ML22223A075

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Lacrossesolutions, LLC, LC-FS-PR-008, Rev 0, LACBWR Site Restoration Project Final Radiation Survey Data Assessment
ML22223A075
Person / Time
Site: La Crosse  File:Dairyland Power Cooperative icon.png
Issue date: 07/28/2022
From: Reheard R
LaCrosseSolutions
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML22223A088 List:
References
LS-2022-0014 LC-FS-PR-008, Rev 0
Download: ML22223A075 (56)
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Text

LACROSSE~ SOLVTIONS

LACBWR Site Restoration Project Final Radiation Survey Data Assessment Procedure No. LC-FS-PR-008 Revision No. 0

Preparer (Print name /Sign) R J Reheard Date: 3-28-2016

Secondary Reviewer (Print Name /Sign)JD Jacobsen Date: 3-29-2016

Regulatory Required Reviews (attach completed LC -RA-PR-001 forms)

Part 50 License: 10 CFR 50.59 and 50.90 0 YES X NO

Fire Protection: 10 CFR 50.48(f) 0 YES X NO

Conditions of License: PSP: IO CFR 50.54(p) 0 YES X NO

Condition s of License: E-Plan: 10 CFR 50.54(q) 0 YES X NO

Termination of License: 10 CFR 50.82(a)(6) and 50.82(a)(7) 0 YES X NO

Part 72 License: 10 CFR 72.48 0 YES X NO

Prog ram Required Reviews

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RP: X YES ONO SIGNATURE avi-tJ"'*vv** - ~ DATE: 3-29-2016 QA: 0 YES X NO SIGNATURE _ ___ ______ _ __ DATE: ___ _

QTR: 0 YES X NO SIGNATURE ________ _____ DATE: _ _ _ _ _

Approval Section

PROJECT MANAG ER:

Effective Date: L\\::l9-dDt w ( assigned by Document Control or Project Manager)

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 TABLE OF CONTENTS

1. PURPOSE AND SCOPE.......................................................................................................3
2. REFERENCES.......................................................................................................................4
3. GENERAL..............................................................................................................................4 3.1. Responsibilities...........................................................................................................4 3.2. Definitions...................................................................................................................5 3.3. Acronyms....................................................................................................................7 3.4. Precautions, Limitations, and Prererequisites.............................................................8 3.5. Records.....................................................................................................................11
4. PROCEDURE......................................................................................................................11 4.1. Data Validation.........................................................................................................11 4.2. DQO Checklist..........................................................................................................13 4.3. Preliminary Data Review for FSS.............................................................................13 4.4. Preliminary Data Review for STS............................................................................16 4.5. Selection and Performance of Statistical Tests.........................................................17 4.6. Investigations............................................................................................................20 4.7. Corrective Actions for Final Radiation Survey Failure............................................23 4.8. Survey Package Closeout..........................................................................................23
5. ATTACHMENTS................................................................................................................23

Page 2 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0

1. PURPOSE AND SCOPE

1.1. Purpose

This procedure provides guidance to interpret survey results using the Data Quality Assessment (DQA) process during the assessment phase of Final Radiation Survey (FRS) at the La Crosse Station Restoration Project (LSRP). Because of differences in the conceptual models and required source terms, the FRS includes two different approaches depending on the media; (1) Final Status Survey (FSS) is conducted on soil, buried piping and groundwater to demonstrate that residual radionuclide concentrations are equal to or below site-specific Derived Concentration Guideline Levels (DCGL), and (2) a Source Term Survey (STS) is conducted to demonstrate that the inventory of residual radioactivity in building basements, embedded piping and penetrations is below a source term inventory commensurate with the dose criterion in 10 CFR 20.1402.

The term FRS is used in this procedure to represent both the FSS and STS surveys.

When the discussion applies to only one of the survey methods, either FSS or STS is referenced.

1.2. Scope

This procedure implements the requirements of applicable U.S. Nuclear Regulatory Commission (NRC) regulations and guidance documents; specifically, NUREG-1757, Volume 2, Revision 1 Consolidated Decommissioning Guidance -, Survey, and Determination of Radiological Criteria (Reference 2.1), NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM, Reference 2.2) and Chapter 5 of the LCSRP License Termination Plan (LTP) (Reference 2.4).

This procedure applies to all persons involved with the receipt, management, storage and conversion of data collected in support of FRS. The data to be received and processed includes direct download data from instrumentation, counting instrument reports, instrument control and calibration databases, field survey records and other manual entry data. Data processing includes converting measurement data into reporting units, validating instrument applicability and sensitivity, calculating relevant statistical quantities, and verification that all Data Quality Objectives (DQO) have been met. Following data validation, processing, reduction and evaluation, a release record will be generated in accordance with procedure LC-FS-PR-009, Final Radiation Survey Data Reporting (Reference 2.5).

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LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0

2. REFERENCES

2.1. NUREG-1757, Consolidated NMSS Decommissioning Guidance -, Survey, and Determination of Radiological Criteria Volume 2, Revision 1 - September 2002

2.2. NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) - August 2000

2.3. LC-AD-PR-004, Corrective Action Program

2.4. La Crosse Station Restoration Project License Termination Plan - December 2014

2.5. LC-FS-PR-009, Final Radiation Survey Data Reporting

2.6. LC-QA-PN-001, Final Radiation Survey Quality Assurance Project Plan

2.7. LC-FS-PR-006, Survey Unit Classification

2.8. LC-FS-PR-010, Isolation and Control for Final Radiation Survey

2.9. LC-FS-PR-002, Final Radiation Survey Package Development

2.10. LaCrosseSolutions Technical Support Document RS-TD-313196-001, Radionuclides of Concern for Soil and Basement Fill Model Source Terms - December 2015

3. GENERAL

3.1. Responsibilities

3.1.1 Radiation Protection (RP)/ FRS Manager - is responsible for:

Providing overall technical support for the review, validation and interpretation of FRS results and analysis.

Reviewing and approving the conclusions reached for the survey unit from the assessment of the survey data.

Ensuring the conclusions from FRS are appropriately documented and technically defensible.

3.1.2 FRS Supervisor - is responsible for:

Ensuring the survey data taken for FRS is authentic and of sufficient quality.

Ensuring all required surveys have been performed and documented in accordance with the FRS Sample Plan for the survey unit.

The evaluation of FRS data & results using the DQA process.

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LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 3.1.3 Graphics/GPS Specialist - is responsible for:

Preparing survey maps, layout diagrams, composite view drawings and other graphics as necessary to support FRS data analysis.

3.1.4 Final Radiation Survey (FRS) Technician(s) - are responsible for:

Obtaining and documenting survey measurements and samples in accordance with the FRS Sample Plans and all applicable procedures.

3.2. Definitions

3.2.1 Basement Dose Factors - For basements/structures below 636 foot elevation, building-specific Basement Dose Factors were calculated in units of mrem/yr per mCi. The total inventory remaining for each Radionuclide-of-Concern (ROC) will be multiplied by the Basement Dose Factors for each radionuclide to calculate the actual dose from the remaining basement source term. These Basement Dose Factors are radionuclide-specific values that are determined for each ROC.

3.2.2 Basement Inventory Levels (BIL) - For basements/structures below 636 foot elevation, the Basement Dose Factors were used to calculate a hypothetical maximum inventory level for each ROC in each basement. These calculated values, which are designated as Basement Inventory Levels (BIL), are used during STS design to determine a reasonable areal coverage based upon the theoretical potential of exceeding the inventory level based upon survey data.

The BIL do not represent the inventory levels expected to remain at license termination.

3.2.3 Derived Concentration Guideline Level (DCGL) - A derived, radionuclide specific activity concentration within a survey unit corresponding to the release criterion. The DCGLW (the DCGL used for the statistical tests) is based on an average concentration over a large area. The DCGLEMC (the DCGL used for the elevated measurement comparison) is derived separately for small areas of elevated activity.

3.2.4 Elevated Measurement Comparison (EMC) - A comparison of measured values against the DCGLW modified to account for small areas where residual radioactivity levels exceed the DCGLW. The modified DCGL (DCGLEMC) is the acceptable level of residual radioactivity over a small but defined area which meets the site release criterion.

3.2.5 Final Radiation Survey (FRS) - Measurements and sampling to describe the radiological conditions of a site, following completion of decontamination activities (if any) in preparation for release.

Page 5 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 3.2.6 Final Status Survey (FSS) - FRS conducted on soil, buried piping and groundwater to demonstrate that residual radionuclide concentrations are equal to or below site-specific DCGLs.

3.2.7 Frequency Plot - A bar chart of the number of data points within a certain range of values. The frequency plot may reveal any obvious departures from symmetry, such as skewness or bimodality (two peaks), in the data distributions for survey units or background reference areas.

