ML23023A144

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LC-FS-PR-015, Revision 2, Final Status Survey for Structures
ML23023A144
Person / Time
Site: La Crosse  File:Dairyland Power Cooperative icon.png
Issue date: 01/23/2019
From: Bishop W
LaCrosseSolutions
To:
Office of Nuclear Material Safety and Safeguards
M. Doell,NMSS/DDUWP
Shared Package
ML23023A141 List:
References
LC-FS-PR-015, Rev 2
Download: ML23023A144 (1)
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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 Summary of Changes in this Revision:

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

TABLE OF CONTENTS

1. PURPOSE AND SCOPE.................................................................................. 5 1.1. Purpose.............................................................................................................. 5 1.2. Scope................................................................................................................. 5
2. REFERENCES................................................................................................. 5 2.1. LaCrosse Station Restoration Project (LCSRP) License Termination Plan..... 5 2.2. Nuclear Regulatory Commission (NRC), Title 10, Part 20, Subpart E, Radiological Criteria for License Termination................................................. 5 2.3. NUREG-1757, Volume 2, Revision 1, Consolidated Decommissioning Guidance - Characterization, Survey, and Determination of Radiological Criteria, Volume 2, Revision 1, September 2002............................................. 5 2.4. NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), August 2000............................................................................... 5 2.5. LC-AD-PR-003, Records Management Program............................................. 6 2.6. LC-FS-PR-008, Final Status Survey Data Assessment.................................... 6 2.7. LC-FS-PR-009, Final Status Survey Reporting................................................ 6 2.8. LC-QA-PN-001, Final Status Survey QAPP.................................................... 6 2.9. LaCrosseSolutions RS-TD-313196-003, LaCrosse Boiling Water Reactor Historical Site Assessment................................................................................ 6 2.10. LC-AD-PR-003, Records Management Program............................................. 6 2.11. LC-FS-PR-006, Survey Unit Classification...................................................... 6 2.12. LC-FS-PR-008, Final Status Survey Data Assessment.................................... 6 2.13. LC-FS-PR-010, Isolation and Control for Final Status Survey........................ 6 2.14. LC-FS-TSD-002, Operational Derived Concentration Guideline Levels for Final Status Survey........................................................................................... 6 2.15. LaCrosseSolutions RS-TD-313196-003, LaCrosse Boiling Water Reactor Historical Site Assessment................................................................................ 6 2.16. LaCrosseSolutions RS-TD-313196-001, Radionuclides of Concern During LACBWR Decommissioning........................................................................... 6 2.17. International Standards Organization (ISO) 7503-1, Evaluation of surface contamination - Part 1: Beta-emitters (maximum beta energy greater than 0.15 MeV) and alpha-emitters.......................................................................... 6
3. GENERAL........................................................................................................ 6 3.1. Responsibilities................................................................................................. 6 3.2. Definitions......................................................................................................... 7 3.3. Acronyms........................................................................................................ 10

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 3.4. Precautions, Limitations and Prerequisites..................................................... 11 3.5. Records........................................................................................................... 13

4. PROCEDURE................................................................................................. 13 4.1. FSS Package Numbering................................................................................ 13 4.2. FSS Survey Package Development................................................................. 13 4.3. FSS Data Quality Objectives and Survey Design........................................... 15 4.4. Survey Package Instructions........................................................................... 24 4.5. FSS Survey Package and Cover Sheet Approval............................................ 26 4.6. Survey Implementation................................................................................... 26 4.7. FSS Data Assessment and Survey Unit Closure............................................. 27
5. ATTACHMENTS........................................................................................... 28 5.1. Attachment 1, Base Case and Operational Above Grade Building DCGLs... 28 5.2. Attachment 2, Dose Significant Radionuclides and Relative Ratios.............. 28 5.3. Attachment 3, FSS Recommended Scan Survey Coverage............................ 28 5.4. Attachment 4, FSS Scan and Static Survey Investigation Levels................... 28 5.5. Attachment 5, Sample and Measurement Unique Identification Designation 28 5.6. Attachment 6, Calculation of Static and Scan MDC...................................... 28 5.7. Attachment 7, Number of Samples Required for Sign Test........................... 28 5.8. Attachment 8, Typical FSS Survey Instrumentation...................................... 28 5.9. Attachment 9, Typical FSS Instrument Sensitivities...................................... 28 5.10. Attachment 10, FSS Survey Cover Sheet....................................................... 28 5.11. Attachment 11, FSS Data Quality Objectives and Survey Design................. 28 5.12. Attachment 12, FSS Survey Instructions........................................................ 28 5.13. Attachment 13. FSS Field Log........................................................................ 28 5.14. Attachment 14. FSS Static Measurement Identification and Location........... 28 5.15. Attachment 15. FSS Scan Area Identification and Location.......................... 28

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

1. PURPOSE AND SCOPE

1.1. Purpose

This procedure provides instructions for the planning and implementation of final status surveys (FSS) that will be performed on structural surfaces in buildings at the LaCrosse Station Restoration Project (LCSRP), to demonstrate compliance with dose-based unrestricted release criteria. This procedure includes guidance for development of survey methods and for performing FSS activities that will meet applicable Nuclear Regulatory Commission (NRC) guidance and will be in accordance with requirements in the LaCrosse Station Restoration Project License Termination Plan (Reference 2.1). The FSS for structures includes scan surveys and static measurements on surfaces to demonstrate that residual radionuclide concentrations are equal to or less than the Derived Concentration Guideline Levels (DCGLs). The DCGLs are commensurate with the dose criterion of 25 mrem/year total effective dose equivalent (TEDE) in NRC Title 10, Code of Federal Regulations (CFR), Part 20, Subpart E, Radiological Criteria for License Termination (specifically 20.1402) (Reference 2.2).

1.2. Scope

This procedure implements the requirements of applicable NRC regulations and guidance documents; specifically, 10 CFR 20, Subpart E (Reference 2.2); NUREG-1757, Volume 2, Revision 1, Consolidated Decommissioning Guidance - Characterization, Survey, and Determination of Radiological Criteria (Reference 2.3); NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (Reference 2.4); and Chapter 5 of LaCrosse Station Restoration Project License Termination Plan (LCSRP LTP) (Reference 2.1).

This procedure applies to all personnel planning FSS surveys and personnel performing FSS field survey activities.

