The first consideration is process knowledge (PK) of the area, i.e., do you have:
* a good understanding of the radiological condition of the area in question, and * a well documented history of area use Many sites, especially older sites, have been known to relocate soils/spoil for a variety of reasons. Haddam Neck had an interesting history with this. An approach to use is the MARRSIM approach to determine whether the area was un-impacted or impacted by plant operation based on the PK. Un-impacted, no survey required. Impacted, then classify the area according to contamination level with the underlying premise that the higher the potential for contamination the greater the survey rigor. Finally, the null hypothesis used by MARSSIM is the area exceeds the release criteria. In any event, the burden of proof is on the Licensee using the typical MARSSIM approach. There is an alternate null hypothesis where you would essentially conclude the area contamination is indistinguishable from background. From: [email protected] [mailto:[email protected]] On Behalf Of Holmes, Stephen J:(GINNA) Sent: Tuesday, November 26, 2013 4:35 PM To: [email protected] Subject: Powernet: Benchmarking Radiological Characterization of Excavations and Site Modifications in Non-Radiological areas Hello all, I am benchmarking best practices with regards to sampling and radiological characterization of excavations and modifications outside of radiological areas. If you have feedback to any or all of the questions below, I would appreciate it. I filled in the Ginna answers as a point of reference. What are your practices for performing volumetric sampling for radiochemical analysis? o Do you perform volumetric analysis of excavated soil, asphalt, gravel, concrete, roofing material, paint, or any other types of material? Ginna will typically perform gamma spec of anything volumetric that can be broken down to fit the GELI. If it doesn't meet the geometry requirements we will often do a "qualitative" gamma spec o Do you have standardized sampling plans (number of samples, locations, sampling patterns, etc)? If so, do you have a basis for your technique (such as MARSSIM/ MARSAME statistics or some other established method)? Ginna sampling plans are developed on a case-by-case basis. There is no standard procedure. o Do you analyze for anything other than gamma emitters? In most cases Ginna typically analyzes just for gamma emitters o What is your release criteria? Ginna - No detectable when counted to less than the ODCM LLDs. If analyzed in SAM, <5000 dpm. Do you perform direct frisk/scan surveys of materials outside of the RCA? This is not a usual practice at Ginna o If so, what type(s) of instrument(s) is/are used (e.g. scintillator, proportional counter, etc)? Do you use In-Situ Gamma Spec or any other survey techniques different from those I have already mentioned? Ginna will use the Small Article Monitor to analyze certain items (such as carpet) that aren't quantifiable by Gamma Spec. Ginna does not use In-Site Gamma Spec Do you have a formal document describing areas outside the RCA with higher risk of radiological contamination and, if so, do you use this when developing your survey plans? (for example, in the MARSSIM world, areas are categorized into three distinct levels based on expected residual contamination each category has different survey requirements) Ginna does not have a document of this type other than what is documented as required by 50.75(g).There is nothing formal to direct specific sampling requirements based on expected risk of residual contamination Do your practices change if you are outside the Protected Area? Ginna will do minimal, if any, radiological surveys or sampling for activities outside the PA Any procedures or other documents you would like to share? I can share Ginna's procedure if you would like. It has very little detail (which is why I am doing this Benchmark) Thanks and have a great Thanksgiving! -Steve Stephen J Holmes, CHP, PE Sr. Plant Health Physicist, RE Ginna NPP [email protected]<mailto:[email protected]> 585-771-3577 This e-mail and any attachments are confidential, may contain legal, professional or other privileged information, and are intended solely for the addressee. If you are not the intended recipient, do not use the information in this e-mail in any way, delete this e-mail and notify the sender. -EXCIP
