ML20078C173
| ML20078C173 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 01/20/1995 |
| From: | Fisher M PUBLIC SERVICE CO. OF COLORADO |
| To: | Joseph Austin NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| P-95011, NUDOCS 9501260211 | |
| Download: ML20078C173 (7) | |
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Public Service
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P.O. Bou 840 16805 WCR 191/2; Platteville, Colorado 80651 o nver,co sa20s m40 January 20,1995 Fort St. Vrain P-95011 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555 ATrN:
Mr. John H. Austin, Chief Decommissioning and Regulatory Issues Branch Docket No. 50-267 i
SUBIECT:
Response to Camments Regarding the Maal Survey Plan for Site Rh
REFERENCES:
1.
NRC Letter, Pittiglio to Crawford, dated January 17,1995 (G-95005) 2.
PSCo letter, Fisher to Austin, dated January 11, 1995 (P-95005) 3.
PSCo Ietter, Warembourg to Austin, dated September 21, 1994 (P-94080)
Dear Mr. Austin:
Attached are Public Service Company of Colorado's (PSCo) responses to the NRC's comments from Reference 1, regarding the revised Fort St. Vrain Final Survey Plan for Site Release.
PSCO considers that the attached responses, combined with the responses provided in References 2 and 3, fully address the NRC's comments and are consistent with our recent discussions with Messrs. David Fauver and Clayton Pittiglio of your staff. Based on the clarifications and commitments provided herein and in References 2 and 3, PSCo requests approval of the revised Final Survey Plan.
i 95o126o211 95o120 DR ADOCK 0500 7
P-95011 Jaraary 20,1995 Page 2 If you have any questions regarding this information, please contact Mr. M. H. Holmes at (303) 6201701.
1 Sincerely, PSP
$tAry3Gsk h/
Mary J. Fisher Decommissioning Program Director MJF/SWC Attachment cc:
w/ attachment Regional Administetor, Region IV i
Mr. Robert M. Quillin, Director Radiation Control Division Colorado Department of Public Health and Environment l
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FORT ST. VRAIN NUCLEAR. STATION FINAL SURVEY PLAN FOR SITE RELEASE j
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i RESPONSE TO NRC COMMENTS l
PROVIDED IN JANUARY 17,1995 LETTER FROM C. L. PITTIGLIO i
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ATTACHMENT TO P-95011 J
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NRC Ca===d 1 i
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WEll direct menanrunnents be saken at locadens ident(fled as elended during the scan j
surveyt 1
l Yes, if an area of elevated activity is identified durirq the scan of a survey unit, the j
location will be marked and fixed point measurements for removable and total activity j
will be collected at that location in addition to the prescribed set of systematic measurements for the survey unit.
Will ne resuhs qf asse direet nenasurements be included in the calculadens of ne mean and assaderd drainden te detersmine conyssace mith univstrieted use criteria, i
and included in neJinal survey report?
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Yes, the results of these fixed point measurements will be included in the calculation of the mean and standard deviation for the survey unit to determine compliance with the unrestricted use criteria, assuming that the survey unit does not require 2
i remediation and/or reclassification. If the survey unit requires remediation or
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reclassification, the results of the initial fixed point measurements will be archived as i
characterization survey data and the survey unit, or newly-defined subunit, will be j
resurveyed.
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The results of resurvey will be considered as the final survey of record and will be j
included in the calculation of the mean and standard deviation for the survey unit to
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determine compliance with the unrestricted use criteria. For instances where resurvey
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is performed, the final report will be annotated indicating that the initial data for a i
survey unit has either been replaced or supplemented with absequent survey data.
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NRC Camawat 2 i
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What charnetarisaden data, or sunty data, will be used to support classificadon of survey units as qWeeted, suspect and non-suspect, and unqWeeted areast One or more of the following types of data is available and will be used to determine the initial classification of survey units; operational history, characterization data, j
operational surveys performed to support decommissioning, routine surveillances and l
turnover surveys (for affected survey units only).
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NRC Camment 3 3)
What criteria udll be used to classify amas as geded/smped, deded/non-smpect,
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and undededt i
j A survey unit may be classified as belonging to one of three categories; unaffected, j
non-suspect affected, and suspect affected.
