Text

Restoration Project, FSS Final Report - Phase 1
	ML18331A013
Person / Time
Site:	Zion File:ZionSolutions icon.png
Issue date:	10/31/2018
From:	Wood G; ZionSolutions
To:	; Office of Nuclear Material Safety and Safeguards
Shared Package
ML18331A015	List: ML18331A003; ML18331A004; ML18331A005; ML18331A006; ML18331A007; ML18331A008; ML18331A009; ML18331A010; ML18331A011; ML18331A012; ML18331A013; ZS-2018-0093, Submittal of Final Status Survey (FSS) Final Report - Phase 1;
References
	ZS-2018-0093
	Download: ML18331A013 (45)
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ZION STATION RESTORATION PROJECT FINAL STATUS SURVEY FINAL REPORT - PHASE 1 OCTOBER 2018

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 TABLE OF CONTENTS 1 Introduction ............................................................................................................................. 6 1.1 Executive Summary ......................................................................................................... 6 1.2 Phased Submittal Approach ............................................................................................. 9 2 Final Status Survey Program Overview ................................................................................ 10 2.1 Survey Planning ............................................................................................................. 12 2.2 Survey Design ................................................................................................................ 16 2.3 Survey Implementation .................................................................................................. 19 2.4 Survey Data Assessment ................................................................................................ 20 2.5 Quality Assurance and Quality Control Measures ......................................................... 20 3 Site Information .................................................................................................................... 21 3.1 Site Description .............................................................................................................. 21 3.2 Survey Unit Description ................................................................................................. 22 3.3 Summary of Historical Radiological Data ..................................................................... 24 3.4 Conditions at the Time of Final Status Survey .............................................................. 26 3.5 Identification of Potential Contaminants........................................................................ 26 3.6 Radiological Release Criteria ......................................................................................... 27 4 Final Status Survey Protocol ................................................................................................. 27 4.1 Data Quality Objectives ................................................................................................. 27 4.2 Survey Unit Designation and Classification .................................................................. 32 4.3 Background Determination ............................................................................................ 33 4.4 Final Status Survey Sample Plans .................................................................................. 33 4.5 Survey Design ................................................................................................................ 33 4.5.1 Determination of Number of Data Points ............................................................... 33 4.5.2 Sample Locations .................................................................................................... 34 4.6 Instrumentation............................................................................................................... 34 4.6.1 Detector Efficiencies ............................................................................................... 35 4.6.2 Detector Sensitivities .............................................................................................. 35 4.6.3 Instrument Maintenance and Control...................................................................... 36 4.6.4 Instrument Calibration ............................................................................................ 36 4.7 Survey Methodology ...................................................................................................... 36 4.7.1 Scan Surveys ........................................................................................................... 36 4.7.2 Soil Sampling .......................................................................................................... 37 3

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 4.8 Quality Control Surveys ................................................................................................. 37 5 Survey Findings .................................................................................................................... 38 5.1 Survey Data Conversion................................................................................................. 39 5.2 Survey Data Verification and Validation ....................................................................... 39 5.3 Anomalous Data/Elevated Scan Results and Investigation ........................................... 40 5.4 Evaluation of Number of Sample/Measurement Locations in Survey Units ................. 40 5.5 Comparison of Findings with Derived Concentration Guideline Levels ....................... 41 5.6 Description of ALARA to Achieve Final Activity Levels ............................................. 42 5.7 NRC/Independent Verification Team Findings ............................................................. 42 6 Summary ............................................................................................................................... 43 7 References ............................................................................................................................. 43 8 Appendices ............................................................................................................................ 45 4

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 LIST OF TABLES Table 1-1, Phase 1 Survey Units ..................................................................................................... 7 Table 2-1, Base Case and Operational DCGLs for Surface Soils(1) ............................................. 15 Table 2-2, Typical Final Status Survey Unit Areas ...................................................................... 16 Table 2-3, Dose Significant Radionuclides and Mixture(1)........................................................... 17 Table 4-1, Surrogate Ratios .......................................................................................................... 29 Table 4-2, Action Levels for Phase 1 Survey Units...................................................................... 30 Table 4-3, Number of Surface Soil Samples for FSS ................................................................... 34 Table 4-4, Recommended Scan Coverage .................................................................................... 36 Table 4-5, Summary of Total Area Scanned ................................................................................ 37 Table 5-1, Basic Statistical Properties of Phase 1 Systematic Sample Populations ..................... 39 Table 5-2, Mean Base Case SOF and Dose Contribution from Soil ............................................ 41 LIST OF FIGURES Figure 1-1, Phase 1 Survey Unit Locations .................................................................................... 8 Figure 2-1, Characterization/License Termination Group Organizational Chart ......................... 11 5

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 1 Introduction 1.1 Executive Summary The purpose of this Phase 1 Final Status Survey (FSS) Final Report is to provide a summary of the survey results and overall conclusions which demonstrate that the Zion Nuclear Power Station (ZNPS) facility, or portions of the site, meets the 25 mrem per year release criterion as established in Nuclear Regulatory Commission Regulation 10 CFR 20.1402 Radiological Criteria for Unrestricted Use. This Phase 1 FSS Final Report encompasses open land area surface soils. The FSS results provided herein assess and summarize that any residual radioactivity results in a Total Effective Dose Equivalent (TEDE) to an average member of the critical group (AMCG) that does not exceed 25 mrem per year, and the residual radioactivity has been reduced to levels that are as low as reasonably achievable (ALARA). The release criterion is translated into site-specific Derived Concentration Guideline Levels (DCGLs) for assessment and summary.

This report documents that FSS activities were performed consistent with the guidance provided in the Zion Nuclear Power Station, Units 1 and 2 - Issuance of Amendments 191 and 178 for the Licenses to Approve the License Termination Plan (LTP) (Reference 1);

NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) (Reference 2); ZS-LT-01, Quality Assurance Project Plan for Characterization and FSS (QAPP) (Reference 3); ZS-LT-300-001-001, Final Status Survey Package Development (Reference 4); ZS-LT-300-001-003, Isolation and Control for Final Status Survey (Reference 5); ZS-LT-300-001-004, Final Status Survey Data Assessment (Reference 6); as well as various station implementing procedures.

Revision 2 of the Zion LTP, along with the accompanying Safety Evaluation Report (SER) was approved on September 28, 2018. The Phase 1 Final Report and all attached Release Records have been verified compliant with Zion LTP Rev. 2, including work completed prior to the final approval of Rev 2.

This FSS Final Report has been written consistent with the guidance provided in NUREG-1757, Vol. 2, Consolidated Decommissioning Guidance Characterization, Survey, and Determination of Radiological Criteria (Reference 7); MARSSIM; and the requirements specified in ZS-LT-300-001-005, Final Status Survey Data Reporting (Reference 8).

To facilitate the data management process, FSS Final Reports will incorporate multiple Survey Unit Release Records. Release Records are complete and unambiguous records of the as-left radiological status of specific survey units. Sufficient data and information are provided in each Release Record to enable an independent re-creation and evaluation at some future time of both the survey activities and the derived results.

This Phase 1 Final Report specifically addresses ten (10) open land area survey units that total approximately 221,234 m2 in area. This report contains a compilation of all ten (10) 6

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 Release Records that are within the Phase 1 scope. Table 1-1 provides a listing of all the survey units addressed in this report, along with their classifications and size. Figure 1-1 depicts the locations of the survey units in relation to the ZNPS site as well as survey unit boundaries.

All FSS activities essential to data quality have been implemented and performed under approved procedures. Trained individuals, using properly calibrated instruments and laboratory equipment that are sensitive to the suspected contaminants, performed the FSS of the Phase 1 survey units. The survey data for all Phase 1 survey units demonstrate that the dose (TEDE) from residual radioactivity is less than the maximum annual dose (TEDE) which corresponds to the release criterion for license termination for unrestricted use specified in 10 CFR 20.1402 and support the release of these areas from the 10 CFR 50 licenses. Additionally, the ALARA requirement of 10 CFR 20.1402 has been satisfied.

Table 1-1, Phase 1 Survey Units Survey Unit Name Class Size (m2) 10205 Switchyard 3 54,573 10212A NE Corner of Exclusion Area - Lakeshore 3 12,256 10213A NE Corner of Exclusion Area - Power House 3 11,887(1) 10219A Area Far South of Switchyard (A) 3 2,433 10219B Area Far South of Switchyard (B) 3 7,516 10220C Adjacent to South Restricted Area - Lakeshore 3 27,870 10222 North Beach Area 3 21,778 10223 Power Block Beach Area 3 12,371 10224 South Beach Area 3 14,608 10301 West Training Area 3 55,942 2

(1) Survey Unit area varies from implemented survey design (12,255m ) as detailed in section 3.2 As stated above, this report contains only the results of the FSS that address the dose due to soil. Based upon the results of groundwater monitoring performed on the ZNPS site since June of 1998 (when both Zion units were placed in a SAFSTOR condition) through the current period of active decommissioning, no groundwater contamination has been identified by groundwater monitoring as of the date of this Final Report. However, if groundwater contamination is identified during decommissioning, the dose will be calculated using the Groundwater Exposure Factors presented in Chapter 6 of the LTP.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 Figure 1-1, Phase 1 Survey Unit Locations 8

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 1.2 Phased Submittal Approach To minimize the incorporation of redundant historical assessment and other FSS program information, and to facilitate potential phased releases from the current licenses, FSS Final Reports will be prepared in a phased approach. ZionSolutions estimates that a total of four (4) FSS Final Reports will be generated and submitted to the NRC during the decommissioning project.

Release of Non-Impacted Open lands On August 27, 2015, ZionSolutions submitted a request (ZS-2015-0134) to release a portion of the ZNPS site from the 10 CFR 50 licenses (DPR-39 and DPR-48) in accordance with 10 CFR 50.83, Release of Part of a Power Reactor Facility or Site for Unrestricted Use, and 10 CFR 100, Reactor Site Criteria. Specifically, a report was generated for the request that addresses the release of eleven (11) non-impacted open land areas from the 10 CFR 50 licenses. The report contains a summary of the final assessment performed as well as a summary of the characterization surveys performed of these non-impacted survey units. ZionSolutions reviewed and assessed the subject property to ensure that the radiological condition of these land areas will have no adverse impact on the ability of the site, in aggregate, to meet the 10 CFR 20, Subpart E, Radiological Criteria for License Termination. The submitted report was not captured as a Phased Submittal with a FSS Final Report because the survey units incorporated within the report are classified as non-impacted, and as such, no statistical tests, scan measurements, static measurements, or elevated measurement comparisons are required. The release of the non-impacted areas from the license(s) was approved by the NRC on March 31, 2016.

