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{{#Wiki_filter:LC-FS-PR-002 Final Radiation Survey Package Development | {{#Wiki_filter:LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 TABLE OF CONTENT | ||
: 1. PURPOSE AND SCOPE .......................................................................................................3 1.1. Purpose........................................................................................................................3 1.2. Scope ...........................................................................................................................3 | : 1. PURPOSE AND SCOPE.......................................................................................................3 1.1. Purpose........................................................................................................................3 1.2. Scope...........................................................................................................................3 | ||
: 2. REFERENCES .......................................................................................................................3 | : 2. REFERENCES.......................................................................................................................3 | ||
: 3. GENERAL ..............................................................................................................................4 3.1. Responsibilities ...........................................................................................................4 3.2. Definitions...................................................................................................................5 3.3. Acronyms ....................................................................................................................8 3.4. Precautions, Limitations, and Prerequisites ................................................................9 3.5. Records .....................................................................................................................13 | : 3. GENERAL..............................................................................................................................4 3.1. Responsibilities...........................................................................................................4 3.2. Definitions...................................................................................................................5 3.3. Acronyms....................................................................................................................8 3.4. Precautions, Limitations, and Prerequisites................................................................9 3.5. Records.....................................................................................................................13 | ||
: 4. PROCEDURE ......................................................................................................................13 4.1. FRS Package Numbering ..........................................................................................13 4.2. FRS Sample Plan Development ................................................................................13 4.3. FRS Sample Plan Cover Sheet ..................................................................................15 4.4. FRS Data Quality Objectives and Survey Design ....................................................15 4.5. Sample Plan Survey Instructions ..............................................................................24 4.6. Sample Plan Approval ..............................................................................................26 4.7. Survey Package Implementation...............................................................................26 | : 4. PROCEDURE......................................................................................................................13 4.1. FRS Package Numbering..........................................................................................13 4.2. FRS Sample Plan Development................................................................................13 4.3. FRS Sample Plan Cover Sheet..................................................................................15 4.4. FRS Data Quality Objectives and Survey Design....................................................15 4.5. Sample Plan Survey Instructions..............................................................................24 4.6. Sample Plan Approval..............................................................................................26 4.7. Survey Package Implementation...............................................................................26 | ||
: 5. ATTACHMENTS ................................................................................................................27 Page 2 of 46 | : 5. ATTACHMENTS................................................................................................................27 | ||
Page 2 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 | |||
: 1. PURPOSE AND SCOPE | |||
1.1. Purpose | |||
This procedure provides instructions for the development, implementation and review of Final Radiation Survey (FRS) survey packages and sample plans generated to demonstrate compliance with the dose-based unrestricted release criteria at the LaCrosse Station Restoration Project (LCSRP). Because of differences in the conceptual models and required source terms, the FRS includes two different approaches depending on the media; (1) Final Status Survey (FSS) is conducted on soil, buried piping and groundwater to demonstrate that residual radionuclide concentrations are equal to or below site-specific Derived Concentration Guideline Levels (DCGL), and (2) a Source Term Survey (STS) is conducted to demonstrate that the inventory of residual radioactivity in building basements, embedded piping and penetrations is below a source term inventory commensurate with the dose criterion in 10 CFR 20.1402. | |||
The term FRS is used in this procedure to represent both the FSS and STS surveys. | The term FRS is used in this procedure to represent both the FSS and STS surveys. | ||
When the discussion applies to only one of the survey methods, either FSS or STS is specifically referenced. | When the discussion applies to only one of the survey methods, either FSS or STS is specifically referenced. | ||
1.2. Scope This procedure implements the requirements of applicable U.S. Nuclear Regulatory Commission (NRC) regulations and guidance documents; specifically, NUERG-1757, Volume 2, Revision 1 Consolidated Decommissioning Guidance - , Survey, and Determination of Radiological Criteria (Reference 2.1), NUER -1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM, Reference 2.2) and Chapter 5 of the LCSRP License Termination Plan (LTP) | |||
1.2. Scope | |||
This procedure implements the requirements of applicable U.S. Nuclear Regulatory Commission (NRC) regulations and guidance documents; specifically, NUERG-1757, Volume 2, Revision 1 Consolidated Decommissioning Guidance -, Survey, and Determination of Radiological Criteria (Reference 2.1), NUER -1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM, Reference 2.2) and Chapter 5 of the LCSRP License Termination Plan (LTP) | |||
