ML25217A080

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License Termination Plan License Amendment Pre-Submittal Meeting August 6, 2025 Licensee Slides
ML25217A080
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 08/05/2025
From: Yetter B
Energy Solutions, Kewaunee Solutions
To:
Office of Nuclear Material Safety and Safeguards
References
Download: ML25217A080 (1)
v • d • e


Text

PRE-ASSESSMENT MEETING:

KEWAUNEE POWER STATION LICENSE TERMINATION PLAN OVERVIEW Bob Yetter ENERGYSOLUTIONS DIRECTOR, LICENSE TERMINATION/FINAL STATUS SURVEY

Reference Used For LTP Development 2

  • NUREG-1505, A Nonparametric Statistical Methodology for the Design and Analysis of Final Status Decommissioning Surveys
  • NUREG-1507, Minimum Detectable Concentrations with Typical Radiation Survey Instruments for Various Contaminants and Field Conditions
  • NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)
  • NUREG-1575, Supplement 1, Multi-Agency Radiation Survey and Assessment of Materials and Equipment Manual (MARSAME)
  • NUREG-1576, Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAP)
  • NUREG-1700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans
  • NUREG-1757, Volume 2, Consolidated Decommissioning Guidance - Characterization, Survey, and Determination of Radiological Criteria, Final Report

Use of Lessons Learned For LTP Development 3

Zion Nuclear Power Station Kewaunee Power Station LACBWR Fort Calhoun Station SONGS EnergySolutions Decommissioning Projects SEFOR

Chapter 1: General Information 4

  • Decommissioning Objective
  • Facility Description
  • Site description
  • Current/future land use
  • Meteorology and Climatology
  • Geology and Seismology
  • Surface and ground water hydrology
  • Environs and natural resources
  • Operational Background
  • License Termination Plan Summary
  • Regulatory Notifications of Changes
  • License conditions that establishes the criteria for determining when changes to the LTP require prior NRC approval. Changes require prior NRC approval when the changes:

require Commission approval pursuant to 10 CFR 50.59, result in significant environmental impacts, detract or negate the reasonable assurance that adequate funds will be available decrease a survey unit classification (i.e., Class 1 to Class 2 or Class 3, or Class 2 to Class 3) increase release criteria (DCGLs) increase Investigation Levels change the statistical test applied increase the Type I Decision Error change the approach used to demonstrate compliance with the dose criteria (e.g., change from demonstrating compliance using DCGLs to demonstrating compliance using a dose assessment that is based on final concentration data), or change parameter values or pathway dose conversion used to calculate the dose such that the resultant dose is lower than in the approved LTP and if a dose assessment is being used to demonstrate compliance with the dose criteria.

Chapter 1: General Information 5

KPS Owner Controlled Area/Licensed Site Boundary (883 acres)

Non-Impacted Areas (634 acres)

Impacted Areas Outside Protected Area (234 acres)

Impacted Areas Inside Protected Area (11 acres)

ISFSI (out of scope)

(4 acres)

Chapter 1: General Information 6

KPS Site Layout and Demolition Phases

Chapter 2: Site Characterization 7

Concrete Coring 5/1/23-8/23/23 Soil Sampling 10/3/23-6/27/24 Kd Study in progress

Chapter 2: Site Characterization 8

The purpose of site characterization is to ensure that the final status survey (FSS) will be conducted in all areas where contamination existed, remains, or has the potential to exist or remain. The results of the characterization survey, along with the information in the Historical Site Assessment (HSA), demonstrate that it is unlikely that significant quantities of residual radioactivity have gone undetected.

Types of Measurements and Samples Open Land Areas:

Gamma scans Surface and Subsurface soil samples Sediment and Surface Water samples Structures:

Beta/gamma scans Beta/gamma static measurements Volumetric concrete samples Smears for loose surface contamination Sediment samples in embedded/buried piping Total Non-Imp Class 3 Class 2 Class 1 Concrete Cores/Samples 1,130 0

159 8

963 Surface Soil Samples 461 164 212 10 75 Subsurface Soil Samples 84 0

0 0

84 Sediment Samples 31 0

25 0

6 There are areas known to potentially contain contamination that were inaccessible during the initial characterization which will be surveyed as access is gained. List provided in Ch 5. Results provided in relevant survey unit release records (SURRs).

