ML070600772

Attachment 5, Transmittal of Survey Packages in Support of Big Rock Point Phased License Termination, Class 1 Final Status Survey Release Record, 11C11, East Protected Area

ML070600772
Person / Time
Site:	Big Rock Point  File:Consumers Energy icon.png
Issue date:	10/27/2006
From:	Consumers Energy
To:	NRC/FSME
References
Download: ML070600772 (38)

Text

ATTACHMENT 5 CONSUMERS ENERGY BIG ROCKPOINT DOCKET NUMBERS 50-155 AND 72-043 TRANSMITTAL OF SURVEY PACKAGES IN SUPPORT OF BIG ROCK POINT PHASED LICENSE TERMINATION CLASS I FINAL STATUS SURVEY RELEASE RECORD, I IC11, EAST PROTECTED AREA October 27, 2006 37 Pages

Class I Final Status Survey Release Record North 11C 1 1 North Radwaste Staging Area SURVEY PACKAGE CLOSURE Final Status Survey Documentation is authorized for closure. All required reviews are complete and the evaluation of data results have satisfied the criteria established for unrestricted release.

Sioned~ 2~2I ~ Date: *o (ESSG)

Signed: Date: ci .. ,

(ES"S6erfintendent)

Signed: Date: e'9 -

(~Rl5 & ES'Manager)

Survey Area Requirements Final Status Survey, Release Record North 11C 1 1 North Radwaste Staging Area Survey Description Final Status Survey North 11C,1 encompasses 1339 m2 in the northern section of old radwaste staging area. No materials of plant origin remain in the survey area.

History During power operations the Radwaste Staging Area was used to store, process, and prepare plant radioactive waste for offsite shipment. No materials of plant origin remain in this location.

Surveys conducted following excavation and removal of foundations and subsurface components have determined that residual radioactivity does not exist in soils below grade elevation in this area (Survey 11Cqi 1). A detailed review of the history and radiological characterization of Survey Unit North 11 is provided in Appendix 2B and 2E of the LTP (License Termination Plan).

Current Radiological Status Characterization surveys and radiological evaluations following removal of subsurface components and materials do not indicate the presence of elevated levels of residual radioactivity in this survey area. Based on operational history, process knowledge, and survey measurements, the radiological status of this survey unit is Class 1.

Post-Construction Expectations Final Status Survey North 11 Cl will be performed in the following activity sequence:

1. Walkdown: Environmental Services Survey Group (ESSG) personnel will perform a walkdown assessment to ensure survey area preparations are complete and confirm that the following post-construction expectations have been satisfied as applicable:

" Groundwater and Surface water control is adequate

• All construction debris has been removed from the survey area

• The survey location status meets all applicable safety requirements

2. Survey Area Isolation and Control: Control measures will be established to ensure that any potential ongoing decommissioning activities in adjacent locations do not impact the current survey area status. Isolation and control measures include postings, barriers, access points, and the evaluation of ongoing work activities in adjacent areas.

Survey Area Requirements Survey North 11C11 Page 1 of 2

L

3. Survey Design and Execution: Survey design and execution will follow the Data Quality Objectives for North 11 Cl1 in accordance with the survey requirements established in procedures RM-76, Final Status Survey Design and RM-77, Final Status Survey Implementation, and LTP, Chapter 5. Survey size will be based on the statistical requirements of the Sign Test for Class 1 areas with soil samples collected in random start, systematic data point locations. Surface scanning will be performed with 100%

survey area coverage. This survey will be conducted in accordance with approved BRP procedures and follow the guidance of NUREG 1575.

4. Data Quality Assessment: Isolation and control of the survey area will be maintained until the survey Data Quality Assessment demonstrates that the regulatory requirements for unrestricted site release have been satisfied.

Survey Area Requirements Survey North 11C 11 Page 2 of 2

DATA QUALITY OBJECTIVES Final Status Survey, Release Record North 11C 11 North Radwaste Staging Area STATE THE PROBLEM The Problem:

To demonstrate that the level of residual radioactivity in Class 1 Survey Unit North 11 does not exceed the release criteria of 25 mrem/year Total Effective Dose Equivalent (TEDE) as specified in the License Termination Plan (LTP).

Stakeholders:

The primary stakeholders interested in the answer to this problem are Consumers Energy Co., and the general public as represented by the Michigan Department of Environmental Quality (MDEQ), and the US Nuclear Regulatory Commission (USNRC).

The Planning Team:

The planning team consists of members of the BRP Environmental Services Survey Group (ESSG). The primary decision maker will be the Final Status Survey Supervisor.

The Final Status Survey Supervisor will obtain input from the site Construction Group and Scheduling Group for issues relating to schedule and costs.

Schedule:

Approximately five (5) working days are projected to implement the survey and to collect and analyze field data.

Resources:

The primary resources needed to determine the answer to the problem are two (2) technicians to perform fieldwork, one (1) technician to prepare the samples and conduct laboratory analyses, and two (2) survey team members to prepare and review the design, generate maps, coordinate field activities and evaluate data.

2. IDENTIFY THE DECISION Several decisions need to be defined to address the stated problem.

PrincipalStudy Question (1):

Does the mean concentration of residual radioactivity in the survey unit exceed the release criteria stated above?

