NRC-09-0070, Enrico Fermi Atomic Power Plant, Unit 1, Submittal of NRC Requested Information Regarding License Termination Plan

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Enrico Fermi Atomic Power Plant, Unit 1, Submittal of NRC Requested Information Regarding License Termination Plan
ML093640040
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 12/03/2009
From: Plona J
DTE Energy
To:
Document Control Desk, NRC/FSME
References
NRC-09-0070
Download: ML093640040 (27)
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Joseph H. Plona Site Vice President 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.5910 Fax: 734.586.4172 DTE Energy-December 03, 2009 NRC-09-0070 U.S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D.C. 20555

Reference:

1) Enrico Fermi Atomic Power Plant, Unit 1 NRC Docket No. 50-16 NRC License No. DPR-9
2) Detroit Edison Letter, NRC-09-0017, "Proposed License Amendment -

License Termination Plan", Dated March 25, 2009

3) Detroit Edison Letter, NRC-09-0046, "Modeling Scenarios for Fermi 1 License Termination Plan Criteria", Dated August 27, 2009
4) Detroit Edison Letter, NRC-09-0053, "Information Regarding the Fermi 1 License Termination Plan", dated October 30, 2009

Subject:

Enrico Fermi Atomic Power Plant, Unit 1 Information Regarding the Fermi 1 License Termination Plan The NRC requested that certain documents be submitted and docketed to aid in their technical review of the Enrico Fermi Unit 1 (EFI) License Termination Plan (LTP).

The following documents are being submitted for review:

1. An EF1 site boundary diagram
2. Figures 1.2 and 1.3 in 1 lx17 legible versions
3. Site locations of events

+5Mg

USNRC December 03, 2009 NRC-09-0070 Page 2

4. List of LTP references revisions or effective date
5. List of questions with EFI answers
6. MEF215, "Final Status Survey Background Assessment" and associated Form 52, "Background Assessment Data Sheet" Note that the attached site drawing shows the Fermi 1 portion of the Fermi site. The actual license termination boundary is the portion of the site within the Fermi 1 perimeter road as discussed in the License Termination Plan, Section 1.3.2.

Should you have any questions, please contact Lynne Goodman, Manager, Fermi 1 at (734)586-1205 Sincerely,

~4 Joseph H. Plona JHP/ME/ljd Attachments cc: NRC Regional Administrator, Region II.

T. Smith, NRC (Washington, D.C.)

NRC Resident Inspector- Fermi 2 P. Lee, NRC Region III T. Strong (Michigan Dept. of Environmental Quality)

USNRC December 03, 2009 NRC-09-0070 Page 3 bcc: w/o attachments J. Austerberry D. Breiding A. Bodipo-Memba C. Byrd W. Colonnello J. Conner J. Conen L. Goodman R. Johnson K. Lindsey R. Nearhoof D. Niemeyer J. H. Plona J. Robinson S. Stasek J. Thorson T. VanderMey Fermi 1 Staff Information Management (140 NOC) - Fermi 1 Records w/electronic attachments NRR Chron File (Licensing) w/o attachments NRC Notebook (Fermi 1) w/o attachments

Enrico Fermi Unit 1 License Termination Plan References, Revisions, and Dates NRC-09-0070 Page 1 Chapter 1 U.S. Nuclear Regulatory Commission Regulatory Guide 1.179 "Standard Format and Contents for License Termination Plans for Nuclear Power Reactors" January, 1999 U.S. Nuclear Regulatory Commission NUREG-1575 "Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) Rev. 1" August, 2000 U.S. Nuclear Regulatory Commission NUREG-1700 "Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans" Rev. 1 April, 2003 U.S. Nuclear Regulatory Commission NUREG-1757 "Consolidated NMSS Decommissioning Guidance" Vol. 2 Rev. 1 September, 2006 U.S. Nuclear Regulatory Commission NUREG-0586 "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities." August, 1988 Chapter 2 Enrico Fermi Atomic Power Plant, Unit 1, Fermi 1 Manual Revision 110 Power Reactor Development Company, Technical Information and Hazards Summary Report June, 1961 Technical Based Document, (TBD) NESF-08-0018, Radionuclide Selection for DCGL Development Revision 0 U.S. Nuclear Regulatory Commission NUREG/CR-2082 - Monitoring for Compliance with Decommissioning Termination Survey Criteria 1981 Chapter 3 Fermi 2 Updated Final Safety Analysis Report Revision 13