(Reference 2.3). | (Reference 2.3). | ||
This procedure applies to all personnel performing FRS survey package development and/or implementation. | This procedure applies to all personnel performing FRS survey package development and/or implementation. | ||
: 2. REFERENCES 2.1. NUERG-1757, Consolidated NMSS Decommissioning Guidance - , Survey, and Determination of Radiological Criteria Volume 2, Revision 1 - September 2002 2.2. NUERG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) - August 2000 2.3. LaCrosse Station Restoration Project License Termination Plan - December 2014 2.4. LC-AD-PR-003, Records Management Program 2.5. LaCrosseSolutions RS-TD-164026-009, Use of In-Situ Gamma Spectroscopy for Source Term Survey of End State Structures - May 2015 Page 3 of 46 | : 2. REFERENCES | ||
2.1. NUERG-1757, Consolidated NMSS Decommissioning Guidance -, Survey, and Determination of Radiological Criteria Volume 2, Revision 1 - September 2002 | |||
2.2. NUERG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) - August 2000 | |||
2.3. LaCrosse Station Restoration Project License Termination Plan - December 2014 | |||
2.4. LC-AD-PR-003, Records Management Program | |||
2.5. LaCrosseSolutions RS-TD-164026-009, Use of In-Situ Gamma Spectroscopy for Source Term Survey of End State Structures - May 2015 | |||
Page 3 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 2.6. LC-FS-PR-008, Final Radiation Survey Data Assessment | |||
2.7. LC-FS-PR-009, Final Radiation Survey Reporting | |||
2.8. LC-QA-PN-001, FRS QAPP | |||
2.9. LC-FS-PR-006, Survey Unit Classification | |||
2.10. LC-FS-PR-010, Isolation and Control for Final Radiation Survey | |||
2.11. LC-FS-PR-012,Chain-Of-Custody | |||
2.12. ISO 7503-1, Evaluation of surface contamination - Part 1: Beta-emitters (maximum beta energy greater than 0.15 MeV) and alpha-emitters | |||
2.13. LaCrosseSolutions RS-TD-313196-006, Ludlum Model 44-10 Detector Sensitivity | |||
- February 2012 | |||
2.14. LaCrosseSolutions Technical Support Document RS-TD-313196-003, La Crosse Boiling Water Reactor Historical Site Assessment | |||
: 3. GENERAL | |||
3.1. Responsibilities | |||
3.1.1 RP/FRS Manager - is responsible for: | |||
Providing overall guidance and support for the development and implementation of FRS sample plans and survey packages. | Providing overall guidance and support for the development and implementation of FRS sample plans and survey packages. | ||
Reviewing and approving all FRS sample plans. | Reviewing and approving all FRS sample plans. | ||
3.1.2 | |||
3.1.2 FRS Supervisor - is responsible for: | |||
Preparing FRS sample plans and survey packages. | Preparing FRS sample plans and survey packages. | ||
Ensuring FRS surveys are conducted in accordance with approved survey and sampling plans, procedures, and work instructions. | Ensuring FRS surveys are conducted in accordance with approved survey and sampling plans, procedures, and work instructions. | ||
Providing technical direction and guidance to field survey and sampling activities. | Providing technical direction and guidance to field survey and sampling activities. | ||
Controlling and implementing sample plan instructions during field activities. | Controlling and implementing sample plan instructions during field activities. | ||
Survey area/unit preparation, isolation, turnover and prerequisites (e.g., | Survey area/unit preparation, isolation, turnover and prerequisites (e.g., | ||
reference grid layout, identification of working constraints and accessibility needs). | reference grid layout, identification of working constraints and accessibility needs). | ||
Providing daily supervision and guidance to field survey and sampling crews and performing quality checks of field activities. | Providing daily supervision and guidance to field survey and sampling crews and performing quality checks of field activities. | ||
LC-FS-PR-002 Final Radiation Survey Package Development | Page 4 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 Overseeing the preparation of samples for transfer to on or off site laboratories. | ||
Ensuring all necessary instrumentation and other equipment is available to support survey activities. | Ensuring all necessary instrumentation and other equipment is available to support survey activities. | ||
3.1.3 | |||
3.1.3 Graphics/GPS Specialist - is responsible for: | |||
Preparing survey maps, layout diagrams, composite view drawings and other graphics as necessary to support survey design and reporting. | Preparing survey maps, layout diagrams, composite view drawings and other graphics as necessary to support survey design and reporting. | ||
Interacting with the FRS Supervisor regarding the preparation of maps, diagrams and other graphics which present survey units and sample or measurement locations. | Interacting with the FRS Supervisor regarding the preparation of maps, diagrams and other graphics which present survey units and sample or measurement locations. | ||
3.1.4 | |||
3.1.4 FRS Technicians - are responsible for: | |||
Obtaining and documenting survey measurements in accordance with the survey package instructions. | Obtaining and documenting survey measurements in accordance with the survey package instructions. | ||
Ensuring that all activities, actions, observations and obstructions that are encountered during the performance of FRS are documented in Attachment 14, Field Log for that survey unit. | Ensuring that all activities, actions, observations and obstructions that are encountered during the performance of FRS are documented in Attachment 14, Field Log for that survey unit. | ||
LC-FS-PR-002 Final Radiation Survey Package Development | 3.2. Definitions | ||
3.2.6 | |||
3.2.7 | 3.2.1 Area Factor (AF) - The factor by which an individual measurement within a specific area can exceed the DCGL, while maintaining compliance with the release criterion. | ||
3.2.8 | |||
3.2.9 | 3.2.2 Biased Measurements - Measurements performed at locations selected using professional judgment based on unusual appearance, location relative to known contamination areas, high potential for residual radioactivity, general supplemental information, etc. Biased measurements are not included in the statistical evaluation of the survey unit data because they violate the assumption of randomly selected, independent measurements. Instead, judgment measurements are individually compared to the DCGLW. | ||
3.2.10 | |||
3.2.3 Data Quality Assessment (DQA) - The scientific and statistical evaluation of data to determine if the data are of the right type, quantity, and quality for the intended use. | |||
3.2.4 Data Quality Objectives (DQO) - Qualitative and quantitative statements derived from the DQO process that clarify study technical and quality objectives, define the appropriate type of data, and specify tolerable levels of potential decision errors that will be used as the basis for establishing the quality and quantity of data needed to support decisions. | |||
