John, I cannot speak for how TVA would receive this type of initiative, but I would definitely put in the work to do this. Here are some thoughts
1. Based on the information you provide it sounds like the sediments do NOT contain LICENSED MATERIAL. I’m assuming your survey and data analysis were rigorous enough to demonstrate through non-parametric statistics that it is indistinguishable from background. I’m curious did you use a background sample set of surface soils or river sediments? As you know you can see a very big spike of Cs-137 in outside sediment locations such as down spouts that have been there for many years. 2. Discuss with plant management, and your resident. Determine if the regulator would like to perform a review of your survey prior to proceeding, just to be sure they are allowed the opportunity to review your statistical analysis prior to proceeding. 3. I wouldn’t worry about using a decommissioning standard, like NUREG 1505. There are plenty of statistical books out there for doing this type of statistical comparison. I used a text book version of the WRS and sign test with outlier detection methods in the early 90s for a similar analysis at Fort St. Vrain. ProUCL is free software provided by the EPA, that does a great job with the data and you can easily apply all the non-parametric tests using it: WRS, Sign Test, and tests etc fhttps://www.epa.gov/land-research/proucl-software Contact me, if I can provide additional information. Radiation Safety is a Cornerstone of Safe Operation Betsy Langille, CHP Senior Program Manager, Nuclear Power Group Governance and Oversight 1101 Market Street, BR 3C-C Chattanooga, TN 37402-2801 (423) 751-8659 office (865) 300-8616 cell [email protected]<mailto:[email protected]> NOTICE: This electronic message transmission contains information which may be TVA SENSITIVE, TVA RESTRICTED or TVA CONFIDENTIAL. Any misuse or unauthorized disclosure can result in both civil and criminal penalties. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the content of this information is prohibited. If you have received this communication in error, please notify me immediately by email and delete the original message. From: John Sukosky (Generation - 3) [mailto:[email protected]] Sent: Wednesday, May 04, 2016 1:18 PM To: '[email protected]' Cc: William Terry (Generation - 3); Jim Keithley (Generation - 3) Subject: [powernet] Powernet: Control or Free Release of Onsite Soil/Sediment Containing Only Cs-137 at Offsite Environmental Levels TVA External Message. Please use caution when opening. Surry Power Station would like to know if anyone has experience with the requirement for handling or free releasing onsite soil/sediment containing only Cs-137? We have about 50,000 tons of sediment that was placed onsite in a spoils area years ago from offsite river dredging. We used MARSSIM which directed use of NUREG-1505 to perform the analysis of Cs-137. The NUREG-1505 analysis determined that the Cs-137 residual radioactivity at the site is indistinguishable from environmental background Cs-137 in offsite sediment. However the Cs-137 in the onsite sediment is above the ODCM LLD. 1. Is there any requirements for onsite use of this sediment containing only Cs-137 at environment levels? Our engineers are considering using this sediment to build a road that is onsite. 2. Has anyone in an operating nuclear power plant ever used a MARSSIM or NUREG-1505 analysis to dispose (free release to unrestricted areas) of soil or sediment containing only Cs-137 at environmental levels? It appears that MARSSIM can only be used for decommissioning not operating plants. Thanks, John M. Sukosky, CHP Health Physicist III Radiological Protection, Surry Power Station Dominion Generation Phone: 757-365-2594; Internal: 8-798-2594 Fax: 757-365-2668 Pager: 804-273-3030 3636; E-mail: [email protected]<mailto:[email protected]> From: Galloway Jr., Gary Ross [mailto:[email protected]] Sent: Tuesday, May 03, 2016 4:40 PM To: Creamer, Charles E; '[email protected]' Subject: [powernet] RE: Dosimeter Pre-Alarms Brunswick does not use the pre-alarm function, we also use the 80% rule to exit. From: Creamer, Charles E [mailto:[email protected]] Sent: Wednesday, April 27, 2016 2:44 PM To: '[email protected]' Subject: [powernet] Dosimeter Pre-Alarms *** Exercise caution. This is an EXTERNAL email. DO NOT open attachments or click links from unknown senders or unexpected email. *** Has anyone used the pre-alarm function of the electronic dosimeter lately. I remember hearing something about them in the past in which dosimeter prelarms counted the same as an alarm but could not remember the specifics. At Browns Ferry we do not use them and brief people to exit the area before they get to 80% of the dose alarm set point Chuck Creamer Charles E. Creamer Health Physicist Tennessee Valley Authority Browns Ferry Nuclear Plant P.O. Box 2000 (Mail Stop NAB-1G-BFN) Decatur, Al. 35609-2000 Phone: 256-729-2983 Fax: 256-729-3101 Pager: 1-800-323-4853, pin 30-053 mailto:[email protected] This electronic message transmission contains information which may be TVA SENSITIVE, TVA RESTRICTED or TVA CONFIDENTIAL. Any misuse or unauthorized disclosure can result in both civil and criminal penalties. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the content of this information is prohibited. If you have received this communication in error, please notify me immediately by email and delete the original message. ________________________________ CONFIDENTIALITY NOTICE: This electronic message contains information which may be legally confidential and or privileged and does not in any case represent a firm ENERGY COMMODITY bid or offer relating thereto which binds the sender without an additional express written confirmation to that effect. The information is intended solely for the individual or entity named above and access by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this information is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you.