2. REFERENCES

2.1. LaCrosse Station Restoration Project (LCSRP) License Termination Plan

2.2. Nuclear Regulatory Commission (NRC), Title 10, Part 20, Subpart E, Radiological Criteria for License Termination

2.3. NUREG-1757, Volume 2, Revision 1, Consolidated Decommissioning Guidance -

Characterization, Survey, and Determination of Radiological Criteria, Volume 2, Revision 1, September 2002

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

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 2.5. LC-AD-PR-003, Records Management Program

2.6. LC-FS-PR-008, Final Status Survey Data Assessment

2.7. LC-FS-PR-009, Final Status Survey Reporting

2.8. LC-QA-PN-001, Final Status Survey QAPP

2.9. LaCrosseSolutions RS-TD-313196-003, LaCrosse Boiling Water Reactor Historical Site Assessment

2.10. LC-AD-PR-003, Records Management Program

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

2.12. LC-FS-PR-008, Final Status Survey Data Assessment

2.13. LC-FS-PR-010, Isolation and Control for Final Status Survey

2.14. LC-FS-TSD-002, Operational Derived Concentration Guideline Levels for Final Status Survey

2.15. LaCrosseSolutions RS-TD-313196-003, LaCrosse Boiling Water Reactor Historical Site Assessment

2.16. LaCrosseSolutions RS-TD-313196-001, Radionuclides of Concern During LACBWR Decommissioning

2.17. International Standards Organization (ISO) 7503-1, Evaluation of surface contamination - Part 1: Beta-emitters (maximum beta energy greater than 0.15 MeV) and alpha-emitters

3. GENERAL

3.1. Responsibilities

3.1.1 FSS Manager - is responsible for:

1.) Providing guidance and support for the development of FSS plans and performance of FSS surveys.

2.) Reviewing and approving all FSS plans/packages and reviewing FSS survey data.

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 3.1.2 FSS Supervisor - is responsible for:

1.) Preparing FSS plans and survey packages.

2.) Ensuring FSS surveys are conducted in accordance with approved survey packages, procedures, and work instructions.

3.) Providing technical direction and guidance to field survey activities.

4.) Controlling and implementing FSS plan instructions during field activities.

5.) Survey Unit preparation, isolation, turnover and prerequisites (e.g., reference grid layout, identification of working constraints, hazards and accessibility needs).

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

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

3.1.3 Graphics/GPS Specialist - is responsible for:

1.) Preparing survey maps, layout diagrams and other graphics needed to support survey design and reporting.

2.) Interacting with the FSS Supervisor regarding the preparation of maps, diagrams and other graphics which present survey units or measurement locations.

3.1.4 FSS Technicians - are responsible for:

1.) Obtaining and documenting survey measurements in accordance with the survey package instructions.

2.) Ensuring that all activities, actions, observations and obstructions that are encountered during the performance of characterization are documented in Attachment 13, FSS Field Log for each survey unit.

3.2. Definitions

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 3.2.1 Biased Measurements - Measurements performed at locations selected using professional judgment based on unusual appearance, location relative to known contamination areas, increased potential for residual radioactivity, general supplemental information, etc. Biased measurements are not included in the statistical evaluation of the survey unit data because they violate the assumption of randomly selected, independent measurements. Instead, biased (also known as judgmental) measurements are individually compared to the DCGLW.

3.2.2 Data Quality Assessment (DQA) - The scientific and statistical evaluation of data to determine if the data are of the right type, quantity and quality for the intended use.

3.2.3 Data Quality Objectives (DQO) - Qualitative and quantitative statements derived from the DQO process that clarify technical and quality objectives, define the appropriate type of data, and specify tolerable levels of potential decision errors that will be used as the basis for establishing the quality and quantity of data needed to support FSS decisions.

3.2.4 Derived Concentration Guideline Level (DCGL) - A radionuclide-specific activity concentration corresponding to a dose-based release criterion.

DCGLs are derived from activity/dose relationships based on various exposure pathway scenarios. DCGLs are derived differently for the nonparametric statistical test (DCGLW) and for the Elevated Measurement Comparison (DCGLEMC). The DCGLW is based on the average concentration over a large area. The DCGLEMC is derived separately for small areas of elevated activity, and is not used for Class 2 and 3 survey units.

3.2.5 Final Status Survey (FSS) - final surveys conducted to demonstrate that residual radionuclide concentrations are less than or equal to the appropriate DCGLs.

3.2.6 Gray Region - A range of values of the parameter of interest for a survey unit where the consequences of making a decision error are relatively minor. The upper bound of the gray region in MARSSIM is set equal to the DCGLW and the Lower Bound of the Gray Region (LBGR) is usually a site-specific variable.

3.2.7 Historical Site Assessment (HSA) - A compilation of information prepared for use in planning the FSS of a survey unit or structure. It summarizes the operational history, remedial actions, operational survey data and other information, such as past burials, releases, spill events and other unusual occurrences, to help establish the final survey unit classification and the bases for the design of the FSS.

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 3.2.8 Investigation Level - A level of radioactivity based on the survey unit classification and the DCGLW which, if exceeded, initiates an investigation of the survey measurement location. An investigation may include taking additional measurements to verify the activity and/or to define the elevated area, verifying proper instrument operation or performing remedial actions. If radioactivity above the investigation level is confirmed or if remedial actions are required, the elevated area or the entire survey unit must be reclassified to at least the next highest classification and resurveyed.

3.2.9 Measurement - For the purpose of MARSSIM, measurement is used interchangeably to mean: 1) the act of using a detector to determine the level or quantity of radioactivity on a surface or 2) the quantity obtained by the act of measuring.

3.2.10 Minimum Detectable Concentration (MDC) - The minimum detectable concentration is 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 concentration.

3.2.11 Nonparametric Statistical Test - A test based on relatively few assumptions about the exact form of the underlying probability distributions of the measurements. As a consequence, nonparametric statistical tests are generally valid for a fairly broad class of distributions. The Sign test is an example of a nonparametric statistical test.

3.2.12 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.

3.2.13 Survey Area - Survey areas are established based on logical physical boundaries and site landmarks for the purpose of documenting and conveying radiological information, and in order to facilitate the scheduling, management and reporting of FSS data. Survey areas are often sub-divided into one or more survey units to meet the size requirements specified by MARSSIM.

3.2.14 Survey Package -A written document that contains detailed survey requirements, including a description of the area to be surveyed, the types of surveys, locations of surveys, types of instruments, investigation levels and the minimum data required for a survey unit. Survey packages are prepared for each survey unit.

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 3.2.15 Survey Unit - A defined area consisting of structures of a specified size for which a separate decision will be made to judge whether the area meets the criteria for unrestricted release. Survey units are generally formed by grouping contiguous areas with a similar use history and the same potential for residual contamination to be present. Survey units are established to facilitate the survey process and the statistical analysis of survey data. The survey unit is the fundamental unit of compliance. Each survey unit will meet, or fail to meet, the release criteria independently of all the other survey units.

3.2.16 Type I Error () - A decision error that occurs when the null hypothesis is rejected, when it is actually true for the scenario considered. This would result in incorrectly releasing an area that does not meet the release criteria.

3.2.17 Type II Error () - A decision error that occurs when the null hypothesis is not rejected, when it is actually false for the scenario considered. This would result in failing to release an area that meets the release criteria.

3.2.18 Unity Rule - A rule applied when more than one radionuclide is present at a concentration distinguishable from background and where a single concentration comparison does not apply. In practice, the combination of measurement results for each singular radionuclide present in the distribution may be compared to the release criteria by applying the unity rule. This is accomplished by determining the fraction of the DCGL for each radionuclide.

