200 l <3.000 l I 12.-15. Scaffold Knuckle I 5-1-81  ! 150 l <1.000 l 450 I <3,000 I I 16.-26. Scaffold Knuckle l 5-1-81 I 75 I <1.000 I 225 I <3,000 l I 27. Scaffold Knuckle I 5-1-81 I 350 I <1,000 I 1,050 l <3,000 ! I 28. Scaffold Knuckle I 5-1-81 l 80 I <1,000 l 240 l <3,000 I l 29. Scaffold Knuckle I 5-1-81 I 500 I <1,000 I 1,500 I <3.000 l I 30. Scaffold Knuckle l 5-1-81 I 250 I <1.000 I 750 I <3,000 l I 31. Scaffold Knuckle I 5-1-81 I 160 I <1.000  ! 480 l <3,000 l I 32. Scaffold Knuckle I 5-1-81 I 10,000 I <1.000  ! 30,000 I <3,000 I l 33. Scaffold Knuckle I 5-1-81 I 350 I <1.000 I 10,500 I <3,000 l I 34. Eng i nee rs Box I 5-1-81 I 200 I <1,000 I 600 I <3,000 I I 35. Tape I 5-1-81 I 300 I <1,000 I 900 I <3,000 I l 36. Ti le I 5-1-81 I 600 l <1,000 I 1,800 l <3.000 I l 37. Box Wrench I 5-1-81 I 80 I <l.000 [ 240 I <3,000 I I 38. Brass Fittings I 5-1-81 I 800 I <1.000 I 2,400 I <3,000 I I 39. Hydrolazer [ 5-1-81 I 2,000 l 3,700 I 6,000 I 11,000 I I f

          - -   ---                 I- -

I

                                            -  - - -]
                                                                    - -I I                I
                                                                                               -  ----    I-

[

                                                                                                                  -   - - -I I

l 40. Wrench (1 13/16") l 5-1-81 I 650 I <1,000 I 1,950 I <3,000 l All remaining items were discovered I 41. Wrench ( 1 3/8") I 5-1-81 I 300 I <l,000 I 900 I <3,000 I after December 31, 1983. I 42. Wrench ( 1") I 5-1-81 l 400 I <1,000 I 1,200 l <3,000 I I 43. Pump Unit I 5-1-81 I 500 I <1,000 [ 1,500 l <3.000 I I 44. Tripod I 5-1-81 l 160 I <1.000 I 480 I <3,000 l [ 45. Ratchet Wrench I 5-1-81 I 350 I <1.000 I 1,050 l <3,000 [ I 46. Hand Press l 5-1-81 I 200 I <1,000 I 600 l <3,000 I I 47. Steel Rule I 5-1-81 I 4,000 I <1,000 l 12,000 I <3,000 l I 48. C-Clamp (8"}, I 5-1-81 r 300 l <1,000 l 900 l <3.000  ! I 49. c-c lamp ( 11 r) I 5-1-81 I 120 I <1.000 I 360 I <3,000 l I 50. C-Clamp (6") l 5-1-81 I 210 l <1.000 l 630 I <3,000 I I 51. Pipe Die I 5-1-81 I 200 I <1.000 I 600 I <3,000 I I 52. Pipe Bender I 5-1-81 I 900 I <1.000 I 2,700  ! <3,000 I I 53. 8 rea ke r Ba r ( 1 8" J I 5-1-81 l 2,200 I <1,000 l 6,600 l <3,000 I i 54. Pipe Threader l 5-1-81 I l, 000 l <1,000 I 3,000 I <3,000 l [ 55. Tripod I 5-1-81 I 300 l <1,000 I 900 I <3,000 l J 56. Gas Regulator I 5-1-81 l 500  ! <1,000  ! 1,500 I <3,000 I I 57. Grinder Catch Pot I 5-1-81  ! 200 I 1,500 l 600 I 4,500 I I 58. Pipe Vise I 5-1-81 I 120 l <1,000 I 360 l 11,000 I l .59. Shaft I 5-1-81 l 90 I <1,000 I 180 I 11,000 I

APPENDIX 1 PAGE 7 OF 7 APPENDIX 1

SUMMARY

OF CONTAMl!:'jATED ITEMS I I i ACTIVITY DETECTED ACTIVITY WHEN RELEASED I l l ESTIMATED I FIXED PLUS I REMOVABLE FIXED PLUS I REMOVABLE I COMMENTS [ LOCATION/ ITEM DESCRIPTION I RELEASE I REMOVABLE I 21 REMOVABLE I 21 I [ DATE l (com) I {d2mL100cm ) I {c12m) 1 ( d12mL1 oocm) I I I I l I l l I 60. Pipe Vise  ! 5-1-81 I 350 I <1,000 I 1,050 I <3,000 I I 61. Wood (2" X 4 11 X 18") l 5-1-81 I 300 I <1,000 l 900 I <3,000 I I 62. Tool Box I 5-1-81 I ( lnterna I) I <1,000 I 30,000 I <3,000 I External radiation at contact I I I 10,000 l  ! I I < 0. 1 mR/hr when found. I l I ( Externa I) I <1,000 l 600 l <3,000 I I I  ! 200 I I I I I 63. Grinder Whee I l 5-1-81 I 140 I <1,000 I 420 I <3,000 I I 64. Bucket Lid l 5-1-81 I 200 I 1,500 I 600 I 4,500 I I 65. Table I 5-1-81 I 200 I <1,000 l 600 I 11,000 I I 66. Resistor I 5-1-81 I 150 I <1,000 I 450 I 11,000 I I 67. Resistor I 5-1-81 I 120 I <l,000 I 360 I 11,000 I I I I I I I l l I I I I I I I Ameren, Lot 12  !  ! l I I l I I I I I I I I 1. Eye Bolt I 5-1-81 I 14,000  ! <1,000 I 42,000 I <3,000 I Items 1 , 2 and 3 contaminat ed l 2. Eye Bolt I 5-1-81 I 500 I <1,000 I 1,500 I <3,000 I on threads. I 3. Eye Bolt I 5-1-81  ! 10,000 I <l,000 I 30,000 I <3,000 I Potentia I whole body and skin doses I 4. Air Conditione r I 5-1-81 I 1,200 l <1,000 I 3,600 l <3,000 l posed by l tern 1 a re bounded by I I l I I l I the evaluation s contained in l warehouse B I I l l I I Appendices 3 and 4. I I I l I l I l 1. Fan I 5-1-81 I 1,500 I <1,000 I 4,500 I <3,000 I l [ l I I l I l I I r r I I

 ! Pa intLSandbl ast Yard          I              I                    I                  [                l                   I I                                I              I                    I                  l                I                   I I 1. Nylon Sling (8')            I 5-1-81       I          200       I       <1,000     I        600     I         <3,000 I l     2. Gate Valve              I 5-1-81        I          180       I       <1,000     l        540     I         <3,000 l I    3. Gate Va I ve ( 1"}       I 5-1-81       I          600       I       <1,000     I     1,800      1         <3,000 I l                                 I              I                    I                  I                I                   I I Edi son Warehouse               I              I                   I                   f                i                  I I                                 r              I                    I (Internal) I                      l                   I I     1. Tripod Jack             I 5-1-81        I       1,800       I         3,000     I     5,400      I          9,000 I      The contaminat ion on Item 3 flaked I                                I              I                    I ( Externa I) I                     l                  I    off', leaving the tool clean.

I I I I <1,000 I l <3,000 I Appendices 5 and 6 bound the l 2. Pipe Bender [ 5-1-81 I 4,000 I <1,000 I 12,000 I <3,000 l potential dose from either inhaling l 3. Hi It i Roto Hammer I 5-1-81 l 1,500 I 15,000 [ 4,500 I 45,000 I or ingesting the entire amount of l 4. Electrics I Plug I 5-1-81 I 6,000 I <1,000 I 18,000 I <3,000 l con tam i nation. I 5. Fire Extinguish er l 5-1-81 I 1,400 I <1,000 I 4,200 I <3,000 I Contaminat ion on Item 5 was I 6. Fire Extinguish er  ! 5-1-81 I 200 I <1,000 [ 600 I <3,000 I conf'ined to base of' the cylinder.

!      7. Welding Box             I 5-1-81       l           300      I       <l,000     I        900     !         <3,000 l I                                 I              I                    I                  I                I                   l l                                !               l                    I                 l                 I                  I I                                I               I                    I                  J                I                   I I                                l              l                     I                 l                 I                  I l                                 I              l                    l                  r                 I                  I I                                I              l                     I                 I                I                   I l                                 I              l                    l                  !                I                   I I                                 l              I                    r                  I                l                   I I                                 r              I                    I                  l                l                   I 0929K

SONGS HP INDIVIDUAL TASK ASSIGNMENT (!TA) A, ORIGINATOR: CompJ!'t~ thi.,_s Section,

1) Name (Print)

.~ 3) q_

                                             ~
                      ,\ L~~1:\~y. 1'!)\.. ,n.P('!~..         ! A .l)                   p?- P"',1r>:. ~
                                                             *I ;-re*1 ..t::1(.1',l~/ ,r~;ce:::/'L,(         * \ lv,.                                                   ..* '*,*,:,~*.~--t:.:~.:;.*~~-~.:.:.:. ~

l1~pv2  :,.<':CA:'. C-~~~-........,= ~~---r-~~~~ ~=~~'-'.,-'=".M**~,".' t al . '"--"'=*=**~**,_*,.. ,,,.:

5) Li's t a pp ro pr i a\ e reference s ___ 1

(~__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

                                                      -Jllllliiiiiiill , , ~*.                      \)*er

6) sign and Da te~_t;::c,;"" )_."...~1-.1+f-"- - - - - - - - - - - - - - - - - - - - - - - - - -

B. ASSIGNOR(S): Compliance with this Section is indicated by your signature or initials below.

1) All necessary documents are to be referenced and/or readily available and/or attached,

2) Prime assignor and assigne. discuss this ITA and agree on Prime Due D .., nor enters:

~r:~b~~~u~;: E:s :~:~::::*~ ~::~*i :~:: g : : : c ~ - ~ B y On ~~5 ./~) .?~}:',cf' SUB DUE DATE* of Assigned to By _ _ _ _ __

4) Assignor(s) gives original ITA to assignee and forwards a copy to TAC Coordinator.

                       *Prime Due Dates should be at least 5 caleridar days beyond the date when task first assigned and Sub Due Dates must not be later than Prime Due Dates,
        ,*.,,\ C, DUE DA TE EXTENTION REQUEST : Th i s Sect i on i s not a s ubst it ut e for the Pr i me Due Date i n Sect 1o n J*
     ... *::.'J'       B which must be agreed to between assignor/assig nee prior to establishment . Required exten-sions, initiated by assignee, are to be requested as far in advance of the pending due date(s) as possible whenever completion date problems are identified.

1) New SUB DUE DATE of _ _ _ _ _ _ _ _ _ _ _ _ _ Requested By _ _ _ _ _ _ _ _ _On _ _ _ _ __

2) New PRIME DUE DATE of Requested By On~~~- -

3) Reason why due date cannot be met ________

4) New SUB DUE DATE of _ _ _ _ _ _ _ _ _ _ _ _ _ Approved By ______ ____ On _ _ _ _ __

5) New PRIME DUTE DATE of Approved By On_~---

6) Copy of ITA forwarded to TAC Coordinator By _______ _______ _______ __~

D. TASK COMPLETION: To be completed by assignee and forwarded to originator.

1) Statement of completed action ~IE.. &16MQR A0bt ))..)l____i?.£&( ~Tu--.:b, JA../

                       ~ Pi&NE1 1-.JA.S ~ '-:P/2EPAeBb

2) Date comp l eted _ _ __,0~_-___.2_,,,_CJ-....---...:~=-+-'----,,..-------------------

3) Is a copy of 7 v es (ACTION rs NOT COMPLETE WITHOUT THIS)

4) Signature of Assignee

5) Originator documentation to TAC Coordinator, To TACC on date, By _______ _______ _______

D'istribution: White - Originator Canary & Pink - Assignee Goldenrod - TAC Coordinator

                 .s(:E so(123} !07 RBV,         o 11/24/oa

                                *MEMORANDU!i FOR FILE June 20) 1984

SUBJECT:

Discovery of Additional Contaminated Mater1a*1 Outside SONGS Restricted Areas

REFERENCE:

Memorandum For File) - 11 Evaluation of 1 Most Significant 1 Pote ntia ~ica l conditions from Inadvertently Re'J eased Contaminated Materi a1 111 dated December 21 1 1983 On the afternoon of March 27 1 1984) - Senior stationed in the North Holddown A r e ~ e t e c t e d Radwas radioa te Handler ctive contamination on several items being transferred to the Unit 1 Restri~ Area. Since the material exceeded Station release l i m i t s ) - ted confiscated the items and the pallet which contained them ~ t h e material to radwaste storage. Using a hanct~held GM probe and meter, 700 cpm was measured on a short length of hose, 250 cpm aoncount two rate (2) nylon slings , and 150 cpm on a third slign. All four items were free of removable contamination. n ue t'oning the teamster who was accompaning the contaminated material, M learned that the material transf er had originated from the Offshore there, the material entered through the South Holddown Area Units 2/3, was transported across the Restricted Area to the North olddow Area where it was identi fied as contaminated material. for n that during the move across the Restricted Area, severa an oo s were as told removed from the pa 11 et by Maintenance Shop Personne 1. to the Maintenance Shop determined which tools had been* removed gfrom then went pallet , and evaluated each item for residual contamination. All of ihetheitems 1 were found to be free of contamination. On the following day ~Ma 28 rcb to Radwaste han dle rs- to the Offshore Pad to meet SCE Maintenance. the individual who loade

• e contam nated items on the pa let whichis WB$

eventually stopped in the North Holddown Area. The handlers were directed the storage container from which the contaminated items were removed. That to container was one of seven which had been on the Offshore Pad for severa1 years. Then handlers performed an item-by-item survey of all remaining material in the suspect container and four of the other contai ners. All material in those five containers was found to be free of residu al contamination. The remaining two containers were not readily access ible and were not surveyed at that time. - s t a t e d that, to the best of his kn owl edge, the it.ems were never used after being placed in storage and were*now being distrib be used. He also stated that other similar material haduted where they could been moved to the Special Tools and Rigging (STAR) Yard) (previously known as the GRIP Area) the Mesa. at

'MEMORANDUM FOR FILE                                             June 20, 1984 The two Radwaste handlers were then sent to the STAR Yard to evaluate material which had been received from the Offshore Pad. The handlers examined the material and found no evidence of radioactive contamination. However, during the course of their survey, four metal boxes (4 1 x 6 1 x 3 1 ) containing rigging for turbine overhaul work were located. Though the handlers were assured by personnel at the STAR Yard that the four boxes did not come from the Offshore Pad, because of the nature of the contents they chose to survey the itrnes, Two of those four boxes were found to contain material-w*ith detectab   le contamination: One (1) choker with 2,000 cpm fixed and 2,000 dpm/100 cm 2 removable ~r, one (1) other piece of rigging with 100 cpm fixed ~o and no removable contamination. The two boxes which contained the contaminated items were labeled as radioactive material and the area around them was barricaded.

Immediate Action

1. The two boxes found at the STAR Yard which contained the contaminatec material were removed to the Unit 1 Restricted Area.

2. Controls were established at the access road for Units 2/3 to ensure that material leaving the Offshore Pad and the.llllllllfTool Room would first be evaluated for residual contamination.

3. An investig ation was initiated to determine the source of the contaminated material and the areas which would require radiological survey to*locat e other potentia lly contaminated items.

been in storage on the Offshore Pad for several years. Ment lllllllll lllillwa s contacted and questioned regarding his group 1 s efforts on ~ a d . He described large amounts of tools the task of salvaging any items that may be useful during t e Unit 1 that have was assigned return-t o-servic e outage. Salvaged items, primarily rigging equipment, were transfer red either to Unit 1 or to the STAR Yard at the Mesa. Material was not transfer red to any other locations. Before hiring on with Edison, ~ w a s employed by Bechtel as a millwright at Units 2 and 3. He. expla in~ri ng his years as a millwright it was common practice to. obtain from Unit 1 any items needed for work at Units 2 and 3, He believed that other crafts followed the same practice . When asked if he were certain. that the items which were identifie d as contaminated came the container on the Offshore Pad, he said it was possible that they were from added to the pallet during its transit through the Units 2/3 Restricted Area. However, he r e - c dding materi a 1 of the type that was found to be contaminated. felt confident that at least some of the items he had removed from tna s orage container labeled 11 Millwrights 11 had originated at Unit 1. It appears that there is little doubt that the contaminated items d*lscovered h Holddown for Units 2/3 came from the Offshore Pad. From statements, it appears that.the items must have been removed from nt n transfer red to Units 2/3 several years ago,

• MEMORANDUM FOR FILE June 20 > 1984

.-i. an Edi son Supervisor at the STAR Yard> was interviewed ~ o v e m e n t of material into and out of his facility. The STAR Facility, formerly the GRIP Yard> was established in mid-September 1983. The yard is accumulating special tools and rigging equipment to support unit In addition> load testing of rigging equipment is perfomed there. explained that they have essentially only been receiving material at y The only material removed from the facility were items which had been load tested and were being returned to the units. lllllllllllstate d that the four boxes, two of which contained the contaminated

~ been among the first materials they received. The boxes had come from an area near Ameron, where several of the items were sandblasted and repainted. He estimated that the material had been present in the STAR Yard for approximately 6 months, One member of his crew who previously worked for Unit 1 Maintenance, identified the boxes and their contents as having been stored at the Reservoir> north of Unit 1.

To understand how this material could have been present at the STAR Facility after the extensive radiological survey that was performed at the Mesa and the controls established on material movement between the various facilities located at the Mesa, requires a review of some significant events and dates:

1. A substantial amount of old Unit 1 equipment, of which the four boxes found in the STAR Yard were a part, was previously stored at the Reservoir. During the second calendar quarter of 1982 1 that material was removed to the Ameren area to allow the installation of office trailers around the Reservoir.

2. Some time before material in the Tarea was identified as contaminated, July 28, 1983, and before placing a guard to control

     . material movement into and out of the area on August 1, 1983 1 the four boxes were moved to the sandblast area.

3. Survey efforts at the GRIP (now STAR) Yard were completed on September 15> 1983, Control of* material movement into and out of that facility was terminated at that time. *

4. On September 27, 1983, contaminated material was* found in an area to the east of the Ameron area. The following day the guard was relocated to permit material accountability control of the entire south end of the Mesa.

It appears, then, that some time between September 15, 1983, when the GRIP r.acility was dec'lared 11 clean 11 and September 28, 1983, when full accountability control was established, that the four boxes were moved from the sandblast area to the STAR Yard. Since the survey efforts at the Fab Shop> the area south of the GRIP Yard, were also completed in mid-September 1983, there was concern that contaminated material may also have been transferred there. Like the GRIP Facility, the Fab Shop has also been redesignated. The structure and surrounding yard are now used for rnotk-up training. Only new training aid~ and new material for fabrication of training aids have been moved into that area.

' MEMORANDUM FOR FI LE June 20, 1984 There is one additional area which lies between the STAR Yard and the Mock~up Facility, That small area is being used by Edison Field Forces for laydown of construction material, Field Forces Supervisor, was *questioned regarding the origin of materials present in the yard. He explained that there were no salvaged items in the yard. All material was either new or had been obtained from the Edison Alhambra Facility. The only shipments*out of the yard went to the units and the structural materials from those shipments have already been installed.

~                          Civil Superintendent, is resp-m aterial
~ h e Offshore Pad. During an interview,                             recounted that a substantial amount of material had been remove fro~ t e ad within the last three months of 1983, In January, the number of material shipments decreased because of reductions in the work force. Between February and April, 1984, only a few transfers were made consisting essentially of office furniture. Transfers from the Offshore Pad have again increased since mid~April 1984.

According to lllllllllllll all material removed from the Offshore Pad was sent either to t h e ~ i t y or to Warehouse Bat the Mesa. He also mentioned that there was a constant movement of tools and equipment between the Offshore Pad and the & Tool Room. That Too 1 Room was 1ocated south of the Unit 3 and West of OB 1 and* 2. The structure which housed the tool room is being replaced by the new South Security Processing Facility. All of the tools and equipment which were stored there were loaded into cargo~containers and moved inside the Restricted Area.

 ~ Edison Supervisor of Warehouse Operations, was also
~ d i n ~ a n s f e r s from the Offshore Pad to the Mesa.
~ c o n f i r m e d ~ narrative.

It was determined that further investigation of the Mesa Warehouse area was not indicated since:

1. Health Physics personnel were present at the Mesa Warehouse area through February 8, 1984, performing radiological surveys of all mate.rials;

2. All transfers of potentially contaminated material from the Offshore Pad after March 30, 1984, were surveyed; and,

3. No transfers of potentially contaminated material from the Offshore Pad to the Mesa Warehouse area occurred between February 8 and March 30, 198~.

~MEMORANDUM FOR FILE June 20, 1984 It was then desired to establish a scope of Radiological surveys required to locate any radioactively contaminated material which may exist outside of SONGS Restricted Areas. Following, is a list of locations that were included in the intensive, item-by-item survey effort:

1. Off shore Pad

2. Mesa STAR Yard and Fab Shop area~

3. Batch Plant (south of site)

4. AWS Machine shop

5. AWS B&C Mechanic She~

6. AWS Paint Shop

7. AWS Maintenance Supervision Offices

8. AWS Tool Room

9. AWS Calibrated Tool Roo~

Radiological surveys of those locations were initiated on April 9, 1984, and completed on May 31, 1984. Approximately 20,000 man-hours were expended during the survey effort. Attachment 1 is a description of each recovered item and the measured activity. Also included is *the 11 Calculated Activity When Released 11 which was determined by the methods discribed in the referenced report. DISCUSSION A few of the recovered items deserve special mention. Two hammers, Items A2 and A3 on Attachment 1, were found on a shelf in a portion of 'the AWS Building Paint Shop previously used by the carpenter. When found, both hammers were covered with dust indicating they had been in that

~ e time. It was determined that the hammers which belonged to 111111111111111ad not been used since the Unit 1 Sleeving Outage, 1981.

Two wrenches, Items A9 and AlO on Attachment 1, were also located in the Paint Shop. Those wrenches were found in a tool box of a worker who had left the site in 1978. There was no evidence that any of the tools in that box had been used since that individual left in 1978. Items A30 through A35 on Attachment 1 were found in the Maintenance Shop Crypt. Two of those items were identified in a previous survey, October 1981, and were described in the referenced memorandum. Apparently, after their i dent ifi cation as contaminated materi a 1, the items were not removed from the Crypt. As explained in the refer memorandum, material stored in the Crypt is isolated from personnel. Maintenance Supervisor, recalled only one instance during the past few s when the Crypt was opened. On that occassion, the Crypt was inspected without personnel entry. On May 5, 1984, a contaminated rawhide hammer, Item A67 on Attachment 1, was received at the AWS Building Tool Room. The worker delivering the tool was questioned about its origin. The Health Physics Technician was told by the

.worker that he had obtained the hammer from the Unit 2 Elevation 70 1 Tool Room and, assuming the tool had already been checked by Health Physics, he removed it from the Restricted Area through the portal monitor. Although located within the Restricted Area, that Unit 2 Tool Room is outside of the Red Badge Zone and the presence of contaminated material was not expected there.

MEMORANDUM FOR FILE June 20, 1984 A Health Physics Technician was sent to the Unit 2 Tool Room to evaluate other material stored there. Eight other contaminated items were recovered with fixed residual contamination ranging from 100 cprn to 600 cpm ~o. Several steps have taken to prevent the removal of tools and equipment from SONGS Restricted Areas through the portal monitors:

1. Signs have been posted within the Restricted Area directing personnel to remove tools and equipment only through the Holddown Areas.

2. Changes to Health Physics Procedure S0123~VII-7.3.2, 11 Release of Potentially Contaminated Items From the Restricted Area, 11 have been submitted which will clarify the requirement that tools and equipment be removed only through the Holddown Areas.

3. Manager of Health Physics, has been in contact with Manager of Security, to obtain Security Officer elp prevent tool and equipment removal through the portal

4. A letter was issued from Mr. to Mr .......... .. Nuclear Training Manager, which requested that the B a s i ~

Training/Re training courses include instruction for the proper release of material from the Restricted Area. CONCLUSIONS With the accomplishment of the four corrective steps mentioned above it appears that the Health Physics Division has now established control over all avenues for the inadvertent release of contaminated material from the SONGS Restricted Area. Again, as was reported in the referenced memorandum, and with the exception of the rawhide hammer described above, the recently recovered items appear to have been released from the SONGS Restricted Area several years ago. The radiological conditions presented by each of the items was compared to those presented by the 11 Most Significant 11 items evaluated in the referenced report. It was determined that none of the recently recovered items posed a condition that was not already bounded by our radiological impact evaluation. II l 197K/2007xlll cc:

ATTACHMt:NT 1 SUMMAHY OF CONIAMJNAJLL) 1*1 LM:i l'd~jli" l l}f 11

          -***** *---***    -  - - - -------*         ..                                                                                   j *.*   ---*-** - - - - - - - - -

I I ACflVITY 0("1"1-c'ri.-ll _ I ACT1*1 IVY Hill"j'{ HI i-1 ASI li I LSI !MAT[D I F ! XED PLUS I HLMOVAllL[ FIXED Pl US I HEMOVA£31.E "i COMMLNIS LOCA fl ON/ i *1 LM DLSC!l I PI l ON l RELEASE I REMOVAllLE I 21 REMOVABLE I 21

          ----------*                            - jJ .. DATE   I   (CQIO)    I ( dQmllOOcm l          *( CQffi)   I! dQml100cm.LJ.

l I I l l I l I I I I I I l A. AHS WAfifJ:.!0US£ I I I l I I I I I I Pa int Shop:  ! I I l I I I I I I

1. T-Handle I j-1-81 I 250 l <1,000 750 I <3,000 I Items l througt1 6 \/ere 2., 3. liarnme r I 5-1-81 [ 7,000 I 1,000 21,000 I 3,000 l found on a shelf" in a 4.,5. wrench I 5-1-81 I 100 I <1,000 300 I <3,000 l corner of the Pa int

6. Wrench I 5-1-81 I 150 l <l,000 450 I <3,000 I Shop.The items had not

7. Wrench I 5-1-81 I 500 I <1,000 1,500 I <3,000 l been used since 1981.

8. Dri l I Mo uir I 5-1-81 I 1.500 I <1.000 4,500 I <3,000  !

9. Wrench  ! 3-1-77 I 3,400 I 3,000 !14,200 I 39,000  ! Items 9 and 10 'dere

10. Wrench I 3-1-77 I 1,900 I 3,500 24,700  ! 4-5, 500 l found in a tool box left

11. Electric Adapter I 5-1-81 l 600 l <1,000 1,800 I <3,000 I behind by a .to rke r .tho

12. Hammer l 5-1-81 l 100 I <1,000 300 I <3,000 1 left site in 1978.

13. Grinder [ 5-1-81 I 200 l <1,000 600 I <3,0.00 1

14. Needle Gun I 5-1-81 I 250 I <1,000 750 I <3,000 1 15.-18. Air Hoses I 5-1-81 I 300 I <1,000 900 [ <3,000  !

19. Air Ori! I [ 5-1-81 I 300 I <1,000 900 I <3,000  !

I l  !  ! I Machine Shop: I I I l I l l I I I 20.-22. Wrench 1 5-1-81 [ 150 I <1,000 450 I <3,000 1

23. -21L Snubber 1 5-1-81 I 150 I <1,000 450 l <3,000 I

25. Pipe Roller l 5-1-81 1 1,200 I <1,000 3,600 I <3,000 I

26. Pipe Roi !er I 5-1-81 I L100 I <1,000 1,200 I <3,000 I

27. Welding Hose l 5-1-81 I 600 I <1,000 1,800 I <3,000 I 28 Pipe Wrench I 5-1-81 I 100 l <1,000 300 I <3,000 l

29. Snubber Parts l 5-1-81 I 400 t <1,000 1,200 I <3,000 I I I I I 1 Machine Shop Crypt: I I l I I I 1 I l I

30. Airlock Parts I 1-1-81 I 500 I <1,000 2,200 I <4,400 I Materia I stored in the

31. Eye Bolt I 1-1-81 I 900 l <1,000 3,950 I <4,400 I Crypt 'd3S isolated f"rom

32. Pa int Sprayer I 1-1-81 I 3,000 I <1,000 13, 150 I <4,400 I personne I.

33. Stud Tensioner l 1-1-81 l 250 I <l,000 1,100 I <4,400 I

34. RCP Seal Mock-up I 1-1-81 I 900 I <1,000 3,950 I <4,400 I I I I I I

SUMMARY

Of CONTAMI N/\T[l) ITEMS l l ACT IV !TY DEH CH:D AC.II r I VY ~/Ill N itl I i A!;t ll _) l ESTIMAT EDTr'Txr n PLUSJI"fr 'r-iOVABL E l* IX(b- PLUs-*1 -,,i.r-1i)VAi1i ( iOCAl ION/ll[M DESCRIPT ION l !t[L[/\S[ I f<EMOVAB L[ I cor-111Lr, rs 21 RCMOV/\tl LL I  ;: I DATE I

                                           -- fl                     I (cpm)           lls_Jpm/lO Ocm)            (cpn!.l         l(Q.E!i~OU Glll)__l _______ _______ ______

I I l l I I I Tool uo~l!!i: I I I I I I I I l I 3:,. I 5-1-81 I l 1,000 I <1,000 3,000 l <J,UOU 3G. llamrnu 1' I 5-1-81 l I 200 I <1, 000 600 I <3, 000 3!. llamrner l I 5-1-81 I 350 I <1,000 1,050 I 3fl. \*/ rcnctr <3,(JOO I I 5-1-81 I 500 I <l,000 1,500 I <3,0(HJ

39. ~/ nmcl1  ! 5-1-151 I I 100 I <l, lHJO 300 I <3, OUU I lf[J. \/rcnc!1 I  :,-1-81 I 200 1, 1. vii re liooks I 5-1-81 I 200 I

l

                                                                                              < 1 , OUO
                                                                                             <1, 000 600         I        <3, 000         i 1,2.         Cilanne I ocl,s                                                                                    600         I        <3, (ll)(J      I I   5-1-81          I         100     l      <1,000 1, 3.        Socket                        f   5-1-81          I    *, ,ooo      I     <1, 000 300         I        <3,000          l Li It ~      l.french 3,000         I         <3,000         I I   5-1-81         l          100     I     <1,000                   300        I         <3,0UO 1,5_         Al ignmc,nt Bar               I   :,-1-81                                                                                              I I          1~0     l     <1,0UO                   450        I         <3,000 I1G.         Dia I Cuage                                                                                                                             I f    '.,-1 :-81     I      1,,~0lJ     l     <1,000                3,600         l         <3,000 l17.         Gauge Box                    I    5-1-81                                                                                               J l          250     I     <1,000                   750        I         <3,0UO lJ8.         Pipe ~/rcnct1                                                                                                                          I I    5-1-81         I          100     I     <1, 000                  300        I         <3, 000        I 11 ')

• Pliers f 5-1-81 I 500 l <1,000 1;500 I <3,0UO l 50.,:, l. Hrench f 5-1-81 I 100 I <1,000

52. socket 300 l <3,0Ull I I 5-1-81 I 200 I <1,000 600 I <3,000

53. -:;:,;. Socket l l 5-1-81 I 150 l <1,000 1,50 l 56.-58. socket <3,000 l I 5-1-81 I 100 I <1,000 300 I <3,000 I l I  ! l Cal ibraLed loo! Room: I

                                               !                   I                  I                                         I                        I I                  l                  I                                         l

59. Spec i;:i I Too I I I 5-1-81 l 250 I <1,000 750 I <3,000 I

60. Lo;:id Ce I I I 5-1-81 l 300 l <1,000

61. Lo;:id Ce! I 900 f <3,000 I I 5-1-81 l 2,1100 I <1,000 7,200 I <3,000

62. Torque \-trench l l 5-1-81 I 200 I <1,000 600 I <3,000 l

63. Micro Meter I 5-1-81 I 150 l <1,000 61,. 450 I <3,000 I Meter Parts t 5-1-81 I 200 I <1,000 l 600

65. DC Voltmet er I <3,0UO l f 5-1-81 l 250 I <1, 000 l 750 l <3, 000 I

66. Meter Leads I 5-1-81 I 100 I <1,000 I 300 I <3,000 I l I I I I luul Room: l I l I I I I

[ l I l I

67. Rawhide Hammer I I 5-5-84 I 3,000 l <1,000 l 3,000 J <l,000 I l tt:rn Nuu1bc,r' 1;1 ,.,;:is trans-

68. C-Clamp I 5- l-8LI I 500 I <1,000 I 1,500 1

69. Slugging Wrench

                                                                                                                                          <3,000       I fercc.i rcorn tlie Res trict:ed I     5-1-8lf      l            350   !       <1,000         l      1,050       I           <3,000       I Area 1:0 tlie A\-/S Bui I ding

70. \*trench I 5-1-84 l 1:,0 I <l,000 I lJ50 l <3,000 I Too I Room on May 5, 1984.

