Text

Enclosure 5: Oyster Creek Generating Station Radiological Characterization Report Revision 1, April 24, 2023
	ML24214A044
Person / Time
Site:	Oyster Creek
Issue date:	04/24/2023
From:	Bisson J, Messier C; BHI Energy I Power Services, Holtec Decommissioning International, Westinghouse
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML24214A209	List: ML24214A037; ML24214A039; ML24214A043; ML24214A044; ML24214A048; ML24214A049; ML24214A051; ML24214A052; ML24214A053; ML24214A054; ML24214A057; ML24214A058; ML24214A060; ML24214A061; ML24214A064; ML24214A065; ML24214A069; ML24214A070; ML24214A072; ML24214A075; ML24214A079;
References
	HDI-OC-24-018
	Download: ML24214A044 (1)
	v • d • e

OYSTER CREEK GENERATING STATION SITE RADIOLOGICAL CHARACTERIZATION REPORT

Revision 1 April 24, 2023

BHI Energy l Power Services 97 Libbey Industrial Pkwy Weymouth, MA 02189 (800) 225-0385 Table ol Contents, list of Tables, List of Figures

Originated By: ~ ~((fl!E (A~~~.re~ 20:44EDT)

Joseph Bisson - Sr. Radiological Engineer

Originated By: Christopher M. Gans Christopher Gans - Sr. Radiologi cal En

Originated By:

Chri Messier - Vice President Engineering

Reviewed By: Martin Erickson ~ C~n, Martin Erick~Radiologica l Engineer

Approved By: _Jom_ .,_ o,_,(A_p,_~1;_, 202_.3 _20._02 _EDT_) ----------------

Jimmy Orr - Vice President of Radiological Operations

~ , 8 H 1 @westinghouse

R evisi on 1 Table of Contents, List of Tables, List of Figures

Record of Revision Revision Modified Revision Summary Revision Number By Date 0 Initial Issue 3/17/23 1 GansAdded Section 3.12 for Ground Water and other minor editorial changes

Revision 1 Table of Contents, List of Tables, List of Figures

List of Tables ............................................................................................................................................... iv List of Figures ............................................................................................................................................. vii Acronyms and Abbreviations .................................................................................................................... viii 1 Int r oduct ion........................................................................................................................................... 1-1 1.1 Radiological Site Characterization Organization .......................................................................... 1-3 1.2 Radiological Assessment criteria .................................................................................................. 1-4 1.3 Site Characterization Quality Requirements ................................................................................. 1-5 1.3.1 Site Characterization Quality Assurance/Quality Control Requirements .............................. 1-5 1.3.2 Radiation Detection Instrumentation Sensitivity .................................................................... 1-7 1.4 Laboratory Analytical Methods .................................................................................................... 1-7 2 Radiological Characterization of OCNGS Site..................................................................................... 2-1 2.1 Survey Methods and Techniques .................................................................................................. 2-1 2.2 Survey Designs by Area................................................................................................................ 2-4 2.3 Survey Area Plans and Site Characterization Procedures ............................................................. 2-4 2.4 BHI Mobile Chemistry Laboratory ............................................................................................... 2-7 3 Radi ol ogical Fi ndi ngs ........................................................................................................................... 3-1 3.1 NOCA-1 (SAP 01 - Open Land) .................................................................................................. 3-3 3.1.1 Area Description..................................................................................................................... 3-3 3.1.2 Survey Summary .................................................................................................................... 3-3 3.1.3 Survey Data Summary ............................................................................................................ 3-6 3.1.4 Data Quality Comparisons ..................................................................................................... 3-9 3.1.5 Survey Plan Deviation(s) ...................................................................................................... 3-14 3.1.6 Survey Area Investigations .................................................................................................. 3-14 3.1.7 Survey Area Conclusions ..................................................................................................... 3-14 3.2 NOCA-2 (SAP 02 - Open Land) ................................................................................................ 3-15 3.2.1 Area Description................................................................................................................... 3-15 3.2.2 Survey Summary .................................................................................................................. 3-15 3.2.3 Survey Data Summary .......................................................................................................... 3-17 3.2.4 Data Quality Comparisons ................................................................................................... 3-20 3.2.5 Survey Plan Deviations ........................................................................................................ 3-21 3.2.6 Survey Area Investigations .................................................................................................. 3-21 3.2.7 Survey Area Conclusions ..................................................................................................... 3-22 3.3 SOCA-1 (SAP 03 - Open Land) ................................................................................................. 3-23 3.3.1 Area Description................................................................................................................... 3-23 3.3.2 Survey Summary .................................................................................................................. 3-23 3.3.3 Survey Data Summary .......................................................................................................... 3-25 3.3.4 Data Quality Comparisons ................................................................................................... 3-27 3.3.5 Survey Plan Deviations ........................................................................................................ 3-31 3.3.6 Survey Area Investigations .................................................................................................. 3-31 3.3.7 Survey Area Conclusions ..................................................................................................... 3-31 3.4 SOCA-2 (SAP 04 - Open Land) ................................................................................................. 3-32 3.4.1 Area Description................................................................................................................... 3-32 3.4.2 Survey Summary .................................................................................................................. 3-32 3.4.3 Survey Data Summary .......................................................................................................... 3-34

i Revision 1 Table of Contents, List of Tables, List of Figures

3.4.4 Data Quality Comparisons ................................................................................................... 3-35 3.4.5 Survey Plan Deviations ........................................................................................................ 3-38 3.4.6 Survey Area Investigations .................................................................................................. 3-39 3.4.7 Survey Area Conclusions ..................................................................................................... 3-39 3.5 EOCA-1 (SAP 05 - Open Land) ................................................................................................ 3-40 3.5.1 Area Description................................................................................................................... 3-40 3.5.2 Survey Summary .................................................................................................................. 3-40 3.5.3 Survey Data Summary: ........................................................................................................ 3-43 3.5.4 Data Quality Comparisons ................................................................................................... 3-46 3.5.5 Survey Plan Deviation(s) ...................................................................................................... 3-54 3.5.6 Survey Area Investigations .................................................................................................. 3-54 3.5.7 Survey Area Conclusions ..................................................................................................... 3-54 3.6 NPA (SAP 06 - Open Land) ....................................................................................................... 3-55 3.6.1 Area Description................................................................................................................... 3-55 3.6.2 Survey Summary .................................................................................................................. 3-55 3.6.3 Survey Data Summary .......................................................................................................... 3-57 3.6.4 Data Quality Comparisons ................................................................................................... 3-59 3.6.5 Survey Plan Deviations ........................................................................................................ 3-63 3.6.6 Survey Area Investigations .................................................................................................. 3-63 3.6.7 Survey Area Conclusions ..................................................................................................... 3-63 3.7 SPA (SAP 08 - Open Land) ....................................................................................................... 3-64 3.7.1 Area Description................................................................................................................... 3-64 3.7.2 Survey Summary: ................................................................................................................. 3-64 3.7.3 Survey Data Summary .......................................................................................................... 3-66 3.7.4 Data Quality Comparisons ................................................................................................... 3-69 3.7.5 Survey Plan Deviation(s) ...................................................................................................... 3-73 3.7.6 Survey Area Investigations .................................................................................................. 3-73 3.7.7 Survey Area Conclusions ..................................................................................................... 3-73 3.8 RCA (SAP 10 - Open Land) ...................................................................................................... 3-74 3.8.1 Area Description................................................................................................................... 3-74 3.8.2 Survey Summary .................................................................................................................. 3-74 3.8.3 Survey Data Summary: ........................................................................................................ 3-77 3.8.4 Data Quality Comparisons ................................................................................................... 3-80 3.8.5 Survey Plan Deviation(s) ...................................................................................................... 3-84 3.8.6 Survey Area Investigations .................................................................................................. 3-84 3.8.7 Survey Area Conclusions ..................................................................................................... 3-84 3.9 DCA (SAP 12 - Open Land) ...................................................................................................... 3-85 3.9.1 Area Description................................................................................................................... 3-85 3.9.2 Survey Summary .................................................................................................................. 3-85 3.9.3 Survey Data Summary .......................................................................................................... 3-86 3.9.4 Data Quality Comparisons ................................................................................................... 3-88 3.9.5 Survey Plan Deviation(s) ...................................................................................................... 3-89 3.9.6 Survey Area Investigations .................................................................................................. 3-89 3.9.7 Survey Area Conclusions ..................................................................................................... 3-90 3.10 NPA (SAP 07 - BUILDINGS/STRUCTURES) ........................................................................ 3-91 3.10.1 Area Description................................................................................................................... 3-91 3.10.2 Survey Summary .................................................................................................................. 3-91

ii Revision 1 Table of Contents, List of Tables, List of Figures

3.10.3 Survey Data Summary .......................................................................................................... 3-93 3.10.4 Data Quality Comparisons ................................................................................................... 3-94 3.10.5 Survey Plan Deviation(s) ...................................................................................................... 3-94 3.10.6 Survey Area Investigations .................................................................................................. 3-94 3.10.7 Survey Area Conclusions ..................................................................................................... 3-95 3.11 SPA (SAP 09 - BUILDINGS/STRUCTURES) ......................................................................... 3-96 3.11.1 Area description ................................................................................................................... 3-96 3.11.2 Survey Summary .................................................................................................................. 3-96 3.11.3 Survey Data Summary .......................................................................................................... 3-97 3.11.4 Data Quality Comparisons ................................................................................................... 3-99 3.11.5 Survey Plan Deviation .......................................................................................................... 3-99 3.11.6 Survey Area Investigations ................................................................................................ 3-100 3.11.7 Survey Area Conclusions ................................................................................................... 3-100 3.12 GROUNDWATER ................................................................................................................... 3-101 3.12.1 Introduction ........................................................................................................................ 3-101 3.12.2 Discussion .......................................................................................................................... 3-102 3.12.3 Groundwater Conclusions .................................................................................................. 3-104 4 Concl usi ons........................................................................................................................................... 4-1 5 Re c omm e ndat i ons ................................................................................................................................. 5-1 6 References............................................................................................................................................. 6-1

iii Revision 1 Table of Contents, List of Tables, List of Figures

LIST OF TABLES

Table 1-1 Survey Areas for the OCNGS Site ............................................................................................ 1-2 Table 1-2 OCNGS DCGL Values by Radionuclide of Concern (ROC) .................................................... 1-5 Table 1-3 Assessment Criteria ................................................................................................................... 1-5 Table 2-1 Summary of Survey Area Plans ................................................................................................. 2-5 Table 3-1 Decision Logic for Evaluating Survey Area Data ..................................................................... 3-1 Table 3-2 Field Instrumentation Information ............................................................................................. 3-2 Table 3-3 GPS Coordinates for Sample Locations in the NOCA-1 Survey Area ...................................... 3-4 Table 3-4 On-Site Laboratory Gamma Analysis Results for NOCA1 Surf ace Soil Samples .................... 3-7 Table 3-5 On-Site Laboratory Gamma Analysis Results for NOCA1 Sediment Samples ........................ 3-8 Table 3-6 On-Site Laboratory Gamma Analysis Results for NOCA1 Asphalt Samples ........................... 3-8 Table 3-7 On-Site Laboratory Gamma Analysis Results for NOCA -1 Deep Subsurface Soil Samples ... 3-9 Table 3-8 Duplicate Sample Analysis for NOCA1-SOIL-05-D .............................................................. 3-10 Table 3-9 Duplicate Sample Analysis for NOCA-1-SOIL-14-D ............................................................. 3-10 Table 3-10 Duplicate Sample Analysis for NOCA1-SOIL-19-B -D ........................................................ 3-11 Table 3-11 On-Site/Off-Site Sample Analysis for NOCA1-SOIL-03-QC .............................................. 3-12 Table 3-12 On-Site/Off-Site Sample Analysis for NOCA1-SOIL-11-QC .............................................. 3-13 Table 3-13 On-Site/Off-Site Sample Analysis for NOCA1-SOIL-20-B-QC .......................................... 3-13 Table 3-14 Off-Site Laboratory Results for HTDs in NOCA-1 QC Samples ......................................... 3-14 Table 3-15 GPS Coordinates for Sample Collection Locations in the NOCA-2 Survey Area ................ 3-16 Table 3-16 On-Site Laboratory Gamma Analysis Results for NOCA-2 Surface Soil Samples .............. 3-18 Table 3-17 On-Site Laboratory Gamma Analysis Results for NOCA-2 Sediment Samples ................... 3-18 Table 3-18 On-Site Laboratory Gamma Analysis Results for NOCA-2 Asphalt Samples ..................... 3-19 Table 3-19 On-Site Laboratory Gamma Analysis Results for NOCA-2 Deep Soil Samples .................. 3-19 Table 3-20 Duplicate Sample Analysis for NOCA2-SEDI B-D ........................................................ 3-20 Table 3-21 On-Site/Off-Site Sample Analysis for NOCA2-SOIL-3-B-QC ............................................ 3-21 Table 3-22 Off-Site Laboratory Results for HTDs in NOCA-2 QC Sample ........................................... 3-21 Table 3-23 GPS Coordinates for Sample Locations in the SOCA-1 Survey Area .................................. 3-24 Table 3-24 On-Site Laboratory Gamma Analysis Results for SOCA-1 Surface Soil Samples ............... 3-26 Table 3-25 On-Site Laboratory Gamma Analysis Results for SOCA-1 Asphalt Samples ...................... 3-27 Table 3-26 Duplicate Sample Analysis for SOCA1-SEDI D ............................................................ 3-27 Table 3-27 Duplicate Sample Analysis for SOCA1- SEDI D ............................................................. 3-28 Table 3-28 Duplicate Sample Analysis for SOCA1-SEDI D ............................................................. 3-28 Table 3-29 On-Site/Off-Site Sample Analysis for SOCA1-SOIL-05-QC ............................................... 3-29 Table 3-30 On-Site/Off-Site Sample Analysis for SOCA1-SOIL-13-QC ............................................... 3-30 Table 3-31 On-Site/Off-Site Sample Analysis for SOCA1-SOIL-15-QC ............................................... 3-30 Table 3-32 Off-Site Laboratory Results for HTDs in SOCA-1 QC Samples .......................................... 3-31 Table 3-33 GPS Coordinates for Sample Locations in the SOCA-2 Survey Area .................................. 3-33 Table 3-34 On-Site Laboratory Gamma Analysis Results for SOCA-2 Surface Soil Samples ............... 3-35 Table 3-35 Duplicate Sample Analysis for SOCA2-SOIL-03-D ............................................................. 3-36 Table 3-36 Duplicate Sample Analysis for SOCA2-SOIL-08-D ............................................................. 3-36 Table 3-37 On-Site/Off-Site Sample Analysis for SOCA2-SOIL-06-QC ............................................... 3-37

iv Revision 1 Table of Contents, List of Tables, List of Figures

Table 3-38 On-Site/Off-Site Sample Analysis for SOCA2-SOIL-13-QC ............................................... 3-38 Table 3-39 OffSte Laboratory Results for HTDs in SOCA-2 QC Samples............................................. 3-38 Table 3-40 GPS Coordinates for Sample Locations in the EOCA-1 Survey Area .................................. 3-41 Table 3-41 On-Site Laboratory Gamma Analysis Results for EOCA-1 Surface Soil Samples ............... 3-44 Table 3-42 On-Site Laboratory Gamma Analysis Results for EOCA-1 Sediment Samples ................... 3-45 Table 3-43 On-Site Laboratory Gamma Analysis Results for EOCA-1 Asphalt Samples ...................... 3-46 Table 3-44 Duplicate Sample Analysis for EOCA1-SOIL-02-D ............................................................ 3-46 Table 3-45 Duplicate Sample Analysis for EOCA1- SOIL-20-D ............................................................ 3-47 Table 3-46 Duplicate Sample Analysis for EOCA1-SOIL-24-D ............................................................ 3-47 Table 3-47 Duplicate Sample Analysis for EOCA1-SOIL-26-D ............................................................ 3-48 Table 3-48 Duplicate Sample Analysis for EOCA1-SOIL-33-B -D ........................................................ 3-48 Table 3-49 QC Sample Analysis for EOCA1-SOIL-06-QC .................................................................... 3-49 Table 3-50 QC Sample Analysis for EOCA1-SOIL-10-QC .................................................................... 3-50 Table 3-51 QC Sample Analysis for EOCA1-SOIL-12-QC .................................................................... 3-50 Table 3-52 QC Sample Analysis for EOCA1-SOIL-17-QC .................................................................... 3-51 Table 3-53 QC Sample Analysis for EOCA1-SOIL-28-QC .................................................................... 3-51 Table 3-54 QC Sample Analysis for EOCA1-SOIL-34-B-QC ................................................................ 3-52 Table 3-55 QC Sample Analysis for EOCA1-SOIL-42-B-QC ................................................................ 3-52 Table 3-56 Off-Site Laboratory Results for HTDs in EOCA-1 QC Samples .......................................... 3-53 Table 3-57 GPS Coordinates for Sample Locations in the NPA Survey Area ........................................ 3-56 Table 3-58 On-Site Laboratory Gamma Analysis Results for NPA Surface Soil Samples ..................... 3-58 Table 3-59 On-Site Laboratory Gamma Analysis Results for NPA Sediment Samples ......................... 3-59 Table 3-60 On-Site Laboratory Gamma Analysis Results for NPA Asphalt Samples ............................ 3-59 Table 3-61 Duplicate Sample Analysis for NPA-SEDI- 02-B-D ............................................................. 3-60 Table 3-62 Duplicate Sample Analysis for NPA-SOIL- 10-B-D ............................................................. 3-60 Table 3-63 On-Site/Off-Site Sample Analysis for NPA-SOIL-04-B-QC ................................................ 3-61 Table 3-64 On-Site/Off-Site Sample Analysis for NPA-SOIL-14-B-QC ................................................ 3-62 Table 3-65 Off-Site Laboratory Results for HTDs in NPA QC Samples ................................................ 3-62 Table 3-66 GPS Coordinates for Sample Locations in the SPA Survey Area ......................................... 3-65 Table 3-67 On-Site Laboratory Gamma Analysis Results for SPA Surface Soil Samples ...................... 3-67 Table 3-68 On-Site Laboratory Gamma Analysis Results for SPA Sediment Samples .......................... 3-68 Table 3-69 On- Site Laboratory Gamma Analysis Results for SPA Subsurface Soil Samples ................ 3-68 Table 3-70 On-Site Laboratory Gamma Analysis Results for SPA Deep Soil Samples ......................... 3-69 Table 3-71 On-Site Laboratory Gamma Analysis Results for SPA Asphalt Samples ............................. 3-69 Table 3-72 Duplicate Sample Analysis for SPA-SEDI- 01-B-D .............................................................. 3-70 Table 3-73 Duplicate Sample Analysis for SPA-SEDI- 06-B-D .............................................................. 3-70 Table 3-74 On -Site/Off-Site Sample Analysis for SPA-SEDI-02-B-QC ................................................ 3-71 Table 3-75 On-Site/Off-Site Sample Analysis for SPA -SOIL-12-B-QC ................................................ 3-72 Table 3-76 Off-Site Laboratory Results for HTDs in SPA QC Samples ................................................. 3-72 Table 3-77 GPS Coordinates for Sample Locations in the RCA Survey Area ........................................ 3-75 Table 3-78 On-Site Laboratory Gamma Analysis Results for RCA Surface Soil Samples ..................... 3-78 Table 3-79 On-Site Laboratory Gamma Analysis Results for RCA Sediment Samples ......................... 3-79 Table 3-80 On-Site Laboratory Gamma Analysis Results for RCA Deep Soil Samples ........................ 3-79

v Revision 1 Table of Contents, List of Tables, List of Figures

Table 3-81 On-Site Laboratory Gamma Analysis Results for RCA Subsurface Soil Samples ............... 3-80 Table 3-82 On-Site Laboratory Gamma Analysis Results for RCA Asphalt Samples ............................ 3-80 Table 3-83 Duplicate Sample Analysis for RCA-SOIL- 04-B-D ............................................................. 3-81 Table 3-84 Duplicate Sample Analysis for RCA -SOIL- 12-B-D ............................................................. 3-81 Table 3-85 On-Site/Off-Site Laboratory Comparisons for Sample RCA- SOIL-08-B-QC ..................... 3-82 Table 3-86 On-Site/Off-Site Laboratory Comparisons for Sample RCA- SOIL-13-B-QC ..................... 3-83 Table 3-87 On-Site/Off-Site Laboratory Comparisons for Sample RCA- SOIL-20-B-QC ..................... 3-83 Table 3-88 Off-Site Laboratory Results for HTDs in RCA QC Samples ................................................ 3-84 Table 3-89 GPS Coordinates for DCA Sampling Locations ................................................................... 3-85 Table 3-90 On-Site Laboratory Analysis Results for DCA Sediment Samples ....................................... 3-87 Table 3-91 Duplicate Sample Analysis for DCA-SEDI- 03-B-D ............................................................. 3-88 Table 3-92 On-Site/Off-Site Sample Analysis for DCA-SEDI-01-B-QC ............................................... 3-89 Table 3-93 Off-Site Laboratory Results for HTDs in DCA QC Samples ................................................ 3-89 Table 3-94 Planned Number and Type of Measurements by Structure in the NPA ................................ 3-92 Table 3-95 Data Summaries for Statistically -Determined Warehouse Floor Measurement Locations ... 3-93 Table 3-96 Data Summaries for Biasedly-Determined Warehouse Measurement Locations .................. 3-94 Table 3-97 Planned Number and Type of Measurements by Structure in the SPA ................................. 3-97 Table 3-98 Data Summaries for Statistically -Determined OCAB Floor Measurement Locations .......... 3-98 Table 3-99 Data Summaries for Biasedly-Determined OCAB Measurement Locations ........................ 3-98 Table 3-100 Data Summaries for Statistically-Determined SEB Floor Measurement Locations ............ 3-98 Table 3-101 Data Summaries for Biasedly-Determined SEB Measurement Locations .......................... 3-99 Table 3-102 Data Summaries for Statistically-Determined NGF Floor Measurement Locations ........... 3-99 Table 3-103 Data Summaries for Biasedly -Determined NGF Measurement Locations .......................... 3-99 Table 3-104 Recent Results from the OCNGS NEI 07-07 Groundwater Protection Program .............. 3-103

vi Revision 1 Table of Contents, List of Tables, List of Figures

LIST OF FIGURES

Figure 1-1 Survey Areas Within the OCNGS Site Boundary .................................................................... 1-3 Figure 1-2 Site Characterization Organization .......................................................................................... 1-4 Figure 3-1 NOCA-1 Survey Area and Sample Locations .......................................................................... 3-5 Figure 3-2 NOCA-2 Survey Area and Sample Locations ........................................................................ 3-16 Figure 3-3 SOCA-1 Survey Area and Sample Locations ........................................................................ 3-25 Figure 3-4 SOCA-2 Survey Area and Sample Locations ........................................................................ 3-34 Figure 3-5 EOCA-1 Survey Area and Sample Locations ........................................................................ 3-42 Figure 3-6 NPA Survey Area and Sample Locations .............................................................................. 3-57 Figure 3-7 SPA Survey Area and Sample Locations ............................................................................... 3-66 Figure 3-8 RCA Survey Area and Sample Locations .............................................................................. 3-76 Figure 3-9 DCA Survey Area and Sample Locations .............................................................................. 3-86 Figure 3-10 OCNGS RGPP Monitoring Wells for the Cohansey Aquifer ............................................ 3-101 Figure 3-11 OCNGS RGPP Monitoring Wells for the Cape May Aquifer ........................................... 3-102

vii Revision 1 Acronyms and Abbreviations

ACRONYMS AND ABBREVIATIONS

AC Assessment Criteria BHI BHI Energy Services CFR Code of Federal Regulations CoC Chain of Custody cm2 square centimeters cpm counts per m inute CST Condensate Storage Tank D&D Decontamination and D ecommissioning DCA Discharge C anal Area DCGL Derived Concentration Guideline Level DoD Department of Defense DOE Depart of Energy DQA Data Quality A ssessment DQO Data Quality Objective dpm disintegrations per minute EOCA East O wner-Controlled Area EPA Environmental Protection A gency FSS Final Status Survey GPS Global Positioning System HDI Holtec Decommissioning International HSA Historical Site Assessment HTD Hard-to-Detect (radionuclide)

ISFSI Interim Spent Fuel Storage Installation m2 square meters MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MDC Minimum Detectable Concentration mrem/y millirem per year NaI sodium iodide ND Not D etected NELAP National Environmental Laboratory Accreditation Program NGF New Gatehouse Facility NIST National Institute of Standards and Technology NJAC New Jersey Administrative Code NOCA North Owner Controlled Area NORM Naturally Occurring Radioactive Materials NPA North Protected Area NRC (U.S.) Nuclear Regulatory Commission OCA Owner Controlled Area OCAB Oyster Creek Administration Building OCNGS Oyster Creek Nuclear Generating Station PA Protected Area

viii Revision 1 Acronyms and Abbreviations

pCi/g picocuries per gram pCi/L picocuries per liter QA/QC Quality Assurance/Quality Control QAPP Quality Assurance Project Plan RCA Radiologically Controlled Area RGPP Radiological Groundwater Protection Program RMA Radioactive Material Area RP Radiation Protection RWP Radiation Work P ermit ROC Radionuclide-of-Concern SAP Survey Area Plan SCP Site Characterization Plan SEB Site Emergency Building SOCA South Owner-Controlled Area SPA South Protected Area uR/h micro-Roentgen per hour V&V Verification and Validation VSP Visual Sample Plan

ix Revision 1 SECTIONONE Introduction 1 INTRODUCTION Oyster Creek Nuclear Generating Station ( OCNGS), located at 741 Route 9 South Forked River, New Jersey, is a single-unit boiling water reactor with a Mark I type containment. It is in Lacey Township, Ocean County, New Jersey, approximately two miles south of the community of Forked River. OCNGS was licensed to generate 1930 megawatts thermal (MWt). The reactor began comme rcial operation on December 23, 1969, and was licensed to Jersey Central Power and Light (JCP&L).