3.2.8 Investigation Level - A level of radioactivity that is based on the survey unit classification and the DCGLW which, if exceeded, initiates an investigation of the survey measurement.

3.2.9 Mean - The average value of the data set, obtained when the sum of the individual measurements is divided by the number of measurements.

3.2.10 Median - The center of the data set when data points are ranked in order from smallest to largest. The median is the center data point if the data set contains an odd number of values or the average of the two center data points if the data set contains an even number of values.

3.2.11 Minimum Detectable Concentration (MDC) - An a priori radioactivity level that a specific instrument and technique can be expected to detect 95% of the time.

3.2.12 Outlier - A measurement that is unusually large or small relative to the rest and therefore is suspected of misrepresenting the population from which it was collected.

3.2.13 Posting Plot - A map of the survey unit with the data values entered at the measurement locations. The posting plot can reveal spatial non-homogeneities in the survey unit such as patches of elevated residual radioactivity or groupings of measurements that exceed the DCGLW.

3.2.14 Quantile Plot - A plot used to diagnose asymmetry in a data set. A quantile plot is constructed by ranking the data from smallest to largest. Each data value is plotted against the percentage of the data set with that value or less.

3.2.15 Range - The measure of the difference between the largest and smallest values in the data set.

3.2.16 Sign Test - A nonparametric statistical test used to demonstrate compliance with the site release criterion when the radionuclide of interest is not present in background or constitutes a small fraction of the DCGLW.

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LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 3.2.17 Source Term Survey (STS) - FRS conducted to demonstrate that the inventory of residual radioactivity in building basements, embedded piping and penetrations is below a source term inventory commensurate with the dose criterion in 10 CFR 20.1402.

3.2.18 Standard Deviation - The measure of the variability around the mean of the data set.

3.2.19 Unity Rule - A rule applied when more than one radionuclide is present at a concentration that is distinguishable from background and where a single concentration comparison is not applied.

3.3. Acronyms

AF Area Factor

BIL Basement Inventory Level

FRS Final Radiation Survey

LT License Termination

CoC Chain-of-Custody

DCGL Derived Concentration Guideline Level

DQA Data Quality Assessment

DQO Data Quality Objectives

EMC Elevated Measurement Comparison

FOV Field of View

FRS Final Radiation Survey

FSS Final Status Survey

HTD Hard-to-Detect

ISOCS In-Situ Object Counting System

LTP License Termination Plan

MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual

MDC Minimum Detectable Concentration

NIST National Institute of Standards and Technology

Page 7 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 NRC US Nuclear Regulatory Commission

QA Quality Assurance

QAPP Quality Assurance Project Plan

QC Quality Control

ROC Radionuclides-of-Concern

SOF Sum-of-Fractions

STS Source Term Survey

TSD Technical Support Document

LCSRP LaCrosse Station Restoration Project

3.4. Precautions, Limitations, and Prererequisites

3.4.1 Precautions

1.) Documents and databases containing FRS data are Quality Assurance (QA) records when complete. Positive control of this data shall be maintained in accordance with section 2.5.2 of LC-QA-PN-001 Final Radiation Survey Quality Assurance Project Plan (Reference 2.6).

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.

3.) Direct access to FRS data shall be limited to personnel authorized by the RP FRS Manager.

4.) When assessing STS results, if the potential dose from the activity concentration of the identified plant-derived gamma-emitting radionuclide exceeds 10% of the dose limit (2.5 mrem/yr), then additional concrete samples shall be acquired and analyzed for the presence of Hard-to-Detect (HTD) radionuclides. If the analysis of the additional samples indicates a radionuclide distribution significantly different than the normalized mixture fractions presented in Attachment 1, then the new mixture fractions will be derived, documented and applied to the effected STS unit.

5.) If surveys indicate the presence of gamma-emitting radionuclides at concentrations greater than 50% of a DCGL in soils or buried pipe, then the samples shall be analyzed for the presence of HTD radionuclides.

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LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 6.) When assessing STS results, verify that no plant-derived gamma emitting radionuclides other than the dose-significant ROC from Table 6-3 of LTP Chapter 6 were identified at concentrations greater than MDC. If a plant-derived gamma emitting other than the ROC were identified at concentrations greater than MDC, then perform an investigation to assess the dose significance of the identified radionuclide.

7.) The total mean dose inventory in each basement, considering all STS units contained within the basement, must be below 25 mrem/yr. If a basement has multiple STS units then the sum of the mean inventory fractions (total mean dose for the survey unit divided by the dose criterion of 25 mrem/yr) for each STS unit contained within the basement must be less than one. If the sum exceeds one, then an investigation will be performed which may result in the acquisition of additional measurements, the reclassification of STS units, or additional remediation. If the sum exceeds 0.5, then an investigation will be performed to provide additional assurance that the 25 mrem/yr dose criterion is met with 95% confidence.

8.) When assessing FSS results, if the analysis of a surface soil sample, or the results of a surface gamma scan indicates the potential presence of residual radioactivity at a concentration of 75% of the surface DCGLw, then additional biased subsurface soil sample(s) shall be taken to the appropriate depth within the area of concern as part of the investigation.

9.) Remediation, Reclassification, and Resurvey

A. Re-classification of a survey unit from a less restrictive classification to a more restrictive classification shall be performed in accordance with procedure LC-FS-PR-006, Survey Unit Classification (Reference 2.7).

B. A survey unit may not be reclassified to a lesser classification (e.g.

from a Class 1 to a Class 2 or from a Class 2 to a Class 3) without RP FRS Manager approval.

C. The decision to separate out and reclassify a new survey unit due to the presence of elevated residual radioactivity with the remainder of the original survey unit retaining its original classification should consider the following;

i. The assumptions made as to how the original survey unit was classified.

ii. The postulated cause of the elevated residual radioactivity.

D. The possibility for other similar areas within the original survey unit having gone undetected.

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LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 E. The extent of the elevated residual radioactivity (and corresponding remediation) relative to the total area of the original survey unit.

3.4.2 Limitations

1.) Data accepted as the FRS of record shall be reviewed to verify they are authentic, appropriately documented, and technically defensible.

2.) Survey data may be accepted as FRS data provided the following requirements are met:

A. Methodology, techniques, and quality controls required for the FRS have been applied and achieved.

B. No further remediation will be performed in the survey unit or, if remediation is performed, then the remediation that occurs will be localized in nature, all resultant contamination material will be controlled, and the area impacted by the remediation activity will be re-scanned.

C. Isolation and control measures have been implemented and maintained in accordance with procedure LC-FS-PR-010, Isolation and Control for Final Radiation Survey (Reference 2.8).

3.) Use of Graphics for Data Evaluation

A. A frequency plot is useful where anomalies in the data are encountered or where the data distribution is otherwise suspected to depart from symmetry.

B. A posting plot and histogram can be useful as part of an investigation survey where one or more direct measurements or volumetric samples exceed the DCGL.

C. Other graphical data representation tools may be used, as appropriate, to examine the general shape of the data distribution or to identify spatial patterns, relationships, or potential anomalies in the data that might go unnoticed using purely numerical methods.

3.4.3 Prerequisites

1.) Programs developed to assist in calculating FRS data (i.e. Excel spreadsheets) shall be tested to verify and validate that the calculations are correct before they are used.

2.) Any field copies of data collection forms generated in support of FRS implementation shall be filed with the applicable survey package.

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LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 3.5. Records

3.5.1 Attachment 10, Final Radiation Survey Data Quality Objectives Review Checklist

3.5.2 Attachment 11, FSS Preliminary Survey Data Summary

3.5.3 Attachment 12, STS Preliminary Survey Data Summary

3.5.4 Attachment 13, Sign Statistical Test

3.5.5 Attachment 14, Final Radiation Survey Investigation

3.5.6 ATTACHMENT 14, Corrective Actions for Final Radiation Survey Failure

3.5.7 Attachment 16, STS Survey Plan Closeout

3.5.8 Attachment 17, FSS Survey Plan Closeout

4. PEOCEDURE

4.1. Data Validation

4.1.1 Ensure that the survey area and survey unit for which the data is relevant is clearly marked on the data report.

4.1.2 Perform a validation of the survey data to ensure the data results are authentic, realistic and valid. Assess each specific sample or measurement result individually. Data validation includes the following;

1.) Verify that the unique sample identification number for each sample or measurement is consistent between the sample analysis report, the Chain-of-Custody (CoC) form, the FRS Sample Plan and/or the survey instructions.

2.) Verify that the recorded sample date & time for each sample or measurement is consistent with the CoC form (if applicable) and the survey record.

3.) Verify that the data is complete and that there are no missing results or supporting data, including but not limited to MDC, uncertainty, background, or methods of analysis.

4.) Verify 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 FRS Sample Plan for that survey unit.

5.) Verify 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.

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LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 6.) For data collected with a data logging instrument, verify the data has been downloaded with a unique file name.

