ML042670472

Orise 04-1186, Confirmatory Survey of the Administration Building at the Connecticut Yankee Haddam Neck Plant, Haddam, Connecticut.

ML042670472
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	08/31/2004
From:	Adams W Oak Ridge Institute for Science & Education
To:	NRC/NMSS/DWMEP
References
-RFPFR, RFTA 03-008 ORISE 04-1186
Download: ML042670472 (41)

Text

CONFIRMATORY SURV7EY i OF THE ADMINISTRATION

- BUILDING AT THE

- CONNECTICUT YANKEE HADDAM NECK PLANT HADDAM, CONNECTICUT

[DOCKET NO. 50-0213, RFTA NO. 03-008]

W. C. ADAMS Prepared for the U.S. Nuclear Regulatory Commission Division of Waste Management and Environmental Protection

-f

- n d"Site A-ssessment rga

- Further dissemination authorized to U.S. Government Agencies and their contractors; other requests shall be approved by the originating facility or higher DOE programmatic authority.

The Oak Ridge Institute for Science and Education (ORISE) is a U.S. Department of Energy facility focusing on scientific initiatives to research health risks from occupational hazards, assess environmental cleanup, respond to radiation medical emergencies, support national security and emergency preparedness, and educate the next generation of scientists. ORISE is managed by Oak Ridge Associated Universities. Established in 1946, ORAU is a I consortium of 86 colleges and universities.

NOTICES The opinions expressed herein do not necessarily reflect the opinions of the sponsoring institutions of Oak Ridge Associated Universities. ]

This report was prepared as an account of work sponsored by the United States Government. Neither the United States Government nor the U.S. Department of Energy, nor any of their employees, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe on privately L

owned rights. Reference herein to any specific commercial product, process, or service by trade name, mark, manufacturer, or otherwise, does not necessarily constitute or imply its endorsement or recommendation, or favor by the U.S. Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the U.S. Government or any agency thereof.

ORISE 04-1186 CONFIRMATORY SURVEY OF THE ADMINISTRATION BUILDING AT THE CONNECTICUT YANKEE HADDAM NECK PLANT HADDAM, CONNECTICUT Prepared by W. C. Adams Environmental Survey and Site Assessment Program Radiological Safety, Assessments and Training Oak Ridge Institute for Science and Education Oak Ridge, Tennessee 37831-0117 Prepared for the U.S. Nuclear Regulatory Commission Division of Waste Management and Environmental Protection FINAL REPORT AUGUST 2004 This report is based on work performed under an Interagency Agreement (NRC Fin. No. J-5403) between the U.S. Nuclear Regulatory Commission and the U.S. Department of Energy. Oak Ridge Institute for Science and Education performs complementary work under contract number DE-AC05-00OR22750 with the U.S. Department of Energy.

Connecticut Yankee Administration Building projects\0857\Reports\2004-08-20 Final Report

CONFIRMATORY SURVEY OF THE ADMINISTRATION BUILDING AT THE CONNECTICUT YANKEE HADDAM NECK PLANT HADDAM, CONNECTICUT Prepared by: Date: ___/ LI W. C. Adams, Project Leader Environmental Survey and Site Assessment Program Reviewed by( Date: __ _

ReT. J. Vitki, Skrvey Projects Manager Environmental Survey and Site Assessment Program Reviewed by: E7. (e 4 Date: ______/6 R. D. Condra, Laboratory Manager Environmental Survey and Site Assessment Program Reviewed by: Date:

A. T. Payne, Quality Marger Environmental Survey and Site Assessment Program Reviewed by: Date:

E. W. Abelquist, Prog D tor Environmental Survey and Site Assessment Program Connecticut Yankee Administration Building projects\0857\Reports\2004-08-20 Final Report

ACKNOWLEDGMENTS The author would like to acknowledge the significant contributions of the following staff members:

FIELD STAFF A. L. Mashbum LABORATORY STAFF R. D. Condra J. S. Cox W. P. Ivey CLERICAL STAFF D. K. Herrera K. L. Pond A. Ramsey ILLUSTRATOR T. D. Herrera T. L. Brown Connecticut Yankee Administration Building projectsW0857\Reports\2004-08-20 Final Report

TABLE OF CONTENTS PAGE List of Figures ........................... ii List of Tables ............................. iii Abbreviations and Acronyms ........................... iv Introduction and Site History ........................... 1l Site Description ............................ 2 Objectives ............................ 3 Survey Procedures ............................ 3 Sample Analysis and Data Interpretation ............................. 4 Findings and Results ............................. 5 Comparison of Results with Guidelines ............................. 6 Summary ............................. 7 Figures ............................ 8 Table ........................... 13 References ........................... 15 Appendices:

Appendix A: Major Instrumentation Appendix B: Survey and Analytical Procedures Appendix C: IE Circular No. 81-07: Control of Radioactively Contaminated Material and Information Notice No. 85-92: Surveys of Wastes Before Disposal from Nuclear Reactor Facilities Connecticut Yankee Administration Building projects\0857\Reports\2004-08-20 Final Report i

LIST OF FIGURES PAGE FIGURE 1: Location of the Connecticut Yankee Haddam Neck Plant-Haddam, Connecticut ....................................................... 9 FIGURE 2: Plot Plan of Buildings at the Connecticut Yankee Haddam Neck Plant Indicating Location of the Administration Building ....................................................... 10 FIGURE 3: Administration Building, First Floor, Area 1-Measurement and Sampling Locations ........................................................ I FIGURE 4: Administration Building, Second Floor, Area 4-Measurement and Sampling Locations ....................................................... 12 Connecticut Yankee Administration Building .. projects\0857\Reports\2004-08-20 Final Report

LIST OF TABLES PAGE TABLE 1: Surface Activity Levels .............. 14 Connecticut Yankee Administration Building iii projects\0857\Reports\2004-08-20 Final Report