Chapter 2: Site Characterization 9

Non-Impacted Impacted O/S PA

Chapter 2: Site Characterization 10 Impacted I/S PA Structures

Chapter 3: Identification of Remaining Dismantlement Activities 11 Sub-Grade Basements Turbine Building (incl. Admin. Bldg.)

3 below grade (603 AMSL)

No interior walls except pedestals Embedded Piping (floor drains)

Reactor Building 3 below grade No interior walls Concrete removed to liner No embedded piping Auxiliary/Fuel Handling Building 3 below grade No interior walls Embedded piping (floor drains)

Screenhouse 3 below grade ATF &TSC (PH1 demo), Training Building, Sewage Treatment Facility 3 below grade No interior walls Intake/Discharge Structure to remain B/G Above-Grade Buildings Site Boundary Facility (NI - out of scope)

Maintenance Building Switchyard Switchyard Control House Switchyard South Control House Switchyard Spare Parts Building Buried Piping Sanitary Sewer Storm Sewer Service Water Recirculating Water Potable Water Fire Protection Sewage Treatment Plant Switchyard Oil Collection System Waste Disposal Culverts Miscellaneous Buried Pipe (7)

All other structures will be removed in their entirety with the exception of the sub-grade basements, above-ground buildings and the Switchyard.

Once D&D activities are completed, as well as subsequent FSS and IVS, each basement or excavation (if required) will be backfilled to grade with clean (non-impacted) fill from an off-site location.

Chapter 3: Identification of Remaining Dismantlement Activities 12

Chapter 3: Identification of Remaining Dismantlement Activities 13 Milestone Date Milestone Date Demolition of Transformer Bays Q4/2025 Demolition of Administrative & Training Facility Q3/2023 Demolition of Administration Building Q4/2025 Demolition of Maintenance Vehicle Garage Q3/2023 Reactor Vessel Internals Segmentation Q1/2027 Demolition of Office-Warehouse Annex Q3/2023 Demolition of Auxiliary Building Q3/2027 Demolition of Decontamination & Fabrication Bldg.

Q3/2023 Reactor Vessel Segmentation Q4/2027 Demolition of Technical Support Center Q4/2023 Demolition of Intake/Discharge Structures Q3/2029 Demolition of 9-Stall Garage Q4/2024 Demolition of Shield Building 2030 Large Component Removal Q4/2024 Demolition of Waste Handling Facility 2030 Demolition of Gatehouse Q1/2025 Demolition of Containment Waste Structure 2030 Demolition of Sewage Treatment Plant Q3/2025 Final Status Survey Complete 2030 Installation of Containment Waste Structure Q3/2025 License Termination (except for ISFSI) 2031 Installation of Waste Handling Facility Q4/2025 Demolition of Turbine Building Q4/2025

Chapter 3: Identification of Remaining Dismantlement Activities 14 Radiation Exposure Projections for Decommissioning Volume (Cubic Feet)

Waste Class 4,394,944 A

780 B or C 173 GTCC 8,251,450 Clean 12,647,347 Total Projected/Estimated Waste Quantities Exposure-to-Date 6/30/25 (person-rem)

Estimated Exposure (person-rem)

Activity 17.74 17.74 Large Component Removal - S/G & PZR 16.625 16.7 Large Component Removal - prep and all other 1.963 60 Reactor Vessel/Internals Segmentation 1.463 8

AB Surgical Demo 0

10 RCS Removal 0

6 AB RCS/Support Systems 0.310 20 CTMT Surgical Demo 0.006 60 Waste Operations 0

4 Reactor Vessel Head 38.107 202.44 Total Project Activities 0.391 1.2 Walk downs/Tours/Security/NRC 0.781 30 RP Routines 0.098 7.5 Misc. D&D Activities 0

