cs-rs-rp-009-es, revision 1, 'phase ii final status survey ... · phase ii final status survey...

ENERGYSOLUTIONS CS-RS-RP-009-ES

Phase II Final Status Survey ReportMallinckrodt Columbium-Tantalum Plant

St. Louis, Missouri

Executive Summary

Project No. 137131 Revision 1

Prepared by:EnergySohttions, LLCCommercial Projects

1009 Commerce Park Drive, Suite 100Oak Ridge, TN 37830

Authored By:

Reviewed By:

Xchael A. Carr, CHP, Radiological

Engineer/Radiation Safety Officer

Mark Cambra, P.E., Project Manager

A J. Palmer, CHP, PMP, Director, HealthPhysics & Radiological Engineering

01--5- 2.d/5"Date

6-5-2015

Date

DateApproved By:

F-XNon-Proprietary

[DProprietary

DRestricted Information

D-Safeguards Information

D Sensitive Security Information

[]New

[l]itle Change

PRevisionD-RewriteD]Cancellation

Effective Date 6/5/2015

Phase II Final Status Survey Report Mallinckrodt CS-RS-RP-009-ESColumbium-Tantalum Plant, Executive Summary Revision 1

EXECUTIVE SUMMARY

Mallinckrodt LLC (Mallinckrodt) is a Delaware Corporation with its principal place of businesslocated at 675 McDonnell Boulevard, St. Louis, MO, 63042. Their former Columbium-Tantalum(C-T) Plant, located within the Mallinckrodt St. Louis Plant at 3600 North Second Street,St. Louis, Missouri, 63147, is currently licensed by the U.S. Nuclear Regulatory Commission(NRC) and is located near the west bank of the Mississippi River in the northeastern section ofthe City of St. Louis. This licensed facility is being decommissioned in order to terminate theirNRC License STB-401 per the license termination criteria contained in the NRC approvedColumbium-Tantalum (C-T) Phase II Decommissioning Plan (DP).

SITE HISTORY:

Between 1942 and 1958, Mallinckrodt refined uranium ore and concentrate to produce uraniumcompounds and metal in support of early Federal Government programs to develop atomicweapons under the Manhattan Engineering District (MED) and later the Atomic EnergyCommission (AEC). Areas of the St. Louis Plant and vicinity properties affected by MED-AECmaterial are currently being remediated under the U.S. Government Formerly Utilized SitesRemedial Action Program (FUSRAP) by the U.S. Army Corps of Engineers (ACE) and are notaddressed as part of this decommissioning and license termination effort.

From 1956 to 1960, Mallinckrodt extracted columbium, tantalum, uranium, thorium, and rareearth elements from euxenite mineral ore for delivery to the AEC and the General ServicesAdministration (GSA) as part of the Defense Materials Procurement Program. The Euxeniteoperation was performed under AEC source material license R-226 which expired in 1960.

From 1961 to 1989 Mallinckrodt extracted columbium and tantalum compounds under NRCLicense STB-401 from ores in the C-T processing buildings formerly located within the cityblock identified as Plant 5. The C-T feed materials included ore and tin slag; process productsincluded tantalum oxide, potassium fluotantalate, and columbium oxide. The same processingfacilities used under the AEC source material license R-226 were also subsequently used for C-Tprocessing.

APPROACH:

The goal of the decommissioning is to remediate the remaining radiological constituentsassociated with the C-T process to the extent required to terminate the NRC license, STB-401.The guidance as provided in US NRC NUREG-1757, Vol. 2, Section 2.5, notes that there is"flexibility in the general approach to demonstrating compliance with Title 10, Code of FederalRegulations (CFR), Part 20, Subpart E" for license termination. Two major approaches describedin the NRC guidance include 1) development of derived concentration guideline levels (DCGLs)and the performance of final status surveys and 2) dose modeling following characterization andremediation as necessary. The first approach in developing DCGLs and demonstratingcompliance through final status surveys is described in Chapters 5 and 14 of the C-T Phase IIDP; however, the NRC guidance adds that the two approaches are not mutually exclusive andthat both are acceptable to show that the residual dose is acceptable for license termination.

