ML22069A341

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Supporting Documents for Response to Request for Additional Information Related to Partial Site Release and Recent Site Survey Activities, ZS-LT-200-001-001 Rev 6, Radiological Assessments and Remedial Action
ML22069A341
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 05/15/2019
From:
ZionSolutions
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML22069A328 List:
References
ZS-2022-005 ZS-LT-200-001-001, Rev 6
Download: ML22069A341 (21)


Text

ZS-LT-200-001-001 Revision 6 Information Use

D&D Procedure

CHARACTERIZAT ION/LICENSE TERMINATION PROCEDURE

RADIOLOGICAL ASSESSMENTS AND REMEDIAL ACTION SUPPORT SURVEYS ZS-LT-200-001-001 Revision No. 6

Preparer: (Print name / sign): Date: 05- 07-2019 GL Wood

Secondary Reviewer: (Print name / sign): Date: 05-15-2019 Patsy Giza

VP Regulatory Affairs or Designee has reviewed and determined required program & regulatory reviews (*new N/A procedures only*) : SIGNATURE______________________________________________DATE:____________

Regulatory Required Reviews (per AD-11, Regulatory Reviews)

Part 72 ISFSI Impact License: 10 CFR 72.48 YES NO Part 50 License: 10 CFR 50.59 and 50.90 YES NO Fire Protection: 10 CFR 50.48(f) YES NO Conditions of License: E-Plan: 10 CFR 50.54(q) YES NO QA Review Required? YES NO

QA Reviewer: N/A DATE:____________

Print Name / Signature

Technical Review Required? YES NO

Technical Reviewer: N/A DATE:____________

Print Name / Signature

Technical Reviewer: N/A DATE:____________

Print Name / Signature Approval Section

DEPART MENT MANAGER: D. Wojtkowiak/ DAT E: 05-15-2019 Print Name / Signature DECOMMISSIONING N/A PLANT MANAGER*:__________________________________________________DATE:____ __________

Print Name / Signature

  • Required for Technical Reviews only

Effective Date: May 28, 2019

Page 1of 21 ZS-LT-200-001-001 Revision 6 Information Use

Summary of Changes in this Revision:

  • Rev. 5 - Procedure revised to implement recommended actions from ES-Z ION-CR-2019-0046 Issue Review. Changes include; Addition to Prerequisites to include a description of the scope and purpose that is independent of a predecessor task and to include a graphical depiction.

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1. PURPOSE AND SCOPE.......................................................................................................4 1.1. PURPOSE...................................................................................................................4 1.2. SCOPE........................................................................................................................4
2. RESPONSIBILITIES............................................................................................................4
3. DEFINITIONS.......................................................................................................................5
4. PRECAUTIONS, LIMITATIONS, AND PREREQUISITES...........................................7 4.1. Precautions..................................................................................................................7 4.2. Limitations..................................................................................................................7 4.3. Prerequisites................................................................................................................8
5. MAIN BODY..........................................................................................................................8 5.1. General........................................................................................................................8 5.2. Sample Plan Development..........................................................................................9 5.3. Sample Plan Survey Instructions..............................................................................12 5.4. Sample Plan Approval..............................................................................................13 5.5. Sample Plan Implementation....................................................................................13 5.6. Sample Plan Closure.................................................................................................14
6. REFERENCES.....................................................................................................................14
7. RECORDS............................................................................................................................14
8. ATTACHMENTS................................................................................................................14 8.1. Attachment 1, Sample & Measurement Unique Identification Designation............15 8.2. Attachment 2, Calculation of Static and Scan MDC................................................16 8.3. Attachment 3, RA/RASS Survey Design..................................................................18 8.4. Attachment 4, RA/RASS Field Log..........................................................................20
9. FORMS.................................................................................................................................15

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1. PURPOSE AND SCOPE 1.1. PURPOSE The purpose of this procedure is to provide guidance on the development, implementation and review of Radiological Assessment (RA) and Remedial Action Support Survey (RASS) sample plans. RA and/or RASS sample plans are generated to assess the radiological conditions in impacted survey units where radiological conditions may have changed since characterization (RA) or in survey units undergoing remediation (RASS) at the Zion Station Restoration Project (ZSRP).