A survey unit may be initially classified as unaffected if there is little or no potential I
for the presence of licensed material based upon operational history, characterization data, and routine surveillances. %e presence of licensed material (in excess of 4
MDA), or previous remediation would preclude a survey unit from being classified as j
unaffected.
A survey unit consisting of walls above two meters and ceilings within an affected area may be initially classified as suspect or non-suspect. Based upon engineering judgement, and in consideration of operational history, characterization data, operational surveys performed in support of decommissioning, routine surveillances j
and turnover surveys, a survey unit may be classified as non-suspect if:
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It is not expected that average removable or total activity within the survey J
unit will exceed the larger of: 25% of the unrestricted use criteria; or the MDA for the equipment used to perform the survey.
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It is not expected that an individual measurement for removable or total i
activity within the survey unit will exceed the larger of: 50% of the j
unrestricted use criteria; or the MDA for the equipment used to perform the j
survey.
An affected survey unit will be classified as suspect if there is reason to believe that there was licensed material within the survey unit, unless it meets the criteria specified above for a non-suspect affected survey unit.
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NRC Camment 4 4)
Please describe, in greater detail, the procedure for innsdgadng sunty nsults in undected areas that exceed 25% of the unnstricted use criteria and in deeted/non-suspect etwas that exceed 50% in addition, describe what the innstigation will entail, what additional amnples will be collected, and when will areas be reclass4 fled as docted erwas?
The purpose of performing the investigation surveys is to confirm the initial final survey measurement, and if verified to exceed action levels, to define the bounds of the elevated activity. Depending on the results of the investigation survey, the survey unit may require remediation and/or reclassification and resurvey. The investigation surveys will generally consist of a scan survey over 100% of the wenible surfaces and measurements for removable and total activity. Typically the investigation survey will include an area of at least nine square meters, centered around the po* t of m
interest.
Investigation surveys will be performed within an unaffected survey unit if an individual final survey measurement for removable or total surface activity indicates the presence of licensed material (in excess of MDA). If during the investigation survey, measurements for removable or total surface activity are verified to exceed 25% of the unrestricted use criteria, the survey unit will be reclassified.
The action levels to initiate investigation surveys within non-suspect affected survey units are individual final survey measurements for removable or total surface activity in excess of 50% of the unrestricted use criteria. If greater than 10% of the initial final survey measurements within a non-suspect affected survey unit are verified to exceed this action level, or if an individual measurement exceeds the guideline values, then the survey unit will be reclassified as suspect affected and resurveyed.
Conversely, ifless than or equal to 10% of the initial final survey measurements within a non-suspect affected survey unit are verified to exceed this action level, and none of the individual measurements exceed the guideline values, then an investigation survey and/or reclassification will be performed.
The action levels to initiate investigation surveys within suspect affected survey units are individual final survey measurements for removable or total surface activity in excess of 75% of the unrestricted use criteria.
If during the investigation survey the initial measurement results cannot be confirmed, the initial measurement results will be flagged as suspect (anomaly) data in the final survey data base. The computer down loads, filed as part of the survey package, will be annotated as such. The investigation measurement results will be considered as the final survey of record and will be included in the calculation of the mean and standard deviation for the survey unit to determine compliance with the unrestricted use criteria.
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i If during the investigation survey the initial measurement results are confirmed, and r
remediation and/or reclassification is required, the initial measurement results will be archived as characterization data in the final survey data base. The computer down i
loads, filed as part of the survey package, will be annotated as such. The results of l
the post-remediation final survey, or the final survey subsequent to reclassification j
will be considered as the final survey of record and will be included in the calculation l
of the mean and standard deviation for the survey unit to determine compliance with
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the unrestricted use criteria. For instances where resurvey is performed, the final i
report will be annotated indicating that the initial data for a survey unit has either been replaced or supplemented with subsequent survey data.
If during the investigation survey the initial final survey measurement results are confirmed, but remediation and/or reclassification is not required, the initial.
measurement results and the investigation survey results will be considered as the final survey of record and will be included in the calculation of the mean and standard deviation for the survey unit to determine compliance with the unrestricted use criteria.
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