ML21067A199
| ML21067A199 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 02/10/2021 |
| From: | Gerard van Noordennen ZionSolutions |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML21067A225 | List:
|
| References | |
| ZS-2021-0001 | |
| Download: ML21067A199 (138) | |
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=================ZIONSOLUTIONS~---_-_-_-_-_-_-_-__________________ _
I February 10, 2021 ZS-2021-0001 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295 and 50-304
Subject:
References:
Revised Response to Request for Supplemental Infonnation and Request for Additional Infonnation Related to Final Status Survey Final Reports
- 1) Gerard van Noordennen, ZionSolutions, Letter to U.S. Nuclear Regulatory Commission,
Final Status Survey Final Report-Phase 2, Part l," dated March 11, 2019
- 2) Gerard van Noordennen, ZionSolutions, Letter to U.S. Nuclear Regulatory Commission, "Revised Final Status Survey Report-Phase 2," dated September 30, 2019
- 3) Gerard van Noordennen, ZionSolutions, Letter to U.S. Nuclear Regulatory Commission, "Revised Final Status Survey Report-Phase 2 Part 2," dated November 25, 2019
- 4) Gerard van Noordennen, ZionSolutions, Letter to U.S. Nuclear Regulatory Commission, "Revised Final Status Survey Final Reports and Related Release Records as Referenced in the Response to the Request for Additional Information for the Final Status Survey Final Reports for Phases 2a, 2b, and 3," dated June 4, 2020
- 5) Gerard van Noordennen, ZionSolutions, Letter to U.S. Nuclear Regulatory Commission,
Final Status Survey Report-Phase 3," dated December 30, 2019
- 6) Gerard van Noordennen, ZionSolutiom, Letter to U.S. Nuclear Regulatory Commission,
Revised Final Status Survey Release Records for Four Phase 3 Survey Units,"
dated April 30, 2020
- 7) Gerard van Noordennen, ZionSolutions, Letter to U.S. Nuclear Regulatory Commission,
Final Status Survey Report-Phase 4," dated May 1, 2020
- 8) John B. Hickman, U.S. Nuclear Regulatory Commission, Letter to John Sauger, ZionSolutions, "Zion Nuclear Power Station Units 1 and 2 - Request for Additional Information Related to Final Status Survey Reports Phase 2A, 2B, and 3,"
dated April 20, 2020
- 9) Gerard van Noordennen, ZionSolutions, Letter to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Related to the Final Status Survey Final Reports for Phases 2a, 2b, and 3," dated May 15, 2020
- 10) John B. Hickman, U.S. Nuclear Regulatory Commission, Letter to John Sauger, ZionSolutions, "Zion Nuclear Power Station Units 1 and 2 - Request for Additional Information Related to Final Status Survey Reports," dated November 4, 2020
- 11) Gerard van Noordennen, ZionSolutions, Letter to U.S. Nuclear Regulatory Commission,
Response to Request for Supplemental Information and Request for Additional Information Related to Final Status Survey Final Reports," dated November 11, 2020 AJH.5~ o l 101 Shiloh Boulevard, Zion
- IL 60099 (224) 789-4016
- Fax* (224) 789-4008
- www z1onsolutionscompany.com tvtv15_s
ZionSolutions, LLC ZS-2021-0001 Page 2 of3
- 12) John B. Hickman, U.S. Nuclear Regulatory Commission, Letter to John Sauger, ZionSolutions, "Zion Nuclear Power Station Units 1 and 2 - Request for Additional Information Related to Final Status Survey Reports," dated December 17, 2020 The Zion Station Restoration Project (ZSRP) License Termination Plan (LTP), Section 5.11, states that the Final Status Survey (FSS) Final Report will be provided to the NRC in phases as remediation and FSS are completed with related portions of the site. The FSS Final Report and Revised FSS Final Reports for Phase 2, Parts 1 and 2, were submitted for NRC review, as documented in References 1, 2, 3, and 4. The FSS Final Report and Revised FSS Final Report for Phase 3 were submitted to the NRC for review as documented in References 5 and 6. The FSS Final Report for Phase 4 was submitted to the NRC for review as documented in Reference 7.
The NRC staff began its review ofFSS Final Reports for Phases 2a, 2b, and 3 and determined that additional information was required to complete its review. ZionSolutions received a Request for Additional Information (RAI) from the staff on April 20, 2020 (Reference 8). On May 15, 2020, ZionSolutions responded to the RA1 as documented in Reference 9.
The NRC staff later determined that additional information was required to complete its review of the FSS Final Reports. On October 1, 2020, during a project status call and on October 8, 2020, during a follow-up clarification call, the staff verbally communicated the informal request for supplemental information. In addition, ZionSolutions received a formal Request for Additional Information (RAI) from the staff on November 4, 2020 (Reference 10). On November 11, 2020, ZionSolutions responded to the RA1 as documented in Reference 11. The NRC staff performed an acceptance review and determined a revision to the response was required to complete its review. ZionSolutions received a request for additional information on December 17, 2020 as documented in Reference 12.
The purpose of this letter is to provide revised responses to the requested supplemental information and the RAI; this submittal replaces the November 2020 submittal (Reference 10) in its entirety. The requested supplemental information and the response to the RAI are provided in Attachment 1 and, respectively. In addition, ZionSolutions is providing supporting documentation for the responses, as well as revised reports, as indicated in Attachments 1 and 2. Supporting information includes condition reports, discrete radioactive particle survey data, and surveillance survey data.
Enclosed reports include revised release records, the revised Phase 2, Part 1 Final Report, and the revised Partial Site Release Request. The supporting documentation and the revised reports are being provided electronically on the enclosed CD. Attachment 3 contains the preflight report for this submittal; it offers a list of all documents provided on the enclosed CD.
The revised submittal addresses issues identified by the NRC staff in Reference 12. ZionSolutions addressed sequencing of actions, inaccurate statements, survey completion, ORISE findings, controls post survey, corrective actions, condition reports, and discrete particles. As committed to during a clarification call, ZionSolutions interfaced with the NRC staff during preparation of the revised responses.
There are no regulatory commitments made in this submittal. If you should have any questions regarding this submittal, please contact me at (860) 462-9707.
Zio~olutions, LLC ZS-2021-000 I Page 3 of3 Respectfully, Gerard van N oordennen Senior Vice President Regulatory Affairs Attachments:
Gerard P. Van Noordennen Feb 10 2021 1:42 PM : Supplemental Information Related to the Final Status Survey Final Reports : Response to Request for Additional Information Related to the Final Status Survey Final Reports : Preflight Report for Enclosure to ZS-2021-0001
Enclosure:
CD Containing Documents Supporting Revised Response to Supplemental Information and Request for Additional Information Related to Final Status Survey Final Reports cc:
John Hickman, U.S. NRC Senior Project Manager Regional Administrator, U.S. NRC, Region III Zion Nuclear Power Station, Units 1 and 2, License Transfer Service List (without attachments and enclosure)
Zion Nuclear Power Station, Units 1 and 2, License Transfer Service List cc:
Ken Robuck President and CEO Energy Solutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 John Sauger President and Chief Nuclear Officer ReactorD&D Energy Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Todd Eiler Project Director D&D Engineering/Projects Energy Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Gerard van Noordennen Senior VP Regulatory Affairs Energy Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Russ Workman General Counsel Energy Solutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 Steven A. Reynolds Manager, Nuclear Facility Inspection Division of Nuclear Safety Illinois Emergency Management Agency 245 W. Roosevelt Road, Units 55 & 56 West Chicago, Illinois 60185 Kelly F. Grahn Senior Health Physicist Illinois Emergency Management Agency Division of Nuclear Safety 245 W Roosevelt Road, Building 8, Suite 55 West Chicago, IL 60185 Dan Eder, MPH, IPEM, LEHP Interim Manager Lake County Emergency Management Agency 1303 N. Milwaukee Avenue Libertyville, IL 60048-1308
ZionSo/utions ZS-2021-0001 Zion Nuclear Power Station, Units 1 and 2 Supplemental Information Related to the Final Status Survey Final Reports
ZionSo/utions, LLC ZS-2021-0001 Supplemental Information Related to the Final Status Survey Final Reports NRC Questions on Zion FSS Reports -October 1, 2020 Conference Call NRC Question #1 Verify that Release Record 12109 (South Half of Unit 1 Containment) contains a typo in that ORISE performed their confirmatory surveys of this area in April and July 2019 versus the incorrect date of August 2019.
RESPONSE: ZionSo/utions acknowledges the correct dates that ORISE performed their confirmatory surveys in the following Power Block survey units are April and July 2019 versus the incorrect date of August 2019: 10203A, 10203F, 12201A, Band C, 12202A, B, C, D, E and F, 12104, 12105, 12106, 12107, 12108, 12109, 12110, and 12111. This response serves as an addendum to the release records listed above.
NRC Question #2 A conference call is needed to discuss the timeline on the progression of surveys done for RR 12109.
RESPONSE: During a conference call that was conducted on October 8, 2020, the NRC staff communicated a request for a timeline on the progression of surveys done for survey unit 12109.
Survey unit 12109 resides in the Power Block area. The Power Block consists of 19 Class 1 open land survey units for Final Status Survey (FSS).
January to February 2019 - Initial remediation of soils at the 588 ft. elevation in the Power Block (including 12109).
February to April 2019-Post remediation scanning and sampling of soils in the Power Block (including 12109). Excavations were not backfilled to allow for confirmatory survey.
April 15, 2019-ORISE begins confirmatory survey of Power Block.
April 16, 2019-Survey identifies particle in survey unit 12106.
April 17, 2019-Survey identifies a second particle in survey unit 12106. Upon discovery of the second particle, ZSRP Project Management requested that the in-progress confirmatory smvey by ORISE be suspended so that ZSRP could investigate.
April 18, 2019-Commenced resurvey of Power Block soils at the 588 ft. elevation.
May 20, 2019-Completed initial resurvey of Power Block soils (including 12109).
May 20, 2019-A readiness walk-down was performed of the Power Block. Participants included the D&D Manager, D&D Projects Manager, Lead C/L T Engineer, C/L T Supervisor, and the Director Radiological Site Closure.
May 28, 2019 - completed resurvey of Power Block soils at the 588 ft. elevation (including 12109).
Page 1 of17
ZionSo/utions, LLC ZS-2021-0001 Supplemental Information Related to the Final Status Survey Final Reports June 18, 2019 - A readiness report regarding this event in the Power Block was issued to the Site Manager. Upon submittal, the NRC was contacted pertaining to the resumption of the confirmatory survey of the Power Block.
July 15-19, 2019-ORISE completed the confinnatory survey of the Power Block. Upon completion of the surveys, ZSRP backfilled all excavations and imported clean fill to the site to raise the elevation of the Power Block soils from the 588 ft. elevation to the 591 ft.
elevation as required by the LTP.
September 4, 2019 -Performed FSS of survey unit 12109.
Supplemental or Revised Documentation: "Power Block RA Report Attachments" and "Power Block RA Readiness Review" NRC Question #3 A call is needed to discuss Release Record 10221B (Near railroad)
RESPONSE: During a conference call that was conducted on October 8, 2020, the NRC staff communicated a request for clarification of the timing ofFSS versus an RA performed in survey unit 10221 B. The release record for the FSS of survey unit 10221 B states the following, "An investigation was performed based on the results of gamma scans performed under an RA on June 17, 2019 on the railroad ballast located in survey unit 10221 B and the soil areas I-meter beyond the ballast gravel (these scans were performed subsequent to the scans performed under the FSS Sample Plan)." ZionSolutions has revised the release record for survey unit 10221B to clarify that the RA performed on the railroad ballast (which covered numerous survey units) was performed at the same time as the FSS of 10221B.
On May 14, 2019, FSS was performed of survey unit 10221D. An elevated area was identified directly adjacent to the railroad ballast supporting the rail line that transited through the southern portion of the survey unit. The railroad ballast is comprised oflarge granite rocks and gravel, making it difficult to acquire a volumetric sample, and as sampling was not possible, decisions regarding potential radiological contamination could only be made by scanning. Please note that the identified elevated area in survey unit 10221D was found to be from soil contamination that was remediated and not from contaminated ballast. However, while investigating the elevated area in survey unit 10221D, inquiries were made with the railroad pertaining to the potential need to remediate the ballast. ZionSolutions was infonned by the railroad that any physical movement and/or removal of the ballast could potentially undermine the structural stability of the rail line and, that the railroad must be on-site to observe the remediation and recertify the stability of the rail line before it was used again. Therefore, in order to assess the potential involvement of the railroad and to coordinate their potential presence on-site, project management directed that the ballast for the entire rail line be assessed by scanning to estimate the potential scope of any necessary remediation.
Page 2 of17
ZionSolutions, LLC ZS-2021-0001 Supplemental Information Related to the Final Status Survey Final Reports The FSS of survey unit 10221B commenced on June 7, 2019. The scans of the entire rail line commenced under the RA on June 17, 2019, while the FSS in survey unit 10221B was still in progress, and were considered as additional judgmental scans. Even though the ballast is not considered a soil, the RA scans were performed using a scan MOC sufficient for detecting the OpDCGLs for surface soils and the scan alarm was set to the instrument MDCR plus background. The ballast RA survey documentation ("Ballast RA Attachments") is provided on the enclosure to this response.
Elevated areas were identified by the scan of the ballast not only in survey unit 10221B. The areas were investigated, and the contamination was discovered in small soil footprints, adjacent to the ballast, which were spot remediated and resurveyed during FSS.
ZionSolutions has revised the following sections of the release record for 10221B to clarify the timeline as described above.
The Executive Summary, Survey Implementation, and Survey Results sections previously stated, However, subsequent scans were performed under a Radiological Assessment (RA) survey on June 17, 2019 on the railroad ballast located in survey unit 10221B and on the soil areas one-meter beyond the ballast gravel. The RA survey identified two (2) small areas of elevated activity (see Section 9 for further discussion)."
ZionSolutions revised as follows: "While FSS was in progress, scans were performed on the entire rail line to ascertain if it was necessary to remediate any ballast, which could potentially impact the structural integrity of the rail line. The additional scans identified two (2) small areas of elevated activity in the soils bordering the ballast (see Section 9 for further discussion)."
The Survey Implementation section previously stated, "While performing a gamma scan of the railroad ballast located in survey unit 10221B, and the soil areas one-meter beyond the ballast gravel, two (2) small areas of elevated activity were identified (these scans were performed subsequent to the scans performed under the FSS Sample Plan)."
ZionSolutions revised as follows: "While performing a gamma scan of the railroad ballast located in survey unit 10221B, and the soil areas one-meter beyond the ballast gravel, two (2) small areas of elevated activity were identified (these scans were additional judgmental scans from performing an RA of the rail line ballast at the same time as FSS)."
The Investigations and Results section previously stated, "An investigation was performed based on the results of gamma scans performed under an RA on June 17, 2019 on the railroad ballast located in survey unit 10221B and the soil areas I-meter beyond the ballast gravel (these scans were performed subsequent to the scans performed under the FSS Sample Plan). The RA identified two (2) small areas of elevated activity, both less than 100 cm2, reading 3,200 cpm and 4,700 cpm (a map of these areas is included in Page 3 ofl7
ZionSolutions, LLC ZS-2021-0001 Supplemental Information Related to the Final Status Survey Final Reports )." ZionSo/utions revised as follows, "While FSS was in progress, scans were performed on June 17, 2019 of the entire rail line to ascertain if it was necessary to remediate any ballast, which could potentially impact the structural integrity of the rail line. The additional scans identified two (2) small areas of elevated activity, the first reading 3,200 cpm and the second reading 4,700 cpm with an area for both less than 100 cm2, in the soils bordering the ballast in survey unit 10221B, prompting an investigation."
Supplemental or Revised Documentation: Revised Release Record 10221B, Ballast RA Attachments" NRC Question #4 Smyey 10220F (Near ISFSI) - There was a hot particle found in this area when removing buried pipe in June 2018. Which survey unit contained the hot particle? Was it found before or after the pipe removal?
RESPONSE: The particle was discovered during the performance of an RA in support of the removal of buried pipe in Class 3 survey unit 10220B. The particle was discovered during the scan of the top-side excavation footprint, prior to excavation, for the removal of a non-contaminated buried pipe system. As a result, the particle was remediated prior to the excavation, and as a corrective action for the discovery of the particle, the single Class 3 survey unit was subsequently divided into five Class 1 survey units (10220B, 10220D, 10220E, 10220F, and 10220G). After division of survey unit 10220B into five survey units, the particle would have been within the boundaries of survey unit 10220G.
NRC Question #5 Buried Pipes - Need a cross reference table for buried pipe survey units. It is hard to correlate with the open land survey units above the buried pipe.
RESPONSE: The open land survey units where each of these buried pipes are physically located is provided in the table below.
Buried Pipe Survey Units Survey Name Class Area {ft)
Pipe Open Land Unit ID Survey Units 00IOIA Condensate Feed Water Supply 3
2,455 T-103, T-105, and 12205C and Recirculation Buried Pipe T-106 0010IB Primary Water Supply Header 2
308 T-095 and T-102 12205B T-095 and T-102 Buried Pipe Diesel Generator Heat Exchangers A0-27, AO-28, 12104, 12109 00IOIF Service Water Supply and Service 3
956 A0-30, AO-31, Water Return Buried Pipe TO-32, and T0-33 00101H Service Water Supply Header 3
5,248 C0-26 and CO-29 12205C CO-26 and CO-29 Buried Pipe 00150A/B North End Storm Drain Buried 2
2,187 NA 10214D, 10213A,
&C Piping 10212D Page 4 of 17
ZionSo/utions, LLC ZS-2021-0001 Supplemental Information Related to the Final Status Survey Final Reports NRC Question fK>
North Yard Storm Drain - Need Eberline sample ID # for the sediment sample.
RESPONSE: The sediment sample (L2-10214C-RJGS-001-SM) was collected from the west access point during the performance of an FSS surveillance. Both Cs-137 and Co-60 were positively detected at concentrations of2.22E+OO pCi/g and 1.80E-Ol pCi/g, respectively, by the on-site gamma spectroscopy system.
In response to a previous RAJ pertaining to this sample, ZionSo/utions recovered the sediment sample from the archives and sent the sample for full isotopic analysis. The Eberline lab ID is 20-04072-10. This sample report was provided in Attachment 3 of the ZionSo/utions response to the Phase 2 Part 2 RAI submitted in May 2020. ZionSolutions has provided another copy of the gamma spectroscopy report on the enclosure to this response.
Supplemental or Revised Documentation: Gamma Spectroscopy Report for L2-10214C-RJGS-001-SM NRC Question #7 North Yard Storm Drain - When was the NRC notified when ZionSolutions found contamination in the storm drain pipes? Provide a copy of the email or correspondence. Alternative may be the CR package. The licensee should provide additional information on the on-site source of the residual radioactivity that contaminated the drain system.
Also, the licensee should state whether additional on-site storm drain systems were investigated for similar contamination of were removed from the site.
RESPONSE: ZionSolutions notified NRC Region III Inspectors in June 2019 (via phone call) of the storm drain piping reclassification. In response, the Inspectors made a site visit to discuss the issue. In addition, a CR was generated (ES-ZION-CR-2019-0165). CR-2019-0165 is included on the enclosure to this response.
The surveillance that was performed in June 2019 that identified the residual radioactivity in the manhole for the North Yard Storm Drain was in response to a flooding incident that completely flooded the site from inside of the fenced area north of Unit 2 Containment into survey units 10212 and 10213 and into the parking lot (10214). The concern was for potential cross contamination of soils due to carryover of sediment from inside the fenced controlled area. The area (parking lot, manways, etc.) was subjected to a surveillance following the incident to assess the radiological impact of this event. A timeline depicting all the events in 10212, 10213, and 10214 leading up to the completion ofFSS is provided on the enclosure to this response. As shown in the timeline, in March and November of 2019, particles were discovered in 10214. The response to RAJ Question # 11 b provides discussion on the source and spread of particles discovered on-site.
Page 5 of17
ZionSo/utions, LLC ZS-2021-0001 Supplemental Information Related to the Final Status Survey Final Reports The investigation of other buried pipe systems is addressed in the Response to Additional NRC Question #6.
Revised or Supplemental Documentation: CR-2019-0165, Drainage Ditch Flood Timeline" Page 6 of 17
ZionSolutions, LLC ZS-2021-0001 Attachment I Supplemental Information Related to the Final Status Survey Final Reports Additional NRC Questions on Zion FSS Reports -October 8, 2020 Conference Call Additional NRC Question #1 Verify when ORISE survey was performed for 12109.
RESPONSE: Upon review of C/L T schedule and logs, it was determined that ORISE was physically on-site at Zion to complete the confirmatory survey of the Power Block remediated soils from July 15, 2019, to July 19, 2019.
Additional NRC Question #2 Review Phase 2 Part I Release Records for how replicate QC
!SOCS measurements were assessed, discuss why we are in compliance with the QAPP and check for consistency in use of the resolution table from NRC Inspection Procedure No. 84750.
(specifically reference QAPP sections 4.1.1 and 4.1.2 and 6.2.2.1 - uncertainty).
RESPONSE: The Phase 2 Part 1 release records were reviewed for how replicate QC !SOCS measurements were assessed. The !SOCS was used during FSS to demonstrate compliance with the structural release criteria in 18 Phase 2 Part 1 release records. While an !SOCS measurement is basically a timed static measurement, it also assesses the volumetric residual radioactivity concentrations in the media measured. Therefore, !SOCS replicate measurements collected for QC comparison are addressed similarly to duplicate and split samples in QAPP Section 4.2 and LTP Section 5.9.3.2. Both sections state thatNRC Inspection Procedure, No. 84750, "Radioactive Waste Treatment, and Effluent and Environmental Monitoring" is used to determine the acceptability of split and duplicate sample analyses. QAPP Sections 4.1.1 and 4.1.2 are not applicable to the QC assessment ofISOCS measurements. In addition, LTP Section 5.9.3.2 also states, "Agreement is ultimately determined when the same conclusion is reached for each compared result. If the split sample or duplicate sample results do not agree, then further evaluations will be performed." This conclusion is interpreted, for the QC assessments of the ZSRP FSS, as both the standard and comparison sample or measurement activities being above or below the OpDCGL (i.e., the same dose conclusion is reached). As part of the review for this response, an !SOCS QC summary table was compiled (!SOCS QC Comparison Review" below). An additional tool of +/-20% was utilized in this summary table as a check, but this tool was not documented in the release records for the survey units that utilized !SOCS for FSS.
The most current revision ofZS-LT-01, "Quality Assurance Project Plan (QAPP) for Characterization and FSS" is Revision 7, dated 09/24/19. The QAPP references NRC Inspection Procedure No. 84750, "Radioactive Waste Treatment, and Effluent and Environmental Monitoring" - March 1994. The resolution table presented in Table 4-1 of the QAPP matches the resolution table presented in the current version of Inspection Procedure No. 84750.
A review of the "Replicate Measurement Assessment" forms found in the Attachments for the Phase 2 Part 1 release records where the !SOCS was used to demonstrate compliance found that Page 7 of17
ZionSolutions, LLC ZS-2021-0001 Supplemental Information Related to the Final Status Survey Final Reports the resolution table presented in the current version of Inspection Procedure No. 84750 was used in 13 of the 18 release records. The now obsolete resolution table from the previous revision of the QAPP (which had an acceptance range for resolutions less than 4) was used on the Replicate Measurement Assessment forms in the release records for survey units 03202, 06107, 06108, 06201, and 06202. For comparisons that had resolutions less than 4 when comparing Cs-137, the comparison was then made using K-40. If the resolution in the comparison using K-40 was less than 4, then agreement was determined by comparing the standard and comparison measurement activities to the OpDCGL. Agreement was ultimately determined when the same dose conclusion was reached.
Each gamma spectroscopy report is validated by a Radiological Engineer in accordance with Section 5.1 of procedure ZS-LT-300-001-004, Final Status Survey Data Assessment." The procedure addresses the required content from QAPP Section 6.2.2.1, including the verification of the absence of anomalies in the sample or measurement results, or in the supporting data, including but not limited to MDC, uncertainty, deviation from established procedure, or analysis flags.
In the 18 Phase 2 Part 1 release records where the ISOCS was used to demonstrate compliance, 73 QC replicate measurements were taken:
Of the 73 QC replicate measurements taken, 37 QC replicate measurements demonstrated adequate agreement, based on Cs-137 activity, using Procedure No. 84750.
In 22 of the 73 measurements, the Cs-137 activity in either the standard or replicate measurement was less than MDC, or the resolution of the standard measurement for Cs-137 was less than 4. As Cs-13iwas no longer comparable, K-40 activity was substituted for Cs-137. Acceptable agreement was reached during the comparison of the standard and replicate measurement, based on K-40 activity, in accordance with Procedure No. 84750.
In 14 of the 73 measurements, acceptable agreement using the acceptance criteria specified in Procedure No. 84750 was not achieved. In 12 of the 14 measurements, the reason for unacceptable agreement was due to resolutions less than 4 while assessing K-40 activity. In the other 2 measurements, the comparison ratio for K-40 fell outside of the acceptable range for the observed resolution of the standard measurement. In these cases, agreement was determined by comparing the standard and comparison measurement activities to the OpDCGL. Agreement was ultimately determined when the same dose conclusion was reached.
The results of the review of the QC measurements collected using the ISOCS that was requested are provided in the following table. Due to rounding errors, the values provided in the table below may deviate slightly from the values provided in the applicable release records.
Page 8 ofl7
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ZionSolutions, LLC ZS-2021 -000 I Attachment I Supplemental Information Related to the Final Status Survey Final Reports ISOCS QC COMPARISON REVIEW (continued)
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- Le/19 Cou G/S 0./>I.
- 304708: 2297, 24 10, 2341, 2196, and 2413 cpm, averaging 2331 cpm.
- 3047 12: 2374, 2249, 2411, 2396, and 232 cpm, averaging 2352 cpm.
- 04713: 2494, 2122, 2402, 2529, and 2327 cpm, averaging 2375 cpm.
- 304711: 2844, 2752, 2972, 2275, and 2872 c,-pm, averaging 2743 cpm.
- 304726: 2007, 2139, 1926, 1969, and 23 13 cpm, averaging 207 1 cpm.
- samples were collected. The response to NRC RAI Question #3c provides a detailed description of each case.
- 5b). It extended from the outfall of the Switchyard located in adjacent Class 3 survey unit 10213A and discharged into a gated outfall pipe which discharged to the beach. At times, the gated outfall pipe became clogged, causing the drainage ditch to overflow its banks.
- PR327895, on the date of the survey, was 0.0044; it was derived in accordance with section 5.1 of procedure ZS-L T-300-001-006. The values cited in Table 4 of the release record were taken from Table 5-28 from L TP Chapter 5. The efficiency of 0.024 cited for the Ludlum 44-159 Cs I detector in Table 4 is a typical", or example, efficiency and not the efficiency applied for the FSS of this pipe.