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Phase 1I Final Status Survey Report Mallinckrodt CS-RS-RP-009-ESColumbium-Tantalum Plant, Executive Summary Revision 1

During decommissioning, the facility was delineated into survey units for ease of remediationand final status survey. For most survey units, Mallinckrodt was able to demonstrate compliancewith the NRC-approved approach as described in Chapters 5 and 14 of the C-T Phase II DP;however, for a limited number of survey units, compliance could not be demonstrated throughthe application of the sum of fractions (SOF) using the DCGLs alone and dose assessments wereperformed. Performance of direct dose assessments for compliance demonstration following theguidance of NUREG-1757 is not included in the C-T Phase II DP and the use of this means ofcompliance demonstration represents an adjustment, or change, to the approved DP. Section 9.5of the C-T Phase II DP describes adjustments to the decommissioning process and provides a listof conditions that must be satisfied for a justified change related to the decommissioning processto be acceptable to the NRC without filing an application for amendment. All conditions ofSection 9.5 of the C-T Phase II DP (a through m) were either not applicable to this change orwere satisfied and approved by Mallinckrodt's and EnergySolutions' Project Managers andRadiation Safety Officers; however, based upon discussions with the NRC, a license amendmentwould be required. Subsequently, per the NRC's request, Mallinckrodt submitted a licenseamendment request to the NRC (ADAMs Accession Number ML15063A404; 2015-03-06)requesting a change to allow for the use of dose modeling as an available option to demonstratecompliance with the license termination criteria. This license amendment request is currentlyunder NRC review.

The application of the dose assessments was limited to situations where inaccessible residualcontamination exceeded an SOF of one. Residual contamination was considered inaccessible if itcould not be removed because remediation activities would negatively impact active plantbuildings, systems and/or operations (e.g., residual contamination under the vertical pipe standsin Plant 5).

SuMMARY FINDINGS:

Final status data evaluation and statistical analyses were performed and a separate decision madefor each survey unit of the C-T Plant as to its suitability for release for unrestricted use basedupon the release criterion as established in Chapter 5 of the C-T Phase II DP. Data was collectedand compared to the DCGLs and each survey unit assessed including an evaluation of anyremaining elevated areas. Survey units that failed the DCGL (i.e. SOF > 1) and elevated areaanalyses were further evaluated using dose assessments to demonstrate compliance with theresidual dose requirements for license termination. A summary of the final status results and theresidual dose(s) for the survey units from Plant 5 is provided as Table ES-1 and Table ES-2respectively.

In addition to the FSS sampling summarized in Table ES-i and Table ES-2, any residualsubsurface contamination as applicable was also evaluated across each survey unit. The verticalcolumn of soil averaged in 1 meter increments (i.e., 0-1, 0-2, 0-3 etc) was assessed using thesame screening tests as applied to evaluate the FSS data. No concerns were identified withresidual subsurface contamination.

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Phase II Final Status Survey Report Mallinckrodt CS-RS-RP-009-ESColumbium-Tantalum Plant, Executive Summary Revision 1

REQUESTS FOR ADDITIONAL INFORMATION:

The NRC completed the review of the Final Status Survey Report (FSSR) Chapters 1 through 33and issued a request for additional information (RAI) for clarification to address technicalconcerns that were identified with the FSSR (ML14175A305; 2014-09-03). These includedcomments on the use of the dose modeling approach and to ensure the modeling was performedconsistent with the approach taken for DCGL development (probabilistic modeling) as well asother specific FSSR Chapter comments. Following a public meeting held on October 9, 2014, arevised RAI was issued (ML14324A524; 2014-11-28). Mallinckrodt submitted their responses tothe RAIs in November of 2014 (ML14339A278; 2014-12-08). Subsequent to NRC review ofthese responses, an additional public meeting was held on May 7, 2015 (ML15112B138;2015-04-22) to discuss remaining issues with respect to the FSSR and RAI reponse submittals.Three additional information requests were made by the NRC including a request for additionalinformation on the remaining Plant 5 sewer systems, clarification on the dose modeling forsurvey unit 18 and an update to this Executive Summary to include the NRC correspondencefollowing the original submittal of the FSSR. Mallinckrodt has submitted their responses to theadditional items requested based on the May 7, 2015 meeting under separate submittal, includingthis revised Executive Summary.

