ML24214A039

Enclosure 3: Oyster Creek Station, Historical Site Assessment (Hsa) Revision 2, November 2021

ML24214A039
Person / Time
Site:	Oyster Creek
Issue date:	11/30/2021
From:	Mccarthy J Comprehensive Decommissioning International, Holtec Decommissioning International, SNC-Lavalin Nuclear
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML24214A209	List: ML24214A037 ML24214A039 ML24214A043 ML24214A044 ML24214A048 ML24214A049 ML24214A051 ML24214A052 ML24214A053 ML24214A054 ML24214A057 ML24214A058 ML24214A060 ML24214A061 ML24214A064 ML24214A065 ML24214A069 ML24214A070 ML24214A072 ML24214A075 ML24214A078 ML24214A079
References
HDI-OC-24-018
Download: ML24214A039 (1)

Text

Oyster Creek Station

Historical Site Assessment (HSA)

Revision 2

Prepared by: Oyster Creek Decommissioning

Generated: February 2020 Revised: November 2021

Page 1 OYSTER CREEK STATION HSA Revision 2 Historical Site Assessment Principal Investigator: N/A -Document Revision to address NJDEP Comments Jack McCarthy, Certified Health Physicist Revised By: rJ/ Tom Williamson, Project Manager Reviewer:

Ed O'Brien, Professional Geologist Approver:

adiation Protection and Chemistry Disclaimer: The use of any trade names, products or materials in this manual does not constitute an endorsement by Comprehensive Decommissioning International (COi).

The information in the HSA is provided free of charge. COi assumes no responsibility to a person or entity for the use of this information. There are no representations or warranties, expressed or implied, of any kind regarding this information.

Page 2 OYSTER CREEK STATION HSA Revision 2

1. Glossary of Term, Acronyms and Abbreviations ....................................................... 8

2. Executive Summary ................................................................................................ 13

3. Purpose of the Historical Site Assessment .............................................................. 14

4. Property Identification ............................................................................................. 16 4.1. Physical Characteristics ....................................................................................... 16 4.1.1. Name .................................................................................................................. 16 4.1.2. Location .............................................................................................................. 16 4.1.3. Topography ......................................................................................................... 17 4.1.4. Stratigraphy ......................................................................................................... 17 4.2. Environmental Setting ......................................................................................... 17 4.2.1. Geology ............................................................................................................... 17 4.2.2. Hydrogeology ...................................................................................................... 18 4.2.3. Hydrology ............................................................................................................ 20 4.2.4. Meteorology ........................................................................................................ 20

5. Historical Site Assessment ...................................................................................... 22 5.1. Approach and Rationale ...................................................................................... 22 5.1.1. Identify Planning Team Members including the Decision Maker ........................... 22 5.1.2. State the Problem ................................................................................................ 23 5.1.3. Classify the site as Impacted or Non-Impacted .................................................... 23 5.2. Boundaries of the site .......................................................................................... 24 5.3. Documents Reviewed .......................................................................................... 24 5.4. Property Inspections ............................................................................................ 26 5.5. Personal Interviews ............................................................................................. 28

6. History and Current Usage...................................................................................... 29 6.1. History ................................................................................................................. 29 6.2. Current Usage ..................................................................................................... 30 6.3. Adjacent Land Usage .......................................................................................... 31

7. Findings .................................................................................................................. 32 7.1. Potential Contaminants........................................................................................ 32 7.2. Potential Contaminated Areas ............................................................................. 36 7.2.1. Impacted Areas known and potential ................................................................... 37 7.2.1.1. Structures...................................................................................................... 37 7.2.1.1.1. AOB and Annex ......................................................................................... 37 7.2.1.1.2. AOG Building ............................................................................................. 39

Page 3 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.3. Boiler Houses ............................................................................................. 42 7.2.1.1.4. Breathing Air Compressor Building ............................................................. 44 7.2.1.1.5. Building 3 Old Machine Shop ...................................................................... 46 7.2.1.1.6. Building 4 Site Storage Building .................................................................. 48 7.2.1.1.7. Chlorination Building ................................................................................... 50 7.2.1.1.8. Clean Rigging and Storage Buildings ......................................................... 51 7.2.1.1.9. Condensate Transfer Pump House and Systems ....................................... 53 7.2.1.1.10. Contractor Trailer Complex (CB&I) ........................................................... 55 7.2.1.1.11. Diesel Generator Building ......................................................................... 57 7.2.1.1.12. Dilution Pump House ................................................................................ 58 7.2.1.1.13. Drywell Processing Center........................................................................ 60 7.2.1.1.14. Fire Water Pump House ........................................................................... 62 7.2.1.1.15. Fish Sample Pond .................................................................................... 63 7.2.1.1.16. Hazard Collection Building ........................................................................ 65 7.2.1.1.17. Hot Machine Shop .................................................................................... 67 7.2.1.1.18. Hot Tool Room ......................................................................................... 69 7.2.1.1.19. Intake and Discharge Structure ................................................................. 71 7.2.1.1.20. ISFSI Area ................................................................................................ 73 7.2.1.1.21. Level D Building........................................................................................ 75 7.2.1.1.22. LLRWSF ................................................................................................... 77 7.2.1.1.23. MAC Facility ............................................................................................. 80 7.2.1.1.24. MAF ......................................................................................................... 82 7.2.1.1.25. Main Gate Security Center........................................................................ 84 7.2.1.1.26. Maintenance Supervisor Building .............................................................. 86 7.2.1.1.27. MOB - Office Building .............................................................................. 88 7.2.1.1.28. New Maintenance Building ....................................................................... 91 7.2.1.1.29. New Sampling Building ............................................................................. 93 7.2.1.1.30. NRW Building ........................................................................................... 95 7.2.1.1.31. NRW Chlorination Facility ....................................................................... 100 7.2.1.1.32. OCAB ..................................................................................................... 101 7.2.1.1.33. ORW Building ......................................................................................... 103 7.2.1.1.34. ORW North Annex .................................................................................. 108 7.2.1.1.35. Pretreatment Building ............................................................................. 110 7.2.1.1.36. RCA OSSC ...................................... ....................................................... 112

Page 4 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.37. Reactor Building ..................................................................................... 113 7.2.1.1.38. Respirator Facility ................................................................................... 119 7.2.1.1.39. Scaffold Building ..................................................................................... 121 7.2.1.1.40. SEB ........................................................................................................ 123 7.2.1.1.41. Service Water Monitor Building ............................................................... 125 7.2.1.1.42. Stack and Base of Stack......................................................................... 127 7.2.1.1.43. Stack RAGEMS ...................................................................................... 131 7.2.1.1.44. Turbine Building ...................................................................................... 133 7.2.1.1.45. Turbine Generator Services Trailer ......................................................... 137 7.2.1.1.46. Turbine RAGEMS Building ..................................................................... 139 7.2.1.1.47. Warehouse ............................................................................................. 141 7.2.1.2. Storage Tanks ............................................................................................. 143 7.2.1.2.1. CST .......................................................................................................... 143 7.2.1.2.2. Dirty Oil Tank ........................................................................................... 145 7.2.1.2.3. DWST ...................................................................................................... 146 7.2.1.2.4. Liquid Nitrogen Tank ................................................................................ 148 7.2.1.2.5. MFOT ....................................................................................................... 149 7.2.1.2.6. New Demineralized Water Tank ............................................................... 150 7.2.1.2.7. ORW Surge Tank ..................................................................................... 151 7.2.1.2.8. Outdoor Tank and Enclosure .................................................................... 153 7.2.1.2.9. Redundant Fire Water Tank ..................................................................... 155 7.2.1.2.10. Sodium Hypochlorite Storage Tanks ....................................................... 156 7.2.1.2.11. TWST ..................................................................................................... 157 7.2.1.3. Land Areas ................................................................................................. 159 7.2.1.3.1. East PA Non-RCA .................................................................................... 159 7.2.1.3.2. East Wooded Area ................................................................................... 161 7.2.1.3.3. Main Parking Lot ...................................................................................... 163 7.2.1.3.4. North PA Non-RCA .................................................................................. 165 7.2.1.3.5. North Parking Lot ..................................................................................... 167 7.2.1.3.6. Northeast Parking Lot ............................................................................... 169 7.2.1.3.7. North Wooded Area .................................................................................. 171 7.2.1.3.8. RCA Yard ................................................................................................. 173 7.2.1.3.9. South PA Non-RCA .................................................................................. 175 7.2.1.3.10. South Parking Lot ................................................................................... 178

Page 5 OYSTER CREEK STATION HSA Revision 2 7.2.1.3.11. South Wooded Area ............................................................................... 179 7.2.1.3.12. West PA Non-RCA ................................................................................. 181 7.2.1.4. Subsurface SSC .......................................................................................... 183 7.2.1.4.1. Basements, Footings, Tunnels, Pipe Chases, and Piping ......................... 183 7.2.1.5. Subsurface Soil ........................................................................................... 188 7.2.1.5.1. North Parking Lot Subsurface ................................................................... 188 7.2.1.5.2. RCA Yard Subsurface .............................................................................. 190 7.2.1.5.3. Reactor Building/Turbine Building Subsurface .......................................... 191 7.2.1.5.4. South PA Non-RCA Subsurface ............................................................... 192 7.2.1.5.5. West PA Non-RCA Subsurface ................................................................ 193 7.2.1.6. Intake and Discharge Canals ...................................................................... 194 7.2.2. Non-Impacted Areas .......................................................................................... 196 7.3. Potential Contaminated Media ........................................................................... 196 7.3.1. Surface Soil ....................................................................................................... 196 7.3.2. Structures .......................................................................................................... 196 7.3.3. Systems ............................................................................................................ 197 7.3.4. Subsurface Soil ................................................................................................. 197 7.3.5. Surface Water ................................................................................................... 197 7.3.6. Groundwater ...................................... ............................................................... 197 7.3.7. Sediment ........................................................................................................... 198 7.3.8. Miscellaneous .................................................................................................... 198 7.4. Related Environmental Concerns ...................................................................... 198

8. Conclusions .......................................................................................................... 198

9. References ............................................................................................................ 199

10. Appendices ........................................................................................................... 201 10.1. Figures and Conceptual Model and Site Diagram showing Classifications ......... 201 10.2. List of radiological incident files §50.75(g)(1)` ............................................................ 212 10.3. Photo documentation Log .................................................................................. 252

Page 6 OYSTER CREEK STATION HSA Revision 2

List of Tables Table 1: 2020- 2021 Waste stream list of positively identified radionuclides 33 Table 2: HSA complete list 34 Table 3: Alpha level characterization as defined by RP -AA- 302 35 Table 4: Current alpha classification of areas at the site 35 Table 5: AOG Building radiological conditions summary 39 Table 6: Boiler Houses radiological conditions summary 42 Table 7: Hot Machine Shop radiological conditions summary 67 Table 8: LLRWSF radiological conditions summary 77 Table 9: NRW Building radiological conditions summary 95 Table 10: ORW Building radiological conditions summary 103 Table 11: Reactor Building and drywell radiological conditions summary 113 Table 12: Stack and Base of Stack radiological conditions summary 127 Table 13: Turbine Building and condenser bay radiological conditions 133 summary Table 14: Outdoor Tank and Enclosure radiological conditions summary 153 Table 15: Subsurface Structures 184 Table 16: Buried Pipe 185

List of Figures Figure 1: Oyster Creek Site Vicinity 202 Figure 2: Oyster Creek Site Boundary 203 Figure 3: Geologic Cross -Section 204 Figure 4: Hydrogeologic Cross -Section 205 Figure 5: Location of Major Buildings 206 Figure 6: Location of Major Outdoor Tanks 208 Figure 7: Conceptual Site Model 209 Figure 8: Known or Suspected Subsurface and Soil Relocation Outside the 210 RCA Areas Figure 9: Intake and Discharge Canals 211

Page 7 OYSTER CREEK STATION HSA Revision 2

1. Glossary of Terms, Acronyms and Abbreviations

§ section symbol

§§ sections symbol ABHP American Board of Health Physics AC Alternating Current ACM Asbestos Containing Material ADAMS Agencywide Documents Access and Management System (NRC)

AEC Atomic Energy Commission ALARA As Low As Reasonably Achievable ALTA American Land Title Associate ANI American Nuclear Insurers AOB Auxiliary Office Building AOC Area of Concern AOG Augmented Offgas Building AREOR Annual Radiological Environmental Operating Report ARERR Annual Radioactive Effluent Release Report AST Aboveground Storage Tank bgs below ground surface BWR Boiling Water Reactor CAC Containment Atmospheric Control CAM Continuous Air Monitor CAP Corrective Action Program CB&I Chicago Bridge and Iron cfs cubic feet per second CHP Certified Health Physicist CIPP Cured in place pipe

cm2 square centimeters cpm counts per minute CRDM Control Rod Drive Mechanism CS Carbon steel CSM Conceptual Site Model

Page 8 OYSTER CREEK STATION HSA Revision 2

CST Condensate Storage Tank DAW Dry Active Waste DCGL Derived Concentration Guideline Levels dpm disintegrations per minute DQO Data Quality Objectives DW Drywell DWEDT Drywell Equipment Drain Tank D&D Decontamination and Dismantlement ECR Engineering Change Request EPRI Electric Power Research Institute FSS Final Status Survey GIS Geographic Information Systems gm gram GPI Groundwater Protection Initiative GPU General Public Utilities GTCC Greater Than Class C HDI Holtec Decommissioning International, LLC HEPA High Efficiency Particulate Air HP Health Physics hp horsepower HRA High Radiation Areas HSA Historical Site Assessment HTD Hard to Detect HWC Hydrogen Water Chemistry HWCP Hazardous Waste Contingency Plan IEB Information Enforcement Bulletin IR Issue Report ISFSI Independent Spent Fuel Storage Installation ISOCS In-Situ Object Counting System JCP&L Jersey Central Power and Light kg kilogram LER Licensee Event Report

Page 9 OYSTER CREEK STATION HSA Revision 2

LLC Limited Liability Company LLD Lower Limit of Detection LLRWSF Low Level Radwaste Storage Facility LSA Low Specific Activity LTA License Transfer Application LTP License Termination Plan m meter MAC Monitor and Change Facility MAF Main Access Facility MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MCL Maximum Contaminant Level MDA Minimum Detectable Activity MFOT Main Fuel Oil Tank MOB Main Office Building mr/hour milliroentgen per hour msl mean sea level MUX Multiplexer mg milligram mph miles per hour mrem millirem MSIV Main Steam Isolation Valves msl mean sea level MW Megawatt MWe MegaWatts electrical MWt MegaWatts thermal Nb Niobium NEI Nuclear Energy Institute NJAC New Jersey Administrative Code NJDEP New Jersey Department of Environmental Protection NJPDES New Jersey Pollutant Discharge Elimination System NOAA National Oceanic and Atmospheric Administration NORM Naturally Occurring Radioactive Materials

Page 10 OYSTER CREEK STATION HSA Revision 2

NRC Nuclear Regulatory Commission NRW New Radwaste NSPS National Society of Professional Surveyors NSSS Nuclear Steam Supply System OCA Owner Controlled Area OCAB Oyster Creek Administrative Building OCEP Oyster Creek Environmental Protection, LLC OCNGS Oyster Creek Nuclear Generating Station ODCM Offsite Dose Calculation Manual ORW Old Radwaste OSSC Onsite Storage Container PA Protected Area pCi picoCurie POL Provisional Operating License ppm parts per million RAGEMS Radiation Gas Emissions Monitoring System RAM Radioactive Material RB Reactor Building RBCCW Reactor Building Closed Cooling Water RBEDT Reactor Building Equipment Drain Tank RCA Radiological Controlled Area RCRA Resource Conservation and Recovery Act REMP Radiological Environmental Monitoring Program RGPP Radiological Groundwater Protection Program RMS Remote Monitoring System ROC Radionuclides of Concern RP Radiation Protection RSSI Radiation Survey and Site Investigation RWCU Reactor Water Clean-up SAFSTOR Safe Storage SBGT Standby Gas Treatment SEB Site Emergency Building

Page 11 OYSTER CREEK STATION HSA Revision 2

SNM Special Nuclear Material SPCC Spill Prevention, Control and Countermeasures SS Stainless Steel SSC Systems, Structures, and Components TB Turbine Building TBOF Turbine Building Operating Floor TRU Transuranic TWST Torus Water Storage Tank UFSAR Updated Final Safety Analysis Report USEPA United States Environmental Protection Agency USNRC United States Nuclear Regulatory Agency UST Underground Storage Tank UTM Universal Transverse Mercator V&V Verification and Validation WR Work Request WST Waste Surge Tank

Page 12 OYSTER CREEK STATION HSA Revision 2

2. Executive Summary

The Historical Site Assessment (HSA) documents a comprehensive assessment pertaining to events that may have led to radiological contamination during the operating history of Oyster Creek. The HSA identifies areas or Systems, Structures, and Components (SSC) where there is a potential for radiological contamination to exist. The HSA is the primary assessment used to define the current radiological condition of the site. Contamination refers to radiological contamination in the context of the HSA assessment.

The HSA consisted of a review and compilation of historical records, plant and radiological incident files, site plan drawings, operational survey records, and annual environmental reports submitted to the United States Nuclear Regulatory Commission (USNRC). Site reconnaissance and walk downs included unoccupied and seldomly accessed outlying areas. Personnel interviews with present and former employees provided valuable insight regarding changes to Site usage and configuration; and to the operational events that caused, or might have caused, contamination in areas or SSC not designed to contain radioactive materials. Historical landscape and aerial photographs revealed the visual transformation of Site condition from the time of construction to termination of operation and entry into Decontamination and Dismantlement (D&D).

All areas and SSC with recognized contamination or the potential for the same are determined to be radiologically impacted. An area or SSC is conservatively classified as radiologically impacted when there are insufficient process knowledge or data gaps to confirm a classification of non-impacted. All areas and SSC were given a preliminary classification based on available survey data, process knowledge, and results of employee interviews. The preliminary classification of an area or SSC may be revised between now and the time of Site closure or license termination when additional characterization data become available.

The HSA assessed a total of seventy -eight (78) locations of interest that included SSC, exterior tanks, open land areas, subsurface SSC, subsurface soil, and the Intake and Discharge Canals. All areas and SSC within the site boundary were classified as radiologically impacted. Figures showing the SSC and a Conceptual Site Model (CSM) showing locations of known or suspected contamination are included in the HSA. A figure showing the location of areas with known or suspected subsurface contamination and relocation of soil from the Radiological Controlled Area (RCA) are also included.

The Intake and Discharge Canals are included as a figure as well.

The completed HSA provides the necessary data and technically defensible basis for developing survey and sampling plans and delineating the Site into survey units for further and more focused characterization. The HSA is updated periodically to ensure that the Site radiological conditions are up to date and valid by incorporating the latest D&D evolutions and modifications and eliminating obsolete information.

Page 13 OYSTER CREEK STATION HSA Revision 2

3. Purpose of the Historical Site Assessment

The purpose of an HSA is to assist in planning for the decommissioning, release, and restoration of the site. The HSA classifies areas and SSC as radiologically impacted or non- impacted. An area or SSC with no reasonable potential for residual contamination in excess of natural background or fallout levels is classified as non -impacted.1 No further characterization or final survey is required for an area or SSC when operating experience, confirmatory data, and process knowledge show that an area or SSC is non- impacted since it has been demonstrated to have no plausible potential for residual contamination. An area or SSC is conservatively classified impacted when there are insufficient process knowledge or data gaps to confirm a classification of non- impacted.

The HSA is the first step in the survey planning process described by the Multi -Agency Radiation Survey and Site Investigation Manual (MARSSIM). The MARSSIM provides a standardized approach towards demonstrating compliance with the dose based criteria specified in Title 10 of the Code of Federal Regulations (CFR) Part 20 Subpart E Radiological Criteria for License Termination.

The HSA identifies potentially contaminated media and contaminants. While the MARISSIM scope focuses on surface soils and structures it does provide guidance on other media including subsurface soil, sediment, surface water, and ground water. The HSA does not include plant operating and abandoned system classification as these are likely to be released for unrestricted use and left on site or disposed of as waste. The contaminants or Radionuclides of Concern (ROC) are those that would be remaining at the time of Final Status Survey (FSS). Many radionuclides present during plant operation will not be present at FSS due to radioactive decay and lack of production.

The HSA also provides input to characterization survey and sampling design.

Characterization surveys are conducted when the HSA is completed to provide site-specific information from random and judgmental measurements based on the HSA.

The characterization survey is the most comprehensive of all the MARSSIM survey types and generates the most data.

The HSA provides the information to develop the Conceptual Site Model (CSM). The CSM is a site diagram showing locations of known or suspected Area of Concern (AOC) based on contamination or suspected contamination. The CSM includes the types and concentrations of radionuclides when known, and locations of potential background reference areas. Background reference areas are discussed in Section 7.2.2. The CSM should include the general layout of the Site including structures and property boundaries. The CSM will be modified as information becomes available during D&D.

1 §50.2 Definitions

Page 14 OYSTER CREEK STATION HSA Revision 2 The HSA will be useful when developing the open- air demolition plan. Open- air demolition contamination controls are driven by contact dose rates and removable contamination. The controls are implemented during the demolition of structures to mitigate the spread and release of radiological contamination to the environs. The HSA will provide a basis for determining the type of survey(s) a structure would require prior to demolition. The two types of survey are unrestricted release and additional characterization to fully recognize the radiological condition.

Finally, the HSA provides crucial input to the development of the License Termination Plan (LTP), specifically Chapter 2 Site Characterization. The regulations in

§50.82(a)(9)(ii) require that the LTP include site characterization. The USNRC staff has observed that some submitted LTP have been submitted with incomplete or inadequate characterization of radiological conditions making it difficult to agree with the rationale justifying the proposed classification of an area or SSC.

Page 15 OYSTER CREEK STATION HSA Revision 2

4. Property Identification

4.1. Physical Characteristics

4.1.1. Name

Oyster Creek Generating Station

USNRC License Number DPR-16 Docket Numbers 50- 219 and 72- 15 Decommissioning Operator HOLTEC Decommissioning International, LLC Owner Oyster Creek Environmental Protection, LLC

Facility Single cycle, forced circulation, boiling light-water reactor and electrical generating equipment

Nuclear Steam Supply NSSS Supplier: General Electric Company Systems (NSSS) Supplier Turbine- Generator Supplier General Electric Company Architect-Engineer Burns & Roe, Inc.

Constructor Burns & Roe, Inc.; J. A. Jones Construction Co.

Reactor Design General Electric (GE) Boiling Water Reactor (BWR)-2 Containment GE Mark I Turbine- Generator: GE Type N -1 Turbine- Generator 1800 Revolutions per Minute (RPM),

Tandem Compound 4.1.2. Location

Oyster Creek Nuclear Generating Station (OCNGS) 741 Route 9 South Forked River, New Jersey 08731

OCNGS is a non-operational single unit nuclear power plant on approximately a 152 acre parcel located within Lacey and Ocean Townships, in Ocean County, New Jersey.

OCNGS is approximately two miles inland from the shore of Barnegat Bay and nine miles south of Toms River, New Jersey (Figure 1). The site is further identified by an intake canal flowing in from Barnegat Bay along the northern portion of OCNGS and a discharge canal flowing from the southern portion of OCNGS out to Barnegat Bay (Figure 2).

Page 16 OYSTER CREEK STATION HSA Revision 2 4.1.3. Topography

Topography in the region is relatively level landscapes associated with the coastal plains. Site elevation ranges from approximately 0 to 15 feet above mean sea level (msl) immediately adjacent to the Intake and Discharge Canals to slightly more than 30 feet msl in the northwest portion of the station property. The ground surface features are comparatively flat except for the man- made steep slopes at areas adjacent to the Intake and Discharge Canals.

The sites drainage characteristics are dominated by typical pine barren surface features consisting of grasses, low shrubs, and small to medium-sized pines atop sandy glacial deposits. Surface drainage at the site generally flows from the high point in the center of the site toward the Intake Canal to the north and west; the Discharge Canal to the south and west; and Route 9 to the east. OCNGS is bounded on the north by the South Branch of the Forked River and to the south by the Oyster Creek. The Oyster Creek is dammed upstream of the Discharge Canal, creating an impoundment that serves as a source of surface water for fire protection.

4.1.4. Stratigraphy

OCNGS lies on the New Jersey Coastal Plain Physiographic Province which is underlain by a layer of unconsolidated sediments ranging from Cretaceous to recent in age. The thickness of the Coastal Plain sediments varies from a fine edge to as much as 3,500 feet at the edge of the continental shelf.

The regional stratigraphy includes beds of sand, gravel, clay, and marl dipping gently to the southeast. These coastal plain deposits are overlain by more recent sands and gravels. The major stratigraphic units in the Oyster Creek region are: 1) fill, 2) Cape May (Pleistocene), 3) Cohansey (Miocene), and 4) Kirkwood (Miocene) formations. The strike of the formation bedding is generally in a northeast direction with a dip to the southeast. A cross- section showing the regional geology in the vicinity of the region is shown by Figure 3.

4.2. Environmental Setting

4.2.1. Geology

The Cape May Formation is the youngest formation in the Oyster Creek region. Its average thickness is 40 feet and it is comprised of a light gray to tan, medium to fine sand, trace silt, coarse sand. It is poorly compacted and commonly contains thin, shallow black clay beds in coastal areas.

The Cohansey Formation lies beneath the Cape May Formation. Its average thickness is 60 feet and it is primarily composed of a red- brown and tan, medium to fine sand, trace silt, coarse sand, and some coarse to fine gravel. Lenticular beds of clay are also sometimes found, and the lower portions of the unit are densely compacted.

Page 17 OYSTER CREEK STATION HSA Revision 2 The Kirkwood Formation lies beneath the Cohansey. It consists of a light gray to yellow- brown micaceous and lignitic very fine to fine grained quartz sand and coarse to fine gravel. The Cohansey formation is densely compacted and extends from a depth of about 100 feet to at least 250 feet below the surface.

The fill material at the site area is a medium to fine grained sand with trace to some silt.

The density is typically less than that of the Cape May Formation. Based on the historic descriptions, a substantial portion of the fill material appears to consist of Cape May Formation deposits relocated during site construction activities. The fill thickness ranges from 5 to 10 feet; however, the maximum fill thickness is estimated to be approximately 50 to 55 feet in the immediate area of the Reactor Building.

4.2.2. Hydrogeology

The site hydrogeology consists of a water table aquifer extending from approximately 12 to 100 feet beneath the OCNGS property. This unconfined aquifer comprises the Cape May Formation and the underlying Cohansey Formation. These formations are separated by a 5-10 foot thick upper clay. The underlying Kirkwood Formation, which is a locally confined aquifer, extends to an estimated depth of 500 feet. The lower clay separates the Cohansey and Kirkwood Formations.

Plant construction is believed to have affected the ground water flow regime at the site due to excavation and recontouring of the grounds surface. Excavation at the Intake and Discharge Canals and some site structures is presumed to have penetrated the upper clay layer of the Cohansey. Therefore, the Cape May Formation and the Cohansey Formation are hydraulically connected in these areas and the flow direction in the Cohansey Formation is toward the canals rather than the general eastward regional direction.

The sites hydrogeology has also been influenced by both shallow and deep ground water pumping wells as well as the circulating water pumps, service water pumps, and dilution water pumps in the canal. Possible removal of sections of the upper clay layer and overlying strata during plant construction may have resulted in altered gradients around the deeper foundations and a possible decrease in water table levels across portions the site.

The station ground water monitoring wells monitor the water table in the: 1) Cape May Formation, 2) Cohansey Formation in the upper, intermediate, and deep intervals of the water table aquifer, and 3) the confined Kirkwood Formation.

The Cape May Formation groundwater flow is generally from east to west across the horseshoe portion of the OCNGS property toward the Intake and Discharge Canals.

However, groundwater contours indicate localized variations including a hydraulic low beneath the Turbine Building and northerly and southerly flow components adjacent to the Intake and Discharge Canals away from the west end of the horseshoe. Due to these variations, the calculated horizontal hydraulic gradient in the Cape May Formation

Page 18 OYSTER CREEK STATION HSA Revision 2 between the eastern portion of the station and the Intake and Discharge Canals along the western portion of the station ranges from approximately 0.01 to 0.04 feet/foot, which is typical of a well- sorted sand/gravel. Assuming an average effective porosity of 0.25 and using the calculated horizontal gradients, the average linear groundwater flow velocity in the Cape May Formation ranges from approximately 300 feet/year in the central portion of the OCNGS to 1800 feet/year in the area adjacent to the Intake Canal.

Based upon historic hydrogeologic investigations, there is a downward vertical hydraulic gradient between the shallow Cape May Formation and the Cohansey Formation. The vertical gradient does not exist in areas where the upper clay layer is absent (i.e. in the Protected Area and in the area of the canal).

Groundwater flow in the shallow portion of the Cohansey Formation is divergent (radial flow) from a hydraulic high just south of the Reactor Building. Groundwater flow to the north, west, and south is toward the canals. These flow patterns indicate that, within the footprint of the station, the flow of ground water is primarily influenced by the Intake and Discharge Canals, which are receiving ground water from the Cohansey Formation.

The horizontal hydraulic gradient in the Cohansey Formation beneath the station is direction dependent due to the radial flow pattern. The calculated horizontal gradient is steepest in the shallow Cohansey (0.005 feet/foot) from the apparent hydraulic high in the southeastern portion of the station to the south toward the Discharge Canal.

Calculated horizontal gradients are less steep moving away from the hydraulic high to the west (0.001 feet/foot) and to the northwest (0.003 feet/foot). Assuming an average effective porosity of 0.25 and using the calculated horizontal gradients, the average linear groundwater flow velocity in the Cohansey Formation ranges from approximately 100 feet/year in the central portion of the station to 550 feet/year adjacent to the Intake Canal. Between the shallow/intermediate Cohansey Formation and the Kirkwood Formation, there is an upward vertical hydraulic gradient.

Groundwater flow in the Kirkwood Formation is easterly toward Barnegat Bay and the Atlantic Ocean, which is consistent with the regional groundwater flow direction. The calculated horizontal hydraulic gradient in the Kirkwood Formation between the JCP&L property to across US Route 9 from the station is 0.003 feet/foot. The Kirkwood aquifer is under confined conditions at and near the OCNGS.

Groundwater flow in the Cape May and Cohansey Formations at the site is primarily controlled by the Intake and Discharge Canals, which are the discharge areas for groundwater within these two formations. In addition, the groundwater flow is also influenced by historical excavation activities during OCNGS construction and subsequent construction of subsurface foundations associated with the Reactor Building, the Turbine Building, and the Intake and Discharge Tunnels. The high potentiometric elevations observed in the Kirkwood wells along with the presence of sandy seams and lenses suggests the presence of an upward gradient between the Kirkwood to the Cohansey and the potential for leakage between the two formations.

Figure 4 depicts a hydrogeologic profile of the site.

Page 19 OYSTER CREEK STATION HSA Revision 2 4.2.3. Hydrology

Surface water bodies in the vicinity of the site consist of the South Branch Forked River, Oyster Creek, the Intake and Discharge Canals, and the Barnegat Bay. The South Branch and Oyster Creek are fresh water sources from upland Pineland areas, whereas the Intake and Discharge Canals are saline due to their hydraulic connection to the Barnegat Bay and Atlantic Ocean. Vernal ponds also exist in some of the remaining wooded areas to the west, south, and east of the site.

Surface water in the area is widely used for recreation, commercial fishing, and to a lesser extent, for shipping and irrigation. Saltwater fishing, crabbing, boating, and swimming are popular pastimes associated with Barnegat Bay and the Atlantic Ocean.

Nearby freshwater lakes and streams are also used for recreational activities. Some shipping occurs in the Intracoastal Waterway, which runs through Barnegat Bay. The Bay also supports limited commercial fisheries.

Historically, ground water is and has been used for irrigation within the area of the site.

According to the Ocean County Planning Department, less than 3% of land in the entire county was categorized as agricultural as of 1998.

With few exceptions, potable water in the vicinity of the site is provided by municipal water systems in Lacey and Ocean Townships. The Ocean Township Municipal Water System utilizes wells screened in the Cohansey and Kirkwood Aquifers (well depths range from 150- 350 feet). Lacey Townships water is drawn from the Kirkwood-Cohansey, Atlantic City 800- Foot Sand and Potomac -Raritan-Magothy Aquifers..

4.2.4. Meteorology

The OCNGS site is located along the eastern coast of south- central New Jersey where the climate is described as a zone of transition between continental and coastal influences. The regional climate is influenced to some degree by continental air masses however, the influence of the Atlantic Ocean can be seen throughout the year, especially during the spring, summer and early fall seasons.

The region is dominated by a sub- tropical high- pressure system during the spring, summer and early fall which typically present warm and humid conditions. Differential heating of the land and water during these seasons can cause the formation of a thermally induced wind flow from the east and south known as a sea breeze. Most air masses during the fall through early spring seasons when the jet stream shifts to the south are of continental origin, characterized by cool and dry air..

Generally, the area is characterized by stable atmospheric conditions. Maximum wind speeds in the vicinity of the OCNGS typically occur in March and April; and minimum wind velocities are observed in August. During winter there is a predominance of winds from the northwest and during summer, the prevailing winds are from the southwest.

The sea breeze phenomenon results in onshore circulation during late morning through early afternoon.

Page 20 OYSTER CREEK STATION HSA Revision 2 July is the warmest month of the year at OCNGS, averaging in the mid- seventies (Fahrenheit) and January is the coldest month with temperatures averaging in the low thirties (Fahrenheit).

The area surrounding the OCNGS receives an annual average of approximately 39 inches of precipitation. The highest monthly average precipitation typically occurs in August while November is typically the driest.

Local meteorological conditions have been routinely monitored throughout the operational history of the OCNGS via the onsite 400 foot meteorological tower.

Page 21 OYSTER CREEK STATION HSA Revision 2

5. Historical Site Assessment

5.1. Approach and Rationale

The HSA is the first step in the investigative process described by the MARSSIM. The HSA consisted of a review and compilation of historical records, operational and radiological incident files (§50.75(g)(1)), operational survey records, and annual environmental reports to the USNRC. 2 Radiological data was evaluated using the Data Quality Assessment (DQA) process whenever possible. 3

Evaluation of site configuration changes over time was performed using photo documentation (aerial, construction, and Google Earth Pro) and an early 2000s three-dimensional scale model site plan of permanent structures. Site reconnaissance was performed as time and weather conditions permitted.

Personnel interviews were conducted to obtain information regarding operational events that caused contamination in areas or systems not designed to contain radioactive materials; and major renovations or modifications to the site that relocated actual or potentially contaminated soil, capped contaminated areas, or changed RCA boundaries.

A decision-making tool called the Data Quality Objective (DQO) process is an essential part of good survey planning. 4 The experience of previous decommissioning projects demonstrates that the DQO process strengthens the survey planning process by improving efficiency, promoting defensibility of data, and saving resources. The MARSSIM consistently encourages the use of the DQO process as a practical and systematic approach to designing and conducting surveys. While the HSA is not a survey as such, it is an integral part of survey planning by providing as much background information as possible to design and implement efficient and effective survey plans. Three DQO products for the HSA are described in the following sections.

5.1.1. Identify Planning Team Members including the Decision Maker

The planning team for this revision was comprised of four individuals with diverse experience in the field of nuclear power and decommissioning. The principal investigator is certified by the American Board of Health Physics (ABHP) and has an extensive decommissioning and MARSSIM background. The first reviewer is a professional geologist with an extensive site assessment background. The second reviewer is the Project Manager. The approver and primary decision maker is the Manager Site Radiation Protection and Chemistry.

2 §50.75 Reporting and recordkeeping for decommissioning planning 3 MARSSIM 8.2 Data Quality Assessment (DQA) is a scientific and statistical evaluation that determines if the data are of the right type, quality, and quantity to support their intended use.

4 MARSSIM 2.3.1 The DQO Process provides systematic procedures for defining the criteria that the survey design should satisfy, including what type of measurements to perform, when and where to performmeasurements, the level of decision errors for the survey, and how many measurements to perform.

Page 22 OYSTER CREEK STATION HSA Revision 2 Other stakeholders include the USNRC, State of New Jersey Department of Environmental Protection (NJDEP) Bureau of Environmental Radiation (BER), and local communities surrounding the OCNGS.

5.1.2. State the Problem

A comprehensive assessment of operating history and events is needed to define the nature and extent of radiological conditions at the site to support the decision that areas and SSC have or have not been radiologically impacted at the site.

5.1.3. Classify the site as Impacted or Non-Impacted

Areas and SSC are classified as radiologically impacted or non- impacted based on the results of the HSA. Non-impacted areas and SSC in MARSSIM terminology have no reasonable potential for residual contamination and require no further evidence such as survey and sampling to demonstrate compliance with the release criterion. Impacted areas and SSC would be subject to further evaluation and survey and sampling based on the quantity and extent of residual contamination.