Phase 2, 3, and 4 Final Status Survey Final Reports As discussed above, ZionSolutions anticipates three additional FSS Final Report submittals. The schedule and identity of survey units included in each of the remaining submittals were developed based on a review of the demolition and FSS schedule, as well as in consideration of NRC review requirements. The demolition schedule, including the cleanup of demolition debris to allow survey access, is dynamic and subject to continued refinement. With potential changes in the decommissioning schedule, it is possible that interim submittals will be filed with the NRC with the goal of providing Release Records as soon as possible to support review and the potential release of site open lands.

The Phase 2 FSS Final Report will encompass remaining basement structures, embedded pipe, penetrations, and buried pipe. The Phase 3 FSS Final Report will include the open land survey units encompassing the southern portion of the site, and the Phase 4 FSS Final Report will encompass the northern portion.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 2 Final Status Survey Program Overview The FSS Program consists of the methods used in planning, designing, conducting, and evaluating FSS at the ZNPS site to demonstrate that the premises are suitable for release in accordance with the criteria for decommissioning in Title 10 CFR 20, Subpart E. Final Status Surveys serve as key elements to demonstrate that the Total Effective Dose Equivalent (TEDE) to an Average Member of the Critical Group (AMCG) from residual radioactivity does not exceed 25 mrem per year, and that all residual radioactivity at the site is reduced to levels that are ALARA.

To implement the FSS Program, ZionSolutions established the Characterization/License Termination (C/LT) Group, within the Radiation Protection division, with sufficient management and technical resources to fulfill project objectives. The C/LT Group is responsible for the safe completion of all surveys related to characterization and final site closure. Approved site procedures and detailed technical support documents (TSD) direct the FSS process to ensure consistent implementation and adherence to applicable requirements. Figure 2-1 provides an organizational chart of the C/LT Group.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 Figure 2-1, Characterization/License Termination Group Organizational Chart 11

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 2.1 Survey Planning Following the cessation of commercial operation, the development and planning phase was initiated in 1999 by the ComEd Zion Station Historical Site Assessment (HSA)

(Reference 9) and the initiation of the characterization process. The characterization process is iterative and will continue until, in some cases, up to the time of completing FSS.

The HSA consisted of a review of site historical records regarding plant incidents, radiological survey documents, and routine and special reports submitted by Exelon to various regulatory agencies. Along with these assessments, interviews with current and past site personnel, reviews of historical site photos, and extensive area inspections were performed to meet the following objectives:

Develop the information necessary to support FSS design, including the development of Data Quality Objectives (DQO) and survey instrument performance standards.

Develop the initial radiological information to support decommissioning planning, including building decontamination, demolition, and waste disposal.

Identify any unique radiological or health and safety issues associated with decommissioning.

Identify the potential and known sources of radioactive contamination in systems, surface or subsurface soils, groundwater, and on structures.

Divide the ZNPS site into manageable areas or units for survey and classification purposes.

Determine the initial classification of each survey area or unit as non-impacted or impacted. Impacted survey areas or units are Class 1, 2, or 3, as defined in MARSSIM.

Data Quality Objectives are qualitative and quantitative statements derived from the DQO process that clarify technical and quality objectives, define the appropriate type of data, and specify the tolerable levels or potential decision errors used as the basis for establishing the quality and quantity of data required to support inference and decisions. This process, described in MARSSIM and Procedure ZS-LT-300-001-001, Final Status Survey Package Development, is a series of graded planning steps found to be effective in establishing criteria for data quality and guiding the development of FSS Sample Plans. DQOs developed and implemented during the initial phase of planning directed all data collection efforts.

The DQO approach consists of the following seven steps:

State the Problem - This step provides a clear description of the problem, identification of planning team members (especially the decision makers), a conceptual model of the hazard to be investigated, and the estimated resources required to perform the survey. The problem associated with FSS is to determine whether a given survey unit meets the radiological release criterion of 10 CFR 20.1402.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1

Identify the Decision - This step consists of developing a decision statement based on a principal study question (i.e., the stated problem) and determining alternative actions that may be taken based on the answer to the principle study question. Alternative actions identify the measures to resolve the problem. The decision statement combines the principal study question and alternative actions into an expression of choice among multiple actions. For the FSS, the principal study question is: Does residual radioactive contamination present in the survey unit exceed the established DCGL values? The alternative actions may include no action, investigation, resurvey, remediation, and reclassification.

Identify Inputs to the Decision - The information required depends on the type of media under consideration (e.g., soil, water, concrete) and whether existing data are sufficient or new data are needed to make the decision. If the decision can based on existing data, then the source(s) will be documented and evaluated to ensure reasonable confidence that the data area acceptable. If new data are needed, then the type of measurement (e.g., scan, direct measurement, sampling) will need to be determined.

Define the Study Boundaries - The step includes identification of the target population of interest, the spatial and temporal features of that population, the time frame for collecting the data, practical constraints, and the scale of decision making.

In FSS, the target population is the set of samples or direct measurements that constitute an area of interest. The medium of interest is specified during the planning process. The spatial boundaries include the entire area of interest, including soil depth, area dimensions, contained water bodies, and natural boundaries. Temporal boundaries include activities impacted by time-related events including weather conditions, season, operation of equipment under different environmental conditions, resource loading, and work schedule.

Develop a Decision Rule - The step develops the binary statement that defines a logical process for choosing among alternative actions. The decision rule is a clear statement using the If...then... format and includes action level conditions and the statistical parameter of interest.

Specify Tolerable Limits on Decision Errors - This step incorporates hypothesis testing and probabilistic sampling distributions to control the decision errors during data analysis. Hypothesis testing is a process based on the scientific method that compares a baseline condition (the null hypothesis) to an alternative condition (the alternative hypothesis). Hypothesis testing rests on the premise that the null hypothesis is true and that sufficient evidence must be provided to reject it.

Optimize the Design for Obtaining Data - The final step in the DQO process leads to the development of an adequate survey design. By using an on-site analytical laboratory, sampling and analysis processes are designed to provide near real-time data assessment during implementation of field activities and FSS. Gamma scans 13

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 provide information on soil areas that have residual radioactivity greater than background and allow appropriate selection of biased sampling and measurement locations. This data will be evaluated and used to refine the scope of field activities to optimize implementation of the FSS design and ensure the DQOs are met.

As stated, the primary objective of the DQO process was to demonstrate that the level of residual radioactivity found in the soils in the land area survey units, including any areas of elevated activity, was equal to or below the site-specific DCGLs that correspond to the 25 mrem/yr release criterion.

The LTP defines surface soil as that contained in a 0.15 m depth from the surface. The LTP defines subsurface as that contained in a 1 m depth of soil from the surface. Site-specific DCGLs were calculated for both the surface and subsurface soils. Based on characterization data and historical information (LTP Chapter 5, section 5.2.3), there are no expectations of encountering a source term geometry that is comprised of a clean surface layer of soil over a contaminated subsurface soil layer. ZionSolutions TSD 14-011, Soil Area Factors (Reference 10) and LTP Chapter 6, section 6.8, provides the exposure scenarios and modeling parameters that were used to calculate the site-specific DCGLs for soils (referred to as Base Case Soil DCGLs).

Each radionuclide-specific Base Case DCGL is equivalent to the level of residual radioactivity (above background levels) that could, when considered independently, result in a TEDE of 25 mrem per year to an AMCG. To ensure that the summation of dose from each source term is 25 mrem/year or less after all FSS is completed, the Base Case DCGLs are reduced based on an expected, or a priori, fraction of the 25 mrem/year dose limit from each source term. These reduced values are designated as Operational DCGLs (LTP Chapter 5, section 5.2.4) and these Operational DCGLs are then used as the DCGL for the FSS design of the survey unit (calculation of surrogate DCGLs, investigations levels, etc.).

Details of the Operational DCGLs derived for each dose component and the basis for the applied a priori dose fractions are provided in ZionSolutions TSD 17-004, Operational Derived Concentration Guideline Levels for Final Status Survey (Reference 11).

Table 2-1 provides a listing for the surface soil Base Case and Operational DCGLs of the main Radionuclides of Concern (ROC) used for the FSS of the Phase 1 land areas.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 Table 2-1, Base Case and Operational DCGLs for Surface Soils(1)

Base Case Operational Radionuclide DCGL DCGL (pCi/g) (pCi/g)

Co-60 4.26 1.091 Cs-134 6.77 1.733 Cs-137 14.18 3.630 Ni-63 3,572.10 914.458 Sr-90 12.09 3.095 (1) Compiled from Tables 5-5 and 5-7 of the LTP The development of information to support decommissioning planning and execution was accomplished through a review of all known site radiological and environmental records.

Much of this information was consolidated in the HSA, TSD 14-028, Radiological Characterization Report (Reference 12), and in files containing copies of records maintained pursuant to Title 10 CFR 50.75(g) (1). These documents are discussed further in applicable sections of this report.

An initial objective of site characterization and assessment was to correlate the impact of a radiological event to physical locations on ZNPS site and to provide a means to correlate subsequent survey data. To satisfy these objectives, the entire 331 acre site was divided into survey areas. Survey area size determination was based upon the specific area and the most efficient and practical size needed to bound the lateral and vertical extent of contamination identified in the area. Survey areas that have no reasonable potential for contamination were classified as non-impacted. These areas had no radiological impact from site operations and are identified in the HSA. Survey areas with reasonable potential for contamination were classified as impacted.

Classification, as described in MARSSIM, is the process by which an area or survey unit is described according to its radiological characteristics and potential for residual radioactivity. Residual radioactivity could be evenly distributed over a large area, appear as small areas of elevated activity, or a combination of both. In some cases, there may be no residual radioactivity in an area or survey unit. Therefore, the adequacy and effectiveness of the FSS process depends upon properly classified survey units to ensure that areas with the highest potential for contamination receive a higher degree of survey effort.