71. Level I 5-1-84 l 1;,0 l <1,0QO l 450 I 1 3/Lf" Combina tion

                                                                                                                                          <3,000       l

72. I l I I I Wrench I I 5-1~84 l 1,000 I <1,000 I 3,000 I <3,000 I

73. 1 1/4"-15 /16" Wfench I 5-1-84 I 150 l <1,000 I L150 l <3,000 I 711. 1 5/8 11 Open end Wrcnct1 f 5-1-811 I 100 I < I , 000 I 300 I <3, 000 I

75. Hex Head wrench I 5-1-8lf I 150 I <1, 000 l lf50 l <3, 000

76. Breaker Bar I l 5-1-84 I 1,000 l <1,000 I 3,000 l <3,000 l

llf*1MAl<Y or CON rl\M I NIU ru I !11-1'.i f'H ~JU

.! ll I /1 I I /\GT IV ITY DEH.C-I TD--- -------- *- - -- - - .. ***-**---- --

I AC r I r I VY 1*111 l N 1,El [A:Sl D ---*l --*- --*-- .. -* . ----- -

                                                           !  ES   r ! MATl~D           I FIXED PLUS I R[MOV AlllE                         I FIXID l'LU'.3 I HEMOVA BLE l OC!, r I ON/ I -1 f"M Dl"SCH li'flON       I     1,[1 J"/\S!'                                                                                                                                    COH[,11 N rs I l([MOVA l3L[           I                     2i HEMOV /\lll [                  I                   ?I
            -------- -----                           - ! --         !JI\ TE             I    {q~ml          . [J___Q__[imllO[h:m)                   { c [lfil            I ( c!pru/ 1O!~cur L__! _____

l I I I ---*- -- --- ---- I l l loo I ( con Li nucd): I l

        !(tJOIU I                           I                                                                                                           l I                                                       I                         I I                           I                         I

{[. Break, !r Bar I 5-1-811 I I I 200 t <1,000 GOO I <3, ()(JU

78. 2 1/lt" Socket I 5-1-81; I l

79. 300 I <1,000 900  ! <3,0UO 1 5/8" Socket I 5-1-811 I  !

100 I <1,000

80. 1/2 11 - 5/8" Rubber l I l 300 I I

                                                                                                                                                                                 <3,000            l Co I I a r                         I     5-1-811               I                                                                                                           !

1 II Impact \-/rem;! ! 100 I <1,000 300 I <1,000

81. I 5-1-811 I I

82. 100 I <1,000 300 l <3,000 4" lmµact Extens ion I 5-1-811 I 1100 I

83. Hex Head Socket I <1,000 1,200 I <3,000 I I 5-1-84 I 200 I <l,000 GOO 311. 1 rr Socket I 5-1-811 J <3,UUO I l 7,000 l <l,000 21,000 l

85. ] II

                             //R" Soc kc L               l      5-1-81.j                                                                                                         <3,0UO           I
                                                                                      !           150          I    < 1. ()LJ()                       1150             l

86. 2 *1 /16" lfllpEICL Soch,, L I 5-1-811 I 100 <1, (J[)()

                                                                                                                                                                                 <3' {)()()       I

87. I 300 I <3,0UO I 2 13/16" l mpact Such.e L  ! 5-1.-811 I 1 ?0

88. l <1,000 11'.;>0 I <3,000 2 1/2" Impact Soc Ii.CL I 5--1-811 I  !

3Gu Pipe \-l renct1 300 I <1,000 900 I <3,000

89.  ! 5-1-8/J I <],()()()

90. 211" Pipe Hr*cnch 150 l 1150 I <3, {H)O I I '.:>-1-811 I 300 I <l ,UCJU

91. M;1grie t i C Buse I 5-1-811 900 I <3,000 I

92. Flash! igllt I GOU l < 1, ()(l() 1,800 I <3,000 I I 5-1-8/J I 200 I <1,000 Goo

93. 6" Pipe 1-/rcnct i j 5-1-81, I <3,000 I I 300 I <1,000 900 I <3,000 911. //5 Strap \-/rencl1 I 5-1-B!J I l

200 I <1,000 600 I <3,000 I

95. 32 Oz. 11:,rnmc r I  :;-l-tl/1 I 1 '.,()

96. Sledge I-lamme r I <1,000 l150 l <3,000 l I 5-1-811 l 200  ! <l,000 GUO

97. Grindi ng o*isk I <3,UOO I I 5-1-84 l 150 I <l ,000 1150

98. Air Motor I <3,000 l I 5-1-811 I 200 l <1,000 600

99. 3/4" Air Ori I I  ! <3,000 I l 5-1-811 l 200 I <1,000 600 100. 1 1/2" Air lmpaeL I <3,000 l I 5-1-811 I l, 350* I <l ,000 4,050 101. Kero Test. Rig l <3,000 I I 5-1-8lf I 150 I <1, ouo 450 102. J-1 i It i [lect. Cord I <3,000 l I 5-1-8/J I 200 l <1,000 600 103. ti i l t i Bit I <3,000 I I 5-1-811- I 200  ! <1,000 600 l 1011. 1 1 ;11-" Eye Solt I 5-1-811 <3,000 I l 200  ! <l,000 600 I <3,000 105.,1 06. C-C!cim p I 5-1-811 l l 100 I <l,000 300 I <3,000 107. Clippi ng I lammer l 5-1-81! I 1 ()() l I <1,000 300 I <3,000 l I 08. Clippi ng !-lamme r I 5-1-811 I 200 <1, ()(_)lj 1()9. I GOO l <3,000 J Weldin g Hose I 5-1-84 I 100 110. I <l,000 300 I <3,000 J Light Cord I 5-1-1.111- I 2:>0 I <1,000 750 l <3,000 l 111- Hydra ulic App. I 5-1-811 l 200 l <1,000 600 J <3,000 l 112. Cab le Clamp J 5-1-8LI- l 200 I <l,000 600 I <3,000 I 113. Cab le Clamp l 5-1-8I1 l 350 l <1,000 1,050 I <3,000 I 1111. 11" Pipe Nipple l 5-1-811- I 100 I <1, 000 300 I <3,000  !

115. 1/4" Hight u r i t 1 l 5-1-81! t 300 I <1,000 116. 3/4" X 12 11 900 l <3, ()00 l [Xt. t 5-1-8L1 I 150 l <1,000 1150 I <3,000 I Super-v isur- Of'fice Ar*ea: No items round

SUMMAl,Y CJ 1* GONTAM I NJ\ t !"[) I TLMS J l ACT l V !TY DEii~cT rn l ACT l l I VY i111 uT"T\i.'1 °(/\SI IJ - - i"- ------ --- ---* I 1 SI J MA.! F.O I r1xrn PLUS l RI.MOVA BLE I FIXlll l'lll~, l f<l 0 MOVAl ilf""i

                         ! OCA r j ur,/ j I [M DLSCI{ J l'T JON       J    H[Ll"ASE            I  R[MOVA llL[        I                2 l  REMOV/, lll E COl'll*llN IS I                   2 I
                                                                      !       DA f E           I    ( cpmL__l G!J!.!!,.U ..PDcm l              ( cp1!]J __ J LQI!J!!L lUOc:J.!tLL. _____ ____ _

l I l I I I I l l B. j I I I I I I l I I 1" l!(1se l I  :,-1-814 l 700 l <1,000 21,000 I <3,UOU 1 u:ms 2., 3. Nylon SI i n:1 l 5-1-811 I l 1 l.hr'<lll(Jl r 11 'w'e,e I!. 250 I <1, 000 750 I <3, OOU I tt1e in it. i a I i terns found Nylon SI irig l '.)-1-811 l 150 l <1,000 450 I <3,000 i in Um U11it 2/3 holdO\m

5. \-lcld ing Lecirl l 5-1-84 I 300 l <1,000

6. Oxygen Bettle 900 I <3,000 I area.

I 5-1-811 l 200 I <l, 000 600

7. Pipin\J 'vi/Valve s 5-1-81!

l <3, 000 I J I 200 l <1,000 600 l <3,000

8. Electri c Shop l 5-1-8!1 I I 100 I <1, 000 300 I <3, 000 l

9. Oxygen Bottle l 5-1-8l; l 350 I <1,000

10. D,a in Sr1roud 1,050 I <3,000 I I 5-1-81! 1 120 1 <1,000 360 1 <3;ooo 11 . Paint Ser-ape r 5-1-84 1 I l 3,200 l <l,000 9,600 I <3,0UO I l I

-------      -------------------------------------------------                                                      I
                                                                                                       ------------------------------------------          J                          I G. BATCl!    __ PL/..t; I                                                                                                                                              -----------------------------

1. Hoist Trol ly 5-1-84 600 <1,000 1,800 <3", 000 Jhis Item wah transfe rred Lo the Ba Lct1 f' I ant t* rom Uw Bcr..:htc: I I oo l Room in Februa ry 19811.

D.  !:1!.'>'\ l I I ------- I l I l l SfAn/Cf {IP Ynr*d: I l l I I I I 1

1. Oxygc,1 130 t t f e I 3-1-77 I 300 1 <1,000 3,900 <13,000 I 2 Stiac!{IC I 3-1-77 I 600 I <1,000 7,800 <13,0UO I

3. c<,b I e ctwker I 3-1-77 I 2,000 I 1,000 25,800 13,000 I

11. Li ft Strap l 3-1-77 l 2,000 l 2,0UO 25,800 25,800

5. Tube* Ber,de r I l 3-1-77 I 100 l <1, CJ(}() <1,300 <13,000 l

6. h'renct1 I 3-1-T/ J 1 ()() I <1 , 1)()0 1,300 <13,000 l

                    *1.        Li f"L lC i D                      l     3-1-77             l           JOO             < 1, ouo l                         l,3UU               <13,0UO             I l                         I                     1                                                                 l fab Sliup/f*lO Ch-up Area:                                 l                        l                      I No    i terns fuLrnd I

I l l l I I I I I [ l I I l I l I I I I l I I I l I l I l I I I I I  ! I I I l I I I I I l I 9"!H./20 llJX

SONGS HP INDIVIDUAL TASK ASSIGNMENT (ITA) A, ORIGINATOR: assigning ITA is to complete Section B, l) number £fi4.-4~~ 3) B. ASSIGNOR(S): Compliance with this Section is indicated by your signature or initials below.

1) All necessary documents are to be referenced and/or readily available and/or attached.

2) Prime assignor and assignee discuss thi Pr' e, assignor entersM~.

PRIME DUE DATE* of Assigned to, B on/f...S~°-+-

3) Subsequent assignor and assignee discuss lgree~n Sub Due- w e,-assignor enters:

SUB DUE DATE* of Assigned to____ By On _ _ _ _ __

4) Assignor(s) gives original ITA to assignee and forwards a copy to TAC Coordinator.

   *Prime Due Dates should be at least 5 caleridar days beyond the date when task first assigned and Sub Due Dates must not be later than Prime Due Dates.

C. DU E D~ TE EXTEN TI ON RE QUEST : Th i s Se c t i on i s not a s ubs ti tu t e f o r th e P*r i me Due Da t e i n Se c t i on B which must be agreed to between assignor/assignee prior to establishment. Required exten-sions, initiated by assignee, are to be requested as far in advance of the pending due date(s) as possible whenever completion date problems are identified.

1) New SUB DUE DATE of _ _ _ _ _ _ _ _ _ _ _ _ _ Requested By _ _ _ _ _ _ _ _ _ On _ _ _ _ __

2) New PRIME DUE DATE of Requested By _ _ _ _ _ _ _ _ _ On ______

3) Reason why due date cannot be met ________ ________ ________ ____

4) New SUB DUE DATE of Approved By ________ __On ______

5) New PRIME DUTE DATE of _ _ _ _ _ _ _ _ _ _~.Approved By On _ _ _ _~

6) Copy of !TA forwarded to TAC Coordinator By ________ ______~

D. TASK COMPLETION: To be completed by assignee and forwarded to originator. l) Sta ternen t of completed action ________ ________ ________ ______

2) Date completed ________ ________ ________ ________ _____

3) ls a copy of completion document attached _ _ _ Yes (ACTION IS NOT COMPLETE WITHOUT THIS)

4) Sign a tu re of Assignee ________ ________ ________ _________

5) Originator is to forward original !TA and supporting documentation to TAC Coordinator.

To TACC on ________ ______ date, By ________ ________ ____ Distribution: White - Originator Canary & Pink - Assignee Goldenrod - TAC Coordinator ,seeso(123) 101 REV, o 11/24/02

E~4-4-8'~ MEMORANDUM FOR FILE November 6, 1984

SUBJECT:

Disposal of Contaminated Intake Sludge San Onofre Nuclear Generating Station Units 2 and 3

REFERENCE:

and-from-

                             . ,- ated ~ S u b j e ~

a -e Sludge The referenced memo documents the deposition of contaminated sediments in the Unit 3 intake structure in 1983. Presently, contaminated sediments containing small concentrations of Co-60 are also beino observed in the Unit 2 intake structure. The source of the contaminated sludge is postulated to be ocean bottom sediment containing very small concentrations of radioactivity from Unit 1 operation, At the request o f - o f the Maintenance Department, Health Physics evaluated what the~~effective option was available to dispose of approximately 6,000 ft 3 of Unit 2 intake sludge. The recommended option is to pump the intake s1udge into the Unit 3 discharge and handle the sludge as an effluent release. Both Station Engineering and Effluent Engineering have concurred with this suggested disposal method, The recommended disposal sequence for potentially contaminated intake sludge is as follows:

1. The cognizant work group planning to remove sludge from either the Unit 2 or Unit 3 intake structure should contact the Health Physics Radwaste Group at PAX -

2. The Radwaste Group will collect sludge samples and coordinate with Chemistry to have an analysis performed.

3. If the analysis results indicate that no contamination is present then the Radwaste Group will complete form S0(123) 212, 11 Release of Liquid, Sludge or Slurry. 11 The cognizant work group will then be notified that the sludge may be free released from SONGS.

4. If the analysis results indicate that contamination is present then the Radwaste Group will notify the cognizant work group and Effluent Engineering that the sludge should be pumped to the discharge structure and treated as an effluent release.

5. The Radwaste Group will provide sample analysis results to the Effluent Engineering Group.

MEMORANDUM FOR FILE ~ 2 - November 6, 1984

6. The cognizant work group will provide to Effluent Engineering an estimate of the volume of sludge required to be removed from the intake.

7. Effluent Engineering will generate a release permit for the intake sludge.

8. The cognizant work group will obtain approval from Station Eng-ineering and Operations to pump the sludge to the discharge prior to commencing sludge removal.

It is recorrrnended that the disposal sequence be formalized in a Station procedure. Since the disposal method is an effluent release coming under the responsibility of Effluent Engineering, it is recommended that this disposal method be contained in a Chemistry procedure. DDD:mjk Fil es

SONGS HP INDIVIDUAL TASK ASSIGNMENT (JTA) A. ORIGINATOR: Complete this Sectio n, individ ual assign ing ITA is to complete Sectio n B,

1) Name (Print ) _ _ _ 2) Enter your next JTA number fZ 8'ft;: {Y)..,l{J

3) Describ e Task. Jkf;'~V,l'1'J/J1fZ Jf:µ!JdR... *.;j;o (}12 )C'4 :Y-- -:f.~ -----

       --**tJ _;      :Lf- t 9h
                   <"_*                 b ~--*fb,_,_X-~*lO-* *_s -~t ::e _-+ ---t ~-- ----

11-**

4) Describe what consti tutes completion ____ _l\J\-*-*~f~~'*rrJ,-*~C>~-+-tfsi_)..,.C),_

__*_,*'£,_*~/-{.~i/i!t...,=*~ - ~ - - - ~-~

6) Sign and Date ~~~~

B. ASSIGN~R(S): Compliance your signatu re or initia ls below.

1) All necess ary documents are to be referen ced and/or readily availa ble and/or attach ed.

2) Prime assign or and nee ct'isc.uss t h i ~ and.

IaT reeA on Prime Due Date, assign orente .,rs: PRHfE DUE DATE*. of*

3) Subsequent assign Assigned to B y - - O n 4 U'2 assign ee discus s an agree on Sub Due- Daie, assign or enter 1'i'iJ SUB DUE DATE* of s:' '

Assigned to By On _ _ _ _ __

4) Assign or(s) gives origin al ITA to assign ee and forwards a copy to TAC Coordi nator.

      *Prime Due Dates should be at least 5 calend ar days beyond and Sub Due Dates must not be later than Prime Due Dates.                  th~       date when task fitst assign ed

c. DUE DATE EXTENTION REQUEST: This Section is not a sub1ti tute for the Prime Due Date in B which must be agreed to between assign or/assi gnee Sectio n prior to establi shmen t. Required exten-sions, initiat ed by assign ee, are to be reques ted as f~r in advance of the pending due date(s )

as possib le whenever completion date problems are identi fied.

1) New SUB DUE DATE. of**,

                                  --,.:,,.,- ---- ---- -- Requested By --- --- ---On - - - - -

2) N~w PRIME. DUE DATE of ~--- ----- -~~R eque sted By On _ _ _ __

3) Reason why due date cannot be met _ _~ - - - - ~

                                                                          --------~~----~~----

4) New SUB DUE DA TE of _ _ _ _ _ _ _ _ _ ___,.__ App roved By _ _ _ _ _ _ _ _ _ on _ _ _ __

5) New PRIME DUTE DATE of _ _ _ _ _ _ _~_ _ _ Approved By

_ _ _~_ _ _ _ _ On

6) Copy of !TA forwarded to TAC Coordi nator B y -

                                                                        --------------~-----~-

D. TASK COMPLETION: To be completed by assign ee ~nd forward ed to origin ator.

1) Statem ent of completed action . ;A:-t1::ctclte-J 111-e, 1111-0 +/-__J._ ~-- ---- ---

2) Date comp 1 et e d - - - - - - - - - - - - - - - = =

                                                                     =~.         ....:------------------

3) ls a copy *of completion TION rs NOT COMPLETE WITHOUT THIS)

4) Signat ure of Assignee _ __

5) Origin ator is to forward origin al !TA and suppor ting docum entation to TAC Coordi nator.

To TACC on /1~ / 3 I I [Cf date, By Dist rib uti on: White - Origin ator Canary & Pink - Assignee sj:.E so(1z3) 117 REV, 0 11/Z4/82 Goldenrod

• TAC Coordi nator

MEMORANDUM FOR FILE March 10, 1988

SUBJECT:

Radioiodine in Fish Basket Waste

REFERENCES:

1. - t o . . . - . dated May 16, 1986;

                   ~ s p o s ~ e Materials Accumulated at SONGS

2. ITA E88-020 Radioiodine was detected in fish basket waste from all three San Onofre Units in mid-February. The source of the iodine was steam generator secondary water, contaminated by primary to secondary leakage, which was overboarded to the outfall to resolve abnormal chemistry. The benthic waste drawn back into the intakes of each Unit had very low, but detectable, levels of I-131. The purpose of this memorandum is to document the calculations used to determine holding times for each volume of waste, and to demonstrate that the final released product had no detectable activity.

Given: A 1 liter Marinelli sample counted for the required 300 seconds (Reference) has an LLD for I-131 of 5E-8 uCi/cc. Assume I-131 half life is 8 days. Unit 1 Fish Basket collected 2/17/88 Act 1 = 1.1 E-6 uCi/cc Act = 5.0 E-7 uCi/cc Act 32 = 0.0 uCi/cc For the highest concentration: 1 E-6 = 20 times 2x = 20 times 5 E-8 x = 5 half-lifes 5 half-lifes =5 x 8 = 40 days Recommend: Hold material for 40 days, resample; if not detectable activity, release. Units 2 and 3 Fish Baskets collected 2/22/88 Act - U3 = 2.0 E-7 uCi/cc Act - U3~ = 2,4 E-7 uCi/cc Act - u2 1 = 3.0 E-7 uCi/cc Act - u2 2 = 0.0 uCi/cc

MEMORANDUM FOR FILE March 10, 1988 For the highest concentration: 3 E-7 = 6 times 2x = 6 times 5 E-8 x = 3 half-lifes 3 half-lifes x 8 days= 24 days Recommend: Hold material for 24 days, resample, if no detectable activity, release. Unit 1 Fish Basket collected 2/25/88 Act= 1,4 E-7 uCi/cc Added to previous Unit 1 material Unit 3 Fish Basket collected 3/3/88 Act 1 = 2.3 E-8 Error= 55% Recommend: Hold for 1 half-life (till 3/11/88), resample, if not detectable, release. Resample (release) data printouts will be attached as they are completed

• cc:

Th* raeults ara in. What followm ara thm LLDa for* 1 liter marinalli countad fer 300 aaconda Cin uCi/cc>:

I: '"":l 2)1  ::'i £:£***{:\

Xrrt""*:f. ~~:.:~ i::1 1::i.'-**7 Cs*..*:l.37 7 E**.. l':\ CF.o""*l::M 1:3 l:::**--13 c,::,,,,. 60  ;;,~ E ..... 7 Cc,, .... f:'5g 7 1:::: ..-8 Momt all tha LLD* wera in th* E-8 to E-7 ranga.

• • • • ~***~***********
        • • • • ~******** ***** *************************************

18-FE B-88 09:59 :23 ***************** U-1 F18H 02 17 AH 05 !:\i, ,*.E COL.1..ECTH)N !:'i'l'AHT or.in~: l.7 ..*FErn*. *1:),1:~ (10: 00: (H) SAMPLE COLLECTION END DATE 17-FE B-88 14:80 :00 SAMPLE IDENTIFICATION: 8924 TYPE OF ~::t:-i1v1PU:'. : u:u~s: H. F*. SAMPLE QUANTITY: 1000. 000 UNITS: ML PER CENT YIELD: 100. 00000 REACTOR#: 0 !:lAMPLI:: OEOME:THY: !L. L.J:1;) MA!=U:NEL.L. l'. OPl::HATOI:~::) HHTl'.(.. ';L:?.:: . . . . EFFICIENCY FILE NAME: EFFE . MARlLE ~

                                                                                          'II*

ACQUIRE DATE: 18-FEB-88 09: "l*(:,: \:i2

• FWHM < 1~:1::1~,) : .t . 1;~1e;, j PRESET TIMECLIVE): :30<:I. $1:tC *!~  ::~l:~N::~ITIVITV: f:), 000 ELAPSED REAL TIME:  :?.oo. ~::tc
• SHAPE PARAMETER: .t 0. 0 :,~

ELAPSED LEVE TIME: 800. SEC

• NBR ITERATIONS: J. Cl, DETE;'.C:"l'l'.:lf~: mt:F~ME:'. '*

                                                                                         'II*      LJ Elf~AFW : NLIC:L                . I~ XL I G!

CALJ:EI DATf::: J.t3***FEE~"*i:::t:3 01:l: Qt: 2J.

• ENERGV TOLERANCE:

i(EV/C:HNL: J.. 500KV

0. 4':i,":i'~r,4,t 1

• HALF LIFE RATIO:

OFFSET: -o. 0461368 KEV e. 00

• ABUNDANCE LIMIT: 75. 00%

l:~Nl:mOY wi:Nnow 2.il. ':i)!:i TO 2047. 7 J. PK rr E'.NE:f,~CW {!-if~EA l:11('.(;ihll:I r:*wHM C:Hf'~NNEL LEFT Pl,J c:T!::/~::EC: %:E:'.F!f;: F'.IT J. (I 6::). .. e>' rv,-:- cf i:*

                              ~ ~.                 J. :~L                 J. J..              0. 6J.            J.27. **t*")
                                                                                                                        ..: . ,(. l.24            7 ii. O!:.;E***02 47. 4 2       0       ~n'..  ~:17 pl!. t.1-( .t '7.                       20.                   .1.. '.:l(l      1 ~:14, ~=:~:;    1 :1:,          ~;, 5. 6~i'!E***02 44., 4

:~ (l  ::3~H. !:51;) 7.  ::I. (I. 9(1 70:1( :3t.:) t.:/i)*;) . },. ~. *;)

1. (I *:) :J:: :]~Et ..... () :C? ,.-;:,,;*,

4. 0 ~::(:,4*~ 4~:lj 1~. I 10(:1, 7~?.9. ()~:,

tli .. ,

10. .t. '..::11 '72~?, ~?.(> '.,/,I

• l:.,OE:*--0:l .t 0. ,~* ,.I PEAK SEARCH COMPLETED <REV 1.2)

                                                                                                                   /:./. ' //Ifii.---

h.l - / v-

• u1 * / ~

\II..IC:Lt DE lt1ENT IF l C:{~'T *.r ON ::::Y$TESl"I ( fiiClhl(:i/;i ljEf;! ::ti. 0, EV!:l'.7) Bt.Jl~11iM\Y OF i"lUCL. J: DE t-iCT J: VI TY rOT{},L 1....:r.NE~:; lhl ~::PEC"fF<UM -INijS NOT LISTED IN LIBRARY I [IF '! F':t f.::D IN l::il...lMMAf;:v m::PCIF:T .t J. ~-:::: J: 131'1Pi 'IIUCL I l:lf.~: ~:il:tHf;! HLIFE DECAY UCI /UNIT J: ..* J.~~J. 1::p E:f~f~Ctf~  :.::£::Rf~  :,~M :t X

8. 04D J.. 072 l.. 079E -6 J.. J.:301:: ***7 J. 0. L) 7 J. (l(), ()(I ACTIVITY FROM ISOTOPE GROUP= 1. 079E-06 UCI /UNIT TOTAL ACTJ:VJ:TY ~ l. 079E-0 6 UCI /UNIT

• • • ~**********************************************************
      • • • • • • • • • • • • • • 19-FEB -88 08:28: 14 *****************

!:)(* LI:~ COl..1..1:~CT J'. ON  ::n AF~T Df.!Tl:l: J. '?~*Fl:'.f::1***1:::1:~ J. 4: :30: 00 SAMPLE COLLECTION END DATE 17-FEB-88 14:80:0 0 SAMPLE IDENTIFICATION: 8892 TYPE OF SAMPLE: UZ/8 H. P. SAMPLE QUANTITY: 1000. 000 UNITS: ML Pim CEI\IT V :t ELD : .t 00. 0000() f\Ef1CTCIR ii:: .1

• "*AMl">i

      * ** 1**  "'l"1~1v11**1*1

..I *1 :~ *1**,y : JI, ** L* 1*r

                                                          , .11 1*1;,1*~1*1, 1                11**1 I 1*

• 1*~r,*1*r1**,**

                                                                                                                             ,,I*(,::,* l'l"l"l"J'(.'I

,::, ,  :: l.:1 l"l "\ . 'I:: ..... , I,')l"~* 1i::: *,1*1 , 'I , , *1 ...,. EFFICIENCY FILE NAME: EFFE . MARlLE

                                                                                            *ll*

ACQUIRE DATE: 17-FEB-88 .l ~i: ~?.~:i: 1 7  ?~* FWf*WI < .1. ::~::!::;;~ ) : PRESET TIMEILIVi>:  :;)(10. ::)l::C '** t:::l:~N:B IT IV J: TY:  !:), 000 ELAPSED RtAL TIME: ~~100. SE'.C

• SHAPE PARAMETER: 10. 0 :;.:

ELAPSED LEVE TIME:  :~JOO. ::::EC

• NBR ITERATIONS: 1o.