0.2 FSS Activities 0.031 2

Misc. Operational Activities 1.301 40.9 Total Operational Activities 39.408 243.34 Project Total

Chapter 4: Remediation Plans 15

  • Remediation Actions
  • Scabbling, Pressure Washing, Grit or Sponge Blasting, Hydrolasing, Needle Guns, Excavation, etc.
  • Remediation Activities Impact on the Radiation Protection Program
  • Costs to remediate and transport waste (plus risk), worker dose, analysis equation

==

Conclusion:==

No benefit to remediation past the DCGL FCS Auxiliary Building

Chapter 5: Final Status Survey Plan 16 The purpose of the FSS Plan is to describe the methods to be used in planning, designing, implementing, evaluating and reporting the FSS at KPS. The FSS Plan also provides discussion on Quality Assurance (QA).

Planning Design Implementation Assessment Reporting 5 Principal Elements of the FSS Process The FSS Plan describes the final radiation survey process used to demonstrate that the site complies with the radiological criteria for unrestricted use specified in 10 CFR 20.1402.

Chapter 5: Final Status Survey Plan: Planning 17 Establish Radionuclides of Concern and Mixture Fraction Half Life Radionuclide 4.32E+02 Am-241 7.38E+03 Am-243 5.73E+03 C-14 2.85E+01 Cm-244 5.27E+00 C0-60 2.06E+00 Cs-134 3.00E+01 Cs-137 1.35E+01 Eu-152 8.80E+00 Eu-154 2.70E+00 Fe-55 1.24E+01 H-3 Half Life Radionuclide 7.50E+04 Ni-59 9.60E+01 Ni-63 2.14E+06 Np-237 2.62E+00 Pm-147 8.77E+01 Pu-238 2.41E+04 Pu-239 6.60E+03 Pu-240 1.44E+01 Pu-241 2.76E+01 Sb-125 2.91E+01 Sr-90 2.13E+05 Tc-99 Initial Suite of Radionuclides Half Life Radionuclide 1.24E+01 H-3 5.73E+03 C-14 2.70E+00 Fe-55 5.27E+00 C0-60 9.60E+01 Ni-63 2.03E+04 Nb-94 3.00E+01 Cs-137 2.03E+04 Nb-94 Final ROC and mixture fractions for each media are established in TSD 25-01 (in development)

Chapter 5: Final Status Survey Plan: Planning 18 Establish Derived Concentration Guideline Levels (DCGLs)

A Derived Concentration Guideline Level (DCGL) is a derived, radionuclide-specific activity concentration within a survey unit corresponding to the release criterion.

DCGLs are derived from activity/dose relationships through various exposure pathway scenarios.

To ensure that the summation of dose from each source term is 25 mR/year or less after all FSS is completed, the Base Case DCGLs are reduced based on a projected, or a priori, fraction of the 25 mR/year dose limit from each media.

The reduced DCGLs, or Operational DCGLs, are then used for survey design and implementation.

Table showing DCGLBC and DCGLOP for each media provided in Chapter 5.

DCGL Units of Measure A priori Fraction Media pCi/m2 0.15 Basement Floors/Walls pCi/m2 0.3 Basement Embedded Pipe pCi/g 0.28 Soil dpm/100 cm2 0.14 Buried Pipe dpm/100 cm2 0.09 Above-ground Building pCi/g 0.02 Basement Fill DCF (mrem/year per pCi/L) 0.02 Existing Groundwater 1

Sum a priori Dose Fractions for End State Media The radiological criteria for unrestricted use specified in 10 CFR 20.1402 are:

1) the residual radioactivity that is distinguishable from background radiation results in a total effective dose equivalent (TEDE) to an average member of the critical group (AMCG) that does not exceed 25 millirem/year, including that from groundwater sources of drinking water, and 2) the residual radioactivity has been reduced to levels that are as low as is reasonably achievable (ALARA).