- PR327895 daily, prior to use (Pre-Test) and upon completion of surveys (Post-Test). The performance of the checks is documented on Attachment 2 from procedure ZS-L T-300-001-006, and the actual survey is documented on Attachment 3. Images of the completed Attachment 2 and Attachment 3 forms from the FSS package for survey unit 01 I 11 are provided as part of this Response.
- ~
- Un *
- Page 40 of l 09 U1bc 11**1&ourc:c 1upoa1c co*1 tall 0*1uk 0 11be ut11bM*cd
- ac:cqnabr ~1po*1e rH1,c,... ~o),therl "t 1rw.eaddi110nalsoure.
- acctp1able ttspou.u rau1c (-20). tti!'n initiate three additional,ource connls, lfnlofthc 3 addthonalio uN:c chccb fa llwrhi1 the a ccpUtbk response range. then the opcratb nalresponsc check is satisfactory. !f I of the 3 additionahource counts fals outside of the acceptable response ran!e, tben initiate laddffionalsourcc count. lftbe additional source check. falls \\\\itbin 1he !'lcceptablc response rnnge. then the
- nsat isfact ory Techuiciru A. Simon Date 12/812017 Tim<9:30 Post-Work Instnanent Response Check:
- line location 9.5" I loffl'Dntal Inn
- Ultll,COWll)'GISO.,.
- 42. Also provide information on the location ofboth sample L1-12112A-FQGS-014-SS and the scan alarms in rows 41 and 42 in relation to the scan alarms. If the scan alarms did not identify the particle observed in sample L 1-12112A-FQGS-014-SS and/or the elevated area observed by ORISE, provide information on the reason that the scan might have missed the particles.
- 2 12 Syste:rs5c S rroles lnvestigatbnal Measuretl'ent
- s
- u"" C:.r,:;* GS Dl,:t Date Sam kl taken: 01 l1&'2019 Drawing:
- Sa p'a IM The scan alarms in rows 41 and 42 identified by ZS were in similar location in which ORISE identified elevated measurements. The cause of the elevated measurements in these locations were due to NORM and not DRPs as discussed in further detail in the RAJ # 1 0a response. A DRP of source strength similar in nature as to that identified in soil sample Ll-12112A-FQGS-014-SS would not have been identified during scans as it would be below the MDA of the detector as discussed in further detail in the RAJ # 11 a response.
- of Scan Unit Row (cpm)
- -Corrective actions, when identified, were implemented in a timely manner and were determined to be effective.
- realistic, and Co-60 is not recommended for use to demonstrate agreement. As a note, positively detected concentrations of Co-60 were documented for both the, standard and QC sample on the
- 2. 16E-02 6.71 0.5-2.0 6.68E-02 l.44E-01 2.17 No LI - I 02038-FSGS-005-SS Ll-102038-FQGS-005-SS 102038 East Training Area 4
- 9. 13E-O I 16.43 0.6-1.66 I.S6E+ol 9.33E-01 0.96 Yes LI-10203E-FSGS-00i-SS Ll-10203E-FQGS-OOI-SS K-40 5.49E-+-OO 4.49E-01 12.23 0.6-1.66 4.65E+OO 3.93E-OI 1.18 Yes l0203E F.ast Train~ Area 3
- 5. 19E-01 13.20 0.6-1.66 6.94E-+-OO 5.27E-0 1 0.99 Yes LI - I 0204A-FSGS-009-SS Ll-10204A-FQGS-009-SS K-40 2.97E-+-OO
- 3. I 7E-01 9.37 0.6-1.66 3.50E-+-00 3.46E-01 0.85 Yes 10204A North Gate Area 4
- 0. 75-1.33 8.62E-+-OO 5.54E-OI 1.03 Yes 102048 North Gate Area 4
- 0. 75-1.33 6.17E+OO 3.71&01 1.05 Yes Ll-102201-FSG -006-SS LI-I 02201-FQGS-006-SS K-40 5.87E+oo 4.50E-01 13.04 0.6-1.66 6.80E+oo ~
- 0. 75-1.33 7.26E+OO 4.51&01 1.03 Yes Ll-1 022 1A-FJGS-OOI-SS Ll-10221A-QJGS-OOI-SS K-40 7.94E+oo 5.58E-01 14.23 0.6-1.66 4.97E+oo 4.02&01 1.60 Yes I0221A Soti.h of Protected Area - lnlard 4
- 0. 75-1.33 9.45E+OO 5.88E-Ol 1.01 Yes 12107 South HalfofFuel & AUXIliary Buildings 4
- 0. 75-1.33 7.29E+OO 5.16E-O I 1.08 Yes 1211 2 Unit I PWSTISST Area West No Cs-137 NIA 5.48E-02 2.75E-02 1.99 3.02E-02 1.87E-02 1.81 No Ll-121 I2A-FIGS-002-SS Ll-121 12A-QIGS-002-SS K-40 l.61E+Ol l.62E+oo 9.94 0.6-1.66 1.73E+OI l.66E+OO 0.93 Yes 12113 Unit I PWSTISST Area West 3
- 6. IOE-0 1 14.51 0.6-1.66 9.9 IE+OO 6.54E-Ol 0.89 Yes 1220IC North Protected Area Yard 4
- 0. 75-1.33 l.OIE+Ol 5.67E-01 1.47 No Cs-137 2.67E-02 8.57E-03 3.12 NIA 3.17E-02 7.94E-03 0.84 No Ll - l2203A-FIGS-O IO-SS Ll-12203A-QIGS-O I 0-SS 12203A Under Service Buiding and Smtheast Yard 4
- 0. 75-1.33 9.81E+OO 5.12E-OI 0.80 Yes Ll-12203A-FIGS-001-SB Ll-12203A-QIGS-OOI-SB K-40 l.63E+Ol 9.18E-Ol 17.76
- 0. 75-1.33 l.48E+OI 9.l lE-01 1.10 Yes LI-l 2203A-FIGS-O 14-SS Cs-137 8.13E-02
- l. 19E-02 6.83 0.5-2.0 2.40E-02 7.SOE-03 3.39 Yes Ll-12203A-QIGS-014-SS K-40 5.54E+OO 3.37E-OI 16.44 0.75-1.33 6.36E+OO 3.79E-Ol 0.87 Yes 122038 Under Service Building and Sol.theast Yard Yes LI -122038-FSGS-004-SS Ll-122038-FQGS-004-SS K-40 3.70E+OO 3.54E-Ol 10.45 0.6-1.66 4.52E+OO 3.68E-Ol 0.82 Yes 12203C Under Service Building and Sol.theast Yard Yes Ll-12203C-FSGS-007-SS LI-12203C-FQGS-007-SS K-40 7.0SE+OO 5.14E-OI 13.72 0.6-1.66 7.66E+OO 5.38E-Ol 0.92 Yes 12203D Under Service Buiding and Smtheast Yard Yes Ll-12203D-FSGS-004-SS Ll - I 2203D-FQGS-004-SS K-40 8.21E+OO 5.93E-Ol 13.84 0.6-1.66 9.24E+OO 5.9 IE-Ol 0.89 Yes Page 99 of 109
- l. 14E-02 1.40 Yes 6.42E-Ol 0.99 Yes 5.95E-01 0.97 Yes 6.34E-01 0.97 Yes 6.l8E-01 1.16 Yes 6.56E-01 0.93 Yes 5.52E-OI 1.05 Yes 5.6IE-0I 1.02 Yes
- 2 (Additional NRC Questions on Zion FSS Reports -October 8, 2020 Conference Call).
- 2 (Additional NRC Questions on Zion FSS Reports -October 8, 2020 Conference Call) and NRC RAl Question #13b.
- 2 (Additional NRC Questions on Zion FSS Reports -October 8, 2020 Conference Call) and NRC RAJ Question #13b.
- Control Limit evaluated Limit_
- 1. Remove large rocks, vegetation, and foreign materials, and break the remainder into small clumps.
- 2. Place a sufficient amount of sample into a clean sample-drying container.
- 3. Dry the sample using a drying oven until all visible traces of moisture are removed (typically 6 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />).
- 4. Break the blend into a fine homogeneous mixture and transfer into an approved container (typically a 1-liter Marinelli), after determining the sample mass, for gamma spectroscopy.
- 1. From the split sample collected at the site, the sample is packaged and sent to the laboratory with no sample preparation.
- 2. If the analysis of volatile radionuclides (i.e., H-3, Tc-99, or 1-129) is requested, then thoroughly mix the sample and remove approximately 50 grams for separate processing and analysis.
- 3. For soil samples that require drying, determine the sample mass and transfer to a drying pan.
- 4. Place samples into a pre-heated drying oven at 104 degrees Celsius for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or until dry and re-weigh after drying.
- 5. Using a pulverizer, pulverize each sample to the appropriate mash size, unless other instructions are given from the laboratory manager.
- 6. After pulverization, blend each sample until homogeneous.
- 7. Transfer each sample into a container close to the standard counting geometry (volume and mass). Weigh each sample and proceed with gamma spectroscopy.
- 1. The LT/FSS Manager and Director of Radiological Site Closure will be the primary authors of Chapter 5 of the LTPs for all future EnergySolutions projects to ensure the FSS Page 108 of 109
- 2. EnergySolutiom will divide final reports into smaller, more concise reports with fewer release records for ease ofNRC reviews.
- 3. The release record and final report review process will be modified to provide more detailed focus on both editorial and technical errors.
- 4. Independent third-party reviewers will be utilized as part of the release record and final report review process.
- 5. To promote the goals of readability and consistency when writing L TPs, survey unit release records, and FSS final reports, EnergySolutions will follow the guidance provided in NUREG-1379, NRC Editorial Style Guide.
- 6. Any references to meeting the intent of the LTP have been deleted and replaced with language depicting results and language demonstrating compliance with the criteria in 10 CFR Part 20, Subpart E.
Background
RPTF Instrument Lab BACKGROUND DETERMIN ATION Cal Due Date: 4/12/2018 Cal Due Date: 4/1212018 Count Time (lb) i;;,P.;;.o.;;.;si;.;.;ti.c.on;;.....#c...l ---,------+P
__ o--s_it--io_n_#_2 __ r-------t-Po_s_it_io_n_#_3 __ -r---------l minutes counts c
counts c
counts C m 10 2130 213 2090 209 2127 213 Mean Back~
212 cpm (BR) Mean Background +20% -"2-'-54 ____ cpm Mean Ba~
round -20"/o _1""69 ____ cpm EFFICIENCY FACTOR DETERMINATION Source information Isotope* Cs-137 Serial No* 1599 1 Activity 3 02E-08 Ci Count Time Count Time (min)
Gross Counts Gross cpm Netcpm (min)
Gross Counts Gross cpm Net com I
I 496 496 284 16 I
482 482 270 2
I 550 550 338 17 I
520 520 308 3
I 510 510 298 18 I
540 540 328 4
I 511 511 299 19 I
501 501 289 5
I 502 502 290 20 I
503 503 291 6
I 501 501 289 21 I
503 503 291 7
I 517 517 305 22 I
510 510 298 8
I 517 517 305 23 I
524 524 312 9
I 520 520 308 24 I
554 554 342 10 I
487 487 275 25 I
561 561 349 II I
532 532 320 26 I
482 482 270 12 I
480 480 268 27 I
487 487 275 13 I
506 506 294 28 I
563 563 351 14 I
465 465 253 29 I
495 495 283 15 I
497 497 285 30 I
475 475 263 Efficiency Factor Determination Mean Source SER EITiciency Factor Net crrn Standard Deviation
+2u value
-2u value (dpm) 298 25 349 248 67044 Performed by:..:.A.;.;.n;.:;to"'n...::Sc.:.im"'o"'n ________________________ _
Approved by:....:G:;.;..*..;.W;..;ood Page 39 of 109 (Mean Net cpm/dpm) 0.0044 Date 12/6/20 I 7 Date 12/6/2017
ZionSolutions, LLC ZS-2021-000 I Response to Request for Additional Information Related to the Final Status Survey Reports ZS-LT-300-001-006, ATTACHMENT 2: DOCUMENTATION FROM FSS PACKAGE 01111 PRE-WORK Detector Type:
Date:
44-159 7/2017 Tune:
15* 0 crial o.:
PR..12789 al Date:
2017 al Due Dmc:
201 Data Logger Type:
2350-1 Datn Logger rial 30471 nl Date:
2017 Cal Due Dn1e:
2018 Pipe ize: _I_.-_ in able Length: --12Q._ fl Bockgroiuid RPTF Instrument Lnb PRE-WORK BAC.:KGRO, D CH[ K ccptable Ba kgr 1D1d Range (from Auacm.,,t ll ~ 200/4.lL:__ pm
-20% 169.25 pm Initial Ba ount OlDll #
COlDll Tine (tb mil) initial JO I I p t C*\\\\ rl. b,cJ,;:@fo1a1d\\\\.1lhm th, acceptable range?
l I m~u pre,..\\\\t>rk blckpom d
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o D C01lll )
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Mll IM M DETECT BL[ COUNT RATE (MDCR):
3+3_9~
MDCR yv,** '\\' T,_'
B R __ cpm "18\\
Count II 2
3 Count Tine (tb) min COllltS can Background (BR)~---~
10 min 49.64 pm PRE-WORK OUR urcc inJi nuation crial o: __
__;1.c..599-~"'"6-
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Activity __ -...a*.;.;*02=E-- ;.;;... __
Initial Additional 2
2o value:
349 cpm
-2o value:
248 cpn
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ZionSolutions, LLC ZS-2021-000 I Response to Request for Additional Information Related to the Final Status Survey Reports POT-WORK Date: 12/8/2017 Time:
9:30 POST-WORK BACKGROU D CHECK Acceptable Background Range (from A11ncmer11 1 l ~ 20% 253.88 cptn
-20%
169.25 Cptll ount #
11111 10 I. Is P<<'*"~rk bactirot11d \\\\;1 hm I he acceptable ran,:r?
2 I ""'"° pn,-m,rk bo<kJttomd
\\\\Uhiu 1he acceptrible raoJ=,e.,
count 1762 Yes @ No D Ye 0 No 0 C
(BR 176.2 oddi11on:1I bod;:1round CO\\Dlls)
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re:1 ons for c.hAn~ HJ IJnCkl'fOl.1(1)
PO T-WORK SOURCE RESPO SE CHECK Additional Buck1troU11d Counts (if necessary)
Count l'me (tb)
Count II-(mm) counts com (BR)
I 2
3 Mean Backgrmu1d (BR)
Source infom1:1tio11 I otope: ____
c_*_-_13_7 ___
erial No:
1599-36-1 Activity 3.02E-08 Ci i\\cccptablc Response Rnnge (from 11 achm,nt I)
Menn ct cpm: 298. 1333 cpm
+2a vah.tc: __
34_9 __ cpm
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2_4 __ cpm JI Initial Count Time mm Gross count*
Gross c 507 507 A dd..
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NIA 2
1 NIA 3
1 NIA Sat 0 NIA Sat D NIA Sat D NIA Sat D Un""t O Unsat 0 Unsat 0 Unsat 0 ll'tllc 111l,01.11ce1c po11,ccom1tfitlk o u1sldconhcuh'lb lllcd
~-4-~---~~---~--N_ IA __...__N_/_A _ __.! Sat O Unsat 0 COMMENTS ope ratio nalresponse check is satisfae10 ryand the detector maybe used. If more than lo fthe 3 addlbnal sourcc checks fa I outside of the acceptable response range. or iftbe sin~ lc additional source check falls ou1silc of the acceptable res po nsc range. then place the detector out of service.
Del eel or/Data Lo!'l'er Assembly Physical lnspec1i, Sal isfact ory 0 'nsal is factory T eclmiciat A. Simon Dale 12/6/2017 Tim< 1530 Pre-Work Detector BackP'ound Determination:
Satisfactory 0 'nsatisfectory Tcchniciat A. Simon Dale 12/61201 7 Tim, 1530 Pre-Work Instrument Response Check:
Satisfactory 0 nsat is factory D Tech1tici111 A. Simon Dale 12/6/2017 Tim, 1530 Post-Work Detector Back!tfotud Determination:
Sat is factory 0
Satisfactory 0 usat isfact ory TcclmiciaJ A. Simon Dale 12/8/2017 Tim,9:30 Approved by: GWood Date 12/612017 Page 41 of 109
ZionSolutions, LLC ZS-2021-000 I Response to Request for Additional Information Related to the Final Status Survey Reports ZS-LT-300-001-006, ATTACHMENT 3: DOCUMENTATION FROM FSS PACKAGE 01111 Date:
.c.;12/cc....c...8/20=-c..lc....c7 __
Timc:
1:52 Building:
Ul CTMT Elevation:
56_5' __ Acccss Point Arca: ___ C_f_M_T_Brid_* ~g~e _
Sys tem:
1.n O>re SullJ>
Pipe Diameter.
_ _ l_.5 ___ in.
Pipe #:
Pl25 Type o f Survey Investigation O O,aracteri7ation O
Buried O FSS Detector:
44-159 Detector ID H:
PR327895 Cal Date:
5/2/7JJl7 C'.al Due Date:
4/11/2018 Data l.ogger:
23>>.l Data Logger ID #: _304 7_1_3 ______ _
Cal Date:
4/12/2017 Cable Length:
150 ft.
__ 4_9_.64 __ cpm Efficiency Factor for Pipe Diameter Cal Due Date:
4/11/7JJl8 (taken from Attachment 2) 0.0044 (taken from Attachment I)
MDCsu,.;c 11281.82 dpm/fool of pipe Sample Count Time (Is) min (s the MDCatalic acceptable?
Yes @
No O (ifno, Mjllll._plec:ounttime.,drecalculate MJ>Cll Comments: The (intreadin location wu on tbesu were lalcen in the vertical
&. the other 21 Pipe Interior Raclologkal S nYy Radiolog.ical Survey Commenced: Date:
12/7/2017 Time:
19:15 Radiological Survc..-y lncn:menl Fn:qucncy:
One mcuun;mc.."Dt for every feel of pipe surveyed Sample cet into Count Time ffe,:ti\\ C A cli\\'it /
Pipe from (I,)
Arca Area Position #
Opening (min)
Gross Counts Gross cpm dpm (m2)
(pCi/m2)
Zero 0
l 111666 111666 25378636 0.036 3.13E+-08 1
1 1
16907 16907 3842500 0.036 4.74E+-07 2
2 1
3561 3561 809318 0.036 9.98E+-06 3
3 1
1589 1589 361136 0.036 4.4SE+-06 4
4 1
1557 1557 353864 0.036 4.361,-(16 5
5 I
1232 1232 280000 0.036 3.4SE+-06 6
6 1
1229 1229 279318 0.036 3.4SE+-06 60C 6
1 1185 1185 269318 0.036 3.3:zHt-06 7
7 1
1170 1170 265909 0.036 3.28E+-06 8
8 1
1056 1056 240000 0.036 2.96E+06 9
9 1
910 910 206818 0.036 2.SSE+-06 10 10 1
10l3 10l3 230227 0.036 2.84E+06 11 11 1
849 849 192955 0.036 2.38Bt-06 12 12 1
750 750 170455 0.036 2.100+-06 120C 12 l
760 7(,()
172727 0.036 2.13B-06 13 13 1
740 740 168182 0.036 2.07E+06 14 14 1
642 642 145909 0.036 l.80E+-06 15 15 l
652 652 148182 0.036 1.83B-06 16 16 l
795 795 180682 0.036 2.23B-06 17 17 1
875 875 198864 0.036 2.45B-06 18 18 1
1021 1021 232045 0.036 2.86E+06 19 19 l
842 842 191364 0.036 2.36E+-06
]JJ 20 1
1()40 1040 236364 0.036 2.92E+06 200C 20 1
1486 1486 337727 0.036 4.17B-06 21 21 1
3817 3817 867500 0.036 l.07E+07 22 22 l
1712 1712 389091 0.036 4.800+-06 Page 42 of 109
ZionSolutions, LLC ZS-2021-000 I Response to Request for Additional Information Related to the Final Status Survey Reports Pipe Interior Sunt>y Completion Radiological Survey Completed: Date:
12/7/2017 Time: __ 2_0_:0_7 __
Length of Pipe Surveyed and the umber of Bends:
22 feet in, 90° elbow nexpected Condition Encountered ( pecify any ob truction encountered or other re uhs that may impac future work):
one Did the equipment work properly?
Yes ~
No 0 (if"no", explain below)
Summary of Radiological Conditions (include average radiological results and any hot spot location(s) encountered: Gunna Scan Range: 642 to 16,907 cpm Suivey Completed By:
Jose A Torres 12/8/2017 (Print rune)
(Signature)
(Date & Time)
K. Long-Holt 12/8/2017 (Print Name)
(Signature)
(Date & Time)
(Print Name)
(Signature)
(Date & Time)
Suivey Reviewed By:
Vicki Bald win 12/19/2017 (Print Natlle)
(Signature)
(Date & Time)
Page 43 of I 09
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports The "Activity/Area" value represents a gross gamma measurement in units of pCi/m2* The radionuclide mixture within the pipe assumes the distribution for Containment from LTP Chapter 5, Table 5-2. To express the concentrations of the other gamma-emitting ROC, the Containment mixture from Table 5-2 was normalized to include only the gamma-emitting ROC. The ratios for inferring HTD ROCs are taken from the maximum ratios from LTP Chapter 5, Table 5-15.
This is illustrated in the following table.
Containment Mixtures and Ratios (LTP Chapter 5, Table 5-2 and Table 5-15)
CTMTBldg Normali7.ed Nuclide Gamma HTD Ratios Mixture Mixture r
0.08%
1.76 ]
o-60 4.72%
6.43%
i-63 26.50%
442 Sr-90 0.03%
0.021 Cs-134 0.01%
0.01%
I Cs-137 68.17%
92.87%
Eu-152 0.44%
0.60%
Eu-154 0.06%
0.08%
The gross gamma value for each measurement was then multiplied by each applicable mixture percentage to derive specific concentrations for each gamma-emitting ROC. The resultant concentration for Co-60 was then multiplied by the maximum ratio to derive a concentration for Ni-63, and the resultant concentration for Cs-137 was then multiplied by the maximum ratio to derive a concentration for H-3 and Sr-90.
NRC RAJ Question #6b Provide additional information on the location of the elevated measurement near the opening of the pipe, and any ALARA measures that may have been taken to evaluate or reduce activity of the elevated area within the pipe system.
RESPONSE: The elevated measurement was located 6 inches from the opening of the pipe and six inches from the 90-degree elbow. No additional ALARA measures were specifically applied to the pipe itself; however, it should be noted that a significant volume of concrete was remediated and removed from the Unit 1 Containment Under-Vessel area following the performance of this survey. In addition, the pipe was completely grouted. The discussion regarding the as-left condition of the pipe is provided in the response to NRC RAI Question #2a.
NRC RAJ Question #6c Check the values presented in Attachment 2 and provide the raw measurement data if available. Provide a revised release record for this survey unit with corrected information if errors are confirmed in Attachment 2.
Page 44 of 109
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports RESPONSE: The value listed in Attachment 2 for the BcSOF for measurement Sl-0111 IAF-SSM-002-GD is incorrect. The BcSOF value of 0.464, presented in the submitted release record, should be 0.070. A review of the data concluded the value in the spreadsheet used to generate was correct, and that correct values were used in the calculation of statistical values. Please note that it was the only error identified in Attachment 2 as the other data presented was verified correct. ZionSolutions has provided a revised release record for survey unit O 1111 with a corrected Attachment 2.
Supplemental or Revised Documentation: Revised Release Record for survey unit O 1111.
NRC RAJ Question #7a Clarify under what circumstances the licensee decided to perform FSS of excavated and remediated soil prior to placing clean backfill versus only performing post-remediation or RASS surveys.
RESPONSE: LTP Chapter 5, section 5.7.1.6 states, "Any soil excavation created to expose or remove a potentially contaminated subgrade basement structure will be subjected to FSS prior to backfill. The FSS will be designed as an open land survey using the classification of the removed structure in accordance with section 5.6.4 of the L TP using the Operational DCGLs for subsurface soils as the release criteria." The only potentially contaminated sub-grade basement that was exposed by excavation at Zion was the bottom of the Spent Fuel Pool which was uncovered for the demolition of the Fuel Handling Building (FHB) and Car Shed. Consequently, in accordance with section 5.7.1.6, an FSS was performed of the excavation prior to backfill.
The sub-grade soil beneath the FHB was divided into three (3) Class 1 survey units (12105K, 12106K, and 12107K). The results of the FSS performed in these three survey units are provided as addendums to the release records for survey units 12105, 12106, and 12107.
NRC RAJ Question #7b The licensee should clarify if the subsurface access-interfering structures (e.g., Waste Annex Building) that were removed to expose soil in Survey Units 12109 and 12110 classify as 'potentially contaminated sub-grade basement structures' according to the LTP Section 5.7.1.6. If they do, the licensee should provide a reason for why the FSS was not performed on the excavation prior to backfilling with clean soil.
RESPONSE: The other subsurface access-interfering structures cited in survey units 12109 and 12110, such as the Waste Handling Annex, were on-grade concrete slabs with no sub-grade basements; therefore, they were not subject to the FSS requirement of L TP Section 5. 7.1.6.
When the slab was removed, the resultant shallow depression was scanned and surveyed under an RA in accordance with LTP Section 5.4.1. Backfilling was performed after the NRC did not object to backfilling subject to FSS results.
Page 45 of 109
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports NRC RAI Question #7c For the land survey units that had an FSS performed on a sub-grade soil excavation, the dose from the sub-grade excavation should be accounted for when determining the total compliance dose.
RESPONSE: As stated in the response to NRC RAI Question #7a, the only sub-grade soil excavation that underwent FSS (as per LTP Section 5.7.1.6 requirements) was the soil beneath the FHB (survey units 12105K, 12106K, 12107K). Although the results of the FSS were provided as addendums to the release records for survey units 12105, 12106, and 12107, dose was not attributed to these three soil sub-grade survey units. Consequently, a dose assessment was performed in accordance with LTP Section 5.2.14, and the results are summarized in the table below. Note that the investigational samples with OpSOF greater than one (L 1-12106K-FIGS-005-SB, Ll-12106K-FIGS-008-SB, Ll-12106K-FIGS-010-SB) were not included in the dose calculation. The small, elevated areas where these samples originated were remediated and verified by follow-up samples to have activities below the OpDCGL. Although these three samples were remediated, they were inadvertently included in the judgmental/investigational data set within the release record but should not have been.
Survey Unit MeanBcSOF Dose (mrem/yr) 12105K 0.020 0.509 12106K 0.041 1.016 12107K 0.040 0.992 This response serves as addendums to the release records for survey units 12105, 12106, and 12107 and the Phase 4 Final Report. Additionally, Table 9 on Attachment, "Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License," to ZS-2020-0011 has been revised as follows:
Survey Units 12105K, 12106K, and 12107K were added to Table 5 -Phase 4 Survey Units, as separate land area (soil) survey units.
Survey Units 12105K, 12106K, and 12107K were added to Table 9-Mean BcSOF Values for Soil, to include the mean BcSOF and dose contributions from the survey units.