A summary of the FSSR Chapters and the NRC RAI comments is provided in Table ES-03. TheFSSR Chapters as originally submitted to the NRC have not been revised in response to theseRAIs unless otherwise specified in Table ES-03. The Mallinckrodt responses to the NRC's RAIsas submitted in November of 2014 (ML14339A278; 2014-12-08) provide the requestedinformation and revised dose assessments as a supplement to the original submittals.

CONCLUSION

Based upon the FSS data as collected and evaluated within the Plant 5 area as summarized inTable ES-1, Table ES-2 and presented in this report and Mallinckrodt's subsequent responses toNRC's comments, it has been shown that the C-T licensed areas meet the requirements forunconditional release as outlined in the C-T Phase II DP. As a result, it is recommended that theMallinckrodt LLC NRC License STB-401 be terminated.

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Phase II Final Status Survey Report MallinckrodtColumbium-Tantalum Plant. Executive Summary

CS-RS-RP-009-ESRevision 1

Table ES-1 Survey Unit Summary - Compliance Matrix (Surface)

Data Set Analysis (Systematic Sample Set). Elevaited Area'AnalysisRClassS va Ihpe I TA l ,o semReleasableR-(1, 2: or 3) Min/Max Low Level' DCGL b WRS h Retrospective EMC Limit Index Dose•Anfalysis E CDCGLENIc- Assessmentc

Plant 5 Pavement 6 3 Pass Pass N/A N/A Pass -- N/A N/A N/A YESSU01 7 .1 Pass N/A N/A N/A Pass EA#1 Pass Pass N/A-(Pass) YESSU02 8 1 Pass N/A N/A N/A Pass EA#I Pass Pass N/A (Pass) YES

SU03 9: I Pass N/A N/A N/A Pass -- N/A NIA N/A YESSU04 10 1 Pass N/A N/A N/A Pass - N/A N/A N/A YESSU05 II I Fail N/A Pass Pass Pass EANI Pass Pass N/A (Pass) YESSU06 12 1 Pass N/A N/A N/A Pass EA1/2 Pass N/A (Pass)

SU07__3___Pass N/A__N/A___/A _ _ss__ -EA/A2 Fail PassS 707 13 1 Pass N/A N/A N/A Pass - N/A N/A N/A YES'SU09 14 1 , Pass N/A N/A N/A Pass - N/A N/A N/A YESSU09 15 ___1 Pass ' N/A N/A N/A Pass -- N/A N/A N/A YES~SUI0 16 1 Pass N/A N/A N/A Pass EA# I Pass Pass N/A (Pass) YES

EA#I Pass N/A (Pass)SUlI 17 1 Fail N/A Pass Pass Pass EA#2 Pass Fail Pass YES

EA#3 Fail PassEA91 Fail PassEA#2 Fail Pass

SUI2 19 I Fail N/A Pass Pass Pass Pass Fal Pass YESEA#4 Fail Pass

SU13 19 2 Pass N/A N/A N/A Pass - N/A N/A N/A YESSUI4 20 1 Pass N/A N/A N/A Pass - NIA N/A N/A YESSU15 21 1 Pass N/A 'N/A N/A Pass -- N/A N/A N/A YESSUI16 22 1 Pass N/A N/A N/A Pass -- N/A N/A N/A YES