Enrico Fermi Unit 1 License Termination Plan References, Revisions, and Dates NRC-09-0070 Page 2 Chapter 4 None Chapter 5 Technical Based Document, (TBD) NESF-08-0018, "Radionuclide Selection for DCGL Development" Rev. 0 Technical Based Document, (TBD) NESF-08-0022, "Instrument Efficiency Determination for Use in Minimum Detectable Concentration Calculations Rev. 1 Enrico Fermi Atomic Power Plant, Unit 1, Fermi 1 Manual Rev. 110 MEF200 Final Status Survey (FSS) Program Rev. 0 MEF201 FSS Quality Assurance Program Procedure (QAPP) Rev.0 MEF202 Collection of Site Characterization and FSS Samples Rev. 0 MEF203 Sample Security and Chain of Custody Rev. 0 MEF204 Sample Receipt and Preparation Rev. 0 MEF205 Determination of the Number and Locations of FSS Samples Rev.0 MEF206 Turnover and Control of Areas for FSS Rev.0 MEF207 Survey Unit Classification Rev. 0 MEF208 Preparation of FSS Survey Plans Rev. 0 MEF209 Statistical Tests Draft MEF210 Area Surveillance Following FSS Draft MEF2 11 Data Quality Assessment Draft MEF212 Preparation of FSS Reports Draft MEF213 Split Sample Assessment for Final Status Survey Draft MEF214 Computer Determination of the Number and Location of FSS Samples and Measurements Rev. 0 MEF2i5 FSS Background Assessment Rev. 0 MEF216 ALARA Evaluations for Final Status Survey Areas Draft MEF217 Setup and Operation of the Ludlum 2350-1 Digital Survey Instrument Rev. 0 MEF218 Control and Accountability of FSS Portable Survey Instruments Rev.0 Chapter 6 Code of Federal Regulations, Title 10, Section 20.1402, "Radiological Criteria for Unrestricted Uses." (1-1-03 Edition)

Chapter 7 None Chapter 8 Fermi 1 Safety Analysis Report. Rev.5 Fermi 2 Updated Final Safety Analysis Report Rev. 13

List of NRC Questions with Enrico Fermi Unit 1 Responses NRC-009-0070 Page 1 Q. Explain how the volumetric contaminationwill be determinedfor the exteriors of the buildings as part of the characterizationprocess.

EFJ Answer:

Through the years there have some repairs made to the roofs of the EF1 structures. There repairs have been the addition of tar or membranes to provide a leak-tight surface. It is EF1 intentions to perform scans and fixed-point measurements on the surfaces with gas-flow proportional instrumentation as well as ganmma scans performed with a scintillation detector. It is our opinion that a layer of tar or a membrane would not attenuate the gamma readings sufficiently so as to mask potential areas of activity and that scanning and fixed-point measurements are sufficient for the surveys. Should activity be identified there may be need for volumetric assessments.

Q. Explain how the potentialfor under building contaminationwill be determined and verification that the subsurface soils are below release criteria.

EF1 Answer:

The interior surfaces of the EF1 buildings will be surveyed and will be assessed for not only the presence of contamination but for the potential for the migration of contamination through the structure into the subsurface soils. If there is indication that contamination may have migrated into the subsurface soils, EF1 will perform subsurface soil assessments by appropriate means (e.g. core boring, etc.).

Q. Provide the technical basisfor the determinationand use of reference backgroundareas employed in the Fermi-] characterization,remedial action andfinal status surveys.

EF1 Answer:

EFi procedure MEF215 "Final Status Survey Background Assessment" provides direction on the determination and use of background areas and a copy of that procedure is attached.

Q. Provide decommissioning technical basis documentsfor the following:

Bartlett Engineering Calculations ENG-001 through ENG-006 Radionuclide selection for DCGL development (Ref 6.8.5, NSEF-08-0018, July 21,2008)

Buried and embedded piping derived concentration guideline levels (DCGLs)

DCGLs for volumetrically contaminated materials Detector sensitivity for minimum, detectable concentrations (MDCs)

Determination of investigation criteria and hot particle detection Provide your evaluation of the effects of surface coatings for beta detection (NUREG-1507)

List of NRC Questions with Enrico Fermi Unit 1 Responses NRC-009-0070 Page 2 EF1 Answer:

All documents have been, or will be, provided with the exception of the "Determination of investigation criteria and hot particle detection" and DCGLs for volumetrically contaminated materials. EF1 has not experienced the presence of hot particles and historical documentation has not determined that hot particles have been present at EFI, therefore we have not found it necessary to generate a Technical Based Document addressing hot particles. If during the continuing characterization process we identify hot particles we will develop "adocument addressing these. During the course of characterization of the EF1 site, volumetric contamination has not been observed. This is expected due to the very limited duration of operation of the plant as well as the design of a Liquid Metal Fast Breeder Reactor (LMFBR). If, during the continued characterization of EF1, volumetric contamination is found, EF1 will develop volumetric DCGLs and submit them, and the methodology, to the NRC for approval.

The engineering calculations will be submitted in a separate letter.

Q. Explain how direct radiationmeasurements areperformed and evaluatedfor the containment structure, specifically the exterior containment dome EF1 Answer:

Biased scans and biased fixed-point measurements will be performed on accessible exterior areas of the dome (i.e. locations accessible from the ground). The paint on the dome is original; therefore no correction is necessary for the coatings. The maximum distance from the surface to the detector (due to the curvature of the dome) will be utilized in the correction to the 47t efficiency.

Q. Indicate if grouting of embedded piping will occur. Note that if new DCGLs are developed for embedded piping, NRC review and approval of the DCGLs will be required.

EF1 Answer:

If the embedded piping DCGLs are utilized the embedded piping will be grouted in accordance with Technical Based Document NSEF-09-0016 "Derived Concentration Guideline Levels for Embedded Piping" which has been included in the documents submitted.

Q. Provide the following nine references:

EF1 Historical Site Assessment from 2008, (Ref 2.6.6) 6.8.5 Detroit Edison Technical Based Document, "Radionuclide Selection for DCGL Development, "Enrico Fermi Unit 1, NSEF-08-0018, July 21,2008.

6.8.J 1 Bartlett Engineering Calculation ENG-001, Sensitivity Analyses to Support EF1 Building Surface DCGLs, July 2008.

6.8.12 Bartlett Engineering Calculation ENG-002, Sensitivity Analysis for EF1 DCGLs for Soil, July 2008

List of NRC Questions with Enrico Fermi Unit 1 Responses NRC-009-0070 Page 3 6.8.13 Bartlett Engineering Calculation ENG-003, Calculation of EFI Building Surface DCGLs, September 2008.

6.8.14 Bartlett Engineering Calculation ENG-004, Calculation of EF1 Soil DCGLs, September 2008.

6.8.15 Bartlett Engineering Calculation ENG-005, Calculation of EF1 Building Surface Area Factors, October 2008.

6.8.16 Bartlett Engineering Calculation ENG-006, Calculation of DECo EF1 Area Factor for Soil, October 2008.

8.5.2 Detroit Edison letter, NRC-87-0174, "Transmittal of Supplemental Environmental Information Enrico Fermi Atomic Power Plant, Unit 1", dated September 25, 1987 as listed on page 8-17.

EF1 Answer:

The requested documents with the exception of the Engineering Calculations were submitted in Reference 4. The Engineering Calculations will be submitted separately.

Q. Provide requested hydrogeologicalinformation in GW questions EF1 Answer:

The hydrogeological information will be submitted in a subsequent submittal.

Q. If not already provided,provide information on the radiologicalcharacterizationof the site.

.This would include residual radioactivityin all media (including buildings; systems and equipment that will remain after license termination,surface and subsurface soil, and surface and subsurface ground water), characterizationof the radiologicalstatus (e.g., process historicaldevelopment, records of leakage or disposal), and clearly relate the information provided in the discussion of radiologicalstatus of the site with the discussion of source-term abstraction. Maps and cross-sectionswould be of benefit when detailing the extent of residual radioactivity left on the site.

EF1 Answer:

A site map is submitted with the locations of historical spills. The radiological characterization wasprovided in the EF1 Historical Site Assessment submitted in Reference 4.

Q. If not alreadyprovided,provide information on the potential contaminants of concern including details on the process of obtaining the final radionuclidesof concern EF1 Answer:

The Technical Based Document on Radionuclide selection for DCGL development provides these details and was included in Reference 4.