4.1.3 For the assessment of open land or buried pipe survey units, present survey data results in units appropriate for comparison to the DCGL. As applicable, convert the units for the reported data to the DCGL units by correcting for survey instrument background, efficiency, geometry, detector area, and/or measurement size.

NOTE The Canberra In-Situ Object Counting System (ISOCS) has been selected as the primary instrument that will be used to perform STS.

4.1.4 For the assessment of STS units, present the survey data in units of activity per m2 for each gamma-emitting ROC. As applicable, convert the units for the reported data to activity by correcting for survey instrument efficiency and geometry.

4.1.5 Indicate the analysis or measurement results has been validated by signing, dating and entering the time on the cover of the analysis or survey report next to the words, DATA VALIDATED.

4.1.6 Once analysis or measurement results have been validated, place the documentation in the survey unit package for FRS data evaluation.

4.1.7 If an analysis result, measurement or set of data cannot be validated, then highlight the sample or measurement result in question. The reviewer shall place their initials next to the measurement or sample in question and notify the RP FRS Manager.

1.) The RP FRS Manager or designee shall;

A. Consider initiating an investigation into the reason or cause in accordance with LC-AD-PR-004, Corrective Action Program (Reference 2.3).

B. Assess the valid data for the survey unit in order to make a determination if the remaining data is sufficient to meet the DQOs for that survey unit.

C. Direct the acquisition of additional measurements or samples as necessary if the remaining data is insufficient to continue FRS.

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LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 4.2. DQO Checklist

4.2.1 Initiate Attachment 10, Final Radiation Survey Data Quality Objectives Review Checklist when notified that all samples and measurements required by the FRS Sample Plan and sample instructions have been taken or acquired.

4.2.2 Using the checklist, review the FRS Sample Plan, the sample instructions, the Field Notes, survey records and/or data analyses reports to ensure that the DQOs used for the survey design are applicable and valid.

4.2.3 If the review identifies discrepancies, then document any corrective actions that were taken to resolve the discrepancy.

4.2.4 If discrepancies remain that are unresolved, then forward the documentation to the RP FRS Manager for completion.

1.) The RP FRS Manager or designee shall;

A. Assess the data that has been impacted by the discrepancy to determine if the data remains valid.

B. Assess the remaining data that has not been impacted by the discrepancy to make a determination if the remaining data is sufficient to meet the DQOs for that survey unit.

C. Consider initiating an investigation into the reason or cause in accordance with LC-AD-PR-004, Corrective Action Program (Reference 2.3).

D. Direct the acquisition of additional measurements or samples as necessary if the remaining data is insufficient to continue FRS.

4.3. Preliminary Data Review for FSS

NOTE Attachment 11, FSS Preliminary Survey Data Summary is designed for the assessment of volumetric media for FSS. If FSS is performed on a buried pipe system using gross measurements to demonstrate compliance, then an equivalent format using gross measurements may be used. Preliminary data review can also be processed using alternate formats, pre-programmed computer databases, computer spreadsheets, electronic calculators and hand calculations provided that all requisite data is included.

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LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 4.3.1 Using Attachment 11, FSS Preliminary Survey Data Summary or an equivalent form, prepare a summary of the survey data that will be used for FSS for the survey unit, including scan survey results, any biased samples that were taken and any investigation measurements or samples that were taken as a result of elevated scan measurements.

4.3.2 Ensure all valid measured numerical values are recorded, including values below the MDC and values that are negative.

NOTE For FSS, only samples or measurements taken as part of the systematic sample population for the survey unit are used to derive statistical data.

Biased, judgmental and/or investigation samples are compared directly against the respective DCGL.

4.3.3 Derive and list the basic statistical data for each analyzed radionuclide or direct measurement in the systematic sample population to be used to demonstrate compliance for the survey unit. At a minimum, the statistics will include;

1.) Minimum value.

2.) Maximum value.

3.) Mean value of the data set.

4.) Median value of the data set.

5.) Standard deviation.

4.3.4 Calculate the Sum-of-Fractions.

NOTE Attachment 2 presents the site-specific DCGLs for surface soils reproduced from Table 5-4 of LTP Chapter 5. Attachment 2 also presents the site-specific DCGLs for buried pipe reproduced from Table 5.5 of LTP Chapter 5.

For multiple radionuclides, the DCGL is 1 and the unity rule applies.

NOTE If a surrogate DCGL was calculated as part of the survey design for the FSS (section 5.4.4 of LC-FS-PR-002, Final Radiation Survey Package Development [Reference 2.9]), then the surrogate DCGL calculated will be used for the selected surrogate radionuclide.

1.) Denote the appropriate DCGL(s) value for each ROC.

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LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 2.) Calculate a Fraction of the DCGL for each sample or measurement by dividing the reported concentration by the DCGL. If a sample has multiple ROCs, then the Fraction of the DCGL for each ROC will be summed to provide a Sum-of-Fractions (SOF) for the sample.

NOTE For soil survey units, if both surface (grade to 1 meter below grade) and subsurface (greater than 1 meter below grade) soil samples are taken, then an average SOF is determined as part of the statistical sample population.

3.) Calculate an average SOF for the systematic sample population for the survey unit.

A. The average SOF is calculated using the following equation;

where: n = Number of measurements or samples;

SOFi = SOF for the ith measurement or sample.

B. If the average SOF is less than or equal to unity (1), then proceed to the next step. If an average SOF is greater than unity (1), then stop data assessment and notify the RP FRS Manager.

4.3.5 Denote the results of any biased or judgmental samples and/or measurements taken in the survey unit.

4.3.6 Assess the scan survey results for the survey unit.

1.) Compare the reported scan results to the appropriate scan investigation level for the survey unit. Scan investigation levels are presented in Attachment 8.

2.) If a scan measurement exceeds an investigation level, then ensure that a biased sample or measurement was taken at the flagged location.

4.3.7 Prepare a map for the survey unit that includes the following information;

1.) The survey unit boundaries.

2.) The locations corresponding to the coordinates for each systematic measurement or sample.

3.) The locations corresponding to the coordinates where any elevated scan measurements were detected.

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LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 4.) The locations corresponding to the coordinates for each biased or investigation measurement or sample.

NOTE Refer to section 8.2.2.2 of MARSSIM (Reference 2.2) for examples and methods for the graphical representation of data.

4.3.8 Display the data using graphical representation by creating a posting plot and a frequency plot.

4.4. Preliminary Data Review for STS

NOTE Attachment 3 reproduces Table 5-3 from LTP Chapter 5, which presents the Basement Dose Factors in units of mrem/yr per mCi. Attachment 4 presents the Basement Inventory Levels (BIL) from Table 5.7 from LTP Chapter 5 in units of pCi for each ROC. Attachment 5 presents the BIL values in Attachment 4 divided by the area of each basement survey unit.

NOTE In accordance with section 5.2 of LTP Chapter 5, it was determined that Co-60, Sr-90, and Cs-137 accounted for 100% of all dose in contaminated concrete. Attachment 1 reproduces Table 5-2 from LTP Chapter 5, which presents the final suite of ROC for the decommissioning of LCNPS and the normalized mixture fractions based on the radionuclide distribution for the Waste Treatment Building and soils.

NOTE Attachment 12, STS Preliminary Survey Data Summary is designed for the assessment of direct measurements using the ISOCS for STS. If STS is performed on an embedded pipe system or penetration using gross measurements to demonstrate compliance, then an equivalent format using gross measurements may be used. Preliminary data review can also be processed using alternate formats, pre-programmed computer databases, computer spreadsheets, electronic calculators and hand calculations provided that all requisite data is included.

4.4.1 Using Attachment 12, STS Preliminary Survey Data Summary or an equivalent form, prepare a summary of the survey data that will be used for STS for the survey unit, including any investigation measurements or samples that were taken as a consequence of higher than expected direct measurement results.

4.4.2 List the measured activity for each gamma-emitting ROC.

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LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 4.4.3 Using the radionuclide mixture fractions applicable to the survey unit, derive inferred activity for any HTD ROC.

4.4.4 Calculate a fraction for each ROC by dividing the reported concentration by the BIL per area levels in Attachment 5. If a sample has multiple ROCs, then the fractions for each ROC are summed to provide a SOF for the measurement.

4.4.5 Derive and list the data for each measurement that will be used to demonstrate compliance for the STS unit. At a minimum, the statistics will include;

1.) The Total Mean Activity per ROC.

2.) The Total Mean Dose for each ROC.

3.) The Total Mean Dose for the STS unit.

4.) The Mean Inventory Fraction for the STS unit.

4.4.6 If the SOF for an individual measurement exceeds the STS Investigation Levels presented in Attachment 7 or, if the Total Mean Dose exceeds 25 mrem/yr or, if the sum of the Mean Inventory Fractions for all STS units in a basement exceeds one, then;

1.) Notify the RP FRS Manager.

