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February 2005

Connecticut Yankee Atomic Power CompanyHaddam Neck Plant

Final Status Survey Report - Phase IIFebruary 2005

Prepared By:

k- FSS Engineer

Date: i

Reviewed By:

k FnginotB

Date: I

Approved By: Date:. . _ b _

Connecticut Yankee Atomic Power Company Haddam Neck Plant

Final Status Survey Final Report - Phase 1. February 2005

TABLE OF CONTENTS

1.0 Introduction ................................ 41.1 Executive Summary ..................................... 41.2 Phased Submittal Approach ..................................... 7

2.0 Final Status Survey Program Overview ............................... 102.1 Survey Planning .122.2 Survey Design .162.3 Survey Implementation ..................................... 192.4 Survey Data Assessment .202.5 Quality Assurance and Quality Control Measures .21

3.0 Site Information ....................... 233.1 Site Description .233.2 Survey Area/Unit Description .243.3 Summary of Historical Radiological Data .263.4 Conditions at the Time of Final Status Survey .303.5 Identification of Potential Contaminants .313.6 Radiological Release Criteria .33

4.0 Final Status Survey Protocol ....................... 334.1 Data Quality Objectives .334.2 Survey Unit Designation and Classification .404.3 Background Determination .414.4 Final Status Survey Plans .414.5 Survey Design .424.6 Instrumentation .434.7 Survey Methodology .474.8 Quality Control Surveys .49

5.0 Survey Findings . . ........... 495.1 Survey Data Conversion .505.2 Survey Data Verification and Validation .515.3 Evaluation of Number of Sample/Measurement Locations in Survey Units

525.4 Comparison of Findings with Derived Concentration Guideline Levels 535.5 USNRC/Independent Verification Team Findings .54

6.0 Summary . . ........ 547.0 References .......... 558.0 Appendices .......... 59

Connecticut Yankee Atomic Power Company Haddam Neck P~lant

Final Status Survey Final Report - Phase H February 2005

LIST OF TABLES

1-1 Phase II Survey Unit Classification and Description List 5

2-1 Derived Concentration Guideline Levels for Land Area FSS 14

2-2 FSS Area Classifications 16

2-3 Easy-To-Detect and Hard-To-Detect Radionuclides 17

3-1 Basic Statistical Quantities of 9531-0001 Characterization Samples 30

3-2 Statistical Quantities of Post-Remediation Samples from 9535-0001 31

4-1 Number of Surface Samples for FSS 43

4-2 SPA-3 Technical Details 44

4-3 Action Levels and Associated Background Counts per Minute 46

4-4 Scan Coverage 48

4-5 Summary of Total Area Scanned 48

5-1 Summary of Statistical Analysis 52

5-2 IVT Confirmatory Survey 55

LIST OF FIGURES

1-1 Phase II Survey Unit Locations 6

1-2 FSS Final Report Phased Submittal Areas 9

2-1 FSS Organizational Chart 11


Final Status Survey Final Report - Phase II February 2005

1.0 INTRODUCTION

1.1 Executive Summary

The purpose of this Phase II Final Status Survey (FSS) Final Report is toprovide a summary of the survey results and the overall conclusions,which demonstrate that the Connecticut Yankee Atomic PowerCompany's (CYAPCO) Haddam Neck Plant (HNP) site, or portions of thesite, meets the CYAPCO established 10 mrem/yr Administrative LevelDerived Concentration Guideline Levels (DCGL) for soils. The FinalStatus Survey results provided herein address the dose component due tosoil as provided in the License Termination Plan (LTP) complianceEquation 5-1. The second component of Equation 5-1, dose contributiondue to groundwater radiological contamination, for this phase of thesubmittal, is addressed in Health Physics Technical Support Document(TSD) CY-HP-0193, "Assessment of Existing Groundwater Dose forPhase II Release Areas of the Final Status Survey Report" (Reference7.1). The dose contribution from the third component of Equation 5-1,"future groundwater," is zero since there are no structures containingresidual radioactivity for the survey areas submitted in this Phase II report.

This report also documents that the FSS activities were performedconsistent with the guidance provided in the Haddam Neck Plant LicenseTermination Plan (Reference 7.2), NUREG-1575, "Multi-AgencyRadiation Survey and Site Investigation Manual " (MARSSIM) (Reference7.3), CYAPCO program document ISC-GQP-00001-003, "Final StatusSurvey Quality Assurance Plan" (Reference 7.4), CYAPCO ProcedureRPM 5.1-00, "Final Status Survey Program" (Reference 7.5), as well asvarious station implementing procedures.

This FSS Final Report has been written consistent with the guidanceprovided in NUREG-1757, Vol. 2, "Consolidated NMSSDecommissioning Guidance-Characterization, Survey, and Determinationof Radiological Criteria"' (Reference 7.6), MARSSIM, and therequirements specified in Procedure RPM 5.1-22, "Preparation of FinalStatus Survey Reports " (Reference 7.7).

To facilitate the data management process, as well as overall projectmanagement, FSS Final Reports will usually incorporate multiple SurveyUnit Release Records. Survey Unit Release Records are complete andunambiguous records of the as-left radiological status of specific surveyunits. Sufficient data and information are provided in each Survey UnitRelease Record to enable an independent re-creation and evaluation atsome future time of both the survey activities and the derived results.

This Phase II FSS Final Report specifically addresses fourteen (14) landarea survey units and one (1) subsurface soil survey unit within the east

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Connecticut Yankee Atomic Power Company Haddam Neck PlantConnecticut Yankee Atomic Power Company Haddam Neck Plant


mountainous and lowland survey areas of the HNP site that totalapproximately 313 surface acres in size. This report contains acompilation of all fifteen (15) Survey Unit Release Records that are withinthe Phase II scope. Table 1-1 provides a listing of all survey unitsaddressed in this report including the classification and general descriptionfor each. Figure 1-1 depicts the locations of the survey units in relation tothe HNP site as well as survey unit boundaries.

All final status survey activities essential to data quality have beenimplemented and performed under approved procedures. Trainedindividuals, using properly calibrated instruments and laboratoryequipment that are sensitive to the suspected contaminants, performed theFinal Status Survey of the Phase II survey units. The survey data for allPhase II survey units demonstrate that the dose from residual radioactivityis less than the maximum annual dose criterion for license termination forunrestricted use specified in Title 10CFR20.1402 and support release ofthese areas from the IOCFR50 license. The additional requirement of10CFR20.1402 that residual radioactivity be reduced to levels that is AsLow As Reasonably Achievable (ALARA) has been satisfied.

Table 1-1 Phase II Survey Unit Classification and Description List

Survey Survey Class General Description of the Survey UnitArea Unit (see Section 3.2 for a more detailed description)

9523 0000 3 Southeast Wetland Area; land area (151,364 mi2 )

9524 0000 3 South Site Grounds; land area (61,975 M2 )

9525 0000 3 Southeast Site Road; land area (28,000 in2 )

9526 0000 3 Northeast Mountain Side; land area (444,700 in2 )



9528 0000 3 Southeast Mountain Side; land area (508,000 in2 )



9535 0001 1 Southeast LandfillArea; land area (1,860 in2 )

9535 0002 2 Southeast Landfill Area; land area (3,320 mi2 )

9536 0000 2 Constnrction Piles Near Rifle Range; land area (1,536 in2 )

9537 0000 2 PernittedLandfillArea; land area (850 mi2 )

9538 0000 2 Material Storage Area; land area (1,500 mi2 )

9806 0000 A Southeast Landfill-9535; subsurface soils (5,180 in2 )

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Figure 1-1, Phase II Survey Unit Locations

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1.2 Phased Submittal Approach

To minimize the incorporation of redundant historical assessment andother FSS program information, and to facilitate potential phased releasesfrom the current license, FSS Final Reports will be prepared and submittedin a phased approach. CYAPCO estimates that a total of four (4) FSSFinal Reports will be submitted during the decommissioning project (seeFigure 1-2 for locations of phased submittal areas).

Phase I Final Status Survey Final Report

On April 29, 2004, CYAPCO submitted a request to release a portion ofthe HNP site (Reference 7.8) from the IOCFR50 License (DPR-61).Specifically, the request addressed the removal/release of the East SiteGrounds (Survey Area 9532), a non-impacted area, from the Part 50License. In accordance with Section 1.4.2 of the HNP LTP and UnitedStates Nuclear Regulatory Commission (USNRC) Safety Evaluation datedNovember 25, 2002 (Reference 7.9), CYAPCO determined the proposedaction would have no adverse impact on the ability of the site in aggregateto meet 1 OCFR20, Subpart E, criteria for unrestricted release. The requestdid not contain a FSS Final Report for Survey Area 9532 because this areais characterized as non-impacted. The site release and removal of SurveyArea 9532 from the site was approved by the USNRC on September 01,2004 (Reference 7.10).

Phase III and Phase IV Final Status Survey Final Reports

As discussed above, CYAPCO anticipates at least two additional FSSFinal Report submittals. In the following text, there is a list of theremaining survey areas, grouped by phase, with the approximatedsubmittal date. Details on the number, description, and location of surveyunits within each survey area can be found in Chapter 2 of the LTP.

The schedule and identity of survey areas included in each of theremaining submittals were developed based on a review of the demolitionand final status survey schedule, as well as in consideration of USNRCreview requirements. The demolition schedule, including the cleanup ofdemolition debris to permit access for FSS, is dynamic and subject tocontinued refinement in logic, durations, and completion dates. It isCYAPCO's intent to maintain the basic submittal milestone scheduleprovided below. However, because of potential changes in thedecommissioning schedule, it is possible that additional, interimsubmittals will be filed with the USNRC with the goal of providingSurvey Unit Release Records as soon as possible to support the agency'sreview, as well as CYAPCO's goals regarding the release of site lands.

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Final Status Survey Final Report - Phase 11 February 2005

Phase III FSS Final Report Submittal scheduled for December 2005

* 2000 Primary Auxiliary Building - Soils/Foundations* 4000 Turbine Building - Soils/Foundations* 5000 Service Building - Soils/Foundations* 5502 Circulating Water System Discharge Structures* 6000 Waste Disposal Building - Soils/Foundations* 7002 Screen house Building/Intake Structure* 9106 Discharge Canal* 9202 Switchgear Building "B"* 9518 Southwest Site Grounds (Non-Protected Area)* 9520 Southwest Site Storage Area* 9521 Southeast Pond* 9522 Southeast Site Grounds (Non-Protected Area)* 9527 East Mountain Side* 9528 Southeast Mountainside (Survey Unit 0002)* 9530 Central Peninsula Area* 9531 South End of Peninsula* 9804 Subsurface Soils Associated with 9522* 9805 Subsurface Soils Associated with Peninsula

Phase IV FSS Final Report Submittal Scheduled for December 2006

* 1000 Fuel Building - Soils/Foundations* 1308 Fuel Building Spent Fuel Pit* 3000 Reactor Containment* 9102 YD 115KV Switchyard Area* 9302 Northwest Protected Area Grounds* 9304 Southwest Protected Area Grounds* 9306 South Central Protected Area Grounds* 9308 Southeast Protected Area Grounds* 9310 East Protected Area Grounds* 9312 Northeast Protected Area Grounds* 9313 Central Site Grounds* 9402 Emergency Operations Facility - Soils/Foundations* 9502 Northeast Site Grounds (Non-Protected Area)* 9504 Bypass Road / Secondary Parking Lot* 9506 North Site Grounds (Non-Protected Area)* 9508 Pond* 9510 Access Road* 9512 Northwest Site Grounds (Non-Protected Area)* 9514 Primary Parking Lot* 9801 Subsurface Soils in Radiologically Controlled Area* 9802 Subsurface Soils Associated with 9308* 9803 Subsurface Soils Located North of Industrial Area

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Connecticut Yankee Atomic Power Company H.

Final Status Survey Final Report - Phase II

Figure 1-2, FSS Final Report Phased Submittal Areas

addam Neck Plant

February 2005

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2.0 FINAL STATUS SURVEY PROGRAM OVERVIEW

The FSS Program consists of the methods used in planning, designing,conducting, and evaluating FSS at the HNP site to demonstrate that the premisesare suitable for release in accordance with the criteria for decommissioning inTitle 10CFR20, Subpart E. Final Status Surveys serve as key elements todemonstrate that:

* Dose from residual radioactivity is less than the maximum annual dosecriterion for license termination for unrestricted use as specified in Title1OCFR20.1402 provided that the residual radioactivity that isdistinguishable from background radiation results in a Total EffectiveDose Equivalent (TEDE) to an average member of a critical group thatdoes not exceed 25 millirem per year;

* All residual radioactivity at the site is reduced to levels that are ALARAin accordance with Title 1OCFR20.1402;

* Although the annual dose criteria in the LTP is 25 mrem/yr and ALARA,Final Status Surveys for the areas addressed in this Final Report weredesigned to an administrative annual dose criterion of 10 mrem/yr for theland area surveys performed.

This report contains the results of the FSS that addresses the dose due to soil inthe LTP Equation 5-1. As there are no structures containing residual radioactivityin the survey areas addressed in this report, this dose component for thecompliance calculation is zero. Any impact from exiting groundwater is addressedin the associated Release Record and Reference 7.1.