1.2. SCOPE This procedure implements the requirements of applicable U.S. Nuclear Regulatory Commission (NRC) regulations and guidance documents; specificall y, NUREG-1757, Volume 2, Revision 1 Consolidated Decommissioning Guidance - Characterization, Survey, and Determination of Radiological Criteria (Reference 6.1), and NUREG-1575, Multi-Agency Radiation Sur vey and Site Investigation Manual (MARSSIM, Reference 6.2).

This procedure applies to all personnel performing RA and RASS survey package development and/or implementation, data review and sample plan closeout.

2. RESPONSIBILITIES 2.1. Characterization/License Termination (C/LT) Manager - is responsible for:

Providing overall guidance and support for the development and implementation of RA and/or RASS sample plans.

Reviewing and approving all RA and /or RASS sample plans.

2.2. Radiological Engineer (RE) - is responsible for:

Preparing RA and /or RASS sample plans.

Reviewing and closing out RA and/RASS Sample Plans Ensuring RA and /or RASS surveys are conducted in accordance with approved survey and sampling plans, procedures, and work instructions.

Providing te chnical direction and guidance to field survey and sampling activities.

2.3. Characterization/License Termination (C/LT) Supervisor(s) - areresponsible for:

Controlling and implementing sample plan instructions during field activities.

Providing daily supervision and guidance to field survey and sampling crews and performing quality checks of field activities.

Overseeing preparation of samples for transfer to on-site or off-site laboratories.

Ensuring all necessary instrumentation and other equipment is available to support survey activities.

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2.4. Survey Mapping/CAD Specialist - is responsible for:

Preparing survey maps, layout diagrams, composite view drawings and other graphics as necessary to support survey design and reporting.

Interacting with the RE regarding the preparation of maps, diagrams and other graphics which present survey units and sample or measurement locations.

2.5. Database and LTP Support Engineer (D/LTP) - is responsible for:

Maintaining an index of pending, active and closed RA/ RASS sample plans and packages and assigning storage locations.

Ensuring that RA/RASS sample plans and packages are properl y labeled, stored and controlled per AD-20, Records Management Program (Reference 6.3) and ZS-LT-01, Quality Assurance Project Plan (for Characterization and FSS)

(QAPP) (Reference 6.4).

Serves as Department Records Custodian in accordance with AD-20.

2.6. Characterization/License Termination (C/LT) Technicians - are responsible for:

Obtaining and documenting survey measurements in accordance with the sample plan instructions.

Ensuring that all activities, actions, observations and obstructions that are encountered during the performance of the required surveys are documented in the RA/RASS Field Log (Attachment 4) for that survey unit.

3. DEFINITIONS 3.1. Action Level - The numerical value that will cause the decision maker to choose an alternative action. It may be a regulatory threshold standard, a dose or risk-based concentration level (e.g., Derived Concentration Guideline Level [DCGL]), or a reference-based standard.

3.2. Judgmental Measurements - Also referred to as biased measurement, judgmental measurements are performed at locations selected using professional judgment based on unusual appearance, location relative to known contamination areas, high potential for residual radioactivity, general supplemental information, etc.

3.3. Derived Concentration Guideline Level (DCGL) - A derived, radionuclide -specific activity concentration within a survey unit corresponding to the release criterion (referred to as Base Case DCGLs). DCGLs are derived from activity/dose relationships through various exposure pathway scenarios. To ensure that the summation of dose from each source term is 25 mrem/yr or less after all Final Status Survey (FSS) is completed, the Base Case DCGLs are reduced based on an expected, or a priori, fraction of the 25 mrem/yr dose limit from each source term. These reduced DCGLs are called Operational DCGLs. The Operational DCGL is then used as the DCGL for the FSS design of the survey unit (calculation of surrogate DCGLs, investigations levels, etc.).