Decision (1):

Determine whether the mean concentration of residual radioactivity in the survey exceeds the release criteria stated in the problem.

Actions (1):

Alternative actions include failure of the survey unit, remediation, or no action required.

Data Quality Objectives FSS North I1C1C Page 1 of 5

PrincipalStudy Question (2):

Do any areas of elevated activity in the survey unit exceed the release criteria?

The Decision (2):

Determine if any areas of elevated activity in the survey unit exceed the release criteria.

Actions (2):

Alternative actions include confirmation and investigation, performing the elevated measurement comparison (EMC), remediation, or no action required.

PrincipalStudy Question (3):

Is the potential dose from residual radioactivity in the survey unit ALARA as stated?

The Decision (3):

Determine if the potential dose from residual radioactivity in the survey unit is ALARA.

ALARA requirements for soil remediation are defined in Chapter 4 of the LTP.

Actions (3):

Alternative actions include remediation or no action required.

3. IDENTIFY INPUTS TO THE DECISION Information Needed:

Characterization measurements are required to define the radionuclides present and determine the extent and variability of residual radioactivity in the survey area for design and implementation of the survey. Survey area classification, ALARA analysis, potential radionuclides of interest, and site-specific DCGL values are also required inputs to the decision process. The primary information required for evaluation is the analytical results of survey measurements.

Source of the Information:

The soil sample data to be used for survey development are the radionuclide-specific measurements of representative soil samples collected for radiological characterization and excavated soil surveys conducted to determine suitability for transport of excavated soil to the SVA. The soil samples obtained were judgmentally selected as a result of multiple surveys conducted during the excavation and transport process. The ALARA analysis for potential soil remediation is provided in LTP, Section 4.4. Site-specific DCGL values and BRP radionuclides of interest are defined in LTP Chapter 5, Table 5-1 and Procedure RM-76, Final Status Survey Design.

The survey will be conducted in accordance with applicable regulatory guidance as established in LTP Chapter 5 for Class 1 areas. Soil samples will be utilized for radionuclide-specific measurements in this evaluation.

4. BOUNDARIES OF THE STUDY Boundaries of the Survey:

The target population for this survey is the total thickness of prepared soil in the survey area of 1339 M 2 .

Data Quality Objectives FSS North IIC 1I Page 2 of 5

Temporal Boundaries:

Scanning and sampling in this survey unit will only be performed during daylight hours under dry weather conditions. Surface soils must be free of significant snow cover and standing water prior to surface scanning. Soils must be in a non-frozen state or fragmented for collection to satisfy BRP procedural sampling requirements. The anticipated start date for the survey is September 26, 2006.

Constraints:

Cold weather or rainy conditions may effect the operation of electronic equipment.

Adverse weather conditions that include accumulations of rain or snow may limit area access and delay survey efforts.

5. DEVELOP A DECISION RULE The following decision rules have been developed to define a logical process for choosing among alternative actions for the principal study questions associated with this survey area.

Decision Rule (1):

If all reported concentrations for residual radioactivity are less than the site-specific DCGL's and the unity rule has been satisfied for each sample, then the survey unit meets release criteria. No further action is required.

Decision Rule (2):

Ifthe mean value of activity in the survey unit is greater than the DCGL, then the survey unit fails to meet the release criteria.' Remediate, resurvey, and evaluate the results relative to the decision rule.

Decision Rule (3):

If the mean activity in the survey unit is less than the DCGL and any individual sample measurement exceeds this value, conduct the Sign Test and the elevated measurement comparison (EMC) per LTP, Chapter 5 and Procedure RM-76, Final Status Survey Design. Ifthe EMC and the Sign Test have been satisfied then the survey unit meets the release criteria and no further action is required. Ifthe EMC or the Sign Test has not been satisfied then remediate the area(s) of elevated activity, resurvey as appropriate, and evaluate the results relative to the decision rule.

Decision Rule (4):

If the potential dose from residual radioactivity in the survey unit is ALARA, then no further action is necessary. Ifthe potential dose from residual radioactivity in the survey unit is not ALARA, then remediate and resurvey.

6. SPECIFY TOLERABLE LIMITS ON DECISION ERRORS The Null Hypothesis:

It is assumed that residual radioactivity in the survey unit exceeds the release criterion.

1 When multiple radionuclides are present the mean activity value is determined as the average of the weighted sum. The DCGL of the weighted sum is 1.

Data Quality Objectives FSS North 11C, 1 Page 3 of 5

Type I Error(a ):

The a error is the maximum probability of rejecting the null hypotheses when it is true.

The a error is defined in the LTP at a value of 0.05 (5%) and cannot be changed to a less restrictive value unless prior approval is granted by the USNRC. The a error value of 0.05 will be used for survey planning and data assessment for this survey area.

Type // Error(8):

The /8 error is the probability of accepting the null hypothesis when it is false. A value of 0.05 (5%) will be used for survey planning and data assessment for this survey area.

The Lower Bound of the Gray Region (LBGR):

The LBGR is initially set at one-half the DCGLw for this survey unit. The LBGR may be adjusted during survey design to achieve an optimum relative shift between 1.0 and 3.0.

Relative Shift (A/a):

The relative shift will be maintained within the range of 1.0 and 3.0 by adjusting the LBGR as appropriate.