ABBREVIATIONS AND ACRONYMS 0-y beta-gamma di index of sensitivity Etotal total efficiency

£; instrument efficiency es surface efficiency BKG background cm centimeter Co-60 cobalt-60 cpm counts per minute Cs-137 cesium-137 CYAPCO Connecticut Yankee Atomic Power Company DOE Department of Energy dpm disintegrations per minute per 100 square centimeters ESSAP Environmental Survey and Site Assessment Program ft feet HNP Haddam Neck Plant ISM integrated safety management ITP Intercomparison Testing Program JHA job hazard analysis MAPEP Mixed Analyte Performance Evaluation Program MDC minimum detectable concentration MDCR minimum detectable count rate min minute mm millimeter msl mean sea level MW megawatts Nal sodium iodide NIST National Institute of Standards and Technology

-NRC Nuclear Regulatory Commission NRIP NIST Radiochemistry Intercomparison Program ORISE Oak Ridge Institute for Science and Education PSDAR Post Shutdown Decommissioning Activities Report RCA radiologically controlled area sec second SU survey unit Tc-99 technetium-99 URS unconditional release survey Connecticut Yankee Administration Building iV projects\0857\Reports\2004-08-20 Final Report

CONFIRMATORY SURVEY OF THE ADMINISTRATION BUILDING AT THE CONNECTICUT YANKEE HADDAM NECK PLANT HADDAMI, CONNECTICUT INTRODUCTION AND SITE HISTORY The Connecticut Yankee Haddam Neck Plant (HNP), owned by the Connecticut Yankee Atomic Power Company (CYAPCO), began commercial operation in January 1968 under Atomic Energy Commission Docket Number 50-213, License Number DPR-61. The plant incorporated a 4-loop, closed-cycle, pressurized water type nuclear steam supply system; a turbine generator and electrical systems; engineered safety features; radioactive waste systems; fuel handling systems; instrumentation and control systems; and the necessary auxiliaries and structures to house plant systems and other onsite facilities. HNP was designed to produce 1,825 megawatts (MW) of thermal power and 590 MW of gross electrical power.

On December 4, 1996, the HNP permanently shut down after approximately 28 years of operation. On December 5, 1996, CYAPCO notified the U.S. Nuclear Regulatory Commission (NRC) of the permanent cessation of operations at the HNP and the permanent removal of all fuel assemblies from the Reactor Pressure Vessel and their placement in the Spent Fuel Pool.

The CYAPCO board of directors voted to permanently cease further operation and decommission the plant and submitted the Post Shutdown Decommissioning Activities Report (PSDAR), in accordance with IOCFR50.82 (a)(4), on August 22, 1997. The PSDAR was accepted by the NRC. On January 26, 1998, CYAPCO transmitted an updated Final Safety Analysis Report to reflect the plant's permanent shutdown status, and on June 30, 1998, the NRC amended the HNP Facility Operating License to reflect this plant condition (CYAPCO 2002).

CYAPCO conducted decontamination efforts and performed surveys in the Administration Building using an unconditional release survey (URS) procedure (CYAPCO 2004a). The objective of the URS procedure is to provide guidance for preparing, performing, documenting, and approving pre-demolition surveys for offsite release of secondary side buildings and structures, which are intended to be unconditionally released from the site. The licensee provided the URS results for the Administration Building to the NRC for review. CYAPCO Connecticut Yankee Administration Building projects\0857\Reports\2004-08-20 Final Report

surveys encompassed the first and second floors of the interior of the building and the exterior surfaces of the building.

The NRC's Headquarters and Region I Offices requested that the Oak Ridge Institute for Science and Education's (ORISE), Environmental Survey and Site Assessment Program (ESSAP) perform confirmatory surveys of the Administration Building after CYAPCO completed URS reports for the survey units that are to be released.

SITE DESCRIPTION The HNP is located at 362 Injun Hollow Road in the Town of Haddam, Middlesex County, Connecticut on the east bank of the Connecticut River at a point 21 miles south-southeast of Hartford, Connecticut, and 25 miles northeast of New Haven, Connecticut (Figure 1).

The HNP is a 525 acre site on a level, 600-foot (ft)-wide terrace at an elevation of 21 ft above mean sea level (msl). A parking lot occupies the area to the north of the industrial area.

Adjacent to the parking lot is a small man-made pond. A 5,500 foot-long cooling water discharge canal return was constructed and used during plant operation to return heated circulating water from the secondary plant back to the Connecticut River and to process and discharge liquids containing radioactivity. The discharge canal is separated from the Connecticut River by a 200 to 1,000 ft wide peninsula flood plain that ranges in elevation from about 5 to 15 ft above msl. A steep, wooded hill rises immediately east of the industrial area to elevations over 300 ft above msl. The lowermost 30 to 40 ft of the hillside adjacent to the plant consists of nearly vertical rock cut.

The HNP design includes several structures engineered and constructed to contain radioactive material. These structures include the Containment Building, the Primary Auxiliary Building, the Service Building, the Waste Storage Building, Ion Exchange Structure, Spent Resin Facility, and structures containing tanks for storage of radioactive liquids. These structures and facilities are located within the Radiologically Controlled Area (RCA) boundaries. The site also includes ancillary facilities that were used to support normal plant operations. These facilities consist of warehouses, administrative office buildings, an information center and Emergency Operations Connecticut Yankee Administration Building 2 projects\0857\Reports\2004-08-20 Final Report

Facility. Most buildings and facilities are centrally located on a 15 acre plot adjacent to the Connecticut River (Figure 2).

For this report, confirmatory surveys were performed on the Administration Building (Figures 2 through 4). The Administration Building is a two-story, red brick structure with concrete floors and outer walls of concrete block and inner walls of white brick, ceramic tile, concrete, sheetrock, metal panels and glass. The building contains several offices for station management, conference rooms and restrooms. All areas of the Administration Building were outside the RCA.