To implement the FSS Program as provided in Reference 7.5 and MARSSIM,CYAPCO established a Final Status Survey organization, within the Site ClosureGroup, with sufficient management and technical resources to fulfill projectobjectives and goals. The FSS organization was responsible for the safecompletion of all activities related to FSS necessary to obtain the radiologicalrelease for unrestricted use of the HNP site. Approved site procedures directedthis process to ensure consistent implementation and adherence to applicablerequirements. Figure 2-1 provides an organizational chart of the FSS organizationand its relationship within the Site Closure Group.

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Figure 2-1 FSS Organizational Chart

|Nuclear

| Safety |

+ LSite Release/Technical

Support Lead [

Site Release/TechnicalSupport Engineer

LTP Programs

IndependentOversight Group

Final Status SurveyProject Lead

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indwaterect Lead

Final Status SurveyFSS Engineer Senior LeadFSS Engineer(s)Implementation Coordinator

Coordinator Pre-Demolition Surveys (URS/CVS)FSS Engineer LeadImplementation CoordinatorDesign Specialist

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FSS TechniciansSite Radiological Characterization

FSS Engineer LeadFSS Engineer

I

I Core Bore Contractor

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Connecticut Yankee Atomic Power Company Hadldam Neck Plant


2.1 Survey Planning

Following termination of commercial operations, the initial developmentand planning phase started in 1997 with the characterization and HistoricalSite Assessment (HSA) process that continued until submittal of the LTPin 2000. The assessment consisted of a review of site historical recordsregarding plant incidents, radiological survey documents, operations andmaintenance records, plant modification documents, and both routine andspecial reports submitted by CYAPCO to various regulatory agencies.Along with the assessment, interviews with site personnel, both past andpresent, reviews of historical site photos and extensive area inspectionswere performed to meet the following objectives:

* To develop the information to support FSS design including thedevelopment of Data Quality Objectives (DQO) and surveyinstrument performance standards;

* To develop the initial radiological information to supportdecommissioning planning including building decontamination,demolition, and waste disposal;

* To identify any unique radiological or health and safety issuesassociated with decommissioning.

. To identify the potential and known sources of radioactivecontamination in systems, on structures, in surface or subsurfacesoils, and in ground water;

* To divide the HNP site into manageable areas or units for surveyand classification purposes; and

* To determine the initial classification of each survey area or unit asnon-impacted or impacted Class 1, 2, or 3 as defined in MARSSIMor Class A, B, or C for subsurface soils (below 15 cm) as describedin the LTP.

Data Quality Objectives are qualitative and quantitative statements derivedfrom the DQO process that clarify technical and quality objectives, definethe appropriate type of data, and specify tolerable levels of potentialdecision errors used as the basis for establishing the quality and quantityof data needed to support decisions. This process, described in MARSSIMand Procedure RPM 5.1-11, "Preparation of Final Status Survey Plans, "(Reference 7.11), is a series of graded, planning steps found to be effectivein establishing criteria for data quality and developing survey plans. DQOsdeveloped and implemented during the initial phase of planning directedall data collection efforts.

Used extensively during HNP FSS, the DQO approach consists of thefollowing seven steps:

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Connecticut Yankee Atomic Powver Company Haddam Neck Plant

Final Status Surve' Final Report - Phase II February 2005

* State the Problem- 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 andthe estimated resources;

* Identify the Decision- consists of developing a decision statementbased on a principal study question, which is typically "Doesresidual radioactive contamination present in the survey unitexceed the release criteria?" The alternative actions may includeno action, investigation, resurvey, remediation and reclassification;

* Identify the Inputs to the Decision- depends on the type of mediaunder consideration (e.g., soil, water, concrete) and whetherexisting data are sufficient or new data are needed to make thedecision;

* Define the Boundaries of the Survey- Spatial boundaries includethe entire area of interest including soil depth, area dimensions,contained water bodies and natural boundaries, as needed.Temporal boundaries include those activities impacted by time-related events including weather conditions, seasons, operation ofequipment under different environmental conditions, resourceloading and work schedule;

* Develop a Decision Rule- The statement that defines a logicalprocess for choosing among alternative actions;

. Specify Tolerable Limits on Decision Errors- incorporateshypothesis testing and probabilistic sampling distributions tocontrol decision errors during data analysis, and

* Optimize the Design for Obtaining Data- leads to thedevelopment of an adequate survey design.

As stated, a primary objective of the DQO process was to demonstrate thatthe level of residual radioactivity in the survey area or unit, including anyareas of elevated activity, met the CYAPCO established AdministrativeLevel DCGLSOi of 10 mrem/yr. The administrative criteria represent a60% reduction of the 25 mrem/yr Base Case DCGLSOl designed for HNPduring the development of the LTP. These administrative limits, used inthe ALARA survey design process, provided the minimum sensitivitiesrequired for the available survey instruments, Minimum DetectableConcentration (MDC), and techniques, and in some cases, the spacing offixed measurements or samples within a survey unit.

Table 2-1 provides a listing for the soil DCGLs used for FSS.

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Final Status Survej Final Report - Phase H February 2005

Table 2-1 Derived Concentration Guideline Levels for Land Area FSSBase Case Soil Administrative Level Required MDC

Radionuclide DCGL (pCilg) DCGL (pCi/g) (pCilg)

H-3 412.00 165.00 16.50C-14 5.66 2.26 0.23

Mn-54 17.40 6.96 0.70Fe-55 27400.00 11000.00 1100.00Co-60 3.81 1.52 0.15

Ag-108m 7.14 2.86 0.29Ni-63 723.00 289.00 28.90Sr-90 1.55 0.62 0.06

Nb-94 7.12 2.85 0.29Tc-99 12.60 5.04 0.50

Cs-134 4.67 1.87 0.19Cs-137 7.91 3.16 0.32Eu-152 10.10 4.04 0.40Eu-154 9.29 3.72 0.37Eu-155 392.00 157.00 15.70Pu-238 29.60 11.80 1.18

Pu-239/240 26.70 10.70 1.07Pu-241 870.00 348.00 34.80

Am-241 25.80 10.30 1.03Cm-243/244 29.00 11.60 1.16

The development of information to support decommissioning planningand execution was accomplished through a review of all known siteradiological and environmental records. Much of this information wasconsolidated in the "Historical Site Assessment Supplement" (HSA)(Reference 7.12), "Characterization Report" (Reference 7.13) and in filescontaining copies of records maintained pursuant to Title 1 OCFR 50.75(g)(1). These documents are discussed further in applicable sections of thisreport.

An initial objective of site characterization and assessment was tocorrelate the impact of a radiological event to physical locations on theplant site and to provide a means to correlate subsequent survey data. Tosatisfy these objectives, the FSS organization divided the site into large,manageable areas and assigned a unique four digit System Survey Code(e.g. Survey Area 9528) to each area. The area designations form the basisfor survey units presented in Table 1-1 of this report. Physically, surveyarea boundaries were determined using commercially available mappingsoftware with coordinates consistent with the Connecticut State PlaneSystem.

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Upon completion of survey area assignment, the FSS organization beganthe task of initial classification and establishing the initial set of surveyunits. Classification, as described in MARSSIM, is the process by whichan area or survey unit is described according to its radiologicalcharacteristics and potential for residual radioactivity. Not all areas of thesite had the same potential for residual radioactivity. Residualradioactivity could be evenly distributed over a large area, appear as smallareas of elevated activity or a combination of both. In some cases, theremay be no residual radioactivity in a survey unit. Therefore, the adequacyand effectiveness of the FSS process depends upon properly classifiedsurvey units to ensure that areas with the highest potential forcontamination receive a higher degree of survey effort.

The surface area limits provided in MARSSIM were used to establish theinitial set of survey units for the HNP LTP. A survey area may consist ofone or more survey units. A survey unit is a physical area consisting ofstructures or land areas of a specified size and shape that would besubjected to a FSS. Survey units were limited in size based onclassification, exposure pathway modeling assumptions, and site-specificconditions. Utilization of this method of classification and size limitationensures that each area was assigned an adequate number of data points.For identification, survey units were assigned the area four-digit code anda sub-code to designate the unit within the survey area (e.g. Survey Unit9528-0002). Table 2-2 provides an outline for classification and arealimits.

Prior to FSS, several units or areas have undergone reclassification.Survey unit verification and a change to increase the class (morerestrictive) can be performed at anytime. Typically, reclassification occurswhen the evaluation of new sample results or emergent data indicates thatmeasures that are more conservative are needed. Final classification wasperformed in conjunction with the preparation of the Final Status SurveyWork Package, thus indicating all issues of classification are resolved.

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Connecticut Yankee Atomic Power Company Hadldam Neck PlantConnecticut Yankee Atomic Power Company Haddam Neck Plant


Table 2-2 FSS Area Classifications

Survey Unit Surface ContaminationClassification Area Limit Potential

Class 1: Structures(floor area) Up to 100 m2

Land areas Up to 2,000 m2 Highest

Class A: SubsurfaceClass 2: Structures 100 22 to 1,000 m2

(floor area)Land areas 2,000 m2 to 10,000 m2 Moderate

Class B: SubsurfaceClass 3: Structures

(floor area) no limitLand areas no limit Lowest

Class C: Subsurface

2.2 Survey Design

Final status surveys for the HNP surface soils and structures are designedfollowing HNP procedures, Chapter 5 of the LTP and MARSSIMguidance using combinations of fixed measurements, traditional scanningsurveys, and other advanced survey methods, as appropriate, to evaluatesurvey units relative to the applicable release criteria.

During characterization and in preparation for FSS, the HNPRadiochemistry Lab, using gamma spectroscopy, analyzed soil samplescollected from random and biased locations in selected survey units forEasy-to-Detect (ETD) radionuclides (Table 2-3). Gamma spectroscopyindicated that Cs-137 and/or Co-60 would be the primary radionuclides ofconcern for survey design and FSS for a majority of the areas submitted inthis report. Applied statistically, these data were used to determine theexpected variability, number of samples required, and to establish theOperational DCGLSII.

For the purposes of survey planning, the Operational DCGL for multipleradionuclides is based upon "unity" or sum of the fractions. For a singleradionuclide, the Operational DCGL is the Administrative Level DCGLfor the nuclide of concern.

Although the LTP only required a minimum of 5%, approximately 10% ofthe soil samples were sent to an off site laboratory for analysis of Hard-to-Detect (HTD) radionuclides listed in Table 2-3. Hard-to-Detect

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Connecticut Yankee Atomic Power Company Haddam Neck PlantConnecticut Yankee Atomic Power Company Haddam Neck PlantFinal Statuls Survey Final Report - Phase H1 Februar 2005

radionuclides, mainly Sr-90, were detected in most of the samples. Levelsof HTDs were usually less than 5% of the DCGL and were not consideredas nuclides of concern in survey design. Exceptions to this are discussed inapplicable sections of this Final Report and associated release records.Consistent with Equation 5-7 of the LTP, the 5% rule for singleradionuclides or 10% rule for multiple radionuclides is conservativerelative to the process presented in Title lOCFR20 in which radionuclidesthat contribute less than 10% to dose, provided the aggregate does notexceed 30%, are not required to be included in the dose assessment.

Table 2-3 Easy-to-Detect andHard-to-Detect RadionuclidesRadionuclide Analyses

H-3 HTDC-14 HTD

Mn-54 ETDFe-55 HTDCo-60 ETD

Ag-108m ETDNi-63 HTDSr-90 HTD

Nb-94 ETDTc-99 HTD

Cs-134 ETDCs-137 ETDEu-152 ETDEu-154 ETDEu-155 ETDPu-238 HTD

Pu-239/240 HTDPu-241 HTDAm-241 ETD/HTD

Cm-243/244 HTD

Survey design objectives included a verification of the survey instrument'sability to detect the radiation(s) of interest relative to the DCGL. Asstandard practice to ensure that this objective was consistently met,radiation detection instruments used in FSS were calibrated every sixmonths with a National Institute of Standards and Technology (NIST)traceable Cs-137 source in accordance with CYAPCO HNP procedures.Instruments were response checked before and after the instrument wasused. Minimum Detectable Count Rates (MDCR) were established prior toFSS and verified. Control and accountability of survey instruments weremaintained and documented to assure the quality and prevent the loss ofdata.

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Connecticut Yankee Atomic Powver Company Hadldam Neck Plant


Based upon classification, areas were selected and scanned with gammaradiation detection instruments. Information obtained during the surveywas automatically logged by the instrument for review and analysis.Samples were collected at areas with elevated scan readings identifiedduring the scanning. Each sample point was also scanned and theinformation logged.

Soil sample locations were determined randomly for Class 3 or bytriangular systematic grid for Class 1 and 2 using commercially availablesoftware. Sample location coordinates are programmed into a GlobalPositioning System (GPS), then physically located, marked or "flagged".

Samples were collected horizontally to a dept of 15 cm (6") below the topsoil surface. Leaves, rocks, and roots were excluded as much as possiblefrom the sample prior to bagging and closure. When applicable,subsurface samples were collected, using a backhoe or "push-probe"technology, to a depth of 3 meters or refusal. Composite samples werecollected from this profile and prepared for shipment as mentionedpreviously. Routinely, approximately ten percent (10%) of the samplescollected were designated for quality control analysis such as "splitsamples" or duplicates.