The fraction is the ratio of the concentration of a radionuclide to the DCGL for that radionuclide. To demonstrate compliance for a survey unit, the sum-of-fractions (SOF) for all radionuclides in the mixture cannot exceed 1.

3.3. Acronyms

Type I Error Probability Type II Error Probability Standard Deviation (sigma)

CFR Code of Federal Regulations DCGL Derived Concentration Guideline Level DQA Data Quality Assessment DQO Data Quality Objectives FSS Final Status Survey HSA Historical Site Assessment LCSRP LaCrosse Station Restoration Project LBGR Lower Bound of the Gray Region LTP License Termination Plan

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MDC Minimum Detectable Concentration N number of systematic measurement locations (Sign test)

NRC United States Nuclear Regulatory Commission QA Quality Assurance QC Quality Control RASS Remedial Action Support Survey ROC Radionuclides of Concern RWP Radiation Work Permit SOF Sum-of-Fractions TSD Technical Support Document VSP Visual Sample Plan 3.4. Precautions, Limitations and Prerequisites

3.4.1 Precautions

1) Documents and databases containing FSS survey data and survey records are Quality Assurance (QA) records when complete. Positive control of these records shall be maintained until they are forwarded to the Records Management organization in accordance with LC-AD-PR-001, Records Management Program (Reference 2.5).
2) When documenting survey information, ensure that all records are of good quality and legible. Legible means a document is readable and reproducible.
3) For this FSS survey design, the contaminants are not present in background or they constitute a small fraction of the DCGLw. Therefore, the Sign Test will be used for FSS data analysis.
4) Smear samples are not taken during the FSS of buildings. The DCGLs for above grade structures are for total activity, with no DCGL for removable activity.

3.4.2 Limitations

1) All attachments described in this procedure may be generated electronically. If electronic attachments are used, the physical layout of the attachment may be modified provided the information required and the intent described in this procedure is not changed.
2) The output of the design process is a survey package. A survey package is prepared for each survey unit independently.

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

3) Radiation detection and measurement instrumentation will be selected based on the type and quantity of radiation to be measured. The target MDC for measurements obtained using field instruments is 50 percent of the applicable DCGLw.
4) The target MDC for static measurements obtained using field instruments is 50% of the applicable DCGLW.
5) The MDC for scan surveys should not exceed the DCGLW.
6) Measurements with an MDC that exceeds the target MDC value may be accepted as valid data, if approved by the RP FSS Manager.
7) After completion of the FSS in a survey unit, the survey package is reviewed for completeness and the FSS data is validated in accordance with LC-FS-PR-008, Final Status Survey Data Assessment (Reference 2.6) before survey unit closure and the reporting of results.
8) Upon closure of each survey package, a release record will be prepared for each survey unit in accordance with LC-FS-PR-009, Final Status Survey Reporting (Reference 2.7).
9) If a selected measurement location is found to be either inaccessible or unsuitable, the location will be moved to the closest adjacent suitable location.

In these cases, a notation will be made in Attachment 13, FSS Field Log and the coordinates of the new location will be documented.

3.4.3 Prerequisites

1) A FSS survey package will be prepared for each survey unit. A folder designated for the FSS survey package should be used to keep original documents. The folder shall be controlled in accordance with the record quality requirements of LC-QA-PN-001, Final Status Survey QAPP (Reference 2.8).
2) The impacted structures at LCSRP that will remain after D&D activities have been completed are divided into Class 2 or Class 3 survey units. The initial classifications and initial survey unit boundaries are given in RS-TD-313196-003, LaCrosse Boiling Water Reactor Historical Site Assessment (HSA), and (Reference 2.9). Actual building (structure) survey unit boundaries may vary from the conceptual survey unit boundaries presented in the HSA, based on actual conditions at the time of survey design, as long as the classification does not change.
3) The survey units will be comprised of the total surfaces of each impacted building that will remain at the site.
4) The size of a Class 2 structural survey unit where compliance will be determined by FSS will not exceed 1,000 m2 without approval of the FSS Manager. Although no Class 1 structural survey units have been identified for above grade structures, if conditions warrant the establishment of a Class 1 2 survey unit, the size should not exceed 100 m. Class 3 survey units have no maximum size.

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

5) Final classification of a structural survey unit subjected to FSS should be validated in accordance with LC-FS-PR-006, Survey Unit Classification (Reference 2.10).
6) A survey unit must be reclassified if at any time in the planning phase, survey phase or data evaluation phase, it is determined the criteria for the current classification are no longer satisfied.
7) Prior to issuance of a specific Survey Package for performance of FSS, isolation and control measures shall be established in accordance with LC-FS-PR-010, Isolation and Control for Final Status Survey (Reference 2.11).
8) Survey units should be cleared of all loose equipment and materials to the maximum extent possible.
9) All identified physical hazards in the survey unit shall be either removed, marked as appropriate.
10) Prior to performing FSS, a reference grid system will be established.
11) Systematic measurement locations within survey units will be clearly identified and documented for the purposes of reproducibility. Actual measurement locations will be marked and identified by tags, labels, markings, photographic record, or equivalent.
12) Prior to using any survey instrument, the current calibration will be verified.

Response checks will be performed daily before instrument use and again at the end of each use.

3.5. Records

3.5.1 Survey Packages, typically consisting of the items listed in 4.2.3.

3.5.2 Instrument Records (e.g., calibration records, background data, daily response checks, etc.)

4. PROCEDURE

NOTES The Survey Area Number, Survey Unit Number and current classification are taken from the updated master copy of Survey Units for Structures that is maintained by the FSS Manager in accordance with procedure LC-FS-PR-006, Survey Unit Classification.

4.1. FSS Package Numbering

4.1.1 Prepare a Survey Package for each Survey Unit. FSS Packages will be designated with an alpha-numeric code as shown in Attachment 5, Sample

& Measurement Unique Identification Designation.

4.2. FSS Survey Package Development

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 4.2.1 Prepare a FSS Survey Package for each survey unit independently

4.2.2 Validate the final classification of structural survey units subjected to FSS in accordance with LC-FS-PR-006, Survey Unit Classification (Reference 2.10).

NOTE The FSS Supervisor tasked with the development of multiple FSS Survey Packages must be aware that it is possible that duplicate survey/measurement numbers may be generated when using the guidance for designating unique survey identification numbers in Attachment 5, Sample & Measurement Unique Identification Designation. Therefore, the responsible FSS pupe must beao ensure that this does not occ.

Q.O.P A FSS Survey Package will usually contain the items listed below.

1.) Attachment 10, FSS Survey Package Cover Sheet

2.) Area Turnover and Control Checklist from LC-FS-PR-010, Isolation and Control for Final Status Survey.

3.) Pre-Turnover Walk-Down form contained in LC-FS-PR-010, Isolation and Control for Final Status Survey.

4.) Survey Unit Classification Basis Summary from LC-FS-PR-006, Survey Unit Classification.

5.) Survey Unit Classification Worksheet from LC-FS-PR-006, Survey Unit Classification.