Because the mean BcSOF for Survey Unit 12106K (0.041) is larger than the previous maximum BcSOF for Survey Unit 12203A, this value was used for the variable "Max BcSOFsorr.,) in the compliance equation (Equation 3).
Equation 4 was revised to include the change to the "Max BcSOFsorr.," (0.041). This increased the final dose summation for the site from 17.781 mrem/year to 17.8 mrem/year.
Page 46 of 109
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports Supplemental or Revised Documentation: "Subsurface Soil PSS Dose" spreadsheet NRC RAJ Question #7d The licensee should revise the release records for Survey Units 12109 and 12110 to include the post-remediation survey data for that was performed in accordance with section 5.4.2 of the LTP. The revised release record should show how the RASS scans meet the DQOs of the PSS and how the data collected as part of the RASS is sufficient for NRC to have reasonable assurance that the performance objectives are met. The data should include any analysis for HTDs or insignificant radionuclides in samples that were acquired during the post-remediation surveys.
RESPONSE: As stated in the response to NRC RAI Question #7a, the only sub-grade soil excavation that underwent PSS (as per LTP Section 5.7.1.6 requirements) was the soil beneath the FHB. Because a major sub-grade structure was not removed in survey units 12109 and 12110, the requirements ofLTP Section 5.7.1.6 are not applicable.
A RASS as described in LTP Section 5.4.2 was not performed in survey units 12109 and 12110.
Rather, an RA was performed in accordance with L TP Section 5.4.1 prior to backfill. During the RA, a gamma scan survey was performed over 100% of the surfaces in the excavations. The scans were performed using the same instrumentation, survey methodologies, and alarm setpoints that would have been used during an PSS, thus meeting the DQOs of PSS.
Ten (10) soil samples were obtained in each survey unit prior to backfill. The following table presents the radionuclide concentrations, MDC, and SOP as compared to the subsurface soil OpDCGLs for the 20 samples collected prior to backfill in survey units 12109 and 12110. This information is recreated from the "12000 A 09 1st REMED 2 NRC" and "12000 A 09 2nd REMED 2 NRC" tables in the Power Block RA Readiness Review."
Page 4 7 ofl 09
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports Sample ID Co-60 (pCi/g)
Cs-134 (pCl/g)
Cs-137(pCl/g)
OpSOF Result MDC MDC Result MDC Ll-12109A-RIGS-017-SB
<MDC 6.23E-02 5.37E-02 5.69E-02 4.07E-02 0.20 Ll-12109A-RIGS-018-SB
<MDC 3.18E-02 4.00E-02
<MDC 4.23E-02 0.12 Ll-12109A-RIGS-019-SB
<MDC 5.09E-02 5.43E-02
<MDC 5.62E-02 0.18 Ll-12109A-RIGS-020-SB
<MDC 4.53E-02 5.93E-02
<MDC 4.32E-02 0.17 Ll-12109A-RIGS-021-SB
<MDC 4.64E-02 3.75E-02
<MDC 4.73E-02 0.15 Ll-12109A-RIGS-022-SB
<MDC 4.94E-02 5.98E-02 9.81E-02 6.61E-02 0.20 Ll-12109A-RIGS-023-SB
<MDC 5.67E-02 5.77E-02
<MDC 5.77E-02 0.20 Ll-12109A-RIGS-024-SB
<MDC 5.00E-02 4.64E-02
<MDC 4.57E-02 0.17 L 1-12109 A-RI GS-025-SB
<MDC 4.63E-02 4.88E-02
<MDC 5.14E-02 0.16 Ll-12109A-RIGS-026-SB
<MDC 3.44E-02 3.91E-02
<MDC 3.88E-02 0.12 Ll-121 IOA-RIGS-034-SB
<MDC 5.85E-02 8.30E-02
<MDC 8.05E-02 0.23 Ll-121 IOA-RIGS-035-SB
<MDC 7.27E-02 7.70E-02
<MDC 7.57E-02 0.26 Ll-121 IOA-RIGS-036-SB
<MDC 6.75E-02 7.83E-02 1.50E-01 9.96E-02 0.28 Ll-121 IOA-RIGS-037-SB
<MDC 7.87E-02 7.87E-02
<MDC 7.13E-02 0.23 Ll-121 IOA-RIGS-038-SB
<MDC 6.54E-02 6.39E-02
<MDC 7.35E-02 0.23 Ll-121 IOA-RIGS-039-SB
<MDC 5.69E-02 6.18E-02
<MDC 5.70E-02 0.20 Ll-121 IOA-RIGS-040-SB
<MDC 5.74E-02 5.12E-02
<MDC 5.16E-02 0.19 Ll-121 IOA-RIGS-041-SB
<MDC 5.88E-02 5.59E-02
<MDC 7.02E-02 0.21 Ll-121 IOA-RIGS-042-SB
<MDC 5.32E-02 5.09E-02
<MDC 6.70E-02 0.19 Ll-121 IOA-RIGS-043-SB
<MDC 7.08E-02 7.16E-02
<MDC 7.31E-02 0.25 The required number of samples for the RA was selected in accordance with ZS-LT-200-001-001, Radiological Assessments and Remedial Action Support Surveys." Cs-137 was positively identified in 3 of the 20 samples, with a maximum concentration of l.50E-0 1 pCi/g. No other ROC were positively identified at concentrations above MDC. The maximum SOF, when compared to the OpDCGLs for subsurface soil, was 0.28. Backfilling was performed after the NRC did not object to backfilling subject to FSS results.
This response serves as addendums to the release records for survey units 12109 and 12210.
NRC RAJ Question #7e For any other survey units in Phase 3 or Phase 4 where soil remediation occurred, but the FSS took place after clean back-fill had been placed, the licensee should clarify if there were removed sub-grade basement structures removed to access those Page 48 of 109
ZionSolutior,s, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports areas. The licensee should provide the post-remediation or RASS surveys performed just prior to backfill, describe how those surveys meet the DQOs of the FSS, and provide a dose based on the post-remediation surveys.
RESPONSE: For any survey units in Phase 3 or Phase 4 where soil remediation occurred, radiological surveys were performed in accordance with ZS-L T-200-001-001, Radiological Assessments and Remedial Action Support Surveys," prior to the placement of clean backfill.
Scan surveys were performed using the same instrumentation, survey methodologies, and alarm setpoints that would have been used during an FSS, thus meeting the DQOs of FSS. The required number of samples for the RAs/RASSs were selected in accordance with ZS-L T-200-001-001.
As stated in the response to NRC RAJ Question #7a, the only sub-grade soil excavation that underwent FSS (as per L TP Section 5.7.1.6 requirements) was the soil beneath the FIIB. Because a major sub-grade structure was not removed in any other survey units, the requirements of L TP Section 5. 7.1.6 are not applicable, and the assignment of dose to the survey units is not compulsory. Data and survey documentation for RAs performed prior to backfill are provided on the enclosure to this response ("Buried Pipe RA Results" spreadsheet, "July 2019 Power Block Remediation Results" spreadsheet, Power Block RA Readiness Review," and Power Block RA Report Attachments).
NRC RAI Question #8a Provide additional information on any land survey unit where buried piping or subgrade piping systems were removed that required subsurface remediation before FSS (e.g., WWTP subsurface piping), including the results of the post-remediation surveys.
RESPONSE: From March 2017 through June 2019, a significant amount of buried pipe was excavated and removed from various soil areas around the Zion site. While low levels of contamination were found in several pipes after they were removed, most of the pipe removed was uncontaminated drain pipe servicing storm drains and rainwater run-off from building exteriors. The contamination event cited for survey unit 12112 was the only instance of cross-contamination of soils caused by the removal of buried pipe. It should be noted that the remediation of the cross-contaminated soil in survey unit 12112 was performed manually and not by excavation.
Section 5.7.1.7 ofLTP Chapter 5 states, "ZSRP will not stockpile and store excavated soil for reuse as backfill in basements. However, overburden soils will be created to expose buried components (e.g. concrete pads, buried pipe, buried conduit, etc.) that will be removed and disposed of as waste or to install a new buried system. In these cases, the overburden soil will be removed, the component will be removed or installed, and the overburden soil will be replaced back into the excavation. In these cases, a RA will be performed. The footprint of the excavation, and areas adjacent to the excavation where the soil will be staged, will be scanned prior to the excavation. In addition, periodic scans will be performed on the soil as it is excavated, and the exposed surfaces of the excavated soil will be scanned after it is piled next to Page 49 of 109
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports the excavation for reuse. Scanning will be performed in accordance with section 5.7.1.5.1. A soil sample will be acquired at any scan location that indicates activity in excess of 50% of the soil Operational DCGL. Any soil confirmed as containing residual radioactivity at concentrations exceeding 50% of the soil Operational DCGL will not be used to backfill the excavation and will be disposed of as waste."
All radiological surveys performed to evaluate soils from the excavations of buried pipe, including the grade footprint of the excavation, the grade footprint of the overburden laydown area, the bottom and sidewalls of the excavation, and acceptability of the overburden to be used to eventually backfill the excavation were performed in accordance with L TP Chapter 5, section 5.7.1.7. RAs were designed, evaluated and documented in accordance with ZionSolutions procedure ZS-L T-200-001-001, Radiological Assessments and Remedial Action Support Surveys." For all media sampling performed to evaluate excavation soils, the OpDCGLs for subsurface soils from L TP Chapter 5, Table 5-8 were used as the action level. The action level for scanning was set at the MDCR of the instrument plus background. The instrument and data quality requirements specified in procedure ZS-L T-200-001-001 for the performance of an RA are the same instrument and data quality requirements required for the performance ofFSS.
Toe RA survey design required the scanning of the footprint of the excavation, the footprint of the area where the excavated overburden would be placed, and the periodic scanning of the material in the excavator bucket as it was removed from the excavation. When complete, if the excavation could be accessed safely, then the exposed surfaces within the excavation were also scanned. If not, then the excavator was used to acquire soil samples from the bottom and sides of the excavation at a typical frequency of approximately one sample every 10 feet. The results were documented in the applicable RA.
A graphic depicting the approximate locations of the buried pipe that was removed, broken into seven areas, is provided below. On the enclosure to this response, ZionSolutions has provided the spreadsheet documenting the soil sample analysis results for all soil samples acquired to assess the acceptability of excavation overburden prior to backfill into the excavation from which it was obtained.
Supplemental or Revised Documentation: Buried Pipe RA Results" spreadsheet Page 50 of 109
ZionSolutions, LLC ZS-2021-000 I Response to Request for Additional Information Related to the Final Status Survey Reports Page 5 I of I 09 Buried Pipe Removal Area*
HAOI.J.1.&M,,.,_,.Ent f2'01(.,._fl}
1011MNll
Date 01,. 20
ZionSolutions, LLC ZS-2021-000 I Response to Request for Additional Information Related to the Final Status Survey Reports NRC RAI Question #Sb For Survey Unit 102200, provide the source of the radioactive particle and describe why it was located subsurface.
RESPONSE: The particle found was not located in subsurface soil. It was detected in the footprint of an impending excavation on the surface. Please see response to NRC Question #4 for additional details (NRC Questions on Zion FSS Reports - October I, 2020 Conference Call).
The source of particles in soil at Zion is discussed in our response to NRC RAI Question# 11 b.
NRC Supplemental RAI Question #8 (December 17, 2020) The response states that, "ZSRP was required to solicit permission from the NRC prior to backfilling any excavation. Permission was typically solicited through e-mail correspondence from ZSRP to the NRC with an attached letter detailing the location of the excavation, the purpose, the results of scanning, and soil sample analysis from the RA. Until regulatory permission was received, excavations were not backfilled and remained open." Staff note that the example of the correspondence provided in the response is an internal memo from the Zion Rad Engineer to the Zion Licensing Manager as opposed to an example ofNRC correspondence permitting backfill. Regardless, any permission to backfill from NRC during decommissioning is "at-risk" and is not commensurate with release of the survey unit. The licensee still needs to provide a technical basis in the release record that the survey unit meets the release criteria, including excavated or remediated areas that have been backfilled. Staff are requesting the post-remediation surveys where buried piping was removed to be submitted formally to demonstrate that the site meets the release criteria.
RESPONSE: From late 2017 until July 2019, ZSRP was required to solicit permission from the NRC prior to backfilling any excavation. Permission was typically solicited through e-mail correspondence from ZSRP to the NRC with an attached letter detailing the location of the excavation, the purpose, the results of scanning, and the results of soil sample analysis from the RA. Until regulatory permission was received, excavations were not backfilled and remained open. ZionSolutions understands that, regardless of any permission from NRC during decommissioning, backfilling is "at risk" and is not commensurate with release of the survey unit. Excavations created to remove buried pipe do not fall under the criteria of LTP Section 5.7.1.6; therefore, FSS was not required prior to backfill. However, as shown in the enclosed spreadsheet, the as-left survey data demonstrate that all ROC concentrations in soil are below a 0.5 OpSOF and would have passed FSS.
NRC Supplemental RAI Question #8 (December 17, 2020) LTP Section 5.7.1.7, "Reuse of Excavated Soils," states that a soil sample will be collected at any scan location with residual radioactivity in excess of 50% of the soil OpDCGL, and that any soil confirmed with concentrations exceeding 50% of the soil OpDCGL will be disposed as waste. Page 45 of states that the subsurface soil OpDCGLs were used as action levels for scans and sampling. Page 47 of Attachment 2 states the alarm set point was 90% of the subsurface OpDCGL for scans. Page 48 of Attachment 2 states that no sample locations exceeded "0.50 of Page 52 of I 09
ZionSolutions, LLC ZS-2021-000 I Response to Request for Additional Information Related to the Final Status Survey Reports the MDC" were identified. Please clarify these statements in terms of the L TP commitment to not reuse soil that is above 50% of the soil OpDCGL from excavations and describe how the scans were used to identify soils above 50% of the soil OpDCGL for sampling and possible disposition as low-level waste.
RESPONSE: L TP Section 5.7.1.7, "Reuse of Excavated Soils" specifically states "Scanning will be performed in accordance with section 5.7.1.5.1. A soil sample will be acquired at any scan location that indicates activity in excess of 50% of the soil Operational DCGL. Any soil confirmed as containing residual radioactivity at concentrations exceeding 50% of the soil Operational DCGL will not be used to backfill the excavation and will be disposed of as waste."
ZionSolutions determined the acceptability of overburden soils in accordance with Section 5.7.1.7 ofLTP Chapter 5 using the results of gamma spectroscopy analysis of soil samples.
Scanning was performed to determine biased locations for the acquisition of soil samples and not to determine acceptability. Due to the very low Operational DCGLs for subsurface soils, the alarm set point used for scanning was set at the instrument MDCR plus background. Scan measurements observed at activity greater than the instrument MDCR plus background would prompt the acquisition of a soil sample at the location identified. Overburden soil identified as containing residual radioactivity in excess of 50% of the soil Operational DCGL by gamma spectroscopy (as highlighted in the enclosed spreadsheet) was not placed back into the excavation, but rather removed and disposed of as radioactive waste.
NRC RAI Question #9a Provide a list of all survey units in which concrete debris was stored or transported through after the FSS had been completed for the survey unit.
RESPONSE: From January 2019 through June 2019, CCDD was temporarily stored in survey units 12205A, l 2205B, 12205C, 12205D, and l 2205E with the intention of eventually using this material as fill. Survey units 12112, 12113, 12203A, 12203B, 12203C, and 12203D were also impacted as they were used as staging areas and transfer paths for the movement of the CCDD.
All of the survey units cited had recently been subjected to FSS and compliance with the unrestricted release criteria was demonstrated as required by the LTP. Following the removal of the CCDD, a decision was made to re-perform the FSS in survey units 12205A, I 2205B, 12205C, 12205D, and 12205E. This decision was not prompted due to any potential radiological cross-contamination but rather, from the creation of a depression that required backfill to restore the grade. In the other survey units impacted by the storage or transfer of the CCDD (survey units 12112, 12113, 12203A, l 2203B, l 2203C, and 12203D), post-FSS special surveillances were performed in accordance with ZionSolutions procedure ZS-L T-300-001-003, "Isolation and Control for Final Status Survey" to assess any potential radiological cross-contamination.
The following documents the timeline and milestone events pertaining to the movement, storage and eventual disposition of Clean Concrete Demolition Debris (CCDD) from the demolition of Unit 1 and Unit 2 Containment structures.
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ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports May 2016 -
Aug 2016 April 2018-May 2018 July 2018-Aug 2018 Sept 2018 -
Jan 2019 Nov 2018 Jan 2019 Unconditional Release Surveys (URS) of the Unit I and Unit 2 Containment exterior concrete surfaces were performed in accordance with ZionSolutions procedure ZS-L T-400-001-001, "URS of Materials Equipment and Secondary Structures."
Performed scan survey of all exterior concrete surfaces that could safely be accessed from grade using a man-lift A foot and 1/2 of "clean fill" from off-site sources was used to cover the ground around both Containments as well as filling the Auxiliary Building and FHB basements. (Due to this act, all concrete demolition debris from the demolition of the Unit 1 and Unit 2 Containments would fall on "clean un-contaminated" soil)
Isolation and control measures specified in procedure ZS-L T-300-001-003 were established around each Containment, the Auxiliary Building and FHB to mitigate the risk of any cross-contamination.
All machinery used to demolish the Unit 1 and Unit 2 Containments were surveyed and verified as clear of plant-derived contamination.
Both Unit 1 and Unit 2 Containments were demolished as "clean" structures.
Metal and rebar were removed and the concrete debris was reduced in size.
A management decision was made to move excess CCDD from around containments into open land survey units where FSS had been successfully completed.
FSS was successfully performed in open lands survey units 12112, 12113, l 2203C, l 2203D, 12205A, 12205B, l 2205C, l 2205D, and l 2205E.
Isolation and control measures as specified in procedure ZS-L T-300-001-003 were established around each.
Commenced transfer of CCDD from areas around Containment to the base layer for storage stockpile located in survey units 12205A, 12205B, l 2205C, l 2205D, and l 2205E.
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ZionSolutions, LLC ZS-2021-000 l Response to Request for Additional Information Related to the Final Status Survey Reports Feb 2019 March 2019 FSS was successfully performed of open lands survey units 12203A and l 2203B. Isolation and control measures as specified in procedure ZS-LT-300-001-003 were established around each.
Commenced dumping ofCCDD from areas around Containment to the hard surface placed in survey units 12203B, 12203C, 12203D, 12112, and 12113.
CCDD was then pushed from the hard surface in survey units 12205A, I 2203B, l 2203C, l 2203D, 121 12, and 12113 onto the large storage pi le in survey units l 2205B, 12205C, l 2205D, and 12205E (note; this activity occurred with l&C measures in place - frisking, boundary control, technician monitoring).
Completed transfer of CCDD onto the large storage pile in survey units 12205A, 12205B, l 2205C, l 2205D, and l 2205E.
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ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports April 2019 June 2019 Project management revised the approach from potentially using the concrete debris as clean fill to disposing of the concrete as potentially contaminated waste.
CCOO hard surface removed from survey units 12203A, l 2203B, 12203C, 122030, 12112 and 12113 and placed into storage stockpile in survey units 12205A, 12205B, 12205C, 122050, and 12205E.
Following the removal of all CCOO from survey units 12203A, l 2203B, 12203C, 122030, 12112, and 12113, a walkdown and inspection was performed. It was determined that the hard-frozen soil surface prevented mixing of CCOO with the soil during the transfer process, exposing the soil grade that was previously successfully subjected to FSS. The assessment of any potential radiological cross-contamination was to be made by surveillance as per procedure.
To support shipment, the CCDO was transferred from survey units 12205A, l 2205B, 12205C, 122050, and 12205E to survey units 102148 and 10206B.
All concrete debris was loaded into rail cars at these two locations and disposed of as potentially radioactive materials.
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ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports During the movement ofCCDD to survey units 10214B and 10206B, walkdowns and inspections performed in survey units 12205A, l 2205B, 12205C, 12205D, and 12205E noted significant intermixing and deep settling of the CCDD in the survey unit footprints.
On June 18, 2019, a surveillance was performed in survey unit 12203A, located directly south and adjacent to the CCDD storage pile. The portion of the surface soil within the survey unit that was impacted by CCDD was scanned and 8 biased soil samples were acquired. Surveillance scans and soil sample analyses yielded radiological conditions consistent with FSS results for survey unit 12203A (all scans were less than investigation levels, and all soil samples were less than surface soil OpDCGLs). Also reference ES-ZION-CR-2019-0066.
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ZionSolutions, LLC ZS-2021-000 I Response to Request for Additional Information Related to the Final Status Survey Reports July 2019 On July 30, 2019, a surveillance was performed in survey unit 12112. The surface impacted by the CCDD within the survey unit was scanned and 2 biased soil samples were acquired. Surveillance scans and soil sample analyses yielded radiological conditions consistent with FSS results for survey unit 12112 (all scans were less than investigation levels, and all soil samples were less than surface soil OpDCGLs)
A walkdown and inspection was performed following the removal of all CCDD from survey units 12205A, 12205B, 12205C, 12205D, and 12205E.
Based on observations of the physical condition of these survey units, a decision was made to re-perform the FSS in survey units 12205A, 12205B, 12205C, 12205D, and 12205E. Due to intermixing and deep settling of the CCDD into the surface soil layer, removal of the CCDD had created a shallow excavated depression in the survey unit. Clean fill was imported from off-site and used to restore the grade. Condition report ES-ZlON-CR-2019-0 IO 1 was initiated to capture the schedule change and any other potential impacts.
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ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports Aug 2019 Sept 2019 Oct 2019 Nov 2019 Dec 2019 Jan 2020 On August 1, 2019, smveillances were performed in survey units 12203B, 12203C and 12203D. Between the 3 surveillances performed, the surface impacted by the CCDD within the survey units were scanned and 5 biased soil samples were acquired. Surveillance scans and soil sample analyses yielded radiological conditions consistent with PSS results for survey units 12203B, 12203C and 12203D (all scans were less than investigation levels, and all soil samples were less than surface soil OpDCGLs)
On September 6, 2019, a surveillance was performed in survey unit 12113.
The surface impacted by the CCDD within the survey unit was scanned and 2 biased soil samples were acquired. Surveillance scans and soil sample analyses yielded radiological conditions consistent with PSS results for survey unit 12113 (all scans were less than investigation levels, and all soil samples were less than surface soil OpDCGLs)
The repeat PSS of survey units 12205A, 12205B, 12205C, 12205D, and 12205E is successfully completed. The isolation and control measures that were previously implemented in January 2019 remain in effect.
All CCDD in survey unit 10206B loaded into railcars and shipped off-site as potentially contaminated waste.
The PSS of survey unit 10206B is successfully completed. Isolation and control measures as specified in procedure ZS-LT-300-001-003 were established.
All CCDD in survey unit 10214B loaded into railcars and shipped off-site as waste. At this point, all excess CCDD has been removed from site.
The PSS of survey unit 10214B is successfully completed. Isolation and control measures as specified in procedure ZS-LT-300-001-003 were established.
On January 7, 2020, a surveillance was performed in survey unit 12203D.
Biased scan surveys were performed and 4 biased soil samples were acquired. Surveillance scans and soil sample analyses yielded radiological conditions consistent with PSS results for survey unit 12203D (all scans were less than investigation levels, and all soil samples were less than surface soil OpDCGLs). Also reference ES-ZION-CR-2020-0001.
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ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports May 2020 August2020 On May 26, 2020, surveillances were performed in survey units 12113, 12203A, 12203B, 12203C and 12203D. Biased scan surveys were performed. Surveillance scans indicated radiological conditions consistent with FSS results for survey units 12113, 12203A, 12203B, 12203C, and 12203D. (all scans were less than investigation levels)
Between August and September 2020, surveillances were performed in survey units 12113, 12203A, 12203B, 12203C, and 12203D. Biased scan surveys were performed. Surveillance scans indicated radiological conditions consistent with FSS results for survey units 12113, 12203A, 12203B, 12203C and 12203D. (all scans were less than investigation levels)
Following removal of the concrete debris from the survey units, FSS was re-performed on survey units 12205A, 12205B, 12205C, 12205D, and 12205E. The radiological conditions described in the release record for each pertain to the end-state of the survey units after CCDD removal and restoring the soil to grade. The release records for survey units 12112, 12113, 12203A, 12203B, 12203C, and 12203D describes the FSS performed prior to the introduction of CCDD into these survey units; however, the radiological conditions presented in the release records were validated by several post-FSS surveillances that were performed in accordance with procedure ZS-LT-300-001-003. The FSS of survey units 10206B and 10214B were performed after the excess CCDD was removed from site.
Revised or Supplemental Documentation: CR-2019-0066, CR-2019-0101, CR-2020-0001 NRC RAI Question #9b For any survey unit in which concrete was stored on or transported through after completion of the FSS, provide details on: the amount and type of debris stored on the survey unit, remediation performed to remove the debris after completion of the FSS, surveys performed post removal of the debris, and data collected during surveys performed post-removal of the debris.
RESPONSE: The type of debris that was stored on, or transported through, the survey units discussed in the response to NRC RAJ Question #9a was CCDD generated from the demolition of Unit 1 and Unit 2 Containment exteriors. The demolition of each Containment building generated approximately 15,000 cubic yards of CCDD, for a total of 30,000 cubic yards. This equates to 57,510,000 pounds ofCCDD. After demolition, this material was transported through, or temporarily staged in, survey units 12112, 12113, 12203A, 12203B, 12203C, and 12203D.
The majority of the CCDD was temporarily placed in survey unit 12203A, located directly south and adjacent to the CCDD storage pile. The total volume of material was ultimately stored in 12205A, 12205B, 12205C, 12205D, and 12205E.
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ZionSolutions, LLC ZS-2021-000 I Response to Request for Additional Information Related to the Final Status Survey Reports Details on the remediation performed to remove the debris after completion of the FSS, surveys performed post removal of the debris, and data collected during surveys performed post-removal of the debris are provided in the responses to NRC RAJ Questions #la and #9a.
NRC RAJ Question #9c Provide revised release records which reflect the final status of the survey units for any survey unit in which concrete debris was stored on or transported through after completion of the FSS.
RESPONSE: The release records submitted by ZionSolutions to demonstrate compliance for the survey units in question represent the end-state conditions of the survey units. For the survey units in question, the radiological conditions presented in the release records were validated by several post-PSS surveillances that were performed in accordance with procedure ZS-LT-300-001-003.
NRC RAJ Question #9d Provide information on measures used to prevent the concrete debris from contaminating neighboring survey units that were already final status surveyed. Provide information on surveys performed to confirm that neighboring survey units were not contaminated from the concrete debris after FSS had been completed.