2.) Perform an investigation as to the cause of the higher than expected activity.

This may include the acquisition of additional measurements to bound the area of elevated activity.

3.) Perform an assessment to determine if the basis for the current classification of the survey unit is still valid. If it is determined that the classification basis is no longer valid, then proceed to step 4.6.1.

4.4.7 Prepare a map for the survey unit that includes the following information:

1.) The survey unit boundaries.

2.) The locations corresponding to the coordinates for each direct measurement.

3.) The locations corresponding to the coordinates for each biased or investigation measurement or sample.

4.5. Selection and Performance of Statistical Tests

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LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0

NOTE Statistical tests will only be applied to the systematic sampling and/or measurement populations. For soil survey units, the statistical test will be performed on the systematic sample population that represents the as-left grade of the surface soil.

4.5.1 If every measurement in the systematic sample population;

is less than or equal to the DCGLw, or

where a background reference area is used, the difference between the maximum survey data set measurement and the minimum background reference area measurement is less than or equal to the DCGLw, or

has a SOF less than one,

then a statistical test is not required and proceed to step 4.6.3.

NOTE For STS, the Sign Test will be used to evaluate the remaining residual radioactivity in each survey unit against the BIL presented in Attachment 5.

The Sign Test is expected to be the most appropriate test for LSRP FSS results because background is expected to constitute a small fraction of the DCGL.

4.5.2 Perform the Sign test as follows;

NOTE Attachment 14, Sign Statistical Test, or an equivalent form can be used to document the performance of the Sign test. Data can also be processed using one or more of the following methods: the use of pre-programmed computer databases, computer spreadsheets, electronic calculators and hand calculations.

1.) List the survey unit measurements, 1, 2, 3, n; where n = the number of measurements.

NOTE Gross activity measurements taken on structural surfaces will be corrected for material specific gross background activity.

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LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 2.) For volumetric media, list the fraction of DCGL (measured concentration divided by the DCGLw) for each ROC. For direct measurements, divide the gross direct measurement by the Adjusted Gross DCGL. For STS, list the SOF for each STS measurement.

3.) For volumetric media, sum the individual fractions for each ROC to derive a weighted sum (Ws). For direct measurements, use the fraction of the Adjusted Gross DCGL as the weighted sum for the measurement (Ws). For STS, use the SOF as the weighted sum for the measurement (Ws).

4.) Subtract the weighted sum (Ws) from unity (one) to obtain the difference.

5.) Discard differences where the value is exactly zero and reduce n by the number of such zero measurements.

6.) Count the number of positive differences. The result is the test statistic S+,

or critical value.

NOTE In accordance with section 5.5.2.2 of LTP Chapter 5, the Type I decision error that was used for STS design was set at 0.05

7.) Compare the value of S+ to the critical values in Table I.3 of MARSSIM (Reference 2.2).

A. If S+ is greater than or equal to the critical value for the Type 1 Error

(), then the null hypothesis can be rejected and the survey data set passes the Sign test.

B. If S+ is less than the critical value, then the survey data set fails the Sign test.

4.5.3 If the survey unit passes the statistical test, then proceed to step 4.6.3. If the survey unit fails the statistical test, then inform the RP FRS Manager and further analyze the data to determine why the statistical test failed.

1.) If it appears that the failure is caused by the presence of radioactivity concentrations that will require further remediation, then proceed to step 5.7.

2.) If it appears that the failure is due to statistical fluctuations, then the survey unit may be resurveyed and another set of discrete measurements or samples collected for statistical analysis. A larger number of measurements may increase the probability of passing the statistical test if the survey unit actually meets the site release criterion.

Page 19 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 3.) If it appears the power of the test is insufficient due to the number of measurements, then a retrospective power analysis for the test may be performed as described in Appendices I.9 and I.10 of MARSSIM (Reference 2.2) to determine if additional data may be collected and included in the data set.

4.6. Investigations

4.6.1 For STS, if the survey unit fails the statistical test or, if it was determined in step 4.4.6 that the SOF for an individual measurement exceeds the STS Investigation Levels presented in Attachment 7 or, if the Total Mean Dose exceeds 25 mrem/yr or, if the sum of the Mean Inventory Fractions for all STS units in a basement exceeds one, then proceed to step 4.6.4.

4.6.2 For FSS, if any location identified by volumetric sample, scan or static measurements exceeds the investigation levels as presented in Attachment 7 that are applicable to the survey unit, then proceed to step 4.6.4.

4.6.3 If the survey unit (FSS and STS) has passed the statistical test, and does not have any volumetric sample, scan or static measurements in excess of the investigation levels, then close out the survey package per section 5.8 and commence the generation of the FRS Release Record for this survey unit in accordance with procedure LC-FS-PR-009, Final Radiation Survey Data Reporting (Reference 2.5).

NOTE At LCSRP, Elevated Measurement Comparison (EMC) only applies to Class 1 open land survey units.

NOTE Investigation(s) can also be processed using alternate formats, pre-programmed computer databases, computer spreadsheets, electronic calculators and hand calculations provided that all requisite data is included.

4.6.4 If the results of the FRS require an investigation, then initiate ATTACHMENT 14, Final Radiation Survey Investigation or equivalent.

4.6.5 Document the reason for the investigation.

4.6.6 List the locations and sample or measurement results that exceed the investigation levels.

Page 20 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 4.6.7 Using the sample or measurement coordinates, assess if the elevated area has been adequately bounded. If the elevated area has not been adequately bounded, then take additional samples or measurements as necessary to establish the boundaries of the elevated area.

NOTE Use of location plots on a map of the survey unit is an effective tool to determine bounding and area size.

4.6.8 List the bounding samples or measurements for each elevated area.

4.6.9 If the survey unit is a STS unit, then proceed to step 4.6.10. If the survey unit is a FSS survey unit and is classified as Class 2, then proceed to step 4.6.12. If the survey unit is a FSS survey unit and is classified as Class 3, then proceed to step 4.6.13. If the survey unit is classified as a FSS Class 1 open land area, then perform an EMC as follows;

1.) In each elevated area, denote the DCGLw(s) for each ROC pertinent to the elevated sample(s) or the applicable Adjusted Gross DCGL.

NOTE Attachment 6 reproduces Tables 5-6 from LTP Chapter 5, which presents the Area Factors (AF) for surface soils.

2.) Calculate an area in square meters for the identified elevated area(s) and select the appropriate AF from Attachment 6 that corresponds to the area with the elevated activity.

3.) Calculate a DCGLEMC for each applicable radionuclide or for gross activity by multiplying the DCGLw for the elevated measurement(s) or sample(s) by the AF.

NOTE The Average Radioactivity Fraction is calculated using only sample results from the systematic sample population that are located outside of any identified elevated area.

4.) For volumetric media, sum the products of the average concentration for each individual radionuclide divided by its respective DCGLw. For gross measurements, the Average Radioactivity Fraction (j) is calculated by dividing the average gross activity concentration by the Adjusted Gross DCGL.

5.) Calculate an Elevated Radioactivity Fraction (fEMC) for each identified elevated area as follows; Page 21 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 A. Determine the average concentration (j) for gross activity for gross measurements or for each radionuclide for volumetric media in each identified elevated area.

B. For gross measurements, subtract the Average Gross Activity (j) from the Average Gross Activity Concentration (j) in the elevated area and divide this value by the DCGLEMC to derive an Elevated Radioactivity Fraction (fEMC) for the elevated area.

C. For volumetric media, subtract the Average Concentration of Radionuclide (j) for each radionuclide from the average radionuclide concentration (j) in the elevated area and divide this value by the DCGLEMC to derive a Fraction of DCGLEMC (fEMC) for each radionuclide.

6.) Sum the Elevated Radioactivity Fractions (fEMC) for each elevated area.

7.) Add the Average Radioactivity Fraction (favg) to the summed Elevated Radioactivity Fractions (fEMC). This value represents the EMC SOF for this survey unit.

4.6.10 If the survey unit is STS, proceed to step 5.7.

4.6.11 If the survey unit is classified as FSS Class 1, and the measured gross activity or, the concentration for any radionuclide reported for any systematic, biased or investigative sample or measurement taken in the survey unit is equal to or greater than its respective DCGLw, and, the EMC SOF for the survey unit is greater than unity (1), then proceed to step 4.7. If the EMC SOF is less than or equal to unity (1), then the survey unit will pass the EMC, the investigation is complete and the FRS Release Record for this survey unit may be generated in accordance with procedure LC-FS-PR-009, Final Radiation Survey Data Reporting (Reference 2.5).

4.6.12 If the survey unit is classified as a FSS Class 2 survey unit, and the measured gross activity or the concentration for any radionuclide reported for any systematic, biased or investigative sample or measurement taken in the survey unit is equal to or greater than its respective DCGLw, then proceed to step 5.7. If the action level has not been exceeded, then the investigation is complete and the FRS Release Record for this survey unit may be generated in accordance with procedure LC-FS-PR-009, Final Radiation Survey Data Reporting (Reference 2.5).