SU17 ' 23 1 Pass N/A N/A N/A Pass -- N/A N/A N/A YES-

SUA 24 1 Na NA N/A PassYESSU 8 24i NA /A /A IA /AEA# Ib N/A _N/A PassYE

SU19 25 1 Fail N/A Pass Pass Pass EANI Pass Pass N/A (Pass) YESEA#/ Pass N/A (Pass)

SU20 26 1 Fail N/A Pass Pass Pass EA#2 Pass Fail Pass YESEA#3 Fail Pass

SU21 27 3 Pass Fail' N/A N/A Pass -- N/A N/A N/A YESEA#1 a Pass N/A (Pass)

SU22 28 1(3)f Pass N/A N/A N/A Pass EA#2 Pass Pass N/A (Pass) YES

EA#3 Fail Pass

Sewerage 29 3 Pass Pass N/A N/A Pass -- N/A N/A N/A YES30 (SUl) 2 Pass N/A N/A N/A Pass - N/A N/A N/A YES31 (SU2) 2 Pass N/A N/A N/A Pass - N/A N/A N/A YES32 (SU3) 2 Pass N/A N/A N/A Pass - N/A N/A N/A YES

33 (SU4) 2 Pass N/A N/A NIA Pass - N/A N/A N/A YESThe low level screening test was not applicable for Class I and 2 areas.The WRS test was not applicable if the Min/Max value was less than 1 (i.e., no systematic measurements exceed the DCGLw).Per the approved DP, a dose assessment was only required if either the EMC Limit test or the index value for any individual elevated area exceeded 1. However, at the request of the NRC, dose assessments were performed for all elevated areas.A specific FSS was not performed for SU18. SUJ18 was a small area that was segregated from SU21 based upon sample results. SU18 was evaluated using a dose assessment for compliance.The low level screening test failed for SU21 as several samples exceeded the investigation level for a Class 3 area. These areas were investigated further and no additional concerns were identified.SU22 was origionally classified as a Class 3 area Based upon sample results, this survey unit was reclassified as a Class 1.

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Phase II Final Status Survey Report MallinckrodtColumbium-Tantalum Plant, Executive Summary


Table ES-2 Survey Unit Summary - Residual Dose (Plant 5)

SurveySystematic Samples EMC Dose a Total Dose Area (2 Fractional FractionalSystematict Saplserea()(osm(r/r

SOFNet Dose (mr/yr) (mr/yr) (mr/yr) Area (% Dose (mr/yr)

SU01 0.02 0.50 3.23 3.73 353 1.56% 0.06SU02 0.04 1.00 0.87 1.87 161 0.71% 0.01SU03 0.06 1.50 N/A 1.50 252 1.11% 0.02SU04 0.05 1.25 N/A 1.25 102 0.45% 0.01SU05 0.09 2.25 4.84 7.09 480 2.12% 0.15SU06 0.10 2.50 2.12 4.62 393 1.73% 0.08SU07 0.04 1.00 N/A 1.00 577 2.54% 0.02SU08 0.02 0.50 N/A 0.50 101 0.45% 0.00SU09 0.01 0.25 N/A 0.25 269 1.19% 0.00SU10 0.08 2.00 1.23 3.23 743 3.27% 0.11SUl1 0.05 1.25 0.38 1.63 767 3.38% 0.05SU12 0.22 5.50 1.70 7.20 701 3.09% 0.22SU13 0.14 3.50 N/A 3.50 2,170 9.56% 0.33SU14 0.10 2.50 N/A 2.50 227 1.00% 0.03SU15 0.05 1.25 N/A 1.25 338 1.49% 0.02SU16 0.01 0.25 N/A 0.25 156 0.69% 0.00SU17 0.03 0.75 N/A 0.75 305 1.34% 0.01SU18 - -- 6.23 6.23 248 1.09% 0.07SU19 0.11 2.75 0.00 2.75 303 1.34% 0.04SU20 0.03 0.75 0.40 1.15 294 1.30% 0.01SU21 0.04 1.00 N/A 1.00 11,131 49.05% 0.49SU22 0.08 2.00 19.79 21.79 2,622 11.55% 2.52Total N/A N/A N/A N/A 22,693 100 % 4.25

Average 0.06 1.56 N/A 3.41 N/A N/A N/AThe EMC dose as presented was calculated by dose assessment for each elevated area which failed the EMC index test as specified in Table ES-1.