Page 5 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 3.2.5 Derived Concentration Guideline Level (DCGL) - A derived, radionuclide-specific activity concentration within a survey unit corresponding to the release criterion. The DCGL is based on the spatial distribution of the contaminant and hence is derived differently for the nonparametric statistical test (DCGLW) and the Elevated Measurement Comparison (DCGLEMC). DCGLs are derived from activity/dose relationships through various exposure pathway scenarios. | |||
3.2.6 Final Radiation Survey (FRS) - Measurements and sampling to describe the radiological conditions of a site, following completion of decontamination activities (if any) in preparation for release. | |||
3.2.7 Final Status Survey (FSS) - FRS conducted on soil, buried piping and groundwater to demonstrate that residual radionuclide concentrations are equal to or below site-specific DCGLs. | |||
3.2.8 Gray Region - A range of values of the parameter of interest for a survey unit where the consequences of making a decision error are relatively minor. The upper bound of the gray region in MARSSIM is set equal to the DCGLW, and the Lower Bound of the Gray Region (LBGR) is a site-specific variable. | |||
3.2.9 Investigation Level - A derived media-specific, radionuclide-specific concentration or activity level of radioactivity that: 1) is based on the release criterion, and 2) triggers a response, such as further investigation or cleanup, if exceeded. | |||
3.2.10 Historical Site Assessment (HSA) - A compilation of information prepared for use in planning the FRS of a survey unit. It summarizes the operational history,, | |||
remedial action, or operational survey data, and other information, such as past burial or spill events, to help establish the final survey unit classification and the bases for the design of the FRS. | remedial action, or operational survey data, and other information, such as past burial or spill events, to help establish the final survey unit classification and the bases for the design of the FRS. | ||
LC-FS-PR-002 Final Radiation Survey Package Development | 3.2.11 Measurement - For the purpose of MARSSIM, it is used interchangeably to mean: 1) the act of using a detector to determine the level or quantity of radioactivity on a surface or in a sample of material removed from a media being evaluated, or 2) the quantity obtained by the act of measuring. | ||
3.2.15 | |||
3.2.16 | 3.2.12 Minimum Detectable Concentration (MDC) - The minimum detectable concentration is the a priori activity level that a specific instrument and technique can be expected to detect 95% of the time. When stating the detection capability of an instrument, this value should be used. The MDC is the Detection Limit, LD, multiplied by an appropriate conversion factor to give units of activity concentration. | ||
3.2.17 | |||
3.2.18 | 3.2.13 Nonparametric Statistical Test - A test based on relatively few assumptions about the exact form of the underlying probability distributions of the measurements. As a consequence, nonparametric statistical tests are generally valid for a fairly broad class of distributions. The Wilcoxon Rank Sum test and the Sign test are examples of nonparametric statistical tests. | ||
3.2.19 | |||
3.2.20 | Page 6 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 3.2.14 Reference Area - Geographical area from which representative reference measurements are performed for comparison with measurements performed in a specific survey unit at remediation site. A site radiological reference area (background area) is defined as an area that has similar physical, chemical, radiological, and biological characteristics as the site area being remediated, but which has not been contaminated by site activities. | ||
3.2.21 | |||
Page 7 of 46 | 3.2.15 Sample Plan - Sample plans are prepared for each survey unit independently and contain, at a minimum, survey instructions, the number and location of survey measurements and samples, survey maps, instrumentation requirements, and safety requirement as necessary. | ||
3.2.16 Sign Test - A nonparametric statistical test used to demonstrate compliance with the site release criterion when the radionuclide of interest is not present in background or constitutes a small fraction of the DCGLW. | |||
3.2.17 Source Term Survey (STS) - FRS conducted to demonstrate that the inventory of residual radioactivity in building basements, embedded piping and penetrations is below a source term inventory commensurate with the dose criterion in 10 CFR 20.1402. | |||
3.2.18 Survey Area - Survey areas are established based on logical physical boundaries and site landmarks for the purpose of documenting and conveying radiological information, and in order to facilitate the scheduling, management and reporting of the FRS. The survey areas may then be sub-divided into one or more survey units to meet the size requirements as specified by MARSSIM. | |||
3.2.19 Survey Package - Survey packages are prepared for each survey unit. A survey package is, in essence, a file that contains all sample plans, results, records and other documents relevant to the FRS of the survey unit. | |||
3.2.20 Survey Unit - The study area consisting of structures or land areas of specified size and shape for which a separate decision will be made to judge whether the remedial action has achieved the site-specific reference-based cleanup standard for the designated pollution parameter. Survey units are generally formed by grouping contiguous site areas with a similar use history and the same classification of contamination potential. Survey units are established to facilitate the survey process and the statistical analysis of survey data. The survey unit is the fundamental unit of compliance. Each survey unit will meet, or fail to meet, the release criteria independently of all the other survey units. All the survey units must pass if the site is to be released. | |||
3.2.21 Survey Unit Release Record - A document compiled for each survey unit, which demonstrates that it is suitable for unrestricted use. It contains evaluated survey data and supporting information to provide a concise record of the survey results and basis for the conclusion that the release criteria are satisfied. | |||
Page 7 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 3.2.22 Type I Error () - A decision error that occurs when the null hypothesis is rejected when it is true for the scenario used. This would result in incorrectly releasing an area that does not meet the release criteria. | |||
3.2.23 Type II Error () - A decision error that occurs when the null hypothesis is not rejected when it is false for the scenario used. This would result in failing to release an area that meets the release criteria. | |||
3.2.24 Unity Rule - A rule applied when more than one radionuclide is present at a concentration that is distinguishable from background and where a single concentration comparison does not apply. In this case, the combination of measurement results for each singular radionuclide present in the distribution are compared against the release criteria by applying the unity rule. This is accomplished by determining: 1) the ratio between the concentration of each radionuclide in the mixture, and 2) the concentration for that radionuclide that coincides with the release criteria (DCGL). To demonstrate compliance for the survey unit, the sum-of-fractions (SOF) for all radionuclides in the mixture should not exceed 1. | |||