6.) Attachment 11, FSS Data Quality Objectives and Survey Design.

7.) Attachment 12, FSS Survey Instructions.

8.) Attachment 13, FSS Field Log.

9.) Attachment 14, FSS Static Measurement Identification and Location.

10.) Attachment 15, FSS Scan Area Identification and Location.

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

12.) FSS field measurement and analytical results.

4.2.4 Include any relevant information for the survey unit, (i.e., floor plans, blue prints, photographs, computer generated or hand drawn survey maps) in the FSS Survey Package.

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 4.2.5 Provide a unique survey identification number for all static measurements in accordance with Attachment 14, FSS Static Measurement Identification and Location.

4.2.6 Select the appropriate radiation survey instrumentation based on the type and quantity of radiation to be measured. The target MDC for static measurements obtained using field instruments is 50 percent of the applicable DCGLw and the MDC for scan surveys should not exceed the DCGLw.

4.3. FSS Data Quality Objectives and Survey Design

4.3.1 Initiate Attachment 11, FSS Data Quality Objectives and Survey Design for the survey unit.

4.3.2 State the Problem - commence the survey design through the DQO process by providing a clear description of the problem and a conceptual model of the hazard to be investigated.

1.) Clearly state the problem (whether the survey unit meets a specified radiological release criterion).

2.) Identify the stakeholders.

3.) Identify the planning team and decision maker(s).

4.) Specify the anticipated schedule for the activity.

5.) Identify the resources and support that will be required to successfully complete the activity.

4.3.3 Identify the Decision - develop objectives for the FSS, or if applicable, several objectives, based on the stated problem.

1.) State the principal study question.

NOTE The principal study question for the FSS might be, Does the residual dioac cn the surynitxceed the rea criteria? Alternative actions may include investiga Jey remediation and/or reclassification. The stated decision may be, If any of the meaaesxceed the relea criteriathe ane evaluate the alternative action or combination of actions.

O.F List any alternative actions.

3.) Clearly state the decision.

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 4.3.4 Identify Inputs to the Decision - Identify the types and quantity of radiological data that will be necessary to address the objectives identified in the previous step.

1.) State the information needed.

A. Identify the survey media (e.g., concrete, cinder block, metal, wood).

B. Identify the types of measurements (e.g., scans and static measurements).

C. Identify sources of information that will be used (e.g., HSA, previous survey data, inspections of survey units).

2.) Summarize any relevant historical information for the survey unit using the following guidance:

A. Summarize the function of the area containing the survey unit during facility operation.

B. Summarize the current radiological condition of the survey unit using all available past and present radiological surveys data (e.g., scoping surveys, routine surveys) that is pertinent to the survey unit.

3.) List the Radionuclides-of-Concern (ROC) and the basis for being included.

NOTE Attachment 1 presents the Base Case and Operational DCGLs for above grade buildings from LC-FS-TSD-002 (Reference 2.12). For multiple radionuclides in a survey unit, the unity rule applies.

4.) State the release criteria (DCGL) for each ROC applicable to the survey.

5.) Summarize the radiological survey data that will be used in FSS design for structural survey units.

A. Review the characterization and/or remedial action support survey (RASS) data to determine if adequate data is available to design the FSS.

B. Determine the basic statistical indicators in the survey data that will be used for the FSS design. At a minimum, the statistics should include the minimum, maximum, mean, median and the standard deviation of the data set.

C. For structural surface FSS, derive the Adjusted Gross DCGL that will be used for the FSS design (or, if desired, use the most limiting individual radionuclide DCGL from the mixture).

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

NOTE The radionuclide mixture for LCRSP is presented in Reference 2.12 and is reproduced in Attachment 2. The mixture is used to derive the ratios for the calculation of the Adjusted Gross DCGL for the FSS.

Perform a gross activity DCGL calculation for the beta emitting radionuclides determined to be present in significant fractions using the following equation:

= 1 1 2

[ + + ]

1 2 Where DCGLAG = Adjusted Gross DCGL in units of 2 dpm/100 cm DCGLi = Gross DCGL for detectable radionuclide 2 in units of dpm/100 cm (Attachment 1) fi = Mixture fraction of detectable radionuclides (Attachment 2)

D. Calculate a mean SOF for the survey data that will be used for the FSS design using the following equation:

= 1 + 2 +

1 2

Where Concn = mean concentration of radionuclide n and DCGLn = DCGL of radionuclide n E. Calculate a weighted Standard Deviation (SOF) for the survey data that will be used for the FSS design for the survey unit.

1 2 2 2 2

= [( ) + ( ) +( ) ]

1 2

Where n = standard deviation of radionuclide n and DCGLn = DCGL of radionuclide n

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

NOTE Characterization or RASS data with excessive variability is typically not representative of the radiological condition of the survey unit at the time of the FSS.

F. Assess the variability of the survey data that will be used for survey design. When preliminary data are not obtained, it may be reasonable to assume a coefficient of variation on the order of 30%, based on direction provided in MARSSIM.

G. If applicable, document in the Survey Package that Characterization and/or RASS data to be used for FSS design is satisfactory. If the data is not satisfactory, provide a technical justification to develop the Survey Package using process knowledge and/or historical information. Document the basis in the Survey Package or if needed, perform additional characterization surveys and repeat the planning process.

H. Describe the investigation levels, as well as the actions that will be taken if they are exceeded. The investigation level provides the criterion used during the decision process for choosing among alternative actions. Alternative actions may include taking additional measurements to verify the activity and/or to define the elevated area, verifying proper instrument operation, or performing remedial actions.

I. If radioactivity above the investigation level is confirmed or if remedial actions are required, the elevated area or the entire survey unit must be reclassified to at least the next highest classification and resurveyed according to the new classification.

J. Establish the scan coverage area needed for the Survey Package and the basis for the selection.

K. Establish a reference grid system for each survey unit and document the grid system on hand-drawn or computer generated maps that show the grid numbers and locations for floors and walls. For ceiling areas, grids may correspond to floor grid numbers. For example, a grid numbered F03 on the floor can be projected vertically onto the ceiling as grid C03.

L. Survey units will be scanned in accordance with their classification.

Scan coverage recommendations for each class of survey unit are presented in Attachment 3.

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 M. If less than 100% scan coverage is required, designate areas to be scanned using the reference grid system that equates to the required total area to be scanned, and document the basis for selecting those areas.

N. Designate scan locations and grid coordinates on Attachment 15 Scan Area Identification and Location and identify locations on survey maps.

O. If less than 100% scan coverage is required, then a 1-meter radius should be scanned around biased locations (if any), in addition to the area designated for scanning.

6.) Determine and document the type and frequency of Quality Control (QC) measurements using guidance in LC-QA-PN-001, Final Status Survey QAPP.

7.) Determine the investigation levels using Attachment 4 as guidance and document investigation levels in the Survey Package.

NOTE Static and Scan MDCs for scanning structures will be determined in accordance with the guidance provided in Attachment 6.

