ML070380025

Yankee Response, Dated January 18, 2007, to NRC Questions on Final Status Surveys TBN-01, NOL-01, WST-01, AUX-01, and NSY-12

ML070380025
Person / Time
Site:	Yankee Rowe
Issue date:	01/18/2007
From:	Carson A - No Known Affiliation
To:	John Hickman, Youngblood T NRC/FSME/DWMEP/DURLD
References
Download: ML070380025 (16)

Text

John Hickman - Written responses to FSS questions Page 11I John Hickman Written responses to FSS questions Page 1 From: "Alice Carson" <acarson 1967 @comcast.net>

To: "'John Hickman"' <JBH @nrc.gov>, <thy@ nrc.gov>

Date: 01/18/2007 3:18:42 PM

Subject:

Written responses to FSS questions John, Here are written responses to questions identified in your matrix. Please let me know ifyou require any additional information.

Regards, Alice Carson CC: "'Greg Babineau"' <Babineau@yankeerowe.com>, <erickson@yankeerowe.com>, "'Joe Bourassa"' <Bourassa@CYAPCO.com>, "'Gerard P. Van Noordennen"'

<VanNoordennen @CYAPCO.com>

Yankee and its NRC Project Manager, John Hickman, have recently undertaken a review of decommissioning correspondence to identify requests for additional information and any responses to those requests. Through this review it was determined that there were three sets of emailed questions that had been discussed in teleconferences but for which no written response could be found. These questions centered on the first five final status survey reports submitted: TBN-01, NOL-01, WST-01, AUX-01, and NSY-12. The attached pages document those questions as well as Yankee's responses to ensure closeout of these items. It is noted that a number of the questions prompted changes to the final status survey report structure of subsequent reports.

Page 1 of 12

Additional Questions for April 10, 2006 Call (Email from John Hickman to Alice Carson dated Monday, April 10, 2006)

NRC Question #1: YR indicates that ISOCS is not suitable for discrete hot particles. How does YR plan to survey for discrete particles?

[ISOCS result provided for the 1.2 uCi Co-60 source was useful information.]

Yankee Response: It is Yankee 's position that ISOCS is sutitablefordetecting discrete particles. Yankee used both 1SOCS andSPA-3 for turnover surveys. Generally, the SPA-3 did not identify anything that the 1SOCS did not; although there were isolatedcases where one instrument did identify a particle,and the other one had not. SPA-3 investigationsfollowing an elevated ISOCS resultprovide additionalassurancethat any existing contaminationis appropriatelyidentified.

YA-REPT-00-O01-06 and YA-REPT-00-12-06 provided to the NRC via email on June 19, 2006 discussparticledetection sensitivityfor scan instrumentation,inchlding SPA-3 and ISOCS.

NRC Question #2: Does YR have any empirical data using ISOCS for surface contamination measurements?

Yankee Response: No, Yankee does not have empiricaldatafor surface contamination.

Yankee committed togethersuch data if activity was encountered,while performing subsequent surface measurements. However, activity was not identified in subsequent measurements. The basisfor the use oflSOCSfor surface contamination measurements is provided in modeling documented in YA-REPT-00-018-05, "Use of ln-situt Gamma Spectrum Analysis to Perform Elevated Measurement Comparisonin Support of Final Status Surveys, " which discusses ISOCS modeling.

NRC Question #3: YR & ORISE have reported results to NRC for the discrete particle identified in FSS-TBNOI-00 (0.2 uCi & 1 uCi). Have you discussed analysis results for the discrete particle with ORISE?

Yankee Response: No, Yankee has not seen the results. There are a number offactors to be consideredin the analysis, all of which can accountfor the difference in the results:

weight assumed,geometry, andphysical configuration,as there is great directional dependence.

Page 2 of 12

YR TBN Final Status Surveys Comments/Questions Email from Hickman to Carson dated June 14, 2006 TBN01-00 FSS Questions:

(TBN-01-01; TBN-01-09 through TBN-01-17)

NRC Question #1: Section 5.2.4 Survey Results and the Table 10 results are in cpm, and the fixed-point measurement criteria or DCGL criteria is in dpm/100-cm2. YR has not demonstrated that the criteria vixerel not exceeded.

