**NRC INSPECTION MANUAL** DWMEP/DCD

INSPECTION PROCEDURE 83801

INSPECTION OF REMEDIAL AND FINAL SURVEYS AT

PERMANENTLY SHUTDOWN REACTORS

PROGRAM APPLICABILITY: 2561

83801-01 INSPECTION OBJECTIVES

01.01 To verify that permanently shutdown power reactor sites have been
decontaminated to acceptable residual radioactivity levels in accordance
with the License Termination Plan (LTP) requirements for unrestricted or
restricted use.

01.02 To verify that the radiological measurements, surveys and
documentation of remedial action support surveys (RASS) and final status
surveys (FSSs) are conducted in accordance with the licensee=s LTP and
implementation procedures.

01.03 To verify that the licensee\'s implementation or completion of
remediation surveys have been adequately performed and the survey units
have been prepared and are acceptable for the performance of FSSs.

01.04 To verify that the licensee\'s implementation of the FSS program
and to confirm the acceptability of the FSS results. See Appendix A,
\"Final Status Survey Program Inspection Checklist.\"

83801-02 DEFINITIONS

02.01 [Remedial Action Support Surveys]{.underline}

Remedial action support surveys are defined as those surveys that are
performed by the licensee after soil remediation activities or structure
dismantling and decontamination activities have been completed. RASS=s
are performed to support remediation activities, as a pre-requisite to
verify the area has been properly decontaminated and prepared for the
FSS to be implemented and to provide data for planning the FSS. RASS=s
typically include verification that there is no significant
contamination at depth either in soil or in structures, cracks, crevices
and floor-wall interfaces, and that there is no significant loose
surface contamination on structures.

02.02 [Final Status Surveys]{.underline}

Final Status Surveys are measurements and sampling performed by the
licensee following the completion of decontamination activities in
preparation for release. The FSS is conducted to demonstrate that the
residual radioactivity levels are less than the derived concentration
guideline levels (DCGLs) in the approved LTP.

02.03 [In-Process Surveys]{.underline}

NRC=s in-process surveys and sampling may be conducted simultaneously
with the licensee=s activities. The in-process surveys may be conducted
either during or prior to completing remediation activities to assess
the licensee=s progress in preparing for FSSs, or may be conducted
during the licensee=s performance of FSSs to verify that the licensee is
performing radiological measurements and obtaining results consistent
with the FSS design and procedures and the LTP. The inspectors should
collect side-by-side, split samples or arrange for Around robin@
sampling, with the licensee for comparative purposes, and should compare
in-field instrument readings and sensitivity. In the Around robin@
sampling approach, the samples are collected in the presence of the
inspector, counted by the licensee, and the inspector sends the samples
to the NRC contracted laboratory for analysis. To validate laboratory
capability, the inspector may count samples previously collected and
analyzed by the licensee.

NOTE: NRC lessons learned and experience have shown that the in-process
approach has resulted in significant savings in cost, assured a more
accurate FSS, and had less of an impact on the licensee in maintaining
the survey unit accessibility for NRC inspectors.

02.04 [Confirmatory Surveys]{.underline}

Confirmatory Surveys are performed after the licensee has completed
their FSS measurements. Confirmatory surveys are performed to validate
the licensee=s survey program and to provide assurance that the survey
unit meets residual radioactivity levels for release.

83801-03 INSPECTION PLANNING AND CONDUCT

03.01 [Inspection Survey Preparation]{.underline}

a.  The inspectors should review licensee records for the types of
    radioactive materials used, occurrence of any significant safety
    issues, and any special concerns about the site expressed by the
    Project Manager(PM), NRC staff or other stakeholders.

b.  The inspectors should review the licensee=s LTP to determine the
    scope of facility contamination and the licensee\'s decontamination,
    remediation survey, and FSS programs. If the licensee does not have
    an approved LTP, the inspectors should review the licensee\'s
    procedures for performing these tasks.