Page 22 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 4.6.13 If the survey unit is classified as a FSS Class 3 survey unit and, the measured gross activity or, the concentration for any radionuclide reported for any systematic, biased or investigative sample or measurement taken in the survey unit is equal to or greater than 50% of its respective DCGLw, then proceed to step 4.7. If the action level has not been exceeded, then the investigation is complete and the FRS Release Record for this survey unit may be generated in accordance with procedure LC-FS-PR-009, Final Radiation Survey Data Reporting (Reference 2.5).

4.7. Corrective Actions for Final Radiation Survey Failure

4.7.1 If the survey unit did not pass FRS, then initiate Attachment 16, Corrective Actions for Final Radiation Survey Failure or equivalent. Attachment 9 provides potential corrective actions that may be taken as corrective actions for the FSS failure of a survey unit. These corrective actions may require remediation, reclassification, and/or resurvey.

4.7.2 Submit completed form to the RP FRS Manager for approval.

4.7.3 When the RP FRS Manager has approved the corrective action, then prepare a revision (addendum), as appropriate, to the FRS Sample Plan in accordance with LC-FS-PR-009, Final Radiation Survey Package Development (Reference 2.9).

If any new survey units were created from existing survey units, then prepare a new survey design in accordance with LC-FS-PR-002, Final Radiation Survey Package Development (Reference 2.9).

4.8. Survey Package Closeout

4.8.1 For STS Survey packages, complete Attachment 17, STS Survey Plan Closeout and file the completed form in the appropriate survey package.

4.8.2 For FRS Survey packages, complete Attachment 18, FSS Survey Plan Closeout and file the completed form in the appropriate survey package.

5. ATTACHMENTS

5.1. Attachment 1, Dose Significant Radionuclides and Mixtures

5.2. Attachment 2, DCGLs for Soils and Buried Pipe

5.3. Attachment 3, Basement Dose Factors

5.4. Attachment 4, Basement Inventory Levels (BIL)

5.5. Attachment 5, STS Investigation Levels

5.6. Attachment 6, Area Factors for Surface Soils

Page 23 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 5.7. Attachment 7, STS Investigation Levels

5.8. Attachment 8, FSS Investigation Levels

5.9. Attachment 9, Remediation, Reclassification and Resurvey Actions

5.10. Attachment 10, Final Radiation Survey Data Quality Objectives Review Checklist

5.11. Attachment 11, FSS Preliminary Survey Data Summary

5.12. Attachment 12, STS Preliminary Survey Data Summary

5.13. Attachment 13, Sign Statistical Test

5.14. Attachment 14, Final Radiation Survey Investigation

5.15. ATTACHMENT 14, Corrective Actions for Final Radiation Survey Failure

5.16. Attachment 16, STS Survey Plan Closeout

5.17. Attachment 17, FSS Survey Plan Closeout

Page 24 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 1 Table 5-1 Dose Significant Radionuclides and Mixture

Radionuclide(2) Distribution Fraction

Co-60 0.014

Sr-90 0.010

Cs-137 0.976

1.) Based on maximum percent of total activity from Table 22 of La CrosseSolutions RS-TD-313196-001, Radionuclides of Concern for Soil and Basement Fill Model Source Terms (Reference 2.10), normalized to one for the dose significant radionuclides.

2.) Does not include dose significant radionuclides for activated concrete (H-3, Eu-152, Eu-154) under the assumption that all activated concrete will be removed and disposed of as waste.

Page 25 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 2 DCGLs FOR SOILS AND BURIED PIPE

Table 5-2 DCGLs for Soils (pCi/g)

Radionuclide Surface Soil DCGL (pCi/g)

Co-60 1.28E+01 Sr-90 6.55E+03 Cs-137 5.79E+01

DCGLs for Buried Pipe

Table 5-3 DCGLs for Buried Piping (dpm/100cm2)

Pipe DCGL (dpm/100cm2)

Radionuclide 2 in 3 in 4 in 6 in 8 in 48 in

I I I I I I I I Co-60 6.27E+03 1.41E+04 2.51E+04 5.64E+04 1.00E+05 3.61E+06 Sr-90 2.85E+04 6.40E+04 1.14E+05 2.56E+05 4.55E+05 1.64E+07 Cs-137 3.22E+06 7.25E+06 1.29E+07 2.90E+07 5.15E+07 1.85E+09

Page 26 of 56 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 3 BASEMENT DOSE FACTORS

Table 5-4 Basement Dose Factors (mrem/yr per mCi)

Reactor Building Waste Treatment Building Groundwater Drilling Excavation Groundwater Drilling Excavation Scenario Spoils Scenario Scenario Spoils Scenario Scenario Scenario mrem/yr per mCi mrem/yr per mCi Co-60 4.86E-01 1.16E-01 1.55E+00 6.80E-02 1.14E+00 2.05E+01 Sr-90 5.03E+00 2.06E-04 3.01E-03 2.99E+00 2.03E-03 3.99E-02 Cs-137 1.75E-01 2.84E-02 3.41E-01 4.25E-02 2.79E-01 4.52E+00

Waste Gas Tank Vault Remaining Basements Groundwater Drilling Excavation Groundwater Drilling Excavation Scenario Spoils Scenario Scenario Spoils Scenario Scenario Scenario mrem/yr per mCi mrem/yr per mCi Co-60 1.19E-01 5.93E-01 6.84E+00 1.49E-02 1.31E-01 3.43E+00 Sr-90 1.09E+00 1.04E-03 1.34E-02 1.27E+00 2.31E-04 6.69E-03 Cs-137 4.76E-02 1.45E-01 1.51E+00 5.62E-03 3.18E-02 7.57E-01

Page 27 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 4 Basement Inventory Levels (BIL) Used for STS Design

Table 5-5 Basement Inventory Levels (BIL) Used for STS Design (mCi Total Inventory)

Reactor WTB WGTV Remaining Building Basements

I I I I I I (mCi) (mCi) (mCi) (mCi)

Co-60 1.16E+01 1.15E+00 3.31E+00 6.98E+00 Sr-90 4.97E+00 8.25E+00 2.26E+01 1.96E+01 Cs-137 4.59E+0 1 5.16E+00 1.47E+01 3.15E+01

Page 28 of 56 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 5 BIL Divided by Basement Survey Unit Area

Reactor WTB WGTV Remaining Building Basements

I I I I I I (mCi) (mCi) (mCi) (mCi)

Co-60 2.26 E-03 1.12 E-02 7.20 E-04 1.05E-03 Sr-90 9.7 E-04 8.09 E-02 4.91E-03 2.94E-03 Cs-137 8.9 E-03 5.06 E-02 3.19E-03 4.72E-0

Note: Attachment 5 presents the Basement Inventory Level values in attachment 4 divided by the area of each basement survey unit. (

obtained from LTP Chapter 5, on page 5-26 from table 5-8. )

Page 29 of 56 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 6 Area Factors for Surface Soils Table 5-6 Area Factors for Soils

Radionuclide Area Factor 1 m2 2 m2 5 m2 10 m2 100 m2

I I I I I I I Co-60 9.44 5.56 3.07 2.04 1.19 Sr-90 11.22 6.66 3.69 2.45 1.41 Cs-137 9.11 5.42 3.01 2.00 1.18

Page 30 of 56 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 7 STS INVESTIGATION LEVELS

STS Unit Classification Direct Measurement Investigation Levels:

Class 1 None

Class 2 > SOF of 0.5

Class 3 > SOF of 0.1

Note 1 Exceeding the investigation levels for STS could incur the acquisition of additional measurements to increase the areal coverage of the survey. Consequently, as the areal coverage for a Class 1 STS unit is 100%, there is no applicable investigation level for a Class 1 STS unit.

Note 2 These STS units will be subjected to an areal coverage commensurate with the guidance pertaining scan coverage as presented in the MARSSIM. As the areal coverage is commensurate with the lower range of the scan coverage guidance, the investigation levels for STS have been conservatively adjusted to 50% of the limit.