7. OPTIMIZE DESIGN FOR OBTAINING DATA Statistical Test Sign Test:

Radionuclides of potential plant origin also present in soil as background activity resulting from fallout constitute only a small fraction of the DCGL. Therefore, the Sign Test will be used where applicable in the survey evaluation to determine if the survey area meets the requirements for unrestricted release.

Number of Samples Determined:

The number of samples required for this survey will be determined based on the relative shift as defined by the requirements of the Sign Test (LTP, Chapter 5.) and Procedure RM-76, Final Status Survey Design. The LBGR is initially set at one-half the DCGLw and may be adjusted as necessary for optimizing the survey design to achieve a relative shift between 1.0 and 3.0. Sample point locations are to be determined using a random start, systematic square grid spacing.

Judgmental Sampling:

Co-60 is the most limiting radionuclide for identification by surface scanning; judgmental surface and subsurface core samples will be collected in any location that exceeds the scan investigation level.

Scan Coverage:

Scanning for this survey area will provide 100% coverage.

Number of Samples for Quality Control:

A minimum of 5% of the sample population will be collected for quality evaluation.

These samples may include sample splits, sample recounts, or third party sample analysis. Quality analyses will be conducted as defined in LTP, Chapter 5 and Procedure RM-79, FinalStatus Survey Quality Control.

Data Quality Objectives FSS North 1-1C,1 Page 4 of 5

Additional Sample Analysis Requirements:

The area of soil excavation intersects the identified waterborne pathway for Tritium migration and shall require Tritium in soil analyses for a minimum of 10% of the sample population. Soil samples will be collected in the same random locations as those selected for QA/QC evaluation and sent to an independent laboratory for Tritium analysis. Data results will be provided in the survey package.

Investigation Levels:

Investigation levels defined in LTP, Chapter 5 and BRP Procedure RM-76, Final Status Survey Design, shall be conservatively established for this survey as shown below:

The investigation levels for soil sample measurements are meant to include any individual radionuclide result greater than the site-specific DCGL or where the combined radionuclide values exceed the unity rule. Co-60 is the most limiting radionuclide for identification by surface scanning; further investigation will be initiated at any location that exceeds the Co-60 Scan DCGL of 1818 CPM above background as detailed in the survey design.

Data Quality Objectives FSS North 11ClC Page 5 of 5

FINAL STATUS SURVEY DESIGN Release Record North 11C 11 North Radwaste Staging Area Survey Unit Description Survey North 11 C1 1 encompasses an area of 1339 m2 in the northern section of the Radwaste Staging Area. No materials of plant origin exist in this survey unit.

Soil Sample Design Scoping Data Scoping measurements and supporting surveys performed in the Radwaste Staging Area following removal of subsurface components and demolition debris do not indicate the presence of elevated levels of residual radioactivity in this survey area. Input data for survey design were conservatively estimated based on supporting surveys of excavated soils resulting from subsurface structure and component removal within the Protected Area.

Table 1 Input Data for Survey Design (pCi/g)

Radionuclides Cs-137 Co-60 0.524 0.255 DCGL 11.93 3.21

• Survey data detailed in Attachment 1 Sample Requirements The number of sample data points for this survey is based on the requirements of the Sign Test.

The Unity Rule is used for the presence of multiple radionuclides. The Standard Deviation of the weighted sum is described by the following:

Cy GCSl37 2+ Mcow DCGLcsi37) + DCGLcowo) 2

( = 0.091 Relative Shift Relative Shift = DCGLw-LBGR Relative Shift = 1-0.818 0.091 Relative Shift = 2.0 With cc and 13error levels set at 0.05 and the relative shift of 2.0, the Sign Test requires 15 sample data points (Table 5.5 NUREG 1575).

Survey Design FSS North 11C1 l Page 1 of 7

Sample Locations Sample locations are selected in a random start, systematic square grid pattern with the southwest corner of the survey unit as origin (X=0, Y=0). Two numbers between 0 and 1 have been randomly selected and then applied to the survey unit maximum X and Y dimensions to determine the random start location as shown below:

Table 2 Random Numbers Random #, X Axis Random #, Y Axis 0.619105 0.748234 Survey Unit Dimensions: X = 45 meters Y = 30 meters Random Start Location X = (0.619105)(45) = 27.9 meters With SW Corner Origin: Y = (0.748234)(30) = 22.4 meters Sample Spacing As a conservative measure sample spacing will be calculated based on 18 samples for this survey. Samples are located in a systematic square grid pattern with sample spacing determined by the following:

LA n

Where: A= area of survey unit, and n = number of samples.

,1339 L =F - 8.6 meters 18 With sample spacing established at 8.6 meters, 15 data points are available for this survey.

Data point locations are identified in Attachment 2.

QAIQC Sampling A minimum of 5% of the sample population and 5% of the scan survey area are required to be selected for QA/QC verification in accordance with BRP Procedure RM-79, Final Status Survey Quality Control. As a conservative measure, three (3) soil samples and 10% of the scan survey area will be selected for QA/QC evaluation. Data point locations for soil samples will be determined by random number selection.