RESPONSE: Prior to demolition, the concrete domes of both Containments were surveyed twice for unconditional release in accordance with ZionSolutions procedure ZS-L T-400-001-001,
Unconditional Release Survey (URS) of Materials Equipment and Secondary Structures." The first survey was performed in September of 2016, and the survey was performed again in April of 2018. The URS results were documented in Technical Support Document 17-010 Final Report - Unconditional Release Surveys (URS) at the Zion Station Restoration Project." The surveys were performed in situ with hand-held survey instruments using a graded MARSAME approach, and Lower Limits of Detection (LLD) in the 2,500-3,000 dpm/100 cm2 range were achieved. TSD 17-010 was previously submitted to the NRC, and it was incorporated as a license condition for the approval of Revision 2 of the Zion L TP. Following completion and documentation of these surveys, in accordance with ZionSolutions approved processes and procedures for the unrestricted release of materials, the concrete was considered to be "non-radioactive" material.
To ensure the pedigree of the "non-radioactive" designation, three feet of clean sacrificial fill, imported from off-site sources, was placed over the indigenous soils surrounding the Containments. The area around both Containments were then subjected to isolation and control (I&C) measures in accordance with procedure ZS-LT-300-001-003, "Isolation and Control for Final Status Survey." These measures are designed to prevent the reintroduction of a source term into an area that has been surveyed and determined to be "non-radioactive." The measures include establishing rope boundaries, controlling personnel and equipment access into the areas Page 61 ofl 09
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports through Access Control logs, and the scanning of personnel and equipment prior to entry into the l&C area to ensure radioactive material was not introduced.
During the demolition of the Containment exteriors and the period afterwards, l&C controls ensured that no additional radioactive material was introduced into the area. As the demolition progressed, the l&C controls were merged with the I&C measures already established in survey units 12205A, 12205B, 12205C, 12205D, and 12205E, located adjacent and to the west of the Containment domes. I&C measures were also already in place around survey units 12112, 12113, 12203A, 12203B, 12203C, and 12203D as FSS was recently completed in those survey units.
I&C measures remained in place around survey units 12112, 12113, 12203A, 12203B, 12203C, 12203D, 12205A, 12205B, 12205C, 12205D, and 12205E throughout the entire time that the concrete was excavated and placed in dump trucks for transportation to survey unit 10214B for loading into railcars for disposal. The controls were suspended following the decision to ship the concrete from survey unit 10206B instead of 10214B. At that time, it made no sense to continue attempting to maintain the pedigree of the concrete as non-radioactive. As described in the response to NRC RAI Question #la, the FSSs performed in survey units 12205A, 12205B, 12205C, 12205D, and 12205E were deemed invalid and the FSSs were performed again once the concrete debris was removed from the survey units. This decision was not prompted due to any potential radiological cross-contamination but rather, from the creation of a depression that required backfill to restore the grade. In the other survey units impacted by the storage or transfer of the CCDD (survey units 12112, 12113, 12203A, 12203B, 12203C and 12203D), post-FSS special surveillances were performed in accordance with ZionSolutions procedure ZS-LT-300-001-003, Isolation and Control for Final Status Survey" to assess any potential radiological cross-contamination. The FSSs of survey units 10206B, 10214B, and all of the survey units that were in the travel path from the storage pile in survey units 12205A, 12205B, 12205C, 12205D, and 12205E to the shipping locations in survey units 10206B and 10214B were performed after the shipment of the concrete debris.
NRC RAI Question #lOa For Survey Units 10209C, 102201, 12112 and 12204A, provide information on investigations and remediation performed after the FSS was completed (including any investigations and remediation based on issues identified by ORISE) and provide the results of scans and sample analyses performed after the FSS.
RESPONSE: Confirmatory surveys were performed by ORISE in these 4 survey units in December 2019 with follow-up surveys occurring in January 2020. Section 6.1 of ORISE Report 5271-SR-08-0 states the following, Five other areas had elevated gamma radiation levels distinguishable from background: survey areas 10209C, 102201, 12112, 12113, and 12204A.
Two of the locations were localized (less than 1 square meter [m2]) and had slightly-elevated gamma radiation levels compared to surrounding gamma radiation levels, while the other three Page 62 of 109
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports locations were discrete (0.1 to 0.5 m2) and had significantly-elevated gamma radiation levels compared to surrounding gamma radiation levels."
In addition to scans, ORISE Report 5271-SR-08-0 states that 37 soil samples were taken by ORISE for the survey. Of the 37 soil samples taken, soil analysis showed only sample with residual radioactivity at concentrations more than a SOF of one when compared to the OpDCGLs. This sample was taken from survey unit 10209C. The report then states, "This judgmental sample (5271 S0075) represented the soil surrounding a piece of concrete debris that was identified as having elevated direct gamma radiation. As requested by NRC staff, the debris (collected as sample 5271S0074) was not submitted for laboratory analysis and was left with site personnel." ORISE also acquired investigation soil samples from elevated scan locations in survey units 10208A (5271S0082) and 12113 (5271S0101). The result of the soil analysis performed by ORISE on the other 2judgmental samples are presented in B.7 ofORISE Report 5271-SR-08-0. The report indicates that only Cs-137 was positively detected at concentrations greater than MDC in sample 5271 S0082 at a concentration of 8.80 E-02 pCi/g. No other ROC was positively detected at concentrations exceeding the instrument MDC. The ZionSolutions staff investigated the other 3 areas exhibiting elevated scans. The actions taken in each are described below.
10209C In survey unit 10209C, ZionSolutions collected the piece of concrete debris discovered during the confirmatory survey and initiated Condition Report ES-ZION-CR-2019-0176. The piece of concrete debris weighed 283 grams and was discovered approximately two inches below the ground surface. The collected piece of concrete was transferred to the on-site laboratory where gamma spectroscopy analysis indicated Co-60 at a concentration of2.69 E+02 pCi/sample and Cs-137 at a concentration of 1.21 E+o5 pCi/sample. The soil where the debris was found was scanned by both ORISE and ZionSolutions using a Ludlum Model 44-10 NaI detector. The soil comprising ORISE judgmental sample 5217S0075 had already been removed from the location, leaving a shallow hole. Scanning of the soils at and around that location did not indicate residual radioactivity at levels exceeding the MDCR of the detector plus background. Section 7 of ORISE Report 5271-SR-08-0 states that a gamma walkover scan was also performed by ORISE and showed gamma radiation levels to be similar to the surrounding area. As scanning did not indicate the presence of any additional residual radioactivity at levels exceeding background, no additional actions were deemed necessary at the time. ZionSolutions realizes that, in addition to scanning, a soil sample should have been collected as further confirmation that the location contained no more elevated material after removal of the concrete debris. In lieu of this sample, an elevated area dose calculation was performed using the ORISE judgmental sample 5217S0075, in accordance with ZS-L T-300-001-004, "Final Status Survey Data Assessment" The calculation of the Elevated Radioactivity Fraction is provided below.
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ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports Where ROC DCGLsc Co-60 4.26E+OO Cs-134 6.77E+OO Cs-137 1.42E+ol Ni-63 3.57E+03 Sr-90 l.21E+0l
~ TJ-Oj
!ELEV = L DCGLEMC fELEV = Elevated Radioactivity Fraction r1 = average concentration for each ROC in elevated area o1 = average concentration for each ROC in survey unit AF (0.1 m2)
DCGLu.ic 1:1 81 T:1 - 81 1.23E+o2 5.24E+02 7.00E-03 3.19E-02
-2.49E-02 l.33E+o2 9.00E+02 5.00E-02 l.30E-02 3.70E-02 l.50E+02 2.13E+03 7.25E+00 6.04E-02 7.19E+OO 6.92E+04 2.47E+08 6.30E-01 5.75E+OO
-5.12E+-OO 8.52E+03 1.03E+05 0.OOE+o0 1.21E-04
-l.21E-04 fROC fELEV 0.0000 0.0000 0.0034 0.0034 0.0000 0.0000 The Elevated Radioactivity Fraction for the ORISE judgmental sample 5217S0075 is 0.0034.
The original BcSOF for survey unit 10209C is 0.0153, which equates to a dose of 0.382 mrem/year. Adding the Elevated Radioactivity Fraction to the BcSOF results in a total SOF of 0.0187, which equates to a dose of 0.466 mrem/year. This response serves as an addendum to the release record for survey unit 10209C and the Phase 4 Final Report. Additionally, the dose attributed to survey unit 10209C has been revised in Table 9 on Attachment, "Supporting Information for the Phased Release of Land from the 10 CFR Part 50 License," to ZS-2020-0011.
The concrete debris was not identified during FSS most likely due to the discrete nature of the contamination and detector geometry differences between ZS and ORISE. This is explained in more detail in the RAI # 11 response. Once the concrete debris was removed, as well as surrounding contaminated soils in the ORISE judgmental sample 5217S0075, a biased scan of the area where the concrete debris was identified was performed over an area of approximately 25 m2* No measurements above the MDCR plus background were identified. The follow-up survey, "2019-1953 Follow Up to Concrete in 10209C," is included on the enclosure to this response.
102201 The area identified as exhibiting elevated scan measurements in survey unit 102201 was investigated by ZionSolutions. The soil identified as "elevated" by ORISE was scanned using a Ludlum Model 44-10 Nal detector. The scan identified gross counts at approximately twice the ambient background while scanning an approximate 1 m2 area of soil surface. The investigation narrowed the focus to a small piece of asphalt debris, which was removed and recovered along with the surrounding soil. The recovered debris was labeled as 102201-120519 Asphalt Sample (sample ID 81865) and was analyzed by the on-site gamma spectroscopy system. No plant-Page 64 of 109
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports derived gamma-emitting radionuclides were positively identified at concentrations greater than MDC. Based on the gamma spectroscopy results, it was concluded that the elevated scans observed in survey unit 102201 were due to the presence of NORM. Following the removal of the debris, the location was scanned again, and no measurement exceeded the MDCR of the detector plus background. No additional actions were deemed necessary. The results of all surveillances performed since the ORISE visit are consistent with the radiological conditions as established during the FSS, and no additional findings were identified. All the surveillance surveys from 2020, 2020 Surveillance Surveys," are included on the enclosure to this response.
12112 Following the discovery by ORISE of elevated scan results in survey unit 12112, ZionSo/utions performed an investigation of the identified location. The area was scanned, and the presence of the elevated scan measurement was verified. However, the same location was also identified as a location of elevated scan measurements during the FSS of survey unit 12112 in January 2019.
During the FSS, elevated scans were identified at the end of scan rows 41 and 42, which corresponds to the same location identified by ORISE. This is illustrated in the following graphic from the FSS package for survey unit 12112. An investigation surface soil sample was taken in each row: Ll-12112A-FIGS-001-SS in row 41 and Ll-12112A-FIGS-002-SS in row 42.
In addition, a subsurface soil sample was also taken at the same locations to a depth of one meter.
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ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports Sample Map for FSS of Survey Unit 12112 from January 2019 f legend D
SuMly Jnlt,SU) *2* 12 Syoto:T1sijo San:o1n lnvca1tg1tiollll Measurement (IMI Sa!llpleo Final Slaw, Survey SU12112 - Class 1 Sa~Map Orawln;;
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ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports Photo of Elevated Scan Location During FSS of Survey Unit 12112 from January 2019 The gamma spectroscopy results of the investigation samples taken during FSS are presented in the following table.
Summary of Gamma Spectroscopy Results for Investigation Surface Soil Samples Co-60 Cs-134 Cs-137 Ni-63 Sr-90 MEASUREME T ID (pCi/g)
(pCi/g)
(pCi/g)
(pCi/g)
(pCi/g)
OpSOF Ll-12112A-FIGS-00I -SS 1.71 E-02 3.75E-02 I.99E-02 3.09E+00 3.98E-05 0.046 LI-12112A-FIGS-002-SS I.06E-04 l.75E-02 5.48E-02 1.91 E-02 I.IOE-04 0.025 Ll-12112A-FIGS-001-SB 2.03E-03 0.O0E+00 0.00E+O0 3.66E-0I 0.0OE+o0 0.004 Ll-l2112A-FIGS-002-SB 2.03E-02 3.48E-02 2.97E-02 3.66E+00 5.94E-05 0.088 During the performance of the scan, it was identified that the soil at this location contained quantities of clay as part of the soil matrix. The clay had been identified as a causal factor for increased background during scanning due to the increased concentrations of NORM. Due to the lack of significant concentrations of plant derived radioactivity in the investigations samples taken and the continued presence of elevated scan measurements at the identified location, it was concluded that the elevated scan measurements were the result of the presence of clay material.
Upon the successful performance of FSS, survey unit 12112 was subjected to I&C measures in accordance with procedure ZS-LT-300-001 -003, "Isolation and Control for Final Status Survey" and was isolated from the time FSS was concluded until the performance of the ORISE confirmatory survey. The investigation concluded that this was the same location identified during the FSS, and no further actions were necessary.
It also should be noted that since the completion ofFSS field activities in survey unit 12112, four (4) surveillances have been accomplished in accordance with procedure ZS-LT-300-001-003, Section 5.4. Three (3) of these surveillances were performed after December of 2019. The results of all four surveillances are consistent with the radiological conditions as established Page 67 of I 09
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Infonnation Related to the Final Status Survey Reports during the FSS, and no additional findings were identified. All the surveillance surveys from 2020 are included on the enclosure to this response.
12204A Following the discovery by ORISE of elevated scan results in survey unit 12204A, ZionSo/utions performed an investigation of the identified location. Scanning identified the presence of a radioactive particle. The particle was retrieved and captured and Condition Report ES-ZION-CR-2019-0177 was initiated. The bag containing the radioactive particle and surrounding soil was assessed using portable instrumentation and then sent to on-site laboratory for qualitative isotopic analysis. Gamma spectroscopy analysis of the sample positively identified Co-60 at a concentration of 9.87 E+05 pCVg. No other plant-derived gamma-emitting ROC were positively identified. The soil where the particle was found was scanned again using a Ludlum Model 44-10 Nal detector and scans did not indicate residual radioactivity at levels exceeding the MDCR of the detector plus background. In addition, a verification soil sample was taken at the same location where the particle was located, and gamma spectroscopy analysis of the verification sample indicated Cs-137 at a concentration of 1.05 E-01 pCVg. No other gamma-emitting ROC were positively detected at concentrations greater than MDC. The follow-up survey, 2019-1971 Follow Up to Particle in 12204A," is included on the enclosure to this response.
The DRP was not identified during FSS most likely due to the discrete nature of the contamination and detector geometry differences between ZS and ORISE. This is explained in more detail in the RAI # 11 response. There was no breakdown in isolation and control measures identified. The results of all surveillances performed since the ORISE visit are consistent with the radiological conditions as established during the FSS, and no additional findings were identified. All the surveillance surveys from 2020 are included on the enclosure to this response.
Revised or Supplemental Documentation: "2019-1953 Follow Up to Concrete in 10209C;" ZS-2020-0011, Attachment, Revision 2; 2020 Surveillance Surveys;" and "2019-1971 Follow Up to Particle in 12204A;" CR-2019-0176, CR-2019-0177 NRC RAI Question #lOb In the survey units where the source of the elevated areas identified by ORISE was found to be a discrete particle (e.g., 12204A), provide information on composition of the particle. Provide information on the expected origin of these particles given their composition and location.
RESPONSE
The composition of the particle is indicative of activated metal, and the particle was visible to the naked eye. The origin of this DRP, and other similar DRPs identified on-site, are most likely to have originated in the Unit 1 and Unit 2 Containment Buildings and were generated during reactor internals segmentation activities. A comprehensive list of survey units where DRPs were identified is provided in the Recommended Table for Licensee Completion" spreadsheet, which is included on the enclosure to this response.
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ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports Revised or Supplemental Documentation: "Recommended Table for Licensee Completion" spreadsheet NRC RAJ Question #lOc Provide information on corrective actions taken to ensure that elevated areas like those identified by ORISE are not missed in other survey units.
RESPONSE: As a response to changing radiological and operational conditions brought about by site decommissioning activities, a decision was made in July of 2016 to reclassify all Class 2 survey units within the Security Restricted Area and Class 3 survey units located within the Radiologically Restricted Area, as Class 1 FSS units. This action was also taken to ensure that the open land survey units susceptible to the potential presence of particles were scanned during FSS with the appropriate rigor. This action impacted the reclassification of the following open land survey units: Class 3 survey units 10201, 10202, 10203, 10204, 10206, 10207, 10208, 10209, 10210, 10211, 10219A, 10220A, 10220B, 10221A, and 10221B and Class 2 survey units 12201, 12202, 12203, 12204, and 12205. The survey units within the Security Restricted Area were reclassified from Class 2 to Class 1 primarily due to these areas being directly impacted by demolition of the Containment Buildings, Auxiliary Building, and Fuel Handling Building, including the deposition oflow levels of radioactive material within the surface soils, movement and storage of low levels of radioactive material during demolition. These survey units became part of the expanded Radiologically Controlled Area during demolition activities. Some of these survey units were also locations of previously identified DRPs and considered higher risk. Some of the survey units were reclassified from Class 3 to Class 1 within the Radiologically Restricted Area for similar reasons as those within the Security Restricted Area, such as survey units 10209, 10221B, 10208, and 10210. The eastern portions of survey units 10206 and 10207, and the southern portion of 10203, were going to become part of the demolition area and Radiologically Controlled Area The remaining survey units were reclassified for conservatism as they had the potential to be impacted by demolition activities and the movement of radioactive material around the site during said activities. The Radiologically Restricted Area was selected as the boundary for reclassification, as equipment and personnel movement impacted by radioactive material were typically only within this boundary.
Scan survey parameters for using a Ludlum Model 44-10 Nal detector is included in the survey instructions for every Class 1 open land survey. Typical scan instructions were to walk and move the detector in a serpentine motion at a scan speed of0.25 to 0.5 mis while maintaining the detector end-cap within two inches of the ground surface. The technician would advance the detector approximately 20 cm per lateral pass (5 passes per linear meter) in one meter scan rows.
This was to ensure 100% scan coverage of the ground area in the chosen survey areas.
Technicians were trained in the proper scanning technique during qualification, and if a technician was observed in the field not adhering to the correct technique, the technician was coached in the proper operation by supervision.
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ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports A large percentage of the accessible soil surfaces in most of the Class 1 open land survey units were scanned multiple times prior to performing FSS. Aside from the scanning and sampling performed under RAs and RASSs, all open land survey units were completely scanned as part of the turnover process described in procedure ZS-LT-300-001-003, "Isolation and Control for Final Status Survey." Any discrete particles, when discovered, were immediately removed/remediated, and the surrounding area was scanned to ensure no additional particles were present. Radiological Operations personnel performed surveys in accordance with Job Aid ZS-RP-JA-011, "Use of the M3/M12-44-10 Gamma Detector for Discrete Radioactive Particles" of travel paths from the Radiologically Controlled Area/Demolition Boundary to the Radiation Protection Control Point multiple times per week during open-air demolition of radiological structures. Radiological Operations personnel performed the same DRP surveys of the travel path from the Radiologically Controlled Area/Demolition Boundary to the Lower South Lot where demolition debris was staged and loaded for transport throughout 2018 and 2019. All DRPs identified by Radiological Operations personnel were immediately remediated and disposed of. Isolation and control measures were implemented for survey units at the start of FSS in accordance with procedure ZS-LT-300-001-003, "Isolation and Control for Final Status Survey." The isolation and control measures remained in place from the time FSS was initiated, throughout the performance of the ORISE confirmatory survey, and will remain in place until License Termination. These I&C measures were sufficient to prevent any spread of contamination including DRPs.
Based upon the identification of multiple DRPs in areas outside of structures in October of 2014, following the event identified in CR-2014-001074, the 8-120 liner storage area present within portions of survey units 10208, 10209, and 10221, was deemed an elevated risk for DRPs. Soil was utilized for shielding purposes inside of roll-off containers surrounding the liner storage array, as well as within the array in-between the liner shield vaults and the roll-off containers.
All of this soil was remediated and disposed of as radioactive waste in June 2016. The rad vaults and roll-offs were surveyed and removed from the site. Once cleared of all material, all of the asphalt surfaces were surveyed to ensure no DRPs were present. As follow-up to the CR-2014-001074 event in 2014, radiological surveys in adjacent potentially impacted areas outside of the Security Restricted Area and outside of the Radiologically Restricted Area were performed.
These surveys did not identify the presence of DRPs.
Based upon the identification of multiple DRPs in areas outside of the Unit 2 Containment Building in June of 2015 (CR-2015-000324), the ground areas within the Security Restricted Area surrounding the Containment Construction Doors in each Containment Building were deemed an elevated risk for DRPs. Within the CR-2015-000324 investigation, the DRPs were determined to be legacy in nature and not related to the outside storage of radioactive material.
The origin of the DRPs, based upon their radiological and dimensional characteristics, was assumed to be from within the Containment Buildings. The most likely source of the DRPs is Page 70 of 109
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports activated metal tailings generated during reactor internals segmentation activities. An exact date or dates of contamination spread could not be determined. The DRPs were not highly transportable, were deposited outside and adjacent to the Containment Buildings, and remained primarily localized within these areas over time. Prior to commencement of open-air demolition of the Auxiliary Building and Fuel Handling Building, the top 6"-8" of surface soils surrounding both Containment Buildings were remediated and disposed of as radioactive waste in July of 2016. This was performed as a precautionary measure to reduce the risk ofDRPs being present prior to commencing major demolition of radiological structures.
Revised or Supplemental Documentation: CR-2014-001074, CR-2015-000324 NRC RAI Question #lOd For any survey unit in which there were investigations and/or remediation performed after the FSS was completed, provide revised release records that incorporate the post-FSS investigations and remediation and that accurately describe the final status of the survey unit.
RESPONSE: There have been no investigations required based upon continuing surveillances.
Investigations and remediations performed as a result of ORISE confirmatory surveys are documented in the Corrective Action program and in these RAI responses. All release records currently provided to the NRC to demonstrate compliance with the unrestricted release criteria reflect the final conditions of the site.
NRC RAI Question #lOe For the NRC staff to have reasonable assurance that the elevated areas identified by ORISE in confirmatory report 5271-SR-07-0 were investigated and remediated properly prior to the licensee emplacing clean fill, and for completeness of the release records, more information should be included in the release records where investigations and remediation occurred as a result of the confirmatory surveys.
RESPONSE: The elevated areas identified by ORISE in confirmatory report 5271-SR-07-0 were investigated and remediated properly prior to the placement of clean fill. The response to NRC RAI Question #4a provides specific details on the investigations performed and the results in the affected survey units.
NRC RAI Question #lla Demonstrate that the scan sensitivity was adequate to meet the data needs for the survey and was adequate to detect small discrete particles like the one observed in the QC sample in Survey Unit 12112. This demonstration should include an evaluation of the assumed relative ratio of radionuclides observed in the particles (i.e., the particles primarily consisting ofCo-60 versus primarily consisting ofCs-137). The demonstration should also evaluate the impact of the collimators used on the field of view. The licensee should also revise the scan MDC calculations for the Ludlum 44-10 detector to address the small discrete particles ofCo-60 with the collimator.
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ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports RESPONSE: In reference to QC sample Ll-12112A-FQGS-014SS-A, the release record describes the difference between the on-site and off-site laboratories as due to a potential DRP present in the sample. The presence of a DRP would explain the difference in the two results, as the sample geometry for the instrumentation both on-site and off-site assume the activity in the sample is homogenously mixed. However, a DRP present in the sample, in a different physical geometry within the sample matrix on-site versus off-site, would result in different analysis results due to the inherent shielding characteristics of the sample material. The result of the off-site sample analysis was 1.01 pCi/g of Co-60. The MOCRscan referenced in the release record for survey unit 12112 was 3.75 pCi/g. This was based upon an average background count rate of 5,000 cpm and 95% Cs-137 and 5% Co-60 radionuclide composition, with a scan speed of 0.5 mis. A collimator was used on the 44-10 which reduced the background count rate down to an average of approximately 2,367 cpm. Utilizing TSD 11-004, this equates to an MDCRswveyor of 735 cpm. Assuming 100% Co-60 homogenously mixed within the survey unit surface soils, this equates to an MOCR.scan of 1.60 pCi/g. Empirical testing was performed to evaluate the field of view (FOV) reduction on the 44-10 when utilizing the collimator. This resulted in an average reduced response rate for Co-60 of 412 cpm/µR/hr versus the value of 430 cpm/µR/hr referenced in TSD 11-004. Utilizing this value for the response rate equates to a slightly higher MDCRscan of 1.67 pCi/g. If the collimator was not utilized, assuming a background count rate of 5,000 cpm at 100% Co-60 contamination, the MDCRscan would have been approximately 2.32 pCi/g. The reduction ofFOV and induced reduction in detector response is more than offset by the reduction in background when utilizing a collimator. The 44-10 will achieve a smaller MDCR utilizing the collimator primarily due to the reduction in background. The presence of 1.01 pCi/g Co-60, if homogenously mixed within the surface soils, would not have resulted in a scan alarm as it was below actual field MOCR.scan of 1.67 pCi/g.
The mass of the sample was approximately 749.17 grams. Utilizing the off-site analysis result of 1.01 pCi/g of Co-60, would result in a DRP with activity of approximately 757 pCi based upon 1.01 pCi/g. Empirical testing was performed to determine the impact of collimator use on DRPs versus a homogenously mixed source. Utilizing the same assumptions in TSD 11-004, the 44-10 would view a 50 cm diameter region that is 15 cm deep during a one-second interval at a scan rate of 0.5 m/s. During this one-second interval, the DRP could be present anywhere within this volume. Specific responses were determined based upon the location of the DRP within this volume. The best-case geometry of the detector centerline directly above the DRP on the surface, would result in a Minimum Detectable Activity (MDA) ofapproximately 7,987 pCi of Co-60, assuming the same average background of2,367 cpm. This assumes the utilization of a collimator with a detector response of 412 cpm/µR/hr. This also demonstrates that the 44-10 would not have been able to detect the calculated Co-60 DRP during the scan of the survey unit.
Given a typical 50 cm diameter region that is 15 cm deep being analyzed during a one-second window, and advancing the detector in 25 cm steps, the detector could, at best-case geometry, be Page 72 of 109
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports directly above the DRP at some point during the scan. At worst-case geometry during the same pass, the detector would be at the edge of the region approximately 25 cm away from the DRP.
If the DRP were offset at 12.5 cm from the center of the region between both passes, this would be the best-case geometry from the detector, and 28 cm away from the detector at the worst-case geometry during both passes. MicroShield was utilized to determine approximate Co-60 DRP activity strength at positions directly under the centerline of the detector, at 12.5 cm, 25 cm, and 28 cm offsets on the surface of the soil. The Co-60 DRP activity was evaluated utilizing detector sensitivity based upon empirical testing with and without a collimator. With the detector directly above the DRP, the average detector response is approximately 6.3% less for Co-60 and 6.9%
less for Cs-137 when utilizing a collimator. With the detector at a 12" offset from the DRP, the average detector response is approximately 22.1 % less for Co-60 and 44.3% less for Cs-137 when utilizing a collimator. Based upon the empirical data and MicroShield evaluations, utilizing the collimator with reduced background and reduced detector response can achieve a lower MDCR than without the collimator at higher background levels. This is assuming the detector is in the same relative position with respect to the DRP. The position of the DRP within the survey region has the greatest impact to the MOCR of the detector during surveys. At worst-case geometries, the MDA for detection of a DRP is approximately 17 times higher than that during best-case geometries. This is primarily due to the positional dependence and limited FOV of the DRP due to the collimator on the 44-10 response. This positional and FOV impact can result in elevated readings during one survey and no elevated readings above background in another survey of the same region with the same detector if the detector is not moved in the exact same scan path. This positional impact would explain the DRPs identified during the ORISE surveys in survey units 12204A, 12202D, and 12202F. The positional impact is larger for Cs-137 than it is for Co-60 based upon the empirical testing. Because the piece of concrete debris that was identified by ORISE in survey unit 10209C was discrete rather than uniform contamination in the survey region, its detection would have been impacted by this positional dependence and FOV of the collimated 44-10.