Page 5of 21 ZS-LT-200-001-001 Revision 6 Information Use

3.4. Measurement - For the purpose of MARSSIM, it is used interchangeabl y to mean: 1) the act of using a detector to determine the level or quantity of radioactivity on a surface or in a sample of material removed from a media being evaluated, or 2) the quantity obtained by the act of measuring.

3.5. Minimum Detectable Concentration (MDC) - The Minimum Detectable Concentration (MDC) is defined as the a priori activity level that a specific instrument and technique can be expected to detect 95% of the time. When stating the detection capability of an instrument, this value should be used. The MDC is the detection limit, ( LD), multiplied by an appropriate conversion factor to give units of activity. The critical level, (LC), is the lower bound on the 95% detection interval defined for LD and is the level at which there is a 5% chance of calling a background value greater than background. This is the value used when actuall y counting samples or making direct radiation measurements.

Any response above this level should be considered as above background (i.e., a net positive result). This will ensure 95% detection capability for LD. The MDC is dependent upon the counting time, geometry, sample size, detector efficiency and background count rate.

3.6. Sample Plan - Sampling plans are prepared for each survey unit independently and contain, at a minimum, survey instructions, the number and location of survey measurements and samples, survey maps, instrumentation requirements, and safet y requirements as necessary.

3.7. Survey Unit - The study area consisting of structures or land areas of specified size and shape for which a separate decision will be made to judge whether the remedial action has achieved the site-specific reference-based cleanup standard for the designated pollution parameter. Survey units are generall y formed by grouping contiguous site areas with a similar use history and the same classification of contamination potential.

3.8. Acronyms

ALARA - As Low As Reasonabl y Achievable CoC - Chain-of-Custody DCGL - Derived Concentration Guideline Level DQO - Data Quality Objectives FSS - Final Status Survey GPS - Global Positioning System HSA - Historical Site Assessment HTD - Hard-to-Detect MARSSIM - Multi-Agency Radiation Survey and Site Investigation Manual MDC - Minimum Detectable Concentration NRC - U.S. Nuclear Regulatory Commission QA - Quality Assurance

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QAPP - Quality Assurance Project Plan RA - Radiological Assessment RASS - Remedial Action Support Survey RE - Radiological Engineer ZSRP - Zion Station Restoration Project

4. PRECAUTIONS, LIMITATIONS, AND PREREQUISITES 4.1. Precautions 4.1.1 Documents and databases containing characterization survey data and survey records are Quality Assurance (QA) records when complete. Positive control of these records shall be maintained until such time that they are forwarded to Records Management.

4.1.2 When documenting survey information, all personnel shall ensure that all QA records are of good quality and legible. Legibility is determined to be readable and reproducible.

4.1.3 Radiological Assessments and Remedial Action Support Surveys may include, when practicable, a description of the scope and purpose of the survey that is independent of proper execution of a predecessor task and, to include a graphical depiction of scope as necessar y.

4.1.4 The RE tasked with the development and implementation of multiple RA and/or RASS sample plans must be aware that it is possible that duplicate sample/measurement numbers may be generated when using the guidance for designating a unique sample identification number in accordance with the Sample

& Measurement Unique Identification Designation presented in Attachment 1.

Consequently, the responsible RE must be vigilant to ensure that this does not occur. The guidance provided in Attachment 1 may be supplemented b y the RE with alternative designations as specified in the RA/RASS Sample Plan.

4.1.5 Ten percent (10%) of any soil samples collected during an RA in a survey area, with a minimum of one sample, will be analyzed for the full initial suite of radionuclides (including Hard-to-Detect [HTD] radionuclides). Additionally, if levels of residual radioactivity from gamma Radionuclides-of-Concern (ROC) in an individual soil sample exceed the Sum-of-Fractions (SOF) of 0.1, then the sample will be analyzed for the full initial suite of radionuclides (includes HTD radionuclides).

4.2. Limitations 4.2.1 All attachments described in this procedure may be generated electronically. If electronic attachments are used, the ph ysical layout of the attachment may be modified provided the intent described in this procedure is not changed.

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4.2.2 The output of the design process is the sample plan (instructions). A sample plan is prepared for each survey unit independently. A survey package is prepared for each survey unit and may contain one or more sample plans.