Offsite laboratories were chosen to perform ETD and HTD analysis ofsamples collected during FSS. Laboratory DQO and analysis results werereported as actual calculated results. Sample report summaries includedunique sample identification, analytical method, radioisotope, result, anduncertainty of two standard deviations (2a), laboratory data qualifiers,units, and required MDC. Results reported as <MDC (less than MinimumDetectable Concentration) were not accepted for FSS.

A consideration of survey design was the use of "surrogates." In lieu ofanalyzing every sample for HTDs, the development and application of"Surrogate Ratio DCGLs" is an accepted industry practice to assay HTDradionuclides. Surrogate Ratios allow for expedient decision making incharacterization, remediation planning, or FSS design.

Briefly described, a surrogate is a mathematical ratio where an ETDradionuclide concentration is related to a HTD radionuclide concentration,such as Cs-137/Sr-90. From the analytical data, a ratio is developed andapplied in the survey scheme for samples taken in the area. The result isreferred to as the surrogate DCGL. Details and applications of this methodare provided in Section 5.4.7.3 of the LTP.

Some portion of the Cs-137 and Sr-90 found in the soil samples iscertainly attributed to "background" or fallout; however, the DQO processassessed the application of media specific radiation background andambient area radiation background to specific survey areas and units.Based upon the DQO process, the FSS planning determined that

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background subtraction would not be applied during the survey of the landareas included in this submittal.

2.3 Survey Implementation

Final Status Survey implementation started in November 2001.Implementation was the physical process of Final Status Survey Plan(FSSP) execution for a given survey unit. Each FSSP was assigned to aFSS Engineer for implementation and completion in accordance withCYAPCO FSS program procedures and FSSQAP. Some of the tasksincluded in the implementation are:

* Verification and Validation of personnel training as required byProcedure RPM 5.4-0 "Site Closure Training Program"(Reference 7.14);

* Monitoring instrument calibration as detailed in ProcedureRPM 5.1-4, "Control and Accountability of Portable SurveyInstnuments for Scoping, Characterization and Final StatusSurveys " (Reference 7.15);

* Implementation of applicable operating, health and safetyprocedures and personnel safety as detailed in Procedure 000-GEN-0000-00061-00, "Work Plan and Inspection Record"(WPIR) (Reference 7.16);

* Determination of the amount of sampling required to meetsurvey DQOs as described in Procedure R5.1-12,"Determination of the Number of Surface and SubsurfaceSamples for FSS of Opemn Land Areas" (Reference 7.16);

* Determination of where measurements or samples are to bemade or collected along with maps of the survey area showingthe measurement/sample locations, in accordance withProcedure RPM 5.1-11;

* Maintaining Quality Assurance/Quality Control requirements(e.g., replicate measurements or samples) in accordance withProcedure RPM 5.1-24, "Split Sample Assessment for FinalStatus Survey" (Reference 7.18) and the FSSQAP;

* Sample submission to approved laboratories as provided inProcedure RPM 5.1-5, "Chain of Custody for Final StatusSurvey Samples" (Reference 7.19);

* Application of the DCGLs to sample results in accordance withthe Data Quality Assessment (DQA) process as detailed inProcedure RPM 5.1-23, "Data Quality Assessment"(Reference 7.20) as well as,

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Connecticut Yankee Atomic Power Company Haddlam Neck Plant


* Determination of investigation methodology;

* Corrective actions, if applicable.

The FSS implementation and completion process resulted in thegeneration of raw data consisting of measurements taken with handheldradiation detection equipment, field logs, and radionuclide specificanalysis. Data were stored electronically on the CYAPCO network server.

2.4 Survey Data Assessment

Prior to proceeding with data evaluation and assessment, the assigned FSSEngineer resolves and documents discrepancies between the data qualityor the data collection process and the applicable requirements.

The DQA process is an evaluation method used during the assessmentphase of FSS to ensure the validity of FSS results and demonstrateachievement of the survey plan objectives. The first step in the dataassessment process converts all of the survey results to DCGL units. Theindividual measurements and sample concentrations are compared to theDCGL for evidence of small areas of elevated activity or results that arestatistical outliers relative to the rest of the measurements. When practical,graphical analyses of survey data that depicts the spatial correlation of themeasurements were used.

To demonstrate that survey data fulfills the radiological release criteria,FSS planning incorporated hypothesis testing and probabilistic samplingdistributions to control decision errors during data analysis. Hypothesistesting is a process based on the scientific method that compares a baselinecondition to an alternate condition. The baseline condition is technicallyknown as the null hypothesis. Hypothesis testing rests on the premise thatthe null hypothesis is true and that sufficient evidence must be providedfor rejection. In designing the survey plan, the underlying assumption, ornull hypothesis was that residual activity in the survey unit exceeded therelease criteria. Rejection of the null hypothesis would demonstrate thatresidual activity was at or below the release criteria objective of the FSS.

Hypothesis testing is demonstrated through the application of the SignTest on the sample data collected in the survey unit. The Sign Test isconsidered a one-sample statistical test that compares sample data directlyto the release criteria. Combined with an effective sampling scheme,passing the Sign Test constitutes satisfying the release criteria. Selectionof the Sign Test is prudent and conservative in the assumption that theradionuclides being considered are not present in background or are atlevels at a small fraction of the applicable release criteria. Reference areasand reference samples are not needed, thus simplifying the FSS.Furthermore, any background contribution (e.g., Cs-137 from atmosphericweapons testing) in the sample increases the likelihood of failing the

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survey unit, which is conservative. If the release criteria were exceeded orif results indicated the need for additional data points, appropriate furtheractions were implemented usually through the issue of an addendum to theFSSP.

2.5 Quality Assurance and Quality Control Measures

Quality assurance and control measures were employed throughout theFSS process to ensure that all decisions are based on data of acceptablequality. Quality assurance and control measures were applied to ensure:

* The plan is correctly implemented as prescribed;

* DQOs are properly defined and derived;

* All data and samples are collected by individuals with the propertraining following approved procedures;

* All instruments are properly calibrated;

* All collected data are validated, recorded, and stored in accordancewith approved procedures;

* All required documents are properly maintained; and,

* If necessary, corrective actions are prescribed, implemented andtracked.

Independent laboratories used for analysis of the samples collected duringFSS maintain Quality Assurance Plans designed for their facility.CYAPCO reviews these plans, as required by the "Quality AssuranceProgram for Haddam Nuclear Plan " (CYQAP) (Reference 7.21), and theFSSQAP, prior to selection of a laboratory for FSS sample analysis toensure standards are acceptable.

During 2004, three Quality Surveillance Reports (QSRs) were producedon activities related to FSS. In general, these reports were performed toevaluate the adequacy of the implementation of regulatory and LTP/FSSrequirements.

QSR-04-072-CY (Reference 7.22) performed during March 29 to April 8,2004, was an independent review of the FSS program. The LTP, FSS Plan,and procedures, interviews, inspection of FSS equipment, and FSS dataand documentation were reviewed and compared. The assessmentconsidered procedures, organization, and performance in assessing LTPimplementation. Experience and lessons learned from other FSS programswere considered by the Assessment Team. The use of the assessment toevaluate the program was considered a very positive initiative and usefultool for improving performance in the Site Closure group. Thesurveillance verified that the controls instituted to plan, design, conduct,

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and evaluate LTP/FSS requirements at HNP demonstrate compliance withUSNRC radiological criteria for unrestricted use.

QSR-04-073-CY (Reference 7.23) performed during June 7 to June 16,2004, evaluated the guidance for preparing, performing, documenting, andapproving the FSS Plan for Survey Unit 9537-0000, Permitted Landfill.The surveillance verified that the controls instituted to plan, design,conduct, and evaluate FSS at HNP demonstrate compliance with USNRCradiological criteria for unrestricted use. The FSS Plan was consistent withMARSSIM guidelines.

QSR-04-078-CY (Reference 7.24) performed during April and June of2004, evaluated the guidance for performing field activities during theFSS for Survey Units 9535-0001/0002 and 9806-0000. The surveillanceverified that the controls instituted to plan, design, and conduct the FSS atthe HNP site demonstrate compliance with the USNRC radiologicalcriteria for unrestricted use. The general and specific FSS Plan wasconsistent with MARSSIM guidelines.

In June of 2004, the "Final Status Survey Program Assessment Report"(Reference 7.24) was issued. The objective of this comprehensive,independent assessment was to evaluate the effectiveness of the FSSprogram in implementing LTP requirements including a "limited" reviewof the LTP. Training, instrumentation, documentation, and datamanagement were also assessed during this time. The report concludedthat the CYAPCO FSS program contained the necessary elements to meetLTP requirements to perform FSS of land areas. However, there werethree findings in the areas of document and software controls, andtraining. Condition Report 04-0810 (Reference 7.26) and 04-0811(Reference 7.27) were issued to document and implement correctiveactions. The training program was revised and controlling proceduresissued.

An internal audit was performed in November 2004 by CYAPCO. Theobjective of the CY Nuclear Safety Audit Report, CY-04-A09-01, "FinalSite Survey (FSS)/License Termination Plan (LTP)" (Reference 7.28),was to assess the compliance with commitments and regulatoryrequirements and to verify that FSS/LTP implementation was maintainedconsistent with associated requirements and that implementation wasmeeting expectations. Only one deficiency was identified during the audit.Condition Report CR 04-1298, "Failure to process timely License BasisDocument Change Request (LBDCR) for the License Termination Plan(LTP) changes, " (Reference 7.29) was issued to document and implementcorrective actions based on the audit finding.

By the end of 2004, all findings from the QSRs, audits, and assessmentswere corrected and systematic controls implemented.

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3.0 SITE INFORMATION

3.1 Site Description

Haddam Neck Plant, owned by Connecticut Yankee Atomic PowerCompany, is located on the east bank of the Connecticut River,approximately 21 miles south-southeast of Hartford.

The site consists of approximately 525 acres, with a minimum distanceoverland from the reactor containment to the site boundary of 1,740 ft andthe distance to the nearest residence is over 2,000 ft.

The plant incorporated a 4-loop closed-cycle pressurized water typeNuclear Steam Supply system (NSS system); a turbine generator andelectrical systems; engineered safety features; radioactive waste systems;fuel handling systems; instrumentation and control systems; the necessaryauxiliaries; and structures to house plant systems and other onsitefacilities. HNP was designed to produce 1,825 MW of thermal power and590 MW of gross electrical power.

Westinghouse Electric Corporation was responsible for design andfabrication of all NSS and auxiliary systems and equipment, as well asdesign and supply of all secondary plant mechanical and electricalequipment, which it normally manufactures. Stone and WebsterEngineering Corporation was responsible for site development, design ofbuildings and secondary systems, and all plant construction. Each of thesecontractors was responsible to CYAPCO for tasks performed in theirrespective areas of design and construction. Pre-operational plantcheckout, core loading, plant start-up, and operation were theresponsibility of CYAPCO.

On December 4, 1996, HNP permanently shut down after approximately28 years of operation. On December 5, 1996, CYAPCO notified theUSNRC of the permanent cessation of operations at the HNP and thepermanent removal of all fuel assemblies from the Reactor PressureVessel and their placement in the Spent Fuel Pool. Following the cessationof operations, CYAPCO began the decommissioning of the HNP. ThePost Shutdown Decommissioning Activities Report (PSDAR) wassubmitted, in accordance with Title IOCFR50.82 (a) (4), onAugust 22, 1997, and was accepted by the USNRC. On January 26, 1998,CYAPCO transmitted an Updated Final Safety Analysis Report to reflectthe plant's permanent shutdown status, and on June 30, 1998, the USNRCamended the HNP Facility Operating License to reflect plant conditions.On October 19, 1999, the Operating License was amended to reflect thedecommissioning status of the plant and long-term storage of the spentfuel in the spent fuel pool. Additional licensing basis documents were alsorevised and submitted to reflect long-term fuel storage in the spent fuel

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Final Status Suney Final Report - Phase HI February 2005

pool (Defueled Emergency Plan, Security Plan, QA program, andOperator Training Program).

In 1997, in accordance with NUREG/CR-5849 (Reference 7.30) initial sitecharacterization was implemented. In 1999, following the guidelines ofMARSSIM, initial characterization was completed. The informationdeveloped during the initial HNP characterization program represented- aradiological assessment based on the knowledge and information availableat the end of 1999.

3.2 Survey Area/Unit Description

The following information is a description of each survey unit at the timeof FSS from November 2001 until August 2004. During this period,fifteen (15) final status surveys covering approximately 313 surface acreswere completed on the outlaying lands surrounding the Haddam NeckPlant. Mostly wooded, located to the north and east of the plant, the areasconsist of hilly, rocky uplands that drain to wetland areas.

Survey Unit 9523-0000

Survey Unit 9523-0000, (Southeast Wetlands Area) is designated Class3, and consists of approximately 151,363.19 m2 (37.4 acres) ofuninhabited, undeveloped land located about 0.75 miles from the centerof the Haddam Neck Plant Containment Building.


Survey Unit 9524-0000 (South Site Grounds area) is designated Class 3,and is located approximately 0.85 miles from the Haddam Neck PlantIndustrial Area. The survey unit is located south of the southeastmountainside and has a land area of 61,974.8 m2 (15.3 acres).