Page 31 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 8 FSS INVESTIGATION LEVELS

Table 5-7 Investigation Levels

Survey Unit Scan Investigation Levels: Direct Measurement Classification Investigation Levels:

Class 1 > DCGLEMC > DCGLEMC

Class 2 > DCGLW or > MDCscan if > DCGL MDCscan is greater than DCGLW w

Class 3 > DCGLW or > MDCscan if > 50 percent of DCGL MDCscan is greater than DCGLW w

Page 32 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 9 REMEDIATION, RECLASSIFICATION AND RESURVEY ACTIONS Page 1 of 2 REMEDIATION Remediation Criteria Proposed Remediation

1) The EMC SOF for survey unit is less than or equal to unity (1) None Class 1 FSS Survey 2) The Elevated Radioactivity Fraction (fEMC) exceeds unity in 5% or less of the survey Spot Remediation & Resurvey Unit unit area.
3) The Elevated Radioactivity Fraction (fEMC) exceeds unity in greater than 5% of the General Remediation and Restart FSS survey unit area.
1) The mean inventory fraction (total mean dose for the survey unit divided by the dose Class 1 STS Unit criterion of 25 mrem/yr) is greater than or equal to one. General Remediation and Restart STS
2) The sum of the mean inventory fractions for each STS unit contained within a building basement is greater than or equal to one.

RECLASSIFICATION Reclassification Criteria Proposed Action The extent of the elevated area relative to the Reclassify only the bounded discrete area of total area of the survey unit is minimal and the elevated activity to Class 1.

One or several survey measurements source of the residual radioactivity is known (scan, sample or direct measurement) The extent of the elevated area relative to the Reclassify 2,000 m2 for soils or 100 m2 for Class 2 Survey Unit exceed 50% of the dose criterion or a total area of the survey unit is minimal and the structures around the area of elevated activity DCGLw or a portion of the survey unit source of the residual radioactivity is unknown as Class 1.

is remediated.

The extent of the elevated area relative to the Reclassify the entire survey unit as Class 1.

total area of the survey unit is significant.

One or several survey measurements The extent of the elevated area relative to the Reclassify the area of elevated activity to (scan, sample or direct measurement) total area of the survey unit is minimal Class 1 and create a Class 2 buffer zone of exceed 50% of the dose criterion or a appropriate size around the area.

DCGLw or a portion of the survey unit The extent of the elevated area relative to the Reclassify the area of elevated activity to is remediated. total area of the survey unit is significant. Class 1 and create a Class 2 buffer zone of Class 3 Survey Unit appropriate size around the area.

The extent of the elevated area relative to the Reclassify the area of elevated activity to One or several survey measurements total area of the survey unit is minimal Class 2.

(scan, sample or direct measurement) For soils, reclassify 10,000 m2 around the area exceed 1% of the dose criterion or 50% The extent of the elevated area relative to the of elevated activity to Class 2. For structures, of a DCGLw total area of the survey unit is significant. reclassify 1,000 m2 around the area of elevated activity to Class 2.

Page 33 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 9 REMEDIATION, RECLASSIFICATION AND RESURVEY ACTIONS Page 2 of 2 RESURVEY Resurvey Criteria Proposed Action Re-scan remediated area; collect replacement The extent of the elevated area relative to the systematic population samples/measurements The survey unit has been remediated. total area of the survey unit is minimal. within the remediated area using random selection.

Class 1 Survey Unit The extent of the elevated area relative to the Resurvey entire survey unit using a new total area of the survey unit is significant. survey design.

Survey unit has been reclassified from a No remediation was performed. Increase scan or areal coverage to 100%.

Class 2 survey unit. Additional statistical samples are not required.

The area of the new Class 1 survey unit relative to the area of the initial Class 2 survey unit is Increase scan or areal coverage in Class 2 Survey unit has been divided to minimal and no statistical samples were survey unit.

Class 2 Survey Unit accommodate a new Class 1 survey affected.

unit. Statistical sample population was affected by Increase scan or areal coverage in Class 2 the reclassification. survey unit and resurvey entire survey unit using a new survey design.

The area of the new Class 2 survey unit relative Increase scan or areal coverage in Class 3 to the area of the initial Class 3 survey unit is survey unit, collect replacement systematic Survey unit has been divided to minimal. population samples/measurements within the Class 3 Survey Unit accommodate a new Class 2 survey remediated area using random selection.

unit. The area of the new Class 2 survey unit relative Resurvey entire survey unit using a new to the area of the initial Class 3 survey unit is survey design.

significant.

Page 34 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 10 FINAL RADIATION SURVEY DATA QUALITY OBJECTIVES REVIEW CHECKLIST Page 1 of 2 Survey Area: No.

Description:

Survey Unit: No.

Description:

Classification:

Reviewer: Date: Time:

Have all measurements and/or analysis results that will be subjected to data

1. analysis for FRS been individually reviewed and validated in accordance with step 5.1 of this procedure? Yes No (explain)

Have all systematic measurements and/or samples been taken or acquired at

2. the locations specified in the FRS Sample Plan and the FRS Sample Instructions? Yes No (explain)

Have all scans surveys been performed of the areas specified as required in the

3. FRS Sample Plan and the FRS Sample Instructions? (applicable to FSS only)

Yes No (explain)

4. Was a meter circumference scanned around each systematic sample or measurement location? (applicable to FSS only) Yes No (explain)

Have all biased measurements and/or samples been taken or acquired at the

5. locations specified in the FRS Sample Plan & the FRS Sample Instructions?

(applicable to FSS only) Yes No (explain)

6. Have duplicate and/or split samples or measurements been taken or acquired at each location designated as a QC sample? Yes No (explain)

Were the instruments used to measure or analyze the survey data capable of

7. detecting the ROCs or gross activity at a MDC less than the specified target MDC? Yes No (explain)
8. Are the MDCs and the assumptions used to develop the MDCs appropriate for the instruments and methods used to analyze the data? Yes No (explain)

Was the calibration of all instruments that were used to measure or analyze

9. data, current at the time of use and were those calibrations performed using a NIST traceable source? Yes No (explain)
10. Were the instruments successfully response-checked before use and, where required, after use on the day the data was measured? Yes No (explain)
11. Was the custody of samples collected for laboratory analysis tracked from the point of collection until final results were obtained? Yes No (explain)

Do the QC sample results meet the acceptance criteria as specified in LC-QA-

12. PN-001, Final Radiation Survey Quality Assurance Project Plan(QAPP)

(Reference 6.5) Yes No (explain)

If No was the response to any of the questions above, then document the discrepancy as well as any corrective actions that were taken to resolve the discrepancy.

Page 35 of 56 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 10 FINAL RADIATION SURVEY DATA QUALITY OBJECTIVES REVIEW CHECKLIST Page 2 of 2 Survey Area: No.

Description:

Survey Unit: No.

Description:

Discrepancy;

Corrective Actions Taken;

13. Have the corrective actions resolved the discrepancies with the data? Yes No
a. If No, then forward this form to the RP FRS Manager.
14. The following questions will be answered by the RP FRS Manager.
a. If the answer to question 13 was No, then is the affected data still valid?

Yes No

b. If No, then are the existing valid measurements or samples sufficient to demonstrate compliance for the survey unit? Yes No
c. If No, then direct the acquisition of additional measurements or samples as necessary to demonstrate compliance for the survey unit.

Prepared by (FRS Supervisor):

(Print Name) (Signature) (Date)

Approved by:

(RP FRS Manager) (Signature) (Date)

Page 36 of 56 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 11 FSS PRELIMINARY SURVEY DATA

SUMMARY

Page 1 of 3 Survey Area: No.

Description:

Classification:

Survey Unit: No.

Description:

Sample ID Location Radionuclides of Concern SOF Northing Easting Cs-137 I I I I I _______ _______ _______ _______ _______

Result DCGL Fraction of DCGL Result DCGL Fraction of DCGL Result DCGL Fraction of DCGL Result DCGL Fraction of DCGL Result DCGL Fraction of DCGL Result DCGL Fraction of DCGL Result DCGL Fraction of DCGL

Page 37 of 56 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 11 FSS PRELIMINARY SURVEY DATA

SUMMARY

Page 2 of 3 Sample ID Location Radionuclides of Concern SOF Northing Easting Cs-137 _______ _______ _______ _______ _______

Result DCGL Fraction of DCGL Result DCGL Fraction of DCGL Result DCGL Fraction of DCGL Result DCGL Fraction of DCGL Result DCGL Fraction of DCGL Result DCGL Fraction of DCGL Result DCGL Fraction of DCGL Result DCGL Fraction of DCGL

Page 38 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 11 FSS PRELIMINARY SURVEY DATA

SUMMARY

Page 3 of 3

Statistical Quantities Radionuclides of Concern Cs-137 _________ _________ _________ _________ _________

Number of Measurements =

  1. of Measurements > MDC =
  1. of Measurements > DCGL =
  1. of Samples with SOF >1 =

Mean Concentration = Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

Median Concentration = Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

Minimum Concentration = Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

Maximum Concentration = Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

Standard Deviation =

Average Fraction of DCGL =

Average Sum-of-Fractions for Survey Unit = Average Dose for Survey Unit = mrem

Prepared by (FRS Supervisor):

(Print Name) (Signature) (Date)

Page 39 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 12 STS PRELIMINARY SURVEY DATA

SUMMARY

Page 1 of 3 STS Unit:

Description:

Classification:

Location FOV Ratio Measured Inferred Activity per BIL 1 SOF 3 Total Sample ID ROC to Activity Activity ROC Fraction of Activity 4 X Y BIL 2 (m2) Cs-137 (pCi/m2) (pCi/m2) (pCi/m2) (pCi/m2) (pCi/m2)

Coordinate Coordinate Co-60 Cs-137 Ni-63 Sr-90 Co-60 Cs-137 Ni-63 Sr-90 Co-60 Cs-137 Ni-63 Sr-90 Co-60 Cs-137 Ni-63 Sr-90 Co-60 Cs-137 Ni-63 Sr-90 Co-60 Cs-137 Ni-63 Sr-90 Notes 1 From Attachment 5 2 Activity per ROC divided by the BIL/Area 3 Sum of the Fraction of BIL 4 Sum of Activity per ROC

Page 40 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 12 STS PRELIMINARY SURVEY DATA

SUMMARY

Page 2 of 3

Location FOV Ratio Measured Inferred Activity per BIL 1 SOF 3 Total Sample ID ROC to Activity Activity ROC Fraction of Activity 4 X Y BIL 2 (m2) Cs-137 (pCi/m2) (pCi/m2) (pCi/m2) (pCi/m2) (pCi/m2)

Coordinate Coordinate Co-60 Cs-137 Ni-63 Sr-90 Co-60 Cs-137 Ni-63 Sr-90 Co-60 Cs-137 Ni-63 Sr-90 Co-60 Cs-137 Ni-63 Sr-90 Co-60 Cs-137 Ni-63 Sr-90 Co-60 Cs-137 Ni-63 Sr-90 Notes 1 From Attachment 5 2 Activity per ROC divided by the BIL/Area 3 Sum of the Fraction of BIL 4 Sum of Activity per ROC

Page 41 of 56

LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 12 STS PRELIMINARY SURVEY DATA

SUMMARY

Page 3 of 3 STS Unit:

Description:

Classification:

Number of Measurements Taken in STS Unit--- Corresponding Areal Coverage based on FOV (1)---------- %

Maximum SOF Observed (5)--------------------- Mean of Total Activity Results (6)------------------------ pCi/m2

Calculation of Mean Activity and Dose Mean Activity per (7) Total Mean Activity (8) Basement Dose (9) Mean Dose per (10) Total Mean Dose (11) Mean Inventory ROC ROC per ROC Factors ROC for STS Unit Fraction for STS (12)

(pCi/m2) (mCi) (mrem/yr per mCi) (mrem/yr) (mrem/yr) Unit I I I I I I I Co-60 Cs-137 Ni-63

I I I I I I I Sr-90

(1) The Maximum SOF value observed in the SOF column from the Preliminary Data Summary.

(2) The average of the Total Activity column from the Preliminary Data Summary.

(3) The average of the Activity per ROC column from the Preliminary Data Summary.

(4) The Mean Activity per ROC converted to units of mCi/m2 multiplied by the area of the STS unit.

(5) From Attachment 3.

(6) The Total Mean Activity per ROC multiplied by the Basement Dose Factors.

(7) The sum of the Mean Dose per ROC.

(8) The Total Mean Dose for STS unit divided by 25 mrem/yr. See section 4.1.7.

Prepared by (FRS Supervisor): (Print Name) (Signature) (Date)

Page 42 of 56 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 13 SIGN STATISTICAL TEST Survey Area: No.

Description:

Survey Unit: No.

Description:

Classification: Type I ()Error: Number of Samples (n):

Fraction of the Release Criterion

  1. Radionuclides of Concern Activity or Weighted 1 -W s Sign SOF Sum (Ws)

Cs -137 ______ ______ ______ ______ ______ (as applicable)

1 2

3 4

5 6

7 8

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

Critical Value (Table I.3 of MARSSIM) = Number of Positive Differences (S+) =

The survey unit (meets) (does not meet) the acceptance criteria

Prepared by ( FRS

Supervisor ):

(Print Name) (Signature) (Date)

Reviewed by RP FRS Manager :

(Print Name) (Signature) (Date)

Page 43 of 56 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 14 FINAL RADIATION SURVEY INVESTIGATION Page 1 of 8 Survey Area: No.

Description:

Classification:

Survey Unit: No.

Description:

Performed by: Date: Time:

1. Reason for Investigation FSS Sample(s) with Result(s) > Investigation Levels Scan Measurement(s) > Investigation Levels STS Measurement(s) with Results(s) > Investigation Levels Failure of Statistical Test Other
2. Identified Elevated Sample(s)

Location Radionuclides-of-Concern Sample ID Cs-137 _________ _________ _________ _________ _________

Northing Easting ________ Fraction ________ Fraction ________ Fraction ________ Fraction ________ Fraction ________ Fraction

Page 44 of 56 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 14 FINAL RADIATION SURVEY INVESTIGATION Page 2 of 8

3. Bounding of Identified Elevated Area(s)
a. Is the elevated area(s) adequately verified and bounded by the existing samples? Yes No
1) If Yes, then proceed to step Q If No, then prepare an addendum to the FRS Sample Plan for this survey unit to take additional samples as necessary to adeq tely rify and bound the identified aaEsFected eted acvity.

Bounding Sample(s)

Location Radionuclides -of -Concern Sample ID Cs -137 _________ _________ _________ _________ _________

I I I I I I I I I I I I I I I I Northing Easting ________ Fraction ________ Fraction ________ Fraction ________ Fraction ________ Fraction ________ Fraction

Page 45 of 56 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 14 FINAL RADIATION SURVEY INVESTIGATION Page 3 of 8

4. Elevated Measurement Comparison
a. If the survey unit is an STS unit or classified as FSS Class 2 or Class 3, then proceed to step 5.
b. In each elevated area, denote the DCGL w pertinent to the location where the elevated sample is located.
c. Calculate an area in square meters for the identified elevated area(s) and select the appropriate Area Factor from Attachment 6 that corresponds to the area and to the radionuclide with the elevated activity.

Elevated Area #1 Area Size: m 2

Cs - 137 _________ _________ _________ _________ _________

I I I I I I

DCGL w Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

I I I I I I I I Area Factor

2 Elevated Area #2 Area Size: m

Cs - 137 _________ _________ _________ _________ _________

I I I I I I

DCGL w Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

I I I I I I I I Area Factor

2 Elevated Area #3 Area Size: m

Cs - 137 _________ _________ _________ _________ _________

I I I I I I

DCGL w Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

I I I I I I I I Area Factor

Page 46 of 56 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 14 FINAL RADIATION SURVEY INVESTIGATION Page 4 of 8

d. Calculate a DCGL EMC for each applicable radionuclide by multiplying the DCGL w for the elevated measurement(s) or sample(s) by the Area Factor.

Elevated Area #1

Cs -137 _________ _________ _________ _________ _________

DCGL EMC Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

Elevated Area #2

Cs -137 _________ _________ _________ _________ _________

DCGL EMC Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

Elevated Area #3

Cs -137 _________ _________ _________ _________ _________

DCGL EMC Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

e. Calculate the Average Radioactivity Fraction for the survey unit as follows; Note: The Average Radioactivity Fraction is calculated using only sample results from the systematic sample population that are located outside of any identified elevated area.

Cs -137 _________ _________ _________ _________ _________

Avg. Concentration of Radionuclide (j) Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

DCGL w Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

Average Fraction of DCGL ( fj)

1) Sum the Fraction of DCGL (fj) values for each pertinent radionuclide to derive the Aveadioacvityrac favg) =

Page 47 of 56 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 14 FINAL RADIATION SURVEY INVESTIGATION Page 5 of 8

f. Calculate an Elevated Radioactivity Fraction ( fEMC) for each identified elevated area as follows;
1) Determine the average concentration (j) for each radionuclide in each identified elevated area.
2) Subtract the Average Concentration of Radionuclide (j) for each radionuclide from step 4e from the avera ge radionuclide concentration (j) in the elevated area and divide this value by the DCGL EMC from step 4d to derive a Fraction of DCGL EMC (felev) for each radionuclide.
3) Sum the Fraction of DCGL EMC (felev) values for each pertinent radionuclide to derive the Elevated Radioactivity Fraction ( fEMC) for the elevated area.