Chapter 5: Final Status Survey Plan: Planning 19 Verify Classification of Survey Units

Class 1 areas are impacted areas that have, or had prior to remediation, a potential for radioactive contamination (based on site operating history) or known contamination (based on previous radiological surveys) above the DCGLW, and there is insufficient evidence to support reclassification as Class 2 or Class 3.

Class 2 areas are impacted areas that have, or had prior to remediation, a potential for contamination or known contamination, but are not expected to exceed the DCGLW and little or no potential for small areas of elevated activity.

Class 3 areas are not expected to contain residual radioactivity, or are expected to contain levels of residual radioactivity at a small fraction of the DCGL, based on site operating history and previous radiological survey, and have little or no potential for small areas of elevated activity. Previous remediation would preclude a survey unit from having a Class 3 designation.

Suggested Surface Area Limit Survey Unit Type/Classification 100 m2 2,000 m2 2,000 m2 Class 1:

Above-ground Structures (floor area)

Land Areas Basements (all surfaces combined) 100 to 1,000 m2 2,000 m2 to 10,000 m2 2,000 m2 to 10,000 m2 Class 2:

Above-ground Structures (floor area)

Land Areas Basements (all surfaces combined) no limit no limit no limit Class 3:

Above-ground Structures (floor area)

Land Areas Basements (all surfaces combined)

Class 1 or Class 2 basement survey unit sizes can exceed the open land area sizes listed in Table 5-1, but the direct measurement frequency (i.e., samples per area) must be equal to or greater than that derived assuming survey unit sizes of 2,000 m2 and 10,000 m2, respectively.

KS-FS-PR-302

Chapter 5: Final Status Survey Plan: Planning 20 Isolation and Control Measures Isolation & Control measures are implemented IAW KS-FS-PR-003 Describes the protocols used to verify that a survey unit is in suitable physical condition for FSS implementation, that proper I&C measures are in place to limit the potential for cross-contamination from other decommissioning activities and that the final physical and radiological conditions are maintained Walkdowns performed to verify:

All decommissioning activities are completed All surfaces are prepared for FSS (mark grids/survey locations, mowing, etc.)

All tools and equipment not needed for FSS are removed Measures to prevent cross-contamination are in place Hazards have been identified - mitigation measures in place or hazard eliminated Travel paths through area are removed or re-routed Periodic surveillances performed and I&C measures remain in force throughout FSS and until there is minimal risk of cross-contamination from D&D or the survey unit released from the license.

KS-FS-PR-303

Chapter 5: Final Status Survey Plan: Planning 21 Background Reference Areas and Ambient Background A background study may be necessary to determine Cs-137 levels present in local soil due to fallout from nuclear weapons testing and power plant accidents (Chernobyl)

A background study may be necessary to determine Cs-137 levels present in local soil due to fallout from nuclear weapons testing and power plant accidents (Chernobyl)

Using the Data Quality Objective (DQO) process, a sample plan is prepared to obtain measurements/samples at offsite locations (Background Reference Area) having similar geographical features as the licensed site Using the Data Quality Objective (DQO) process, a sample plan is prepared to obtain measurements/samples at offsite locations (Background Reference Area) having similar geographical features as the licensed site A Background Reference Area is needed if the Wilcoxon Rank Sum (WRS) is used for the Partial Site Release of Non-Impacted portions of the license property. Normally, the Sign Test is used for FSS and therefore, a Background Reference Area study is not necessary A Background Reference Area is needed if the Wilcoxon Rank Sum (WRS) is used for the Partial Site Release of Non-Impacted portions of the license property. Normally, the Sign Test is used for FSS and therefore, a Background Reference Area study is not necessary Depending on the DCGLs, determination and subtraction of ambient background may be required during the FSS of buried piping and above-grade buildings Depending on the DCGLs, determination and subtraction of ambient background may be required during the FSS of buried piping and above-grade buildings Media-specific background determinations are typically not needed if using the Sign Test Media-specific background determinations are typically not needed if using the Sign Test

Chapter 5: Final Status Survey Plan: Planning 22 Additional Chapter 5 Planning Discussions Surrogate Radionuclides Surrogate ratios have been established for several different mixture fractions.