Yankee Response: Yankee Response: The fixed point measurement resultsfor TBN-01-01 and TBN-01-09 through TBN-01-17 areprovided in Table 8 in cpm and dpm/1 00 cm 2. Table 11 provides the resultsforfixed point measurementsfor survey units TBN-01-02 through TBN-0O-08, however, they are given only in units of cpm. Table 10 provides the survey design parametersfor TBN-01-02 through 08 and sets the investigationlevel as 694 cpm, based upon a DCGLw of 434 cpm. Table 11 shows that mean of thefixed point measurement is generally less than halfof the DCGLw and all measurements are below the DCGLw, thus the criteriawere not exceeded and the survey units passed.

Yankee provided the results in dpm/100cm 2 infitture reports tofacilitate comparison with the DCGL criteria NRC Questions #2: Table 9 - Summary of ISOCS Scan results - provides the number of scans for each survey unit and the 'results' (action level exceeded) as "NO". Where is the ISOCS scan data - other than in the ISOC scan reports?

Yankee Response: Yankee agrees goingforwardthat the data will be presented in Table 9 ratherthan "no. " In addition, Yankee will remove the term "statisticaloutlier" and use more clear terminology with the same intent.

NRC Question #3: Vol. 1, Main Report: Table 5 DCGLw & DCGL-EMC for ISOCS (Co-60 and Cs-137. DCGLw for Co-60 is 6.3E+3 dpm/ 100cm2 , and Cs-137 2.2E+4 dpm/100 cm2 ).

Co-60 AF= 7.3 (comparison used 1-m2 EMC)

Cs-137 AF= 7.3 (comparison used 1-m2 EMC)

Table 11 (Co-60 only. DCGL is 7.2E+3 dpm/100 cnl)

Co-60 AF=16.67 (area of EMC not specified)

Yankee Response: The AFs are correspondto the lm2 areaas it is the smallest area in the LTPfor which thesefactors are calculated(andare the maximum AFs calculatedin the LTP). These lead to the highest MDCEAfc, which is conservative. In addition, the values are used to establish "action levels" and not the actuala-prioriDCGLEAfc. The "action levels" trigger an investigation, at which time the actual a-posterioriDCGLEAfc is appliedto the measurements.

Page 3 of 12

NRC Question #4. Vol. 1, Main Report, Table 10. Sample size is a function of relative shift (delta/sigma), and the relative shift should be a dimensionless number.

LBGR & sigma are in different units. LBGR in dpm/100cm 2 and sigma is in cpm.

Yankee Response: Although the values in Table 10 are correct, the units were incorrect and should not have been listed. The values of the relativeshift are correctlygiven as dimensionless in subsequent reports.

NRC Question #5: Vol. 1, Main Report, Table 11. An Investigation level is listed for the HP OOC & SPA-3. Please provide an example calculation for the HP OOC scan MDC for alpha and beta radiation. Table 11 lists HP IOOC IL as > 1.2E+4 or 7.2E+4 dpm/100 cm2 & a statistical outlier.

LTP page 5-39 indicates that the scan MDCs will be documented prior to performing the FSS.

Yankee Response: Section 3.0 of the FinalStatus Survey Plan (FSSP)provides the referencefor the calculation of the scan MDCs. These are calculatedand documented priorto the start of the FinalStatus Survey. The FSSPs are inchlded in the FSS report package. The calculationhas been attachedto these responsesfor ease of reference.

NRC Question #6: Vol. 1, Main Report, Section 4.1.3. Are compensatory measures needed for situations where a 4 cm2 "hot spot" was not detected by ISOCS? Table 5 indicates that the ISOCS Co-60 DCGLemc = 4.6E+4 dpm/100 cm2 or assuming that activity is uniformly spread over a one-m2 area.

Yankee Response: In subsequent surveys the FSS Engineerreviewing the scan data was made aware of the possibility of very small areasof activity. In cases where the results of the scan were less than unity but exhibiteda concentrationdue solely to Co-60, additionalinvestigationswere made.

NRC Question #7: Vol 3, Appendix C, YA-REPT-00-018-05. Table 3 provide the one-meter squared surface DCGLw values (Co-60 is 6300 dpm/100 cm 2 adjusted to 8.73 mrem/y and DCGLECIC is 46,000 dpm/100 cm2 over 1-m 2).