Survey Unit 9525-0000 (Southeast Site Road) is a Class 3 section ofasphalt-paved road with a steep grade located east of Haddam Neck Plantsite industrial area. The road area selected for the survey unit isapproximately 1,400 meters in length, 2.5 meters wide (0.86 acres), andruns in a north-south direction.


Survey Unit 9526-0000, (Northeast Mountainside Area) , is designatedClass 3, and consists of approximately 444,700 m2 (110 acres) ofuninhabited and undeveloped land located about a tenth of a mile (0.09miles) from the center of the Containment Building.

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Survey Unit 9526-0001 (Northeast Mountainside Area) is designatedClass 2, and consists of approximately 6,503.5 m2 (1.6 acres) ofuninhabited, undeveloped land located about a tenth of a mile (0.09miles) from the center of the Containment Building.


Survey Unit 9526-0002 (Northeast Mountainside Area) is designatedClass 2, and consists of approximately 6,068 m2 (1.5 acres) of uninhabited,undeveloped land located about a tenth of a mile (0.09 miles) from thecenter of the Haddam Neck Plant Containment Building.


Survey Unit 9528-0000 (Southeast Mountainside Area) is a Class 3 areaand consists of approximately 508,000 m2 (125.5 acres) of uninhabited,undeveloped land located about a quarter of a mile (0.23 miles) from thecenterline of the containment building.


Survey Unit 9528-0003 (Southeast Mountainside) Haul Road Section 2 isa Class 2 area that comprises an open land area of approximately

0,000m2 (2.5 acres) located between the Discharge Canal on the southand approximately 15 meters into the interior of area 9528-0000 on thenorth.


Survey Unit 9528-0004 (Southeast Mountainside) Haul Road Section 3, isClass 3 open land area of approximately 3,100 m2 (0.8 acre) locatedoutside of the Industrial Area. It includes the access road to the SoutheastLandfill Area and 15 meters north of the road.


Survey Unit 9535-0001 (Southeast Landfill) is a Class 1 area locatedapproximately 0.85 miles from the Industrial Area and has a land area of1,860 m2 (0.45 acres).


Survey Unit 9535-0002 (Southeast Landfill) is a Class 2 area locatedapproximately 0.85 miles from the Industrial Area. Survey Unit 9535-0002 is located north of the pistol range and has a land area of 3,320 m2

(0.82 acres).

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Survey Unit 9536-0000 (Construction Piles near the Rifle Range) is aClass 3 open land area of 1,536 m2 (0.38 acres). The survey unit is at thesouth end of an excavated sandpit approximately 0.85 miles from theIndustrial Area, west of the former pistol range and adjacent to thePermitted Landfill.


Survey Unit 9537-0000 (Permitted Landfill) is a Class 2 open land area of850 m2 (0.21 acres). The Permitted Landfill is at the south end of anexcavated sandpit approximately 0.85 miles from the Industrial Area andwest of the former pistol range.


Survey Unit 9538-0000 (Material Storage Area) is designated Class 2and consists of approximately 1,500 m2 (0.36 acres) of uninhabited,undeveloped, open land located about 0.85 miles from the center of theHaddam Neck Plant Containment Building.


Survey Unit 9806-0000 (Southeast Landfill Area) is a Class A arealocated approximately 0.85 miles from the Industrial Area and has a landarea of 5,180 m2 (1.27 acres). Survey Unit 9806 is the subsurface FSSevaluation of Survey Unit 9535.

3.3 Summary of Historical Radiological Data

The site historical radiological data for HNP includes the results ofHistorical Site Assessment, conducted during the late 1990s and in 2001,scoping surveys completed in 1998, initial characterization surveyscompleted in 1999, characterization surveys conducted prior to FSS and aremedial action survey.

3.3.1 Scoping Surveys

The purpose of the scoping surveys was to establish early in thedecommissioning process, the necessary areas requiringremediation and to what extent. Details of the scoping surveys areprovided in "Results of Scoping Survey for CYAPCO 's HaddamNeck Plant, " 1998 (Reference 7.31). The scoping survey identified140 events that could potentially contaminate the facility outside ofthe Radiologically Controlled Area. From this list, only two eventswere considered to have the potential to contaminate survey unitsdiscussed in this FSS Final Report. The first event(s) was the

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unplanned radioactive releases from the plant stack in December1979. The second event involved plant related waste materials thatwere disposed of at the Southeast Landfill Area. As described inthe release record, only Survey Unit 9535-0001 was documentedas containing plant related radioactive materials resulting from thisevent.

3.3.2 Characterization Surveys

The characterization of radiological and hazardous materialsconditions of all areas of the HNP site, an initial task in the plantdecommissioning and license termination process, centered aroundfour main objectives:

* Determine the nature and extent of contamination;

* Provide the basis for initial classification of areas;

* Provide a basis for remediation planning, includingrecommendations for additional surveys or samples, and

* Provide input into the FSS design.

Following plant shutdown at the end of 1996, it was determinedthat there was a need for additional surveys to better define thescope of radioactivity or "characterization" in several on-site areas.To fill this gap, surveys were conducted in plant areas along withthe sampling and analysis of environmental media that includedground water, paved surfaces outside the radiologically controlledarea and soils suspected of containing radioactive materials.

The coalescence of this data, as well as all available site data,occurred during the development of the HSA. The HSA consistedof a review of plant operational records since initial licenseapproval, a review of events that have potential impact ondecommissioning activities compiled in accordance with TitlelOCFR50.75 (g) (1), and interviews with present and formeremployees regarding events and activities that may impact licensetermination.

The results of the HSA identified radiological conditions or eventsthat impacted the HNP. These events fall into several categories:

* Normal plant operation that affected systems, components,and building surfaces that are designed to containradioactive material. Examples of these are the reactorcoolant system, residual heat removal pumps, and buildingareas such as sumps and pipe vaults.

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* The discharge and runoff of radiological effluents to thecanal;

* Operational events that occurred in which radioactivematerials were released from ventilation, and wasteprocessing systems. Examples are elevated readings on theprimary auxiliary building roof and owner controlledhillside locations east of the plant, and

* Leakage of water containing radioactive material that wasdocumented historically. Incidents of this nature includedleaking lines under the PAB drumming room floor,overflowing of a manhole just east of the Service Buildingand leakage from radioactive liquid storage tanks.

The summary information developed during the HSA process wasevaluated concurrently with the information provided in the "NRCHistorical Review Team Report - Radiological Control and AreaContamination Issues at Haddam Neck" (Reference 7.32), datedMarch 26, 1998, to assure completeness of the historical data.

Another significant document, the "Characterization Report"-(Reference 7.13), provided an assessment of the radiological andhazardous material conditions for each of the site buildings andsubsections of the site grounds at a specific point in time. A listingof the areas was provided in the table of contents, along with thearea identification number(s) and the area's initial classification inaccordance with the criteria established in MARSSIM. Site mapswere provided to locate the areas and the respective survey areanumber(s). A report for each area contained a description(boundaries) of the area, known radiological and hazardousmaterial information, impacted systems within an area andrecommendations for further samples or surveys. Buildingsassumed to remain in support of spent fuel storage activities, werenot included (i.e. not be part of the LTP process).

As suggested in the "Characterization Report" and discussed inthe applicable release records, recent characterization surveys toaid in the FSSP design were performed as needed for each surveyunit.

3.3.3 Remedial Action Surveys

All survey areas submitted in this Final Report were evaluated inaccordance with Health Physics TSD BCY-HP-0078, "ALARAEvaluation of Soil Remediation in Support of Final StatusSurvey," (Reference 7.33). This evaluation determined thatremediation beyond that required to satisfy the release criteria to

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Final Status Surety Final Report - Phase H February 2005

be unnecessary and that the remaining residual radioactivity insoil was ALARA.

During the phase of decommissioning and surveying covered bythis report, remedial action, and Remedial Action Surveys (RAS)were only conducted in Survey Unit 9535-0001, the SoutheastLandfill.

Survey Unit 9535-0001 is a Class I area located approximately0.85 miles from the Haddam Neck Plant Industrial Area. In July of2003, a characterization of Survey Unit 9535-0001 was performedthat focused on those areas previously identified in 1997 and 1999as containing residual radioactivity related to plant operations. Thesurvey included radiation surveys with a sensitive gamma radiationdetector and the collection and analysis of soil samples. During thesurvey, approximately 100% of the land area was scanned with agamma detector and twenty soil samples were collected andanalyzed by gamma spectroscopy. Most samples were collectedfrom discrete locations indicating elevated activity (i.e. instrumentresponse was greater than twice ambient background).

The analytical data from the twenty (20) samples were subjected toreview and statistical analysis. Cs-137 was identified in all of thesamples collected. Thirteen (13) of the twenty (20) samplescontained identifiable amounts of Co-60. Compared toAdministrative Level DCGLs routinely used for FSS, nine of thetwenty samples would exceed the 10 mrem/yr DCGLSOI,administrative limit. An overview of the statistical analysis forsamples prior to remediation is provided in Table 3-1.

Table 3-1 Basic Statistical Quantitiesof 9535-0001 Characterization Samples.

Cesium-137 Cobalt-60Parameters (pCi/g) (pCi/g)

Minimum Value: 0.0814 0.00211Maximum Value: 15.9 1.90Mean: 3.29 0.273Median: 2.79 0.115Standard 3.78 0.518Deviation: 3

A remedial action plan was developed and implemented from July30 to October 21, 2003. Three samples collected during theremedial action were analyzed off-site for the full suite of ETD andHTD radionuclides. The highest concentrations reported in the

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Final Status Survey Fijial Report - Phase II February 2005

analysis were Co-60 at 2.21 pCi/g and Cs-137 at 52.9 pCi/g. TheHTD analyses identified SR-90, Ni-63, and C-14 as well. Anindependent analysis of the three samples by Oak Ridge Institutefor Science and Education also confirmed these results.

During the remediation, approximated 4,000 ii3 of soil wasremoved for transport and disposition. All concrete and otherindustrial materials removed from the area were surveyed andfound not to exceed the radiological release criteria for unrestricteduse under the radiation protection program's "unconditionalrelease" criteria. Based on the results of the radiation survey andthe sample results, the remedial action was completed on October21, 2003.

Post remediation sampling and analysis identified Cs-137 in thesoil samples at levels consistent with those concentrationsdetermined from off-site locations. Table 3-2 provides a statisticalanalysis of the post remediation samples collected in Survey Unit9535-0001.

Table 3-2 Statistical Quantities ofPost Remediation Samples from 9535-0001.

Cesium-137 Cobalt-60Parameters (pCi/g) (pCilg)

Minimum value: 0.0835 0.00149Maximum Value: 0.408 0.0156Mean: 0.211 0.00715Median: 0.182 0.00487Standard 0.121 0.00615Deviation:

3.4 Conditions at the Time of Final Status Survey

The land areas discussed in this report are mostly wooded or open landareas with little to no disturbance occurring since the construction of HNP.A transmission right-of-way, partially maintained, runs through theproperty. In addition, several areas contain service roads or fire roads thatwere used to access the site during FSS. Most of these roads are no longerin use and are closed for security reasons and/or are in disrepair. Somesurvey areas have undergone archaeological investigations that resulted insmall test pits and trenches.

Recent activities have occurred mostly in two general areas. The firstarea(s) is associated with the construction of the Independent Spent FuelStorage Installation (ISFSI). The reconstruction of the roads leading to theISFSI, along with the building of the ISFSI has occurred since 2002.

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- - -



The other area includes the Rifle Range, Permitted Landfill, andRadioactive Materials Storage Area (Survey Units 9524, 9535, 9536,9537, and 9538). This open area located to the east of the HNP industrialsite, undenvent remediation and removal of radioactive materials (SurveyUnit 9535-0001), hazardous materials (lead), typical debris and refuseresulting from normal plant operations. Minor amounts of concrete debristhat was below release criteria were left as backfill. These areas werebackfilled with clean soil, restored, graded and seeded for erosion control.Release records associated with these areas provide further details.

Prior to FSS, areas ready for survey were isolated and controlled underProcedure RPM 5.1-16, "Turnover and Control of Open Land Areas forFinal Status Survey, " (Reference 7.34). This includes posting of the areaas well as notifications to site personnel. Permission to enter and work inthese areas must be obtained from FSS staff. Obvious posting of theboundaries in the heavily wooded areas controls public access; however,the impact of public access is considered minimal to nonexistent. InSurvey Area 9528, the area around the IFSI is a controlled security area.

3.5 Identification of Potential Contaminants

In general, the identification of potential contaminants was accomplishedthrough the review of plant operating records, radiological surveys, andlaboratory analysis for ETD gamma emitting radionuclides. Duringcharacterization, soil samples collected from areas that would undergoFSS were sent to an off site laboratory for HTD analysis. In addition, dataobtained from waste streams analyzed for Title 10CFR61 radionuclideswere reviewed and considered. The 10CFR61 and HTD analysis usuallyincludes chemical separation or other advanced methods of detection notavailable at HNP.