> NOTE: Without an approved LTP that establishes the permissible
> residual radioactivity levels, the licensee is at risk for performing
> remediation and FSSs activities.

c.  The inspectors, in conjunction with the PM and headquarters health
    physicist, should consider the following when planning inspection
    surveys. In areas where in-process surveys were not conducted, or
    samples were not collected, confirmatory surveys and sampling may be
    performed after the licensee has completed decontamination
    activities and performed the FSS. Sites where in-process surveys and
    sampling have not identified significant weaknesses in the FSS
    program may not require confirmatory surveys and sampling. However,
    confirmatory surveys may be deemed necessary for sites where
    unresolved radiological program weaknesses were previously
    identified or where violations were identified. Confirmatory surveys
    should be considered where there is historical information of spills
    or unusual occurrences involving the spread of contamination at the
    site. The goal is to conduct sufficient confirmatory surveys and to
    collect an adequate number of samples so that the inspector and
    staff can conclude that the licensee=s decommissioning activities
    and survey program has been implemented in a manner that provides
    confidence in the results.

03.02 [Inspection Effort]{.underline}

Based on the characterization data and other information provided by the
licensee during the course of the decommissioning, the PM, the
headquarters health physicist and the Regional Inspectors should
determine in advance the level of effort to be employed to collect
sufficient data and information that will allow the staff to ascertain
that the licensee has met residual radioactivity requirements. Table A
below provides recommendations for focusing the inspection effort for
various phases of the decommissioning.

Table A - Recommended Inspection Focus

+-----------------+---------------+---------------+-------------------+
| Licensee        | NUREG 1757    | Inspection    | Inspection        |
| Activity        |               | Purpose       | Process           |
|                 | Guidance      |               |                   |
+-----------------+---------------+---------------+-------------------+
| Dismantling and | Section 4.2 - | Ensure health | NRC Inspection    |
| Decontamination |               | and safety of | Manual Chapter    |
| Remediation     | Validate data | remediation   | 2561,             |
| Activities      | consistency   | workers and   | ADecommissioning  |
|                 | with          | public        | Power Reactor     |
|                 | licensee\'s   |               | Inspection        |
|                 | cha           |               | Program@ and NRC  |
|                 | racterization |               | Inspection        |
|                 |               |               | Procedure 83750,  |
|                 | surveys       |               | APlant Support@   |
+-----------------+---------------+---------------+-------------------+
| Remedial Action | Section 4.3 - | Ensure areas  | Observation of    |
| Support Surveys |               | are prepared  | Licensee surveys  |
|                 | Verify area   | for FSS       | and survey        |
|                 | is prepared   |               | records for       |
|                 | for FSS and   |               | compliance with   |
|                 | validate the  |               | LTP survey        |
|                 | FSS design    |               | requirements      |
+-----------------+---------------+---------------+-------------------+
| FSS in-progress | Section 4.4 - | Ensure        | Observation and   |
|                 |               | LTP-FSS       | inspection of     |
|                 | Validate FSS  | compliance    | licensee surveys  |
|                 | design and    |               | and performance   |
|                 | performance   |               | of NRC In-process |
|                 |               |               | Surveys           |
+-----------------+---------------+---------------+-------------------+
| FSS completed   | Section 4.4 - | Verify        | Performance of    |
|                 |               | compliance    | NRC Confirmatory  |
|                 | Verify FSS    | with LTP -    | Surveys and       |
|                 | residual      | FSS           | review of         |
|                 | radioactivity | requirements  | licensee survey   |
|                 | levels        |               | records           |
+-----------------+---------------+---------------+-------------------+
| FSS Reports     | Section 4.5 - | Verify        | Review of         |
|                 |               | compliance    | licensee survey   |
|                 | Verify FSS    | with LTP-FSS  | records, and NRC  |
|                 | report        | Reporting     | In-process or     |
|                 | requirements  |               | Confirmatory      |
|                 |               |               | Surveys for       |
|                 |               |               | agreement with    |
|                 |               |               | licensee          |
|                 |               |               | conclusions       |
+-----------------+---------------+---------------+-------------------+

a.  Inspections of facilities where the NRC in-process surveys have not
    identified significant weakness in the facility=s radiation
    protection program implementation or deficiencies in the FSS program
    and FSS report, may not require additional in-process or
    confirmatory surveys.

b.  Facilities that have experienced the following may require extensive
    in-process or confirmatory surveys to be performed:

    1.  Significant unresolved weaknesses that are identified during the
        inspection of the licensee=s survey program.