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Table ES-3 Request for Additional Information Cross Reference Table

FSSR FSSR NRC RAI Comment SummarySection Chapter (ML14175A305 / ML14324A524) a Resolution Chapter Revision

Executive ES May 7, 2015 Conference Call; Executive Summary updated to include a text Revised- Rev 1Summary (ML15112B138) summary and this RAI cross-reference table 2015-06-05

Update Executive Summary pursuant regarding the NRC request(s) for additional

to RAI response and the May 7, 2015 information. Tables ES-i and ES-2 updatedwith revised data based on the RAI

Conference Call responses.

Introduction Chapter 1 Specific Comment #1; (ML14175A305) Clarification provided on licensing history. No - See Mallinckrodt's* Clarification required on licensing RAI Response for specifics

history. (ML14339A278) b

FSS Design Chapter 4 Specific Comment #2; (ML14175A305) Clarification provided on how Investigation No - See Mallinckrodt's* Clarification required on the definition Levels and Action Levels were defined and RAI Response for specifics

used for the purpose of the Final Status (ML14339A278) bof Investigation vs Action Levels. SresSurveys.

Specific Comment #3; (ML14175A305) Bulk materials were defined as it applied to

* What is meant by bulk materials and the FSS and the release criteria specified as

what release criteria applied? applicable.

Specific Comment #5 & 6; (ML14175A305) Sample preparation process re-iterated. Plus* Was plus sized material sieved from size material processed with the sample and

samples prior to analysis and did it not removed in the field. Plus size materialssampedelease p rioert lisan also analyzed as part of the sample spoilsexceed release criteria, analysis to verify activity was not discarded.

Specific Comment #25; (ML14175A305) Off-site lab selection justified.

* How was the off-site laboratoryselected?

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Data Quality Chapter 5 Specific Comment #7; (ML14175A305) Calibration procedures were in accordance No - See Mallinckrodt'sAssessment * Include detector efficiencies and with ANSI N323A-D. Survey documentation RAI Response for specifics

discussion of calibration procedures also incorporated the ISO-7503 standards as (ML14339A278) b

for project instrumentation. applicable.

Specific Comment #8; (ML 14175A305) Survey instrument MDCs demonstrated to be

• Demonstrate that MDCs were below below 50% of the applicable DCGLs.

50% of the DCGLs.

Specific Comment #9; (ML14175A305) FSS samples demonstrated to be

* Confirm FSS samples as presented in representative of the as left final conditions.

the FSSR are representative of the finalcondition.

Plant 5 Chapter 6 Specific Comment #10; (ML14175A305) It was recognized that the surface activity No - Data table wasPavement * Surface activity potentially may be underreported due to the use of large properly footnoted.

areas detectors. Applicable table wasunderestimated by using large area footnoted with the corrected data rangesdetectors. assuming 100 Cm

2.

SU-01 Chapter 7 General Comment #1; (ML14324A524) Survey unit demonstrated to meet the No - See Mallinckrodt's

* Demonstrate all areas of residual 1OCFR20.1402 release criteria via RESRAD RAI Response for specifics

contamination below structures meet dose modeling (including all areas of residual (ML14339A278) b

10CFR20.1402 criteria contamination). Dose modeling summariesprovided.

General Comment #2a; (ML14324A524) All dose models were re-performed using

* Re-perform dose modeling using probabilistic modeling consistent with the

consistent with DCGL development. Dose modelingprobabils pmodeing. summaries provided.DCGL development.

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FSSR FSSR NRC RAI Comment SummarySection Chapter (ML14175A305 / ML14324A524)a Resolution Chapter Revision

SU-01 (Cont.) Chapter 7 General Comment #2e; (MNL14324A524) Justification provided for time spent as part No - See Mallinckrodt's

* Justification required for time spent in of the trenching scenario using the RSMeans RAI Response for specifics

trenches as part of the trenching construction estimating manual. (ML14339A278) b

scenario.