The classified survey areas established by the HSA were further divided into survey units.

The suggested surface area limits provided in MARSSIM were used to establish the initial set of survey units for the LTP. A survey unit is a portion of a structure or open land area that is surveyed and evaluated as a single entity following FSS. Survey units were 15

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 delineated to physical areas with similar operational history or similar potential for residual radioactivity to the extent practical. To the extent practical, survey units were established with relatively compact shapes and highly irregular shapes were avoided unless the unusual shape was appropriate for the site operational history or the site topography. For identification, survey units were assigned a five-digit number that could be further modified by a letter for future divisions if needed (e.g.., if the classification changes, then the corresponding survey unit size limitation changes). Physically, survey unit boundaries were determined using commercially available mapping software with coordinates consistent with the Illinois State Plane System North American Datum (NAD). Table 2-2 provides an outline for classification versus area size for open land survey units consistent with MARSSIM, Table 1.

Table 2-2, Typical Final Status Survey Unit Areas Classification Area Type Suggested Area Class 1 Land Up to 2,000 m2 Class 2 Land 2,000 to 10,000 m2 Class 3 Land No Limit Prior to FSS, each survey units classification is reviewed and verified in accordance with the LTP and its implementing procedures. A classification change to increase the class may be implemented without notification to regulatory authorities. A classification change to decrease the class may be implemented only after accurate assessment and notification to regulatory authorities as detailed in the LTP and its implementing procedures. Typically, reclassification occurs after the evaluation of continuing characterization results or emergent data indicates a more restrictive classification is required. Final classification was performed in conjunction with the preparation of the FSS Sample Plan. The Sample Plan reconciles all outstanding characterization data into the final characterization.

2.2 Survey Design Final Status Surveys for the ZNPS site are designed following ZionSolutions procedures, the LTP, and MARSSIM guidance. FSS design utilizes the combination of traditional scanning surveys, systematic sampling protocols and investigative/judgmental methodologies to evaluate survey units relative to the applicable release criteria for open land sample plans.

To aid in the development of an initial suite of potential radionuclides of concern for the decommissioning of ZNPS, the analytical results of representative characterization samples collected at the site were reviewed. In general, the samples associated with these results were collected from within various waste/process streams and sent off site to meet the analysis criteria of 10 CFR 61, Subparts C and D. This initial suite of potential radionuclides was further refined by the Containment and Auxiliary Building concrete core 16

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 data analysis. This analysis determined that Co-60, Cs-134, Cs-137, Ni-63, and Sr-90 accounted for 99.5% of all dose in the contaminated concrete mixes. For activated concrete, H-3, Eu-152, and Eu-154, in addition to the five aforementioned nuclides, accounted for 99% of the dose. Due to the assumption that all activated concrete will be removed and disposed of as waste, the final suite of ROC for all areas outside of the Containments does not include H-3, Eu-152, and Eu-154.

The results of surface and subsurface soil characterization in the impacted area surrounding ZNPS indicate that there is minimal residual radioactivity in soil. At this time, based on the characterization survey results to date, ZSRP does not anticipate the presence of significant concentrations of soil contamination. In addition, based on process knowledge, minimal contamination is expected in any of the buried piping that may be abandoned in place. Consequently, due to the absence of any significant source term in soil or in any buried piping, the suite of ROC and radionuclide mixture derived for the Auxiliary Building concrete was considered a reasonably conservative mixture to apply to soils for FSS planning and implementation. The final suite of potential radionuclides and the mixture to be applied to soils is provided in Table 2-3.

Table 2-3, Dose Significant Radionuclides and Mixture(1)

% of Total Activity Radionuclide (normalized)

Co-60 0.92 Cs-134 0.01 Cs-137 75.32 Ni-63 23.71 Sr-90 0.05 (1) Compiled from Table 5-2 of the LTP Characterization results determined that Co-60 and/or Cs-137 would be the primary ROC for the majority of survey design. All the FSS results provided in this report utilize Cs-137 as the primary ROC. Cs-137 characterization data for the survey units discussed in this report were used to determine the expected variability, number of samples required, and investigation levels for FSS design.

The dose contribution from each ROC is accounted for using the Sum-of-Fractions (SOF) to ensure that the total dose from all ROC does not exceed the dose criterion. The SOF or unity rule is applied to the data used for the survey planning, and data evaluation and statistical tests for soil sample analyses since multiple radionuclide-specific measurements will be performed or the concentrations inferred based on known relationships. The application of the unity rule serves to normalize the data to allow for an accurate 17

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 comparison of the various data measurements to the release criteria. When the unity rule is applied, the DCGLW (used for the nonparametric statistical test) becomes one (1). The soil DCGLs (DCGLSS, DCGLSB) are directly analogous to the DCGLW as defined in MARSSIM. The use and application of the unity rule will be performed in accordance with section 4.3.3 of MARSSIM.

Survey design objectives included a verification of the survey instruments ability to detect the radiation(s) of interest relative to the DCGL. As standard practice to ensure that this objective was consistently met, radiation detection instruments used in FSS were calibrated on a yearly frequency with a National Institute of Standards and Technology (NIST) traceable source in accordance with ZionSolutions procedures. Instruments were response checked before and after use. Minimum Detectable Count Rates (MDCR) were established and verified prior to FSS. Control and accountability of survey instruments were maintained and documented to assure quality and prevent the loss of data.

Based upon classification, areas were selected and scanned with gamma radiation detection instruments. Information obtained during the survey was automatically logged by the instrument for review and analysis. Sample and scan coordinates were identified using a random sample tool in Visual Sample Plan (VSP), and a survey unit-specific required scan surface area was applied around the sample point. Sample location coordinates were programmed into a Global Positioning System (GPS), then physically located and marked.

Investigational samples were collected at areas of elevated scan readings. All details and instructions were incorporated into the survey area/units FSS Sample Plan.

Surface soil samples were collected to a depth of 0.15 meters below the top soil surface.

Leaves, rocks, roots, and other objects were excluded as much as possible from the sample.

In Class 3 open land survey units, no subsurface soil samples were taken as part of the survey design. If a surface soil sample measurement had exceeded 75% of the Operational DCGL, then a subsurface soil sample would have been required from the same location.

This scenario was not encountered during the FSS of any of the 10 open land survey units addressed in this report.

Designated soil samples were sent to an off-site laboratory for Hard-to-Detect (HTD) analysis. Laboratory DQO and analysis results were summarized in Release Records and reported as actual calculated results. Sample report summaries within the Release Records included unique sample identification, analytical method, radioisotope, result, uncertainty of two standard deviations, laboratory data qualifiers, units, and required Minimum Detectable Concentration (MDC).

Another consideration of survey design was the use of surrogates. In lieu of analyzing every sample for HTD radionuclides, the development and application of Surrogate Ratio DCGLs as described in MARSSIM, Sect. 4.3.2 was applied to estimate HTD radionuclides.

Surrogate ratios allow for expedient decision making in characterization, remediation planning, or FSS design.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 A surrogate is a mathematical ratio where an Easy-to-Detect (ETD) radionuclide (i.e., Cs-137) concentration is related to a HTD radionuclide (i.e., Sr-90) concentration. From the analytical data, a ratio is developed and applied in the survey scheme for samples taken in the area. Details and applications of this method are provided in section 5.2.11 of the LTP.

Some portion of the radioactivity found in the soil samples is certainly attributed to fallout or background. Due to the lack of significant activity revealed during background studies, assessments and characterization, it was determined that background subtraction would not be applied during FSS.

2.3 Survey Implementation Final Status Survey implementation of the Phase 1 survey units started in March, 2016.

Implementation was the physical process of the FSS Sample Plan execution for a given survey unit. Each Sample Plan was assigned to an FSS Engineer for implementation and completion in accordance with ZionSolutions procedures and the QAPP for Characterization and FSS. The tasks included in the implementation were:

Verification and validation of personnel training as required by Training Department and Radiation Protection procedures.

Monitoring instrument calibration as detailed in ZS-RP-108-000-000, Radiological Instrumentation Program (Reference 13) and ZS-RP-108-004-012, Calibration and Initial Set Up of the 2350-1 (Reference 14).

Implementation of applicable operating and health and safety procedures.

Implementation of isolation of control of the survey unit in accordance with ZS-LT-300-001-003, Isolation and Control for Final Status Survey.

Determination of the amount of sampling required to meet DQOs as described in ZS-LT-300-001-001, Final Status Survey Package Development.

Determination of sample locations and creation of survey unit maps displaying the locations in accordance with ZS-LT-300-001-001.

Proper techniques for collecting and handling FSS samples in accordance with Job Aid LT-JA-004, FSS Sample Collection (Reference 15).

Maintaining Quality Assurance/Quality Control requirements (i.e., replicate measurements or samples) in accordance with the QAPP for Characterization and FSS.

Sample Chain-of-Custody maintained in accordance with ZS-LT-100-001-004, Sample Media Preparation for Site Characterization (Reference 16).

Sample submission to approved laboratories in accordance with ZS-WM-131, Chain of Custody Protocol (Reference 17).

Application of the DCGLs to sample results in accordance with the Data Quality Assessment (DQA) process as detailed in ZS-LT-300-001-004, Final Status Survey Data Assessment.

Determination of investigation methodology and corrective actions, if applicable.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 The FSS implementation and completion process resulted in the generation of field data and analysis data consisting of measurements taken with handheld radiation detecting equipment, observations noted in field logs, and radionuclide specific analysis. Data were stored electronically on the ZionSolutions common network.

2.4 Survey Data Assessment Prior to proceeding with data evaluation and assessment, the assigned FSS Engineer ensures consistency between the data quality and the data collection process and the applicable requirements.

The DQA process is an evaluation method used during the assessment phase of FSS to ensure the validity of FSS results and demonstrate achievement with the FSS Sample Plan objectives. A key step in the data assessment process converts all of the survey results to DCGL units, if necessary. The individual measurements and sample concentrations are compared to the DCGL for evidence of small areas of elevated activity or results that are statistical outliers. When practical, graphical analyses of survey data that depicts the spatial correlation of the measurements was used.