A. Designate the radiological instrumentation that will be used for field measurements and document that the static and scan MDCs are sufficient for the investigation levels.

4.3.5 Define Survey Unit Boundaries

1.) Generate a survey map or drawing for each survey unit, including the boundaries of the entire survey unit, and showing major physical features.

Ensure the graphic representation of the dimensions and boundaries correspond to the established reference grid system.

2.) Describe the boundaries, physical conditions, orientation and landmarks of the survey unit using the following guidance:

A. Describe the spatial boundaries of the survey unit, including length and width in meters.

B. Describe the different type surfaces present in the survey unit (e.g.

concrete, cinder block, brick, metal, wood, etc.).

C. Describe any physical landmarks or identifying features present.

3.) Describe the anticipated schedule for performing the FSS and any time constraints.

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 4.) Describe any practical constraints or conditions where surveys may not be possible, including but not limited to, physical obstacles to access the area.

5.) Identify contingencies, when possible, to define acceptable solutions or alternatives to any constraints.

4.3.6 Develop a Decision Rule - Using the If format, create a condition or set of condition(s) where a conclusion or set of conclusions can be made in regard to the objectives of the survey, based on comparison of the survey results with the investigation levels and/or an assessment of the data statistics.

4.3.7 Specify Limits on Decision Errors

1.) State the null hypothesis (e.g., The survey unit exceeds the release criteria.)

2.) Define both the Type I or ( value) error, and the Type II or ( value) error as 0.05. The Type I error will always be set at 0.05 unless prior NRC approval is granted for using a less restrictive value. The Type II error may be adjusted with the concurrence of the FSS Manager, after weighing the resulting change in the number of required measurement locations against the risk of unnecessarily investigating and/or remediating survey units that are truly below the release criterion.

3.) Establish the lower bound of the gray region (LBGR). The LBGR should be initially set at the mean concentration of residual radioactivity that is estimated to be present in the survey unit or the mean Sum-of-Fractions (SOFMean), if multiple radionuclides are present.

NOTE If adequate information is not available regarding the survey unit radioactivity levels, the LBGR may initially be set equal to 0.5 times the applicable DCGLW.

4.3.8 Optimize the Design

NOTE The Sign Test is the appropriate test for FSS results in Class 1, 2 or 3 areas, since background is expected to constitute a small fraction of the DCGL. For Class1, Class 2 and Class 3 survey units, if every measurement in the systematic sample population is less than or equal to the DCGLw (which is expected), the Sign test is not required.

1.) Calculate the relative shift (/) for Class 1 Class 2, and Class 3 areas using the following equation:

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

where; / = Relative Shift LBGR = Lower Bound of the Gray Region A. If the resulting Relative Shift is from one (1) up to three (3), go to step 3.) below. Otherwise, proceed to the next step.

B. If the Relative Shift is greater than three (3), use a value of three (3) as the adjusted Relative Shift. Adjust the LBGR by subtracting the estimated concentration variability from the DCGL.

C. If the Relative Shift is less than one (1), return to the DQO process to determine the cause and/or make adjustments to the DQOs.

D. Determine the number of surveys (N) needed in the survey unit for the selected values of Type I error (), Type II error () and the Relative Shift (/), from MARSSIM, Section 5.5.2, Table 5.5 and record N in the space provided.

E. Ensure that the scan MDCs of the instruments and detectors that will be used for scanning is less than the DCGLw of the most limiting ROC. If the scan MDC is greater than the DCGLw of the most limiting ROC, the N value must be adjusted in accordance with MARSSIM, Section 5.5.2.

NOTE Software such as Visual Sample Plan (VSP) may be used to determine the location of static measurements in lieu of the following steps.

2.) Calculate the Grid Spacing for Class 1 and Class 2 areas

A. If the survey unit is classified as Class 3, proceed to Step 3.B below.

B. Calculate the Grid Spacing (L) for Class 1 and 2 areas as follows:

for a triangular grid, or for a square grid

3.) Generate a Survey Map showing the Grids, each with a unique number.

A. Assign a unique identification number to each survey location using the guidance in Attachment 5.

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

NOTE A computer generated survey map should be generated for each Survey Package showing the boundaries of the entire survey unit, major physical features (if any) and the grid number for all survey locations. Software such as VSP may be used to determine the location of surveys or static measurements in lieu of the following steps.

B. If the survey unit is Class 3, establish survey locations on the survey map using a random-number generator and continue to Step F below.

NOTE The grid spacing may be rounded down for ease of locating measurement locations on the grid. Depending on the configuration and layout of the survey unit and the starting grid location, the minimum number of measurement locations may not be identified (as they fall out of the survey unit footprint). In this event, either generate a new random starting location or adjust the grid spacing downward until the appropriate number of locations is reached.

C. If the survey unit is classified as FSS Class 1 or Class 2, establish a Random Starting Point within the Survey Unit.

D. Starting from the randomly-selected location, establish a row of points parallel to one of the survey units axes at intervals of L.

E. Establish additional rows parallel to the first row.

i. For a triangular grid, additional rows will be added at a spacing of 0.866XL from the first row, with points on alternate rows spaced mid-way between the points from the previous row.

ii. For a square grid, points and rows will be spaced at intervals of L.

F. Using the reference grid system, determine the grid number for each survey location.

G. Specify static survey locations and grid numbers on Attachment 14, FSS Static Measurement Identification and Location.

H. Designate scan survey areas and grid numbers on Attachment 15, FSS Scan Area Identification and Location.

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

i. Scan surveys will be performed on building surfaces with coverage equal to 100% for Class 1 survey units and 10% to 100% of accessible surfaces for Class 2 survey units. For Class 3 survey units, a judgmental percent of the area should be scanned, with an emphasis on areas of potentially higher risk, such as historical traffic paths, near floor drains (if any) and in lower elevation areas.

ii. Upper walls (100% of accessible area in Class 1 survey units) will have biased static surveys performed. For Class 2 survey units, biased surveys will be performed on 10% to 100% of accessible areas. Overhead surveys should emphasize horizontal surfaces (top of light fixtures, top of ductwork, ledges, etc.) and areas near ceiling vents or penetrations.

iii. For Class 3 survey units, biased static survey locations will be based on judgment and an emphasis will be placed on areas of potentially higher risk. Static surveys in Class 3 areas will be conducted at biased locations based on professional judgment.

4.) Designate 5% of the systematic measurement locations, chosen at random, for replicate measurement in accordance with the QAPP. Designate the QC survey locations on Attachment 14, FSS Static Measurement Identification and Location and on the survey map.

NOTE Biased surveys are not included as part of the Statistical Sample Population.

They are treated as pre-emptive investigation surveys and compared directly to the applicable DCGL.

5.) Designate if any biased surveys will be taken at the discretion of the survey designer and the basis for taking them.

A. Using the reference grid system, determine the grid numbers for each biased survey location.

B. Designate biased survey locations and their grid numbers on Attachment 14, FSS Static Measurement Identification and Location and on the survey map.