Specific Comment #11; (NvL14175A305) In general, the on-site lab did report

* NRC contests that the on-site lab did conservative results; however, it was noted

not report conservative results for Th- that all FSS samples were sent to the off-site

232. laboratory for analysis.

Specific Comment #12; (M1L14175A305) Method of performing GWS surveys, survey

* Sample results do not seem to match mapping and sampling was specified

up with GWS data results including inherent errors and how the data isinterpreted.

Specific Comment #13; (ML14175A305) Typographical error corrected and the Revised - Rev 1;

* Typographical error in elevated area calculation corrected accordingly. 2014-11-07

calculation (ML 14339A279)

SU-02 Chapter 8 General Comment #1; (ML14324A524) Survey unit demonstrated to meet the No - See Mallinckrodt's* Demonstrate all areas of residual 1OCFR20.1402 release criteria via RESRAD RAI Response for specifics


contamination). Dose modeling summaries1OCFR20.1402 criteria provided.

General Comment #2a; (ML14324A524) All dose models were re-performed using• Re-perform dose modeling using probabilistic modeling consistent with the

probabilistic modeling consistent with DCGL development. Dose modelingsummaries provided.DCGL development.

General Comment #2e; (ML14324A524) Justification provided for time spent as part

• Justification required for time spent in of the trenching scenario using the RSMeans

trenches as part of the trenching construction estimating manual.

scenario.

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SU-03 Chapter 9 None N/A N/A


SU-05 Chapter 11 General Comment #1; (ML14324A524) Survey unit demonstrated to meet the No - See Mallinckrodt's

* Demonstrate all areas of residual 1OCFR20.1402 release criteria via RESRAD RAI Response for specifics

contamination below structures meet dose modeling (including all areas of residual (ML14339A278) bI10CFR20.1402 criteria contamination). Dose modeling summaries

provided.

General Comment #2a; (ML14324A524) All dose models were re-performed using

* Re-perform dose modeling using probabilistic modeling consistent with theDCGL development. Dose modeling

probabilistic modeling consistent with summarevided.DCGLdevlopmnt.summaries provided.

DCGL development.

General Comment #2e; (ML 14324A524) Justification provided for time spent as part* Justification required for time spent in of the trenching scenario using the RSMeans


scenario.

SU-06 Chapter 12 General Comment #1; (ML14324A524) Survey unit demonstrated to meet the No - See Mallinckrodt's• Demonstrate all areas of residual 10CFR20.1402 release criteria via RESRAD RAI Response for specifics


I10CFR20.1402 criteria contamination). Dose modeling summariesprovided.

General Comment #2a; (ML 14324A524) All dose models were re-performed using* Re-perform dose modeling using probabilistic modeling consistent with the

wih DCGL development. Dose modelingprobabilistic m odeling consistent w ith sum marie v ide d.

DCGLsummaries provided.DCGL eveloment

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FSSR FSSR NRC RAI Comment Summary RSection Chapter (ML14175A305 / ML14324A524)a Resolution Chapter Revision

SU-06 (Cont.) Chapter 12 General Comment #2e & Specific Comment 15; Justification provided for time spent as part No - See Mallinckrodt's(ML14324A524) of the trenching scenario using the RSMeans RAI Response for specifics

* Justification required for time spent in construction estimating manual. (ML14339A278) b

trenches as part of the trenchingscenario.

Specific Comment 14; (ML14175A305) Typographical error corrected and the Revised - Rev 1;

* Typographical error in elevated area calculation corrected accordingly. 2014-11-07

calculation (MIL14339A279)




SU-10 Chapter 16 General Comment #1; (ML14324A524) Survey unit demonstrated to meet the No - See Mallinckrodt's0 Demonstrate all areas of residual 1OCFR20.1402 release criteria via RESRAD RAI Response for specifics

contamination below structures meet dose modeling (including all areas of residual (ML14339A278) bI10CFR20.1402 criteria contamination). Dose modeling summaries

provided.