The QA/QC scan starting point and track direction are also determined by random number selection. The first random data point selected will identify the scanning start point and the second random data point will determine the direction in which the scan will track. QA/QC location results are provided in Table 3 below:

Survey Design FSS North 11C,1 Page 2 of 7

Table 3 Random Numbers Generated for QA/QC QA/QO Soil Random Random Samples Sample Verification Scan Sample Sampes _Number _Number Split Sample: 3 Start Point: 6 Sample Recount: 6 Scan Toward: 13 Sample Recount: 12 IScan Area Requirement: 134 m 2 Surface Scanning The coverage requirement for surface scanning in this Class 1 area is 100%. The Scan MDc has been established at fractional values of the DCGLw for typical background activity levels at Big Rock Point. Scan MDC values for varying backgrounds are provided in Attachment 3. The investigation level for identification of potential areas of elevated activity in this survey area will be the Scan DCGL as defined by the following:

Scan DCGL = Detector Rating CPM . Exposure Model uR/hr

• DCGLw uR/hr pCi/g Scan DCGL for Co-60 = 1818 CPM Scan DCGL for Cs-137 = 3518 CPM Where:1 Detector Rating = 1200 CPM Cs -137 and 565 CPM Co -60 uR/hr uR/hr Exposure Model = 1.229 uR/hr Cs-137 and 5.029 uR/hr Co-60 5pCi/g 5 pCi/g DCGLW = 11.93 pCi/g Cs-137 and 3.21 pCi/g Co-60 The DCGLw for Co-60 is the most limiting value for scanning measurements performed to identify areas of potentially elevated activity. Scanning conducted for this survey will assume all residual radioactivity to originate from Co-60 and the instrument response at the Co-60 DCGLw (1818 cpm) will be used as the scanning investigation level for FSS North 11C11.

'These values established in EA-BRP-SC-0201, Nal Scanning Sensitivity for Open Land Survey.

Survey Design FSS North I1COl Page 3 of 7

Attachment I Design Data - FSS North 11C 11 Protected Area Supporting Surveys Cs-1 37 Co-60 Survey No. Sequence Activity Activity No. (pCi/g) (pCi/g)

,HH060705 1T653878 1;'26:- 06 HH0607,05 '.1,6539 ,006 6 7HH060705' -1,6540 1,05,'.', 2 0'%66

iTB06280'5- 18755 1.16--- 27 tTB062805 "...16756,, ..... ill

'TB062805$- 1l6ý7

• 0,1 97*,

• 0*31' Mean: 0.698 0.352 Std Dev: 0.524 0.255

• Measurement system MDA - Co-60 not identified in this sample Survey Design FSS North 11C, 1 Page 4 of 7

Attachment 2 Soil Sample Locations - Survey North 11 C1I North Radwaste Staging Area 4+

0 Sam-ple Location 0

I 2.5 5 10 Meters I

M Survey UnitNorthl11C1_1 Sample spacing is 8.6 meters Survey Design FSS North 11C11 Page 5 of 7

Attachment 3 Scan MDC In Varying Backgrounds Background d' __s_ MDCRsurveVor Cs-137 Co-60 Cs-137 Co-60 2000 2.48 4 28.64 607.47 0.51 1..08 2.06 1.07

-2$O0'< 2.4,8 K4~ 39.00' 6~87

_Q1. 0T5 022 2.__0 3000 2.48 4 35.07 744.00 0.62 1.32 2.52 1.31 3500 2.48 4 37.88 803.61 0.67 1.42 2.72 1.41 4000 2.48 4 40.50 859.10 0.72 1.52 2.91 1.51 4500 2.48 4 42.95 911.21 0.76 1.61 3.09 1.60 5 0 11Z _45.& -~9,60.~ -A~ n 5500 2.48 4 47.49 1,007.38 0.84 1.78 3.42 1.77 6000 2.48 4 49.60 1,052.17 0.88 1.86 3.57 1.85 6500 2.48 4 51.63 1,095.14 0.91 1.94 3.71 1.93 7000 2.48 4 53.57 1,136.48 0.95 2.01 3.85 2.00 8000 2.48 4 57.27 1,214.95 1.01 2.15 4.12 2.14 8500 2.48 4 59.04 1,252.34 1.04 2.22 4.25 2.20 9000 2.48 4 60.75 1,288.65 1.07 2.28 4.37 2.27 9500 2.48 4 62.41 1,323.96 1.10 2.34 4.49 2.33 10500 2.48 4 65.61 1,391.90 1.16 2.46 4.72 2.45 11000 2.48 4 67.16 1,424.65 1.19 2.52 4.83 2.51 11500 2.48 4 68.67 1,456.67 1.21 2.58 4.94 2.56 12000 2.48 4 70.14 1,488.00 1.24 2.63 5.04 2.62 13000 2.48 4 73.01 1,548.76 1.29 2.74 5.25 2.73 13500 2.48 *4 74.40 1,578.26 1.32 2.79 5.35 2.78 14000 2.48 4 75.77 1,607.22 1.34 2.84 5.45 2.83 14500 2.48 4 77.11 1,635.67 1.36 2.89 5.55 2.88

...... .. 6... .248.4....... 2.94 5.6 Mod~Ie'&xp~osu5.