    2.  Repetitive radiation protection violations.

    3.  Partial site releases that include impacted areas.

    4.  Records of spills or unusual occurrences involving the spread of
        contamination during decommissioning activities at the site.

03.03 [Inspection Plan]{.underline}

The inspector should develop an inspection plan outlining the types of
measurements, the samples to be taken, the survey units to be surveyed,
and the documents to be reviewed. The inspection plan should include a
survey plan that is consistent with the licensee=s approved DCGLs,
survey unit classification and media sampling and survey methods.
Inspections should be biased toward the conduct of surveys and the
review of documents from Class 1 rather than Class 2 or 3 survey areas.
The inspectors should also ensure that survey units have been properly
classified or re-classified as a result of decommissioning activities.

03.04 [Inspection of Remediation Activities and Transition to
FSSs]{.underline}

Inspection of remediation activities should include reviews of
procedures for sample chain-of-custody, access control to future FSS
areas, survey data collection and data management, quality control
surveys, and records retention and management. Instrumentation
calibration and survey methods should be evaluated to ensure
measurements are meeting the required percentage of the area to be
surveyed, instrument scan sensitivity, and direct survey or sampling
requirements for the survey unit classification. Inspection activities
should evaluate the licensee=s RASS completion and that the prerequisite
activities required for FSSs have been performed. In performing this
evaluation, the inspector should review the procedures and performance
of RASSs as follows:

a.  Review the radiation technician/surveyors training and qualification
    records to ensure compliance with technical specifications and the
    LTP.

b.  Review the method for determining the background radioactivity level
    for the survey is consistent with the LTP.

c.  For remnant structures, review the procedures for performing surveys
    that determine contamination-at-depth in cracks, crevices and floor
    wall interfaces. Review the licensee=s surveys or samples taken to
    verify that remnant structures were remediated to the appropriate
    depth.

d.  For remnant structures, review the surveys that determine the loose
    surface contamination is less than 10% of the total residual
    radioactivity.

e.  For soil areas, review the surveys that demonstrate that the areas
    were remediated to the appropriate depth.

f.  If automated measurement systems are employed, a review of the
    licensee=s technical bases documents, including calculations,
    validation tests, and software verification must be performed. These
    systems may include portable In-situ gamma spectroscopy systems,
    conveyor based monitors, and bulk monitors.

g.  Ensure access control measures were followed for areas where FSSs
    have been completed and re-survey protocols are addressed.

03.05 [Conduct of In-Process Surveys]{.underline}

The \"In-Process\" final survey inspection is to provide confidence that
the licensee\'s survey results are accurate and representative of the
conditions at the facility. Inspectors should review any license
conditions related to the prerequisite activities for performing the
RASS and FSS in the LTP. Review the licensee=s final status survey
design packages, and/or survey reports, as applicable. See Appendix A,
\"Final Status Survey Program Inspection Checklist.\"

03.06 [Conduct of Confirmatory Surveys]{.underline}

Inspection activities for completed FSSs may include the collection of
confirmatory samples or measurements to provide confidence that the
licensee=s FSS program is adequate. These surveys may be in addition to
the findings of the in-process inspection. The confirmatory surveys are
performed to ensure that the survey results reported by the licensee are
accurate and representative of the conditions at the facility.

03.07 [Review of FSS Records]{.underline}

The review of FSS Records shall include the following: review of FSS
records packages for completeness, licensee review and approvals,
training and qualification records for survey technicians and instrument
calibration records. For a detailed discussion of FSS inspection areas,
see Appendix A.