The initial assumption is that none of the necessary information is available resulting in an initial classification as impacted. Gaps or low confidence in necessary information would result in an initial classification as impacted. In fact, the MARSSIM working hypothesis is that all impacted areas being evaluated for release have a potential for radioactive contamination above the release criteria.

Areas and SSC determined to be impacted were further classified using the Radiation Survey and Site Investigation (RSSI) process as Class 1, Class 2, or Class 3 based on the quantity and extent of contamination. The classifications were determined in accordance with guidance provided in the MARSSIM and reflect professional judgement based upon the information available for the preliminary decision. The MARSSIM uses these classifications as a graded approach to characterization and final release by requiring larger survey effort for areas and SSC with higher potential for contamination and remediation.

Class 1 areas and SSC have the highest potential for contamination and remediation and therefore require more investigation and effort than Class 2 or Class 3 areas and SSC. The underlying premise of the MARSSIM is to consider all areas and SSC as Class 1 areas unless some basis for reclassification is present in a technically defensible manner. The DQO process allows for re- evaluation of the preliminary classification as new data becomes available.

Class 1 areas and SSC have, or had prior to remediation, a potential for radioactive contamination at concentrations greater than the site release criteria based on site operating history or known contamination based on previous radiation surveys.

Class 2 areas and SSC have, or had prior to remediation, a potential for radioactive contamination at concentrations expected to be less than the site release criteria based on site operating history or known contamination based on previous radiation surveys.

Page 23 OYSTER CREEK STATION HSA Revision 2 Class 3 areas and SSC are expected to have residual radioactivity at a small fraction of the site release criteria based on site operating history or known contamination based on previous radiation surveys.

The MARSSIM does not provide the radiological quantities needed to classify impacted areas and SSC. To do this, decommissioning sites have the option of using: 1) accepted screening values for building surface and surface soil contamination, 2) site specific values known as Derived Concentration Guideline Values (DCGL) for building surface and surface soil contamination. The second option would require special modelling and acceptance by regulatory stakeholders such as the USNRC.

To justify changing the default classification from Class 1 to Class 2 would require measurement data that provides a high degree of confidence that no individual measurement would exceed the building surface or surface soil contamination values.

A Class 3 designation would require measurement data and a high degree of confidence that any residual radioactivity be a small fraction of the building surface or surface soil contamination values.

5.2. Boundaries of the site

The Oyster Creek Site is approximately 152 acres located west of U.S. Highway Route 9 between the south branch of the Forked River and the Oyster Creek. 5 Most of the Site is identified as Block 100, Lot 4.02 in Lacey Township according to a 2018 American Land Title Association (ALTA)/National Society of Professional Surveyors (NSPS) land title survey . 6 The site includes a small land area south of the Discharge Canal identified as Block 4, Lot 43 in Ocean Township. A perimeter security fence surrounds the protected area of the site. A reference coordinate system identified alphabetically on one axis and numerically on the other axis is used with most figures to facilitate identification of legend locations.

5.3. Documents Reviewed

The following list summarizes most of the sources of data and information used to develop this HSA:

• Control Points Associates, Inc. Preliminary ALTA/NSPS Land Title Survey Oyster Creek Powerplant

• Critique Action Item C90019.1 Review OC Systems per IE Notice 80-10, 1990

• CY-AA- 170- 301 Offsite Dose Calculation Manual for Oyster Creek Generating Station, revision 9

• DPP-4 Site Characterization Plan

• G01-1275- 002 Site Characterization Plan for the Oyster Creek Nuclear Generating Station, TLG Services, 1998

5 OCNGS Decommissioning Safety Analysis Report (DSAR) 2.1.1 6 Control Points Associates, Inc. Preliminary ALTA/NSPS Land Title Survey Oyster Creek Powerplant

Page 24 OYSTER CREEK STATION HSA Revision 2

• GPU memorandum Request to Relocate Slightly Contaminated Soil, 1985

• Hydrogeologic Investigation Report, Conestoga- Rovers and Associates, 2006

• Hydrogeologic Investigation Report, GDH (formally Conestoga- Rovers and Associates), 2017

• OC 008 Oyster Creek Site Specific 137Cs Study

• OCNGS Site Characterization Plan, 1999

• Oyster Creek Annual Radioactive Effluent Release Report, 2018

• Oyster Creek Decommissioning Database

• Oyster Creek Decommissioning Dose Estimate 990-2783, 1998

• Oyster Creek Generating Station List Required by RP-AA- 228

• Oyster Creek Generating Station Unit 1 Annual Radiological Environmental Operating Report, 2018

• Oyster Creek Generating Station Unit 1 Annual Radiological Groundwater Protection Program Report, 2018

• Preliminary Assessment/Site Investigation Report - Radiological Volumes 1 and 2, Site Remediation Program Case Number E99575, McLaren/Hart, 2000

• Procedure RP-AA- 228 10 CFR 50.75(g) and 10 CFR 72.30(f) Documentation Requirements, revision 3

• Radiation Protection Calculation and Position Paper: 2018 - Alpha Characterization Defuel Outage 1D27

• Radiation Protection Calculation and Position Paper: Analysis of Category 1 and Category 2 Radioactive Material, 2017

• RGPP Five-Year Internal Assessment, 2018

• Safety Evaluation 402533- 001 Safety Evaluation Report in Support of an Onsite Low-Level Radioactive Waste Storage Facility at Oyster Creek Nuclear Generating Station, revision 5

• Site Plan Drawing JC 19702, various revisions

• Site Plan Drawing TWU9-84, revision 2

• Spill Prevention, Control, and Countermeasure (SPCC) Plan & Hazardous Waste Contingency Plan (HWCP), 2017

• Topical Report 116 Oyster Creek Underground Piping Program Description and Status, revision 8

• Transmittal of Radiological Environmental Data Concerning Surge Tank Soil Samples, 1982

• USNRC Evaluation of the Radiological/Environmental Impact of GPU Nuclears Proposed Project for Disposal of Contaminated Soil on Oyster Creek Property, 1982

Page 25 OYSTER CREEK STATION HSA Revision 2 5.4. Property Inspections

Site reconnaissance was conducted during the months of August through and including January 2020. Land area reconnaissance focused on infrequently accessed open areas potentially impacted by radioactive materials, particularly relocated soils, and spoils during operation. The site Remote Monitoring System (RMS), pictures, and videos were used to supplement the walk downs in the Radiological Controlled Area (RCA) to reduce radiation dose.

Physical tours of the following structures were conducted:

• Auxiliary Office Building (AOB)

• Augmented Offgas (AOG) Building

• Boiler Houses

• Breathing Air Compressor Building

• Building 3 Old Machine Shop

• Building 4 Site Storage Building

• Chlorination Building

• Clean Rigging and Storage Trailers

• Condensate Transfer Pump House

• Contractor Trailer Complex

• Drywell Processing Center

• Firewater Pump House

• Hazard Collection

• Hot Machine Shop

• Hot Tool Room

• Intake and Discharge Structures

• Independent Spent Fuel Storage Installation (ISFSI)

• Level D Building

• Low Level Radwaste Storage Facility (LLRWSF)

• Monitor and Change (MAC) Facility

• Main Access Facility (MAF)

• Main Gate Security Center

• Main Office Building (MOB)

• New Sampling Building

• New Radwaste (NRW) Building

• NRW Heat Exchanger Building

• Oyster Creek Administrative Building (OCAB)

• Old Radwaste (ORW) Control Room

• ORW Compactor

Page 26 OYSTER CREEK STATION HSA Revision 2

• ORW High Efficiency Particulate Air (HEPA) Room

• Overboard Radiation Monitor Room

• Pretreatment Building

• RCA Onsite Storage Container (OSSC)

• Service Water Monitor Building

• RCA general yard area

• Reactor Building

• Respirator Facility

• Scaffold Building

• Site Emergency Building (SEB)

• Service Water Monitor Shack

• Stack and Base of Stack

• Stack Radiation Gas Emissions Monitoring System (RAGEMS)

• Turbine Building

• Turbine Generator Services Trailer

• Turbine RAGEMS

• Warehouse

Physical tours of the following storage tank areas were conducted:

• Condensate Storage Tank (CST)

• Dirty Oil Tank

• Demineralizer Water Storage Tank (DWST)

• Liquid Nitrogen Tank

• Main Fuel Oil Tank (MFOT)

• New Demineralizer Water Tank

• ORW Surge Tank

• Outdoor Tank and Enclosure

• Redundant Firewater Tank

• Sodium Hypochlorite Tanks

• Torus Water Storage Tank (TWST)

Page 27 OYSTER CREEK STATION HSA Revision 2 Physical tours of the following land areas were conducted:

• East Protected Area (PA) Non-RCA

• East Wooded Area

• Main Parking Lot

• North PA Non-RCA

• North Parking Lot

• Northeast Parking Lot

• North Wooded Area

• RCA Yard

• South PA Non-RCA

• South Parking Lot

• South Wooded Area

• West PA Non-RCA

Physical tours of the Intake and Discharge Canals were conducted.

5.5. Personal Interviews

Interviews were conducted with long-tenured site personnel from various disciplines in 1999 when OCNGS owners were considering permanent shutdown and decommissioning. A questionnaire was solicited for voluntary response regarding information related to work responsibilities and their recollection of historical contamination events that may have significance during plant decommissioning.

Personnel recollections and/or anecdotal information was maintained in a database, which was retained when OCNGS was sold and remained operational. The database was used during the development of the HSA.

Station employees, especially retirees with a radiological background and solid institutional knowledge of operation and events of the time were consulted during the preparation of this HSA. These individuals provided valuable and necessary information relating to events where data gaps existed and where documents were not as complete as required by §50.75(g)(1). Questions based on previous interview responses and recent fact finding were generally more specific about certain events.

Page 28 OYSTER CREEK STATION HSA Revision 2

6. History and Current Usage

6.1. History

The Oyster Creek Station was a single unit boiling water reactor utilized for the generation and transmission of electric power using nuclear fission as the source of production. A second unit was anticipated but not completed, although the site does include a Unit 2 Discharge Structure. The Station was refueled 26 times during operation spanning a period of almost a half century. Oyster Creek Station was the oldest U.S. BWR at the time of permanent shutdown and defueling in 2018.

A brief history of the major milestones related to Oyster Creek Station construction, operational history, and ownership is as follows:

Application for a Construction Permit was filed with the March 26, 1964 Atomic Energy Commission (AEC)

Construction Permit was issued by the AEC to Jersey Central Power and Light (JCP&L) December 15, 1964 License Number DPR- 16 was issued by the AEC permitting reactor operation up to 5 MegaWatts thermal (MWt) Apri1 9, 1969 Fuel loading completed April 28, 1969 Initial criticality with the reactor head off the vessel was attained at 20:17. May 3, 1969 Reactor vessel head was installed June 19, 1969 License was amended to authorize reactor operation at a power level of 1600 MWt August 1, 1969 Turbine- generator was synchronized to the transmission September 23, 1969 system for the first time Full power achieved December 7, l969 One-hundred- hour full power demonstration December 22, 1969 Began commercial operation at 530 MegaWatts electric (MWe) net December 23, 1969 Began commercial operation at 620 MWe December 11, 1971 General Public Utilities Nuclear (GPUN) assumed responsibility for operations 1980 Full Term Operating License Issued July 2, 1991 July 2, 1991 USNRC approves transfer of license to AmerGen June 6, 1999 USNRC approves transfer of license to Exelon December 23, 2008

Page 29 OYSTER CREEK STATION HSA Revision 2 6.2. Current Usage

The Oyster Creek Station has been shutdown and permanently defueled for over a year at the time of this HSA. The Title 10 CFR Part 50 license no longer authorizes the operation of the reactor or emplacement or retention of fuel in the reactor vessel.

The decommissioning has transitioned from Safe Storage (SAFSTOR) to prompt D&D following the revised Post-Shutdown Decommissioning Activities Report (PSDAR) and transition of the License to Oyster Creek Environmental Protection (OCEP) and Holtec Decommissioning International (HDI). Prompt D&D has begun on Reactor Building (RB) 119 foot elevation with large component removal (e.g., shield blocks, mirror insulation, Drywell and Reactor heads) followed by reactor internal and vessel segmentation.

A brief synopsis of the major milestones related to Oyster Creek Station current usage and future is as follows:

Exelon notified the USNRC that the Station would permanently January 7, 2011 cease power operations by December 31, 2019 Exelon notified the USNRC intent to retire the Station no later than October 31, 2018 February 14, 2018 Exelon submits PSDAR pursuant to §50.82(a)(4)(i) choosing SAFSTOR decommissioning option May 21, 2018 Exelon and Holtec submit a License Transfer Application (LTA) requesting USNRC consent to transfer the Oyster Creek August 31, 2018 renewed facility operating license and the ISFSI general license to OCEP and HDI Oyster Creek Station permanently shutdown September 17, 2018 Defuel outage 1D27 commence September 17, 2018 Defuel outage 1D27 complete September 25, 2018 Exelon certifies that fuel is permanently removed from the September 25, 2018 reactor vessel in accordance with §50.82(a)(2)

Holtec submits revised PSDAR pursuant to §50.82(a)(4)(i) September 28, 2018 choosing prompt DECOM decommissioning option USNRC approves license transfer to OCEP and HDI June 20, 2019 OCEP and HDI assumes ownership of Oyster Creek Station July 1, 2019

Page 30 OYSTER CREEK STATION HSA Revision 2 6.3. Adjacent Land Usage

Land use in the area consists of mixed residential, commercial, and undeveloped property. Immediately to the west across the Intake Canal is the Maxim Power Corps Forked River Power Plant, a combustion turbine facility formerly owned by JCP&L/First Energy. An undeveloped 637 acre parcel of wooded land is located immediately to the east of OCNGS and is referred to as the former Finninger Farm Property. Further west of the facility is undeveloped land and the Garden State Parkway.

No historic properties including prehistoric and historic archaeological sites, above-ground historic structures or traditional cultural properties eligible for listing or listed on the National Register of Historic Places (NRHP) are found within the Oyster Creek Station operational area. Review of state files in response to the AEC inquiries in 1973 and 1974 found no record of cultural, historical, or archaeological resources that might be affected by plant construction.

Page 31 OYSTER CREEK STATION HSA Revision 2

7. Findings

Seventy-eight (78) locations of interest on the site have been evaluated for the potential of radiological impact. The locations of interest are subdivided into SSC (47), exterior tanks (11), open land areas (12), subsurface SSC (1), subsurface soil (5), and the Intake and Discharge Canals (2). All areas of interest have been determined to be radiologically impacted. The areas have been initially classified as either MARSSIM Class 1 (27 total), Class 2 (14 total), Class 3 (20 total), and composite MARSSIM Class (3 total) when the MARSSIM classification applied (i.e., SSC, exterior tanks, and open land areas). Some SSC described by revision 1 of the HSA are no longer physically intact or present at the Site. Descriptions of release and disposition are provided in subsequent modules of this Section.

7.1. Potential Contaminants

The potential contaminants are those radionuclides expected to remain and be detected at the time of license termination. The RP calculation and position paper documenting the 2020- 2021 waste stream characterization was the basis for initially generating the list of potential contaminants for the HSA. The list includes the fraction of the radionuclide remaining over time, which is an important consideration during survey planning since some radionuclides currently identified may not be present in significant concentrations at the time of characterization or final survey. Refer to Table 1.

Radionuclides were added to generate a complete list based on previous decommissioning data and disposal requirements. The radionuclides europium -152, europium-154, and europium-155 are expected to be present in activated concrete; and analysis for technetium -99, iodine- 129, and cerium -144 is required for low -level radioactive waste intended for disposal at licensed land disposal facilities and manifests. The list displays the radionuclides categorized into groups for the purposes of this HSA. Refer to Table 2.

Included with the complete list are USNRC default screening values used to demonstrate compliance with unrestricted release. The screening values for soil and buildings are from NUREG -1757 Volume 1 Appendix B. There may not be soil or building screening values for some radionuclides.

The radionuclides listed in Table 2 should be requested when analyzing samples for offsite analysis. The screening soil levels may be used to establish required Minimum Detectable Concentration (MDC) for the requested radionuclides. Radioactive decay should be considered during future D&D planning to eliminate those radionuclides that would have decayed to negligible quantities. Site specific DCGL should be considered in the future.

Page 32 OYSTER CREEK STATION HSA Revision 2

Table 1: 2020-2021 Waste stream list of positively identified radionuclides. The sample media was filter sludge, which is conservative. Radionuclides with a fraction remaining that is less than 1E-06 (i.e., 1 x 10-6) can be considered negligible.

Radionuclide Half-life Fraction Remaining After (years)Note 1 2 years 5 years 10 years 50 years

tritium 1.23E+01 8.94E-01 7.55E-01 5.70E-01 6.00E-02 carbon- 14 5.72E+03 1.00E+00 9.99E-01 9.99E-01 9.94E-01 manganese- 54 8.54E-01 1.97E-01 1.73E-02 2.99E-04 2.37E-18 iron-55 2.75E+00 6.04E-01 2.84E-01 8.04E-02 3.36E-06 cobalt-58 1.94E-01 7.88E-04 1.74E-08 3.04E-16 2.60E-78 cobalt-60 5.27E+00 7.69E-01 5.18E-01 2.68E-01 1.39E-03 nickel-59 7.60E+04 1.00E+00 1.00E+00 1.00E+00 1.00E+00 nickel-63 1.01E+02 9.86E-01 9.66E-01 9.34E-01 7.10E-01 zinc-65 6.68E-01 1.26E-01 5.58E-03 3.12E-05 2.94E-23 strontium-90 2.88E+01 9.53E-01 8.87E-01 7.86E-01 3.00E-01 cesium-137 3.01E+01 9.55E-01 8.91E-01 7.94E-01 3.16E-01 plutonium-238Note 2 8.77E+01 9.84E-01 9.61E-01 9.24E-01 6.74E-01 plutonium-239 2.41E+04 1.00E+00 1.00E+00 1.00E+00 9.99E-01 plutonium-240Note 2 6.56E+03 1.00E+00 9.99E-01 9.99E-01 9.95E-01 plutonium-241 1.43E+01 9.08E-01 7.85E-01 6.16E-01 8.86E-02 americium-241Note 2 4.33E+02 9.97E-01 9.92E-01 9.84E-01 9.23E-01 curium-242 4.46E-01 4.47E-02 4.22E-04 1.78E-07 1.79E-34 curium-243 2.91E+01 9.53E-01 8.88E-01 7.88E-01 3.04E-01 curium-244 1.81E+01 9.26E-01 8.26E-01 6.82E-01 1.47E-01

Note 1 Adapted from Chart of the Nuclides, Seventeenth Edition Note 2 The fraction of these radionuclides remaining is higher due to ingrowth from the radioactive decay of other transuranic radionuclides (e.g., plutonium- 241 radioactive decay feeds americium- 241)

Page 33 OYSTER CREEK STATION HSA Revision 2

Table 2 - HSA complete list. List based on current waste stream, waste stream classification process, previous decommissioning data, and disposal requirements.

Default screening levels for soil and buildings were included for convenience.

BuildingNote 2 Radionuclide GroupNote 1 SoilNote 2 (pCi/g) (dpm/100cm2) Source

tritium HTD 1.10E+02 1.20E+08 2020 Dry Active Waste (DAW) and Appendix G to 10 CFR 20 carbon- 14 HTD 1.20E+01 3.70E+06 2020 DAW and Appendix G to 10 CFR 20 manganese- 54 ETD 1.50E+01 3.20E+04 2020 DAW iron-55 HTD 1.00E+04 4.50E+06 2020 DAW cobalt-58 ETD 2020 DAW cobalt -60 ETD 3.80E+00 7.10E+03 2020 DAW nickel -59 HTD 5.50E+03 2020 DAW

nickel -63 HTD 2.10E+03 1.80E+06 2020 DAW zinc -65 ETD 2020 DAW strontium -90 HTD 1.70E+00 8.70E+03 2020 DAW technetium -99 HTD 1.90E+01 1.30E+06 Appendix G to 10 CFR 20 iodine- 129 HTD 5.00E -01 3.50E+04 Appendix G to 10 CFR 20 cesium -137 ETD 1.10E+01 2.80E+04 2020 DAW cerium -144 HTD WMG 102- NP -A europium -152 ETD 8.70E+00 EPRI 3002010610 europium -154 ETD 8.00E+00 EPRI 3002010610 europium -155 ETD EPRI 3002010610 plutonium -238 HTD 2.50E+00 2020 DAW plutonium -239 HTD 2.30E+00 2020 DAW plutonium -240 HTD 2020 DAW plutonium -241 HTD 7.20E+01 2020 DAW americium -241 HTD 2.10E+00 2020 DAW curium -242 HTD 1.60E+02 2020 DAW curium -243 HTD 3.20E+00 2020 DAW curium -244 HTD 2020 DAW

Note 1 HTD - Hard to Detect; ETD - Easy to Detect Note 2 Screening values for soil and buildings are from NUREG -1757 Volume 1 Appendix B

Page 34 OYSTER CREEK STATION HSA Revision 2 Another very important consideration is alpha level classification. Alpha emitting TRU can result in significant dose to workers when not properly identified and controlled.

Alpha emitting Transuranic (TRU) is more difficult to detect following extended shutdowns due to the decay of the shorter lived easier to detect fission and corrosion and wear products. Oyster Creek will have been in extended shutdown, more than two years, when open air demolition is scheduled to begin. As a result, more samples will require analysis for alpha than the minimum required for routine surveys specified by procedure NISP-RP-002.

Table 3: Alpha level characterization as defined by RP-AA- 302. Ranking is from lowest risk to high risk radiologically.

Characterization Risk Level Internal RiskNote 1 level 1 minimal <10%

level 2 significant >10%

level 3 elevated >90%

Note 1 Percentage of total internal dose from inhalation

Table 4: Current alpha classification of areas at the site.

Characterization Number of Areas Percentage level 1 32 38%

level 2 42 57%

level 3 4 5%

Some systems and components do not have data available, or the SSC needs evaluation. Some systems are abandoned in place allowing beta-gamma radionuclides to decay at significantly higher rates compared to alpha radionuclides, which has proportionately decreased the beta- gamma to alpha activity ratio. These SSC will be considered as alpha level 2 until surveys prove otherwise; results will be captured in a future calculation when evaluated and classified.

Recommended Future Activity

Determine appropriate frequency of alpha analyses to ensure adequate hazard characterization.7

7 Required by RP-AA- 302

Page 35 OYSTER CREEK STATION HSA Revision 2 7.2. Potential Contaminated Areas

Potentially contaminated areas are analogous to impacted areas in the HSA. The primary goal of the HSA is to provide an initial classification of site areas and SSC as radiologically impacted or non-impacted. Non-impacted areas should have no history of using, storing, or burying radioactive materials. The MARSSIM and HSA Section 3 illustrate the types of information and conditions to consider and explore when making a decision on radioactive contamination potential. The percentage of information that is available and the level of confidence in this information is reflected in the classification.

Procedure RP-AA- 228 provides instructions for maintaining a list of documentation that is relevant to meeting the requirements of §50.75(g)(1) and §72.30(f)(1). This documentation includes records of radiological spills or other unusual occurrences involving the spread of contamination in and around the site. Included in this list are references to other documents and data relevant to decommissioning. The list identifies areas currently and formerly designated as restricted areas per §20.1003. Procedure RP-AA- 228 requires that this list be updated no less than every two years. This list was updated 2 March 2020 and is included as Appendix 10.2.

The initial assumption during this investigation is that all Site areas and SSC were impacted by Station operation. This is a reasonable assumption based on the longevity of operation, potential and actual releases of radioactive material (e.g., spills, leaks, and isolation condenser operation), storage and alternate disposal of radioactive materials onsite (e.g., disposal under §20.302), relocation of known or suspect radioactive spoils during site modifications, and previous experience at other sites that have completed an HSA. Most spills and leaks of radioactive materials were confined to the RCA.

Remediation was either complete or limited to prevent the spread of the contamination.

The following Sections 7.2.1 and 7.2.2 complete the initial classification of site areas and SSC as impacted or non- impacted.

Page 36 OYSTER CREEK STATION HSA Revision 2 7.2.1. Impacted Areas known and potential

7.2.1.1. Structures

7.2.1.1.1. AOB and Annex

Description and Historical Use

The AOB and annex were support facilities for the RP, Chemistry, and Environmental groups. The AOB and annex location are shown by Figure 5 as B1 at reference coordinate C2. The AOB and annex centerline geographical coordinates are zone 18s, easting 568012.70 meters (m), northing 4407348.98 m using the Universal Transverse Mercator (UTM) coordinate system.

The AOB and annex were outside the RCA and within the PA. The AOB was formally known as the Plant Engineering Building. A small Radioactive Material Area (RMA) was setup in the past in the west side Chemistry area. The RMA was to support gamma spectroscopy of low-level radioactivity samples. Radioactive materials were found in the AOB during Operation Clean Sweep in 2001. Gamma spectroscopy of selected items showed plant related radionuclides cobalt -60 and cesium -137. Radioactive materials free of loose surface contamination were packaged in the AOB and annex in preparation for shipment. Groundwater samples containing tritium were stored in the AOB until shipped to an offsite laboratory. Potentially contaminated carpet was removed from the AOB circa 2010, although some carpet remained in closet spaces and the area used to package and store well water samples containing tritium.

The AOB and annex were maintained free of radioactive contamination (no posted contaminated areas). There were no radioactive systems in the AOB.

There was potential for trace levels of radioactivity from airborne deposition contamination on the AOB and annex roofs from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• discrete radioactive particles

Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

• remaining carpet

Page 37 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The AOB and annex were preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

Recommended Future Investigation Activities

The building demolition plan designated the AOB and annex as structures 7 and 8.

Although outside the RCA, the AOB and annex were surveyed for unrestricted release based on the radiologically impacted classification. Buildings that have not housed contaminated systems normally exhibit little or no contamination and have been surveyed for unrestricted release (i.e., free release) at many power plant decommissioning projects.

A survey and sampling plan for unrestricted release was developed and implemented for the AOB and annex. The AOB and annex met the survey and sample release criteria for unrestricted use and were released for demolition. The AOB and annex were demolished to grade with the AOB concrete foundation remaining, and the annex to soil.

Above grade structural materials were removed from the Site as demolition waste.

There is some demolition waste such as concrete block, concrete, and metal accumulated on the western edge of the foundation; however, those materials may have come from another non- RCA demolition activity on the Site.

The footprint of the AOB and annex trailer are included in the South Protected Area (PA) Non-RCA land area (7.2.1.3.9) and will be radiologically evaluated as part of the same area.

Page 38 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.2. AOG Building

Description and Historical Use

The AOG Building houses the systems and components associated with reducing gaseous releases to the environs during plant operation. HEPA filters located downstream of the charcoal holdup beds complete the treatment of condenser off -gas.

The AOG Building location is shown by Figure 5 as B2 at reference coordinate D3. The AOG Building centerline geographical coordinates are zone 18s, easting 568097.85 m, northing 4407461.76 m using the UTM coordinate system.

The AOG is inside the RCA. Oyster Creek was one of several boiling water reactors requiring backfit with an AOG processing system. The AOG system became operational circa 1977 and was in use until shutdown and permanent defuel. Virtually all systems and components in the AOG Building have been abandoned in place.

Areas of the AOG were contaminated in the past; many of been released. The 23 foot elevation, normally a clean area, has been setup as a contaminated area to perform non- AOG work (e.g., Traversing In- Core Probe (TIP) tube testing). Airborne radioactivity in the form of noble gases and their progeny has occurred from leaks in the AOG. During cycle 10 offgas significantly increased by almost a factor of five. The recombiner rooms were posted as a locked high radiation area in the late 1970s and early 1980s due to failed fuel indicating the potential for legacy alpha TRU. Remaining source term, if any after prolonged shutdown, is expected to be longer -lived particulate contamination, tritium, and legacy alpha TRU.

The following table provides radiological conditions at various locations in the AOG Building. The data were collected from surveys available at the time of the HSA. The data were collected during and following shutdown and permanent defueling as available. Radiological conditions are relative to the time and location collected and may not be representative of actual radiological conditions found during D&D.

Table 5: AOG Building radiological conditions summary. Dose rates are general area.

Table is not all inclusive of survey areas in the AOG Building. Alpha classification is based on current list required by RP-AA- 302.

Map Dose Rate Alpha Number Area mr/hr Classification AY8 AOG 23 Foot <0.1 N/A*

AZ8 AOG 38 Foot <0.1 N/A*

• No contaminated areas, therefore alpha classification is N/A

Page 39 OYSTER CREEK STATION HSA Revision 2 The AOG is currently maintained free of radioactive contamination (no posted contaminated areas); however, there are radioactive systems in the AOG.

The roof area may have been radiologically impacted from the radionuclides released during operation of the isolation condensers.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Drains and Sumps

• pipe chase sump southwest corner elevation 23 foot o flame arrestor drain o holdup piping drain

• pipe chase floor drain sump southwest corner elevation 23 foot o discharge from pipe chase sump pumps o recombiner drains o water removal unit discharge o cubicle drains

Subsurface SSC or Tunnels

• pipe tunnel elevation 17 foot

• offgas piping routed to the AOG via AOG pipe vault

• treated offgas routed to Main Stack via AOG pipe vault

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• discrete radioactive particles

• tritium

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• system piping and component internal contamination

• charcoal and palladium catalyst media

• insulation

• sumps and drains

• soil surrounding sumps, drains, buried pipe and tunnels

Page 40 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The AOG Building and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification.8 Levels of residual radioactivity are not expected to exceed the USNRC default screening values based on operating history and radiological surveys. The AOG Building would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior and roof

• scan and contamination surveys of systems and components

• assess alpha level due to extended plant shutdown, inaccessible areas, and gaps in classification

• evaluate charcoal and palladium catalyst

• evaluate building sumps and drains

• evaluate below ground surface (bgs) concrete for radiological contamination and penetration depth

• evaluate sub-surface soil in the vicinity of sumps, drains, buried pipe and tunnels for radiological contamination and penetration depth

8 MARSSIM 2.2 Class 1 examples: leaks or spills, and initial assumption

Page 41 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.3. Boiler Houses

Description and Historical Use

The Boiler Houses provide plant heating steam to buildings and the NRW evaporator.

The Boiler House locations are shown by Figure 5 as B3 at reference coordinate C3.

The Boiler Houses centerline geographical coordinates are zone 18s, easting 568048.72 m, northing 4407453.25 m using the UTM coordinate system.

The Boiler Houses are inside the RCA. There were originally two boilers providing plant heating steam. Leakage from the NRW evaporators occurred in 1980 and 1985 resulted in the boilers and floor drain to become contaminated. There is suspicion that the contamination by the drain may be covered over by paint. Several spills in the RCA originated from boiler leaks over the course of operation. Two new boilers were installed in separate Kelly buildings circa 2005 and 2011, respectively.

The following table provides radiological conditions at various locations in the Boiler Houses. The data were collected from surveys available at the time of the HSA. The data were collected during and following shutdown and permanent defueling as available. Radiological conditions are relative to the time and location collected and may not be representative of actual radiological conditions found during D&D.

Table 6: Boiler Houses radiological conditions summary. Dose rates are general area.

Table is not all inclusive of survey areas in the Boiler Houses. Alpha classification is based on current list required by RP- AA- 302.

Map Dose Rate Alpha Number Area mr/hr Classification BAA Boiler House <0.1 N/A*

• No contaminated areas, therefore alpha classification is N/A

The Boiler Houses are maintained free of radioactive contamination (no posted contaminated areas); however, there are radioactive systems in the Boiler Houses.

The roof area may have been radiologically impacted from the radionuclides released during operation of the isolation condensers.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Page 42 OYSTER CREEK STATION HSA Revision 2

Drains and Sumps

• floor drains routed to the base of the stack 1-12 sump

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• tritium

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• system piping and component internal contamination

• insulation

• soil surrounding floor drain piping

Preliminary Classification

The Boiler Houses and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification. 9 Levels of residual radioactivity are not expected to exceed the USNRC default screening values based on operating history and radiological surveys. The Boiler Houses are good candidates for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all these buildings.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior and roof

• scan and contamination surveys of systems and components

• evaluate building drains

• evaluate soil surrounding floor drains and associated piping for radiological contamination

9 MARSSIM 2.2 Class 1 examples: leaks or spills, and initial assumption

Page 43 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.4. Breathing Air Compressor Building

Description and Historical Use

The Breathing Air Compressor Building houses the compressors, tanks, and piping used to supply breathing air during refuel outages. The Breathing Air Compressor Building location is shown by Figure 5 as B4 at reference coordinate B4. The Breathing Air Compressor Building centerline geographical coordinates are zone 18s, easting 567917.66 m, northing 4407469.77 m using the UTM coordinate system.

The Breathing Air Compressor Building is outside the RCA and within the PA. There is no record of the Breathing Air Compressor Building being contaminated or used as a Radioactive Material (RAM) storage area. The breathing air system was evaluated under Bulletin 80-10 and found to be not radioactively contaminated. The record shows that modifications were made to prevent system internal contamination.

The Breathing Air Compressor Building is currently maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the Breathing Air Compressor Building.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

• system piping and component internal contamination

Preliminary Classification

The Breathing Air Compressor Building is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is projected based on the above discussion and data gaps to support a non- impacted classification. 10

10 MARSSIM 2.2 Class 3 examples: areas with very low potential for residual contaminationbut insufficient information to justify a non- impacted classification

Page 44 OYSTER CREEK STATION HSA Revision 2 Recommended Future Investigation Activities

• scan and contamination survey of the building interior up to 2 meters (6 feet)

• scan and contamination survey of the building exterior and roof

• scan and contamination surveys of systems and components

Page 45 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.5. Building 3 Old Machine Shop

Description and Historical Use

Building 3 is a support facility that houses Maintenance and Security personnel.

Building 3 includes the Turbine Building RCA access/egress. Building 3 has a loft area with various materials and equipment. Building 3 location is shown by Figure 5 as B5 at reference coordinate B2. The Building 3 building centerline geographical coordinates are zone 18s, easting 567965.54 m, northing 4407377.98 m using the UTM coordinate system.

Building 3 is outside the RCA and within the PA. Building 3 buffers the Turbine Building RCA access/egress, which is initially designated as Class 1 (see Section 7.2.1.1.44).

There is heating steam piping labeled internally contaminated still in use in the overhead. Building 3 was used as a contaminated machine shop until 1982 when the area was released for unrestricted use and painted. A portion of Building 3 was once posted as a high contamination area. Main Steam Isolation Valve (MSIV) poppets were some of the highly contaminated equipment machined there. There is strong potential for fixed contamination in the overhead and floor drains based on historical use. Radioactive materials were found in Building 3 during Operation Clean Sweep in 2001. Gamma spectroscopy of selected items showed plant related radionuclides cobalt-60 and cesium -137.

Building 3 is currently maintained free of radioactive contamination (no posted contaminated areas; however, there are radioactive systems in the Building 3.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• discrete radioactive particles

Potentially Contaminated Media

• interior floors, walls and remaining carpet

• external walls and roof

• soil surrounding floor drain piping

• heating system piping and component internal contamination

• insulation

• floor drain

Page 46 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

Building 3 is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification.11 Levels of residual radioactivity are not expected to exceed the USNRC default screening values based on operating history and radiological surveys. Building 3 would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior and roof

• remove carpet or perform 100% direct frisk survey

• scan and contamination surveys of systems and components

• evaluate building drain

• evaluate soil surrounding floor drains and associated piping for radiological contamination

11 MARSSIM 2.2 Class 1 examples: leaks or spills, and initial assumption

Page 47 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.6. Building 4 Site Storage Building

Description and Historical Use

Building 4 was a support facility that housed an overhead crane, heavy machinery and equipment, tools, and scaffold. Building 4 location is shown by Figure 5 as B6 at reference coordinate B2. Building 4 centerline geographical coordinates are zone 18s, easting 567950.02 m, northing 4407330.61 m using the UTM coordinate system.

Building 4 was outside the RCA and within the PA. The concrete floor slab was originally bare then painted in the past. Building 4 was a RAM storage area for drums and B-25 containers until the early 1980s. Dry spills from containers occurred according to the historical records. The south end of the Building 4 was posted contaminated for low pressure turbine diaphragm cutting in 1996 during refuel outage 16R. Radioactive materials were found in Building 4 during Operation Clean Sweep in 2001. Gamma spectroscopy of selected items showed plant related radionuclides cobalt-60 and cesium -137.

Building 4 was maintained free of radioactive contamination in current years (no posted contaminated areas). There were no radioactive systems in Building 4.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

Page 48 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

Building 4 was preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

Recommended Future Investigation Activities

The building demolition plan designated the Building 4 as Building 4. Although outside the RCA, Building 4 was surveyed for unrestricted release based on the radiologically impacted classification. Buildings that have not housed contaminated systems normally exhibit little or no contamination and have been surveyed for unrestricted release (i.e.,

free release) at many power plant decommissioning projects.