OBJECTIVES The objectives of the confirmatory survey were to provide independent contractor field data reviews and to generate independent radiological data for use by the NRC in evaluating the adequacy and accuracy of the licensee's procedures and URS results and conclusions.

SURVEY PROCEDURES ESSAP performed confirmatory survey activities on the two judgmentally-selected survey units (SU) within the Administration Building at the Connecticut Yankee Haddam Neck Plant in Haddam, Connecticut on March 17, 2004. The selected SUs were the First Floor, Area 1 and the Second Floor, Area 4. These SUs were selected based on their proximity to the main traffic areas on each floor. Survey activities consisted of alpha plus beta and gamma surface scans, total beta surface activity measurements and removable alpha and beta surface activity measurements. These survey activities were conducted in accordance with a site-specific inspection plan, submitted to and approved by the NRC, and the ORISE/ESSAP Survey Procedures and Quality Assurance Manuals (ORISE 2004a, 2003, and 2004b).

DOCUNIENT/DATA REVIEW/PERFORMIANCE OBSERVATIONS ESSAP reviewed CYAPCO's survey documentation to determine the appropriateness and adequacy of the URS radiological instrumentation and procedures (CYAPCO 2004b, c and d).

The LJRS results for the Administration Building were provided prior to ESSAP's confirmatory Connecticut Yankee Administration Building projects\0857\Reports\2004-08-20 Final Report 3

survey activities. ESSAP personnel also observed a CYAPCO technician perform routine survey activities in the Administration Building.

REFERENCE SYSTEM The reference grid system established by the licensee was used to reference measurement and sampling locations within the Administration Building.

SURFACE SCANS Alpha plus beta and gamma radiation surface scans were performed on up to 75% of the floor and lower wall surfaces and approximately 5% of the uipper surfaces in the selected survey units.

Scans were performed using gas proportional and Nal scintillation detectors coupled to ratemeters or ratemeter-scalers with audible indicators.

SURFACE ACTIVITY MEASUREMENTS Construction material specific backgrounds were performed on poured concrete and white brick in the Administration Building, which were the only locations available with these materials; other construction material specific backgrounds were performed in the Office Building. ESSAP personnel performed direct measurements for alpha and beta surface activity at 20 locations within the Administration Building (10 locations in each selected SU). Measurement locations were randomly selected to encompass a wide area within the selected SUs and included floors, lower walls and upper surfaces. Direct measurements were performed using gas proportional detectors coupled to ratemeter-scalers. Smear samples, for determining removable gross alpha and gross beta activity levels, were collected from each direct measurement location.

Measurement locations are shown on Figures 3 and 4.

SAMPLE ANALYSIS AND DATA INTERPRETATION Samples and data were sent to the ORISE/ESSAP laboratory in Oak Ridge, Tennessee for analysis and interpretation. Sample analyses were performed in accordance with the ORISE/ESSAP Laboratory Procedures Manual (ORISE 2004c). Smears were analyzed for gross Connecticut Yankee Administration Building 4 projects\0857\Reports\2004-08-20 Final Report

alpha and gross beta activity using a low-background gas proportional counter. Smear sample results and direct measurement data were reported in units of disintegrations per minute per 100 square centimeters (dpm/100 cm2).

Survey data were then compared with the licensee's pre-demolition contamination limits documented in Table 2, Section 6.3 of their URS procedure (CYAPCO 2004a). The procedure incorporated the surface contamination control criteria of NRC IE Circular 81-07 and NRC Information Notice No. 85-92 (NRC 1981 and 1985). The primary contaminants of concern for the Administration Building were beta-gamma emitters-fission and activation products-resulting from reactor operation. Appendices A and B provide additional information concerning major instrumentation, sampling equipment, and analytical procedures discussed in this report, including minimum detectable concentrations for field and laboratory instruments.

FINDINGS AND RESULTS DOCUMENT REVIEW AND PERFORMANCE OBSERVATION ESSAP reviewed the licensee's URS documentation and observed a CYAPCO technician performing routine surveys within the Administration Building. The reviews, the performance observation, and the subsequent ESSAP surveys indicated that there were some basic issues concerning CYAPCO's radiological survey procedures.

During the performance observation, a CYAPCO technician performed a background scan by placing a thin aluminum shield over the beta scintillator face and turned the instrument face away from the wall surface to collect the instrument "ambient" background scan range. The technician then took the shield off and placed the face of the instrument approximately 1 cm from the surface of the wall and performed a surface scan of the same area. Upon completion of the scan; the technician checked a box on a field survey record form that states that "No detectable activity identified during scan." The technician did not record the scan range or perform a direct measurement. This technique was used for areas with low potential for contamination.

Connecticut Yankee Administration Building 5s projects\0857\Reports\2004-08-20 Final Report

ESSAP identified the absence of CYAPCO final scan data and/or direct measurement data documentation in the URS reports and discussed this observation with the NRC. ESSAP and NRC then discussed surface scanning procedures/techniques with CYAPCO personnel during the close-out meeting. ESSAP recommended that CYAPCO consider the appropriateness of not documenting scan results. The NRC documented the observations and conclusions in the NRC Inspection Report No. 05000213/2004001.

SURFACE SCANS Alpha plus beta and gamma surface scans of the selected SUs floors, lower walls and upper surfaces did not identify any area of elevated direct radiation.

SURFACE ACTIVITY LEVELS Results of total and removable surface activity for the Administration Building are provided in Table 1. Total beta surface activity for the First Floor, Area I ranged from -360 to 570 dpm/100 cm 2 and for the Second Floor, Area 4 ranged from -310 to 800 dpm/100 cm 2 .

Removable surface activity for both areas ranged from 0 to 1 dpm/1 00 cm 2 for gross alpha and

-3 to 7 dpm/100 cm2 for gross beta.