In 1980 General Public Utilities (parent of JCP&L) assumed responsibility for the operation of OCNGS .

The license was transferred to AmerGen on June 6, 1999, and then to Exelon Generation, LLC. on December 23, 2008. The original license was renewed to allow the unit to operate until April 9, 2029.

In February 2018, Exelon announced its plan to retire OCNGS no later than October 31, 2018, in accordance with 10 CFR 50.82(a)(l)(i) and 10 CFR 50.4(b)(8). OCNGS permanently shut down on September 17, 2018. Exelon certified to the U.S. Nuclear Regulatory Commission (NRC) that it had permanently removed fuel from the reactor vessel at Oyster Creek in accordance with 10 CFR 50.82(a)(2).

Holtec Decommissioning International, LLC (HDI) is a wholly owned subsidiary of Holtec International headquartered at the Krishna P. Singh Technology Campus, Camden, NJ. HDI functions as the licensed operator for Holtec-owned nuclear power plants. HDI provides the licensee oversight of the decommissioning work that is performed. HDIs goal for the project is to initiate the prompt decommissioning of OCNGS .

In support of the Oyster Creek decommissioning, the Oyster Creek Station Site Characterization Plan [Ref.

1] (SCP) was developed to guide site radiological characterization activities at the OCNGS site. The SCP incorporates guidance in NUREG-1575, Multi-Agency Radiation Survey, and Site Investigation Manual (MARSSIM) [ Ref. 2]. The primary objectives of the SCP were to provide guidance and a path forward for:

Closing gaps in the radiological data provided in the Oyster Creek Station Historical Site Assessment [Ref. 3] (HSA), and

the collection of quality characterization data to support future decommissioning decisions.

This report is not an end point for radiological characterization of the OCNGS site. Site characterization is an iterative process. This report only presents the radiological status of the site during the early transition phase (i.e., the time between permanent reactor shutdown and the start of implementation of the decommissioning strategy) and is based on information provided in the HSA. Radiological characterization continues during active dismantling with the objectives to:

update radiological inventory as site decontamination progresses,

provide estimates for decontamination factors, and

update input to FSS planning.

After physical dismantling, decontamination, and remediation, site characterization surveys are performed to:

demonstrate that technologies applied during decommissioning activity were adequate to achieve site release,

build confidence of stakeholders that relevant actions were successful, and

optimize input for FSS planning.

1-1 Revision 1 SECTIONONE Introduction For radiological characterization purposes, the OCNGS site was divided into nine survey areas to increase the efficiency of collecting, managing, and recording data. Boundaries for these areas were established at easily recognizable site features. Table 1-1 lists the survey areas established for the OCNGS site. The boundaries for the survey areas are shown in Figure 1-1.

The SCP followed the g uidance in NUREG-1575 to establish the Data Quality Objectives (DQOs) for th is characterization project. The project used radiation detection instrumentation, laboratory analyses, and survey designs to ensure the quality of data collected to support decommissioning decisions. Furthermore, the SCP described the approach for developing the individual Survey Area Plans (SAPs) and established the Data Quality Assessment (DQA) process for evaluating and accepting characterization data.

The BHI Site Characterization Team, shown in Figure 1-2, performed all field activities associated with the implementation of the SCP under the OCNGS Radiation Protection Program and the Health and Safety Program between July 11, 2022, and November 17, 2022.

This Characterization report provides detailed information about the radiological conditions of open land areas and building structures within the OCNGS site boundary. It includes information about the types and levels of radioactive materials.

Table 1-1 Survey Areas for the OCNGS Site Survey Area Code Approximate Area (m2)

North Owner Controlled Area - 1 NOCA1 180,100 North Owner Controlled Area - 2 NOCA2 35,700 South Owner Controlled Area - 1 SOCA1 81,700 South Owner Controlled Area - 2 SOCA2 87,900 East Owner Controlled Area EOCA1 73,300 Radiation Controlled Area RCA 22,000 North Protected Area NPA 73,900 South Protected Area SPA 51,300 Discharge Canal Area DCA 35,700

1-2 Revision 1 SECTIONONE Introduction Figure 1-1 Survey Areas Within the OCNGS Site Boundary

1.1 RADIOLOGICAL SITE CHARACTERIZATION ORGANIZATION

Figure 1-2 shows the BHI engineering site radiological characterization organization and the HDI interface.

1-3 Revision 1 SECTIONONE Introduction

Holte c-OCNGS PO C

Rad iolog ica l Engin ee ring Pr oj e ct C on t r ol s Site Ch ara cte ri za tion Proj ec t O ffs ite La bo ra tory Sc he dulin g Ma nag er (Rad iolog ica l A na lys is )

GPS/AutoCAD/Grap hic s

B HI C or po ra te Sup por t

C oun t Ro om Ma nag er SC Ra dio logic al En gine er D ata Con trol Spe cia lis t (1) ( 1) (1)

C oun t Ro om Te chn icia n

( 1)

M ob il e La bo rato ry

SC RP Su pe rv i s or Instrum ent atio n Spe cia list SC RP Su pe rv i s or (1) (1) (1)

S C RP T e ch ni ci an SC RP Tec hnic ian

( 3) ( 3)

Figure 1-2 Site Characterization Organization The roles and responsibilities of the OCNGS Site Characterization Organization are provided in section 3.1 of the SCP [Ref. 4].

1.2 RADIOLOGICAL ASSESSMENT CRITERIA Site-specific Derived Concentration Guideline Level (DCGL) values were developed to demonstrate compliance with the NRC radiological criteria for unrestricted use established in 10 CFR 20.1402.

The DCGL values developed for demonstrating compliance with the NRC unrestricted release criteria, shown in Table 1-2, were ratioed to correspond to the New Jersey Administrative Code (NJAC) 7:28 -

12.8(a)(1) dose criterion. The 15- mrem/y criterion established in the NJAC serves as the basis for the assessment criteria. The assessment criteria in Table 1-3 represent adjustments to 15 mrem/ y and were

1-4 Revision 1 SECTIONONE Introduction applied as the characterization data evaluations . In addition to their use in data assessments, the assessment criteria values have two other applications in site characterization :

Establishing the basis for required sensitivities for radiation detection instrumentation and laboratory analyses, and

Support the identification of site areas requiring remediation due to unacceptably high contamination levels.

Table 1-2 OCNGS DCGL Values by Radionuclide of Concern (ROC)

Building Building Soil Structure Soil Structure DCGL DCGL DCGL DCGL ROC (pCi/g) (dpm/100cm2) ROC (pCi/g) (dpm/100cm2)

Am-241 2.61E+01 1.65E+03 Nb-94 6.93E+00 1.85E+04 C-14 2.84E+00 6.42E+06 Ni-63 7.24E+02 1.63E+07 Cm-243 8.75E+01 2.40E+03 Np-237 1.10E+00 1.34E+03 Cm-244 4.88E+01 3.03E+03 Pu-238 2.19E+01 1.88E+03 Co-60 4.07E+00 1.35E+04 Pu-239 2.81E+01 1.70E+03 Cs-137 9.60E+00 4.70E+04 Pu-240 2.81E+01 1.70E+03 Eu-152 9.80E+00 2.71E+04 Pu-241 8.83E+02 6.75E+04 Eu-154 9.07E+00 2.56E+04 Sb-125 3.06E+01 7.52E+04 Fe-55 5.16E+04 3.85E+07 Sr-90 1.77E+00 8.14E+04 H-3 5.05E+02 2.10E+08 Tc-99 1.57E+01 5.05E+06 Mn-54 1.71E+01 5.34E+04 Table 1-3 Assessment Criteria Soil Structures Soil Structures ROC (pCi/g) (dpm/100cm2) ROC (pCi/g) (dpm/100cm2)

Am-241 1.57E+01 9.88E+02 Nb-94 4.16E+00 1.11E+04 C-14 1.70E+00 3.85E+06 Ni-63 4.35E+02 9.77E+06 Cm-243 5.25E+01 1.44E+03 Np-237 6.58E-01 8.02E+02 Cm-244 2.93E+01 1.82E+03 Pu-238 1.31E+01 1.13E+03 Co-60 2.44E+00 8.10E+03 Pu-239 1.69E+01 1.02E+03 Cs-137 5.76E+00 2.82E+04 Pu-240 1.69E+01 1.02E+03 Eu-152 5.88E+00 1.62E+04 Pu-241 5.30E+02 4.05E+04 Eu-154 5.44E+00 1.53E+04 Sb-125 1.83E+01 4.51E+04 Fe-55 3.10E+04 2.31E+07 Sr-90 1.06E+00 4.88E+04 H-3 3.03E+02 1.26E+08 Tc-99 9.42E+00 3.03E+06 Mn-54 1.03E+01 3.20E+04

1.3 SITE CHARACTERIZATION QUALITY REQUIREMENTS

1.3.1 Site Characterization Quality Assurance/Quality Control Requirements

1-5 Revision 1 SECTIONONE Introduction All quality assurance/quality control (QA/QC) requirements established by the SCP were met during the radiological characterization activities. Those QA/QC requirements were:

Characterization Sample Analyses:

QC sample analysis - a contracted commercial radioanalytical laboratory analyzed 10% of the planned volumetric samples from each survey area for gamma-emitters and Hard -to-Detect (HTD) beta-emitters.The HTD beta -emitters identified for the OCNGS are H-3, Sr-90, C-14, Fe-55, Ni-63, Tc-99, and Pu- 241. Site-wide presence of these HTD ROCs was not expected based on information in the HSA. All QC samples were analyzed for the Sr -90, C-14, Fe-55, Ni-63, and Tc-

99. Pu- 241 was included in the HTD analyses for QC samples collected in the NPA, SPA, and RCA; that is, the survey areas having the highest potential for transuranic contamination.

Duplicate sample analysis - 10% of the planned volumetric and smear samples from each survey area were sent to the on-site mobile laboratory for duplicate analysis.

Sample Control:

Samples delivered to the contracted commercial radioanalytical laboratory were controlled using a Chain of Custody (CoC) procedure and documented by a completed CoC form.

Radiation detection instruments :

All radiation detection instruments had current calibrations with the calibration date affixed to the detector and instrument. Calibrations utilize d the National Institute of Standards and Technology (NIST)-traceable radioactive sources.

Pre- and post-use operability checks for field instruments were performed and documented following approved procedures.

Contracted Commercial Laboratory:

The commercial laboratory supplying radiological analytical services possessed current National Environmental Laboratory Accreditation Program (NELAP) and New Jersey certifications.

On-Site Chemistry Trailer:

All laboratory radiation detection and counting systems used to collect characterization data were calibrated and operated following approved procedures.

Daily operability and QC checks were performed and documented as required by the applicable procedure.

1-6 Revision 1 SECTIONONE Introduction 1.3.2 Radiation Detection Instrumentation Sensitiv ity The detection sensitivity of the radiation detection instruments used for walk -over gamma scans was sufficient for detecting gamma radiation levels at the AC for Cs-137 in soil (listed in Table 1-3). SAPs specified a gamma scan speed of 6 inches per s econd while maintaining a surface -to-detector distance of 3 inches. The scan speed was reduced to 3 inches per second when the background count rate exceeded 11,000 cpm. Additionally, a slower scan speed was used at the discretion of the SC RP Supervisor when necessary to determine whether an elevated reading was truly elevated or a fluctuation in background radiation.

Section 5.6.2 of the SCP provides the equations to determine the alpha/beta scans minimum detectable concentration (MDC) values using a Ludlum Model 3003 with a 43- 68 gas proportional detector. Section 5.7 provides a detailed discussion of the MDC calculation when performing gamma scans using a Ludlum Model 3003 multi-detector survey meter with a 44- 10 NaI scintillator. MDC calculation s are maintained as project files.

1.4 LABORATORY ANALYTICAL METHODS Target detection sensitivities for laboratory analytical methods performed in the on-site chemistry trailer or by the contracted off -site commercial laboratory are 10% of the assessment criteria listed in Table 1-3. If 10% of the assessment criterion is not reasonably achievable, then laboratory methods should be capable of detecting the target ROCs at concentrations that are at least 50% of the assessment criteria. These laboratory analytical sensitivity requirements were achieved during this phase of the site characterization project.

1-7 Revision 1 SECTIONTWO Radiological Characterization of PNPS Site 2 RADIOLOGICAL CHARACTERIZATION OF OCNGS SITE

2.1 SURVEY METHODS AND TECHNIQUES Radiation Scans

Walk-over gamma scans were performed using calibrated Ludlum 3003 survey meter coupled with a 44-10 detector (or equivalent) to identify elevated radioactivity focusing on area boundaries, surface run-off collection points, and drainage and run- off paths. F ield personnel adhered to scan speeds no greater than 6 inches per second while maintaining a surface- to-detector distance of 3 inches and using an audible distinction above background as the action level. A scan speed of 3 inches per second was used when t he background count rates exceeded 11,000 counts per minute.

Alpha/Beta, radiation scans of structures and buildings at the OCNGS site were performed using:

Gas proportional detectors attached to two -channel (i.e., alpha and beta) scaler/rate meter (e.g.,

Ludlum Model 3003 or equivalent) for scans on walls and floor areas:

o Hand-held 126 cm2 gas proportional detectors (e.g., Ludlum Model 43- 68 or equivalent),

and o Cart-mounted 584 cm2 large area gas proportional detectors (e.g., Ludlum Model 43- 37 or equivalent).

Scintillation detectors attached to a two-channel (i.e., alpha and beta) scaler/rate meter (e.g.,

Ludlum Model 3002 or equivalent) for scans on roof areas not accessible with gas proportional detectors:

o Hand-held 100 cm2 Zinc Sulfide plastic scintillator detectors (e.g., Ludlum Model 43 -93 or equivalent).

Characterization field personnel relied on audible distinction above the background during the walk-over gamma and beta scans to identify areas of elevated radioactivity.

Total Radioactivity Measurements (direct measurements)

One-minute direct measurements on building and structure surfaces were performed using a hand- held 126 cm2 gas proportional detector, such as the Ludlum 3003 with 43- 68 or an equivalent device.Quarter -inch Stand -offs mounted on the detector were used to ensure a consistent source to detector geometry during direct measurements.

Removable Radioactivity Measurements

Removable surface radioactivity was assessed using cloth disc smears using a standard technique to obtain 100 cm2 samples. Smears were analyzed in the mobile laboratory for gross alpha and gross beta contamination.

2-1 Revision 1 SECTIONTWO Radiological Characterization of PNPS Site Volumetric Samples

Volumetric samples were collected using grab sample techniques. The use of hand -held split spoon samplers aided the collection of subsurface soil. S amples consisted of 4 media types; sediment, asphalt, roof gravel, and soil .

Sediment, the solid matter that settles to the bottom of a liquid, was sampled in two forms wet (DCA sediment) and dry (all other sediments). Asphalt samples were obtained in locations where a layer of asphalt covered the desired underlying sample media . Roof gravel, a layer of small stones used as a final coating to protect the roof, was sampled.

All remaining samples were soil, which is the upper layer of earth consisting of a mixture of organic remains, clay, and rock particles, and were obtained at various dep ths. To check for gross stratification, samples were obtained at multiple depths. Samples designated SOIL were taken from the top 6 inches of soil below any asphalt and/or compacted surface covering such as ro ck. Samples taken at the next depth, between 6 and 12 inches, were designated SSUB . Samples designated DEP1 were taken at depths beginning at either 6 or 12 inches and down to 4 feet below the surface. If taken, samples designated DEP2 represent depths between 4 and 8 feet.

Samples were transported to the on- site laboratory for preparation . Preparation activities included a process of weighing and drying until minimal change was detected in the sample mass. Following drying, the samples were crushed into a flowable solid consistency and placed in Marinelli containers for analysis (if appropriate). When sufficient sample volume was available, the final sample mass was between 700 and 1000 grams.

The driver for sample location selection was one of three reasons; randomly selected (generated using Visual Sample Plan (VSP)), selected as a bias location based on historical information provided by the HSA, area walk-downs, and professional judgment, or for purposes of investigating elevated scan readings at a location.

Sample Labeling

A standard technique for labeling samples was established to support data management. The technique consisted of identifiers for the survey area, sample media, sample number, and unique designators (e.g.,

identifiers for QC samples or samples requiring duplicate counts or collected during investigations).

2-2 Revision 1 SECTIONTWO Radiological Characterization of PNPS Site Labeling of samples collected from open land areas used the general convention AAA -BBBB-##-X, where:

AAA = survey area code BBBB = medium code asph = asphalt conc = concrete sedi = sediment soil = soil layer 0-6 in ssub = sub surface layer 15-30 cm dep1 = deep soil sample using geoprobe up to 4 feet depth or until resistance dep2 = deep soil sample using geoprobe beyond 4 feet depth or until resistance xxxx = used on maps only to identify multiple sample media/depths in a single location

1. = sample number X = Sample designators Blank = If no X value is listed, the sample was generated using Visual Sample Plan (VSP) .

B = Indicates a biased sample.

I = Indicates an investigative sample.

D = Indicates the sample has been selected for duplicate counting.

QC = Indicates a quality control sample .

Labeling of measurements collected f rom buildings used the general convention AAA- BBB-##-X, where:

AAA = survey area code BBB = building/structure code

1. = sample number X = Sample designators Blank = If no X designator is listed, the sample was generated using VSP.

B = Indicates a biased sample.

I = Indicates an investigative sample.

D = Indicates the smear sample has been selected for duplicate counting.

Labeling of volumetric samples collected from buildings used the general convention AAA-BBB- CCC-##,

where:

AAA = survey area code BBB = building/structure code CCC = medium code sedi = sediment

1. = sample number

2-3 Revision 1 SECTIONTWO Radiological Characterization of PNPS Site 2.2 SURVEY DESIGNS BY AREA NOCA-1, SOCA-1, and SOCA-2 Large sections in the north owner-controlled area (NOCA) and the south owner-controlled area (SOCA) are covered by trees and heavy vegetation. These areas likely have not been impacted by the historical use of radioactive materials. Due to the very low probability of residual plant -related contamination in NOCA-1, SOCA-1, and SOCA-2, the characterization surveys for these areas were designed as MARSSIM-compliant Class 3 surveys to collect sufficient quality data to confirm the preliminary Class 3 designation.

The survey designs followed the guidance in NUREG-1575. They differed from survey design s for the other OCNGS site areas by including the rigor of statistical-based random soil sampling enhanced with biased soil sampling and walk -over gamma scans.

NUREG- 1575 guidance calls for a random selection of sample locations when designing a MARSSIM Class 3 survey. The requirement for a random selection process for identifying measurement locations within these areas was satisfied using the VSP software. The VSP software also generated coordinates associated with measurement locations within the survey areas. Global Positioning System ( GPS) equipment was used to locate and stakeout measurement points in NOCA-1, SOCA-1, and SOCA -2.

Alternate locations were selected when VSP-identified soil samples could not be collected due to rock formations, wetlands, or other obstructions. The alternate locations were recorded using GPS.

EOCA-1, N OCA- 2, NPA, SPA, RCA and DCA The survey designs for EOCA -1, NOCA- 2, NPA, SPA, RCA, and DCA consisted of random and biased measurement locations. These areas contain radioactive material travel paths, deposited soil from historical site excavation activities, and wooded areas that may have been radiologically impacted by Isolation Condenser releases during operation. Random locations were selected using VSP , and the biased measurement locations were based on historical information provided by the H SA, area walk-downs, and professional judgment.

2.3 SURVEY AREA PLANS AND SITE CHARACTERIZATION PROCEDURES Eleven Survey Area Plans (SAPs) were developed as area- specific work plans to ensure efficient radiological data collection and compliance with the SCP. The SAPs are shown in Table 2-1. SAP number 11 is designated for RCA building/structure(s). Buildings and structures in this area are scheduled for demolition. Characterization of remaining structure(s), if appropriate, will be scheduled.

2-4 Revision 1 SECTIONTWO Radiological Characterization of PNPS Site Table 2-1 Summary of Survey Area Plans SAP Survey Area Number Designator Planned Samples and Measurements 01 NOCA1 Gamma scans at boundaries and 1 m2 scans at each survey open land area location.

Twenty-five samples from 15 random and 8 bias locations (23 surface soil and 2 deep samples) 02 NOCA2 Gamma scans at boundaries and 1 m2 scans at each survey open land area location.

Ten samples from 4 biased locations (3 asphalt, 3 so il, 3 deep, and 1 sediment sample).

03 SOCA1 Gamma scans at boundaries and 1 m2 scans at each survey open land area location.

Twenty-three samples at 15 random and 7 bias ed locations.

(22 soil and 1 asphalt sample).

04 SOCA2 Gamma scans at boundaries and 1 m 2 scans at each survey open land area location.

Fifteen soil samples collected from 15 random sample locations.

05 EOCA1 Gamma scans at boundaries and 1 m2 scans at each survey open land area location.

Forty-four samples from 13 random and 13 bias ed sample locations (39 soil, 4 sediment s, and 1 asphalt sample ).

06 NPA Gamma scans at boundaries and 1 m2 scans at each survey open land area location.

Eighteen samples from fifteen biased locations. (8 soil, 7 sediments, 1 asphalt, and 2 de ep samples).

07 NPA Alpha/Beta scans of 10% of the floor/roof surfaces and 1 m2 building/structure(s) scans at survey floor/roof and wall locations.

Low-Level Rad Waste Structure:

Two hundred fifty samples from 160 random and 90 biased measurement locations.

Warehouse:

One hundred forty-nine samples from 90 random and 59 biased locations.

Demin Storage Tank:

Thirteen samples from 13 random locations.

2-5 Revision 1 SECTIONTWO Radiological Characterization of PNPS Site SAP Survey Area Number Designator Planned Samples and Measurements 08 SPA Gamma scans at boundaries and 1 m2 scans at each survey open land area location.

Twenty-one samples from 16 biased locations (15 soil, 3 asphalt, 2 deep, and 1 sediment sample).

09 SPA Alpha/Beta scans of 10% of the floor/roof surfaces and 1 m2 building/structure(s) scans at survey floor/roof and wall locations.

Oyster Creek Admin Building:

One hundred fifty- five samples total (100 random and 55 biased locations)

Site Emergency Building:

One hundred sixty-five samples total (125 random and 40 biased locations)

New Gatehouse Facility Sixty samples total (45 random and 15 biased locations) 10 RCA Gamma scans at boundaries and 1 m2 scans at each survey open land area location.

Thirty-five samples from 19 biased locations (17 soil, 8 asphalt, 3 sediment, 1 subsurface, and 6 deep sample locations).