List of NRC Questions with Enrico Fermi Unit 1 Responses NRC-009-0070 Page 4 Q. The site-specific conceptual model should describe the following:

1. Either the qualitative or quantitativejustification that the criticalgroup is the highest exposed group for the assumed land use(s). The selection of the criticalgroup may be dependent on the assumption of the relative mixture of radionuclidesand sources of residual radioactivitypresent at the site.
2. Both the hydrologicand environmental transportprocesses important at the site, including the most importantphysical, chemical, and biologicalprocesses at the site.
3. The contaminants of the source area and how they are likely to be releasedinto the environment.
4. How contaminantsof the groundwaterpathway could migrate through the unsaturatedand saturatedzones to potential receptors (e.g., a well or a spring). Important processes that should be characterizedinclude the dimensions and state conditions (e.g., steady-state) offlow; dimensions and state conditions of transport(e.g., dispersion); chemical and mass transfer processes (e.g., sorption,precipitation,complexation); and transformationprocesses (e.g.,

radioactiveingrowth and decay).

5. Major assumptions which are consistent and defensible.

EF1 Answer:

The site-specific conceptual model will be submitted in a subsequent submittal.

Q. Provide input/outputfiles or printouts of computer modeling data EF1 Answer:

These files were submitted in Reference 3.

Q. Sec. 2.1.6 "Event Descriptions,"p. 2-15: The EF] HistoricalSite Assessment (HSA)from 2008 as described in Sec. 2.1.1 on p. 2-6 should provide more qualitative and quantitativedetail on the unplanned events.

EF1 Answer:

Details of these events are in EF1 Historical Site Assessment from 2008 which is included with Reference 4.

Q. App. 6A, Sec. 1 "Room Dimensions," p. 6-23: "The room on the secondfloor of the Sodium Building was selected as a representative room for the EF1 site buildings and was used as the modeling basisfor the building surfaces DCGLs." Provide the technicalbasis on why the Sodium Building can be used a representative room.

EF1 Answer: 2 While the 2 nd floor of the Sodium Building is not the largest room at EF1 (e.g. OFB (1170 m each floor), RXB (757 m2 each floor)) it is not the smallest (e.g. Vent. Bldg. (175 m2 , Tressleway (200 M2 ) the room selected (316 M2 ) falls between the rooms available for selection, size wise, and is the most probable for occupancy in the future since there are no scheduled

List of NRC Questions with Enrico Fermi Unit 1 Responses NRC-009-0070 Page 5 demolition/remedial actions~that would hamper occupancy (i.e. activities that would cause large holes in the floor or walls).

Q. App. 6F, Sec. 3 "Contaminated Zone Erosion Rate, "p. 6-49: The relationshipbetween two groundwatermonitoring wells and the erosion rate is not clear. If the topographicelevation of.

the two well localities were used in order to determine the slope between the two topographic points, the tepresentativeness of these two pointsfor the site slope would need to be demonstrated.

EF1 Answer:

The "Data Collection Handbook to Support Modeling the Impacts of Radioactive Material in Soil" states. the following:

The erosion rate of the contaminated zone only becomes significant if and when the cover zone is completely eroded, thus exposing the contaminated zone to the erosive effects of the environmental elements. If there is no initial cover, a greater erosion rate will remove the contaminated material faster. This may lead to lower doses than found for an initial cover case.

The RESRAD model uses a default value of an annual erosion rate equal to 0.001 m/y for both the cover and contaminated zones. The modeling for the Fermi 1 site did not include a cover, thus, the only erosion rate required was that for the contaminated zone. Rather than using the RESRAD default erosion rate, an erosion rate for the Fermi 1 site was determined from site-specific information provided in the Golder Associates report. This determination was enabled because the RESRAD modeling guidance cited above and Attachment C to NUREG/CR-6697 both provide erosion rates based on slope. The slope based on elevations of and distance between wells 10S and 8S (1.9%) was used as the basis for selecting the erosion rate input Value (6X10-4 m/y, which should be assumed for a 2% slope). The calculated slope (1.9%) is supported as a representative site slope by Figures 3 and 4 in the "Report on Groundwater Characterization -. Enrico Fermi 1 License Termination" issued by Golder Associates Inc.

Figure 3 shows the geologic cross section, including an elevation profile, for the Protected Area at the Fermi 1 site in the north-south direction. As shown in that figure, well 4S is located at the highest elevation near the mid-point of the north-south length of the Protected Area. This creates 2 potential slopes: one slope from well 4S to lower site elevations to the north and another slope from well 4S to lower elevations to the south. The slope from well 4S to well 8S approximately 145 ft to the north is approximately 1.1%. A similar slope exists to the south of well 4S. The slope from well 4S to well 6D (a distance of about 180 ft) is approximately 0.9%.