Typical scan instructions for performing surveys with the 44-10 were to walk and move the detector in a serpentine motion at a scan speed of 0.25 to 0.5 mis while maintaining the detector end-cap within two inches of the ground surface. The technician would advance the detector approximately 20 cm per lateral pass (5 passes per linear meter) in one-meter scan rows. These typical scan instructions are representative of scan surveys performed by the Site Characteriz.ation/License Termination Group as well as the Radiological Operations Group. The alarm level was typically established based upon the average background in the scan area plus the MDCRsurveyor for the detector. A collimator was utilized to reduce background when applicable, and as explained above, would allow the technicians to scan to a lower MDCR even when accounting for the reduced FOV of the detector. The technicians would utilize headphones to enable better hearing of deviations in counts and typically did not walk next to other Page 73 of 109
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports technicians. Upon hearing an increase in the audible counts, the technician would slow the scan speed to better identify a potential discrete elevated area. These typical scan instructions were to ensure technicians could identify radiological material, whether distributed or discrete in nature, to levels as low as practical depending upon background radiation levels. This typical survey protocol was successfully used to identify the hundreds ofDRPs on-site over the course of the project. The Site Characterization/License Termination Group would also typically utilize GPS and data loggers when performing surveys to further enhance the ability to identify regions of elevated measurements for biased sample locations.
The action level was established at MDCR plus background for all scans. The scan sensitivity was as low as achievable based upon background radiation within each survey unit and was adequate to meet the needs of the survey designs. A DRP of similar source strength as referenced in Survey Unit 12112 would not have been identified during scans. The source strength of such a DRP would have been below the MDA of the detector, and, below the action level. The use of the collimator on the 44-10 did restrict the FOV of the detector, and as a result, reduced the sensitivity of the 44-10. The 44-10 with a collimator was still able to achieve a lower MDCR than without a collimator. This was due to the reduction of POV and induced reduction in sensitivity being offset by the reduced background radiation levels.
NRC RAJ Question #11 b Provide information on the composition of particles found onsite.
Provide information on the source of the particles observed onsite given their composition and location. Provide details on what areas of the site in which these particles would be expected to be found.
RESPONSE: The majority of all DRPs identified on-site outside of structures from 2014 onward have been composed of primarily Co-60, based upon on-site gamma spectroscopy analyses. The DRPs are metallic in nature, mildly magnetic, typically visible to the naked eye, irregular in shape, and with typical dimensions of around 1 mm in diameter and less than 1 mm thick. Below is a photo of typical tailings generated from reactor internals segmentation activities, which utilized a diamond wire saw, taken during equipment mockups. The DRPs identified on-site are similar in appearance and size to these tailings.
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ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports The identification ofCo-60 as the sole gamma emitter in the majority of the DRPs identified is consistent with the neutron activated reactor internals components.
Prior to the implementation of physical decommissioning and demolition activities, discrete radioactive particles as defined in procedure ZS-RP-I 06-002-005 were not encountered in soils at the Zion site. As part of the site characterization, the entire exposed soil surface was scanned using a Ludlum Model 44-10 detector, and no particles were identified.
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ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports DRPs were first identified outside of structures after a spread of contamination event in September of 2014. 8-120 liners loaded with reactor internals segments were temporarily stored in a shielded array in the lower south lot present in survey units I 0221A, I 0221 B, and 10221 C.
The spread of contamination event is documented in CR-2014-001074, with subsequent investigation performed under an Apparent Cause Evaluation. The cause of the contamination spread was inserting an 8-120 liner into its overpack outside. The liner was transported north across the site to the NGET parking lot located in survey unit I 0202. DRPs were identified in survey unit 10221, where the loading took place, across survey units 10208, 10207, 10206, 10204, 10203, and then in 10202, where the liner and trailer were staged temporarily for shipping survey. Over 100 DRPs ranging from 0.001 µCi to 3 µCi were identified and remediated after this event. Surveys were performed of walking areas adjacent to the travel path of the liner, parking areas inside and outside of the Radiologically Restricted Area, and the main access road entering the Radiologically Restricted Area. No DRPs were identified in these areas.
No surveys were performed of areas inside the Security Restricted Area, as they were not considered impacted by this event. The cause of the spread of contamination was corrected, and all contamination was remediated following this event. The corrective action documentation and surveys are supplied on the enclosure to this response.
A Radiological Assessment performed in survey unit 10203A during 2014 identified seven DRPs with a maximum level of 6.76E-3 µCi within the Security Restricted Area near the west fence.
The DRPs were remediated along with surrounding soils at time of discovery.
DRPs were again identified in June of2015 as documented in CR-2015-000324. The DRPs were identified during down-posting of a Radiological Material Area (RMA) outside of the Unit 2 Containment Building that previously contained pieces of the Steam Generators. The DRPs were again consistent with activated metal tailings identified during the September 2014 event. Expanded surveys were performed within the Security Restricted Area concentrating around the Unit I and Unit 2 Containment Buildings and the western path between the two buildings. Approximately 100 DRPs were identified ranging from 0.002 µCi to 0.5 µCi. The presence of the DRPs was determined to be not related to the temporary RMA and Steam Generator segments. Below is an image identifying locations of DRPs identified during this investigation.
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ZionSolutions, LLC ZS-2021-000 I Response to Request for Additional Information Related to the Final Status Survey Reports Initial RMAArea 06/03/2015 Partlcios Collected Partidas Not Collec;;Ced L.:j =~~c!=,
OOl R.medieted CJ Surv.y Units Arll Not Scanned (Due., high becl<groood)
Note: Survey rest.Its are oross c:ounts using a 2 x 2 Hal oeuaor.
Page 77 of I 09 Particle Identification Overview NADBJ n. Stet. Plane Ent 120, (w.lefl) 2012Mrlels - L-~IL~
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Dates Surve ed 06--03-15 thru ~9-15 Drawing 201fK)()()324.e
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports The cause of the spread of contamination within the Security Restricted Area could not be determined. The DRPs were believed to have originated from reactor internals segmentation activities. In June of 2015, reactor internals segmentation activities were complete, and both reactor cavities were drained, cleaned, and locked down with a fixative. One program failure identified during the investigation was the inadequacy of instrumentation Radiological Operations personnel were utilizing to survey areas outside of structures, primarily Geiger Mueller type friskers versus scintillation detectors. Corrective actions were implemented to ensure down-posting of RMAs including the use of scintillation type detectors. Additionally, the Site Characterization/License Termination Group performed secondary surveys prior to down-posting. The corrective action documentation and surveys are supplied on the enclosure to this response.
During generation of lessons learned for the Zion D&D in early 2019, the cause of the DRPs located within the Security Restricted Area was re-evaluated. In the second half of 2014, partially full 8-120 liners, the Unit 2 Lower Core Support Assembly, tooling, and components were relocated from the Unit 2 reactor cavity to the Unit 1 reactor cavity by transportation along the west side of the Security Restricted Area. This was determined to not be a cause, as there was no breakdown in radiological controls identified during these movements. The Containment Building ventilation was re-evaluated as another potential cause. Engineering analyses were performed when creating the construction openings into each Containment Building in late 2011.
These evaluations ensured that the Containment Buildings maintained a negative pressure with respect to outside atmosphere and that air was being pulled into the Containment Building. What was not considered in the evaluation was the face velocity of the opening compared against average wind speeds impacting the opening. Based upon the ventilation capacity and the size of the opening in each Containment Building, the face velocity entering each opening was less than one mile per hour. This was not adequate to overcome the average wind speed. The most likely cause for the DRPs identified within the Security Restricted Area was wind entrainment of DRPs inside of each Containment Building in the immediate vicinity of the openings. This potential cause was created as a lesson learned for future D&D projects. With this being the most probable cause of DRPs within the Security Restricted Area, it is likely the DRPs could have migrated outside of each Containment Building between approximately 2012 through late 2016 when the tented enclosures were installed around each Containment Building opening.
Following this logic, it is reasonable to assume that, since no DRPs were identified outside of the Security Restricted Area or Radiologically Restricted Area in areas adjacent to the travel path of the liner contamination event in 2014, the DRPs were not highly mobile and were not easily dispersed throughout the site. It is also reasonable to assume that more DRPs may have migrated outside of each Containment Building after the identification and remediation of DRPs within the Security Restricted Area in 2015, albeit to a lesser extent, as reactor internals segmentation activities were completed and there was no longer a generation source for this type of Page 78 of 109
ZionSolutions, LLC ZS-2021-000 I Response to Request for Additional Information Related to the Final Status Survey Reports contamination. Based upon this information, the highest-risk areas for the presence of DRPs would have been within the Security Restricted Area, concentrating in the areas around each Containment Building and the western side of the Fuel Handling Building travel path between each Containment Building. A second high-risk area for the presence of DRPs would have also been in survey units 10221 A, I 0221 B, and I 0221 C, where reactor internals segmentation liners were temporarily stored and due to the event documented in CR-2014-001074.
In 2016, these two high-risk areas were remediated. The south liner storage array in survey units 10221A, 10221B, and 10221C was dismantled, and all potentially DRP contaminated soils utilized for shielding was shipped off-site as radioactive waste. Due to the identification of DRPs within the Security Restricted Area in 2015, a management decision was made to remediate approximately 6"-8" of surface soils around each Containment Building to further reduce the risk of DRPs still being present. This was performed prior to building the tented enclosures around each Containment Building opening and prior to commencement of open-air demolition of the Auxiliary Building and Fuel Handling Building. There was approximately seven million pounds of soils shipped off-site in 2016, accounting for this potentially contaminated DRP material.
Open-air demolition of the Auxiliary Building and Fuel Handling Building, as well as internal demolition of each Containment Building, was performed from late 2016 through early 2018.
During this time, demolition debris from each Containment Building, along with system components from the Auxiliary Building and Fuel Handling Building, was loaded into milgon containers within each Containment Building tented enclosure. Structural steel and concrete debris generated during Auxiliary Building and Fuel Handling Building demolition was staged and loaded in outside areas on the west side of the Containment Buildings and Fuel Handling Building, within the old Security Restricted Area footprint. During this time, the old Security Restricted Area boundary became part of the Demolition Boundary and was treated as an RCA.
All personnel were required to perform frisking prior to exiting the RCA. Radiological Operations personnel would survey all equipment and material prior to allowing exit and removal of materials from the RCA. The travel paths from the exits of this demolition area/RCA to the Radiological Control Point located in the old NGET Building, present in survey unit 10203, were surveyed weekly by Radiological Operations personnel utilizing Job Aid ZS-RP-JA-011, "Use of the M3-44-10 Gamma Detector for Discrete Radioactive Particles."
Radiological Operations identified and remediated approximately 15 DRPs from early 2017 through the middle of 2018, ranging in activity from 0.004 µCi to 0.23 µCi ofCo-60 and were consistent with activated metal tailings identified earlier in the project. In the middle of 2018, the lower south lot became the primary waste staging and loading area for demolition debris in survey units 10221A, 10221B, and 10221C. The waste travel path from the Demolition Area exit near the southern end of survey unit l 0202D to the lower south lot waste loading area were surveyed weekly by Radiological Operations personnel utilizing Job Aid ZS-RP-JA-011, "Use of Page 79 of I 09
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports the M3-44-10 Gamma Detector for Discrete Radioactive Particles." Radiological Operations identified and remediated approximately 24 DRPs from the middle of 2018 through most of 2019, ranging in activity from 0.00054 µCi to 1.08 µCi of Co-60 and were consistent with activated metal tailings identified earlier in the project.
Concrete debris generated during all radiological structural demolition was never a source of DRPs on-site. The majority of all DRPs identified outside of structures throughout the project are conducive with the radiological, metallurgical, and dimensional characteristics representative of reactor internals segmentation tailings.
The remaining demolition debris from the Auxiliary Building and Fuel Handling Building was shipped off-site by the middle of 2018. Approximately 100 million pounds of contaminated soils from within the Radiologically Restricted Area were shipped off-site in 2019. This is the equivalent ofremediating the top two feet of soil within the entire old Security Restricted Area footprint. The majority of the soils originated within the Security Restricted Area, the lower south lot waste loading area, and the transit areas in between these two locations.
As a response to changing radiological and operational conditions brought about by site decommissioning activities, a decision was made in July of2016 to reclassify all Class 2 survey units within the Security Restricted Area and the majority of Class 3 survey units located within the Radiologically Restricted Area, as Class 1 FSS units. This action was also taken to ensure that the open land survey units susceptible to the potential presence of particles were scanned during FSS with the appropriate rigor. This action impacted the reclassification of the following open land survey units: Class 3 survey units 1020 I, I 0202, I 0203, 10204, I 0206, I 0207, I 0208, 10209, 10210, l 0211, I 0219A, 10220A, 10220B, l 0221 A, and l 0221 B and Class 2 survey units 12201, 12202, 12203, 12204, and 12205.
As a result of performing 100% scan surveys, an additional 14 DRPs were identified during FSS and pre-FSS activities occurring in 2019, primarily in the areas that were re-classified.
The risk of DRPs remaining on-site at License Termination has been mitigated through the initial identification and remediation of DRPs in 2014 and 2015, the remediation of soils prior to large scale radiological demolition in 2016, the extensive soil remediation occurring in 2019, frequent Radiological Operations survey and subsequent identification and remediation of DRPs, and expanded scope of FSS to include the majority of the Radiologically Restricted Area as Class I and subsequent identification and remediation of DRPs.
A map depicting the survey units within which particles were discovered is included on the enclosure to this response.
Revised or Supplemental Documentation: CR-2014-001074, CR-2015-000324, 2014 DRP Surveys, 2015 DRP Surveys, 2016 DRP Surveys, 2017 DRP Surveys, 2018 DRP Surveys, 2019 DRP Surveys, Zion Survey Unit Particle Identification Map Page 80 of 1 09
ZionSolutions, LLC ZS-2021 -000 I Response to Request for Additional Information Related to the Final Status Survey Reports NRC RAI Question #llc For Survey Unit 12112, provide information on the location of sample L1-12112A-FQGS-014-SS in relation to the location of the scan alarms in rows 41 and
RESPONSE: Below is a picture identifying the location ofLl-12l l2A-FQGS-014-SS in relation to the scan alarms in rows 41 and 42 of Survey Unit 12112. The scan alarms occurred at location of soil samples Ll-12112A-FIGS-00I-SS in row 41 and Ll-12112A-FIGS-002-SS in row 42. The location ofL1-12112A-FQGS-014-SS is annotated in map by marker 14-QC.
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ZionSolutions, LLC ZS-2021-000 I Response to Request for Additional Information Related to the Final Status Survey Reports Sample Map for FSS of Survey Unit 12112 from January 2019 i---------~
i Legend c::J Survey Unit *s* )
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ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports NRC RAJ Question #lld Describe any corrective actions taken to ensure that all risk-significant particles were identified in all survey units.
RESPONSE: This is answered in the response to NRC RAJ Question #1 lb.
Supplemental NRC RAJ Question #11 Provide an estimate of the dose from a hypothetical intake (both inhalation and ingestion) of a typical discrete particle for the site, taking into account the range of siz.es, chemical compositions, and radioactivity of the discrete particles discovered in soils at the site.
RESPONSE: ZionSolutions performed a dose assessment for the hypothetical intake (both inhalation and ingestion) of a typical discrete particle for the site. The results are provided in the "Ingestion Pathway Dose" and "Inhalation Pathway Dose" tables below.
Based upon a review of all DRPs identified on-site over the course of the project, the average activity of those identified was approximately 0.21 µCi of Co-60. These DRPs were identified under various background radiation levels typically with the collimator being used on the 44-10.
The general background levels during the liner event in 2014 were 5,000 to 13,000 cpm. The general background levels during the spread of contamination identified in 2015 were 2,000 to 12,000 cpm. The general background levels during FSS of survey units within the Radiological Restricted Area were 2,000 to 3,000 cpm. For those survey units near the southwest end of the Radiological Restricted Area, the average background during FSS was 4,000 cpm. The background dose rates varied during Radiological Operations surveys performed between 2016 and 2019, based upon proximity to stored radioactive material, with an average background level of approximately 3,000 cpm.
As the majority ofDRPs identified on-site are believed to have originated from reactor internals segmentation activities, Waste Management Group activation ~alysis report 07-460-RE-088 (provided on the enclosure to this response) was utiliz.ed for the radionuclide composition of the DRPs. A weighted average was determined for all radionuclides based upon both units and all components. All activities were then decay corrected to a date of January 1, 2021. Below is a table of the radionuclide constituents and their calculated radionuclide activity concentrations.
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ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports Radionuclide Constituents and Activity Concentradons Radionuclide Activity Concentration (Ci/g) as of 1/1/2021 H-3 l.32E-06 C-14 2.02E-06 Mn-54 4.36E-12 Fe-55 4.00E-05 Co-60 5.49E-04 Ni-59 9.00E-06 Ni-63 1.28E-03 Nb-94 3.1 lE-08 Tc-99 6.53E-09 As described in the response to NRC RAJ Question #1 lb, the DRPs were typically irregularly shaped and of various dimensions. For calculation of activity median aerodynamic diameter (AMAD) the DRP was assumed to be spherical in nature. For a Co-60 DRP with a source strength of 0.21 µCi, this would equate to an AMAD of approximately 450 µm.
NCRP 130, Biological Effects and Exposure Limits for Hot Particles" was reviewed with respect to internal dose evaluation. NCRP 130, Section 9.3, Respiratory System" states, "It is recommended that: 'Limitation be based on currently applicable effective dose limits, with the effective dose determined using general respiratory system models and residence times for insoluble material.'" NCRP 130, Section 9.4, "Gastrointestinal (GI) System" states, "It is recommended that: 'Limitation be based on currently applicable effective dose limits, with the effective dose determined using general GI system models and residence times for insoluble material."'
Ingestion Pathway Dose ICRP 100, Human Alimentary Tract Model for Radiological Protection (HA TM)" was evaluated with respect to more recent dose modeling for the ingestion pathway. ICRP 100 states, "The HA TM can be used to calculate doses from discrete particles of high activity such as fragments of irradiated fuel (often called 'hot particles'), as well as for the normal situation of distribution of activity throughout the contents of the alimentary tract The consideration of realistic target cell locations in the HA TM enables doses to be calculated using radiation transport calculations considering, for example, different particle sizes, densities, and elemental compositions. The particles can be taken to be at different radial positions within the lumen as this can lead to a different dose to the target cells. Calculations of this sort have been performed Page 84 of 109
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports using a model similar to the HA TM (Darley et al., 2003). This approach takes absorption of energy within the particle into account. It generally yields lower doses than the Publication 30 model, although the extent of the difference will depend on the radionuclides that provide the major fraction of the dose and the size of the particles."
Additionally, ICRP I 00 states, Previous in vitro studies have shown that the particles are not readily soluble and are likely to pass through the alimentary tract with the loss of only a small proportion (:SI%) of their radionuclide content."
Based upon this review, ICRP 30 models and assumptions were utilized to assess the internal dose based upon the ingestion pathway. Due to the insoluble nature ofDRPs, the lowest solubility class was utilized for each radionuclide when selecting dose conversion factors.
Dose conversion factors were taken from Federal Guidance Report No. 11, Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors For Inhalation, Submersion and Ingestion." Below is a table summarizing the Committed Effective Dose Equivalent (CEDE) to an individual from a 021 µCi Co-60 DRP following the ingestion pathway.
Ingestion Pathway Dose Scaling Intake Uptake CEDE CEDE Radionuclide Factor Activity Fraction (fl)
(Sv/Bq)
(mrem)
(µ.Ci)
H-3 0.002409186 0.000505929 1
l.73E-11 3.24E-05 C-14 0.003673375 0.000771409 1
5.64E-10 l.61E-03 Mn-54 7.93822E-09 1.66703E-09 0.1 7.48E-10 4.61E-09 Fe-55 0.072707804 0.015268639 0.1 l.64E-10 9.27E-03 Co-60 1
2.l0E-01 0.05 2.77E-09 2.15E+-O0 Ni-59 0.016384405 0.003440725 0.05 5.67E-11 7.22E-04 Ni-63 2.324053072 0.488051145 0.05 l.56E-10 2.82E-01 Nb-94 5.65344E-05 l.18722E-05 0.01 1.93E-09 8.48E-05 Tc-99 l.18866E-05 2.49619E-06 0.8 3.95E-10 3.65E-06 Total 2.45E+o0 The calculated hypothetical CEDE due to ingestion of a 0.21 µCi Co-60 equivalent DRP is approximately 2.45 mrem.
Inhalation Pathway Dose Page 85 of 109
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports ICRP 66, Human Respiratory Tract Model for Radiological Protection (HR.TM)" was evaluated with respect to more recent dose modeling for the inhalation pathway. No additional information was identified with respect to the internal dose modeling following the inhalation of a single DRP.
As recommended in NCRP 130, ICRP 30 models and assumptions were utilized to assess the internal dose based upon the inhalation pathway. ICRP 30 states, For an unusual distribution with an AMAD of greater than 20 µm, complete deposition in the N-P pathway can be assumed." Based upon this information, a DRP of 0.21 µCi equating to an AMAD of 421 µm would have remained in the extrathoracic region and transferred to the GI tract thus following the ingestion pathway with associated dose as descnbed earlier. To assess a hypothetical dose to the body from inhalation, the DRP size was corrected to 20 µm AMAD. At this AMAD the approximate activity of the DRP would have been 1.86£-05 µCi of Co-60.
Due to the insoluble nature ofDRPs, the longest clearance time was utilized for each radionuclide when selecting dose conversion factors. Dose conversion factors were taken from Federal Guidance Report No. 11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors For Inhalation, Submersion and Ingestion." Below is a table summarizing the CEDE to an individual from a 20 µm AMAD Co-60 DRP following the inhalation pathway.
lnbaladon Pathway Dose Scaling Intake CEDE CEDE Radionuclide Activity Class/ fl Factor (Sv/Bq)
(mrem)
(uCi)
H-3 0.002409186 4.46924E-08 Vapor-1 l.73E-11 2.86£-09 C-14 0.003673375 6.81441E-08 1
5.64E-10 1.42E-07 Mn-54 7.93822E-09 1.4726£-13 W-0.1 l.81E-08 9.86E-12 Fe-55 0.072707804 l.34879E-06 D- 0.1 7.26E-10 3.62E-06 Co-60 1
1.86£-05 Y - 0.05 5.91E-08 4.06E-03 Ni-59 0.016384405 3.03944E-07 D-0.05 3.58E-10 4.03E-07 Ni-63 2.324053072 4.3113 lE-05 D- 0.05 8.39E-10 l.34E-04 Nb-94 5.65344E-05 1.04876£-09 Y - 0.01 l.12E-07 4.35E-07 Tc-99 1.18866£-05 2.20507E-l 0 W-0.8 2.25E-09 1.84E-09 Total 4.19E-03 Page 86 of I 09
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports The calculated hypothetical CEDE due to inhalation of a 20 µm AMAD DRP is approximately 0.004 mrem.
This calculation is extremely conservative. The dose conversion factors from FGR-11 were derived based on an assumed inhalation of an aerosol distnbution with an AMAD of 1 micron. That is, the particle sizes of the inhaled radioactivity covered a range of sizes with half of the activity being associated with particles with an AMAD less than 1 micron and half with an AMAD greater than 1 micron. Such a distribution of particles would be inhaled and deposited throughout the entire respiratory system, including the nasal-pharyngeal region, the tracheal-bronchial region, and the pulmonary region. For dosimetry purposes, the deposition pattern of such a dispersed distribution is assumed to be uniform within a given dosimetric segment of the respiratory tract. Material deposited in the respective segments of the tract may be absorbed into body fluids, transported to the throat and swallowed, expelled through the nose or mouth, or trapped in lymph tissue.
This is very dissimilar to the fate and behavior of a single 20-micron particle, which would deposit at a single site in the upper respiratory tract and be cleared by swallowing or be expelled from the nose or mouth. As a related aside, it is also an accepted dosimetric truth that the potential (cancer) risk from respiratory tract dose delivered by a single particle of a given activity is less than the risk from the same amount of activity spread unifonnly over a larger area of the respiratory tract.
ZionSolutions acknowledges the fact that ORISE confirmatory surveys identified 3 DRPs.
Based upon this fact, and the limitations of the 44-10 detection capability, it is plausible that some DRPs may still exist on-site at end state. With respect to the hypothetical internal dose from DRPs, it was the intention of ZionSolutions to identify and immediately remediate all DRPs on-site. Through both extensive surveys by the Site Characterization/License Termination Group and Radiological Operations groups, as well as extensive remediation and disposal of soils potentially contaminated with DRPs, it is highly unlikely that DRPs currently remain on-site.
The average soil ingestion transfer rate from NUREG/CR-5512 is 0.05 grams/day which equates to 18.25 grams/year. Conservatively assuming one DRP is present in each one-second interval survey region, this equates to approximately one DRP in 15,000 grams of soil. This is based upon a survey region 50 cm in diameter, 15 cm thick, and a soil density of 1.6 glee. The probability of an average member of the critical group ingesting a DRP is therefore l.22E-03, or 0.122%. Inhalation of a DRP is not deemed plausible, as the AMAD for the tailings generated during reactor internals segmentation activities was significantly larger than 20 µm, and an inhaled DRP would ultimately be transferred to the GI tract.
Revised or Supplemental Documentation: 07-460-RE-088 NRC RAI Question #12a Additional information is needed regarding the remediation and post-remediation scans of the keyway soils. (See RAl7 above).
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ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports RESPONSE: Based upon the history cited in the Zion HSA, section 5.3.4.4 ofLTP Chapter 5 states that the subsurface soils in the "keyways" between the Containment Buildings and the Turbine Building will be assessed for radiological contamination of subsurface soils once subsurface utilities and subsurface access-interfering structures (e.g., Waste Annex Building) had been removed.
In May 2016, as part of the demolition of the Turbine Building, the approximate nine feet of soil over the Unit 1 Steam Tunnel located along the south side of Unit 1 Containment and three feet of soil over the Unit 2 Steam Tunnel located along the north side of Unit 1 Containment was excavated, removed, and disposed of as potentially contaminated waste. This included the volume of soil located in each "keyway and positioned on-top of these subsurface structures (grade of 588 foot, top of Steam Tunnels and Diesel Fuel Oil Tank rooms are at approximate grade of 579 foot or nine feet below grade). The roofs of the exposed Steam Tunnels were subsequently demolished, exposing the inner walls and floor surfaces. The interior of the Steam Tunnels and the 9-foot deep excavations created to expose the structures were then backfilled with clean fill from off-site sources. This process was necessary to support machinery weight from the eventual demolition of the Containment domes. It should be noted that this area was not considered to be contaminated as surface and subsurface soil samples were acquired from the keyways during characterization. The maximum observed concentration of Co-60 in soil was 1.04 pCi/g, and the maximum observed concentration of Cs-137 in soil was 3.39 pCi/g.