___,3E _____

Survey Design FSS North 11C, 1 Page 6 of 7

Attachment 4 Area Factors for Open Land Survey Evaluation Contaminated Calculated Area Factors at Time of Peak Dose H-3 Mn-54 Fe-55 Co-60 Sr-90 Cs-137 Eu-152 Eu-154 Eu-155 Area (ind) 8094 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 4047 1.00 1.01 1.00 1.01 1.00 1.02 1.02 1.01 1.02 2024 1.00 1.03 1.00 1.03 1.00 1.03 1.03 1.03 1.03 1012 1.35 1.04 1.00 1.04 1.00 1.04 1.05 1.04 1.04 506 2.91 1.09 1.98 1.08 1.98 1.13 1.07 1.07 1.06 253 6.05 1.14 3.95 1.13 3.94 1.20 1.11 1.11 1.09 126 12.4 1.20 7.93 1.20 7.87 1.29 1.17 1.16 1.14 63 24.9 1.30 15.8 1.30 15.6 1.41 1.27 1.26 1.23 32 49.2 1.49 31.2 1.49 30.5 1.62 1.44 1.45 1.39 16 98.9 1.78 62.0 1.78 59.9 1.93 1.72 1.73 1.63 8 198 2.38 123 2.38 117 2.58 2.30 2.31 2.14 4 397 3.61 243 3.62 230 3.91 3.49 3.52 3.19 2 794 5.68 473 5.75 452 6.14 5.48 5.55 4.90 1 1590 9.57 905 9.73 887 10.3 9.24 9.39 7.88 Survey Design FSS North 11COl Page 7 of 7

RM-76 Revision 1 FINAL STATUS SURVEY DESIGN Page 19 of 19 RM-76-5 FINAL STATUS SURVEY APPROVAL AND AUTHORIZATION FOR IMPLEMENTATION Survey Code North 11C, 1 Survey Area

Description:

Final Status Survey North 11 Ci1 encompasses 1339 m 2 in the southern section of the old radwaste stagingq area. No materials of plant origin remain in this Class 1 survey unit.

The survey area is authorized for Final Status Survey Implementation.

Designed by Date Technical Review by %Date RM-76.doc

RM-77 Revision 2 FINAL STATUS SURVEY IMPLEMENTATION Page 8 of 12 RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 1 of 3 Step Initial Date

(+)

1.0 PREPARATION FOR SURVEY CIL11CI. I Survey #

1.1 Survey Area Status:

a. Final Status Survey Design has been approved for implementation (see RM-76-5, Final Status Survey Approval and Authorization for Supplementation).

1. Survey area walkdown complete

2. Survey area determined ready for FSS

3. Decommissioning activities that may impact the environmental status of the survey area have been completed.

4. Survey area environment is controlled by barriers ooi-a2J50 O and postings or other approved method to restrict OESSG access.

b. Survey area has been turned over to the Environmental Services Survey Group (ESSG) in acceptable condition for FSS.

GE-S-SG OAL9joto 1.2 Field Preparation:

a. Survey unit boundaries delineated (Step 6.1.1)

b. Statistical soil samples predetermined in the survey design are located and marked within the survey unit.

(Step 6.1.2) 1~ C. Soil sample locations verified (Step 6.1.2.c)

-V d. Instruments and equipment have been collected and calibrated for data measurement and collection (Step 6.1.3) Cýlu VLO

e. Field documentation is prepared (Step 6.1.4) JSSG RM-77.doc

RM-77 Revision 2 FINAL STATUS SURVEY IMPLEMENTATION Page 9 of 12 RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 2 of 3 Initial Date 2.0 DATA COLLECTION 2.1 Soil Survey:

All soil samples collected and controlled (Step 6.2.1). n/ff . 1l01Io4

,VESSG 2.2 Surface Scan:

,/ Surface Scan complete. Action response requirements have been conducted on any identified areas exceeding the investigation level (Step 6.3).

qSSG 2.3 Judgmental Soil Samples:

4 a. Judgmental soil samples have been collected and controlled (Step 6.2.3).

dL b. Deep core profiles performed in areas identified to contain elevated residual activity (Step 6.2.3). (AL D,wa(.O

ýESSG 3.0 SAMPLE PREPARATION AND LABORATORY ANALYSIS 3.1 Sample Preparation (Step 6.4.1):

a. Soil samples are homogenous Soil samples are visibly dry prior to packing c., Non-soil materials have been removed from sample

d. Soil samples have been transferred to one-liter Marinelli containers and are labeled and sealed. DtJ.P~

RM-77.doc

RM-77 Revision 2 FINAL STATUS SURVEY IMPLEMENTATION Page 10 of 12 RM-77-1 SURVEY IMPLEMENTATION CHECKLIST Page 3 of 3 Initial Date 3.2 Laboratory Analysis:

Isotopic analyses are complete. The spectroscopy report requires a signature of completion by the laboratory analyst and a signature of evaluation documenting that a second level review has been performed (Step 6.4.2). I &SSG eli)9-9)0ýa 3.3 Sample Control and Documentation:

-Z Chain of custody documentation exhibits control of soil samples (Step 6.4.3).