In cases where the use of surrogate ratios is not feasible, direct analysis of HTD radionuclides will be required.

Adjusted Gross DCGLs For the FSS of above-ground buildings, adjusted gross DCGLs are calculated because radionuclide-specific data is not acquired with static measurements.

Sum of Fractions (SOF)

The SOF or unity rule is applied to the data used for the survey planning, data evaluation and statistical tests for the analyses of media since multiple radionuclide-specific measurements will be performed or the concentrations inferred based on known relationships.

When the unity rule is applied, the DCGLW (used for the nonparametric statistical test) becomes one.

Area Factors Rather than using statistical methods, a simple comparison to an investigation level is used to assess the impact of potential elevated areas.

The investigation level for this comparison is the DCGLEMC, which is the DCGLW modified by an AF to account for the small area of the elevated radioactivity.

Dose from Groundwater Dose from Fill Material

Chapter 5: Final Status Survey Plan: Survey Design 23 Relevant Procedures For FSS and RASS, the survey design is specific for each survey unit For Characterization surveys and RAs (which is a form of continuing characterization), individual survey units may be grouped together Likewise, non-impacted survey units may be grouped together when performing characterization surveys to support Partial Site Release KS-FS-PR-201, Characterization Sample Plan Development KS-FS-PR-301, Final Status Survey Sample Plan Development KS-FS-PR-306, Radiological Assessments (RA) and Remedial Action Support Surveys (RASS)

Chapter 5: Final Status Survey Plan: Survey Design 24 Data Quality Objectives (DQOs)

5. Develop a Decision Rule
7. Optimize the Design
1. State the Problem
2. Identify the Decision
4. Define the Boundaries
6. Limits on Decision Error
3. Identify the Inputs The DQO process includes a series of planning steps found to be effective in establishing criteria for data quality and developing survey plans. DQOs allow for systematic planning and are specifically designed to address problems that require a decision to be made, and alternate actions defined.

Chapter 5: Final Status Survey Plan: Survey Design 25 A reference grid will be used for reference purposes and to locate the sampling and measurement locations. The reference grid will be physically marked during the survey to aid in the collection of samples and measurements Software tools such as Visual Sample Plan (VSP) will be used to establish grid spacing, including random start points. Mapping tools such as GIS will be used to determine coordinates for GPS Systematic Random Judgmental Systematic sampling and measurement locations for Class 1 and Class 2 survey units will be located in a systematic pattern or grid. The grid spacing (L), will be determined using a triangular or square grid. Random start grid location.

For Class 3 survey units, each sampling and measurement location will be randomly selected using a random number generator Judgmental (biased) sampling and measurement locations are performed at locations selected using professional judgment based on unusual appearance or at locations of known or suspected contamination

Chapter 5: Final Status Survey Plan: Survey Design 26 Section 5.5 of MARSSIM and Appendix A of NUREG-1757 describe the process for determining the number of sampling and measurement locations (sample size) necessary to ensure that the data set is sufficient for statistical analysis such that there is reasonable assurance that the survey unit will pass the requirements for release.

Decision Errors The value will always be set at 0.05 (5 percent) unless prior NRC approval is granted for using a less restrictive value.

The value will also be initially set at 0.05 (5 percent), but may be modified, as necessary, after weighing the resulting change in the number of required sampling and measurement locations against the risk of unnecessarily investigating and/or remediating survey units that are truly below the release criterion.

Unity Rule or SOF will be used for survey design/data analysis since multiple radionuclide-specific measurements will be performed.

Gray Region Upper Bound of the Gray Region Lower Bound of the Gray Region Relative Shift The general approach prescribed by MARSSIM for FSS requires that at least a minimum number of measurements or samples be taken within a survey unit, so that the nonparametric statistical tests used for data assessment can be applied with adequate confidence.