3.2.24 | |||
3.3. Acronyms | |||
3. | |||
LC-FS-PR-002 Final Radiation Survey Package Development | Type I Error Probability Type II Error Probability Standard Deviation (sigma) | ||
5.) | AF Area Factor CoC Chain-of-Custody CFR Code of Federal Regulations FRS Final Radiation Survey RP FRS Radiation Protection Final Radiation Survey DCGL Derived Concentration Guideline Level DQA Data Quality Assessment DQO Data Quality Objectives EMC Elevated Measurement Comparison ETD Easy to Detect FRS Final Radiation Survey FOV Field of View FSS Final Status Survey GPS Global Positioning System HSA Historical Site Assessment HTD Hard-to-Detect | ||
3.4.2 | |||
Page 8 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 ISOCS In-Situ Object Counting System L Grid Spacing LBGR Lower Bound of the Grey Region LTP License Termination Plan MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MDC Minimum Detectable Concentration NAD North American Datum NRC United States Nuclear Regulatory Commission QA Quality Assurance QC Quality Control QAPP Quality Assurance Project Plan QC Quality Control RASS Remedial Action Support Survey ROC Radionuclides of Concern RWP Radiation Work Permit SFP Spent Fuel Pool SOF Sum-of-Fractions STS Source Term Survey TSD Technical Support Document VSP Visual Sample Plan LCSRP LaCrosse Station Restoration Project | |||
3.4. Precautions, Limitations, and Prerequisites | |||
3.4.1 Precautions | |||
1.) Documents and databases containing FRS survey data and survey records are Quality Assurance (QA) records when complete. Positive control of these records shall be maintained until they are forwarded to Records Management in accordance with LC-AD-PR-001, Records Management Program (Reference 2.4). | |||
2.) When documenting survey information, ensure that all QA records are of good quality and legible. Legibility is determined to be readable and reproducible. | |||
3.) For FSS survey design because the contaminant is not in the background, or constitutes a small fraction of the DCGLw, the Sign Test shall be used. | |||
Page 9 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 4.) In Class 1 open land survey units, a subsurface soil sample shall be taken at 10% of the systematic surface soil sample locations in the survey unit with the location(s) selected at random. | |||
5.) For open land survey units, if during the performance of FSS, the analysis of a surface soil sample, or the results of a surface gamma scan indicates the potential presence of residual radioactivity at a concentration of 75% of the surface DCGLw, then additional biased surface soil sample(s) shall be taken to the appropriate depth within the area of concern as part of the investigation. | |||
3.4.2 Limitations | |||
1.) All attachments described in this procedure may be generated electronically. | |||
If electronic attachments are used, the physical layout of the attachment may be modified provided the intent described in this procedure is not changed. | If electronic attachments are used, the physical layout of the attachment may be modified provided the intent described in this procedure is not changed. | ||
LC-FS-PR-002 Final Radiation Survey Package Development | 2.) The output of the design process is the sample plan (instructions). A sample plan is prepared for each survey unit independently. A survey package is prepared for each survey unit and may contain one or more sample plans. | ||
9.) | |||
3.) Radiation detection and measurement instrumentation will be selected based on the type and quantity of radiation to be measured. The target MDC for measurements obtained using field instruments will be 50 percent of the applicable DCGLw. | |||
4.) Instruments used for scan measurements in Class 1 areas are required to be capable of detecting radioactive material at the DCGLEMC. | |||
5.) The target MDC for measurements obtained using laboratory instruments will be 10 percent of the applicable DCGLw. | |||
6.) Measurement results with associated MDC that exceed the target MDC values may be accepted as valid data after evaluation by RP/FRS supervision. | |||
7.) The Canberra In-Situ Object Counting System (ISOCS) has been selected as the primary instrument that will be used to perform STS. LaCrosseSolutions RS-TD-164026-009, Use of In-Situ Gamma Spectroscopy for Source Term Survey of End State Structures (Reference 2.5) provides the initial justification for selecting a reasonably conservative geometry for efficiency calibrations for the ISOCS based on the physical conditions of the remediated surface and the depth and distribution of activity in the concrete surface. Review post remediation conditions and surveys to determine if the geometry of remaining residual radioactivity has significantly changed from that assumed in RS-TD-164026-009. If the geometry appears to be significantly different from that which was assumed in RS-TD-164026-009, then inform the RP/FRS Manager. | |||
Page 10 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 8.) After completion of the FRS in a specific survey unit, the sample plan is reviewed for completeness and the data validated in accordance with LC-FS-PR-008, Final Radiation Survey Data Assessment (Reference 2.6) before sample plan closure and the reporting of results. | |||
9.) Upon closure of the sample plan, a survey unit release record will be prepared for each survey unit within the survey area in accordance with LC-FS-PR-009, Final Radiation Survey Reporting (Reference 2.7). | |||
10.) For the FRS of Class 3 survey units, if a randomly selected location is found to be either inaccessible or unsuitable, then the location will be adjusted to the closest adjacent suitable location. In these cases, a notation will be made in Attachment 14, Field Log and the coordinates of the new location documented. | 10.) For the FRS of Class 3 survey units, if a randomly selected location is found to be either inaccessible or unsuitable, then the location will be adjusted to the closest adjacent suitable location. In these cases, a notation will be made in Attachment 14, Field Log and the coordinates of the new location documented. | ||
3.4.3 | |||
2.) | 3.4.3 Prerequisites | ||
1.) A FRS package will be prepared for each applicable survey unit. A folder designated as the FRS package should be utilized to keep original documents. The folder shall be controlled in accordance with the record quality requirements of LC-QA-PN-001, Final Radiation Survey QAPP (Reference 2.8). | |||
2.) The impacted structural and open land survey areas at LCSRP have been subdivided into Class 1, Class 2, or Class 3 survey units. The initial classifications and survey unit boundaries are specified RS-TD-313196-003, LaCrosse Station Historical Site Assessment, (HSA, Reference 2.9). | |||