During FSS and characterization, elevated readings led to theidentification of plant related radionuclides in Survey Units 9528-0004and 9535-0001. Levels of Co-60 in Survey Unit 9528-0004 wereidentified and confirmed at a maximum concentration of 0.359 pCi/g, 23%of the Administrative Level DCGLSOii. In 9535-0001, analysis indicatedthat multiple radionuclides were present, Cs-137, Co-60, Sr-90, Ni-63 andC-14. As discussed previously, a remedial action plan for 9535-0001 wasdeveloped and implemented in 2003. In addition, some of the samplescollected along the Discharge Canal have indicated low levels of Co-60.

As shown by the FSS Release Records, the plant related radionuclideidentified in most of the samples was Cs-137 and in a few areas, Co-60.For a majority of the samples, the concentrations of Cs-137 were below orat those concentrations determined from off-site locations as documentedby Health Physics TSD BCY-HP-0063, "Background Cs-137Concentration in Soil," and (Reference 7.35). With one exception (Survey

31



Unit 9535-0001), the reported values of Cs-137 were not enough towarrant radiological soil remediation.

Cesium-137 deposition resulting from nuclear weapons testing is thoughtto be the source of most of the Cs-137 encountered in samples collected inthe outlands surrounding HNP. Geological deposition, regionalconcentrations and transport mechanisms are well documented and thesubject of numerous publications and studies. However, as a conservativemeasure, Cs-137 resulting from fallout or "background" was notsubtracted from analytical results for FSS at HNP.

Another nuclide resulting from nuclear weapons testing and originallydeposited with Cs-137 fallout is Sr-90. With the exception of Survey Unit9535-0001, concentrations found in samples collected in the outland areasof HNP compares favorably with research conducted in other regionalareas concerning fallout resultant from nuclear testing in the past asreferenced in EPRI Technical Report 1003030, "Determnining BackgroundRadiation Levels in Support of Decomnnissioning Nuclear Powver Plants"(Reference 7.36).

Analysis for HTD radionuclides identified Pu-239/240, Pu-241, and Am-241 in some samples. Given the very low concentrations and sensitivitiesof the analysis, the likely source of the plutonium/americium is from pastatmospheric nuclear weapons testing fallout, Chernobyl, and bum-up andvaporization of the United States SNAP 17A satellite in the atmosphere.At times, analytical errors such as "false positives" contributed to the HTDindicators. These indicators were assessed and are discussed in theapplicable release records.

During the FSS implementation, areas of interest were "scanned" withportable, hand-held radiation detection meters. Prior to scanning,background levels were determined and investigation levels set inaccordance with Health Physics TSD BCY-HP-008 1, "Scan MDC of LandAreas using a 2-inch by 2-inch Sodium Iodide Detector," (Reference7.37). Areas were then scanned for elevated readings. When an elevatedarea was found, the area was marked and a sample collected at thatlocation for gamma spectroscopy analysis and further evaluation.

Occasionally, during the scanning surveys, rock outcroppings wouldexhibit elevated activity above the investigation levels established by thesample plan. As suspected, pegmatite containing primordial radionuclideswas the cause of the elevated instrument readings. Details on thisoccurrence are discussed further in Health Physics TSD BCY-HP-0150,"Investigation of Rock Outcropping Exhibiting Elevated Activity,"(Reference 7.38) and mentioned in associated release records.

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3.6 Radiological Release Criteria

All FSSs for the land area surveys submitted in the Phase II report wereconservatively designed to the 10 mrem/yr Administrative Level DCGLsoiland all results compared to this value. However, since the release criteriawas based on the 25 mrem/yr DCGL, failure of the survey unit to meet the10 mrem/yr DCGL did not "disqualify" the unit from release provided thatthe 25 mrem/yr criteria was not exceeded. For the two survey unitsaffected by groundwater in this phase submittal, 9528-0000 and 0003, thedose attributed to groundwater is less than 0.2 mrem/yr. This is detailed inReference 7.1.

4.0 FINAL STATUS SURVEY PROTOCOL

4.1 Data Quality Objectives

The DQO process as outlined in Section 2.0 of this report was applied foreach FSSP and contains basic elements common to all FSSPs at HNP. Anoutline of those elements presented in the HNP FSSPs is as follows:

* STATE THE PROBLEM

The problem: To demonstrate that the level of residual radioactivityin a survey unit including any areas of elevated activity does notexceed the release criteria of 25 mrem/yr Total Effective DoseEquivalent (TEDE) as specified in the LTP; is below anadministrative level of 10 mrem/yr TEDE; and that the potential dosefrom residual radioactivity is ALARA.

Stakelholders: The primary stakeholders interested in the answer tothese problems are CYAPCO, the CT Department of EnvironmentalProtection (CTDEP), and the USNRC.

The Planning Team: The planning team consisted of the SiteClosure personnel with input from CYAPCO Health Physicsmanagement. The primary decision maker was the assigned FSSEngineer. The engineer obtained input from CYAPCO ProjectSupport on issues relating to schedule and costs.

Schedule: The approximate time to complete a FSSP and collect fielddata. Security constraints and activities related to the ISFSI mighttemporarily limit access to area, if applicable.

Resources: The primary resources needed to determine the answer tothe problem are American National Standards Institute (ANSI)qualified Health Physics Technicians to perform fieldwork andqualified FSS Engineers to prepare the plan, generate maps,coordinate field activities, and evaluate data. An off site laboratorywill analyze the samples and provide radionuclide specific results.Ancillary support may be required from the HNP Radiochemistry

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Count Room for soil sample gamma spectroscopy analysis, Securityfor access through site gates and the Warehouse to assist in shipmentof samples offsite.

* IDENTIFY THE DECISION

Several decisions need to be defined to address the stated problem:

Principal Study Question (1): Does the mean concentration of residualradioactivity in the survey unit exceed the release criteria or the statedadministrative level?

Alternate Actions (1): Alternative actions include failure of the surveyunit, remediation, reclassification, and no action.

The Decision (1): Determine whether the mean concentration ofresidual radioactivity in the survey unit exceeds the release criteria orthe administrative level stated in the problem.

Principal Study Question (2): Do any areas of elevated activity in thesurvey unit exceed the release criteria or the stated administrativelevel?

Alternate Actions (2): Alternative actions include confirmation andinvestigation, performing the, spot remediation, reclassification of partor the entire survey unit and no action.

The Decision (2): Determine if any areas of elevated activity in thesurvey unit exceed the release criteria or the administrative level statedin the problem.

Principal Studdy Question (3): Is the potential dose from residualradioactivity in the survey unit ALARA?

Alternate Actions (3): Alternative actions include remediation,resurvey, and no action.

The Decision (3): Determine if the potential dose from residualradioactivity in the survey unit is ALARA.

* IDENTIFY THE INPUTS TO THE DECISION

Information Needed: The survey unit requiring evaluation of residualactivity in accordance with Section 5.7.3.2.3 of the LTP. Newmeasurements of sample media are needed to determine theconcentration and variability for those radionuclides potentiallypresent at the site at the time of final status survey and if required,the extent of any areas of elevated activity or results that arestatistical outliers relative to the rest of the measurements.

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Source of the Inforniation: A review of historical information,1OCFR50.75 (g) (1) files, and radiological surveys providing anindication of the potential for contamination.

Sampling and Analysis Methods to Meet the Data Requirements: Themedia consisted of soils, asphalt, or concrete as required to completethe FSS. Soil samples were collected down to a depth of 15 cm (6inches) and analyzed by an off site laboratory. Other mediaconsidered during FSS planning included underlying soil, that is, soilbelow the asphalt, concrete, and groundwater.

As detailed in Reference 7.1, only two survey units in this phasesubmittal are affected by dose attributed to groundwatercontamination. Survey Units 9528-0000 and 9528-0003 wereassessed and the resultant dose was less than 0.2 mrem/yr for bothunits. The LTP does not associate the remaining survey units inPhase II submittal with groundwater contamination (LTP Table 5-4for groundwater). With the exception of Survey Unit 9806,subsurface soil samples were not collected or analyzed to support theobjectives of the FSSP. Radiation scans were performed to identifyareas of elevated activity.

Table 2-12 of the LTP lists twenty radionuclides potentially present atthe site. Derived Concentration Guideline Levels were calculated foreach of the radionuclides listed based on a 25 mrem/yr dose limit. Tocalculate DCGLs, dose models were developed to relate levels ofresidual radioactivity into potential dose. The DCGLs presented inChapter 6 of the LTP were developed for exposures from threepotential media, which is residual radioactivity in soil, existinggroundwater radioactivity, and additional future groundwaterradioactivity from the potential burial of concrete debris from sitebuildings containing residual radioactivity. In the LTP, Equation 5-1expresses the total dose (H) from all three media:

HTotal can be expressed as:

HTotal = Hsoil + H&Lsting GY + HFUiUreGW (Equation 5-1)

The elimination of the existing and future groundwater dosecomponents from Equation 5-1 for the purpose of performing theFSS for soil simplifies the use of the subsequent equation, LTPEquation 5-2, for the determination of dose from residualradioactivity in soil.

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Final Status Suntey Final Report - Phase II February 2005

Dosefrom the residual radioactivity from radionuclide "i" is:

H' =25* DCGL' (Equation 5-2)

For soil, Base Case DCGLSOi was determined for the radionuclideslisted in Table 2-12 of the LTP using the resident farmer scenario.The assumption is that residual radioactivity is present in the soil,which is used for residential and light farming activities.

Characterization was performed under a sample plan with dataquality commensurate with objectives of the survey. Characterizationmay have included radiation scanning for areas of elevated activitywithin one-meter radius of the sample measurement location andsample collection and transfer to the on-site laboratory using properchain-of-custody controls for analysis by gamma-spectroscopy.Qualified personnel using approved procedures implemented thecharacterization plan. Equipment was properly calibrated inaccordance with procedure.

The data was evaluated to determine if any of the twenty listedradionuclides are present in quantities greater than 5% of theapplicable Base Case DCGL in the survey unit at the time of FSS. Inaddition, the evaluation determines if the aggregate concentration ofthe twenty radionuclides will exceed 10%. The use of the 5% and 10%rule is consistent with the development of surrogate ratio DCGLs asdescribed in the LTP.

Available data is used to determine the radiological concentrationvariability in the survey unit and number of radionuclides present. Ifa single radionuclide is assumed present, then determining theoperational DCGL is simplified. In addition, the Base Case DCGLsfor all radionuclides used in FSS design are reduced by 60% toachieve the administrative level of 10 mrem/yr TEDE.

Meeting the administrative level automatically satisfies the releasecriteria by design, pending any groundwater dose.

As verification, a minimum of 5% of the samples required forcompliance are analyzed for all radionuclides listed in Table 2-1 ofthis report. All radionuclides listed in Table 2-1 verified present inFSS samples are included in the assessment of data and incorporatedinto the decision process as necessary.

Based on survey unit class, a decision to apply the ElevatedMeasurement Comparison (EMC) was evaluated. During Phase IIFSS, surveys indicated that EMC was not required. For example,

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EMC was included in the FSSP design of Survey Unit 9535-0001;however, application of the EMC was not used since isolated areas ofelevated activity were not found.

A decision to use Surrogate DCGLs was evaluated based onradionuclide analysis. During Phase II FSS, surrogates were onlyapplied in Survey Unit 9535-0001.

Soil samples analyzed on site were dried and analyzed by gammaspectroscopy. Samples analyzed off site at an approved laboratorywere dried in accordance with approved vendor procedures andanalyzed by gamma spectroscopy. Samples sent off site for HTDradionuclides (e.g., Sr-90, Pu-239/240) were analyzed using alphaspectroscopy or other radiochemistry methods (e.g., liquidscintillation).

The LTP specifies a required scanning coverage fraction of 0% to100% based on FSS classification. The fraction of scanning coverageis determined during the DQO process with the total amount, andlocation(s) based on the likelihood of finding elevated activity duringFSS.

All activities fall under the FSSQAP. This plan requires, among otherthings, the use of trained technicians, calibrated instruments, andprocedures. In addition to these requirements, a minimum of 5% ofthe required number of samples will be selected for QC evaluation.This evaluation may be either splits or duplicates.

Basis for Determining the Action Level: An Action Level, asdescribed by LTP Equation 5-30, is based on the concentrations ofresidual radioactivity compared to the reduced DCGLs by complyingwith the unity rule, or sum of the fractions.

Sampling and Analysis Methods to Meet the Data Requirements: TheLTP requires that MDCs for fixed measurements (samples areconsidered fixed measurements) be as far below the DCGL aspossible. A value of 10% is the desired level of sensitivity with up to50% of the DCGL being acceptable. The MDC for soil samples is40% of the Base Case DCGLs listed in Table 2-1 to account for theAdministrative Level DCGL of 10 mremlyr TEDE. Experience hasshown that gamma spectroscopy is capable of achieving these resultsin soil. For some HTD analyses, the radionuclides may not fulfillMDC requirements due to analytic method (e.g., C-14 in soil). Inthese cases, comparison to the higher value (i.e., 50% of the DCGL)or alternate methods may be used to evaluate the effectiveconcentration relative to the release criteria.

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Laboratory analysis results would include actual calculated results.Results reported as <MDC were not accepted for FSS. Resultsincluded reporting error, observed MDC and data qualifiers asappropriate.

* DEFINE THE BOUNDARIES OF THE SURVEY.

Boundaries of the survey: The actual physical boundaries as statedfor each survey unit.