1:IETEC:TOf~: GEF~ME :s1, L. H.IR{~fW: NUC:L. . RXLJ GI CALIB DATE: 17-FEB-88 09:24:2 4

• ENERGY TOLERANCE: 1. 500KV KEV /C:HNL: 0. 4'::> 1:v'::>4(:,2
• HALF LIFE RATIO: 8. 00 OFFSET: 0. 0043561 KEV
• ABUNDANCE LJ:MET: 75. 00%

1:1NEHOY WINDOW ,.. ~ 1:r

                                                                                                    ,t .. *.I,     00 TO                20*W7. '71:)

AREf.\ E\K(:ihll:I Fl*JHM C:Ht1NNEL L.EFT PW CT~:i/~:iEC: :1.:E:f~f\ F:tT f:)4. 0. J.. 1:~,=~ '"/~?,;). J.J. 72l. 20 J.. ::JOE-0 J. 1.:3, (;, PEAK SEARCH COMPLETED <REV 12)

• NUC~IDE IDENTIFICATION SYSTEM (SONGS VER 8. 0, 8/87)

SUMMARY

OF NUCLIDE .ACTIVITY TOTAL LINES IN SPECTRUM J. LINES NOT LISTED IN LIBRARY 0 ro~ IFIED IN

SUMMARY

REPORT l FI ~::~:i :r. ON F'f~CIDUC:T J. ~-::) l'. 01'1A hll.lC:L.. :t m:: $1::Hf~ HLIFE DECAY UCI /UNIT ERROR '.'l.:f:~:m\  :,,;M :t X J: ..*J.:3J. FP e. 04D 1. 008 6. 047E -7 6. 867E -e J. :;( ~) l. J, (IQ, 00 TOTAL ACTIVITY* 5. 047E-07 UCI /UNIT

• *il- 'R' *'~**,* ** *~ %*lf.1\~ ***it*:* *IH* *ll* *~HHf *l* *l'-. *lt *lt *l~ o\'f *If'*'* *iHHf *Ii- *ihHHt *w *1t *lH:', *l} *It *Vs- *li- *il- *!(* *l* *lHHt *fHH1'*i'< *!HHf *!* *lHi<

 *****************                                                  18-FEB -88 16:28: 87                                                  *****************

Ul FISH 3RD GA~~LE FROM BATCH 02l8JB01 10 MIN COUNT FEB 1. 8 1988

!(. d:~ COI..I..ECTJ:ON ~rrAm* DATE: l.l:~"'Fi:rnl*-l:~I;~ U:,: (10: (l(l

 !::(!)l"lr.::*u.:: COLLECT'.[ ('.IN END DP, TE                                                   18-FEB -88 16:00: 00 SAMPLE IDENTIFICATION:                                                    8949 TYF'E: OF S;{JiMPLE: :                               U-:?./~:I H.                   F'.

SAMPLE QUANTITY: 1000. 000 UNITS: ML F'Ef~ CENT vrn:u:1 : 100. 00000 RE'.AC:TCIR 4*: .t (:~i(W1PL.1:~ l)EtOMEtTflY: J. I.. L. l'. Gl MMi I !\JELL I OPE~1:1?rrm::s l 1\1 IT I AL:': )- EFF IC I ENCV FILE NAME: EFFE . MARlLE ACG1u:rn1~: l:i{~TE: u~1-~FEJ:l*"i.M:l .ti:,: 12: ~:iEI * -)~ FWHM <1 ::~1:::12) : 1. '::l~;i J PRESET TIMECI..IVE): El..i~f:*m~:D F~E{~L 'T".t ME: 600. SEC **  ::)E~N::) IT l'. ~) J: TY:  !;), <)00 (:,00. ~:;EC

• SHAPE PARAMETER: .l 0. 0 X, ELAPSED LIVE TIME: 600. SEC
• NBR ITERATIONS: l. (I, m::-rn:c:TOf~; l'.;i[f~ME
• LJBRARY:NUCL . RXLIQ i:~r.iL.Ul DAT!:~: J.t:}**FErn~-1:m 01:~: OJ.: 2l.
• ENERGY TOLERANCE: 1. 500KV

 !(EV /CHI\IL:                              0. 4':il':r':il41 .t

• HALF LIFE RATIO: 8. 00 OFFSET: -o. 046J.86 8 KEV
• AB~~DANCE LIMIT: 75. 00%

                                                                                                          ~*

l:~NEflOY Wl'. NDOW 24. 95 TO 2047. 71 PK IT ENERGY AREA FWHM CHANNEL LEFT PW CTS/GEC ~ERR FIT 1 o 1.4Mt. 1.7 -~A_u J.4. o. J.. 37 2920. 79 2912 j PEAK SEARCH COMPLETED <REV 12)

~UCL,,l:DE ,.i:,mt1,rn1::1:CATIOJ\l !:lY!BTl:11'1 (!;::01,~0!:) Vl:'.fl :3. 0,

                                                                                                          ;{:'",(J,..Y d - r ( /5' l;Vl:::7 >

~UMMARY OF NUCLIDE ACTIVITY F'{.~J)[:'. .t FEB J 8 1988' ri:)TAL I..J'.I\IE:~~ l:1\1 :m:)Ecn~UM J. .JNES NOT LISTED lN LIBRARY 1 EDF. 1FIED IN

SUMMARY

RijPORT 0 o. ()r.)'.%: ACTIVITY FROM ISOTOPE GROUP~ 0. OOOE-01 UCI /UNIT TOTAL ACTIVITY m Q OOOE-01 UGI /UNIT

I '

• • • • • • • • • • • • • • • • • 22-FEB-8 8 18.08:5~ ~*******~********

U8 FISH INTAKE 02ZZRHOl

         ?LE COLLECTION START DATE:                                          22-FEB-88 12:45:00

• t*1t1IF'l.. E C:Cll..L..EC:T :t ON EhtD !){~ TE: 22***FE:El***f.:1(:1 .t 2. *1,i:i: 00 SAMPLE IDE~TIFICATION: 0061 TYPE OF SAMPLE: U2/8 H. P.

!~\N'IPU:: 1~*11.JAl\fl"J:'Pr': J, (H)O. ()(l(l I..IN J:'H3: ML. PER CENT YIELD: 100. 00000 REACTOR#: 8 !:\AMPLE OEt:'JME:TFW: l.l.. I..J'.Gl Mr-im:Nt::LU'. OPl::f-1(.rJ"m1!:) J:I\IJ:Tl'.f.11.. !:>:11111 EFFICIENCY FILE NAME: EFFE , MAR1LE

                                                                                   ,:f, ACQUIRE DATE: 22-FEB-8 8 18:02:21                                                   ~I*    Fl~HM ( 1*:.:1~(12) :

PRESET TIMECLIVE): 800. SEC ** !:ll:tl\l::~ J: TI \J 1: TY:  !;), (i()Q ELAPSED REAL TIME: 800. SEC ';l* ~t;H(!\F'E: P/'!1R/~1ME:TEf~; 10. 0 :,.: ELAPSED LIVE TIME: 800. SEC

• NBR ITERATIONS: J. o.
  • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • +**

J:iETEC:"f'('.lf~: OEf~ME ~,. LlEIIW1l~V: MUC:L. . F:n.:tG! CALIB DATE: 22-FEB-88 08: 12:20

• ENERGY TOLERANCE: 1. 500KV KEV/CHhL: 0. 4~98b84
• HALF LlFE RATlO: 8. 00 OFFSET: -0. 02971.47 KEV
• ABUNDANCE LIMIT: 75. OOX
  • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • +**

l:~I\IEFmY l;,JJ:N!)Ol,~ 2.lL *pl!) TO 2047. ,q:3 Pf( :t "f' EhlEl~(W (:,t::[;'.{:1 1:11 ( (;i hi [I F'WHM C:HAhlhlE:l.. L.E:FT F'l~ f::Ti.::/S:E:C: :1,;E:f:~,.~~ F'JT

1 J.. 0. (I, l

~1!) 72*;), !:i2 72::) 14 7. (l(l[ ..*02  ::: J.. l:\

NUCLIDE IDENTIFICATION SYSTEM (SONGS VER 8. 0, 8/871 ,::*t r If*,,r* ,., , 11:11t*11,., \ ,., .. *r,, 1-1r.:* 1,J..1::* 1*' 1t,1r*t , i., r:\1,.,,....r..,t v* ,*r *r* 1Y, TOTAL LINES IN SPECTRUM J, LINES NOT LJSTED IN LIBRARY 0 1:.. \JT J: Fl: ED 1: 1\1 ::>I.JMM?\F\Y i:rnr1:)oi:rr J. J. 00, oo:v. J. ***::> l'. OIY\l1 NUCL.1 DE t::I:.IHF: HL.:l FE: m::c:{:,y I.IC'.[ /Uhl'.( T  !::m~t:IF: ~.:E:F:F! :1,;jvl :r :r; J: ... J,:;)J, i:;1:) 8. 04D 1. 001 L. 959E -7 4. 274E -8 21.. 82 LOO. 00 ACTIVITY FROM JSOTDPE GROUP* l. 959E-07 UCJ /UNIT

• • • • ~************ 22-FEB-8 8 JO: 88:20

       .,.~LE COLLECT J: 01\1 !:H Mn D~\TE: 22***r:i::B***l:)l:) 07: :;W: ()(I

!:::oHMF'L.E C:OU ..F.::CT :r t)hl END DAn:: 22 . **F'E:E:-..,(:l(l 07: '..:10: 00 !:'>f.W1PI..E J: Dl::I\IT i: 1:~ J: C(.)T l ON:  !:)6 TYPE OF SAMPLE: U2/8 H. P.

lAM1::*u:t 1;)1J(.\NT l'. TY: l. 000. 0(1(1 UN l T::*;: ML..

PER CENT YIELD: 100. 00000 REACTOR#* 8 !:>AMPLE 131::0Ml::TflV: J.1.. L.Hl MAfll'.l'lEL.L.l i:w*EF(AToi=~:;;~ 111.HTJ:(.~L.!=~:U!IE EFFICJENCY FILE NAME: EFFE , MAR1LE ACQUIRE DATE: 22-FEB-88 10: .t .1 : ~,'.(:.

• F'l~JHM ( 1~:l~:12 ) :

Pl:~l:1!31:[T T Hil:1 ( L. I VE) :  :~~ 0 O.  ::> I:: C *it  ::::EN!:\J:Tl:VITY:  !:5. 000 ELAPSED REAL Tl~E:  ::100.  !:::EC

• SHAPE PARAMETER: lo. 0 :;,:

ELAPSED LIVE TJ:ME: :300.  ::11::C

• NBR J:TERATION8: J. 0.
  • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • ~**********

                                                                                        *Ii.-

DETEC:TCIF{: (;1E:f;:ME: I/!* t..:rnr::,~f~Y; hlUC:l.. ' F:XL.:tl;! CALIB DATE: 22-FEB-8 8 08: 12:20

• ENERGY TOLERANCE: l.. 500KV KEV/CHNL: 0. 4998684
• HALF l..IFE RATIO: 8. 00 OFFSET: -o. 0297l.47 KEV
• ABUNDANCE LIMJ:T: 75. OOX
  • • • • • • • • • • • • ~************************************************

                                             !::Nl:ti=\OY WJ:I\IDOv~                            24. 9t.)      TO         2047. 4::~

(.!)f~E:?'~ l:ll<Ohll:l F'l.JHM CH{:.11,lhlEL. LEF'T F'\,J C"l"~~:/\::E:C: :1.:£:},f:: F' :t 'T 2b. ....:), J.. 1.:;i *7:~?*;). 2'7 *7:;?!:) ,;, 1;~, !:)OE***C::12 :;tJ, (I PEAK SEARCH COMPLETED <REV 12)

NUCLIDE IDENTIFICATION SYSTEM (SONGS VSR 8. 0, 8/87) 1.:*l

• .* , *1t'*11t*11-~f:*v*

fl ,; 1*,** 1r:* 1*, 1l*1(**t

                                           ** ** *c

• i... r,:.'.l t*r"t
• 1v;* .** . 1J .*i *1""(

TOTAL LINES IN SPECTRUM J. LINES NOT LISTED IN LIBRARY (l Ir ~TIFIED IN

SUMMARY

REPORT J. 1. oo. oo:Y. FI!:;::::i'.(CtN PF~ODUCT J. *--:::: I OM(.'1 NUCl ..:t DE ~.;,E1HR HLIFE DECAY UCI /UNIT ERROR ~ERR ~MIX 1: ... J. ::) J. 1::p 8. 040 J.. 010 2. 898E -7 5. 624E -8 28. 08 J.00. 00 ACTIVJTY FROM ISOTOPE GROUP= 2. 898E-07 UCJ /UNIT TOTAL ACTIVITY m 2. 398E-07 UCI /UNIT TOTAL Fl8SJON PRODUCTS/ TOTAL ACTIVATION PRODUCTS UNDlFINCD"

• • W####6******************************************************
    • • • • • • • • • • • • • • • 22-FEB-88 10:23:85 *****************

SAMPLE COLLECTION START DATE: 22-FEB-88 07:45:00 SAMPLE COLLECTJON END DATE 22-FEB-98 07:45:00 SAMPLE IDENTIFICATION: 0055 TYF'l~: OF !:~:Ai"IF'Lc::. : U2/:'.:: H. P.

ffiiAMr;*us 17,!IJANT i: TY: J. 000. 000 UN I r::i;: ML PER CENT YIELD: 100. 00000 REACTOR#: 2

,::*~1*.,l 1v11:::,l... ,:.. 1 r.:.* j'"*l"~n1v1r.::*1"F",\,I.

                              ,.,"ti:;-.,,"' *11:..  \ J .. j* I.... L" r 1:*1 JvJAF'~' i* 1,1r.::'
                                                                                  .,t,          '    i;;.. L... l I 111         ...             \l"'I "l" 1....

F'*O f"1r,;:11s;;. '"1f:\*.,,I 11:::* 'I' J, 1,1 J 1" 11,1* AL,:::*'

                                                                                                                                                                                              ,,.. ,t *
                                                                                                                                                                                                     +

EFFICIENCY FILE NAME: EFFD . MAR1LD

                                                                                                                     *lr ACQUIRE DATE: 22-FEB-99                                                                 H): .1.1: .1.2                11-    FWHM ( J.::::::1:2) :

PRESET TIME(LIVE): 800. SEC

• SENSITIVITY: 5. 000 ELAPSED REAL TIME: 800. SEC
• SHAPE PARAMETER: IO. 0 %

ELAPSED LIVE TIME: 800. SEC

• NBR ITERATIONS: J. o.

                                                                                                                     ~*

DETEC:TOH: OEF~MD

• LIBRARY:NUCL . RXLIQ CALIB DATE: 22-FEB-88 08:00:00
• ENERGY TOLERANCE: 1. 500KV f(EV/CHNL: 0. 4':::,)'::'74':i'
• HALF LIFE RATIO: 9. 00 OFFSET: 0. 2243660 KEV
• ABUNDANCE LIMIT: 75. 00%

EI\JEFmv t~ I NDOl,J *")t::.."'

                                                                                                                            .t:.. ,...,.   ~:~ ~:~      TO            '.2()41::. 12 if;RE::f.\                 Bl<ONti                         F\AJHM CHhNhlEL l..l:;'.F'r                                                 P\.\I         CT::::/:E:l;;:'.C '.Y~E'J!::R          F:CT J.          0                                                :;1:J:1.                  J.4,,                  J.. 64                    H?.4. ()::!:                    179               J. 1 J.. 101:::: ***01 2:3. 6
          ~?:          0                                                 .t :2.                   20 .                   .t. 4!5                   476. 1;:1:~i:                   471                       ...... 1;~: ::~: E. . . c):;2 1.~, .1.' ::::
                                                                                                                                                                                                     .l ::~: **::i

~;: ()  :]::~:. J.O. 0. ::11:,~ 7':;;~:~l ~:,2 '722 1 ~:1 1. J. OE-,().t 2:~r.. 0 PEAK SEARCH COMPLETED (REV 12)

NUa.IDE*IDENTIFICATION SYSTEM (SONGS VER 8. 0, 8/87)

SUMMARY

OF NUCLIDE ACTIVITY TOTAL LINES IN SPECTRUM ,-::, 1.,,1

s NOT LISTED IN LIBRARY 2NTIFIED IN

SUMMARY

REPORT .t J. . . . :~:I(:iM{a~ NUCLIDE  :;1:BHF\ HLIFE DECAY UCI /UNIT ERROR %ERR XMIX I*** l :?;1.1. r,::*p 8. 04D 1. 009 2. 970E -7 6. 581E -8 21. 99 J.00. 00 ACTIVITY FROM ISOTOPE GROUP* 2. 970E-07 UCI /UNIT TOTAL ACTIVITY* 2. 970E-07 UCI /UNIT

• lHl* *lF*ll--lH'.* *)H'dl* -il* 11* *)HHr *il* *)H!* *lH~ *ll* -ll* *)t ,)!, *l!* *l~ *lHHr ,JHl* 11* *)Hl-{Hl* *ll* *ll* Bl..~*)~ ~I* *ll* *ll* *)!* ~. *lH!* *)I* *)HI* ,)l, 1/Hr 'lr ,)l, *)I* 1 1Hr # *-lHl*
  • • • • • • • • • • • • • • • • 22-FEB-8 8 13:07:04 *****************

I' rzsH INTAKE 0222RH02 SAMPLE COLLECTION START CATE: 02-FEB-89 12:45:00 SAMPLE COLLECTION END DATE 02-FEB-88 12:46:00 SAMPLE IDENTIFICATION: 0060 TVPE OF :~::Al"IPLE : U2/:1: H. P.

AlvlPLI:~ 1'.;!U{-'I\IT I TY: 1000. 000 UN :t T:rr::: ML PER CENT YIELD: 100. 00000 REACTOR#: 2

,:;* r.:, t... I::;' "' {,\1 1v1 r ti.. 1~*

                             ...*ti,     11, 1v1 ,:::* 1*F:'t;, y .

r"';..' n i:;;.

• 11.... L.. **c 1".....'1 I"'*1r*'F.::0 1

II'\,*c Ne,*, r.;.. .... I.... *'( n*.. rr.:;, r.::* 1:",,r,*1I,\ "I" f"J... 1;*\1,.,, i;;;. ..:::* ,,'f. I'*"I1 .,. "r .1L,. 1{,)1l....,:::;,...*-

• J. 1 EFFICIENCY FILE NAME: EFFD . MAR1LD ACQUIRE DATE: 22-FEB-9 8 18:01:88 *

                                                                                                                                      *H*   Fl,,JHM ( .t :;;::32 ) :                                                                             ::2 . () ::~: ::1 PnE::.:il:::T T J. ME (LI VE) :                                                               :~:l(H). ::::E:.C                        *ll-  :::,EtN:::: IT IV J: TY:                                                                             5. 000 ELAPSED REAL TIME:                                                                            800. SEC

• SHAPE PARAMETER: J.O. O ~1; ELAPSED LIVE TIME: 300. SEC
• NBR ITERATIONS: .t 0.

                                                                                                                                      -li*

DETl:~CTOI::.:: l~il~:1::.:MD

• LIBRARV:NUCL . RXLIQ CALIB DATE: 22-FEB-88 08:00:00
• ENERGY TOLERANCE: 1. 500KV KEV/CHNL: 0. 4999749
• HALF LIFE RATIO: 8. 00 OFFSET: 0. 2248660 KEV
• ABUNDANCE LIMIT: 75. 00%

Pl< :t T l:~I\IIEF<OY FWHM CHANNEL LEFT PW CTS/SEC %ERR F:cr PEAK SEARCH COMPLETED <REV 12)

NUCLIDE.IDENTIFICATION SYSTEM (SONGS VER 8. 0, 8/87)