Reviewed by Date RM-77.doc

RM-59 Revision 11 SAMPLING AND ANALYSIS OF OPEN LAND Page 7 of 13 AREAS FOR SITE CHARACTERIZATION SURVEYS ATTACHMENT RM-59-1 SAMPLING AND ANALYSIS REPORT Date: 09-26-2006 Time: 1600 Location: North 11 C 1 Tech:

DSSO/JHW/LEDIWMH SURVEY IDENTIFICATION / DESCRIPTION Survey North 11C,1 encompasses 1339 m 2 at or below the grade elevation in the northern section of the old radwaste stagqing area. No materials of plant origin remain in this area.

SURVEY TYPE Survey Type: Characterization X Scan (Motive)

Remediation X Final Scan (Static)

Trenching and Digging (use RM-59-4)

SURVEY DESIGN

.Sample Collection: _ Judgmental _ Random X Systematic _ Large Container Assay Scan Coverage: 100%

ANALYSIS Inst.SN/Cal Due 186192/03-14-2007 DAILY CHECK: X SAT UNSAT INIT: sso Inst.SN/Cal Due 186194/02-08-2007 DAILY CHECK: X SAT UNSAT INIT: LED Inst.SN/Cal Due 186201/09-30-2006 DAILY CHECK: X SAT UNSAT INIT: WMH Inst.SN/Cal Due 189086/01-26-2007 DAILY CHECK: X SAT UNSAT INIT: JHW Inst.SN/Cal Due Det. # 6 DAILY CHECK: X SAT UNSAT INIT: Jp Investigation of Unidentified Peaks: X SAT UNSAT INIT: JLR Minimum Detectable Activity (Section 5.3.2) X SAT UNSAT INIT: JLR COMMENTS Survey North 11 Ci1 was performed in a random start, square -grid, systematic samplinq pattern with samples collected at 15 data point locations. Laboratory analyses did not identify residual radioactivity above trace levels of the DCGL value. Surface scanning identified no areas of elevated residual radioactivity. The results of the QA/QC verification scan (10%) were consistent with the findings of the primary survey scan.

Technician Signature:s / Dat' /~ 6(

Second Level Review Signature: Date: 1O.Ž1/o RM-59.doc

Soil Sample Activity Summary Release Record North 11 Cll North Radwaste Staging Area

• Sample Location 0 2.5 5 10 Meters Survey Unit North 1IC1_1

Surface Scan Summary Release Record North 11 Cll North Radwaste Staging Area

• Sample Location Survey Unit North 11CI_1 RED Values are Average Mobile Scan General Area Activity (kcpm)

BLUE Values are Average Verification Scan General Area Activity (kcpm)

GREY Values are Average General Background Area Activity (kcpm)

Primary Scan: 6.

Technician Signature: Date: .,.

Time: i%*

QC Verification Scan: 0  %

Technician Signature: J/4IA .1 J/ Date: -2L-Time: /,<za

RM-72 Revision 0 SAMPLE CHAIN-OF.CUSTODY Page 1of 5 RM-72-1 CHAIN-OF-CUSTODY RECORD Sample Number Sampling Location Date Time Final Disposition of Sample Z-  %*o~o 1o 9__V"___1) I L-OI 0

• 1.7*coix* 1MQL 13~~ 14oL.ý.

(Samples may be analyzed and stored, shipped for offsite evaluation or analyzed and disposed of.)

1._Religu4 ,J, *i~ Date Time Receive*iingood in go condition c by:

2 Rs yTe

3. Relinquished by: Date Time Received in good condition by:

4. Relinquished by: Date Time Received in good condition by:

4. Relinquished by: Date Time Received in good condition by:

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 19 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 1 of 8 FINAL STATUS SURVEY: /14r 7~A //* /

1.0 DATA VERIFICATION 1.1 Data Acceptance Review the Implementation Checklist (RM-77-1) to verify that survey isolation and control measures were executed prior to FSS and are being maintained.

Review RM-77, Final Status Survey Implementation, to verify that methods, techniques, and survey activities required for FSS have been applied in accordance with the appropriate procedures.

1.2 Field QC Records:

Review all assessments, Condition Reports and audits to ensure that identified issues have been resolved.

Comments:

Verify scan instrumentation was in calibration and the QC source checks were performed prior to and after surveys.

Verify daily QC source checks for Canberra gamma spectroscopy detector properly logged prior to soil sample analysis.

1.3 Review Verification:

71 Verify that the Data Quality Objectives are complete.

__ Verify that the survey design has been technically reviewed.

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 20 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 2 of 8 Verify that gamma spectroscopy results have received a technical review.

Verify the Sample and Analysis Report (RM-59-1) is completed and reviewed.

Data Verification Completed: CIIIs No Comments Assessor Date RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 21 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 3 of 8 2.0 DATA VALIDATION 2.1 Documentation Review:

Perform documentation review for quality control purposes and validate the data collected is complete and appropriate for use as defined by the survey design. Documentation includes:

Field measurement records j Chain-of-custody Quality Control (QC) measurement records Current qualification of survey personnel

/ Corrective Action Reports V* Data inputs (laboratory spectroscopy)

_ Sample preparation techniques 2.2 Detection Limit Review:

§Scan MDCs are below established site DCGLs.

7' Forced-count values are assigned as necessary when activity is not detected in a sample.

_,,_ Minimum Detectable Concentration (MDC) values of gamma spectroscopy are below established DCGLs.