Temporal boundaries: Estimated times and dates for the survey.Scanning and sampling in a survey unit is normally performed onlyduring daylight and dry weather.

Constraints: The most common constraints are the weather, the brushand undergrowth, and potential chance of local flooding fromseasonal rainfall or tidal flows.

* DEVELOP A DECISION RULE

The following decisions rules were developed to define a logicalprocess for choosing among alternative actions for the principalstudy questions associated with each survey unit.

Decision Rule (1): If all reported concentrations for residualradioactivity are less than the Administrative Level DCGL and theunity rule has been satisfied for each sample then the survey unit meetsboth the LTP specified and administrative release criteria. No furtheraction is required.

Decision Rule (2): If the mean of the sum of the ratios of the residualradioactivity from the required number of samples exceeds theoperational DCGL, then the survey unit fails the release criteria.Resurvey the area after considering remediation and reclassification.

Decision Rutle (3): If the mean of the sum of the ratios of the residualradioactivity from the required number of samples is less than theoperational DCGL, but an individual sample result exceeds theoperational DCGL, then conduct the Sign Test in accordance withProcedure RPM 5.1-21, "Perform the Sign Test," (Reference 7.39),and the EMC in accordance with the LTP Section 5.5.1.5. If the EMCand the Sign Test have been satisfied then the survey unit meets boththe LTP specified and administrative release criteria. No further actionis required. If the EMC or the Sign Test has not been satisfied, thenremediate the area(s) of elevated activity, resurvey the affectedlocation, and evaluate the results relative to the decision rule.

Decision Rule (4): If the potential dose from residual radioactivity inthe survey unit is ALARA then no further action is necessary. If the

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Final Status Sunrey Final Report - Phase H February 2005

potential dose from residual radioactivity in the survey unit is notALARA, then remediate and resurvey.

* SPECIFY TOLERABLE LIMITS ON DECISION ERRORS

The Null Hypothesis: Residual radioactivity in the survey unitexceeds the release criteria.

Type I Error: This is the ax error. This is the error associated withincorrectly concluding that the null hypothesis was rejected. The LTPhas set the a error at 0.05 (5%) unless prior approval is granted fromthe USNRC to use a less restrictive value. Therefore, a value of 0.05(5%) was used for survey planning and data assessment for FSS.

Type II Error: This is the P error. This is the error associated withincorrectly concluding that the null hypothesis was accepted. A valueof 0.05 (5%) was used for survey planning and data assessment forthese survey units.

The Lower Bound of the Gray Region (LBGR): The LBGR is set oradjusted during the optimization phase of the DQO process.

Relative Shift (A/a): The relative shift will be maintained within therange of 1.0 and 3.0 by adjusting the LBGR in accordance withProcedure RPM 5.1-11.

* OPTIMIZE DESIGN

Type of statistical test: The Sign Test was selected as the statisticaltest for FSS.

The Sign Test is conservative as it increases the probability ofincorrectly accepting the null hypothesis (i.e., the conclusion will bethat the survey unit does not meet the release criteria) and will notrequire the selection or use of a background reference area.

Number of samples determined in accordance with Procedure RPMS. 1-12, "Determination of the Numnber of Surface Samples for FSS ofOpen Land Areas ". (Reference 7.17) The number of samples forsystematic Sample Measurement Locations (SMLs) was determinedin accordance with Procedure RPM 5.1-12. The LBGR is set toobtain a relative shift in the range of 1 and 3. The locations of thesamples were determined using software Visual Sample Plan (VSP)in accordance with Procedure RPM 5.1-14, "Identif ing and MarkingSurface Sample Locations for FSS in Open Land Areas" (Reference7.40), and the appropriate grid spacing for the assigned class (i.e.random or systematic).

Nunber of judgmental samples and locations: The selection ofjudgmental or biased samples was at the discretion of the FSS

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Engineer. Locations chosen for sampling were usually areas ofinterest (small piles, trenches, etc).

Number of scan areas and location: Scan survey areas locations werebased on the conditions found during the area inspection or historicevaluation.

Number of samples for Quality Control: The minimum number ofquality control samples is 5% of the sample set. The locations forsplit samples are selected randomly using the Microsoft® Excel"RANDBETWEEN" function.

Investigation Levels: Investigation levels are established in the LTPfor the various classifications. Investigation levels may promptadditional survey and analysis to identify areas of elevated activity.The investigation level for a soil sample measurement includesindividual radionuclide results greater than the Administrative LevelDCGL or if the combined radionuclide results exceed the unity rule.For scan measurements, the investigation level is the MDC^N withvalues determined as a function of ambient background level usingguidance in Health Physics TSD BCY-HP-0081, "Scan MDCs forLand Areas using a Two-Inch by Two-Inch Sodium Iodide Detector,(Reference 7.37).

Power Curve: The Power Curve, developed using characterizationdata described in the FSSP and COMPASS software, showed adequatepower for the survey design.

4.2 Survey Unit Designation and Classification

Procedure RPM 5.1-10, "Survey Unit Classification," (Reference 7.41)defines the decision process for classifying an area in accordance with theLTP and MARSSIM. During the FSS of areas submitted for Phase II FinalReport, three survey areas, Survey Area 9526, 9528, and 9535, weresubdivided and reclassified.

In the Class 3 Survey Area 9526, a soil sample identified Cs-137 abovethose concentrations found at offsite locations within the vicinity of theHNP. Based on these sample results, a small section of Survey Area 9526was subdivided and a new Class 2 Survey Unit 9526-0001 was created.The 9526-0001 survey unit included the location where the elevated Cs-137 radioactivity was identified and confirmed. The land area for 9526-0001 exceeded the LTP size requirements for a FSS Class 2 area and theunit was split into two Class 2 survey units designated as 9526-0001 and9526-0002.

Several areas were identified in Survey Unit 9528-0000 along the southernborder of 9528 that possibly contained plant related radioactive materials.

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Initially the area was subdivided into one survey unit, 9528-0001. Thisarea, located along the Discharge Canal, was approximately 5.75 acres anddesignated Class 2. During the FSS of survey unit 9528-0001 it wasdetermined that plant-related activity was present in a soil sample locatedin an area along the Canal Road. Based on area limitations from the LTP,the decision was made to subdivide area 9528-0001, and create three newsurvey units. Each of the areas resulting from this subdivision, SurveyUnits 9528-0002, 0003 and 0004, were designated Class 2.

For Survey Area 9535, the reclassification and subsequent remedialactions are discussed further in Section 3.0 of this Final Report anddescribe in detail in the Final Status Survey Release Record for SurveyUnit 9535-0001, 9535-0002 and Survey Unit 9806.

4.3 Background Determination

As previously stated, "background" for soil samples was not calculatednor included in the DCGL comparisons to sample data. However, twodocuments are referenced, Health Physics TSD BCY-HP-0063,"Background Cs-137 Concentration in Soil," (Reference 7.35), and EPRITechnical Report 1003030, "Determining Background Radiation Levels inSupport of Decommissioning Nuclear Power Plants," (Reference 7.42).These documents, respectively, provided justification and support indetermining the origins of non-HNP derived Cs-137 and Sr-90encountered during the sampling campaign. None of the radionuclideconcentrations believed to be non-HNP derived were subtracted from theDCGL comparisons.

During FSS, area scanning, ambient backgrounds were determined and thetechnician established the "elevated" reading "action level" orinvestigation limit for that scan area. Instrument backgrounds arediscussed in the applicable procedure and in Health Physics TSD BCY-HP-0081. Instrument readings and a discussion about the scan areas areenclosed with each release record in the appendices.

4.4 Final Status Survey Plans

The level of effort associated with planning a survey is based on thecomplexity of the survey and nature of the hazards. To assist the SiteClosure FSS Engineers when preparing survey plans to support FSS,guidance is provided in Procedure RPM 5.1-11, "Preparation of FinalStatus Survey Plans" (Reference 7.7).

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Final Status Survey' Final Report - Phase H February 2005

4.5 Survey Design

4.5.1 Determination of Number of Data Points

The number of samples for SMLs were determined in accordancewith Procedure RPM 5.1-12., "Determination of the Number ofSurface Samples for FSS of Open Land Areas, " (Reference 7.17).A summary of survey design data points is provided in Table 4-1.

Table 4-1 - Number of Surface Samples for FSS

Survey Unit Survey Design Biased InvestigationSamples Samples' Samples

9523-0000 15 17 269524-0000 15 6 19525-0000 15 29526-0000 15 2 39526-0001 17 5 69526-0002 17 7 59528-0000 14(2) - 19528-0003 15 4 129528-0004 15 59535-0001 15 4 -

9535-0002 15 3 79536-0000 15 - 69537-0000 15 - 79538-0000 15 139806-0000 31 3 1

1. The collection ofjudgmental samples may be at the discretion of the FSS Engineer.2. Survey Design was for 15 samples. However, one sample was subsequently located in anothersurvey unit.

4.5.2 Sample Locations

Locations of the samples were determined using software VisualSample Plan (VSP) in accordance with Procedure RPM 5.1-14.VSP software imports a topographical map of the selected surveyarea and designates the VSP SMLs with coordinates and bearingsbased on the Connecticut State Plane System.

Pacific Northwest National Laboratory (PNNL) created VSP forthe United States Department of Energy. This software is verifiedand validated by Health Physics TSD BCY-HP-0079, "Use andVerification of Visual Sample Plan, " (Reference 7.43). The TSDcontains documentation including a user's manual for VSPVersion 1.0 and verification documentation.

For those locations where access was impractical or unsafe,alternate random sample locations were generated anddocumented.

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Sample locations were identified using GPS coordinates inaccordance with Procedure RPM 5.1-19, "Global PositioningSystem (GPS) Calibration, Setup, Operation and Soil SampleLocation Identification Instructions," (Reference 7.44), and areconsistent with the Connecticut State Plane System. Once located,sample points are physically marked as required by ProcedureRPM 5.1-14 and graphically plotted using AutoCAD-LtD software.

4.6 Instrumentation

The DQO process evaluates the ability of the instrument to measureradioactivity at levels below the applicable DCGL. Referenced by thesurvey plan, this evaluation is documented in Health Physics TSD BCY-HP-0081. Detector sensitivities are also discussed in Section 5.7 of theLTP.

4.6.1 Detector Efficiencies

The Eberline E-600 survey instrument coupled with the SPA-3High Sensitivity Gamma Detector was selected as the primaryradiation detection instrumentation for FSS land surveys at HNP.Efficiencies for the SPA-3 Sodium Iodide probe are demonstratedduring calibration as the ability to respond as expected whenexposed to a gamma radiation field from a NIST traceable Cs-137source in a Shepard Calibrator Model 28.5. For calibration, thedetector is exposed to a 0.4 mR/hr gamma radiation field for aperiod of 60 seconds. Instrument readings taken during theexposure time are used to calculate a cpm/itR (count perminute/micro-REM) reading, which is compared to a range ofaccepted values. If the cpm/4R reading is within an acceptablerange, the detector may be placed in service. If values are notwithin the range of acceptable response, the instrument isconsidered "Out of Service" and sent for evaluation and repair.This method is described in Procedure RPM 4.2-14, "Calibrationof the Eberline SPA-3 Smart Probe, " (Reference 7.45).

4.6.2 Detector Sensitivities

Instrument DQOs include a verification of the ability of the surveyinstrument to detect the radiation(s) of interest relative to theDCGLSO. DQOs established that the E-600 with the SPA-3scintillation probe, operated in the data-logging, rate-meter mode,set to audio response, met the detection criteria needed to performFSS surveys. Table 4-2 provides specifications for the SPA-3detector.

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Table 4-2 - SPA-3 Technical DetailsSpecifications

Application High sensitivity gamma measurementsDetector Type 2" diameter by 2" thick Nal (TI) (5.1 x 5.1cm)Operating 1,000 v nominalVoltageDead Time 14 ,s nominalBackground - 1.2 Mcpm/mR/hSensitivity (Cs-137)Energy Range - 60 keV to 2 MeVOperating -220 to +1 400 F (-30° to +600 C)TempHousing Aluminum bodyConnector CJ-1Size 2.63" diameter x 11.13" long (6.7 x 28.3 cm)Weight 3.4 lbs. (1.5 kg)

Detector sensitivity, or the ability to detect radionuclides of interestat levels acceptable for FSS, is derived as a function of theapplication of the DQO process, from vendor specifications,instrument calibration, survey technique and a determination ofbackground and MDCR. Unless noted otherwise in the releaserecords, before performing FSS of land areas, a scanning actionlevel was established at each sample location and judgmental scanarea based upon the background levels at the location. Thebackground level was determined by holding the detector at armslength and at waist height near the scan location and the readinglogged. An "Action Level" is then established which is equal to theMDCR plus the background counts per minute (cpm) rate.. Anyareas identified with readings above the Action Level requiredinvestigation and sampling. Table 4-3, from Health Physics TSDBCY-HP-0081, provides calculated action levels and associatedScan MDCs for Cs-137 and Co-60.

The methods described in NUREG-1507, "Minjinunm DetectableConcentrations with Typical Radiation Survey Instntments forVarious Contaminants and Field Conditions," December 1997(Reference 7.46), were incorporated in Health Physics TSD BCY-HP-0081 during the development of this document.