4.2.3 Radiation detection and measurement instrumentation will be selected based on the type and quantity of radiation to be measured. For direct measurements and sample anal yses, MDCs less than 10% of the Operational DCGL are preferable while MDCs up to 50% of the Operational DCGL are acceptable.

4.2.4 Instruments used for scan measurements in Class 1 areas are required to be capable of detecting radioactive material at the Base Case DCGL.

4.2.5 The MDC for measurements obtained using laboratory instruments will be 10 percent of the applicable Operational DCGL.

4.2.6 Measurement results taken with instrumentation that exceed s the maximum MDC values may be accepted as valid data after evaluation by a RE.

4.2.7 All RA or RASS direct measurements and/or samples will be given a unique sample identification number in accordance with the Sample & Measurement Unique Identification Designation presented in Attachment 1.

4.2.8 During sample plan development, the letter A will always be used as a default for digit 8 in the nomenclature on Attachment 1 if there are no sub-units in the survey unit.

4.3. Prerequisites 4.3.1 All survey or counting instruments used to produce RA and/or RASS survey data shall be in current calibration and verified to be operational.

5. MAIN BODY 5.1. General 5.1.1 Remedial Action Support Surveys (RASS) are conducted to; 1.) Support remediation of a structure that will be subjected to FSS.

2.) Support guided remediation in an excavation of contaminated soils.

3.) Support pre -demolition surveys of structures that could impact a previously characterized structure or open land survey unit.

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NOTE At a minimum, a RA performed to support an excavation shall consist of scans of the footprint of the excavation and scans of the area where the soil will be staged, with a minimum scan coverage commensurate with the survey unit classification where the excavation occurs (in accordance with LTP Chapter 5, Table 5-24). In addition, periodic scans will be performed on the soil as it is excavated and a final scan will be performed when the excavation is complete. Soil samples may be obtained throughout the process using engineering judgment; however, a minimum of one sample must be obtained upon completion of the excavation and pipe removal activities and prior to backfill.

5.1.2 Radiological Assessments (RA) are performed:

1.) Where an excavation is created to expose buried components (e.g. concrete pads, buried pipe, buried conduit, etc) or to install a new buried s ystem, 2.) Determine when a survey unit is ready for Final Status Survey (FSS),

3.) Update characterization data as necessar y to use for FSS survey design.

5.1.3 The documented results of RA and RASS surveys shall be placed in the survey folder for the open land or structural survey units that is pertinent to the area and/or items surveyed and documentation shall be controlled in accordance with the record quality requirements of the ZionSolutions QAPP.

5.2. Sample Plan Development 5.2.1 Initiate Attachment 3, RA/RASS Survey Design for the applicable survey unit.

5.2.2 Complete the Description section, providing the following:

1.) The type of survey (RA or RASS),

NOTE Sample plans will be numbered in numerical sequence for each t ype (RA or RASS) of survey in each individual survey unit. For example, if three (3)

RASS surveys have been previously worked in a survey unit, then the next sample plan generated for that survey unit would be numbered #04.

2.) The next sequential sample plan number for the survey unit, 3.) Survey Area Number and Description, 4.) Survey Unit Number and Description.

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5.2.3 Designate the t ype of survey unit.

NOTE The Zion Station Historical Site Assessment (HSA) (Reference 6. 5) esta blished the initial survey unit classification for each survey unit. Radiological survey data from characterization surveys, operational surveys in support of D&D, routine surveillance, and any other applicable survey data may provide indications that would cause an increase in survey area classifications (for example, from Class 3 to Class 2 and from Class 2 to Class 1) until the time of commencement of the FSS. Final classification is performed and verified as a DQO during FSS design.

5.2.4 Designate the current classification of the survey unit.

5.2.5 Denote the reason for performing the survey.

5.2.6 State the Action Levels applicable to the survey.

NOTE The action levels for gross activity (static or scan) should be set at an observed reading of elevated activity above background where an action, such as reclassification, performing an additional investigation or performing additional remediation would be required. This action level may be based on the sensitivity of the instrument used, an ALARA criterio n for the remediation of structural surfaces or an adjusted gross DCGL for soils.