A survey and sampling plan for unrestricted release was developed and implemented for Building 4. Building 4 met the survey and sample release criteria for unrestricted use and was released for demolition. Building 4 was demolished to grade with the concrete foundation remaining. Above grade structural materials were removed from the Site as demolition waste. There is some soil accumulated on the southern edge of the foundation; however, those spoils may have come from another non- RCA demolition activity on the Site.

The footprint of the Building 4 is included in the West PA Non-RCA land area (7.2.1.3.12) and will be radiologically evaluated as part of the same area.

Page 49 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.7. Chlorination Building

Description and Historical Use

The Chlorination Building houses the chlorination system for the main condensers. The Chlorination Building location is shown by Figure 5 as B7 at reference coordinate B3.

The Chlorination Building centerline geographical coordinates are zone 18s, easting 567898.27 m, northing 4407433.48 m using the UTM coordinate system.

The Chlorination Building is outside the RCA and within the PA. There is no record of the Chlorination Building being contaminated or used as a RAM storage area.

The Chlorination Building is currently maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the Chlorination Building.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

Preliminary Classification

The Chlorination Building is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is projected based on the above discussion and data gaps to support a non- impacted classification. 12

Recommended Future Investigation Activities

• scan and contamination survey of the building interior up to 2 meters (6 feet)

• scan and contamination survey of the building exterior and roof

12 MARSSIM 2.2 Class 3 examples: areas with very low potential for residual contaminationbut insufficient information to justify a non- impacted classification

Page 50 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.8. Clean Rigging and Storage Buildings

Description and Historical Use

The Clean Rigging and Storage Buildings are used to store clean rigging equipment, ice vest washing machine and dryer, and miscellaneous maintenance equipment.

The Clean Rigging and Storage Buildings are currently not occupied. The Clean Rigging and Storage Buildings are shown by Figure 5 as B8 at reference coordinate B5.

The Clean Rigging and Storage Buildings centerline geographical coordinates are zone 18s, easting 567921.07 m, northing 4407531.38 m using the UTM coordinate system.

The Clean Rigging and Storage Buildings are outside the RCA and within the PA.

There is no record of the Clean Rigging and Storage Buildings being contaminated or used as a RAM storage area.

The Clean Rigging and Storage Buildings are maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the Clean Rigging and Storage Buildings.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

Page 51 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Clean Rigging and Storage Buildings are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is projected based on the above discussion and data gaps to support a non- impacted classification. 13

Recommended Future Investigation Activities

• scan and contamination survey of the building interior up to 2 meters (6 feet)

• scan and contamination survey of the building exterior and roof

13 MARSSIM 2.2 Class 3 examples: areas with very low potential for residual contaminationbut insufficient information to justify a non- impacted classification

Page 52 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.9. Condensate Transfer Pump House and Systems

Description and Historical Use

The Condensate Transfer Pump House contains the pumps and piping for the connecting the CST and Demineralizer tanks to the Condensate system. The Condensate Transfer Pump House location is shown by Figure 5 as B9 at reference coordinate B3. The Condensate Transfer Pump House centerline geographical coordinates are zone 18s, easting 567902.06 m, northing 4407434.87 m using the UTM coordinate system.

The Condensate Transfer Pump House is outside the main RCA; however, most of the facility is controlled as a satellite RCA. The Condensate Transfer Pump House contains internally contaminated systems and drains. Condensate spills have occurred from leaking valves and system breaches. The concrete floor slab has been painted multiple times in the past. Underground piping leaks have occurred between the Condensate Transfer Pump House and the CST. A section of the concrete slab was removed in 1992 to access piping and adjoining soil. The underground piping between the Condensate Transfer Pump House and CST was cut at the surface, decontaminated, and capped in 1996.

The Condensate Transfer Pump House is currently maintained free of radioactive contamination (no posted contaminated areas); however, there are radioactive systems in the Condensate Transfer Pump House.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Drains and Sumps

• condensate transfer pump house sump routed to the 1-3 sump

• floor drains

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• tritium

Page 53 OYSTER CREEK STATION HSA Revision 2 Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• system piping and component internal contamination

• sumps and floor drains

• soil surrounding sumps, floor drains and associated piping

Preliminary Classification

The Condensate Transfer Pump House is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification.14 Levels of residual radioactivity are not expected to exceed the USNRC default screening values based on operating history and radiological surveys. The Condensate Transfer Pump House would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior and roof

• scan and contamination surveys of systems and components

• evaluate building drains and sump

• evaluate soil surrounding sumps, floor drains and associated piping for radiological contamination

14 MARSSIM 2.2 Class 1 examples: leaks or spills, initial assumption

Page 54 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.10. Contractor Trailer Complex (CB&I)

Description and Historical Use

The Contractor Trailer Complex was an administrative office complex occupied by several groups of maintenance contractors during outages. The Contractor Trailer Complex was abandoned in place. The Contractor Trailer Complex location is shown by Figure 5 as B10 at reference coordinate C5. The Contractor Trailer Complex centerline geographical coordinates are zone 18s, easting 567954.93 m, northing 4407529.00 m using the UTM coordinate system.

The Contractor Trailer Complex was outside the RCA and within the PA. There is no record of the Contractor Trailer Complex being contaminated or used as a RAM storage area.

The Contractor Trailer Complex was maintained free of radioactive contamination (no posted contaminated areas). There were no radioactive systems in the Contractor Trailer Complex.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

Preliminary Classification

The Contractor Trailer Complex was preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data,

§50.75(g)(1) historical data, and process knowledge.

Page 55 OYSTER CREEK STATION HSA Revision 2 Recommended Future Investigation Activities

The building demolition plan designated the Contractor Trailer Complex as Building 20. Although outside the RCA, the Contractor Trailer Complex was surveyed for unrestricted release based on the radiologically impacted classification. Buildings that have not housed contaminated systems normally exhibit little or no contamination and have been surveyed for unrestricted release (i.e., free release) at many power plant decommissioning projects.

A survey and sampling plan for unrestricted release was developed and implemented for the Contractor Trailer Complex. The Contractor Trailer Complex met the survey and sample release criteria for unrestricted use and was released for demolition. The Contractor Trailer Complex was demolished to grade (soil). Above grade structural materials were removed from the Site as demolition waste.

The footprint of the Contractor Trailer Complex is included in the East Protected Area (PA) Non-RCA land area (7.2.1.3.1) and will be radiologically evaluated as part of the same area.

Page 56 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.11. Diesel Generator Building

Description and Historical Use

The Diesel Generator Building houses the diesel oil storage tank and two diesel generators. The Diesel Generator Building location is shown by Figure 5 as B11 at reference coordinate A2. The Diesel Generator Building centerline geographical coordinates are zone 18s, easting 567909.31 m, northing 440732.46 m using the UTM coordinate system.

The Diesel Generator Building is outside the RCA and within the PA. There is no record of the Diesel Generator Building being contaminated or used as a RAM storage area.

The Diesel Generator Building is currently maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the Diesel Generator Building.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

Preliminary Classification

The Diesel Generator Building is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data,

§50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is projected based on the above discussion and data gaps to support a non- impacted classification. 15

Recommended Future Investigation Activities

• scan and contamination survey of the building interior up to 2 meters (6 feet)

• scan and contamination survey of the building exterior and roof

15 MARSSIM 2.2 Class 3 examples: areas with very low potential for residual contaminationbut insufficient information to justify a non- impacted classification

Page 57 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.12. Dilution Pump House

The Dilution Pump House was used to divert water from the Intake Canal to the Discharge Canal for moderation of discharge temperature. The Dilution Pump House location is shown by Figure 5 as B12 at reference coordinate A3. The Dilution Pump House centerline geographical coordinates are zone 18s, easting 567776.43 m, northing 4407409.83 m using the UTM coordinate system.

The Station had maintained a zero radioactive liquid effluent discharge station policy since 1990. The decision to be zero discharge was a management decision. The Station began discharging low -level radioactive tritiated liquid from site wells to the canal circa 2009. The Station resumed radioactive liquid effluent discharges in 2019 following shutdown and permanent defuel. Discharge flow rate has been substantially reduced with circulation and dilution pumps secured. Flow in the Discharge Canal was designed to flow south to southeast away from the Discharge Pump House; however, the low discharge rate has been observed to fan backwards to the west and northwest towards the Dilution Pump House. The site has discharged 1,355,648 gallons to date for a total activity released of 5.9 total Curies.

A 1998 memo identified relocation of potentially contaminated soil behind a retaining wall east of the Dilution Pump House. Samples collected in 2000 and 2006 identified only Naturally Occurring Radioactive Material (NORM); however, those sample locations relative to the retaining wall area could not be verified.

The Dilution Pump House is currently maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the Dilution Pump House.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

There is potential for trace levels of contamination within the Dilution Pump House and supporting systems from discharges of liquid effluent.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• tritium

Page 58 OYSTER CREEK STATION HSA Revision 2 Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

• system piping and component internal contamination

• bgs concrete exposed to tritium

• soil behind retaining wall east of the Dilution Pump House

Preliminary Classification

The Dilution Pump House and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 2 designation is projected based on the above discussion and data gaps to support a lower classification. 16 Levels of residual radioactivity are expected to be at a small fraction of the USNRC default screening values based on operating history and radiological surveys. The Dilution Pump House would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

The Dilution Pump House subsurface concrete is a good candidate for an As Low As Reasonably Achievable (ALARA) quantitative cost benefit analysis under NUREG-1727 Appendix D.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior up to 2 meters (6 feet)

• scan and contamination survey of the building exterior and roof

• scan and contamination surveys of systems and components

• perform radiological analysis of bgs concrete for tritium contamination and penetration depth

• Evaluate soil stored behind retaining wall east of the Dilution Pump House for radiological contamination

16 MARSSIM 2.2 Class 2 examples: locations where radioactive materials werepresent in an unsealed form

Page 59 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.13. Drywell Processing Center

Description and Historical Use

The Drywell Processing Center was constructed circa late 1980s to support access to the Drywell during outages. The Drywell Processing Center contained briefing areas, dress out areas, and a personnel decontamination area. Only the dress out and personnel decontamination areas are within the RCA. Included in this area is the walkway from the Reactor Building northeast airlock to the Drywell Processing Center and the RCA exit. The Drywell Processing Center location is shown by Figure 5 as B13 at reference coordinate C4. The Respirator Facility centerline geographical coordinates are zone 18s, easting 567991.38, northing 4407512.28 m using the UTM coordinate system.

More than half of the Drywell Processing Center was maintained outside of the RCA.

The former Operations Support Center (OSC) was in the Drywell Processing Center non- RCA area. Protective clothing and supplies were stored in the dress out up area.

A personnel decontamination shower with two hold- up tanks and associated piping was available as needed. The holdup tanks were pumped to radwaste when required.

Personnel and small item contamination monitoring was performed when exiting the RCA.

The Drywell Processing Center is currently maintained free of radioactive contamination (no posted contaminated areas); however, there are radioactive systems in the Drywell Processing Center.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• discrete radioactive particles

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• remaining carpet

• system piping and component internal contamination

• decontamination shower

• soil surrounding decontamination shower, hold- up tanks, and associated piping for radiological contamination

Page 60 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Drywell Processing Center and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is projected for areas outside the RCA based on the above discussion and data gaps to support a non- impacted classification. 17

An initial MARSSIM Class 1 designation is projected for areas inside the RCA based on the above discussion and data gaps to support a lower classification. 18 Levels of residual radioactivity are not expected to exceed the USNRC default screening values based on operating history and radiological surveys. The Drywell Processing Center in the RCA would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior and roof

• remove carpet or perform 100% direct frisk survey

• scan and contamination surveys decontamination shower

• evaluate soil surrounding decontamination shower, hold-up tanks, and associated piping for radiological contamination

17 MARSSIM 2.2 Class 3 examples: areas with very low potential for residual contaminationbut insufficient information to justify a non- impacted classification 18 MARSSIM 2.2 Class 1 examples: initial assumption

Page 61 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.14. Fire Water Pump House

Description and Historical Use

The Fire Water Pump House is a sheet metal facility that houses two diesel driven fire pumps. The Fire Water Pump House location is shown by Figure 5 as B14 at reference coordinate A4. The Fire Water Pump House centerline geographical coordinates are zone 18s, easting 567841.29 m, northing 4407479.86 m using the UTM coordinate system.

The Fire Water Pump House is outside the RCA and within the PA. There is no record of the Fire Water Pump House being contaminated or used as a RAM storage area.

The Fire Water Pump House is currently maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the Fire Water Pump House.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

Preliminary Classification

The Fire Water Pump House is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data,

§50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is projected based on the above discussion and data gaps to support a non- impacted classification. 19

Recommended Future Investigation Activities

• scan and contamination survey of the building interior up to 2 meters (6 Feet)

• scan and contamination survey of the building exterior and roof

19 MARSSIM 2.2 Class 3 examples: areas with very low potential for residual contaminationbut insufficient information to justify a non- impacted classification

Page 62 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.15. Fish Sample Pond

The Fish Sample Pond was used to minimize marine life stress from intake operation.

The Fish Sample Pond location is shown by Figure 5 as B15 at reference coordinate A3. The Fish Sampling Pond centerline geographical coordinates are zone 18s, easting 567828.93 m, northing 4407442.94 m using the UTM coordinate system.

The Fish Sample Pond is outside the RCA and within the PA. There is no record of the Fish Sample Pond being contaminated or used as a RAM storage area.

The Station had maintained a zero radioactive liquid effluent discharge station policy since 1990. The decision to be zero discharge was a management decision. The Station began discharging low -level radioactive tritiated liquid from site wells to the canal circa 2009. The Station resumed radioactive liquid effluent discharges in 2019 following shutdown and permanent defuel. Discharge rate has been substantially reduced with circulation and dilution pumps secured. Flow in the Discharge Canal was designed to flow south to southeast away from the Fish Sample Pond; however, the low discharge rate has been observed to fan backwards to the west and northwest towards the Fish Sample Pond. The site has discharged 1,355,648 gallons to date for a total activity released of 5.9 total Curies.

The Fish Sample Pond is currently maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the Fish Sample Pond.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent.

There is potential for trace levels of contamination within the Fish Sample Pond and supporting systems from discharges of liquid effluent.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• tritium

Potentially Contaminated Media

• system piping and component internal contamination

• sediment

Page 63 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Fish Sample Pond is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 2 designation is projected based on the above discussion and data gaps to support a lower classification. 20 Levels of residual radioactivity are expected to be at a small fraction of the USNRC default screening values based on operating history and radiological surveys. The Fish Sample Pond would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• evaluate sediment samples in pond

20 MARSSIM 2.2 Class 2 examples: locations where radioactive materials werepresent in an unsealed form

Page 64 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.16. Hazard Collection Building

Description and Historical Use

The Hazard Collection Building is a potentially hazardous waste collection station described as O -12 by the HWC Plan. The Hazard Collection Building location is shown by Figure 5 as B16 at reference coordinate B2. The Hazard Collection Building centerline geographical coordinates are zone 18s, easting 567926.26 m, northing 4407337.72 m using the UTM coordinate system.

The Hazard Collection Building is outside the RCA and within the PA. There is no record of the Hazard Collection Building being contaminated or used as a RAM storage area.

The Hazard Collection Building is currently maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the Hazard Collection Building.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

Page 65 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Hazard Collection Building is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data,

§50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is projected based on the above discussion and data gaps to support a non- impacted classification. 21

Recommended Future Investigation Activities

• scan and contamination survey of the building interior up to 2 meters (6 feet)

• scan and contamination survey of the building exterior and roof

21 MARSSIM 2.2 Class 3 examples: areas with very low potential for residual contaminationbut insufficient information to justify a non- impacted classification

Page 66 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.17. Hot Machine Shop

Description and Historical Use

The Hot Machine Shop was a designated structure where contaminated equipment could be worked in a low dose area. The Hot Machine Shop housed three containment Kelly buildings, jib crane, work benches, and shielded frisking booth. The Hot Machine Shop location is shown by Figure 5 as B17 at reference coordinate B4. The Hot Machine Shop centerline geographical coordinates are zone 18s, easting 567934.98 m, northing 4407493.51 m using the UTM coordinate system.

Maintenance and equipment refurbishments were typically performed in the Hot Machine Shop during refuel outages. The equipment was RAM with loose contamination, fixed contamination, or both. Maintenance and refurbishment could have had the potential for generated airborne activity; therefore, work was performed in metal containment enclosures with HEPA air removal as an engineering control.

The Hot Machine Shop contained three separate Kelly enclosures housing machinery for work on contaminated equipment and material. One enclosure housed a lathe, another a boring mill, and the last was used for miscellaneous machining and welding.

Enclosures HEPA ventilation systems would have discharged back into the Hot Machine Shop requiring a Continuous Air Monitor (CAM) during use. There is a ventilation exhaust system for the Hot Machine Shop that included a sampling station; however, evidence of use could not be confirmed. A jib crane in the room supported the moving of heavy loads into the containments through roof openings. There was a shielded frisking booth for personnel monitoring prior to exiting the room. The Hot Machine Shop was used to store RAM until recently. Approximately 25% of the Hot Machine Shop was posted as a contaminated area.

Floors inside the Kelly enclosures have been exposed to high contamination levels during maintenance activities. The southeast corner housed a freon unit to decontaminate tools. Highly contaminated reactor recirculation pumps seals were deconned in the freon unit. Glove containment failures and poor work practices led to contamination outside the containment including the floor.

There was a decontamination shower and sink in the Hot Machine Shop that was removed, and according to the historical records the piping remained. There is reportedly a decontamination sump in the Hot Machine Shop that is tied to the Turbine Building 1- 1 sump.

Table 7: Hot Machine Shop radiological conditions summary. Dose rates were general area. Table is not all inclusive of survey areas in the AOG Building. Alpha classification was based on current list required by RP-AA- 302.

Map Dose Rate Alpha Number Area mr/hr Classification MAA Hot Machine Shop 0.5 3

Page 67 OYSTER CREEK STATION HSA Revision 2 There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• discrete radioactive particles

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• system piping and component internal contamination

• sump and drain

Preliminary Classification

The Hot Machine Shop and all systems within were preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

Recommended Future Investigation Activities

The building demolition plan includes the Hot Machine Shop as structure 21. Since the Hot Machine Shop was in the RCA a survey plan was generated and performed.

Radioactive materials, Kelly enclosures, and equipment were first removed.

Radiological surveys were then performed on the floor and walls up to six feet (2 meters). Spot remediation was performed on the walls and the floor was scabbled.

Subsequent radiological surveys were performed, and the Hot Machine Shop was released from the RCA.

Following demolition of the Hot Machine Shop concrete slab, investigation activities should include evaluation of soil surrounding the sump, floor drains and associated piping for radiological contamination

Page 68 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.18. Hot Tool Room

Description and Historical Use

The Hot Tool Room was used to issue and store radioactive tools. The Hot Tool Room location is shown by Figure 5 as B17 at reference coordinate B4. The Hot Tool Room centerline geographical coordinates are zone 18s, easting 567942.29 m, northing 4407481.28m using the UTM coordinate system.

The Hot Tool Room is inside the RCA. The Hot Tool Room was originally the office of the radiological controls field operations manager. The area then became the snubber rebuild room and then the air sample repair shop.

The Hot Tool Room is currently maintained free of radioactive contamination (no posted contaminated areas); however, there are radioactive systems in the Hot Tool Room.

The Hot Tool Room has been cleared of tools and equipment and will be used in the future for dress out and RP equipment storage.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• discrete radioactive particles

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

Page 69 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Hot Tool Room and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification.22 Levels of residual radioactivity are not expected to exceed the USNRC default screening values based on operating history and radiological surveys. The Hot Tool Room would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior and roof

22 MARSSIM 2.2 Class 1 examples: initial assumption

Page 70 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.19. Intake and Discharge Structure

Description and Historical Use

The Intake and Discharge Structure houses the systems associated with the once through cooling of the main condenser and other condensers. The Intake and Discharge Structure components include the trash racks, traveling screens, stop logs, Circulation Water Pumps, Service and Emergency Service Water pumps, screen wash pumps, and an ice control recirculation flow path. There are stop logs in the Unit 2 discharge tunnels. The Intake and Discharge Structure location is shown by Figure 5 as structure B18 at reference coordinate A4. The Intake and Discharge Structure centerline geographical coordinates are zone 18s, easting 567821.06 m, northing 4407398.78 m using the UTM coordinate system.

The Intake and Discharge Structure is outside the RCA and within the PA. The Station had maintained a zero radioactive liquid effluent discharge station policy since 1990.

The decision to be zero discharge was a management decision. The Station began discharging low-level radioactive tritiated liquid from site wells to the canal circa 2009.

The Station resumed radioactive liquid effluent discharges in 2019 following shutdown and permanent defuel. Discharge rate has been substantially reduced with circulation and dilution pumps secured. Flow in the Discharge Canal was designed to flow south to southeast away from the Intake and Discharge Structures; however, the low discharge rate has been observed to fan backwards to the west and northwest towards the Intake and Discharge Structure. The site has discharged 1,355,648 gallons to date for a total activity released of 5.9 total Curies.

Exterior surfaces of the tunnel may have become contaminated because of CST leakage discovered during refuel outage 13R according to historical records.

The REMP sampling between the condenser discharge and the dilution system outlets identified the leakage.

The Intake and Discharge Structure are maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the Intake and Discharge Structures.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

There is potential for trace levels of contamination within the Intake and Discharge Structure and supporting systems from discharges of liquid effluent.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• tritium

Page 71 OYSTER CREEK STATION HSA Revision 2 Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

• system piping and component internal contamination

• bgs concrete exposed to tritium

• wooden stop logs

Preliminary Classification

The Intake and Discharge Structure and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 2 designation is projected based on the above discussion and data gaps to support a lower classification. 23 Levels of residual radioactivity are expected to be at a small fraction of the USNRC default screening values based on operating history and radiological surveys. The Intake and Discharge Structure would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

The Intake and Discharge Structure including subsurface tunnels are good candidates for an ALARA quantitative cost benefit analysis under Appendix D of NUREG -1727.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior up to 2 meters (6 feet)

• scan and contamination survey of the building exterior and roof

• evaluate cracks in floors and walls below grade that have the potential to spread contamination

• perform radiological analysis of bgs concrete for radiological contamination and penetration depth

• evaluate wooden stop logs

23 MARSSIM 2.2 Class 2 examples: locations where radioactive materials werepresent in an unsealed form

Page 72 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.20. ISFSI Area

Description and Historical Use

The ISFSI Area is designed and constructed for the interim storage of spent nuclear fuel and Greater than Class C (GTCC) waste. The ISFSI Area location is shown by Figure 5 as B19 at reference coordinate E4. The ISFSI Area centerline geographical coordinates are zone 18s, easting 568179.81 m, northing 4407527.79 m using the UTM coordinate system.

The ISFSI Area is outside the RCA; however, the ISFSI is designated as a Restricted Area per §20.1003. The ISFSI Area includes level D storage to the north and former CBI weld/laydown area to the south. Soil sampling was performed in 1992 prior to ISFSI construction. Samples were collected north of the former auxiliary contractor parking including all of level D storage and the fuel pump area. A 1998 memo identified the southern berm as containing potentially contaminated excavated soil. Oyster Creek began transferring fuel from the Spent Fuel Pool (SFP) to the Horizontal Storage Modules (HSM) on the ISFSI pad in 2002. The ISFSI project started November of 2019 and is currently in progress. The transfer of all spent fuel from the SFP to the ISFSI is expected to be complete late 2021. The ISFSI is expected to be a stand- alone facility following completion of D&D and termination of the 10CFR50 license for the Station.

The ISFSI is currently maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the ISFSI.

The ISFSI Area may have been radiologically impacted from the radionuclides released during operation of the isolation condensers.

There is potential for trace levels of radioactivity from airborne deposition contamination on the ISFSI pad from routine operation and discharge of gaseous effluent, and from the movement of personnel and radioactive material particularly during ISFSI campaigns.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• neutron activation products

• discrete radioactive particles

• special nuclear material (SNM)

Page 73 OYSTER CREEK STATION HSA Revision 2 Potentially Contaminated Media

• storage module internal contamination

• external walls and roof

• southern berm soil

Preliminary Classification

The ISFSI Area is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification. 24 The ISFSI Area would be a good candidate for further evaluation after D&D and removal of spent fuel and GTCC RAM from the ISFSI.

Recommended Future Investigation Activities

• sample southern berm soil

24 MARSSIM 2.2 Class 1 examples: waste storage site

Page 74 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.21. Level D Building

Description and Historical Use

The Level D Building is collection station used to store abandoned equipment and material and is isolated and secured by fencing and a locked gate. The Level D Building location is shown by Figure 5 as B20 at reference coordinate E5. The Level D Building centerline geographical coordinates are zone 18s, easting 568181.35 m, northing 4407552.65 m using the UTM coordinate system.

The Level D Building is outside the RCA and within the PA. There is no record of the Level D Building being contaminated or used as a RAM storage area.

The Level D Building is currently maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the Level D Building.

The roof area may have been radiologically impacted from the radionuclides released during operation of the isolation condensers.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

Page 75 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Level D Building is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is projected based on the above discussion and data gaps to support a non- impacted classification. 25

Recommended Future Investigation Activities

• scan and contamination survey of the building interior up to 2 meters (6 feet)

• scan and contamination survey of the building exterior and roof

25 MARSSIM 2.2 Class 3 examples: areas with very low potential for residual contaminationbut insufficient information to justify a non- impacted classification

Page 76 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.22. LLRWSF

Description and Historical Use

The LLRWSF supports the onsite storage of low-level radioactive material/waste and contaminated equipment. The bulk of the low-level radioactive material/waste generated takes the form of spent resin, filter sludge, evaporator bottoms, and DAW. The contaminated equipment is temporarily stored until reused as needed. The LLRWSF location is shown by Figure 5 as B21 at reference coordinate C5. The LLRWSF centerline geographical coordinates are zone 18s, easting 567988.91 m, northing 4407615.42 m using the UTM coordinate system.

The LLRWSF is outside the main RCA; however, most of the facility is controlled as a satellite RCA. The LLRWSF was put into operation circa 1985 primarily to house packaged low-level radioactive waste in a retrievable manner until access to a burial site was available. Most of the equipment and waste stored in the building is containerized and in shippable form. All radioactive contaminated materials stored without containers have fixed contamination with no smearable contamination being allowed. RP can allow decontamination and assembly of components with smearable contamination in LLRWSF following evaluation to ensure that radioactive material releases are negligible. There is anecdotal evidence of this occurring as recently as 2008 with the changing of recirculation pump seal oil on the 2 nd floor. However, as a rule, decontamination, and assembly of unencapsulated or smearable contaminated components in LLRWSF is avoided. A modification was made to the DAW compaction area (never used) to relocate Radiac calibration circa 2011.

The following table provides radiological conditions at various locations in the LLRWSF Building. The data were collected from surveys available at the time of the HSA. The data were collected during and following shutdown and permanent defueling as available. Radiological conditions are relative to the time and location collected and may not be representative of actual radiological conditions found during D&D.

Table 8: LLRWSF radiological conditions summary. Dose rates are general area. Table is not all inclusive of survey areas in the LLRWSF. Alpha classification is based on current list required by RP-AA- 302.

Map Dose Rate Alpha Number Area mr/hr Classification WAA Low Level Radwaste Storage Facility 0.01 - 0.5 N/A*

• No contaminated areas, therefore alpha classification is N/A

Page 77 OYSTER CREEK STATION HSA Revision 2 The LLRWSF is currently maintained free of radioactive contamination (no posted contaminated areas). The LLRWSF cleanup project has resulted in the reduction of RAM that is no longer needed on the Site, particularly in the DAW storage area. There are no radioactive systems in the LLRWSF.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Drains and Sumps

• cell drain trenches

• cell storage area sump

• main facility sump

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• resin and filter media

• discrete radioactive particles

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• system piping and component internal contamination

• resins

• sumps and trenches

• soil surrounding sumps, drains, trenches and associated piping

Preliminary Classification

The LLRWSF and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification.26 Levels of residual radioactivity are not expected to exceed the USNRC default screening values based on operating history and radiological surveys. The LLRWSF would be a good candidate for further

26 MARSSIM 2.2 Class 1 examples: waste storage site

Page 78 OYSTER CREEK STATION HSA Revision 2 evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior and roof

• scan and contamination surveys of systems and components

• evaluate building sumps and drains

• evaluate soil surrounding sumps, drains, trenches and associated piping for radiological contamination

Page 79 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.23. MAC Facility

Description and Historical Use

The MAC Facility provides access to the Turbine Building and Reactor Building airlock.

The MAC Facility is an ingress/egress area to/from the RCA, although it is currently shutdown following permanent shutdown and defuel. The MAC Facility location is shown by Figure 5 as B22 at reference coordinate C4. The MAC Facility centerline geographical coordinates are zone 18s, easting 567957.65 m, northing 4407485.49 m using the UTM coordinate system.

Approximately 50% of the MAC Facility is in the RCA. There was another structure, a hurricane shelter, at this location prior to MAC construction. A spill from the SFP migrated from the Reactor Building through a hurricane rollup door in 1984 to an area under the MAC according to the historical records.

Radioactive materials were found in the MAC Facility during Operation Clean Sweep in 2001. Gamma spectroscopy of selected items showed plant related radionuclides cobalt-60 and cesium -137.

The MAC Facility has been maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the MAC.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• soil beneath the MAC

Page 80 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The MAC Facility is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is projected for areas outside the RCA based on the above discussion and data gaps to support a non- impacted classification. 27

An initial MARSSIM Class 1 designation is projected for areas inside the RCA based on the above discussion and data gaps to support a lower classification. 28 Levels of residual radioactivity are not expected to exceed the USNRC default screening values based on operating history and radiological surveys. The MAC would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior and roof

• evaluate soil beneath the MAC for radiological contamination

27 MARSSIM 2.2 Class 3 examples: areas with very low potential for residual contaminationbut insufficient information to justify a non- impacted classification 28 MARSSIM 2.2 Class 1 examples: initial assumption

Page 81 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.24. MAF

Description and Historical Use

The MAF serves as the main access point to the PA. The MAF constructed circa 2004 replaced the Main Gate Security Center as primary access to the PA when the boundary was expanded. Preconstruction soil sampling and analyses could not be located. The MAF location is shown by Figure 5 as B23 at reference coordinate D2.

The MAF building centerline geographical coordinates are zone 18s, easting 568154.13 m, northing 4407408.46 m using the UTM coordinate system.

The MAF is outside the RCA and within the PA. Radioactive nickel- 63 sealed sources are housed in security equipment in the MAF. These sources are leak checked by RP on a periodic basis. All leak test criteria have been satisfied; no leaking sources have been identified. The MAF also houses two x -Ray devices used by Security.

The MAF is currently maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the MAF.

The MAF may have been radiologically impacted from the radionuclides released during operation of the isolation condensers.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

Page 82 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The MAF is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 2 designation is projected based on the above discussion and data gaps to support a lower classification.29 Levels of residual radioactivity are expected to be at a small fraction of the USNRC default screening values based on operating history and radiological surveys. The MAF would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior and roof

29 MARSSIM 2.2 Class 2 examples: downwind from stack release points

Page 83 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.25. Main Gate Security Center

Description and Historical Use

The Main Gate Security Center served as the main access point to the PA until replaced circa 2004 by the MAF. The Main Gate Security Center is primarily a support facility for Security. The Main Gate Security Center location is shown by Figure 5 as B24 at reference coordinate C3. The Main Gate Security Center building centerline geographical coordinates are zone 18s, easting 568022.72 m, northing 4407395.43 m using the UTM coordinate system.

The Main Gate Security Center is outside the RCA and within the PA. Radioactive nickel-63 sealed sources in security equipment are stored in the MAF. These sources are leak checked by RP on a periodic basis. All leak test criteria have been satisfied; no leaking sources have been identified.

The Main Gate Security Center is currently maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the Main Gate Security Center.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent; and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• remaining carpet

Page 84 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Main Gate Security Center is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data,

§50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 2 designation is projected based on the above discussion and data gaps to support a lower classification. 30 Levels of residual radioactivity are expected to be at a small fraction of the USNRC default screening values based on operating history and radiological surveys. The Main Gate Security Center would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior and roof

• remove carpet or perform 100% direct frisk survey

30 MARSSIM 2.2 Class 2 examples: downwind from stack release points

Page 85 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.26. Maintenance Supervisor Building

Description and Historical Use

The Maintenance Supervisor Building was an administrative office occupied by Maintenance. The Maintenance Supervisor Building location is shown by Figure 5 as B25 at reference coordinate B5. The Maintenance Supervisor Building centerline geographical coordinates are zone 18s, easting 567873.51 m, northing 4407539.53 m using the UTM coordinate system.

The Maintenance Supervisor Building was outside the RCA and within the PA.

The Maintenance Supervisor Building was formally used as the North Guardhouse during outages until circa 2002.

The Maintenance Supervisor Building was maintained free of radioactive contamination (no posted contaminated areas). There were no radioactive systems in the Maintenance Supervisor Building.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• discrete radioactive particles

Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

• remaining carpet

Page 86 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Maintenance Supervisor Building was preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

Recommended Future Investigation Activities

The building demolition plan designated the Maintenance Supervisor Building as structure 16. Although outside the RCA, the Maintenance Supervisor Building was surveyed for unrestricted release based on the radiologically impacted classification.

Buildings that have not housed contaminated systems normally exhibit little or no contamination and have been surveyed for unrestricted release (i.e., free release) at many power plant decommissioning projects.

A survey and sampling plan for unrestricted release was developed and implemented for the Maintenance Supervisor Building. The Maintenance Supervisor Building met the survey and sample release criteria for unrestricted use and was released for demolition.

The Maintenance Supervisor Building was demolished to grade with the concrete foundation remaining. Above grade structural materials were removed from the Site as demolition waste.

The footprint of the Maintenance Supervisor Building is included in the West Protected Area (PA) Non-RCA land area (7.2.1.3.12) and will be radiologically evaluated as part of the same area.

Page 87 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.27. MOB - Office Building

Description and Historical Use

The MOB houses Operations personnel. The 3rd floor MOB provides three accessways and one access/egress to the RCA. The MOB roof in the RCA is accessible from a ladder in the 3 rd floor back stairwell. The multiplexer (MUX) room, upper cable room, and MOB roof in the RCA are accessible from the corridor adjacent to the Control Room access. The Turbine roof and Condensate Demineralizer corridor in the RCA are accessible from the Operations access. The Hot Chemistry Lab is in the MOB on elevation 35 foot. The MOB location is shown by Figure 5 as B26 at reference coordinate B3. The MOB building centerline geographical coordinates are zone 18s, easting 567975.16 m, northing 4407420.33 m using the UTM coordinate system.

The MOB is mostly outside the RCA and within the PA. The MOB provides access to the RCA, which is initially designated as Class 1. The 3rd floor access/egress to the RCA has a decontamination area in the former RWP and Equipment Operators room.

Workers in the 1970s wore their contaminated protected clothing to this area, disrobed, and deposited the clothing in a laundry chute which went down to the old laundry facility (currently the Hot Chemistry Lab). The laundry chute appears isolated from the Hot Chemistry lab and the wooden cover is labeled internal contamination. Hot particles have been found in this area in the past.

Recently, reactor cavity water leakage from the Reactor Building 51 foot elevation west side resulted in minor through wall seepage of radioactive water to the 3rd floor outside the ladies room. The area was posted a contaminated area; the area has been released for unrestricted use.

The MOB is currently maintained free of radioactive contamination (no posted contaminated areas); however, the former laundry chute is labeled internal contamination.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Page 88 OYSTER CREEK STATION HSA Revision 2

Drains and Sumps

• drains from the Hot Chemistry Lab are routed to the Lab Drain Tank (T 003) on Reactor Building elevation 23 foot northwest corner

Process Sinks

• several hooded sinks in the Hot Chemistry Lab

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• discrete radioactive particles

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• remaining carpet

Preliminary Classification

The MOB is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is projected for areas outside the RCA based on the above discussion and data gaps to support a non- impacted classification. 31

An initial MARSSIM Class 1 designation is projected for areas inside the RCA based on the above discussion and data gaps to support a lower classification. 32 Levels of residual radioactivity are not expected to exceed the USNRC default screening values based on operating history and radiological surveys. The MOB would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

31 MARSSIM 2.2 Class 3 examples: areas with very low potential for residual contaminationbut insufficient information to justify a non- impacted classification 32 MARSSIM 2.2 Class 1 examples: leaks or spills and initial assumption

Page 89 OYSTER CREEK STATION HSA Revision 2 Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior and roof

• remove carpet or perform 100% direct frisk survey

• scan and contamination survey former laundry chute

Page 90 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.28. New Maintenance Building

Description and Historical Use

The New Maintenance Building housed the clean and hot machine shops, electrical shop, loft storage area, clean tool room on 1 st and 2nd floor, locker rooms and toilet facilities, and office spaces. The New Maintenance Building is currently occupied by Maintenance. The New Maintenance Building location is shown by Figure 5 (cont) as B27 at reference coordinate B4. The New Maintenance Building centerline geographical coordinates are zone 18s, easting 567921.23 m, northing 4407502.83 m using the UTM coordinate system.