Yankee Response: Correct. However, the DCGLEMc values provided in Table 3 were developedfor the determination of investigation levels and would not be used in place of the actual a-posterioriDCGLEMc that would be calculatedduring the investigation.

These "investigation levels " are the values that trigger the additionalinvestigation.

Page 4 of 12

NRC Question #8: Vol. 3, Appendix B, SUs TBN-01-10, -12. -13. -16, -17. The mean ambient background column is 20 entries and the sample data is 10 entries?

Comments Yankee Response: Appendix B to TBN-01 is Technical Report YA-REPT-00-015-04, which discusses instrument efficiencies anddoes not discuss the specific number offixed point measurementsprovidedfor the different survey units in TBN-01. Attachment B to TBN-01 is the DQA for TBN-01 and includes the "PreliminaryData Review Form"for each of the survey units. Thisform lists 20 fixedpoint measurementsfor each of the units identifiedabove (-10, -12, -13, -16, and -17). It also lists the gross activity concentrationsfor each of the 20 measurement IDs associatedwith the fixed point measurement in cohlmnarform. The entries in the cohlmnfor "mean ambient background" are the mean backgroundvalue determinedfor that survey unit and are not vahlesfor different backgroundmeasurements. This column isfor the ease of the calculationof net counts and is not a one-to-one pairingoffixed point and background measurements.

Page 5 of 12

YR WST Final Status Surveys Comments/Questions Email from Hickman to Carson dated June 14, 2006 WST-01-01 Survey Unit Background information:

Class I survey unit.

(WST-01-01 is a single survey unit (WST-01-02) of the remnants of WST-01-01 which was the "Old PCA Storage Building" that has been demolished. Reinforced concrete remnants of the potentially-contaminated-area (PCA) storage building within the RCA yard area.)

NRC Question #1: Page 12, Ta ble 7. What are the ISOCS results? Suggest that this information be placed in the FSS.

Yankee Response: This information has been provided in subsequent FSS reports.

NRC Question #2: Regarding the ISOCS scans locations map: It appears to be more then 97 ISOCs scans (114 data set )?

Yankee Response: The scans start with the scan number of 101 and end with a scan number of 196, indicating96 scans were performed. The report erroneouslyindicated

97. Attachment A to the FSS reportfor WST-01 inchldes a total of 96 ISOCS reports.

NRC Question #3: Regarding the direct measurements locations map: The concrete structure in the upper portion had only one measurement and 12 ISOCS scans?

Yankee Response: The concrete structurehas an unusual configuration,which necessitated additionalISOCS scans to provide 100% coverage. As a result there was a greatdeal of overlap in the 1SOCS scansfor the partialwall. The fixed measurements were determined by a triangulargrid with a random start. In this case only one fixed point measurementfell on the structure.

NRC Question #4: Page 1, Section 1.3: Indicates that 97 ISOCS scans supplemented by hand-held survey meters and 24 fixed-point measurements were taken. Did the data variability indicate that adequate samples were taken?

Yankee Response: Although it is true that the retrospectivestandarddeviation was largerthat the prospective standarddeviation, the originalsample calculation calledfor a total-of l5fixed-point measurementsto be taken. The FSS Engineer added 9 more fixed-point measurements to the plan, therefore increasingthe power of the survey. The additionalpower added to the survey offset the slightly higher standarddeviation by Page 6 of 12

"closingtip" the measurementgrid, resultingin an adequatenumber of measurements being taken.

NRC Question #5: ISOCS measurements were affected by radiation from the ISFSI.

These areas were supplemented by SPA-3 scans. The SPA-3 scans identified two elevated soil areas in NOL-05-02.

Yankee Response: That is correct. The two areas were scanned with a SPA-3, and subsequent remediationwas performed in the two areas. One was a particleand the other was a small area containingdistributedactivity. Subsequent surveys in the area adjacent to the ISFSI used the criteriathat any plant relatedactivitypresent was investigated(i.e. OOL-10-02)

Page 7 of 12

YR NOL Final Status Survey Units Comments/Questions NOL-01 has four (4) final status survey units Email from Hickman to Carson dated June 14, 2006 NRC Question #1: The NOL FSS documentation is much better written than TBNO1-00. It includes the ISOCS data for the survey units (i.e., fraction - DCGL)

Yankee Response: No response necessary.