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 4.4. Survey Package Instructions

NOTE Survey instructions may be provided without using Attachment 12, FSS Survey Instructions provided all the applicable items of the attachment are included.

4.4.1 Complete the General Instructions section of Attachment 12, Survey Instructions. The types of instructions in the General Instructions section include, but are not limited to, the following:

1.) Provide an area description, survey unit dimensions, and physical features (if 2 applicable). Class 1 structures should be approximately 100 m or less, Class 2 structures should be from 100 m2 up to 1,000 m2 and Class 3 structures have no maximum size.

2.) Document any temporal boundaries such as:

A. Time constraints

B. Schedule for surveys (e.g., round-the-clock, daylight hours).

3.) Provide references to relevant procedures for performance of surveys.

4.) List all equipment and instrumentation that will be used for surveys, as well as applicable procedural references.

5.) Specify quality control measures, such as instrument calibration requirements, instrument control requirements and instrument response check requirements.

6.) Specify types of measurements (i.e., beta-gamma static measurements, beta-gamma scan surveys).

7.) For all survey units, establish a reference grid system to identify the locations for systematic static measurements. Section 4.3.8 provides details for establishing the grid system.

8.) For Class 3 survey units, each static measurement location may be randomly selected using a random number generator.

9.) Provide additional requirements such as physical marking of grids, static survey locations, photographs, etc.

4.4.2 Complete the Specific Instructions section of Attachment 12. The types of instructions in the Specific Instructions include, but are not limited to, the following:

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 1.) Describe potential safety hazards that may be encountered during performance of surveys, including any required Personal Protective Equipment, safety sampling and/or safety surveillances.

2.) If pre-selected survey locations contain obstructions or safety hazards that will prevent surveys, identify alternative solutions to support survey requirements. If a selected measurement location is found to be either inaccessible or unsuitable, the location will normally be moved to the closest adjacent suitable location. In these cases, make a note in Attachment 13, FSS Field Log and provide the grid numbers of the new location.

3.) Provide specific instructions for performing beta-gamma scan surveys, beta-gamma static measurements or special measurements (if any), that may include, but are not limited to:

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

B. Establishing a reference grid system to identify the locations of static measurements and marking survey units with grid identification numbers prior to surveys.

C. Specifying scan survey instructions including, as applicable, scan speed, pattern (e.g., serpentine), alarm set-points, investigation levels, use of headphones, background levels, etc.

D. Specifying scan MDC requirements (For Class 1, Class 2 and Class 3 survey units the scan investigation level is >DCGLw or > MDCscan if MDCscan is greater than DCGLw.)

E. Providing a contingency for relocating survey locations due to obstacles, obstructions, or for safety reasons.

F. Providing instructions for background corrections on scan surveys and static measurements.

G. Specifying count times for static measurements to achieve desired MDC.

4.) Provide instructions for performing other radiological surveys, if needed.

5.) Provide instructions for quality control.

6.) Determine the type and frequency of Quality Control (QC) measurements, using guidance in LC-QA-PN-001, Final Status Survey QAPP.

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 7.) Specify actions to be taken if investigation levels are exceeded. If additional surveys confirm residual activity above the investigation level, notify the FSS Supervisor for further instructions.

8.) Specify documentation requirements (e.g., survey packages, survey maps, documentation of anomalies, clarity and good legibility of records).

9.) Identify any areas where the progress of the survey will be contingent on interaction or support from another department or group (e.g., security notifications, man-lift support, scaffold erection support, etc.).

4.5. FSS Survey Package and Cover Sheet Approval

4.5.1 Once the Survey Package for a specific survey unit has been completed, forward it to the responsible FSS Supervisor for an independent peer review against the guidance provided in Attachments 11 and 12. This review shall include plan completeness, accuracy of calculations and viability of assumptions.

4.5.2 The FSS Supervisor shall complete the General Section of Attachment 10.

4.5.3 The FSS Supervisor shall assess the readiness of the survey unit by completing the Preparation for Final Status Survey section of Attachment 10 using the following guidance:

1.) Ensure that a pre-FSS walk-down of the survey unit has been performed in accordance with LC-FS-PR-010, Isolation and Control for Final Status Survey and that all items identified for hazard mitigation and area preparation have been satisfactorily completed.

2.) Ensure that all turnover items that were identified on the Area Turnover and Control Checklist from LC-FS-PR-010, Isolation and Control for Final Status Survey, have been completed or resolved prior to signifying readiness.

4.5.4 The FSS Supervisor shall verify by signature on Attachment 10 that the survey unit is ready for FSS implementation and forward the completed Attachment 10 to the FSS Manager for final approval.

NOTE The FSS may not proceed in a survey unit until Attachment 10 has been approved by the FSS Manager.

4.6. Survey Implementation

4.6.1 Perform a pre-survey briefing with the FSS Technicians to review instructions and safety issues. (FSS Supervisor)

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 4.6.2 Initiate a FSS Field Log (Attachment 13) for the Survey Package. (FSS Supervisor)

4.6.3 Perform surveys in accordance with the survey instructions contained in each FSS survey package, after performing instrument response checks and daily instrument QC checks (e.g., current calibration date, batteries OK, etc.). (FSS Technicians)

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

2.) Make minor changes that do not affect the technical content of the survey package (typographical errors, instrument ID, etc.) using a pen and ink change. (FSS Technicians)

4.6.4 If it appears that major changes are needed to the Survey Package which affect the technical content (i.e. number of measurements, instrument MDC, etc.), notify the FSS Supervisor and pause surveys until the appropriate revisions can be made and approved. (FSS Technicians)

4.6.5 Revise the Survey Package instructions, include a revision number, and document the reasons for the changes, before forwarding the revised Survey Package to the FSS Manager for approval. (FSS Supervisor)

4.6.6 Complete all scan surveys and static measurements according to the Survey Package. Report all anomalies and results that are confirmed to be above an investigation level to the FSS Supervisor. (FSS Technicians)

4.7. FSS Data Assessment and Survey Unit Closure

4.7.1 Review the FSS data for completeness and validate the survey data in accordance with LC-FS-PR-008, Final Status Survey Data Assessment, before survey unit closure and reporting of results. (FSS Supervisor)

4.7.2 IF every measurement in the systematic sample population is less than or equal to the DCGLw (which is expected), the Sign test is not required. If a Sign test is required (e.g., for a Class 1 area that exceeds the criteria),

perform the test in accordance with Section 4.5.2 of LC-FS-PR-008, Final Status Survey Data Assessment.(FSS Supervisor)

4.7.3 If any location is identified by scans or static measurements exceeds an investigation level, refer to Section 4.6 of LC-FS-PR-008, Final Status Survey Data Assessment for further actions that are required.

4.7.4 Upon final closure of each survey package, prepare a release record for each survey unit in accordance with LC-FS-PR-009, Final Status Survey Reporting.(FSS Supervisor)

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 4.7.5 After all survey units in a building or structure have been completed and a release record has been prepared for each survey unit, the building or structure continue to post and control (until building demolition or license termination) in accordance with guidance in LC-FS-PR-010, Isolation and Control for Final Status Survey and/or other appropriate procedures, in order to prevent the handling, storage or use of radioactive material in the building.