1.) If static measurements will be taken during the survey, then state the action level for static measurements and the appropriate units.

2.) If scan measurements will be taken dur ing the survey, then state the action level for scan measurements and the appropriate units.

NOTE The action level for isotopic activity (gamma -emitters or beta/alpha-emitters) is typicall y the Operational DCGL for the ROC.

3.) If sample(s) of a media will be taken, then denote the type of anal ysis that will be performed.

A. If gamma spectroscop y analysis will be performed, then denote the desired isotopic MDC for Cs-137 and Co-60.

B. Any samples sent for analysis for HTD radionuclides will be anal yzed for the full initial suite of radionuclides as specified in LTP Chapter 5, Table 5-1.

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NOTE The type(s) of measurements and/or samples and the necessar y sample/measurement population size will be determined by the professional judgment of the responsible RE.

The number of measurement/sample(s) are a minimum population that will be taken. Additional measurement/sample(s) may be taken as necessary based upon the observed conditions or activities as the survey is being performed.

5.2.7 Denote the minimum number of samples and/or measurements that are required to adequatel y address the objectives of the survey.

NOTE Static and Scan MDC for scanning structures and Scan MDC for soil will be determined in accordance with the guidance provided in Attachment 2.

5.2.8 Designate the radiological instrumentation and detectors that will be used to acquire field measurements and document the static and scan MDC.

1.) Denote the assumption(s) for the variable(s) used to calculate the static and scan MDC(s) in the Notes section.

NOTE The location of measurements and/or samples that will be taken will be determined by the professional judgment of the responsible RE.

Measurement/sample locations may be pre-determined or based on real-time observations as decommissioning activities occur (e.g. excavation, remediation, system removal, demolition, backfill and grading).

Consideration should be given to locations that exhibit the greatest potential for elevated radioactivit y, including depressions, discolored areas, cracks, low point gravity drain points and actual or potential spill locations.

5.2.9 Describethe location(s) of where measurement(s) and/or sample(s) will be taken.

NOTE Pre-determined measurement/sample location(s) may be selected at random, using a s ystematic approach or judgmental.

Chosen location(s) may be physically marked using flags and/or marking paint or denoted by using Global Positioning System (GPS) coordinates.

1.) If measurement/sample locations are pre-determined, then denote how the locations will be selected and marked.

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2.) If measurement/sample locations will be selected based on real -time observations, then describe the criteria that should be employed to determine when and where a measurement/sample should be taken.

5.3. Sample Plan Survey Instructions

NOTE Survey instructions may be provided without using RA/RASS Survey Design (Attachment 3) provided all the applicable items of the Survey Instruction attachment are included.

5.3.1 Complete the Survey Instructions section of RA/RASS Survey Design (Attachment 3). The t ypes of instructions that may be specified include, but are not limited to the following:

1.) Description of potential safet y hazards that may be encountered during performance of the survey including any required Personal Protective Equipment, safet y sampling and/or safet y surveillances.

2.) A list of all equipment and instrumentation required to perform the survey, as well as applicable procedural references.

3.) Identified areas, conditions or constraints where sampling or surveying may not be possible and alternative solutions to support survey requirements if these obstacles are encountered.

4.) Specific instructions for performing sampling, scans, total surface contamination measurements, loose surface contamination measurements or special measurements including:

A. Area (in square meters) and location for surface scans.

B. Specific scanning instructions including scan speed, pattern (e.g., serpentine),

alarm set-points, action levels, background check, etc.

C. Instructions for background correction if applicable.

D. Count times for static measurements.

E. Desired depth and volume requirements for surface and subsurface soil samples.

F. Directions for taking water, sediment or vegetation samples as necessar y.

5.) Instructions for qualit y control (e.g., techniques to prevent cross-contamination, proper sampling, and labeling techniques).

6.) Action(s) to be performed if an action level(s) is exceeded.