For the Class 3 Open Land areas addressed by this final report, the survey data was evaluated using the Sign Test (as described in the LTP). The Sign Test is a one-sample statistical test that compares data directly to the release criteria. Combined with an effective sampling scheme, passing the Sign Test satisfies the release criteria. Selection of the Sign Test is prudent and conservative in the assumption that the radionuclides being considered are not present in background or are at levels at a small fraction of the applicable release criteria. Furthermore, any background contribution (e.g., Cs-137 from global fallout) in the sample increases the likelihood of failing the survey unit, which is conservative. If the release criteria were exceeded or if results indicated the need for additional data points, appropriate further actions were implemented usually through the issue of an addendum to the FSS Sample Plan.

2.5 Quality Assurance and Quality Control Measures Quality assurance and control measures were employed throughout the FSS process to ensure that all decisions were based on data of acceptable quality. Quality assurance and control measures were applied to ensure:

The plan was correctly implemented.

The DQA process was used to assess results.

DQOs were properly defined and derived.

All data and samples were collected by individuals with the proper training and in adherence to approved procedures and sample plans.

All instruments were properly calibrated.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1

All collected data was validated, recorded, and stored in accordance with approved procedures.

All required documents were properly maintained.

Corrective actions were prescribed, implemented and tracked, as necessary.

Independent laboratories used for analysis of the samples collected during FSS maintain Quality Assurance Plans designed for their facility. ZionSolutions reviews these plans, as required by ZS-QA-10, Quality Assurance Project Plan (Reference 18) and the QAPP for Characterization and FSS, prior to selection of a laboratory for FSS sample analysis to ensure standards are acceptable.

The ZionSolutions QA department provided oversight of the Characterization/License Termination Group on a consistent basis throughout the project at ZSRP. QA surveillances have scrutinized the LTP, C/LT procedures, Sample Plans, and C/LT records. The responses to the QA surveillances are captured in the Corrective Action Program (CAP).

3 Site Information 3.1 Site Description Zion Nuclear Power Station, owned by Exelon Nuclear Generation, LLC (Exelon), is located in Zion, Illinois, on the west shore of Lake Michigan. The site is approximately 40 miles north of Chicago, Illinois, and 42 miles south of Milwaukee, Wisconsin.

The owner-controlled site consists of approximately 331 acres, and within the owner-controlled area is an approximate 87-acre, fence-enclosed nuclear facility. The center of the community of Zion is approximately 1.6 miles from the plant location on the site.

There are no schools or hospitals within one mile of the site, and no residences are within 2,000 feet of any ZNPS structures.

Westinghouse Electric Corporation, Sargent and Lundy Engineers, and the Commonwealth Edison Company (ComEd) jointly participated in the design and construction of ZNPS.

The plant was comprised of two pressurized water reactors with supporting facilities. The primary coolant system for each unit employed a four-loop pressurized water reactor nuclear steam supply system housed in a steel-lined, reinforced concrete containment structure. Each unit employed a pressurized water reactor nuclear steam supply system furnished by Westinghouse Electric Corporation, designed for a power output of 3,250 MWt. The equivalent warranted gross and approximate net electrical outputs of the plant were 1085 MWe and 1050 MWe, for Unit 1 and Unit 2 respectively.

ZNPS was previously operated by Commonwealth Edison until it was permanently shut down on February 13, 1998. On March 9, 1998, ComEd certified to the NRC that all fuel assemblies had been permanently removed from both reactors and placed in the Spent Fuel Pool. The NRC acknowledged the certification of permanent cessation of power operation and permanent removal of fuel from the reactor vessels in a letter dated May 4, 1998. In 21

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 2000, the licenses were transferred from ComEd to Exelon. In 2008, the licenses were transferred to ZionSolutions to coordinate and execute the decommissioning of the site.

The Post Shutdown Decommissioning Activities Report (PSDAR) (Reference 19) was submitted, in accordance with 10 CFR 50.82(a), in February 2000 and accepted by the NRC. An amended PSDAR was submitted in March 2008 to accommodate the transfer of the 10 CFR 50 licenses to ZionSolutions and to revise cost estimates and the decommissioning schedule. The Defueled Safety Analysis Report (DSAR) (Reference 20) was updated in October 2016. An evaluation of the systems, structures, and components (SSCs) was performed to determine the function these systems would perform in a defueled condition. With the relocation of the spent fuel to the Independent Spent Fuel Storage Installation (ISFSI), the license basis for the majority of the SSCs was changed and only minimal SSCs were needed to support the ongoing active decommissioning. The remaining SSCs needed to support active decommissioning had controls established in the DSAR and the Offsite Dose Calculation Manual (ODCM) (Reference 21).

On November 2, 2011, site characterization commenced. At the time these surveys were performed, the site-specific ZionSolutions characterization plans and procedures were still under development. Consequently, due to schedule restraints, ZionSolutions contracted the EnergySolutions Commercial Services Group (ESCSG) to perform characterization of the ISFSI location, the Vertical Concrete Cask (VCC) Construction Area, and the pathway for the new rail track. The results of these surveys were validated and integrated into the subsequent site-specific characterization program, which was approved in February 2012.

Initial scheduled site characterization efforts concluded on November 11, 2013.

3.2 Survey Unit Description The following information is a description of each survey unit at the time of FSS from March, 2016 until March 2017. During this period, ten (10) FSS, covering approximately 54.67 acres (221,234 m2), were completed on the open land areas surrounding ZNPS which are presented in this Phase 1 Final Report.

Survey Unit 10205 Survey Unit 10205 or Switchyard, was classified as Class 3 and consists of approximately 54,573 m2 (13.49 acres) of open land. It is bounded by Class 2 survey unit 10214A, 10214B, and 10214C to the north, Class 1 survey units 10204A, 10206A, 10207A, 10208A to the east, the Independent Spent Fuel Storage Installation (ISFSI) to the south, and non-impacted survey units 10216 and 10217 to the west.

Survey Unit 10212A Survey Unit 10212A or Northeast Corner of Exclusion Area - Lakeshore, was classified as Class 3 and consists of approximately 12,256 m2 (3.03 acres) of open land. It is bounded by Class 3 survey unit 10222 to the east, Class 3 survey unit 10213A to the west, 22

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 Class 3 survey unit 10212B to the north, and Class 1 survey units 10201A, 10202A, and 10203E to the south. A drainage ditch runs west to east along the southern edge of the survey unit.

Survey Unit 10213A Survey Unit 10213A or Northeast Corner of Exclusion Area - Power House, was classified as Class 3 and consists of approximately 11,887 m2 (2.94 acres) of open land. It is bounded by survey unit 10212A to the east, the site access road and Class 2 survey unit 10214D to the west, Class 3 survey unit 10212B to the north, and Class 1 survey units 10203B, 10203C, and 10203D to the south. The FSS was designed and performed to the previous area of the survey unit, which was 12,255 m2. A portion of the southwest corner of the survey unit was a major vehicle traffic area. To minimize the impact of vehicles driving over a portion of the survey unit after FSS was performed, the southwest corner (approximately 368 m2 in area) was attributed to the adjacent survey unit which will be surveyed in a later phase of the project.

Survey Unit 10219A Survey Unit 10219A or Area Far South of Switchyard (A), was classified as Class 3 and consists of approximately 2,433 m2 (0.60 acres) of open land. It is bounded by a wetlands area and non-impacted survey unit 10217 to the south, Class 3 survey unit 10219B to the west, the ISFSI area to the north, and Class 2 survey unit 10220B to the east. A wetlands depression area runs along the southern edge of the survey unit.

Survey Unit 10219B Survey Unit 10219B or Area Far South of Switchyard (B), was classified as Class 3 and consists of approximately 7,516 m2 (1.86 acres) of open land. It is bounded by the ISFSI to the north, wetlands areas and non-impacted survey unit 10217 to the west and south, and Class 3 survey unit 10219A to the east.

Survey Unit 10220C Survey Unit 10220C or Adjacent to South Restricted Area - Lakeshore, was classified as Class 3 and consists of approximately 27,870 m2 (6.89 acres) of open land. It is bounded by Class 2 survey units 10220A, 10220B, and 10220D to the north, non-impacted survey units 10217 and 10304 to the west, and Class 3 survey unit 10224 and Lake Michigan to the east and the Illinois Beach State Park to the south. Bull Creek traverses the center of the survey unit in an east/west direction.

Survey Unit 10222 Survey Unit 10222 or North Beach Area, was classified as Class 3 and consists of approximately 21,778 m2 (5.38 acres) of open land. It is bounded by Class 3 survey units 10212B and 10212A and Class 1 survey units 10201A, 10201B, 10201C, and 10201D to 23

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 the west, Class 3 survey unit 10223 to the south, Lake Michigan to the east, and Hosah Park and non-impacted survey unit 10402 to the north.

Survey Unit 10223 Survey Unit 10223 or Power Block Beach Area, was classified as Class 3 and consists of approximately 12,371 m2 (3.06 acres) of open land. It is bounded by Class 1 survey units 12101, 12102, 12103, 12204A, 12204B, 12204C, 12112, and 12203D to the west, Class 3 survey unit 10224 to the south, Class 3 survey unit 10222 to the north, and Lake Michigan to the east.

Survey Unit 10224 Survey Unit 10224 or South Beach Area, was classified as Class 3 and consists of approximately 14,608 m2 (3.61 acres) of open land. It is bounded by Class 1 survey units 10211A, 10211B, 10221E, 10221F, 10221G, and 10221H to the west, Class 3 survey unit 10223 to the north, Class 3 survey unit 10220C to the south, and Lake Michigan to the east.

Survey Unit 10301 Survey Unit 10301 or West Training Area, was classified as Class 3 and consists of approximately 55,942 m2 (13.82 acres) of open land. It is bounded by Shiloh Boulevard to the north, non-impacted survey unit 10215 to the east, and non-impacted survey unit 10306 to the south.

3.3 Summary of Historical Radiological Data The site historical radiological data for this Phase 1 FSS Final Report at ZNPS incorporates the results of the HSA issued in 1999 and supplemented in 2006, and includes the initial characterization surveys completed in 2013.