12 DCA Seven samples from 7 biased locations (7 sediment sample open land area locations).

BHI site characterization staff utilized the following procedures:

ENG- OP-001, Radiation Survey Performance

ENG- OP-002, Volumetric, and Material Sampling

ENG- OP-003, Chain of Custody for Transferring Samples

ENG- OP-007, Determination of the Number and Locations for Survey Measurements

ENG- OP-011, Use of The Ludlum 3003 Multi-Detector Survey Meter

ENG- OP-012, Operation of the Ludlum 3002 Digital Survey Meter

ENG- OP-026, Operation, and Calibration of the iMATIC

ENG- OP-032, GENIE-2000 Gamma Spectroscopy System Calibration

ENG- OP-033, GENIE-2000 Gamma Spectroscopy System Operation

ENG- OP-034, Operation of LEICA FLX100 GPS

ENG- OP-40, Laboratory Balances

RP-AA-800, Control, Inventory, and Leak Testing of Radioactive Sources

2-6 Revision 1 SECTIONTWO Radiological Characterization of PNPS Site

RP-OC-220-1003, Operation of the iMatic

SA-AA-117, Excavation, Trenching, and Shoring

SA-AA-122, Handling and Storage of Compressed Gas Cylinders

2.4 BHI MOBILE CHEMISTRY LABORATORY The mobile laboratory and dedicated laboratory personnel were provided to expedite the turnaround of characterization sample analyses and increase the SC project s overall efficiency. The laboratory is equipped with the following analytical equipment:

One iMatic automatic sample changer,

Three HPGe gamma spectroscopy systems, and

Isolated sample preparation area within the laboratory.

Staffing for the trailer consisted of a Chemistry Manager and one Chemistry technician. All RCA samples were prepared in the OCNGS hot chemistry laboratory to prevent cross-contamination of the mobile laboratory.

2-7 Revision 1 SECTIONTHREE Radiological Findings

3 RADIOLOGICAL FINDINGS The SC Project Manager and Radiological Engineers performed the DQA process described in the SCP to ensure the data s quality. The DQA process included the following verification and validation steps:

Verify the collection of the planned number and types of measurements.

Validate the detection sensitivities achieved during laboratory analyses.

Verify pro cedural adherence.

Verify the use of calibrated instrumentation .

Evaluate data against assessment criteria. C omparisons were made directly to the acceptance criteria without consider ation of the background.

Determine the range, mean, standard deviations, and estimates for the percentage of removable contamination of area data sets.

Verify that QC and duplicate sample requirements were met, including evaluating comparisons of QC and duplicate sample results.

During the review of Co-60 and Cs-137 results, the decision logic shown in Table 3-1 was applied.

Table 3-1 Decision Logic for Evaluating Survey Area Data

Range of Analytical Results

Area Nuclide Lower Upper Actions to Consider Classification Concentration Concentration

Class 3 Co-60 Non-Detect1* Retain Classification of Cs-137 Non- Detect 1 0.244 pCi/g 0.576 pCi/gMARSSIM Class 3 Area

> 0.244 pCi/g 1.22 pCi/g

Retain Classification of Class 2 Co-60 Cs-137 > 0.576 pCi/g 2.88 pCi/gMARSSIM Class 2 Area

Evaluate for HTD beta-emitters

Retain Classification of Class 1 Co-60 > 1.22 pCi/g 2.44 pCi/gMARSSIM Class 1 Area Cs-137 > 2.88 pCi/g 5.76 pCi/g

Evaluate for HTD alpha/beta-emitters

> 2.44 pCi/g

Ressaonf Class 1 Co-60 Cs-137 > 5.76 pCi/g RSSIM Cls 1rea

Consider Remediation

1 - Results reported as less than the achieved MDC values for Co-60 and Cs-137 were considered non -detects.

3-1 Revision 1 SECTIONTHREE Radiological Findings Agreement between on- site and off-site gamma analyse s was demonstrated using the NRC inspection procedure 84525, Quality Assurance and Confirmatory M easurements for In-Plant Radiochemical Analysis

[Ref. 4].

The instrument information used in the DQA process can be found in Table 3-2. The conversion of the logged count rates to activity allowed for comparing the in -field reading to the assessment criteria for structures listed in Table 1-3 .

Table 3-2 Field Instrument ation Information Instrument Library Type Serial Number Instrument Efficiency Calibration Instrument Detector Beta Alpha Gamma Due Date 3002/43-93 25022547 PR401534 0.1062 0.1987 8/18/23 3002/43-93 25022557 PR402520 0.08 0.1588 8/18/23 3002/43-93 25022558 PR402523 0.1066 0.1888 8/18/23 3002/43-93 25022571 PR402538 0.0897 0.1687 8/18/23 3002/43-93 25022574 PR402505 0.0958 0.1735 8/18/23 3002/43-93 25022587 PR402511 0.0882 0.1718 8/18/23 3003/44-10 25022620 PR404285 0.104 5/17/23 3003/43-68 25022620 PR172197 0.153 0.14 5/17/23 3003/43-68 25022620 PR178495 0.184 0.18 5/17/23 3003/44-10 25022629 PR404293 0.086 5/17/23 3003/43-68 25022629 PR160699 0.173 0.13 5/17/23 3003/43-68 25022629 PR180706 0.188 0.116 5/17/23 3003/43-37 25022631 PR161289 0.2785 0.1531 5/12/23 3003/43-37 25022631 PR401384 0.2923 0.1698 5/12/23 3003/44-10 25022635 PR404290 0.086 5/17/23 3003/43-68 25022635 PR177614 0.184 0.187 5/17/23 3003/43-68 25022635 PR177611 0.176 0.179 5/17/23 3003/43-37 25022636 PR401383 0.2981 0.1705 5/13/23 3003/43-37 25022636 PR190281 0.265 0.1649 5/13/23 3003/44-10 25022643 PR404287 0.1 5/17/23 3003/43-68 25022643 PR190221 0.185 0.168 5/17/23 3003/43-68 25022643 PR190242 0.183 0.17 5/17/23

3-2 Revision 1 SECTIONTHREE Radiological Findings 3.1 NOCA-1 (SAP 01 - OPEN LAND)

3.1.1 Area Description NOCA- 1 is north of the Protected Area; it includes the intake canal and is illustrated in Figure 3-1. It is 180,123 m2 in size and covered with trees and vegetative growth. Low -lying areas are wet, as indicated by cattails growing in the area. There are no plant structures within the NOCA-1 area. The HSA preliminarily classified this as an impacted area. Approximately 1000 cubic yards of radiologically clean construction debris (soil, brush, concrete, and asphalt) from the Design Basis Threat (DBT) project was placed here in 2007. Sandblast grit was discovered in the NOCA-1 area. However, the HSA does not state if the grit was from sandblasting of contaminated materials. NOCA-1 is not likely to be impacted by D&D activities ;

therefore, its radiological status is not expected to change.

3.1.2 Survey Summary Survey Dates : 8/24/2022 through 9/28/2022

Survey and field activities were governed by SAP 01, North Owner Controlled Area-1. Survey planning for the NOCA- 1 area included using the VSP program to identify 15 random sample locations consistent with MARSSIM methodology. In addition, The Radiological Engineer selected 8 biased locations where radioactivity from other areas may have been introduced due to plant-related activities. The sample locations are illustrated in Figure 3-1.

Three of the random sample locations were relocated (NOCA1 -SOIL-08, -09, and -10 ) due to the original locations being in the intake canal area. During sampling, alternative sample locations were selected from nearby areas where representative soil samples could be safely collected. BHI recorded GPS coordinates for the alternate sample locations to document the new locations.

A total of 30 samples were obtained from the NOCA-1 area: 23 surface soil samples (15 random and 8 bias locations), 2 sediment samples (1 random and 1 bias location) , 2 asphalt samples (1 random and 1 bias location), and 3 samples at depths greater than 6 in (all bias sample locations) . Asphalt samples were obtained from locations where the soil was covered by asphalt (NOCA1- ASPH-03 and NOCA1- ASPH B). GPS coordinates for as-taken sample locations are listed in Table 3-3 .

Two of the samples obtained at depths greater than 6 in (NOCA1-DEP1-17-B and NOCA1-DEP1-18-B) were selected based on the belief that potentially contaminated soil and/or sandblasting grit had been placed there based on aerial photographs. At the client's request, the third sample was obtained at depths greater than 6 in (NOCA1-DEP1-23-B). This request was based on the sample location where contaminated soil had been deposited and piled.

Walk-over gamma scans at the NOCA-1 boundaries were performed using calibrated Ludlum Model 44-10 detector pairings with Model 3003 multi- detector survey meters. The scans were based on professional judgment, focusing on areas of potential migration of radioactivity into or out of the survey area. Gamm a scan measurements were also conducted at each sample location. Count rates were observed between 4,100 and 11,500 cpm at sample locations in the NOCA- 1 area. A total of 173 m2 were scanned. The gamma scans did not identify a reas with an audible distinction above the location background count rate.

3-3 Revision 1 SECTIONTHREE Radiological Findings Table 3-3 GPS Coordinates for Sample Locations in the NOCA-1 Survey Area Sample Location Easting Northing NOCA1-SOIL-01 574662.7273 358569.9082 NOCA1-SOIL-02 575572.2446 359409.8478 NOCA1-SOIL-03-QC 574094.279 357263.3355 NOCA1-SOIL-04 574549.0376 358943.2147 NOCA1-SOIL-05-D 574321.6583 358383.255 NOCA1-SOIL-06 575231.1756 359223.1946 NOCA1-SOIL-07 575236.5048 358787.6703 NOCA1-SOIL-08: Original location coordinates 574099.6082 357387.7710 Sample relocation coordinates 574284.3636 357446.4080 NOCA1-SOIL-09: Original location coordinates 574554.3668 359067.6502 Sample relocation coordinates 574591.6753 359020.6040 NOCA1-SOIL-10: Original location coordinates 574895.4358 359347.6301 Sample relocation coordinates 574952.9818 359246.6146 NOCA1-SOIL-11-QC 574213.2978 358880.997 NOCA1-SOIL-12 574668.0565 358321.0372 NOCA1-SOIL-13 575577.5738 359160.9768 NOCA1-SOIL-14D 573929.0737 357761.0775 NOCA1-SOIL-15 574838.591 358601.0171 NOCA1-SOIL-16-B 575375.2112 358580.8871 NOCA1-SOIL-17-B 575312.8426 358634.9662 NOCA1-DEP1-17-B NOCA1-SOIL-18-B 575256.7897 358620.7556 NOCA1-DEP1-18-B NOCA1-SOIL-19-B-D 575175.9485 358477.4286 NOCA1-SOIL-20-B-QC 574881.7451 358406.9308 NOCA1-SOIL-21-B 574573.6641 358311.4534 NOCA1-SOIL-22-B 574258.6444 357989.2174 NOCA1-SOIL-23-B 574046.2985 357240.4575

3-4 Revision 1 SECTIONTHREE Radiological Findings

Figure 3-1 NOCA-1 Survey Area and Sampl e Locations

3-5 Revision 1 SECTIONTHREE Radiological Findings 3.1.3 Survey Data Summary Discussion Cesium-137 concentrations were less than the achieved MDC values for most NOCA-1 samples. However, Cs-137 was detected at concentrations greater than the MDC values in 5 samples (NOCA1-SOIL-07, NOCA1-SOIL-18-B, NOCA1 -SOIL-23-B, NOCA1-SEDI-22-B, and NOCA1-D EP1-23-B). The 5 samples were comprised of 3 surface soil samples, 1 sediment sample, and 1 deep subsurface soil sample.

Results can be seen in Table 3-4, Table 3-5, and Table 3-7 , respectively. The positive findings are all less than 1.60E- 01 pCi/g, which is less than 27% of the Class 3 AC for Cs -137. The low Cs-137 concentrations may be attributable to the movement of potentially contaminated soil, site runoff, or fallout from gaseous effluent releases. Table 3-6 provides the results for the asphalt samples.

In contrast, Co- 60 concentration results were all below the achieved MD C values. The Co-60 MDC values ranged from 2.71E- 02 pCi/g to 8.00E- 02 pCi/g, indicating that, if present in NOCA1, Co- 60 contamination would likely not be widespread or exceed a small fraction of the Class 3 AC for Co -60.

The presence of HTD b eta-emitting ROCs (i.e., Sr-90, C-14, Fe-55, Ni-63, and Tc -99) in the NOCA1 survey area was evaluated using analytical results for the QC samples transferred to the off-site laboratory.

As shown in Table 3-14, the results did not identify any HTD beta- emitting ROC above the MDC value.

3-6 Revision 1 SECTIONTHREE Radiological Findings Table 3-4 On -Site Laboratory Gamma Analysis Results for NOCA1 Surf ace Soil Samples

So il Sample Gamma Spe c - D at a Q ualit y A s s e s s me nt Surv e y A re a: NOCA1 N umbe r o f Sample s : 23 Initial Clas s ific atio n: Class 3 R e s ult C o mparis o n Co-60 Cs -137 A c hie ve d A c hie ve d Measured MD C AC Measured MD C AC A c t iv it y V a lu e Exceeded Da ta V a lu e Exceeded Sample # ( pC i/g) ( pC i/g) (Y/N) ( pC i/g) ( pC i/g) (Y/N)

NOCA1-SOIL-1 - 1. 51E- 02 3. 65E- 02 N 6. 37E- 02 9. 72E- 02 N NOCA1-SOIL-2 - 1. 67E- 02 7. 33E- 02 N 3. 42E- 02 6. 34E- 02 N NOCA1-SOIL-3-QC 3. 52E- 03 3. 35E- 02 N - 2. 13E- 02 5. 38E- 02 N NOCA1-SOIL-4 2. 41E- 03 3. 14E- 02 N 2. 29E- 03 5. 48E- 02 N NOCA1-SOIL-5-D 2. 15E- 02 4. 02E- 02 N 8. 80E- 03 5. 81E- 02 N NOCA1-SOIL-6 9. 88E- 03 4. 94E- 02 N 3. 81E- 02 9. 72E- 02 N NOCA1-SOIL-7 1. 09E- 02 4. 13E- 02 N 1. 47E- 01 5. 43E- 02 N NOCA1-SOIL-8 2. 11E- 03 2. 71E- 02 N 2. 90E- 03 5. 83E- 02 N NOCA1-SOIL-9 2. 90E- 02 6. 07E- 02 N - 1. 66E- 02 6. 56E- 02 N NOCA1-SOIL-10 7. 69E- 03 4. 70E- 02 N 4. 58E- 02 8. 51E- 02 N NOCA1-SOIL-11-QC 6. 87E- 03 4. 86E- 02 N 4. 01E- 02 7. 58E- 02 N NOCA1-SOIL-12 2. 66E- 02 4. 81E- 02 N 6. 73E- 02 1. 05E- 01 N NOCA1-SOIL-13 8. 12E- 04 5. 71E- 02 N 4. 23E- 02 1. 15E- 01 N NOCA1-SOIL-14-D 1. 90E- 02 4. 85E- 02 N - 1. 05E- 02 7. 11E- 02 N NOCA1-SOIL-15 4. 90E- 03 5. 65E- 02 N 3. 17E- 02 8. 71E- 02 N NOCA1-SOIL-16-B 1. 65E- 02 5. 49E- 02 N 2. 19E- 02 5. 87E- 02 N NOCA1-SOIL-17-B 4. 65E- 03 4. 81E- 02 N 8. 19E- 03 5. 97E- 02 N NOCA1-SOIL-18-B 1. 08E- 02 4. 01E- 02 N 8. 13E- 02 4. 39E- 02 N NOCA1-SOIL-19-B-D - 1. 07E- 02 4. 13E- 02 N 2. 61E- 02 7. 28E- 02 N NOCA1-SOIL-20-B-QC 1. 11E- 02 4. 58E- 02 N 4. 88E- 02 8. 54E- 02 N NOCA1-SOIL-21-B 2. 09E- 02 5. 47E- 02 N 3. 84E- 02 8. 09E- 02 N NOCA1-SOIL-22-B 3. 60E- 02 4. 84E- 02 N - 1. 90E- 03 7. 35E- 02 N NOCA1-SOIL-23-B 2. 42E- 02 4. 82E- 02 N 1. 55E- 01 6. 21E- 02 N A ve r a ge 9. 86E- 03 3. 71E- 02 SD 1. 34E- 02 4. 49E- 02 Data Range - 1. 67E- 02 to 3. 60E- 02 - 2. 13E- 02 to 1. 55E- 01

3-7 Revision 1 SECTIONTHREE Radiological Findings Table 3-5 On -Site Laboratory Gamma Analysis Results for NOCA1 Sediment Samples

Table 3-6 On -Site Laboratory Gamma Analysis Results for NOCA1 Asphalt Samples

A s phalt Sample Gamma Spe c - D at a Q ualit y A s s e s s me nt Surv e y A re a: NOCA1 N umbe r o f Sample s : 2 Initial Clas s ific atio n: Class 3 R e s ult C o mparis o n Co-60 Cs -137 Measured A c hie ve d AC Measured A c hie ve d AC A c t iv it y MDC Value Exceeded Da ta MDC Value Exceeded Sample # (pCi/g) (pCi/g) (Y/N) ( pC i/g) ( pC i/g) (Y/N)

NOCA1-ASP H-3 2. 33E- 02 6. 36E- 02 N 2. 00E- 02 6. 60E- 02 N NOCA1-ASP H-22B 2. 23E- 03 5. 03E- 02 N 1. 98E- 02 6. 21E- 02 N A ve r a ge 1. 28E- 02 1. 99E- 02 SD 1. 49E- 02 1. 41E- 04 Data Range 2. 23E- 03 to 2. 33E- 02 1. 98E- 02 to 2. 00E- 02

3-8 Revision 1 SECTIONTHREE Radiological Findings Table 3-7 On -Site Laboratory Gamma Analysis Results for NOCA -1 Deep Subsurface Soil Samples

D e e p C o mpo s it e So il Sample Gamma Spe c - D at a Q ualit y A s s e s s me nt Surv e y A re a: NOCA1 N umbe r o f Sample s : 3 Initial Clas s ific atio n: Class 3 R e s ult C o mparis o n Co-60 Cs -137 Measured A c hie ve d AC Measured A c hie ve d AC A c t iv it y MDC Value Exceeded Da ta MDC Value Exceeded Sample # ( pC i/g) ( pC i/g) (Y/N) ( pC i/g) ( pC i/g) (Y/N)

N O C A 1- D EP 1 B 8. 37E- 03 6. 27E- 02 N 2. 81E- 02 6. 49E- 02 N N O C A 1- D EP 1 B 9. 91E- 03 6. 29E- 02 N 1. 03E- 02 7. 86E- 02 N N O C A 1- D EP 1 B 2. 32E- 02 5. 78E- 02 N 1. 02E- 01 6. 36E- 02 N A ve r a ge 1. 38E- 02 4. 68E- 02 SD 8. 15E- 03 4. 86E- 02 Data Range 8. 37E- 03 to 2. 32E- 02 1. 03E- 02 to 1. 02E- 01

3.1.4 Data Quality Comparisons

On-Site Duplicate Counts The comparisons of the Cs -137 and Co- 60 results for the duplicate samples NOCA1 -SOIL-5-D, NOCA1 -

SOIL-14-D, and NOCA1-SOIL-19-B-D are shown in Table 3-8, Table 3-9, and Table 3-10, respectively.

All comparisons were found acceptable. Agreement is assumed when results are below the achieved MDC value.

3-9 Revision 1 SECTIONTHREE Radiological Findings Table 3-8 Duplicate Sample Analysis for NOCA1 -SOIL-05-D

Table 3-9 Duplicate Sample Analysis for NOCA SOIL-14-D

3-10 Revision 1 SECTIONTHREE Radiological Findings Table 3-10 Duplicate Sample Analysis for NOCA1 -SOIL-19-B-D

On-Site / Off -Site Laboratory Comparisons The comparisons of the Cs -137 and Co- 60 results for QC samples NOCA1-SOIL-03-QC, NOCA1-SOIL-11-QC, and NOCA1-SOIL-20-B-QC are shown in Table 3 -11, Table 3-12, and Table 3-13, respectively.

All comparisons were found acceptable. Agreement is assumed when results are below the achieved MDC value.

3-11 Revision 1 SECTIONTHREE Radiological Findings Table 3-11 On -Site/Off-Site Sample Analysis for NOCA1 -SOIL-03-QC

3-12 Revision 1 SECTIONTHREE Radiological Findings Table 3-12 On -Site/Off-Site Sample Analysis for NOCA1 -SOIL-11-QC

Table 3-13 On -Site/Off-Site Sample Analysis for NOCA1 -SOIL-20-B-QC

3-13 Revision 1 SECTIONTHREE Radiological Findings

Off-Site Laboratory HTD Analyses Table 3-14 Off -Site Laboratory Results for HTDs in NOCA-1 QC Samples HTD Measured Achieved AC Sample Number Medium Beta (pCi/g) MDC Exceeded (pCi/g) (Y/N)

Sr-90 -1.70E-02 7.35E-02 N C-14 -7.45E-02 1.05E+00 N NOCA1-SOIL-03-QC SoilFe-551.27E+011.97E+02N Ni-63 5.21E+00 1.88E+01 N Tc-99 -7.48E-02 2.19E+00 N Sr-90 2.61E-02 8.28E-02 N C-14 -4.00E-02 1.07E+00 N NOCA1-SOIL-11-QC SoilFe-55-1.65E+012.00E+02N Ni-63 -7.22E+00 3.29E+01 N Tc-99 -1.83E-01 2.18E+00 N Sr-90 3.89E-02 4.96E-02 N C-14 -3.68E-01 1.05E+00 N NOCA1-SOIL-20-B-QC SoilFe-553.77E+011.21E+02 N Ni-63 7.43E+00 3.12E+01 N Tc-99 -2.39E-01 2.18E+00 N

3.1.5 Survey Plan Deviation(s)

Three sample points required relocation due to safety concerns. The original VSP-determined sample points NOCA1-SOIL-08, -09, and -10 were locations covered by the water of the intake canal. Each of the 3 sample points was relocated to the nearest accessible location on the bank/berm of the canal.

3.1.6 Survey Area Investigations None.

3.1.7 Survey Area Conclusions The following conclusions were reached for the NOCA-1 area:

MARSSIM Class 3 designation is appropriate for the NOCA-1 survey area.

Excavation or remediation of soil within the NOCA-1 area is not likely within this area to meet the site release criteria.

3-14 Revision 1 SECTIONTHREE Radiological Findings 3.2 NOCA- 2 (SAP 02 - OPEN LAND)

3.2.1 Area Description NOCA- 2 (aka North Parking Lot) is the area immediately north of the Protected Area and is illustrated in Figure 3-2. It is 35,667 m 2 in size and is currently covered with an asphalt parking lot. In 1982 GPU Nuclear received NRC approval to relocate approximately 17,000 cubic feet of contaminated soil under §20.302.

The disposal method was burial in shallow trenches below a minimum cover of six inches of clean soil.

The area within the NOCA- 2 boundary has been preliminarily classified as Class 1 due to the burial of this material.

3.2.2 Survey Summary Survey Dates: 9/8/2022

Survey and field activities were governed by SAP 02 , North Owner Controlled Area-2. Survey planning for the NOCA-2 area identified 4 sample locations where plant-related radioactivity m ight have been introduced from other areas. One sample location was relocated (NOCA2-XXX- 04-B) due to the presence of underground utilities and could not be safel y collected as planned. An a lternative sample location w as selected close to the original l ocation and where a representative sample could be safely collected . GPS coordinates for this alternate sample location were recorded during sampling to document the new locations.

The sample locations are shown in Figure 3-2.

A total of 10 samples were obtained from the NOCA -2 area: 3 surface soil samples, 1 sediment sample, 3 asphalt samples, and 3 at depths greater than 6 in. All samples collected were from biased locations.

Asphalt samples were obtained at locations where the soil was covered by asphalt (NOCA2-ASPH-02-B, -

03-B, and B). GPS coordinates for as-taken sample locations are listed in Table 3-15.

Sediment sample location NOCA2 -SEDI-01-B was chosen due to the presence of a storm drain that could potentially collect runoff from the surrounding area.

Samples obtained at depths greater than 6 in (NOCA2- DEP1-02-B, B, and B) were selected based on information from the HSA regarding the on- site disposal of approximately 17,000 cubic feet of contaminated soil buried in shallow trenches within the NOCA2 boundary.