The New Maintenance Building is outside the RCA and within the PA . The New Maintenance Building buffered the RCA and included the clean tool room and abutting external trailer, machine shop, office spaces, locker rooms, hot machine shop, hot tool room, and respiratory repair facility. The hot machine shop had a separate, filtered, and monitored ventilation on the roof; however, the exhaust fan EF 43, filter units, and sampling station appear to have been abandoned for some time.

The New Maintenance Building was constructed circa 1980. A clean locker storage area on the 1 st floor west was used as an air sample count room in the early 1980s.

The room was used to calibrate and repair air samplers with internal and fixed external contamination. There was a containment box in the room that had internal smearable contamination from the opening of air samplers that had internal contamination. The room was released for unrestricted use at some point in the past. Material above the release limits were found in the clean tool room in 1989 through 1990. Potentially radioactive materials were found in Building 3 during Operation Clean Sweep in 2001.

Gamma spectroscopy of selected items showed plant related radionuclides cobalt -60 and cesium-137.

There was the potential for trace levels of contamination in the New Maintenance Building from airborne deposition on the roof from routine operation, previous use as a RAM storage and contamination area, and from the movement of personnel and equipment between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• discrete radioactive particles

Page 91 OYSTER CREEK STATION HSA Revision 2 Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

• remaining carpet

Preliminary Classification

The New Maintenance Building is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data,

§50.75(g)(1) historical data, and process knowledge.

Recommended Future Investigation Activities

The building demolition plan designated the New Maintenance Building as structure 21.

Although outside the RCA, the New Maintenance Building was surveyed for unrestricted release based on the radiologically impacted classification.

A survey and sampling plan for unrestricted release was developed and implemented for the New Maintenance Building. The New Maintenance Building met the survey and sample release criteria for unrestricted use and were released for demolition.

The footprint of the New Maintenance Building is included in the East Protected Area (PA) Non-RCA land area (7.2.1.3.1) and will be radiologically evaluated as part of the same area.

Page 92 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.29. New Sampling Building

Description and Historical Use

The New Sampling Building houses the systems associated with the transfer and sampling of the two chemical and two high purity test tanks. The New Sampling Building location is shown by Figure 5 (cont) as B28 at reference coordinate C3. The New Sampling Building centerline geographical coordinates are zone 18s, easting 568000.32 m, northing 4407481.35 m using the UTM coordinate system.

The New Sampling Building is inside the RCA. The New Sampling Building is a metal structure with concrete floor next to the Outdoor Tank and Enclosure. The building contains two chemical waste and two high purity sample pumps. Pump leak off runs to a 6 inch trench that drains to Radwaste sump.

The area is currently maintained radiologically clean with the trench posted as a contaminated area. The Pumps are labeled contaminated; and, historically, the pumps have leaked and some of the pumps and foundations were replaced. A spill in1997 showed contamination on the floor.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• tritium

Potentially Contaminated Media

• interior floors and walls

• external walls

• roof

• system piping and component internal contamination

• concrete

• insulation

• soil beneath pump foundations, trench and associated piping

Page 93 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The New Sampling Building and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification.33 Levels of residual radioactivity are not expected to exceed the USNRC default screening values based on operating history and radiological surveys. The New Sampling Building would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior

• scan and contamination surveys of systems and components

• perform core bore or sample pump foundation

• perform survey and sampling of trench

• evaluate soil beneath the pump foundations, trench and associated piping for radiological contamination

33 MARSSIM 2.2 Class 1 examples: leaks or spills, and initial assumption

Page 94 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.30. NRW Building

Description and Historical Use

The NRW Building houses the systems associated with the various radwaste collection and processing systems. The NRW heat exchanger building is included in the NRW building footprint. The NRW Building location is shown by Figure 5 (cont) as B29 at reference coordinate C5. The NRW Building centerline geographical coordinates are zone 18s, easting 568006.11 m, northing 4407544.25 m using the UTM coordinate system.

The NRW Building is inside the RCA. The NRW was put into operation circa 1980 to replace and abandon many ORW storage and processing systems. Some areas contain retired radwaste components. There have been incidences of tanks overflowing and resin spills over the course of plant operation. Incidents of area contamination on the 23 foot elevation have occurred as recent as the date of HSA revision 0. The percentage of alpha level 2 (significant) classifications for NRW Building contaminated areas is 74%. The SL-T-2A spent resin tank room has been identified as alpha level 3 (elevated), the highest classification. Most suspect contaminated systems do not have an alpha classification representing a data gap requiring further investigation and characterization.

The following table provides radiological conditions at various locations in the NRW Building. The data were collected from surveys available at the time of the HSA.

The data were collected during and following shutdown and permanent defueling as available. Radiological conditions are relative to the time and location collected and may not be representative of actual radiological conditions found during D&D.

Table 9: NRW Building radiological conditions summary. Dose rates are general area.

Table is not all inclusive of survey areas in the NRW Building. Alpha classification is based on current list required by RP- AA- 302.

Map Dose Rate Alpha Number Area mr/hr Classification N3A NRW Truckbay 1.5 - 130 2 N3D Fill Aisle/Liner Storage 5 - 500 2 N3I #2 Sump Room 1 - 12 2 N3N South Operating Gallery 0.5 - 1 2 N3P HP-P-1A High Purity Pump Room <0.2 - 2 2 N3Q WC-P-1B Waste Chem Pump Room 10 - 30 2 N3R WC Valve Area Room 2 - 6 2 N3S WC-P-1A ROOM <2 - 3 2 N3U A Evaporator 2 - 10 2

Page 95 OYSTER CREEK STATION HSA Revision 2

Table 9: NRW Building radiological conditions summary. Dose rates are general area.

Table is not all inclusive of survey areas in the NRW Building. Alpha classification is based on current list required by RP- AA- 302.

Map Dose Rate Alpha Number Area mr/hr Classification N3W B Evaporator 4 - 30 2 N4A A Holdup Tank SL-T-3A 20 - 600 2 N4B B Holdup Tank SL-T-3B 20 - 100 2 N4F CLW Process Valve Area 2 - 8 2 N4H Spent Resin Transfer Piping Room 20 - 200 1 N4K Spent Resin Valve Gallery 2 - 10 2 N4L Pipe Gallery West/Valve Area Resurge Regen 0.5 - 4 1 N5A SLT-1A A Concentrated Liquid Waste Tank 2 - 6 2 N5B SLT-1B B Concentrated Liquid Waste Tank 0.8 - 5 2 N5C WC-F-1A Chemical Waste Filter Room 2 - 5 2 N5D HP-F-1A High Purity Filter Room 2 - 8 1 N5E WC-F-1B Chemical Waste Filter Room 0.5 - 10 2 N5F HP-F-1B High Purity Filter Room 2 - 10 2 N5G S-P-1A CLW Pump Room 0.6 - 15 1 N5I S-P-1B CLW Pump Room 0.5 - 5 1 N5J New Radwaste Sample Sink 0.5 - 8 2 N5O Filter Precoat/Body Feed Room 0.2 1 N5P SL-T-2A Spent Resin Tank 3 - 30 3 N5Q SL-T-2B Spent Resin Tank 20 - 60 2 N5S NRW 48' HVAC Room and Filter 0.1 - 0.6 2 N5U WC-T-1B Chem Waste / Floor Drain Tank 8 - 45 2

Page 96 OYSTER CREEK STATION HSA Revision 2 There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Drains and Sumps

• NRW 1-1 sump northwest corner elevation 23 foot o waste collector tank room elevation 23 foot o waste pump rooms and valve areas elevation 23 foot o passageway by concentrator drain collector tank (23')

o valve areas and electric tray area elevation 38 foot west o change and laundry room elevation 48 foot o air conditioner, personnel sink, and shower elevation 48 foot o heating and ventilation equipment room, expansion tank area, and crane bay elevation 48 foot

• NRW 1-2 sump southeast corner elevation 23 foot o valve areas and spent resin tanks elevation 23 foot south o radwaste concentrator and passageway south and east elevation 23 foot o fill station and pumps elevation 23 foot o radwaste holdup tank and demineralizer rooms elevation 35 foot and 33 foot, respectively.

o valve areas, operating galleries, and passageway east and south of concentrators elevation 38 foot o radwaste filter rooms, concentrated waste tank rooms, and associated pump rooms and operating galleries elevation 48 foot o filter precoat room and passageway elevation 48 foot

• NRW 1-3 sump southwest corner elevation 10 foot pipe chase o truck bay elevation 23 foot o NRW heat exchanger building

Process Sink

• sample sink elevation 48 foot

Subsurface SSC or Tunnels

• pipe chase to NRW elevation 10 foot

• NRW 1-3 sump

• NRW tunnel to ORW

• piping and components of the radwaste system, heating and process steam system, water treatment and distribution system, and electrical conduits

Page 97 OYSTER CREEK STATION HSA Revision 2

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• resin and filter media

• discrete radioactive particles

• tritium

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• system piping and component internal contamination

• embedded piping

• resins

• insulation

• sumps and drains

• sample sink

• bgs concrete exposed to tritium

• soil surrounding the building foundation

• soil surrounding sumps, drains, piping and tunnel connection

Preliminary Classification

The NRW building is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion. 34 Levels of residual radioactivity are expected to exceed USNRC default screening values based on operating history and radiological surveys.

34 MARSSIM 2.2 Class 1 examples: leaks or spills, and initial assessment

Page 98 OYSTER CREEK STATION HSA Revision 2 Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior

• scan and contamination surveys of systems and components

• evaluate embedded piping

• evaluate building sumps and drains

• perform radiological analysis of bgs concrete for tritium contamination and penetration depth

• reassess the alpha level for areas, systems, and components due to extended plant shutdown, inaccessible areas, and gaps in classification

• remediate resins in rooms and cubicles then resurvey

• evaluate cracks in floors and walls below grade that have the potential to spread contamination

• evaluate soil surrounding the building foundation for radiological contamination

• evaluate soil surrounding sumps, drains, piping and tunnel connection for radiological contamination

Page 99 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.31. NRW Chlorination Facility

The NRW Chlorination Facility provides gaseous chlorine for biological growth control and to prevent biofouling of the NRW and AOG closed cooling water heat exchangers.

The NRW Chlorination Facility location is shown by Figure 5 (cont) as B30 at reference coordinate A4. The NRW Chlorination Facility centerline geographical coordinates are zone 18s, easting 567839.80 m, northing 4407445.09 m using the UTM coordinate system.

The NRW Chlorination Facility is outside the RCA and within the PA. There is no record of the NRW Chlorination Facility being contaminated or used as a RAM storage area.

The NRW Chlorination Facility is currently maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the NRW Chlorination Facility.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

Preliminary Classification

The NRW Chlorination Facility and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is projected based on the above discussion and data gaps to support a non- impacted classification. 35

Recommended Future Investigation Activities

• scan and contamination survey of the building interior up to 2 meters (6 feet)

• scan and contamination survey of the building exterior and roof

35 MARSSIM 2.2 Class 3 examples: areas with very low potential for residual contaminationbut insufficient information to justify a non- impacted classification

Page 100 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.32. OCAB

The OCAB serves as the main office building at the site. The OCAB was constructed circa 1994 replacing the MOB as the primary office and administrative center.

Preconstruction soil sampling and analyses could not be located. The OCAB location is shown by Figure 5 (cont) as B31 at reference coordinate D2. The OCAB centerline geographical coordinates are zone 18s, easting 568102.48 m, northing 4407342.60 m using the UTM coordinate system.

The OCAB is outside the RCA and within the PA. Radioactive mixed gamma sealed sources for the WBC are stored in the OCAB 1st floor. These sources are leak checked on a periodic basis. All leak test criteria have been satisfied; no leaking sources have been identified. Beginning in 2019, small containers of potentially contaminated soil and water have been prepared and surveyed on the 3 rd floor for shipping to offsite laboratories for analysis.

The OCAB is currently maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the OCAB.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

• remaining carpet

Page 101 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The OCAB is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is projected based on the above discussion and data gaps to support a non- impacted classification. 36

Recommended Future Investigation Activities

• scan and contamination survey of the building interior up to 2 meters (6 feet)

• scan and contamination survey of the building exterior and roof

• remove carpet or perform 100% direct frisk survey

36 MARSSIM 2.2 Class 3 examples: areas with very low potential for residual contaminationbut insufficient information to justify a non- impacted classification

Page 102 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.33. ORW Building

Description and Historical Use

The ORW Building houses the systems associated with the various radwaste collection and processing systems. The ORW Building includes the sample pump house at the north- west corner, HEPA storage building, compactor area, control room, and overboard radiation monitor room. The ORW Building location is shown by Figure 5 (cont) as B32 at reference coordinate D3. The ORW Building centerline geographical coordinates are zone 18s, easting 568039.81 m, northing 4407487.57 m using the UTM coordinate system.

The ORW Building is inside the RCA. The ORW Building was the original radwaste processing plant until updated by the construction of the NRW building circa 1980.

Many of the systems, controls and indications have been abandoned including the overboard radiation monitor; however, there are systems and components still in use with the main plant and NRW systems. High dose rates and contamination are expected based on design and use. There have been incidences of tanks overflowing and resin spills over the course of plant operation. Some vaults accessible from the roof are suspected to contain retired radwaste components and other waste. The percentage of alpha level 2 (significant) classifications for ORW Building contaminated areas and systems are at 66% and 33% respectively. The ORW tank room has been identified as alpha level 3 alpha (elevated), the highest classification. Some ORW system breaches have identified alpha level 3 alpha conditions. About 20% of suspect contaminated systems do not have an alpha classification representing a data gap requiring further investigation and characterization.

The following table provides radiological conditions at various locations in the ORW Building. The data were collected from surveys available at the time of the HSA.

The data were collected during and following shutdown and permanent defueling as available. Radiological conditions are relative to the time and location collected and may not be representative of actual radiological conditions found during D&D.

Table 10: ORW Building radiological conditions summary. Dose rates are general area.

Table is not all inclusive of survey areas in the ORW Building. Alpha classification is based on current list required by RP- AA- 302.

Map Dose Rate Alpha Number Area mr/hr Classification PBA Small Pump Room, Waste Storage Tanks 30 - 350 2 PSB ORW Control and Precoat Room 0.1 - 2.8 2 PUA Large Pump Room and Mezzanine 2 - 6 2 PUU Old Radwaste Tank Room 8 - 22 3

Page 103 OYSTER CREEK STATION HSA Revision 2

The roof area may have been radiologically impacted from the radionuclides released during operation of the isolation condensers.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

The ORW Building includes a loading ramp, but not the area below it. That area is included under the RCA yard surface and subsurface survey area (7.2.1.3.8 and 7.2.1.5.2).

Basement

• small pump room elevation 6 foot

Drains and Sumps

• 1-9 sump large pump room elevation 22 foot o large tank room elevation 23 foot o outside tank area curbed area drains o large pump room elevation 23 foot

• 1- 10 sump small pump room elevation 6 foot o small pump room elevation 6 foot o concentrated waste storage area o waste surge tank curbed area elevation 23 foot (possibly abandoned) o filter sludge tank and demineralizer cubicles o precoat room

• 1- 11 sump small pump room elevation 6 foot o centrifuge o spent resin tank o demineralizer drains waste and fuel pool cooling o concentrator distillate o filter drains o clean sample drains

Process Sink

• sample sink elevation 23 foot

Page 104 OYSTER CREEK STATION HSA Revision 2

Subsurface SSC or Tunnels

• 1- 10 and 1-11 sumps

• small pump room

• concentrated waste tank (NV-28)

• filter sludge tank (NV-09)

• spent resin tank (NV-29)

• NRW tunnel to ORW

• ORW tunnel to base of stack

• piping and components of the radwaste system, heating and process steam system, water treatment and distribution system, and electrical conduits

• ORW ventilation

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• resin and filter media

• discrete radioactive particles

• tritium

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• system piping and component internal contamination

• embedded piping

• resins

• insulation

• sample sink

• sumps and drains

• soil surrounding the building foundation

• soil surrounding tanks, sumps, drains, piping, pipe tunnels and other below grade SSCs

Preliminary Classification

The ORW Building and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

Page 105 OYSTER CREEK STATION HSA Revision 2 An initial MARSSIM Class 1 designation is projected based on the above discussion. 37 Levels of residual radioactivity are expected to exceed USNRC default screening values based on operating history and radiological surveys.

37 MARSSIM 2.2 Class 1 examples: leaks or spills, and initial assumption

Page 106 OYSTER CREEK STATION HSA Revision 2 Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior

• scan and contamination surveys of systems and components

• evaluate embedded piping

• evaluate building sumps and drains

• evaluate cracks in floors and walls below grade that have the potential to spread contamination

• perform radiological analysis of bgs concrete and soil for radiological contamination and penetration depthreassess the alpha level for areas, systems, and components due to extended plant shutdown, inaccessible areas, and gaps in classification

• remediate resins in rooms and cubicles then resurvey

• open and explore legacy waste concentrator vaults for retired components and waste

• evaluate soil surrounding building foundation for radiological contamination

• evaluate soil surrounding tanks, sumps, drains, piping, tunnels and other below grade SSCs for radiological contamination

Page 107 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.34. ORW North Annex

Description and Historical Use

The ORW North Annex is a prefabricated metal structure attached on the north side of ORW at the door to the entrance to ORW operating aisle. The ORW North Annex was used as a trash sorting area and for Non- Destructive Examination (NDE) equipment storage. The ORW North Annex has been abandoned in place. The ORW North Annex location is shown by Figure 5 (cont) as B33 at reference coordinate C4. The ORW North Annex centerline geographical coordinates are zone 18s, easting 568005.96 m, northing 4407488.19 m using the UTM coordinate system.

The ORW North Annex is inside the RCA. The ORW North Annex has been used mostly as a trash sorting area. It was also used as a control point for work inside of the ORW. Some of the annex was contaminated during the recovery of the ORW drum conveyor area (now HEPA storage room) according to the historical records.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• discrete radioactive particles

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

Page 108 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The ORW North Annex is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification. 38 . Levels of residual radioactivity are not expected to exceed the USNRC default screening values based on operating history and radiological surveys. The ORW North Annex would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior and roof

38 MARSSIM 2.2 Class 1 examples: leaks or spills, and initial assessment

Page 109 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.35. Pretreatment Building

Description and Historical Use

The Pretreatment Building houses the tanks, pumps, and systems for processing raw well water to supply domestic and makeup water. The Pretreatment Building has been abandoned in place. The Pretreatment Building location is shown by Figure 5 (cont) as B34 at reference coordinate B2. The Pretreatment Building centerline geographical coordinates are zone 18s, easting 567930.11 m, northing 4407363.44 m using the UTM coordinate system.

The Pretreatment Building is outside the RCA and within the PA. There is no record of the Pretreatment Building being contaminated or used as a RAM storage area.

The Pretreatment Building is currently maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the Pretreatment Building.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

Page 110 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Pretreatment Building is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is projected based on the above discussion and data gaps to support a non- impacted classification. 39

Recommended Future Investigation Activities

• scan and contamination survey of the building interior up to 2 meters (6 feet)

• scan and contamination survey of the building exterior and roof

39 MARSSIM 2.2 Class 3 examples: areas with very low potential for residual contaminationbut insufficient information to justify a non- impacted classification

Page 111 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.36. RCA OSSC

Description and Historical Use

The RCA OSSC is a steel -reinforced concrete structure similar in size and shielding characteristics to standard casks to ship radioactive waste (e.g., dewatered resin liners).

The RCA OSSC is currently empty. The RCA OSSC location is shown by Figure 5 (cont) as B33 at reference coordinate C4. The RCA OSSC centerline geographical coordinates are zone 18s, easting 568048.15 m, northing 4407514.05 m using the UTM coordinate system.

The RCA OSSC is inside the RCA. THE RCA OSSC was used to store high dose rate radioactive material until packaged for shipment as waste.

The OSSC concrete lid may have been radiologically impacted from the radionuclides released during operation of the isolation condensers.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• interior floor and walls

• external walls and concrete lid

Preliminary Classification

The RCA OSSC is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification. 40 The RCA OSSC cask is a good candidate for waste disposal.

Recommended Future Investigation Activities

• scan and contamination survey of the OSSC interior

• scan and contamination survey of the OSSC exterior and concrete lid

40 MARSSIM 2.2 Class 1 examples: initial assumption

Page 112 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.37. Reactor Building

Description and Historical Use

The Reactor Building houses the reactor vessel, spent fuel, spent fuel and equipment storage pits, drywell, torus, primary coolant system, and auxiliary systems necessary for plant operation. The primary containment system consisted of the drywell, vent pipes, and a pool of water contained in the torus. The Reactor Building is shown by Figure 5 (cont) as B35 at reference coordinate C4. The Reactor Building centerline geographical coordinates are zone 18s, easting 567986.81 m, northing 4407459.10 m using the UTM coordinate system.

The Reactor Building is inside the RCA. High dose rates and contamination are expected based on design and use. There have been incidences of tanks overflowing and spills over the course of plant operation. In recent years there has been leakage of contaminated liquid to the Reactor Building during cavity flood up. The percentage of alpha level 2 (significant) classifications for Reactor Building contaminated areas and systems are at 44% and 73% respectively. There are currently no known alpha level 3 (elevated) classified areas or systems. About 20% of suspect contaminated systems do not have an alpha classification representing a data gap requiring further investigation and characterization.

All Control Rod Drive Mechanisms (CRDM) were removed from the under vessel and shipped offsite following shutdown and permanent defuel. All SNM was removed from the vessel and is stored in the SFP, 95 foot elevation cage or 37 foot elevtion TIP shields. The reactor vessel is partially assembled with moisture separator and steam dryer in their normal configuration. Cleanup and removal of RAM on the 119 foot elevation were in progress during development of the HSA.

The following table provides radiological conditions at various locations in the Reactor Building and drywell. The data were collected from surveys available at the time of the HSA. The data were collected during and following shutdown and permanent defueling as available. Radiological conditions are relative to the time and location collected and may not be representative of actual radiological conditions found during D&D.

Table 11: Reactor Building and drywell radiological conditions summary. Dose rates are general area. Table is not all inclusive of survey areas in the Reactor Building. Alpha classification is based on current list required by RP-AA- 302.

Map Dose Rate Alpha Number Area mr/hr Classification IAA DW 13 Foot 60 - 100 2 IAC DW CRD and Subpile Room 80 - 450 2 IBA DW 23 Foot 12 - 25 2 ICA DW 46 Foot 8 - 40 1

Page 113 OYSTER CREEK STATION HSA Revision 2

Table 11: Reactor Building and drywell radiological conditions summary. Dose rates are general area. Table is not all inclusive of survey areas in the Reactor Building. Alpha classification is based on current list required by RP-AA-302.

Map Dose Rate Alpha Number Area mr/hr Classification IEA DW 82 Foot 20 - 60 1 RB1 Torus Room -19 Foot 1 - 2 2 RBB RB -19 Foot North-East Corner Room 0.1 - 0.2 1 RBC Containment Spray Pump Room South- East 0.2 - 2.5 1 RBE CRD Pump Room and Core Spray Pumps 0.3 - 3 1 RBF RBEDT Room and Core Spray Pumps 3 - 70 1 RBS Top of Torus 0.2 - 0.5 1 RC2 Elevator Pit <0.2 - 0.2 1 RC5 Railroad Airlock 0.4 - 1.6 1 RC6 Drywell Labyrinth <2 - 10 1 RCA North Scram Dump 7 - 70 1 RCB Laundry Drain Tank and Pumps <2 - 4 1 RCS South Scram Dump 2 - 25 1 RCT RB 23 Foot General Area <0.1 - 5 1 RD8 Shutdown Cooling Pump Room 4 - 22 1 RDM TIP Drive Area 0.4 - 1.2 1 REF Shutdown Cooling Heat Exchanger Room 2 - 28 1 REO Noble Metals Area 3 - 80 1 REQ Cleanup System Pump Area 0.1 - 8 2 RER Cleanup System Valve Nest 30 - 120 1 RET Cleanup Filter Sludge Pump Room 120 - 300 2 REY RB 51 Foot General Area 0.1 - 2 1 RFC Cleanup Valve Aisle and Control Area 5 - 100 2 RFH Old Fuel Pool Heat Exchanger/Pump Area 1 - 8 1 RFL Control Rod Drive Rebuild Room <0.1 - 1 1 RFQ RB 75 Foot General Area 0.2 - 8 1 RGF Recirc Seal Rebuild Room 2 - 10 2 RGU RB 95 Foot General Area <0.3 - 1 1

Page 114 OYSTER CREEK STATION HSA Revision 2

Table 11: Reactor Building and drywell radiological conditions summary. Dose rates are general area. Table is not all inclusive of survey areas in the Reactor Building. Alpha classification is based on current list required by RP-AA-302.

Map Dose Rate Alpha Number Area mr/hr Classification RH3 Reactor Building 119 Foot 0.1 - 5 1 RH5 RB Roof 0.2 - 0.8 1 RHA Reactor Cavity 18 - 34 2 RHD Equipment Storage Pool 8 - 15 2 RHL Refuel Bridge 1 - 3 2

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Basement

• core spray pump room northwest corner room elevation -19 foot

• containment spray pump room northeast corner room elevation - 19 foot

• containment spray pump room southeast corner room elevation - 19 foot

• control rod drive (CRD) system pump room northwest elevation -1 foot

• reactor building equipment drain tank (RBEDT T 001) southwest elevation -6 foot

• drywell elevation 13 foot

• torus elevation - 19 foot

Drains and Sumps

• 1-6 sump northeast corner room elevation -19 foot o north CRD module area: 9 floor drains and 2 hub drains o shutdown cooling room: 2 floor drains o core spray booster pump area on elevation 51 foot: 2 hub drains o contaminated tool crib elevation 51 foot: 1 floor drain o north end of elevation 75 foot: 4 floor drains and 1 hub drain o north end of elevation 95 foot: 4 floor drains and 1 hub drain o northwest corner room: floor drain o laundry and lab tank overflow and drains

Page 115 OYSTER CREEK STATION HSA Revision 2

• 1-7 sump southeast corner room elevation 19 foot o south CRD module area elevation 23 foot: 8 floor drains and 1 hub drain o reactor water cleanup (RWCU) area elevation 51 foot: 3 floor drains o reactor building closed cooling water (RBCCW) area elevation 51 foot: 2 floor drains o cleanup filters, demineralizer, and precoat mixing area elevation 75 foot: 3 floor drains o CRD rebuild area elevation 75 foot: 8 floor drains o south end of reactor building elevation 95 foot: 4 floor drains o southwest corner room: 1 floor drain o RBEDT pump seal and overflow o 1- 6 sump (gravity)

• RBEDT southwest elevation -6 foot o elevation 19 foot: 2 hub drains o elevation 23 foot: 6 hub drains, vents, and drains from the scram discharge volume, CRD nest pan drains o elevation 51 foot: 13 hub drains from the cleanup system area and the shutdown cooling room.

o elevation 75 foot: 8 hub drains from various equipment o elevation 95 foot: 10 hub drains o post accident sampling system (PASS) drains (non- accident) o trunion room: 1 hub drain

• Lab Drain Tank northwest corner elevation 23 foot o chemistry lab drains

• Laundry Drain Tank northwest corner elevation 23 foot o cask wash down area elevation 119 foot

• Drywell 1-8 sump under vessel elevation 6 foot o various equipment leakage (unidentified) o local power range monitor (LPRM) seal tubes o drywell equipment drain tank (DWEDT) overflow and vent o drywell recirculation fan cooler drip pan drains

• DWEDT between Alpha and Echo Recirculation Pumps elevation 12 foot o recirculation pump seal leakage o reactor head vents o recirculation loop suction and discharge valve stem leak off o refueling bellows seal assembly drains o RWCU inlet valve V-16-1 stem leak off

Process Sink

• cleanup sample sink elevation 51 foot

• reactor water sample sink elevation 75 foot

Page 116 OYSTER CREEK STATION HSA Revision 2

Subsurface SSC or Tunnels

• core spray pumps and system

• containment spray pumps and system

• recirculation pumps and system

• torus suppression pool

• CRD pump and system

• RBEDT

• 1- 6 sump

• 1- 7 sump

• 1- 8 sump

• DWEDT

• reactor building tunnel to base of stack

• reactor building exhaust ventilation

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• neutron activation products

• resin and filter media

• high activity fission products

• discrete radioactive particles

• tritium

• SNM

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• system piping and component internal contamination

• embedded piping

• contaminated and activated steel and concrete

• resins

• insulation

• sumps and drains

• bgs concrete exposed to tritium

• sand bed region

• soil surrounding building foundation

• soil surrounding tanks, sumps, drains, piping, pipe tunnels and other below grade SSCs

Page 117 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Reactor Building and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification. 41 Levels of residual radioactivity are expected to exceed USNRC default screening values based on operating history and radiological surveys.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior

• scan and contamination surveys of systems and components

• evaluate embedded piping

• evaluate building sumps and drains

• evaluate cracks in floors and walls below grade that have the potential to spread contamination

• perform radiological analysis of bgs concrete and soil for radiological contamination and depth

• evaluate drywell steel liner to assess activation and depth

• evaluate concrete samples to assess activation and depth

• remediate resins in rooms and cubicles then resurvey

• perform radiological analysis for high activity fission products during vessel segmentation and SFP cleanout

• evaluate the sand bed region

41 MARSSIM 2.2 Class 1 examples: leaks or spills, and initial assumption

Page 118 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.38. Respirator Facility

Description and Historical Use

The Respirator Facility is primarily used to issue and store respirator equipment and parts. There is a radioactive source permanently assigned to the area to perform instrument response checks. The facility is also used to store RMS equipment.

The Respirator Facility location is shown by Figure 5 (cont) as B36 at reference coordinate B4. The Respirator Facility centerline geographical coordinates are zone 18s, easting 567931.36 m, northing 4407473.65 m using the UTM coordinate system.

The Respirator Facility is inside the RCA. The Respirator Facility, also known as the Cleaning and Maintenance Facility, was constructed in 1986. The purpose was to receive, clean, survey, inspect, repair, test, sanitize, package, store, and issue respirators. The facility included a HEPA filtered system ventilation unit to remove contaminants exhausted from the capture velocity hood. The HEPA ventilation system is not running and interviews indicate the system has not been running for more than a decade. The General Dynamics respirator cleaner and associated equipment have not been used for over a decade. That respirator cleaner and equipment location is currently in a posted contaminated area accessible by door from the north and east.

The Respirator Facility is currently maintained free of radioactive contamination (no posted contaminated areas); however, there are radioactive systems in the Respirator Facility.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• discrete radioactive particles

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• system piping and component internal contamination

• insulation

Page 119 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Respirator Facility and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification.42 Levels of residual radioactivity are not expected to exceed the USNRC default screening values based on operating history and radiological surveys. The Respirator Facility would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior

• scan and contamination surveys of respirator cleaner and associated equipment

42 MARSSIM 2.2 Class 1 examples: initial assumption

Page 120 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.39. Scaffold Building

Description and Historical Use

The Scaffold Building is a structure located on the south end of NRW used to store scaffold and miscellaneous equipment and material. The Scaffold Building location is shown by Figure 5 as B37 at reference coordinate C4. The Scaffold Building centerline geographical coordinates are zone 18s, easting 568020.68 m, northing 4407532.43 m using the UTM coordinate system.

The Scaffold Building is inside the RCA. The Scaffold Building has been used to store scaffolding material with fixed contamination and HEPA units. Smearable contamination and discrete particles have been found in the past according to historical records.

The Scaffold Building is currently maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the Scaffold Building.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• discrete radioactive particles

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

Page 121 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Scaffold Building is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification.43 Levels of residual radioactivity are not expected to exceed the USNRC default screening values based on operating history and radiological surveys. The Scaffold Building is a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all these buildings.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior and roof

43 MARSSIM 2.2 Class 1 examples: leaks or spills

Page 122 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.40. SEB

Description and Historical Use

The SEB was primarily a support facility for the Emergency Plan housing the Technical Support Center (TSC) until the Station entered phase 3 of decommissioning.

The SEB housed various craft and professional staff, including Reactor/Turbine Services and NDE during outages, on the 2nd floor during plant operation and currently houses personnel supporting the reactor vessel internal segmentation project. Station network systems are located on the 1 st floor. The SEB location is shown by Figure 5 (cont) as B38 at reference coordinate B1. The SEB building centerline geographical coordinates are zone 18s, easting 568024.71 m, northing 4407298.20 m using the UTM coordinate system.

The SEB is outside the RCA and within the PA. A radioactive sealed check source for the Emergency Plan was stored in the TSC on the 1 st floor. These sources were leak checked on a periodic basis. All leak test criteria were satisfied; no leaking sources were identified. The sources have been removed. Radioactive materials were found in the SEB during Operation Clean Sweep in 2001. Gamma spectroscopy of selected items showed plant related radionuclides cobalt -60 and cesium -137. There are some tools and equipment remaining in the Reactor/Turbine Services and NDE areas on the 2nd floor. Naturally occurring radon progeny has been identified in the TSC.

The SEB is currently maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the SEB.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• discrete radioactive particles

Potentially Contaminated Media

• interior floors and walls up to 2 meters (6 feet)

• external walls and roof

• remaining carpet

Page 123 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The SEB is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is projected based on the above discussion and data gaps to support a non- impacted classification. 44

Recommended Future Investigation Activities

• scan and contamination survey of the building interior up to 2 meters (6 feet)

• scan and contamination survey of the building exterior and roof

• remove carpet or perform 100% direct frisk survey

44 MARSSIM 2.2 Class 3 examples: areas with very low potential for residual contaminationbut insufficient information to justify a non- impacted classification

Page 124 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.41. Service Water Monitor Building

Description and Historical Use

The Service Water Monitor Building houses the systems for monitoring contaminated leakage from Reactor Building Closed Cooling Water (RBCCW) to Service Water.

The Service Water Monitor Building location is shown by Figure 5 (cont) as B28 at reference coordinate C3. The Service Water Monitor Building centerline geographical coordinates are zone 18s, easting 568000.32 m, northing 4407481.35 m using the UTM coordinate system.

The Service Water Monitor Building is inside the RCA. The monitoring system has the potential to contain low level internal contamination from routine operation. There is permanent shielding on the detector housing.

The Service Water Monitor Building is currently maintained free of radioactive contamination (no posted contaminated areas); however, there are radioactive systems in the Service Water Monitor Building.

The roof area may have been radiologically impacted from the radionuclides released during operation of the isolation condensers.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• discrete radioactive particles

• tritium

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• system piping and component internal contamination

• insulation

Page 125 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Service Water Monitor Building and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification.45 Levels of residual radioactivity are not expected to exceed the USNRC default screening values based on operating history and radiological surveys. The Service Water Monitor Building would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior and roof

• scan and contamination surveys of systems and components

45 MARSSIM 2.2 Class 1 examples: initial assumption

Page 126 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.42. Stack and Base of Stack

Description and Historical Use

The Stack is a 394 foot reinforced concrete structure (368 feet above grade) linked by tunnels to the Reactor Building, Turbine Building, and both Radwaste Buildings. These tunnels contain piping and air ducts between the buildings and the stack. The tunnels are accessible through a stairway to a concrete block enclosed entrance at grade level directly west of the stack. The Stack and Base of Stack are shown by Figure 5 (cont) as B39 at reference coordinate C3. The Stack and Base of Stack centerline geographical coordinates are zone 18s, easting 568031.02 m, northing 4407451.67 m using the UTM coordinate system.

The Stack and Base of Stack are inside the RCA. The Stack is a concrete structure with a smooth internal surface to minimize particle accretion. The Standby Gas Treatment (SBGT) system filters, piping, and valving are in the Base of the Stack as well as the number 1- 12 sump. Water collecting in the 1- 12 sump is pumped to the NRW Building by two sump pumps. The SFP letdown, condensate resin transfer, Reactor Building resin and filter sludge lines are also in the Base of the Stack. Access restrictions are generally put into place during resin/sludge transfers and SFP letdown due to elevated dose rates on contact with piping and within the general area.

The following table provides radiological conditions at various locations in the Base of the Stack. The data were collected from surveys available at the time of the HSA. The data were collected during and following shutdown and permanent defueling as available. Radiological conditions are relative to the time and location collected and may not be representative of actual radiological conditions found during D&D.