The geologic cross section, including an elevation profile, in the east-west direction is provided by Figure 4. The site slope from well 2S to well IS, separated by a distance of approximately 320 ft across the span of the Protected Area, is approximately 0.4%.

The elevation profiles shown in these 2 figures provide additional support that the use of an erosion rate based on a site slope of 1.9% is representative for the Fermi 1 site.

aN5 A A .

(NORTH) EFT.S/D (SOUTH)

EFT-8S & EFT-2SID EF-S EFT-6S EF'T-60 EFT--SR----- 585 Legend

- - - - - .. ", ASPHALT FILL o- FLL[ FILL El SILTY CLAY 575-- -- -- SILTY CLAY W/

-RACE FINE GRAVEL -

570, - - ------------- 7 SANDY CLAY GLACI LAE CLAY GLACIALLAKECLAY SILT 555 -- -- - - - - - - -- - - - - - - - - - - - ---- - -- - -- - - - - - - - -- - 565 E BED ROCK PIEZOMETRIC V'78.3'V GROUNDWATER 0 560 --560 ELEVATION

.GLACIAL TILL (OCT./NOV. 2004)

GLACIAL TILL POTENTDOMETRIC s* GROUNDWATER 5- - ---------- -------- - - - - - --- - - ELEVATION (OCT./NOV. 2004)

"0 MONITORING WELL PROFILE BEDROCK: BASS ISLANDS DOLOMITE 2! -SHO4 "GEOLOGIC CROSS SECTION A - A' 0,*/1/os " DETROIT EDISON GY FERMI I 2L 0IG *8 .... DY us FERMI MI DETROIT,

-~023-4093 1- 0 -~ ... 0TIEERMIl INI ' 3

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Legend ASPHALT FILL 0

[] SILTY CLAY 07 SILTY CLAY W/

TRACE FINE GRAVEL

] SAND 0 SANDY CLAY sBE RLT

[] BED ROCK PIEZOMETRIC CD GROUNDWATER

" eo ELEVATION (OCT./NOV. 2004) 0 cjn POTENTIOMETRIC GROUNDWATER ELEVATION (OCT./NOV. 2004)

(D1 cn MONITORING WELL PROFILE BEDROCK: BASS ISLANDS DOLOMITE

545 A "GEOLOGIC CROSS SECTION B - B' 03/18/0 DETROIT EDISON F= D DY FERMI 1

. is DETROIT, MI

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List of NRC Questions with Enrico Fermi Unit 1 Responses NRC-009-0070 Page 8 Q. App. 6F, Sec. 4 "Soil Type, "p. 6-49: The EFI site soil is classified as a sandy loam in this section. However, this descriptionseems to contradict the descriptiongiven in Section 2.2.3.1, page 2-53, number 2. In this section the fill material was describedas consisting primarilyof clay, and to a lesser extent sand and crushed stone. The 2007 Golder report also described the fill materialas being clay rich (Section 3.1.1).

EF1 Answer:

When classifying the soil type for the modeling of the Resident Farmer Scenario EF1 thought it prudent to rely on empirical data and therefore collected seven soil samples for analysis. The results of these samples are found in ENG-002 "DTE EF1 Soil Sensitivity Calc. Rev. 1" Attachment 2. The results indicate a content of 5.2-19.3 % clay with the remainder comprised of sand, silt and gravel. While visually the soils Would appear to be clay ricfi, the grain size distributions, as applied to the USDA method of soil classification, determined that the soil was of a sandy loam type, and as a result EF1 used this classification in the modeling.

Q. App. 6F, Sec. 9&10, pp. 6-52&53: The calculated unsaturatedzone thickness is given at 6.5 ft. If the fill material is lOft thick, the remaining thickness for the saturatedzone is 3.5 ft. It would need to be demonstrated that this saturatedzone could provide enough water to satisfy the water use consumption as given in Table 6F-3 on p. 6-52. Specifically, the following items would need to be addressed: the thinness of the aquifer, the low rate of recovery of water levels that were observed during slug tests, and highly localized horizontal movement of the perched groundwateras stated in Section 2.2.3.1, page 2-53, number 4.