Walk-over gamma scans were conducted at the N OCA-2 boundaries. They were performed using calibrated Ludlum Model 44- 10 detectors with Model 3003 multi- detector survey meters to identify any areas of concern or potential migration of radioactivity beyond the survey area. Gamma scans were also conducted at each sample location. A total of 154 m2 were scanned. The observed background c ount rates ranged between 11,200 and 30,500 cpm. Nearby external sources influenced the count rate observed in several locations in this area.The s cans did not identify areas with an audible distinction above the location background count rate.

3-15 Revision 1 SECTIONTHREE Radiological Findings Table 3-15 GPS Coordinates for Sample Collection Locations in the NOCA-2 Survey Area Sample Number Easting Northing NOCA2-SEDI-01-B-D 575096.6836 358443.5636 NOCA2-ASPH-02-B NOCA2-SOIL-02-B 574907.5087 358358.6976 NOCA2-DEP1-02-B NOCA2-ASPH-03-B NOCA2-SOIL-03-B-QC 574702.6765 358211.0408 NOCA2-DEP1-03-B NOCA2-ASPH-04-B: Original location coordinates 574550.8564 358106.9594 NOCA2-SOIL-04-B: Sample relocation coordinates 574555.9538 358108.8321 NOCA2-DEP1-04-B

Figure 3-2 NOCA-2 Survey Area and Sample Locations

3-16 Revision 1 SECTIONTHREE Radiological Findings 3.2.3 Survey Data Summary Discussion

Cesium-137 concentrations were less than the achieved MDC values for most NOCA-2 samples. However ,

Cs-137 and Co-60 were detected at concentrations greater than the MDC values in one sample (NOCA2-SEDI-01-B-D), and Cs-137 was detected at a concentration greater than the MDC value in one sample (NOCA- DEP1-02-B) as seen in Table 3-19.

The deep soil sample was collected at a depth range of 6 inches to 4 ft.; the on- site gamma analysis report shows the Cs -137 concentration to be 4.75E-01 pCi/g, which is less than 9% of the Class 1 AC for Cs -137 (5.76E+00 pCi/g), as seen in Table 3-16. The asphalt and surface soil samples collected directly above the deep sample showed Cs- 137 concentrations below the achieved MDC values. The Cs-137 concentration in the deep sample is potentially from the residual contamination associated with the NRC -approved relocation of contaminated site soil to the NOCA -2 area in 1982 prior to the expansion of the North Parking Lot.

The sediment sample from the storm drain sample contained detectable Cs- 137 and Co- 60 at 1.07E-01 pCi/g and 6.51E-02 pCi/g, respectively. The activity concentration is less than 6% of the Class 1 AC for Co-60 and Cs-137, as seen in Table 3-17. P ositive findings were not wholly unexpected because the storm drain is a collection point for site runoff that may have contain ed fallout from gaseous effluent releases.

The Co-60 concentrations in the asphalt (Table 3-18), surface soil (Table 3-16), and deep soil samples were below the achieved MDC values, which ranged from 4.66E-02 pCi/g to 9.81E-02 pCi/g indicating that if present in NOCA-2, Co-60 contamination would likely not be widespread or exceed a small fraction of the Class 1 AC for Co-60.

The presence of HTD beta -emitting ROCs (i.e., Sr -90, C-14, Fe-55, Ni-63, and Tc-99) in the NOCA-2 survey area was evaluated using analytical results for the QC samples transferred to the off -site laboratory.

The results of those analyses (provided in Table 3-22) did not identify any HTD beta-emitting ROC above the MDC value achieved during the analyses.

3-17 Revision 1 SECTIONTHREE Radiological Findings Table 3-16 On -Site Laboratory Gamma Analysis Results for NOCA-2 Surface Soil Samples

Table 3-17 On -Site Laboratory Gamma Analysis Results for NOCA- 2 Sediment Samples

3-18 Revision 1 SECTIONTHREE Radiological Findings Table 3-18 On -Site Laboratory Gamma Analysis Results for NOCA-2 Asphalt Samples

Table 3-19 On -Site Laboratory Gamma Analysis Results for NOCA- 2 Deep Soil Samples

3-19 Revision 1 SECTIONTHREE Radiological Findings 3.2.4 Data Quality Comparisons

On-Site Duplicate Counts The comparisons of the Cs-137 and Co- 60 results for the duplicate sample NOCA2-SEDI-01-B-D are shown in Table 3 -20. The comparisons were found acceptable.

Table 3-20 Duplicate Sample Analysis for NOCA2 -SEDI-01-B-D

On-Site / Off-Site Laboratory Comparisons The comparisons of the Cs-137 and Co- 60 results for the QC sample NOCA2-SOIL-03-B-QC are shown in Table 3-21. T he comparisons were found acceptable. Agreement is assumed when results are below the achieved MDC value.

3-20 Revision 1 SECTIONTHREE Radiological Findings Table 3-21 On -Site/Off-Site Sample Analysis for NOCA2-SOIL-3-B-QC

Off-Site Laboratory HTD Analyses Table 3-22 Off -Site Laboratory Results for HTDs in NOCA-2 QC Sample HTD Measured Achieved AC Sample Number Medium Beta (pCi/g) MDC Exceeded (pCi/g) (Y/N)

Sr-90 6.47E-02 8.22E-02 N C-14 1.11E-01 5.89E-01 N NOCA2-SOIL-03-B-QC SoilFe-559.91E+01 1.44E+02 N Ni-63 -1.79E+00 2.70E+01 N Tc-99 -3.36E-02 9.42E-01 N

3.2.5 Survey Plan Deviations One sample point required relocation due to safety concerns. Sample point NOCA2-XXX-04 was located over underground utilities. The sample point was relocated to the nearest accessible location.

3.2.6 Survey Area Investigations None.

3-21 Revision 1 SECTIONTHREE Radiological Findings 3.2.7 Survey Area Conclusions The following conclusions were reached for the NOCA-2 area:

Excavation of the contaminated soil relocated in 1982 under the North Parking is not likely necessary, as indicated by the low Cs- 137 concentration in the deep soil sample (i.e., a measured concentration of less than 10% of the Cs-137 AC). The measured Cs-137 and Co- 60 concentrations in NOCA- 2 samples indicate that the area meets MARSSIM Class 3 criteria.

MARSSIM Class 1 designation is appropriate for the NOCA -2 survey area: basis (waste storage location).

3-22 Revision 1 SECTIONTHREE Radiological Findings 3.3 SOCA-1 (SAP 03 - OPEN LAND)

3.3.1 Area Description SOCA- 1 is south of the Protected Area and North of the discharge canal, illustrated in Figure 3-3. It is 81,656 m2 in size and includes the south parking lot, with the rest of the ar ea covered with trees, vegetative growth, and wetlands. Other than the parking lot, there are no plant structures within the SOCA -1 area.

Although the HSA indicates that SOCA -1 is an impacted area, there is no current or known historical use of radioactive material. SOCA-1 is not likely to be impacted by D&D activities; therefore, its radiological status is not expected to change.

3.3.2 Survey Summary Survey Dates: 8/29/2022 through 9/28/2022

Survey and field activities were governed by SAP 03, South Owner Controlled Area-1. Survey planning for the SOCA-1 area included using the VSP program to identify 15 random sample locations consistent with MARSSIM methodology. In addition, 7 biased locations were selected by the Radiological Engineer as locations where plant-related radioactivity may have been introduced from other areas. The sample locations are shown in Figure 3-3 .

Three of the random sample locations were relocated due to the original location being within wetland areas (SOCA1-SOIL-10 and SOCA1-SOIL-12) and the inability to access due to a thorn thicket that made safe passage not possible (SOCA1-SOIL-06-D).N earby areas where representative soil samples could be collected were selected as alternative sample points. GPS coordinates for the se alternate sample locations were recorded during sampling to document the new locations.

Asphalt samples were obtained where the soil was covered by asphalt (SOCA1 -ASPH-07 and SOCA1-ASPH-14). A total of 24 samples were obtained from the SOCA-1 area: 22 surface soil samples (15 random and 7 bias samples) and 2 asphalt samples. GPS coordinates for the sample locations are listed in Table 3-23.

Walk-over gamma scans were conducted at the SOCA -1 boundaries. They were performed using calibrated pairings of Ludlum Model 44- 10 detectors with Model 3003 multi-detector survey meters to identify any areas of elevated radioactivity. A total of 152 m2 were scanned. Gamma scan measurements were also conducted at each sample location. Count rates were between 2,800 and 6,550 cpm at sample locations in the SOCA1 area. Scans did not identif y areas with an audible distinction above the location background count rate.

3-23 Revision 1 SECTIONTHREE Radiological Findings Table 3-23 GPS Coordinates for Sample Locations in the SOCA-1 Survey Area

Sample Number Easting Northing SOCA1-SOIL-01 575462.3613 356726.8083 SOCA1-SOIL-02-D 575935.8707 356521.5801 SOCA1-SOIL-03 575699.116 357137.2647 SOCA1-SOIL-04 575225.6066 356624.1942 SOCA1-SOIL-05-QC 576172.6254 356932.0365 SOCA1-SOIL-06-D: Original location coordinates 575580.7387 356453.1707 Sample relocation coordinates 575587.6946 356448.5329 SOCA1-ASPH-07 575107.2293 356761.013 SOCA1-SOIL-07 SOCA1-SOIL-08 576054.2481 357068.8553 SOCA1-SOIL-09 574870.4745 356555.7848 SOCA1-SOIL-10: O riginal location coordinates 575817.4934 356863.6271 Sample relocation coordinates575856.7035 356878.9469 SOCA1-SOIL-11 576291.0028 356658.3989 SOCA1-SOIL-12: Original location coordinates 575995.0594 356673.601 Sample relocation coordinates 575945.5869 356582.4727 SOCA1-SOIL-13-QC 575758.3047 356468.3728 SOCA1-SOIL-14-D 575284.7953 356776.2151 SOCA1-SOIL-15-QC 575639.9273 356878.8292 SOCA1-SOIL-16-B 575564.3788 356879.1818 SOCA1-SOIL-17-B 575222.1222 356759.9735 SOCA1-SOIL-18-B 575053.4665 356707.3417 SOCA1-SOIL-19-B 574894.1677 356614.4759 SOCA1-SOIL-20-B 574879.6647 356593.8910 SOCA1-SOIL-21-B 575658.6151 357094.4778 SOCA1-SOIL-22-B 575965.7508 357208.1624

3-24 Revision 1 SECTIONTHREE Radiological Findings

Figure 3-3 SOCA-1 Survey Area and Sample Locations

3.3.3 Survey Data Summary Discussion

Cesium-137 concentrations were less than the achieved MDC values for most SOCA- 1 samples. However, Cs-137 and Co- 60 were detected at concentrations greater than the MDC values in one sample ( SOCA1-SOIL-22-B); and Cesium-137 only was detected at a concentration greater than the MDC value in fi ve additional samples (SOCA1- SOIL-3, SOCA1-SOIL -4, SOCA1-SOIL -8, SOCA1-SOIL -9, and SOCA1 -

SOIL -10 ).

The positive Cs-137 findings are all less than 2.46E-01 pCi/g, which is less than 43% of the Class 3 A C for Cs-137 (5.76E-01 pCi/g). The positive Co- 60 finding is less than 1.07E- 01 pCi/g, which is less than 44 %

of the Class 3 AC for Co -60 (2.44E-01 pCi/g). These results are shown in Table 3-24.Table 3 -25 provides the results for the asphalt samples.

The sample containing Cs -137 and Co- 60, SOCA1- SOIL-22-B, was collected from a culvert/drain outlet that receives runoff from the parking lot in the southeast corner of the EOCA-1 survey area. Samples containing the highest Cs-137 concentrations, SOCA1 -SOIL-09 and SOCA1 -SOIL-10, were collected in a washout area at the southwest corner of SOCA1. This location was subject to runoff from the SPA and wet

3-25 Revision 1 SECTIONTHREE Radiological Findings decomposing organic material. There is no record of current or historical use of radioactive materials in the SOCA1 survey area.

The presence of HTD beta- emitting ROCs (i.e., Sr-90, C-14, Fe-55, Ni-63, and Tc-99) in the S OCA1 survey area was evaluated using analytical results for the QC samples transferred to the off-site laboratory. As shown in Table 3 -32, the results did not identify any HTD beta-emitting ROC above MDC.

Table 3-24 On -Site Laboratory Gamma Analysis Results for SOCA-1 Surface Soil Samples

So il Sample Gamma Spe c - D at a Q ualit y A s s e s s me nt Surv e y A re a: SOCA1 N umbe r o f Sample s : 22 Initial Clas s ific atio n: Class 3 R e s ult C o mparis o n Co-60 Cs -137 A c hie ve d A c hie ve d Measured MD C AC Measured MD C AC A c t iv it y V a lu e Exceeded Da ta V a lu e Exceeded Sample # ( pC i/g) ( pC i/g) (Y/N) ( pC i/g) ( pC i/g) (Y/N)

SOCA1-SOIL-1 6. 39E- 03 5. 65E- 02 N 1. 14E- 02 7. 96E- 02 N SOCA1-SOIL-2-D 1. 25E- 02 6. 01E- 02 N 3. 93E- 02 9. 06E- 02 N SOCA1-SOIL-3 1. 07E- 02 4. 24E- 02 N 4. 74E- 02 4. 68E- 02 N SOCA1-SOIL-4 8. 38E- 03 4. 74E- 02 N 4. 43E- 02 4. 17E- 02 N SOCA1-SOIL-5-QC 5. 01E- 03 3. 01E- 02 N 2. 10E- 02 6. 46E- 02 N SOCA1-SOIL-6-D 1. 77E- 02 5. 55E- 02 N 4. 10E- 02 8. 67E- 02 N SOCA1-SOIL-7 1. 36E- 02 5. 16E- 02 N 2. 64E- 02 6. 91E- 02 N SOCA1-SOIL-8 1. 24E- 02 4. 32E- 02 N 6. 88E- 02 3. 63E- 02 N SOCA1-SOIL-9 9. 22E- 03 4. 50E- 02 N 2. 24E- 01 5. 42E- 02 N SOCA1-SOIL-10 3. 18E- 03 5. 80E- 02 N 2. 46E- 01 7. 30E- 02 N SOCA1-SOIL-11 1. 13E- 02 5. 44E- 02 N 4. 97E- 02 8. 17E- 02 N SOCA1-SOIL-12 1. 45E- 02 5. 18E- 02 N 4. 43E- 02 5. 21E- 02 N SOCA1-SOIL-13-QC 2. 67E- 02 5. 83E- 02 N 3. 36E- 02 7. 74E- 02 N SOCA1-SOIL-14-D - 2. 83E- 02 4. 48E- 02 N 2. 44E- 02 7. 34E- 02 N SOCA1-SOIL-15-QC 2. 70E- 02 6. 28E- 02 N 3. 19E- 02 8. 72E- 02 N SOCA1-SOIL-16-B 1. 20E- 02 5. 01E- 02 N - 1. 42E- 02 7. 31E- 02 N SOCA1-SOIL-17-B 1. 81E- 02 5. 20E- 02 N - 2. 08E- 02 6. 62E- 02 N SOCA1-SOIL-18-B 2. 71E- 02 3. 72E- 02 N - 8. 16E- 02 5. 78E- 02 N SOCA1-SOIL-19-B 1. 89E- 03 5. 75E- 02 N 4. 61E- 02 6. 31E- 02 N SOCA1-SOIL-20-B 9. 24E- 03 6. 69E- 02 N 5. 22E- 02 8. 74E- 02 N SOCA1-SOIL-21-B 1. 46E- 02 5. 52E- 02 N 4. 68E- 02 9. 39E- 02 N SOCA1-SOIL-22-B 1. 07E- 01 9. 68E- 02 N 1. 94E- 01 1. 27E- 01 N A ve r a ge 1. 55E- 02 5. 35E- 02 SD 2. 33E- 02 7. 57E- 02 Data Range - 2. 83E- 02 to 1. 07E- 01 - 8. 16E- 02 to 2. 46E- 01

3-26 Revision 1 SECTIONTHREE Radiological Findings Table 3-25 On -Site Laboratory Gamma Analysis Results for SOCA-1 Asphalt Samples

3.3.4 Data Quality Comparisons

On-Site Duplicate Counts The comparisons of the Cs-137 and Co-60 results for the duplicate samples SOCA1 -SOIL-02-D, SOCA1-SOIL-06-D, and SOCA1-SOIL-14-D are shown in Table 3 -26, Table 3-27, and Table 3 -28 respectively.

All comparisons were found acceptable. Agreement is assumed when results are below the achieved MDC value, respectively.

Table 3-26 Duplicate Sample Analysis for SOCA1 -SEDI D

3-27 Revision 1 SECTIONTHREE Radiological Findings Table 3-27 Duplicate Sample Analysis for SOCA1 -SEDI-06-D

Table 3-28 Duplicate Sample Analysis for SOCA1 -SEDI-14-D

3-28 Revision 1 SECTIONTHREE Radiological Findings On-Site/Off-Site Laboratory Comparisons The comparisons of the Cs-137 and Co-60 results for the QC samples SOCA1-SOIL-05-QC, SOCA1-SOIL-13-QC, and SOCA1- SOIL-15-QC are shown in Table 3-29, Table 3-30, and Table 3-31, respectively.

All comparisons were found acceptable. Agreement is assumed when results are below the achieved MDC value.

For sample SOCA1-SOIL-15-QC the off-site laboratory analysis showed detectable Cs-137 activity at an activity concentration below the on- site laboratorys MDC value. The agreement is assumed because the off-site laboratorys reported Cs -137 concentration falls between the on- site and the off-site laboratorys MDC values.

Table 3-29 On -Site/Off-Site Sample Analysis for SOCA1-SOIL-05-QC

3-29 Revision 1 SECTIONTHREE Radiological Findings Table 3-30 On -Site/Off-Site Sample Analysis for SOCA1-SOIL-13-QC

Table 3-31 On -Site/Off-Site Sample Analysis for SOCA1-SOIL-15-QC

3-30 Revision 1 SECTIONTHREE Radiological Findings Off-Site Laboratory HTD Analyses Table 3-32 Off -Site Laboratory Results for HTDs in SOCA-1 QC Samples HTD Measured Achieved AC Sample Number Medium Beta (pCi/g) MDC Exceeded (pCi/g) (Y/N)

Sr-90 -1.24E-02 6.81E-02 N C-14 -1.48E-01 6.14E-01 N SOCA1-SOIL-05-QC SoilFe-55-3.78E+011.43E+02N Ni-63 -2.94E-01 2.85E+01 N Tc-99 4.82E-01 1.51E+00 N Sr-90 2.91E-02 7.75E-02 N C-14 -2.34E-01 6.09E-01 N SOCA1-SOIL-13-QC SoilFe-557.73E+011.97E+02N Ni-63 -9.56E+00 2.85E+01 N Tc-99 6.63E-01 1.28E+00 N Sr-90 5.09E-02 7.84E-02 N C-14 -3.41E-01 6.03E-01 N SOCA1-SOIL-15-QC SoilFe-557.76E+011.47E+02N Ni-63 1.10E+00 2.38E+01 N Tc-99 7.31E-01 9.42E-01 N

3.3.5 Survey Plan Deviations Three sample points required relocation due to safety concerns. Sample points SOCA1-SOIL-06-D, -10, and -12 were randomly located by VSP in wetland areas or other environmental hazards. Sample points were relocated to the nearest accessi ble location on the bank/berm of the canal.

3.3.6 Survey Area Investigations None.

3.3.7 Survey Area Conclusions The following conclusions were reached for the SOCA -1 area :

MARSSIM Class 3 designation is appropriate for the SOCA-1 survey area.

Excavation or remediation of soil within the SOCA1 area is likely not necessary for the area to meet site release criteria.

3-31 Revision 1 SECTIONTHREE Radiological Findings 3.4 SOCA-2 (SAP 04 - OPEN LAND)

3.4.1 Area Description SOCA-2 is the small parcel of land south of the Discharge Canal, illustrated in Figure 3-4 . It is 87, 957 m2 in size and includes a roadway, with the rest of the area covered with trees, vegetative growth, and wetlands.

There are no plant structures within the SOCA-2 area. T he HSA ide ntifies SOCA- 2 is an impacted area, with no current or known historical use of radioactive material. The SOCA-2 is not likely to be impacted by D&D activities, and its radiological status is not expected to change.

3.4.2 Survey Summary Survey Dates: 9/8/2022 through 9/28/2022

Survey activities were governed by SAP 04, South Owner Controlled Area-2 . Survey planning for the SOCA- 2 area included using the VSP program to identify 15 random sample locations consistent with MARSSIM methodology. The sample locations are shown in Figure 3-4.

Four sample locations were relocated because the original location was within wetland areas (SOCA2-SOIL-04, SOCA2-SOIL-09, SOCA2-SOIL-11, and SOCA2-SOIL-15). Nearby areas where representative soil samples could be collected were selected as alternative sample points. GPS coordinates for these alternate sample locations were recorded during sampling to document the new locations.

A total of 15 random surface soil samples were obtained from the S OCA-2 area. GPS coordinates for as-taken sample locations are listed in Table 3 -33.

Walk-over gamma scans were conducted at the SOCA-2 boundaries. They were performed using calibrated pairings of Ludlum Model 44- 10 detectors with Model 3003 multi- detector survey meters to identify the presence of elevated radioactivity in runoff collection areas at the SOCA-2 boundaries and each sample location. A total of 105 m 2 were scanned. The c ount rates logged during the gamma scans ranged between 2,800 and 6,670 cpm .Scans did not identify areas with audible distinction above the location background count rates.

3-32 Revision 1 SECTIONTHREE Radiological Findings Table 3-33 GPS Coordinates for Sample Locations in the SOCA-2 Survey Area Sample Number Easting Northing SOCA2-SOIL-01 575507.8392 356250.8371 SOCA2-SOIL-02 576107.0965 355929.4815 SOCA2-SOIL-03-D 574608.9531 356411.5149 SOCA2-SOIL-04: Original location coordinates 575208.2105 356090.1593 Sample relocation coordinates 575213.1507 356044.9800 SOCA2-SOIL-05 574065.8761 357054.226 SOCA2-SOIL-06-QC 576163.2769 356000.8939 SOCA2-SOIL-07 576013.4626 356215.1309 SOCA2-SOIL-08-D 575713.8339 355893.7753 SOCA2-SOIL-09: Original location coordinates 575039.6693 355947.3346 Sample relocation coordinates 575122.3388 355924.0927 SOCA2-SOIL-10 574290.5976 356911.4013 SOCA2-SOIL-11: Original location coordinates 575489.1124 356108.0124 Sample relocation coordinates 575506.8941 356025.79302 SOCA2-SOIL-12 575788.741 356179.4247 SOCA2-SOIL-13-QC 575002.2157 356232.9840 SOCA2-SOIL-14 576050.9162 356072.3062 SOCA2-SOIL-15: Original location coordinates 575152.0301 355804.5099 Sample relocation coordinates 575129.1989 355828.0233

3-33 Revision 1 SECTIONTHREE Radiological Findings

Figure 3-4 SOCA-2 Survey Area and Sampl e Locations

3.4.3 Survey Data Summary Discussion

Cesium-137 concentrations were less than the achieved MDC values for just over 50% of the SOCA -2 samples (8 of 15). However, Cs -137 was detected at concentrations greater than the MDC values in 7 samples, SOCA2- SOIL-1, SOCA2-SOIL-4, SOCA2-SOIL-7, SOCA2-SOIL-9 , SOCA2-SOIL-12, SOCA2-SOIL-13-QC, and SOCA2-SOIL-14. Although Cs -137 concentrations were less than the achieved MDC values for 8 EOCA-1 samples, it was detected at low concentrations above the MDC values in 7 soil samples. The positive Cs-137 findings ranged from 5.85E-2 pCi/g to 1.63E-1 pCi/g, which falls below 29% of the Class 3 AC for Cs -137 (5.76E-01 pCi/g). The results can be seen in Table 3-34. The low Cs-137 concentrations may be attributable to fallout from gaseous effluent releases or the potential presence of background Cs-137.