Table 12: Stack and Base of Stack radiological conditions summary. Dose rates are general area. Table is not all inclusive of survey areas in the Stack and Base of Stack. Alpha classification is based on current list required by RP-AA- 302.

Map Dose Rate Alpha Number Area mr/hr Classification 7BA Base of Stack 1-12 Sump 4 2 7CA Base of Stack 4 - 10

• BBA Round Room 0.2 *

• No data available; default classification for contaminated area is alpha level 2

Page 127 OYSTER CREEK STATION HSA Revision 2

The Stack internals are considered internally contaminated the entire height of the stack.

The 1- 12 sump area is a circular room beneath the base of the stack that contains the number1- 12 sump and two associated sump pumps, piping and valves. The area is accessed via down ladders from the ORW pipe tunnel or the Turbine Building pipe tunnel. The area is generally covered with 1 to 2 inches of water due to in leakage of rainwater. The number 1- 12 sump has been known to back up according to the historical records. The area has also been subject to contamination tracked in from the ORW small pump room via the ORW tunnel. The number 1- 12 sump is considered highly contaminated.

The Reactor and Turbine Building tunnels have been contaminated over the years according to the historical records. There has been leaks in the tunnels from steam and condensate systems; rainwater intrusion is also a problem. Parts of the floor are worn from water intrusion. Some piping contains high activity sludge and resins. The ventilation ducts are also internally contaminated.

The round room is adjacent to and entered from the old Boiler House. There is a hatch in the overhead; however, no entry has been made through that hatch since circa 1970s when a boiler stack inside of the Stack was removed after it collapsed.

Numerous spills have occurred in the round room according to the historical records.

Basement

• pipe tunnel (ORW, Turbine Building (TB), and Reactor Building (RB) tunnel)

Drains and Sumps

• 1- 12 sump elevation 6 foot

Subsurface SSC or Tunnels

• 1- 12 sump

• ORW tunnel

• TB tunnel

• RB tunnel

• SBGT system

• RB, TB, ORW ventilation

• heating steam

• 4160 Alternating Current cables

• various radioactive systems including processing and drain lines

• RB exhaust ventilation

Page 128 OYSTER CREEK STATION HSA Revision 2 Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• resin and filter media

• discrete radioactive particles

• tritium

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• system piping and component internal contamination

• embedded piping

• charcoal

• resins

• insulation

• sumps and drains

• bgs concrete exposed to tritium

• soil surrounding stack base and foundation

• evaluate surface and below ground surface soil around buried pipes/previously buried pipes, valves, sumps, and trenches for radiological contamination

Page 129 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Stack and Base of Stack are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data,

§50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification. 46 Levels of residual radioactivity are expected to exceed USNRC default screening values based on operating history and radiological surveys.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior

• scan and contamination surveys of systems and components

• evaluate embedded piping

• evaluate charcoal

• evaluate building sumps and drains

• evaluate cracks in floors and walls below grade that have the potential to spread contamination

• evaluate bgs concrete and soil for radiological contamination and penetration depth

46 MARSSIM 2.2 Class 1 examples: leaks or spills, and initial assumption

Page 130 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.43. Stack RAGEMS

Description and Historical Use

The Stack RAGEMS Building houses the systems associated with the sampling and measurement of discharges to the Stack. Samples pass through radiation monitors that measure the source stream. The Stack RAGEMS Building location is shown by Figure 5 (cont) as B39 at reference coordinate C3. The Stack RAGEMS Building centerline geographical coordinates are zone 18s, easting 56802.09 m, northing 4407441.11 m using the UTM coordinate system.

The Stack RAGEMS is inside the RCA. The sampling system has the potential to contain low level internal contamination from routine operation and unplanned elevated offgas releases. There is reference to contamination to the floor in the past in the historical records. There is permanent shielding in the form of bare lead on the low range detector housing; and the high range detector housing contains a licensed quantity cesium-137 source.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• discrete radioactive particles

• tritium

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• system piping and component internal contamination

• insulation

• soil surrounding building foundation

Page 131 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Stack RAGEMS Building and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification.47 Levels of residual radioactivity are not expected to exceed the USNRC default screening values based on operating history and radiological surveys. The Stack RAGEMS Building would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior

• scan and contamination surveys of systems and components

• evaluate soil surrounding building foundation for radiological contamination

47 MARSSIM 2.2 Class 1 examples: initial assumption

Page 132 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.44. Turbine Building

The Turbine Building houses the turbine generator, condenser bay, turbine building crane, NSSS and auxiliary systems necessary for plant operation. The turbine RAGEMS structure, turbine ventilation, and large component access to the condenser bay are located on the heater bay roof. The Turbine Building location is shown by Figure 5 (cont) as B40 at reference coordinate B3. The Turbine Building centerline geographical coordinates are zone 18s, easting 567931.71 m, northing 4407426.04 m using the UTM coordinate system.

The Turbine Building is inside the RCA. Some systems and components in the turbine basement have been abandoned in place. There have been incidences of tanks overflowing, resin spills, and steam leaks over the course of plant operation. The percentage of alpha level 2 (significant) classifications for Turbine Building contaminated areas and systems are at 43% and 44% respectively. There are currently no known alpha level 3 (elevated) classified areas or systems. About 39% of suspect contaminated systems do not have an alpha classification representing a data gap requiring further investigation and characterization.

The following table provides radiological conditions at various locations in the Turbine Building and condenser bay. The data were collected from surveys available at the time of the HSA. The data were collected during and following shutdown and permanent defueling as available. Radiological conditions are relative to the time and location collected and may not be representative of actual radiological conditions found during D&D.

Table 13: Turbine Building and condenser bay radiological conditions summary. Dose rates are general area. Table is not all inclusive of survey areas in the Turbine Building.

Alpha classification is based on current list required by RP-AA- 302.

Map Dose Rate Alpha Number Area mr/hr Classification TC2 Condenser Bay 0.3 - 8 1 TL2 HI/LO Conductivity Room 1.5 - 10 2 TO2 Turbine Operating Floor (TBOF) 0.1 - 0.3 1 TPE Demineralizer Regen Tank Room 0.8 - 17 1 TS2 Steam Jet Air Ejector Room 0.5 - 7 1 TTA Trunnion Room 8 - 22 2

Page 133 OYSTER CREEK STATION HSA Revision 2 There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Basement

• TB basement 0 foot

• condenser bay elevation 0 foot

Drains and Sumps

• 1-1 sump northwest corner near lube oil purifier area elevation 0 foot o lube oil bay: 3 floor drains and 4 hub drains o TB mezzanine northwest: 3 floor drains and 1 hub drain o flooding from alpha control room (CR) heating ventilation and air conditioning (HVAC) mechanical equipment room: 1 floor drain o turbine building closed cooling water (TBCCW) surge tank overflow piped to mezzanine floor drain o lower cable spreading room: 2 floor drains o bleed off from #2 sprinkler system in lube oil bay

• 1-2 sump northeast corner of drain tank pit area in Condenser Bay elevation -8 foot o drain tank pit: 2 floor drains and 1 hub drain o auxiliary flash tank pump seal leakage

• 1-3 sump northwest corner of the Condensate Pump pit elevation 0 foot o condenser bay: 18 floor drains and 10 hub drains o heater bay: 5 floor drains and 5 hub drains o feed pump room: 9 floor drains and 3 hub drains o condensate storage tank (CST) and demineralized water storage tank (DWST) overflow and drains via condenser bay to floor drain o 1-1 Sump via condenser bay floor drain o condensate transfer pump house sump via cst overflow line o turbine building underfloor sumps 1-13, 1-14, and 1-15 o northeast access corridor: 1 floor drain o south access between mechanical vacuum pump room and feed pump room:

1 floor drain and 1 hub drain

• 1-4 sump southwest corner Hi- Low Conductivity Tank room elevation 0 foot o mechanical vacuum pump room: 3 hub drains o stem jet air ejector (SJAE) room: 1 floor drain and 4 hub drains o hi-lo conductivity tank room: 1 floor drain o condensate demineralizer vault: 3 floor drains o condensate demineralizer area: 2 floor drains

Page 134 OYSTER CREEK STATION HSA Revision 2

• 1-5 sump southwest corner of basement makeup system area elevation 0 foot o south basement: 15 floor drains and 31 hub drains o south mezzanine area: 7 floor drains and 2 hub drains o charlie battery room area: 2 floor drains and 2 hub drains o turbine building under floor sumps 1-16 and TBCCW Heat Exchanger Sump

Process Sink

• sample sink elevation 0 foot

• sample sink elevation 23 foot

Subsurface SSC or Tunnels

• TBCCW pumps and system

• air compressors and system

• condenser and water boxes

• condensate and feed systems

• drain tanks

• reheaters

• moisture separators

• feed pumps and system

• condensate Pumps and system

• 1- 1 sump

• 1- 2 sump

• 1- 3 sump

• 1- 4 sump

• 1- 5 sump

• 1- 13 sum east Feed Pump room

• 1- 14 sump alcove outside SJAE room

• 1- 15 sump alcove outside SJAE room

• 1- 16 sump 1-1 air compressor

• turbine building tunnel to base of stack

• various radioactive systems including processing and drain lines

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• resin and filter media

• discrete radioactive particles

• tritium

• soil surrounding building foundation

• soil surrounding below grade SSCs

Page 135 OYSTER CREEK STATION HSA Revision 2 Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• system piping and component internal contamination

• embedded piping

• resins

• insulation

• sumps and drains

• bgs concrete exposed to tritium

Preliminary Classification

The Turbine Building and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion. 48 Levels of residual radioactivity are expected to exceed USNRC default screening values based on operating history and radiological surveys. Additional characterization might lead to a less restrictive MARSSIM classification for some of the building and systems.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior

• scan and contamination surveys of systems and components

• evaluate embedded piping

• evaluate building sumps and drains

• evaluate cracks in floors and walls below grade that have the potential to spread contamination

• perform radiological analysis of bgs concrete for radiological contamination and penetration depth

• remediate resins in rooms and cubicles then resurvey

• evaluate bgs soil surrounding building foundation and SSCs for radiological contamination

48 MARSSIM 2.2 Class 1 examples: leaks or spills, and initial assumption

Page 136 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.45. Turbine Generator Services Trailer

Description and Historical Use

The Turbine Generator Services Building is a 20 foot trailer that housed maintenance personnel during outages involving turbine and turbine generator work. The trailer is on the Turbine Building roof and is used as a ready room. The Turbine Generator Services Trailer location is shown by Figure 5 (cont) as B41 at reference coordinate B3.

The Turbine Generator Services Building centerline geographical coordinates are zone 18s, easting 567958.72 m, northing 4407414.45 m using the UTM coordinate system.

The Turbine Generator Services Building is inside the RCA. The Turbine Generator Services Building was contaminated in the past according to the historical records.

The Turbine Generator Services Building is currently maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the Turbine Generator Services Building.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

Page 137 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Turbine Generator Services Building and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 2 designation is projected based on the above discussion and data gaps to support a lower classification.49 Levels of residual radioactivity are expected to be at a small fraction of the USNRC default screening values based on operating history and radiological surveys. The Turbine Generator Services Building would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior and roof

49 MARSSIM 2.2 Class 2 examples: areas downwind from stack release points

Page 138 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.46. Turbine RAGEMS Building

Description and Historical Use

The Turbine RAGEMS Building houses the systems associated with the sampling and measurement of discharges from the condensate/feedwater pump room, lube oil area, and TBOF during plant operation. Samples passed through radiation monitors that measured the source streams. The effluent was released outside the Turbine Building.

The Turbine RAGEMS building is on the heater bay roof and has been abandoned in place. The Turbine RAGEMS Building location is shown by Figure 5 (cont) as B42 at reference coordinate B3. The Turbine RAGEMS Building centerline geographical coordinates are zone 18s, easting 567943.36 m, northing 4407455.35 m using the UTM coordinate system.

The Turbine RAGEMS Building is inside the RCA. The sampling system has the potential to contain low level internal contamination from routine operation and unplanned elevated offgas releases. There is reference to contamination to the floor in the past in the historical records. There is permanent shielding in the form of bare lead on the low range detector housing; and the high range detector housing contains a licensed quantity source, current activity is 374 µ Ci of cesium-137.

The Turbine RAGEMS Building is maintained free of radioactive contamination (no posted contaminated areas); however, there are radioactive systems in the Turbine RAGEMS Building.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• discrete radioactive particles

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• system piping and component internal contamination

• insulation

Page 139 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Turbine RAGEMS Building and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification.50 Levels of residual radioactivity are not expected to exceed the USNRC default screening values based on operating history and radiological surveys. The Turbine RAGEMS Building would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior

• scan and contamination surveys of systems and components

50 MARSSIM 2.2 Class 1 examples: leaks or spills, and initial assumption

Page 140 OYSTER CREEK STATION HSA Revision 2 7.2.1.1.47. Warehouse

Description and Historical Use

The Warehouse houses containing stored material including consumable goods and replacement parts on the 1st floor. The 1st and 2nd floor office spaces were occupied by Supply and Purchasing, Station Services, and Maintenance Planning. The Warehouse location is shown by Figure 5 (cont) as B43 at reference coordinate D5. The Warehouse centerline geographical coordinates are zone 18s, easting 568068.59 m, northing 4407591.09 m using the UTM coordinate system.

The Warehouse is outside the RCA and within the PA. The Warehouse is staffed part-time as needed. The 1st and 2nd floor office spaces are abandoned. An RMA/SNM storage and staging area are established in the west Warehouse upper deck by the loading dock. SNM is currently stored in the Warehouse RMA. There was an RMA established on the east Warehouse lower deck; that has been released for unrestricted use.

The Warehouse is maintained free of radioactive contamination (no posted contaminated areas). There are no radioactive systems in the Warehouse.

The roof area may have been radiologically impacted from the radionuclides released during operation of the isolation condensers.

There is potential for trace levels of radioactivity from airborne deposition contamination on the exterior from routine operation and discharge of gaseous effluent, and inside from the movement of personnel and radioactive material between onsite buildings particularly during outages. There is potential for trace levels of contamination in remaining carpet.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• discrete radioactive particles

• SNM

Potentially Contaminated Media

• interior floors and walls

• external walls and roof

• remaining carpet

Page 141 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Warehouse is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 2 designation is projected based on the above discussion and data gaps to support a non- impacted classification. 51 Levels of residual radioactivity are expected to be at a small fraction of the USNRC default screening values based on operating history and radiological surveys. The Warehouse would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for the Warehouse.

Recommended Future Investigation Activities

• scan and contamination survey of the building interior

• scan and contamination survey of the building exterior

• remove carpet or perform 100% direct frisk survey

• removal of SNM and release of RMA storage area

51 MARSSIM 2.2 Class 2 examples: downwind from stack release points

Page 142 OYSTER CREEK STATION HSA Revision 2 7.2.1.2. Storage Tanks

7.2.1.2.1. CST

Description and Historical Use

The CST, also known as T 1, is a vertical vented tank with a capacity of 525,000 gallons. The CST provides makeup volume for the condensate system.

The CST location is shown by Figure 6 as T1 at reference coordinate B3. The CST centerline geographical coordinates are zone 18s, easting 567890.47 m, northing 4407446.62 m using the UTM coordinate system.

The CST is outside the RCA and within the PA. The CST is in a fenced, posted RMA due to the shine dose from the bottom of the tank. There are permanent shielding blocks in the east and north; the shield blocks at the tank are two foot high; and the shield blocks along the east fence are five foot high. The CST has contained reactor coolant, condensate system water, and fuel pool water.

During refuel outages the CST received higher activity water from reactor cavity drain down via the condenser hotwells. This is the major source of the high activity sludge that settles on the bottom of the CST. The CST was decontaminated reducing the CST from a high radiation source to a radiation area source.

The CST has a history of multiple spills and pipe leaks to the surrounding surface and subsurface soil. The CST had underground piping capped and abandoned in place due to a history of leakage. The underground piping was replaced with above ground piping in 1996. A cement pipe tunnel was installed in 1996 between the CST and TB Basement North. This pipe is accessible by removing cement covers over the top of the tunnel. These covers have not been removed since they have been put in place.

There is potential for trace levels of radioactivity from airborne deposition contamination on the tank top from routine operation and discharge of gaseous effluent.

Page 143 OYSTER CREEK STATION HSA Revision 2

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• tritium

Potentially Contaminated Media

• tank internals and vent

• connected systems

• tank exterior and top

• soil surrounding tank and associated valves and piping

Preliminary Classification

The CST is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification. 52 Levels of residual radioactivity are expected to exceed USNRC default screening values based on operating history and radiological surveys.

Recommended Future Investigation Activities

• scan and contamination survey of the tank interior

• scan and contamination survey of the exterior and top

• scan behind permanent shielding

• survey of accessible connected systems

• cores surrounding the tank

• cores within tank to obtain subsurface soil directly below the tank

• evaluate bgs soil in the vicinity of tank and associated buried piping

52 MARSSIM 2.2 Class 1 examples: subjected to remedial actions, leaks or spills, initial assumption

Page 144 OYSTER CREEK STATION HSA Revision 2 7.2.1.2.2. Dirty Oil Tank

Description and Historical Use

The Dirty Oil Tank, also known as T 1, was used to store lubricating oil from the Turbine Building system during maintenance outages. The Dirty Oil Tank was recently used to transfer oil from the lubricating oil system for removal from site. The Dirty Oil Tank location is shown by Figure 6 as T2 at reference coordinate B4. The Dirty Oil Tank centerline geographical coordinates are zone 18s, easting 567886.66 m, northing 4407467.34 m using the UTM coordinate system.

The Dirty Oil Tank was outside the RCA and within the PA. There is no record of the Dirty Oil Tank being contaminated.

There is potential for trace levels of radioactivity from airborne deposition contamination on the tank top from routine operation and discharge of gaseous effluent.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• tank exterior and top

Preliminary Classification

The Dirty Oil Tank was preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

Recommended Future Investigation Activities

The building demolition plan designated the Dirty Oil Tank as structure 38. Although outside the RCA, the Dirt Oil Tank was surveyed for unrestricted release based on the radiologically impacted classification.

A survey and sampling plan for unrestricted release was developed and implemented for the Dirty Oil Tank. The Dirty Oil Tank met the survey and sample release criteria for unrestricted use and was released for demolition. The Dirty Oil Tank was removed intact from the Site as demolition waste.

The footprint of the Dirty Oil Tank is included in the West Protected Area (PA) Non-RCA land area (7.2.1.3.12) and will be radiologically evaluated as part of the same area.

Page 145 OYSTER CREEK STATION HSA Revision 2 7.2.1.2.3. DWST

Description and Historical Use

The DWST, also known as T-12-103, provided makeup volume for the CST and other systems. The DWST location is shown by Figure 6 as T1 at reference coordinate B4.

The DWST centerline geographical coordinates are zone 18s, easting 567886.17 m, northing 4407458.52 m using the UTM coordinate system.

The DWST was outside the RCA and within the PA. The DWST is in a fenced, posted RMA due to the shine dose from the bottom of the CST. The DWST had underground piping capped and abandoned in place due to a history of leakage. The underground piping was replaced with above ground piping in 1998.

The demineralizer water system was cross contaminated with fuel pool water in 1994.

Most of the system was thoroughly flushed; however, pockets of low -level contamination are suspected in dead legs in the Turbine Building. The DWST was decontaminated in 1992.

There is potential for trace levels of radioactivity from airborne deposition contamination on the tank top from routine operation and discharge of gaseous effluent.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• tritium

Potentially Contaminated Media

• tank internals and vent

• connected systems

• tank exterior and top

Page 146 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The DWST was preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

Recommended Future Investigation Activities

The building demolition plan designated the DWST as structure 25. Although outside the RCA, the DWST was surveyed for unrestricted release based on the radiologically impacted classification.

A survey and sampling plan for unrestricted release was developed and implemented for the DWST. The DWST met the survey and sample release criteria for unrestricted use and was released for demolition. The structure including the bottom was demolished to grade (soil). Structural materials were removed from the Site as demolition waste. The reinforced concrete continuous circular foundation remained.

The footprint of the DWST is included in the West Protected Area (PA) Non-RCA land area (7.2.1.3.12) and will be radiologically evaluated as part of the same area.

Page 147 OYSTER CREEK STATION HSA Revision 2 7.2.1.2.4. Liquid Nitrogen Tank

Description and Historical Use

The Liquid Nitrogen Tank, also known as T-23-3, was a leased component of the CAC system used to provide nitrogen for containment inerting during plant operation.

The Liquid Nitrogen Tank has been abandoned in place. The Liquid Nitrogen Tank location is shown by Figure 6 as T3 at reference coordinate C3. The Liquid Nitrogen Tank centerline geographical coordinates are zone 18s, easting 568004.68 m, northing 4407418.52 m using the UTM coordinate system.

The Liquid Nitrogen Tank is outside the RCA and within the PA. There is no record of the Liquid Nitrogen Tank being contaminated or used as a RAM storage area.

The tank is an 11,000- gallon double walled, insulated pressure container with 6 top connections and 4 bottom connections. The tank label has 1986 as a built date, which corroborates with interviews conducted during this evaluation.

The roof area may have been radiologically impacted from the radionuclides released during operation of the isolation condensers.

There is potential for trace levels of radioactivity from airborne deposition contamination on the tank roof from routine operation and discharge of gaseous effluent.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• tank exterior

Preliminary Classification

The Liquid Nitrogen Tank is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

Recommended Future Investigation Activities

The evaluation for Liquid Nitrogen Tank unrestricted release in August 2019 determined that there was no reasonable potential for residual contamination in the tank. The evaluation proposed optional external smear/wipe survey during the breach and separation of the tank from the system.

Page 148 OYSTER CREEK STATION HSA Revision 2 7.2.1.2.5. MFOT

Description and Historical Use

The MFOT is used to store fuel oil for the Boilers and Diesel Generators. The MFOT location is shown by Figure 6 as T4 at reference coordinate D- 3. The MFOT centerline geographical coordinates are zone 18s, easting 568062.78 m, northing 4407458.58 m using the UTM coordinate system.

The MFOT is outside the RCA and within the PA. There is no record of the MFOT being contaminated or used as a RAM storage area.

The roof area may have been radiologically impacted from the radionuclides released during operation of the isolation condensers.

There is potential for trace levels of radioactivity from airborne deposition contamination on the tank roof from routine operation and discharge of gaseous effluent.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• tank exterior and top

Preliminary Classification

The MFOT is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is based on the above discussion and data gaps to support a non-impacted classification. The MFOT would be a good candidate for unrestricted release.

Recommended Future Investigation Activities

• release for unrestricted use

Page 149 OYSTER CREEK STATION HSA Revision 2 7.2.1.2.6. New Demineralized Water Tank

Description and Historical Use

The New Demineralized Water Tank, also known as T 4, is a vertical vented tank with a capacity of 187,700 gallons. The New Demineralized Water Tank was an upgrade to the demineralization system to mitigate tritium release to site storm drains circa 2009. The New Demineralized Water Tank location is shown by Figure 6 as T2 at reference coordinate B4. The New Demineralized Water Tank centerline geographical coordinates are zone 18s, easting 567889.28 m, northing 4407486.33 m using the UTM coordinate system.

The New Demineralized Water Tank is outside the RCA and within the PA. There is no record of the New Demineralized Water Tank being contaminated.

There is potential for trace levels of radioactivity from airborne deposition contamination on the tank roof from routine operation and discharge of gaseous effluent.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• tank exterior and top

Preliminary Classification

The New Demineralized Water Tank is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data,

§50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is based on the above discussion and data gaps to support a non-impacted classification. The New Demineralized Water Tank would be a good candidate for unrestricted release.

Recommended Future Investigation Activities

• release for unrestricted use

Page 150 OYSTER CREEK STATION HSA Revision 2 7.2.1.2.7. ORW Surge Tank

Description and Historical Use

The ORW Surge Tank also known as the Waste Storage Tank (WST) and HP -T-3 is located north of ORW. The tank was designed for condensate quality water between pH 5 and 7.5 as a component of the water management plan. The ORW Surge Tank has been permanently abandoned in place. The ORW Surge Tank location is shown by Figure 6 as T5 at reference coordinate C4. The ORW Surge Tank centerline geographical coordinates are zone 18s, easting 568026.29 m, northing 4407500.32 m using the UTM coordinate system.

The ORW Surge Tank is inside the RCA.

As noted in historical documents, during early service the tank was exposed to less pure water coming from such systems as the floor drain system, the waste collection system, and the waste neutralizing tanks. Subsequently, the bottom of the tank became severely corroded and the tank was placed out of service in the early 1980s. The tank interior was decontaminated to remove all sludge and was then pumped dry to prevent further leakage of contaminated liquid.

The tank was abandoned in 1990 by installing blanks on the tanks flanges in all but two of the pipelines to which it was connected. A safety/environmental determination was initiated in 1996 to permanently isolate the tank from the two remaining lines in the ORW Building and eliminate the possibility of a future leak to the environment by inadvertently filling the tank or due to pipe failure.

Some of the exterior discharge piping was shielded to reduce local dose rates and eliminate a radiological hot spot. The shielding was removed about 10 years ago

Walk down of the ORW Surge Tank and accessible areas of piping and pump confirm system has been abandoned and has not been in use for some time. Blank flanges were observed at the suction to the WST pump adjacent to the tank. A reinforced bulkhead surrounds much of the WST area; spoils from various projects within the RCA are contained within this bulkhead. The current height of spoils is between 4 and 5 feet; volume of spoils is estimated at 300 to 400 cubic yards. Radioactive contamination of the spoils is suspected based on §50.75(g)(1) historical data.

In 1982 core bore sampling was conducted at the ORW Surge Tank. This sampling was completed on 9/29/1982. The radionuclides cobalt -60 and cesium -137 were identified down to a depth of almost 13 feet. The samples did not include analyses for alpha TRU. Alpha TRU are most likely present due to significant fuel failures that occurred while the tank was in use.

Analysis of decay corrected sample analyses indicates that the average concentrations in this area could be below the release criteria; however, there is not a high degree of confidence that all sample concentrations with be less than the release criteria.

Page 151 OYSTER CREEK STATION HSA Revision 2

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• tritium

There is potential for trace levels of radioactivity from airborne deposition contamination on the tank top from routine operation and discharge of gaseous effluent.

Potentially Contaminated Media

• tank internals and vent

• tank exterior and top

• capped systems

• exterior sump/trench

• soils

Preliminary Classification

The ORW Surge Tank is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion. 53 Levels of residual radioactivity are expected to exceed USNRC default screening values based on operating history and radiological surveys.

Recommended Future Investigation Activities

• scan and contamination survey of the tank interior

• scan and contamination survey of the tank exterior and top

• survey of accessible connected systems

• cores surrounding the tank and within the bermed area

• cores within tank to obtain subsurface soil directly below the tank

• assess the alpha level for tank, components, and soils both within the bermed area and around/under the tank

• evaluate soil in the vicinity of SSC associated with the tank for radiological contamination

53 MARSSIM 2.2 Class 1 examples: leaks or spills, and initial assessment

Page 152 OYSTER CREEK STATION HSA Revision 2 7.2.1.2.8. Outdoor Tank and Enclosure

Description and Historical Use

The Outdoor Tank and Enclosure houses two chemical waste (WC -T-3A/3B) and two high purity (HP-T-2A/2B) sample tanks located outdoors between the RB and ORW.

The enclosure is a relatively new addition having been installed circa 1990. Tanks HP-2-2A/2B have been modified to process low -level radioactive effluent for discharge to the 30 inch header via the seal well in the RCA yard. The Outdoor Tank and Enclosure location is shown by Figure 6 as T6 at reference coordinate C3. The Outdoor Tank and Enclosure centerline geographical coordinates are zone 18s, easting 568006.18 m, northing 4407477.12 m using the UTM coordinate system.

The Outdoor Tank and Enclosure is inside the RCA. The tanks normally handle low radioactivity water, but high activity was inadvertently introduced in the past according to the historical documents. High contamination levels are likely after the tanks are drained. The moat and concrete pad have been contaminated in the past. The drain in the moat has capability to go overboard but has been chained in position to the number 1-9 sump. The drain and associated piping are considered contaminated.

An entry in the §50.75(g)(1) historical data show a spill in 2011 that resulted in high levels of contamination. The leak was identified with the chemical waste tank WC-T-3 on waste line 3- 222.

The following table provides radiological conditions in the Outdoor Tank and Enclosure.

The data were collected from surveys available at the time of the HSA. The data were collected during and following shutdown and permanent defueling as available.

Radiological conditions are relative to the time and location collected and may not be representative of actual radiological conditions found during D&D.

Table 14: Outdoor Tank and Enclosure radiological conditions summary.

Dose rates are general area. Alpha classification is based on current list required by RP-AA-302. Although no data was available for the general area system breach has identified alpha up to level 3, the most significant classification.

Map Dose Rate Alpha Number Area mr/hr Classification UAB Outdoor Tank and Enclosure 2 - 6 *

• No data available; default classification for contaminated area is alpha level 2 The roof area may have been radiologically impacted from the radionuclides released during operation of the isolation condensers.

There is potential for trace levels of radioactivity from airborne deposition contamination on the tank and enclosure roofs from routine operation and discharge of gaseous effluent.

Page 153 OYSTER CREEK STATION HSA Revision 2

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• tritium

Potentially Contaminated Media

• tank internals and vent

• tank exterior and top

• connected systems

• concrete

• soil surrounding the tanks, moat/pad, and associated valving and piping

Preliminary Classification

The Outdoor Tank and Enclosure is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data,

§50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion. 54 Levels of residual radioactivity are expected to exceed USNRC default screening values based on operating history and radiological surveys.

Recommended Future Investigation Activities

• scan and contamination survey of tank interiors

• scan and contamination surveys of tank exteriors and tops

• survey of accessible connected systems

• cores surrounding the tank

• assess the alpha level for tanks and components

• evaluate surface and below ground surface soil around the tanks, moat/pad, pipes, and valves for radiological contamination

54 MARSSIM 2.2 Class 1 examples: leaks or spills, and initial assessment

Page 154 OYSTER CREEK STATION HSA Revision 2 7.2.1.2.9. Redundant Fire Water Tank

Description and Historical Use

The Redundant Fire Water Tank, also known as T-9-101, is a 300,000-gallon tank used as an alternate supply to the yard fire water loop. The Redundant Fire Water Tank location is shown by Figure 6 as T7 at reference coordinate A4. The Redundant Fire Water Tank centerline geographical coordinates are zone 18s, easting 567842.69 m, northing 4407495.11 m using the UTM coordinate system.

The Redundant Fire Water Tank is outside the RCA and within the PA. There is no record of the Redundant Fire Water Tank being contaminated or used as a RAM storage area.

There is potential for trace levels of radioactivity from airborne deposition contamination on the tank roof from routine operation and discharge of gaseous effluent.

There is potential for contamination of the ground surface in the vicinity of the tank that has been used for storage of portions of the segmented drywell head.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• tank exterior and top

• concrete and asphalt surface in the vicinity of the tank

Preliminary Classification

The Redundant Fire Water Tank is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data,

§50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is based on the above discussion and data gaps to support a non-impacted classification. The Redundant Fire Water Tank would be a good candidate for unrestricted release.

Recommended Future Investigation Activities

• release for unrestricted use

• evaluate surface in the vicinity of the tank potentially impacted by radiological contamination from storage of segmented drywell head

Page 155 OYSTER CREEK STATION HSA Revision 2 7.2.1.2.10. Sodium Hypochlorite Storage Tanks

Description and Historical Use

The Sodium Hypochlorite Storage Tanks are used to prevent biofouling of the Service and Emergency Service Water Systems. The Sodium Hypochlorite Storage Tanks are shown by Figure 6 as T8 at reference coordinate B3. The Sodium Hypochlorite Storage Tanks centerline geographical coordinates are zone 18s, easting 567888.74 m, northing 4407430.32 m using the UTM coordinate system.

The Sodium Hypochlorite Storage Tanks are outside the RCA and within the PA.

There is no record of the Sodium Hypochlorite Storage Tanks being contaminated or used as a RAM storage area.

There is potential for trace levels of radioactivity from airborne deposition contamination on the tank roofs from routine operation and discharge of gaseous effluent.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

Potentially Contaminated Media

• tank exterior and top

Preliminary Classification

The Sodium Hypochlorite Storage Tanks are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is based on the above discussion and data gaps to support a non-impacted classification. The Sodium Hypochlorite Storage Tanks would be good candidates for unrestricted release.

Recommended Future Investigation Activities

• release for unrestricted use

Page 156 OYSTER CREEK STATION HSA Revision 2 7.2.1.2.11. TWST

Description and Historical Use

The TWST was a vertical, vented tank with a capacity of 750,000 gallons. The TWST was used to store water from the Torus when it is drained for maintenance. It was also used for temporary storage of water waiting to be processed by radwaste. The TWST was abandoned in place, underground piping was cut and capped to support construction of the new demineralizer tank in 2010. The TWST location is shown by Figure 6 as T9 at reference coordinate B4. The DWST centerline geographical coordinates are zone 18s, easting 567879.49 m, northing 4407507.08 m using the UTM coordinate system.

The TWST was outside the RCA and within the PA. Historically when water was put into the tank the particulate settled to the bottom of the tank creating a sludge layer resulting in higher dose rates at the bottom of the tank. Removal of the water increased the dose rates around the tank resulting boundary postings changes. The TWST has been decontaminated in the past.

A valve leaked approximately 50 gallons of liquid to the ground circa 1993. Spills, leaking piping, and use of an externally contaminated fire hose spread contamination to the sand and gravel. This soil and gravel were remediated and removed in drums.

There is potential for trace levels of radioactivity from airborne deposition contamination on the TWST top from routine operation and discharge of gaseous effluent.

Known and Potential Contaminants

• loose and fixed beta-gamma contamination

• loose and fixed legacy alpha TRU contamination

• discrete radioactive particles

• tritium

Potentially Contaminated Media

• tank internals and vent

• connected systems

• tank exterior and top

• surface soil

• subsurface soil

Page 157 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The TWST was preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

Recommended Future Investigation Activities

The building demolition plan designated the TWST as structure 22. Although outside the RCA, the TWST was surveyed for unrestricted release based on the radiologically impacted classification.

A survey and sampling plan was developed and implemented for the TWST. The TWST was released for demolition following the survey and sampling. Contamination controls and environmental sampling were performed during demolition. Additional control to prevent airborne or spread of radioactivity was done by affixing the lower two thirds with a protective coating. The structure including the bottom and sump was demolished to grade (soil). Structural materials were removed from the Site as radioactive demolition waste. The reinforced concrete continuous circular foundation and 4- inch sand layer installed between the top of the foundation and the bottom side of the tank base remained. Almost all the sand layer was collected into B -25 boxes and is being stored in the RAM area adjacent to the Redundant Fire Water Tank as radioactive material.

The footprint of the TWST and reinforced concrete continuous circular foundation are included in the West Protected Area (PA) Non-RCA land area (7.2.1.3.12) and will be radiologically evaluated as part of the same area.

Page 158 OYSTER CREEK STATION HSA Revision 2 7.2.1.3. Land Areas

7.2.1.3.1. East PA Non-RCA

The East PA Non- RCA consisting of 388,024 ft 2 (8.9 acres) location is shown by Figure 7 as L1 at reference coordinate C3. The East PA Non- RCA centerline geographical coordinates are zone 18s, easting 567965.70 m, northing 4407561.24 m using the UTM coordinate system.

The East PA Non- RCA is outside the RCA. Existing SSC are the New Maintenance Building, Clean Rigging and Storage trailers, outage trailer complex, MAC, Drywell Processing Center, Level D materials storage area, and the Warehouse. Most buildings have concrete pad floors.

The area is an RCA buffer zone along the east and northern fence line. Migration of contaminated soil to outside the RCA in this area has occurred since the fence line is chain link fence. Trucks routinely leave the RCA through gate 20 and sometimes through gate 6.

A pile of soil from an excavation by the Condensate Transfer Pump House was stored north of the New Maintenance building in 1997; the soils were sampled with results showing low-level cobalt-60 and cesium -137 radioactivity. The spoils were relocated around the ORW Surge Tank in a newly formed bermed area.

A structure known as the hurricane shelter was in use prior to the MAC Facility to access the Reactor Building and keep storm debris from damaging the equipment in the 460 volt switchgear room. A spill from the SFP migrated from the Reactor Building through a hurricane rollup door in 1984 to an area under the current MAC Facility location according to the historical records.

The area may have been radiologically impacted from the radionuclides released during operation of the isolation condensers.

There is the potential for trace levels of contamination in this area from airborne deposition from routine operation and discharge of gaseous effluent, and from the movement of personnel and radioactive material between onsite buildings particularly during outages. Radioactive material is routinely transported through the area.