Elevated Area #1

Cs -137 _________ _________ _________ _________ _________

Avg. Concentration of Elevated Area (j) Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

Avg. Concentration of Radionuclide (j) Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

(j - j) = Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

DCGL EMC

Fraction of DCGL EMC (felev)

Elevated Radioactivity Fraction ( fEMC) for Elevated Area #1

Elevated Area #2

Cs-137 _________ _________ _________ _________ _________

Avg. Concentration of Elevated Area (j) Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g Average Concentration of Survey Unit (j) Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g (j - j) = Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g DCGLEMC Fraction of DCGLEMC (felev)

Elevated Radioactivity Fraction (fEMC) for Elevated Area #2 Page 48 of 56 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 14 FINAL RADIATION SURVEY INVESTIGATION Page 6 of 8 Elevated Area #3

Cs -137 _________ _________ _________ _________ _________

Avg. Concentration of Elevated Area (j) Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

Average Concentration of Survey Unit (j) Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

(j - j) = Ci/g Ci/g Ci/g Ci/g Ci/g Ci/g

DCGL EMC

Fraction of DCGL EMC (felev)

Elevated Radioactivity Fraction ( fEMC) for Elevated Area #3

g. Sum the Elevated Radioactivity Fractions ( fEMC) for each elevated area.
h. Add the Average Radioactivity Fraction ( favg) from step 4e to the summed Elevated Radioactivity Fractions (fEMC). This value represents the EMC SOF for this survey unit.
i. If the SOF is less than or equal to unity (1), then the survey unit will pass the EMC. If the SOF is greater than unity (1), then the need for additional remediation is likely.
5. Investigation Conclusions
a. STS Unit
1) Did the survey unit fail the statistical test or, was determined in step 5.4.6 that the SOF for an individual measurement exceeds the STS Investigation Levels (Attachment 7) or, the Total Mean Dose exceeds 25 mrem/yr or, the sum of the Mean Yes No Inventory Fractions for all STS units in a basement exceeds one?

(If Yes, then initiate Attachment 16, Corrective Actions for Final Radiation Survey Failure. If No, then the investigation is complete and no further action is required.)

b. FSS Class 3 Survey Unit
1) Is the concentration for any radionuclide reported in any systematic, biased or investigative sample taken in the survey unit equal to or greater than 50% of its respective DCGLw? Yes No Page 49 of 56 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 14 FINAL RADIATION SURVEY INVESTIGATION Page 7 of 8 (If Yes, then initiate Attachment Corrective Actions for Final Radiation Survey Failure. If No, then the investigation is cend no fuacquireF FSS Class 2 Survey Unit
1) Is the concentration for any radionuclide reported in any systematic, biased or investigative sample taken in the survey unit equal to or greater than its respective DCGL w?

Yes No

(If Yes, then initiate Attachment 16, Corrective Actions for Final Radiation Survey Failure. If No, then the investigation is cend no fuacquireF FSS Class 1 Survey Unit

1) Is the concentration for any radionuclide reported in any systematic, biased or investigative sample taken in the survey unit equal to or greater than its respective DCGL w?

Yes No

(If Yes, then proceed to next step. If No, then the investigation is complete and no further action is req d.F Is the EMC SOF for this survey unit greater than unity (1)? Yes No (If Yes, then initiate Attachment 16, Corrective Actions for Final Radiation Survey Failure. If No, then stiga cend no fuacquireF

Comments;

Page 50 of 56 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 14 FINAL RADIATION SURVEY INVESTIGATION Page 8 of 8

6. Comments (continued);
7. Approval Prepared by ( FRS Supervisor ):

(Print Name) (Signature) (Date)

Reviewed by RP FRS Manager :

(Print Name) (Signature) (Date)

Page 51 of 56 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0

ATTACHMENT 15 CORRECTIVE ACTIONS FOR FINAL RADIATION SURVEY FAILURE Survey Area: No.

Description:

Survey Unit: No.

Description:

Classification:

Performed by: Date: Time:

Resurvey, Reclassification or Remediation Based upon the failure of the statistical test or the results of an investigation, the following action(s) are required.

Note: Use the guidance provided in Attachment 9 for determination of appropriate action(s).

Resurvey Action(s) Required

Reclassify Action(s) Required

Remediate Action(s) Required

Approval Prepared by (FRS Supervisor):

(Print Name) (Signature) (Date)

Approved by:

(RP/FRS Manager) (Signature) (Date)

Page 52 of 55 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 16 STS SURVEY PLAN CLOSEOUT Page 1 of 2

STS Sample Plan #: Survey Unit #:

Survey Unit Location/Description:

The following documentation is included in the STS Sample Plan

DESCRIPTION TOTAL COMMENTS LC-FS-PR-002 Attachment 10, FRS Sample Plan Cover Sheet LC-FS-PR-010 Attachment 1, Area Turnover and Control Checklist LC-FS-PR-010 Attachment 2, Pre-Turnover Walk-Down LC-FS-PR-006 Attachment 1, Survey Unit Classification Basis Summary LC-FS-PR-006 Attachment 2, Survey Unit Classification Worksheet LC-FS-PR-002 Attachment 11, FRS Data Quality Objectives and Survey Design LC-FS-PR-002 Attachment 12, FRS Survey Instructions LC-FS-PR-002 Attachment 13, Field Log.

LC-FS-PR-002 ATTACHMENT 14, Sample/Measurement Identification and Coordinates.

LC-FS-PR-002 Attachment 15, Scan Area Identification and Coordinates.

Photographs, maps, and/or drawings of the survey unit.

FRS field measurement and analytical results.

LC-FS-PR-008 Attachment 10, Final Radiation Survey Data Quality Objective Review Checklist LC-FS-PR-008 Attachment 12, STS Preliminary Survey Data Summary LC-FS-PR-008 Attachment 13, Sign Statistical Test Other : ____________________________________

Page 53 of 55 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 16 STS SURVEY PLAN CLOSEOUT Page 2 of 2

Sign Test/ - STATISTICAL VALUES

The Survey Unit data results are Accepted The Survey Unit data results are Rejected

Reason:_______________________________________

SURVEY UNIT REMEDIATION No remediation required.

Perform additional investigation surveys.

For survey units containing residual radioactivity above the DCGL, recommend remediation.

If a Class 2 survey unit has a verified individual survey measurement (scan or direct) that exceeds the DCGL, consider reclassification of the survey unit or a portion of the survey unit.

If a Class 3 survey unit has an individual survey measurement (scan or direct) that exceeds 0.5 DCGL, recommend reclassification of the survey unit or a portion of the survey unit as a Class 2.

Other (Specify):

Surveys have been completed and data has been evaluated. All forms are legible and complete. The survey unit has been properly classified and survey unit remediation prescribed.

Date:

Prepared by:

(Print/Sign) FRS Supervisor

Date:

Reviewed and Approved by:

(Print/Sign) RP FRS Manager

Page 54 of 55 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 17 FSS SURVEY PLAN CLOSEOUT Page 1 of 2

FRS Sample Plan #: Survey Unit #:

Survey Unit Location/Description:

The following documentation is included in the FRS Sample Plan

DESCRIPTION TOTAL COMMENTS LC-FS-PR-002 Attachment 11, FRS Sample Plan Cover Sheet LC-FS-PR-002 Attachment 1, Area Turnover and Control Checklist LC-FS-PR-010 Attachment 2, Pre-Turnover Walk-Down LC-FS-PR-006 Attachment 1, Survey Unit Classification Basis Summary LC-FS-PR-006 Attachment 2, Survey Unit Classification Worksheet LC-FS-PR-002 Attachment 11, FRS Data Quality Objectives and Survey Design LC-FS-PR-002 Attachment 12, FRS FRS Survey Instructions LC-FS-PR-002 Attachment 13, Field Log.

LC-FS-PR-002 ATTACHMENT 14, Sample/Measurement Identification and Coordinates.

LC-FS-PR-002 Attachment 15, Scan Area Identification and Coordinates.

Photographs, maps, and/or drawings of the survey unit.

FRS field measurement and analytical results.

LC-FS-PR-008 Attachment 10, Final Radiation Survey Data Quality Objective Review Checklist LC-FS-PR-008 Attachment 11, FSS Preliminary Survey Data Summary LC-FS-PR-008 Attachment 13, Sign Statistical Test Other : ____________________________________

Page 55 of 55 LC-FS-PR-008 Final Radiation Survey Data Assessment Revision 0 ATTACHMENT 17 FSS SURVEY PLAN CLOSEOUT Page 2 of 2

Sign Test - STATISTICAL VALUES

The Survey Unit data results are Accepted The Survey Unit data results are Rejected

Reason:_________________________________________

SURVEY UNIT REMEDIATION No remediation required.

Perform additional investigation surveys.

For survey units containing residual radioactivity above the DCGL, recommend remediation.

If a Class 2 survey unit has a verified individual survey measurement (scan or direct) that exceeds the DCGL, consider reclassification of the survey unit or a portion of the survey unit.

If a Class 3 survey unit has an individual survey measurement (scan or direct) that exceeds 0.5 DCGL, recommend reclassification of the survey unit or a portion of the survey unit as a Class 2.

Other (Specify):

Surveys have been completed and data has been evaluated. All forms are legible and complete. The survey unit has been properly classified and survey unit remediation prescribed.

Date:

Prepared by:

(Print/Sign) FRS Supervisor

Reviewed and Approved by: Date:

(Print/Sign) RP FRS Manager

Page 56 of 55

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