Radiological coverage and surveys performed for this activity were provided under a Radiation Work Permit. No RA or RASS surveys were performed, because the excavation completely removed all the overburden soils and no subsurface soils remained inside of the excavation.
In 2017, the concrete ceiling and the of the Unit 1 and Unit 2 Diesel Fuel Oil Tank rooms was removed to support the removal of radioactive commodities from the Auxiliary Building. The clean fill introduced into the "keyways" prior to building demolition was completely removed and disposed of as waste, exposing the east entrances into the Steam Tunnel and the Unit 1 and 2 East and West Valve Rooms. The Unit 1 and Unit 2 East Valve rooms are located directly in the "keyways". The interiors of the Unit 1 and 2 East and West Valve Rooms were successfully subjected to FSS in April of 2018. Prior to demolition of the Containment domes, this entire area was backfilled with clean fill from off-site. The figure below shows the keyways and the underlying structures following the removal of the indigenous soil.
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ZionSolutions, LLC ZS-2021-000 I Response to Request for Additional Information Related to the Final Status Survey Reports Unit 1 and Unit 2 Keyways NRC RAI Question #12b The licensee should describe the continuing characterization soil samples from under the SFP foundation slab, that were part of the commitments in LTP Section 5.3.4.4 or point to the release record in which they are discussed. If no samples were taken prior to backfill, provide additional information to support that these soils do not contain residual radioactivity that would be in excess of the release criteria.
RESPONSE: 1n March of 2018, the walls and floor of the FHB were demolished and removed.
A large excavation was created to accomplish this, and when complete, the only part of the FHB that remained was the bottom of the SFP.
The soil directly beneath the SFP slab was inaccessible. Attempts to sample the soil beneath the slab with angled boring techniques (GeoProbe) were met with refusal due to a previously unidentified mud-mat. Additionally, during FSS of the SFP/Transfer Canal, hotspots were not observed that would indicate a crack or travel path for subsurface contamination.
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ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports The Excavation Created for Demolition of the Fuel Handling Building Inside the FHB Excavation Looking West As illustrated in the photos, the excavation created to remove the FHB completely exposed the subsurface soils around the north, west, and south side of the SFP floor concrete slab. The subsurface soils surrounding the SFP slab were scanned and sampled as part of the FSS of this excavation prior to backfill. The results of scanning and soil samples taken directly adjacent to the SFP floor slab are found in the release records for survey units 12106 and 12107, Addendum l which documents the FSS of the open excavation. The following table reproduces the scan results reported in the release records.
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ZionSo/utions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports Results of Scan Surveys of Soils Directly Adjacent to SFP Floor Pad Survey Scan Highest Logged Reading Action Level
(cpm)
Alarms 12106K 24 14000 3269 1
12106K 25 3120 3269 0
12106K 26 3350 3388 0
12106K 27 6770 3269 1
12107K 31 2794 3261 0
12107K 32 2794 3261 0
12107K 33 2796 3261 0
12107K 34 2890 3261 0
12107K 35 2902 3261 0
12107K 36 2909 3261 0
12107K 37 3064 3261 0
12107K 38 3135 3261 0
12107K 39 3067 3261 0
Investigations were performed in two (2) areas identified by gamma scans.
Following investigation, spot remediation occurred at each location directed by scanning until all identified elevated activity was removed. The final post remediation sample result showed a maximum OpSOF of0.922.
Results of Analysis of Subsurface Soils Directly Adjacent to SFP Floor Pad Sample ID Co-60 Cs-134 Cs-137 Ni-63 Sr-90 (pCi/g)
(pCi/g)
(pCi/g)
(pCi/g)
(pCi/g)
OpSOF Ll-12106K-FSGS-021-SB S.09E-02 0.00E+-00 1.03E+-OO 9.18E+o0 2.06E-03 0.629 Ll-12106K-FSGS-022-SB 2.35E-01 2.62E-02 1.40E-01 4.24E+ol 2.80E-04 0.578 Ll-12107K-FSGS-001-SB 3.92E-02 2.22E-02 5.36E-02 7.07E+o0 1.07E-04 0.127 Ll-12107K-FSGS-005-SB 6.68E-02 0.OOE+-00 1.0lE-01 1.21E+ol 2.02E-04 0.189 Ll-12107K-FSGS-015-SB 3.78E-02 0.OOE+-00 1.60E-01 6.82E+oo 3.20E-04 0.159 NRC RAJ Question #13a At a minimum, the discussion of these QA/QC topics should address how quality assurance protocols were followed during collection and analysis of these samples (e.g., measurement instrument performance checks, MOCs for the original and QC sample measurements, chain of custody, etc.).
RESPONSE: The QA/QC requirements for the performance of PSS at Zion is addressed in LTP Section 5.9 and the approved QAPP. As stated in LTP Section 5.92, compliance with the QAPP ensured the following:
PSS was implemented in accordance with the approved procedures, PSS was conducted by trained personnel using calibrated instrumentation, Page 91 ofl 09
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports The quality of the data collected was adequate, All phases of package design and survey were properly reviewed, and
The QA/QC requirements from the QAPP were incorporated into approved procedures used to implement FSS, including replicate measurement and sample frequency and agreement criteria, data validation, instrumentation quality checks, and corrective action.
Instrument quality requirements such as calibration frequency, instrument performance checks (pre-and post-use), and acceptance criteria are addressed in the instrument implementation procedure for the instrument. Required QA/QC requirements such as the acquisition frequency for duplicate measurem~ts and samples and acceptable instrument MDC are specified in the survey design for the FSS of each survey unit. Data validation requirements are addressed in the FSS Data Analysis procedure, and the quality aspects. of sample acquisiti.on, preparation, and Chain-of-Custody requirements are addressed in the sample preparation procedure.
Each gamma spectroscopy report and instrument download report is validated by a Radiological
.Engineer in accordance with Section 5.1 of procedure ZS-LT-300-001-004, Final Status Survey Data Assessment." The procedure addresses the required content from QAPP Section 6.2.2.1, including the verification of the absence of anomalies in the sample or measurement results, or in the supporting data, including but not limited to MDC, uncertainty, deviation from established procedure, or analysis flags.
The QC requirements for data acquisition are addressed in LTP Section 5.9.3, which requires the that a replicate measurement be performed at 5% of the static and scan locations or a duplicate sample be taken at 5% of the volumetric sample locations (systematic and biased). In accordance with Section 4.1.2 of the QAPP, as well as L TP Section 5.9.3, the acceptance criteria specified for replicate measurements states, "The acceptance criteria for static measurements and scan surveys, based OQ. *the professional judgment of the Radiological Engineer, is that the same conclusion is reached for each measurement location and no other locations, greater than the
-scan investigation level for the area classification, are found." The acceptance criteria for duplicate or split volumetri~ samples is addressed in QAPP Section 4.2 and LTP Section 5.9.3.2,,
which both state, "NRC Inspection Procedure, No. 84750, "Radioactive Waste Treatment, and Effluent and Environmental Monitoring" will be used to determine the acceptability of split and duplicate sample analyses."- In addition, LTP Section 5.9.3.2 also states, "Agreement is ultimately determined when the same conclusion is reached for_ each compared result" NRC RAI Question #13b For original and split samples with results greater than the MDC, explain why the QC checks failed the acceptance criterion for compared sample results. If the subsequent investigation and/or discussion reveals the survey data is suspect and may not Page 92 of I 09
ZionSolutiom, ILC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports represent actual conditions in the survey unit, provide information on the collection of additional measurements, the usability of the survey data, and the potential for the discrepancy to adversely affect the decision on the radiological status of the overall survey unit.
RESPONSE: Please refer to the response to Additional NRC Question #2 (Additional NRC Questions on Zion FSS Reports-October 8, 2020 Conference Call) for discussion of replicate
!SOCS measuremen~ that were acquired for QC agreement.
During the FSS of the 116 open land survey units at Zion, 183 duplicate or split samples were acquired t(_) meet the required frequency of 5%. Of the 183 samples analyzed, Cs-137 was,
positively detected in both the standard and QC sample in 42 samples. In the remaining 141 surface and subsurface soil samples acquired to meet the replicate frequency, no plant-derived radionuclides were positively detected in.either the standard sample or the QC sample. In the absence of positive concentrations of plant-derived radionuclides, K-40 was used to demonstrate agreement. As K-40 is a naturally occurring gamma emitter with a discemable 1,460 KeV gamma, it can be used to demonstrate accuracy and precision agreement on a counting system used to analyze two aliquots. As it is assumed to be homogeneously distributed in the soil media, it can be used in lieu of a water-soluble radionuclide such as Cs-137. The other major gamma-emitting ROC at Zion is Co-60. Co-60 is a particulate radionuclide and is not soluble.
Therefore, the homogeneous distribution of Co-60 in a soil matrix between* two aliquots is not
Replicate Measurement Assessment forms for 4 of the 183 samples. However, in all four cases, Cs-13 7 was also positively detected, and the documented Co-60-results were not used to demonstrate agreement.
In 27 of the 42 samples where Cs-137 was positively detected in both the standard and QC sample, agreement was achieved using the resolution table from Inspection Procedure No.
84750._ Ten (10) of the 42 sample comparisons showed a resolution for Cs-137 ofless than four, which is not comparable. In these 10 cases, agreement was achieved using K-40 with ratios acceptable to the resolution table from the current revision of Inspection Procedure No. 84750.
In 5 of the 42 samples where Cs-137 was positively d,etected*iri both the standard and QC sample, sample comparisons showed an unacceptable ratio for Cs-137 between the standard and QC sample. In 4 of the 5 sample comparisons with unacceptable ratios for Cs-137, agreement was achieved using the K-40 concentrations. As this is an indicator that the C~-13 7 concentrations were not homogeneou~ly distributed between the two aliquots, the acceptable ratios for K-40 demonstrated acceptable agreement. In the one sample comparison where both Cs-137 and K-40 demonstrated unacceptable ratios, three additional QC samples were acquired, and agreement was demonstrated in all three.
Page 93 of 109
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports Based on this review, ZionSolutions concluded that the survey data is not suspect and represents the actual radiological conditions in the overall survey units. The results of the review of the analysis of QC soil samples taken during the FSS of open land survey units is provided in the following table. Due to rounding errors, the values provided in the table below may deviate slightly from the values provided in the applicable release records.
Page 94 of 109
ZionSo/utions, LLC ZS-2021-000 l Response to Request for Additional Information Related to the Final Status Survey Reports Review of QC Soil Samples Acquired during FSS of Open Land Survey Units Sample ID Standanl QC Survey Correct Unit Description Phase 84750 Table Slandanl QC Isotope Activity Error Resolution Range Activity Error Ratio Agreement Cs-137 6.12E-02 I.S6E-02 3.92 NIA 6.32E-02 I.S6E-02 NIA No 10201A NE Comer of Restricted Area - Lakeshore No Ll-10201A-FSGS-006-SS Ll-10201A-FQGS-006-SS K-40 l.03E-+-OO 7.28E-01 1.41 0.5-2.0 9.57E-+-00 6.91E-OI 0.11 Yes 102018 NE Comer of Restricted Area - Lakeshore No LI - 102018-FSGS-006-SS ~
FQGS-006-SS K-40 3.97E-+-OO 3.50E-01 11.34 0.5-2.0 3.65E-+-OO 3.32E-Ol 1.09 Yes l0201C NE Comer of Restricted Area - Lakeshore Yes LI - 10201C-FSGS-012-SS Ll -1 0201C-FQGS-012-SS Cs-137 l.20E-Ol 1.56E-02 7.69 0.6-1.66 l.70E-01 l.40E-02 0.71 Yes LI - 1020 I D-FSGS-012-SS Ll-10201D-FQGS-012-SS Cs-137 4.98E-02 l.24E-02 4.02 0.5-2.0 4.06E-02 7.03E-03 1.23 Yes 1020 1D NE Comer of Restricted Area - Lakeshore Yes Ll-10201D-FSGS-012-S8 Ll-10201D-FQGS-012-S8 K-40 4.55E-+-OO 3.92E-O l 11.61 0.6-1.66 5.07E-+-OO 4.23E-01 0.90 Yes 10202A IRSF/Fi-e Trailing Area No LI-I 0202A-FSGS-007-SS Ll-10202A-FQGS-007-SS K-40 5.I IE-+-00 4.l lE-0 1 12.43 0.6-1.66 5.18E-+-OO 4.22E-01 0.99 Yes LI - I 02028-FSGS-004-SS Ll-102028-FQGS-004-SS K-40 4.55E-+-OO 3.78E-01 12.04 0.6-1.66 4.52E-+-OO 3.87E-01 1.01 Yes 102028 lRSF/Fi-e Trailing Area No Ll-102028-FIGS-OO I-SS Ll-102028-QIGS-001-SS K-40 5.23E-+-OO 4.17E-O I 12.54 0.6-1.66 5.09E+OO 4.07E-Ol 1.03 Yes LI - I 02028-FIGS-008-SS Ll-102028-Q JGS-008-SS Cs-137 7.33E-02 1.51 E-02 4.85 0.5-2.0 6.39E-02 1.41 E-02 1.15 Yes l0202C IRSF/Fi-e Trailing Area No LI-I 0202C-FSGS-007-SS Ll-10202C-FQGS-007-SS K-40 5.97E-+-00 4.64E-01 12.87 0.6-1.66 6.23E-+-OO 4.82E-OI 0.96 Yes LI - I 0202D-FSGS-OIO-SS LI-10202D-FQGS-OIO-SS K-40 6.07E-+-OO 4.49E-01 13.52 0.6-1.66 6.76E-+-OO 4.74E-01 0.90 Yes 10202D IRSF/Fi-e Trailing Area No Ll-102028-F JGS-OOI-SS Ll-102028-Q IGS-OOI-SS K-40 7.85E-+-OO 5.79E-OI 13.56 0.6-1.66 9.16E-+-OO 6.17E-OI 0.86 Yes 10203A F.ast Trainng Area 4
No LI - I 0203A-FSGS-O 13-SS Ll-l0203A-FQGS-013-SS K-40 6.85E-+-OO 5.19E-0 1 13.20 0.6-1.66 6.94E-+-OO 5.27E-Ol 0.99 Yes Cs-137 l.45E-01
Yes K-40 6.36E-+-OO 4.77E-01 13.33 0.6-1.66 6.21E-+-OO 4.80E-OI 1.02 Yes LI-I 02038-FJGS-OOI-SS LI - I 02038-QJGS-OO 1-SS K-40 7.24E-+-OO 5.16E-01 14.03 0.6-1.66 7.38E-+-OO 5.24E-01 0.98 Yes Ll-10203C-FSGS-004-SS Ll-10203C-FQGS-004-SS K-40 6.04E-+-OO ~
I 13.33 0.6-1.66 7.24E-+-OO 5.4 1E-OI 0.83 Yes 10203C East Trainr@ Area 4
Yes LI-I 0203C-F JGS-001-SS Ll -1 0203C-QJGS-OOI-SS Cs-137 9.81E-02 2.00E-02 4.91 0.5-2.0 6.53E-02 l.90E-02 I.SO Yes LI - I 0203D-FSGS-002-SS Ll -1 0203D-FQGS-002-SS K-40 6.46E-+-OO U4&01 13.63 0.6-1.66 6.96E-+-OO 5.04E-01 0.93 Yes 10203D East Training Area No Ll-10203D-FJGS-00 1-SS LI-I 0203D-QJGS-OO 1-SS K-40 l.50E+ol
No LI - I 0203E-FIGS-002-SS Ll-10203E-QIGS-002-SS K-40 7.59E-+-OO 5.64E-01 13.46 0.6-1.66 7.41E-+-OO 5.40E-01 1.02 Yes 10203F East Training Area 4
Yes Ll-10203F-FSGS-008-SS Ll-10203F-FQGS-008-SS K-40 6.85E-+-OO
Yes LI - I 0204A-FSGS-O 19-SS Ll-10204A-FQGS-019-SS K-40 5.72E-+-OO 4.66E-01 12.27 0.6-1.66 5.20E-+-OO 4.56E-Ol 1.10 Yes LI - 102048-FSGS-009-SS Ll-102048-FQGS-009-SS K-40 8.84E-+-OO 5.65E-OI 15.65
Yes Ll-102048-F IGS-001-SS Ll-102048-QJGS-OOI-SS K-40 1.05E+o l 6.45E-01 16.28 0.75-1.33 l.08E+ol 6.68E-01 0.97 Yes 10204C North Gate Area 4
Yes LI - 10204C-FSGS-OOI-SS Ll-10204C-FQGS-OOI-SS K-40 4.30E-+-OO 3.56E-OI 12.08 0.6-1.66 5.39E-+-OO 4.06E-01 0.80 Yes LI - I 0204D-FSGS-O 12-SS Ll-10204D-FQGS-012-SS K-40 5.21E-+-OO 4.33E-01 12.03 0.6-1.66 5.78E-+-OO 4.46E-01 0.90 Yes 10204D North Gate Area 4
Yes Ll-10204D-FIGS-OOI-SS Ll-10204D-QJGS-OOI-SS K-40 2.85E-+-OO 2.72E-OI 10.48 0.6-1.66 3.49E-+-OO 2.94E-0 1 0.82 Yes 10205 Switc~ard Yes L3-10205A-FRGC-013-CV L3-10205A-FRQC-013-CV K-40 I.S2E-+-OO 4.80E-OI 3.17 NIA 2.21E+ol 7.15E-01 0.07 Yes Cs-137 6.08E-02 l.62E-02 3.75 NIA l.14E-01 l.74E-02 0.53 No LI - I 0206A-FSGS-005-SS Ll-10206A-FQGS-005-SS 10206A Station Construction Area 4
Yes K-40 6.21E+OO 4.43E-01 14.02 0.6-1.66 6.72E-+-OO 4.71E-0 1 0.92 Yes Ll-10206A-FSGS-013-SS ~
0206A-FQGS-O 13-SS K-40 8.62E-+-OO 5.94E-01 14.51 0.6-1.66 9.13E-+-OO 6.20E-01 0.94 Yes 6.21E-0 1 LI-I 02068-FSGS-005-SS Ll-102068-FQGS-005-SS K-40 l.03E+OI 6.74E-01 15.28 0.6-1.66 9.33E+OO 1.10 Yes 102068 Station Construction Area 4
Yes Ll-102068-FIGS-OO I-SS Ll-102068-QIGS-00 1-SS K-40 1.05E+ol 6.46E-Ol 16.25 0.75-1.33 8.90E-+-OO 5.69E-0 1 1.18 Yes Page 95 of I 09
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports Review of QC Soil Samples Acquired during FSS of Open Land Survey Units (continued)
Sample rD S1andard QC Survey Corn:c1 Unit Description Phase 84750 Table Slandard QC Isotope Adivily En-or Resolution Range Activity En-or Ratio Ag~ement Cs-137 5.91&02 1.53E-02 3.86 NIA 5.97&02 l.52E-02 0.99 No 10206C Station Construction Area 4
Yes Ll-10206C-FSGS-014* S Ll-10206C-FQGS-014*SS K-40 7.70E+oo 5.66&01 13.60 0.6--1.66 8.56E+oo 6.19E-01 0.90 Yes Ll-10206D-FSGS-0 13-SS Ll-10206D-FQGS-013-SS Cs-137 7.10&02 l.39E-02 5.11 0.5-2.0 4.23&02 1.1 IE-02 1.68 Yes 10206D Station Construction Area 4
Yes Ll-10206D-FIGS-001-SB LI* 10206D-QIGS-OOl*SB K-40 6.40E+oo 4.37E-0I 14.65 0.6--1.66 9.50E+oo 6.22E-01 0.67 Yes 10206E Station Construction Area 4
Yes LI* I 0206F,-FSGS-008-SS LI -10206F,-FQGS-008-SS K-40 6.08E+oo 4.74E-01 12.83 0.6--1.66 7.40E+oo 5.40E-01 0.82 Yes LI -10207A-FSGS-0 l 2-SS Ll-10207A-FQGS-012-SS K-40 1.14E+-01 7.29E-01 15.64 0.6--1.66 l.12E+-01 7.37E-01 1.02 Yes LI -10207A-FSGS-017-SS Ll-10207A-FQGS-0l 7-SS K-40 6.14E+oo 4.30&01 14.28 0.6--1.66 5.39E+oo 3.97E-01 1.14 Yes 10207A North Warehouse Area 4
Yes LI -10207A-FIGS-OOI-SS Ll-10207A-QIGS-OOI -SS K-40 I.I 9E+-01 7.19E-01 16.55 0.75-1.33 1.20E+-01 6.50E-0I 0.99 Yes LI -10207A-FIGS-025-SS Ll-10207A-QIGS-025-SS K-40 3.92E+oo 3.70&01 10.59 0.6-- 1.66 3.28E+oo 3.19E-01 1.20 Yes LI - 102078-FSGS-0 14-SS Ll-1020713--FQGS-0 14-SS K-40 I. I 5E+-01 7.06E-0 1 16.29 0.75-1.33 9.1 IE+oo 6.18E-01 1.26 Yes 102078 North Warehouse Area 4
Yes Ll-102078-FIGS-001-SS Ll-1020713--QIG -001-SS K-40 4.38E+oo 3.78&01 11.59 0.6-- 1.66 4.35E+oo 3.92E-01 1.01 Yes LI* I 0207C-FSGS-009-SS Ll-10207C-FQGS*009*SS K-40 1.02E+-OI 6.81&0 1 14.98 0.6--1.66 9.61E+oo 6.46E-0 1 1.06 Yes 10207C orth Warehouse Area 4
Yes Cs-137 5.07&02 1.50&02 3.38 NIA 7.38E-02 l.20E-02 0.69 No LI -10207C-FIGS-OOI-SS LI - I 0207C-QIGS-OO 1-SS K-40 8.75E+oo 5.68E*0I 15.40 0.6--1.66 9.35E+oo 5.15E-01 0.94 Yes LI -10207D-FSGS-O 12-SS Ll-10207D-FQGS-01 2-SS Cs-137 5.44&02 1.46&02 3.73 NIA 4.53&02 1.40&01 1.20 No 10207D North Warehouse Area 4
Yes K-40 8.14E+oo 5.3 1E-0 I 15.33 0.6--1.66 9.57E+oo 6.09E-0 1 0.85 Yes LI -102070-FIGS-OOI-SS Ll-10207D-QIGS-OO I-SS K-40 8.09E+oo 5.40E-0 1 14.98 0.6--1.66 8.20E+oo 5.37E-0 1 0.99 Yes 10207E orth Warehouse Area 4
Yes Ll-10207E-FSGS-0 I0-SS Ll-10207FrFQGS*0I0*SS K-40 6.44E+oo 4.90E-0 1 13.14 0.6--1.66 7.80E+oo 5.62E-0I 0.83 Yes
--4 LI-I 0208A-FSGS-0 I 9-SS LI - 10208A-FQGS-Ol 9-SS K-40 8.94E+oo 6.11&01 14.63 0.6--1.66 9.44E+oo 6.20E-01 0.95 Yes 10208A Soith Warehouse Area 4