Page 159 OYSTER CREEK STATION HSA Revision 2

Known and Potential Contaminants

• beta- gamma contamination

• tritium

Potentially Contaminated Media

• asphalt

• surface soil

• subsurface soil

Preliminary Classification

The East PA Non- RCA is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 2 designation is projected based on the above discussion and data gaps to support a lower classification. 55 The Levels of residual radioactivity are expected to be at a small fraction of the USNRC default screening values based on operating history and radiological surveys. The East PA Non- RCA would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this area.

Recommended Future Investigation Activities

• scan and sampling of asphalt and underlying soil including subsurface

55 MARSSIM 2.2 Class 2 examples: downwind from stack release points, areas handling low concentrations of radioactive materials, and areas onthe perimeter of former contamination control areas

Page 160 OYSTER CREEK STATION HSA Revision 2 7.2.1.3.2. East Wooded Area

Description and Historical Use

The East Wooded Area consisting of 231,216 ft 2 (5.3 acres) location is shown by Figure 7 as L2 at reference coordinate C4. The East Wooded Area centerline geographical coordinates are zone 18s, easting 568296.04 m, northing 4407558.80 m using the UTM coordinate system.

The East Wooded Area is outside the RCA and the PA. This land area is vacant and undeveloped. This area has not been used for the storage of radioactive material.

It has been a wooded area since before the plant went operational. A railroad bed went through this area east and parallel to U.S. Route 9. Access to the area interior is difficult due to interfering vegetation, dense vines, and brush, and is heavily wooded in some areas. Walk downs did not identify soil disturbances associated with using, storing, or burying radioactive materials. The main access road to the plant adjacent to this area is used for radioactive shipments entering and leaving the site.

The area may have been radiologically impacted from the radionuclides released during operation of the isolation condensers.

There is the potential for trace levels of contamination in this area from airborne deposition from routine operation and discharge of gaseous effluent.

Known and Potential Contaminants

• beta- gamma contamination

Potentially Contaminated Media

• surface soil

Page 161 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The East Wooded Area is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 2 designation is projected based on the above discussion and data gaps to support a lower classification. 56 The Levels of residual radioactivity are expected to be at a small fraction of the USNRC default screening values based on operating history and radiological surveys. The East Wooded Area would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this area.

Recommended Future Investigation Activities

• scan and soil sampling of the interior

56 MARSSIM 2.2 Class 2 examples: downwind from stack release points

Page 162 OYSTER CREEK STATION HSA Revision 2 7.2.1.3.3. Main Parking Lot

Description and Historical Use

The Main Parking Lot consisting of 204,072 ft2 (4.7 acres) location is shown by Figure 7 as L3 at reference coordinate D4. The Main Parking Lot centerline geographical coordinates are zone 18s, easting 568282.53 m, northing 4407413.97 m using the UTM coordinate system.

The Main Parking Lot is outside the RCA and the PA. The area is used for vehicle parking and general access to the site since the beginning of 2019. It was the original access way until 2001 modifications opened the north gate to general access. The main access road and area to the east are used for radioactive shipments entering and leaving the site.

The area may have been radiologically impacted from the radionuclides released during operation of the isolation condensers.

There is the potential for trace levels of contamination in this area from airborne deposition from routine operation and discharge of gaseous effluent. Radioactive material is routinely transported through the area.

Known and Potential Contaminants

• beta- gamma contamination

Potentially Contaminated Media

• asphalt

• surface soil

Page 163 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Main Parking Lot is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 2 designation is projected based on the above discussion and data gaps to support a lower classification. 57 The Levels of residual radioactivity are expected to be at a small fraction of the USNRC default screening values based on operating history and radiological surveys. The Main Parking Lot would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this area.

Recommended Future Investigation Activities

• scan and sampling of asphalt and underlying soil

57 MARSSIM 2.2 Class 2 examples: downwind from stack release points

Page 164 OYSTER CREEK STATION HSA Revision 2 7.2.1.3.4. North PA Non-RCA

The North PA Non- RCA consisting of 280,001 ft 2 (6.4 acres) location is shown by Figure 7 as L4 at reference coordinate C2. The North PA Non- RCA centerline geographical coordinates are zone 18s, easting 567955.80 m, northing 4407611.54 m using the UTM coordinate system.

The North PA Non-RCA is outside the RCA. Existing SSC is the LLRWSF and internally contaminated frac tanks stored to the west of LLRWSF.

This area started as a barren sand expanse after construction with the only visible objects being electric poles and a transformer that brought in electrical power from the town of Forked River. This area was in the RCA until the fall of 1979 according to the historical records. As an RCA the yard was used for storage of large trucks, boxes, and equipment. Surveys for release as an RCA were conducted during the summer and fall of 1979. Several items of radiological importance were discovered during this survey according to the historical records and interviews. Several soil locations had radioactivity above release criteria and were marked with paint and shoveled into drums.

Approximately 1,000 yards of soil potentially contaminated with tritium was relocated to the North PA Non-RCA from the service water pipe replacements near AOG according to the historical records. The soils were deposited in two locations: 1) north of Warehouse, 2) east within the PA fence by Gate 8.

Walk downs and historical aerial photographs have identified rubble, spoils, rock, macadam, and debris stockpiles from miscellaneous modifications and projects at the site.

There is the potential for trace levels of contamination in this area from airborne deposition from routine operation and discharge of gaseous effluent, and from the movement of personnel and radioactive material between onsite buildings particularly during outages. Radioactive material is routinely transported through the area.

Page 165 OYSTER CREEK STATION HSA Revision 2

Known and Potential Contaminants

• beta- gamma contamination

Potentially Contaminated Media

• asphalt

• surface soil

• subsurface soil

Preliminary Classification

The North PA Non- RCA is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 2 designation is projected based on the above discussion and data gaps to support a lower classification. 58 The Levels of residual radioactivity are expected to be at a small fraction of the USNRC default screening values based on operating history and radiological surveys. The North PA Non- RCA would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this area.

Recommended Future Investigation Activities

• scan and sampling of asphalt and underlying soil including subsurface

58 MARSSIM 2.2 Class 2 examples: areas handling low concentrations of radioactive materials, and areas on the perimeter of former contamination control areas

Page 166 OYSTER CREEK STATION HSA Revision 2 7.2.1.3.5. North Parking Lot

Description and Historical Use

The North Parking Lot consisting of 137,891 ft 2 (3.2 acres) location is shown by Figure 7 as L5 at reference coordinate B3. The North Parking Lot centerline geographical coordinates are zone 18s, easting 567987.81 m, northing 4407700.62 m using the UTM coordinate system.

The North Parking Lot is outside the RCA and the PA. The area was used for vehicle parking during outages until circa 2002. The area was used for radioactive shipments entering and leaving the site. This area is now vacant and no longer used. A portion of the North Parking Lot is now within the PA following security modifications circa 2004.

In 1982 GPU Nuclear requested and received NRC approval to relocate approximately 17,000 cubic feet of contaminated soil under a §20.302(a) disposal provision. The reason given was to support proper draining and paving near NRW. The disposal method was burial in shallow trenches below a minimum cover of six inches of clean soil. The submittal suggested that the area might be asphalt capped in the future, but this could not be validated. The relocation area was within the site boundary (owner controlled area) but not in an RCA. Sources and personnel interviews place the relocation area somewhere between LLRWSF and the north domestic water pump house; however, the exact location cannot be verified. Evaluation of known soil results indicates levels of residual radioactivity that could exceed USNRC default screening values.

A Radioactive Material Quantities of Concern (RAMQC) area was established in the North Parking Lot to temporarily store moisture separator segments and other Class A, B, and C radioactive materials associated with reactor vessel segmentation in waste containers. There are currently nine tank cassettes stored in the area.

Analysis of decay corrected sample analyses indicates that the average concentrations in this area will be below the release criteria; however, there is not a high degree of confidence that all sample concentrations with be less than the release criteria.

There is the potential for trace levels of contamination in this area from airborne deposition from routine operation and discharge of gaseous effluent, and from the movement of personnel and radioactive material to the parking lot during outages.

Radioactive material was routinely transported through the area.

Known and Potential Contaminants

• beta- gamma contamination

• alpha TRU contamination

Page 167 OYSTER CREEK STATION HSA Revision 2 Potentially Contaminated Media

• asphalt

• surface soil

• subsurface soil

Preliminary Classification

The North Parking Lot is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification.59 Levels of residual radioactivity below the surface could exceed the USNRC default screening values based on operating history and radiological surveys. The North Parking Lot would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this building.

Recommended Future Investigation Activities

• scan and sampling of asphalt and underlying soil including subsurface

59 MARSSIM 2.2 Class 1 examples: disposal site, initial assumption

Page 168 OYSTER CREEK STATION HSA Revision 2 7.2.1.3.6. Northeast Parking Lot

Description and Historical Use

The Northeast Parking Lot consisting of 182,603 ft 2 (4.2 acres) location is shown by Figure 7 as L6 at reference coordinate B4. The Northeast Parking Lot centerline geographical coordinates are zone 18s, easting 568176.53 m, northing 4407681.07 m using the UTM coordinate system.

The Northeast Parking Lot is outside the RCA and the PA. The area is used for vehicle parking and was the general access to the site until the beginning of 2019. A gasoline pumping station is in use to refuel company vehicles. Walk downs did not identify soil disturbances associated with using, storing, or burying radioactive materials. The area and former main accessway were used for radioactive shipments entering and leaving the site.

There is a drainage basin on the east side of the old check point.

The area may have been radiologically impacted from the radionuclides released during operation of the isolation condensers.

There is the potential for trace levels of contamination in this area from airborne deposition from routine operation and discharge of gaseous effluent. Radioactive material was routinely transported through the area.

Known and Potential Contaminants

• beta- gamma contamination

Potentially Contaminated Media

• asphalt

• surface soil

Page 169 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Northeast Parking Lot is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 2 designation is projected based on the above discussion and data gaps to support a lower classification. 60 The Levels of residual radioactivity are expected to be at a small fraction of the USNRC default screening values based on operating history and radiological surveys. The Northeast Parking Lot would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this area.

Recommended Future Investigation Activities

• scan and sampling of asphalt and underlying soil

60 MARSSIM 2.2 Class 2 examples: downwind from stack release points

Page 170 OYSTER CREEK STATION HSA Revision 2 7.2.1.3.7. North Wooded Area

Description and Historical Use

The North Wooded Area consisting of 1,437,538 ft 2 (33 acres) location is shown by Figure 7 as L7 at reference coordinate A3. The North Wooded Area centerline geographical coordinates are zone 18s, easting 568017.30 m, northing 4407854.80 m using the UTM coordinate system.

The North Wooded Area is outside the RCA and the PA. This large land area is generally vacant and undeveloped. Access to the area interior is difficult due to interfering vegetation, dense vines and brush, and is heavily wooded in some areas.

There is an abandoned pre- three mile island (TMI) air sampling building in the north-northeast. There was standing water within the interior, particularly in the east starting behind the fuel pumps. The dominant presence of phragmite, also known as the common reed, in the area indicates damp, sandy soil as observed in flooded brackish areas.

Area walk downs identified soil disturbances associated with the relocation of demolition spoils (soil, brush, concrete, and asphalt) in 2007 from the 2004 DBT project. Almost 1,000 cubic yards were reported to have been relocated there. The results of survey and sampling of debris showed no activity or natural products only except for one composite soil sample that reported trace level cesium -137 that was determined to be background cesium from fallout. The area contained standing water as observed during two different walk downs.

An early decommissioning record claims that sand blast grit was unloaded in this area.

Sandblasting was also performed in this area according to personnel interviews and an earlier decommissioning record.

A water mound located on the south bank of the Intake Canal was constructed in 1967 for the purpose of preventing intrusion of estuarine water from the Oyster Creek intake canal into the ground water. The water mound is a canal filled with fresh water to maintain a pressure head on the freshwater aquifers. estuarine water from the Oyster Creek intake canal into the ground water. The water mound construction was constructed in accordance with the Second Interim Order issued by the New Jersey Board of Public Utility Commissioners on April 22, 1966. The water mound is approximately 1,200 feet long by 30 feet wide at the top, and 15- 20 feet wide at the bottom. The original depth was 8 feet with an overflow drain to ensure a minimum water depth of 1.5 feet. Silt has accumulated in the water mound over the years, reducing the depth considerably. Water was observed in the overflow drain during a walk down indicating that there is water in the canal. Walk down of the water mound perimeter was difficult due to interfering vegetation, phragmite, woods.

There is a swale leading from the north side of the Site to the water mound.

Page 171 OYSTER CREEK STATION HSA Revision 2 There is the potential for trace levels of contamination in this area from airborne deposition from routine operation and discharge of gaseous effluent.

Known and Potential Contaminants

• beta- gamma contamination

Potentially Contaminated Media

• surface soil

• subsurface soil

Preliminary Classification

The North Wooded Area is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is projected based on the above discussion and data gaps to support a non- impacted classification. 61

Recommended Future Investigation Activities

• scan and soil sampling of the interior

• surface water and sediment sample at mound

• scan and contamination survey of the abandoned air sampling building

61 MARSSIM 2.2 Class 3 examples: areas with very low potential for residual contaminationbut insufficient information to justify a non- impacted classification

Page 172 OYSTER CREEK STATION HSA Revision 2 7.2.1.3.8. RCA Yard

The RCA Yard consisting of 130,763 ft2 (3 acres) location is shown by Figure 7 at area L8 at reference coordinate C3. The RCA Yard centerline geographical coordinates are zone 18s, easting 568062.98 m, northing 4407501.84 m using the UTM coordinate system.

The RCA Yard is an outdoor area within the main RCA fence. Existing SSC are the Drywell Processing Center, New Sampling Building, Service Water Monitor Building, Outdoor Tank and Enclosure, Boiler Houses, Stack and Base of Stack, Stack RAGEMS, AOG, ORW Building, area below the ORW Building loading dock (east), ORW North Annex, RCA OSSC, ORW Surge Tank, NRW Building, and Scaffold Building.

The RCA Yard area is used to store radioactive material and containers and support radioactive material and waste shipments. New fuel was stored here temporarily during operation. Radioactive material from segmentation on the Reactor Building 119 foot is being stored in the RCA Yard until these are shipped offsite for disposal.

Many areas in the RCA Yard were the site of spills according to the historical records and interviews. Areas were remediated or paved over to contain radioactive material.

The yard sewer drains are believed to be contaminated from spills and operation of the isolation condensers. The area under the isolation condensers was found contaminated after auto initiation of the isolation condensers in 2007.

The area has been radiologically impacted from the radionuclides released during operation of the isolation condensers.

There is the potential for trace levels of contamination in this area from airborne deposition from routine operation and discharge of gaseous effluent, and from the movement of personnel and radioactive material between onsite buildings particularly during outages. Radioactive material is routinely transported through the area.

Known and Potential Contaminants

• beta- gamma radionuclides

• alpha TRU radionuclides

• tritium

• discrete radioactive particles

Potentially Contaminated Media

• asphalt

• surface and subsurface soil

• buried pipes, pipe vaults/tunnels

Page 173 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The RCA Yard is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion and data gaps to support a lower classification. 62 Levels of residual radioactivity are expected to exceed USNRC default screening values based on operating history and radiological surveys.

Recommended Future Investigation Activities

• scan and sampling of asphalt and underlying soil including subsurface

• perform radiological assessment of storm drains and surrounding soil, particularly under the isolation condensers and ORW loading dock

• collect samples under the ORW loading dock

• perform radiological assessment of pipe vaults/tunnels and surrounding soil

• perform radiological assessment of 30- inch Overboard Discharge pipeline and surrounding soil

62 MARSSIM 2.2 Class 1 examples: leaks or spills, initial assumption

Page 174 OYSTER CREEK STATION HSA Revision 2 7.2.1.3.9. South PA Non-RCA

Description and Historical Use

The South PA Non- RCA consisting of 391,284 ft 2 (9 acres) location is shown by Figure 7 as L9 at reference coordinate D3. The South PA Non- RCA centerline geographical coordinates are zone 18s, easting 568077.49 m, northing 4407342.66 m using the UTM coordinate system.

The PA Non-RCA South is outside the RCA. Existing SSC include the SEB, Building 4 (scheduled for demolition), AOB and Annex (demolished), AOG pipe vault to the stack, Reactor Building pipe vault, Main Gate Security Center, OCAB, MAF, and MFOT. The footing and pad for an early location of the hydrogen bank pad shed is present in the southeast corner. Early site plans showed Trailer 250, now removed, southeast of the SEB. Trailer 250 was used for administrative purposes according to sources contacted. Most buildings have concrete pad floors.

Migration of contaminated soil or resin in this area is suspected to have occurred, particularly in the north along the RCA fence. Soil samples collected between the MFOT and the RCA fence in late summer 1999 showed detectable radioactivity below the release criteria to a depth of 3 feet. Contaminated soil was stored in the bermed area around the MFOT. Soil contamination has been identified in the southwest corner of the AOG at the RCA boundary, possibly under the asphalt as indicated by historical records.

A former on- site Treatment Facility was used for liquids discharged to outfall DSN 004 until 1982. The discharge type was sanitary as opposed to industrial. The structure is long been removed from the Site. The footprint of the Treatment Facility is included in this survey area and will be radiologically evaluated as part of the same area.

There are several vaults located along the southern wall of the Reactor Building. These vaults were used as a form of secondary containment for pipes. The Reactor Building vaults extend 3 to 6 feet from the building connecting the Reactor Building to the Exhaust tunnel. Access to these vaults is via hatches at the 23 foot elevation. The southwest and center hatches are posted and controlled by RP; the southeast hatch allows access, but a portion of the vault is posted and controlled by RP. Radioactive systems (e.g., resin, filter media, and RBCCW lines) are contained within these vaults.

The 30- inch Overboard Discharge Pipeline passes through this area.

There is the potential for trace levels of contamination in this area from airborne deposition from routine operation and discharge of gaseous effluent, and from the movement of personnel and radioactive material between onsite buildings particularly during outages. Radioactive material is routinely transported through the area.

Known and Potential Contaminants

• beta- gamma contamination

• alpha TRU contamination

Page 175 OYSTER CREEK STATION HSA Revision 2

• tritium

Page 176 OYSTER CREEK STATION HSA Revision 2 Potentially Contaminated Media

• asphalt

• surface soil

• subsurface soil

• piping and storm drains

• sediment

• pipe vaults/tunnels

Preliminary Classification

The South PA Non- RCA is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 2 designation is projected based on the above discussion and data gaps to support a lower classification. 63 The Levels of residual radioactivity are expected to be at a small fraction of the USNRC default screening values based on operating history and radiological surveys. The South PA Non- RCA would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this area.

Recommended Future Investigation Activities

• scan and sampling of asphalt and underlying soil including subsurface

• perform radiological assessment of storm drains and surrounding soil

• perform radiological assessment of pipe vaults/tunnels and surrounding soil

• perform radiological assessment of 30- inch Overboard Discharge Pipeline and surrounding soil

63 MARSSIM 2.2 Class 2 examples: areas handling low concentrations of radioactive materials, and areas on the perimeter of former contamination control areas

Page 177 OYSTER CREEK STATION HSA Revision 2 7.2.1.3.10. South Parking Lot

Description and Historical Use

The South Parking Lot consisting of 47,113 ft2 (1.1 acres) location is shown by Figure 7 as L10 at reference coordinate D3. The South Parking Lot centerline geographical coordinates are zone 18s, easting 568087.47 m, northing 4407245.63 m using the UTM coordinate system.

The majority of the South Parking Lot is outside the RCA and the PA. Historical aerial photographs show the parking lot in use in 2002. The area was used for vehicle parking; and tents were occasionally erected for special events. This area is now vacant and no longer used. A portion of the South Parking Lot is now within the PA following security modifications circa 2004. That portion south of the OCAB and SEB and former Gate N1 will be included with the PA land area description and use. Walk downs did not identify soil disturbances associated with using, storing, or burying radioactive materials.

There is the potential for trace levels of contamination in this area from airborne deposition from routine operation and discharge of gaseous effluent.

Known and Potential Contaminants

• beta- gamma contamination

Potentially Contaminated Media

• asphalt

• surface soil

Preliminary Classification

The South Parking Lot is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is projected based on the above discussion and data gaps to support a non- impacted classification. 64

Recommended Future Investigation Activities

• scan and sampling of asphalt and underlying soil

64 MARSSIM 2.2 Class 3 examples: areas with very low potential for residual contaminationbut insufficient information to justify a non- impacted classification

Page 178 OYSTER CREEK STATION HSA Revision 2 7.2.1.3.11. South Wooded Area

Description and Historical Use

The South Wooded Area consisting of 1,600,495 ft 2 (36.7 acres) location is shown by Figure 7 as L11 at reference coordinate D4. The South Wooded Area centerline geographical coordinates are zone 18s, easting 568267.01 m, northing 4407244.25 m using the UTM coordinate system.

The South Wooded Area is outside the RCA and the PA. This large land area is generally vacant and undeveloped. Access to the area interior is difficult due to interfering vegetation, dense vines, and brush, and is heavily wooded in some areas.

Walk downs did not identify soil disturbances associated with using, storing, or burying radioactive materials. There was evidence of past soil disturbance behind the hydrogen bank pad as indicated by mounds nearby. The area contains wetlands and environmentally sensitive areas. There are two storm water outfalls in the area and a small pond to the south. There is an abandoned pre- TMI air sampling building in the south- southeast. There appears to be an old disused dirt road behind the former hydrogen bank pad leading 75 feet west to an old fence. There is no known history of using, storing, or burying radioactive materials in this area.

The South Wooded Area contains a small parcel of land south of the Discharge Canal identified as Block 4, Lot 43 in Ocean Township.65 There is a paved road from Route 9 to JCP&L and other properties formally owned and then leased by OCNGS.

The Oyster Creek, which appeared to be somewhat stagnant, goes through here as well.

A railroad siding entered the South Wooded Area west of route 9. Immediately north of the Discharge Canal the siding divided into two spurs. The railroad siding was used solely for the transport of equipment and materials during the construction of the Station. The railroad siding was not used after 1973, or for the transport of radiological materials or wastes.

There is a storm drainage area located south of the main gate entrance just southeast of the employee parking lot.

There is the potential for trace levels of contamination in this area from airborne deposition from routine operation and discharge of gaseous effluent.

65 Control Points Associates, Inc. Preliminary ALTA/NSPS Land Title Survey Oyster Creek Powerplant

Page 179 OYSTER CREEK STATION HSA Revision 2

Known and Potential Contaminants

• beta- gamma contamination

Potentially Contaminated Media

• asphalt

• surface soil

• surface water

• sediment

Preliminary Classification

The South Wooded Area is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 3 designation is projected based on the above discussion and data gaps to support a non- impacted classification. 66

Recommended Future Investigation Activities

• scan and soil sampling of the interior

• surface water and sediment sample at pond and outfalls

• surface water and sediment sample of the Oyster Creek

• scan and contamination survey of the abandoned air sampling building

66 MARSSIM 2.2 Class 3 examples: areas with very low potential for residual contaminationbut insufficient information to justify a non- impacted classification

Page 180 OYSTER CREEK STATION HSA Revision 2 7.2.1.3.12. West PA Non-RCA

Description and Historical Use

The West PA Non- RCA consisting of 286,001 ft 2 (6.6 acres) location is shown by Figure 7 as L12 at reference coordinate D3. The West PA Non- RCA centerline geographical coordinates are zone 18s, easting 567898.36 m, northing 440739.49 m using the UTM coordinate system.

The West PA Non- RCA is outside the RCA. Existing SSC are Building 4, spare Transformers, Diesel Generator Building, Pre- Treatment Building, Main and Startup Transformers, Chlorination Building, Condensate Transfer Pump House, CST, Demineralizer Tank, new Demineralizer Tank, TWST, and the Maintenance Supervisor Building. The Radiac calibration trailer was located here until demolished circa 2012.

There were other trailers, an ambulance building, and scaffold utility building located here that have been removed. Most buildings have concrete pad floors.

The CST and TWST areas have a history of spills and pipe leaks contaminating surface and subsurface soils outside the area. A valve on the CST froze and broke in 1987 releasing contaminated water to the soil and the CST bottom leaked in 1991.

Underground piping was been replaced or cut and capped. A cement pipe tunnel was installed in 1996 between the CST and TB basement north. This pipe tunnel is accessible by removing cement covers over the top of the tunnel.

Elevated tritium levels were identified in water pumped out of a concrete vault containing ESW cables in 2009. The cause was determined to be from leaks in the 8 inch and 10 inch carbon steel condensate transfer system lines SS -4 and CS-24 respectively.

The storm drainage system may have internal contamination due to CST spill events.

Condition and integrity of underground piping is unknown, so exfiltration from these systems into the soil from joint and crack failures is possible.

There is anecdotal information that soils potentially containing tritium were relocated to a berm surrounding the Diesel Generator.

There is the potential for trace levels of contamination in this area from airborne deposition from routine operation and discharge of gaseous effluent; and from the movement of personnel and radioactive material between onsite buildings particularly during outages. Radioactive material is routinely transported through the area.

An RMA was recently established near the Redundant Fire Water Tank for segmented Drywell and Reactor head pieces until these are shipped offsite for disposal.

Page 181 OYSTER CREEK STATION HSA Revision 2

Known and Potential Contaminants

• beta- gamma contamination

• alpha TRU contamination

• discrete radioactive particles

• tritium

Potentially Contaminated Media

• asphalt

• surface soil

• subsurface soil

• piping and storm drains

Preliminary Classification

The West PA Non- RCA is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 2 designation is projected based on the above discussion and data gaps to support a lower classification. 67 The Levels of residual radioactivity are expected to be at a small fraction of the USNRC default screening values based on operating history and radiological surveys. The East PA Non- RCA would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this area.

The West PA Non- RCA would be a good candidate for further evaluation where additional characterization might lead to a less restrictive MARSSIM classification for some or all this area.

Recommended Future Investigation Activities

• scan and sampling of asphalt and underlying soil including subsurface

• locate CST, DWST, and TWST and 30-inch Overboard Discharge pipeline underground piping and perform integrity evaluation and radiological assessment of piping and surrounding soil

• perform radiological assessment of storm drains and surrounding soil

67 MARSSIM 2.2 Class 2 examples: areas handling low concentrations of radioactive materials, and areas on the perimeter of former contamination control areas

Page 182 OYSTER CREEK STATION HSA Revision 2 7.2.1.4. Subsurface SSC

7.2.1.4.1. Basements, Footings, Tunnels, Pipe Chases, and Piping

Description and Historical Use

The Site will have significant subsurface SSC at the time of D&D. These SSC include Reactor and Turbine Building basements, a portion of the Old Radwaste Building basement, Intake Structure, Discharge Structure, Dilution Water Structure, exhaust tunnel system (i.e., Turbine, Reactor, ORW Building tunnels), NRW Building tunnel, AOG pipe vault to the stack, Reactor Building pipe vault, other vaults associated with the underground piping project, and the sandbed region. These contain internally contaminated systems with a known history of leakage. Leaks within the Reactor Building and Torus room have occurred over the operating history of the site. Structural cracks and loss of embedded piping integrity could lead to radiological contamination of subsurface soils. The structure base and footings are in the water table and may have been impacted by groundwater tritium contamination. The ORW tunnel has significant alpha TRU that requires additional radiological controls even for routine inspection entry or minor maintenance. Most tunnels are infrequently accessed.

Table 15 below displays the lowest floor and bottom -of-slab nominal elevations for below grade structures that are expected to remain in place following demolition of above grade structures. Bottom of slab elevations vary due to slope and location of sumps and connecting tunnel systems. Below grade structure slabs and lower walls are below nominal groundwater elevation in the vicinity of the structure and are expected to be founded on saturated soil.

The majority of piping at Oyster Creek was placed in vaults or tunnels during original construction or as a result of subsequent modifications during the operational phase of the plant. Some piping is direct buried and was subjected to integrity monitoring in accordance with the Underground Piping Program. For example, the offgas 30 inch and 48 inch holdup lines are located in the South PA Non-RCA survey area. The lines are 6 feet to 10 feet bgs running parallel from east to north along the boundaries of Building 3, MOB, and Reactor Building until terminating at the Stack. The lines are direct buried.

Table 16 below displays potentially radiologically contaminated buried pipe types, nominal quantities and locations. The information in Table 16 was taken from Technical Report 116, Oyster Creek Underground Piping Program Description and Status, identified in Subsection 5.3.

Page 183 OYSTER CREEK STATION HSA Revision 2 Table 15 Subsurface Structures

Lowest Bottom of Structure Elevation Slab (nominal (nominal ft) ft)

Reactor Building (-) 19 6 (-) 29 6 Turbine Building (-) 8 (-) 6 to (-) 18 Old Radwaste Building 6 6 3 6 Exhaust Stack (-) 3 (-) 10 Exhaust Tunnels 8 6 to 5 6 to 2 3 New Radwaste Pipe Tunnel 10 6 7 9 Intake Structure (-) 18 (-) 21 IntakeTunnel 0 6 (-) 2 6 U1 Discharge Structure (-) 11 (-) 13 U1 Discharge Tunnel (-) 12 (-) 14 U2 Discharge Structure (-) 11 (-) 13 U2 Discharge Tunnel (-) 16 (-) 18 Dilution Water Structure (-) 15 (-) 18 Dilution Water Discharge (-) 8 (-) 10 Tunnel

Page 184 OYSTER CREEK STATION HSA Revision 2 Table 16 Buried Pipe

System Description Piping Location

Offgas Offgas Holdup Lines 510 of 48 CS Between TB and Stack pipe 400 of 36 CS pipe AOG Supply 100 of 4 CS Between Stack and AOG Bldg Pipe AOG Return 100 of 2 CS Between Stack and AOG Bldg Pipe AOG Sump Drain 175 of 1.5 CS Between AOG Bldg and Boiler Pipe House Condensate Condensate Transfer 25 of 6 Al pipe Condensate Transfer Pumps to TB to TB Condensate Transfer 4 of 12 Al pipe Under slab between NW to CRD corner of RB and TB Condensate Transfer 30 of 10 CS Between Condensate Transfer Pipe Bldg and west wall of TB Condensate Transfer 10 of 6 Al pipe Between Pipe Tunnel and RB Line to RB @ SW corner of RB CST Return 30 of 3 CS Pipe Between CST and NE corner of TB Condensate Pump 30 of 1 CS Pipe Between Condensate Transfer Startup Seal Water Bldg and west wall of TB Condensate for 3 SS pipe S of RB between RB and Pipe RWCU Demin Resin Tunnel Transfer Solid Waste RWCU Demin Resin 3 SS pipe S of RB between RB and Pipe Transfer Tunnel Torus Torus Water Transfer 1000 of 4 CS Between TWST and N face of Water Pipe RB Overboard Overboard Discharge >1000 of 30 From Radwaste discharge tie-Discharge Line CIPP in to Discharge Canal Storm Stormwater Drainage Various Sizes Yard and roof stormwater Sewer and Materials collection, piping and outfall

Page 185 OYSTER CREEK STATION HSA Revision 2 Refer to Sections 7.2.1.1.19, 7.2.1.1.30, 7.2.1.1.33, 7.2.1.1.37, 7.2.1.1.42, 7.2.1.1.44, ,

and 7.2.1.4 for addition detail regarding subsurface SSC.

Known and Potential Contaminants

• loose and fixed beta- gamma contamination

• loose and fixed legacy alpha TRU contamination

• resins

• discrete radioactive particles

• tritium

Potentially Contaminated Media

• interior floors and walls

• external walls

• system piping and component internal contamination

• embedded piping

• concrete

• resins

• tanks, sumps, and drains

• soil surrounding SSC

• buried pipe

Page 186 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Subsurface SSC and all systems within are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

An initial MARSSIM Class 1 designation is projected based on the above discussion. 68 Levels of residual radioactivity are expected to exceed USNRC default screening values based on operating history and radiological surveys.

Recommended Future Investigation Activities

• scan and contamination survey of the structure interior

• perform scan and contamination surveys of systems and components

• evaluate embedded piping

• analyze sediment samples of structure sumps and drains

• evaluate cracks and perform core boring in floors and walls below grade and in the water table

• reassess the alpha level for areas, systems, and components due to extended plant shutdown, inaccessible areas, and gaps in classification

• perform radiological assessment of soil surrounding subsurface SSC

68 MARSSIM 2.2 Class 1 examples: leaks or spills, and initial assumption

Page 187 OYSTER CREEK STATION HSA Revision 2 7.2.1.5. Subsurface Soil

MARSSIM has clear guidance on the conduct of an FSS for land area surface soil; however, it does not provide guidance on FSS for land areas or soils under structures that have subsurface contamination. The soil DCGL developed for a typical site assumes a depth of 15 centimeters (6 inches). Sites that previously went through D&D identified extensive subsurface contamination that required site-specific modelling, dose assessment, and sampling density to support LTP release limits and approach acceptable to the USNRC.

Subsurface soil modelling, dose assessment, and sampling density is beyond the scope of the HSA. Focus will be on the identification and initial classification of known and suspected subsurface areas. The subsurface preliminary classification will be radiologically impacted only with no MARSSIM class designation to avoid confusion with surface soil classification.

7.2.1.5.1. North Parking Lot Subsurface

Description and Historical Use

The North Parking Lot general description was discussed in Section 7.2.1.3.5.

In 1982 GPU Nuclear requested and received NRC approval to relocate approximately 17,000 cubic feet of contaminated soil under a §20.302. The reason given was to support proper draining and paving near NRW. The disposal method was burial in shallow trenches below a minimum cover of six inches of clean soil. The submittal suggested that the area might be asphalt capped in the future, but this could not be validated. The relocation area was within the site boundary but not in an RCA. Sources and personnel interviews place the relocation area somewhere between LLRWSF and the north domestic water pump house; however, the exact location cannot be verified.

Evaluation of known soil results indicates levels of residual radioactivity that could exceed USNRC default screening values.

Analysis of decay corrected sample analyses indicates that the average concentrations in this area will be below the release criteria; however, there is not a high degree of confidence that all sample concentrations with be less than the release criteria.

Known and Potential Contaminants

• beta- gamma contamination

• alpha TRU contamination

Page 188 OYSTER CREEK STATION HSA Revision 2 Potentially Contaminated Media

• subsurface soil

Preliminary Classification

The North Parking Lot Subsurface is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data,

§50.75(g)(1) historical data, and process knowledge.

Recommended Future Investigation Activities

• scan and sampling of subsurface soil

• biased/judgmental locations particularly between LLRWSF, Warehouse, and north domestic water pump house

• consider transect trenching followed by survey and sampling to identify the burial site location

Page 189 OYSTER CREEK STATION HSA Revision 2 7.2.1.5.2. RCA Yard Subsurface

Description and Historical Use

The RCA Yard general description was discussed in Section 7.2.1.3.8.

The RCA Yard has a history of spills and pipe leaks contaminating surface and subsurface soils outside the area. In 1982 GPU Nuclear removed approximately 17,000 cubic feet of contaminated soil from the RCA Yard. The reason given was to support proper draining and paving near NRW. Samples collected in 1982 near the ORW loading dock identified radioactive concentrations exceeding the USNRC default screening values. The radiological conditions under the ORW Surge Tank were discussed in Section 7.2.1.2.7. Contamination was identified south of the Reactor Building following a laundry drain line leak. The RCA Yard includes potentially contaminated subsurface soil under the ORW, ORW Surge Tank, and NRW SSC.

Figure 8 depicts known or suspected areas of subsurface contamination and soil relocations outside the RCA.

Known and Potential Contaminants

• beta- gamma contamination

• alpha TRU contamination

Potentially Contaminated Media

• subsurface soil

Preliminary Classification

The RCA Yard subsurface is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

Recommended Future Investigation Activities

• scan and sampling of subsurface soil

• biased/judgmental locations particularly ORW loading dock, between ORW and MFST, east of NRW by rollup door

• consider transect trenching followed by survey and sampling

• locate Overboard Discharge pipeline and perform integrity evaluation and radiological assessment of piping and surrounding soil

Page 190 OYSTER CREEK STATION HSA Revision 2 7.2.1.5.3. Reactor Building/Turbine Building Subsurface

Description and Historical Use

The Reactor and Turbine Buildings general description was discussed in Section 7.2.1.1.37 and 7.2.1.1.44 respectively.

Leaks and spills are known to have occurred in these structures.

Known and Potential Contaminants

• beta- gamma contamination

• alpha TRU contamination

• tritium

Potentially Contaminated Media

• subsurface soil

Preliminary Classification

The Reactor/Turbine Building Subsurface is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge.

Recommended Future Investigation Activities

• perform core bores of concrete

• perform radiological assessment of drains and sumps

• perform radiological assessment of subsurface soil

Page 191 OYSTER CREEK STATION HSA Revision 2 7.2.1.5.4. South PA Non-RCA Subsurface

Description and Historical Use

The South PA Non-RCA general description was discussed in Section 7.2.1.3.9.