General Comment #2a; (ML14324A524) All dose models were re-performed using* Re-perform dose modeling using probabilistic modeling consistent with the

probabilistic modeling consistent with DCGL development. Dose modeling

DCGL development. summaries provided.


* Justification required for time spent in of the trenching scenario using the RSMeans


scenario.

Specific Comment # 16; (ML 14175A305) Justification provided.* 100% survey not performed due to

standing water.

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FSSR FSSR NRC RAI Comment Summary RSection Chapter (ML14175A305 / ML14324A524)a Resolution Chapter Revision

SU-1 1 Chapter 17 General Comment #2a; (ML14324A524) All dose models were re-performed using No - See Mallinckrodt's

Re-perform dose modeling using probabilistic modeling consistent with the RAI Response for specifics

probabilistic modeling consistent with DCGL development. Dose modeling (ML14339A278) b

summaries provided.DCGL development.




scenario.

Specific Comment #17; (ML14175A305) Area remediated. Representative samples

* FSS sample 0624 not sent off-site. 1252 and 1254 taken in immediate area ofsample 0624 and were sent for off-siteanalysis.

SU-12 Chapter 18 General Comment #2a; (ML14324A524) All dose models were re-performed using No - See Mallinckrodt's

* Re-perform dose modeling using probabilistic modeling consistent with the RAI Response for specifics


probabils pmodeing. summaries provided.DCGL development.

General Comment #2e; (ML14324A524) Justification provided for time spent as part* Justification required for time spent in of the trenching scenario using the RSMeans


scenario.

Specific Comment #18; (ML14175A305) Header was corrected. Revised - Rev 1; See new

* Typographical error in the Header NRC Submittal2014-06-05

Specific Comment #19; (ML14175A305) Figure replaced. Revised - Rev 1;

* Recommended to replace hand drawn 2014-11-07

figure with computer generated figure. (ML14339A279)

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SU-18 Chapter 24 General Comment #2e; (ML14324A524) Justification provided for time spent as part No - See Mallinckrodt's



scenario.

May 7, 2015 Conference Call; Oversight as part of the initial RAI response. No - See new NRC(ML15112B1138) The SU-18 dose models have been re- submittal

* Were the SU-18 dose models re- performed using probabilistic modeling 2015-06-05performed using the probabilistic consistent with the DCGL development.

Dose modeling summaries provided with themodeling consistent with the DCGL new NRC submittal.development?

SU-19 Chapter 25 General Comment #2a; (ML14324A524) All dose models were re-performed using No - See Mallinckrodt's* Re-perform dose modeling using probabilistic modeling consistent with the RAI Response for specifics

probabilistic modeling consistent with DCGL development. Dose modeling (ML14339A278) bprobab vltcmotent. w summaries provided.DCGL development.

General Comment #2e; (M1L14324A524) Justification provided for time spent as part



scenario.

Specific Comment #20; (ML14175A305) In depth discussion and justification

* Address readings 5 to 7 time provided.

background

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Phase I Final Status Survey Report MallinckrodtColumbium-Tantalum Plant, Executive Summary



SU-20 Chapter 26 General Comment #2a; (ML14324A524) All dose models were re-performed using No - See Mallinckrodt's* Re-perform dose modeling using probabilistic modeling consistent with the RAI Response for specifics

probabilistic modeling consistent with DCGL development. Dose modeling (NML14339A278) b

summaries provided.DCGL development.

General Comment #2e; (ML14324A524) Justification provided for time spent as part* Justification required for time spent in of the trenching scenario using the RSMeans


scenario.


SU-22 Chapter 28 General Comment #2a; (ML14324A524) All dose models were re-performed using No - See Mallinckrodt's

* Re-perform dose modeling using probabilistic modeling consistent with the RAI Response for specifics


DCGL development. summaries provided.