NRC Question #2: Tables 16 & 17 indicate that an investigation was done for samples no. 17. What were the results of the soil sample that prompted the investigation?

Yankee Response: Table 16 indicates that an investigation was prompted by an 1SOCS scan. Table 17 shoes that the ISOCS scan results was 1.13 times unityfor the scan investigationlevel. Subsequent soil samples determining the boundariesof the elevated areaand the average concentrationof activity within this areaarefound in Table 17.

Table 16 - Summary of ISOCS Scan Results for Survey Unit NOL-01-02. Table 16 indicates to See Table 17, but Table 17 does not provide soil samples results in terms of pCi/g, but indicates that the sample results was 1.13 f-DCGL.

Yankee Response: Table 16 is a summary of ISOCS scan results which are reportedin the fraction of unit of the investigation level. The valheforf-DCGLfor the 1SOCS scan for NOL-01-02-17-F-G was greaterthan I (1.13, as stated in thefirst row of Table 17),

prompting an investigationvia soil sample. The results of those investigatorysoil samples areprovided in the subsequent rows of Table 17 (NOL-01-02-032-F-1,etc.) in units ofpCi/g as indicated in cohmms 2, 3, and 4.

Page 32. An Investigation was done at scan location 17. The elevated area was 2-m x 2.3-m. Four random soil samples were taken and an EMC calculation was made.

The sum-of-fractions appears to be 0.25 (0.10 + 0.15), and the survey unit passes the criteria.

Yankee Response: Based upon the suggestion above, Yankee revised the way this data was presented in subsequent reports. Table 16 included the originalsample vahle, and Table 17 provided the resample results. A conchlsionfor that sample (for example, "the criteriawas met') and the basis is being providedforfiuturereports,as well as the overallconclusion that "the criteriawas met and the unit passed the FSS."

Page 8 of 12

NRC Question #3: What are the implications for YR survey methodologies by the fact that ORISE identified an elevated area of activity in NOL-01-03? Additional remediation was required & table 23 presents the results of the post-remediation sampling.

Yankee Response: As a result of this, Yankee subsequently decided to utilize the same methodologyforpost-remediation/characterization samples, as thatfor FSS (i.e., ISOCS scanning); thereforeproviding consistent instrument sensitivity by using consistent advanced technology in both surveys. In addition Yankee adopted a practiceof using both ISOCs and SPA-3 scansfor remediation/characterization surveys for robustness.

Are there any indicators (ISOCS scan results or otherwise) that may have indicated that elevated activity was in that survey unit?

See Table 22 & Table 23.

Yankee Response: ISOCS scans did indicate activity present in the survey unit, albeit not above the investigationlevel, whereas SPA-3 scans did not indicate an elevated area.

NRC Question #4: An investigation was done because of the ISOCS scan NOL-Ol-03-012 results. The data for this ISOCS scan is not provided in the Table 25.

It would be appropriate to indicate the mean and variance/standard deviation of the mean for the data in Table 26.

Yankee Response: Table 25 illustrates "as left" resultsfor the survey unit. Subsequent reportsshow all scan andsample results, as well as the mean andstandarddeviationfor the data.

NRC Question #5: Data Quality Assessment. Are the data evaluations geared toward validating the assumptions (spatially independent concentrations, etc.)

underlying the statistical tests used?

Is the data uncertainty larger than the assumed sigma used to calculate the number of soil samples needed? YR indicates that the retrospective power curve indicated that the survey unit would pass the criteria for the samples taken.

Yankee Response: In all instances, the purpose of the Data QualityAssessment is to ensure that the sample data are representativeof the parent. The risk associatedwith having a largerretrospective standarddeviation is an increasedType H error(falsely failing the survey unit)..

Page 9 of 12

YR Alternative Scenarios Potential Exposure to Hot Particles for the Anticipated Land Use Email Hickman to Carson Dated September 5, 2006 NRC Comment: YR has provided a dose calculation for the EDE for a 24-h exposure to a hot particle on the skin using the X. G. Xu dose factors in the technical literature.

This calculation may not adequately address the scope of potential exposure(s) that could arise for the public use of the decommissioned site. Other exposure pathways that should be considered include skin dose, inhalation dose, and ingestion dose from hot particles.