Migration of contaminated soil or resin in this area is suspected to have occurred, particularly in the north along the RCA fence. Soil samples collected between the MFOT and the RCA fence in late summer 1999 showed detectable radioactivity below the release criteria to a depth of 3 feet. Contaminated soil was stored in the bermed area around the MFOT. Soil contamination has been identified in the southwest corner of the AOG at the RCA boundary, possibly under the asphalt as indicated by historical records. The stormwater sewer is suspected to be contaminated.

Known and Potential Contaminants

• beta- gamma contamination

• alpha TRU contamination

Potentially Contaminated Media

• subsurface soil

Preliminary Classification

The South PA Non-RCA Subsurface is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data,

§50.75(g)(1) historical data, and process knowledge.

Recommended Future Investigation Activities

• scan and sampling of asphalt and underlying soil including subsurface

• consider transect trenching followed by survey and sampling

• locate AOG delay piping and perform integrity evaluation and radiological assessment of piping and surrounding soil

• locate Overboard Discharge pipeline and perform integrity evaluation and radiological assessment of piping and surrounding soil

• perform radiological assessment of storm drains particularly AOG south

Page 192 OYSTER CREEK STATION HSA Revision 2 7.2.1.5.5. West PA Non-RCA Subsurface

Description and Historical Use

The West PA Non-RCA general description was discussed in Section 7.2.1.3.9.

The CST and TWST areas have a history of spills and pipe leaks contaminating surface and subsurface soils outside the area. Elevated tritium levels were identified in water pumped out of a concrete vault containing ESW cables in 2009. The storm drainage system may have internal contamination due to CST spill events. Condition and integrity of underground piping is unknown, so exfiltration from these systems into the soil from joint and crack failures is possible. There is anecdotal information that soils potentially containing tritium were relocated to a berm surrounding the Diesel Generator.

Backwash from the pretreatment building discharges to a seepage pit or backwash sump located adjacent to the northwest of the former ambulance building.

The discharge consists of sand-filter backwash water. The discharge is regulated by New Jersey Pollutant Discharge Elimination System (NJPDES) discharge to ground water (DGW) Permit Number NJ 0101966.

Known and Potential Contaminants

• beta- gamma contamination

• alpha TRU contamination

• tritium

Potentially Contaminated Media

• subsurface soil

Preliminary Classification

The West PA Non-RCA Subsurface is preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data,

§50.75(g)(1) historical data, and process knowledge.

Recommended Future Investigation Activities

• scan and sampling of asphalt and underlying soil including subsurface

• consider transect trenching followed by survey and sampling

• locate Overboard Discharge pipeline and perform integrity evaluation and radiological assessment of piping and surrounding soil

• investigate seepage pit

Page 193 OYSTER CREEK STATION HSA Revision 2 7.2.1.6. Intake and Discharge Canals

Description and Historical Use

The Intake and Discharge Canals are associated with the once through cooling of the main condenser and other condensers. The Intake Canal is 499870 ft2 (11.5 acres) and longer in length and larger in volume than the Discharge Canal at 420,140 ft 2 (9.6 acres).

The Intake and Discharge Canals were radiologically impacted in the past from overboard discharges of low- level radioactive liquids and recirculation of sediments to the Intake from Barnegat Bay. The Site received permission in 2001 to dispose of 180,000 cubic yards of previously dredged sediment containing licensed radioactive material pursuant to §20.2002. 69 The radionuclides identified in the sediment attributable to effluents from Oyster Creek were Cobalt -60 and Cesium -137.

The Site is authorized to discharge non- contact cooling water from DSN -004A in accordance with the requirements of the NJPDES permit. Discharge DSN 004 is located south of the land bridge that separates the Intake and Discharge Canals. DSN 004 is an outfall discharge point for storm water runoff, non- contact cooling water from reactor building and emergency service water heat exchangers, and discharge from the 1-5 sump. DSN 004 was also the point of discharge for liquid radioactive waste during the first 20 years of station operation, prior to the initiation of the zero radioactive liquid effluent discharge policy in 1990. The Station resumed radioactive liquid effluent discharges in 2019 following shutdown and permanent defuel. Discharge rate has been substantially reduced with circulation and dilution pumps secured. Flow in the Discharge Canal was designed to flow south to southeast away from the Intake; however, the low discharge rate has been observed to fan backwards to the west and northwest towards the Intake. The site has discharged 1,355,648 gallons to date for a total activity released of 5.9 total Curies.

Figure 9 depicts the Intake and Discharge Canals.

Known and Potential Contaminants

• beta- gamma contamination

Potentially Contaminated Media

• sediment

• wooden retaining walls, pier, and riprap shoring along canal banks

• former train trestle

69 Approval of 10 CFR 20.2002 request to disposeof dredged material - Oyster Creek Nuclear Generating Station (TAC NO. MB1 088)

Page 194 OYSTER CREEK STATION HSA Revision 2 Preliminary Classification

The Intake and Discharge Canals are preliminarily classified as radiologically impacted based on conditions observed during reconnaissance, past and present survey data,

§50.75(g)(1) historical data, and process knowledge.

Recommended Future Investigation Activities

• collect core sediment samples to depth

Page 195 OYSTER CREEK STATION HSA Revision 2 7.2.2. Non-Impacted Areas

There were no non- impacted areas identified. The preliminarily classification as radiologically impacted was based on conditions observed during reconnaissance, past and present survey data, §50.75(g)(1) historical data, and process knowledge, non-impacted classification.

A background reference area provides a location of background measurements used for statistical comparison with survey data. The primary considerations for selecting a background reference area are that the location: 1) is representative of the survey location, 2) non- impacted by site operation. This implies that background reference areas should be reasonably close and upwind of the site to be representative. There are no background reference areas on site since all areas are radiologically impacted.

7.3. Potential Contaminated Media

7.3.1. Surface Soil

Surface soil at the top 15 cm (6 in) layer at the site. The depth reflects the modeling assumptions used to develop the release criteria for surface soil activity. Surface soil can be defined as the thickness of soil that can be measured using scan or scanning techniques. The depth is typically used with modelling to determine scanning instrument MDC.

The MARSSIM addresses surface soil for the FSS survey as it represents a likely scenario for contamination based on §50.75(g)(1) historical data and process knowledge. The survey design allows direct measure of radioactivity using scanning techniques.

7.3.2. Structures

Any installation, facility, structure, or portion thereof that is being considered for RSSI.

Structures may or may not be described by the Decommissioning Safety Analysis Report (DSAR). Some structures described by the HSA may no longer be present onsite and are only included for historical purposes.

The MARSSIM addresses structures for the FSS survey as it represents a likely scenario for contamination based on §50.75(g)(1) historical data and process knowledge. The survey design allows direct measure of surface radioactivity using scanning techniques.

Page 196 OYSTER CREEK STATION HSA Revision 2 7.3.3. Systems

Piping, drains, sewers, sumps, tanks, and other components of fluid handling systems that may or may not be described by the DSAR. Systems were either designed to transport or communicate with radioactive fluids or were inadvertently contaminated during plant operation as documented by Bulletin 80- 10. The HSA does not include plant operating and abandoned system classification as these are likely to be released for unrestricted use and left on site or disposed of as waste.

The MARSSIM does not address systems for the FSS survey. However, systems represent a likely scenario for contamination based on design or inadvertent cross-contamination.

7.3.4. Subsurface Soil

Subsurface is that soil not considered to be surface soil (>15 cm depth). The purpose of RSSI is to locate and define the vertical extent of the contamination. Subsurface RSSI can be intensive in areas where accessibility is limited or where alpha- emitting TRU radionuclides may be present.

The MARSSIM does not address subsurface soil for the FSS survey. However, subsurface soil contamination represents a likely scenario for contamination based on

§50.75(g)(1) historical data and process knowledge.

7.3.5. Surface Water

Surface water includes streams, rivers, certain ditches, and intermittently flowing streams. The RSSI determines whether radionuclides are likely to migrate to surface waters or sediments from surrounding environs or plant operation.

The MARSSIM does not address surface water for the FSS survey. Surface water should not represent a likely scenario for contamination based on §50.75(g)(1) historical data and process knowledge.

7.3.6. Groundwater

Groundwater is subsurface water held underground in the soil or in pores and crevices in rock. The RSSI determines whether radionuclides are likely to migrate to surface waters, sediments, or surrounding area during migration.

The MARSSIM does not address groundwater for the FSS survey. Groundwater represents a likely scenario for contamination based on §50.75(g)(1) historical data and process knowledge.

Page 197 OYSTER CREEK STATION HSA Revision 2 7.3.7. Sediment

Sediment is the accumulation of sand and dirt that settles in the bottom of low energy environments that includes ditches, swales, and the Intake and Discharge Canals.

The MARSSIM does not address sediment for the FSS survey. Sediment represents a likely scenario for contamination based on previous history of overboard discharges and the restoration of overboard radioactive release in 2019.

7.3.8. Miscellaneous

Miscellaneous is a general category of asphalt paving, concrete, paint, and waste piles containing construction spoils that could contain radioactive material.

The MARSSIM does not address this category for the FSS survey. These items represent a likely scenario for contamination based on §50.75(g)(1) historical data and process knowledge.

7.4. Related Environmental Concerns

No other environmental concerns were identified beyond what was discussed in the content.

8. Conclusions

The HSA assessed a total of seventy-eight (78) locations of interest that included SSC, exterior tanks, open land areas, subsurface SSC, subsurface soil, and the Intake and Discharge Canals. All areas and SSC within the site boundary were classified as radiologically impacted. Figures showing the SSC and a Conceptual Site Model (CSM) showing locations of known or suspected contamination are included in the HSA.

A figure showing the location of areas with known or suspected subsurface contamination and relocation of soil from the Radiological Controlled Area (RCA) are also included. The Intake and Discharge Canals are included as a figure as well.

The completed HSA provides the necessary data and technically defensible basis for developing scoping survey plans and further the delineating site into survey units for further and more focused characterization.

Page 198 OYSTER CREEK STATION HSA Revision 2

9. References

9.1. USNRC 10 CFR 20 Standards for the Protection Against Radiation

9.2. USNRC 10 CFR 50.75(g) Reporting and Recordkeeping for Decommissioning Planning

9.3. USNRC 10 CFR 37 Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material

9.4. USNRC 10 CFR 61.55 Waste Classification

9.5. USNRC Bulletin 80-10 Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment, 1980

9.6. USNRC Final Waste Classification and Waste Form Technical Position Papers

9.7. USNRC Health Physics Position HPPOS- 288 Acceptance for Referencing, RADMAN Topical Report (WMG-102, as Revised from WMG -101P)

9.8. USNRC Information Notice 86- 20 Low-level Radioactive Waste Scaling Factors, 10 CFR Part 61

9.9. NUREG-1727 NMSS Decommissioning Standard Review Plan Appendix D ALARA Analysis, 2000

9.10. NUREG-1757 Decommissioning Process for Materials Licensees Volume 1, revision 2

9.11. NUREG-1757 Characterization, Survey, and Determination of Radiological Criteria Volume 2, revision 1

9.12. NUREG/CR- 7021 A Subsurface Decision Model for Supporting Environmental Compliance

9.13. NJAC 7.28- 12 Remediation Standards for Radioactive Materials

9.14. USEPA National Primary Drinking Water Regulations

9.15. NEI 07-07 Industry Groundwater Protection Initiative, 2007

9.16. EPRI 1000093 Preparing for Decommissioning: The Oyster Creek Experience, June 2000

9.17. EPRI 1015500 Final Status Survey and Site Release Experience Report Detailed Experiences 1996 - 2007

Page 199 OYSTER CREEK STATION HSA Revision 2 9.18. EPRI 3002005252 Review of Waste Management Best Practices During Nuclear Plant Decommissioning

9.19. EPRI 3002010610 Nuclear Power Plant Decommissioning Sourcebook

9.20. WMG 102-NP-A Volume 1 RADMAN - A Computer Code

9.21. Oyster Creek Nuclear Generating Station Decommissioning Safety Analysis Report (DSAR), 2018

9.22. White Paper Oyster Creek Site Characterization, revision 0, 2019

9.23. Oyster Creek Generating Station Operation Clean Sweep, 2001

9.24. Oyster Creek Topical Report 116 Oyster Creek Underground Piping Program Description and Status

9.25. HU- AA- 1212 Technical Task Risk/Rigor Assessment, Pre-Job Brief, Independent Third-Party Review, and Post -Job Review

9.26. Abelquist EW. Decommissioning Health Physics A Handbook for MARSSIM Users, 2nd ed. Boca Raton: Taylor & Francis Group; 2014

9.27. Johnson TE, Birky BK. Health Physics and Radiological Health, 4th ed.

Baltimore, MD: Wolters Kluwer/Williams & Wilkins

9.28. Nuclides and Isotopes. Chart of the Nuclides, Seventeenth Edition

9.29. Letter from James McCullough, New Jersey Department of Environmental Protection to Andrea Sterdis, HDI, Radiological Preliminary Assessment Report, (December 2020) including Appendix B Historical Site Assessment (HSA)

Revision 1 (November 2020) dated August 10, 2021

10. Appendices

10.1. Figures and Conceptual Model and Site Diagram showing Classifications

10.2. List of radiological incident files §50.75(g)(1)

10.3. Photo documentation Log

Page 200 OYSTER CREEK STATION HSA

10.1. Figures and Conceptual Model and Site Diagram showing Classifications

Page 201 1 2 3 4 5 6

A

B

C

D

Figure 1: Oyster CreekSiteVicinity

Project: E Oyster Creek Historical Site Assessment Oyster Creek Site

Reference:

741 Route 9 South2018EnvironmentalReport Forked River, NJ 08731Preparer:

Jack McCarthy 9/19/2019 Rev.0

Page 202 1 2 3 4 5 6

Legend A

Oyster Creek Site D-4 L U.S. Highway Route 9 L Expressway

B

C

D

Figure2: Oyster Creek SiteBoundary

Project: E Oyster Creek Historical Site Assessment Oyster Creek Site

Reference:

741 Route 9 South2018EnvironmentalReport Forked River, NJ 08731Preparer:

Jack McCarthy 9/12/2019 Rev.0

Page 203 1 2 3 4 5 6

A

B

C

D

Figure3: Geologic Cross-Section

Project: E Oyster Creek Historical Site Assessment Oyster Creek Site

Reference:

741 Route 9 SouthCSD-DDGS04-6 Forked River, NJ 08731Preparer:

Jack McCarthy 9/19/2019 Rev.0

Page 204 1 2 3 4 5 6

A

B

C

D

Figure4: HydrogeologicCross-Section

Project:

Oyster Creek Historical Site Assessment E

Reference:

Oyster Creek Site Hydrogeologic InvestigationReport 741 Route 9 South Preparer:

Forked River, NJ 08731 JackMcCarthy 9/24/2019 Rev. 0

Page 205 1 2 3 4 5 6

B12

B15 A B18 B14 Legend

B1 AOB C2 B11 B2 AOG D3 B7 B3 Boiler Houses C3B4 Breathing Air Compressor Building B4 B16 B9 B5 Building 3 Old Machine Shop B2 B4 B25 B6 Building 4 Site Storage Building B2 B6 B7 Chlorination Building B3B8 Clean Rigging and Storage Trailers B5

B9 Condensate Transfer Pump House B3 B B5 B17 B8 B10Contractor Trailer Complex (CB&I) C5 B11Diesel Generator Building A2 B12 Dilution Pump House A3 B13 Drywell Processing Center C4 B14 Fire Water Pump House A4 B15 Fish Sample Pond A3 B10 B16 Hazard Collection Building B2 B1 B17 Hot Machine Shop/Hot Tool Room B4 B24 B21 B18 Intake and Discharge Structure A4B19 ISFSI E4C B20Level D Building E5 B3 B21 LLRWSF C5 B22 MAC Facility C4 B23 MAF D2 B24 Main Gate Security Center C3 B25 Maintenance Supervisor Building B5 B26MOB - Office Building B3

MARSSIM Class 3 B2 MARSSIM Class 2 D MARSSIM Class 1 Released for D&D and/or demolished

B23

Figure5: Locationof MajorBuildings

Project:

B19 Oyster Creek Historical Site Assessment E

Reference:

B20 Oyster Creek Site SiteMap 741 Route 9 South Preparer:

Forked River, NJ 08731 Jack McCarthy 11/16/2020 Rev. 1

Page 206 1 2 3 4 5 6

B30 A Legend

B27 New Maintenance Building B4 B28 New Sampling/Service Water Monitor Buildings C3 B29NRW Building C5 B30 NRW Chlorination Facility A4 B34 B40 B36 B31OCAB D2 B32ORW Building D3 B33 ORW North Annex/RCA OSSC C4 B34Pretreatment Building B2 B35Reactor Building C4B B41 B42 B27 B36 Respirator Facility B4 B37Scaffold Building C4 B38 B38SEB B1 B39Stack and Base of Stack/Stack RAGEMS C3 B40Turbine Building B3 B35 B41Turbine Generator Services Trailer B3 B42Turbine RAGEMS Building B3 B43Warehouse D5 B28 B37 MARSSIM Class 3 B39 MARSSIM Class 2 C B33 B29 MARSSIM Class 1Release for D&D and/or demolished B32

B31 B43 D

Figure5: Locationof Major Buildings(cont)

Project: E Oyster Creek Historical Site Assessment

Reference:

Oyster Creek Site Site Map 741 Route 9 South Preparer:

Forked River, NJ 08731 JackMcCarthy 11/16/2020 Rev. 1

Page 207 1 2 3 4 5 6

T7 A Legend

T1 CST/DWST B3 T2 DirtyOil/NewDeminerilizedWater Tank B4 T1 T2 T3 LiquidNitrogenTank C3 T8 T4 MFOT D3 T9 T5 ORW Surge Tank C4 T6 Outdoor TankandEnclosure C3 T7 RedundantFire WaterTank A4 T8 SodiumHypochlorite Storage Tanks B3 T9 TWST B4 B

MARSSIM Class 3 MARSSIM Class 2 MARSSIM Class 1 Release for D&D and/or demolished T3 T6 T5 C

T4

D

Figure 6: Location of Major OutdoorTanks

Project:

Oyster Creek Historical Site Assessment E

Reference:

Oyster Creek Site Site Map 741 Route 9 South Preparer:

Forked River, NJ 08731 Jack McCarthy 11/16/2020 Rev. 1

Page 208 1 2 3 4 5 6

Legend A

East PA Non-RCA PA L1 East Wooded Area OCAL2 Main Parking Lot OCAL3 L7 North PA Non-RCA PA L4 North Parking Lot OCAL5 Northeast Parking Lot OCA L6 North Wooded Area OCA L7 RCA Yard RCAL8 L5 South PA Non-RCA PA L9 B South Parking Lot OCAL10 South Wooded Area OCA L11 West PA Non-RCA PA L12

MARSSIM Class 3 MARSSIM Class 2 MARSSIM Class 1 L4 C

L12 L9 D

L10 L11

Figure 7: Conceptual Site Model

Project:

Oyster Creek Historical Site Assessment E Oyster Creek Site Ref erence::

741 Route 9 South ALTA/NSPS Land Title Survey Forked River, NJ 08731 Preparer:

Jack McCarthy 2/17/2020 Rev. 0

Page 209 1 2 3 4 5 6

Legend A

Impacted - no MARSSIM Class

B

C

D

Figure8: Known orSuspectedSubsurfaceand Soil Relocation Outside the RCA Areas

Project:

Oyster Creek Historical Site Assessment E Oyster Creek Site

Reference:

741 Route 9 SouthHistorical Records and Personnel Interviews Forked River, NJ 08731Preparer:

Jack McCarthy 2/24/2020 Rev. 0

Page 210 1 2 3 4 5 6

Legend A

Impacted - no MARSSIM Class

B

C

D

Figure 9: Intake and Discharge Canals

Project:

Oyster Creek Historical Site Assessment E Oyster Creek Site Ref erence::

741 Route 9 SouthGoogleEarth Forked River, NJ 08731Preparer:

Jack McCarthy 3/4/2020 Rev. 0

Page 211 OYSTER CREEK STATION HSA

10.2 List of radiological incident files §50.75(g)(1)

Page 212

Jack McCarthy, CHP / 2 March 2020 Updated by

Kevin Wolf 2 March 2020 Approved by

Table of Abbreviations and Symbols AOB Auxiliary Office Building CAP Corrective Action Program cc cubic centimeters CFR Code of Federal Regulation CHP Certified Health Physicist Co Cobalt Cs Cesium CST Condensate Storage Tank D&D Deactivation and Decommissioning DBT Design Basis Threat DCGL Derived Concentration Guideline Levels DPR Decommissioning Planning Rule DQO Data Quality Objectives e exponent EDG Emergency Diesel Generator EDMS Electronic Document Management System EF Exhaust Fan EG&G Edgerton, Germeshausen, and Grier ESSF Expanded Safety Systems Facility ESW Emergency Service Water FSS Final Status Survey gpm gallons per minute HSA Historical Site Assessment I Iodine IAW In accordance with Inc. Incorporated IR Issue Report ISFSI Independent Spent Fuel Storage Installation

Page 213 ISRA Industrial Site Recovery Act K Potassium LLRWSF Low Level Radwaste Storage Facility LTP License Termination Plan m meter MAC Monitor and Change Facility MARSSIM Multi Agency Radiation Survey and Site Investigation Manual MDA Minimum Detectable Activity mL milli-Liters Mn Manganese MOB Main Office Building MSI Millennium Services Inc.

NEI clear Energy Institute NJDEP New Jersey Department of Environmental Protection NORM Naturally Occurring Radioactive Material NRC Nuclear Regulatory Commission NRW New Radwaste OC Oyster Creek OCAB Oyster Creek Auxiliary Building OCNGS Oyster Creek Nuclear Operating Station ORISE Oak Ridge Institute for Science and Education ORW Old Radwaste PAR Preliminary Assessment Report pCi/Kg picoCurie per Kilogram pdf portable document format RA Regulatory Assurance RB Reactor Building RCA Radiological Controlled Area RK Rack RP Radiation Protection RPM Radiation Protection Manager SAM Small Article Monitor SCM Surface Contamination Monitor

Page 214 SFP Spent Fuel Pool SIMS Survey Information Management System SIR Site Investigation Report SMCM Subsurface Multi-Spectral Contamination Monitor SRA Shonka Research Associates Inc.

SRRS Standard Records Retention Schedule TRU Transuranics TWST Torus Water Storage Tank U Uranium UTM Universal Transverse Mercator y yard

µCi/cc miie per cubic centim

µCi/gm miie p am

µR c -r i

ions

1. number

< less tn

% perage

Procedure RP-AA- 228 procedure requires a list of information relevant to meeting the requirements of §20.50.75(g)(1) and §72.30(f)(1). This documentation includes records of radiological spills or other unusual occurrences involving the spread of contamination in and around the site. Included in this list were references to other documents and data relevant to decommissioning (e.g., RAM/soil/spoils relocation). Also included were areas currently and formerly designated as restricted areas per §20.1003. Procedure RP-AA-228 requires that this list be updated no less than every two years. This list was last updated 2 December 2019.

Some documents have been scanned into Adobe Acrobat pdf and are retained electronically at K:\\RadCon\\ Radiological Engineering\\ 10CFR50.75(g)(1). Others are maintained in the RP/RA areas or otherwise available electronically. Portions of this list have been revised to reflect terminology used in decommissioning and the MARSSIM.

Page 215

SUMMARY

OF CHANGES DATE ORIGINATOR CHANGE

3/2/2020 J. McCarthy Page 37: Added establishment of outdoor RMA for storage of drywell head segments.

Update required by RP-AA-228 10 CFR 50.75(g) and 10 CFR 72.30(f) Documentation Requirements.

11/25/2019 J. McCarthy Page 32: Added relocation and storage of shield blocks from the RB 119 foot elevation to the RCA yard.

Page 1: Removed RPM approval, which is not required for this list by RP-AA- 228.

10/25/2019 J. McCarthy Added small spill from ORW Control Room to asphalt outside doorway.

Updated 2008 DBT Spoils Release narrative.

Minor editorials associated with transition from Exelon.

3/19/2019 J. McCarthy Added sample results for soil relocation from north of OCAB.

2/19/2019 J. McCarthy Added acronym for UTM, added § symbol page 3, added meter and yard to acronym table, minor formatting.

Added isocondenser picture.

Added entry for area near 30-inch sampling pump discharge.

Added entry for soil relocation from north of OCAB building to north yard.

Updated alpha entry to provide Station permanent shut down date and time, and statement that Station has entered decommissioning.

Page 216

SUMMARY

OF CHANGES DATE ORIGINATOR CHANGE

10/4/2018 J. McCarthy Added entry for leak onto the MOB 3rd floor. Updated Table of Contents to reflect this entry.

Added D&D, §§, mL, and MOB to table of abbreviations and symbols.

3/14/2018 J. McCarthy Add reference to inter-office memorandum dated 29 June 1982 and provide addition description of Technical Data Report 393 - Drains Identification Study.

Update required by RP-AA-228 10 CFR 50.75(g) and 10 CFR 72.30(f) Documentation Requirements. Update completes Decommissioning Transition Organization database action OC- RP-000002- 0002.

7/21/2017 J. McCarthy Added issue report (IR) number 4033552 for hose leak to asphalt in RCA yard.

Corrected typographical errors in Section 39 Compliance with Revised §§ 20.1406 and 20.1011

6/21/2017 J. McCarthy Added issue report (IR) number 2721211, 2016 Leak from Frac Tank to Moat and RCA Yard

3/30/2017 J. McCarthy Added entry for water intrusion into Reactor Building during refuel outage 1R26.

3/9/2017 J. McCarthy Update required by RP-AA-228 10 CFR 50.75(g) AND 10 CFR 72.30(f) Documentation Requirements.

Document compliance with revised §§ 20.1406 and 20.1501.

Page 217

SUMMARY

OF CHANGES DATE ORIGINATOR CHANGE

10/25/2016 J. McCarthy Added entry for leaking FRAC Tank in the RCA yard.

Updated alpha determination following refuel outage 1R26.

2/16/2016 J. McCarthy Update required by RP-AA-228 10 CFR 50.75(g) AND 10 CFR 72.30(f) Documentation Requirements. No changes since last update 8/14/2015.

8/14/2015 J. McCarthy Added summary of changes table; added gamma spectroscopy results from asphalt sampling in former parking lot South of OCAB; minor formatting.

Revision to 2009 Tritium in ESW Vault entry (Table of Contents number 28) to reflect update to original record dated 16 June 2009 based on newer information and references.

Page 218 TABLE OF CONTENTS

1. AUTHORIZED 10 CFR 20.2002 ............................................................................................... 221

2. SURVEY AND SAMPLING PLANS AND ASSESSMENTS FOR OYSTER CREEK ................ 221

3. DECOMMISSIONING COST ESTIMATE ................................................................................ 225

4. DECOMMISSIONING DOSE ESTIMATE ............................................................................... 225

5. CONTAMINATED SOIL

SUMMARY

...................................................................................... 226

6. NORTH PARKING LOT ......................................................................................................... 227

7. CONDENSATE STORAGE TANK .......................................................................................... 227

8. DUMPSTER ........................................................................................................................... 227

9. LEVEL D AREA ..................................................................................................................... 228

10. RCA YARD ............................................................................................................................ 228

11. SOIL SAMPLING PRIOR TO BUILDING THE NEW OFFICE BUILDING ............................... 228

12. SOIL SAMPLING - 250 TRAILER COMPLEX ....................................................................... 229

13. SOIL SAMPLING PRIOR TO ISFSI CONSTRUCTION ........................................................... 229

14. SOIL SAMPLING FOR PROPOSED ESSF ............................................................................ 229

15. SOIL SAMPLING FOR PROPOSED NEW GAS STATION SITE ........................................... 230

16. ORW SURGE TANK .............................................................................................................. 230

17. TWST ..................................................................................................................................... 230

18. DBT PROJECT - 2004 .......................................................................................................... 231

19. MISCELLANEOUS SOIL SAMPLES ..................................................................................... 231

20. OUTDOOR SPILLS ................................................................................................................ 233

21. INDOOR SPILLS ................................................................................................................... 235

22. MISCELLANEOUS ................................................................................................................ 2 36

23. 2006 TRITIUM PROJECT ...................................................................................................... 2 38

24. 2007 CESIUM PROJECT ....................................................................................................... 2 38

25. 2007 ISOLATION CONDENSER INITIATION ........................................................................ 238

26. 2008 DBT SPOILS RELEASE ............................................................................................... 2 39

27. 2009 ISOCONDENSER LEAK ...............................................................................................2 39

28. 2009 TRITIUM IN ESW VAULT .............................................................................................. 2 39

29. 2009 LEAK ON CONDENSATE TRANSFER LINE IN CONDENSER BAY ............................ 240

30. 2010 LEAK FROM FRAC TANK TO MOAT AND RCA YARD ............................................... 240

31. 2011 LEAK FROM ORW CHEMICAL WASTE TANK WC-T-3 TO MOAT.............................. 2 40

32. 2011 AREAS POTENTIALLY IMPACTED BY PLANT OPERATION ..................................... 2 41

33. 2012 ISOLATION CONDENSER INITIATION ........................................................................ 242

34. 2014 TORUS ROOM .............................................................................................................. 242

35. 2015 ASPHALT SAMPLING .................................................................................................. 242

36. 2016 SPILL INTO REACTOR BUILDING FROM REFUEL CAVITY VENT ............................ 242

37. 2016 LEAK FROM FRAC TANK TO MOAT AND RCA YARD ............................................... 242

38. 2017 LEAK FROM HOSE TO RCA YARD ASPHALT DURING TRANSFER ......................... 2 43

39. 2018 LEAK ONTO THE MOB 3RD FLOOR ............................................................................. 243

40. 30- INCH HEADER SAMPLING PUMP DISCHARGE ............................................................. 243

41. SOIL RELOCATION FROM NORTH OF OCAB .................................................................... 244

42. 2019 SMALL SPILL ON ASPHALT OUTSIDE ORW CONTROL ROOM ............................... 245

43. STORAGE OF RB 119 FOOT ELEVATION SHIELD BLOCKS IN RCA YARD ...................... 246

44. COMPLIANCE WITH REVISED §§ 20.1406 AND 20.1011 .................................................... 247

45. STORAGE OF DRYWELL HEAD SEGEMENTS IN OUTDOOR RMA .................................... 248

46. ALPHA DETERMINATION ..................................................................................................... 249

Page 219

47. AREAS CURRENTLY AND FORMERLY DESIGNATED AS RESTRICTED AREAS PER 10 CFR 20.1003 .......................................................................................................................... 2 51

Page 220

1. AUTHORIZED 10 CFR 20.2002

NRC Letter dated 12/14/2001: On December 14, 2001 the NRC issued approval to dispose of previously dredged material pursuant to 10 CFR 20.2002.

This file included:

A. Dredging chronology and sample results

B. Miscellaneous correspondence

RP Calculation OC 009 Radiological Evaluation of the Dredged Material Located on the Former Finninger Farm Property and RP Calculation OC 05 Former Finninger Farm Nuclide Aggregate Assessment Pursuant to 10CFR37 provide additional radiological information relative to the disposed dredge material area.

2. SURVEY AND SAMPLING PLANS AND ASSESSMENTS FOR OYSTER CREEK

A. Document EG&G 11265-1050 - An Aerial Radiological Survey of the Oyster Creek Nuclear Power Plant and Surrounding Area - May 1994: An aerial radiological survey was conducted of the Oyster Creek Nuclear Power Plant and surrounding area in September 1992. The purpose of the survey was to document the terrestrial gamma radiation environment. The survey was conducted at an altitude of 150 feet over a 26 square mile area. The results of the aerial survey were reported as inferred gamma radiation exposure rates at 1 meter above ground. Outside the plant boundary, exposure rates were found to vary between 4 and 10 µR per hour and were attributed to naturally occurring uranium, thorium and radioactive potassium gamma emitters.

B. Document G01- 1275-002 - Site Characterization Plan for the Oyster Creek Nuclear Generating Station - February 1998: The plan, prepared by TLG Services, Inc., included measurements and sampling for radiological and non- radiological contaminants for the following areas of the facility:

• Site Structures

• Site Systems and Equipment

• Neutron- Irradiated Structures and Components

Page 221

• Site Environmental (i.e., land, soil, water).

C. Policy and Procedure Manual 2870- PLN- 4520.02 - Radiological Scoping Survey of the Forked River Site: An Oyster Creek procedure developed to provide methods for conducting a scoping survey of the Forked River site (owner controlled area adjacent to and west of the Oyster Creek Generating Station) using the MARSSIM. The Policy and Procedure Manual included a map of the Forked River site.

D. Forked River Site - Scoping Survey Final Report - July 1998: In support of the divestiture of generation related properties, a radiological scoping survey was performed of selected portions of the site. The survey was performed using the guidelines for class 3 areas in accordance with the MARSSIM. The survey was performed by MSI with support by SRA. The surveys were performed during the period beginning on June 24, 1998 and concluding on June 30, 1998.

Building surveys were performed with the SCM and SIMS. Land surveys were performed with in situ gamma measurements using the SMCM as well as traditional measurements with sodium iodide detectors. Soil samples were obtained and analyzed by Oyster Creek at specific points identified by MSI during the survey. Split samples were provided to representatives of the NJDEP.

Surveys included 21 large area land surveys covering more than 47,000 square feet and floor surfaces in 17 buildings covering more than 11,000 square feet. Survey results from both the building and land surveys did not identify any areas that exceeded the DCGL established by Oyster Creek for this survey.

Page 222 E. NRC Inspection number 50- 219/1999-013: On November 15-18, 1999, NRC staff conducted a safety inspection of the owner controlled area referred as, the Forked River Property, an area adjacent to, and west of Oyster Creek Nuclear Generating Station. The inspection consisted of observations by the inspectors, interviews with personnel, selective examination of records, and a confirmatory survey of Forked River Property conducted under the supervision of NRC by the Environmental Survey and Site Assessment Program of ORISE. NRC determined that Oyster Creek adequately characterized the Forked River Property and conducted adequate surveys to demonstrate that residual radioactive material from plant related activities were well below the dose based release criteria of 10 CFR Part 20, Subpart E Radiological Criteria for License Termination. However, NRC noted that the Switchyard, located adjacent to the intake canal, had been excluded from the scoping survey.

F. Preliminary Assessment Report - Non Radiological - December 1999: A PAR limited to non-radiological issues generated by URS Greiner Woodward Clyde.

G. Due Diligence Sampling Results - 1999: Two binders labeled Volume 1 and Volume 2.

Volume 1 contained a survey and sampling plan, map, and gamma spectroscopy results.

Volume 2 contained gamma spectroscopy results.

H. Site Investigation / Remedial Investigation - Non Radiological - January 2000: URS Greiner Woodward Clyde was retained to provide environmental services at Oyster Creek. The report provided the results for non- radiological concerns from investigations conducted in late 1999 and early 2000.

I. Preliminary Assessment / Site Investigation Report - Radiological - February 2000: A two volume radiological PAR and SIR generated by McLaren/Hart, Inc. The report was assembled based upon discussions with the NJDEP as part of a request for deferral of radiological ISRA investigations and remediation until decommissioning.

Volume 1

• Site History

• Recent Site Operations

• Radioactive substances/Waste inventory

• Description of Wastewater Discharges

• Description of Historic and Current Waste Streams

Page 223

• Areas of Concern

• Radioactive Environmental Soil Results for Co-60

• Radioactive Environmental Soil Results for Cs-137

• Groundwater Monitoring Network and Results

• Underground Process Lines

• Interpretation of Historical Aerial Photographs

• Discharge History of Hazardous Substances and Wastes

• Remediation Activities

• Environmental Permits

• Enforcement Actions

• Figures (Maps)

• Theoretical Release Study Report

Page 224 Volume 2

• Site Investigation - Radiological Report

• Radiological Environmental Monitoring Report - 1998

J. Document 990- 2798 - OCNGS Site Characterization Plan - circa 2000: A detailed document to guide site characterization of Oyster Creek using the MARSSIM.

K. Memo RP 030 - RCA Fence Line Plan - April 2002: A binder containing a survey and sampling plan to support reduction of the RCA. Gamma spectroscopy results and a map are included.

L. Remedial Investigation - Response to October 13 2004 NJDEP Comment Letter - February 2005: The activities described in this report are the remaining non radioactive activities associated with NJDEP comment letter of May 29 2003.

3. DECOMMISSIONING COST ESTIMATE

Decommissioning cost estimate prepared by TLG Services, Inc., in April 1996, document number G01- 1196- 004.

4. DECOMMISSIONING DOSE ESTIMATE

A decommissioning dose estimate was prepared in December 1998 and revised in August 1999, document number 990- 2783. Additional information is included on the common drive under K:\\Radcon\\ Radiological Engineering\\ 10CFR50.75(g)(1)\\Decommissioning Dose Estimates.