Sample Size Determination

Chapter 5: Final Status Survey Plan: Survey Design 27

survey unit preparation requirements including isolation & control measures

maps showing the survey unit boundaries, measurement/sample locations, and locations of elevated readings

applicable DCGLs

instrumentation to be used and methodologies for use

types and quantities of measurements or samples to be made or collected

measurement and sample nomenclature

chain of custody requirements

investigation criteria

QA/QC requirements (e.g., replicate measurements or split samples)

applicable health and safety precautions and mitigation measures The product of the FSS survey design process is a sample plan. Sample plans are prepared for each survey unit independently and address various elements of the survey, including, but not limited to:

Chapter 5: Final Status Survey Plan: Implementation 28 Trained and qualified personnel will perform survey measurements and collect samples. The types of measurements performed for FSS include surface scans, static measurements, gamma spectroscopy of volumetric materials, and in-situ gamma spectroscopy.

The survey implementation requirements and objectives have been outlined in the LTP and incorporated into procedures.

Chapter 5: Final Status Survey Plan: Implementation 29 Measurements and/or samples collected to describe the as-left radiological conditions of above-grade structures, basements (including penetrations and embedded piping), surface soil, sub-surface soil, buried piping that are earmarked to remain on site at time of license termination Scanning is performed in order to locate small, elevated areas of residual activity above the investigation level Static measurements and media samples are the COMPLIANCE data ISOCS measurements serve as scan and volumetric measurements

Chapter 5: Final Status Survey Plan: Implementation 30 Detector Model Instrument Model Effective Detector Area

& Window Density Detector Type Measurement Type Ludlum 44-116 Ludlum 3001/3 1.2 mg/cm2 0.01 Plastic Scintillation 125 cm2 Scintillation Beta Static/Scan Measurement Ludlum 44-10 Ludlum 3001/3 2 diameter x 2 length NaI Scintillation Gamma Scan Measurement Ludlum 44-20 Ludlum 3001/3 3 diameter x 3 length NaI Scintillation Gamma Scan Measurement AEGIS (Mirion) In Situ Object Counting System (ISOCS)

N/A High-purity Germanium Gamma Static/Scan Measurement Ludlum 44-159 Ludlum 44-157 Ludlum 44-162 Ludlum 3001/3 0.75 x 0.75 2 x 2 3 x 3 CsI NaI NaI Gamma Pipe Static Measurement N/A Canberra Lab In Situ Detector or Kromek N/A High-purity Germanium/CZT Surface and Volumetric Material (soil, etc.)

Typical FSS Survey Instrumentation

Chapter 5: Final Status Survey Plan: Implementation 31 FSS of Buried Piping, Embedded Piping, and Penetrations Ludlum 3001 0.75 x 0.75 CsI 2 x 2 NaI Or 3 x 3 NaI Detectors are configured in a fixed geometry relative to surveyed surface.

Detectors are deployed in the pipe and static measurements are acquired at intervals commensurate with the contamination potential.

Chapter 5: Final Status Survey Plan: Implementation 32 FSS of Basements and Excavations Using In Situ Object Counting System (ISOCS)

  • Performed on Basement Surfaces, Excavations
  • ISOCS Instrumentation used for Basements
  • Determines total inventory with depth in concrete
  • Allows remote access; minimizes hands on scan/static surveys or sampling (coring)
  • Nominal FOV of (10-30 m2)
  • FSS Survey Units
  • BFM not sensitive to elevated activity levels and size of elevated areas
  • No MARSSIM survey unit size restrictions
  • Averages contamination over entire field of view (FOV)

AEGIS system being used at KPS, which does not require the bulky cooling components

Chapter 5: Final Status Survey Plan: Data Assessment 33 The Data Quality Assessment (DQA) approach is an evaluation method used during the assessment phase of FSS to ensure the validity of FSS results and demonstrate achievement of the survey plan objectives.