3-34 Revision 1 SECTIONTHREE Radiological Findings In contrast, Co- 60 concentration results were all below the achieved MDC values. The Co -60 MDC values ranged from 2.71E-02 pCi/g to 8.00E-02 pCi/g, indicating that, if present in NOCA1, Co- 60 contamination would likely not be widespread or exceed a small fraction of the 2.44E-01 pCi/g Class 3 AC for Co-60.

The presence of HTD beta- emitting ROCs (i.e., Sr-90, C-14, Fe-55, Ni-63, and Tc-99) in the SOCA2 survey area was evaluated using analytical results for the QC samples transferred to the off-site laboratory. As shown in Table 3-25, HTD beta -emitting ROCs were not identified above the MDC .

Table 3-34 On -Site Laboratory Gamma Analysis Results for SOCA-2 Surface Soil Samples

So il Sample Gamma Spe c - D at a Q ualit y A s s e s s me nt Surv e y A re a: SOCA2 N umbe r o f Sample s : 15 Initial Clas s ific atio n: Class 3 R e s ult C o mparis o n Co-60 Cs -137 A c hie ve d A c hie ve d Measured MD C AC Measured MD C AC A c t iv it y V a lu e Exceeded Da ta V a lu e Exceeded Sample # ( pC i/g) ( pC i/g) (Y/N) ( pC i/g) ( pC i/g) (Y/N)

SOCA2-SOIL-1 1. 57E- 02 3. 88E- 02 N 1. 62E- 01 5. 70E- 02 N SOCA2-SOIL-2 1. 56E- 02 5. 49E- 02 N 1. 79E- 02 8. 95E- 02 N SOCA2-SOIL-3-D 1. 45E- 02 4. 44E- 02 N 7. 68E- 02 9. 97E- 02 N SOCA2-SOIL-4 1. 55E- 02 5. 58E- 02 N 7. 73E- 02 3. 12E- 02 N SOCA2-SOIL-5 3. 35E- 02 6. 29E- 02 N 4. 13E- 02 9. 04E- 02 N SOCA2-SOIL-6-QC 9. 70E- 03 3. 40E- 02 N 4. 09E- 02 8. 84E- 02 N SOCA2-SOIL-7 1. 66E- 02 3. 66E- 02 N 1. 63E- 01 5. 99E- 02 N SOCA2-SOIL-8-D 2. 85E- 02 6. 43E- 02 N 1. 23E- 02 7. 65E- 02 N SOCA2-SOIL-9 5. 27E- 03 4. 61E- 02 N 5. 85E- 02 4. 28E- 02 N SOCA2-SOIL-10 2. 95E- 02 6. 87E- 02 N 6. 10E- 02 6. 35E- 02 N SOCA2-SOIL-11 1. 13E- 02 6. 71E- 02 N 4. 15E- 02 6. 41E- 02 N SOCA2-SOIL-12 - 2. 63E- 03 2. 81E- 02 N 1. 03E- 01 3. 74E- 02 N SOCA2-SOIL-13-QC 1. 48E- 02 3. 03E- 02 N 7. 54E- 02 3. 77E- 02 N SOCA2-SOIL-14 1. 83E- 02 2. 95E- 02 N 1. 25E- 01 4. 96E- 02 N SOCA2-SOIL-15 6. 49E- 03 3. 76E- 02 N 4. 00E- 02 4. 24E- 02 N A ve r a ge 1. 55E- 02 7. 31E- 02 SD 9. 51E- 03 4. 69E- 02 Data Range - 2. 63E- 03 to 3. 35E- 02 1. 23E- 02 to 1. 63E- 01

3.4.4 Data Quality Comparisons

On-Site Duplicate Counts The comparisons of the Cs -137 and Co- 60 results for the duplicate samples SOCA2- SOIL-03-D and SOCA2- SOIL-08-D are shown in Table 3-35 and Table 3-36, respectively. All comparisons were found acceptable. Agreement is assumed when results are below the achieved MDC value.

3-35 Revision 1 SECTIONTHREE Radiological Findings Table 3-35 Duplicate Sample Analysis for SOCA2 -SOIL-03-D

Table 3-36 Duplicate Sample Analysis for SOCA2 -SOIL-08-D

3-36 Revision 1 SECTIONTHREE Radiological Findings On-Site/Off-Site Laboratory Comparisons The comparisons of the Cs- 137 and Co- 60 results for the QC samples SOCA2-SOIL-06-QC and SOCA2-SOIL-13-QC are shown in Table 3-37 and Table 3-38, respectively. MDC All comparisons were found acceptable. Agreement is assumed when results are below the achieved MDC value.

For sample SOCA2- SOIL-06-QC the off-site laboratory analysis showed detectable Cs- 137 activity at an activity concentration below the on- site laboratorys MDC value. Agreement is assumed because the off-site laboratorys reported Cs -137 concentration falls between the on- site and the off-site laboratorys MDC values.

Table 3-37 On -Site/Off-Site Sample Analysis for SOCA2-SOIL-06-QC

3-37 Revision 1 SECTIONTHREE Radiological Findings Table 3-38 On -Site/Off-Site Sample Analysis for SOCA2-SOIL-13-QC

Off-Site Laboratory HTD Analyses Table 3-39 Off Ste Laboratory Results for HTDs in SOCA-2 QC Samples HTD Measured Achieved AC Sample Number Medium Beta (pCi/g) MDC Exceeded (pCi/g) (Y/N)

Sr-90 2.08E-02 7.82E-02 N C-14 -9.40E-02 6.15E-01 N SOCA2-SOIL-06-QC SoilFe-55-9.93E+011.77E+02N Ni-63 -8.56E+00 2.60E+01 N Tc-99 3.47E-01 1.57E+00 N Sr-90 1.61E-02 1.07E-01 N C-14 -1.81E-02 6.08E-01 N SOCA2-SOIL-13-QC SoilFe-551.34E-011.58E+02 N Ni-63 -8.98E+00 3.14E+01 N Tc-99 6.77E-01 1.75E+00 N

3.4.5 Survey Plan Deviations Four sample points required relocation due to safety concerns. Sample points SOCA2- SOIL-04, -09, -11, and -15 were randomly located by VSP in wetland areas.Sample points were relocated to the nearest accessible location .

3-38 Revision 1 SECTIONTHREE Radiological Findings 3.4.6 Survey Area Investigations None.

3.4.7 Survey Area Conclusions The following conclusions were reached for the SOCA-2 area:

MARSSIM Class 3 designation is appropriate for the SOCA-2 survey area.

Excavation or remediation of soil within the SOCA-2 area is likely not necessary for the area to meet site release criteria.

3-39 Revision 1 SECTIONTHREE Radiological Findings 3.5 EOCA-1 (SAP 05 - OPEN LAND)

3.5.1 Area Description EOCA- 1 is the eastern portion of the Owner Controlled area. It has a 73,337 m2 footprint covered with trees, vegetative growth, and asphalt asphalt-covered parking lots. It includes the Northeast P arking Lot, the Main Parking Lot, the East wooded area, and small sections of the North and South Wooded Area, as illustrated in Figure 3-5 . The HSA classifies the East Wooded Area and Northeast and Main Parking Lots as a MARSSIM Class 2 area due to potential contamination releases from the isolation condensers and historical uses as a travel path for radioactive shipments. The HSA classifies the small sections of the North and South Wooded Areas as MARSSIM Class 3. Other than tr avel routes, EOCA1 is not likely to be impacted by D&D activities . Therefore, its radiological status is not expected to change in the future.

3.5.2 Survey Summary Survey Date: 9/12/2022 through 9/15/2022 Survey and field activities were governed by SAP 05, East Owner Controlled Area-1. Planners of the EOCA-1 SAP suspected that the North Wooded Area (EOCA-1A) and the East Wooded Area and South Wooded Area (EOCA-1B) would meet MARSSIM Class 3 criteria . The refore, survey planning included using VSP to identify 30 random sample locations consistent with MARSSIM methodology in the EOCA-1A and EOCA-1B areas (15 random samples in each area). During the walk- downs, 13 biased locations were identified for the remaining EOCA area .The boundaries of EOCA-1A and -1B and sample locations are shown in Figure 3-5.

A total of 44 samples were obtained from E OCA-1: 39 surface soil samples, 4 sediment samples, and 1 asphalt sample. GPS coordinates for as-taken sample locations are listed in Table 3-40.These samples were obtained in the following areas:

EOCA- 1A - 15 soil samples - Samples EOCA1 -SOIL-01 through EOCA1 -SOIL-15.

EOCA- 1B - 15 soil s amples - Samples EOCA1 -SOIL-16 through EOCA1-SOIL-30.

Northeast and Main Parking Lots - 9 soil samples, 4 sediment samples, and 1 asphalt sample -

Samples EOCA1-SOIL-31 through EOCA1- SOIL-43. An asphalt sample EOCA1- ASPH-41-B was obtained where the soil was covered by asphalt. The sediment samples, EOCA1-SEDI-35-B through EOCA1- SEDI-38-B, were in the vicinity of 4 storm drains in the southeastern employee parking lot.

Walk-over gamma scans were conducted at the E OCA-1 boundaries . They were performed using calibrated pairings of Ludlum Model 44- 10 detectors with Model 3003 multi- detector survey meters to identify the presence of elevated radioactivity. Gamma scan measurements were also conducted at each sample location. A total of 393 m 2 were scanned. Count rates were logged between 3,540 and 29,100 cpm at sample locations in the EOCA-1 area. The highest measurement was due to the proximity to the ISFSI pad.

Scans identified no areas with an audible distinction above the location background count rate.

3-40 Revision 1 SECTIONTHREE Radiological Findings Table 3-40 GPS Coordinates for Sample Locations in the EOCA-1 Survey Area Sample Number Easting Northing EOCA1-SOIL-01 575681.4927 358282.9458 EOCA1-SOIL-02-D 575605.8223 358451.3582 EOCA1-SOIL-03 575662.5751 358507.4957 EOCA1-SOIL-04 575586.9048 358226.8083 EOCA1-SOIL-05 575624.7399 358251.7583 EOCA1-SOIL-06-QC 575631.8340 358307.8958 EOCA1-SOIL-07 575556.1637 358476.3082 EOCA1-SOIL-08 575707.5044 358195.6208 EOCA1-SOIL-09 575518.3285 358364.0332 EOCA1-SOIL-10-QC 575669.6692 358532.4457 EOCA1-SOIL-11 575499.4109 358438.8832 EOCA1-SOIL-12-QC 575650.7516 358158.1958 EOCA1-SOIL-13 575575.0813 358326.6083 EOCA1-SOIL-14 575612.9164 358551.1582 EOCA1-SOIL-15 575641.2928 358457.5957 EOCA1-SOIL-16 575727.8106 357726.3475 EOCA1-SOIL-17-QC 575951.8306 357585.5233 EOCA1-SOIL-18 575802.4839 357839.0069 EOCA1-SOIL-19 576101.1774 357416.5342 EOCA1-SOIL-20 575914.4940 357923.5014 EOCA1-SOIL-21 575765.1472 357501.0288 EOCA1-SOIL-22 575690.4739 358007.9959 EOCA1-SOIL-23 575839.8206 357538.5819 EOCA1-SOIL-24-D 575895.8256 357623.0764 EOCA1-SOIL-25 575746.4789 357876.5600 EOCA1-SOIL-26-D 576045.1723 357454.0874 EOCA1-SOIL-27 575671.8055 357707.5709 EOCA1-SOIL-28-QC 575634.4689 357820.2303 EOCA1-SOIL-29 575783.8156 357651.2413 EOCA1-SOIL-30 575709.1422 357482.2522 EOCA1-SOIL-31-B 575493.9878 357124.2337 EOCA1-SOIL-32-B 575559.0088 357423.4646 EOCA1-SOIL-33-B-D 575580.9836 357369.4031 EOCA1-SOIL-34-B-QC 575936.9564 357466.3570 EOCA1-SEDI-35-B 575861.3894 357384.6116 EOCA1-SEDI-36-B 575983.2947 357415.9790 EOCA1-SEDI-37-B 575901.0740 357264.3698 EOCA1-SEDI-38-B 576018.4642 357298.1135 EOCA1-SOIL-39-B 575612.5887 357535.2703 EOCA1-SOIL-40-B 575556.0323 357854.1725

3-41 Revision 1 SECTIONTHREE Radiological Findings Sample Number Easting Northing EOCA1-ASPH-41-B 575228.1001 358437.0839 EOCA1-SOIL-41-B EOCA1-SOIL-42-B-QC 575480.0000 358237.0000 EOCA1-SOIL-43-B 575346.2032 358527.8593

Figure 3-5 EOCA-1 Survey Area and Sampl e Locations

3-42 Revision 1 SECTIONTHREE Radiological Findings 3.5.3 Survey Data Summary:

Discussion Twenty-eight of the 44 samples collected from EOCA-1 contained low concentrations of Cs-137.

Fifteen samples were collected from the EOCA-1A area (EOCA1-SOIL-1 through EOCA1- SOIL-15), 9 contained low concentrations of Cs-137. The results are provided in Table 3 -41. The positive Cs-137 results ranged from 4.93E-02 pCi/g to 2.49E-01 pCi/g, which is less than 9 % of the AC for Cs -137 (2.88E+00 pCi/g). Co-60 was not detected in the EOCA-1A soil samples.

Fifteen samples were collected from EOCA- 1B (EOCA1-SOIL-16 through EOCA1 -SOIL-30), 12 contained low concentrations of Cs-137. The positive Cs -137 results ranged from 4.12E-02 pCi/g to 2.18E-1 pCi/g, which is less than 8% of the Class 2 AC for Cs-137. Co -60 was not detected in the EOCA -1B soil samples. The results are p rovided in Table 3 -41.

Thirteen samples were collected from 13 locations in the remaining EOCA1 area 8 soil, 4 sediments, and 1 asphalt. The soil sample results are provided in Table 3-41, the sediment samples in Table 3-42, and the asphalt result is in Table 3-43. Six soil samples contained low levels of Cs -137. The positive Cs- 137 results ranged from 6.96E-02 pCi/g to 2.85E-01 pCi/g, which is less than 10% of the Class 2 AC for Cs -137. Co-60 was not detected in any of the samples.

One of the 4 sediment samples collected around the drains in the employee parking lot (EOCA1- SEDI B) contained low concentrations of Cs- 137 and Co-60. However, the measured Cs-137 and Co-60 concentrations were small percentages of the respective Class 2 ACs (less than 3% and 10%, respectively).

Results for the other 3 sediment samples confirmed that widespread contamination is not present in the lot.

The asphalt sample results are provided in Table 3-42.

The presence of HTD beta- emitting ROCs (i.e., Sr -90, C-14, Fe-55, Ni-63, and Tc-99) in the EOCA-1 survey area was evaluated using analytical results for the QC samples transferred to the off -site laboratory.

As shown in Table 3-56, those analyses did not identify any HTD beta-emitting ROC above the MDC value achieved during the analyses.

3-43 Revision 1 SECTIONTHREE Radiological Findings Table 3-41 On -Site Laboratory Gamma Analysis Results for EOCA-1 Surface Soil Samples

3-44 Revision 1 SECTIONTHREE Radiological Findings

Table 3-42 On -Site Laboratory Gamma Analysis Results for EOCA-1 Sediment Samples

Se dime nt ( SE D I ) Sample Gamma Spe c - D at a Q ualit y A s s e s s me nt Surv e y A re a: EOCA1 N umbe r o f Sample s : 4 Initial Clas s ific atio n: Class 2 R e s ult C o mparis o n Co-60 Cs -137 Measured A c hie ve d AC Measured A c hie ve d AC A c t iv it y MDC Value Exceeded Da ta MDC Value Exceeded Sample # ( pC i/g) ( pC i/g) (Y/N) ( pC i/g) ( pC i/g) (Y/N)

EOCA1-SEDI-35-B 1. 13E- 01 2. 91E- 02 N 6. 60E- 02 5. 78E- 02 N EOCA1-SEDI-36-B 2. 82E- 02 6. 25E- 02 N 2. 43E- 02 6. 90E- 02 N EOCA1-SEDI-37-B 6. 28E- 02 8. 56E- 02 N 3. 66E- 02 6. 41E- 02 N EOCA1-SEDI-38-B 2. 25E- 02 6. 99E- 02 N 1. 08E- 02 6. 33E- 02 N A ve r a ge 5. 66E- 02 3. 44E- 02 SD 4. 16E- 02 2. 35E- 02 Data Range 2. 25E- 02 to 1. 13E- 01 1. 08E- 02 to 6. 60E- 02

3-45 Revision 1 SECTIONTHREE Radiological Findings Table 3-43 On -Site Laboratory Gamma Analysis Results for EOCA-1 Asphalt Samples

3.5.4 Data Quality Comparisons

On-Site Duplicate Counts The comparisons of the Cs-137 and Co- 60 results for the duplicate samples EOCA1 -SOIL-02-D, EOCA1 -

SOIL-20-D, EOCA1-SOIL-24-D, EOCA1-SOIL-26-D, and EOCA1 -SOIL-33-B-D are shown in Table 3-44, Table 3-45, Table 3-46 , Table 3-47, and Table 3-48 respectively. All comparisons were found acceptable. Agreement is assumed when results are less than the achieved MDC value.

Table 3-44 Duplicate Sample Analysis for EOCA1 -SOIL-02-D

3-46 Revision 1 SECTIONTHREE Radiological Findings Table 3-45 Duplicate Sample Analysis for EOCA1 -SOIL-20-D

Table 3-46 Duplicate Sample Analysis for EOCA1 -SOIL-24-D

3-47 Revision 1 SECTIONTHREE Radiological Findings Table 3-47 Duplicate Sample Analysis for EOCA1 -SOIL-26-D

Table 3-48 Duplicate Sample Analysis for EOCA1 -SOIL-33-B-D

3-48 Revision 1 SECTIONTHREE Radiological Findings On-Site/Off-Site Laboratory Comparisons The comparisons of the Cs-137 and Co- 60 results for the QC samples EOCA1-SOIL-06-QC, EOCA1-SOIL-10-QC, EOCA1-SOIL QC, EOCA1-SOIL-17-QC, EOCA1-SOIL-28-QC, EOCA1-SOIL-34-B-QC, and EOCA1-SOIL-42-B-QC are shown in Table 3-49, Table 3-50, Table 3-51, Table 3-52, Table 3-53, Table 3-54, and Table 3-55 respectively. All comparisons were found acceptable. Agreement is assumed when results are less than the achieved MDC value.

For sample EOCA1-SOIL-12-QC the off-site laboratory analysis showed detectable Cs- 137 activity at an activity concentration below the on- site laboratorys MDC value. Agreement is assumed because the Cs-137 concentration reported off-site laboratory falls between the on-site and the off -site laboratorys MDC values.

Table 3-49 QC Sample Analysis for EOCA1 -SOIL-06-QC

3-49 Revision 1 SECTIONTHREE Radiological Findings Table 3-50 QC Sample Analysis for EOCA1 -SOIL-10-QC

Table 3-51 QC Sample Analysis for EOCA1 -SOIL-12-QC

3-50 Revision 1 SECTIONTHREE Radiological Findings Table 3-52 QC Sample Analysis for EOCA1 -SOIL-17-QC

Table 3-53 QC Sample Analysis for EOCA1 -SOIL-28-QC

3-51 Revision 1 SECTIONTHREE Radiological Findings Table 3-54 QC Sample Analysis for EOCA1 -SOIL-34-B-QC

Table 3-55 QC Sample Analysis for EOCA1 -SOIL-42-B-QC

3-52 Revision 1 SECTIONTHREE Radiological Findings Off-Site Laboratory HTD Analyses Table 3-56 Off -Site Laboratory Results for HTDs in EOCA-1 QC Samples HTD Measured Achieved AC Sample Number Medium Beta (pCi/g) MDC Exceeded (pCi/g) (Y/N)

Sr-90 4.96E-02 9.83E-02 N C-14 -2.73E-01 1.06E+00 N EOCA1-SOIL-06-QC SoilFe-559.72E+001.47E+02N Ni-63 -4.24E+00 3.35E+01 N Tc-99 2.05E-01 2.30E+00 N Sr-90 6.23E-03 4.91E-02 N C-14 -3.31E-02 1.05E+00 N EOCA1-SOIL-10-QC SoilFe-551.32E+021.99E+02N Ni-63 4.55E+00 3.99E+01 N Tc-99 4.79E-01 2.20E+00 N Sr-90 2.23E-02 7.60E-02 N C-14 7.44E-02 1.06E+00 N EOCA1-SOIL-12-QC SoilFe-552.58E+011.08E+02N Ni-63 -8.04E+00 2.59E+01 N Tc-99 1.00E+00 2.16E+00 N Sr-90 5.10E-03 6.12E-02 N C-14 4.90E-01 1.08E+00 N EOCA1-SOIL-17-QC SoilFe-551.17E+022.47E+02N Ni-63 -9.24E-01 3.67E+01 N Tc-99 1.27E+00 2.13E+00 N Sr-90 -4.40E-03 7.97E-02 N C-14 1.17E-02 6.14E-01 N EOCA1-SOIL-28-QC SoilFe-556.32E+012.42E+02N Ni-63 -4.05E+00 2.25E+01 N Tc-99 1.29E+00 1.86E+00 N Sr-90 -1.88E-03 5.92E-02 N C-14 1.70E-01 1.06E+00 N EOCA1-SOIL-34-B-QC SoilFe-551.09E+021.87E+02 N Ni-63 -4.35E+00 3.53E+01 N Tc-99 3.20E+00 3.54E+00 N Sr-90 2.74E-02 4.13E-02 N C-14 2.25E-03 6.12E-01 N EOCA1-SOIL-42-B-QC SoilFe-55-5.18E+001.03E+02 N Ni-63 -1.11E+01 2.55E+01 N Tc-99 -4.45E-03 1.70E+00 N

3-53 Revision 1 SECTIONTHREE Radiological Findings 3.5.5 Survey Plan Deviation(s)

Four sample points required relocation due to safety concerns. Sample points SOCA2-SOIL-04, -09, -11, and -15 were randomly located by VSP in wetland areas. Sample points were relocated to the nearest accessible location on the bank/berm of the water hazard .

3.5.6 Survey Area Investigations None.

3.5.7 Survey Area Conclusions The following conclusions were reached in the EOCA1 area :

MARSSIM Class 2 designation is appropriate for the waste travel routes within the EOCA -1 boundary .

EOCA- 1A and EOCA-1B should be established as separate MARSSIM Class 3 areas. Residual plant-related contamination in the survey area meets the criteria in NUREG -1575 for a MARSSIM Class 3 area.

Excavation or remediation of soil within EOCA1 Class 3 areas is likely not necessary to meet site release criteria.

3-54 Revision 1 SECTIONTHREE Radiological Findings 3.6 NPA (SAP 06 - OPEN LAND)

3.6.1 Area Description NPA is north of the Radiologically Controlled Area (RCA) inside the Protect ed Area (PA). It includes the area between the RCA and the north parking lot and is illustrated in Figure 3-6. Its 73,931 m2 footprint consists of asphalt -covered roadways, concrete pads, buildings, and structures. The NPA has been located outside the RCA since 1979. When the NPA was situated inside the RCA, it was used to store trucks, boxes, and equipment. S everal locations were identified to be above the release criteria when surveying the area for release from the RCA. These areas were remediated by removing the contaminated soil from the area. Approximately 1, 000 yd3 of soil with potential tritium contamination was relocated to this area beginning in 2009 . The soil was deposited in two locations: 1) north of the Warehouse and 2) east within the PA fence by Gate 8.

3.6.2 Survey Summary Survey Dates: 8/23/2022 through 9/27/2022

Survey and field activities were governed by SAP 06, North Protected Area.Planners of the SAP identified 13 sample locations where plant- related radioactivity might have been introduced from other areas. One sample point, NPA- SEDI-12-B, was relocated due to industrial safety concerns. An alternative sample location was selected close to the original point and where representative samples could be safely collected.

The sample locations are shown in Figure 3-6. GPS coordinates for an alternate sample location were recorded during sampling to document the new location. One additional sample point, NPA- XXX-03-B, was canceled due to the presence of underground utilities and could not be safely collected as planned .The sample point was evaluated for relocation , and it was determined that due to the distance the sample would have to be moved, the intended purpose of the biased sample location would be lost.Following the initial walk-down and bias point selections, a water main break resulted in a significant erosion of soil. This location NPA- SOIL-16-B was selected following initial planning for sampling due to soil exposure. GPS coordinates for the sample location were recorded during sampling to document the location.GPS coordinates for as-taken sample locations are listed in Table 3-57.