03.08 [Inspection Report]{.underline}

a.  The inspectors will prepare an inspection report that summarizes the
    actions taken under this inspection procedure and the findings and
    evaluations of the inspection staff. Issue the inspection report to
    the licensee and distribute a copy of the Inspection Report to the
    appropriate licensing staff. The report should include or reference
    NRC contractor reports documenting in-process or confirmatory
    surveys performed during the inspection period.

b.  The Inspection Reports are part of the basis for the staff=s finding
    that the licensee has met the release criteria. The licensee=s FSS
    reports are the licensee=s demonstration of the residual
    radioactivity levels remaining in each survey unit meet the DCGLs in
    the LTP. Inspection reports include the NRC in-process and
    confirmatory survey results, document the licensee=s FSS results and
    are used as part of the basis for license termination.

03.09 [Inspection Resources]{.underline}

The direct onsite inspection hours required to complete this inspection
depend on the

complexity of the facility and the duration of the licensee\'s
remediation and final survey program. For facilities needing a
significant final survey effort, approximately 10 to 40 inspection hours
will be needed to complete the inspection of each soil or building
survey unit.

END

**APPENDIX A**

**FINAL STATUS SURVEY PROGRAM INSPECTION CHECKLIST**

I.  CONSIDERATION FOR DESIGNING FINAL STATUS SURVEY INSPECTIONS

    A.  Inspections should be made against commitments in the LTP and
        the licensee\'s FSS plan. If items for further or future review
        were identified in the Safety Evaluation Report that supported
        the LTP approval, the inspectors should also verify that these
        items are addressed.

    B.  Inspection of a licensee\'s FSS program may include independent
        in-process or confirmatory measurements by the inspector or NRC
        contractor. The extent of the confirmatory measurements, and
        whether the use of an NRC contractor is warranted, depends on a
        number of factors discussed in Section III below.

    C.  For each inspection, the inspector should identify which
        inspection areas and activities listed below are covered.

II. INSPECTION ITEMS DURING FSS

    A.  Review the Organization and Responsibilities for
        adequacy/completeness:

        1.  Survey program documentation

        2.  Responsibilities and qualifications of the survey staff.

        3.  Relevant License Termination Plan, design and procedure
            changes in accordance with 10 CFR 50.59 or 72.48.

    B.  Review the Quality Assurance/Quality Control (QA/QC) Programs
        for adequacy/completeness:

        1.  Organizational structure

        2.  QC Surveillance Program

        3.  Document Control/Records Management Program

        4.  Equipment Maintenance and Control Program

        5.  Audits and Corrective Action Program

    C.  Determine if the laboratory analytical procedures, sample
        chain-of-custody procedures, data management, (including QA/QC)
        are acceptable, and if the results are adequately documented.

    D.  Determine if the licensee=s survey implementation procedures are
        consistent with the LTP and FSS Plan.

    E.  Determine if the field and laboratory instrumentation are
        adequate and appropriate for scanning, direct measurements, and
        analysis for the radionuclides of concern (ROCs), the DCGL and
        DCGL- Elevated Measurement Comparison (DCGL~EMC~).

    F.  Determine if the calibration accounts for the ROCs.

    G.  Review ROCs, area classification, survey unit size, estimated
        mean and standard deviation for samples.

    H.  Review the methods used to address the impact of multiple ROCs
        in FSS planning.

    I.  Review instrument use procedures:

        1.  Minimum Detectable Concentration (MDC) and scan MDC
            calculations

        2.  Actual vs. required scan sensitivity; and

        3.  Calibration, including accounting for multiple radionuclides
            and any environmental factors that may influence instrument
            performance, such as temperature limitations or moisture
            concerns.

    J.  Review project documentation for completeness, accuracy, and
        represents current radiological conditions relative to the
        DCGLs.

III. NRC IN-PROCESS AND CONFIRMATORY SURVEYS

     A.  The PM and inspector should determine if an in-process or
         confirmatory survey is to be performed. Extensive in-process or
         confirmatory surveys should be considered if any of the
         following exist:

         1.  Significant, unresolved, weaknesses identified during the
             inspection of the licensee\'s final status survey program.

         2.  Repetitive radiation protection violations.

         3.  Partial site release of impacted areas.

         4.  Records of spills or unusual occurrences involving the
             spread of contamination during decommissioning activities
             at the site.