5. ATTACHMENTS

5.1. Attachment 1, Base Case and Operational Above Grade Building DCGLs

5.2. Attachment 2, Dose Significant Radionuclides and Relative Ratios

5.3. Attachment 3, FSS Recommended Scan Survey Coverage

5.4. Attachment 4, FSS Scan and Static Survey Investigation Levels

5.5. Attachment 5, Sample and Measurement Unique Identification Designation

5.6. Attachment 6, Calculation of Static and Scan MDC

5.7. Attachment 7, Number of Samples Required for Sign Test.

5.8. Attachment 8, Typical FSS Survey Instrumentation

5.9. Attachment 9, Typical FSS Instrument Sensitivities

5.10. Attachment 10, FSS Survey Cover Sheet

5.11. Attachment 11, FSS Data Quality Objectives and Survey Design

5.12. Attachment 12, FSS Survey Instructions

5.13. Attachment 13. FSS Field Log

5.14. Attachment 14. FSS Static Measurement Identification and Location

5.15. Attachment 15. FSS Scan Area Identification and Location

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

ATTACHMENT 1

BASE CASE AND OPERATIONAL ABOVE GRADE BUILDING DCGLS

Base Case DCGLs for Above Grade Buildings (DCGLAGB)

ROC Above Grade Building (dpm/100 cm2)

Co-60 7100 Sr-90 8700 Cs-137 28000 Eu-152 12700 Eu-154 11500

Operational DCGLs for Above Grade Buildings (OpDCGLAGB)

Above Grade Building ROC OpDCGLAGB (dpm/100 cm2)

Co-60 1136 Sr-90 1392 Cs-137 4480 Eu-152 2032 Eu-154 1840

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

ATTACHMENT 2

DOSE SIGNIFICANT RADIONUCLIDES AND RELATIVE RATIOS

Radionuclide % of Total Activity (normalized)(1)

Co-60 6.44E-02 Sr-90 9.81E-02 Cs-137 8.29E-01 Eu-152 5.49E-03 Eu-154 2.81E-03 (1) Normalized radionuclide mixture for dose significant ROC from Table 41 of TSD RS-TD-31319-001 (Reference 2.13).

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

ATTACHMENT 3

FSS RECOMMENDED SCAN SURVEY COVERAGE

Area Scan Coverage Surface Activity Measurements Classification Or Soil Samples As determined by statistical tests; additional Class 1 100 percent measurements/samples to account for small areas of elevated activity as necessary

Class 2 10 to 100 percent As determined by statistical tests Class 3 1 to 10 percent (Judgmental)

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

ATTACHMENT 4

FSS SCAN AND STATIC SURVEY INVESTIGATION LEVELS

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

Class 1 > DCGLEMC > DCGLEMC

Class 2 > DCGLW or > MDCscan if > DCGLw MDCscan is greater than DCGLW

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

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

ATTACHMENT 5 SAMPLE & MEASUERMENT UNIQUE IDENTIFICATION DESIGNATION

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

B 2 0 0 9 1 0 1 F S A

Classification & Survey Area Survey Unit Number & Survey and Surface Type Measurement No. Media Type Sequence Indicator Measurement Type st 6th,7th and 8th digits indicate The 9th digit indicate The 11th digit indicates th th th 1 digit indicates type of Survey Area Survey Unit Number the type of survey. the type of surface The 13 digit indicates the th The 16 and 17 L = Open Land Area alphabetical sequence. 14 and digits indicate the B = Structural Survey Area (from Tables 6-1 and 6-2 ) A = Assessment where the 15th digits indicate the numerical type of media that S = System B = Background measurement was measurement number, was sampled.

nd S = Scoping taken. sequentially 01 through 99 SS = Surface Soil 2 digit indicates Classification C = Characterization F = Floor Sequence A-J allows the survey SB = Subsurface 1 = Class 1 R = Remedial Action W = Wall unit to be divided into 10 smaller Soil 2 = Class 2 F = FSS C = Ceiling survey units SM = Sediment 3 = Class 3 I = Investigation S = System WT = Water 4 = Non-impacted V = Verification R = Roof LQ = Other liquids 5 = Unassigned Q = QA/QC P = Paved Road besides water 3rd, 4th and 5th digits indicate Survey Area Number The 10th digit G = Ground OL = Oil

[(The Survey Area Number, Survey Unit Number and indicates the type of L = Water CV = Volumetric classification are taken from the updated master copy of measurement. The 12th digit indicates Concrete Survey Units for Structures that are maintained by the B = Background the material AV = Volumetric FSS Manager) S = Systematic composition where the Asphalt J = Biased surface measurement MT = Metal I = Investigation was taken. PT = Paint V = Verification C = Concrete BD = Beta Direct Q = QA/QC M = Metal AD = Alpha Direct W = Wood GM = Gamma B = Cinder Block measurement K = Brick BS = Beta Scan A = Asphalt GS = Gamma Scan S = Soil JS = Juncture Scan T = Tar JD = Juncture L = Liquid Direct O = Other (describe) PS = Penetration Scan PD = Penetration Direct

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

ATTACHMENT 6 CALCULATION OF STATIC AND SCAN MDC Page 1 of 2 MDC is the minimum detectable concentration on a surface that an instrument is expected to detect 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 2.14).

Beta-Gamma 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)2 2 A = detector area in cm (not to exceed 126 cm )

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.

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 ATTACHMENT 6

CALCULATION OF STATIC AND SCAN MDC Page 2 of 2

Static Beta-Gamma Measurement MDC

Static (direct) measurements utilize the following formula:

3.0+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 2 A = detector window area (cm )

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

ATTACHMENT 7 NUMBER OF SAMPLES REQUIRED FOR THE SIGN TEST

0.01 0.025 0.05 0.10 0.25 0.1 2984 2459 2048 1620 1018 0.2 754 622 518 410 258 0.3 341 281 234 185 117 0.4 197 162 136 107 68 0.5 130 107 89 71 45 0.6 94 77 65 52 33 0.7 72 59 50 40 26 0.8 58 48 40 32 21 0.9 48 40 34 27 17 1.0 41 34 29 23 15 1.1 36 30 26 21 14 1.2 33 27 23 18 12 1.3 30 24 21 17 11 1.4 28 23 20 16 10 1.5 27 22 18 15 10 1.6 24 21 17 14 9 1.7 24 20 17 14 9 1.8 23 20 16 12 9 1.9 22 18 16 12 9 2.0 22 18 15 12 8 2.5 21 17 15 11 8 3.0 20 17 14 11 8

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 Attachment 8 Typical FSS Survey Instrumentation

Effective Detector Measurement Type Detector Type Area & Window Instrument Model Detector Model Density 126 cm2 Beta Static/Scan Gas-Flow 0.8 mg/cm2 Ludlum 2350-1 Ludlum 43-68 Measurement Proportional Aluminized Mylar Beta Static/Scan 1.2 mg/cm2 0.01 Measurement Scintillation Plastic Scintillation Ludlum 2350-1 Ludlum 44-116 125 cm2 584 cm2 Beta Scan Gas-Flow 0.8 mg/cm2 Ludlum 2350-1 Ludlum 43-37 Measurement Proportional Aluminized Mylar

Gamma Scan Scintillation 2 diameter x 2 Ludlum 2350-1 Ludlum 44-10 Measurement length NaI Gamma Static/Scan High-purity N/A Canberra In Situ Object Counting System Measurement Germanium (ISOCS)

Gamma Pipe Static CsI 0.75 x 0.75 Ludlum 44-159 Measurement NaI 2 x 2 Ludlum 2350-1 Ludlum 44-157 NaI 3 x 3 Ludlum 44-162 Surface and High-purity Canberra Lab or In Volumetric Material Germanium N/A Situ Detector N/A (soil, etc.)