Historical Site Assessment The HSA was a detailed investigation to collect existing information (from the start of ZNPS activities related to radioactive materials or other contaminants) for the site and its surroundings. The HSA focused on historical events and routine operational processes that resulted in contamination of plant systems, onsite buildings, surface and subsurface soils within the Radiologically Controlled Area (RCA). It also addressed support structures, open land areas and subsurface soils outside of the RCA but within the owner controlled area. The information compiled by the HSA was used to establish initial area survey units and their MARSSIM classifications. This information was used as input into the development of site-specific DCGLs, remediation plans and the design of the FSS. The scope of the HSA included potential contamination from radioactive materials, hazardous materials, and other regulated materials.

The objectives of the HSA were to:

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1

Identify potential, likely, or known sources of radioactive and chemical contaminants based on existing or derived information.

Distinguish portions of the site that may need further action from those that pose little or no threat to human health.

Provide an assessment of the likelihood of contaminant migration.

Provide information useful to subsequent continuing characterization surveys.

Provide an initial classification of areas and structures as non-impacted or impacted.

Provide a graded initial classification for impacted soils and structures in accordance with MARSSIM guidance.

Delineate initial survey unit boundaries and areas based upon the initial classification.

The survey units established by the HSA were used as initial survey units for characterization. Prior to characterization, survey unit sizes were adjusted in accordance with the guidance provided in MARSSIM section 4.6 for the suggested physical area sizes for survey units for FSS.

For the survey units of interest in this report; the HSA indicated that the presence of residual radioactivity in concentrations in excess of the unrestricted release criteria was not expected, several survey units residing outside of the Radiologically Restricted Area that were originally classified as non-impacted in the HSA were reclassified as Class 3 due to expected decommissioning activities in areas adjacent to or in near proximity to the open land survey units (10301, 10222, 10223, 10224, and 10220C).

Characterization Surveys Site characterization of the ZNPS was performed in accordance with ZS-LT-02, Characterization Survey Plan (Reference 22). It was developed to provide guidance and direction to the personnel responsible for implementing and executing characterization survey activities. The Characterization Survey Plan worked in conjunction with implementing procedures and survey unit specific survey instructions (sample plans) that were developed to safely and effectively acquire the requisite characterization data.

Characterization data acquired through the execution of the Characterization Survey Plan was used to meet three primary objectives:

Provide radiological inputs necessary for the design of FSS.

Develop the required inputs for the LTP.

Support the evaluation of remediation alternatives and technologies and estimate waste volumes.

The final output of the initial site characterization was TSD 14-028, Radiological Characterization Report. The report concluded that based on the results of the characterization surveys, it was expected that minimal residual plant-derived radioactivity was present in the 10 survey units addressed by this report.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 3.4 Conditions at the Time of Final Status Survey The land areas discussed in this report are open land areas with little to no disturbance occurring since the shut-down of ZNPS. Most survey units contained thick undergrowth which had to be trimmed before FSS implementation. A transmission right-of-way runs through the property and borders within survey units 10213A and 10301. During 2011 and 2012, survey units 10219A and 10219B were utilized as soil laydown areas during the construction of the ISFSI.

Prior to FSS, areas ready for survey were isolated and controlled under ZS-LT-300-001-003, Isolation and Control for Final Status Survey. This included posting of the area as well as notifications to site personnel. Permission must be obtained from C/LT staff to enter and work in these areas. Posting of the boundaries controls public access, a routine surveillance program monitors for any inadvertent public access with procedurally defined recovery and reporting protocols in the event of any impact to these survey units final status.

3.5 Identification of Potential Contaminants ZionSolutions TSD 11-001, Potential Radionuclides of Concern during the Decommissioning of Zion Station (Reference 23) was prepared and approved in November 2011. The purpose of this document was to establish the basis for an initial suite of potential ROC for the decommissioning. Industry guidance was reviewed as well as the analytical results from the sampling of various media from past plant operations.

Based on the elimination of some of the theoretical neutron activation products, noble gases and radionuclides with a half-life of less than two years, an initial suite of potential ROC for the decommissioning of the ZNPS was prepared.

As shown by the FSS Release Records, the plant related radionuclide identified in most of the samples was Cs-137. For all of the samples, the concentrations of Cs-137 were typical of the concentrations determined from off-site locations and fallout as documented by TSD 13-004, Examination of Cs-137 Global Fallout in Soils at Zion Station (Reference 24).

Co-60 was not identified in any sample from the FSS of the survey units discussed in this report.

Cs-137 deposition resulting from global fallout is thought to be the source of most of the Cs-137 encountered in samples collected in the open lands surrounding ZNPS. Geological deposition, regional concentrations and transport mechanisms are well documented and the subject of numerous publications and studies. However, as a conservative measure, Cs-137 resulting from fallout or background was not subtracted from analytical results for FSS at ZNPS.

In accordance with the LTP, a minimum of 10% of the systematic sample population or any sample with a SOF of 0.1 or greater was sent to an off-site laboratory for HTD ROC 26

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 analysis. This process is done to verify the surrogate ratios between HTD ROC and the ETD ROC as established in the LTP. For soil samples with positive results for both a HTD ROC and the corresponding surrogate radionuclide, the HTD to surrogate ratio was derived. The maximum surrogate ratio was used during data assessment. Analyses for HTD radionuclides identified Sr-90 and Ni-63 in some samples, but the conditions related above were not encountered, except for in survey unit 10223, where Cs-137 and Sr-90 were both identified in one sample. The surrogate ratio was calculated and used for data assessment, as it was greater than that given in the LTP. More details are presented in the Release Record for survey unit 10223.

During the FSS implementation, areas of interest were scanned with portable, hand-held radiation detection meters. Prior to scanning, background levels were determined and investigation levels set in accordance with the Sample Plan. Areas were then scanned for elevated readings. When an elevated area was found, the area was marked and a sample collected at that location for gamma spectroscopy analysis and further evaluation.

3.6 Radiological Release Criteria All FSSs for the land area surveys submitted in the Phase 1 Final Report were conservatively designed to the Operational DCGL for surface soils and all results were compared to this value. However, since the release criteria were based on the Base Case DCGL, surpassing the Operational DCGL did not disqualify a survey unit from meeting the release criteria provided that the Base Case DCGL was not surpassed as well.

4 Final Status Survey Protocol 4.1 Data Quality Objectives The DQO process as outlined in Section 2 of this report was applied for each FSS Sample Plan and contains basic elements common to all FSS Sample Plans at ZSRP. An outline of those elements presented in the ZSRP FSS Sample Plans are as follows:

State the Problem The problem: To demonstrate that the level of residual radioactivity in a survey unit does not exceed the release criteria of 25 mR/year TEDE and that the potential dose from residual radioactivity is ALARA.

Stakeholders: The primary stakeholders interested in the answer to this problem are ZionSolutions LLC, Exelon Nuclear Generation LLC (Exelon), the Illinois Environmental Management Agency (IEMA) and the United States Nuclear Regulatory Commission (USNRC).

The Planning Team: The planning team consisted of the assigned C/LT Engineer with input from other C/LT personnel as well as the Safety Department. The primary decision maker was the Technical Lead/Radiological Engineer with input from the C/LT Manager.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 Schedule: The approximate time projected to mobilize, implement, and asses an FSS unit was eight (8) days.

Resources: The following resources were necessary to implement an FSS Sample Plan:

C/LT Engineer to prepare the plan and evaluate data.

C/LT Field Supervisor to monitor and coordinate field activities.

Survey Mapping/CAD Specialist to prepare survey maps, layout diagrams, composite view drawings, and other graphics as necessary to support design and reporting.

C/LT Technicians to perform survey activities, collect survey measurement data, and collect media samples.

Chemistry/Analysis laboratory Staff to analyze samples as necessary.

Identify the Decision Principal Study Question: Are the residual radionuclide concentrations found in the soil equal to or below site-specific DCGLs for surface soils?

Alternate Actions: Alternative actions include failure of the survey unit, remediation, reclassification, and resurvey.

The Decision: If the survey unit fails to demonstrate compliance with the release criteria, then the survey unit is not suitable for unrestricted release. The DQA process is reviewed to identify the appropriate additional action or combination of actions.

Identify Inputs to the Decision Information Needed: The survey unit requiring evaluation of residual activity and its surface area. The characterization surveys and HSA were preliminary sources of information for FSS. New measurements of sample media are needed to determine the concentration and variability for those radionuclides potentially present at the site at the time of FSS.

Historical Information: The classification as originally identified in the HSA and the verification of that classification during characterization. A summary of site processes or incidents that occurred in the survey unit.

Radiological Survey Data: The current radiological survey data from characterization, Remedial Action Support Surveys (RASS), Radiological Assessments (RAs), or turnover surveys. This information is used to develop a sample size for FSS.

Radionuclides of Concern: The ROC for the FSS of open land areas are presented in Section 2.2, Table 2-3, of this report.

Basis for the Action Level: The action level for the FSS of Class 3 open land areas was 50%

of the Operational DCGL, in accordance with Table 5-25 of the LTP.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 During FSS, concentrations for HTD ROC Ni-63 and Sr-90 were inferred using a surrogate approach. As presented in the LTP, Cs-137 is the principle surrogate radionuclide for Sr-90 and Co-60 is the principle surrogate radionuclide for Ni-63. The mean, maximum and 95% Upper Confidence Level (UCL) of the surrogate ratios for concrete core samples taken in the Auxiliary Building basement were calculated in ZionSolutions TSD 14-019, Radionuclides of Concern for Soil and Basement Fill Model Source Terms (Reference

25) and are presented in Table 4-1. The maximum ratios are used in the surrogate calculations during FSS unless area specific ratios are determined by continuing characterization.

Table 4-1, Surrogate Ratios Auxiliary Building Ratios Mean Max 95%UCL Ni-63/Co-60 44.143 180.450 154.632 Sr-90/Cs-137 0.001 0.002 0.002 For the FSS of the relevant survey units in this report, the surrogate Operational DCGLs for Co-60 and Cs-137 were computed based on the maximum ratios from Table 4-1.