7.) Documentation requirements (e.g., survey map, documentation of anomalies).

8.) Chain-of-Custody (CoC) instructions for media samples.

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9.) Any areas of interface where the progress of the survey will be contingent on interaction or support from another department or group (e.g., securit y notification, man-lift support, scaffold erection support, excavation or soil loading support, etc.).

5.4. Sample Plan Approval 5.4.1 When the sample plan is complete, the Attachment 3 will be reviewed and signed b y t he RE and then forwarded to the C/ LT Manager for approval.

5.4.2 The C / LT Manager will signify approval of the sample plan by signing Attachment 5.5. Sample Plan Implementation 5.5.1 C / LT Supervisor shall perform a pre-survey briefing with the C/ LT Technicians assigned to execute the sample plan during which the survey instructions and safet y issues will be reviewed.

5.5.2 C/ LT Technicians shall perform surveys in accordance with the survey instructions contained in the sample plan.

1.) If a situation is encountered in which survey instructions cannot be followed as written, then contact the responsible RE for resolution.

5.5.3 C/ LT Technicians shall create a RA/RASS Field Log (Attachment 4) for the survey.

The type(s) of information that may be documented in the RA/RASS Field Log (Attachment 4) include, but are not limited to the following:

1.) A description of the physical conditions encountered.

2.) Observed background as well as obvious sources contributing to background from adjacent areas.

3.) Instrument(s) and detector(s) used, serial numbers and calibration date(s).

4.) Changes in measurement/sample location(s) due to encountered obstacle(s) and/or physical constraint(s).

5.) A description of location(s) or item(s) surveyed where the applicable action level(s) were exceeded, the results of an y investigation(s) and an y action(s) taken as a result.

5.5.4 C / LT Technicians shall denote on a survey map the location of all measurement/sample location(s) and area(s) scanned.

5.5.5 When the survey and all investigations are complete, C / LT Technicians shall forward all completed RA/RASS Field Log s (Attachment 4), survey maps, instrument download report(s) and sample anal ysis report(s) to the C/ LT Supervisor.

5.5.6 The C / LT Supervisor shall review the completed documents for completeness and accuracy. When the review is satisfactor y, the completed survey will be forwarded to the responsible RE for sample plan closure.

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5.6. Sample Plan Closure 5.6.1 The RE shall perform an evaluation of the sample plan to determine if survey results are acceptable and complete. The review should include, but is not limited to the following:

1.) Ensure that survey measurements are recorded in units appropriate for comparison to the applicable Action Levels.

2.) Review all laborator y analysis reports formedia samples.

3.) Review the counting parameters of survey measurements and anal ytical results of sample media to ensure that the count times used resulted in an acceptable MDC.

4.) Compare survey results to the applicable action level. If any survey result exceeds the action level, then ensure that appropriate actions or investigations areimplemented.

5.6.2 When the survey has been reviewed and accepted, then the RE shall sign RA/RASS Survey Design (Attachment 3) and forward the package to the C/ LT Manager or designee for approval.

5.6.3 The C / LT Manager will signify closure of the sample plan by signing Attachment 3.

6. REFERENCES 6.1. NUREG-1757, Consolidated NMSS Decommissioning Guidance - Characterization, Survey, and Determination of Radiological Criteria Volume 2, Revision 1 6.2. NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) 6.3. AD-20, Records Management Program 6.4. ZS-LT-01, Quality Assurance Project Plan (for Characterization and FSS) (QAPP) 6.5. Commonwealth Edison Zion Station Historical Site Assessment 6.6. ISO 7503-1, Evaluation of surface contamination - Part 1: Beta -emitters (maximum beta energy greater than 0.15 MeV) and alpha-emitters 6.7. ZionSolutions TSD -2011-004, Ludlum Model 44-10 Detector Sensitivity
7. RECORDS 7.1. Attachment 3, RA/RASS Survey Design 7.2. Attachment 4, RA/RASS Field Log
8. ATTACHMENTS 8.1. Attachment 1, Sample & Measurement Unique Identification Designation 8.2. Attachment 2, Calculation of Static and Scan MDC