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 Attachment 9 Typical FSS Survey Instrument Sensitivities

Background Typical Typical TYPICAL Instruments Radiation Count Time Background Instrumentb and Detectors a (minutes) (cpm) Efficiency Scan MDC (t)

Model 43-68 Beta-Gamma 1.0 300 0.258 612 Model 44-116 Beta 1.0 200 0.124 1990 Model 43-51 Beta 1.0 40 0.126 2782 Model 43-37 Beta-Gamma 1.0 1,200 0.236 372 Model 44-10 Gamma 1.0 8,000 N/A 5.2 pCi/g(Cs-137)

HPGe Gamma Up to 60 N/A 60% relative 0.15-0.30 pCi/g Volumetric(Cs-137 Model 44-159 Gamma 1.0 700 0.024 N/A Model 44-157 Gamma 1.0 6,300 0.212 N/A Model 44-162 Gamma 1.0 16,000 0.510 N/A

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

ATTACHMENT 10 FSS SURVEY PACKAGE COVER SHEET

GENERAL SECTION

Survey Unit No.: Area/Description:

Survey Unit Type:

Classification: - Class 1 - Class 2 - Class 3 - Non-impacted

PREPARATION FOR FINAL STATUS SURVEY ACTIVITIES Reference Grid has been established (if appropriate).

A walk-down has been performed of the SU and the Pre-Turnover Walk-Down form has been completed in accordance with LC-FS-PR-010, Isolation and Control for Final Status Survey.

Area Turnover and Control Checklist has been completed in accordance with LC-FS-PR-010, Isolation and Control for Final Status Survey and all issues identified have been resolved.

All preparation activities (floor cleared, scaffolding erected, etc.) have been completed.

Area has been cleared of all non-essential materials and equipment.

Area has been posted and access control measures have been implemented in accordance with LC-FS-PR-010, Isolation and Control for Final Status Survey.

ALL ABOVE ACTIONS ARE COMPLETE AND SURVEY UNIT IS READY FOR FSS ACTIVITIES

FSS Supervisor Date

SURVEY APPROVAL

A SURVEY PACKAGE HAS BEEN COMPLETED, REVIEWED AND APPROVED FOR USE.

Prepared by: __________________________ ____________________ __________

Print Name Signature Date Approved by: __________________________ ____________________ __________

FSS Manager (Print Name) Signature Date

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 ATTACHMENT 11 FSS DATA QUALITY OBJECTIVES AND SURVEY DESIGN Page 1 of 2

DATA QUALITY OBJECTIVES 1.0 STATE THE PROBLEM Problem Statement Identify Stakeholders Identify the Planning Team Prepare a Schedule Identify Resources 2.0 IDENTIFY THE DECISION Principal Study Question State Alternate Actions Decision Statement 3.0 IDENTIFY INPUTS TO THE DECISION Identify Information Needed Gather Historical Information Identify Radionuclides of Concern State Release Criteria Identify Radiological Survey Data Develop Basis for the Action Level Develop Basis for Scan Measurements Develop Basis for Quality Control (QC) Measurements Determine Investigation Levels Determine Survey and Analysis Methods to Meet Data Requirements 4.0 DEFINE THE BOUNDARIES OF THE SURVEY Define Boundaries of the Survey Define Temporal boundaries Identify Constraints 5.0 DEVELOP A DECISION RULE Develop Decision Rule

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

ATTACHMENT 11 FSS DATA QUALITY OBJECTIVES AND SURVEY DESIGN Page 2 of 2

6.0 SPECIFY TOLERABLE LIMITS ON DECISION ERRORS State The Null Hypothesis Set Type I Error Set Type II Error Determine Lower Bound of the Gray Region 7.0 OPTIMIZE DESIGN Determine Type of Statistical Test Calculate Number of Systematic Measurements Calculate Number of Biased Measurements and Locations Calculate Number of Measurements for Quality Control

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2

ATTACHMENT 12 FSS SURVEY INSTRUCTIONS

Survey Unit: No.:

Description:

Survey Unit Type:

Survey Unit Classification:

- Class 1 - Class 2 - Class 3

General Instructions:

Personnel will follow all relevant safety directives and procedures while performing this work.

1. Survey and sampling will be performed by qualified technicians under the direction of Characterization/FSS Supervision.
2. Instrumentation used in the field will be used in accordance with applicable procedures.
3. Detailed field notes and observations will be documented during survey and sampling.
4. Photographs should be taken as necessary to clarify survey and sampling activities or survey constraints.
5. Samples will be controlled under Chain-of-Custody in accordance with procedure LC-FS-PR-012, Sample Processing Log.
6. Documents generated during the performance of survey and sampling will be complete and legible.

Corrections will be made using a single line-out followed by an initial and date.

7. Measurement locations will be identified by markings where possible.

Specific Instructions:

1. Identify measurement locations that are not accessible and choose nearest accessible location. Note changes on a Field Log and mark on map or drawing if applicable.
2. Utilize a Field Log to document all other changes or notable issues.

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 ATTACHMENT 13 FSS FIELD LOG

Survey Unit #: _ Survey Unit

Description:

Field Log Date: _________

Time: Observation or Comment: Technician

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 ATTACHMENT 14 FSS STATIC MEASUREMENT IDENTIFICATION AND LOCATION

Survey Unit No.: _ Survey Unit

Description:

Date Category Type Media Measurement Grid ID# Notes ID#

Category: BD = Beta-Gamma Static Measurement Type: B = Background, S = Systematic, J = Biased, I = Investigational, V = Verification, Q = QA/QC Media: C = Concrete, M = Metal, W = Wood, B = Cinder Block, K = Brick, O = Other (Describe in Notes)

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Final Status Surveys LC-FS-PR-015 for Structures Revision 2 ATTACHMENT 15 FSS SCAN AREA IDENTIFICATION AND LOCATION Survey Unit #: B No.:

Description:

Surface % of Total

Scan ID: 2 Grid Numbers Covered Notes Area (m ) SU Area

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