COMPARISON OF RESULTS WITH GUIDELINES The primary contaminants of concern for the CYAPCO are beta-gamma emitters-fission and activation products-resulting from reactor operation. Cesium-137 (Cs-137) and cobalt-60 (Co-60) were identified during characterization as the predominant radionuclides present on surfaces. The minimum detection criteria from NRC IE Circular 81-07 (NRC 1981) are as follows:

Total Activity 5,000 P-y dpm/100 cm 2 , maximum in a 100 cm 2 area Removable Activity 1,000 13-y dpm/lO0 cm2 Connecticut Yankee Administration Building projects'0857XReports\2004-08-20 Final Report 6

The supplemental guidance to IE Circular 81-07, NRC Information Notice No. 85-92 states that "In practice, no radioactive (licensed) material means no detectable radioactive material."

CYAPCO used "No detectable activity identified during scan" as a release limit for URS criteria.

No confirmatory direct measurements performed in the Administration Building exceeded the criteria and confirmatory surface scans did not indicate any direct radiation above surface material backgrounds.

SUMMARY

At the request of the Nuclear Regulatory Commission's Headquarters and Region I Offices, the Environmental Survey and Site Assessment Program of the Oak Ridge Institute for Science and Education conducted a confirmatory survey of the Administration Building at the Connecticut Yankee Atomic Power Company Haddam Neck Plant, in Haddam, Connecticut. Confirmatory activities were performed on March 17, 2004 and included reviews of unconditional release survey procedures and data, surface scans, direct surface activity measurements and performance observations. Overall, the results of the survey activities confirmed that the radiological conditions of the Administration Building met the licensee's pre-demolition contamination limits documented in Table 2, Section 6.3 of their unconditional release survey procedure (CYAPCO 2004a) and also included recommendations for enhancing survey documentation.

Connecticut Yankee Administration Building 7 projects\0857\Reports\2004-08-20 Final Report

L-I i

L-i i

i L

FIGURES I

i i6-I L-I 111 I

i L

I i

i Connecticut Yankee Administration Building projects\0857\Reports\2004-08-20 Final Report L

857-013 (2)

Plant Neck Haddam Yankee Connecticut Conetiu Yake Hada m Neck Plant MERIDENl

, -_ -_ _ _ _- _- _ _-, _ __-_-_-,

. -

FIUR Loato of th Connecticut Yankee Haddam Neck Plan -HadmConciu NOT TO SCALE FIGURE 1: Location of the Connecticut Yankee Haddam Neck Plant - Haddam, Connecticut Connecticut Yankee Administration Building 9 projects\0857EReports\2004-08-20 Final Report

857-018 (x)

Warehouse #2 Office Bldg.

PAP CONNECTICUT RIVER E] SURVEYED AREA NOT TO SCALE FIGURE 2: Plot Plan of Buildings at the Connecticut Yankee Haddam Neck Plant Indicating Location of the Administration Building Connecticut Yankee Administration Building 10 projects\0857\Reports\2004-08-20 Final Report

857-016 (1)

I 0 2

II\

.

10

@8 4

-I 0

-J 3 F- a 9

.4 GUARD SHACK (ie D 06 l

N

+/-

MEASUREMENT/SAMPLING LOCATIONS

1. SINGLE-POINT FLOOR A # SINGLE-POINT LOWER WALLS NOT TO SCALE FIGURE 3: Administration Building, First Floor, Area 1 - Measurement and Sampling Locations Connecticut Yankee Administration Building I1I projects\0857\Reports\2004-08-20 Final Report

857-017 (1) 4 0

15 19A DUCT 20-I-BEAM I

C(E COLUMN 0

17 1 16 0

N MEASUREMENT/SAMPLING LOCATIONS A.b #SINGLE-POINT .{

SINGLE-POINT FLOOR

1. SINGLE-POINT A LOWER WALLS NOT TO SCALE FIGURE 4: Administration Building, Second Floor, Area 4 - Measurement and Sampling Locations Connecticut Yankee Administration Building 12 projects\0857\Reports\2004-08-20 Final Report

TABLE Connecticut Yankee Administration Building projects\0857\Reports\2004-0S-20 Final Report

TABLE I SURFACE ACTIVITY LEVELS ADMINISTRATION BUILDING CONNECTICUT YANKEE HADDAM NECK PLANT HADDAM, CONNECTICUT Location 2 SurfaCeb rface Total Beta Activity Removabl cmvt

__________ Material (dpm/100 Cm2 ) (dpm/100 cm)

Alpha lBeta First Floor, Area 1 I LW Sheetrock 280 0 4 2 LW White Brick 130 1 4 3 LW White Brick 430 0 1 4 F Tile 12 0 -2 5 LW I-Beam 330 0 4 6 F Tile 130 0 7 7 LW Concrete Block 570 0 2 8 F Concrete 160 0 -3 9 UW White Brick -360 0 -3 10 UW Sheetrock 310 0 3 Second Floor, Area 4 11 F Concrete -49 0 6 12 LW White Brick -90 0 4 13 UW Plaster/Sheetrock 460 0 3 14 F Concrete -130 0 -2 15 LW Plaster/Sheetrock 800 1 3 16 LW Plaster/Sheetrock 380 0 -1 17 F Concrete -310 0 -2 18 LW I-Beam 290 0 -1 19 US Exhaust Duct 370 0 -2 20 US I-Beam -90 0 2

'Refer to Figures 3 and 4.

bF= floor, LW = lower wall and US = upper surface.

Connecticut Yankee Administration Building projects\0857\Rcports\2004-08-20 Final Report 14

REFERENCES Connecticut Yankee Atomic Power Company (CYAPCO). License Ternination Plan, Connecticut Yankee Decommissioning Project, Haddam Neck Plant, Revision 1A. Haddam, Connecticut; October 2002.