The equation for calculating a surrogate DCGL is as follows:

1

=

1 2 3

+ + +

2 3 Where: DCGLSur = Surrogate radionuclide DCGL DCGL2,3n = DCGL for radionuclides to be represented by the surrogate Rn = Ratio of concentration (or nuclide mixture fraction) of radionuclide n to surrogate radionuclide Using the Operational DCGLs presented in Table 2-1 and the maximum ratios from Table 4-1, the following surrogate calculations were performed:

1 (137) = = 3.622 /

1 0.002 3.630 +

(137) 3.095 (90)

The surrogate Operational DCGL that was used for Cs-137 in the survey units for direct comparison of sample results to demonstrate compliance is 3.622 pCi/g.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 1

(60) = = 0.898 /

1 180.45 1.091 +

(60) 914.458(63)

The surrogate Operational DCGL that was used for Co-60 in the survey units for direct comparison of sample results to demonstrate compliance is 0.898 pCi/g.

The action level for investigation in a Class 3 open land survey unit was 50% of the Operational DCGL. The surrogate DCGL for Co-60 while inferring Ni-63 is 0.898 pCi/g, and the surrogate DCGL for Cs-137 while inferring Sr-90 is 3.622 pCi/g. Using the normalized mixture for gamma emitting ROC from Table 2-3, the surrogate adjusted gamma DCGL is then calculated as follows:

1

() = = 3.494 /

0.012 0.00001 0.988 0.898 + 1.733 + 3.622 (60) 134 (137)

The surrogate adjusted gamma DCGL equals 3.494 pCi/g. The action levels for the Phase 1 survey units are based on 50% of the DCGL and are presented in Table 4-2.

Table 4-2, Action Levels for Phase 1 Survey Units DCGL ROC (pCi/g)

(1)

Co-60 0.449 Cs-134 (2) 0.867 (3)

Cs-137 1.811 (4)

Gross Gamma 1.747 (1) Based on 50% of surrogate adjusted DCGL of 0.898 pCi/g for Co-60 while inferring Ni-63.

(2) Based on 50% of Operational DCGL.

(3) Based on 50% of surrogate adjusted DCGL of 3.622 pCi/g for Cs-137 while inferring Sr-90.

(4) Based on 50% of surrogate adjusted DCGLs of 3.494 pCi/g for gamma emitting ROC.

Investigation Levels: The scan investigation level was based on 50% of the normalized surrogate adjusted DCGLs for gamma emitting ROC. The soil investigation level was 50%

of the Operational DCGL. Investigation levels were developed in accordance with Table 5-25 of the LTP.

Sampling and Analysis Methods to Meet the Data Requirements: Surface soil samples were collected down to a depth of 0.15 meters (6 inches) and analyzed for gamma emitting radionuclides by the on-site gamma spectroscopy. The media consisted of soils and sand as required to complete the FSS. Subsurface soil sampling was not required in these Class 3 30

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 survey units. Typically, fourteen (14) surface soil samples were required for FSS, with the exception of survey unit 10222, which had fifteen (15).

The target MDC for measurements obtained using laboratory instruments was 10% of the applicable Operational DCGL. Measurement results with associated MDC that exceeded these values were accepted as valid data after evaluation by health physics supervision.

The evaluation considered the actual MDC, the reported value for the measurement result, the reported uncertainty, and the fraction of the Operational DCGL identified in the sample.

As per the LTP, 10% of the volumetric samples (a minimum of 1) collected during FSS, or any sample with a SOF of 0.1 or greater were sent off-site for HTD ROC analysis. These analyses aimed to reaffirm that the radionuclide mix was not significantly different than that assumed in the LTP.

Table 5-24 of the LTP specifies that the required scanning coverage for Class 3 open land survey units is judgmental. For the Phase 1 survey units, a scan coverage of 5% of the total area of the survey unit was selected. Walkover scans were conducted with a Ludlum Model 2350-1 instrument coupled to a Ludlum Model 44-10 detector at a scanning speed of 0.25 m/sec.

All activities fell under the QAPP for Characterization and FSS, which requires, among other things, the use of trained technicians, calibrated instruments, and procedures. In addition to these requirements, a minimum of 5% of the required number of samples were selected for QC evaluation. At least one (1) duplicate soil sample was collected in each survey unit for QC evaluation. In addition, for each survey unit, replicate scans were conducted on 5% of the scan locations chosen at random.

Define the Boundaries of the Survey Boundaries of the Survey: The actual physical boundaries as stated for each survey unit.

Temporal Boundaries: Estimated times and dates for the survey. Scanning and sampling in a survey unit was normally performed only during daylight and dry weather.

Constraints: The most common constraints were the weather, brush or undergrowth, and standing water in a survey unit.

Develop a Decision Rule Decision Rule: If any measurement data results exceeded the release criteria, the DQA process would be used to evaluate alternative actions.

Specify Tolerable Limits on Decision Errors The Null Hypothesis: Residual radioactivity in the survey unit exceeds the release criteria.

Type I Error: This is also known as the error. This is the error associated with incorrectly concluding the null hypothesis has been rejected. In accordance with LTP section 5.6.4.1.1, the error was set at 0.05 (5%).

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 Type II Error: This is also known as the error. This is the error associated with incorrectly concluding the null hypothesis has been accepted. In accordance with LTP section 5.6.4.1.1, the error was set at 0.05 (5%).

The Lower Bound of the Gray Region (LBGR): The LBGR was set at 50% of the Operational DCGL. In using the unity rule, the Operational DCGL becomes one (1) and the LBGR is set as 0.5.

Optimize Design Type of Statistical Test: The Sign Test was selected as the non-parametric statistical test for FSS. The Sign Test is conservative as it increases the probability of incorrectly accepting the null hypothesis (i.e., the conclusion will be that the survey unit does not meet the release criteria) and does not require the selection or use of a background reference area.

Number of Systematic Samples: For a relative shift of three (3), the number of systematic samples is fourteen (14). The locations of the samples were determined using software Visual Sample Plan (VSP).

Number of Judgmental Samples and Locations: The selection of judgmental samples was at the discretion of the C/LT Engineer. Locations chosen for sampling were usually areas of interest (small piles, trenches, etc.).

Number of Scan Areas and Locations: For each survey unit, a scan area was developed around each systematic sample location that, when totaled, equated to 5% of the total surface area of the survey unit. Typically, the survey unit contained fourteen (14) random scan areas. In some cases, due to physical constraints in the survey unit, scan areas were combined or moved.

Number of Samples for Quality Control: The number of quality control samples was 5%

percent of sample set. The locations for duplicate samples and replicate scan areas were selected randomly using a random number generator.

Power Curve: The Prospective Power Curve, developed using characterization data and COMPASS software, showed adequate power for the survey design in each of the survey units.

4.2 Survey Unit Designation and Classification Procedure ZS-LT-300-001-002, Survey Unit Classification (Reference 26), defines the decision process for classifying an area in accordance with the LTP and MARSSIM.

During the FSS of areas submitted for the Phase 1 Final Report, no survey units were wholly reclassified. A small portion of survey unit 10213A was divided off and then added to the adjacent survey unit, 10214D, after FSS was performed, because it was a major vehicle traffic area. The Survey Unit Release Record for 10213A details the impact of the change to the survey unit.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 4.3 Background Determination During FSS area scanning, ambient backgrounds were determined and the technician established the Alarm Set Point (ASP) based on the background for that scan area. Each survey unit Release Record discusses scan area readings. Instrument readings for each scan area are enclosed with each Release Record in the appendices.

4.4 Final Status Survey Sample Plans The level of effort associated with planning a survey is based on the complexity of the survey and nature of the hazards. Guidance for preparing FSS plans is provided in procedure ZS-LT-300-001-001 Final Status Survey Package Development. The FSS plan uses an integrated sample design that combines scanning surveys and sampling.

4.5 Survey Design 4.5.1 Determination of Number of Data Points The number of soil samples for FSS was determined in accordance with procedure ZS-LT-300-001-001 Final Status Survey Package Development and MARSSIM. The relative shift (/) for the survey unit data set is defined as shift (), which is the Upper Boundary of the Gray Region (UBGR), or the DCGL (SOF of 1), minus the Lower Bound of the Gray Region (LBGR) (SOF of 0.5), divided by sigma (), which is the standard deviation of the data set used for survey design (characterization). The relative shift for all Phase 1 survey units was three (3). The sample size from Table 5.5 in MARSSIM that equates to and errors of 0.05 and a relative shift of 3 is 14. One (1) sample location was added to the systematic sample population (15 samples total) in survey unit 10222 as a measure to ensure enough survey coverage as a large portion of the survey unit was inaccessible due to the changing water level of Lake Michigan.

A breakdown of the number of soil samples collected for the Phase 1 survey units is provided in Table 4-3 below.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 Table 4-3, Number of Surface Soil Samples for FSS Systematic Judgmental Investigation Survey Unit Samples Samples Samples 10205 14 - -

10212A 14 6 2 10213A 14 - 2 10219A 14 8 -

10219B 14 - -

10220C 14 5 -

10222 15 - -

10223 14 - -

10224 14 1 -

10301 14 1 2 4.5.2 Sample Locations Locations of the samples were determined using software Visual Sample Plan (VSP). VSP software imports a topographical map of the selected survey area and designates the sample locations with coordinates and bearings based on the Illinois State Plane System. Pacific Northwest National Laboratory (PNNL) created VSP for the United States Department of Energy. For those locations where access was impractical or unsafe, alternate random sample locations were generated and documented. Sample locations were identified using GPS coordinates and are consistent with the Illinois State Plane System. Once located, sample points were physically marked as required by ZS-LT-300-001-001 and graphically plotted using drafting software.

4.6 Instrumentation Radiation detection and measurement instrumentation for performing FSS is selected to provide both reliable operation and adequate sensitivity to detect the ROC identified at the site at levels sufficiently below the Operational DCGL. Detector selection is based on detection sensitivity, operating characteristics and expected performance in the field.

The DQO process includes the selection of instrumentation appropriate for the type of measurement to be performed (i.e., scan measurements and sample analysis) that are calibrated to respond to a radiation field under controlled circumstances; evaluated periodically for adequate performance to established quality standards; and sensitive enough to detect the ROC with a sufficient degree of confidence.

The field instrumentation will, to the extent practicable, use data logging to automatically record measurements to minimize transcription errors.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 Specific implementing procedures control the issuance, use, and calibration of instrumentation used for FSS. The specific DQOs for instruments are established early in the planning phase for FSS activities, implemented by standard operating procedures and executed in the FSS Sample Plan.