SUMMARY

OF NUCLIDE ACTIVITY ro~~l LINES IN SPECTI~UM

   .S NOT l."Im"fSD IN L.Hlf.:::AF\Y

~~~NTIFIEC IN

SUMMARY

REPORT o. oo:Yi: ACTIVITY FROM ISOTOPE GROUP* 0. OOOE-01 UCI /UNIT TOTAL ACTIVITY= 0. OOOE-01 UCI /UNIT

• • • • • • • • • • • • • • • • • 25-FEB-88 14:88:45 *****************

SAMPLE COLLECTION START DATE: 25-FEB-88 14:00:00 SAMPLE COLLECTION END DATE 25-FEB-98 14:00:00 SAMPLE IDENTIFICATION: 0241 TYPE OF SAMPLE: U2/8 H. P.

AMPLE G!Uf-~NT I 'l"Y: 1000. 000 UN I TS::: ML PE Ft CEI\IT V H:11....ti : .t 00. 00000 1::::E?'-~CTOFi: :I*: 1

,::*-t\J*i11::*1.... I.":..

• tt1'l"1 r.:: r:*1::*n1*,*1

                           ...1 ... , ...

1:::*:r*c~,y

• t... r\ . J. L. I.... I 1:""**1 1111*, 1)1~:,

                                                                                           **1 \ J', N1~:*1     l 1*1.*
                                                                                                         ..........            1**1F:,r::*1::*A"l"1"*11**
                                                                                                                                ... i;;** ,      *** "'      1*"! J', *r* l', f.,)I
                                                                                                                                                          ..::* J', "'                  ..1 .... ,::*
                                                                                                                                                                                                 ,.. ,1,*

• EFFICIENCY FILE NAME: EFFD . MAR1LD ACQUIRE DATE: 25-FEB-88 14:26:58
• FWHMC1382) : 1. 929 PHE(i::ET TI Mt::'. CL.. I ~/E:: > : ~:OO,  :::,EC *  !::;f::J\Ji:::; IT IV J'. TY: f;:i. 000 ELAPSED REAL TIME: 800. SEC
• SHAPE PARAMETER: 10. 0 X EU*~P:1:;ED LIVI~:: TH1E:  :~::00.  :::iEC *li- NBF~ ITEf;~ATJ:ONS: 10.

                                                                                                                        *il*

{l, l:HSTl:~CTCIF~: C:it:;]~MD

• LIBRARY:NUCL . RXLIQ CALIB DATE: 25-FEB-88 08:28:41
• ENERGY TOLERANCE: 1. 500KV KEV/CHNL: 0. 5001084
• HALF LIFE RATIO: 8. 00 OFFSET: 0. 0628753 KEV
• AEVNDANCE LIMIT: 75. 00%

                                                                                                                        *ll*

25. 07 TO 2048 .. 51 FWHM CHANNEL LEFT PW CTS/SEC %ERR F:r.T J. 0  :;.:6/.1,. 7'::ly(3 I J. ~:i.  ;::i. .l. 14 '72'::'. 29 .,:2:::::

PEAK SEARCH COMPLETED <REV 12>

NUCLIDE IDENTIFICATION SYSTEM (SONGS VER 8. 01 8/87)

SUMMARY

OF NUCLIDE ACTIVITY TOTAL LINES IN SPECTRUM J.

       .SNOT LISTED IN LIBRARY                         0

. iNTIFIED IN

SUMMARY

REPORT .I. J. ,... r:;::r l~ilY!A I\IUCL :c DE  :::il::HR HLIFE DECAY UCI /UNIT ERROR %ERR %MIX I*--1:3.l FP 8. 04D 1. 002 1. 864E -7 4. 411E -8 32. 88 100. 00 ACTIVITY FROM ISOTOPE GROUPm 1. 864E-07 UCI /UNIT TOTAL ACTIVITY* 1. 864E-07 UCI /UNIT TOTP'IL FT.::::::::IOI\I PF<CIDUCT::::: / TOT~~L.. (.~C:TIVf~T:COI\I F'l~ODUC:1":::: 11 1.Jl\ll:IIF:Cl~E::D

MINIMUM DETECTABLE ACTIVITY REPORT (SONGS REV 2 12/86) PEAK WIDTH* 8. 00 FWHM. CONFIDENCE LEVEL* 4. 66. t1 IIJ\IJ.MUM

          .,,:LIDE::                                                  UC :I: /UN I *r 1\1 (.~ ...,:~~ 4              c:,. 1 ::.1t.:-:,1::1. e5?;::i        0, OOOOE::-*O J.

hl:~ .... ,(.i J 0. 129::~:. 64 (). OOOOf::. . -0 .t cr;~ . ~!5 .1. i"ll\l*. *!:S4 1. 2!::iO!;:iE*-*07 MN"*"::::i6 <). 1 ::~: J. 0. 72 0. OOOOf!.:>**O J. co-..,!~P 6. .t ::n. 01.:, 4. 'iP.::.2:::1::~-*0::::l J..  ::H O. '7!::i 7. 0 ('.~, 7 E: I:::: .... 0 :;~: Fl::i:*. *!;:i9 0. .1.29 .t. !::i(:. 0. 00001:::: . -0 .1, co . ,. 1,~.o .1. ' ! :;: :r:: :;! ' I.I*~:, 1. .1. .1. ()';:1[-07 cu . ~1.:,4 J., ;L ::.11.1.!!:i. *:;):3 2. ::;:!;;:iO!~,E*,. O!::i Zl\l*..*6t:i 1. 1 .I. J. !::i. f:::i2 r, . . I:: ::::14  :;;?,,  :;~1:~1.1.. ,~:io 4. 1:: 1 .1. o:~:r::: . . ,07 I< I~~ ""' :;: e:i r::~. ~51 ;,~:. ,:;,,;:)  :;r.. 4<)1.J.C>E**"C:,:::, ~i:: fl *** 1:::1 !:i M  :::::. .l ~5 .l. .t l:;: 4, :~;1()()/.:,f:;(*u*OJ::;I

                               .1.,      402. !:;,:?,1                9 . '7 6 .l/, ::~:Ii:::"'" (l I::::

2. 196. :~~:2 .t . :~~ ::~: :;:: r;:; 1:s *m, 0 *7 J.. 1::1*::):~:1. (>::::: J.. ,:::,E: '7 6,E .... Cl~:,

f~ E: -* l::l 1:r1 7. 92:241:i::""'()'7

F~~. 91 L .1.024.

::::o 2. 7721 f::.-*07 y .... *:r, j, M O. f::;i !:::i 7. !:;i'7 0. OOOOE-0 .1.

(). .t ::::: 1::1 ::.: . i;;, 5 0, OOOOE-*O J. y ..... *:i'J2 l. 9:'.::4, !;:;,() I.:,. :;::I ::~: !:511:[;. "-() '7 '(. *"'"'::I l.  :;~67. ()~;. 4 ..L~:i9:2E***07 (l, 7 /.:,P,:i, °7';:I 0. OOOOF.::. ***Cl .I. J., .. '"':.)5fvl 1. t:.,J. J.2E'.*. *07 ZF< . ***:;;*;;::i .1.

• 7 f.:i I.:,. '7 2 .1. * .t 9::u~,E-**0'7 NX:::~.. 97 .1.. J. Ol.~,c:,E*-07 z1;: ...,97 0. 7.ll<:l 40 0. OOOOE*. *O .l M0***9'~) J.. 7::.:*,). 4 7 4. *;i)*;)2:2E ... 07 TC .... *;"I*::) M 2. .1.40. !;11.l  ::, . ,:::: ::;: *7 (~11:~ """ C:) ::::

RU"* 1 o:~::  ::::. 1.1,';)7, 01::: 1:E:. *~) :::: *~) .c!~ E!~ ..... () :~: r~u~...1. 06 :2. I.:,:~~ .t. 1:it4 7. ':,) () 41:;:: l::'.-0 '7 h(J,.... J. 1(llvl \::I. 6!::i40E:**01:: !;~: l~: ~" :l 2 4 .t. 60::~!. 7 .l  !:5. t.l,l.:,~:,9E**OI:::: XE~ .. J,:;:IJ.M 1. 2'::17!::iE:.***06

r-.t::~:2 J.. (::,(,7. 70 I.:,. ';:i'04f:::1E*"*OI::::

I ..... l :::;::J:: .1. . ~::!i :~:~ ,:;~. :::;: ,;)  !"~~. ~;i:J::!~!i J, E!:* 0

                                                                                                      "()::::

x1:;;~...1.:::):::: ~:i.  :;;:,I,, 00 .1.. 2':i'J:::OE . **07 XE*-*J. ::.::::::ivJ ~(.  :::~:]:;,:, .1, l:;;l :::::. J. 72:2E--.. 07 c::::: ......1:::.:4 .1., 71::,:::;.  :;!;:() 1:: 1. 0l::l t'5 4, I: : *.. 0l:~I I .... 1 :~::.1.1 J..  :~:::::: LJ.. ():~:: 1. 700:~:'.E*. O"'/

r. ~ .. J. :::::!::;i 0. .t2/.:.0. 4.l 0. 00001:::;.... c, .1.

X1:2 .....t :;;;: :;:i ~~i, 24'::), 79 1!:,. :27 J. 71:::*-01::: C::::.i*-* .l ::::/.:, .1.. J. 04:E:. .t 0 .I.. .t 0721:~ . ,. 07 c:r::: ......1.:::::7 /.J,, /.:,/.~, 1. 64* 1. ::.: 6, 'f:) :~::Et ..... () '? XI:::.*"* .1.::::11::I r::i' l;~: /.J, ,l /,:, f::. ... ()';'

0. OOOOE **01

!:::(..~-... .I.:::::*;,                                              2 . .l 40 .1.1::1'""07 p                . .lj.(l     o.         r5:::r1. 2~::;               o. 00001::::-0 J.

L. .l 40 0. .1. !;;i'::lf.:,, 40 0. OOOOE**"O .1.

F'hC:il:::: ;;~ PEAK WIDTH* 8. 00 FWHM. CONFIDENCE LEVEL* 4, 66. tv1INil'1UM

           ... '.tD!:::'.                           UC! /UN'.tT CE:'.*** 14 .1.                     ,1.4!::,. 1.1.4  <l:,, .I. 24::iE**. O:J L(.,\***.1.42.                     !.:,1.1.t . .1."l Cf;;;'.-..*J.4:~:I                                   9, 40~:i15it~*():;::

Cl::'.-o~ .t/.J.,'.I, 2 ..l ':,;*o:~:1E:-0'7 (,) "'" J. 1::1'7 :2. 479. !;:,:~:  ;;r,. 6 !'.:, 1::1 i' ,~: "'" 0 "i' I\IP***:Z:'.::*~> 1 , ::::1 .I. 241:'.-** 0 '7

• • • • • • • ~******************************************************
              • • • • • • • • • • 08-MAR-88 10:02: 11 *****************

~MMPLE COLLECTION START DATE: 08-MAR-ea 08:50:00 SAMPLE COLLECTION ENO DATE SAMPLE IDENTIFICATION: 0476 TYPE OF SAMPLE: U2/8 H. P.

a; i*~ 1v11::t,, I:[ (i:!1. .1 /.:*~NT J: TY : .!. 0 () Cl . Cl (H'.l UJ\I J: T t\: : J'tl L. SUB-STANDARD QUALITY 1:*1:~i::~ C:E:I\IT V:tl:~:1.... r::i : .1.00. 00000 F~l:rn1::::'f'OF( 11:r:  ::;: BEST AVAILABLE COPY

,t.:*r\1v11::,1 11 1::: ,*:*1:::n1v11i::"'l"I::*,\;' IL I110,l,.!1 I' 1"! 1v1~\1~**  ::01 I.. ,.J,'I'

                                                                                                                                                     .,. 1111\1~1111111                     n1::,1:::*1:*,{,i"l"1'     "11:* .. ::*      *1*  1' 1 'I' "I"   'I' ,;:.1 ,::* .

• .. ,1 1 EFFICIENCY FILE NAME:

                      "l>*J"             ,i.11111111          ru,          ~Ji                      ,1 H EFFC
                                                                                                                                          /"1 ~11
                                                                                                                                                         , MAR1LD m           ,111 ~("/      u, ~,,.,I        11 ">11,            J,f~ 11 , > 1 , 1 , . , 1 , , _ ,

MAH C\ :: . E~:~:' 11* 1 ... t:,I'" I..,I "'[ 1'"t,"11"":::. f.'\1 t,: ,...I {'1 "f I"" I" *'" 1v111*, (..") ,,~! " ,w, J':~l" l'"l."....1", I\ I'"~ "' ~hi"

                                                                                                                                 "'it~-il..,:, t, * *0:1 : (") ,,::I   .~

F' \,J HM < .1. : ~1 :;11 : 11 ) :  ::;?.. .I. .1. :l 1 11 111

~ :

c* C{n  %

                                                                                          .. ,

• 11 l::*F.;,r.::*,::*1::*"1" i,~111*..-l 11,i "l"J'1*"I1:::*,n, 1m, rv 1~:::*.., I\ ,,

                                                  ,                                                                   '** ,       ,j 1 '1("1
                                                                                                                                     ,,.,   ,. 1
                                                                                                                                                         ,::*~:-!"*

r,..lf;; m'..

                                                                                                                                                                                  *M*       ::.;i I~: N:::,1 .t T' :r \/ I TY :                                                 !~5. (100 Ii~ L. (..~ P::%SD Fl 1:::. i/,\ L T :r MIi::                                                   :                             , l'.>{ttr:-...             $      I::. C

• SHAPE PARAMETER: .lO. 0 '.'.*t

~~ L r.::i1:::, :!:::!~:: D L. 1; VI:!! "I" :1: 1"11::[ :                                                                    .I. 0 0 0. :::; 1/:: C:

• NBR ITERATIONS: .I, Cl,

                                                                                                                                                                                  *~*

Df:~"f'f.!::C"l"OF1: i:::11::::F~l"ID

• LIBRARV:NUCl , RXLIQ CALIB DATE: 03-MAR-89 08:88:80
• ENERGY TOLERANCE: .1.. ~OOKV KEV/CHNL: 0. ~000224
• HALF LIFE RATIO: 9. 00 0 Fi:;:* !:::i r.i'. "I" : O. .1. 0 7 !:::i '7 "/ :J:: I< 11:: '/
• ABUNDANCE LIMIT: 7~. OOX

                                                                                                                                                                                  ,u, i~#~************************************************************

1::r.1,1m1:i::~1::;v WI I\ID(H;.J ,.. ,u,1 1

                                                                                                                                                                                            ....!11*,;,1,     .l l     TO                :;~ () ,!.J. 15:: 4      2()

1~:*1< :t'T' 1::i 1\11:::. Fi l'.'.i Y (~)i::::E(.,\ tJl<C:ihlD F\.oJHM CH(.,\1\11'~1:Sl... l... f::i:F:-"I" F'hl i::: "f" ::;:: ,/ !ll:~ Ht c: :1i:1:i:1:::1:~: F:tT

l. 0 '!ii~;:~ I ,1. .t 1-HiYf H:1. 1~:* *'"t

0. 7"7 J, l~:14, 00 J, "'/ t,::, J.6, .I.. o:~::

                                                                                                                                                         .... 1.,1 ...                                                                                                                          :r::1::~1,::::1,111       60. 4
            *"~

Cl it 1:i:(~1.  ::~: *::> ,{f/').'5"'1 2.1.. **::,  ::~17*;;~, ::~i(:;1 I'll'/ 11!1, 4,;, 1/5 I

                                                                                                                                                                 /,                   '1111,       J::~                                                 ::r:it::.i::::       .l4       : ;~. .t.::::1::~" "02 :;;::7 .

0

                                                                                                                                                                                                                                                                                                                                       ';:I
            ;::::           ()                ~:mt.::,r:'.J..                                                     *:1:,,                                        7.                    0. 6,i!:,                    "l :;~ 1:;::, / ,,~.

u.11,11*,

                                                                                                                                                                                                                                                        '? i1, 1:1~         .1.4 :::;,, i::i7llii:*""():::l !~;i!}~i, 4
                                          .ttM,.1.. :;:1:::;~ ~11-0                                                                                                                   -11 ... '? *?.t : ;~ ,:;~ : ~~ ::;:' 09 ::;~ *::, ,t ::rri 4               ()                                                                                                                                  0.                    *'"1
                                                                                                            .<'.J,!:::i *                                                                                                                                                    .1.7 4, !;;;t Ol~ 0 ::;t .1.4 . 1::1 UI~

PEAK SEARCH COMPLETED (REV 12>

• • • • • • • • • • • • • • • • • • i**~*****************************~**********
    • ~****'******** 22-MAR-88 11:~8: 12 *****************

ef/Y> . ******* ******* ******* ************** ******* ************* l~PtSH THAT HAS BEEN STORITTD IN LOT i 0822AH06 8~ JS COLL!CTlON START DATE: ZZ-MAR=88 10:30:0 0 l:J(.\11'\l:)LJ:: COl.,L"l:tCT J: C:11\1 l:tl'~t:1 X)(.\Tl:l  ::ti~*"*Mr::W\'"*IBl::i J. 0: !:j(I: OCI l,:l{,WIPI.J:', :r.D!:'.l\l'nl::*:r.cAT:(t:11\I: 1'..~1()4 TYPITT OF SAMPLfil: U2/3 H, P. ~::{~MF'U~: G!UPihl"fTTV: .t 000. O<.'.lO Uhl'.( "f'l:l: 1v1t.. 1= 1em i:::1:tl~'1" y1: l:11,.D : J. 00. (l()(l(l(l 1:~l::(,'iCTOI;~ 1\): J. 1.**At1IFl*0 ,.,. r1t'"('11v1ri"r*1 ,::, ' lo  :=l I~ ,.:;I II t!:1 *,,v !

                                      "~.             I1t t"l *t ( t<1I'r)' f"'"\ *r 11r:"1 1 *r nf"lt"'f''

NI I fh I \  :~- ,.,a ,U * , .. * ~~I \rl-) *r* l.i, r,,::* *t t 1*r 'f' *r h

                                                                                                                                             *,1,:",1.*,    I " I    I 1**
                                                                                                                                                                        'll tndl  I -

1m:q:q: i:~ l: 1m,1i:::v 1:1 1: Ut i'lAMl:t: l:t1::;pie1 , 1'1?Wl J.L.Et 4} ACQUIRE DATE: 22-MAR-88 11:4e:Oi ~I* f:'WHM < .t (:1:;11~?. ) : ~(.. ()~1~" 1::i1~~rntt:>mt r *r J: 1,1mt , L~ J: v1:t) : 1

~~t,c,.  !:::1~ti:~ *I* mtN!:~ l: T 1: ~; 1: TY:  !;j, (l(t(l is:L. (.~f~'mr:~t) f~i~:t),t, ~r :riv,~~::  ::~1()(), ~t,tt:c:

• SHAPE PARAM~TER: .1.0. 0 :1,:

ELAPSED LIVE TIME: 800. SEC

• NBR ITERATIONS: J, (II
  • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • ~**

1:m: n~: C: TCl f~ : (:a::FWI E~:

• LIWRARY:NUC:L . RXLIG c~At.1: l:'! t)~)'rmt:  :;t:;~ 1\1(.,F<*"~1=~1~~ ()E'j: :~'~:::::: <:11:~

1

• EI\IE~OY TOLERANCE: 1. ~oo~v KEV/CHNL: 0. 49994,1
• HALF LIFE RATIO: 8. 00 01:q:;!:mtT: ***O. Cl!::.'i'r:~4 J. *;) 1-.:'.E[V
• ABUNDANCE LIMIT: 75. 00%

24. 94 TO 2047. 72 FWHM CHANNEL LEFT PW CTS/GEC X~~R F' '.IT PEAK SEARCH COMPLETED <REV 12)

                                            *-                       ,a.~;;- 8;?
                                            ,.s
                                             \
                                                            *le, c/i4.1 .s                                   ~"'"" ,~ )t.

_... ....................."'l:l'I"--*****~ R<Ls"" I 1- +;" ,,,_ c~_:__:1/~,~~

          .e~s klL-~                                ,~"'- :p.-44, l<"-c1 (0 +--

OM t.. \ (>o ~ {d <f.o (,.,, /':)/e. "f-Sf(_ ( f?i"t?" $1,1 p, S j

        ..                                                  yo1.,.. r- *
                                                    \A.~ -

!\I I.JC i.... I Di:::: I D1::::1-rr l F: I C(YI" :t Ohi :~; Y:::tr El'! ( '.::: 0 J\I (i '.::: VE:: F: ::::, 0 , l:::/ l::::'7 )

SUMMARY

OF NUCLIDE ACTIVITY TOTAL LINES IN SPECTRUM 4 I. '['.:::: NOT L I :::rn:: D I 1\1 L l l~:r:i?H'f/ _NTIFIED IN

SUMMARY

REPORT J. SWB}ff ANDA~~ QUALITY

,;F,*, r AVAIL!.bl... E. COPY J. "'"'.;;: J: C:il"'J(..'.1 MAR O3 191 NUCLIDE SBHR HLIFE DECAY UCI /UNIT ERROR %ERR %MIX I-181 FP 8. 04D 1. 004 2. 808E -8 1. 279E -8 65. 48 100. 00 ACTIVITY FROM ISOTOPE GROUP= 2. 8085-08 UCI /UNIT TOTAL ACTIVITY= 2. 808E-08 UCI /UNJ:T

      ***~************~
      ********~*********'~~***************~*************~**~********

l8 FISH 0310AH05

.

• Lf::: COJ....1...11:.C::T I ON ::;;Ti:if(I" DhTE: .I. 0*..*1**1l,:1F:;,.. -:::::f; J. 4: :~::o: 00 SAMPLE COLLECTION END DATE 10-MAR-88 14:80:00 SAMPLE IDENTIFICATION: 0799 TYPE GF SAMPLE: U2/3 H. P.

  !;::(.,\l"'IPL..E 1]i.J1:::1NT I TY:                                                                   J, 000. 00(,                                                                            UJ\l J: T:~::                               Mi....

F'EF~ Cl:~t\!T Y :t ELD : .l. 0(1. 00000 nl:::'.PiCTOF: :j:J,:  ::::;

,,;:,.....fuj 111I'"'    '"' L.,, I""
                                    ;;;, f,., '"* I"";;;, 1,.,/- ru1 I' r,;;, "f* 1**
                                                                               '\ \}

I ; J,' l'" I"" ..... ,I, I~,., 1v1 /"') ,., I"'"i* 1,I,* l\1 r.;, L I"" "

                                                                                                                                                                   . "'""            1*         ...,I"'"', ,,.;

l.,1 I'.!" I"',

                                                                                                                                                                                                                   ....," 1"1 "I" l"'t  "\ ,;;, "*1* N J', "I" 1*, I"\
                                                                                                                                                                                                                                   .., ,........                            " I"" .~;,

EFFICIENCY FILE NAME: EFFD . MAR1LD

iC(~!U:Cl:~1::: J.:i(..\TE:: :1.0*"*l..,li*~F:: ..-::::::;:: .L!:::i: 06: .1.9

,flE::::E:T TI ME~ ( L. J: \!E) : *11 F l,\IHM ( .I. ::;:::;.:2) :

'.:::00. ,:::;Fl"'*

t...hF*::~:i::::o i:,:Er.~:.... T :r 1..-il:::: *,:r  ::::E]\/!.::; IT l 1,1 I TY:  !;::i, 000

H)O. i:::;D::::

'.L..~1F':::::E::D I.... I vi::: T J: r*!f:::: JOO. :1::1:::c

• SHAPE PARAMETER: .1. () ' <) ~~1;;
• NBR ITERATIONS : J. o.

1 "11:::"*r* *:~" I'": "I" n p ' C:i r::: F< MD I.... ... ... * * * ,~* ** ... .. ,..., .... c*) c*, ,.1

• L:r.t:::l::u*,\1f!\Y: I\IUC:I.~ . 1:~>d.. . :tG1 .........

J. 0 ..... t'1,f.lr-i i.. .... i-** r,, l

              ,,.*1 "'""'

J 1::, n(.)Ti:: * ..... :::::::::: Ck, : .::, .. : .., ., ,8. 1\ i;:*k,1r.::*1::*1*i' f;, .. 1** i:... *~ "iV

                                                                                                                                                                                                                                     }        "l"f"ll E::*1::;;~~I\ICF::::                             .1.' ~~:,(.)(,)!<. V
                                               "" I                "'                 '**         I""*"( "'"U I:::'                                                                                                                         td  "'  '"

l<EV/CHl\lL: !J ..::,!J.JU/U ....,

• HAL..F LIFE RATIO: 8. 00

                       ... ... ,,.,1"
                                ... E*.......I **                                         c",. ,.*(")*:::,
                                                                                                                            ..,,,., 1. ,,:::,..., 1.t1::*v
           ,,*.. ,r.I' . f** .....
              ~

r,.....

• ABUNDANCE LIMIT: 75. OOX

25. 09 TO 2048. 88

                                                                                                                                                                                                   .

• 1**....:1..,1"1111 F~,ihi'1 1**1 \ \ 1,:;i....

• • • 1.... ,:::.. . ,****r*

                                                                                                                                                                                                                                                                             **                ,.....,1.,
                                                                                                                                                                                                                                                                                                      ,,          r.::"l"::.:.:.:./:.:::cc
                                                                                                                                                                                                                                                                                                                   .                       ;,::cm:: FIT
                                                                                                                                                                        /.j,i.::,,                1 J,.          ...~:J,::*I 87 1. 05[-0l 85. 5

0. J. J '::7 28 3. OOE-02 88. 3

o. .t. i::::o 10 3. 67E-02 80. 2 R. '2,( e.Gc R

                                                                                                                                                                                                                                                 $(.t.vv-yl(:/

!*.Ji.,.(:,;;: L.. I Di:::: , I Ui:::. NT I F' l C;;,yr I O)\j ::::: i' :;;; *n::: !*'i '. ::::: C.11\i (i ::, ',; E:Y.: ::::. (l , :;;: / :::.: 7' >

SUMMARY

OF NGCL1DE ACTlV!TY TOTAL LINES IN SPECTRUM LINES NOT LISTED IN LIBRARY lTIFIED IN

SUMMARY

REPORT 0 ACTIVITY FROM ISOTOPE GROUP* 0. OOOE-OJ UCI /UNIT

UNKNO~N LINE REPCRT F' f\, (:i C .l BKGND FWHM CHANNEL LEFT PW CTS/SEC %ERR 0 1

1 ::~. !:;;i () 4,'.:,. .t. 2t.::,

 .;:: () .i. 4r.::, .1.. :::::::::: 1. .l..

t WE8T3 3/14/89 11139AM (690 byt*** 13 l~) mi 11;,t T' Triad to ~ontaQt you befcr* RMO atMff mautin~ at 1800 but unMbla. Apper*ntly, 8Mt 3/12 Whit I Ft1h mhQW&d Xa-133 Mt w**

l,.1;(1IZ1

l/!:::,-,,'t' 1,,1e:t/1::H::1 (~~,i:::f:!ct) "f':l,/il:i:),. "/"t'df/1! b///1$f*t,((i\"t: :/,!lil l1(:M */u.1,;/. l/i1'1"1/;/

raquir** r*mQVal. Whit ia tha dtmp~aiticn c? thin matariM11 How lon; till rwaamplin;? Pl9MBE CGhtmQt I ( ti!, <'i'/t 1'11 p :/, :/, 'i"I ~} *b (,,'/! i::; h )'1 :/. (;:) :[ 1::1 'lI ) 1

                                                                                                                                                                             !lf/,1:::1 aha o*~ mkm Mp~                                                     *an;amw~t1. Scrry for th*

/. Y's 1::* ,:::, '.l"I V (Iii* )I :l 0.WI c::* (I;~.

  *****************                                                         12-MAR -88 14:58:2 8                                                                                ******~**********

1t*il* 11* 1t* il")l* ~HHI* ')I*% *~HI**)\* ~t* {t* {Hl* >,\* *HI* *)l* {HHl* >,\* -tt* ~I* ';I* :;1, ::1, *::t* ,;I**~* ,r,, *rt* :;l* -:~* >.\* *** 'n* ~I* :n, *:I, ,1, ,~. *~* *ll* ,)1* *~* ,:i, *O* '11* *:1,::1, ,11..;i..~*~Hl* *** *** SUB-STANDARP QUAL.FY BEST AVAIL.Ab\..\:. COi y

3(.'\l'1F'L.1:: COI..L.ECT J:CJI\I ff1'(.1Fi.T D?Yl'E: J. ,;: .... J'1 (-1 P. *** l:j 0 ), ,,I; ), (1;

                                                                                                                                                                                                                                                    ,~~

(,I(.' f:;{.!il'IF'l..E: C:CIU ..E:C:T:r Ohl E'.N[I J:1r'HE: \ ~;~ ..... Mr, F~ **** ::: 1:::: , ,,.. \ 1) 00

oAMl:)J..E l'. DEl\fr l F J'. Ct1T T. 01'**1: \:i::k,( 1 TYF'E CIF f:;hl"ll:'l..E: .

>(.ll',WI..E G)U(-l\\H J: T'r':

U'.;'./:::: l*I. F'. J. OC10. (1(1(1 UNIT:::;: Ml.. l 3/Pr - PER CENT YIELD JOO. 00000 F:E'.hC:TC1F: Jtj: 0 /2LSG

>Al'1F'L.1:: 01::0111::T fl'r': l'. :30TOF' IC . .,1::,1::1:.;,

I., ** ,H ~, *1* U.. 1:;,.....::*, J', t**~. 1 J"l' l',11 c' I.....,::*,,*

• E:FF 1 Cll:]\ICY FI LE hl(.',,t*'ll::: ff.FT E: . 1*1r:,i:: .1 L.E'. M~R i 4 \9SS

                                                                                                                           *~*

ACG!UIF,:E l'.11;TE'.- .I. 2-*l'l(~F:*.. (::f: .14: .-;.7 f:i:J ,:1- f='l.,Jf-\1'1 ( .1 '..::::;:2) .1 . ,;, O'.i'. Fl1\::!::;F.:T T l'.1'11:1 ( L. l: VE) :  ::::(1(1.  ::ll::C ,:; :3E]~::l IT I 1v1 I TY:  !:). (1()(1 r::u~F=*i::CD m::11,t.. T 1 l'IE:  ::~:oo. ::t:rc: *>>* '.:::f-11:,r:*[ F'{:1r:r:i1*1E'.TE'.F:. I 0. () ,1,: l::U1P!:)i::D L. I VE: T J: 1*11:::  ::::()0. ::::EC

• NBR ITERATIONS: J.(1, DE:TE:CTOf~: (;i[~F.:l*IE
• LIBRARY NUCL . RXl..18 Cf.'lL IB DflTE: u~-M(.~F(**i:)l;:l o::l; 22: :3!::1 *~ E:l'~E1:wy TOI...E:F;:f.'1NCEi: J,. !:)0(1!<',)

KEV/CHNL: 0. ~000556 '~* l*lf°.!1l..F' l..1 FE'. F:{ff'I (I \:\, 00 OFFSET: -0. 0205877 KEV

• ABUNDANCE LIMIT: 75. 00%

                                                                                                                         ,~.
 ****************************~*o*******************************

l F'f( :tT E'. hi E'. f:: Ci y r:,F:E:{:, E:f:.'.1'.:',hll.1 J. (I 1::~c,. *?,) *~)  ;~:,. (1, (1. *7i:) l,~:i:~:. (1(1 J.!:5,~:*  :::: :~::. (1(1E: ..... c,:~ -tH.1. ::::

                                          ~::~:1                    l .,.
       *'"'/
       ~:..        ()    .\4(:,0.                  KL/-0           . I .                              0.                       .1. c;, . ;, ~~~*:;,~~~(), /~.'/ ~~~i;, .1 ~:i                                        .l   .1     ~;i, 1,;/7(:.h*()::~. ~;~,*;., :;:

PEAK SEARCH COMPLETED :REV 121

i\iU1..:L.'.\l.lL. 11'.l[J\ITH :ti...i*fl':ICJJ\i \~;'/:.:;'\1 .. l'1 (:.:;Uhii.<: \/U*: ::.:. (l. U/(;:'/)

SUMMARY

OF NUCLIDE ACTIVITY TCIT(~,L. L. I hlE'.!:.:; :r hi f:F*[CTnl.11"1 LINES NOT LISTED IN LIBRARY J.

r DE'.hlT:t F :r E:Li J hi ::::UMl1lf.1FN f*:ET'Ctf:tf' .I  !.'.,(), oo:,.: f!L<.,S .S/f~

MAR j 1 1988 hlUC:l .. 1 DE:  ::::E:l*ff: HL. l FE: J:.ir::c:r::*1\' Ul:: :t /1..11'11 :IT Xl::***J.:3:3

,l;r::r:!r~ ,11;1'1'1 J :x:

1::c,  !:L 2 !:H) J.. 0 UL) J.. (I (I J. [ -* '? 4. c,::~6E ..... :::: 4(1. :::::;:: 1. (1(1, (.1(1 SUB*STANDARD QUAI /TY BEST AVAILABLE COPY TOTAL ACTIVITY= J.. OOlE-07 UCI /UNIT

  <R       \~~*~~~~~~**~*~*~*******~************************************
 *****************                                                      14-MAR -88 09:41:0 3                                                                *****************
 **************************~***********************************

SAMPLE CGLLECTION START G~TE: 14-MAR-88 08:55. 00

                                                                                                                                                                                                              /2LSS                    3/; ~-

,(.,if"IF'L.C ,:* .i)L..L.t: ,.::T 1 i::.1\\' tt**~D D!'*\ *1* i::: .1 ,.*, *-1**;1':in--uc ,.:J:::: :.::;!5: oo

 ,::,.:*1l'*1F:'L.E'. l Di~: l\iT J 17:* I CAT J: 01\I:                        1)::::,9~:i MAR i 4 \9~S T\'f*C (Ii:: :::,(\l'IF'I._L

• U2..::.~: H. r*.

H-1l"IF'l..[ OUhl\JTI. ;'(:

SUB-STANDARD QUALII'.i J.(n)0.01> ) IINJT*:.:*. ML f.!EC'T11 VA/l/f-,1 , 'r F'Ei::; :::r::::NT v :r E 1...n : .too. o(:.iuoo Ri::r~c+r.~,R

=.1**'

                                                                                                                                                       'i:J :*          2                              * .v             1
                                                                                                                                                                                                                         ..,          * *\    :,d: GOP>?
  - *1 Mr::,L     1 r .c:. i-**E*:*n1*11::"rf

_, . ... ... "'\ Y*.0 iL l_ J'i'.' . ....1 t*1***f-*J'l'

                                                                                      ~, '\ .. ~1E*:*L

• 1,_ 1. i"'ll::,r.::*1:*,:-*1*,-

                                                                                                                             *. 1;, 1(-4 _1R"":*       **,, l l'*~1 J'"l"J',*L
                                                                                                                                                                              . ri *.*

EFFICIENCY FILE NAME: EFFD . MARlLD

 **********************~***************************************

ACG!U I F:,12 WYTI::..

                                             .l 4-*l'iAf::--c::::; 0*::1: :*.:.:~!i: :::::"?                       ~* 1:::l,JHM ( 1:;:::32) :

PRESET TIMECL. IVEl: 300. SEC -i:,* *::Ehl:::: IT I 1v I TY:  !:;i, ()(11) Elf-1F'S;EJ) RE(..~l.. T :r. Mf::.:  :;::OO.  :::-:E:C

• SHAPE PARAMETER: l (). (l '.Y~
• ELAF*:::f.::.D LI VE TI lIE:  :::::(10.  :::EC.
• NBR ITERATIONS: l 0.

i~ tiETECTCIR: 1JERMD Cf".'.tLlF.: DhTE:

                                                                                                                  **        L lE:f,hRY: NUCL                                . RXL l (J J.4-*M{:iF:-::::::: O::.::                     ~t:::: J.f.5

• EI\JEFWY TOL.ERANCE: J.. 500~:::V t:::r:::v /CHNl.. : c,. 4*~197,::.,:~:*::., *l~ HALF LI FE RfH l Ci:  ::::. 00 oi:.*Fi::ET: (1. J. 7;:;;:2:::,:77* f,:.E\,' .;,:. Pif:::Ui\lDP1\'JCE': L. IM IT: n:,. 00:\

il

 *********~***********************~**************~*************
                                                           "" ~"

i*H** r;.1/\..1

                                                        /\

2 J. 0

                  \.)    2,::1 e:.. J.2

.:~.5.2, 00 e,J"\

Pk?-' J.4. 1,:::, *~* J. . :~:1 *~J

1. 55 5 9 0. J. ,4  ::;; ::: ;~ .l :;: Lj.. t.!:, '"1 E:: ......) '.Z: :'.;: ~~:. :'.;::

708. 94 698 11 6. 04E-02 26. 8 KAO 1_1,

(I J.41.

:,(1, ~;: :~:i 21. (I, 0. 7'::::  :~~ *~)~!2. 6,:2 2,;:.1 f, 1 ~~~ 7. O(>E-<):: 2 J.. ::;:

PEAK SE~RCH COMPLETED (REV 12)

l, *.1,'..L:J.L,1::..' *;,L.:tJ\lTJ.F1Ci'°*iilC1N :i:,r:~:,Tli(t*l (::'.,Cil1/.:.,*:::, VEF:; .::::. ,.,,  :;;::,1:~:'?1

SUMMARY

OF NUCLIDE ACTIVITY PAGE TOTAL LIN~S IN SPECTRUM , . * * ,r:::~: ,~ur 1... :t :~:TE.D :t 1,1 L .i r:::r;:A1:~v .,r. JTIFIED IN

SUMMARY

REPORT Y9LS S 7{?? - hCT :: \' 1 T 1 i *1 .. :i:.w1 l ::::,:'.::IT or C CiF-. C1i.. W*n:i 0. CJ(o1.::,!:... ,cl .I. ,. ,C. .I. /i,,ir**,I IT 1 Mf~R .t h1 \%~ TOTAL ACTIVITY= 0 000E-01 UCI /UNIT

                                                                                                                                  ~ Ur;~7
                                                                                                                                        ~ :,~ff'i,~f"ll\
                                                                                                                                 * [ *'1 "'""
                                                                                                                                                      ~.l .f1 ~X:* '.) ~1 ~~ f* f1"1'. *
                                                                                                                                                    , V J. \
                                                                                                                                                             /:L ,/'1**
                                                                                                                                                                     \l.

.... , ~.

                                                                                                                                                                                    *1  (;J8~>.."
                                                                                                                                                                                     ,* t;) ~*J J,'

(525 bytes: 6 ln)

---

---------- ---- Message Contents ---------- ---------- ---------- -

The Unit 2/3 fish basket waste that was collected 2/22/88 has now decayed to levels below LLD. This is based on the sample dated 3/22/88, sample id 1304. The waste may now be released to a landfill, based on radiological characterization.

NUC~lQE 1DENTIFICATION SYSTEM <SONGS VER 8. 0, 8/87)

SUMMARY

OF NUCLIDE ACTIVITY TOTAL LJNE8 IN SPECTRUM 0 LINES NOT LISTED IN LIBRARY (l

r i:m'" *" 1F :r 1:::0 IN ~::Ul"IMAF:Y 1~t::Pc11:~T 1

          "                                         0 A~rIVITY FROM ISOTOPE OROUPm 0. OOOE-01 UCI /UNIT TOTAL ACTIVITY= 0. OOOE-01 UCJ /UNIT

     *** *** J. .** Al "1'"*U.;l

. **,J.3****,*l i * *** I L.U...,. J. I**** l* ::).,,*1 01 ,* 'c.uyv,..,

                                                                              ,.          L, /;t - I

{~I'll" ,..E

C:Cll.LECT '.{ Cli\l E:T r:,rn [\('.\TC'  :::: .1 .... ,.,r:~r::*. *i.:.1::(: .l ~~:. oo. oo 3AMPLE COLLECTION END DATE 8 J. ***1*1~11:< ..*(::;;\ 1:;: : (1(1: (1(1

(,, t*! P LE :t DE hi T 1 F' 1 C: (,, T.I Cl 1\1. .l 9 .I ,.,.

TYPE OF ::>(.11'1F>L.I:: : U:;:/::!, H. F'. SAMPLE QUANTITY: 1000. 000 Uhl] *n:: 1v1L ..

)l:~F{ CENT Y 1'. ELD : l. 00. (10000 i:::J::hCH:11::: :H : (',I

AMF'L.E (:iEOlvlE:"IT::Y: :1 ::::CIT Or:* 1 C .. ,.:,r:""*':

1.J i *. t\H .. "l"f'il*:"::

                                                                                                                                         , ... , . \ , .*'ill("l'"('

() .... '.[*;-

 ;FFICIENCY FILE NAME: EFFE                                                           . Ml-1fl J. L.E
 ~CQUIRE DATE: 81-MAR-88                                                                                 "-1*  r:-~~f-11*1 ( .I :::::::.:2)                                .I. 97.(
 ~RESET TIME(Ll'.VEl:                                                 :;::(10.       ::lEC               1~    ::::l:'.11.l:::: IT l: 1,) I TY:                           !:\. (1(1(1 rLAPSED REAL TIME:                                                  ::::oo.         '.,:iE:C:           ,:t* !.::H1:1f='E: F*(:,r;:(1l*IE:TET:                        .I 0. () :;;,
 ~LAPSED LIVE TIME:                                                   ::::0(1.       ::itiC

• NBR ITERATIONS: l. 0.

                                                                                                         *-~*
 .:tETE:C:TClf,:              GF:F:ME                                                                    *:l*  L.1 E:f~(:)Ffl t**,Ji..11.::t..               . K( L.] I..!

ALIB DATE: 81-MAR-88 08:48:8 4 *** E:NEF::cr{ TOL.1::F::1-11**~C::E: J.. !:\(1Ul<~i (EV/CHNL.: 0. 499950l *.~* Hf.) L. r* L.'.l F'E: F~ {:, T I U  ::.:: . 0 0 JFFSET: -o. 0148477 KEV

• ABUNDANCE LIMIT: 75. OOX lJl:'.Cihll'.1 F"JT PEAK SEARCH COMPLETED !REV i21

f\ll..11.. :1 .. IQE .'lJ.:!l ::hiT.\F".iC:f°.'."1T.I.Ohl :::;*f:::i'i"[J*I ('::;UhlU:::; *J[Fi. *.::. 0.  :::/C :7) ':;;1,JJ'li"li-iF(i (W NI.JC1 .. ID[ (:1c r J: \.' J: T\.' rC,l;.iL ... i ... :lf,1t:::.:, .'ti*,\ *.:.;r**[C.Ti I.. Il\1[:::; NOT L. l: :::;TU) Ii'! L..:UI*' \ I DF(nF(f 0 (l

r r*, . *,rr :l F :( [D 1 f\l :::;l.. lt.,Ji-11r:,1::v r::r::r

• CIF:T () 0. ()():,,:

[6] /23/88 5:11PM (472 bytes: 5 ln) To: t A'v/S

   ------------- ---------- Message Contents--- -------------- --------------

The Unit 3 f1sh basket waste collected 3/18/88 w1th low levels of 1-131, samples 1221, 1061, 1294, will need to be held for about two half 11ves, or 16 days. Written memo to follow ~

****~wHl'*'*'it*********
,)t~*-ll*-ll*********-11******lt**l~*J-***             J'****:W,******~****~~***~******;;tiH*4HH******* ** .... ,
****************************>ll*******************-)l**e!<*

21-MAf;:-E:(:I .t 0: 01: 5~i ->>*11*'11*,)l**'ll***~BHHHI* * */'di*:;.':*

                                                                                                ******-1**~}******. ** ..., :.;:;:>      ..

U3 FISH 0321AH02 ' e~ .. -E COLLECTION START DATE: 21-MAR-88 08:5 0:00 SAMPLE COLLECTION END DATE 21-MAR-88 09:3 0:00

)AMPLE J:I)l~N'rl'.FICA'TION: l.221.

TYPE OF SAMPLE: U2/8 H. P.

)AMPLE l~)UANT I TY: J. 000. QOO UN l TS: ML.

PER CENT YIELD: 100. 00000 REACTOR#: $AMPLE GEOMETRY: 0 1L. L 1'.Gl MAFn NELL I OPERATOF\~l 1: Nr.T Ir-11 ..f:3 - E:FF :r C: l ENCY F :c LE NAME:: EFFE . MAf\ 1LE~

• • • • • • • • • • • • • • • • ~***************************************

                                                                      -11*

ACQUIRE DATE: 21-MAR-88 0\1: m5: ~i;;, , 'II* FWHM <1~1~12) ; .1. ~:l(:,~:I PRESET TIME(LIVE>: 300. :3EC

• SENSITIVITY: 5. (100 ELAPSED REAL TlME: ~:100. ~::EC:
• SHAPE PARAMETER: .10. 0 :,~

ELAPSED LIVE TIME: 800. :3E:C

• NBR I TE RAT I ON:~,: J. (I, ttETEC:TClfi:: C.;Ef~ME: *

ALIB DATE: 21-MAR-88 08: 11:4 9

• LlBRARY.NUGL . RXLIQ CEV/C~NL:
• ENERGY TOLERANCE: 1. 500KV

0. 4999 615

• HALF LlfE RATIO: 8. 00 JFFSET: -0. 0366 1~3 KEV
• ABUNDANCE LIMI T: 75. 00%

                                                                     ~*

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • ~*************************

ENEROY WINUOW 24. 91:, TO 2047 . I:~ J. F'K IT ENERtiY Af\E:'.A l:lf<GND F'WHM CHAhlblEL LEFT I PW CT{::/~::EC i';E:F~F~ F'1T J. ,;> O:)*") OJ. 14. 4. o. 81:) ....,:,,, *;)*;:ie. 2 9

                  ; .t...

9:,::, 41 rn4. 1(I J,I:) J. t~)

                                                                                                                        ,.,4. t<..)5E-02 '3:3. 4                        (l(J E:1.             4*.       O. El~~;   .t El(:,. 90

3 (I 864. 41:~ ...,..)

                                       "'-,<;.,               13.       0. 74      7'")0:)   O'i) 1 ~:I .t       9     .&t.1 72E-OZ        4,EI, 0
                                                                                      .;;.,.       7~!:]        J.J. 7. 20E-<:t:2 2:3. 6 F'EAf< ~::EARC:H C:CIMF*LETED ( f~EV 12)

~,.,,.,L. 1,111:., l.J,Jl:~1'11 J.1** J,1..,r11 J,1.;1~  ;:)*,::.:011:;1*1 1::>l,Jl'IU::) vt~ri :.::,, 1.1, 1:1/1:::11 ~UMMARY

   .              OF . NUCLIDE     . . -. ~.
                                     '       '. {

ACTlVlTY

                                                   '  *, ;,   ; .           .                                                                  F'ACi[        .\
                             *'*  *'    \ J~     *   . *    '     .... '               .*r,*.*:

'!'.HAL LINES lN SPECTFiUM . . :3** . . . INES NOT LISTED.IN LIBRARY

or. *FrED IN

SUMMARY

REPORT l 'l GS l Clhl PRODUCT J. ~-!S 1: m1A ll.lC:L I DE e:E:Hf~ HLIFE DECAY UCl /UNIT

~-l~H ERROR                XERR              XMIX FP                    a      04D                    1. 004           2. 021E -7              5. 772E -8             28. 56            100, 00 ACTIVITY FROM ISOTOPE GROUP= 2. 021E-07 UCI /UNIT iOTAL ACTIVITY= 2. 021E-07 UCI /UNIT TOTAL Flf:i~:ilON F'f~CIDUCT$ / TOTAL                                                   ACTlVATlOl,I F'l~ODUCT~::             11 Ut~l:l:lF'.lhlE:I:i 11

IIJCL rne -~ f'DENT r F I CAT I ON !:lY::>TEM ( !:lONG::l VEF1 8. O, EV87 > , *, .* *.*, *. ,. l~KNOWN*LINE REPORT

            ..  *,.                                .. _' :...,., .... ,. _._ *,; _,'.' .'i .:.:. *, ' . .:: ..::';;:. \*::\,~,~~~It .. li~i;;itJ;i<i\

PK IT ENERGY AREA B~:ONil FWHM CHANNEL L.EF~T PW CTS/::~EC 'Y.'EtRR*: *': : EFF 9Z. 01 1'~~( .t 4-. 4. 0, 1{:I ,U:\11,. .t 0 .t ~:l .1 9 4-. b5E-02 33. 4 l. 77E-02

  .( .       'il8, 41.lf 'Zl"f  . l:~.       4. o. 88           113/.'), Sl(I     11:~ J.              9 2. 72E-02 48. 0 1. 8LE-02

. INES NOT MEETING

SUMMARY

CRITERIA NONE

• l*.*. . r.:, .*

                                                      . .... *, -~i ....

1\*~I* ~* *k .;1, it* ,}I* ~!I* ;;t* ~* ~* ~*11* {I*;". {t* * .**') 11;:: ... ,l\1 P, f~ ..... };~t ~~: () }.:.1 : ,,* .1  : /.j, fi: *>\* ~:r +;}* il* ".*<* .:;1, ..~* .:,a- *U* *})*~**JI* *'A-*?.!* <;q, *U* ,.:J.

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • .-* ';:/::

U3 FlSH 08l8AH02 SAMPLE COLLECTION START DATE: 18-MAR-88 07:80:00 ~:AMPLJ:'. C:('.IL.L.EC:TJ ON EI\ID DATE .lf::1***1"11~,f:i'.***f~I~:: 07* ::::0: 00 SAMPLE IDENTIFICATION: 1061 1YPE OF SAMPLE: U2/3 H. P. !:)AIY!PI..I:: GlUAI\IT I TY: J. 000. 000 1.Jl'H T!:::: ML. PER CENT YIELD: 100. 00000 REACTOR#: 8 !:i?)MPLE OEOMl:~TflY: J.L LIO MAFHNEI..L.l: 01~:*EF::r-rroi:::::: l'.NJ'.TH1U:::- EFFICIENCY FILE NAME: .EFFE . MARlLE ACQUIRE DATE: 18-MAR-88 0 l;:I ; ~:l 6 : ,U;l -ll- Fl.JHM ( .l ~:,::12) : * .1. (~1(:,9 PRESET Tl'.ME(LIVEI:  ::300. !SEC i} ::>EI\I!:) l: TI V !TY: !5. 00(1 ELAPSED REAL TIME: ~:lOC>. t::EC

• SHAPE PARAMETER .t 0. 0 :1,:

ELAPSED LIVE TIME: :300. ::)t~C

• NBR ITERATIONS: J.O.

                                                                                                                          *k DETEC:TOf\:                             GEf~ME

• LlBRARY:NUCL . RXL.IQ CAL l:B DATE: l.l:?.***MAF\-*19:;; (1:8: J.O: !:W
• ENERGY TOLERANCE: J.. 500KV KEV/CHNL: 0. 4999856
• HALF LIFE RATIO. 8. 00 OFFSET: -0. 0874468 KEV
• ABUNDANCE Ll'.MIT: 75. 00~
  • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • ~***

ENERGY Wl:NDOW 24. *;)C:i TO 2(li~7. ';>(I Pl( IT E~lt:R(W AM:f-i E:ft:01\ID FWHI"\ t:Hr-il,11\IEI *. l..EF'T F'W C:T::::/~::E:C: ;;E:f~F: F':tT

l. (I ,:) *-~

                                    .. ..:... 21:3                      7.                                5.

i (l, 96, i. ::;::Lt. ~:,4 J __ ,,,

                                                                                                                                                                                    ,I I                   2(1 .L,    ,*,

47E:***(t2 !:i6. 4

     *'-        0             '..:1/.:,4*. 4:::1                       1El.                               Cl.                1. o::::         'l~{.'::"J. 06
                                                                                                                                                                                ....., ,*~, I I .,~*.,;.                .l .\ f .. OOE:*.. *O'.~ 2:::1. ,.;,'

PEAK SEARCH COMPLETED (REV 12)

TCITAL°'LL1~*~t; :*1N *'Sif EC:TRUM 1

                                      *:

• 2 LINE:3 :.NC)1\Lt.8TEP l:N LUJRAFW. J.

t DE:NT IF':t Et1 :c N ~iUMM{~f~Y REF'CIFff' .1

l. *-::) l'. Oi"'lf:1 I\IUC:L l DE~ f;;Bf-W-: HL. l FE Dt:.UW UCI /UNIT ERROR '.1,:EJ:F:  :,,;1*111 :x:

I***1.::l1 .FP 0. (14I) l. (1(1.lf 1. 688E -7 8. 9~7E -8 2:3.  !::,7 J, (1(1, (1(1 ACTIVITY FROM lSOTOPE GROUP= 1. b88E-07 UCI /UNIT TOTAL ACTIVITY= 1. 688E-07 LICI /UNIT

. *****~**~******** *. . :-i .**.. : ' 22-MAR-88 09:47:51

 ~*********************
       -~1     *          : ._ . . .;::) :: r. . *:;i . {\. <*******~f**
                                                                                    -..          *-ll*-1~********-ll********

JN Ii' 8 FI SH SAMPLE/0322AH05

 ~A              COLLECTION ~TART DATE: 22-MAR-88 09:30:00 SAMPLE COLLECTION END DATE                                                      22-MAR-88 09:30:00
 >AMPLE IDENTIFICATION:                                             1294 "YF'E OF SAMPLE : U:2/8 H. F'.

AMPLE QUANT I TY: 1000. 000 UN l TS: ML

• e:R CENT YI ELD : 11:,0, (1<)0C10 REACTOR #: ~:

 ~AMPLE GEOMETRY: 1L LIQ MARINELLI OPERATORS INITIA LS:-

tFFICIENCY FILE NAME: EFFD . MARlLD

 ,cQUIRE DATE:                    22-MAR-88                         09:42:27

• FWHM,t1832 ) :

 )RESET TIME<LIVE.):                                                300. SEC

• SENSfTIVIT Y: 5. OCH)

 ~LAPSED REAL TIME:                                                 800. * .:::EC

• SHAFE PARAMETER: 1 o. 0 :,,:

tLAPSED LIVE TlME: 300, SEC

• NBR ITERATIONS: 1(I, f***************~*********************************************

 )ET ECTOR: GERMD                                                                      ** LIBRARY:NUCL . RXLIQ

ALI B DATE: 22-MAR-E:8 OE:: ~:4: 1 7

• ENERGY TOLERANCE: 1.300KV

 '.EV /CHNL:                            0. 4.'r98750

• HALF LIFE RATIO: e. 00

 )FFSET:                                O. 2049477 KEV

• ABUNDANCE LIMIT: 75. 60%

F'f< IT EI\IERIJY

                                                                                                            ~\/._t_v-,..          i';ERR FIT
      !     (l    31.:,4. 36,                ~:-.s                        SA"'~       1~         u)A-S

85. 4

                                                                                                ~<\\.-\-     ~)I..>-~    (9\-
                                               +li.s                  \JV' 0 (" "~ " ~
                                                  +l.-                 \::,~l(e_ry-         +~A-t-        ~        dv.1r- ?,_..,\
                                                                                          ~~~s. ~       Jv.w--\>~(t_
                                                        '.-~ -+e>          +"-L.

JMMAR'i *oF NUCLIDE ACTIVITY PAGE . 1

• )Thl LINEB lN SPECTF<UM 1

NES NOT LISTED IN LIBRARY 0

 )p* .... .,.c:-IED IN 

SUMMARY

REF'ORT 1 1 (>(), ()(.I:'!,

!SION PRODUCT 1-SIGMA IC

Ll DE SBHR HLIFE DECAY UCI /UNIT ERROR

 *1:::: 1          FF'     E:. Cl4D 1. ()01      7. 15/.:.E -13           2. 5!'.::0E -E:
 ,CT IV I TY FROM ISOTOPE (.3ROUF'i:::: 7. 15'7E-08 UC I /UN IT TOTAL ACTIVITY : :.-: 7. 157E-C>8 UC:I /UNIT TOTAL FISSION F'RODUCT::3 / TOTAL ACTIVATION PRODUCT~:                            11 UNDIFINED 11

[ I

f ** MEMORANDUM FOR FILE April 5, 1988

SUBJECT:

Radioiodine in Fish Basket Waste, Part 2

REFERENCES:

1.

                         .. -      . to spos * *.

Accumulated at SONGS

                                               ~ u ..

dated May 16, 1986; e Materials

2. ITA E88-020 Radioiodine was detected in fish basket waste from San Onofre Unit 3 in mid-March. The source of the iodine was Unit 2 steam generator secondary water, contaminated by primary to secondary leakage, which was overboarded to the outfall to resolve abnormal chemistry. The benthic waste drawn back into the intakes of each Unit had very low, but detectable, levels of I-131. The purpose of this memorandum is to document the calculations*used to determine holding times for the waste, and to demonstrate that the final released product had no detectable activity, Given: A 1 liter Marinelli sample counted for the required 300 seconds (Reference) has an LLD for I-131 of SE-8 uCi/cc. Assume I-131 half life is 8 days.

Unit 3 Fish Basket collected 3/18/88 Act 1 = 2.0 E-6 uCi/cc Act 2 = 1.7 E-7 uCi/cc Act 3 = 7.2 E-8 uci/cc For the highest concentration: 2 E-7 =4 times 2x = 4 times 5 E-8 x = 2 half-lifes 2 half-lifes = 2 x 8 = 16 days Recommend: Hold material for 16 days, resample; if not detectable activity, release. Resample (release) data printouts will be attached as they are completed, 0388-29 cc:

APR oe1ses

                                                                                                        ,t I ~:,t!1t:*;
                                                                                                       !:;i. (1(10 I 0. 0 :1.:

l. (I,

• l'.IE2TE:CTClf~: mmME
• lM:t]:lf;:(!\f\Y*.*NUCL. . f~)'.L.1 (;\

'CALIB DATE: 06-0PR-88 09:22 :45

• ENERGY TOLE~ANCE: J.. 500kV KEV/CHNL: 0. 49994 38
• HALF LXF~ RATJO 8. 00 C)Fi= 1m1*r: *~O. J.40r:~:;)22 l<EV
• ABUNDANCE LIMIT: 75. 00%

 *********************************************~********~*******

l:tl\ll:tF~t:,y WJ: NDOW 2.ll. l:3i) TO  :;ioi17. 64 Pl( .l T ffWHl"I C:HAhlhlE'.L. l..E:F'T F'\~ C:T!:::/::::[~C  :,~E.rn,: F':f T J. (I c). (I, 1;)~~ '?(Ii[, (1~t ci'~i*i) J, J, *'o:! fi,',/, !:lOEt**,('.12 44. IMtl 2 .0 o. .t. (;i(;, ~~~i'~'() ~v~~ 1 ~~~j) :t ,::, .\.I ,~,. Cl Ott: **. 0 '.~*. 2f.[i,

                                                                                                                                                .(~

1:,,,

NUCL lpE 1DE.NT IF I C:{:\T lI: !SUt'

t Uhl (:;YEn"E:M (SG~GS VER 8, 0,

          \MAF~Y OF NUCL. I DE (..'\CT IV 1: TY                                 8/87 )
                                                                                                 * , ... l?AOE: . J.       '***' ..
,:: 'f'CITAL. Ll NE~:: . :t N ~::F'E'.C:TF.:UM 2

APR: o:;:e \988 L r.~ !:~ N()T L. J: ::n ED 1:1\1 L. ummN . 1

   . . ~rIFIED JN 

SUMMARY

REPORT ACTIVITY FROM ISOTOPE GROUP~ 0. QOOE-01 ucr /UNI T (Jl.s~ r~'; - SUB-STANDARD QUALITY BEST AVAILABLE COPY TCIT(~l.. AC:TlVJTY ,:: 0. OOOE***O.t UC:l /1.11\i:t f' ror AL. i:: i: ::>::> 1: ON p1:ioD1.JCT:s I TOTAL. ACT r VAT roN PFioDuc-r::> 11 Ul'IID IF J: NED ' 1

April 5, 1988

SUBJECT:

Contaminated Intake Structure Waste During the past two months, several hundred cubic feet of radioactively contaminated marine debris have been collected at all three SONGS Units. The source of the contamination is apparently steam generator secondary water which was contaminated by primary to secondary leakage, and then overboarded to allow refilling the generators in order to achieve proper chemistry. The radioiodine is taken up by marine life offshore and subsequently deposited in fish baskets. The presence of the radioiodine means that we cannot release the material to a landfill, but must hold it until the radioiodine decays to levels below the lower limit of detection. The purpose of this memorandum is to request the Operations add a note in the appropriate procedures (steam generator draining perhaps) to clean the rakes and screens, and change the fish baskets and dumpsters in advance of overboarding steam generator secondary water after tube leakage. This should minimize the level of contamination and may provide enough time for decay before the material is sampled for release. We understand there is no practical means to process the water, nor sufficient tank capacity to *hold it for decay. The benefits to be realized are:

1) reduction (or elimination) of dumpsters being held with marine debris; these dumpsters held in Parking Lot 1 are a health hazard as the material biologically decays, and 2)° minimization of the expense to Housekeeping for holding multiple dumpsters which are awaiting radioactive decay.

Please contact me if I can provide any further information of if you have an alternative approach to the p~oblem. *

                                ~gineering Supervisor cc:

SONGS HP INDIVIDUAL TASK ASSIGNMENT (ITA) A. ORIGINATOR: Complete this Section, individual assigning ITA is to complete Section B.

                                               ----- ---            2) Enter your next ITA number      b9-       'tj'-

3) Describe Tas k-~~~..~~~ , -*~?-ti ~~ :Jun,,~ ~stz"' ,4tJ ~~~-c.;..J r---

      ]) ~ XU 'C                                       ~.D:00            ~               ~ J:;.? ~ YYl1:JL)A. ..,~

E~ vEr-'-.{ T'f1Z' k /h t;;_-Q k Vl'"0 :l / 1.,y_j_.ff..,___ _ _ _ _ _ _ __

4) Describe what constitutes completi on~v.AL JA.~W / ')(.,<,'::fh( ~l:J-M (,) eh., SQ ,2..g -J22I;- I I '-1

5) List appropriate references

     --~e                     '?;?1rtm ~

6) Sign and Date B. ASSIGNOR(S): with this Sec ion is indicated by your signature or initials below.

1) All necessary documents are to be referenced and/or readily available and/or attached.

2) Prime assignor and assignee discuss t h i ~ _ e _ e e o onn Prime Due Date, assi~nor enters:

PRIME DUE DATE* of Assigned t o . . . . . . . _ B y - - - O n - V - i . 1 f . l t -

3) Subsequent assignor and assignee discuss and agree on Sub Due Date, assignor enters:

    .SUB DUE DATE* of                        Assigned

4) Assignor(s) gives original ITA to assignee and forwards a copy to TAC Coordinato r.

     *Prime Due Dates should be at least 5 calendar days beyond the date when task first assigned and Sub Due Dates must not be later than Prime Due Dates .

.C. DUE DATE EXTENTION REQUEST: This Section is not a substitute for the Prime Due Date in Section B which must be agreed to between assignor/as signee prior to establishme nt. Required exten-sions, initiated by assignee, are to be requested as far in advance of the pending due date(s) as possible whenever completion date problems are identified.

1) New SUB DUE DATE of____ _____ __ Requested By _________ ________On

2) New PRIME DUE DATE of _ _ _ _ _ _ _ _ _ _ _ _ Requested

3) Reas ori Why due date Cannot be me ------- ------- ------- ---***-- --*--a* ---*--

4) New SUB DUE DATE of _____ _____ ____ Approved By _____ ____on _______ _

5) New PRIME DUTE DATE o pproved By _____ _____ On _ _ _ _ __

6) Copy of ITA forwarded to TAC Coordinator D. TASK COMPLETION: To be completed by assignee and forwarded to originator.

1) Statement of completed action _ _ _ _ _ _ __

2) Date comple

3) Is a copy of completion document attached _ _ _ Yes (ACTION IS NOT COMPLETE WITHOUT THIS)

4) Sign a tu re of Assignee _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

5) Originator is to forward original ITA and supporting documentati on to TAC Coordinato r.

To TACC on - - - - - - - - - - - date, Distributio n: White~ Originator Canary & Pink - Assignee Goldenrod - TAC Coordinato r SCE so(u.Jl 197 REV. 0 11/';4/A,

SUMMARY

(CONT) Page 2 were quarantined and a 100% release survey policy was established there as well as creating an unofficial ad hoc committee within the health physics organization to deal with long term corrective actions. Additionally, detailed surveys were started in selected areas outside the PA in an effort to identify any other radioactive materials that may have been released. CHRONOLOGICAL DESCRIPTION While the releases can be associated with two distinct mechanisms, they can also be grouped into three distinct incidents. The first two incidents share a single root cause; the third incident had a seperate root cause. This report will discuss the description of the first two incidents, present their root cause and then discuss the third incident and its root cause. THE FIRST INCIDENT On March 15, 1989, while conducting a routine quarterly radiation survey, a health physics (HP) technician discovered radioactive material in several areas of the special tooling and rigging (STAR) yard. Attachment 1 to this report chronologica lly documents each item found. one of the items found on March 15 was located directly in front of the Unit 1 R/F cargo container and led the technicians performing the survey to suspect the contents of the cargo container. Subsequent surveys in the cargo container located a total of 15 items contaminated with levels equal to or greater than 100 ccpm/scan. These items averaged approximately 500 ccpm /scan with the highest recorded reading being 4,000 ccpm/scan as found on a scotch brite cleaning pad in the container. By March 19, the container and it's contents had been 100% surveyed. SEQUENCE OF EVENT OF THE FIRST INCIDENT On or about r. - Fluor refueling worker, ask d to ~ c o n t a i n e r from the backyard. looked in the container a ~ approximate y magenta colored items and told....... .,he did not have the resources to survey the container at that time. Those 5 magenta i oved from the container at that time. continued requesting release surveys for the next two days. loaned of

SEQUENCE OF EVENT OF THE FIRST INCIDENT (CONT) Page 3 . . . . . . . . . . . . began surveying the contents of the cargo ~ i l e it was located in the backyard RBZ. High background levels (200 to 300 cpm) in the backyard prevent ed......... .al from s u r v*eabout -

• two thirds of the c o n t a i n e r ~ u l t i n g with who consulted with the container was moved 1 e
• e RBZ for continued

   - .. - urveys in a low background area within the PA.

It should be noted here that the background issue will not be considered as a contributi ng cause. This is based on the fact that the container was moved to a low background area within the PA prior to it's release specifical ly to perform the release surveys. had been moved to complete), In retrospec t, and after the f i r s t ~ i n a t e d items were discovered in the container, 11111111111111states in

SEQUENCE OF EVENT OF THE FIRST INCIDENT (CONT) Page 4 attachmen t 5, "One problem I. an . identif

                                    . . .is that I didn't directly supervise as one familiar with our Rer                 olicies. He was assigned only to supplemen t our crew for this one task. once I drove him up to the Staryard, I immediatel y returned to the Plant. Apparently , he passed over these two items and I should have spot checked his work and supervised his techniq1tes_ . _My_

hit. 11 It should also be noted (attachmen t 4) that..-. ........ understood that he was to "spot check" items i n t ~ not perform a 100% comprehen sive survey. End of incident. THE SECOND INCIDENT On March 29, 1989, HP technician s performing surveys in the staryard to detect radioactiv e materials potentiall y released from the PA discovered 4 contaminat ed items located on a pallet that had been delivered as part of a truckload of "released" materials from the PA on March 27. Two of the items were marked as potentiall y radioactiv e with magenta paint. Additional surveys the next day located a contamina ted hydraulic motor lift that had been delivered on the same truck. SEQUENCE OF EVENTS OF THE SECOND INCIDENT A housekeepi ng flatbed trailer was staged just west of the Unit 3 turbine buildiing to recieve material cleared from the Unit 2/3 RBZ on or about March 24. The station was implementi ng a housekeepi ng campaign in preparatio n for an upcoming INPO inspection . HP's released materials from the Radwaste building roll up door area throughout the day Friday and through the weekend. These materials were loaded onto pallets and then transferre d around the building and placed on the flatbed trailer. There was a word of mouth policy that nothing was to be placed on the truck unless it had been cleared by the HP's. However, during backshift, and in fact, even during much of the dayshifts for Friday, Saturday and Sunday, the trailer was unattended . Opportunit y existed for materials to be placed on the trailer without the benefit of HP surveys. Monday morning, th_ _w trailer _ s ulled into the hold down area for release. released the trailer without further surv . s ed that (attachmen t 9) he recognized what he thought to be the materials the HP's had been releasing for the previous three days. He documented the release with his release stamp in the release log book (attachmen t 10). The trailer was driven to the staryard and offloaded Monday. The staryard HP technician s noticed a magenta colored tube light on top of one of the pallets Wednesday morning and

SEQUENCE OF EVENT OF THE SECOND INCIDENT (90NT) Page 5 began surveying the load. After finding a total of 4-ems in the load the HP's at the staryard were advised by

   .illlllllllllst aryard supervisor , that a hydraulic motor 11  a