Connecticut Yankee Atomic Power Company. Unconditional Release Surveys of Secondary Side Structures Prior to Demolition. CYAPCO Procedure No. GPP-GGGR-R2210-000 (RPM 2.2-28), Revision CY-000. Haddam, Connecticut; February 26, 2004a.

Connecticut Yankee Atomic Power Company. Survey Plan 134-01, Admin Building, First Floor Interior. Haddam, Connecticut; March 2004b.

Connecticut Yankee Atomic Power Company. Survey Plan 134-02, Admin Building, Second Floor Interior. Haddam, Connecticut; March 2004c.

Connecticut Yankee Atomic Power Company. Survey Plan 134-03, Admin Building, Exterior Surfaces. Haddam, Connecticut; March 2004d.

Oak Ridge Institute for Science and Education (ORISE). Survey Procedures Manual for the Environmental Survey and Site Assessment Program. Oak Ridge, Tennessee; November 7, 2003.

Oak Ridge Institute for Science and Education. Revised Site-Specific Decommissioning Inspection Plan for the Connecticut Yankee Decommissioning Project, Haddam, Connecticut (Docket No. 50-0213; RFTA No.03-008). Oak Ridge, Tennessee; March 9, 2004a.

Oak Ridge Institute for Science and Education. Quality Assurance Manual for the Environmental Survey and Site Assessment Program. Oak Ridge, Tennessee; January 7, 2004b.

Oak Ridge Institute for Science and Education. Laboratory Procedures Manual for the Environmental Survey and Site Assessment Program. Oak Ridge, Tennessee; March 16, 2004c.

U.S. Nuclear Regulatory Commission (NRC). IE Circular No. 81-07: Control of Radioactively Contaminated Material. Washington, DC; May 14, 1981.

U.S. Nuclear Regulatory Commission. Information Notice No. 85-92: Surveys of Wastes Before Disposal from Nuclear Reactor Facilities. Washington, DC; December 2, 1985.

Connecticut Yankee Administration Building 15 projects\0857\Reports\2004-08-20 Final Report

APPENDIX A MAJOR INSTRUMENTATION Connecticut Yankee Administration Building . projects\0W57\Reports\2004-08-20 Final Report

APPENDIX A MAJOR INSTRUMENTATION The display of a specific product is not to be construed as an endorsement of the product or its manufacturer by the author or his employer.

SCANNING INSTRUNIENT/DETECTOR COMBINATIONS Alpha plus Beta Ludlum Floor Monitor Model 239-1 combined with Ludlum Ratemeter-Scaler Model 2221 coupled to Ludlum Gas Proportional Detector Model 43-37, Physical Area: 550 cm2 (Ludlum Measurements, Inc., Sweetwater, TX)

Ludlum Ratemeter-Scaler Model 2221 coupled to Ludlum Gas Proportional Detector Model 43-68, Physical Area: 126 cm2 (Ludlum Measurements, Inc., Sweetwater, TX)

Gamma Eberline Pulse Ratemeter Model PRM-6 (Eberline, Santa Fe, NM) coupled to Victoreen Nal Scintillation Detector Model 489-55, Crystal: 3.2 cm x 3.8 cm (Victoreen, Cleveland, OH)

DIRECT MEASUREMENT INSTRUMENTJDETECTOR COMBINATIONS Beta Ludlum Ratemeter-Scaler Model 2221 coupled to Ludlum Gas Proportional Detector Model 43-68, Physical Area: 126 cm 2 (Ludlum Measurements, Inc., Sweetwater, TX)

Connecticut Yankee Administration Building projects\0857\Reports02004-08-20 Final Report A-1

LABORATORY ANALYTICAL INSTRUMENTATION Low-Background Gas Proportional Counter Model LB-5 100-W (Tennelec/Canberra, Meriden, CT)

Connecticut Yankee Administration Building A-2 projects\0857\Reports\2004-08-20 Final Report

APPENDIX B SURVEY AND ANALYTICAL PROCEDURES Connecticut Yankee Administration Building projects\0857\Reports\2004-08-20 Final Report

APPENDIX B SURVEY AND ANALYTICAL PROCEDURES PROJECT HEALTH AND SAFETY The proposed survey and sampling procedures were evaluated to ensure that any hazards inherent to the procedures themselves were addressed in current job hazard analyses (JHAs). All survey and laboratory activities were conducted in accordance with ORISE health and safety and radiation protection procedures.

Pre-survey activities included the evaluation and identification of potential health and safety issues. Of particular concern for the Administration Building were tripping hazards and cold weather conditions. Survey work was performed per the ORISE generic health and safety plans and a site-specific integrated safety management (ISM) pre-job hazard checklist. CYAPCO also provided site-specific safety awareness training.

CALIBRATION AND QUALITY ASSURANCE Calibration of all laboratory instrumentation was based on standards/sources, traceable to NIST, when such standards/sources were available. In cases where they were not available, standards of an industry-recognized organization were used.

Analytical and field survey activities were conducted in accordance with procedures fronm the following Environmental Survey and Site Assessment Program documents:

• Survey Procedures Manual (November.2003)

• Laboratory Procedures Manual (March 2004)

• Quality Assurance Manual (January 2004)

The procedures contained in these manuals were developed to meet the requirements of Department of Energy (DOE) Order 414.1A and the U.S. Nuclear Regulatory Commission Quality Assurance Manualforthe OfJice of NuclearMaterialSafety and Safeguards and contain measures to assess processes during their performance.

Connecticut Yankee Administration Building projects\0857\Reports\2004-08-20 Final Report B-1

Quality control procedures include:

• Daily instrument background and check-source measurements to confirm that equipment operation is within acceptable statistical fluctuations.

• Participation in MAPEP, NRIP and ITP Laboratory Quality Assurance Programs.

• Training and certification of all individuals performing procedures.

• Periodic internal and external audits.