Actual open land survey unit boundaries may vary from the conceptual survey unit boundaries presented in the HSA based on actual conditions at the time of survey design as long as the classification does not change. The survey units designated for structures below 636 foot elevation from the HSA were based on screening values and source term assumptions that are not applicable. | Actual open land survey unit boundaries may vary from the conceptual survey unit boundaries presented in the HSA based on actual conditions at the time of survey design as long as the classification does not change. The survey units designated for structures below 636 foot elevation from the HSA were based on screening values and source term assumptions that are not applicable. | ||
LC-FS-PR-002 Final Radiation Survey Package Development | 3.) The STS survey units will be comprised of the combined wall and floor surfaces of each remaining building basement ((i.e. the basements of the Reactor Building (612 and 621 foot elevations), WTB (630 and 635 foot elevations), WGTV (618 and 621 foot elevations) and the Remaining Structures (including the Piping and Ventilation Tunnel, Reactor/Generator Plant, the one foot thick portion of the Chimney Foundation, the Turbine sump and the Turbine pit) were deemed to be unique STS units.)). The total embedded pipe located within a STS survey area will be treated as a separate STS survey unit. As such, the STS penetration and/or embedded pipe survey unit will be part of the summation of the fraction of the inventory source term calculated for each building basement in which they are located. | ||
5.) | |||
6.) | Page 11 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 4.) Radiological surveys performed to support commodity removal, and surveys performed to support structural remediation for open air demolition will be used to verify that the contamination potential within each STS survey unit is reasonably uniform throughout all walls and floor surfaces. | ||
7.) | |||
8.) | 5.) The size of a Class 1 open land survey unit will not exceed 2,200 m2 and the size of a Class 2 open land survey unit will not exceed 11,000 m2 without approval of the RP FRS Manager. | ||
6.) Final classification of an open land survey unit should be assigned and/or validated in accordance with LC-FS-PR-006, Survey Unit Classification (Reference 2.10). | |||
7.) Prior to issuance of a specific sample plan for performance of the FRS, isolation and control measures shall be established in accordance with LC-FS-PR-010, Isolation and Control for Final Radiation Survey (Reference 2.11). | |||
8.) Survey units should be cleared of all loose equipment and materials to the maximum extent possible. | |||
NOTES The vegetation in open land survey units should be cut as close to the ground surface as possible. | NOTES The vegetation in open land survey units should be cut as close to the ground surface as possible. | ||
With the exception of accessibility, the use of an ISOCS for FSS does not require vegetation to be removed. | With the exception of accessibility, the use of an ISOCS for FSS does not require vegetation to be removed. | ||
9.) | |||
9.) To eliminate physical obstructions, open land survey units should be cleared of debris and/or vegetation to the extent possible. | |||
10.) All identified physical hazards in the survey unit shall be either removed or marked as appropriate. | 10.) All identified physical hazards in the survey unit shall be either removed or marked as appropriate. | ||
11.) Prior to performing FRS, a reference coordinate system or grid will be established. For the FSS of open land survey units, reference coordinates will be acquired using a Global Positioning System (GPS) coupled with the North American Datum (NAD) standard topographical grid coordinate system. | 11.) Prior to performing FRS, a reference coordinate system or grid will be established. For the FSS of open land survey units, reference coordinates will be acquired using a Global Positioning System (GPS) coupled with the North American Datum (NAD) standard topographical grid coordinate system. | ||
12.) The systematic sampling and measurement locations within each survey unit will be clearly identified and documented for the purposes of reproducibility. Actual measurement locations will be marked and identified by tags, labels, flags, stakes, paint marks, GPS location, photographic record, or equivalent. | 12.) The systematic sampling and measurement locations within each survey unit will be clearly identified and documented for the purposes of reproducibility. Actual measurement locations will be marked and identified by tags, labels, flags, stakes, paint marks, GPS location, photographic record, or equivalent. | ||
13.) Prior to using any survey instrument, the current calibration will be verified. | 13.) Prior to using any survey instrument, the current calibration will be verified. | ||
Response checks will be performed daily before instrument use and again at the end of use for the day. | Response checks will be performed daily before instrument use and again at the end of use for the day. | ||
LC-FS-PR-002 Final Radiation Survey Package Development | Page 12 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 3.5. Records | ||
: 4. PROCEDURE NOTES The Survey Area Number, Survey Unit Number and current classification are taken from the updated master copy of Survey Units for Open Land Areas and Survey Units for Structures that are maintained by the RP FRS Manager in accordance with procedure LC-FS-PR-006, Survey Unit Classification. | |||
4.1. FRS Package Numbering 4.1.1 | 3.5.1 Final Radiation Survey Package | ||
1.) | : 4. PROCEDURE | ||
6.) | |||
4.2. FRS Sample Plan Development 4.2.1 | NOTES The Survey Area Number, Survey Unit Number and current classification are taken from the updated master copy of Survey Units for Open Land Areas and Survey Units for Structures that are maintained by the RP FRS Manager in accordance with procedure LC-FS-PR-006, Survey Unit Classification. | ||
Page 13 of 46 | |||
4.1. FRS Package Numbering | |||
4.1.1 Prepare a FRS Package. FRS Packages will be designated as follows: | |||
1.) The 1st digit indicates the type of Survey Area | |||
A. L = Open Land B. B = Structural C. S = System | |||
2.) The 2nd digit indicates the Current Classification | |||
A. 1 = Class 1 B. 2 = Class 2 C. 3 = Class 3 D. 4 = Non-Impacted E. 5 = Unassigned | |||
3.) The 3rd, 4th and 5th digits indicates Survey Area Number | |||
4.) The 6th and 7th digits indicates Survey Unit Number | |||
5.) The 8th digit is the alphanumeric sequence where: Sequence A-J allows the survey unit to be divided into 10 smaller survey units. Sequence K-Z allows for up to 16 different survey instructions for a single survey unit. | |||
6.) The 9th digit is the letter F to designate FSS or the letter S to designate STS. | |||
4.2. FRS Sample Plan Development | |||
4.2.1 Prepare a FRS Sample Plan for each survey unit independently. A FRS Package may contain one or more FRS Sample Plans. | |||
Page 13 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 | |||
NOTE The FRS Supervisor tasked with the development and implementation of multiple FRS Sample Plans for a single survey unit must be aware that it is possible that duplicate sample/measurement numbers may be generated when using the guidance for designating a unique sample identification number in accordance with the Sample & Measurement Unique Identification Designation presented in Attachment 7. Consequently, the responsible FRS Supervisor must be vigilant to ensure that this does not occur. | |||