   ~ s o arrived on the same truck should be checked. It too was found to be contaminat ed. By the end of the week, the rest of the load had been 100% surveyed and no additiona l radioactiv e materials were found. It should be noted that this investigat ion was unable to determine the origin of the hydraulic motor lift and that the discussion s associated with this incident do not address that item.

End of incident. ROOT CAUSE OF THE FIRST AND SECOND INCIDENT The root cause of the first and second incident was programat ic deficienci es in the release program. Programat ic deficienci es in the release procedure coupled with the excessive ammounts of materials requiring release at the conclusion of the outage compromise d the efficiency of the release program. DISCUSSION OF THE ROOT CAUSE S0123-VII -7.3.2, "Release of Potentiall y Contamina ted Items From the Restricted Area", is subject to interpreta tion and did not require many of the items released to be surveyed. The note to section 6.1.8.2.12 states, "It is not intended that every item released from the Restricted Area be surveyed. Operation al Health Physics has the responsib ility to evaluate each item to determine where it has been and what its potential may be for contamina tion." In accordance with this, the release crew attempted to identify "suspect" items located in the material being released. Those items were surveyed. Additiona lly, section 6.5.5 states, "Evaluate all items which may potentiall y be contaminat ed, radioactiv e, or contain radioactiv e material. However, every reasonable effort should be made to minimize the impact on the flow of materials through the Hold Down Area." By "evaluate" , it is assumed by the release personnel that they are to look for "suspect" items such as those marked with magenta paint or items believed to be contaminat ed for some other reason. In fact, given hindsite into this situation, all materials are suspect that have entered the PA. Yet, the procedure directs personnel to "evaluate" and base surveys on judgement. When these procedural deficienci es are coupled with the high volume of release surveys required at the end of major maintenanc e evolutions and/or clean up campaigns, the efficiency of the release surveys is challenged . In fact, this situation makes a zero release goal unachievab le.

Page 6 CONTRil3U'l1ING CAUSES FOR r.rHE F'IRST AND SIWOND !NDIDim1I 1 The followin g contribu ting causes increase d the liklihoo d that radioact ive material would have been released from the PA, It should be recogniz ed, however, that the solution s to the root causes are independ ent of these contribu ting causes. 1, (First and Second incident ) S0123-V II-7,3.2 states in part, (section 4.1) "Measure s should be employed when practica ble to minimize tools, material , vehicles , and equipmen t taken into the Restrict ed Area, and to prevent their contami nation." contrary to this requirem ent, the station has no formal policy to define the "margin of safety 11 required for the work groupfJ inventor ies and implemen t such complian ce.

2. ( F*lrst incident ) Misoommunioation between the release crew foreman, the HP teohnioi an on loan to tha release crew and the work group allowed the containe r to exit the PA without completi ng the release surveys.

once - a s s u m e d the containe r had been~ cleare he d proc~~ave t transfer red to the Mesa. contacte d to ask further directio n s o oontinui n re ease surveys. Based o n ~ statemen t in attachme nt 4, he consider ed ~ n acaepta le 'on to continua the surveys. It was not until told hi:m to survey it i.n place or at the west a. ha had clear instruct ion as where to survey the containe r. By the time

• returned to the area he had last seen the co a1ner, 1t ad been transfer red to the staryard . This fact placed an addit:i.on al time restrain t on the release surveys and is consider ed a contribu ting cause to the incident .

3. (First and Second incident ) There is no general attitude of segregat ing radioact ive material s within the PA amongst the work groups.

This is evidence d by the. fact that magenta material s were found in the cargo containe r in the first incident and the fact that, in all liklihoo d, the pallet containi ng the magenta tube light and other radioact ive material s was probably loaded onto the trailer in the secon incident without being surveyed . END 01<' DISCUSSI ON OF '!'HE FIRS'l1 AND SECOND INCIDIJ:N 1l 1

Page 7 CHRONOLOGICAL DESCRIPTION THE THIRD INCIDENT On April 4, 5 and 10, 1989, HP technicians performing surveys at the staryard to detect potentially released radioactive materials discovered 6 contaminated items associated with the refueling maintenance group. In addition to the fact that these items were found to be contaminated, it is also noteworthy to mention the fact that two of the items were contaminated with "hot particles". One, a reactor head stud rack, was found to have a FLEA reading 300 ccpm/scan on it, and the other, the transshipmen t impact limiter, was found to have a cobalt particle reading 1500 ccpm/scan on it. Attachment 1 contains additional radiological information on these items. Of the 6 items located, 5 were in or adjacent to the R/F warehouse. The sixth item was found on a pallet load of underwater camera equipment stored temporarily in the main staryard warehouse awaiting transfer to the R/F warehouse. SEQUENCE OF EVENTS OF THE THIRD INCIDENT During the time frame of the end of February and the beginning of March, 1989, transshipment completed and the refueling group completed refueling evolutions in the Unit 1 containment. In the traditional manner, a massive offload of containment and associated transshipment and refueling areas commenced. This investigation has not been able to determine the exact dates and times of the transfers associated with the array of contaminated refueling/tran sshipment items found in the staryard. It can be concluded however, that these items were released during the offload, and probably very near the third or fourth week of February. This conclusion can be drawn from the fact that the individual items identified are normally in use during refueling and transshipment activities. Additionally, attachment 12 indicates that the transfer of the impact limiter probably was released and documented on 2/27/89. No details in any of the release logs identify who released the other refueling equipment. These materials sat at the staryard for about a month until they were surveyed by the staryard HP technicians. The reason the staryard HP technicians surveyed these items is because they were directed to survey suspicious items by their supervision. As of April 12, 1989, about 75% of the refueling groups materials have been surveyed and no additional items have been found to be contaminated. End of incident.

ROOT CAUSE OF THE THIRD INCIDENT Page 8 The root cause of the third incident, the release of contaminated refueling equipment, is the failure to adequately survey the materials. THE CONTRIBUTING CAUSES INCLUDE THE FOLLOWING: 1, Inadequate attention to detail in performing release surveys resulted in the release of small, undetected areas of contamination on large components. The impact limiter, for example, has approximately 3.1 E5 cm2 of surface area. One area approximately 4 in2 was found to have 500 ccpm/scan fixed contamination . Also, a 1500 ccpm/scan cobalt particle was found on one area less than 1 cm2.

2. Excessive materials are brought into the PA to support work evolutions.

Photographs in attachment 3 show a box containing over 100 cam-lock fittings, most of which are new and remain unused. However, a 100% survey of each cam-lock revealed one to have 300 ccpm/scan fixed contamination . As stated previously in the contributing cause section of the first two incidents in this report, no active program exists to define acceptable "margins of safety" associated with work group inventories brought in the PA to support work evolutions. And, as mentioned earlier, that is in violation of section 4.1 of S0123-VII-7.3 .2. END OF DISCUSSION OF THE THIRD INCIDENT

Page 9 CONCLUSIONS While the failure to perform an adequate release survey was noted as the root cause of the third incident, it is recognized that the third incident represents a single, correctable incident. However, the root cause of the first two incidents are programatic and compromise the entire release program. It is assumed that the problem of inadequate surveys will also be minimized, if not corrected by resolving the programatic deficiencies associated with the program. The two components of the programatic deficiencies are:

1. Health Physics procedure S0123-VII-7.3 .2 allows materials to be released from the protected area without being surveyed.

AND

2. The ammount of material requiring release surveys to exit the PA are excessive.

Additionally, there are several contributing causes that are incident specific. These do not necessarily indicate programatic deficiencies. However, the correction of the incident specific deficiencies without the correction of the aforementione d programatic deficiencies is viewed inadequate to attain a zero-release status of radioactive material from the PA. The incident specific contributing causes are:

1. Miscommunica tion between work groups (in the second incident).

2. Failure of the station to comply with procedures requiring the minimization of materials brought into the PA (in the first and second incident).

3. Inadequate attention to detail when performing surveys (in the third incident).

4. The lack of a general feeling of resposibility on the part of the station work groups to segregate radioactive materials (the first and second incident).

In conclusion, certain programatic station wide problems as well as programatic release program deficiencies resulted in the inadvertent release of radioactive materials from the PA. Additionally, inadequate surveys and the aforementione d contributing causes escalated the potential of inadvertent releases from the PA. The corrective actions discussed later is this report attempt to address the programatic problems.

Page 10 CORREC'I1IVE ACTIONS IMMEDIATE CORRECTIVE ACTIONS As mentioned earlier in this report, the station took several immediate corrective actions upon the identificatio n of the inadvertant releases of radioactive materials from the PA. Initial corrective actions were as follows: Upon the initial discovery of the materials associated with the staryard general areas and the Unit 1 R/F cargo container:

1. HP assigned technicians to complete a 100% survey in the cargo container.

2, HP Supervision made a walk down of the staryard area and directed HP technicians to survey identified "suspect" items in the staryard. Upon the discovery of the contaminated items from the PA shipment of March 27, corporate QA issued a "stop work" order to the station manager regarding the release of materials from the PA and the staryard. In response to that order the station implemented the following corrective actions:

1. Implementatio n of a QA/HP exemption list including a 100%

survey policy for materials being released from the PA via that list.

2. Implementatio n of a 100% survey policy for materials being released from the staryard area.

3. Continued the "suspect" item search for radioactive materials in the staryard.

4. HP formed an ad hoc committee to begin resolving the long term implications of this problem.

Upon the discovery (by a QA inspector) of additional radioactive materials in the Material and Equipment Sales yard on the Mesa, The station implemented the following corrective actions:

1. Established a policy, including a management sponsor Ul(h Ill

  ....alll    to have HP survey all materials released from   e Tn't'i're"Mesa.

2. HP staffed an office at the Mesa, established supervisory contacts and began offering the service of release surveys for all the work groups associated with the mesa.

3. HP continued the "suspect" item search for radioactive materials within the staryard.

This concludes the discussion on immediate corrective actions.

Page 11 LONG TERM CORRECTIVE ACTIONS The long term corrective actions require action the part of the station as a whole, No single division can solve the programat ic problems identified within this report. It is with that assumption that the following recommend ations are made:

1. Revise HP release procedures to ensure that radioactiv e materials are surveyed prior to being released from the PA.

Given the current state of affairs, it is assumed that this would require 100% surveys of all materials exiting the PA until such time as it can be proven that contamina ted material does not exist outside the RBZ yet inside the PA.

2. Decrease the ammount of material requiring release surveys from the protected area.

As directed by S0123-VII -7,3.2, section 4.1, "Measures should be employed when practicabl e to minimize *** ". This would require a commitment from station managemen t to formalize a system that identifies inventorie s required to perform planned work in the PA. This system should include performanc e monitoring to ensure compliance . Additiona lly, provisions should be made (such as procedura lly required) such that in the event the work process makes it impractica l to survey materials, HP maintains positive control over such materials until such time as a survey is practical.

3. Include an upgraded lesson into training programs that would educate all workers in the PA as to the requiremen ts of the release program. This should be reinforced by providing performanc e monitoring for compliance .

In short, if zero tolerance is expected from the release program, all contaminat ed materials must be surveyed prior to their release from the PA. This investigat ion has proven that "evaluatio ns" do not work. One cannot tell if something is contaminat ed by looking at it. The only thing that will result in zero release is (a) survey everthing that is released, or (b) maintain control (ie don't release everything ).

                                                                                    ~-rr i This report contains a list of contaminated items found outside the Protected Area as well as the radiological information associated with each item. The area contaminated is:based on information from the individuals surveying
~he material, personal observation or estimated where noted. The frisker

iadings are as reported through various E-mail communications, personal observation and interviews with personnel performing the surveys. The total microcuries is calculated based on a 10% efficiency and a 15 cm2 surface area for a frisker probe. The dose rate is calculated at a depth of 1000 mg/cm2.

__ __ The isotopic distribution is based on a single GeLI report that is assumed to be representative for all of the materials. The reportability is based on the requirements specified in 10CFR20 paragraph 20,405, subparagraph (v). FRISKER ITEM DESCRIPTION READING DOSE REPORTABLE/ DATE (AREA) I ( SMEARABLE) RATE LOCATION CODE*

1. Metal sling. 400-500 ccpm <O .1 mr/hr N0/*1 3/15 (8 in2) 2, Greasy nylon sling. 800 ocpm 3.6 E-3 II II N0/*2 3/15 (10 cm2)

3. Roll of tape. 200-300 ccpm 4.8 E-3 II II N0/*2 3/15 (10 in2)

4. Roll of tape. 300 ccpm 4.1 E-3 II If N0/*3 3/16 ( 8 in2)

5. Wire drill attchmnt 200. ccpm II II N0/*3

  /16     (10 in2)

6. Tool box. 200 ccpm 2.4 E-3 II II N0/*3 3/17 ( 40 cm2)

7. 2(ea) 25 ft. 2 11 hoses. 300 ccpm 1. 4 E72 II ti N0/*3 3/17 (150 cm2)

8. One bull horn. 100 ccpm 4.5 E-4 If II N0/*3 3/17 (10 cm2)

9. Several scotch Brite 400p ccpm 2.1 E-1 II II N0/*3 3/17 Pads. (10 cm2) @ 4000 ccpm (max)

(338 cm2) @ 1000 ccpm (1500 9m2) @ 200 ccpm

10. Bag of 20 nuts/bolts. 300 ccpm 5.8 E-3 II II N0/*3 3/17 (65 cm2)

11. Bag of 12 nuts/bolts. 600 ccpm 1. 2 E-2 II II N0/*3 3/17 (65 cm2, estimated)

12. One pair channel locks. 100 ccpm 4.5 E-4 II II N0/*3 3/17 (13 cm2)

13. One FME notebook. 400 ccpm 1. 8 E-3 II II N0/*3

 ..J/17    ( 2 cm2)

14. One pulley wheel assy. 1000 ccpm 4.5 E-2 II II N0/*4 3/17 (10 cm2)

15. Roll of tape. 100 ccpm J.. 9 E-3 II II N0/*4 3/18 (10 in2 estimated)

 .6. Bag of bolts.                 300 ccpm   1.4 E-3     11    II N0/*3 3/18   (13 cm2)               (2,000 dpm/masslin)

II

17. Bag of bolts. 100 ccpm 7.7 E-4 II N0/*3 3/18 (26 cm2)

II

18. Bag of bolts. 500.ccpm 3.8 E-3 II N0/*3 3/18 (26 cm2} (2,000 dpm/masslin)

19. Punch. 150 ccpm 6.8 E-4 II II N0/*3 3/19 ( 2 cm2)

20. Three bolts (decon Not Avail 1. 3 E-2 II II N0/*3 3/19 masslin 16 in2) (4,000 dpm smearable)

II

21. Battery Charger 200 ccpm 1. 8 E-3 II N0/*4 3/20 ( four in2)

22. synflex hose 400 ccpm 1.8 E-3 II 11 N0/*4 3/21 (13 cm2)

23. Nylon sling. 150 ccpm 1.5 E-3 II II N0/*1 3/22 ( 3 3 cm2)

24. Nylon sling. 100 ccpm 1.4 E-3 11 II N0/*1

 /23   (45 cm2)

I

25. Vacuum cleaner 200 ccpm 9.8 E-1 II II N0/*2 3/27 (See note 1) I

26. Gland seal gasket. 100 ccpm 3.0 E-3 II 11 N0/*5 3/28 (100 cm2}

27, Old REMS box. 200 ccpm 1.5 E-3 II II N0/*2 3/28 (25 cm2)

28. Gland seal gasket. 150 ccpm 4.5 E-3 II II N0/*5 3/28 (100 cm2)

29. Gland seal gasket. 300 ccpm 9.0 E-3 II 11 N0/*5 3/28 (100 cm2)

30. Tube light. 1200 ccpm 6.9 E-2 II II N0/*6 3/29 (26 cm2) @ 1200 ccpm (max)

(936 cm2) @ 200 ccpm (26 cm2) @ 500 ccpm ... removable on masslin

31. Welding* '

whip. 1 I 200 ccpm 1. 8 E-3 II II N0/*6 3/29 ( 3 O cm2)

32. Work glove. 100 ccpm 4.5 E-4 II II N0/*6

  /29   (15 cm2)

33. Work glove. 100 ccpm 4.5 E-4 II II N0/*6 3/29 (100 cm2)

SONGS HP INDIVIDUAL TASK ASSIGNMENT (!TA) A. ORIGINATOR: Complete this Sectio n, indivi dual assign ing !TA is to complete Sectio n B. l) Name (Prin t)~~

• J - - - - - - - 2) Enter your next !TA numbe r c~S ,. . . (ip l 3 ) Des c r i be Ta s k 1? t::,<lF0lri*L ,..:\A -~ /..,d .A) QJ t-:-lJ &J 11-Ut.JJ:) :)S>

7-ak YNC

                            ~d(       VA: Cc        (VJ    ft:T C:;.Yl ::z:-A'{ ..::~

4) Describe what const itutes completion~_r"rt;:;...c.~*~(S=*~~(\~~~;,,,__~

(~s Gtf' ~!fJ?.JJ Pm- M** 4

                                                                                                                            .I 0'..:".:hJ 'ftR!A-;

B. ASSIGNOR(S): is indica ted by your signat ure or initia ls below.

1) All necess ary documents are to be refere nced and/or readil y availa ble and/or attach ed,

2) Prime assign or and assign ee discus s this !TA and agree on Prim ~te , assign or e~1jers:

• PRIME DUE DATE* of ";)11/ft.1 Assigned t o - - - - B y ~ O n

3) Subsequent assign or';nd assign ee discus s and agree on Sub Due Date, assign or enters :

                                                                                                                              <f/¥'

SUB DUE DATE* of Assigned to By On ~-- ---

4) Assig nor(s) gives origin al ITA to assign ee and forwar ds a copy to TAC Coord inator .

       *Prime Due Dates should be at least 5 calend ar days beyond and Sub Due Dates must not be later than Prime Due Dates. the date when task first assign ed C. DUE DATE EXTENTION REQUEST: This Sectio n is not a subst itute for the Prime Due Date in Sectio n B which must be agreed to between assign or/ass ignee prior to establ ishme nt. Required exten-sions, initia ted by assign ee, are to be reques ted as far in advance of the pending due date(s )

as possib le whenever completion date problems are identi fied.

1) New SUB DUE DATE of _ _ _ _ _ _ _ _ _ _ _ _ _ Reque sted By _ _ _ _ _ _ _ _ _ On _ _ _ _ __

2) New PRIME DUE DATE of Requested By On _ _ _ __

3) Reason why due date cannot be m e t - - - - - - -

                                                                                         ---------------~-----

4) New SUB DUE DATE of _ _ _ _ _ _ _ _ _ _ _ _~Appr oved By_ ~-- ---- ~O n

5) New PRIME DUTE DATE of Approved By On _ _ _ __

6) Copy of ITA forwarded to TAC Coord inator By D. TASK COMPLETION: To be completed by assign ee and forwarded to origin ator.

1) Statement of completed a c t i o n - - - - - - - -

                                                                                      ------~--~--------~--~

2) Date completed ___ ___ ___ ___ ___ ___

3) ls a copy of compl etion document attach ed _ _ _ Yes (ACTION IS NOT COMPLETE WITHOUT THIS)

4) Signat ure of A s s i g n e e . - - - - - - - - -

5) Origin ator is to forward origin al !TA and suppo rting documentation to TAC Coord inator .

To TACC on _ _ _ _ _ _ _ _ _ _ _ _ _ _ date, By ___ Distri bution : White - Origin ator Canary & Pink - Assignee .s(:E so(1Z3) 117 REV, 0 11/%4/02 Goldenrod - TAC Coord inator

__ ., ... _....... __ ,_,,,.. ..,_ .......-. . . . _._, ... ---, ............ .... ... _.... __ .....-- ........ _,_ ............ ~::. ...~~- ..............._._

-:'....._)j'f.: _ ... 1.:) .u.., S.~ ..6'-4..t .... /:7-M.A-J'...,. *~-~.0~ ..... ~.... ~~~.-~ ~-r\

                 .~AL ::JV\ I.A:;___ .... ..-'11\ ~ ~YL_ .0'.r"ld -- .
                   . . --*--~--. ~ N.'J:C. . __ . . Cf Lt ~Tz-'1Ct::-,'1...... (~ ..'3 htU:'~.- . /Y.v.~] __. *-* . -...... :.*.
                       . . .~~-l-t. ~--o _. . .~. _o:._~ ': _. .~6. 4R. v:. ~1 _J:-Y.J. ). 4.-:i ~~ G-o ...
------* -*-**---=---~:b- . .~.~~-l) :J t5 ______ rY.l r:--:>~ _)t_rfd ...                                                        ~ ......... J:4 &J!c:.'?~....... ~-:!:.l:bc~.M~L,,..,J. .
......... . -* . - - - *---*-*** --* WJ~~-~.m ~- . ....~.:idJ~C.Y l. .... s.~a,-\)1'..{t.                                                                         **-* *-*-         ... *--*-*-- -* ..... _...
                                                                    )  .

Tc:., t.- t,fw r M (,...,i,_J .

                                                                                                                                                                                                       *--"(,.. ,....~.- ...
                         -_ .D_~v"}"t W<£: ...~~ .

....-............-----*-* .... ~_.A-Jt:::,V\. (\.yl<f, ...... '.. . ****-" ...... . I __ .................... *- . . . . **-*------~- . --2 ~'(:\'_)(.:.~rir:'_ ....CQ. .g.:T"°.......:. . __..:T._~_\$...-~~J:9...___ ,_(h~'1?..~Yk~ . r.!.).~1c:_...

  . .. __ . _ . *- .                                     .. t y ~ . .l(v. tYl.--~..... \i"? sv.:1t:1ZZ:-4 -~                                                                                               ......... .
 -**** *-**--- --*- ---*_.  ,- ........ --~IC..C:
                                                  .   .   .. l A~ _vc                ... ~~ ......G. i-\v."IP_~ vr-                                  ('r') i4-)""t,),z.
                                                                                                                                                    .............              "/,H<!.... -;--.*--
                                                                                                                                                                   .... Lv. ,~ .._I..':<           JU*---- **-*********
                                                                                                          \
 .-- -*-.' - - -........... ~ ~ .. ~ A LU.t). Vb'O *-* ~* x:v Q...L-t.~ .o C. ' ~ ' (~~ O.~:~~ ..

I JV OTC'" .S. t.y.~*.u-:(~~r;~ . 1)}~1... ~Y.r.:!'. L-.J ..~J ' f ~Jl-,1? ... 0

                                      .*... 0.XJ ~w .... r~. .J . ... . ~_c . _-~~

• 1{[-::_ ..... ~'-(] c;-. _ --~.

                                                    ,.S I) L->o!. v-r k                .)1/1 . ~ ~ . i"vi~ L..J ...

at WEST4 4/10/89 9:07AM (5876 bytes: 98 ln) To: cc: - 8 bjec . anhour E s t i ~ a s e Salvage Material at the Mesa 11

   *---------- ---------.: ..-------- .Message Contents ----------~ -:--------- ----------- -

rn t 'th - Warehouse Supervisor , and - S a ~ o n Monday to evaluate the resources uld be required to release the salvage material which

           -       is   presently under the control of the Warehouse.

Three specific areas were defined in order of release priority: 1) Warehouse Salvage Area, 2) M & E Sales Area, and 3) the Scrap Steel Salvage Area. Each of the areas are discussed below:

1. Warehouse Salvage Area:

This material is located inside the Warehouse and consists primarily of material which was issued by the warehouse to the Site then was returned either unused, partially used, or to a lesser degree as used material. No accountab ility exists as to whether this material actually entered the Protected Area or was co-mingled with material which had entered the Protected Area. This salvage area has the highest prioriy for release since it has already been sold and because it is occuping space inside the Warehouse which has been allegated for additional material corning to the Warehouse. This material consists of approxima tely 105 pallets of various types of filters and three rows of miscellane ous electrical parts, insulation , plastic PC's, valve fittings, motors, instrurnen tion, etc. It is estimated that approxima tely 90 pallets of material are contained in these three rows. Eighty to ninety percent of the filters appear unopened. Possibly 30 percent of the remaining material has not been opened. This unopened material should be releasable after externally frisking their containers . The remaining material will require individual hand frisking.

2. M & E Sales Salvage Area:

This material consists primarily of Project related surplus material. The quantity of material in this outside sto~age area is similar to that at the Staryard. This material contains large amounts of cabling, valves, pump parts, steel ,etc. Since no accountab ility exists on this material, 100 percent of it will need to be surveyed. This area has the second highest priority since bids have already been solicited for this material. The cabling material survey can be expediated by pulling the cabling past a fixed bank of stationary friskers. The remaining material will need to be individua lly frisked. Labor support is essential in this area due to the size and weight of many of these items.

3. Scrap Steel Salvage Area:

This area contains 300 tons of material. The quantity of material is probably over four times that which is in the M & E Sales Area. This material consists of radwaste drums, the old makeup demineral izer, large numbers of surplus furniture, old radwaste liners and storage casks, old security shacks and entry point buildings, and large amounts of scrap steel. Much of this material is very bulky and heavy. Whether any accoutabi lity of this material exists is unknown at this time. Ideally, the release of the deminerali zer was documented . If not, then 100 percent survey of this material is required. At times very extensive labor support for this area will be required because of the size of some of this material. This labor support will require crane support at various times. The estimated manhours for release of these t estimated below based on conversati ons with examinatio n of manpower required in the 1983 Area Estimated Manhours Health Physics Laborers

1. Warehouse Salvage 250 100

2. E & C Sales Salvage 1200 600

3. Scrap Steel Salvage 4000 2000 Total: 5450 2700 Using a labor cost of $1200/week for a HP Technician and

$26.02 for a Bechtel Laborer results in a total cost for releasing the salvage material of $233,754. This was based on no overtime and no additional cost for forklift or crane support. The cost for each area is summarized below: Area Estimated cost ( $) HP Laborers Total

1. Warehouse Salvage 7,500 2,602 10,102

2. E & c Salvage 36,000 15,612 51,612

3. Scrap steel 120,000 52,040 172,040

SONGS HP INDIVIDUAL T~SK ASSIGNMENT (!TA) A. ORIGINATOR: this Section, individual assigning !TA is to complete Section B. l) Name (Print) '-------- 2) Enter your next !TA number E ?J -~ ~31

3) Des c r i be Task [) O C ,.~. ~-n ,1,,_.,_;._ _~t~v'~~--~+_J~J~.j__._+~. "'1"-l.,,~_ _h_t>_*~!~_(_;-"j+--lf.,_('_*____

( Q /@ f.( S ~ J L,/ . .*. , + "<~ ~r ;* 5 L. b Q .$ h: r;,. + .~~~*H=. ~+-*'_,_______ fA_~

                        ----~('~*=o_;_"--*~+-*=U..,_._Yh..~,.,,_._ _....,1=J/~,-~I._ ll         vi ; ".\ *'t *

4) Describe what constitutes comp1etion ___~-~l'--1_~t~ . ~~~~"=Q_ _,._(._~-~~r__._~_:_,~)~_**--~'-~1!~1,..__,.f_..Lb.~*-----

6) Sign and Date _ _ _ _. . . . .

B. ASSIGNOR(S): Compliance with this Section is indicated by your signature or initials below.

1) All necessary documents are to be referenced and/or readily available and/or attached.

2) Prime assignor and :*SSig ee discuss t h i ~ P r i , ~ i g n o r e-~Jters/:'

PRIME DUE DATE* of b JO 91) Assigned t o - - B y - - - - - O n 5,_i 1,_l'fr,1

3) Subsequent assignor and assignee discuss and agree on Sub Due Date, assignor enters:

SUB DUE DATE* of Assigned to BY On _ _ _ _ __

4) Assignor(s) gives 6riginal !TA to assignee and forwards a copy .to TAC Coordinator.

                        *Prime Due Dates should be at least 5 caleridar days beyond the date when task first assigned and Sub Due Dates must not be later than Prime Due Dates.

/~-. ! C. DUE DATE EXTENTION REQUEST: This Section is not a substitute for the Prime Due Date in Section B which must be agreed to between assignor/assig nee prior to est~blishment . RequiPed exten-sions, iritiated by assignee, are to be requested as far in advance of the pending due date(s) as possible whenever completion date problems are identified.

1) New SUB DUE DATE of _ _ _~--~---~ --Reques ted By _ _ _ _ _ _ _ _ _On _ _ _ _~-

2) New PRIME DUE DATE of Requested By ~n~--~~

3) Reason why due date cannot be m e t - - - - - - - - - - - - - ~ - - - - - ~ ~ - ~ - - - ~ *

4) New SUB DUE DATE of Approved By

5) New PRIME DUTE DATE of _______ ______Approved By_ _ _ _ _ _ _ _ _ _On _ _ _ _ __

6) Copy of !TA forwarded to TAC Coordinator By D. TASK COMPLETION: To be completed by assignee and forwarded to originator.