EF1 Answer:

The resident farmer scenario includes certain water use assumptions. Consistent to the scenario, these water use assumptions were included in the development of the DCGL values for contaminated soil without confirmation of actual yield of the aquifers at the Fermi 1 site. The belief held is that if the aquifers cannot actually support the water use assumptions, then there is added conservatism in the soil DCGL values.

Q. Golder Work Plan (August 2005), Figure 2: The sheet piling shown in this figure may be important to both the hydrogeology of the site and the erosion rate if the pilings start to deteriorate. Provide more information on potential influences the pilings may have on the hydrogeology and on the pilings themselves, e.g., how are they designed, component materials, design life, effort and cost of maintenance and repair.

EFI Answer:

This question will be addressed as part of the submittal addressing the groundwater questions.

Fermi 1 Procedure MEF215 Fermi 1 Manual Rev. 114 Page 1 FINAL STATUS SURVEY BACKGROUND ASSESSMENT CONTENTS SECTION PAGE P U RP O SE ......................................................................................................................................... 2 SCOPE ........................................................... . ........... 2 1.0 D EF IN IT ION S ..................................................................................................................... 3 2 .0 D IS CU SSION ....................................................................................................................... 3 3.0 PREREQUISITES ....................................... ............................. 4 4 .0 P R O C ED UR E ...................................................................................................................... 4 5.0 REFEREN CES .......................................................................................................... 9

Fermi-l Procedure MEF215 Fermi 1 Manual Rev. 114 Page 2 FINAL STATUS SURVEY BACKGROUND ASSESSMENT PURPOSE The purpose of this procedure is to establish a process for background assessments for Final Status Survey (FSS) at Fermi Unit 1 (EF1).

SCOPE This procedure provides instructions for determining background and ambient radiation levels and background radionuclide concentrations for use in assessing data collected for Final Status (EF1).

Survey (FSS) at Fermi Unit 1

Fermi 1 Procedure MEF215 Fermi 1 Manual Rev. 114 Page 3 1.0 DEFINITIONS Disturbed soil - For the purpose of this procedure, disturbed soil is soil that is known to have been moved by earth-moving equipment since 1945.

Reference Area - An area that has similar physical, chemical, radiological and biological characteristics to the site being surveyed, but which has not been contaminated by site activities. The distribution and concentration of background radiation in the reference area should be the same as that which would be expected on the site if the site had never been contaminated.

2.0 DISCUSSION For the FSS, the Derived Concentration Guideline Levels (DCGLs) for residual radioactivity are levels above background. "Background", in this application, includes all non-plant related radioactive materials in the area being surveyed, including naturally occurring materials and global fallout from nuclear weapons tests and nuclear accidents such as Chernobyl. It is necessary to measure background radionuclide concentrations in order to determine the impact of plant-related (above background) radioactivity in a survey unit.

For direct measurement of radiation levels, "background" refers to all non-EFI related sources of radiation, including cosmic radiation, radiation from naturally occurring radioactive materials in the ground and building materials and radiation from fallout.

Direct radiation emanating from the operation of Fermi 2 is also part of the EF1 ambient radiation level for FSS purposes.

The Data Quality Objective (DQO) process will be used during the planning phase in the preparation of an FSS plan to determine whether media-specific backgrounds, ambient levels or no background will be applied to a survey area or unit.

Background levels are needed when applying the Wilcoxon Rank Sum (WRS) test. If the Sign test is to be used, background levels may be used in some cases but generally are ignored.

All background and ambient measurements should account for both spatial variability over the area being assessed and the precision of the instrument or method being used to make the measurements.

Background levels will be subtracted from total radiation or radioactivity levels to determine the net residual contamination from licensed operations. Therefore, it is necessary for backgrounds to be determined with a detection sensitivity and accuracy equivalent to the data from which it will be subtracted. This can be achieved by using the same instruments and techniques for background assessments as are used in evaluating

Fermi 1 Procedure MEF215 Fermi 1 Manual Rev. 114 Page 4 the final site conditions.

This procedure describes the method for determining the background levels that will be used in total surface contamination measurements, soil sampling and other sampling.

Scan surveys will not use background measurements since scans are performed to identify areas of elevated readings. Other methods of determining applicable background values for specific survey areas (e.g., use of existing empirical data, etc.) may be utilized if the approach is technically sound and documented as approved by the License Termination Manager. Other procedures will determine background levels in laboratory instruments, such as smear counters and gamma detection instruments (HPGe detectors),

for sample analysis.