Yes LI* I 0208A-FSGS-02 I-SS LI -10208A-FQGS-021 -SS Cs-137 8.74&02 1.62&02 5.40 0.5-2.0 5.53&02 1.61&02 1.58 Yes 102088 Soith Warehouse Area 4
Yes Ll-102088-FSGS-010-SS Ll-1020813--FQGS-0I0-SS K-40 6.61E+oo 4.84&01 13.66 0.6--1.66 6.67E+oo 4.74E-0I 0.99 Yes LI* I 0208C-FSGS-005-SS LI - 10208C-FQGS-005-SS K-40 7.44E+oo 4.99&01 14.91 0.6--1.66 6.85E+oo 4.76E-01 1.09 Yes 10208C Sm.ch Warehouse Area 4
Yes Ll - 10208C-FIGS-004-SS LI - I 0208C-Q!GS-004-SS K-40 8.00E+OO 5.65&01 14.16 0.6-- 1.66 7.42E+OO 5.25E-0I 1.08 Yes Ll-10208D-FSGS-005-SS Ll-10208D-FQG -005-SS K--40 l.38E+oo 1.54&01 8.%
0.6--1.66 l.15E+oo 1.57&01 1.20 Yes 10208D Sm.th Warehouse Area 4
Yes Ll-10208D-FIGS-007-SS LI -10208D-QIGS-007-SS K-40 9.69E+oo 6.39E-01 15.16 0.6--1.66 I.I IE+-01 7.04E-01 0.87 Yes Restricted Area Solih of Gate House Ll-10209A-FSGS-010-SS LI - 10209A-FQGS-010-SS K-40 7.78E+oo 5.25&0 1 14.82 0.6--1.66 7.66E+oo 5.18E-01 1.02 Yes 10209A 0
LI* 10209A*FIGS*OOl*SS LI* 10209A*QIGS*OOl*SS K-40 7.66E+oo 5.43E-0I 14.11 0.6--1.66 7.41E+oo 5.43E-01 1.03 Yes 102098 Restricted Area olih of Gate House No LI* I 02098-FSGS-003-SS LI* I 020913--FQGS-003-SS K-40 2.86E+oo 2.89&01 9.90 0.6-- 1.66 3.14E+oo 3.1 IE-01 0.91 Yes Ll-10209C-FSGS-OOI-SS Ll-1 0209C-FQGS-OO I-SS Cs-137 1.48&01 2.1 IE-02 7.0 1 0.5*2.0 1.32&01 l.96E-02 1.12 Yes 10209C Restricted Area South of Gate House 4
Yes Ll-10209C-FSGS-010-SS LI - 10209C-FQGS*0I0-SS Cs-137 8.37&02 1.59&02 5.26 0.5-2.0 8.23E-02 1.60E-02 1.02 Yes 10209D Restricted Area South of Gate House No LI -10209D-FSGS-0l 4-SS Ll-10209D-FQGS-014-SS Cs-137 7.12&02 1.62&02 4.40 0.5*2.0 6.59&02 1.57E-02 1.08 Yes LI* 10209E-FSGS-0l 4-SS Cs-137 6.20&02 1.67E-02 3.71 NIA 6.32&02 l.56E-02 NIA No Ll-10209E-FQGS-014-SS 10209E Restricted Area South of Gate House 0
K-40 7.50E+oo 5.33&01 14.07 0.6--1.66 7.23E+oo 5.27E-01 1.04 Yes Ll-10209D-FIGS-002-SS LI - I 0209D-QIGS-002-SS Cs-137 l.72E-01 2.33&02 7.38 0.6--1.66 1.20&01 l.92E-01 1.43 Yes 10210A Restricted Area Solih ofT..-bne Building Yes Ll-102 1 0A-FSGS-009-SS Ll-10210A-FQGS-009-SS K-40 7.0IE+oo 3.76E-01 18.64 0.75-1.33 7.28E+oo 5.44E-01 0.%
Yes 102108 Restricted Area South ofT..-bne Building 3
Yes Ll-102 108 -FSGS-010-SS LI-I 02 108 -FQGS-0IO-SS K-40 4.67E+oo 4.16E-01 11.23 0.6-- 1.66 4.91E+oo 3.99E-0I 0.95 Yes 102 10C Restricted Area South ofT..-bne Building 3
Yes Ll-10210C-F GS-001* S Ll-10210C-FQGS-OOI-SS K-40 5.45E+oo 4.54&01 12.00 0.6-- 1.66 5.40E+oo 4.30E-01 1.01 Yes 10211A SE Comer of Restricted Area (Lakeshore)
Yes Ll-1021 IA-FSGS-013-SS Ll-1021 IA*FQGS-013-SS K-40 7.27E+oo 4.86&01 14.%
0.6-- 1.66 7.63E+oo 5.43E-01 0.95 Yes Page 96 of l 09
ZionSolutions, LLC ZS-2021-000 I Response to Request for Additional Information Related to the Final Status Survey Reports Review of QC Soil Samples Acquired during FSS of Open Land Survey Units (continued)
Sample ID Standanl QC Survey Con-ect Un~
Description Phase 84750 Table Standanl QC Isotope Activity Error Resolution Range Activity Error Ratio Ag,.,.ment Ll-102 118-FSGS-014-SS LJ-1021 18--FQGS-014-SS K-40 6.80E+oo 5.12E-0I 13.28 0.6-1.66 7.24E+oo 5.28E-0I 0.94 Yes 102118 SE Comer of Restricted Area (Lakeshore)
Yes Ll-1021 18-FSGS-0 14-SB Ll-102 11 8--FQGS-014-SB K-40 6.2IE+OO 4.69E-01 13.24 0.6-1.66 5.93E+OO 4.43E-01 1.05 Yes L2-102 l 2A-FSGS-005-SS L2-I 02 I 2A-FQGS-005-SS Cs-137 l.32E-0I 2.l3E-02 6.20 0.5-2.0 l.62E-0l 2.38E-02 0.81 Yes 10212A E Comer ofExcl.Jsion Area - Lakeshore 4
Yes L2-l0212A-FIGS-002-SS L2-I 02 I 2A-QIGS-002-SS Cs-137 l.48E-0I l.97E-02 7.51 0.5-2.0 l.67E-0I l.97E-02 0.89 Yes LJ-10212B-FRGS-002-SS L3-t 02 128--FQGS-002-SS K-40 6.49E+oo 5.53E-0I 11.74 0.6-1.66 6.97E+oo 5.4 1E-01 0.93 Yes l021 2B VCC Construction Area 4
Yes L3-10212B-FIGS-00t-S LJ-102128--QIGS-OOI-SS K-40 4.I0E+OO 3.63E-01 11.29 0.6-1.66 3.78E+oo 3.5 I E-01 1.08 Yes LI - I 02 I 2C-FSGS-002-SS LI -I 02 12C-FQGS-002-SS K-40 6.82E+OO 5.26E-0I 12.97 0.6-1.66 7.05E+OO 5.40E-01 0.97 Yes 1021 2c NE Comer ofExcllsion Area - Lakeshore 4
Yes Ll-10212C-FSGS-0l 1-SS Ll-l0212C-FQGS-0I 1-SS Cs-137 l.29E-01 l.82E-02 7.09 0.5-2.0 l.59E-0l 2.3 IE-02 0.81 Yes LI - I 02 12D-FSGS-I 06-SS Ll -1 02 120-FQGS-106-SS Cs-137 l.21E-0 I l.96E-02 6.17 0.5-2.0 l.24E-01 2.0 IE-02 0.98 Yes 102120 NE Comer ofExcUSi:m Area - Lakeshore 4
Yes LI - I 02120-FSGS-I I I -SS Ll-102 12D-FQGS-I I 1-SS K-40 5.24E+OO 4.l2E-0 1 12.72 0.6-1.66 4.72E+OO 4.02E-0 1 I.II Yes 10213A NE Corner ofExcUSion Area 4
Yes L2-102 13A-FSGS-005-SS L2-102 IJA-FQGS-005-SS Cs-137 8.5 I E-02 l.52E-02 5.60 0.5-2.0 6.60E-02 l.64E-02 1.29 Yes Ll-10213B-FSGS-0l 5-SS Ll -1 02 138--FQGS-0t 5-SS Cs-137 3.47E+OO 2.l7E-01 15.99 0.6-1.66 2.64E+OO t.74E-0I 1.3 I Yes l0213B E Comer ofExcUSion Area 4
Yes Cs-137 2.l7E-01 2.84E-02 7.64 0.5-2.0 3.75E-0l 3.86E-02 0.58 Yes Ll-102138-FIGS-OO I-SS Ll-102 138-QIGS-OOI-SS K-40 7.38E+OO 5.66E-0 1 13.04 0.6-1.66 6.56E+oo 5.60E-0 1 1.13 Yes LJ-l02t3C-FSGS-004-SS Ll - l0213C-FQGS-004-SS Cs-137 1.17E-01 2.00E-02 5.85 0.5-2.0 7.84E-02 l.75E-02 1.49 Yes l02l3C NE Comer ofExcl.Jsion Area 4
Yes LI-I 02 IJC-FIGS-001-SS LJ-l02 13C-QIGS-00t-SS Cs-137 3.55E-01 3.42E-02 10.38 0.6-1.66 4.82E-01 4.03E-02 0.74 Yes L2-I 02 I 4A-FSGS-002-SS L2-l02 l4A-FQG -002-SS K-40 5.52E+OO 4.16E-0 1 13.27 0.6-1.66 5.34E+oo 4.12E-0I 1.03 Yes 10214A Constru;;tOn Parking Area 4
Yes L2-10214A-FIGS-OO I-SS L2-l02 14A-QIGS-00I-SS Cs-137 9.50E-02 2.27E-02 4.19 0.5-2.0 1.14E-0I 2.11 E-02 0.83 Yes L2-I 02 I 4B-FSGS-006-SS L2-l02 l4B-FQGS-006-SS K-40 2.13E+oo 2.68E-01 7.95 0.5-2.0 2.22E+oo 2.64E-0I 0.96 Yes l0214B Constru::tion Parking Area 4
Yes L2-l0214B-FIGS-001 -SS L2-l0214B-QIGS-001-SS K-40 7.90E+OO 4.55E-01 17.36 0.6-1.66 7.35E+oo 5.70E-01 1.07 Yes L2-10214C-FSGS-0 l 2-SS L2-102 14C-FQGS-0l2-SS K-40 3.47E+OO 3.24E-0 t 10.71 0.6-1.66 3.94E+oo 3.52E-0I 0.88 Yes 10214C Constru::tion Parking Area 4
Yes L2-102 14C-FIGS-OO I-SS L2-l02 14C-QIGS-00I-SS K-40 7.64E+OO 5.16E-0I 14.81 0.6-1.66 7.46E+oo 5.I0E-01 1.02 Yes L2-10214D-FSGS-0 l4-SS L2-l0214D-FQGS-0l4-SS K-40 3.49E+OO 3.50E-0I 9.97 0.6-1.66 3.51E+OO 3.47E-01 0.99 Yes 10214D Constru:ti:m Parking Area 4
Yes L2-10214D-FIGS-OOI-SS L2-l0214D-QIGS-00I-SS Cs-137 6.57E-02 1.73E-02 3.80 NIA 7.67E-02 1.70E-02 0.86 No K-40 7.52E+OO 5.36E-0l 14.03 0.6-1.66 7.95E+oo 5.51E-01 0.95 Yes Lt-l0214E-FSG -008-SS LI-I 0214E-FQGS-008-SS K-40 8.27E+oo 5.96E-0I 13.88 0.6-1.66 6.83E+oo 5.22E-0l 1.21 Yes 10214E Constn.ctOn Parking Area 4
Yes Ll-l0214E-FIGS-OOI-SB Ll-l0214E-QIGS-OOI-SB K-40 6.03E+OO 4.27E-0t 14.12 0.6-1.66 6.28E+OO 4.5IE-0 1 0.96 Yes Ll-102l4F-FSG -011-SS Ll-102 14F-FQGS-011-SS K-40 2.57E+OO 2.77E-0t 9.28 0.6-1.66 2.43E+oo 2.68E-01 1.06 Yes l02l4F Constnction Parking Area 4
Yes Ll - l0214F-FIGS-00t-SS LI-I 02 14F-QIGS-001-SS K-40 6.67E+OO 4.96E-0I 13.45 0.6-1.66 6.38E+OO 4.75E-01 1.05 Yes LJ-102 I 9A-FRGS-006-SS L3-l02l 9A-FRGS-006-SS K-40 7.19E+OO l.78E+OO 4.04 0.5-2.0 7.49E+oo t.78E+OO 0.96 Yes 10219A Area Far Sol4h ofSwtchyard Yes L3-l0219A-FRGS-0 14-SS L3-I 02 l9A-FRGS-014-SS K-40 7.46E+OO l.75E+OO 4.26 0.5-2.0 6.8IE+OO l.74E+OO 1.10 Yes l0219B Area Far Sol4h ofSwtchyard Yes LJ-10219B-FRGS-0l 2-SS LJ-102198-FQGS-0l 2-SS Cs-137 l.56E-01 8.54E-02 1.83 NIA 2.67E-01 1.16E-0I 0.58 Yes LI - I 0220A-FSGS-I 05-SS Ll-l0220A-FQGS-l05-SS K-40 5.36E+oo 4.58E-01 11.70 0.6-1.66 6.08E+oo 4.73E-0I 0.88 Yes 10220A SE Comer ofExch.oion Area - Lakeshore 4
Yes Ll-l0220A-FSGS-l21-SS Ll - l0220A-FQGS-l21 -SS K-40 5.0IE+oo 4.0IE-0 1 12.49 0.6-1.66 5.09E+OO 4.08E-0t 0.98 Yes Ll-l0220A-FIGS-OO I-SS LI-I 0220A-QIGS-00I-SS K-40 5.65E+oo 4.22E-01 13.39 0.6-1.66 6.43E+oo 4.54E-0I 0.88 Yes l0220B SE Comer ofExch.oion Area - Inland 3
Yes Ll-10220B-FSGS-008-SS L 1-102208-FQGS-008-SS K-40 5.02E+OO,--
4.08E-0 I 12.30 0.6-1.66 5.25E+OO 4.37E-0 1 0.96 Yes 10220C Adjacent ofSol4h Restricted Area (Lakeshore)
Yes L3-10220C-FRGS-0 I 1-SS L3-1 0220C-FQGS-0t 1-SS Cs-137 1.65E-0t 3.68E-02 4.48 0.5-2.0 l.95E-0I 4.52E-02 0.85 Yes l0220D SE Comer of Exclusion Area - Inland Yes Lt-102200-FSGS-008-SS Ll-102200-FQGS-008-SS K-40 4.79E+OO 4.26E-0 1 11.24 0.6-1.66 5.57E+OO 5.88E-01 0.86 Yes Page 97 of I 09
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports Review of QC Soil Samples Acquired during FSS of Open Land Survey Units (continued)
Sample ID Standonl QC Survey Corner Unit DHcription Pba1t 84750 Table Standard QC Isotope Activity En-or RHolution Range Activity Error Ratio Ag~ement 10220E SE Comer offxclusion Area - lnlard Yes Ll-10220&FSGS-0I 1-SS Ll-10220E-FQGS-0I I-SS K-40 5.23E+oo 4.30E-01 12.16 0.6-1.66 5.49E+oo 4.21&01 0.95 Yes 10220F SE Comer offxclusion Area - lnlard No Ll-10220F-FSGS-013-SS LI-I 0220F-FQGS-0l 3-SS K-40 2.85E+oo 3.30E-01 8.64 0.6-1.66 3.45E+oo 3.47E-01 0.83 Yes Ll-10220G-FSGS-0I0-SS LI - I 0220G-FQGS-0 I 0-SS K-40 5.02E+oo 3.90E-0 I 12.87 0.6-1.66 4.65E+oo 3.53&01 1.08 Yes 10220G SE Comer offxclusion Area - lnlard 0
LJ-10220G-FSGS-010-SB Ll-10220G-FQGS-0I0-SB K-40 5.12E+oo 3.87&01 13.23 0.6-1.66 5.71E+oo 4.12E-0I 0.90 Yes L 1-I0220H-FSGS-006-SS LI-I 0220H-FQGS-006-SS K-40 4.89E+oo 4.17&01 11.73 0.6-1.66 5.26E+oo 4.17&01 0.93 Yes 10220H SE Comer offxclusion Area - Lakeshore 4
No Cs-137 9.48&01 6.36&02 14.91 0.6-1.66 4.74&01 3.52&02 2.00 Yes Ll-10220H-FJGS-004-SS LI - I 0220H-QJGS-004-SS K-40 6.49E+oo 3.88E-01 16.73
0.86 Yes 102201 SE Comer of Exclusion Area - Lakeshore 4
No Ll-102201-FJGS-005-SS LI - I 02201-QJGS-005-SS Cs-137 1.54E+oo 1.1 0E-0 I 14.00 0.6-1.66 1.41E+oo 1.03&01 1.09 Yes 102201 SE Comer of Exclusion Area - lnlard No L 1-I 02201-FSGS-003-SS Ll -10220J-FQGS-003-SS K-40 5.80E+oo 4.69E-01 12.37 0.6-1.66 4.59E+oo 3.75&0 1 1.26 Yes Ll-1022 1 A-FSGS-005-SS L 1-1 0221 A-FQGS-005-SS K-40 4.52E+oo 3.97&01 11.39 0.6-1.66 6.I0E+oo 4.78&01 0.74 Yes Ll-1022 1A-FIGS-00I-SS Ll-10221A-QIGS-001-SS Cs-137 7.50E+oo 4.66E-01 16.09
Yes Cs-137 3.70&01 3.57&02 10.36 0.6-1.66 6.99&01 5.66&02 0.53 No Ll-10221 A-FIGS-001-SB Ll-10221A-QIGS-OOI-SB K-40 7.97E+oo 5.50&01 14.49 0.6-1.66 7.18E+oo 5.47&01 I.I I Yes Ll-1022 1A-FSGS-107-SS Ll-10221A-FQGS-107-SS K-40 6.19E+oo 4.81&01 12.87 0.6-1.66 6.13E+oo 4.93&01 1.01 Yes Ll-1022 1A-FSGS-I I I-SS Ll-10221A-FQGS-I I I-SS K-40 6.14E+oo 4.31E-0I 14.25 0.6-1.66 5.62E+oo 4.11&01 1.09 Yes Ll-102218-F GS-001-SS Ll-102218-FQGS-001-SS K-40 2.60E+oo 2.55&01 10.20 0.6-1.66 3.08E+oo 2.81&01 0.84 Yes 102218 Soti.h of Protected Area - lnlard No Ll-10221 B-FJGS-001-SS Ll-102218-QJGS-OOI-SS K-40 3.00E+oo 2.98&01 10.07 0.6-1.66 3.24E+OO 3.02&01 0.93 Yes Cs-137 3.18&01 3.23&02 9.85 0.6-1.66 1.52&01 1.95&02 2.09 0
Ll-10221 C-FSGS-012-SS Ll-10221C-FQGS-0l 2-SS K-40 9.45E+oo 6.26E-0I 15.10 0.6-1.66 9.89E+OO 6.29&01 0.96 Yes 10221c Soti.h of Protected Area - lnlard 4
Yes Ll-10221 C-FJGS-001-SS Ll-10221C-QJGS-OOI-SS K-40 3.82E+oo 3.25&01 11.75 0.6-1.66 3.0IE+oo 2.77&01 1.27 Yes LI-I 022 1 C-FIGS-1 I 0-SS Ll-1022 1C-QIGS-I I0-SS K-40 3.53E+oo 3.37&01 10.47 0.6-1.66 2.93E+oo 3.06&01 1.20 Yes Ll-1022 1D-FSGS-009-SS Ll-10221D-FQGS-009-SS K-40 5.67E+oo 4.53E-0I 12.52 0.6-1.66 5~ 4.34&01 1.13 Yes Ll-1022 1 D-FJGS-001-SS Ll-10221 D-QJGS-00 1-SS K-40 2.34E+oo 2.69E-01 8.70 0.6-1.66 2.48E+OO 2.56&01 0.94 Yes l0221D Sotlh of Protected Area - Inland 4
Yes Cs-137 5.75&01 4.90E-02 11.73 0.6-1.66 3.23&01 3.17&02 1.78 No Ll-l0221 D-FIGS-013-SS Ll-10221D-QJGS-0l3-SS 6.32E+oo 4.79&0I 13.19 K-40 0.6-1.66 6.07E+oo 4.55E-0I 1.04 Yes 1022IE Soti.h of Protected Area - Lakeshore Yes Ll-10221 & FSGS-015-SS Ll-1022I E-FQGS-015-SS K-40 7.92E+oo 5.73E-01 13.82 0.6-1.66 8.82E+oo 5.75&0I 0.90 Yes l022JF Soti.h of Protected Area - Lakeshore Yes Ll-10221 F-FSGS-004-SS Ll-1022I F-FQGS-004-SS K-40 7.05E+oo 5.55&0I 12.70 0.6-1.66 6.56E+oo 4.93&0I 1.07 Yes 10221G Soti.h of Protected Area - Lakeshore No Ll-1022 IG-FSGS-002-SS LI -1022 I G-FQGS-002-SS K-40 6.26E+oo 4.70E-01 13.32 0.6-1.66 5.43E+OO 4.29&01 1.15 Yes 10221H Soti.h of Protected Area - Lakeshore 0
Ll-l022IH-FSG -015-SS LI-I 0221H-FQGS-0J 5-SS K-40 3.20E+oo 3.17&01 10.09 0.6-1.66 3.34E+oo 3.12&0I 0.96 Yes 10222 North Beach Area I
Yes LJ-I 0222A-FRGS-007-SS LJ-10222A-FQGS-007-SS K-40 3.55E+oo 3.49&01 10.17 0.6-1.66 4.39E+oo 3.88&01 0.81 Yes 10223 Power Block Beach Area I
Yes L3-l0223A-FRGS-014-SS L3-10223A-FQGS-0l4-SS K-40 4.24E+oo 8.73&01 4.86 0.5-2.0 4.84E+OO 9.37&0I 0.88 Yes
---~
10224 Soti.h Beach Area Yes LJ-I 0224A-FRGS-006-SS LJ-10224A-FQGS-006-SS K-40 4.0IE+oo 8.41&0I 4.77 0.5-2.0 3.82E+oo 8.18&0I 1.05 Yes l0301 West Training Area Yes LJ-I 030 I A-FRGS-0 I 0-SS LJ-1030I A-FQGS-010-SS K-40 7.83E+oo l.08E+OO 7.25 0.6-1.66 8.25E+oo 1.17E+OO 0.95 Yes 12I01 WWTF Sludge Drying Bed Area No Ll-12101 A-FSGS-009-SS LI -12 I 01 A-FQGS-009-SS K-40 8.60E+oo 4.26&01 20.19 0.75-1.33 7.77E+oo 4.65&01 I.II Yes 12102 WWTF Sludge Drying Bed Area No Ll-12 102A-FSGS-OOJ-SS Ll-l 2102A-FQGS-003-SS K-40 l.75E+ol 8.93E-0 1 19.60 0.75-1.33 l.68~
8.65&01 1.04 Yes 12103 WWTF Sludge Drying Bed Area No Ll-l2103A-FSGS-008-SS LI - I 2103A-FQGS-008-SS K-40 9.72E+oo 5.49E-01 17.70 0.75-1.33 9.77E+oo 5.49&01 0.99 Yes Page 98 of I 09
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports Review of QC Soil Samples Acquired during FSS of Open Land Survey Units (continued)
Survey Correct Sample CD Standard QC Unit Description Phase 84750 Table Standard QC Isotope Activity Etror Resolution Range Activity Error Ratio Agreement 12104 North Half ofUnit 2 Containment 4
Yes Ll - 12104A-FSGS-0 13-SS Ll-12104A-FQGS-O 13-SS K-40 9.13E+OO 6.12E-Ol 14.92 0.6-1.66 9.38E+OO 6.21E-Ol 0~
Yes 12105 South Half of Unit 2 Corttairment 4
Yes Ll-12 IOSA-FSGS-002-SS Ll-12 105A-FQGS-002-SS K-40 9.79E+OO 6.30E-01 15.54 0.6-1.66 9.00E+OO 6.04E-01 1.09 Yes 12106 North HalfofFuel & Awciiary Buiklings 4
Yes Ll - 12 106A-FSGS-0 16-SS Ll -12 106A-FQGS-0 16-SS K-40 9.53E+OO 5.90E-0I 16.15
Yes Ll-12107A-FSGS-009-SS Ll -12 107 A-FQGS-009-SS K-40 9.06E+OO 5.89E-Ol 15.38 0.6-1.66 9.06E+OO 5.9 1E-Ol I---
1.00 Yes 12108 North Half of Unit I Containment 4
Yes Ll-12108A-FSGS-001-SS Ll-12 108A-FQGS-OO 1-SS K-40 8.83E+OO 5.65E-Ol 15.63 0.6-1.66 8.42E+OO 5.40E-Ol 1.05 Yes 12109 South Half ofUnit I Corttairment 4
Yes Ll-12109A-FSG -0 12-SS Ll-12109A-FQGS-Ol 2-SS K-40 8.70E+OO 5.88E-Ol 14.80 0.6-1.66 8.59E+OO 5.78E-Ol 1.01 Yes 12110 Yard Between Urit I Corttairurent and Tu-bire 4
Yes Ll-121 IOA-FSGS-006-SS Ll-12 1 IOA-FQGS-006-SS K-40 9.03E+OO 6.22E-0 1 14.52 0.6-1.66 8.62E+OO 6.06E-Ol I.OS Yes Ll-121 IOA-FSG -006-SS Ll-12 1 IOA-FQGS-006-SS K-40 9.34E+OO 6.26E-Ol 14.92 0.6-1.66 8.62E+OO 6.IOE-01 1.08 Yes 12111 South Yard Area Northeast of Gate House 4
Yes Ll-1211 IA-FJGS-OOI-SS Ll -12 1 l lA-QJGS-001-SS K-40 8.52E+OO 5.9 IE-O I 14.42 0.6-1.66 8.61E+OO 5.80E-OI 0.99 Yes Cs-137 3.82E-02 9.83E-03 3.89 NIA 2.35E-01 2.63E-02 0.16 No Ll-121 I2A-FSGS-014-SS Ll-12 11 2A-FQGS-0 14-SS K-40 7.85E+OO 4.68E-O l 16.77
Yes Ll-12113A-FSGS-005-SS LI-I 2 I I 3A-FQGS-005-SS K-40 1.06E+Ol 6.44E-Ol 16.46 0.75-l.33 I.ISE+Ol 7.33E-Ol 0.92 Yes 12201A orth Protected Area Yard 4
Yes Ll-1 2201A-FSGS-0 17-SS Ll-1220 1 A-FQGS-017-SS K-40 9.46E+OO 5.88E-Ol 16.09 0.6-1.66 9.56E+OO 5.97E-Ol 0.99 Yes 122018 North Protected Area Yard 4
Yes LI - I 220 I B-FSGS-007-SS Ll-1220 1 B-FQGS-007-SS K-40 8.85E+OO
Yes L1-12201C-FSG -007-SS L1-1220 IC-FQGS-007-SS K-40 9.33E+OO 6.04E-01 15.45 0.6-1.66 8.89E+OO 5.91E-Ol I.OS Yes Ll-12201 D-FSGS-207-SS Ll-1220 1 D-FQGS-207-SS Cs-137 l.O IE-01 l.82E-02 5.55 0.5-2.0 7.72E-02 I.86E-02 1.3 I Yes 12201D North Protected Area Yard 4
Yes Ll-12201D-FIGS-OOI-SS Ll-1 220 ID-QIG -00 1-SS K-40 4.26E+OO 3.40E-Ol 12.53 0.6-1.66 4.4 1E+OO 3.44E-Ol 0.97 Yes I---
12201E orth Protected Area Yard 4
Yes Ll-1220IE-FSGS-014-SS Ll-1220 1 E-FQGS-014-SS K-40 7.63E+OO 5.47E-Ol 13.95 0.6-1.66 7.17E+OO 5.SSE-01 1.06 Yes 12202A Gate House and Southwest Yard 4
Yes Ll-12202A-FSGS-014-SS Ll -12202A-FQGS-014-SS K-40 9.64E+OO 5.99E-O l 16.09 0.75-1.33 9.82E+OO 6.0SE-01 0.98 Yes 122028 Gate House and Southwest Yard 4
Yes LI -122028-FSGS-007-SS Ll-122028-FQGS-007-SS K-40 8.19E+oo 5.63E-0 I 14.55 0.6-1.66 8.75E+OO 5.96E-01 0.94 Yes 12202C Gate House and Southwest Yard 4
Yes Ll-l2202C-FSGS-O IO-SS LI-I 2202C-FQGS-010-SS K-40 9.67E+OO 6.SIE-0 1 14.85 0.6-1.66 9.79E+OO 6.90E-Ol 0.99 Yes 12202D Gate House and Southwest Yard 4
Yes LI -12202D-FSGS-004-SS L 1-122020-FQGS-004-SS K-40 7.88E+OO 5.65E-0 1 13.95 0.6-1.66 7.93E+OO 5.67E-OI 0.99 Yes LI -12202E-FSGS-004-SS Ll-l 2202E-FQGS-004-SS K-40 7.44E+OO 5.30E-Ol 14.04 0.6-1.66 7.94E+OO 5.71E-01 0.94 Yes 12202E Gate House and Southwest Yard 4
Yes Ll-12202E-FJGS-001-SS LI - I 2202E-QJGS-OO 1-SS K-40 6.59E+OO 4.83E-0 I 13.64 0.6-1.66 6.84E+OO 4.99E-01 0.96 Yes Ll-10202F-FRGS-008-SS LI-I 0202F-FQGS-008-SS K-40 7.42E+OO 5.14E-0 1 14.44 0.6-1.66 6.38E+OO 4.85E-0I 1.16 Yes 12202F Gate House and Southwest Yard 4
Yes Ll-10202F-FJGS-001-SS Ll -10202F-QJGS-00 1-SS K-40 7.95E+OO 5.79E-01 13.73 0.6-1.66 8.93E+OO 6.09E-01 0.89 Yes Cs-137 6.18E-02 l.53E-02 4.04 0.5-2.0 2.32E-O l 2.27E-02 0.27 No Ll-12203A-FSGS-012-SS Ll - l2203A-FQGS-012-SS K-40 l.48E+01 7.82E-Ol 18.93
No K-40 7.83E+OO 4.69E-0 I 16.70
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports Review of QC Soil Samples Acquired during FSS of Open Land Survey Units (continued)
Survey Con-ect Sample ID Standard Unit Description Phase 84750 Table Standard QC Isotope Activity Error Resolution Range Activity 12204A Cm House Area Yes Ll-12204A-FSGS-Ol 5-SS LI-I 2204A-FQGS-OI 5-SS K-40 l.06E+OI 6.07E-OI 17.46 0.75-1.33 9.95E+oo l2204B Cnb House Area 0
Ll-122048-FSGS-004-SS LI -1 2204 B-FQGS-004-SS K-40 l.42E+Ol 7.18E-Ol 19.78 0.75-1.33 1.54E+ol Ll-12204C-FSGS-001-SS Ll -12204C-FQGS-00 I-SS K-40 8.95E+OO 6.35E-01 1409 0.6-1.66 1.3 1 E+ol l 2204C Crib House Area No Ll-l2204C-FSGS-OOI-SB Ll-l 2204C-FQGS-OO I-SB K-40 9.24E+OO 4.72E-0I 19.58 0.75-1.33 9.1 JE+oo Ll -1 2204C-FSGS-002-SS Ll - 12204C-FQGS-002-SS Cs-137 8.47E-02 1.47E-02 5.76 0.5-2.0 6.04E-02 Ll-l2205A-FSGS-l07-SS Ll-l2205A-FQGS-l07-SS K-40 9.75E+OO 6.36E-01 15.33 0.6-1.66 9.85E+oo 12205A Area Under the Ttrbine Buiklif-s 4
Yes Ll-l2205A-FIGS-002-SS LI-I 2205A-QIGS-002-SS K-40 8.80E+OO 5.86E-01 15.02 0.6-1.66 9.1 JE+oo l2205B Area Under the Tu-bine Buiklif-s 4
Yes Ll-122058-FSGS-I 14-SS Ll-122058-FQGS-I 14-SS K-40 I.OOE+OI 6.12E-OI 16.34 0.75-1.33 1.03E+ol 12205C Area Under the Tu-bine Buiklir-6 4
Yes Ll-l2205C-FSGS-I 10-SS Ll -l 2205C-FQGS-I 10-SS K-40 l.05E+OI 6.73E-0I 15.60 0.6-1.66 9.05E+oo l2205D Area Under the Tu-bine Buiklif-s 4
Yes Ll-1 2205D-FSGS-106-SS Ll-12205D-FQGS-l 06-SS K-40 8.77E+OO 6.00E-01 14.62 0.6-1.66 9.39E+oo Ll-l2205E-FQGS-109-SS Ll - l 2205E-FQGS-109-SS K-40 7.67E+OO 5.3 IE-01 14.44 0.6-1.66 7.33E+oo l2205E Area Under the Ttrbine Buiklir-6 4
Yes Ll-12205E-QIGS-l01-SS Ll-12205E-QIGS-I 01-SS K-40 8.35E+OO 5.64E-01 14.80 0.6-1.66 8.l9E+oo Page 100 of 109 QC Error Ratio Agreement 5.60E-01 1.07 Yes 8.l 7E-01 0.92 Yes 7.29E-01 0.68 Yes 5.05E-01 I.OJ Yes
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports NRC RAI Question #13c Provide additional information on what is meant in QC investigations that state the same conclusion was reached for each measurement and therefore no further action is necessary.