1) st,te,e,t of coa,pleted a c t i , O _ ~ t i , c C'(O*W i~- ---

2) Date completed

( ..........4;

               .,:*     3)    Is a copy of completion

4) Signature of Assignee ACTION IS NOT COMPLETE WITHOUT THIS)

5) Ori gi na tor is to fo rwa documentation to TAC Coordinator.

To TACC on

                                                              ~
                                                               $  I
                                                                    /u;_fe-v~ - - - - - date,                  By Distribution:               White - Originator                 Canary & Pink - Assignee                  Goldenrod - TAC Coordinator
                    ~CE RC'lfl?'.l\ IQ'1 ~s:t\f n It Julr,,-,

MEMORANDUM FOR FILE May 23, 1990

SUBJECT:

Radioiodine in Fish Basket Waste

REFERENCE:

Memorandum for File, Radioiodine in Fish Basket Waste, dated 3/10/88 Radioiodine was detected in the Unit 1 and 2 fish basket waste in May 1990. The source of the iodine was most likely steam generator secondary water, contaminated by primary to secondary leakage which was discharged to the outfall. The benthic waste drawn into the Unit intakes had very low, but . detectable, levels of Iodine-131. This memorandum documents the calculations used to determine the holding times for this waste and to demonstrate the released waste had no detectable activity. Given a 1 liter marinelli sample counted for 300 seconds has a critical level of 2.5E-8 µCi/cc (Reference) and the fish basket waste has an activity of l.3E-7 µCi/cc, l.6E-7 µCi/cc and 3.9E-7 µCi/cc (attached}, the calculated decay times are:

1) Unit 2 .693 (t) 8 days 2.5E-8 µCi/cc= 1,3E-7 µCi/cc e-t= 19 days

2) Un it 2 . 693 (t) 8 days 2.5E-8 µCi/cc= l.6E-7 µCi/cc e*

t = 22 days

3) Unit 1 . 693 (t) 8 days 2.5E-8 µCi/cc= 3.9E-7 µCi/cc e*

t = 32 days

MEMOR~NDUM FOR FILE May 23, 1990 Therefore, the recommended times to hold the fish basket waste on site to allow for decay to non-detectable activity levels is 19, 22 and 32 days. After these time periods, the fish basket waste should be re-sampled and counted on the Ge detector. The*results should be forwarded to HP Engineering for final review before shipment off site.

                          ~*******************************************************

i~~~l\~~~uB~~~ H' r*~ ~  ;,., tt.,.,n Y., ** ;r; ~ K "j7-~j~')'-00

                                                                                            ,       I' 1'"1        ,* ..           jl.j,,~/.j,,?b
                                                                                                                                    ,        , *,.,      ,    ,Im '"                          *********,**~**~**~

• lHh..

                          ~*******************************************************

17 TW 04 U2 FISH (:\*.*. ~:..,

                                                                                                                                                                                                                                          .1-~**

flf/'~ ~ r)/"' J, ",*, .... 1~*.11~,,.1 ..... ,*. ,**c*"i 1 'I ("J!"l *1 <?,, '.:\ . , ..,~1,* * . {) . ,:::*/,...~,-., 1::

• 1***1**11 l 1:::*1***"1" 3* 1**1~1.I *~:**1* r,,,,1:*,*1* )"'IA, *1*t~ *

'*,or( l"""" **'** ** '"""" ,..,I '**' l'"I \ " f.*,

(.. ), .. L.1::1 CCIL.1.. . 1:~C::T :t 01\I tIND !)(..~TE :

(.~ MF'L. Ei J: DI~:: I\I TJ:F IC:: r,Yl"J: Cl!\J :

I' I '

                                                                                                                               .l 7 . **l"lf..Y'f . ~':i1(l .t 4: Ou: ou
                                                                                                                                                                           ,..,,; ~ :: ; '.::~

1 1") *,

                                                                                                                                                                                                               '*'./',>"*".,°,;, . ,. , ~ ...
                                                                                                                                                                                                                       * * .*.! :.: <)                                                                                                                                                                                                                                                   "'
                                                                                                                                                                                                                                                               ~   \J .      ~

TYPE OF !;;:/.!1Mr-::*L.E :

(-'.)11*1PLri.'. G:!Uf.iNT J: TY:

1.:.12/::::1 H. F'. J. 000. 000 2 :J:l .1. b I.JN J: T::::: ML.

                                                                                                                                                                                                                                      \ ?:::>>;,.,
                                                                                                                                                                                                                                               .. ,.< <<,1,
                                                                                                                                                                                                                                                                       .       C       \Q ~
                                                                                                                                                                                                                                                                                         \; .

r,:*r::::r,:~ C:El\l"f' Y :r EL.1:1 : .t 00. 00000 F~l:~P1CTOR :n,"?'r O , (:,)"<'/); . . * .*. !,..1ri 1v11:::,L*...... 1::

• 1*:*c::n1v11::

H,lr111, .. , ""..1*1:*,\.1

                                                          \ l .*             L I J' 1:*1 1*.t1(.,1::*,
                                                                          *!.........       ul,               J' 1*"'.-1! 1~~*
                                                                                                     '11"'1 \ .                t I,....,.,. !"'...11:::,r:::1:*,~
                                                                                                                           .......                             Not ~t*11 '1'1"'...11::*\,,,.i                        {.~l,......,::*,.* * ..'.¢,.
                                                                                                                                                                                        ..::* J'. 1,1',I,1"'1'"1',,l"'I                                        r J,i.

c::*1::*1:::* t,,

              '[I'"*'[ c::*1,11*'*\/ r.:~
              ,. ,.,, , I,, ' ,.., \           I' ,.        t., l\l~~l"lf.::*.
                                                    *1* 1"" i:~       l"I     ,., ,

F.=*r::*1::*1*1 l"l(,'~I:", 11 I"I

                                                                                                                                'I '\,. "" "                                                                                                                                           .

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • ,)I, l~CG!I..J:t i::m: D(..fl"E: .t 7 ...,l"lf.W . **':i)(I .1.4:27:83
• FWHM(1882) :

                                                                                                                                                                                                                                           .t. '::17::::i F'RESET TIME<LIVE):                                                                             ::::00.          ::::EC:                    *l!*     i:::l::.N::::ITIVITY:                                                                :::1. f;:iOO EU~P:;;:;f::;1)                   r::ErnL. T :t ME:                                             800. SEC

• SHAPE PARAMETER: .to. o :1.:

ELAPSED LIVE TIME: 800. SEC

• NBR ITERATIONS: .t Cl.

                                                                                                                                            *)[*

DETE~C:"l"OF~: OEL.:c:c, *l!* L. :c Eln/',\l:~v: NUCL. . I.... :r G!U :r D CAL.:m DM"I:::.: J.'? .... l'*'IAY***90 0'7: :J::i:,: .1.0

• ENERGY TOLERANCE: J.. 500kV KEV/CHI\IL.: 0, 499927'6
• HALF LIFE RATIO: 8. 00 c:11:::F::::ET: ***O. l J. J. .ti..1. :1::..:1. l<EV
• ABUNDANCE LJ:MIT: 50. 00%

24. 88 TO 2047. 39 FWHM CHANNEL. LEFT PW CTS/SEC %ERR F:rT

          .l.         (l.             ,1:,2. '70                                                              .t:;;~o .

7.t. L 2r::; .t ::~: ~~,. *::> l.j. .t 1.1. 2. ::::: .::, E.... 0 .1 .t ,:::,. "i'

                                                                                  .1. 0.                                  0.                      1. 7!::i                :~::4:,:~::I J. C)                                          28 3. 88E-02 8.1.. 6 J.4.                                                           0. 7::::                 4 '7,(:;,, ::~11                  47.t                      .1. 2 4. 6'71::'.-*. 0::::'. 40. 4
                                                                                  .1.?::i.                                0.                      .1.' ()!:;i             '7::;:::~l. 4 '7                  72.ll,                        *~) !~:i. 001::::---0 :~! 2 !;::i. l:::l PEAK SEARCH COMPLETED CV2. 0 CSONGS 1/89J)

              !E JDENJIFICATION SYSTEM (SONGS VER 8. 0, 8/87)
              ~    OF ~U8L!DE ACTIVITY TOTAL LINES IN 8PECTRU1 1\11.JCL :Cm:'.       ::~;E:HI:~     HL. :r. Fl:~:  tll::::Cf.~V UCI /UNIT I-, 1 :::::.1,           FP          ::::, 04D                                                   :~~M:CX J.. 002     J.. :;t94E ***7             J. 00.  ()(l ACTIVITY FROM ISOTOPE bROUP* 1. 294E- 07 UCI /UNIT

• TOTAL ACTIVITY= 1. 294E-07 UCI /UNIT

( c. ,t_

                }:.,.\ 'h I
                                                                                ,,, ' v(

/.... 6" ~ A '**U

                                                                                ~~d 1,.,**.,:,

  ,                                                                                                                                                                                                                                                                                                                           ~             f5' -c;,o

~* \,/,!/ *~f ~~ *I~~* **\rf., ** *~: *1} *\.:;' *?} *~:' *t*.;< *%* *\7.l* *:-~*r *~::, *i~* *i"t* .'~;, *l~: *1$.- *!* *!~~ :r.: *~:* *:t.- *!~:' *~~* ,i!: *1~* *:* *l~: *!~* *:~* *l:l* *!}*!:;'*is: *::;- *~* *i* *\:!'*(::0 *!~*!~*!fr *!:t *l~.. *:~~ *!!:" *!':.:. *l!:' *!:;'*:**it!'*:~ *:-t *it:**!~* *i::,

     *)t* *}~* ~I* {:t* ~l* *)t* *~f* *)i* *h* *;)* ;~~* .:;i* ~i* '>I.* ~l* ,;t, *~!l*                                 ::;~ ~~: .... i~*i ,~:., v* '"' (;., <) :{ 0 ,*~. :::: . () ,:: '                                                  ijl* *)i* ;u, *)I*-.:~* *'.ll* ~::, *.U* *_II*,::, ;:f, -::1, *Ir* *~I**))**!!**::*

ACQU1RE DATE: 28-MAY-90 .10: f\,'..?. r; ..1 * ,:,, FhlHl*1l < .t ::::::12) PRESET TIMEILIVE):  :;:: (H).  !;:: I:: C *i*  !:)!:::.!"~!::: IT IV ITV:  :;). !:;,(,(, E:U:iF":.:;ED RtU~,L. TIME. '..:'100. (;;[.(:: *.,1,  !,:;H {W' E F' 1wu:1f*tf:.: T ET:. 10. 0 ;i,; ELAPSED LIVE TIME:  :;;:O(r. i:::l::C

• NBR ITERATIONS: .I. (I,

[l[:'.'TE:C:TOF~. OEl...:t !::: *<!* L. :1 'l::1,:u';ff:"{. NUC:l.. . L 11;11..1 *1 l'.I c1~\1.. i: IJ or,rri:::  :;~:::l-**M(.fV ..**:.lO (n::: *. !:i J.: \:)/::, *i$. El**~EJ\OV TOU::F~(.1NC:I:~: J., !:.:,(101< ~,! t:::E:~; /'C:i . Jt,ll . . : (). 11,.i' :i* :;*,.:;:.*(~,<'~* 11 11

                                                                                                                                                                                     ,:1,       H{,'ll..F' LJ F'E: r::(ff'I Cl                                                                  1.:1. 00 OFF:'.:3ET:                                                          ~-0. O!::i9::3!:):;:1:3 1<1:1~)

• AB~~DANCE LIMIT: 50. 00%

                                                                                                                                                                                          . 24. 94 TO                                         1047. 98

l. 0 83. /.j.!::i x:tut1 J. :;), I.. :;.i:;:: J.27. ()2 J.24 q., :;t?'E . . ~(1:;! !:):t!. :;.1

                            ..:r
                            £"'
                                                 .,. (..),
                                                ,., ..          ,*,**,> 6f::,t;.~/(,I.,,:,,
                                                               'l*::*                                          !*'"a
                                                                                                                                                                                           .1. * '.~ .1                  .1 (;: :\ . (Y:i'                     j 7(:                       .1 1::.1    ..
                                                                                                                                                                                                                                                                                               ~:i .,~ ..         ::;ii::>f;'>**()::.: :~:1~?. ~:*i j. i:,/:,E: 00
                            !::i                'il'.i:. /::, :3                                             ?.Vi',,.                                             a'.::,.                   I.. 4"?                      .I. O!::i. :39                        J.'?:::::                    J.!:) J.. 6:31:1****(1.1. .\.*~). r.:,

4. ()

                              "              i O"I t**
                                            ,I, ,;~.1.,),
                                                               **, t'"I *.a:, A<'t,"Z-j ,;:, ~

b j *'"I

                                                                                                               ' .. ~.1,                                                                                                                                                                   1 1 .:., *;:,r'?[ .. ,()::.~ *:.:ti.. 1i1
                            ~64                                !.., l?:t (3( J. ':,),                                                                         J.!::i.                                                                                                                     :~~*;:, 1~:1. J. '?E . . . (,::;~ :]*?. :;:,

1.~. u .t l.i,(;,0. 06 r<- l/fJ .19. 0. 1:-:i t.:,. :J:::~E:****():;~ :~~~;~. 'i*' PEAK SEARCH COMPLETED (V2. 0 CSONGS 1/89J1

' .,.. N(ICl:.1,J D'f:.: '.l DEhlT :r F' :i C:{,rT I CIN i::v::::TE1*1i ( (::Ctl\iC,i!::: l,.Jf::I:: '.:i. 0' i;i/(:7)

SUMMARY

OF NUCLIDE ACTIVITY "f'OTf.')1L. 1... 1 HE:::i 1 bl f:;F'E:C:Tr;:UM

  ~~JNES NOT LISTED IN LIBRARY

( \l*:*1* *r..1* 1::"f i::"r1 1

• 1.... \L , , [.,, J.... '[, I\I 1.:*11t*

                                                    .... 1 ...

1 il"li'~f;,1,1* 1:,.,r:*r:*

                                                                        "l \        , t,,. "1f;.,"I" 1
                                                                                            ~~    ,                                                            : s; CORRECTION FOR NUCLIDE INTERFERENCE ANALYSIS PERFORMED                                                                                                   )~/
                                                                                                                                                              *(.,.) .
                                                                                                                                                             *~
                                                                                                                                                             ' <!.O
                                                                                                                                                             *~

J."*:::il:0l1h hlUC:L.. l DE m::HF: Hl... :t Ft::: 1:11':'.C:{~ V 1,.11';: 1 /Uhl.! T E.:F:r=:r:ir: J'. .. *J,'.;:il. i::1::, l;), 04i.) 1... 00:3 J.. (,,;1,41:: .... 7 ~:,. J.21:)1::. ***l::l

• ~it*l::'. :1::, :;:;.~i~:*1?~fr: *~~ 1~& *s:'. *~* *~::, *l:; *}t~ *?~ *!:~ ,;*f *~: *l* *!!:- -~* *!(* *!~: ,: ~ *l~* *?!: *!:~ *!::" *!i *ll* ::~; *!~ ,!:t *l!r *l* *ltr *\<f *:~~

                                                                                                                                                                                                                                                                                                    *1~.~t -5"'-~o
                                                                                                                                                                                      *~: *t:: ,;!.:. ,;~. ,i:: ,;:~ *!~* ~* *t* *tt *l* *ti**!.::**!:: *ii* *r~: *!~* *l* *1~* *!* *!* ,!:!* *!~.. *!*

~************************************************************* ACQUIRE DATE\ 21-MAY-90 .t '..:l: 00. :::f:i *ii* F'I..JHM ( 1 '.:::::t'.i'.) . *t , ,::J,::11\, PRESET TIMECLIVE): :300. ::lEC: *i~  !:::1::11'*~:::: J: TI VJ: T'Y:  ::::. ~:~()(~ EUl1F'~\;ED F:E(!il.. Tl t*1lf.:::  ::ioo. i::r:::c *:i* \:iH(~,P*t:.: F*f*f.'.{:1ME:TE:F: 10. 0 ;,.; ELAPSED LIVE TIME:  ::::00.  ::,l::C

• NBR ITERATIONS: 1.(1,

                                                                                                                                                                  *JI*

DETE:CTOI::: Ci[:::l ... :r E: *!I* L. J E:F~(;1F:V NUC:l.. . 1.:.. t 1;11.11 ]:I cr.:11.. n:: D?'.tTE:.: 2 l.** . [1ir.W****i)() 07: :::::ii: ::::i:i *itf 51**~1::i:::ov TOL.EFtl\NCE: J.. i::,r.)Ol<'*i VE'.V/CHl\ll...: 0. ~:iOOO(,(:,t:;, + H~LF LlFE RATJO 8. 00 OFFSET: -o. 03207 09 Kev**

• ABUNDANCE LIMIT: 50. 00%

24. 97 TO 2048. 24

                                                                                                                                               *                     .~:,. !~5 ,~:,                J. :3 :::~. (J ::::                J. :;::tj:,                  '? 2. l::l,~:.J:>**{12                 !:\!:\ . .<f 2:l.                        .'l . .t l:,                   :\ (~tt:i. :~*: .1                 .t '7{::                  .1 ::,(: 1,;:, J~;."~*E'.***():;;::       :~~:~;:. "~*

l.O. l. l.. :3. :~,::*~ .1.1.i)(~. :~:! O 4.*7~~:; l, ,ti, :~*~, :~~ '? f~~ ,~~(~I:;::  !:~,*~~. !:) f;,f.\ .* 11:, 1 . l.:i"E>..<> I 17. r:, PEAK SEARCH COMPLETED (V2. 0 [SONGS 1/89J I

TOTAL Ll~~S lN SPECTRUM ,,

                                                                                                '"l'

,-*' -l'.Ni:t'.::; 1*~0T L.J:::frE~D IN LIEIRPifW *")

                                                                                                .e.

1 1*1r:* 1 l"f"l' l::"f r.:*1*1

    , ***    1\      :

• 1... * *** , **.tt*1lt"l hr

                                    *'[ l', I ,::*1                , { r::*[:*r:*1y;,*r*
                                                                }r:,,..  , ... ,. t, CORRECTION FOf! NUCLIDE INTERFERENCE ANALYSIS PERFORMED F '.[ ::::::::: :r Ohl F'r::'.ODUCT J. ***',::. l: CWli';1 HL. J FT.:         Dt::C:r'::i'/     UC.: :t /Uhl :1 T      E:F'.F:t:H::

8. 04D 1. 004 8. 915E -7 6. 896E -8 J.(1(1, (1(1 TOTAL ACTIVJ:TY

• 3. 9L5E-07 UCI /UNIT

MEMORANDUM FOR FILE June 24, 1992

SUBJECT:

Radioactive Materials Found at the Mesa Salvage Yard The Salvage Yard located at the Mesa is used as a storage facility for scrap materials . .(see attached map). It is a large rectangular lot, fenced on all sides. The fence is 6 foot high chain link with no breaks or gaps and stretches to the ground in all areas. There are two access points to the lot: The north gate remains locked at all times except on rare occasions when a vehicle must pa~s through the lot. The south gate remains locked when Health Physics personnel are not present and is preceded by an additional gate which also remains locked in the absence of HP personnel. Health Physics and Facilities Management are the only possessors of keys to the salvage yard. No one enters the Salvage Yard lot without HP personnel present. It has been the practice of the Health Physics Division to perform precautionary surveys of items in non-restricted areas since early 1990. In early 1990, a wide spread survey effort was conqucted at the Mesa to' verify the absence of radioactive contamination. Virtually the entire Mesa Facility was evaluated, including the STAR Yard areas, Mesa Warehouse, building G-50, and building G-48. Areas which were not surveyed at that time were fenced and maintained under positive HP control until such a time when .surveying the area was practical. One such area was the Mesa Salvage Yard. The scrap material in the yard dates back to this time period. The scr~p material stored in the Salvage Yard is currently being assessed for salvage. It is anticipated that the materials stored at the Salvage Yard are non-radioactive however, as a precautionary effort to ensure that no licensed Radioactive Material is released from Edfaon's control, this scrap material is being surveyed before uncontrolled release from SONGS. During these surveys, a small number of items have been identified with low levels of residual contamination present. A list of the items found and associated physical and radiological data of the current survey effort is presented in the attached spreadsheet. There are various regulations which are applicable to the identification of contaminated items at the salvage yard (i.e. 10CFR20.105; 20.203; 20.405(v); 20.207;'and 49CFR173.403) ..10CFR20.105 specifies dose limits for persons in non-restricted areas. No person shall receive a dose equal to or gi*eater than 2 millirem if that person were to occupy the area for one hour continuously or 100 millirem for a continuous 7 day period. 10CFR20.203 specifies posting requirements for Radiological Materials and Radiation Areas. If the activity present in a given area is greater than ten times the

• Page 2 of 2 Appendix C limits the area must be posted as a "Radioactive Materials Area and if a person is capable of receiving 5 mmirem wholebody dose over a one hour continuous period the area must be posted as a 11 Radiation Area 11
• 10CFR20.405, subparagraph (v),

lists the reportability requirements for personnel exposures in non-restricted areas. If the radiation levels or nuclide concentrations in an unrestricted area are in excess of 10 times any applicable limit then a 11 Reportable 11 situation exists. 10CFR20.207 lists the storage and control requirements for Radioactive Material.s in non-restricted areas. Radioactive Materials stored in an unrestricted area must be secured from unauthorized removal. The description of the salvage yard lot and Health Physics control, over that Jot demonstrates cornpUance with 10CFR20.207. 49CFR173.403, subparagraph (y), states the definition of 'iRadioactive Materials" as being any material with a specific activity greater than 2 nanoCuries per gram of that material. Materials with activity greater than this value are subject to specific transportation and documentation requirements by the Department of Transportation. Compliance with all of the above regulations is demonstrated in the attached spreadsheet. This memorandum and the attached spreadsheet will be updated and distributed periodically to provide information regarding the progress of work at th~ mesa salvage yard. cc:

SAN ONO FRE NUCL EAR GENE.RATION SITE Ceniral Processing Nuclear Information Center Services Computer Training Facility Training and Education Automotive Center Services Parking Lot #9 USWCGal>> Main Gate Main Gate

                                                  /                                Old 101 Cout HigbW,9f    /.

7 / __ _ SCE Prt,pony Un< Packing Lot 12A [

SALVAGE YARD CLEANU P Date Item Total Smearable Nuclide Activity WB D.O.T. 10CFR20 10CFR20.405 Comments Found Description Contam. Contam. I.D. Dose Rate {173.403) Appendix C Reportable (ccpm) (dpm/100 crn"2) (nCi) (rnR/hr) 21-May-92 4" Pipe section 360 <1k Pb-214 1.6E+OO <0.01 <2nCi/g n/a NO Geli, survey, non-uniform 21-May-92 4" Pipe section 360 <1k Pb-214 1.6E+OO < 0.01 <2nCi/g n/a NO Geli, survey, non-uniform 26-May-92 Flex-atalic Gasket 4500 <1k Cs-134;137;Co-60 2.0E+01 < 0.01 <2nCi/g <app. C NO Geli, survey. uniform 05-Jun-92 Wheel 1800 <1k Cs-137 8.1E+OO 7.00E-02 <2nCi/g <app.C NO Survey, uniform, Geli 05-Jun-92 Wheel 1600 <1k Cs-137 7.2E+OO 5.00E-02 <2nCi/g <app. C NO Survey. uniform, Geli - Wholebody dose rate determined using survey and Geli data (1000 mg/cm" 2} and the MicroShield computer code when necessary EXPLANATION OF COMMENTS - Geli: Gamma spectroscopy analysis was performed on item - survey: item was surveyed - Uniform/Non-Uniform distribution of contamination

SONGS HP INDIVIDUAL TASK ASSIGNMENT (!TA) ~ A, ORIGINATOR: Complete this Section, individual assigning ITA is to complete Section BC!/~/'~~

1) Name (Print) 2) Enter your next ITA number : : ~

3) Des Cr i be Ta s k ti: X fL/V'\ f-J=--/3 FL,, J\J rJ.'f I C Ur4 s '7'£:.. <;,. t/--1--f'-,M & A J'..,.......

____v_o_~OT AY--Mfl/z + L 4---M._./;)~J::~/~ l.,~L~--------

4) Describe what constitutes completion_

5) List appropriate references~~~- --------~------

6) Sign and Date ______

B. ASSIGNOR(S): Compliance with this Section is indicated by your signature or initials below,

1) All necessary documents are to be referenced and/or readily available and/or attached,

2) Prime assignor and assignee discuss thi assignor enters:

PRIME DUE DATE* of_g?-2../-'(bssigned to On 8:-/() ... '7'2

3) Subsequent assignor and assignee discuss SUB DUE DATE* of Assigned to .....,. By ______

4) Assignor(s) gives original ITA to assignee and forwards a copy to TAC Coordinator.

    *Prime Due Dates should be at least 5 calendar days beyond the date when task first assigned and Sub Due Dates must not be later than Prime Due Dates.

C. DUE DATE EXTENTION REQUEST: This Section is not a substitute for the Prime Due Date in Section B which must be agreed to between assignor/assignee prior to establishment. Required exten-sions, initiated by assignee, are to be requested as far in advance of the pending due date(s) as possible whenever completion date problems are identified.

1) New SUB DUE DATE of _ _ _ _ _ _ _ _ _ _ _ _ _ Requested By _ _ _ _ _ _ _ _ _On _ _ _ _ __

2) New PRIME DUE DATE of Requested By On~~~~~

3) Reason why due date cannot be m e t - - - - - - - - - - - - - - - - - - - - ~ - - - - - - -

4) New SUB DUE DATE of Approved By On

5) New PRIME DUTE DATE of Approved By On

6) Copy of !TA forwarded to TAC Coordinator BY D, TASK COMPLETION: To be completed by assignee and forwarded to originator,

1) Statement of completed action

2) Date completed

3) Is a copy of completion IS NOT COMPLETE WITHOUT THIS)

4) Signature of Assignee

5) Originator To TACC on - - - - - - - - - - - - - ~ date, By ____________ ________

Distribution: White - Originator Canary & Pink - Assignee Goldenrod - TAC Coordinator see: so(1a3) 191 1,e:v, o 11/24/aa

U'VJ;\""U J.~!J-'V ..,,..,,1..... .,.,-, i.,uv .:.. - 1 MEMORANDUM FOR FILE August 21, 1992

Subject:

   *Exempt Benthic Waste Shipment to Otay Mesa Landfill In accordance with a State of California exemption, obtained for the landfill disposal of the contents from a San Onofre Unit 1 fish basket containing small amounts of radioactivity, I have escorted and observed the proper disposal of said contents.

On August 21 1 1992, I observed the transport of 50 cubic feet of marine debris to the Otay Mesa Landfill. At the landfill, the waste was dumped from the truck in a designated area. Within minutes of dumping, landfill operators spread and covered the material with several feet of dirt and trash 1 as required by the exemption. Samples take.n from the container on August 12, prior to transport, indicated activity levels of 6.82E-7 µCi/ml, l.45E-7

      µCi/ml, and 7.56E-7 µCi/ml of Cobalt-60, Cesium-134 1 and Cesium-137 respectively.

This shipment brings the total volume of all exempt benthic waste disposed of to date to 580 cubic feet, which effectively constitutes fulfillment of the state exemption allowing for a total of 600 cubic feet to be dispoied.

REFERENCE:

so123~v1r-a.2.11 ENCODE: CN04CJ-389~ . NM04wPP I SQ I (When Ferm F'llled C : RELEAS'E OF LIQUID, SL'UDGE OR SLURRY ' ' rfo liquid, sludge or s1urry will be released from th*e Protected Area*'unless Sections I and III of this form are completed and Section *rrr*signed. I. Container/Vehicle data (Completed by Radwaste) A. From 1'/hat system or component vrns the 1iqui d, s1 udge or slurry removed? U/ F1.1,*11 .

8. Estimated tota1* volume (or container dimensions and approximate% full)

S"C /..f g ----

c. Container or vehic1e identificatioh ~*iJ.081011*,f.cl D. Container or vehicle dest1nation

                                                               -"'~-----:----'-.:;.....:.._-----------~

r)ril'/ n, E':r;.7 E. Where is the container or vehicle *1oc*ated .nOI~? .n71-?fl/:::" @ 1..or I F. Proposed shipmen~ date/time , 1.,, .. ~~a** <J :)..*