A total of 16 samples were obtained from the N PA area: 8 soil samples, 7 sediment samples, and 1 asphalt sample. All sediment sample locations were chosen based on facility walk-downs and the identification of water runoff pathways. A n asphalt sample was obtained at the location where the soil was covered by asphalt, EOCA1-ASPH-41-B.

Walk-over gamma scans were conducted at the NPA boundaries . They were performed using calibrated pairings of Ludlum Model 44- 10 detectors with Model 3003 multi-detector survey meters to identify the presence of elevated radioactivity. Gamma scan measurements were also conducted at each sample location. A total of 145 m 2 were scanned. Count rates were logged between 8,490 and 45,400 cpm at sample locations in the NPA area. The highest measurement was due to the proximity to the LLRW truck bay, where a resin liner was loaded into a shipping cask. The gamma scans performed in the NP A survey area did not identify elevated radioactivity requiring further investigation.

3-55 Revision 1 SECTIONTHREE Radiological Findings Table 3-57 GPS Coordinates for Sample Locations in the NPA Survey Area Sample Number Easting Northing NPA-SOIL-01-B 574549.7462 357327.0427 NPA-SEDI-02-B-D 574470.9219 357316.4957 NPA-SOIL-03-B1 NPA-DEP1-03-B 574424.8485 357320.3815 NPA-DEP2-03-B NPA-SOIL-04-B-QC 574514.2197 357753.6377 NPA-SEDI-05-B 574289.4039 357827.7436 NPA-SEDI-06-B 574256.0978 357834.6824 NPA-SEDI-07-B 574437.8934 357955.9719 NPA-SOIL-08-B 574630.2358 357821.6375 NPA-SOIL-09-B 574716.2764 357870.4864 NPA-SOIL-10-B-D 574891.1332 357876.5925 NPA-SEDI-11-B 574931.1005 357902.6822 NPA-SEDI-12-B 575106.5123 358151.9225 NPA-SEDI-13-B 575137.5980 358056.4452 NPA-ASPH-14-B 575185.6142 358199.3836 NPA-SOIL-14-B-QC NPA-SOIL-15-B 575316.6180 357840.7885 NPA-SOIL-16-B 574451.1748 357360.4037 Note 1: See Survey P lan D eviations

3-56 Revision 1 SECTIONTHREE Radiological Findings

Figure 3-6 NPA Survey Area and Sampl e Locations

3.6.3 Survey Data Summary Discussion

Cesium-137 concentrations are less than the achieved MDC values for most N PA samples. However, Cs-137 was detected at concentrations greater than the MDC values in 4 samples (NPA-SOIL-09-B, NPA-SEDI-07-B, NPA-SEDI-11-B, and NPA-SEDI-12-B). The four samples were comprised of 1 surface soil sample and 3 sediment samples. Results can be seen in Table 3-58, Table 3-59, and Table 3-60. The positive findings are all less than 3.39E- 01 pCi/g, which is less than 12 % of the Class 2 AC for Cs -137 (2.88E+00 pCi/g).

Cobalt-60 concentrations are less than the achieved MDC values for most N PA samples. However, Co-60 was detected at concentrations greater than the MDC values in 2 samples (NPA-SEDI-02-B-D and N PA-SEDI-11-B); both samples were sediment samples. Results can be seen in Table 3-59. The positive

3-57 Revision 1 SECTIONTHREE Radiological Findings findings are all less than 1.24E- 01 pCi/g, which is less than 11 % of the Class 2 AC for C o-60 (1.22E+00 pCi/g). Cobalt-60 was not detected in any of the soil samples.

Both Co-60 and Cs-137 concentrations for asphalt samples can be seen in Table 3-60 and are less than the achieved MDC values.

The collected site characterization data provides a snapshot of the current radiological status of the NPA, which may change as the demolition of buildings and structures within the NPA and decommissioning of the OCNGS site precedes . It may be necessary to update the radiological status of the NPA with additional characterization surveys to support FSS planning following the active decommissioning of the site.

The presence of HTD beta -emitting ROCs (i.e., Sr-90, C-14, Fe-55, Ni-63, Tc-99, and Pu-241) in the NPA survey area was evaluated using analytical results for the QC samples transferred to the off -site laboratory.

As shown in Table 3-65, those analyses did not identify any HTD beta-emitting ROC above the MDC value achieved during the analyses.

Table 3-58 On -Site Laboratory Gamma Analysis Results for NPA Surface Soil Samples

So il Sample Gamma Spe c - D at a Q ualit y A s s e s s me nt Surv e y A re a: NPA N umbe r o f Sample s : 8 Initial Clas s ific atio n: Class 2 R e s ult C o mparis o n Co-60 Cs -137 A c hie ve d A c hie ve d Measured MD C AC Measured MD C AC A c t iv it y V a lu e Exceeded Da ta V a lu e Exceeded Sample # ( pC i/g) ( pC i/g) (Y/N) ( pC i/g) ( pC i/g) (Y/N)

NP A-SOIL-1-B 6. 93E- 04 5. 74E- 02 N 2. 42E- 02 4. 25E- 02 N NP A-SOIL-4-B-QC - 9. 91E- 04 4. 28E- 02 N 2. 56E- 02 7. 84E- 02 N NP A-SOIL-8-B 9. 78E- 03 4. 75E- 02 N 1. 69E- 02 4. 02E- 02 N NP A-SOIL-9-B 4. 32E- 02 4. 51E- 02 N 6. 36E- 02 4. 56E- 02 N NP A-SOIL-10-B-D 2. 82E- 02 5. 13E- 02 N 2. 05E- 02 6. 94E- 02 N NP A-SOIL-14-B-QC - 1. 46E- 04 3. 01E- 02 N 2. 76E- 02 7. 39E- 02 N NP A-SOIL-15-B - 1. 14E- 02 4. 52E- 02 N 2. 23E- 02 5. 90E- 02 N NP A-SOIL-16-B 1. 04E- 02 5. 86E- 02 N 4. 08E- 02 7. 49E- 02 N A ve r a ge 9. 97E- 03 3. 02E- 02 SD 1. 77E- 02 1. 52E- 02 Data Range - 1. 14E- 02 to 4. 32E- 02 1. 69E- 02 to 6. 36E- 02

3-58 Revision 1 SECTIONTHREE Radiological Findings Table 3-59 On -Site Laboratory Gamma Analysis Results for NPA Sediment Samples

Table 3-60 On -Site Laboratory Gamma Analysis Results for NPA Asphalt Samples

3.6.4 Data Quality Comparisons

On-Site Duplicate Counts The comparisons of the Cs-137 and Co- 60 results for the duplicate samples NPA-SEDI-02-B-D and NPA-SEDI-10-B-D are shown in Table 3-61 and Table 3-62, respectively. All comparisons were found acceptable. Agreement is assumed when results are less than the achieved MDC value. , respectively .

3-59 Revision 1 SECTIONTHREE Radiological Findings Table 3-61 Duplicate Sample Analysis for NPA-S EDI-02-B-D

Table 3-62 Duplicate Sample Analysis for NPA -SOIL-10-B-D

3-60 Revision 1 SECTIONTHREE Radiological Findings On-Site/Off-Site Laboratory Comparisons The comparisons of the Cs-137 and Co- 60 results for the QC samples NPA- SOIL-04-B-QC and NPA-SOIL-14-B-QC are shown in Table 3-63 and Table 3-64, respectively. All comparisons were found acceptable. Agreement is assumed when results are below the achieved MDC value.

Table 3-63 On -Site/Off-Site Sample Analysis for NPA-SOIL-04-B-QC

3-61 Revision 1 SECTIONTHREE Radiological Findings Table 3-64 On -Site/Off-Site Sample Analysis for NPA-SOIL-14-B-QC

Off-Site Laboratory HTD Analyses Table 3-65 Off -Site Laboratory Results for HTDs in NPA QC Samples HTD Measured Achieved AC Sample Number Medium Beta (pCi/g) MDC Exceeded (pCi/g) (Y/N)

Sr-90 2.08E-03 6.30E-02 N C-14 -6.22E-03 1.04E+00 N NPA- SOIL-04-B-QC SoilFe-556.14E+011.21E+02 N Ni-63 6.81E+00 3.44E+01 N Tc-99 1.72E-01 2.15E+00 N Pu-241 8.05E+00 4.20E+01 N Sr-90 2.47E-02 4.98E-02 N C-14 8.14E-02 1.07E+00 N NPA- SOIL-14-B-QC SoilFe-558.58E+011.79E+02 N Ni-63 4.29E+00 2.89E+01 N Tc-99 -5.72E-01 2.28E+00 N Pu-241 3.34E+01 4.19E+01 N

3-62 Revision 1 SECTIONTHREE Radiological Findings 3.6.5 Survey Plan Deviations One sample point required a deviation due to safety concerns. Sample point NPA-XXX-03-B was located over underground utilities. The sample point was evaluated for relocation; it was determined that due to the distance the sample would have to be moved, the intended purpose of the biased sample location would be lost.

3.6.6 Survey Area Investigations None.

3.6.7 Survey Area Conclusions The following conclusions were reached for the NPA survey area:

The Cs-137 and Co- 60 concentrations found in NPA samples do not require excavation or remediation to meet site release criteria at this time. The current radiological status may change as active decommissioning of the site commences.

Radiological status changes may warrant additional site characterization collec tion to support FSS planning.

Additional characterization in yard areas, including walk- over gamma scans and soil sampling, should be considered when the waste containers are removed.

3-63 Revision 1 SECTIONTHREE Radiological Findings 3.7 SPA (SAP 08 - OPEN LAND)

3.7.1 Area Description SPA is located south of the Radiologically Controlled Area inside the Protected Area. Illustrated in Figure 3-7, it encompasses the area between the RCA and the sou th parking lot. Its 51,255 m2 footprint comprises asphalt-covered roadways, unused parking areas, concrete pads, buildings, and structures. Migration of contaminated soil or resin in this area is suspected of having occurred, particularly in the north along the RCA fence. Soil samples collected between the M ain Fuel Oil Tank (MFOT) and the RCA fence in late summer 1999 showed detectable radioactivity below the release criteria to a depth of 3 feet. Contaminated soil was stored in the berms around the MFOT. Historical records indicate soil contamination has been identified in the southwest corner of the augmented off-gas building (AOG) at the RCA boundary, possibly under the asphalt.

There are several vaults located along the southern wall of the Reactor Building. These vaults were use d as a form of secondary containment for pipes. Radioactive material is routinely transported through the area.

3.7.2 Survey Summary:

Survey Dates: 8/17/2022 through 8/18/2022

Survey and field activities were governed by SAP 08, South Protected Area. Planners of the SAP identified 16 biased sample locations where plant-related radioactivity might have been introduced from other areas.

The sample locations are shown in Figure 3-7

A total of 24 samples were obtained from the SPA area; 12 soil samples, 6 sediment samples, 4 asphalt samples, and 2 samples at depths greater than 6 inches. Sediment sample locations (SPA-SEDI-02-B-QC, B, B, and B) were chosen based on facility walk-downs and the identification of water runoff paths.Sediment samples (SPA -SEDI-02-B-QC, B, and B) were planned as soil samples during the original walk down; however, when the team attempted to obtain the soil samples, the material was not soil but sediment that had filled depressions in the asphalt (SPA -SEDI-02-B-QC and SPA -SEDI-04-B) or sediment that covered concrete (SPA-SEDI-06-B).S amples SPA-SEDI-13-B, SPA-ASPH-13-B, SPA-ASPH-16-B, and SPA-SEDI-16-B were added to the originally planned samples because the original walk -

down identified the location as soil; these samples were obtained to reach the soil samples below. The 2 remaining asphalt samples , SPA -ASPH-10-B and SPA -ASPH-12-B, were obtained where asphalt covered the soil. Locations of samples greater than 6 inches ( SPA-DEP1-15-B and SPA-SSUB-16-B) were selected due to the proximity to piping vaults and to check for potential subsurface migration of contamination, respectively.Sample SPA-SSUB-16-B was initi ally intended to be taken at a depth between 6 and 48 inches; however, resistance was met at a depth of 12 inches, so the sample was given the designator of SSUB, not DEP1. GPS coordinates for as- taken sample locations are listed in Table 3-66.

Walk-over gamma scans were conducted at the SPA boundaries. They were performed using calibrated pairings of Ludlum Model 44- 10 detectors with Model 3003 multi-detector survey meters to identify the presence of elevated radioactivity. Gamma scan measurements were also conducted at each sample location. A total of 106 m 2 was scanned. Count rates were logged between 4,67 0 and 16,7000 cpm at sample locations in the SPA area. The highest measurement was due to the proximity of radioactive material

3-64 Revision 1 SECTIONTHREE Radiological Findings stored in the nearby RCA. The gamma scans performed in the S PA survey area did not identify elevated radioactivity requiring further investigation. Scans identified no areas with an audible distinction above the location background count rate, except as noted above.

Table 3-66 GPS Coordinates for Sample Locations in the SPA Survey Area Sample Number Easting Northing SPA-SOIL-01-B-D 575476.8132 356905.9381 SPA-SEDI-02-B-QC 575325.8257 356869.8565 SPA-SOIL-03-B 575406.3154 356958.6727 SPA-SEDI-04-B 575332.4870 356904.2728 SPA-SOIL-05-B 575057.7120 356899.8320 SPA-SEDI-06-B-D 575002.2020 356985.3175 SPA-SOIL-07-B 574890.0716 357027.5052 SPA-SOIL-08-B 574799.5901 356922.0360 SPA-SOIL-09-B 574573.1090 357099.1132 SPA-ASPH-10-B 574841.2227 357175.1620 SPA-SOIL-10-B SPA-SEDI-11-B 574820.1289 357136.8600 SPA-ASPH-12-B 574888.9614 357330.5902 SPA-SOIL-12-B-QC SPA-SEDI-13-B SPA-ASPH-13-B 575170.9526 357411.6350 SPA-SOIL-13-B SPA-SOIL-14-B 575112.6670 357290.0679 SPA-SOIL-15-B 574794.5942 357187.3742 SPA-DEP1-15-B SPA-SEDI-16-B SPA-ASPH-16-B 574755.7372 357062.7541 SPA-SOIL-16-B SPA-SSUB-16-B

3-65 Revision 1 SECTIONTHREE Radiological Findings

Figure 3-7 SPA Survey Area and Sampl e Locations

3.7.3 Survey Data Summary Discussion

Cesium-137 concentrations were less than the achieved MDC values for most (58%) SPA samples.

However, Cs-137 was detected at concentrations greater than the MDC values in 10 samples (6 soil samples, 2 sediment samples, 1 asphalt sample, and 1 subsurface sample) . The 10 samples are SPA-SOIL-01-B-D, SPA-SOIL-08-B, SPA-SOIL-10-B, SPA-SOIL-13-B, SPA-SOIL-14-B, SPA-SOIL-16-B, SPA-SEDI B-QC, SPA-SEDI-04-B, SPA-SSUB-16-B, and SPA-ASPH-12-B. Results can be seen in Table 3-67, Table 3-68, Table 3-69, and Table 3-71, respectively. The positive findings are all less than 2.52E- 01 pCi/g, which is less than 9% of the Class 2 AC for Cs -137 (2.88E+00 pCi/g).

3-66 Revision 1 SECTIONTHREE Radiological Findings Cobalt-60 concentrations were less than MDC values for most ( 83%) SPA samples. However, Co-60 was detected at concentrations greater than the MDC values in 4 samples (SPA-SOIL-13-B, SPA-SEDI-04-B, SPA-ASPH-12-B, and SPA-ASPH-13-B). The 4 samples were comprised of 1 soil sample, 1 sediment sample, and 2 asphalt samples. Results can be seen in Table 3-67, Table 3-68, and Table 3-71, respectively.

The positive findings are all less than 2.23E-01 pCi/g, which is less than 19% of the AC for Co-60 (1.22E+00).

No activity was detected above the achieved MDC for the sample taken beyond 30 cm, SPA-DEP1-15-B, which can be seen in Table 3-70.

The presence of HTD beta- emitting ROCs (i.e., Sr-90, C-14, Fe-55, Ni-63, Tc-99, and Pu-241) in the SOCA2 survey area was evaluated using analytical results for the QC samples transferred to the off-site laboratory. As shown in Table 3-76, the analyses did not identify any HTD beta- emitting ROC above the MDC value achieved during the analyses.

Table 3-67 On -Site Laboratory Gamma Analysis Results for SPA Surface Soil Samples

3-67 Revision 1 SECTIONTHREE Radiological Findings Table 3-68 On -Site Laboratory Gamma Analysis Results for SPA Sediment Samples

Se dime nt ( SE D I ) Sample Gamma Spe c - D at a Q ualit y A s s e s s me nt Surv e y A re a: SPA N umbe r o f Sample s : 6 Initial Clas s ific atio n: Class 2 R e s ult C o mparis o n Co-60 Cs -137 Measured A c hie ve d AC Measured A c hie ve d AC A c t iv it y MDC Value Exceeded Da ta MDC Value Exceeded Sample # (pCi/g) (pCi/g) (Y/N) ( pC i/g) ( pC i/g) (Y/N)

SP A-SEDI-2-B-QC 8. 69E- 03 6. 04E- 02 N 5. 33E- 02 4. 15E- 02 N SP A-SEDI-4-B 1. 26E- 01 7. 44E- 03 N 8. 71E- 02 4. 76E- 02 N SP A-SEDI-6-B-D 2. 08E- 02 5. 18E- 02 N 3. 81E- 02 7. 38E- 02 N SP A-SEDI-11-B 5. 76E- 02 2. 96E- 02 N 6. 78E- 02 5. 90E- 02 N SP A-SEDI-13-B 2. 23E- 01 4. 28E- 02 N 3. 01E- 01 6. 60E- 02 N SP A-SEDI-16-B 1. 33E- 02 2. 53E- 02 N 2. 04E- 03 6. 91E- 02 N A ve r a ge 7. 49E- 02 9. 16E- 02 SD 8. 48E- 02 1. 07E- 01 Data Range 8. 69E- 03 to 2. 23E- 01 2. 04E- 03 to 3. 01E- 01

Table 3-69 On -Site Laboratory Gamma Analysis Results for SPA Subsurface Soil Samples

3-68 Revision 1 SECTIONTHREE Radiological Findings Table 3-70 On -Site Laboratory Gamma Analysis Results for SPA Deep Soil Samples

Table 3-71 On -Site Laboratory Gamma Analysis Results for SPA Asphalt Samples

3.7.4 Data Quality Comparisons

On-Site Duplicate Counts The comparisons of the Cs-137 and Co- 60 results for the duplicate samples SPA-S EDI-01-B-D and SPA-SEDI-06-B-D are shown in Table 3-72 and Table 3-73, respectively. Al l comparisons were found acceptable. Agreement is assumed when results are below the achieved MDC value.

3-69 Revision 1 SECTIONTHREE Radiological Findings Table 3-72 Duplicate Sample Analysis for SPA -SEDI-01-B-D

Table 3-73 Duplicate Sample Analysis for SPA -SEDI-06-B-D

3-70 Revision 1 SECTIONTHREE Radiological Findings On-Site/Off-Site Laboratory Comparisons The comparisons of the Cs- 137 and Co- 60 results for the QC samples SPA-SEDI-02-B-QC and SPA-SOIL-12-B-QC are shown in Table 3-74 and Table 3-75, respectively. All comparisons were found acceptable.

Agreement is assumed when results are less than the achieved MDC value .

Table 3-74 On -Site/Off-Site Sample Analysis for S PA-SEDI-02-B-QC

3-71 Revision 1 SECTIONTHREE Radiological Findings Table 3-75 On -Site/Off-Site Sample Analysis for SPA -SOIL-12-B-QC

Off-Site Laboratory HTD Analyses Table 3-76 Off -Site Laboratory Results for HTDs in S PA QC Samples HTD Measured Achieved AC Sample Number Medium Beta (pCi/g) MDC Exceeded (pCi/g) (Y/N)

Sr-90 7.04E-03 4.57E-02 N C-14 1.10E-01 1.06E+00 N SPA-SEDI-02-B-QC SoilFe-555.96E+012.14E+02 N Ni-63 9.74E-01 3.06E+01 N Tc-99 1.41E+00 2.26E+00 N Pu-241 6.73E+00 4.11E+01 N Sr-90 5.84E-02 6.63E-02 N C-14 1.90E-01 1.06E+00 N SPA-SOIL-12-B-QC SoilFe-55-4.58E+012.22E+02 N Ni-63 9.72E+00 3.23E+01 N Tc-99 5.85E-01 2.42E+00 N Pu-241 1.97E+01 4.43E+01 N

3-72 Revision 1 SECTIONTHREE Radiological Findings 3.7.5 Survey Plan Deviation(s)

None.

3.7.6 Survey Area Investigations None.

3.7.7 Survey Area Conclusions The following conclusions were reached based on the collected site characterization data from the SPA survey area:

The Cs-137 and Co- 60 concentrations found in SPA samples do not require excavation or remediation to meet site release criteria at this time. The current radiological status may change as active decommissioning of the site commences.

Radiological status changes may warrant additional site characterization collection to support FSS planning.

Additional characterization in yard areas, including walk-over gamma scans and soil sampling, should be considered when waste containers are moved.

3-73 Revision 1 SECTIONTHREE Radiological Findings 3.8 RCA (SAP 10 - OPEN LAND)

3.8.1 Area Description The RCA is located east and north of the west side of the power block and is illustrated in Figure 3-8 . It is a 21,599 m2 area covered with asphalt-covered roadways storage areas, concrete pads, and buildings and structures. The RCA Yard area stores radioactive material and containers and supports radioactive material and waste shipments. According to historical records and interviews, several spills occurred in the RCA Yard. Areas were remediated or paved over to contain radioactive material. The yard storm drains are believed to be contaminated by the operation of the isolation condensers and spills. The area under the isolation condensers was found contaminated after auto initiation of the isolation condensers in 2007.

3.8.2 Survey Summary Survey Dates: 9/14/2022 through 9/21/2022

Survey and field activities were governed by SAP 10, Radiologically Controlled Area. The Radiological Engineer identified 16 biased sample locations where plant -related radioactivity had been introduced from spills and plant operations as indicated by the HSA.The client requested the collection of an additional 2 sample locations (RCA -XXX B and RCA-SOIL-19-B). The sample locations are shown in Figure 3-8 .

A total of 33 samples were collected from the RCA area; 1 7 surface soil samples, 4 sediment samples, 7 asphalt samples, and 5 samples at depths greater than 15 cm. GPS coordinates for the sample locations are listed in Table 3-77.

RCA-SOIL-06-B-QC was not able to be collected as initially planned. During the sampling of the asphalt, a concrete slab was encountered; the asphalt sample, RCA -ASPH-06-B, was kept and ana lyzed. An alternate location was selected, also covered by asphalt resulting in 2 samples, RCA-ASPH-20-B and RCA -

SOIL-20-B-QC. GPS coordinates for the alternative location were recorded.

Sediment sample locations RCA-SEDI-03-B and RCA -SEDI-14-B were selected near storm drains.

Sediment was also obtained from RCA -SEDI-10-B and RCA -SEDI-18-B because sediment covered these planned survey locations.

Asphalt samples were obtained at the locations where the soil was covered by asphalt. The only exception to this was sample RCA -ASPH-06-B, as discussed previously.

Samples at depths greater than 6 inches were obtained based on indications in the HSA where plant-related radioactivity had been introduced from spills and plant operations. Sample RCA-SSUB-05-B was obtained at a depth of 6-12 inches in the loading dock area of the ORW facility based on the historical potential for material to have penetrated the asphalt. Th e 4 remaining samples, taken at depths greater than 6 in ches, were obtained to a depth from 6 inches to 4 feet. These locations ( RCA-DEP1-01-B, B, B, and -

15B) were chosen based on historical spills. Two samples were not obtained at depth per the SAP plan, RCA-DEP2-08-B, and RCA-DEP1-16-B. RCA -DEP2-08-B was not obtained due to the client request ing no samples be taken deeper than 4 feet, and RCA-DEP1-16-B was not obtained due to resistance during sampling in the form of a buried concrete slab.