2.3 Quality Control (QC) Data Review:

____ Quality Control (QC) data results have received required reviews and are complete and consistent.

.4 Results of judgmental samples have been reviewed and evaluated.

.44 Review to ensure that the analytical results of judgmental samples do not impact the evaluation for unrestricted release of the survey area.

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 22 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 4 of 8 2.4 Qualification of Data:

Statistical radionuclide-specific measurements for completeness. Evaluate the survey for determination of data usability and confirm that sufficient qualified data are present for the decision process.

a. Total number of statistical samples planned for the survey:

b. Total number of statistical samples determined as valid: I b x120

c. Calculate % Completeness:

a j Qualified data are >_100% completeness and are sufficient to support the Sign Test requirement for determination of unrestricted release.

Data Validation Completed: & No Comments:

Date RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 23 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 5 of 8 3.0 DATA QUALITY ASSESSMENT 3.1 Review the DQOs and Survey Design:

Confirm that all inputs to the decision have been reviewed and are complete.

Verify that boundaries or constraints identified in the survey area have not affected the quality of the data.

Review the Statement of Hypothesis and confirm that it remains relevant.

__ Confirm that Type I and Type IIerror limits are consistent with DQOs.

v1 Confirm that the survey design is consistent with DQOs and that the appropriate number of data points were obtained.

3.2 Preliminary Review:.

3.2.1 Preliminary Evaluation:

41 Quality Assessment (QA) reports consistent with Procedure RM-79, Final Status Survey Quality Control.

• /I Survey is of sufficient intensity to satisfy classification requirement.

____ Potential trends of radioactivity levels in the survey area do not impact a decision for unrestricted release.

Comments:

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 24 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 6 of 8 3.2.2 Calculate Basic Statistical Quantities:

a. Number of qualified data points

b. Calculation of the Mean '7.O0 'V (<o>

c. Calculation of the Median L.M23 (,oi*

d. Calculation Standard Deviation on," (_-'

,L Attach graphic representation of the data if any radionuclide-specific measurements exceed 50% of the DCGL.

V'" Sample QA/QC measurements consistent with FSS data 3.3 Statistical Evaluation:

NOTE: If all measurement data are less than the DCGLW, statistical testing in not required and the survey unit meets the regulatory requirement for unrestricted release.

v/_ All survey measurements are below the DCGLw.

3.3.1 Verify Assumptions of the Survey Design

____ Review the posting plot to verify that the data exhibits spatial independence. Spatial trends must be investigated and resolved prior to further assessment.

_ Review to verify dispersion symmetry. The appearance of skewed data must be investigated for cause and documented prior to further assessment.

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 25 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 7 of 8

____ Review the dataset standard deviation and range for data variance.

Questionable data must be investigated for cause and documented prior to further assessment.

Verify that the data exhibits adequate power and confirm that the sample size is sufficient to satisfy the DQOs.

3.4 Draw Conclusions from the Data:

3.4.1 Investigation Levels and Response Actions V/ Determine if data results have exceeded any in etition level.

Document findings.

• 7t* 24 "

3.4.2 Evaluation for Unrestricted Release Select applicable conclusion:

____ Survey area acceptance criteria met and survey area satisfies the requirements for unrestricted release:

All concentrations are less than the DCGLw. The Null Hypothesis is rejected.

• The mean concentration of the survey area is below the DCGLw but individual measurements in the survey unit exceed the DCGLw. The Sign Test and EMC evaluation are successful and the Null Hypothesis is rejected.

RM-78.doc

RM-78 Revision 2 FINAL STATUS SURVEY ASSESSMENT Page 26 of 26 RM-78-3 DATA ASSESSMENT REPORT Page 8 of 8 4 _ Survey area acceptance criteria not met and survey area fails to satisfy the requirements for unrestricted release:

_ The mean concentration in the survey area exceeds the DCGLW. and the null hypothesis is confirmed.

The mean concentration of the survey area is below the DCGLw but individual measurements in the Unit exceed the DCGLw..

The Sign Test and EMC evaluation are unsuccessful and the null hypothesis is confirmed.

Data Quality Assessment Completed: No Comments 7 *_Ze * ,

Assessor Date Reviews:

Technical Revie. Date ES SuperMtendent Date RPSýES MVlinager,,ýý Date RM-78.doc

RM-78-3, Attachment 1 Statistical Quantities Release Record North 11Cll North Radwaste Staging Area Sample Cs-1 37 Co-60 Weighted **Weighted Sum Number (pCi/gm) (pCi/gm) Sum (SOR) <DCGLw? DCGL-W. Sum Sign 1 0.1070 0.0060 0.0108 yes 0.9892 +1 2 0.1581 0.0456 0.0275 yes 0.9725 +1 3 0.0462 0.0188 0.0097 yes 0.9903 +1 4 0.0580 0.0062 0.0068 yes 0.9932 +1 5 0.0146 -0.0118 -0.0025 yes 0.9975 +1 6 0.0588 0.0350 0.0158 yes 0.9842 +1 7 0.0606 0.0208 0.0116 yes 0.9884 +1 8 0.0177 0.0045 0.0029 yes 0.9971 +1 9 0.0690 0.0146 0.0103 yes 0.9897 +1 10 0.0736 0.0106 0.0095 yes 0.9905 +1 11 0.0780 -0.0113 0.0030 yes 0.9970 +1 12 0.0457 0.0092 0.0067 yes 0.9933 +1 13 0.0041 -0.0218 -0.0064 yes 0.9936 +1 14 -0.0077 0.0287 0.0083 yes 0.9917 +1 15 0.0504 0.0033 0.0053 yes 0.9947 +1 Std. Dev 0.0416 0.0179 0.0078 Mean 0.0556 0.0106 0.0080 Median 0.0580 0.0092 0.0083 Number of Positive Differences (S+): n/a Critical Value, k, Table 1.3 of Marssim: n/a S+ >thank?: n/a Survey Unit Pass or Fail:

• • Pass

• Note: Forced-Count values are used for samples with activity levels below the MDA.