Detectors used for assessing surface activity were calibrated in accordance with ISO-75031 recommendations. The total efficiency (ctotai) was determined for each instrument/detector combination and consisted of the product of the 27n instrument efficiency (E;) and surface efficiency (es ) : total = C; x s. The static ci was determined to be 0.39 during instrument calibration with Tc-99; the scanning E; was determined to be 0.30 for Tc-99 based on ESSAP experience.

Tc-99 was selected as the calibration source (maximum beta energy of 292 keV) as it provides a conservative representation of the radionuclide mixture. ISO-7503' recommends an Es of 0.25 for beta emitters with a maximum energy of less than 0.4 MeV (400 keV) and an cEof 0.5 for maximum beta energies greater than 0.4 MeV. Since the maximum beta energy for the CYAPCO primary contaminant of concern (Cs-137) is greater than 0.4 MeV, an es of 0.5 was used to calculate etotal.

SURVEY PROCEDURES Surface Scans Surface scans were performed by passing the detectors slowly over the surface; the distance between the detector and the surface was maintained at a minimum-nominally about 1 cm. A Nal scintillation detector was used to scan for elevated gamma radiation. Floor and wall surfaces and indentations were scanned using small area (126 cm 2 ) hand-held detectors. Identification of lintemational Standard. ISO 7503-1; Evaluation of Surface Contamination - Part 1: Beta-emitters (maximumbeta energy greaterthan O.15 MeV) and alpha-emitters. August 1, 1988.

Connecticut Yankee Administration Building B-2 projects\0857\Reports\2004.08-20 Final Report

elevated levels was based on increases in the audible signal from the recording and/or indicating instrument.

Scan minimum detectable concentrations (MDCs) were estimated using the calculational approach described in NUREG-1507 2 . The scan MDC is a function of many variables, including the background level. The background count rates for the gas proportional detectors averaged 414 cpm for concrete, 189 cpm for metal, 806 cpm forwhite brick, 219 cpm for sheetrock, 489 cpm for floor tile, 675 cpm for glazed tile and 410 cpm for ambient air measurements.

Additional parameters selected for the calculation of scan MDC included a two-second observation interval, a specified level of performance at the first scanning stage of 95% true positive rate and 25% false positive rate, which yields a d' value of 2.32 (NUREG-1507, Table 6.1), and a surveyor efficiency of 0.5. To illustrate an example for the hand-held gas proportional detectors, the minimum detectable count rate (MDCR) and scan MDC can be calculated as follows for concrete surfaces:

bi = (414 cpm) (2 sec) (1 min/60 sec) = 13.8 counts MDCR = (2.32) (13.8 counts)/' [(60 sec/min) / (2 sec)] 259 counts MDCRsurveyor = 259 / (0.5) ~'= 366 cpm The scan MDC is calculated using the scanning ctotaI of 0.15:

MDCR 2r Scan MDC = surwyor dpm / 00 cm2 E total The scan MDC for the gas proportional detectors used was approximately 2,400 dpm/l 00 cm2 for concrete surfaces.

Specific scan MDCs for the NaI scintillation detector for Cs-137 and Co-60 in concrete and tile floor surfaces were not determined as the instrument was used solely as a qualitative means to identify elevated gamma radiation for possible concrete sampling.

2 NUREG-1 507. Minimum Detectable Concentrations With Typical Radiation Survey Instruments for Various Contaminants and Field Conditions. U.S. Nuclear Regulatory Commission. Washington, DC; June 1998.

Connecticut Yankee Administration Building B-3 projects\0857\Reports\2004.08-20 Final Report

Surface Activity Measurements Measurements of total beta surface activity levels were performed using a gas proportional detector with portable ratemeter-scalers. Count rates (cpm), which were integrated over one minute with the detector held in a static position, were converted to activity levels (dpm/lO00 cm2 ) by dividing the net count rate by Stot.l and correcting for the physical area of the detector.

Because different building materials (poured concrete, brick, wood, steel, etc.) may have different background levels, average background count rates were determined for each material encountered in the surveyed area at a location of similar construction and having no known radiological history.

The static beta MDCs-calculated using the average construction material background count rates for concrete, metal, white brick, sheetrock, floor tile, glazed tile, and ambient air within the building-for the single gas proportional detector (calibrated to Tc-99) used for direct measurements ranged from 272 to 550 dpm/l 00 cm 2 . The physical surface area assessed by the gas proportional detector used was 126 cm 2.

Removable Activity Measurements Removable gross alpha and gross beta activity levels were determined using numbered filter paper disks, 47 mm in diameter. Moderate pressure was applied to the smear and approximately 100 cm2 of the surface was wiped. Smears were placed in labeled envelopes with the location and other pertinent information recorded.

RADIOLOGICAL ANALYSIS Gross Alpha/Beta Smears were counted for two minutes on a low-background gas proportional system for gross alpha and beta activity. The MDCs of the procedure were 8 dpm/100 cm2 and 15 dpm/100 cm2 for gross alpha and gross beta, respectively.

Connecticut Yankee Administration Building B-4 projects\0857\Reports\2004-08 20 Final Report

DETECTION LIMITS Detection limits, referred to as minimum detectable concentration (MDC), were based on 3 plus 4.65 times the standard deviation of the background count [3 + (4.654[BKG)]. Because of variations in background levels, measurement efficiencies, and contributions from other radionuclides in samples, the detection limits differ from sample to sample and instrument to instrument.

Connecticut Yankee Administrabion Building B-5 projects\O857\Reports\200Z4-8-20 Final Report

APPENDIX C IE CIRCULAR NO. 81-07: CONTROL OF RADIOACTIVELY CONTAMINATED MATERIAL AND INFORMATION NOTICE NO. 85-92: SURVEYS OF WASTES BEFORE DISPOSAL FROM NUCLEAR REACTOR FACILITIES Connecticut Yankee Administration Building projects\O857\Reports\2004-08-20 Final Report

UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C. 20555 May 14, 1981 IE Circular No. 81-07: CONTROL OF RADIOACTIVELY CONTAMINATED MATERIAL Description of Circumstances:

Information Notice No. 80-22 described events at nuclear power reactor facilities regarding the release of radioactive contamination to unrestricted areas by trash disposal and sale of scrap material. These releases to unrestricted areas were caused in each case by a breakdown of the contamination control program including inadequate survey techniques, untrained personnel performing surveys, and inappropriate material release limits.