     B.  If an in-process or confirmatory survey is to be performed,
         determine if an NRC Contractor should be used. Meeting any of
         the criteria listed below will, in general, justify the use of
         a contractor.

         1.  Licensee\'s FSS involves unique or complex technical
             issues.

         2.  Confirmatory survey is expected to require more than a
             person-week effort to complete field surveys and sampling.

         3.  Confirmatory survey is very high priority project that
             cannot be completed by NRC staff in a timely manner.

     C.  Evaluate each anomaly identified during in-process, or
         confirmatory surveys, for compliance with LTP Survey Plan
         requirements, the DCGL and DCGL~EMC~.

         1.  Is it acceptable relative to size and concentration?

         2.  Has the licensee adequately addressed it?

         3.  Is it within the bounds of survey unit classification?

     D.  Select survey units/areas for Confirmation:

         1.  Determine scan coverage based on classification.

         2.  Review analytical procedures for appropriateness for
             measuring the ROCs, the DCGL and DCGL~EMC~.

         3.  Cross-check FSS data packages against plan requirements.

     E.  For soil sampling, determine sampling depth requirements and
         sampling intervals. At a minimum, samples should be collected
         from anomalous or other judgmental areas, together with
         selected licensee-archived samples, for confirmatory analysis.
         The necessity for, and the specific numbers of, other
         random/systematic samples should be separately evaluated, using
         the Data Quality Objectives (DQO) process.

     F.  For structure surfaces, perform direct measurement surveys or
         sampling to determine contamination-at-depth in cracks,
         crevices and floor/wall interfaces.

END

ATTACHMENT 1

Revision History: IP 83801

AINSPECTION OF REMEDIAL AND FINAL SURVEYS AT

PERMANENTLY SHUTDOWN REACTORS@

+--------+-------+--------------------------+-----+---------+----------+
| Comm   | Issue | Description of Change    | Tr  | T       | Comment  |
| itment | Date  |                          | ain | raining | Re       |
| Tr     |       |                          | ing | Com     | solution |
| acking |       |                          | Nee | pletion | A        |
| Number |       |                          | ded | Date    | ccession |
|        |       |                          |     |         | Number   |
+--------+-------+--------------------------+-----+---------+----------+
| N/A    | 08/   | [IP 83801]{.underline}   | No  | N/A     | No       |
|        | 11/97 | (Inspection of Final     |     |         |          |
|        |       | Surveys at Permanently   |     |         |          |
|        |       | Shutdown Reactors) has   |     |         |          |
|        |       | been revised to be       |     |         |          |
|        |       | consistent with the dose |     |         |          |
|        |       | base criteria used un    |     |         |          |
|        |       | the licensee termination |     |         |          |
|        |       | rule and MARSSIM         |     |         |          |
|        |       | guidance. The pervious   |     |         |          |
|        |       | guidance was NUREG-5849  |     |         |          |
|        |       | which was based on       |     |         |          |
|        |       | concentration limits.    |     |         |          |
|        |       | Therefore, in order to   |     |         |          |
|        |       | comply with 10 CFR 20    |     |         |          |
|        |       | subpart E, the licensee  |     |         |          |
|        |       | needs to do a dose       |     |         |          |
|        |       | analysis and follow      |     |         |          |
|        |       | MARSSIM guidance and the |     |         |          |
|        |       | procedure has made the   |     |         |          |
|        |       | appropriate changes.     |     |         |          |
+--------+-------+--------------------------+-----+---------+----------+
| N/A    | 01/   | Incorporated MARSSIM     | No  | N/A     | No       |
|        | 28/02 | guidance                 |     |         |          |
+--------+-------+--------------------------+-----+---------+----------+
| N/A    | 09/   | Major revision           | No. | N/A     | ML0      |
|        | 05/06 | incorporating lessons    |     |         | 61090058 |
|        |       | learned from Maine       |     |         |          |
|        | CN    | Yankee and Trojan        |     |         |          |
|        | 0     |                          |     |         |          |
|        | 6-020 |                          |     |         |          |
+--------+-------+--------------------------+-----+---------+----------+