The DQA process will include a review of the DQOs and survey plan design, will include a review of preliminary data, will use appropriate statistical testing, will verify the assumptions of the statistical tests, and will draw conclusions from the data.

Chapter 5: Final Status Survey Plan: Data Assessment 34 The DQA approach being implemented at KPS is an evaluation method used during the assessment phase of FSS to ensure the validity of FSS results and demonstrate achievement of the survey plan objectives.

verification that the measurements were obtained using approved methods,

verification that the quality requirements were met,

verification that the appropriate corrections were made to any gross measurements, and that the data is expressed in the correct reporting units,

verification that the Minimum Detectable Concentration (MDC) requirements have been met,

verification that the measurements required by the survey design, and any measurements required to support investigation(s) have been included,

verification that the classification and associated survey unit design remain appropriate based on a preliminary review of the data,

subjecting the measurement results to the appropriate statistical tests, and

determining if the residual radioactivity levels in the survey unit meet the applicable release criterion, and if any areas of elevated radioactivity exist.

Chapter 5: Final Status Survey Plan: Data Assessment 35 Non-parametric Statistical Test For KPS, the Sign test is the most appropriate test for FSS. Characterization surveys indicate that Cs-137 found in background due to global fallout constitutes a small fraction of the DCGL. Consequently, the Sign test will be applied to open land, basement surfaces (to include penetrations and steel liner), above-ground buildings, embedded pipe and buried piping when demonstrating compliance with the unrestricted release criteria.

Data Investigations If all measurements are below the DCGLOP, then the survey unit passes FSS - a Sign Test is not required.

If an individual measurement exceeds the DCGLOP, then the Sign Test is performed.

If an individual measurement exceeds the DCGLBC, then an Elevated Measurement Comparison is performed, or the location is remediated.

If the Sign test fails, or if the mean of the total SOFs in a survey unit exceeds one (using Operational DCGLs), then the survey unit will fail FSS.

If the survey unit fails FSS, then an investigation will be implemented. Depending on the results of the investigation, the survey unit will be remediated, reclassified (if necessary) and re-surveyed.

Chapter 5: Final Status Survey Plan: Data Reporting 36 A Survey Unit Release Record will be prepared to provide a complete record of the as-left radiological status of an individual survey unit, relative to the specified release criteria. Survey Unit Release Records will be made available to the NRC for review as appendices to the appropriate FSS Final Report.

An FSS Final Report, which is a written report that is provided to the NRC for its review, will be prepared to provide a summary of the survey results and the overall conclusions which demonstrate that the site, or portions of the site, meets the radiological criteria for unrestricted use, including ALARA.

The FSS Final Report will be provided to the NRC in phases The phased approach for submittal is intended to provide NRC with detailed insight regarding the remediation and FSS early in the process, to provide opportunities for improvement based on feedback, and to support a logical and efficient approach for technical review and independent verification.

Chapter 5: Final Status Survey Plan: Quality Assurance 37 KS-FS-PN-100 Training/

Qualifications QAPP Instrument Quality Documents/

Records QC Surveys Oversight Instrument/

Equipment Calibration Data Acquisition Data Analysis/

Assessment Kewaunee Solutions Quality Assurance Project Plan for the License Termination Plan Development, Site Characterization, and Final Status Survey Projects

Chapter 5: Final Status Survey Plan: Radiological Assessments 38 Sampling and/or measurements performed in survey units to assess the radiological conditions where radiological conditions may have changed since initial site characterization or were unknown due to inaccessibility (another form of site characterization)

Primarily scheduled after secondary-side building demolition/slab removal Successor to building demolition/slab removal Predecessor to backfill of building footprint Performed in trenches/excavations when installing/removing piping Scan topside land where excavation footprint and where excavated soil will be staged Periodic scans/samples obtained as excavation progresses, and final scans/samples obtained when excavation complete Performed in any areas to verify survey unit is suitable for implementation of FSS Large excavations (removal of sub-grade basement) or prior remediation require FSS.