3-74 Revision 1 SECTIONTHREE Radiological Findings Walk-over gamma scans were conducted at the RCA boundaries . They were performed using calibrated pairings of Ludlum Model 44- 10 detectors with Model 3003 multi-detector survey meters to identify the presence of elevated radioactivity. Gamma scan measurements were also conducted at each sample location. A total of 90 m 2 were scanned. Count rates were logged between 2,710 and 24,600 cpm at sample locations in the RCA area. Multiple locations in the RCA were scanned with a collimator shield around the Ludlum 44- 10 detector to reduce ambient background sources. The highest measurement was due to the presence of exposed Radioactive Waste piping. The gamma scans performed in the RCA survey area did not identify elevated radioactivity requiring further investigation.Scans identified no areas with an audible distinction above the location background count rate.

Table 3-77 GPS Coordinates for Sample Locations in the RCA Survey Area Sample Number Easting Northing RCA-SOIL-01-B 574483.7340 357378.2728 RCA-DEP1-01-B RCA-SOIL-02-B 574498.0594 357446.4421 RCA-SEDI-03-B 574961.9068 357444.4662 RCA-SOIL-04-B-D 574935.7258 357445.4541 RCA-ASPH-05-B RCA-SOIL-05-B 575002.9071 357494.3582 RCA-SSUB-05-B RCA-ASPH-06-B 574939.1837 357480.0327 RCA-SOIL-06-B-QC RCA-SOIL-07-B 574858.7079 357485.9086 RCA-SOIL-08-B-QC RCA-DEP1-08-B 574902.1352 357585.7445 RCA-DEP2-08-B RCA-ASPH-09-B 574975.2442 357678.1188 RCA-SOIL-09-B-D RCA-ASPH-10-B RCA-SEDI-10-B 574963.3887 357713.1914 RCA-SOIL-10-B RCA-SOIL-11-B 574807.2910 357738.1374 RCA-DEP1-11-B RCA-SOIL-12-B-D 574802.8452 357750.9808 RCA-ASPH-13-B 574757.3990 357568.2082 RCA-SOIL-13-B-QC RCA-SEDI-14-B 575023.6543 357596.1181 RCA-ASPH-15-B RCA-SOIL-15-B 574857.6770 357462.2495 RCS-DEP1-15-B RCA-ASPH-16-B RCA-SOIL-16-B 574849.7019 357496.8474 RCA-DEP1-16-B RCA-DEP1-17-B 574470.5863 357423.7885

3-75 Revision 1 SECTIONTHREE Radiological Findings Sample Number Easting Northing RCA-ASPH-18-B RCA-SEDI-18-B 575039.4719 357544.8013 RCA-SOIL-18-B RCA-SOIL-19-B 575029.3268 357431.0148 RCA-ASPH-20-B 574934.7228 357469.4062 RCA-SOIL-20-B-QC

Figure 3-8 RCA Survey Area and Sampl e Locations

3-76 Revision 1 SECTIONTHREE Radiological Findings 3.8.3 Survey Data Summary:

Discussion Cesium-137 and Co-60 concentrations exceed the achieved MDC values for most RCA samples.

Characterization data for surface soil samples are provided in Table 3 -78, sediment samples are provided in Table 3-79, asphalt samples are provided in Table 3-82, and soil samples at depths greater than 15 cm are provided in Table 3-81.

Cs-137 concentrations in surface soil samples range d from non-detectable concentrations (less than achieved MDC values) to a maximum concentration of 1.62E+01 pCi/g, exceeding the Class 1 AC value (approximately 3 times the AC) with 11 of 17 soil samples showing concentrations greater than MDC. The Co-60 concentrations in surface soil samples ranged from non- detectable concentrations (less than achieved MDC values) to a maximum Co-60 concentration of 5.97E+00 pCi/g, exceeding the Class 1 AC value (approximately 3 times the AC) with 10 of 17 soil samples showing Co- 60 concentrations greater than MDC.

Cs-137 concentrations in sediment samples were greater than the achieved MDC values, ranging from 1.36E+00 pCi/g (24% of the Class 1 AC) to 3.232E+01 pCi/g (approximately 6 times the Class 1 AC) .For Co-60, concentrations in sediment samples were greater than the achieved MDC values and ranged from 1.10E+00 pCi/g (45% AC) minimum to 1.32E+01 pCi/g (approximately 6 times the AC) maximum, which exceeds the Class 1 AC value.

In asphalt samples, C s-137 concentrations ranged from non-detectable concentrations (less than achieved MDC values) to a maximum 7 concentration of 1.97E+0 0 pCi/g (34% of the Class 1 AC) . A total of 5 of 7 asphalt samples contained Cs -137 at concentrations greater than the MDC. The Co -60 concentrations in asphalt samples ranged from non- detectable concentrations (less than achieved MDC values) to a maximum concentration of 3.49E-01 pCi/g (approximately 14% of the Class 1 AC). A total of 4 of 7 asphalt samples contained Co-60 concentrations greater than MDC.

Soil samples collected at depths greater than 6 inches range from non- detectable concentrations (less than achieved MDC values) to a maximum Cs- 137 activity concentration of 4.04E+02 pCi/g (approximately 70 times the AC). The Co-60 concentrations in those same deep samples range from non- detectable concentrations (less than achieved MDC values) to a maximum Co -60 concentration of 1.11E+02 pCi/g (approximately 45 times the Class 1 AC). The greater contamination levels found in the deep soil sample compared to the surface contamination levels indicate historical leakage from the south pipe chase and overflow from a valve pit.

This data provides a snapshot of the current radiological condition of the RCA survey area, which is expected to change as decommissioning of the site moves forward .The collected site characterization data identified 2 areas that may require special attention during decommissioning. The location of sample s RCA-SOIL-04-B-D (east of Reactor Building railroad bay doors) and RCA-SOIL-15-B (east side of Reactor Building near the south pipe chase) are areas where the concentrations of both Cs-137 and Co- 60 in the surface soil exceeded the respective Class 1 AC values. The surface soil sample RCA-SOIL-04-B-D contained Cs-137 at an activity concentration of 1.62E+01 pCi/g (approximately 3 times the Class 1 AC) and Co- 60 at 5.11E+00 pCi/g (approximately 2 times the Class 1 AC). Sample RCA-SOIL-15-B contained

3-77 Revision 1 SECTIONTHREE Radiological Findings Cs-137 at a concentration of 4.94E+00 pCi/g (approximately 86% of the AC) and Co- 60 at 5.97E+00 pCi/g (approximately 3 times the Class 1 AC).

The presence of HTD beta- emitting ROCs (i.e., Sr-90, C-14, Fe-55, Ni-63, Tc-99, and Pu-241) in the SOCA2 survey area was evaluated using analytical results for the QC samples transferred to the off -site laboratory. As shown in Table 3-88, the analyses did not identify any HTD beta -emitting ROC above the MDC value achieved during the analyses.

Table 3-78 On -Site Laboratory Gamma Analysis Results for RCA Surface Soil Samples

3-78 Revision 1 SECTIONTHREE Radiological Findings Table 3-79 On -Site Laboratory Gamma Analysis Results for RCA Sediment Samples

Table 3-80 On -Site Laboratory Gamma Analysis Results for RCA Deep Soil Samples

D e e p C o mpo s it e So il ( D E E P) Sample Gamma Spe c - D at a Q ualit y A s s e s s me nt Surv e y A re a: RCA N umbe r o f Sample s : 4 Initial Clas s ific atio n: Class 1 R e s ult C o mparis o n Co-60 Cs -137 Measured A c hie ve d AC Measured A c hie ve d AC A c t iv it y MDC Value Exceeded Da ta MDC Value Exceeded Sample # ( pC i/g) ( pC i/g) (Y/N) ( pC i/g) ( pC i/g) (Y/N)

RCA-DEP 1-1-B 9. 55E- 03 9. 58E- 02 N 3. 32E- 02 7. 42E- 02 N RCA-DEP 1-8-B 7. 72E- 02 1. 45E- 01 N 1. 02E+00 1. 14E- 01 N RCA-DEP 1-11-B - 5. 67E- 03 6. 99E- 02 N 1. 78E- 01 9. 62E- 02 N RCA-DEP 1-15-B 1. 11E+02 6. 29E- 01 Y 4. 04E+02 1. 22E+00 Y A ve r a ge 2. 78E+01 1. 01E+02 SD 5. 55E+01 2. 02E+02 Data Range - 5. 67E- 03 to 1. 11E+02 3. 32E- 02 to 4. 04E+02

3-79 Revision 1 SECTIONTHREE Radiological Findings Table 3-81 On -Site Laboratory Gamma Analysis Results for RCA Subsurface Soil Samples

Table 3-82 On -Site Laboratory Gamma Analysis Results for RCA Asphalt Samples

3.8.4 Data Quality Comparisons

On-Site Duplicate Counts The comparisons of the Cs-137 and Co- 60 results for the duplicate samples R CA-SOIL-04-B-D and RCA-SOIL-12-B-D are shown in Table 3-83 and Table 3-84, respectively. All comparisons were found acceptable. Agreement is assumed when results are less than the achieved MDC value.

3-80 Revision 1 SECTIONTHREE Radiological Findings Table 3-83 Duplicate Sample Analysis for RCA -SOIL-04-B-D

Table 3-84 Duplicate Sample Analysis for RCA -SOIL-12-B-D

3-81 Revision 1 SECTIONTHREE Radiological Findings

On-Site/Off-Site Laboratory Comparisons The comparisons of the Cs-137 and Co- 60 results for the QC samples RCA-SOIL-08-B, RCA-SOIL-13-B-QC, and RCA- SOIL-20-B-QC are shown in Table 3-85, and Table 3-86, respectively. All comparisons were found acceptable. Agreement is assumed when results are less than the achieved MDC value.

Table 3-85 On -Site/Off-Site Laboratory Comparisons for Sample RCA - SOIL-08-B-QC

3-82 Revision 1 SECTIONTHREE Radiological Findings Table 3-86 On -Site/Off-Site Laboratory Comparisons for Sample RCA - SOIL-13-B-QC

Table 3-87 On -Site/Off-Site Laboratory Comparisons for Sample RCA- SOIL-20-B-QC

3-83 Revision 1 SECTIONTHREE Radiological Findings Off-Site Laboratory HTD Analyses Table 3-88 Off -Site Laboratory Results for HTDs in RC A QC Samples HTD Measured Achieved AC Sample Number Medium Beta (pCi/g) MDC Exceeded (pCi/g) (Y/N)

Sr-90 4.02E-02 6.52E-02 N C-14 -2.73E-01 6.39E-01 N RCA-SOIL-08-B SoilFe-555.71E+011.68E+02N Ni-63 4.16E+00 2.34E+01 N Tc-99 4.27E-01 7.60E-01 N Pu-241 1.33E+01 4.17E+01 N Sr-90 1.01E-02 6.35E-02 N C-14 -3.78E-01 5.93E-01 N RCA-SOIL-13-B-QC SoilFe-558.78E+012.24E+02N Ni-63 -4.02E+00 2.30E+01 N Tc-99 6.36E-01 1.54E+00 N Pu-241 6.65E+00 3.73E+01 N Sr-90 9.71E-03 6.40E-02 N C-14 -3.96E-02 6.04E-01 N RCA-SOIL-20-B-QC SoilFe-559.24E+011.44E+02N Ni-63 1.10E+00 2.28E+01 N Tc-99 4.85E-01 1.61E+00 N Pu-241 9.00E+00 4.59e+01 N

3.8.5 Survey Plan Deviation(s)

None.

3.8.6 Survey Area Investigations None.

3.8.7 Survey Area Conclusions The following conclusions were reached for the RCA survey area:

The collected data confirms that the RCA is MARSSIM Class 1.

The Cs-137 and Co- 60 concentrations in soil samples from locations 4 and 15 indicate that excavation or remediation is required to meet site release criteria.

3-84 Revision 1 SECTIONTHREE Radiological Findings 3.9 DCA (SAP 12 - OPEN LAND)

3.9.1 Area Description DCA is the area immediately west of the southern protected area, separating the south owner -controlled areas, as illustrated in Figure 3-9. It is 35,667 m 2 in size and includes only the water -covered area. There are no plant structures within the DCA. Since the facility shutdown, the DCA canal has been subjected to silting due to tidal action. The silting of the bed adds to the complication of obtaining reliable characterization data.

3.9.2 Survey Summary Survey Date: 09/13/2022

Survey and field activities were governed by SAP 12, Discharge Canal Area. Seven sample locations were identified where plant-related radioactivity m ight have been introduced from the discharge of radioactive material. Four sample points were relocated to obtain sufficient sample material for analysis. GPS coordinates for the alternate sample locations were recorded during sampling to document the new locations. The sample locations are shown in Figure 3 -9.

A total of 7 sediment samples were obtained from the DCA area. GPS coordinates for as-taken samples locations are listed in Table 3-89

Walk-over gamma scans of the DCA were not conducted within the DCA; however, scans were performed on the DCA border with the adjacent survey areas (shown in Figure 3-1, Figure 3-3, Figure 3-4, Figure 3-6, and Figure 3-7).

Table 3-89 GPS Coordinates for DCA Sampling Locations Sample Number Easting Northing DCA-SEDI-01-B-QC 574426.3648 357054.6517 DCA-SEDI-02-B Original location coordinates 575559.0088 357423.4646 Sample relocation coordinates 574489.1854 356864.5772 DCA-SEDI-03-B-D Original location coordinates 575580.9836 357369.4031 Sample relocation coordinates 574519.3610 356779.5623 DCA-SEDI-04-B Original location coordinates 575936.9564 357466.3570 Sample relocation coordinates 575306.4804 356421.1276 DCA-SEDI-05-B Original location coordinates 575861.3894 357384.6116 Sample relocation coordinates 575943.8672 356265.0603 DCA-SEDI-06-B 574542.0237 356701.5201 DCA-SEDI-07-B 574544.9876 356575.5551

3-85 Revision 1 SECTIONTHREE Radiological Findings

Figure 3-9 DCA Survey Area and Sample Locations

3.9.3 Survey Data Summary

Discussion Cesium-137 concentrations were less than the achieved MDC values for most DCA samples. However, Cs-137 was detected at concentrations greater than the MDC values in 1 sample, DCA-SEDI-02-B. Sample results can be seen in Table 3-90. The positive findings are all less than 2.35E-01 pCi/g, which is less than 41% of the Class 3 AC for Cs -137 (5.76E-01 pCi/g) .

Cobalt-60 concentrations are greater than the achieved MDC values for most DCA samples. Concentrations greater than the MDC values were identified in 5 samples ( DCA- SEDI-01-B-QC, B, B-D, B, and 06-B) . T he positive samples range from 1.01E-01 pCi/g (approximately 41 % Class 3 AC) minimum to a maximum concentration of 5.51 E-01 pCi/g (3 times the Class 3 AC) .

The presence of HTD beta- emitting ROCs (i.e., Sr-90, C-14, Fe-55, Ni-63, and Tc-99) in the SOCA2 survey area was evaluated using analytical results for the QC samples transferred to the off-site laboratory. As

3-86 Revision 1 SECTIONTHREE Radiological Findings shown in Table 3-93, the analyses did not identify any HTD beta -emitting ROC above the MDC value achieved during the analyses.

Table 3-90 On -Site Laboratory Analysis Results for DCA Sediment Samples

3-87 Revision 1 SECTIONTHREE Radiological Findings 3.9.4 Data Quality Comparisons

On-Site Duplicate Counts The comparisons of the Cs-137 and Co- 60 results for the duplicate sample DCA- SEDI-03-B-D are shown in Table 3-91. The comparisons w ere found acceptable. Agreement is assumed when results are less than the achieved MDC Value.

Table 3-91 Duplicate Sample An alysis for DCA- SEDI-03-B-D

3-88 Revision 1 SECTIONTHREE Radiological Findings On-Site/Off-Site Laboratory Comparisons The comparisons of the Cs-137 and Co- 60 results for the QC sample DCA-SEDI-01-B-QC are shown in Table 3-92. The comparisons were found acceptable. Agreement is assumed when results are less than the achieved MDC value.

Table 3-92 On -Site/Off-Site S ample Analysis for DCA -SEDI-01-B-QC

Off-Site Laboratory HTD Analyses Table 3-93 Off -Site Laboratory Results for HTDs in D CA QC Samples HTD Measured Achieved AC Sample Number Medium Beta (pCi/g) MDC Exceeded (pCi/g) (Y/N)

Sr-90 1.89E-02 5.32E-02 N C-14 -2.23E-01 6.14E-01 N DCA- SEDI-01-B-QC SedimentFe-552.06E+011.70E+02N Ni-63 -2.01E+00 1.87E+02 N Tc-99 3.80E+00 1.72E+00 N

3.9.5 Survey Plan Deviation(s)

None.

3.9.6 Survey Area Investigations

3-89 Revision 1 SECTIONTHREE Radiological Findings None.

3.9.7 Survey Area Conclusions The following conclusions were reached for the DCA area:

The Discharge Canal contains detectable quantities of Cs-137 and Co -60.

The current Co-60 findings warrant the reclassification of the Discharge Canal to a Class 2 area.

3-90 Revision 1 SECTIONTHREE Radiological Findings 3.10 NPA (SAP 07 - BUILDINGS/STRUCTURES)

3.10.1 Area Description The buildings and structures within the NPA include the Demin Storage Tank (DST), Low -Level Radioactive Waste Storage Facility (LLRWSF), the Warehouse, Breathing Air Compressor Building, Chlorination Building, Clean Rigging and Storage Trailers, Condensate Transfer Pump House, Contractor Trailer Complex, Drywell Processing Center, Fire Water Pump House, Fish Sample Pond, Hot Machine Shop, Maintenance Supervisor Building, Dilution Pump House, Intake, Discharge Structure, and New Maintenance Building. Refer to section 3.6.1 for the NPA area description. Only the DST, LLRWSF, and the Warehouse are expected to remain following site license termination. This phase of the site characterization effort focused on these three structures. All other NPA buildings are scheduled for demolition and were not surveyed.

Warehouse

RMA storage and staging areas were established in the west Warehouse upper deck by the loading dock and on the east Warehouse lower deck .

LLRWSF and DST

The LLRWSF was controlled as a satellite RCA supporting onsite storage of low -level radioactive waste and material. The bulk of the waste was stored in the form of spent resin, filter sludge, evaporator bottoms, and DAW. Most of the waste and material was containerized and in shippable form. All radioactive materials stored without containers ha d fixed contamination with no smearable contamination being allowed. Decontamination and assembly of components with smearable contamination was allowed .

DST

The DST was in a fenced, posted RMA. The demineralized water system was cross-contaminated with fuel pool water in 1994. Most of the system was thoroughly flushed; however, pockets of low-level contamination are suspected in low-flow areas of piping . The DST was decontaminated in 1992. There is a potential for trace levels of radioactivity from the deposition of airborne contamination on the tank top from routine operation and the discharge of gaseous effluent.

3.10.2 Survey Summary Survey Period: 10/18/2022 through 11/15/2022

Survey activities were governed by SAP 07, Building/Structures - North Protected Area. Survey planning for the NPA buildings/structures area included the use of the VSP program to identify random sample locations consistent with MARSSIM methodology. In addition, biased locations were selected by the Radiological Engineer as locations where plant-related cross-contamination may have resulted from personnel. Some random survey locations were located within 6 feet of the roof's edge and were relocated to the closest point greater than 6 feet from the roof's edge for safety reasons.All sample locations included 1m2 scans with direct beta and alpha radiation measurements and 100 cm2 smears obtained at the highest count rate observed during the scan.

3-91 Revision 1 SECTIONTHREE Radiological Findings Warehouse

Planning for the survey of the Warehouse building included 90 VSP-generated random sample points on floor surfaces. In addition, 59 biased survey locations were selected on walls, including areas most likely to have been touched by personnel: light switches, door handles, frames, thermostat controllers, etc. Six locations on the warehouse roof were identified and surveyed as investigative samples due to elevated readings at roof drain locations. Two roof sample locations (NPA- WHS-86 and NPA-WHS-87) had to be relocated for safety concerns and are discussed in section 3-943.10.5.

Warehouse scans were conducted at all sample locations and general area floor scans using calibrated gas flow proportional or equivalent survey meters to identify the presence of elevated radioactivity. A total of 14,793 m2 were scanned (first floor 6,472 m2, second floor 1,241 m2, and roof 7,080 m 2). Direct measurements were logged. Except for 4 locations on the roof, all the scan surveys did not identify areas with audible distinctions above background. The 4 roof locations were investigated. Details of the investigations are provided in section 3.10.6.

LLR WSF and DST

The SAP 07 included planning for the LLRWSF buildings; however , the implementation of this plan was not performed because the se structures continue to be in use to support decommissioning activities as a storage location for radioactive waste material . Characterization surveys for the LLRWSF are expected to be rescheduled when the building is no longer being used for waste storage.

Planning for the survey of the DST structure, it was determined that the tank's exterior would not yield relevant waste characterization or FSS planning information, so the planned survey was not performed.

Characterization surveys should be scheduled for the DST when the tank is no longer being used, and the tank's interior surfaces are made accessible.

Table 3-94 summarizes the planned number and types of measurement for each structure in the NPA buildings/structures.

Table 3-94 Planned Number and Type of Measurements by Structure in the NPA Fixed-Point Volumetric Building/Structure Code Measurements Smears LAS Samples Low-Level Radioactive Waste Storage Facility LRW 250 250 0 0 Warehouse WHS 155 155 0 0 Demin Storage Tank DST 13 13 0 0

3-92 Revision 1 SECTIONTHREE Radiological Findings 3.10.3 Survey Data Summary Discussion

The characterization data from the Warehouse consist of gross activity measurements without the identification of specific ROCs. It is important to emphasize that gross activity measurements may not reflect only residual plant- related radioactivity and should not be directly compared to any specific ROCs DCGL value without consideration to material background radioactivity (i.e., NORM associated with building materials). Experience has shown that NORM content in various building materials, such as concrete, tiles, wallboard, and ceiling materials, can contribute several hundred counts to gross activity measurements.

The direct beta/gamma measurements collected on the first and second floors of the Warehouse are below the AC for Cs-137 and Co-60, and the direct alpha measurements are below the AC for the representative alpha-emitting ROC (Am- 241). The direct measurements from the roof show wider ranges for beta/gamma and alpha measurements. The upper end of those ranges exceeds the AC for Co-60 (8.10E+03 dpm/100 cm2) and Am-241 (9.88E+02 dpm/100 cm2). S mear data from the roof, first, and second floors show no removable contamination.

The higher measurements from the Warehouse roof do not necessarily reflect a need for remediation. They may reflect the presence of a higher quantity of naturally occurring radioactive materials (NORM) in roofing material or possibly residual deposition from gaseous effluent releases. Further characterization data, particularly the collection of material background radioactivity data, should be collected to support final status survey designs for buildings.

The Warehouse is currently designated as a Class 2 structure. The collection of material background data to determine the amount of potential residual plant-related radioactivity may lead to less restrictive MARSSIM classification for FSS.

Table 3-95 Data Summaries for Statistically -Determined Warehouse Floor Measurement Locations

Direct Measurement Range Standard Gross Minimum Maximum Mean Deviation Percent Instrument Floor Measurement (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) Removable1 Type 1st Beta 967 5993 3511 1616 0.00% 3003/43-68 Alpha 0 91 37 30 0.00% 3003/43-68 2nd Beta 4162 6706 5097 661 0.00% 3003/43-68 Alpha 0 169 42 42 0.00% 3003/43-68 Roof Beta 5756 8531 6861 809 0.00% 3002/43-93 Alpha 239 1093 568 193 0.08% 3002/43-93

3-93 Revision 1 SECTIONTHREE Radiological Findings Table 3-96 Data Summaries for Biasedly -Determined Warehouse Measurement Locations

Direct Measurement Range Standard Gross Minimum Maximum Mean Deviation Percent Instrument Floor Measurement (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) Removable1 Type 1st Beta 2314 4522 3554 571 0.00% 3003/43-68 Alpha 0 61 24 24 0.00% 3003/43-68 2nd Beta 1220 4985 3040 1132 0.00% 3003/43-68 Alpha 0 61 15 19 0.00% 3003/43-68

3.10.4 Data Quality Comparisons

On-Site Duplicate Counts Duplicate counts for all smears were less than MDC. All comparisons for duplicate smears are maintained as project files.