This procedure is implemented at the direction of the License Termination Manager, by a FSS Engineer with support from a Lead FSS Technician. FSS Technicians may be used to take measurements or samples under the direction of a Lead FSS Technician or FSS Engineer.

3.0 PREREQUISITES

" Personnel using this procedure shall be specifically trained as to its contents.

" If on-site locations are to be used, coordinate with RP supervision to ensure that no radioactive material shipments/movements will affect the ambient levels in the area to be surveyed.

" Ensure that any computer programs to be used have been verified in accordance with MES38, "Software Controls for Non-process Computer Systems."

4.0 PROCEDURE 4 1 Background Survey Design 4.1.1 Selection of Reference Areas NOTE (1): EF1 license termination land areas are comprised of disturbed soils.

Historical data has shown that the Cs137 concentration in disturbed soils is low level and too widely varied to be used with background data therefore, any background activity in soil samples taken at EF1 will have to be disregarded, which is conservative.

NOTE (2):, Building surveys may use locally acquired ambient data, taken at the time of the survey. This process is described in EF1 License Termination Plan (LTP) as the "alternative" method. In its simplest form, it would consist of subtracting a closed-window reading from an open-window reading at each sample point. If this method is employed, a technical basis will be documented.

Fermi 1 Procedure MEF215 Fermi 1 Manual Rev. 114 Page 5 a) Identify the material types that comprise the buildings, systems and components at EFI where a reference area will be needed.

b) For each material type identified, locate an uncontaminated area that has similar physical, chemical, radiological and biological characteristics.

4.1.2 Selection of Individual Measurement Locations a) Select 30 individual locations by following the process described in either MEF205 "Determination of the Number and Locations of FSS Samples" or MEF214 "Computer Determination of the Number and Location of FSS Samples and Measurements", unless an alternate number of locations is specified by the License Termination Manager. If you are using the Visual, Sample Plan (VSP) in MEF214, modify the process as follows:

  • Adjust the LBGR as needed to get the desired number of locations or specify the number of measurements in VSP.

" Determine just the locations from the VSP results. Disregard the LBGR and other numbers produced by this process.

4.1.3 Reference Area Survey Package a) Initiate Form 52, "Background Assessment Data Sheet" for each material type identified.

b) Fill in the header information and any survey instructions that have been established and sign as the initiator.

  • Specify the same instrument/detector combination that will be used for FSS direct measurements.
  • In the "Survey Instructions" section, specify the same mode of operation (i.e., scaler or' count rate) that will be used in the performance of surveys.

c) Attach any worksheets, maps and/or printouts providing specific direction for measurement locations.

d) Submit the survey package to the License Termination Manager for approval.

Fermi 1 Procedure MEF215 Fermi 1 Manual Rev. 114 Page 6 4.2 Special Assessments Special background assessments shall be performed as directed by the License Termination Manager.

4.3 Background Survey Implementation NOTE: This section of the procedure may be performed by a FSS Technician, Lead FSS Technician or a FSS Engineer.

4.3.1 Direct Measurements a) Radiological Instrumentation:

Table 1 provides a list of suggested FSS instrumentation and detectors to be used for surface contamination and exposure rate measurements for which various types of background or ambient levels may be needed.

Table 1 Instruments Available for FSS Instrument Detector Purpose Units 2350-1 43-68 Alpha/beta detection cpm 2350-1 43-37 Alpha/beta detection cpm 2350-1 SPA-3 Gamma detection cpm Bicron Plastic Scint. Gamma detection prem/hr b) Material Background Measurements

  • For each instrument/detector combination, record the serial numbers and calibration due dates on Form 52, "Background Assessment Data Sheet".

" Record any comments related to the background measurement in the "Notes/Remarks" section.

  • Place the detector at each survey point specified and take a one-minute count (or for a different count time if directed by the License Termination Manager).
  • If using an instrument with data-logging capabilities, log each count into the memory. If a barcode system is in place, use it to associate to material type/location with the data.
  • For manual instruments, record the data on the same type of data sheet used for similar FSS measurements.

Fermi 1 Procedure MEF215 Fermi 1 Manual Rev. 114 Page 7 c) Data Handling

1) Establish an electronic file for reference area data.
2) Logged data; After collecting background or ambient measurements, download the data from the instrument in accordance with MEF217 "Operation of the Ludlum 2350-1 Digital Ratemeter".