4.2.2 Designate each FRS Sample Plan in the FRS Package specific to a survey unit numerically by sequence (e.g., Plan #1, Plan #2, etc.). | |||
4.2.3 A FRS sample plan will usually contain the items listed below. | |||
1.) Attachment 10, FRS Sample Plan Cover Sheet. | |||
2.) Area Turnover and Control Checklist from LC-FS-PR-010, Isolation and Control for Final Radiation Survey. | |||
3.) Pre-Turnover Walk-Down from LC-FS-PR-010, Isolation and Control for Final Radiation Survey. | |||
4.) Survey Unit Classification Basis Summary from LC-FS-PR-006, Survey Unit Classification. | |||
5.) Survey Unit Classification Worksheet from LC-FS-PR-006, Survey Unit Classification. | |||
6.) Attachment 11, FRS Data Quality Objectives and Survey Design. | |||
7.) Attachment 12, Survey Instructions. | |||
8.) Attachment 13, Field Log. | |||
9.) Attachment 14, Sample/Measurement Identification and Coordinates. | |||
10.) Attachment 15, Scan Area Identification and Coordinates. | 10.) Attachment 15, Scan Area Identification and Coordinates. | ||
11.) Photographs, maps, and/or drawings of the survey unit. | 11.) Photographs, maps, and/or drawings of the survey unit. | ||
12.) FRS field measurement and analytical results. | 12.) FRS field measurement and analytical results. | ||
LC-FS-PR-002 Final Radiation Survey Package Development | 4.2.4 Include any available relevant information for the survey unit, (i.e. as-built floor plans, blue prints, photographs, computer generated or hand drawn survey maps) in the FRS sample plan. | ||
4.3.2 | |||
4.3.3 | 4.2.5 Provide a unique sample identification number for all FRS direct measurements and/or samples in accordance with Attachment 7, Sample & Measurement Unique Identification Designation. | ||
1.) | |||
2.) | Page 14 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 4.3. FRS Sample Plan Cover Sheet | ||
4.3.4 | |||
4.4. FRS Data Quality Objectives and Survey Design 4.4.1 | 4.3.1 Initiate Attachment 10, FRS Sample Plan Cover Sheet for the survey unit. | ||
4.3.2 Complete the General Section of Attachment 11, by entering the requested information. | |||
4.3.3 Assess the readiness of the survey unit by completing the Preparation for Final Radiation Survey section of Attachment 11 using the following guidance: | |||
1.) Ensure that a pre-FRS walk-down of the survey unit has been performed in accordance with LC-FS-PR-010, Isolation and Control for Final Radiation Survey and that all items identified for hazard mitigation and area preparation have been satisfactorily completed. | |||
2.) Ensure that all turnover items that were identified on the Area Turnover and Control Checklist from LC-FS-PR-010, Isolation and Control for Final Radiation Survey, have been completed or resolved prior to signifying readiness. | |||
4.3.4 The responsible FRS Supervisor shall signify by signature on Attachment 11 that the survey unit is ready for FRS implementation. | |||
4.4. FRS Data Quality Objectives and Survey Design | |||
4.4.1 Initiate Attachment 12, FRS Data Quality Objectives and Survey Design for the survey unit. | |||
NOTE The problem associated with FRS is to determine whether the survey unit meets a specified radiological release criterion (e.g., 10 CFR 20.1402). | NOTE The problem associated with FRS is to determine whether the survey unit meets a specified radiological release criterion (e.g., 10 CFR 20.1402). | ||
LC-FS-PR-002 Final Radiation Survey Package Development | 4.4.2 State the Problem - commence survey design through the DQO process by providing a clear description of the problem and a conceptual model of the hazard to be investigated. | ||
4.4.3 | |||
1.) | 1.) Clearly state the problem. | ||
2.) | |||
3.) | 2.) Identify the stakeholders. | ||
4.4.4 | |||
1.) | 3.) Identify the planning team and decision maker(s). | ||
4.) Specify the anticipated schedule for the activity. | |||
5.) Identify the resources and support that will be required to successfully complete the activity. | |||
Page 15 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 | |||
NOTE The principal study question for FSS might be, Does the residual radioactive contamination present in the survey unit exceed the release criteria? The principal study question for STS might be, Is the inventory of residual radioactivity in the building basement, including all relevant embedded piping and penetrations, when multiplied by the Basement Dose Factors, below the 25 mrem/yr dose criterion? Alternative actions may include no action, investigation, re-survey, remediation and/or reclassification. The stated decision may be, IF any of the measurement data results exceed the release criteria, THEN use the DQA process to evaluate the alternative action or combination of actions. | |||
4.4.3 Identify the Decision - develop objectives for the FRS, or if applicable, several objectives, based on the stated problem. | |||
1.) State the principal study question. | |||
2.) List any alternative actions. | |||
3.) Clearly state the decision. | |||
4.4.4 Identify Inputs to the Decision - Identify the types and quantity of radiological data that will be necessary to address the objectives identified in the previous step. | |||
1.) State the information needed. | |||
A. Identify the sample media (e.g., surface soil, concrete). | A. Identify the sample media (e.g., surface soil, concrete). | ||
B. Identify the types of measurement (e.g., scan, static measurement, surface soil sampling, etc.). | B. Identify the types of measurement (e.g., scan, static measurement, surface soil sampling, etc.). | ||
C. Identify sources of information that will be used (e.g., HSA, previous survey data, etc). | C. Identify sources of information that will be used (e.g., HSA, previous survey data, etc). | ||
2.) | |||
2.) Summarize any relevant historical information for the survey unit using the following guidance: | |||
A. Summarize the function of the survey unit during facility operation. | A. Summarize the function of the survey unit during facility operation. | ||
B. Summarize any process events, spills or radiological incidents that have been documented in the HSA and are pertinent to the survey unit. | B. Summarize any process events, spills or radiological incidents that have been documented in the HSA and are pertinent to the survey unit. | ||
C. Summarize the current radiological condition of the survey unit using all available past and present radiological surveys [e.g. routine surveys, Radiation Work Permit (RWP) coverage surveys] that are pertinent to the survey unit. | C. Summarize the current radiological condition of the survey unit using all available past and present radiological surveys [e.g. routine surveys, Radiation Work Permit (RWP) coverage surveys] that are pertinent to the survey unit. | ||
LC-FS-PR-002 Final Radiation Survey Package Development | 3.) List the Radionuclides-of-Concern (ROC) and the basis for being included in the sampling plan. | ||
Page 16 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 | |||
NOTE Attachment 1 presents the Basement Dose Factors from LTP Chapter 5, Table 5-3. Attachment 2 presents the site-specific DCGLs for surface soils reproduced from Table 5-2 of LTP Chapter 5. Attachment 3 presents the site-specific DCGLs for buried pipe reproduced from Table 5-3 of LTP Chapter 5. | |||