On-Site/Off-Site Laboratory Comparisons None - not applicable.

Off-Site Laboratory HTD Analyses None - not applicable.

3.10.5 Survey Plan Deviation(s)

Two measurement locations required deviations for safety concerns. Sample points NPA-WHS-86 and -

87 were randomly located by VSP but were within 6 feet of the buildings edge.The measurement locations were moved to maintain the 6-foot safety margin .

3.10.6 Survey Area Investigations While performing the scan and direct measurements of the VSP-generated survey locations, direct measurements of the warehouse roof revealed 4 roof drains with audible distinction greater than background. To determine the extent of condition, all 6 roof drains were surveyed. The roof drains showed elevated direct measurements and low levels of removable activity. The investigation survey locations were identified with consecutive sample numbers NPA-WHS-150-I through NPA-WHS-155-I. Upon review of the smear results, it was determined that the loose surface activity was attributable to NORM or gaseous effluent fallout.

Additionally, 3 investigative surveys were performed to evaluate the presence of NORM on the roof surface. These sample locations were identified with consecutive sample numbers NPA-WHS-156-I through NPA-WHS-158-I. Upon review of the survey results, it could not be determined conclusively if the measurements were due to either NORM or gaseous effluent fallout.

3-94 Revision 1 SECTIONTHREE Radiological Findings 3.10.7 Survey Area Conclusions The following conclusions were reached for the NPA Buildings/Structures :

The Warehouse does not present an unexpected radiological issue or concern.

Material background data should be collected to support a successful final survey design.

The preliminary Class 2 designation should be retained until material background data become available for determining the potential presence and amount of residual plant-related radioactivity.

The source of the removable activity on the roof needs to be evaluated further.

The LLRWSF and DST should be scheduled for future characterization surveys.

3-95 Revision 1 SECTIONTHREE Radiological Findings 3.11 SPA (SAP 09 - BUILDINGS/STRUCTURES)

3.11.1 Area description The buildings and structures within the SPA include the Oyster Creek Administration Building (OCAB),

Site Emergency Building (SEB), New Gatehouse Facility (NGF), Building 3 Old Machine Shop, Building 4 Site Storage Building, Diesel Generator Building, Hazard Collection Building, Main Access Facility (MAF), Main Gate Security Center, Chlorination Facility, Pretreatment Building, and the liquid nitrogen, main fuel oil , and sodium hypochlorite storage tanks. Refer to section 3.7.1 for the area description. Only the OCAB, SEB, and NGF are expected to remain for use following site license termination. Site characterization focused on these three buildings. All other buildings and structures are scheduled for demolition and were not surveyed during this phase of site characterization.

3.11.2 Survey Summary Survey Period: 9/26/2022 through 11/15/2022

Survey activities were governed by SAP 09, Building/Structures - South Protected Area. Survey planning for the SPA buildings/structures area included the use of the VSP program to identify random sample locations consistent with MARSSIM methodology. In addition, biased locations were selected by the Radiological Engineer as locations where plant-related cross- contamination may have resulted from personnel. Some random survey locations were located within 6 feet of the roof's edge and were relocated to the closest point greater than 6 feet from the roof's edge for safety reasons. All sample locations included 1m2 scans with direct beta and alpha radiation measurements and 100 cm 2 smears obtained at the highest count rate observed during the scan. The planned number of samples and measurement type for each SPA structure are shown in Table 3-94.

Oyster Creek Administration Building

Planning for the survey of the OCAB included 100 VSP-generated random sample points on floor surfaces.

In addition, 56 biased survey locations were selected, 55 on wall surfaces, and 1 on the floor. The biased locations on the walls, including areas below 8 feet, were most likely to have been touched by personnel such as light switches, door handles, frames, thermostat controllers, etc. One of the biased locations (SPA -

OCB-156-B) was selected under a false floor in the computer room.

OCAB scans were conducted at all sample locations and general area floor scans using calibrat ed gas flow proportional or equivalent survey meters to identify the presence of elevated radioactivity.A total of 12, 579 m2 were scanned (first floor 2,884 m2, second floor 3,049 m2, third floor 4,366 m2, and roof 2,280 m2).

Direct measurements were logged.Except for 2 locations on the roof, all t he scan surveys did not identify areas with audible distinctions above background. The 2 roof locations were investigated. Details of the investigations are provided in section 3.10.6.Four roof sample locations (SPA -OCB-61, -62, -63, and -64) had to be relocated for safety concerns and are discussed in section 3.11.5.

3-96 Revision 1 SECTIONTHREE Radiological Findings Site Emergency Building

Planning for the survey of the SEB included 125 VSP-generated random sample points on floor surfaces.

In addition, 46 biased survey locations were selected, 43 on wall surfaces, and 3 on the floor. The biased locations on the walls, including areas below 8 feet and were most likely to have been touched by personnel:

light switches, door handles, frames, thermostat controllers, etc. Three biased locations were selected under a false floor in the computer room. T hree roof sample locations (SPA-SEB-111-D, -112, and -114) had to be relocated for safety concerns and are discussed in section 3.11.5.

SEB scans were conducted at all sample locations and general area floor scans using calibrated gas flow proportional or equivalent survey meters to identify the presence of elevated radioactivity. A total of 5,634 m2 were scanned (first floor 2,395 m 2, second floor 1,821 m2, and roof 1,418 m2). Direct measurements were logged.

New Gatehouse Facility

Planning for the survey of the NGF included 45 VSP-generated random sample points on floor surfaces.

In addition, 15 biased survey locations were selected on the walls, including areas below 8 feet. They were most likely to have been touched by personnel: light switches, door handles, frames, thermostat controllers, etc. Three roof sample locations (SPA-NGF-48, -54, and -55) had to be relocated for safety concerns and are discussed in section 3.11.5.

NGF scans were conducted at all sample locations and general area floor scans using calibrated gas flow proportional or equivalent survey meters to identify the presence of elevated radioact ivity. A total of 1,319 m2 were scanned (first floor 802 m2 and roof 517 m2 ). Direct measurements were logged.

Table 3-97 Planned Number and Type of Measurements by Structure in the SPA Building/Structure Code Fixed-Point Smears Volumetric Measurements Samples Oyster Creek Administration Building OCB 155 155 0 Site Emergency Building SEB 165 165 0 New Gatehouse Facility NGF 60 60 0

3.11.3 Survey Data Summary Discussion

Comparison of the direct measurements to the AC for Cs- 137 and Co- 60 shows that while the upper ends of the measurement ranges are less than the Cs- 137 AC in all the buildings, they exceed the more conservative AC for Co-60 on at least one floor inside each building. Comparing direct measurement ranges for the roofs to the Co- 60 AC show similar results. In addition, the upper ends of the gross alpha measurement ranges for the OCAB and SEB exceed the AC for the representative alpha- emitting ROC (i.e.,

Am-241). Except for the NGF roof, the mean values for the direct measurements are significantly below the AC.

3-97 Revision 1 SECTIONTHREE Radiological Findings The finding that some gross measurements exceed AC do es not necessarily reflect a need for remediation.

Gross measurements collected inside the buildings may reflect varying material backgrounds. Gross measurements from the roofs may reflect a high NORM content in roofing material or possibly residual deposition from gaseous effluent releases. Additional characterization and material background data are needed to determine if the gross measurements reflect NORM or plant-related radioactivity.

Table 3-98 Data Sum maries for Statistically -Determined OCAB Floor Measurement Locations Fixed-Point Measurement Range Standard Gross Minimum Maximum Mean Deviation Percent Instrument Floor Measurement (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) Removable1 Type 1st Beta 1241 6120 2931 1576 0.00% 3003/43-68 Alpha 0 213 44 64 0.00% 3003/43-68 2nd Beta 3461 9630 4671 1413 0.00% 3003/43-68 Alpha 0 84 22 27 0.00% 3003/43-68 3rd Beta 3362 4726 4180 326 0.00% 3003/43-68 Alpha 0 148 30 45 0.00% 3003/43-68 Roof Beta 2019 5700 3395 1080 0.00% 3003/43-68 Alpha 213 911 464 176 0.00% 3003/43-68 Table 3-99 Data Summaries for Biasedly -Determined OCAB Measurement Locations

Fixed-Point Measurement Range Standard Gross Minimum Maximum Mean Deviation Percent Instrument Floor Measurement (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) Removable1 Type 1st Beta 1619 7908 2626 1440 0.00% 3003/43-68 Alpha 0 91 24 26 0.00% 3003/43-68 2nd Beta 2610 4667 3248 455 0.00% 3003/43-68 Alpha 0 106 37 25 0.00% 3003/43-68 3rd Beta 1704 2776 2144 313 0.00% 3003/43-68 Alpha 0 61 22 24 0.00% 3003/43-68 Table 3-100 Data Summaries for Statistically -Determined SEB Floor Measurement Locations

Fixed-Point Measurement Range Standard Gross Minimum Maximum Mean Deviation Percent Instrument Floor Measurement (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) Removable1 Type 1st Beta 3599 8044 5029 981 0.00% 3003/43-68 Alpha 0 141 47 32 0.00% 3003/43-68 2nd Beta 2965 7298 4751 1027 0.00% 3003/43-68 Alpha 0 141 42 40 0.00% 3003/43-68 Roof Beta 4539 9623 6571 951 0.00% 3002/43-93 Alpha 209 1171 519 224 0.00% 3002/43-93

3-98 Revision 1 SECTIONTHREE Radiological Findings Table 3-101 Data Summaries for Biasedly -Determined SEB Measurement Locations

Fixed-Point Measurement Range Standard Gross Minimum Maximum Mean Deviation Percent Instrument Floor Measurement (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) Removable1 Type 1st Beta 2714 8044 5029 981 0.00% 3003/43-68 Alpha 0 141 47 32 0.00% 3003/43-68 2nd Beta 3496 11034 4799 1778 0.00% 3003/43-68 Alpha 0 141 42 40 0.00% 3003/43-68 Table 3-102 Data Summaries for Statistically -Determined NGF Floor Measurement Locations

Fixed-Point Measurement Range Standard Gross Minimum Maximum Mean Deviation Percent Instrument Floor Measurement (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) Removable1 Type 1st Beta 3085 11225 7797 2241 0.00% 3003/43-68 Alpha 0 190 33 39 0.00% 3003/43-68 Roof Beta 7332 11169 9776 1026 0.00% 3002/43-93 Alpha 60 501 234 137 0.00% 3002/43-93 Table 3-103 Data Summaries for Biasedly -Determined NGF Measurement Locations

Fixed-Point Measurement Range Standard Gross Minimum Maximum Mean Deviation Percent Instrument Floor Measurement (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) (dpm/100cm2) Removable1 Type 1st Beta 3306 7539 4620 1102 0.00% 3003/43-68 Alpha 0 113 30 34 0.00% 3003/43-68

3.11.4 Data Quality Comparisons

On-Site Duplicate Counts Duplicate counts for all smears were less than MDC.

On-Site/Off-Site Laboratory Comparisons None - not applicable.

Off-Site Laboratory HTD Analyses None - not applicable.

3.11.5 Survey Plan Deviation Ten sample points required deviations for safety concerns, 3 each at the SEB and NGF, 4 at the OCB.

Sample points SPA -SEB-111-D, SPA-SEB -112, SPA-SEB -114, SPA-OCB-61, SPA-OCB -62, SPA-OCB

-63, SPA-OCB -64, SPA-NGF-48, SPA-NGF -54, SPA-NGF -55 were all randomly located by VSP in areas that were within 6 feet of the building edge. Sample points were relocated to the nearest accessi ble location where the 6-foot safety margin could be maintained.

3-99 Revision 1 SECTIONTHREE Radiological Findings 3.11.6 Survey Area Investigations Elevated readings were identified during the building surface scan surveys on the OCAB's third floor. The location was investigated and recorded as SPA-OCB-159-I. The measurement was not reproducible during the investigation and was determined to be a false positive.

Additionally, surface scans of the OCB roof revealed two locations, SPA-OCB-157-I and SPA-OCB-158-I, where counts with audible distinctions above background. The investigation measurements at the location were within the statistical range of the data set. Smears were counted and identified the presence of alpha contamination above MDC . The a ctivity was still present when the smears were recounted approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> later. Three additional investigation surveys were performed to evaluate the presence of NORM on the roof surface. These sample locations were identified with consecutive sample numbers SPA-OCB-160-I through SPA-OCB-162-I; the results were inconclusive. T he investigation continued by collecting a volumetric sample of sediment from the roof. On -site gamma analysis of the sample (SPA-OCB-SEDI-01-I) showed the presence of NORM, Cs-137 (9.74E-01 pCi/g), and Co-60 (1.60E+00 pCi/g).

Three similar investigative surveys were performed on the SEB and NGF roofs. The SEB sample locations were identified with consecutive sample numbers SPA-SEB-169-I through SPA-SEB-171-I. The NGF sample locations were SPA-NGF-61-I through SPA-NGF-63-I. V olumetric samples of sediment were collected from the two roofs. On-site gamma analysis of the SEB volu metric sample (SPA- SEB-SEDI I) showed the presence of NORM and Cs- 137 (1.43E-01 pCi/g). On -site gamma analysis of the NGF volumetric sample (SPA -NGF-SEDI-01-I) showed the presence of NORM. The results of the investigations could not conclusively determine if the activity was due to NORM or gaseous effluent fallout.

3.11.7 Survey Area Conclusions The following conclusions were reached for the SPA Buildings/Structures:

The OCAB, SEB, and NGF do not present an unexpected radiological issue or concern and areas likely to meet release criteria.

The roof of the OCAB should be reclassified as MARSSIM Class 2. The preliminary Class 3 should be retained for the remaining portions of the SPA Area structures (OCAB, SEB , and NGF).

Consider collecting material background data for various structure media types to support final survey design.

3-100 Revision 1 SECTIONTHREE Radiological Findings 3.12 GROUNDWATER

3.12.1 Introduction NRC regulations (10 CFR 20.1402) and NJAC 7:28 -12.8 include dose contributions from groundwater as a drinking water source and through the groundwater exposure pathways in their radiological criteria for unrestricted release. As part of the radiological characterization of the OCNGS, the current radiological status of the groundwater at the OCNGS site was determined by a review of the 2022 groundwater monitoring data summarized in the February 2023 letter from AMO Environmental Decisions to the OCNGS Radiological Groundwater Protection Program (RGPP) Coordinator [ Ref. 5].

OCNGS continues to monitor groundwater in accordance with NEI 07-07. The monitoring program includes 14 background wells, 14 d etection wells, and 6 long t erm shutdown wells that allow monitoring of the Cohansey and Cape May Aquifers. Figure 3-10 and Figure 3-11 show the locations of OCNGS RGPP groundwater monitoring wells for each aquifer as well as the site groundwater contours.

Figure 3-10 OCNGS RGPP Monitoring Wells for the Cohansey Aquifer

3-101 Revision 1 SECTIONTHREE Radiological Findings

Figure 3-11 OCNGS RGPP Monitoring Wells for the Cape May Aquifer

3.12.2 Discussion The 2022 groundwater data set includes results for 35 samples collected in April, 2 samples collected in June, and 20 samples collected in October. All samples were analyzed for tritium and gamma -

radionuclides. Samples from Detection and Long- Term Shutdown wells were also analyzed for gross-a l pha and beta, and strontium-89 and -90. Table 3-104 provides a summary of the 2022 groundwater data.

The OCNGS RGPP detection limit for tritium in groundwater is 200 pCi/L. Most of the groundwater samples showed non- detectable (i.e., below the detection limit) tritium results. In 2022, tritium was detected at low concentrations in 5 groundwater samples collected from the Cape May Formation wells and in 8 samples collected from Cohansey Formation wells. The positive 2022 data from the Cape May formation wells ranged from 204 pCi/L to 237 pCi/L, whereas the positive 2022 data from the Cohansey formation wells ranged from 209 pCi/L to 605 pCi/L. The Cape May formation sample showing the highest tritium concentration (237 pCi/L) was collected f rom well MW-54 and the Cohansey formation sample showing the highest concentration (605 pCi/L) was collected from well W-13. Well MW-54 is located West of the reactor and turbine buildings, downstream of the historic Condensate Storage Tank (CST)

3-102 Revision 1 SECTIONTHREE Radiological Findings release location. Well W-13 is located northeast of the reactor and turbine buildings, upstream of the historic CST release location. It is noted that several positive detections of tritium in the April samples were found to be significantly lower in the October samples. For example, well MW- 13 showed a tritium concentration equal to 605 pCi/L in the April sample and a significantly lower tritium concentration (313 pCi/L) in the June sample.

Analyses for gross-alpha (suspended), gross-beta (dissolved), and gross beta (suspended) did not show concentrations that exceeded their respective alert levels. Gamma-radionuclides, strontium 89 and 90 are analyzed for annually and were not detected in the samples collected.

Table 3-104 Recent Results from the OCNGS NEI 07-07 Groundwater Protection Program Sample Result Sample Result Well ID Aquifer Date (pCi/L) Well ID Aquifer Date (pCi/L)

MW-16D Cape May 4/27/2022 177 W-5 Cape May 4/26/2022 19110/26/2022 186 10/25/2022 187

MW-67 Cape May4/26/2022 236 W-16 Cape May4/27/2022222 10/26/2022 192 6/23/2022 191

MW-71 Cape May 4/27/2022 164 W-24 Cape May 4/28/2022 17710/26/2022 192 MW-1A -2A Cape May 4/27/2022 167

MW-72 Cape May 4/27/2022 165 W-15 Cape May 4/27/2022 18010/26/2022204 MW-52 Cape May 4/26/2022 187

W-12 Cape May 4/27/2022 185 MW-53 Cape May 4/26/2022 180 10/26/2022 175 MW-54 Cape May4/26/2022 237

W-9 Cape May 4/27/2022 188 W-34 Cohansey 4/28/2022 17910/26/2022 180 10/26/2022 183

MW-15K -1A Cape May 4/26/2022 173 MW-56I Cohansey4/26/2022 209 10/25/2022 190 10/25/2022 270 MW-1I -1A Cape May 4/27/2022 181 MW-57I Cohansey4/26/2022 368 10/25/2022 191 10/25/2022 189 MW-1I -2A Cape May 4/27/2022 181 MW-59I Cohansey4/26/2022 379 10/25/2022 189 10/25/2022 199 MW-55 Cape May 4/26/2022 172 MW-61I Cohansey4/26/2022183 10/25/2022 169 10/25/2022 189 MW-62 Cape May 4/26/2022 193 W-13 Cohansey4/27/2022605 10/25/2022 186 6/23/2022 313

MW-64 Cape May 4/26/2022 180 W-1A Cohansey 4/28/2022 18310/25/2022 191 W-4A Cohansey 4/28/2022 179

MW-65 Cape May 4/26/2022 172 W-10 Cohansey 4/27/2022 19310/25/2022 196 W-14 Cohansey 4/27/2022 180

W-3 Cape May4/26/2022 187 W-6 Cohansey 4/27/2022 187 10/25/2022 196 W-4 Cohansey 4/26/2022 182

3-103 Revision 1 SECTIONTHREE Radiological Findings

3.12.3 Groundwater Conclusions

Based on review of the 2022 RGPP sampling data and historic data, there is no ongoing tritium leak at the Station. OCNGS should continue monitoring the site s groundwater through decommissioning of the site.

The highest tritium concentration in the latest groundwater sampling campaign (i.e., 313 pCi/L in the June 2022 sample from W-13) represents <2% of the EPA drinking water standard (20,000 pCi/L).

3-104 Revision 1 SECTIONFOUR Conclusions

4 CONCLUSIONS The conclusions listed below apply to the OCA's open land areas and structures. Characterization is an iterative process , and additional characterization data will be collected as decommissioning and demolition activities progress.

All gaps identified in the SCP (Table 4-2 Summary of Radiological Data Gaps by OCS Study Area) have been resolved.

OPEN LAND AREAS

NOCA-1, SOCA-1, SOCA-2

MARSSIM Class 3 designation is appropriate for the NOCA-1 survey area.

Excavation or remediation of soil within the NOCA-1 area is likely not necessary for the area to meet site release criteria.

NOCA-2

Excavation of the contaminated soil relocated in 1982 under the North Parking is not likely, as indicated by the low Cs-137 concentration in the deep soil sample (i.e., a measured concentration of less than 10% of the Cs-137 AC). The measured Cs -137 and Co-60 concentrations in NOCA-2 samples indicate that the area meets MARSSIM Class 3 criteria.

MARSSIM Class 1 designation is appropriate for the NOCA -2 survey area: basis (waste storage location).

EOCA-1

Retaining the MARSSIM Class 2 designation for the waste travel routes within the EOCA -1 boundary is appropriate; this is a historical waste travel route, and its continued use is likely.

EOCA- 1A and EOCA-1B should be established as separate MARSSIM Class 3 areas. Residual plant-related contamination in the survey area meets the criteria in NUREG -1575 for a MARSSIM Class 3 area.

Excavation or remediation of soil within EOCA1 Class 3 areas is likely not necessary to meet site release criteria.

NPA, SPA

The Cs-137 and Co- 60 concentrations found in NPA samples do not require excavation or remediation to meet site release criteria at this time. The current radiological status may change as active decommissioning of the site commences.

Radiological status changes may warrant additional site characterization collection to support FSS planning.

Additional characterization in yard areas, including walk- over gamma scans and soil sampling, should be considered when waste containers are moved.

4-1 Revision 1 SECTIONFOUR Conclusions

RCA

Collected data confirms that the RCA is MARSSIM Class 1.

The Cs-137 and Co- 60 concentrations in soil samples from locations 4 and 15 indicate that excavation or remediation is required to meet site release criteria.

DCA

The Discharge Canal contains detectable quantities of Cs-137, Co-60, and Tc-99.

The current Co-60 findings warrant the reclassification of the Discharge Canal to a Class 2 area.

BUILDINGS/STRUCTURES

NPA

The Warehouse does not present an unexpected radiological issue or concern.

Material background data should be collected to support a successful final survey design.

The preliminary Class 2 designation should be retained until material background data become available for determining the potential presence and amount of residual plant-related radioactivity.

The source of the removable activity on the roof needs to be evaluated further.

The LLRWSF and DST should be scheduled for future characterization surveys.

SPA

The OCAB, SEB, and NGF do not present an unexpected radiological issue or concern and areas likely to meet release criteria.

The roof of the OCAB should be reclassified as MARSSIM Class 2. The preliminary Class 3 should be retained for the remaining portions of the SPA Area structures (OCAB, SEB , and NGF).

Consider collecting material background data for various structure media types to support final survey design.

4-2 Revision 1 SECTIONFIVE Recommendations

5 RECOMMENDATIONS The following recommendations are made based on the radiological data collected during this phase of site characterization:

1. Retain the MARSSIM Class 2 designation for the waste travel routes within the EOCA -1 boundary. Establish MARSSIM Class 3 areas for EOCA -1A and EOCA-1B.

2. Retain the MARSSIM Class 1 designation for the NOCA-2 survey area. Additional depth interval sampling should be conducted when waste containers are removed and asphalt is removed to expose underlying soils as part of the iterative characterization process .

3. Perform additional characterization in NPA and SPA yard areas, including walk- over gamma scans and soil sampling when the waste containers are removed.

4. Collect and evaluate building material background data to support final survey design.

5. Retain the preliminary MARSSIM c lassification of buildings until building material background data becomes available.

6. Reclassify OCAB roof as MARSSIM Class 2.

7. Evaluate the nature of the removable activity (i.e., NORM or plant -related) on the warehouse roof.

8. Schedule LLRWSF and DST characterization surveys when no longer required for site use.

5-1 Revision 1 SECTIONFIVE Recommendations

6 REFERENCES

1. Oyster Creek Generating Station Site Characterization Plan, Rev. 0, June 2022

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

3. Oyster Creek Station Historical Site Assessment , Rev. 1, November 2020

4. NRC Inspection Procedure 84525, Quality assurance and confirmatory measurements for in-plant radiochemical analysis (preoperational and supplemental), May 1985

5. Letter from AMO Environmental Decision to the OCNGS RGPP Coordinators, dated, February 24, 2023

6-1 Revision 1

ML24214A044

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