4.6.3 Instrument Maintenance and Control

Control and accountability of survey instruments were maintainedto assure the quality and prevent the loss of data. Health Physics

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Connecticut Yankee Atomic Power Company Haddam Neck PlantConnecticut Yankee Atomic Power Company Haddam Neck PlantFinal Status SurvAe Final Report - Phase 11 February 2005

Technicians operating the E-600 were trained and qualifiedthrough a documented "OJT" program. Procedure RPM 5.2-1,"Setup and Operation of the E-600 Digital Survey Instrument forScoping, Characterization and Final Status Surveys" (Reference7.47), provided details on the instrument for field use.

Table 4-3 - Action Levels and Associated Background Counts per MinuteBackground . Action Scan MDC Scan MDC

cpm Level pCi/g Cs-137 pCilg Co-602500 714 3214 3.13 0.823000 782 3782 3.43 0.903500 845 4345 3.70 0.974000 903 4903 3.96 1.044500 958 5458 4.20 1.105000 1010 6010 4.43 1.165500 1059 6559 4.64 1.226000 1106 7106 4.85 1.276500 1152 7652 5.05 1.327000 1195 8195 5.24 1.377500 1237 8737 5.42 1.428000 1278 9278 5.60 1.478500 1317 9817 5.77 1.519000 1355 10355 5.94 1.569500 1392 10892 6.10 1.6010000 1428 11428 6.26 1.6410500 1464 11964 6.41 1.6811000 1498 12498 6.56 1.7211500 1532 13032 6.71 1.7612000 1565 13565 6.86 1.8012500 1597 14097 7.00 1.8313000 1629 14629 7.14 1.8713500 1660 15160 7.27 1.9114000 1690 15690 7.41 1.9414500 1720 16220 7.54 1.9815000 1749 16749 7.67 2.0115500 1778 17278 7.79 2.0416000 1807 17807 7.92 2.0816500 1835 18335 8.04 2.1117000 1862 18862 8.16 2.1417500 1890 19390 8.28 2.1718000 1916 19916 8.40 2.2018500 1943 20443 8.51 2.2319000 1969 20969 8.63 2.2619500 1995 21495 8.74 2.29

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Connecticut Yankee Atomic Power Company Haddam Neck PlantConnecticut Yankee Atomic Power Company Haddam Neck PlantFinal Status Survey Final Report - Phase II February 2005

Background MDCR cpm Action Scan MDC Scan MDCcpm, P Level pCi/g Cs-137 pCilg Co-60

20000 2020 22020 8.85 2.3220500 2045 22545 8.96 2.3521000 2070 23070 9.07 2.3821500 2094 23594 9.18 2.4122000 2119 24119 9.28 2.4322500 2143 24643 9.39 2.4623000 2166 25166 9.49 2.4923500 2190 25690 9.59 2.5224000 2213 26213 9.70 2.5424500 2236 26736 9.80 2.5725000 2259 27259 9.90 2.5925500 2281 27781 9.99 2.6226000 2303 28303 10.09 2.6526500 2325 28825 10.19 2.6727000 2347 29347 10.28 2.7027500 2369 29869 10.38 2.7228000 2390 30390 10.47 2.7528500 2411 30911 10.57 2.7729000 2433 31433 10.66 2.7929500 2453 31953 10.75 2.8230000 2474 32474 10.84 2.8430500 2495 32995 10.93 2.8731000 2515 33515 11.02 2.8931500 2535 34035 11.11 2.9132000 2555 34555 11.20 2.9432500 2575 35075 11.28 2.9633000 2595 35595 11.37 2.9833500 2614 36114 11.45 3.0034000 2634 36634 11.54 3.0334500 2653 37153 11.62 3.0535000 2672 37672 11.71 3.0735500 2691 38191 11.79 3.0936000 2710 38710 11.87 3.1136500 2729 39229 11.96 3.1437000 2748 39748 12.04 3.1637500 2766 40266 12.12 3.1838000 2785 40785 12.20 3.2038500 2803 41303 12.28 3.2239000 2821 41821 12.36 3.2439500 2839 42339 12.44 3.2640000 2857 42857 12.52 3.28

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4.6.4 Instrument Calibration

Calibration of the Eberline E-600 and SPA 3 was performed everysix months with a NIST traceable Cs-137 source, Source #CY-33(120 mCi - 09/04/85) in a Shepard Calibrator Model 28.5. Surveyinstruments are "response checked" daily before issue and after theinstruments are used with a 5 pCi Cs-137 "button source" serialnumber E212YA.

4.7 Survey Methodology

4.7.1 Scan Surveys

The LTP specifies the minimum amount of scanning required foreach class as summarized in Table 4-4. The total fraction ofscanning coverage is determined during the DQO process with theamount, and location(s) based on the likelihood of finding elevatedactivity during Final Status Survey.

Table 44 - Scan CoverageSurvey Unit Required Scanning Coverage Fraction

ClassificationClass 1 100%

Outdoor areas, floors, or lower walls ofClass 2 buildings: 10% to 100%

Upper walls or ceilings: 10% to 50%Class 3 Judgmental

Upon selection, at the time of FSS, each scan area was located withGPS and marked. The area was divided into manageable 1-meterwide strips with a length approximately 8 to 10 meters long. Thestrips are then mapped and scanned 100%. Areas with elevatedreadings are marked, sampled and a 1-meter radius around eachsample location is scanned and documented. The probe ispositioned as close to the ground as possible and is moved at ascan speed of about 0.5 meters per second. Table 4-5 provides asummary of the area scanned during FSS.

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Connecticut Yankee Atomic Power Company Haddam Neck PlantConnecticut Yankee Atomic Power Company iladdam Neck PlantFinal Status Surv4e' Final Report - Phase H February 2005

Table 4-5 - Summary of Total Area Scanned

Survey Survey Unit Area in Area ScannedUnit Classification Square are Meters % Scan

9523-0000 3 151,364 502.3 0.339524-0000 3 61,975 1,949.8 3.29525-0000 3 28,000 186.7 0.79526-0000 3 444,700 1,000 0.29526-0001 2 6,504 663 10.29526-0002 2 6,068 675.2 11.19528-0000 3 508,000 783 0.159528-0003 2 10,000 1,028 10.39528-0004 3 3,100 388 12.59535-0001 1 1,860 1,860 1009535-0002 2 3,320 3,320 1009536-0000 3 1,536 1,536 1009537-0000 2 850 850 1009538-0000 2 1,500 195 13

9806-0000 A 5,180 Subsurface Not____ ___ ___ _ _ ____ ___ ___ _ _ ____ ___ ___ _ _ ____ ___ ___ ___ ap p licab le '

1. Excavated soils and materials were scanned prior to backfill.

For random and biased sample locations, the scan area for sampleswas a circle of one (1) meter radius around the sample flag. Theprobe was positioned as close to the ground as possible and wasmoved at a scan speed of about 0.5 meters per second.

During the scanning, the technician recorded data in a "DailySurvey Journal." This log documented field activities and otherinformation pertaining to the final survey.

4.7.2 Soil Sampling

In accordance with the FSS plan and Procedure RPM 5.1-3,"Collection of Surface and Subsurface Soil, Shoreline Sediment,Asphalt and Liquid samples for Scoping, Clharacterization andFinal Status Survey, " (Reference 7.53), the FSS techniciancollected surface soil or asphalt samples in random, systematic,and biased locations. Each sample location was documented, alongwith soil conditions and observations, and a chain of custodydeveloped to maintain sample integrity.

4.7.3 Total Surface Contamination Measurements

"Total Surface Contamination Measurements" refers to the FSS ofstructural surfaces such as walls, floors, and ceilings. During thisphase of FSS and submittal, no areas containing structures subjectto FSS were surveyed.

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Based on historic data and potential for use, approximately 20% ofthe cable vaults in Survey Area 9526 were surveyed. The surveysdid not identify any areas that contained detectable plant relatedradionuclides, thus meeting the unconditional release criteria forHNP.

4.8 Quality Control Surveys

Procedure RPM 5.1-24, "Split Sample Assessment for Final StatusSurvey," (Reference 7.49), establishes a method for evaluating QualityControl (QC) split samples collected in support of the FSS program.Quality Control split sample data is assessed on criteria taken from theUSNRC Inspection Manual, Inspection Procedure 84750, "RadioactiveWaste Treatment and Effluent and Environmental Monitoring," March1994 (Reference 7.50).

A minimum of five percent (5%) of the sample locations used in the FSSdesign were selected randomly using the Microsoft® Excel"RANDBETWEEN" function and submitted as "splits." Most splits takenfor FSS were field replicates, that is, samples obtained from one location,homogenized, divided into separate containers, and treated as separatesamples. These samples were used to assess errors associated with sampleheterogeneity, sample methodology, and analytical procedures. It isdesirable that when analyzed, there is agreement between the splitsresulting in data acceptance. If there is no agreement between the samples,the FSS Engineer evaluates the magnitude and impact on sample plandesign, the implementation and evaluation of results as well as the need toperform confirmatory sampling. When the FSS Engineer has determinedthat the discrepancy affects quality or is detrimental to the FSS programthen the discrepancy warrants the issuance of a Condition Report.

To maintain the quality of the FSS, isolation and control measures areimplemented throughout FSS activities until there is no risk ofrecontamination from decommissioning or the survey area has beenreleased from the license. Following FSS, until the area is released, asemi-annual surveillance is performed on FSS completed survey units.This includes an inspection of area postings, inspection of the area forsigns of dumping or disturbance and some sampling from selectedlocations. In the event that isolation and control measures werecompromised, a follow-up survey may be performed after evaluation.

5.0 SURVEY FINDINGS

Procedure RPM 5.1-23, "Data Quality Assessment," (Reference 7.51), providesguidance to Site Closure personnel to interpret survey results using the DQAprocess during the assessment phase of FSS activities. Although intended for FSS

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Connecticut Yankee Atomic Power Company Hadd~am Neck Plant


activities, the DQA process can be used for other radiological data collectionactivities (e.g., characterization and remedial action surveys). The extent to whichof the DQA process applies for these surveys will be commensurate with theobjectives of the particular survey.

The DQA process is the primary evaluation tool to determine that data are of theright type, quality and quantity to support the objectives of the sample plan (e.g.,FSSP and the requirements of the HNP LTP). The five steps of the DQA processare:

* Review the sample plan DQOs and the survey design,

* Conduct a preliminary data review,

* Select the statistical test,

* Verify the assumptions of the statistical test, and

* Draw conclusions from the data.

Data validation descriptors described in MARSSIM Table 9.3 was used during theDQA process to verify and validate collected data as required by the FSSQAP.

5.1 Survey Data Conversion

During the data conversion, the FSS Engineer will evaluate raw data forproblems or anomalies encountered during the FSSP activities (samplecollection and analysis, handling and control, etc.) including thefollowing:

* Recorded data,

* Missing values,

* Deviation from established procedure, and

* Analysis flags.

Once resolved, initial data conversion, which is part of preliminary datareview was performed and consists of converting the data into unitsrelative to the release criteria (i.e., pCi/g), and calculating basic statisticalquantities (e.g., mean, median, standard deviation). Table 5-1 provides asummary of the data analysis.

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Connecticut Yankee Atomic Powver Company Haddam Neck PlantConnecticut Yankee Atomic Power Company Haddam Neck PlantFinal Status Survey Final Report - Phase 11 February 2005

Table 5-1 - Summary of Statistical AnalysisRadionuclide Statistical Summary (pCi/g)

Cs-137 Co-60Survey Unit Class Samples JDCGL-3.16 Ci/g) CGA-1.52 pCng)

Ma en Standard NIStandardMax Mean Deviation Max Mean Deviation

9523-0000 3 15 3.83 1.15 1.10 0.0728 0.0118 0.02749524-0000 3 15 0.646 0.175 0.2219525-0000 3 15 0.0486 0.00729 0.0201 X -

9526-0000 3 15 1.31 0.703 0.290 - - _

9526-0001 2 17 1.87 0.923 0.515 0.0298 0.00205 0.0156

9526-0002 2 17 3.02 0.769 0.455 0.0778 O.0O049 0.0219

9528-0000 3 14 0.943 0.589 0.229 - -

9528-0003 2 15 0.562 0.101 0.158 0.0682 0.00301 0.03019528-0004 2 15 0.875 0.168 0.268 0.0318 -0.0015 0.01579535-0001 1 15 0.313 0.642 0.508 0.00852 0.0288 0.03199535-0002 2 15 0.66 0.169 0.143 0.014 0.00565 0.0103

9536-0000 2 15 0.152 0.0361 0.049 0.0288 0.00017 0.0150

9537-0000 2 15 0.0833 0.0293 0.0273 - -

9538-0000 2 15 0.337 0.170 0.0915 0.0457 0.00479 0.01719806-0000 A 31 0.37 0.0964 0.103 0.0261 0.00464 0.00963Note: Some Co-60 statistics not applicable to survey design. ( - )

5.2 Survey Data Verification and Validation

Items supporting DQO sample design andcompleteness and consistency. This includes:

data are reviewed for

* Classification history and related documents,

* Site description,

* Survey design and measurement locations,

* Analytic method and detection limit and that the requiredanalytical method(s) are adequate for the radionuclides ofconcern,

* Sampling variability has been provided for theradionuclides of interest,

* QC measurements have been specified,

* Survey and sampling result accuracy has been specified,

* MDC limits,

* Field conditions for media and environment, and

* Field records.