The problems that were described in IE Information Notice No. 80-22 can be corrected by implementing an effective contamination control program through appropriate administrative controls and survey techniques. However, the recurring problems associated with minute levels of contamination have indicated that specific guidance is needed by NRC nuclear power reactor licensees for evaluating potential radioactive contamination and determining appropriate methods of control. This circular provides guidance on the control of radioactive contamination.

Because of the limitations of the technical analysis supporting this guidance, this circular is applicable only to nuclear power reactor facilities.

Discussion:

During routine operations, items (e.g., tools and equipment) and materials (e.g., scrap material, paper products, and trash) have the potential of becoming slightly contaminated. Analytical capabilities are available to distinguish very low levels of radioactive contamination from the natural background levels of radioactivity. However, these capabilities are often very elaborate, costly, and time consuming making their use impractical (and unnecessary) for routine operations. Therefore, guidance is needed to establish operational detection levels below which the probability of any remaining, undetected contamination is negligible and can be disregarded when considering the practicality of detecting and controlling such potential contamination and the associated negligible radiation doses to the public. In other words, guidance is needed which will provide reasonable assurance that contaminated materials are properly controlled and disposed of while at the same time providing a practical method for the uncontrolled release of materials from the restricted area. These levels and detection capabilities must be set considering these factors: 1) the practicality of conducting a contamination survey, 2) the potential of leaving minute levels of contamination undetected; and, 3) the potential radiation doses to individuals of the public resulting from potential release of any undetected, uncontrolled contamination.

Connecticut Yankee Administration Building C-1 projects\0857\Reports\2004.08-20 Final Report

EEC 81-07 May 14, 1981 Page 2 of 3 Studies performed by Sommers' have concluded that for discrete particle low-level contamination, about 5000 dpm of beta activity is the minimum level of activity that can be routinely detected under a surface contamination control program using direct survey methods.

The indirect method of contamination monitoring (smear survey) provides a method of evaluating removable (loose, surface) contamination at levels below which can be detected by the direct survey method. For smears of a 100 cm 2 area (a de facto industry standard), the corresponding detection capability with a thin window detector and a fixed sample geometry is on the order of 1000 dpm (i.e., 1000 dpmi/100 cm2 ). Therefore, taking into consideration the practicality of conducting surface contamination surveys; contamination control limits should not be set below 5000 dpm/100 cm2 total and 1000 dpmI/100 cm2 removable. The ability to detect minute, discrete particle contamination depends on the activity level, background, instrument time constant, and survey scan speed. A copy of Sommers studies is attached which provides useful guidance on establishing a contamination survey program.

Based on the studies of residual radioactivity limits for decommissioning (NUREG-06132 and NUREG-0707 3 ), it can be concluded that surfaces uniformly contaminated at levels of 5000 dpm/100 cm 2 (beta-gamma activity from nuclear power reactors) would result in potential doses that total less than 5 mrem/yr. Therefore, it can be concluded that for the potentially undetected contamination of discrete items and materials at levels below 5000 dpm/l 00 cm 2 , the potential dose to any individual will be significantly less than 5mrem/yr even if the accumulation of numerous items contaminated at this level is considered.

Guidance:

Items and material should not be removed from the restricted area until they have been surveyed or evaluated for potential radioactive contamination by a qualified* individual. Personal effects (e.g., notebooks and flash lights) which are hand carried need not be subjected to the qualified individual survey or evaluation, but these items should be subjected to the same survey requirements as the individual possessing the items. Contaminated or radioactive items and materials must be controlled, contained, handled, used, and transferred in accordance with applicable regulations.

The contamination monitoring using portable survey instruments or laboratory measurements should be performed with instrumentation and techniques (survey scanning speed, counting times, background radiation levels) necessary to detect 5000 dpm/100 cm 2 total and 1000 dpm/100 cm 2 removable beta/gamma contamination. Instruments should be calibrated with radiation sources having consistent energy spectrum and instrument response with the

• A qualified individual is defined as a person meeting the radiation protection technician qualifications of Regulatory Guide 1.8, Rev. 1, which endorses ANSI N18.1, 1971.

Connecticut Yankee Administration Building projects\0857\Rcports\2004-08-20 Final Report C-2

IEC 81-07 May 14, 1981 Page 3 of 3 radionuclides being measured. If alpha contamination is suspected appropriate surveys and/or laboratory measurements capable of detecting 100 dpm/100 cm 2 fixed and 20 dpm/100 cm 2 removable alpha activity should be performed.

In evaluating the radioactivity on inaccessible surfaces (e.g., pipes, drain lines, and duct work),

measurements at other appropriate access points may be used for evaluating contamination provided the contamination levels at the accessible locations can be demonstrated to be representative of the potential contamination at the inaccessible surfaces. Otherwise, the material should not be released for unrestricted use.

Draft ANSI Standard 13.124 provides useful guidance for evaluating radioactive contamination and should be considered when establishing a contamination control and radiation survey program.

No written response to this circular is required. If you have any questions regarding this matter, please contact this office.

REFERENCES I Sommers, J. F., "Sensitivity of Portable Beta-Gamma Survey Instruments," Nuclear Safety, Volume 16, No. 4, July-August 1975.

2 U.S. Nuclear Regulatory Commission, "Residual Radioactivity Limits for Decommissioning, Draft Report," Office of Standards Development, USNRC NUREG-0613, October 1979.