• I l*I ,:,9 II, Chem1stry or Counting Room Analysis A, Sample volume (ml) __1_o_c_b_______

8. Total volume (ml) of liquid, sludge or s1urry in the container or vehicle (from I.

above)  !.*!!&; F&i *

• C, Method of Analysis Ge LI C2 ...

                                      -~.....:...:. ........;:..:: ;;,_------- ~--*------- ---

D. Isotopic Identiffcation Nuclide Concentration (µC1/m1) Tota1 Activity (µCi}

                                                     ~ . 8 a JZ 1:- ~ 1'           9.0/.:.C,f-/

(' .I./,')/- 7 1 D .....,":'..-,-:;;- -j

                                                      '7, .,n.; . 'I               I. 07/1.:-:"(5
                          'cian Name

• Date/Time I 4 WtFQIIII III, Radwaste Review A. \.Jould release of this liquid, sludge or slurry represent a radiological hazard?

B. I.Jould release of this liquid, sludge or slurry viol~te the requirements of 10CFR or 49CFR for radioactive materials? ~-

     ' C.  \-las contamination and radiation clearance tag SO(l23) 79 issued? "/1                            1

o. Remarks ') n de- 'E..5{201?'iE:JJ 1c C1r;::;y 1;?$H s E. This liquid, sludge, or slurry is cle~r.ed ~or release.

Na roe

                                                                                                     ,~!4',A .J/.ra
                                                                                                              . Date/Time

                                                   ... ,.J.,..._                                                           unr J..

VU/ l."1/ Q,: J.V I V.L t.JUU QV'-V uv.1.,\.lu l\l!.LV -,-,-, 1,1..1v

• • • ~************* 12-AUG*12 08104113 *****************

MF*HF BENTHIC MASTE '7'.2.0.8/0t11CJol SAMPLE COLLECTION START DATE1 10-AUG~*;12 O:::.:OOH)O SAMF*LE'. C:QLLECHO~J END* DATE 1Q-AUG-'ii2 08:00:00 SAMPLE.IDENTIFICATION: 0641 TYPE OF SAMPLE 1 U 2/3 CHEMISTRY SAMPLE QUANTITY: 1000.000 UNITS: ML PER CENT YIELD : 100.00000 REACTOR I: 0 SAMPLE GEOME'fl~Y: 10CH)ML MARINELLI CIF'ERATORS INiTIALS11!11P EFFICIENCY FILE NAME: EFFC .MAR1LC ~--

• • '**********************J***********************************~

ACQUIRE DATE: 12-AUG-*12 07~58:47

• F*l lHM C1:?,:32) .

1 2. 419 PRESET TIME(LIVE>:  :.:: ()(l. SEC

• SENSITIVITY: 3.ooo ELAPSED REAL TIME:  :)01). SEC
• S;HAF'E PARAMETERr 20,(1 :1.

ELAPSED L1 VE TI ME:  ::::oo. SEC

• NBR IT ERA TI IJNS 1 I"1.,

DETECTOR: GELIC

• LIBRARY:NUCL .LIQUID C: AL .IE: DATE : 12: - AUG - 9 2 0 2 : 5 ';1 : 2 2
• ENERGY TOLE HANCE : 1. 2 5 0 KV KEV/CHNL: 0.4997688 t HALF LIFE RATIO: .8.00 OFFSET: 0.4:31'7:::02 KEV.
• ABWmANCE LIMiir 50.(lOi:

Q, COEFF. -4,7Z6E-O~ KEV/Ci*2 *

• • • • • • • • • • • ~~************************~************************

ENERGY l*U NDON 50.41 TO 2047.41 Pf< IT Et~ERGY AREA BK6ND FMHM . CHANNEL .LEFT PM CTS/SEC :t.f.RR FIT 1 I) 11!,3. ~:~: ;t..35" l.O, 11. 1

• 415  :::20 *;,4 ....I ,.....-,

                                                                                                                                *:=;ii!..L               9     :3. i 7E-02     59.5 II I,(

2 0 2<)7.46,o.J.:;" 1 .:;.-. :l4. 2, 2,5 414.24 406 19 4. ::l'iE- 02 59

• 1

   .-..::,      0     22:*i,, 40Pi> .-t).             24,                          Q 1.         1. 21.:1      4 71.::. 17       472                  17        El.OOE .. 02    46 A:::

4 0 810.E:U.-, .i..?.1 1 () ' .,;. ' 2~79 621.11!1 617 11  ::::

• 1 7E- 02 47.7 5 (l ~l 5 1 . 7 6 pj, ).f'I ;3 1 I 1:2:. 1. 14 702. ';1';1 .~. ,;, t;, U, 1.05E**01 2:~:, 7 4 l;,{)4.53c'...sf3*/ 15. 4' 1. 4 8 1208.7(;1 12:01 :31 5 ,<HE-02 :31 ,4 1. 52E O*

   '=*

7 4 e~09. 1S2 8, il'.I 2!::i ~ z~. i. 4 7 121 ::: * '"il/:.t 1201  :?, 1 :3.48E-02 21 .. 5

3 0 1~,61 ."0:.:.1 c.:.. /3'? n,".1

                                                      ._ 1:,     If                  it ~     1. 79      1:322.:32 1~:1:3                          1 .-,
                                                                                                                                                          '-    1 .~i:;;iE-01   i 5. O
   ,;i          0     7*~!5*. 80 c~ i3

0 1 1 7':?:

• 9 9 (.'.,:, C.-b

                                                                                     *:1        1

• 2::3 15~1(),f.i(l l!:114 1 . 0~ 2:;:4-:1, 26 2:~1:::~9 1 *:,

                                                                                                                                                         *-*   :;.:

• 15E-02 1 *-* 9.(l()E:-02 1i;1. 2 4 .-.. ,-:,

                                                                                                                                                                                  .::.., w L 10 ii             I) i :38 2

• i 2 C* l.,:O

                                                     ..27, 0.

0' 2, 5:3 21;1/:,4*- .:.7 t ~.15*;1

                                                                                                                                                         ,::)

1 ,;,'*' 1 .10E-01 *17. 4 12 0 i 45'7. :?.9 K*'tO 2~. .l 0. t.84 2 i20. :3!5 2't 10 1 19 13. 6 TE-02 1 ri . . ,!, 1 F*EM'. SEARCH COMl:.Lf:'.TED (VZ. O CSCit-!GS 1/i;l';I ~ J

U.)/ i!'l/ lJIJ, !O; U! 'Q'/.L<J, vOO lJVt:U l{kJ 005 NUCLIDE IDENTIFIC:ATLON SYSTEM \SOl~GS \x[V :'.:t,O, :3/::::::)

SUMMARY

OF NUCLJti~ ACTlVITY F*AGS 1 TOTAL LINES IN SPECTRUM

• 1Z LINES NOJ LISTED IN LIBRARY 6 IDENTIFIED IN

SUMMARY

REPORT 5 41.67:~ CORRECTION FOR NUCLIDE INTERFERENCE ANALYSIS PERFORMED CORRECTION FOR DEPOSITION DECAY PERFORMED FISSION GAS E~~D DATE DEPOSIT 1-SIGMA NUCLIUE SBHR HLIFE DECAY DECAY UCI /UN IT E!',:ROR  ;~~*RR

{E

- i :;:i HI FG 11.90D i. 124 1. ()0(1 2 .. Ot::3E -,s 1.Z40E -6 5 1

                                                                                                                             ~/ V 56 ACTT.VATIOt~ PRODUCT END DATE             DEPOSIT                              1-SIGMA r,IUC:L ! DE         SBHR          HLIFE          DECAY              DEC:AY         UC! /UN IT                ERR1jR         :I.ERR CCI- r.:,o*            AP          5.27Y          1. ()(J 1          1

• 0 00 ,~.,, E:22E -7 1. 1 ::n:1E -7 1 7. 4 i FI SS ! ON r'fWDUCi END DATE DEPOSIT 1-SIGMA NUCLIDE SBHR HLIFE DEC:AY DECAY UC I /UMIT . E fi:R ClR ~1!£RR c:s-1::14 FF' 2.0~,y 1.002 *1 .ooo 1,4!31E -7 6.,, 127E -8 .* 42:.l:3*

cs.-187 F'P 30,02Y 1.000 1. ooo 7.561E -7 1.1::;8E. -7 15!09 TOTAL ACTIVITY = :;: * ,:H, 7 E - 0 t.:, UC: I /IJl~IT TOTAL GASE1jus ACTIVITY = 2.0:3:3E-:-OC, uc:1: /LJNIT TOTAL ACTIVITY LESS GASEOUS ACTIVITY  ::, 1.58::.:E-OiS UC: I /UNlT

SONGS HP INDIVIDUAL TASK ASSIGNMENT (ITA) A. ORIGINATOR: Section B. l) Name (Print) 2) Enter your next ITA number CZ 12 6 '7 3 ) Des c r i be Ta s k l£ \1 "' LU )\:J' jL R 'l!. L. IE. A $ IE, DP FL.5'.H _*...,_E'.C>=--->-R~*0~~::>~~~~-h'-+-""?-,_'f 1L ft C. H- I N tf.. A f.l?. $

4) Describe what constitutes completion

                         ~

6) Sign and D a t * = - - - - - - - - - - - - - - - - - - - - - - - - -

B. ASSIGNOR(S): Compliance with this Section is indicated by your signature or initials below. l) All necessary documents are to be referenced and/or readily available and/or attached.

2) Prime assignor and assignee discuss this !TA P r i ~ . s i g n o r enters:

PRIME DUE DATE* of_{;J.-:)._-:_jj:__Assigned to By-------nJj *-Q .. '7 lj

3) Subsequent assignor and assignee discuss and agree on Sub Due Date, assignor enters:

SUB DUE DATE* of Assigned to ._ _ _ By On _ _ _ _ __

4) Assignor(s) gives original ITA to assignee and forwards a copy to TAC Coordinator.

  *Prime Due Dates should be at least 5 calendar days beyond the date when task first assigned and Sub Due Dates must not be l~ter than Prime Due Dates.

C. DUE DATE EXTENTION REQUEST: This Section is not a substitute for the Prime Due Date in Section B which must be agreed to between assignor/assignee prior to establishment. Required exten~ sions, initiated by assignee, are to be requested as far in advance of the pending due date(s) as possible whenever completion date problems are identified. l) New SUB DUE DATE of _ _ _ _ _ _ _ _ _ _ _ _ _ Requested By _ _ _ _ _ _ _ _ _On _ _ _ _ __

2) New PRIME DUE DATE of Requested By

3) Reason why due date cannot be met _ _ _ __

4) New SUB DUE DATE of ____________ _~Approved By

5) New PRIME DUTE DATE of Approved By __________ on _ _ _ _ __

6) Copy of !TA forwarded to TAC Coordinator B y - - - - - - - - - - - - - - - - - - - - - - - ~ ~

D. TASK COMPLETION: To be completed by assignee and l) Statement of completed action k~j Uiue_ tl-12.-'rtt

  -------------'--; ;,~>~~""_i!L_ .ef-eJ- h*r1: CJf:Z.~_]_c;lPf2Q

2) Date camp let ed _______ } ~';2_-~J~,....._ 9~¥--t--*------- ---------------

3) Is a copy of s (ACTION IS NOT COMPLETE WITHOUT THIS)

4) Signature of Assignee

5) Originator is to forward original !TA and supportin tion to TAC Coordinator.

To TACC on__J_:2, ...- 7-f 1 date, By Distribution: White - Originator Canary & Pink - Assignee Goldenrod - TAC Coordinator

December 2, 1994

SUBJECT:

Release of Fish for Use as Teaching Aids

REFERENCES:

1. Letter, "Evaluation of Fish," dated October 18, 1994

2. Letter 'Disposal of Benthic Material,"

dated November 18, 1994 In Reference 1, the Environmental Protection Group requested the Health Physics Division to determine whether fish collected during operation of the plants at San Onofre could be released for use as teaching aids. The short answer is yes, as explained below. Since receiving your request, the Health Physics and Environmental Group (HP&E) completed their evaluation (Reference 2) of the necessity for radiometric analysis before releasing benthic

   *material from the Restricted *.t\rea. Effluent from µnit 1 was explaine4 as .the source of the low level radioactivity found in bentliic material at Units* 2 and 3. The evaluation concluded: "Now that Unit 1 is no longer operating, this means of contaminating seaweed has been eliminated.
    ~ ..The only plausible plant conditions that could coincide with low levels of contamination are:

(1) operation of either lll1it with a secondary activity of 3E~05 µCVml; or (2) liquid radioactive waste releases of specific activity greater than 2E~04 µCVml. ... Apart from these c*onditions ... HP&E recommends discontinuing routine sampling.ofbenthic material for isotopic analysis as a prerequisite for disposing of the material in a local landfill." As recommended, Station is amending practices to discontinue routine sampling and analysis before releasing benthic material unless the plant operating conditions described above make it necessary. Although fish is not specifically mentioned in Reference 2, the term "benthic material" applies to the waste seaweed and entrained marine life collected in the fish baskets. So, the evaluation extends to fish. Landfill disposition is specified because that is the preferred method for disposal. However, since the material is free of radioactive contamination, there is no health physics concern to prevent the desired release of fish for use as teaching aids. Operating Instruction S023~2~6, "Fish Handling System and Entrairunent of Marin~ Mammals and Reptiles," prohibits removing any marine life from the fish baskets for personal consumption or use. It is recommended that EPG verify that this proposed use of collected fish does not

• violate the California Fish and Gatne Code.

December 2, 1994 Before any fish is released for use as teaching aids, appropriate EPG procedures must be modified to require EPG perso1U1el to verify that plant operating and effluent release parameters do not exceed the criteria described above from Reference 2. Please direct any additional questions to -...a,at PAX - Health Physics Manager cc:

        --,  ..  ~  . .. . \ . ......"

November 18, 1994 TO:

SUBJECT:

DISPOSAL OF BENTHIC MATERIAL

REFERENCES:

(1) 'Benthic Waste Release Practices*, 5/6/94 email from (2) = s a l of Waste Materials Accumulated at SONGS* 5/16/86. (3) ~ s of Benthic Material Release Program* 5/24/93. (4) 'SONGS 2 & 3: Correlation of SG Activity to CWS O al N-4097-14 (5) *standard Radiological Effluent Technical Specifications for Pressurized Water Reactors*, Draft 7, Revision 3. 1982 (6) 'Environmental Radioactivity', M. Eisenbud. 2nd edition. 1973 Academic Press In Reference 1, Station Health Physics requested the Health Physics and Environmental Group review the practice of analyzing benthlo material for gamma-emitting Isotopes as a routine part of the disposal process. Given that Unit 1 is shutdown and permanently defueled, the. potential for marine flora and fauna offshore from San Onofre to become contaminated Is greatly reduced. This material is only likely to exhibit detectable activity if there is a significant primary-to-secondary leak with RC$ activity, resulting in steam generator blowdown activity above 3E-5 µCi/ml or if liquid radwaste discharges are greater than 2E-4 µCl/ml. Sampling and analysis frequencies may be modified accordingly, BACKGROUND Radioactive liquids are discharged into the Pacific Ocean as part of the normal operation of SONGS. The Radioactive Effluent Program ensures those discharges are performed In accordance with 1o CFR 20.1301 (previously 20.106) and 1o CFR 50 Appendix I as embodied In the Offsite Dose Calculatio n Manual and site procedures. All releases are diluted in the circulating water system and then, to a much greater extent, by the ocean itself. Samples of seawater, sand, plants, and animals taken as part of the Radiological Environmental Monitoring Program do not routinely show detectable levels of activity. At least theoretically, the potential exists for organisms to occasionally contain trace amounts of radioactive material due to their proximity to San Onofre, primarily as a function of the ability for some species to selectively concentrate different elements with respect to ambient levels. Marine debris collected on the rakes and screens of the circulating water system intake is known as benthio material. In 1986, a prudent radiological protection practice was established of analyzing benthic material for gamma-emitting isotopes prior to disposal (Reference 2). SCE has always maintained that this material is collected from the environment and therefore outside the provisions of 1o CFR 20 regarding 'licensed material-. In 1988 after low-levels of activity had been detected with some frequency In the benthic material, an exemption was obtained from the State to dispose of the waste in a municipal facility. A concise review of documents on this Issue can be found in Reference 3, along with the recommendation to continue the program as it existed at that time.

DISCUSSION There are several mechanisms that, as part of routine plant operation, result in releasing radioactivity to the marine environment, thereby making it available to biota for uptake: (1) Feed and bleed of the RCS to coolant radwaste for chemical control (2) Processing of wastewater through the miscellaneous liquid radwaste system (3) Regeneration of purification Ion exchangers: (a) Slowdown Processing System (BPS) (b) Full Flow Condensate Polishing Demlnerallzer System (FFOPD} (4) Primary to secondary leakage with (a) Slowdown to the outfall for chemical control (b) Overboarding condensers for chemical control (c) Turbine lab drains to the control building sump System fluids from the RCS, SFP, and RWST (Item 1) are processed through Ion exchangers to ensure control of chemical and radiochemical contaminants. Partial drainage of those systems and wastewater collected in the plant sump and drain systems (Item 2) are also processed before being released to reduce the specific activity. These liquid radioactive waste discharges are considered an Intermittent source to the environment. S0123-l!l-5.1.23 establishes an administrative goal of 2E-5

 µCl/ml particulates and iodine before the wastewater is discharged. If there are extenuating circumstances, Effluent Engineering can authorize releases above the administrative limit on a case-by-case basis. As demonstrated In Attachment 1, sampling of benthic material below radwaste concentrations of 1E-4 µCl/ml for all Co isotopes, 1E-5 µCl/ml for all Cs Isotopes and 1E--4 µCi/ml tor I

Isotopes would not likely detect any activity. Not included in the calculation, Is the large dilution that occurs once releases from the plant leave the discharge pipe and enter the ocean. Rapid mixing in the Immediate vicinity of the discharge pipe and subsequent dispersion should further reduce activity by three or more orders of magnitude, Empirical data from liquid release permits have shown that regenerant wastewater (Items 3a and 3b) does not contain significant levels of activity even after use during primary to secondary leakage conditions. Furthermore, short-lived isotopes like 1-131 would be expected to decay away between retention on the resin and subsequent regeneration, particularly If the leakage occurred at the beginning of ion exchanger bed life. Releases from the BPS and FFCPD sumps which would contain concentrations greater than the administrative goal of 2E"5 µCl/ml are not considered likely. During startup and shutdown of the plant, steam generators blowdown may be diverted directly to the outfall, bypassing tt,e BPS, for chemical control (item 4a). This mechanism is considered the most potentially significant In terms of activity being discharged to the environment from the SG or BPS. Calculation N-4097-14 discusses the partitioning of Isotopes between the steam generator liquid and the condensate In detail. The result Is that no meaningful fraction of isotopes Is carried into the secondary side by the steam and, further, given that overboardlng of the condensers to the outfall for chemical control ls Infrequent, item 4b does not constitute a major mechanism for Introducing radioactivity to the marine environment. Similarly, the sample drains from the turbine lab to the control building sump (Item 4c) do not represent a significant pathway. The mechanism which could result in the highest activity being released is therefore Item 4a. Attachment 1 provides the calculated activity for Cs, Co, and I isotopes in steam generator blowdown above which there Is the potential for activity to be detectable In benthlc material entering the plant's Intake structure(s). There are obviously other accidental/catastrophic events (tank or pipe failures, Inadvertent introductio n of high specific activity wastewater to yard drains) which could result In releases of radioactive water to the environment. Given that site programs and procedures have been established to minimize the likelihood of uncontrolled releases, it is not deemed appropriate to Implement a sampling frequency of the benthic material based on these occurrences. 2

Finally, In consideration that there might be a very low potential for this environmental material to be disposed of with very low levels of detectable activity, a dose assessment was performed using the software program IMPACTS and assuming disposal of 300 ft3/month with E-6 µCl/g each of Oo-60 and cs-137, The solid waste Is assumed to be burled In a municipal landfill where the srte Is administratively controlled by the city for 1 year before being released to public use, For the mixture/ of Isotopes consldered1 the transportation worker theoretically obtains a higher dose than the construction and agriculture Intruders, exposed waste Impact, and leaching Into groundwater Impacts. Conservatively, the truck driver could obtain 0,2 mrem/yr

• well below the public dose limits for licensed material In 1o CFR 20, 1006, Conclusion Steam generator blowdown frqm Unit 1 was released to the ocean without processing since phosphates were used for chemical control. As such, whenever there was primary to secondary leakage at Unit 1, there was a strong potential for benthlc material to have detectable levels of activity.

The Impact could be discerned at Units 2 and 3, Just downcoast of Unit 1. Now that Unit 1 Is no longer operating, this means of contaminating seaweed has been eliminated. The philosophy of analyzing the benthlo material prior to disposal as a careful radlologloal protection practice still holds true today, What has changed Is that the likelihood of there being detectable activity In this environmental material has been. reduced even farther, The only plausible plant conditions which could coincide with low levels of contamination are (1) operation of either unit with a secondary activity of 3E-6 µCl/ml or liquid radioactive waste releases of specific activity greater than 2E:4 µCl/ml, Chemistry personnel sample both streams routinely and should modify their procedure s to notify the Health Physics Division whenever these levels a.re exceeded, Subsequent to notification, benthlo material should continue to be analyzed for gamma emitters per existing HP practices. Apart from these conditions, analysis of seaweed and/or entraln~d marine life for gamma Isotopes will not provide *additional assurances of either public health or protection of the environment. HP&E recommends that routine sampling of benthlc material for Isotopic analysis be discontinued as a prerequisite to disposal of the material In a local landfill. Only under those specific plant conditions discussed In the previous paragraph Is analysis of the material likely to show detectable levels of activity. If there are any questions concerning the Information herein, please contact of my staff ~rmyself... - cc: 3

ATTACHMENT 1 ITEMS 1 & 2

• DISCHARGES OF COOLANT OR MISCELLANEOUS LIQUID RADWASTE (1) Feed and bleed of the RCS to coolant radwaste for chemical control (2) Processing of wastewater through the miscellaneous liquid radwaste system At; = Arw
• RR
• BF
• j_

DR DD where At; is activity in the benthic material Arw is activity of radwaste discharges, µCi/ml RR is release rate from radwaste, 100 gal/min DR is dilution rate from 3 circulating pumps, 555000 gal/min BF Is bioconcentratlon factor DD Is dilution from the diffuser ports In circulating discharge pipe, 1o Determine when Ab should be less than environmental MDAs Limiting MDA = Arw

• RR
• BF
• j_

DR DD where MDA Is the minimum detectable activity in environmental samples Arw =MDA

• DR
• _1
• DD
• RR BF

                          µCi/ml=       Q.Ql

• _i&i
• _Js_g kg 1E6 pCi 1E3 g ISOTOPE MDN (pCi/kg) BFb Arw (uCl/ml)

Co-58 130 51 '1.4E-4 Co-60 130 51 1.4E-4 Cs-134 130 553 1.3E-5 Cs-137 150 553 1.SE-5 l*i 31 3000° 1065 1.6E4 a Minimum detection levels taken from Table 4. i 2*1, NUREG-0472 (Reference 5) b Bloconcentratlon factor from Table 6-4 *Environmental Radioactivity', Elsenbud, M.; 2nd edition, i 973 Academic Press (Reference 6) No environmental MDA for fish (wet weight) given. Non-drinking water MDA used (Reference 5) 4

ITEM 4a

• SLOWDOWN OF SG DIRECTLY TO OUTFALL Maximum blowdown rate = 250 gpm/steam generator Assume two generators blown down simultaneously, 500 gpm = RR Substituting A.Q for Arw in the previous equation:

A.g = pCi

• _1&[ * -1s.g
• DR* _1 *'DD kg 1E6 pCi 1E3 g RR BF ISOTOPE MDAa (pCi/kg) BFb ~o (uCi/~1)

Co-58 130 51 2.BE-5 Co-60 130 51 2.BE-5 Cs-134 130 553 2.6E-6 Os-137 150 553 3.0E-6 1-131 3000° 1065 3,1E-5 a Minimum detection levels taken from Table 4. 12-1, NUREG-04 72 (Reference 5) b Bloconcentratlon factor from Table 6-4 "Environmental Radioactivity*, Eisenbud, M.; 2nd edition, 1973 Academic Press (Reference 6) No environmental MDA for fish (wet weight) given. Non-drinking water MDA used (Reference 5) 5

HEALTH PHYSICS DIVISION PROJECT/SERVICE REQUEST FORM REQUESTOR'S NAHE: CODE: PAX: a complish ed;list an

                    ~-*-

c.OMPLETION: (Describe the factors to' be used when determini ng if the project has been completed satisfact orily.) APPROVED BY SUPERINT ENDENT:~ ~--' HEALTH PHYSICS DIVISION PROJECT ASSIGNMENT FORM ID#: CODE: Narne Group PAX TITLE: DUE DATE: _ _ CO.._.:,...,..---____,..~,.,__._,-j......_-_4:1-*_ BUDGETED HOURS: ----- ASSIGNED BY SUPER INTEN DENT:~ -----~-- ------- DATE:

• Codes:

HPD = HPD Mana9er (Knapp) DOS= superv. Dosimetry SUP i:. super int. HPE/ Dosi m. (Warnock) OPS~ superint. OPS HP/RMC (Fee) HPE = superv. HP Engineeri ng Ul = superv. Unit l

.'b...LA =   Lead, A LARA                                                                 U2&3= Superv. Unit 2&3 R.~D =       Lead, Radwaste                                                               Rl~C = Superv. RMC HPI =        Lead, HP Instrumen ts                                                        l-:HP = Hon..:.:-ip Requester       1/!

Generi c Trackin g System (GENTS), 10/27/9 4 seq. No. Document date 10/18/9 4 To Units From iubject Type ACTION File code Status o Receiv ed 10/27/9 4 Due date 11/08/9 4 Foreca st I I Schedu led I I Closed I I Assign ee Key 1 2 3 Seq. No. Cross Ref. 1: 2: 3: 4: 5: Assignm ent No~ and Descri ption:

> HP TO EVALUATE IF FISH COLLEQTED DURING HEAT TREATS CAN BE FREE RELEASE     D
> VIA COUNTING TO PART-TIME BCE.EMPLOYEES FOR EDUCATION RESEARCH & TO SERVE
> AS TEACH AIDS.

(Activ ity Journa l] (none)

1994 OCT 2 4 1994

SUBJECT:

Evaluatio n of Fish ..... "' .... .. ....

                                                                           ~     . ...

The Environme ntal Protection Group (EPG) is requesting the Health Physics Division to evaluate if fish collected during Heat Treatment s can be tree released via counting to part-time SCE employees for education al research and to serve as teaching aids. To reduce costs, EPG has hired high school teachers, universit y professor s and graduate level students as part-time SCE

• employees . The purp6se is to supplemen t the EPG staff and to replace** high priced contract .labor to. perform fish impingeme nt*

activities

• dul:ing heat treatment s. During these*hea' t treatment s,*

these part-time employees ide~tify which species that they would like to remove from SONGS property. These species will be disposed of through the normal trash collection after research data is collected or would be preserved at the schools in glass container s for future teaching aids. Free releasing these ~pecies would hav~ numerous benefits. Destructiv e gill netting can be reduced by local universit y and positive public relations will be generated among the local schools and universit ies. "\ ~~ ' I ' I Please determine if these specimens can be free released. If you have any questions , please contact at - Manager, site Support Services MJ' o* 9 4 16 7 , ls p cc: ____ . _...,,,, .

            *-*7>, ~. ..  -   .   .*

SONGS HP INDIVIDUAL TASK ASSIGNMENT (!TA) A. ORIGINATOR: Complete this Section, individual

1) Name (Print) 3)

6) Sign and Date B, ASSIGNOR(S): Compliance with this Section is indicated by your s(ignature or initials below,

1) All necessary documents are to be referenced and/or readily available and/or attached.

2) Prime assignor and assignee discuss this ~ n P r i ~ g n o r enters:

PRIME DUE DATE* of j~/tf'-:t~ Assigned t o _ _ . . . . . . . _ B y ~ O n /2-~9'-/

3) Subsequent assignor and assignee discuss and agree on Sub Due Date, assignor enters:

SUB DUE DATE* of Assigned to By On _ _ _ _ __

4) Assignor(s) gives original !TA to assignee and forwards a copy to TAC Coordinator.

   *Prime Due Dates should be at least 5 calendar days beyond the date when task first assigned and Sub Due Dates must not be later than Prime Due Dates.

C. DUE DATE EXTENTION REQUEST: This Section is not a substitute for the Prime Due Date in Section B which must be agreed to between assignor/assignee prior to establishment. Required exten-sions, initiated by assignee, are to be requested as far in advance of the pending due date(s) as possible whenever completion date problems are identified.

1) New SUB DUE DATE of _ _ _ _ _ _ _ _ _ _ _ _~Requested By

                                                                                           - - - - - - - -On - - - - - -

2) New PRIME DUE DATE of Requested By _ _ _ _ _ _ _ _ _On _ _ _~ - -

3) Reason why due date cannot be met _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

4) New SUB DUE DATE o f - - - - - - ____Approved By

                                                                                          ~-------On

5) New PRIME DUTE DATE of _ _ _ _ _ _ _ __ Approved By __________ On

6) Copy of ITA forwarded to TAC Coordinator B y - - - - - - - - - - - - - - - - - ~ - - - - - -

D. TASK COMPLETION: To be completed by a_ssignee and forwaJded to originator.

1) Statement of completed action ~ Cf'--pfificl.i4 Ur;:.. /V\/i//

2) Date completed

3) Is a copy of c om p1e t i. on (ACTION rs NOT COMPLETE WITHOUT THIS)

4) Signature of Assignee

5) Originator is to forward original !TA and supporting documentation to TAC Coordinator.

To TACC on * - - - - - - - - - - - - date, By ____________ _________ Distribution: White - Originator Canary & Pink - Assignee Goldenrod - TAC Coordinator SCE !=10/t:;i~\ U7 J?r.'\/ n ti l'IA/n.<J

Author : at WEST4 Date: AM Prior' __ CC: ro:

Subject:

Re: ITA #94268 - Disposa l of Benthic Materia l

  -------- -------- -------- ---- Message Conten ts------ -------- -------- -------

1111111' Let's consider this assignme nt closed. Thanks, The action items required to dispose of benthic materia l without sampling have been complete d. 1, agreed to add a statemen t to 80123-I II-2.22. 23 for Chemist ry to notify the Sup. of RMC when the seconda ry activity exceeds 2E-6 uCi/ml. 2, . . . . . . . has been assigned to TCN Effluen t procedu res to Notify HP of liquid radioac tive waste releases with an activity greater than 2E-4 uCi/ml. 3, HPP S0123-V II-20.9.3 has been revised and states that RMC must ensure the two conditio ns above have not been exceeded before releasin g benthic materia l.}}