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8.3. Attachment 3, RA/RASS Survey Design 8.4. Attachment 4, RA/RASS Field Log

9. FORMS None

Page 15of 21 ZS-LT-200-001-001 Attachment 1 Revision 6 Sample & Measurement Unique Identification Designation Information Use

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17)

Classification & Survey Area Survey Unit Number & Survey and Surface Type Sample or Measurement No. Media Type Sequence Indicator Measure ment Type 1st digit indicates type of Survey Area 6th and 7th digits indicates The 9th digit indicate The 11th digit indicates The 13th, 14th and 15th digits The 16th and 17th digits L = Open Land Area Survey Unit Number the type of survey. the type of surface indicate the alphanumeric indicate the type of B = Structural Survey Area (from Tables 6-1 and 6-2) A = Assessment where the measurement number media that was S = Syst e m B = Background measurement was Sequentially, 001 through 999 sampled.

The 8th digit indicate S = Scoping taNen. SS = Surface Soil 2nd digit indicates Classification alphanumeric sequence C = Characterization F = Floor SB = Subsurface Soil 1 = Class 1 (Sequence A-J) allows the R = Remedial Action W = Wall SM = Sediment 2 = Class 2 survey unit to be divided into F = FSS C = Ceiling WT = Water 3 = Class 3 10 smaller survey units. I = Investigation S = Syst e m LQ = Other liquids 4 = Non-impacted V = Verification R = Roof besides water 5 = Unassigned (Sequence K-Z) allows for up Q = QA/QC P = Paved Road OL = Oil 3rd, 4th and 5th digits indicates Survey Area Number to 16 different survey E = Excavation G = Ground CV = Volumetric (from Tables 6-1 and 6-2) instructions for a single survey The 10th digit indicates L = Water Concrete unit. the type of The 12th digit indicates AV = Volumetric measurement. the material Asphalt B = Background composition of the MT = Metal R = Random surface where the PT = P aint S = Systematic measurement was SW = Smear Sample J = Judgmental taken. BD = Beta Direct I = Investigation C = Concrete AD = Alpha Direct V = Verification M = Metal GD = Static Gamma Q = QA/QC W = Wood measurement B = Cinder Block BS = Beta Scan K = Brick GS = Gamma Scan A = Asphalt JS = Juncture Scan S = Soil JD = Juncture Direct T = Tar PS = Penetration L = Liquid Scan PD = Penetration Direct

Page 16of 21 Attachment 2 ZS-LT-200-001-001 Calculation of Static and Scan MDC Revision 6 Page 1 of 2 Information Use

MDC is the minimum activity concentration on a surface or within a material volume, that an instrument is expected to detect (e.g., activity expected to be detected with 95% confidence).

The MDC is dependent upon the counting time, geometry, sample size, detector efficiency and background count rate. For a portable instrument, MDC is calculated using two different methods depending on the mode of operation, static (MDCstatic) or scanning (MDCscan).

Total Efficiency Instrument efficiencies (i) are derived from the surface emission rate of the radioactive source(s) used during the instrument calibration. Total Efficiency (t) is calculated by multiplying the instrument efficiency (i) by the surface efficiency (s) commensurate with the radionuclides alpha or beta energy using the guidance provided in ISO 7503-1, Evaluation of surface contamination - Part 1: Beta -emitters (maximum beta energy greater than 0.15 MeV) and alpha-emitters (Reference 6.6).

Beta Scan Measurement MDC The formula used to determine the scanning MDC at the 95% confidence level is:

( 60)

=

()( 100)

Where, MDCscan = Minimum Detectable Concentration in dpm/100 cm2 d = index of sensitivity (1.38) i = observation interval (seconds) bi = background counts per observation interval t = total efficiency p = surveyor efficiency (0.5)

A = detector area in cm2 (not to exceed 126 cm2)

The observation interval (i) is considered to be the amount of time required for the detector field of view to pass over the area of concern. This time depends upon the scan speed, the size of the source, and the fraction of the detectors sensitive area that passes over the source. The scan speed is based on one detector window width per second however; other scan speeds may be used. For the Ludlum Model 43-68 gas flow proportional detector, the window width is 8.8 cm resulting in a scan speed of ~3.5 inches per second. The floor monitor detector is the Ludlum Model 43-37 with a window width of 13.35 cm which results in a scan speed of 5.25 inches per second.