For multiple radionuclides, the unity rule applies. | For multiple radionuclides, the unity rule applies. | ||
4.) | |||
5.) | 4.) State the release criteria (DCGL or Basement Dose Factors) for each ROC applicable to the survey. | ||
5.) Summarize the radiological survey data that will be used for FSS design for open land and buried pipe survey units. For STS survey units, summarize the historical radiological conditions applicable to the survey unit and proceed to step 5.4.5. | |||
A. Review characterization and/or RASS sample data to determine if adequate data is available to perform FSS design. When preliminary data are not obtained, it may be reasonable to assume a coefficient of variation on the order of 30%, based on experience. | A. Review characterization and/or RASS sample data to determine if adequate data is available to perform FSS design. When preliminary data are not obtained, it may be reasonable to assume a coefficient of variation on the order of 30%, based on experience. | ||
B. Derive and list the basic statistical data for each analyzed radionuclide or direct measurement in the survey data that will be used for the FSS design for the survey unit. At a minimum, the statistics will include the minimum, maximum, mean and median value of the data set and the standard deviation. | B. Derive and list the basic statistical data for each analyzed radionuclide or direct measurement in the survey data that will be used for the FSS design for the survey unit. At a minimum, the statistics will include the minimum, maximum, mean and median value of the data set and the standard deviation. | ||
C. Calculate a mean SOF for the survey data that will be used for the FSS design using the following equation. | C. Calculate a mean SOF for the survey data that will be used for the FSS design using the following equation. | ||
LC-FS-PR-002 Final Radiation Survey Package Development | = 1 1+ 2 2+ | ||
Where Concn = mean concentration of radionuclide n and | |||
DCGLn = DCGL of radionuclide n | |||
D. Calculate a weighted Standard Deviation (SOF) for the survey data that will be used for the FSS design for the survey unit. | |||
2 2 2 | |||
= [( 11) + ( 2DCGL2)+( )] | |||
Where n = standard deviation of radionuclide n and | |||
DCGLn = DCGL of radionuclide n | |||
Page 17 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 | |||
NOTE Characterization RASS data with excessive variability is typically not representative of the radiological condition of the survey unit at the time of the FSS. | |||
E. Assess the variability of the survey data that will be used for survey design. | E. Assess the variability of the survey data that will be used for survey design. | ||
F. Document on the sample plan that the characterization and/or RASS data that will be used for survey design is satisfactory. If the data is not satisfactory, then provide a technical justification to continue the planning process that includes an assessment of process knowledge and historical information. Document the basis in the sample plan or, stop and perform additional surveys and repeat the planning process. | F. Document on the sample plan that the characterization and/or RASS data that will be used for survey design is satisfactory. If the data is not satisfactory, then provide a technical justification to continue the planning process that includes an assessment of process knowledge and historical information. Document the basis in the sample plan or, stop and perform additional surveys and repeat the planning process. | ||
G. Determine the need to sample and analyze for HTD radionuclides or, if a surrogate relationship will be established between the presence of the HTD radionuclide and a gamma-emitting radionuclide. | G. Determine the need to sample and analyze for HTD radionuclides or, if a surrogate relationship will be established between the presence of the HTD radionuclide and a gamma-emitting radionuclide. | ||
: i. If a surrogate relationship is to be established, then describe the survey populations used to establish the relationship, the fraction that will be used to mathematically describe the relationship between the HTD radionuclide and gamma-emitting or easy-to-detect (ETD) radionuclide and the basis for its use. | : i. If a surrogate relationship is to be established, then describe the survey populations used to establish the relationship, the fraction that will be used to mathematically describe the relationship between the HTD radionuclide and gamma-emitting or easy-to-detect (ETD) radionuclide and the basis for its use. | ||
ii. Derive the surrogate DCGL using the following equation; | |||
ii. Derive the surrogate DCGL using the following equation; | |||
1 | |||
[( ) + ( | = 1 | ||
[( 11) + ( 22) + ( 33) + ( )] | |||
7.) | |||
Where DCGLsur = Surrogate DCGL for ETD radionuclide | |||
Rn = Established ratio of radionuclide n with radionuclide to be used as surrogate | |||
DCGLn = DCGL of radionuclide n | |||
6.) Describe the action levels as well as the actions that will be taken if they are reached. The action level provides the criterion used during the decision process for choosing among alternative actions. | |||
7.) Establish the requisite scan coverage area for the sample plan and the basis for the selection. | |||
A. Survey units will be scanned in accordance with their classification. | A. Survey units will be scanned in accordance with their classification. | ||
Scan coverage recommendations for each class of survey unit is presented in Attachment 4. | Scan coverage recommendations for each class of survey unit is presented in Attachment 4. | ||
LC-FS-PR-002 Final Radiation Survey Package Development | Page 18 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 B. If less than 100% scan coverage is required, then designate areas to be scanned using the reference coordinate system that equates to the required total area that is to be scanned and document the basis of why that area was selected. | ||
C. Designate scan locations, and location coordinates on Attachment 16, Scan Area Identification and Coordinates and on the survey map. | C. Designate scan locations, and location coordinates on Attachment 16, Scan Area Identification and Coordinates and on the survey map. | ||
D. If less than 100% scan coverage is required, then a 1-meter radius should be scanned around each probability-based and biased sample location in addition to the area designated for scanning. | D. If less than 100% scan coverage is required, then a 1-meter radius should be scanned around each probability-based and biased sample location in addition to the area designated for scanning. | ||
8.) | |||
9.) | 8.) Determine and document the type and frequency of Quality Control (QC) measurements using the LC-QA-PN-001, FRS QAPP as guidance. | ||
9.) Determine the investigation levels using Attachment 5 as guidance and document in the sampling plan. | |||
NOTE Static and Scan MDC for scanning structures and soil will be determined in accordance with the guidance provided in Attachment 8. | NOTE Static and Scan MDC for scanning structures and soil will be determined in accordance with the guidance provided in Attachment 8. | ||
