ML24102A162
| ML24102A162 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 03/18/2024 |
| From: | Gregory Chapman Reactor Decommissioning Branch |
| To: | |
| References | |
| Download: ML24102A162 (12) | |
Text
Final Status Survey Report Reviews Final Status Survey Report (FSSR). The results of the final status survey conducted by a licensee to demonstrate the radiological status of its facility. The FSSR is submitted to the NRC for review and approval. (NUREG-1757, Vol 2)
The purpose of the NRC staff review is to verify that the results of the FSS demonstrate that the site, area, or building meets the radiological criteria for license termination.
Section 4.5.1.1.3 Information to be submitted Section 4.5.1.2.1 Minimal Technical Review Section 4.5.1.2.2 Detailed Technical Review Section 4.5.1.2.4 Detailed Review Topics Section 4.5.1.3 Evaluation Criteria NUREG-1757, Vol 2 Guidance on FSSRs
NRC FSSR Review: Land Areas For Typical Open Land Survey Units, it includes:
- Use Chapter 5 of LTP as a reference
- Review summary of variations from LTP and survey plans/justification for changes
- Review summary of significant events/investigations performed/judgmental sampling
- Random verification of transcribed values of datum from laboratory reports
- Instruments Can measure all ROCs/Surrogates Surrogate DCGL determination Calibration/efficiency determination MDCs 10%-50% of DCGLs
- Verification of survey planning basis for # of measurements scan MDC determination survey unit size
- Review confirmatory survey data, if performed, to verify agreement with FSS
- Review inspection reports for the FSS period to verify no findings regarding survey conduct
NRC FSSR Review: Land Areas, Continued Review of results with special attention given to:
- Scanning coverage and exceedance of investigation levels
- Biased sampling/exceedances of the DCGLW (bounded/investigated, location, DCGLEMC, etc.)
- How the SOF is determined, including:
all ROCs considered operational vs base-line DCGL values used insignificant contributors considered surrogate DCGLs determined correctly background/reference materials negative values non-conservative biases present in data
- Verify statistical tests outcomes, if needed
- Does FSS data verify the survey plan (e.g., compare relative shift based on FSS data vs relative shift used for planning FSS)
- QA/QC: verify insignificant contributors and surrogate ratios are appropriate, review duplicate and replicate evaluations to see if in agreement
- Verify all appropriate media considered (GW, small structures, piping, soil, etc.) for demonstration of compliance
NRC FSSR Review: Structures For Typical Structural Survey Units, it includes (similar to Open Land survey units):
- Use Chapter 5 of LTP as a reference
- Review summary of variations from LTP and survey plans/justification for changes
- Review summary of significant events/investigations performed/judgmental sampling
- Random verification of transcribed values of datum from laboratory/survey reports
- Instruments Can measure all ROCs/Surrogates Gross or Surrogate DCGL determination Calibration/efficiency determination MDCs 10%-50% of DCGLs
- Verification of survey planning basis for # of measurements scan MDC determination survey unit size
- Review confirmatory survey data, if performed, to verify agreement with FSS
- Review inspection reports for the FSS period verifying no findings concerning survey conduct
NRC FSSR Review: Structures, Continued
- Review of results with special attention given to:
- Scanning area coverage
- Review measurements taken How background addressed Non-conservative bias present in the data
- Biased measurements/exceedances of the DCGLW Ensure adequately bounded/investigated Impact to adjacent survey units Verify DCGLEMC determination
- Verify statistical tests were performed appropriately, if needed
- Does FSS data support planning for the survey?
- QA/QC: verify insignificant contributors and surrogate or gross activity DCGLW determinations are appropriate, review duplicate and replicate evaluations for appropriate agreement
- Subslab soil, piping, and GW addressed?
FSSR Review Continued
- General
- Was sampling done appropriately?
Subsurface characterized to appropriate depths?
Were excavations/backfill characterized?
Did remediation accomplish removal of significant contamination?
- If ISOCS measurements utilized, was appropriate scanning performed to identify and investigate hot spots?
- Was additional remediation beyond the DCGLs required due to ALARA?
- Did surveys indicate DRPs may be a concern?
- Was GW monitoring and dose assessed consistent with LTP/other requirements?
- Are the methods employed during FSS consistent with MARSSIM/NUREG-1757/LTP?
- Ensure the minimal review requirements in NUREG-1757 Vol 2 are met
- RAIs needed to resolve concerns?
- Review issues identified by interveners and stakeholders and allegations to ensure resolution
- For summary at license termination:
- Develop a spreadsheet to note maximum and average levels of residual contamination and potential dose from each survey unit (also allows check against EPA MOU criteria)
- SER to document what staff evaluate/did during review and whether the FSSR adequately demonstrates compliance with 10 CFR 20, Subpart E.
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