3DJH 17of 21 Attachment 2 ZS-LT-200-001-001 Calculation of Static and Scan MDC Revision 6 Page 2 of 2 Information Use

Direct Beta Measurement MDC Direct (static) measurements utilize the following formula:

2.71+3.29+

=

100 2

Where, MDCstatic = Minimum Detectable Concentration in dpm/100 cm2 ts = sample count time tb = background count time Rb = background count rate (cpm) t = total efficiency A = detector window area (cm2)

Gamma Scan MDC The gamma scan MDC is discussed in detail in TSD-2011-004, Ludlum Model 44-10 Detector Sensitivity (Reference 6.7). This Technical Support Document (TSD) examines the gamma sensitivity for 5.08 by 5.08 cm NaI detectors to several radionuclide mixtures of Co-60 and Cs-137 using sand (SiO2) as the soil base. The TSD derives the MDC for the radionuclide mixtures at various detector distances and scan speeds. The TSD model uses essentially the same geometry configuration as the model used in MARSSIM (Reference 6.2). TSD-2011-004 provides MDC values for the expected ZSRP soil mixture based on detector background condition, scan speed, soil depth (15 cm), soil density (1.6 g/cm3) and detector distance to the suspect surface.

3DJH 18of 21 Attachment 3 ZS-LT-200-001-001 RA/RASS Survey Design Revision 6 Page ___ of ___ Information Use

==

Description:==

Survey Type - RA - RASS Sample Plan No.:

Survey Area No.:

Description:

Survey Unit No.:

Description:

Survey Unit Type:

- Open Land - Structure Interior - Structure E[terior - S ys t em

Survey Unit Classification:

Current Classification: - Non-Impacted - Class 3 - Class 2 - Class 1

Reason for Survey:

RA: - E[cavation Support - FSS Readiness - Characterization Update

RASS: - Remediation Support - E[cavation Support - Demolition Support

Radiological Action Level(s):

- Gross Activity - Isotopic Activity

- Static Measurement - Gamma Spectroscop y (units)

- Scan Measurement - Hard-to-Detect Radionuclide(s)

(units)

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Types and Number of Measurements/Sample(s):

Mi ni mu m # Type Mi ni mu m # Type Surface Soil Sample(s) Swipe Sample(s)

Subsurface Soil Sample(s) Static beta-gamma measurement(s)

Sediment Sample(s) Static alpha measurement(s)

Concrete Core Sample(s) N/A Surface Scans (structures)

Volumetric Concrete Sample(s) N/A Surface Scans (soils)

Volumetric Asphalt Sample(s) Other BBBBBBBBBBBBBBBBBBBBBBBBB Water Sample(s) Other BBBBBBBBBBBBBBBBBBBBBBBBB

Instrument(s) and Detector(s):

Instrument Type: Detector T ype: Static MDC: Scan MDC:

1 2

3 4

Note(s):

3DJH 19of 21 Attachment 3 ZS-LT-200-001-001 RA/RASS Survey Design Revision 6 Page ___ of ___ Information Use

Description of Measurement/Sample Location(s):

Survey Instruction(s):

Survey Plan Approval:

Prepared by: Date:

Rad io lo g ic a l E ng ineer Reviewed and Approved by: Date:

Characterization/License Termination Manager Survey Plan Closure:

Reviewed by: Date:

Rad io lo g ic a l E ng ineer Approved by: Date:

Characterization/License Termination Manager

3DJH 20of 21 Attachment 4 ZS-LT-200-001-001 RA/RASS Field Log Revision 6 Page ___ of ___ Information Use

==

Description:==

Survey Type - RA - RASS Sample Plan No.: Date:

Survey Area No.:

Description:

Survey Unit No.:

Description:

Field Log:

3DJH 21of 21