10.) Determine the type of analyses that will be performed on material sample(s). | 10.) Determine the type of analyses that will be performed on material sample(s). | ||
A. Establish the analytical MDCs and reporting errors necessary to meet objectives of the sampling plan. | A. Establish the analytical MDCs and reporting errors necessary to meet objectives of the sampling plan. | ||
B. Designate the radiological instrumentation that will be used to acquire field measurements and document that the static and scan MDC is sufficient for the action levels specified. | B. Designate the radiological instrumentation that will be used to acquire field measurements and document that the static and scan MDC is sufficient for the action levels specified. | ||
C. Establish criteria for sample moisture content, considering the impact on detection sensitivity to low energy photons or particles (requires drying or maximum moisture content). | C. Establish criteria for sample moisture content, considering the impact on detection sensitivity to low energy photons or particles (requires drying or maximum moisture content). | ||
4.4.5 | |||
2.) | 4.4.5 Define the Study Boundaries | ||
1.) Generate a computerized survey map for the survey unit and include the boundaries of the entire survey unit and major geographic or physical features. (If necessary, drawings may be substituted for computer generated maps). Ensure the graphic representation of the dimensions and boundaries correspond to the established reference coordinate system. | |||
2.) Describe the boundaries, physical conditions, orientation and landmarks of the survey unit using the following guidance: | |||
A. Describe the spatial boundaries of the survey unit, including length and width in meters. | A. Describe the spatial boundaries of the survey unit, including length and width in meters. | ||
LC-FS-PR-002 Final Radiation Survey Package Development | Page 19 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 B. Describe the different surfaces and media present in the survey unit (e.g. surface soil, sediment bed, sand beach). | ||
C. Describe any physical landmarks or prominent features present. | C. Describe any physical landmarks or prominent features present. | ||
D. Describe the orientation of the survey unit in relation to other survey units, prominent or established geographic landmarks and compass direction. | D. Describe the orientation of the survey unit in relation to other survey units, prominent or established geographic landmarks and compass direction. | ||
3.) | |||
4.) | 3.) Describe the temporal boundaries, including the anticipated schedule for performing the survey, the expected weather conditions and any time constraints. | ||
5.) | |||
4.4.6 | 4.) Describe any applicable and practical constraints or conditions when survey performance may not be possible, including but not limited to, physical obstacles to access the area of interest and inclement weather. | ||
4.4.7 | |||
5.) Identify contingencies when possible to define acceptable solutions or alternatives to these constraints. | |||
4.4.6 Develop a Decision Rule - Using the If, Then format, and create a condition or set of condition(s) where a conclusion or set of conclusions can be made in regard to the objectives of the survey based on comparison of the survey results with the action level(s) and/or an assessment of the data statistics. | |||
4.4.7 Specify Limits on Decision Errors | |||
1.) State the null hypothesis (e.g., The survey unit exceeds the release criteria.) | |||
NOTE Section 5.5.2.2 of LTP Chapter 5 presents the logic and reasoning employed to determine adequate areal coverage based upon contamination potential for each STS survey unit. The required number of ISOCS measurements required in each STS survey unit was then calculated as the quotient of the ISOCS Field-of-View (FOV) divided into the surface area required for areal coverage. To ensure that the number of ISOCS measurements based on the necessary areal coverage in a STS survey unit was sufficient to satisfy a statistically based sample design, a simplified calculation was performed to determine sample size using the guidance in MARSSIM. This calculation is summarized in section 5.5.2.2 of LTP Chapter 5 and was applied to the Class 1 and 2 STS survey units. Attachment 6 presents the STS survey units and the minimum number of ISOCS measurements that shall be taken in each for STS. | NOTE Section 5.5.2.2 of LTP Chapter 5 presents the logic and reasoning employed to determine adequate areal coverage based upon contamination potential for each STS survey unit. The required number of ISOCS measurements required in each STS survey unit was then calculated as the quotient of the ISOCS Field-of-View (FOV) divided into the surface area required for areal coverage. To ensure that the number of ISOCS measurements based on the necessary areal coverage in a STS survey unit was sufficient to satisfy a statistically based sample design, a simplified calculation was performed to determine sample size using the guidance in MARSSIM. This calculation is summarized in section 5.5.2.2 of LTP Chapter 5 and was applied to the Class 1 and 2 STS survey units. Attachment 6 presents the STS survey units and the minimum number of ISOCS measurements that shall be taken in each for STS. | ||
LC-FS-PR-002 Final Radiation Survey Package Development | 2.) If performing survey design for STS, then proceed to 5.4.8, step 5. | ||
Page 20 of 46 LC-FS-PR-002 Final Radiation Survey Package Development Revision 0 3.) Define both the Type I, or ( value) error and the Type II, or ( value) error as 0.05. The Type I error will always be set at 0.05 unless prior NRC approval is granted for using a less restrictive value. The Type II error may be adjusted with the concurrence of the RP FRS Manager, after weighing the resulting change in the number of required sample or measurement locations against the risk of unnecessarily investigating and/or remediating survey units that are truly below the release criterion. | |||
NOTE If no other information is available regarding the survey unit, the LBGR may be initially set equal to 0.5 times the applicable DCGLW and may be set as low as the MDC for the specific analytical technique. | NOTE If no other information is available regarding the survey unit, the LBGR may be initially set equal to 0.5 times the applicable DCGLW and may be set as low as the MDC for the specific analytical technique. | ||
4.) | |||
4.4.8 | 4.) Establish the LBGR. The LBGR should be initially set at the mean concentration of residual radioactivity that is estimated to be present in the survey unit or the mean Sum-of-Fractions (SOFMean) if multiple radionuclides are present. | ||
4.4.8 Optimize the Design. | |||
NOTE The Sign Test is expected to be the most appropriate test for LCSRP FRS results because background is expected to constitute a small fraction of the DCGL. | NOTE The Sign Test is expected to be the most appropriate test for LCSRP FRS results because background is expected to constitute a small fraction of the DCGL. | ||
1.) | |||
1.) Calculate the relative shift (/) using the following equation: | |||