4.6.1 Detector Efficiencies The Ludlum Model 2350-1 Data Logger coupled with the Ludlum Model 44-10 2" x 2" Sodium Iodide (NaI) Gamma Scintillation Detector was selected as the primary radiation detection instrumentation for performing scanning for FSS land surveys at ZNPS.

4.6.2 Detector Sensitivities The evaluation of open land areas requires a detection methodology of sufficient sensitivity for the identification of small areas of potentially elevated activity. Scanning measurements are performed by passing a hand-held detector, primarily the Ludlum Model 44-10 NaI detector, in gross count rate mode across the land surface under investigation.

The centerline of the detector was maintained at the ground to detector distance detailed in the sample plan and moved from side to side in a 1-meter wide pattern at a rate of 0.25 m/sec. The audible and visuals signals were monitored for detectable increases in count rate. An observed count rate increase resulted in further investigation to verify findings and to define the level and extent of residual radioactivity.

An a priori determination of scanning sensitivity was performed to ensure that the measurement system (including the surveyor) was able to detect concentrations of radioactivity at levels below the regulatory release limit. The specified performance level and surveyor efficiency was expressed in terms of scan MDCR. This sensitivity is the lowest count rate that can be reliably detected at any given background by the measurement system. The specified MDCR correlates to the targeted MDC.

This approach represents the surface scanning process for land areas defined in NUREG-1507, Minimum Detectable Concentrations with Typical Radiation Survey Instruments for Various Contaminants and Field Conditions (Reference 27). The gamma scan MDCR is discussed in detail in ZionSolutions TSD 11-004, Ludlum Model 44-10 Detector Sensitivity (Reference 28) which examines the gamma sensitivity for a 5.08 by 5.08 cm (2 x 2) NaI detector to several radionuclide mixtures of Co-60 and Cs-137 using sand (SiO2) as the soil base. TSD 11-004 derives the MDCR for the radionuclide mixtures at various detector distances and scan speeds. The model in TSD 11-004 uses the same geometry configuration as the model used in MARSSIM. TSD 11-004 provides MDCR values for the expected ZNPS soil mixture based on detector background condition, scan speed, soil depth (0.15 meters), soil density (1.6 g/cm3) and detector distance to the surface of interest.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 4.6.3 Instrument Maintenance and Control Control and accountability of survey instruments were maintained to assure the quality and prevent the loss of data. All personnel operating radiological instruments, analysis equipment, measurement location equipment etc., were qualified to operate any assigned equipment and recognize off normal results and indications.

4.6.4 Instrument Calibration Instruments and detectors were calibrated for the radiation types and energies of interest or to a conservative energy source. Instrument calibrations were documented with calibration certificates and/or forms and maintained with the instrumentation and project records.

Calibration labels were also attached to all portable survey instruments. Prior to using any survey instrument, the current calibration was verified and all operational checks were performed.

Instrumentation used for FSS was calibrated and maintained in accordance with approved ZionSolutions site calibration procedures. Radioactive sources used for calibration were traceable to the NIST and were obtained in standard geometries to match the type of samples being counted. When a characterized high-purity germanium (HPGe) detector was used, suitable NIST-traceable sources were used for calibration, and the software set up appropriately for the desired geometry. If vendor services were used, these were obtained in accordance with purchasing requirements for quality related services, to ensure the same level of quality.

4.7 Survey Methodology 4.7.1 Scan Surveys The LTP specifies the minimum amount of scanning required for each class as summarized in Table 4-4. The total fraction of scanning coverage is determined during the DQO process with the amount, and location(s) based on the likelihood of finding elevated activity during FSS.

Table 4-4, Recommended Scan Coverage Area Classification Surface Scans Class 1 100%

10% to 100%,

Class 2 Systematic and Judgmental Class 3 Judgmental Each scan area was located with GPS and marked. The scan areas surrounding the random sample locations, when totaled, equated to a minimum of ~5% of the total surface area of 36

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 the survey unit. Each scan area (typically 14 total for a survey unit) was completely scanned. Areas with elevated readings were marked and investigational samples were collected. The probe was positioned as close to the ground as possible and was moved at a scan speed of about 0.25 meters per second. Table 4-5 provides a summary of the area scanned during FSS.

Table 4-5, Summary of Total Area Scanned Survey Survey Unit Area Scanned %

Area (m2)

Unit Classification (m2) Scan 10205(1) 3 54,573 0 0 (2) 10212A 3 12,256 916 8 (2) 10213A 3 12,255 1,180 10 10219A 3 2,433 126 5 10219B 3 7,516 378 5 10220C 3 27,870 1,400 5 10222 3 21,778 1,200 5 10223 3 12,371 630 5 10224 3 14,608 756 5 10301 3 55,942 2,800 5 1: No scanning was performed in survey unit 10205, due to safety concerns.

2: Includes judgmental scan areas.

During the scanning, the technician recorded data and observations in a Field Log. This log documented field activities and other information pertaining to the survey.

4.7.2 Soil Sampling In accordance with the FSS Sample Plan and applicable job aids, FSS technicians collected surface soil samples at locations specified by the survey design. Each sample location was documented, along with soil conditions and observations, and a chain of custody was developed to maintain sample integrity.

4.8 Quality Control Surveys The method used for evaluating Quality Control (QC) split samples collected in support of the FSS program is specified in the QAPP for Characterization and FSS. QC split data was assessed using criteria taken from the USNRC Inspection Manual, Inspection Procedure 84750, Radioactive Waste Treatment and Effluent and Environmental Monitoring (Reference 29).

A minimum of 5% of the sample locations used in the FSS design were selected randomly using the Microsoft Excel RANDBETWEEN function and submitted as splits. Most 37

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 splits taken for FSS were field replicates, that is, samples obtained from one location, homogenized, divided into separate containers, and treated as separate samples. These samples were then used to assess errors associated with sample heterogeneity, sample methodology, and analytical procedures. It is desirable that when analyzed, there is agreement between the splits resulting in data acceptance. If there was no agreement between the samples, the C/LT Engineer evaluated the magnitude and impact on survey design, the implementation and evaluation of results as well as the need to perform confirmatory sampling. If the C/LT Engineer had determined that the discrepancy affected quality or was detrimental to the implementation of FSS, then a Condition Report would have been issued.

To maintain the quality of the FSS, isolation and control measures were implemented throughout FSS activities until there was no risk of recontamination from decommissioning or when the survey area will be released from the licenses. Following FSS, and until the area is released, a semi-annual surveillance will be performed on FSS completed survey units. This includes an inspection of area postings, inspection of the area for signs of dumping or disturbance and some sampling from selected locations. In the event that isolation and control measures were compromised, a follow-up survey may be performed after evaluation.

5 Survey Findings Procedure ZS-LT-300-001-004, Final Status Survey Data Assessment, provides guidance to C/LT personnel to interpret survey results using the DQA process during the assessment phase of FSS activities.

The DQA process is the primary evaluation tool to determine that data is of the right type, quality and quantity to support the objectives of the FSS Sample Plan. The five steps of the DQA process are:

Review the Sample Plan DQOs and the survey design.

Conduct a preliminary data assessment.

Select the statistical test.

Verify the assumptions of the statistical test.

Draw conclusions from the data.

Data validation descriptors described in MARSSIM Table 9.3 were used during the DQA process to verify and validate collected data as required by the QAPP for Characterization and FSS.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 5.1 Survey Data Conversion During the data conversion, the C/LT Engineer evaluated raw data for problems or anomalies encountered during Sample Plan activities (sample collection and analysis, handling and control, etc.) including the following:

Recorded data,

Missing values,

Deviation from established procedure, and

Analysis flags.

Once resolved, initial data conversion, which is part of preliminary data assessment was performed and consisted of converting the data into units relative to the release criteria (e.g., pCi/g) and calculating basic statistical quantities (e.g., mean, median, standard deviation). Table 5-1 provides a summary of the basic statistical properties for Phase 1 systematic sample populations.

Table 5-1, Basic Statistical Properties of Phase 1 Systematic Sample Populations Radionuclide Statistical Summary (pCi/g)

Survey Cs-137 Co-60 Class Samples Unit Standard Standard Max Mean Max Mean Deviation Deviation 10205 3 14 3.42E-02 1.11E-02 0.01087 2.27E-02 8.85E-03 0.00673 10212A 3 14 7.19E-02 2.96E-02 0.02206 1.46E-02 2.71E-03 0.00418 10213A 3 14 3.49E-01 1.10E-01 0.10914 2.49E-02 7.44E-03 0.00913 10219A 3 14 9.07E-02 4.71E-02 0.02654 6.34E-02 1.15E-02 0.01616 10219B 3 14 5.86E-01 2.15E-01 0.14327 2.38E-02 7.09E-03 0.00661 10220C 3 14 3.52E-01 1.67E-01 0.11275 2.93E-02 5.30E-03 0.00875 10222 3 15 2.83E-02 9.69E-03 0.01022 4.71E-02 1.65E-02 0.01506 10223 3 14 1.77E-02 6.44E-03 0.00541 1.54E-02 5.01E-03 0.00520 10224 3 14 2.73E-02 8.67E-03 0.00928 1.90E-02 7.68E-03 0.00554 10301 3 14 2.21E-01 9.03E-02 0.07969 1.88E-02 7.81E-03 0.00707 5.2 Survey Data Verification and Validation Items supporting DQO sample design and data are reviewed for completeness and consistency. This includes:

Classification history and related documents,

Site description,

Survey design and measurement locations,

Analytic method and detection limits and that the required analytical method(s) are adequate for the radionuclides of concern, 39

FINAL STATUS SURVEY FINAL REPORT - PHASE 1

Sampling variability provided for the radionuclides of interest,

QC measurements have been specified,

Survey and sampling result accuracy have been specified,

MDC limits,

Field conditions for media and environment, and

Field records.

Documentation, as listed, is reviewed to verify completeness and that it is legible:

Field and analytical results,

Chain-of-custody,

Field Logs,

Instrument issue, return and source check records,

Instrument downloads, and

Measurement results relative to measurement location.