• • Note: If all measurement data are less than the DCGL ., then the Sign Test is not required.

. t RM-79 Revision I FINAL STATUS SURVEY QUALITY CONTROL Page 11 of 13 RM-79-1 FSS QUALITY CONTROL EVALUATION RESULTS FSS Package # Llr-, / QC Package # "d4Axc, 11 QC Measurement Type Acceptance Criteria Met*? Reference Z 1. Replicate Scan (9 / No Step 5.1.3

2. Sample Recounts Step 5.1.4.1

a. In-house 6i)No 4/' b. Third party Yes / No Split Samples Step 5.1.4.2

c. In-house (I No kziL d. Third party Yes / No

• NOTE: IfAcceptance Criteria is not met, completion of Attachment RM-79-2, FSS Quality Control Investigation Results, is required.

Comments:

, _ý ".'1' 'V,q,::- -,AM,- , "ý'

--P-/' -:::-

Reviews:

Evaluator Date

• .* "-oc' 4o Technical Review Date RM-79.doc

QA Verification Sample Recount Analysis Table I Date: 9/26/2006 Acceptance Criteria Resolution Ratio QA: North 11C,1 North Radwaste Staging Area <4 N/A 4-7 0.5-2.0 Type: Sample Recounts 8-15 0.6-1.66 16-50 0.75-1.33 Lab: In- House 51-200 0.8-1.25

>200 0.85-1.18 A B C D E F G BRP BRP BRP Acceptance Recount Comparison Results in Radionuclide Result Results  % Error BRP Ratio Recount Results Ratio Agreement Sample Below Resolution ResultCopr MDA (pCi/g) (Sigma) (Table 1) Below MDA (pCi/g) F/A Compare Below__ __________ G with D) 6 Co-60 0.0715 n/a. n/a n/a < 0.0491 0.69 YES 6 Cs-137 0.0588 19.61 5.10 0.5-2.0 0.0519 0.88 YES 12 Co-60 < 0.0469 n/a n/a n/a < 0.0565 1.20 YES 12 Cs-137 0.0457 29.81 3.35 n/a 0.0465 1.02 YES Resolution C - (AllB7O

< Indicatesresults less than the MDA.

• Note Results are consideredin agreement for MDA and near-MDA measurement comparisons Results fthat fall agreementmust be investigatedper RM-79.

QA Verification Split Sample Analysis Table 1 Date: 9/26/2006 Acceptance Criteria Resolution Ratio QA: North 11Cl North Radwaste Staoina Area. <4 N/A 4-7 0.5-2.0 Type: Split Sample 8-15 0.6-1.66 16-50 0.75-1.33 Lab: In-House 51-200 0.8-1.25

>200 0.85-1.18 A B C D E F G Re Resolution C = (A)(' A O

< Indicatesresults less than the MDA.

Note Results are consideredin agreement for MDA and near-MDA measurement comparisons Results Ithat fail agreement must be investigatedper RM-79.

L ., , 0 Tritium in Soil Data Results Final Status Survey North 11C 11 Sample 1 Tritium in Soil Number J pCi/g 3 0.056 6 0.039 12 0.027 Mean: 0.0407 Median: 0.0390 St. Dev: 0.0146 Note: The DCGL for Tritium is 327 pCi/g.

Sample results are less than 0.02% of the DCGL

Environmental, Inc.

Midwest Laboratory an Allegheny Technologies Co.

700 Landwehr Road

• Northbrook, IL60062-2310 ph. (847) 564-0700

• fax (847) 564-4517 Mr. David W. Parish LABORATORY REPORT NO. 8022-100-246 Big Rock Point DATE: 10-06-2006 10269 US-31 North SAMPLES RECEIVED: 10-02-2006 Charlevoix, MI 49720 PURCHASE ORDER NO:

Below are the results of the analyses for tritium on three soil samples.

Excavated Soil Survey: NORTH, 11C 1 -1 Sample Collection Lab Concentration MDA Description Date Code (pCi/g of soil) (pCi/g of soil)

H-3 3 09-26-06 BRSO-6706 0.056 +/- 0.019 < 0.027 6 09-26-06 BRSO-6707 0.039 +/- 0.011 < 0.015 12 09-26-06 BRSO-6708 0.027 +/- 0.007 < 0.010 The error given is the probable counting error at 95 % confidence level. The less than, (<), value is based on 4.66 sigma counting error for background sample.

Sincerely, 1'e" /ý26-ýw o'ý1114-Bronia Grob, Laboratory Manager APPROVED BY Tony Coorlim, Quality Assurance