NRC has accepted the technical basis of the YR methodology for scan surveys in the final status surveys, but NRC in-process surveys indicated that some hot particles were not detected by the YR processes. NRC requested in a July 12, 2006, letter that YR provide dose calculations to assist NRC assess the consequences of these hot particles.

NRC does not believe that the EDE calculation provided in its August 16, 2006, response adequately addresses the entire range of the potential exposures.

Dose Assessment Question:

NRC requests that YR Identify (alternate) scenarios that may be reasonably anticipated for the planned land use, and that YR determine the resultant radiation doses from exposures to hot particles for members of the public using the decommissioned site.

Yankee Response:

Thefollowing two reports were provided to the NRC by Yankee on doses due to hot particles to resolve this question.

YA-REPT-O0-016-06, "DiscreteParticleDetection in the PerformanceofFinal Status Surveys at Yankee NuclearPower Station," included as an attachment to BYR 2006-71 datedAugust 16, 2006 and YA-REPT-00-018-06, "EstimatedDosesform Inhalation,Ingestion, and Remote Exposurefrom ResidualDiscreteParticlesat Yankee NuclearPower Station Following License Termination," included as an attachment to BYR 2006-94 datedNovember 16, 2006.

Page 10 of 12

FSS Data Issues Email Hickman to Carson Dated September 5, 2006 TBN-01-02 through TBN-01-08 NRC Question #1 Systematic Survey Data Table 10 provides the survey design and indicates that all are Class 1 survey units.

The survey design or Section 5.2.1.4 narrative indicates that 15 fixed-point samples will be taken in each survey unit. Table 13 provides the systematic survey data, but the results are in cpm. Table 11 provides the DCGL-w, DCGL-EMC and Investigation levels as dpm/100cn 2 units. The staff cannot determine if the DCGLs are exceeded or not.

Yankee Response: As discussed in the response to a similar question regardingTBN-01 datedJune 14, 2006, all measurements are below the DCGL, the criteriawere not exceeded and the survey unitspassed the final status survey. Yankee providedthe results in dpm/lJOOcm 2 infitture reports tofacilitate comparison with the DCGL criteria NRC Question #2 Scan Survey Data:

The staff cannot identify the scan survey data for these survey units in the FSS Report or attachments.

Yankee Response: SPA-3 scan surveys in TBN-01 were performed in accordancewith YNPS ProcedureDP-8540 "Operationand Source Checks of Gamma Friskers,"in audiblescan mode. This procedure instructs the technician to scan the survey unit in audible mode, and to investigate levels greaterthan background. The procedure does not requirethe technicianto log data.The supervisors recordin theirjournalthat no scan measurements iwere detected above background (If an investigation is performed, it is recordedin the fieldjournal.)

Yankee inchlded a statement in subsequent reports in Section 5.4 to indicate that the results of the SPA-3 scans indicate that no residualradioactivityexists above background NOL-01-01 and NISY]-12-01 The FSS Reports listed are both MARSSIM class I survey units, and require both systematic surveys and scan surveys.

The staff cannot locate the scan survey data for NOL-01-01. NOL-01 has four (4) survey units. ISOCS scan data or a data summary was identified for the other three (3) survey units.

Page 11 of 12

The staff cannot locate scan survey data for NISY]-12-01 in the report or attachments. NISYI-12 has a single survey unit.

Yankee Response: SPA-3 scan surveys in NOL-01 and NSY-12 were performed in.

accordancewith YNPS ProcedureDP-8540 "Operation and Source Checks of Gamma Friskers," in audible scan mode. This procedure instructs the technician to scan the survey unit in audible mode, and to investigate levels greaterthan background. The proceduredoes not require the technician to log data. The supervisors recordin their journal that no scan measurements were detected above background (If an investigation is performed, it is recorded in the fieldjournal.)

Yankee inchlded a statement in subsequent reports in Section 5.4 to indicate that the results of the SPA-3 scans indicate that no residualradioactivityexists above background.