After completion of these previously mentioned tasks, a Preliminary Data Assessment record was initiated. This record served to verify that all data are in standard units in relation to the DCGLs and requires the calculation of the statistical parameters needed to complete data evaluation which at a minimum, included the following:

The number of observations (i.e., samples or measurements),

The range of observations (i.e., minimum and maximum values),

Mean,

Median, and

Standard deviation.

In order to adequately evaluate the data set, consideration as additional options included the coefficient of variation, measurements of relative standing (such as percentile), and other statistical applications as necessary (frequency distribution, histograms, skew, etc).

Finalization of the data review consisted of graphically displaying the data in distributions and percentiles plots.

5.3 Anomalous Data/Elevated Scan Results and Investigation In survey units 10212A, 10213A, and 10301, elevated scan results resulted in investigations, which included the collection of investigational surface soil samples. This process was documented in accordance with ZS-LT-300-001-004, Final Status Survey Data Assessment.

5.4 Evaluation of Number of Sample/Measurement Locations in Survey Units An effective tool utilized to evaluate the number of samples collected in the sampling scheme is the Retrospective Power Curve generated by MARSSIM 2000 or COMPASS.

The Retrospective Power Curve shows how well the survey design achieved the DQOs.

40

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 For reporting purposes, all Release Records include a Retrospective Power Curve analysis indicating that the sampling design had adequate power to pass the FSS release criteria (i.e.

adequate number of samples was collected).

The Sign Test was selected as the statistical test for all Release Records submitted in this report. This test, performed in accordance with ZS-LT-300-001-004, along with the Retrospective Power Curve demonstrates survey design adequacy. If the data passed the Sign Test and Retrospective Power Curve, the null hypothesis is rejected and the survey unit can be released with no further actions required. For reporting purposes, all survey unit Release Records passed the Sign Test, indicating that the survey design was adequate (i.e. adequate number of samples was collected).

The Elevated Measurement Comparison (EMC) did not apply to the survey units addressed by this report since all were classified as Class 3 survey units and discrete, elevated areas of contamination were not expected.

5.5 Comparison of Findings with Derived Concentration Guideline Levels The SOF or unity rule was applied to FSS data in accordance with the guidance provided in Section 2.7 of NUREG-1757, Vol. 2, and the LTP. This was accomplished by calculating a fraction of the Operational DCGL for each sample or measurement by dividing the reported concentration by the Operational DCGL. If a sample had multiple ROC, then the fraction of the Operational DCGL for each ROC was summed to provide a SOF for the sample.

If a surrogate Operational DCGL was calculated as part of the survey design for the FSS, then the surrogate Operational DCGL calculated was used for the selected surrogate radionuclide. Unity rule equivalents were calculated for each measurement result using the surrogate adjusted Operational DCGL (typically using gamma emitters), and then used to perform the Sign Test, if applicable.

A Base Case SOF was calculated for each ROC by dividing the reported concentration by the Base Case DCGL. A Base Case SOF of 1 is equivalent to the decision rule, meaning any measurement with a SOF of 1 or greater, would not meet the 25 mR/yr release criteria.

The mean Base Case SOF was multiplied by 25 to establish the dose attributed to soil in a survey unit. A summary of the SOF and dose contribution for each Phase 1 survey unit is provided in Table 5-2 below.

Table 5-2, Mean Base Case SOF and Dose Contribution from Soil Mean Base Survey Unit Dose (mR/yr)

Case SOF 10205 0.00406 0.1015 10212A 0.00423 0.1057 41

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 Mean Base Survey Unit Dose (mR/yr)

Case SOF 10213A 0.01082 0.2705 10219A 0.00857 0.2142 10219B 0.01898 0.4745 10220C 0.01400 0.3500 10222 0.00669 0.1673 10223 0.00366 0.0914 10224 0.00418 0.1044 10301 0.00976 0.2439 5.6 Description of ALARA to Achieve Final Activity Levels Section N.1.5 of NUREG-1757, Vol. 2, states that For residual radioactivity in soil at sites that may have unrestricted release, generic analyses show that shipping soil to a low-level waste disposal facility is unlikely to be cost effective for unrestricted release, largely because of the high costs of waste disposal. Therefore shipping soil to a low-level waste disposal facility generally does not have to be evaluated for unrestricted release. Section 4.4.1 of LTP Chapter 4 presents a simple ALARA analysis for the excavation and disposal of soils as low-level radioactive waste that confirms the statement in section N.1.5 of NUREG-1757, Vol. 2 that the cost of disposing excavated soil as low-level radioactive waste is clearly greater than the benefit of removing and disposing of soil with residual radioactivity concentrations less than the dose criterion. Since the cost is greater than the benefit, it is not ALARA to excavate and dispose of soils with residual radioactivity concentrations below the DCGL.

5.7 NRC/Independent Verification Team Findings The Oak Ridge Institute for Science and Education (ORISE) performed confirmatory survey activities in survey unit 10213A during the period of April 25 through April 28, 2016. The other nine (9) Phase 1 survey units were not surveyed independently as ZSRP was in the process of performing the FSS of those areas at the time of the ORISE survey.

Three (3) soil samples were collected from survey unit 10213A as part of the confirmatory survey. Samples and data collected on site were delivered to the ORAU/ORISE facility for analysis and interpretation. Sample custody was transferred to the Radiological and Environmental Analytical Laboratory (REAL) in Oak Ridge, Tennessee. For the soil samples collected from SU 10213A, only Cs-137 was present above the analytical MDC with a maximum concentration of 0.137 pCi/g, which is a small fraction of the surface soil DCGL.

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FINAL STATUS SURVEY FINAL REPORT - PHASE 1 The ORISE Final Report, DCN 5271-SR-02-0, Independent Confirmatory Survey Summary and Results for the Turbine Building Basement and Open Lands Area at the Zion Nuclear Power Station, Zion, Illinois (Reference 30) concluded that the radiological conditions of survey unit 10213A met the criteria for unrestricted release and that the survey unit was properly classified.

6 Summary Final Status Survey (FSS) is the process used to demonstrate that the ZNPS structures and soils comply with the radiological criteria for unrestricted use specified in 10 CFR 20.1402.

The purpose of FSS Sample Plan is to describe the methods to be used in planning, designing, conducting, and evaluating the FSS.

The two radiological criteria for unrestricted use specified in 10 CFR 20.1402 are; 1) the residual radioactivity that is distinguishable from background radiation results in a TEDE to an AMCG that does not exceed 25 mrem/yr, including that from groundwater sources of drinking water, and 2) the residual radioactivity has been reduced to levels that are ALARA.

The ten (10) Class 3 open land survey units addressed in this Final Report have met the DQOs of the FSS Sample Plans developed and implemented for each. In each survey unit, all identified ROC were used for statistical testing to determine the adequacy of the survey unit for FSS, the sample data passed the Sign Test, the null hypothesis was rejected, and a Retrospective Power Curve showed that adequate power was achieved. Each of the 10 survey units were properly classified as Class 3. Evaluation of the data for each survey unit shows that none of the ROC concentration values exceeded the Operational DCGL or any investigational levels and therefore, in accordance with the LTP Section 5.10, the survey unit meets the release criterion.

7 References

1. Zion Nuclear Power Station, Units 1 and 2 - Issuance of Amendments 191 and 178 for the Licenses to Approve the License Termination Plan (LTP) - September 28, 2018

2. NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)

3. ZS-LT-01, Quality Assurance Project Plan for Characterization and FSS (QAPP)

4. ZS-LT-300-001-001, Final Status Survey Package Development

5. ZS-LT-300-001-003, Isolation and Control for Final Status Survey

6. ZS-LT-300-001-004, Final Status Survey Data Assessment

7. NUREG-1757, Vol. 2, Consolidated Decommissioning Guidance Characterization, Survey, and Determination of Radiological Criteria 43

FINAL STATUS SURVEY FINAL REPORT - PHASE 1

8. ZS-LT-300-001-005, Final Status Survey Data Reporting

9. ComEd Zion Station Historical Site Assessment (HSA)

10. TSD 14-011, Soil Area Factors

11. TSD 17-004, Operational Derived Concentration Guideline Levels for Final Status Survey

12. TSD 14-028, Radiological Characterization Report

13. ZS-RP-108-000-000, Radiological Instrumentation Program

14. ZS-RP-108-004-012, Calibration and Initial Set Up of the 2350-1

15. LT-JA-004, FSS Sample Collection

16. ZS-LT-100-001-004, Sample Media Preparation for Site Characterization

17. ZS-WM-131, Chain of Custody Protocol

18. ZS-QA-10, Quality Assurance Project Plan

19. Post Shutdown Decommissioning Activities Report (PSDAR)

20. Defueled Safety Analysis Report (DSAR)

21. Offsite Dose Calculation Manual (ODCM)

22. ZS-LT-02, Characterization Survey Plan

23. TSD 11-001, Potential Radionuclides of Concern during the Decommissioning of Zion Station

24. TSD 13-004, Examination of Cs-137 Global Fallout in Soils at Zion Station

25. TSD 14-019, Radionuclides of Concern for Soil and Basement Fill Model Source Terms

26. ZS-LT-300-001-002, Survey Unit Classification

27. NUREG-1507, Minimum Detectable Concentrations with Typical Radiation Survey Instruments for Various Contaminants and Field Conditions

28. TSD 11-004, Ludlum Model 44-10 Detector Sensitivity

29. Inspection Procedure 84750, Radioactive Waste Treatment and Effluent and Environmental Monitoring

30. DCN 5271-SR-02-0, Independent Confirmatory Survey Summary and Results for the Turbine Building Basement and Open Lands Area at the Zion Nuclear Power Station, Zion, Illinois 44

FINAL STATUS SURVEY FINAL REPORT - PHASE 1 8 Appendices A1 FSS Release Record, Survey Unit 10205 A2 FSS Release Record, Survey Unit 10212A A3 FSS Release Record, Survey Unit 10213A A4 FSS Release Record, Survey Unit 10219A A5 FSS Release Record, Survey Unit 10219B A6 FSS Release Record, Survey Unit 10220C A7 FSS Release Record, Survey Unit 10222 A8 FSS Release Record, Survey Unit 10223 A9 FSS Release Record, Survey Unit 10224 A10 FSS Release Record, Survey Unit 10301 45

ML18331A013

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