3 U.S. Nuclear Regulatory Commission, "A Methodology for Calculating Residual Radioactivity Levels Following Decommissioning," USNRC NUREG-0707, October.

1980.

4 Draft ANSI Standard 13.12, "Control of Radioactive Surface Contamination on Materials, Equipment, and Facilities to be Released for Uncontrolled Use," American National Standards Institute, Inc., New York, NY, August 1978.

Attachments:

1. Reference 1 (Sommers Study)

2. Recently issued IE Circulars Connecticut Yankee Administration Building C-3 projects\0857\Reports\2004-08-20 Final Report

SSTNS No.: 6835 IN 85-92 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C. 20555 December 2, 1985 Information Notice No. 85-92: SURVEYS OF WASTES BEFORE DISPOSAL FROM NUCLEAR REACTOR FACILITIES Addressees:

All production and utilization facilities, including nuclear power reactors and research and test reactors, holding an operating license (OL) or construction permit (CP).

Purpose:

The purpose of this information notice is to supplement the guidance of IE Circular 81-07 as it applies to surveys of solid waste materials before disposal from nuclear reactor facilities. It is expected that recipients will review the information for applicability to their facilities. However, this information notice does not constitute NRC requirements; therefore, no specific action or licensee response is required.

Description of Circumstance:

Some questions have arisen concerning appropriate methods of surveying solid waste materials for surface contamination before releasing them as nonradioactive (i.e., as wastes that do not contain NRC-licensed material).

Discussion:

The need to minimize the volume of radioactive waste generated and shipped to commercial waste burial sites is recognized by the NRC and industry. Some nuclear power plants have initiated programs to segregate waste generated in radiologically controlled areas. Such programs can contribute to the reduction in volume of radioactive waste; however, care should be taken to ensure that no licensed radioactive material is released contrary to the provisions of 10 CFR Section 20.301. In practice, no radioactive (licensed) material means no detectable radioactive material.

In 1981, IE Circular 81-07 was issued by the NRC. That circular provided guidance on the control of radioactively contaminated material and identified the extent to xvhich licensees should survey for contamination. It did not establish release limits. The criteria in the circular that addressed surface contamination levels were based on the best information available at the time and were related to the detection capability of portable survey instruments equipped with Connecticut Yankee Administration Building C-4 projects\0857\Reports\2004408-20 Final Report

IN 85-92 December 2, 1985 Page 2 of 3 thin-window "pancake" Geiger-Mueller (G.M.) probes, which respond primarily to beta radiation. Monitoring of aggregated, packaged material was not addressed. In 1981, there was no major emphasis on segregating waste from designated contamination areas. As a consequence, large volumes of monitored wastes were not being released for unrestricted disposal. However, because of recent emphasis on minimizing the volume of radioactive waste, current practices at many nuclear power facilities result in large volumes of segregated, monitored wastes, containing large total surface areas, being released as "clean" waste.

When scanning surfaces with a hand-held pancake probe, there is a chance that some contamination will not be detected. (See the papers by Sommers, l for example.) There is the chance also that the total surface area will not be scanned completely. Thus, when numerous items of "clean" material (e.g., paper and plastic items) are combined, the accumulation of small amounts of contamination that have escaped detection with the pancake probe may be detected using a detector that is sensitive to gamma radiation (e.g., by using a sensitive scintillation detector in a low-background area). Such measurements of packaged clean waste before disposal can reduce the likelihood that contaminated waste will be disposed of as clean waste, then found to be contaminated after disposal. (Some operators of sanitary landfills have begun to survey incoming waste for radioactivity using scintillation survey meters which in some cases are supplemented by portable gamma-ray spectrometers. 2 )

In order to preclude the unintentional release of radioactive materials, a good monitoring program likely would include the following:

1. Careful surveys, using methods (equipment and techniques) for detecting very low levels of radioactivity, are made of materials that may be contaminated and that are to be disposed of as clean waste. These survey methods should provide licensees with reasonable assurance that licensed material is not being released from their control.

2. Surveys conducted with portable survey instruments using pancake G.M. probes are generally more appropriate for small items and small areas because of the loss of detection sensitivity created by moving the probe and the difficulties in completely scanning large areas. This does not preclude their use for larger items and areas, if supplemented by other survey equipment or techniques.

3. Final measurements of each package (e.g., bag or drum) of aggregated wastes are performed to ensure that there has hot been an accumulation of licensed material resulting from a buildup of multiple, nondetectable quantities (e.g., final measurements using sensitive scintillation detectors in low-background areas).

Connecticut Yankee Administration Building C-5 projects\0857\Reports\2004-08-20 Final Report

IN 85-92 December 2, 1985 Page 3 of 3 The foregoing does not constitute NRC requirements; therefore, no specific action or written response is required by this information notice. If you have any questions about this matter, please contact the Regional Administrator of the appropriate NRC regional office or this office.

Edward L. Jordan Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement Technical Contact: John D. Buchanan, IE (301) 492-9657 LeMoine J. Cunningham, LE (301) 492-9664 Attachments:

1. References

2. List of Recently Issued IE Information Notices Connecticut Yankee Administration Building C-6 projects\0857\Reports\2004-0S-20 Final Report

Attachment I IN 85-92 December 2, 1985 REFERENCES 1 Sommers, J. F., (a) "Sensitivity of Portable Beta-Gamma Survey Instruments," Nuclear Safe 16 (No. 4), 452-457, July - August 1975, (b) "Sensitivity of GM and Ion-Chamber Beta Gamma Survey Instruments," Health Physics 28 (No. 6), pp. 775-761, June 1975.

2 Anonymous, "LA Nuclear Medicine Community Improves Radiation Monitoring at Landfills, " J. Nuclear Medicine 26 (#4), 336-337, April 1985.

Connecticut Yankee Administration Building projects\0857\Reports\2004-08-20 Final Report C-7