Page 12 of 12

Table 2 MDC/MDCR Table for Building Surface Surveys - Scan MDCR(cp .38 (DP-8853)

MD/c.V where: Rb = background count rate Inputs Calc'd Vals 2

Detector area = 100 cm L = Detector width (cm) = 10 cm = 3.94 in V = Scan speed = 2.00 in/s = 304.80 cm/min 0.0328 min Ad~DCR MDQJD(fCGI_.MC) = =s(f' /1 ,EAF DCGfL) (DP-8853)

Cs-137 Co-60 (A/I O O) f'p ej=! 0.2413 0.2413 es 0.50 0.25 A= 100 cm' DCGL 25000 7200 p= 0.5 f

• 0 1 AF= 1.6 1.6 Rb I MDCR MDC (Table continued) (Tal continued)

(cpm)J (cpm) (fDCGLEMc) Rb MDCR MDC Rb MDCR MDC 50 53.9 0.110 (cpm) (cpm) (fDCGLEMc) (cpm) (cpm) (fDCGLEMC) 60 59.0 0.120 380 148.5 0.302 700 201.6 0.410 70 63.7 0.130 390 150.5 0.306 710 203.0 0.413 80 68.1 0.139 400 152.4 0.310 720 204.4 0.416 90 72.3 0.147 410 154.3 0.314 730 205.8 0.419 100 76.2 0.155 420 156.1 0.318 740 207.3 0.422 110 79.9 0.163 430 158.0 0.322 750 208.6 0.425 120 83.5 0.170 440 159.8 0.325 760 210.0 0.427 130 86.9 0.177 450 161.6 0.329 770 211.4 0.430 140 90.1 0.183 460 163.4 0.333 780 212.8 0.433 150 93.3 0.190 470 165.2 0.336 790 214.1 0.436 160 96.4 0.196 480 166.9 0.340 800 215.5 0.439 170 99.3 0.202 490 168.6 0.343 810 216.8 0.441 180 102.2 0.208 500 170.4 0.347 820 218.2 0.444 190 105.0 0.214 510 172.1 0.350 830 219.5 0.447 200 107.7 0.219 520 173.7 0.354 840 220.8 0.449 210 110.4 0.225 530 175.4 0.357 850 222.1 0.452 220 113.0 0.230 540 177.0 0.360 860 223.4 0.455 230 115.5 0.235 550 178.7 0.364 870 224.7 0.457 240 118.0 0.240 560 180.3 0.367 880 226.0 0.460 250 120.5 0.245 570 181.9 0.370 890 227.3 0.463 260 122.8 0.250 580 183.5 0.373 900 228.6 0.465 270 125.2 0.255 590 185.1 0.377 910 229.8 0.468 280 127.5 0.259 600 186.6 0.380 920 231.1 0.470 290 129.7 0.264 610 188.2 0.383 930 232.3 0.473 300 132.0 0.269 620 189.7 0.386 940 233.6 0.475 310 134.1 0.273 630 191.2 0.389 950 234.8 0.478 320 136.3 0.277 640 192.7 0.392 960 236.1 0.480 330 138.4 0.282 650 194.2 0.395 970 237.3 0.483 340 140.5 0.286 660 195.7 0.398 980 238.5 0.485 350 142.5 0.290 670 197.2 0.401 990 239.7 0.488 360 144.6 0.294 680 198.7 0.404 1000 240.9 0.490 370 146.6 0.298 690 200.1 0.407 92.21 73.2 0.149 Package Development\Tools\MDC-Bldg Surf.xls

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Subject:

Written responses to FSS questions Creation Date 01/18/2007 3:17:45 PM From: "Alice Carson" <acarson 1967 @comcast.net>

Created By: acarson 1967 @comcast.net Recipients nrc.gov OWGWPOO4.HQGWDOO1 JBH (John Hickman) nrc.gov TWGWPO04.HQGWDO01 THY (Thomas Youngblood)

CYAPCO.com VanNoordennen CC ('Gerard P. Van Noordennen')

Bourassa CC ('Joe Bourassa')

yankeerowe.com erickson CC Babineau CC ('Greg Babineau')

Post Office Route OWGWPO04.HQGWDO01 nrc.gov TWGWPO04.HQGWDOO1 nrc.gov CYAPCO.com yankeerowe.com Files Size Date & Time MESSAGE 162 01/18/2007 3:17:45 PM RAIs Addressed in Meetings.pdf 42866 Mime.822 60704 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed

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