Save the downloaded data in the electronic file established in Step 4.3.1 c) 1).

Print a copy of the data file and attach it to Form 52, "Background Assessment Data Sheet".

Go to Step 4.3.1 c) 4).

3) Manual data Manually enter the data into a spreadsheet Save the spreadsheet in the electronic file established in Step 4.3.1 c) 1).

Print a copy of the data file and'attach it to Form 52, "Background Assessment Data Sheet".

Attach the original data sheet-to Form 52, "Background Assessment Data Sheet".

4) Enter the electronic file name in the space indicated on Form 52, "Background Assessment Data Sheet".

4.4 Data Evaluation 4.4.1 Acceptability Determination On a spreadsheet with the data, determine the mean and standard deviation of the results.

Calculate the acceptable number of data points for both the WRS and Sign test by one of the following methods:

Run the COMPASS program, using "practice" with the following inputs:

Test: (run program twice, once for each test)

DCGL: Value for Cs-137 from the EF1 LTP (or as directed by the License Termination Manager).

Fermi 1 Procedure MEF215 Fermi 1 Manual Rev. 114 Page 8 LBGR: Initially 1/2 of the DCGL, this can be adjusted to (DCGL-2c) if necessary to get the relative shift between 1 and 3.

Sigma: Standard deviation calculated above.

Type I (c): 0.05 Type II (p): 0.05

-OR-0 Run MARSSIM Power 2000 using the above described values for input.

-OR-

  • Manually calculate N and N/2 using the steps outlined in procedure MEF205 "Determination of the Number and Locations of FSS Samples".

Compare the calculated N (Sign test) and N/2(WRS test) with the actual number of measurements in the background survey. If the calculated number is no greater than the number of measurements, the data may be used as reference data for either test. Otherwise, bring it to the attention of the License Termination Manager who will decide whether more measurements should be taken or other actions.

Print any worksheet, COMPASS output or MARSSIM Power 2000 sheet and incorporate it into the report.

Fill in and sign the Data Evaluation section of Form 52, "Background Assessment Data Sheet".

4.4.2 Review

" Forward Form 52, "Background Assessment Data Sheet", and all attachments to the License Termination Manager for approval.

" If the data are utilized by the FSS, document the background data set and include a copy in the FSS files.

" If the data are determined to be not applicable (N/A) by the License Termination Manager, annotate on Form 52, "Background Assessment Data Sheet" and file it in the FSS files.

Fermi 1 Procedure MEF215 Fermi 1 Manual Rev. 114 Page 9

5.0 REFERENCES

Fermi 1 License Termination Plan NUREG-1575, "Multi-Agency Radiation Survey and Site Investigation Manual" (MARSSIM),.

Revision 1, August 2000 MEF200, "Final Status Survey Program" MEF201, "Final Status Survey Quality Assurance Project Plan (QAPP)"

MEF205, "Determination of the Number and Locations of FSS Samples" MEF208, "Preparation of FSS SurveyPlans" MEF209, "Statistical Tests" MEF214, "Computer Determination of the Number and Location of FSS Samples and Measurements" MEF217, "Operation of the Ludlum 2350-1 Digital Ratemeter" MEF218, "Control and Accountability of Final Status Survey Portable Instrumentation" MES38, "Software Controls for Non-process Computer Systems"

BACKGROUND ASSESSMENT DATA SHEET Reference Area

Description:

Instruments: 2350-1 Bicron Other Detectors: 43-37 43-68 Material Type:

SPA-3: - Other:

Prepared by (print):

Date: Materials:

Survey Instructions:

Initiator sign/date: License Termination Manager additional instructions:

Prepared by (print): None L1 Attached, 0 Survey data Instrument Data Performed by (print): Type Serial Number Cal. Due Date/time:

Download file name:

Notes/Remarks:

L Additional page(s) attached Performed by (Surveyor sign):

Data Evaluation:

Sign Test LBGR N= Sat. Unsat.

WRS Test LBGR N/2= Sat. Unsat Evaluator sign: Date:

Reviewed by: Date:

Approved by: Date:

License Termination Manager Sheet Form 52 Pg.1/1 Rev. 114 110209 Fermi I1Manual, Fermi Appendix B Manual, Appendix B Background Assessment Data Background Assessment Data Sheet Form 52 Pg. 1/1 Rev. 114 110209

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