General Comment #1 & 2b; (ML14324A524) Survey unit demonstrated to meet the* SU-22 dose assessment does not 10CFR20.1402 release criteria via RESRAD

include dose contributions from all dose modeling (including all areas of residualcontamination). Dose modeling summaries

areas of residual contamination. provided.

General Comment #2c; (ML14324A524) Areas of residual contamination in SU-22 re-* Justification required for bounding the defined, bounded and justified.

areas of residual contamination in SU-22.

General Comment #2d; (ML14324A524) Justification provided for radionuclide

* Justification required for radionuclide concentrations used in dose modeling for

concentrations for areas of residual areas of residual contamination

contamination

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SU-22 (Cont.) Chapter 28 General Comment #2e; (ML14324A524) Justification provided for time spent as part No - See Mallinckrodt's



scenario.

General Comment #3; (NML14175A305) Justification provided for not performing the

* Justification required for not GWS survey inside the buildings. Systematic

performing GWS scans inside and Random samples collected under thebuilding foundation throughout Buildings

Buildings 240 and 250. 240 and 250.

Sewers Chapter 29 Specific Comment #4; (ML14175A305) Remaining sewer lines are active; however No - See Mallinckrodt's

* Scans and direct measurements not they were visually inspected and sediment RAI Response for specifics

performed in the sewer, samples collected as summarized in Table (ML14339A278) b

29-1.

Specific Comment #21; (ML14175A305) Justification provided for the Class 3

* NRC contests that the sewer line classification based on column averaging in

survey units should have been accordance with the approved DP.Additionally, if considered Class 2, there

classified as a Class 2 survey unit and would be no change.not Class 3.

May 7, 2015 Conference Call; Additional information provided with the No - See new NRC

(ML15112B 138) new NRC submittal. submittal

* Request for additional information for 2015-06-05the remaining sewerage system

including potential future use, depthand current use.

Plant 7 Chapters 30- General Comment #4; (ML14175A305) A delineation agreement was established with N/A33 US Army Corp of Engineer delineation USACE in October of 2014 and forwarded to

dfor Plant 7 ad the NRC on February 2, 2015agreemeint reqree. (ML15041A076).surrounding areas.

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General All Specific Comment #22; (ML 4175A305) Term defined. No- See Mallinckrodt's* What is meant by "at depth sampling" RAI Response for specifics

(ML14339A278) b

Specific Comment #23; (ML14175A305) Detailed explanation provided and was

* Why were the on-site laboratory primarily a result of how the Ra-226 was

sample sum-of-fractions about 45% quantified. Additionally, it was noted the on-site lab was a screening tool only to helphigher than the off-site sample results giermdainadteofst aguide remediation and the off-site lab

analyses used to support the FSS.

Specific Comment #24; (ML14175A305) We concur that Equation 8-2 is more(Gen Comment #2a) applicable. Dose modeling was re-performed

* Why is equation 14-7 in the Phase II for all areas of residual contamination for allsurvey units as applicable (SU-01, SU-02,DP (EMC limit screening test) more SU-05, SU-06, SU-10, SU-11, SU-19, SU-20

applicable than Equation 8-2 of and SU-220MARSSIMand SU-22)

MARS SIM?

Specific Comment #26; (MIvL14175A305) An example spreadsheet with calculations

• Provide an example of the spreadsheet was provided for SU-10.

calculations in lieu of the use ofscreening software as required in theC-T Phase II DP.

ab

ML14175A305 dated 2014-09-03 (Original RAI Request); ML14324A524 dated 2014-11-28 (Revised RAI Request)ML14339A278 dated 2014-12-08 is a grouping of NRC Accession Numbers ML14339A276, ML14339A277 and ML14339A279 (NRC RAI responses)

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Attachment 6

Final Status Survey Report

Chapter 18 (rev 1)

cs-rs-rp-009-es, revision 1, 'phase ii final status survey ... · phase ii final status survey...

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