Page 225

5. CONTAMINATED SOIL

SUMMARY

Contaminated soil estimate dated 10/30/1998. This memo described potentially contaminated soil areas as:

• Area behind retaining wall, east of dilution pumps (excavated soil)

• Area around torus tank access (small leaks)

• Areas around CST leaks

• Turbine building footprint (pipe leaks and leaks through concrete cracks)

• Old Machine shop (concrete floor cracks)

• Maintenance Building (hot machine shop, decon shower-piping- sump)

• MAC Facility (spill from RB migrated out the hurricane door prior to construction)

• North of Reactor building (spills during water processing)

• South of Reactor building (laundry drain tank line leaked)

• Fuel Oil tank (excavated soil stockpiled here)

• ORW Surge tank (tank leaks)

• ISFSI (berm on south side contains excavated soil)

• North parking lot (excavated soil from yard)

• East of NRW and ORW (resin, water spills and leaks)

• NRW footprint (expansion joints and cracks)

• ORW footprint (expansion joints and cracks)

• ORW storm drains (migration from contaminated soil)

Page 226

6. NORTH PARKING LOT

In 1982 17,000 cubic feet of soil was transferred from the RCA to the area that is now the north parking lot. This soil was covered with six inches of clean soil and was then paved over.

• Letter to the NRC dated 10/27/1982 describes the proposed transfer of soil

• Memo ML82- 15, dated 10/13/1982 describes the radioactivity contained in this soil, about 1.3E-7 µCi/gm up to 4E -5 µCi/gm

• NRC letter, dated 11/16/1982, titled Evaluation of the radiological/environmental impact at GPU Nuclear proposed project for disposal of contaminated soil at Oyster Creek Facility, concurs with Oyster Creeks proposal.

7. CONDENSATE STORAGE TANK

1991 results of tritium in water samples collected by lysimeter from locations both side and down gradient of the condensate storage tank.

• Memo 6630 0005, dated January 3, 1992, titled 10CFR20.302 Submission for Soil Contaminated by Condensate Water Storage Tank Spill

• Soil removed from hole at the condensate storage tank. Samples taken 4/9/2001 Co-60 2.88E-6 µCi/gm up to 8.1E -5 µCi/gm Cs-137 2.21E-7 µCi/gm

8. DUMPSTER

On 9/4/97 a 30 cubic yard dumpster containing a mixture of intake screen debris and very low levels of radiologically contaminated soil was inadvertently transported off site and disposed of in the land fill (CAP O1997- 0686). Soil was returned and placed in an area next to the ORW Surge Tank.

Page 227

9. LEVEL D AREA

Memo 6630- 92-0110, dated July 27th, 1992, titled Level D Area Soil Sampling.

10. RCA YARD

In 1982 soil sampling was conducted in support of a project to pave the RCA Yard. See memo WTL 82- 49 dated 10/5/1982 titled Soil Sampling Program in support of the RCA Paving Project.

• Soil sample results are as follows:

Co-60 <MDA to 39,066 pCi/Kg Cs-137 <MDA to 28,366 pCi/Kg Cs-134 <MDA to 1,822 pCi/Kg Mn-54 <MDA to 2,256 pCi/Kg

In May, 2002 a portion of the RCA yard was released. Memo RP 030 was written on April 15th, 2002 defining the criteria for this release. Direct surveys and sampling was conducted to support this release.

11. SOIL SAMPLING PRIOR TO BUILDING THE NEW OFFICE BUILDING

Prior to construction of the new OCAB soil sampling was conducted (see memo 6632- 93-008A dated 5/6/1993). Soil was sampled at the surface, 1 foot depth and 2 foot depth at 11 different locations. All but two locations were less than MDA. These two locations were the grass area by the hydrogen storage tanks and the grass/dirt area between the main parking lot and the main road. Follow up sampling was conducted in July 1993.

Page 228

12. SOIL SAMPLING - 250 TRAILER COMPLEX

Soil sampling was conducted, during 1994, in the dirt contractor parking lot, south of the paved heliport parking lot, prior to paving this area. Additional sampling was conducted in 1995 at the surface and at a depth of 3 feet (see memo 95- 0008- C dated 3/16/1995).

13. SOIL SAMPLING PRIOR TO ISFSI CONSTRUCTION

Initial samples were taken, on 8/6/1992, in the area north of the contractor parking, including all of level D storage and the fuel pump area. Soil samples were collected from various areas in and around the level D storage and current gas station site. See memo 6632- 93- 006A dated 4/13/1993.

14. SOIL SAMPLING FOR PROPOSED ESSF

Samples were collected between June 15th and June 18th, 1985 in preparation for excavation of the ESSF (see memo 9300 0638 dated 10/15/1985). Core borings were taken along the torus drain line in the ESSF construction site (see memo 9300- 85-0659 dated 11/1/1985). Sample depth was approximately 5 feet with results showing no detectable activity.

• In 1986 three soil samples were taken to support the RCA fenceline relocation to support this project.

Co-60 1.21E-6 to 5.29E-6 µCi/gm Cs-137 6.62E-7 to 2.81E-6 µCi gm

In 1985 Oyster Creek requested permission from the NRC (IAW 10CFR20.302) to relocate soil to allow for excavation for this project (see letter to Region I dated 12/13/1985)

Page 229

15. SOIL SAMPLING FOR PROPOSED NEW GAS STATION SITE

In preparation for construction of a new gas station soil was sampled at the surface, 1 foot depth and 2 foot depth at five different locations. See memo 6632 019A dated 8/16/1993.

16. ORW SURGE TANK

In 1982 core bore sampling was conducted at the ORW Surge Tank. This sampling was completed on 9/29/1982. The 1982 ORW Surge Tank samples did not include analysis for transuranics. Transuranics are most likely present due to significant fuel failures that occurred while this tank was in use. Forty-two samples were evaluated.

• Activity results ranged as follows:

Co-60 <MDA to 79,807 pCi/Kg Cs-137 125 to 125,780 pCi/Kg Cs-134 <MDA to 1654 pCi/Kg Mn-54 <MDA to 484 pCi/Kg

Reference memo dated 8/17/1983 titled Transmittal of information concerning Planned Decontamination under Old Radwaste Surge Tank.

Reference memo dated 4/9/1984 titled Summary Documentation Concerning Probable Sump near Old Rad Waste

Reference memo dated 1/27/1984 titled Transmittal of Radiological Environmental Data Concerning Surge Tank Soil Samples

17. TWST

Memo 9410- 86-1078 dated 6/13/1986 describes a sampling plan for relocating the RCA fence-line at the TWST.

Page 230

18. DBT PROJECT - 2004

Soil sampling was conducted as part of the DBT project conducted in 2004.

19. MISCELLANEOUS SOIL SAMPLES

• 3/21/86 Soil taken between the fuel oil storage tank and the railroad truck bay:

Co-60 8.54E-6 µCi/gm Cs-137 2.68E-6 µCi/gm

• 4/1/86 Soil removal for Drywell Chiller Pad Installation (Memo 9300- 86-0073 dated 4/1/86) 504 cubic feet of soil was removed with low levels of Co- 60 and Cs-137 and distributed in a non-paved area of the RCA yard

• 5/19/95 Soil samples were taken at accessible locations to support construction of the site protective barriers. All of the samples showed no activity greater than background.

Samples were taken on the surface and at a depth of 1 foot along the south side of the access road to LLRWSF as well as surface samples taken inside the nuisance fence at gate 6

• 11/9/95 Samples of dirt removed from the area between the New Maintenance Building and the Drywell Processing Center were analyzed by Chemistry and found to have no activity greater than background

• 7/16/99 Soil samples taken during excavation at the EDG building:

Cs-137 9.36E-8 µCi/gm

• 8/19/99 Three dirt samples were taken just east of the ORW north Annex:

Co-60 1.28E-6 µCi/gm to 1.02E -5 µCi/gm Cs-137 6.45E-7 µCi/gm to 7.00E-6 µCi/gm Mn-54 <MDA µCi/gm to 4.62E-7 µCi/gm

• 8/27/99 Soil samples were taken east of the reactor building to support work on a service water pipe elbow:

Page 231 Co-60 7.56E-7 µCi/gm to 1.39E-6 µCi/gm Cs-137 1.68E-6 µCi/gm to 2.04E-6 µCi/gm

• 1/6/00 Surface soil mound west of south parking lot identified NORM

• 1/6/00 Surface Soil Behind Dilution Pump identified NORM

• 1/6/00 Surface Soil by Main Fuel Oil Storage Tank identified NORM

• 4/18/01 Soil samples taken at the dirt pile north of the New Maintenance Building Co-60 <MDA to 6.98E-7 µCi /gm Cs-137 <MDA to 6.98E-8 µCi/gm

• 11/8/02 West of NRW in RCA - five Samples taken Co-60 <MDA to 4.12E-8 µCi /gm Cs-137 4.52E-8 µCi/gm to 7.13E-8 µCi/gm

• 10/16/03 South Side of Warehouse Cs-137 2.16E-8 µCi/gm

• 2/24/04 Outside Turbine Building northwest Corner Co-60 6.06E-8 µCi/gm Cs-137 2.12E-7 µCi/gm

• 2/24/04 Canal Roadway sample identified NORM

• 4/28/05 Sludge sample taken at the intake identified NORM

• 12/19/05 15 soil samples taken at the proposed overflow parking lot identified NORM. Map of sample locations included in the file.

• 2/1/06 Soil samples taken at the proposed overflow parking lot identified NORM. Map of sample locations included in the file.

• 9/1/06 Soil samples taken at the dilution structure during excavation for a cable installation identified NORM.

• 2/22/07 2007 Chemistry results for well monitoring identified NORM.

Page 232

20. OUTDOOR SPILLS

IR 449393, 2/2/2006, On Feb. 02, 2006 during demobilization from the Alpha Main Condenser tube cleaning performed via Work Order C2010694, the brushes used to clean the water box tubes unexpectedly alarmed the SAM. The condenser water boxes are maintained as radiologically clean areas during power operation as well as during maintenance activities. Through interviews and walk down of the job, it was discovered that the water supply used to brush clean the condenser tubes was from the Condensate Transfer system, not Demineralized Water as stated in procedure 2400- SMM-3302.01, Main Condenser Cleaning, Inspection, and Tube Testing. The consequence of this event is the potential for an unmonitored radiological release to the discharge canal via the water box outlet valves. An estimated discharge of 11,250 gallons of condensate transfer water occurred.

CAP 2004- 3502, 11/6/2004, two shoe contaminations occurred due to a spill in the RCA yard.

CAP O2004- 1127, 5/8/2004, radioactive material was found on and inside of a storm drain east of NRW within the RCA. A barrel, which was previously used to contain radioactive water (mop water) was used without resurveying or reissuing. It was then (possibly) used for transporting heat exchanger water (sea water) to the storm drain for disposal. Samples collected of the silt in the storm drain revealed Co- 60, Cs-137, Mn-54 and K-40 in the range of 1.67E- 6 µCi/gm to 1.39E -5

µCi/gm. Material was removed from on and inside the storm drain.

CAP O2004- 0266, 2/1/2004, the makeup system to the deairator tank failed and overfilled the dearator. The overflow drain system routed the water to the west aux flash tank (CH-T-5). The drain line for CH-T-5 was frozen and the water spilled onto the ground at the southwest corner of the boiler house (within the RCA). Approximately 100 gallons was spilled. The liquid was sampled and with Cs-137 activity between 2.32E-8 µCi/cc to 2.45E -8 µCi/cc.

CAP O2003-2089, 10/11/03, a small sink hole was discovered, inside the RCA, on the north side of New Rad Waste. Soil samples taken in the sink hole, at a depth of one to two feet, identified Cs-137 activity between 1.65E- 7 µCi/gm to 7.61E -7 µCi/gm.

Page 233 CAP O2003- 2152, 10/17/03, a soil sample was taken under #2 boiler flash tank (under CH-HV-260) due to a weld that was leaking approximately 5 drops/minute. The flash tank is located within the RCA. Sample results identified Co- 60 at 4.54E-7 µCi/gm and Cs -137 activity at 1.11E-5

µCi/gm.

CAP O2003-1201, 6/10/03, while aligning EF-1-7 for a start per procedure 328, approximately 3 to 5 gallons of water came out of the bottom of the fan. It came from the seam at the bottom on the south end of the fan. Water drained for several minutes. The fan was successfully started once the water stopped. It did drip slightly from the bottom in several spots once the fan was running and stopped approximately one minute later.

CAP O2003- 0562, 3/22/03, March 22, 2003 at 1530 a temporary modification for the transfer of water from the Radwaste/Chemwaste system to the TWST was to be removed. This modification had been in place for months due to the freezing of the fire hose. Warm weather had come and Maintenance/Operations wanted to remove the line. Operations began to blow down the line, the drains were partially plugged up and water flowed through out the moat. Water did over flow the moat side and the job was stopped by RP.

CAP O2003-0143, 1/24/03, the #2 boiler flash tank and its drain line were found frozen after prolonged freezing weather.

CAP O2002- 1960, 12/15/02, water leaking from various points on EF 1-6 exhaust duct to the main stack. Approximately 36 gallons of water were drained from the EF 1- 6 plenum and placed in the 1-12 sump. RP smeared areas in question and no contamination was reported. It is suspected that there was steam coming from NRW exhaust duct, possibly from evaporator vent condenser, and condensing and collecting in the EF 1-6 plenum. Problems with the evaporator operation had been occurring and may be the cause of the steam being introduced into the ventilation exhaust

CAP O2001-0024, 1/5/01, a leak was found on the patch installed on CH-T- 005 per TM-MV-2001- 2 at 18:30. The leakage was contained, sampled, and the patch was tightened. The leak was stopped. The leak was estimated at 1gal/hr. It was estimated that approximately 2 gallons were lost to the ground from the time the leak was found till it was contained. The sample contained 2.07E-7 µCi/cc Cs137

Page 234

21. INDOOR SPILLS

Letter dated 8/20/1987 titled Building 3 Floor, northwest area of High-Bay, Contamination Levels

Spills within buildings inside the RCA (CAP Summaries):

• O2004- 0006 RK04

• O2004- 0329 Reactor building 75 elevation west

• O2003- 2287 V-2-659

• O2003- 2311 Cond Demin Regen Room

• O2003- 2395 Reactor building 75 elevation Drum Evaporator area

• O2003- 2387 Reactor building 23 elevation north side

• O2003- 2599 Cond Demin Regen Room

• O2003- 2627 NRW Heat Exchanger Room

• O2003- 0009 NRW truck bay

• O2003- 0039 NRW 23 elevation west walkway

• O2003- 0836 ORW Large Pump room P 4A

• O2003- 0913 Boiler House

• O2003- 0937 NRW SL-P-3A/3B

• O2003- 1030 V-2-716

• O2003- 1057 Reactor building 75 elevation Valve Gallery

• O2003- 1062 Reactor building 75 elevation at precoat tank

• O2003- 1084 Condensate pump pit

• O2003- 1210 Cond Demin Regen Room

• O2003- 1229 Cond Demin Regen Room

• O2003- 1238 Cond Demin Control Room

• O2003- 1396 WC-P-2B seal leak

• O2003- 1428 Bravo CRD pump seal water leak

• O2003- 1566 Hi- Lo Conductivity Room

• O2003- 1828 Floor Drain/Chem Waste Collector tank overflow

• O2003- 1883 Heater Bay/Feed pump room

• O2002- 0043 Reactor building 75 elevation north

• O2002- 0058 Torus room bay #7

• O2002- 0062 CH-P-1B

• O2002- 0260 New Rad Waste 38 elevation

• O2002- 0257 Hot Chem Lab

• O2002- 0344 New Rad Waste Heat Exchanger Room

• O2002- 0481 Hi- Lo Conductivity room

• O2002- 0572 New Rad Waste 23 elevation at SL-T-2A

• O2002- 0663 V-2-621

• O2002- 0672 SL-P-3A/3B

• O2002- 0727 Condenser Bay

• O2002- 0872 Hi- Lo Conductivity Room

• O2002- 1060 1-5 Demin tank access

• O2002- 1118 SL-P-3B Cubicle

Page 235

• O2002- 1151 SL-P-3A/3B

• O2002- 1295 SL-T-2A

• O2002- 1563 Noble Metals Skid

• O2002- 1609 Drywell

• O2002- 1933 SL-P-3B

• O2002- 1957 NRW 23 elevation floor drains

• O2002- 2025 NRW 23 elevation (#1 sump overflow)

• O2001- 0263 Cond Demin Regen Room

• O2001- 0302 Cond Demin Regen Room

• O2001- 0392 New Rad Waste 23 elevation

• O2001- 0404 Condensate Pump Pit

• O2001- 0621 New Rad Waste 38 elevation

• O2001- 0744 Cond Demin Control Room

• O2001- 1138 Cond Demin Control Room

• O2001- 1306 NRW 23 elevation Hallway

• O2001- 1386 Feed water pump room

• O2001- 1415 Reactor building 95 elevation east wall

• O2001- 1486 New Rad Waste outside Alpha Evaporator

• O2001- 1515 New Rad Waste 48 elevation laundry entrance

• O2001- 1588 Reactor Building 75 elevation at sample sink

• 2384314 Torus Room - leak into torus room near west wall bay 11, refer to issue report 2383020

22. MISCELLANEOUS

Fire Pond:

• Engineering Evaluation No. 147- 99

• Fire pond was not radioactively contaminated by the September 17- 18, 1996 fire protection system contamination incident

Drains:

• Technical Data Report 393 Drains Identification Study

• Study was performed because of inadvertent unmonitored release of potentially contaminated liquid to the discharge canal (refer to June 1982 inter-office memo, Task Assignment TA 315302- 002)

• This report identified all drains and classified them to either contaminated, clean or potentially contaminated and determined whether pathways for unmonitored and/or uncontrolled release to the discharge canal existed

Page 236 Obtaining Approval for Disposing of Very-Low-Level Radioactive Waste - 10CFR20.302

• 10CFR20.302a Submittals

• Memo 6632 0016 dated 4/21/1992 describes Oyster Creeks historic and potential 10CFR20.302a submittals

Soil Release Memoranda:

• TID 008, Determination of Calibration Factors for InSitu Counting Using a Sodium Iodide Detector

• Memo 6630- 92-0035, dated February 24, 1992, titled Comments on Exit Interview of S. Michelson.

• Memo 6630- 92-0079, dated June 1, 1992, titled Issues Related to Contaminated Soil and Similar Bulk Materials.

Soil Relocations and Areas of Interest:

• RP-OC-1001 004, in 2007 soil, brush, cement and asphalt were removed from the northeast corner of the owner controlled area. A survey plan was developed prior to the removal. This evaluation was to support the DBT project.

• The plan and sample results have been documented in the following radiation protection calculations:

o RP-OC-1 001 004, Removal of 560 cubic yards of concrete

o RP-OC-1001 005, Removal of 400 cubic yards of brush and soil

o RP-OC-1 001 006, Removal of 15-20 cubic yards of dirt, wood, cement, and asphalt

Page 237

• IR 1240274, Several areas were identified during a Nuclear Regulatory Commission (NRC) on the site that could be, or might have been, impacted by plant operation, which would be of interest during preparation of the decommissioning HSA and LTP.

o A swale east of the ISFSI is a collection point for drainage from the ISFSI pad.

o Soils from the condensate storage tank project have been relocated from their original location on site.

o Spoils have been generated and relocated from the ISFSI pad project, Well 73, and Main Transformer project.

23. 2006 TRITIUM PROJECT

In 2006 a tritium project was conducted to characterize the Oyster Creek site relative to tritium.

Additional information can be found on the common drive under K:\\Radcon\\ Radiological Engineering\\ 10CFR50.75(g)\\Tritium Investigation 2006.

24. 2007 CESIUM PROJECT

In 2007 a study was undertaken to characterize the background Cesium levels in and around Oyster Creek. Additional information can be found on the common drive under K:\\Radcon\\ Radiological Engineering\\ 10CFR50.75(g)(1)\\Cesium Background Study.

25. 2007 ISOLATION CONDENSER INITIATION

RP Calculation RP-OC-1001- 10- 002: On July 17, 2007 a loss of the feed pump and a subsequent unit trip led to isolation condenser actuation venting steam to the environment. The predominant isotope through that release point was tritium as a consequence of the forced evaporation of condensate transfer water in the isolation condenser shell-side when the system was initiated. The isolation condensers were considered a ground level release pathway for gaseous effluents.

Details of for this event are included in RP Calculation RP-OC-1001- 10-002.

Page 238

26. 2008 DBT SPOILS RELEASE

In 2008 a detailed RP- AA-228 Attachment 1 was completed to capture the radiation protection calculation and position papers documenting the release surveys and results for the DBT spoils relocated north of the fuel pumps. The HSA identifies this area as being in the North Wooded Area, approximate geographical coordinates Zone 18s, easting 568173.00 m, northing 4407852.00 m using the UTM system.

The radiation protection calculation and position paper and description of spoils relocated:

• RP-OC-1 001- 07-004, 560 cubic yards of concrete

• RP-OC-1001 005, 400 cubic yards of brush and soil

• RP-OC-1 001 006, 15-20 cubic yards of dirt, wood, cement, and asphalt

27. 2009 ISOCONDENSER LEAK

Following a plant shutdown on February 2009, dripping water from the Bravo Isolation Condenser was observed. This water had an activity concentration for tritium of 2.19Ee-5 µCi/cc. No gamma activity was identified.

28. 2009 TRITIUM IN ESW VAULT

IR 907846, in 2009 elevated tritium levels were identified in water pumped out of a concrete vault containing ESW cables. Investigation of the issue determined that the release of tritiated water was caused by leaks in the 8 inch and 10 inch carbon steel Condensate Transfer System lines, SS- 4 and CS-24 respectively.

There was a revision to the original record dated 16 June 2009. Change was driven by new information and calculations leading to a lower release of activity than originally estimated and subsequent lowering of dose. References to these calculations are included in this record.

Page 239 The additional references were:

• 2009 Annual Radioactive Effluent Release Report Oyster Creek Generating Station, revision2, 2012

• Action Request (AR) A2222268 Technical Evaluation of Tritiated Water Leakage 2009, approved 2 July 2009

29. 2009 LEAK ON CONDENSATE TRANSFER LINE IN CONDENSER BAY

IR 957052, while investigating 1- 3 sump run time and consequent CST level drop, a leak in the condenser bay was discovered. The leak was from the CST header (6 inch pipe) at the west wall entry point into the turbine building (northwest section of condenser bay wall north of Alpha condenser inlet piping (near water quality line scaffolding). The leak was 8 to 12 gpm and spraying up from the pipe. The leak was approximately 3 inches from the wall and 20 feet off the floor.

30. 2010 LEAK FROM FRAC TANK TO MOAT AND RCA YARD

IR 1143087, 11/20/2010, a spill of radioactive water during the filling of a black frac tank with NRW tank WC-T-1A contents. The liquid was contained within the RCA in a moat, the liquid did not reach soil or storm drains.

31. 2011 LEAK FROM ORW CHEMICAL WASTE TANK WC-T-3 TO MOAT

IR 1185014, a leak was identified by RP during midshift on 3/8/2011. The area was posted as a CA upon discover of contamination up to 200,000 disintegrations per 100 squared centimeters.

The spill of radioactive water was in the moat area of the ORW sample tanks shed. The leak was identified with the chemical waste tank WC-T- 3 on waste line 3- 222.

Page 240

32. 2011 AREAS POTENTIALLY IMPACTED BY PLANT OPERATION

IR 1240274, several areas were identified by NRC that could be, or might have been, impacted by plant operation, which would be of interest during preparation of the decommissioning HSA and LTP. These included: a swale east of the ISFSI is a collection point for drainage from the ISFSI pad; soils from the condensate storage tank project have been relocated from their original location on site; spoils have been generated and relocated from the ISFSI pad project, Well 73, and Main Transformer project.

33. 2012 ISOLATION CONDENSER INITIATION

IR 1391942, on 23 July 2012, a loss of off-site power and subsequent unit trip led to isolation condenser actuation venting steam to the environment. The isolation condensers were used to stabilize reactor pressure. The predominant isotope through that release point was tritium as a consequence of the forced evaporation of condensate transfer water in the isolation condenser shell-side when the system was initiated. The isolation condensers were considered a ground level release pathway for gaseous effluents.

Picture 1 - Isocondenser shell-side steam venting to atmosphere through east RB elevation wall 95 elevation. View shows loop B in service with steam venting from two 20- inch lines.

Page 241

34. 2014 TORUS ROOM

IR 2384314, leaks into the Torus Room from the reactor cavity was identified by NRC as being of interest during preparation of the decommissioning HSA and LTP. Refer also to IR 2383020.

35. 2015 ASPHALT SAMPLING

Sampling and on- site analyses by gamma spectroscopy were performed from asphalt located in a former parking lot south of the OCAB. The approximate area was 50 foot by 150 foot. A review of the 10CFR50.75(g)(1) files did not identify radioactive material in or moved to the area.

Radiation Protection specified that ten random core samples be collected and then analyzed by high purity germanium detector. Results did not identify licensed material associated with operation, with only naturally occurring radioactive nuclides being reported or identified by energy line analysis. This entry was made to document the survey and results for future reference.

The results can be found on the common drive under K:\\Radcon\\ Radiological Engineering\\ 10CFR50.75(g)(1)\\OCAB 2015 Asphalt Project.

36. 2016 SPILL INTO REACTOR BUILDING FROM REFUEL CAVITY VENT

IR 2718867 9/22/2016, a spill of radioactive water that made its way into areas of the Reactor Building radiologically controlled area (RCA) from a vent in the refuel cavity. The water was completely contained in the Reactor Building. The water was removed from Reactor Building floors and surfaces and the affected Reactor Building elevations and areas were released as contaminated areas (CA).

37. 2016 LEAK FROM FRAC TANK TO MOAT AND RCA YARD

IR 2721028 9/28/2016 and IR 2721211 9/28/2016, a spill of radioactive water during the filling of a black frac tank with NRW tank WC-T-1A contents. The contamination was contained within the RCA in a moat, the liquid did not reach soil or storm drains.

Page 242

38. 2017 LEAK FROM HOSE TO RCA YARD ASPHALT DURING TRANSFER

IR 4033552 7/20/2017, a minor spill of radioactive water during the transfer from a poly container to the caustic tank in new radwaste (NRW). The liquid did not reach soil or storm drains and the liquid was cleaned up from the asphalt. The estimated amount of liquid on the asphalt was 1/2 gallon according to Radiation Protection (RP).

39. 2018 LEAK ONTO THE MOB 3RD FLOOR

IR 04179858 10/3/2018, a minor leak of radioactive water on the 3rd floor of the MOB. The suspected source is the reactor cavity water leakage into the Reactor Building 51- foot elevation west side. The liquid did not reach the environment and was contained to a small area of the MOB 3rd floor. The estimated amount of liquid on the floor was about 100 to 200 milli-liters (mL) according to the IR.

40. 30- INCH HEADER SAMPLING PUMP DISCHARGE

This entry documents information relevant to site characterization and survey in accordance with

§20.1402 Radiological criteria for unrestricted use. The data captured by RP-AA- 228 Attachment will be useful when classifying this portion of the site by contamination potential. The document identifies the potential for radiological impact to a specific site location from liquid sample line flushing. The sample point and area of interest is located north of the T- 39-1 Diesel Fuel Oil Overflow Collection Tank on the northwest side of the emergency diesel building. Sample point coordinates are 567889.62 E 440733.03 N in the UTM reference system. No contamination has been identified.

Page 243

41. SOIL RELOCATION FROM NORTH OF OCAB

This entry documents information relevant to site characterization and survey in accordance with

§20.1402 Radiological criteria for unrestricted use. Soil and large landscape wall blocks were removed from three locations north of the OCAB building. Approximately 862 m3 (1,127 yd3) of materials were moved when the project was completed in March 2019. The location for the materials was the north yard west of LLRWSF. Future plans are to locate some or all of the large landscape wall blocks to the intake and/or discharge structures for the Security modification.

Picture 2 - Sampling point and area of interest. Area of interest is shown by red shaded area.

The coordinates are 568094.28 E 4407395.23 N in the UTM reference system.

A review of this list and the §50.75(g)(1) files indicate these materials were brought to the Station for landscaping purposes. The large wall blocks are planned for reuse to support the intake structure modification project.

Page 244 Two samples were collected and analyzed onsite by gamma spectroscopy. Trace levels of 137Cs were identified along with NORM. The cesium was much less than 1% of the NRC screening value.1 No other licensed radioactive material was identified.

• Sample 6948 3.04 x 10-2 pCi cm -3

• Sample 6949 4.64 x 10-2 pCi cm -3

42. 2019 SMALL SPILL ON ASPHALT OUTSIDE ORW CONTROL ROOM

This entry documents information relevant to site characterization and survey in accordance with

§20.1402 Radiological criteria for unrestricted use. The data captured by RP-AA- 228 Attachment will be useful when classifying this portion of the site by contamination potential. The document identifies the potential for radiological impact to a specific site location from liquid release to asphalt outside the ORW Control room doorway. The incident occurred on 23 October 2019.

Picture 3: Posted contaminated area outside the ORW Control Room doorway.

The impacted asphalt geographical coordinates are Zone 18s, easting 567986.81 m, northing 4407459.10 m using the UTM system.

1 NUREG- 1757 Volume 1 Table B.2

Page 245

43. STORAGE OF RB 119 FOOT ELEVATION SHIELD BLOCKS IN RCA YARD

Potentially contaminated shield blocks are being stored in the RCA yard along the north and east fence line. The blocks are to be stored for a time when their ultimate disposition for disposal is decided and arranged. Shield dust and core samples identified low -level

60Co and 137Cs. The decontamination, removal, and storage plan required the following:

• loose surface contamination levels less than 1000 dpm/100cm2 o blocks to be painted with RP approval when blocks cannot be decontaminated less than 1000 dpm/100cm 2 after 16 person- hours

• RAM tags with dose rates and loose surface contamination levels

• blocks wrapped in plastic and shrink wrap

• tarp placed over wrapped plugs to protect from the weather

Blocks are elevated off the macadam. The impacted asphalt geographical coordinates are Zone 18s, easting 568095.58 m, northing 4407512.05 m using the UTM system.

Picture 4: Shield blocks along the eastern RCA boundary fence line.

Page 246

44. COMPLIANCE WITH REVISED §§ 20.1406 AND 20.1011

On 17 June 2011, the NRC promulgated the DPR that required licensees to establish operational practices to minimize site contamination and perform reasonable subsurface radiological surveys. The goal of the DPR is that licensees have enough funds to conduct site remediation to terminate their licenses. Regulatory Guide 4.22, Decommissioning Planning during Operations, provides guidance for implementing the DPR.

Although the DPR does require subsurface surveys, it does not require the extensive site characterization and compliance surveys that are required by decommissioning regulations and described by MARSSIM. Existing radiological environmental monitoring programs and subsurface (ground water) monitoring conducted by implementation of NEI 07-07, Industry Ground Water Protection InitiativeFinal Guidance Document are considered adequate to meet the DPR.

Oyster Creek has implemented and follows NEI 07- 07 as reported in an EPRI self -

assessment published in 2013 (EPRI Groundwater Protection Program, Groundwater Protection Initiative Self -Assessment, Exelon Oyster Creek Generating Station, Final Report, October 2013). The radiological groundwater protection program requirements are contained in procedure EN -AA- 408- 4000. Procedure EN-AA- 408-4000 requires internal self-assessments of the radiological groundwater protection program at a minimum frequency of every five years to ensure the acceptance criteria of the NEI 07- 07 are assessed. NRC Inspection Module 71124.07, Radiological Environmental Monitoring Program, also evaluates the groundwater program.

This update documents compliance with the DPR reporting requirements.

Page 247

45. STORAGE OF DRYWELL HEAD SEGEMENTS IN OUTDOOR RMA

Contaminated drywell head segments are being stored in and RMA recently established near the Redundant Fire Water Tank in the west protected area. The segments are to be stored for a time when their ultimate disposition for disposal is decided and arranged. The area is posted, segments are wrapped with external contamination levels less than 1000 dpm/100cm2, and the segments are covered to protect from the weather

The impacted asphalt geographical coordinates are Zone 18s, easting 567852.77 m, northing 4407486.46 using the UTM system.

Picture 5: Drywell head segmentations near Redundant Fire Water Tank.

Page 248

46. ALPHA DETERMINATION

Restrictive annual intake limits for alpha emitting radionuclides and recent operating experience have driven the nuclear power industry to prudently decide to develop a standardized, graded approach to monitoring and characterizing alpha activity. Industry experience at decommissioned facilities with previous fuel defects has shown a higher degree of alpha source term between the time of operation cessation to license termination. This document captures the characterization of Oyster Creek areas and systems alpha source-term and past fuel defects for development of the LTP and as input to the DQO for FSS planning.

The principal production mode for TRU in a nuclear power facility arises from neutron activation of U-238, which is generally 95% or more of the uranium contained in power reactor fuel. The activation of U-238 yields U-239 and subsequent capture reactions create a wide distribution and significant amount of both long and short-lived species of TRU.

Fuel cladding defects can produce persistent alpha contamination even when these defects occurred many fuel cycles earlier in the plant's history. Fuel failures have occurred during operating cycles causing quantities of TRU to be released into the reactor coolant system. Once in the reactor coolant, the material was distributed throughout other systems and in some cases areas of Oyster Creek.

During cycle 10 off-gas significantly increased by almost a factor of five (5). The I-131 to I-133 ratio also increased by a factor of two (2). Forty-seven fuel bundles had cladding failures during fuel sipping operations while the reactor was in cold shutdown. This event has some significance in that a primary barrier against fission product releases had been breached. The plant operated with this condition for at least part of cycle 10.

Page 249 While transporting spent fuel in the SFP on June 15, 1995, a fuel bundle experienced structural failure. Fuel moves were in progress in order to rearrange the fuel in the SFP. As operators were attempting to lower the fuel bundle into its new location in the SPF, the lower tie plate and most of the fuel pins separated from the bundle, dropping approximately 7 to 8 feet into the intended fuel rack location. The tie rods and upper tie plate of the fuel bundle were left suspended from the refueling grapple. The fuel bundle was first placed in the reactor on 4/30/73. This bundle was used over several core operating cycles during the 1970's and was finally removed to the SFP on 4/21/80 for storage. The fuel channel was removed from the assembly on 4/3/84.

The original site alpha assessment performed in accordance with RP-AA- 302 was performed in 2008. A review of historical surveys and current surveys was performed to establish a baseline characterization. The initial assessment has been updated to include smears collected and analyzed in components and areas that were both previously determined to be of higher for significant relative abundance of TRU or are suspect and not previously evaluated. Additionally, alpha analyses are performed during routine surveys as required by RP-AA- 302 based on the classification of the area or component. Ratios were determined between gross beta- gamma results and gross alpha measurement results. Levels were determined based on the ratios and risk of alpha contamination. Radiation Protection calculation and position paper OC-16-008 documents the latest update to the area and systems classification based on data obtained during refuel outage 1R26. This action is required by RP-AA- 302.

Oyster Creek ceased permanent operation 17 September 2018 at 12:33. Accurate site characterization becomes more important to future decommissioning planning as Oyster Creek enters decommissioning. Radiation Protection calculation and position paper OC 008 addresses the changes to current alpha characterizations and classifications due to the differences in half-lives between the easy-to-detect beta-gamma emitters and the hard-to-detect alpha TRU emitters.

Page 250 In Level 1 Areas, the relative abundance of alpha contamination is minimal. Internal exposure from the alpha emitters is not likely to exceed 10% of the total internal dose. In Level 2 Areas, the relative abundance of alpha contamination is significant. Alpha emitters are likely to contribute more than 10% of the internal dose. Additional smears are counted to adequately evaluate the magnitude and extent of alpha contamination in the area. In Level 3 Areas, the relative abundance of alpha contamination is elevated. Internal exposure from the alpha emitters is likely to exceed 90% of the total internal dose based on the inhalation retention model. All smears and all air samples should be counted for alpha contamination. Use of lapels or other breathing zone personal air samplers as internal dosimeters is recommended. Also, alpha frisking of personnel is recommended when the beta- gamma to alpha activity ratio is below 50 to 1.

47. AREAS CURRENTLY AND FORMERLY DESIGNATED AS RESTRICTED AREAS PER 10 CFR 20.1003

• Site Protected Area

• ISFSI Protected Area

Page 251 OYSTER CREEK STATION HSA

10.3 Photo documentation Log

Page 252

12/1959 Page 253 Artist Rendition Page 254 1968 Page 255 6/1968 Page 256 1972 Page 257 Early 1980s Page 258 1993 Page 259 1998 Page 260 2/2002 Page 261 8/2006 Page 262 7/2007 Page 263 9/2010 Page 264 11/2012 Page 265 4/2013 Page 266 9/2013 Page 267 4/2016 Page 268 10/2017 Page 269 5/2018 Page 270 5/2019 Page 271