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Final Status Sunvy Final Report - Phase 11 February 2005

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

* Field and analytical results,

* Chain-of-custody,

* Daily Survey Journals,

* 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 DataReview record was initiated. This record serves to verify that all data arein standard units in relation to the DCGLs and requires the calculation ofthe statistical parameters needed to complete data evaluation. Included, ata minimum, are the following parameters:

* The number of observations (i.e., samples ormeasurements),

* The range of observations (i.e., minimum and maximumvalues),

* Mean,

* Median, and

* Standard deviation.

Considerations as an optional aid to evaluate the data set are thecoefficient of variation, measurements of relative standing, such aspercentile, and other statistical applications as necessary (frequencydistribution, skew etc.). Finalization of the data review consists ofgraphically displaying the data in distributions and percentiles plots.

5.3 Evaluation of Number of Sample/Measurement Locations in SurveyUnits

An effective tool utilized to evaluate the number of samples collected inthe sampling scheme is the Retrospective Power Curve generated byCOMPASS. The Retrospective Power Curve shows how well the surveydesign achieved the DQOs. For reporting purposes, all release recordsinclude a Retrospective Power Curve analysis indicating that the samplingdesign had adequate power to pass FSS release criteria (i.e. adequatenumber of samples was collected).

The Sign Test was the selected statistical test for all release recordssubmitted in this report. This test, performed in accordance with Procedure

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RPM 5.1-21, along with the Retrospective Power Curve demonstratessurvey design adequacy. If the data passes the Sign Test and RetrospectivePower Curve, the null hypothesis is rejected and the survey unit can bereleased with no further actions required. For reporting purposes, allSurvey Unit Release Records passed the Sign Test indicating that thesampling design was adequate (i.e. adequate number of samples wascollected).

The need to apply the EMC was evaluated and determined to be non-applicable for survey areas submitted in this report.

5.4 Comparison of Findings with Derived Concentration Guideline Levels

Upon completion of the Sign Test, the results were compared to thedecision rule provided in the FSSP. Based on the comparison, theinstructions in the FSSP are implemented and may include no action, re-survey or investigate.

Investigations are accomplished through the issue of an addendum to theFSSP. When the investigational criteria (e.g. sample results exceedsAdministrative Level DCGLIoil) is exceeded a "resample" is taken toverify lab results. If verified, several actions may occur at the discretion ofthe FSS Engineer. The most conservative response is a sample plandesigned to bound the elevated area with multiple samples. Informationcollected from this type of plan provides additional information forstatistical analysis and may stimulate further considerations to remediateand resurvey. It should be noted that one or more samples exceeding theAdministrative Level DCGL may not constitute failure of the survey unitand a viable option is to do nothing more in this area.

Areas discovered with concentrations of radionuclides exceeding the 10mrem/yr Administrative Level DCGL may require remedial action andwould therefore need another FSSP upon completion of remediation.

Another consideration is that, although verified, the sample reflects amechanism for concentrating the radionuclide of concern, and additionalsampling would only produce the same results. The engineer, throughconsensus, would take no further action and provide justification asneeded. This situation was encountered during FSS in the wetlands androcky slopes where a natural mechanism for concentrating Cs-137 exists.Researching this event shows that this type of occurrence is common andwell documented in other regions of the United States.

The "no-action" response is the most desirable condition. In general, a noaction response usually means that the sample plan was successful and thesurvey unit passes the release criteria. The assigned FSS Engineer willcompile the data, re-verify the results, and produce the Survey UnitRelease Record as the product of the FSS.

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Connecticut Yankee Atomic Power Company Haddam Neck PlantConnecticut Yankee Atomic Power Company Haddam Neck PlantFinal Status Survey Final Report - Phase 11 February 2005

5.5 USNRC/lndependent Verification Team Findings

The Environmental Survey and Site Assessment Program (ESSAP) of theOak Ridge Institute for Science and Education (ORISE) performedconfirmatory survey activities on selected open land survey units at theHNP site during the period of September 29 through October 1, 2003 andMarch 16 through 17, 2004. Survey units included in the scope of theIndependent Verification Team (IVT) survey are provided in Table 5-2.Survey units 9525-0000, a paved site road, and 9528-0004, which ismostly a rocky ledge and road right of way, were not included. (Samplecollection points for 9525 are below roadway pavement.) Survey Units9524-0000, 9535-0001, 9535-0002 and 9806 were not surveyed asCYAPCO was in the process of performing the FSS of these survey areasat the time of the IVT survey.

Table 5-2 - IVT Confirmatory Survey

I Survey Units I9523-0000 9531-00009526-0000 9532-00009526-0001 9536-00009526-0002 9537-00009528-0000 953+8-00009528-0003

The USNRC "Integrated Inspection Report 05000213/2004001," datedSeptember 20, 2004, (Reference 7.52) and the ORISE Revised FinalReport, "Confirmatory Survey of Open Land Area Survey Units at theConnecticut Yankee Haddam Neck Plant, Haddani, Connecticut"(Reference 7.58), found that the results of the survey activities confirmedthat the radiological conditions of open land area survey units that werepart of these confirmatory survey activities met the approved site-specificDCGLs for Co-60 and Cs-137 and the survey areas were appropriatelyclassified. The results of the laboratory analysis on the three samplescollected in Survey Unit 9535-0001 indicated that the CYAPCOcontractor laboratory data were consistent and in agreement with ESSAP'sanalytical results.

6.0 SUMMARY

The site release criteria for the Haddam Neck site meet the Title 10 CFR 20.1402criteria for unrestricted use. The residual radioactivity, including that from groundwater sources, that is distinguishable from background, must not cause the TotalEffective Dose Equivalent (TEDE) to an average member of the critical group to

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exceed 25 mrem/yr. The residual radioactivity must also be reduced to levels thatare ALARA.

As demonstrated in the Survey Unit Release Records, the fifteen (15) areassubmitted in this phase met the conservatively designed Administrative LevelDCGL of 10 mrem/yr criteria, thereby achieving ALARA.

7.0 REFERENCES

7.1 Health Physics Technical Support Document CY-HP-0193, "Assessmentof Existing Groundwater Dosefor Phase II Release Areas of the FinalStatus Suvey Report. "

7.2 Haddam Neck Plant License Termination Plan (LTP)

7.3 NUREG-1575, Multi-Agency Radiation Survey and Site InvestigationManual (MARSSIM)

7.4 ISC-QGP-00001-003, Final Status Survey Quality Assurance Plan(FSSQAP)

7.5 RPM 5.1 -00, Final Status Survey Program

7.6 NUREG-1757, Volume 2, Consolidated NMSS DecommissioningGuidance-Characterization, Survey, and Determination of RadiologicalCriteria

7.7 RPM 5.1-22, Preparation of Final Status Survey Reports

7.8 W. Norton (CYAPCO) to USNRC, "Letter of Intent Concerning theRelease of the East Site Grounds from the Part 50 License," dated April29, 2004 (CY-04-069 / Docket No. 50-213)

7.9 J. D. Donahue (USNRC) to K. Heider (CYAPCO), "Haddam Neck Plant -Issuance of Amendment RE: Approval of License Termination Plan,"dated November 25, 2002

7.10 T. Smith (USNRC) to W. Norton (CYAPCO), "Haddam Neck Plant -Release of East Site Grounds from Part 50 License," dated September 01,2004

7.11 RPM 5.1-11, "Preparation of Final Status Survey Plans"

7.12 "Historical Site Assessment Supplement" (HSA) June 30, 2000

7.13 "Characterization Report"- January 2000

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7.14 RPM 5.4-0 "Site Closure Training Program"

7.15 RPM 5.1-4, "Control and Accountability of Portable Survey Instrumentsfor Scoping, Characterization and Final Status Surveys"

7.16 CYAPCO Procedure 000-GEN-0000-00061-000, "Work Plan andInspection Record" (WPIR)

7.17 Procedure R5.1-12, "Determination of the Number of Surface andSubsurface Samples for FSS of Open Land Areas."

7.18 RPM 5.1-24, "Split Sample Assessment for Final Status Survey"

7.19 RPM 5.1-5, "Chain of Custody for Final Status Survey Samples"

7.20 RPM 5.1-23, "Data Quality Assessment"

7.21 "Quality Assurance Prograi for Haddam Nuclear Plant, " (CYQAP)

7.22 Quality Surveillance Report QSR-04-072-CY, March 9 - April 8, 2004

7.23 Quality Surveillance Report QSR-04-073-CY, June 7 - June 16, 2004

7.24 Quality Surveillance Report QSR-04-078-CY, April - June 2004

7.25 CYAPCO, "Final Status Survey Program Assessment Report" June, 2004

7.26 Condition Report 04-0810

7.27 Condition Report 04-0811

7.28 CYAPCO Nuclear Safety Audit Report, CY-04-A09-01, "Final SiteSurvey (FSS)/License Termination Plan (LTP), " November, 2004

7.29 Condition Report 04-1298, "Failure to Process timely License BasisDocument Change Request (LBDCR) for the License Termination Plan(LTP) changes"

7.30 US NRC NUREG CR-5 849 "Manualfor Conducting RadiologicalSurveys in Support of License Termination "

7.31 "Results of Scoping Survey for CYAPCO 's Haddam Neck Plant,"CYAPCO 1998

7.32 "NRC Historical Review Team Report - Radiological Control and AreaContamination Issues at Haddam Neck" USNRC, dated March 26, 1998

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Final Status Survey Final Report - Phase ! February 2005

7.33 Health Physics Department Technical Support Document BCY-HP-0078,"ALARA Evaluation of Soil Remediation in Support of Final Status Survey

7.34 RPM 5.1-16, "Turnover and Control of Open Land Areas for Final StatusSurvey."

7.35 Health Physics Technical Support Document BCY-HP-0063,"Background Cs-137 Concentration in Soil."

7.36 EPRI Technical Report 1003030, "Determining Background RadiationLevels in Support of Decommissioning Nuclear Power Plants."

7.37 Health Physics Technical Support Document BCY-HP-0081, "Scan MDCof Land Areas using a 2-inch by 2-inch Sodium Iodide Detector."

7.38 Health Physics Technical Support Document BCY-HP-0 150,"Investigation of Rock Outcropping Exhibiting Elevated Activity,"

7.39 RPM 5.1-21, "Perform the Sign Test"

7.40 RPM 5.1-14, "Identifying and Marking Surface Sample Locations for FSSin Open Land Areas"

7.41 RPM 5.1-10, "Survey Unit Classification"

7.42 EPRI Technical Report 1003030, "Determining Background RadiationLevels in Support of Decommissioning Nuclear Power Plants"

7.43 Health Physics Technical Support Document BCY-HP-0079, "Use andVerification of Visual Sample Plan"

7.44 RPM 5.1-19, "Global Positioning System (GPS) Calibration, Setup,Operation and Soil Sample Location Identification Instructions"

7.45 RPM 4.2-14, "Calibration of the Eberline SPA-3 Smart Probe"

7.46 NUREG-1507, "Minimum Detectable Concentrations with TypicalRadiation Survey Instruments for Various Contaminants and FieldConditions" December 1997

7.47 RPM 5.2-1, "Setup and Operation of the E-600 Digital Survey Instrumentfor Scoping, Characterization and Final Status Surveys"

7.48 RPM 5.1-3, "Collection of Surface and Subsurface Soil, ShorelineSediment, Asphalt and Liquid samples for Scoping, Characterization andFinal Status Survey"

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Connecticut Yankee Atomic Power Company Haddam Neck PlantConnecticut Yankee Atomic Power Company iladdam Neck Plant


7.49 RPM 5.1-24, "Split Sample Assessment for Final Status Survey"

7.50 USNRC Inspection Manual, Inspection Procedure 84750, "RadioactiveWaste Treatment and Effluent and Environmental Monitoring," March1994

7.51 RPM 5.1-23, "Data Quality Assessment"

7.52 USNRC "Integrated Inspection Report 05000213/2004001," datedSeptember 20, 2004

7.53 ORISE Revised Final Report -" Confirmatory Survey of Open Land AreaSurvey Units at the Connecticut Yankee Haddam Neck Plant, Haddam,Connecticut," (Docket No. 50-0213, RFTA No. 03-0008

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8.0 APPENDICES

Al Survey Unit Release Record 9523-0000, Southwest Wetland Area

A2 Survey Unit Release Record 9524-0000, South Site Grounds

A3 Survey Unit Release Record 9525-0000, Southeast Site Road

A4 Survey Unit Release Record 9526-0000, Northeast Mountain Side



A7 Survey Unit Release Record 9528-0000, Southeast Mountain Side



A10 Survey Unit Release Record 9535-0001, Southeast Landfill Area

Al l Survey Unit Release Record 9535-0002, Southeast Landfill Area

A12 Survey Unit Release Record 9536-0000, Construction Pile Near RifleRange

A13 Survey Unit Release Record 9537-0000, Pernitted Landfill Area

A14 Survey Unit Release Record 9538-0000, Material Storage Area

A15 Survey Unit Release Record 9806-0000, Southeast Landfill-9535

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