Gamma scans and soil sampling - gamma spec. analysis expedited

Chapter 5: Final Status Survey Plan: Remedial Action Support 39 Formal surveys conducted in survey units to support remediation, followed by subsequent FSS RASS normally performed in survey units undergoing FSS as a result of:

o a measurement exceeding the DCGL o a measurement exceeding an elevated measurement comparison (EMC) o the survey unit failing the statistical testing Realtime measurements guide remediation

Chapter 6: Compliance with Radiological Criteria for License Termination 40 Compliance Exposure Scenario Excavation of basement walls 3 m below ground surface included in Resident Farmer scenario.

Excavation of basement walls, floors and foundations below 3 m included in Industrial Use scenario.

Bounding Building Occupancy exposure scenario is applied to demonstrate compliance with above-grade buildings.

Less Likely But Plausible Exposure Scenarios Excavation below 3 meters Contaminated drilling spoils brought to the ground surface (drilling through embedded piping in basement floors)

Offsite disposal/recycling of excavated basement concrete walls and Containment steel liner.

Chapter 6: Compliance with Radiological Criteria for License Termination 41 Below Grade Structures Groundwater Flow Clean Fill Lake Michigan Inhalation of Dust Particulates Inhalation of Dust Particulates External Exposure to Radiation External Exposure to Radiation Consumption of Beef, Milk and Fish Consumption of Beef, Milk and Fish Consumption of Vegetables/Fruits Consumption of Vegetables/Fruits 3 Clean Cover Consumption of Well Water Consumption of Well Water Soil Ingestion Soil Ingestion Well Negligible due to clean cover Groundwater Surface Drilling Spoils Pile Groundwater Flow Basement Fill Model X

Resident Farmer Compliance Scenario

Chapter 6: Compliance with Radiological Criteria for License Termination 42 Base Case DCGLs (DCGLW)

Radionuclide specific Below-grade basement surfaces (floor, walls, and penetrations)

Embedded piping Surface Soil (0.15 m)

Subsurface Soil (1.0 m)

Buried piping Screening Values in NUREG-1757, Vol. 2, Table H.1 will be used as DCGLs for above-grade buildings Area Factors will be applied to Soil and Basement Concrete surfaces Operational DCGLs To ensure the summation of dose from each source term is 25 mrem/year after ALL FSS is completed, Base Case DCGLs are reduced based on an expected, or a priori, fraction of the 25 mrem/year dose limit from each source term.

Used as the DCGL for survey design and investigations levels.

Existing groundwater Dose Conversion Factors (DCFs)

Basement Fill dose to source ratios (DSRs) *(if on-sight fill used)

  • Not planned at Kewaunee Power Station (KPS)

Chapter 6: Compliance with Radiological Criteria for License Termination 43 Compliance Dose Summation The final dose to demonstrate compliance is the summation of the average dose from each site media:

Soil (s),

Basement concrete (b,c),

Basement embedded pipe (b,ep),

Buried pipe (bp),

Above ground buildings (agb), and Existing groundwater (egw).

25 mrem/year

Chapter 7: Update of the Site-Specific Decommissioning Costs 44

  • Cost Assumptions Used, Including a Contingency Factor (normally 25%)
  • Cost Estimates Previously Docketed with the NRC
  • Cost Estimate Description and Methodology
  • Summary of the Site-Specific Decommissioning Cost Estimate
  • Radiological Decommissioning Costs Class A Large Components Class A Bulk Materials Class A Containerized Wastes Class B/C Waste
  • Spent Fuel Management Costs
  • Site Restoration Costs

Chapter 8: Supplement to the Environmental Report 45 Site Location and Description Remaining Dismantlement & Decommissioning Activities Impacts on the PSDAR KPS Environmental Description Environmental Effects of Decommissioning Radiological Effects of Decommissioning Non-radiological Effects of Decommissioning Overview of Regulatory Governing Decommissioning Activities and Site Release NRC EPA State & Local Conclusion Verify there are no new or significant environmental change associated with decommissioning

QUESTIONS?

46

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