RESPONSE: ZionSolutions offers the following clarification on what is meant in QC investigations that state "the same conclusion was reached for each measurement and therefore no further action is necessary."
For a replicate scan measurement, the same conclusion is reached if the replicate scan confirms the alarm status of the original scan measurement. For example, if an alarm is produced in the-original scan, agreement would be reached if an alarm was identified in the replicate scan.
For a replicate static measurement (i.e., buried pipe, embedded pipe, and penetration survey units), the same conclusion is reached if both the standard and replicate static measurements are above or below the OpDCGL (i.e., the same dose conclusion is reached).
For duplicate or split volumetric samples and replicate ISOCS measurements, the same conclusion is reached if both standard and comparison sample or measurement activities are above or below the OpDCGL (i.e., the same dose conclusion is reached).
NRC RAI Question #13d Provide a discussion of the supplementary QC steps that were taken, in addition to the use of a K-40 concentration comparison, in the data assessments for the survey units. The NRC staff notes that K-40 should not, by itself, be considered a substitute for explaining the QC assessment results. The licensee should supplement the QC analyses with other data analysis considerations and/or discussion of the various QA/QC processes that lead to confidence in the data assessment results ( e.g., different MDCs for the ROCs in the samples, heterogeneity of soil samples, use of spiked samples, sample reanalysis, etc.).
RESPONSE: All gamma spectroscopy reports fur each FSS sample, including QC samples is subjected to data validation in accordance with section 5.1 ofZS-LT-300-001-004, Final Status Survey Data Assessment", which includes the following:
Verification that unique sample identjfication number is consistent between the sample analysis report, the Chain-of-Custody (CoC) form and the FSS sample plan.
Verification that the recorded date & time is consistent with the CoC form (if applicable) and the FSS Sample Plan.
Verification that the data is complete and that there are no missing results or supporting data, including but not limited to MDC, uncertainty, background, geometry, or methods of analysis.
Verification that the MDC of the instrument used for analysis was adequate to detect all ROC or gross activity at the target MDC values specified in the FSS Sample Plan.
Page 10 I of 109
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports Verification that the absence of anomalies in the sample or measurement results, or in the supporting data, including but not limited to MOC, uncertainty, deviation from established procedure or analysis flags.
Following data validation, additional confidence in the data assessment results is obtained using 0, Final Status Survey Data Quality Objectives Review Checklist" from procedure ZS-LT-300-001-004. Using the checklist, the FSS sample plan, the sample instructions, the Field Notes, survey records and/or data analysis reports are reviewed to ensure that the DQOs used for the survey design were applicable and valid.
The QC process/requirements specified for FSS as documented in the L TP, the QAPP and the implementing procedures were performed and achieved during FSS. Based on the implementation of the existing QC processes and the observed results, no additional supplementary QC steps were considered or performed.
NRC RAI Question #13e Please describe the QC steps used for the ISOCS measurements, including the use of replicate or duplicate measurements and comparisons to core sample analysis for the survey units where ISOCS was a primary measurement instrument. The licensee should clarify if the ISOCS QC measurements are replicate measurements or duplicate measurements. This clarification should address the use ofNRC Inspection Procedure 84750,
Radioactive Waste Treatment and Effluent and Environmental Monitoring," for ISOCS QC measurements, rather than other evaluation methods described in the QAPP that are used to evaluate results from other measurement systems, such as pipe detectors, that provide radiological data in the same units (pCi per square meter).
RESPONSE: This information has been provided in the response to Additional NRC Question
NRC RAI Question #13f For the duplicate or split measurements that had inadequate resolution, ensure that the licensee is applying Table 4-1 of the QAPP for resolution values.
RESPONSE: This information has been provided in the responses to Additional NRC Question
NRC RAI Question #13g For instances where there was high resolution in both the standard and comparison samples, but the comparison failure is attributed to relatively low concentrations" please provide additional information as per the above bullets in the path forward.
Page 102 ofl 09
ZionSolutio-ns, LLC ZS-2021-0001 Response to Request for Additional Infonnation Related to the Final Status Survey Reports RESPONSE: This infonnation has been provided in the responses to Additional NRC Question
NRC RAI Question #14a Review the aforementioned release records to determine the potential for discrete particles of Co-60 in the sample matrix. It is recommended the licensee provide further explanation of the Co-60 results, besides attributing the results to relatively low concentration of Co-60 in the samples matrix.
RESPONSE: ZionSolutions performed a review of the aforementioned release records to determine the potential for discrete particles of Co-60 in the sample matrix. A discrete radioactive particle as defined in procedure ZS-RP-106-002-005 was encountered in survey unit 10202D during FSS. After the small particle was removed from the soil matrix of sample L 1-10202D-FIGS-001-SS, the sample was counted, which resulted in an OpSOF of0.034. Discrete radioactive particles were not encountered in three of the four survey units cited as examples in the basis for this question. Rather, the Co-60 concentrations cited for survey units 10220H, 102201, and 10221A are considered as low-level residual radioactivity positively detected at concentrations greater than the instrument MDC. In these three survey units (10220H, 102201, and 10221A), the cognizant Radiological Engineer listed Co-60 as an isotope to establish agreement between the standard and QC sample. While not a violation of procedure, use ofCo-60 as a comparable radionuclide to establish QC agreement is technically not recommended due to the particulate nature of Co-60 and the inherent inability to completely homogenize the soil matrix between two split soil aliquots. In all three cases, agreement was reached, either using Cs-137 or K-40.
A discussion of the scan sensitivity to adequately detect particles comprised solely of Co-60 by the Ludlum Model 44-10 Nal detector is addressed in the response to NRC RAJ Question # 11 a.
NRC RAI Question #15a The licensee should perform a comparison of the onsite laboratory results to the Eberline results and investigate the potential differences between the labs.
RESPONSE: The on-site laboratory results and the Eberline results have been compared and the potential differences investigated. The results and conclusions of the comparison are presented below.
A total of 183 soil samples were collected for QC comparison during the perfonnance of PSS.
All of the 183 soil samples were analyzed by the on-site gamma spectroscopy system. Of the 183 QC samples, 27 split samples, representing 22 open land survey units, were sent to Eberline Laboratories for gamma spectroscopy and lITD analysis. This population of27 samples is used for the investigation in this response and is sufficient to make statistical conclusions about the entire sample population.
Page 103 of 109
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports Section 4.2.1 of the QAPP states, "During the performance of FSS, approximately 5% of the total number of split samples taken will be sent for analysis by a qualified off-site laboratory."
The 27 split soil samples meet the 5% frequency specified in the QAPP.
Sample results for Cs-137 between the on-site and off-site laboratories were evaluated using the methodology described in NRC Inspection Procedure No. 84750. The results were acceptable in 8 of the 27 sample comparisons. Ten (10) results were not acceptable. Nine (9) of the samples had a resolution for Cs-137 ofless than 4 and therefore were not required to be assessed. Cs-137 was positively detected at concentrations greater than MDC in all of the standard and comparison samples.
The results of the evaluation using NRC Inspection Procedure No. 84750 are presented in the table below.
Number of Number meeting Number not Number with sample pairs meeting_ NRC IP resolution less NRC IP criteria evaluated criteria than4 27 8
10 9
The sample results for Cs-137 were also evaluated using the methodology presented in Appendix C ofNUREG-1576, "Multi-Agency Radiological Laboratory Analytical Protocols Manual" (MARLAP). The results of the evaluation indicated that 22 of the 27 comparisons were below the warning limit Five (5) comparisons were above the warning limit, and of those, 2 comparisons were also above the control limit. One of the two samples that were greater than the control limit was an investigation sample for an elevated area as summarized in the table below.
Numbe_rof Number Number>
meeting Number>
sample pain MARLAPApp.
Warning
C criteria 27 22 5
2 The potential causes in the difference in the results has been investigat:ed. It is speculated that a potential contributing cause is the preparation methodology of the samples. The basis for this reasoning is detailed below in the response to NRC RAI Question #15c.
NRC RAJ Question #15b Describe how radionuclide concentration data from the onsite Zion gamma spectroscopy laboratory and the off-site Eberline Laboratories measurements for the same samples were evaluated and compared under the Zion QAPP.
Page 104 of 109
ZionSo/utions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports RESPONSE: The results from the on-site Zion gamma spectroscopy laboratory and the off-site Eberline Laboratories measurements for the 27 split samples were compared following Section 4.2.2 of the QAPP and MARLAP protocol (see the response to #15a above).
NRC RAI Question #15c Provide additional information on the samples analyzed by both laboratories. For example, provide information on whether the samples analyzed by each laboratory were the same sample, split samples, or separate samples taken from the same location. In addition, provide information on differences in sample preparation between the two laboratories, and any other differences ( e.g., analytical method) that could explain why the onsite laboratory generally reported lower concentrations than Eberline Laboratories.
RESPONSE: The samples sent off-site to Eberline were split samples, a sample in which the original sample aliquot is separated into two aliquots in the sample preparation area and analyzed as separate samples. One aliquot was typically analyzed on-site and the other sent to Eberline for gamma spectroscopy and HID analysis. The use of split samples can produce differing results, since sample heterogeneity may differ from one sample to the other.
At Zion, soil samples were prepared for analysis in accordance with Section 5.1 of ZS-LT-100-001-004, "Sample Media Preparation." The procedure describes the process to sufficiently dry and homogenize the soil media prior to analyzing the sample with the on-site gamma spectroscopy system. The procedure also states, If the soil sample is to be sent to an off-site laboratory for analysis, then only dry the sample if directed by the survey instructions."
ZionSo/utions did not dry or homogenize soil sample media that was intended for off-site analysis, and sample preparation was performed by Eberline.
Differences in sample preparation can result in discrepancies in sample results, including sample homogenization, differences in sample weight and volume, and differences in moisture percentage. These are all factors that could contribute to a consistent reporting of higher radionuclide concentrations.
In addition, the Zion gamma spectroscopy laboratory counted soil samples in 1-liter Marinelli containers, while a split of this sample was sent to Eberline, which also had additional analyses performed. Therefore, there was a difference in sample volume for analysis by gamma spectroscopy which can highlight sample heterogeneity issues. It also should be noted that while the Eberline results seem to be higher than the on-site results, the on-site analysis routinely achieved slightly lower MOCs.
Laboratory Differences in Sample Prep and Analysis On-site Sample Preparation
Page 105 of 109
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports
Off-site (Eberline) Sample Preparation
From the above, it is clear that the Eberline sample preparation is likely to create soil samples that are more homogeneous compared to the on-site soil preparation and that the drying method is more uniform. Also, it is clear that each analysis is of different sample media.
These differences in sample preparation and analysis could account for a bias in the gamma spectroscopy results between the laboratories.
NRC RAI Question #lSd Given the differences between the onsite measurements and the measurements made by Eberline Laboratories, additional justification is needed to provide assurance that the onsite gamma spectroscopy results were not underreporting the concentration of residual radioactivity in the samples analyzed onsite.
RESPONSE
The reported results by both Eberline and the on-site gamma spectroscopy system were both valid and acceptable for use as FSS data This conclusion was reached based on the following:
Page 106 of 109
ZionSolutions, LLC ZS-2021-0001 Res1xmse to Request for Additional Information Related to the Final Status Survey Reports Both gamma spectroscopy systems were calibrated with NIST traceable sources.
Both systems were subjected to and passed daily operational checks, including pre-and post-use source checks against a standardized source.
All sample analysis reports were validated in accordance with procedure ZS-L T-300-001-004, Final Status Survey Data Assessment."
Even though the sample comparison indicated a consistent reporting of higher concentrations of gamma-emitting radionuclides by the off-site gamma spectroscopy system verses the on-site gamma spectroscopy system, and several sample comparisons between the on-site and off-site results did not show acceptable agreement using the resolution table from Inspection Procedure No. 84750, most samples were acceptable following the MARLAP protocol. Based upon the results of the review, it was concluded that the reported results by both Eberline and the on-site gamma spectroscopy system were both valid and acceptable for use as FSS data.
In conclusion, when comparing the replicate analysis of the same sample, the radionuclide concentrations for gamma-emitting ROC that were reported by Eberline were higher than the radionuclide concentrations for gamma-emitting ROC that were reported by the on-site laboratory.
For the FSS of all open land survey units, the derivation of the mean ROC concentrations for the systematic population and the subsequent mean dose assigned to the survey unit exclusively used the results of the on-site gamma spectroscopy system. In addition, while the Eberline data was not used to derive the mean dose fraction for the survey unit, the dose significance of the sample results was assessed in the same manner as a judgmental or investigation sample. In all cases, the individual gamma spectroscopy results were directly compared against the applicable OpDCGL, and if the concentrations exceeded a SOF of one, then the soils represented by the sample results were remediated.
Upon further evaluation, ZS-2020-0011 shows that the total site dose from the soil pathway is 1.016 mrem/year out of a total of 17.8 mrem/year from all pathways. In the event that the Eberline analytical results could be considered more conservative than the on-site analysis, then this difference would be likely bounded by a factor of nearly 2 as shown in the comparison table below. This table includes QC samples analyzed on-site with the corresponding split samples analyzed at Eberline where the relative standard deviation was less than or equal to 25% for both analysis results and for the analysis of K-40 and Cs-137. This data shows that the average ratio of the Eberline results to the on-site results was 1.91 for this data set.
As a conservative measure, ZionSolutions will apply this factor to the soil BcSOF of 0.041. The resulting BcSOF is 0.078, which equates to a dose of 1.95 mrem/year. The final dose summation for the Zion site becomes 18.73 mrem/year. The Attachment to ZS-2020-0011 will be revised to Page 107 oft 09
ZionSolutions, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports include this increased dose. Therefore, ZionSolutions believes this bounds the potential difference between the two types of analysis results.
Standard Eberline Avg. Ratio 1.91 Standard Eberline Eberline/
Standard Sample No.
Isotope Activity Error Activity Error
%CV
%CV STD Ll-10201C-FSGS-012-SS K-40 6.87 0.43 17.70 3.39 6%
19%
2.58 Ll-10203D-FSGS-002-SS K-40 6.46 0.47 13.00 2.66 7%
20%
2.01 Ll-10204A-FSGS-019-SS K-40 5.n 0.47 8.26 1.35 8%
16%
1.44 Ll-10206A-FSGS-005-SS K-40 6.21 0.44 11.70 1.82 7%
16%
1.88 Ll-10208C-FIGS-004-SS K-40 8.00 0.57 10.00 1.40 7%
14%
1.25 Ll-10213B-FSG5-015-SS Cs-137 3.47 0.22 6.26 0.61 6%
10%
1.80 Ll-10213B-FSG5-015-SS K-40 4.66 0.33 10.20 1.84 7%
18%
2.19 Ll-10213B-FIGS-001-SS Cs-137 0.22 0.03 0.89 0.16 13%
18%
4.08 Ll-10213B-FIGS-001-SS K-40 7.38 0.57 15.70 2.56 8%
16%
2.13 Ll-10213C-FIGS-001-SS Cs-137 0.36 0.03 0.83 0.11 10%
14%
2.34 Ll-10213C-FIGS-001-SS K-40 9.65 0.62 14.10 1.99 6%
14%
1.46 L2-10214A-FIGS-001-SS K-40 6.28 0.50 12.30 1.87 8%
15%
1.96 Ll-10214F-FIGS-001-SS K-40 6.67 0.50 17.70 2.41 7%
14%
2.65 Ll-10220D-FSGS-OOS-SS K-40 4.79 0.43 12.10 1.61 9%
13%
2.53 Ll-10220H-FJG5-004-SS Cs-137 0.95 0.06 0.90 0.14 7%
15%
0.95 Ll-102201-FJGS-005-SS Cs-137 1.54 0.11 2.65 0.34 7%
13%
1.72 Ll-10220!-FJGS-005-SS K-40 7.94 0.63 17.30 2.52 8%
15%
2.18 L1-10221A-FIGS-001-SS Cs-137 7.50 0.47 2.14 0.29 6%
13%
0.29 Ll-10221A-FIG S-001-SS K-40 6.39 0.51 9.69 1.60 8%
17%
1.52 Ll-10221A-FIGS-001-SB Cs-137 0.37 0.04 1.37 0.23 10%
17%
3.70 Ll-10221A-FIGS-001-SB K-40 7.97 0.55 14.00 2.36 7%
17%
1.76 Ll-10221D-FIGS-013-SS Cs-137 0.58 0.05 0.66 0.12 9%
18%
1.14 Ll-10221D-FIGS-013-SS K-40 6.32 0.48 12.10 2.58 8%
21%
1.91 L1-12111A-FJGS-001-SS K-40 8.52 0.59 11.00 1.72 7%
16%
1.29 Ll-12112A-FSGS--014-SS K-40 7.85 0.47 15.90 2.51 6%
16%
2.03 Ll-12201E-FSG5-014-SS K-40 7.63 0.55 12.70 2.55 7%
20%
1.66 Ll-12203A-FSGS-012-SS K-40 14.80 0.78 18.10 3.00 5%
17%
1.22 Ll-12204C-FSG5-001-SS K-40 8.95 0.64 21.00 4.05 7%
19%
2.35 Ll-12205E-FlGS-101-SS K-40 8.35 0.56 10.40 1.59 7%
15%
1.25 Revised or Supplemental Documentation: ZS-2020-0011, Attachment NRC RAI Question #16a Review future submittals for overall quality and editorial errors.
RESPONSE: For this submittal, ZionSolutions had the response reviewed by Larry Camper, as an independent reviewer, to determine if there was a full response to the NRC questions.
EnergySolutions will take the following actions to improve the quality of future FSS deliverables:
ZionSolutiom, LLC ZS-2021-0001 Response to Request for Additional Information Related to the Final Status Survey Reports requirements follow standard industry guidance (NUREG-1757, MARSSIM, etc.) and in accordance with NRC guidance/requirements.
Page 109 of 109
ZionSolutions ZS-2021-0001 Zion Nuclear Power Station, Units 1 and 2 Preflight Report for Enclosure to ZS-2021-0001
ZionSo/utions, LLC ZS-2021-0001 Preflight Report This document serves as the preflight report for ZionSolutions letter ZS-2021-0001. The following files do not pass pre-flight criteria or do not meet NRC criteria; however, the text is word searchable and legible.
File Name Preflight Reason Status 01 - ZS-2021-000l_Zion FSS RAis Response -Attachment 1 Passed 02 - ZS-2021-0001 _ Zion FSS RAis Response -Attachment 2 Error I Failed Document contains color maps, digital photos, and scanned pages< 300 ppi, clear and legible 03 - Final Report Phase 2 Part 1 Rev 2 Final Error I Failed Document contains logo, color maps, digital photos, and scanned pages < 300 ppi, clear and legible 04 - Release Record_10221B REV 1 FINAL Error I Failed Document contains logo, color maps, digital photos, and scanned pages < 300 ppi, clear and legible 05 - Release Record_0l 111 REV 1 FINAL Error I Failed Document contains logo, color maps, digital photos, and scanned pages< 300 ppi, clear and legible 06 - Release Record 01112_02112_05120 REV 1 FINAL Error I Failed Document contains logo, color maps, digital photos, and scanned pages < 300 ppi, clear and legible 07 - Release Record_06100 REV 2 FINAL Error I Failed Document contains logo, color maps, digital photos, and scanned pages< 300 ppi, clear and legible 08 - Release Record_06201 REV 2 FINAL Error I Failed Document contains logo, color maps, digital photos, and scanned pages < 300 ppi, clear and legible 09 - Release Record_ 06202 REV 2 FINAL Error I Failed Document contains logo, color maps, digital photos, and scanned pages < 300 ppi, clear and legible 10 - Release Record_06213_06214 REV 2 FINAL Error I Failed Document contains logo, color maps, digital photos, and scanned pages < 300 ppi, clear and legible 11 - Release Record_ 08 I 00 REV 2 FINAL Error I Failed Document contains logo, color maps, digital photos, and scanned pages < 300 ppi, clear and legible
ZionSolutions, LLC ZS-2021-0001 Preflight Report File Name 12 - ZS-2020-0011 Attachment Revision 2 13 - Power Block RA Report Attachments 14 - Power Block RA Readiness Review 15 - Gamma Spectroscopy Report for L2-10214C-RJGS-001-SM 16 46D-RE-088 17 - 2014 DRP Surveys 18 - 2015 DRP Surveys 19 - 2016 DRP Surveys 20 - 2017 DRP Surveys 21 - 2018 DRP Surveys 22 - 2018 Unit 1 and Unit 2 Containment Exterior URS 23 - 2019 DRP Surveys 24 - 2019-1953 Follow Up to Concrete in 10209C 25 ~ 2019-1971 Follow Up to Particle in 12204A 26 - 2020 Surveillance Surveys 27 - Ballast RA Attachments Part 1 of3 27 - Ballast RA Attachments Part 2 of3 27 - Ballast RA Attachments Part 3 of 3 Preflight Reason Status Error I Failed Document contains logo, color maps, digital photos, and scanned pages< 300 ppi, clear and legible Error I Failed Document contains scanned pages < 300 ppi, clear and legible Error I Failed Document contains scanned pages < 300 ppi, clear and legible Passed Error I Failed Document contains scanned pages < 300 ppi, clear and legible Error I Failed Document contains scanned pages < 300 ppi, clear and legible Error I Failed Document contairn scanned pages < 300 ppi, clear and legible Error I Failed Document contains scanned pages < 300 ppi, clear and legible Error I Failed Document contains scanned pages < 300 ppi, clear and legible Error I Failed Document contains scanned pages < 300 ppi, clear and legible Error I Failed Document contains scanned pages < 300 ppi, clear and legible Error I Failed Document contains scanned pages < 300 ppi, clear and legible Error I Failed Document contains scanned pages < 300 ppi, clear and legible Error I Failed Document contains scanned pages < 300 ppi, clear and legible Error I Failed Document contains scanned pages and fonts not embedded <
300 ppi, clear and legible Error I Failed Document contains scanned pages < 300 ppi, clear and legible Error I Failed Document contains scanned pages < 300 ppi, clear and legible Error I Failed Document contains scanned pages < 300 ppi, clear and legible
ZionSolutions, LLC ZS-2021-0001 Preflight Report 28 - CR-2014-001074 29 - CR-2015-000324 30 - CR-2019-0066 31 - CR-2019-0101 32 - CR-2019-0165 33 - CR-2019-0165 34-CR-2019-0177 35 - CR-2020-0001 36 - Special Surveillances File Name 37 - Zion Survey Unit Particle Identification Map 38 - Penetration Dose Calculation Spreadsheet 39 - Buried Pipe RA Results 40 - Drainage Ditch Flood Timeline 41 - July 2019 Power Block Remediation Results 42 - Post-CCDD Surveillance Summary 43 - Recommended Table for Licensee Completion 44-Release Records Revision and Supplement List 45 - Subsurface Soil FSS Dose Preflight Reason Status Passed Passed Passed Passed Passed Passed Passed Passed Error I Failed Document contains scanned pages < 300 ppi, clear and legible Error I Failed Document contains color map< 300 ppi, clear and legible NIA Excel file. Preflight not needed.
NIA Excel file. Preflight not needed.
NIA Excel file. Preflight not needed.
NIA Excel file. Preflight not needed.
NIA Excel file. Preflight not needed.
NIA Excel file. Preflight not needed.
NIA Excel file. Preflight not needed.
NIA Excel file. Preflight not needed.
ZionSolutions ZS-2021-0001 Enclosure Zion Nuclear Power Station, Units 1 and 2 Documents Supporting Revised Response to Supplemental Information and Request for Additional Information Related to Final Status Survey Final Reports
ZionSolutions
~-2021-0001 Enclosure Zion Nuclear Power Station, Units 1 and 2 Documents Supporting Revised Response to Supplemental Information and Request for Additional Information Related to I L 1
Final Status Survey Final Reports I.
I I
11 I